Volume 2
Fourth Session
September 19-21, 1972
Chicago, Illinois
ILLINOIS
CONFERENCE
Pollution of Lake Michigan
and its Tributary Basin,
Illinois, Indiana, Michigan, and Wisconsin
U.S ENVIRONMENTAL PROTECTION AGENCY
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FOURTH SESSION OF THE CONFERENCE
IN THE MATTER OF POLLUTION OF LAKE MICHIGAN
AND ITS TRIBUTARY BASIN
IN THE STATES OF
WISCONSIN, ILLINOIS, INDIANA, AND MICHIGAN
VOLUME II
Bal Tabarin Room
Sherman House
Chicago, Illinois
September 20, 1972
(Jftaiilyn S\cui i^Lssociates
COURT AND CONVENTION REPORTINO
1372 THURELL ROAD
COLUMBUS. OHIO 43229
614 846.3682
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(JONTENT^
Dan R. Galloway
Arthur H, Cratty (as read by Dale S. Bryson)
Joseph Garraan (as read by Dale S. Bryson)
Walter L. Redmon
Carlos Fetterolf
Discussion - Phosphorus
Lloyd Lueschow
Dr. Donald Mount
Carlos Fetterolf
Gary Schenzel
Patricia O'Guin
Miriam G. Dahl
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Fourth Session of the Conference in the Matter of
Pollution of Lake Michigan and Its Tributary Basin, in the
States of Wisconsin, Illinois, Indiana, and Michigan, held
in the Bal Tabarin Room of the Sherman House, Chicago,
5 Illinois, on Tuesday, September 20, 1972, at 9:00 a.m.
6
7 PRESIDING:
Francis T. Mayo, Regional Administrator,
U.S. Environmental Protection Agency,
10 Region V, Chicago, Illinois.
11
12 CONFEREES:
13
Thomas G. Frangos, Administrator, Division
14
of Environmental Protection, Wisconsin
15
Department of Natural Resources, Madison,
16
Wisconsin.
17
William L. Blaser, Director, Environmental
Protection Agency, State of Illinois,
20 Springfield, Illinois.
21 Perry E. Miller, Technical Secretary,
22 Stream Pollution Control Board, Indiana
23 State Board of Health, Indianapolis, Indiana.
24
25
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1 CONFEREES, Continued:
2 Ralph W. Purdy, Executive Secretary,
^ Michigan Water Resources Commission,
Lansing, Michigan.
5
James 0. McDonald, Director, Enforcement
6
Division, U.S. Environmental Protection
7
Agency, Region V, Chicago, Illinois.
8
9
ALTERNATE CONFEREES:
10
-Q Francis H. Schraufnagel, Director, Bureau
^2 of Standards and Surveys, Division of
j_o Environmental Protection, Wisconsin Depart-
2. ment of Natural Resources, Madison, Wisconsin.
15 Carl T. Blomgren, Manager, Standards
16 Section, Division of Water Pollution
17 Control, Illinois Environmental Protection
1& Agency, Chicago, Illinois.
19
David P. Currie, Chairman, Illinois
20
Pollution Control Board, Chicago, Illinois.
21
Oral H. Hert, Director, Water Pollution
22 |
I
Control Division, Indiana State Board of
j Health, Indianapolis, Indiana.
*T
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1 ALTERNATE CONFEREES, Continued:
2 Carlos Fetterolf, Chief Environmental
Scientist, Michigan Water Resources
Commission, Lansing, Michigan.
5
John H« Kitchel, M.D., Commissioner,
6
Michigan Water Resources Commission,
7
Lansing, Michigan*
a
Dale S« Bryson, Deputy Director, Enforcement
Division, U.S. Environmental Protection Agency,
Region V, Chicago, Illinois.
12
PARTICIPANTS:
14 Dan R. Galloway, Environmental Engineer, Environ-
15 mental Control Systems Group, Dow Chemical Company,
16 Chicago, Illinoiso
17 Arthur H. Cratty, Commissioner, U.S. Department
of Agriculture, Great Lakes Basin Commission, East Lansing,
Michigan.
20 Joseph Garman, President, Michigan Soil Conserva-
o-i I
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VI
PARTICIPANTS, Continued:
Lloyd Lueschow, Chief, Laboratory Services,
Wisconsin Department of Natural Resources, Madison, Wisconsin,
Dr. Donald Mount, Director, National Water Quality
Laboratory, U.S. Environmental Protection Agency, Duluth,
Minnesota.
7
Gary Schenzel, U.S. Environmental Protection
d
Agency, Enforcement Division, Region V, Chicagp, Illinois,
q
Patricia O'Guin, Committee to Publicize Crisis
Biology, Indiana University, Bloomington, Indiana.
Miriam G, Dahl, Wisconsin State Division, Izaak
12
Walton League of America, Milwaukee, Wisconsin.
13 "
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F. Mayo
WEDNESDAY MORNING SESSION
MR. MAYO: Ladies and gentlemen, we will continue
with the Fourth Session of the Lake Michigan Water Quality
Enforcement Conference.
By way of a schedule for today, gentlemen, with thv,
little earlier start this morning perhaps we could break
sometime when it is convenient along about 10:30, 10:45
sometime between 10:30. and 11:00; continue to 12:45; again,
take an hour for lunch; and look forward to terminating the
session this afternoon sometime between 4:30 and 5*00
o'clock. And we are very deliberate in our efforts not to
run as long as we did last night.
I think we may be in a much more convenient
position to break into the program. We need to recognize,
however, that we are rather substantially behind the schedule
'I we had set for ourselves yesterday on the agenda, and I would
like to make it generally known that should it not be pos-
sible to have an adequate discussion and presentation of
the thermal information through the 21st, this room has
been reserved for the 22nd, and if necessary we can continue
on into the 22nd.
MR. MILLER: Do you want comments on that?
MR. MAYO: Excuse me. Yes. Go ahead, Perry.
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F. Mayo
MR. MILLER: Mr, Chairman, I would say that we in
Indiana have a comment or ~ pardon me a commitment on
Friday, and we are going to have to leave here on Thursday
evening sometime to get back in Indianapolis for meetings
that have been scheduled for Friday morning, so that I don't
see how Indiana can have a representation here on Friday.
MR. BLASER: Mr. Chairman, I have a similar problem
for the State of Illinois. I can leave a representative here
but I would have to be absent on Friday.
MR. MAYO: Well, I think, as has been the practice
with the enforcement conference sessions, while there is a
desire to move along and handle these things as expeditiously
as possible, that where there are major issues before the
conference, and there is a need for at least adequate presen-
tation of the positions involved by the parties of interest,
that we have made every effort to accommodate that need and
to keep the conference in session as long as it might be
reasonable to do so under the circumstances. And we just
have to be alert to the Indiana and Illinois problems and
try to move ahead as expeditiously as we can.
When we recessed last night, prior to the recess,
we had the introduction of the Phosphorus Technical Committee
report with a summary by Mr. Howard Zar, and we withheld
discussion and commentary on the technical committee report
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290
1 F. Mayo
2 in order to accommodate Dr. Stoermer, and Dr. Lee, and Mr.
3 Dustin, who were not going to be available today.
4 So our order of business this morning is to return
5 to the portion of the agenda dealing with phosphorus and its
6 relationship to water quality in Lake Michigan, and to con-
7 tinue with the presentations that had been identified yes-
8 terday.
9 The presentations we have are: Mr. Dan Galloway
10 from Dow Chemical; and a presentation that Mr. Cratty, State
11 Conservationist for SCS in Michigan and a member of the
12 Great Lakes Basin Commission, left to be introduced into
13 the record this morning. Then we have two supplemental
14 reports: one from the State of Michigan, and one from EPA,
15 dealing with the phosphorus issues in Lake Michigan.
16 I think it would be appropriate, gentlemen, to pro-
17 ceed with those four presentations before getting back to a
13 discussion of the Technical Committee report; and with the
19 four additional statements we ought to have a rather reason-
20 I able package of material to which the conferees can address
21 themselves.
22 | So we will move ahead, at this point this morning,
23 with the statement by Mr. Dan Galloway of Dow Chemical
24 Company.
25 Is Mr, Galloway here?
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291
1 D. Galloway
2
3 STATEMENT OF DAN R. GALLOWAI,
4 ENVIRONMENTAL ENGINEER,
5 ENVIRONMENTAL CONTROL SYSTEMS GROUP,
6 DOW CHEMICAL, CHICAGO, ILLINOIS
7
8 MR. GALLOWAY; Mr. Chairman, conferees, ladies
9 and gentlemen. My name is Dan Galloway. I am an Environ-
10 mental Engineer with Dow Chemical's Environmental Control
11 Systems Group in the Chicago office. My testimony on phos-
12 phorus removal by chemical means will include four main
13 areas:
14 1. Phosphorus Removal - "State of the Art"
15 2. An empirical relationship between metal ion
16 concentration and initial phosphorus concentration.
17 3. Establishing interim treatment in those
13 areas in which the municipality or industry cannot meet
I
19 the deadline for phosphorus removal.
20 4. Estimated capital and operating costs.
t
21 The removal of phosphorus from municipal sewage
22 j is achieved by the addition of a metal salt followed by a
23 high molecular-weight anionic polyelectrolyte flocculant«
24 Contact between the soluble phosphate anions and multi-
25 valent metal cations results in the formation of finely-
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292
1 D. Galloway
2 dispersed insoluble particles.
3 These fine particles normally require agglomera-
4 tion with a polyelectrolyte flocculant for adequate sedi-
5 mentation.
5 ... Slide 1 ...
7 This sequence of processing, which is composed of
g three steps, gives you an idea of the process. The coagu-
9 lation step where the metal ion is added under rapid-mixing
10 conditions is followed by the addition of the flocculant
11 and the general delivery of the form floe to the settling
12 tank.
13 ... Slide 2 ...
14 The metal ion can be introduced prior to primary
15 settling where enhanced suspended solids removal is often
16 experienced. The coagulant can also be added ahead of, or
17 at the tail end of the aeration tanks in activated sludge
18 plants, or added to the feed to trickling filter effluent.
19 I would indicate on this slide that we have found
20 ! in a couple of instances split addition of coagulant. In
21 j other words, addition of the coagulant had a primary settling
22 ; and, in this case, ahead of activated sludge, has been
23 effective in reducing the amount of coagulant necessary to
24 meet the particular requirements.
25 The treatment plant operator must be prepared for
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2 the increased production of sanitary solids inherent in
3 chemical precipitation. Part of these solids are cherai-
4 cally precipitated inorganic salts and part are initially
5 suspended solids which are more effectively captured. It
6 is expected that an average of 20 percent increase in sani-
7 tary and chemical solids will result, to be disposed of or
$ further processed into fertilizer,
9 The inorganic coagulant feed system lends itself
10 to automation. It can be a very straightforward and simple
11 system,
12 ... Slide 3 ...
13 The main components are: 1) a positive displace-
14 ment pump adequately protected against the metal salt
15 environment; 2) (plastic flexible) feed lines; 3) a fiber-
16 glass or rubber-lined storage tank.
17 ... Slide 4 ...
lg The polyelectrolyte feed systems also can be very
19 simple to accommodate the plants in the 0.1 to 3 mgd size
20 range.
21 There we just have a tank for mixing the solution,
22 j with a funnel, an aspirator, a wetting and dry polymer,
23 pump and feed lines to the addition point.
24 ... Slide 5 ...
25 An automatic dry polymer disperser can be utilized
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293
1 D. Galloway
2 the increased production of sanitary solids inherent in
3 chemical precipitation. Part of these solids are chemi-
4 cally precipitated inorganic salts and part are initially
5 suspended solids which are more effectively captured. It
6 is expected that an average of 20 percent increase in sani-
7 tary and chemical solids will result, to be disposed of or
8 further processed into fertilizer.
9 The inorganic coagulant feed system lends itself
10 to automation. It can be a very straightforward and simple
11 system.
12 ... Slide 3 ...
13 The main components are: 1) a positive displace-
14 ment pump adequately protected against the metal salt
15 environment; 2) (plastic flexible) feed lines; 3) a fiber-
16 glass or rubber-lined storage tank.
17 ... Slide 4 ...
IB The polyelectrolyte feed systems also can be very
19 simple to accommodate the plants in the 0.1 to 3 mgd size
20 range.
21 There we just have a tank for mixing the solution,
22 with a funnel, an aspirator, a wetting and dry polymer,
23 pump and feed lines to the addition point.
24 ... Slide 5 ...
25 An automatic dry polymer disperser can be utilized
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1 D. Galloway
2 for the large plants.
3 In this case, the treatment plant operator has to
4 maintain an inventory of the dry flocculant in the hopper.
5 The addition of an automatic flocculant dispersing
6 unit greatly facilitates flocculant solution makeup as well
7 as assures uniform concentrations.
£ For very large plants, 100 mgd or greater, an
9 automated chemical feed system as well as an automatic
10 flocculant dispersing system is often required for economic
11 use of chemicals.
12 ... Slide 6 ...
13 The "loop" system for the automatic control of
14 chemical feed rates operates on two electronic responses:
1$ 1. The amount of orthophosphate present in the
16 raw sewage and registered by the automatic orthophosphate
17 analyzer.
IB \ 2. The volume of sewage flow.
!
19 Just for a second, if you would look at our
20 schematic on the right, a signal from the electronic flow
21 meter regulates the flocculation feed system and also com-
22 bines with a signal from the orthophosphate analyzer to
23 regulate the coagulant feed systems.
24 The concentrations of metal and polyelectrolytes
25 Can be automatically controlled. An example of this "loop"
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SLIDE #6
AUTOMATIC CONTROL LOOP
FOR PHOSPHORUS REMOVAL FROM WASTE-. WATER
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FEED SYSTEM
CONVERTER
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TOTAL P
TOTAL P CON-
CENTRATION
(Mg/l) SIGNAL
TOTAL P LOAD SIGNA
(Lh/Day)
COAGULANT
SOLUTION
(FERRIC
CHLORIDE)
SIGNAL
MULTIPLIER
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D. Galloway
system in operation is Grand Rapids, Michigan, with a flow
of 45 mgd.
... Slide 7 ...»
This slide shows the coagulant feed system at
Grand Rapids.
Note the two 10,000 gallon fiberglass tanks for
storage of the coagulant and the building which encloses the
feed equipment.
.. . Slide 8 ...*
As was indicated, the metallic cation solution
feed is automatically proportioned to the intensity of the
influent orthophosphate signal.
This signal is multiplied by the specific gravity
of the metal ion solution determined by a density transmitter
which is this piece of equipment here (indicating) on the
feed line of the coagulant resulting in a mass flow rate.
... Slide 9 ...*
Here the flocculant feed pumps draw from a regu-
lated inventory of chemical solution to provide a particular
dosage based on the sewage flow. Plow recorders and
totalizers provide a material balance.
As can readily be observed, phosphorus removal
technology has advanced over the past 10 years. Enough
plant scale trials have been conducted that an empirical
relationship has been established between initial phosphorus
*(NOTE: Slide could not be reproduced.)
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10
11
12
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14
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D. Galloway
concentrations and required metal concentrations,
,.. Slide 10 ...
This relationship has been expressed in a design
equation where the final phosphorus concentration over the
initial phosphorus concentration is equal to an exponential
quantity, a k factor times the metal concentration over the
initial phosphorus concentration. (P,, /P = EXP [k. M/P J)
x o tp o
The significant factor of this equation is the
constant k. pH and alkalinity present in sewage have
tp
relatively minor effects upon k. . Effects by industrial
water, however, may be significant.
Loss in efficiency such as mixing, floccula-
tion, sedimentation upon scale-up from laboratory to
plant-size operation, can also be included in the k, factor.
The particular metal salt used and the concentration of the
flocculant also affect the k.
up
The concentration of the metal salt to be added to
a particular waste has been established as a linear relation-
ship to the initial but not the final phosphorus concentra-
tion.
22 | ... Slide 11 ...
In this particular graph, along the right vertical
axis, we have the percent removal from 0 to 99.9 percent;
along the horizontal axis, the metal to the initial phosphoru;
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SLIDE #10
PHOSPHORUS REMOVAL DESIGN EQUATION
PF/P0 = EXP (KpM/P0)
P0 = INITIAL CONCENTRATION
PF = FINAL CONCENTRATION
M = METAL CONCENTRATION
Kp = EMPIRICAL CONSTANT
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PHOSPHORUS REMOVAL DESIGN EQUATION
PF/P0 = EXP (KpM/P0)
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D. Galloway
2 ratio.
3 You can see that for BO percent removal, which would
be in about that area there (indicating) incidentally, I
am sorry, I should have said that this is a weight-to-weight
relationship, metal concentration to initial phosphorus.
At BO percent removal which is that area about
in there (indicating) it is something like maybe 1.& or
1.7 ratio of metal concentration to initial phosphorus.
10 However, if the requirements were to be increased to 99
11 percent removal of total phosphorus, then the ratio of metal
12 concentration to initial concentration would be about 5.
13 So that is quite an increase from #0 percent to 99 percent
14 ratio of metal ion concentration, less than 2 to 5»
15 Thus, it can be seen that the removal of phosphorus
16 i becomes progressively or, if you will exponentially more
17 difficult as the desired final phosphorus concentration is
reduced.
19 ... Slide 12 ...
20 This slide illustrates the variability of different
21 wastes treated with one metal ion. We left one community
22 on there by mistake. We apologize.
23 What we have here is six different domestic sewages
24 that we have established our relationship, and the flatter
the graph, or the more horizontal the graph, the more
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SLIDE #12
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1 D. Galloway
2 difficult the sewage is to treat for phosphorus removal by
3 chemical means.
4 The more vertical, as in this case, the more
5 amenable the sewage is to treatment with chemicals for
6 phosphorus removal.
7 The merit of the generalized design equation is
3 its applicability to a variety of sewages of differing
9 initial total phosphorus content using one metal system.
10 I have demonstrated some of the sophisticated tech-
11 nology and systems that can be applied to permanent installa-
12 tions. I would now like to demonstrate interim treatment
13 with temporary equipment.
14 It should be noted that while most of this equip-
15 ment is indeed temporary, some of it, such as storage tanks,
16 automatic dispersers, and in some instances feed pumps and
17 feed lines, may be incorporated in the final permanent
18 phosphorus removal system,
19 ... Slides 13 and 14 *
20 I ... Slide 15 ...*
21 This is a community in northern Wisconsin where
i
22 i interim treatment was established. Now, at this particular
23 time, they were interested in BOD removal and suspended
24 solids removal while the secondary portion of their plant
25 was down for expansion. But I use this to illustrate
*(NOTE: Slide could not be reproduced.)
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^ 299
1 D. Galloway
2 interim treatment for phosphorus removal as the same type of
3 system and equipment is used. Here they are using a metal
4 ion and an organic flocculant for removal of suspended solids
5 and BOD. Total phosphorus was also run during this interim
6 treatment.
7 i I would like for you to note the simple feed lines
8 and pump arrangement for administering the multiple feed.
9 ... Slide 16 ...*
10 Here a multiple speed selector provides accurate
11 metal ion feed rates. In other words, the treatment plant
12 operator this particular plant was a 3 mgd plant, and the
13 treatment plant operator about 6 or $ times a day will take
14 a measurement of flow off the flow meter of the hydraulic
15 load of the plant, and make his adjustment on this selector
16 for the coagulant feed.
17 ... Slide 17 ...*
18 i With this slide, I would like to demonstrate two
19 methods of administering coagulants that we found success-
I
20 i ful: 1) obviously pumping the metal cation; and 2) we have
21 also had some good experience with feeding by gravity flow
i!
22 ; with the flow meter.
23 ... Slide IB ,. .*
i
24 I hope you can make this out. In the left-hand
i
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25 ! corner there is an automatic dry polymer feed disperser,
*(NOTE: Slide could not be reproduced.)
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1 D. Galloway
2 which we certainly think is necessary in interim treatment
3 for plants, as I indicated, 3 mgd or greater, where there is
4 a certain amount of labor required in mixing the flocculant
5 manually, and this piece of equipment certainly diminishes
6 that manpower need considerably.
7 In our experience with plant scale trials and
8 interim treatment contracts, normally 6 months in duration,
9 the costs for the leased equipment and service have averaged
10 10 to 15 percent of the total cost. A contractor like Dow,
11 who provides this service and has equipment readily avail-
'
12 able, can set up the chemical feed equipment in about 2
13 months. A period of several weeks after installation is
14 required to optimize addition points and chemical dosages.
15 ... Slide 19 ...
16 To give you some idea of the activity around the
17 lakes, this is a compilation of some of our experience so
13 far.
19 I would like to conclude my paper with two
20 slides on operating and capital costs.
21 ... Slides 20 and 21 ...
22 I For the record, this slide includes the following
23 costs: for plant sizes less than 1 mgd, the estimated
24 chemical cost, $35 to $45 per million gallons; 1 to 10 mgd
25 size, $30 to $35 per million gallons; 10 to 25 mgd size,
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SLIDE #20
CAPITAL COSTS FOR PRIMARY PHOSPHORUS REMOVAL
PLANT SIZE CAPITAL REQUIRED CAPITAL COST
(MGD) ($) ($/MIL GAD*
<1 $ 5,000 - $ 10,000 $3,50
1 - 10 12,000 - 25,000 3,28 - 0,68
10 - 25 30,000 - 50,000 0,82 - 0,54
25 - 100 50,000 - 75,000 0,54 - 0,20
>100 75,000 - 150,000 0,40
*BASED ON TWENTY-YEAR STRAIGHT-LINE DEPRECIATION AT
5 PERCENT INTEREST
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SLIDE #21
CHEMICAL COSTS FOR PHOSPHORUS REMOVAL
PLANT SIZE CHEMICAL COST
(MGD) ($/MIL GAL)
<1 $35 - $45
1-10 30 -- 35
10 - 25 25 - 30
25 - 100 22 - 25
>100 20 - 22
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I D. Galloway
2 $25 to $30 a million gallons; and 25 to 100 mgd size, $22 to
3 $25 per million gallons treated; and greater than 100 mgd
4 size plant, $20 to $22 per million gallons treated,
5 These data on operating costs are based on BO per-
6 cent removal of total phosphorus, at an initial concentration
7 of 10 mg/1 of total phosphorus using ferric chloride and an
3 anionic polyelectrolyte. These average costs reflect freight
9 rates from Midland, Michigan to other points in Michigan.
10 This will give you some idea of our estimates on
11 capital requirements for getting set up for primary treatment
12 of phosphorus removal. We are talking about permanent
13 installation; we are talking about this particular slide
14 includes tanks, feed lines, pumps it does not include,
15 say, administration buildings.
16 To reiterate a few of the points, I have talked
17 about how new technology has been put to practical use in
IB permanent phosphorus removal installations in some of the
19 larger plants.
20 I have discussed establishing interim treatment
21 for phosphorus removal, and I have concluded with comments
22 on capital and operating costs for permanent installations of
23 phosphorus removal.
24 Thank you very much.
25 ! MR. MATO: Mr. Galloway, for purposes of the
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1 D. Galloway
2 record, we will want a set of slides to go along with your
3 statement. Will it be possible to make that arrangement?
4 MR. GALLOWAY: A set of slides or reproductions?
5 MR. MAYO; Reproductions.
I
6 MR. GALLOWAY: I can get that for you. I will get
7 them for you.*
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2 handled now is only 20 percent greater than before phosphorus
3 removal?
4 MR. GALLOWAY: As an average. In some cases, we
5 have found it to be at times 50 percent great-er; at other
6 times less than 20 percent. It is kind of a rough number
7 admittedly but
g MR. PURDY: I find it hard to reconcile that with
9 a primary sewage treatment plant the suspended solids
10 removal certainly is going to be less than 50 percent, and
11 maybe down in the range of 30; and you go to chemical treat-
12 ment and you are going to up that suspended solids removal
13 to the 70 to #0 percent range. It just seems to me that the
14 volume of sludge that we are talking about here to be
15 handled the increased volume is substantially more
16 than 20 percent in that case.
17 MR. GALLOWAY: Well, I think most of our experience
IB has been with plants, of course, that include secondary
19 treatment, and where we do increase the solids in the pri-
20 mary, say, from an average of 30 percent removal of suspended
21 solids to SO percent removal of suspended solids, we also
I
22 ! reduce the amount at an activated sludge plant, for
23 instance the amount of waste activated. So the compen-
24 sation there, we have estimated roughly, is a 20 percent
25 increase.
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2 MR. PURDY: Okay. But the point I am trying to
make is if you have a primary sewage treatment plant only
4 and you expect to put in some interim phosphorus removal
facilities, that the volume of sludge that you are going to
have to handle is much greater than 20 percent more than
what you handled yesterday.
8 On an activated sludge treatment plant and you
put phosphorus removal in I am in agreement with you that
10 maybe the increased amount of sludge that you are going to
11 handle is about 20 percent more than you handled yesterday.
12 But your sludge-handling problems, on a primary treatment
13 plant, when you go to interim phosphorus removal may cause
14 some problems.
When you pointed out the capital cost involved
16 ! with phosphorus removal, did this include additional sludge-
17 handling facilities?
I
13 II MR. GALLOWAY: No, sir.
19 MR. PURDY: So this could increase that substan-
20 tially?
21 || MR. GALLOWAY: Yes, sir.
]
22 j MR. PURDY: Is that correct?
23 MR. GALLOWAY: This is only for chemical handling
24 and feed equipment and feed lines to the addition points.
MR. PURDY: Now, were you here yesterday?
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2 MR. GALLOWAY: Yes, sir.
3 MR. PURDY: Are you in agreement with this estimate
4 that was made yesterday of, say, roughly 40 percent increase
5 40 to 50 percent increase in operating chemical cost to
6 go from an 80 percent removal to a 90 percent removal?
7 MR. GALLOWAY: Yes, sir. I think I indicated that
$ somewhat on the slide where I showed you the 80 percent
9 removal to 99.9 percent, which is more than double the
10 amount at a specific level of phosphorus
11 MR. PURDY: Yes, you just didn't stop at the 90
12 percent.
13 MR. GALLOWAY: No, I didn't, but I do agree with
14 Mr. Earth's statement, yes, sir,
15 MR. PURDY: And in your slides, your presentation,
16 you indicated the ease that one can go into an interim phos-
17 phorus removal operation, that this might be the simple
lg addition of some tanks to house chemicals and feed pumps,
19 and so forth, to feed those chemicals.
20 Your slide indicated an operation in Wisconsin cer-
21 tainly under adverse weather conditions. Do those adverse
22 weather conditions require consideration in those interim
23 facilities?
24 MR. GALLOWAY: Yes, sir. In particular, the
25 coagulant I am sorry the flocculant feeding system is
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1 D. Galloway
2 insensitive to cold weather.
3 MR. PURDYi So that all piping, pumping equipment,
4 and so forth, must be protected?
5 MR, GALLOWAY: Must be insulated in the extreme
6 climates, yes, sir.
7 MR. SCHRAUFNAGEL: Is there any change in effi-
8 ciency with the colder temperatures?
i
9 MR0 GALLOWAY: No, sir, not significant.
10 MR. SCHRAUFNAGEL: Mr. Galloway, in one of your
11 slides, you showed the concentration of metal of it being
12 added directly or in your relationship between that concen-
13 tration and the percentage removal. Was this concentration,
14 that you are speaking of, in percentage removal, based on the
15 total phosphorus or was it based on the orthophosphate?
16 MR. GALLOWAY: On that particular slide it was
17 based on the side of phosphorus. A relationship like that
13 can be established for the total phosphorus, too, and can be
19 just as meaningful in predicting amounts of coagulants
20 i necessary for increased removals of phosphorus.
21 MR. SCHRAUFNAGEL: Well, you wouldn't be apt to
i
22 i get up to 99 percent removal of total phosphorus.
23 MR. GALLOWAY: That's right. Yes, sir.
24 MR. McDONALD: Mr. Galloway, how many interim
phosphorus removal facilities do you have on line now?
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1 D. Galloway
2 MR. GALLOWAY: We have several proposed. We have
3 none on line.
4 MR. McDONALD: And how long do you estimate it
5 would take you to set up if you got an order today to
6 go forward with that job?
7 MR. GALLOWAY: About 2 months.
8 MR* McDONALD: And what would be the cost of the
9 setup, or would there be a cost to the community?
10 MR. GALLOWAY: That is a little complicated. Our
11 proposals to communities have been based on a price per million
12 gallons and, as I indicated, most of our proposals are based
13 on 6-month interim treatment; and for a 6-month period of
14 time, the service and equipment rental portion of that
15 contract is about 10 to 15 percent of the total cost.
16 That leaves #5 to 95 percent for the chemical coagulant and
17 flocculant cost.
IB So, to clarify that, our contract would be or
19 any contractor's contract we are suggesting would be for
20 the total package: a price per million gallons for chemi-
21 cals, service, and equipment.
22 MR. McDONALD: In other words, for a 6-month term
23 you would give one billing?
24 MR. GALLOWAY: Yes, for practical purposes, yes,
25 sir.
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MR, McDONALD: I see. Are the two that you have
in the Lake Michigan Basin the two jobs that you are pursuing
now?
MR. GALLOWAY: Yes, sir.
MR. McDONALD: Is your company prepared to handle
a pretty good quantity of interim phosphorus removal jobs?
MR. GALLOWAY: Yes, sir.
MR. McDONALD: Thank you.
MR* HERT: Do you have a liquid polymer that would
further simplify the process of chemical additions?
MR. GALLOWAY: No, sir. I take exception to that,
but no, sir.
MR. MAYO: Are there any other questions, gentle-
men?
MR. PURDY: Yes.
When you stated 2 months' time to put in interim
facilities, does that include those extras needed to take
care of the adverse weather conditions?
MR0 GALLOWAY: Yes, sir.
MR. PURDY: And to do this, you are making the
assumption that the plant has adequate sludge handling
facilities, the 2 months' time will not allow for
MR, GALLOWAY: That is true.
MR. PURDY: any increased equipment that might
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1 D. Galloway
2 be necessary for sludge handling?
3 MR. GALLOWAY: That is true, and as I indicated
4 that can be a real problem.
5 MR. MAYO: Any further questions, gentlemen?
6 MR. FRANCOS: Yes.
7 Could I just run through those cost figures again?
8 What would be the leasing cost for a community served by a
9 1 million gallon per day plant?
10 MR. GALLOWAY: That is tough. It would depend on
11 the first step of this operation, which I didn't mention,
12 and that is a feasibility study or some initial laboratory
13 work, and maybe hydraulic flow studies of the plant,
14 I can't give you a specific number for a 1 mgd
15 plantj I can only tell you, as I indicated before, a per-
16 centage breakdown in cost.
17 MR. FRANCOS: Which was 10 to 15 percent
IS additional?
19 MR. GALLOWAY: Yes, for leasing and manpower
20 requirements to get the interim treatment started, and
21 maintenance of equipment.
22 MR. FRANCOS: Thank you.
23 MR. MAYO: Mr. Galloway, one of the problems that
24 is characteristic of the smaller plants is the difficulty
25 that operating personnel have with the maintenance of
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2 equipment particularly the automated equipment.
3 What kind of service would generally be available?
4 MR. GALLOWAY: For the smaller plants, as I illus-
5 trated on the slide now that community in Wisconsin was
6 a 3 mgd plant and I broke this down mainly in three groups
7 1) 0.1 mgd size plant; 2) 3 mgd size plant; and 3) 50 or 100
8 mgd size plant, where more automatic type equipment is
9 required.
10 For the smaller plants, say, less than 3 mgd or
11 less than that, the sophistication isn't very great at all.
12 You saw the pumps and feedlines that we had installed at this
13 location in northern Wisconsin. The only piece of sophisti-
14 cated equipment is that automatic polymer disperser that we
15 installed. And I think that, with our guidance, or the con-
16 tractor's guidance, these treatment plant operators
17 can be taught to operate that piece of equipment. Part of
i
j
18 i the service that we offer or that a contractor offers
19 is that if there is a problem with addition points or dosages
20 any time during the trial, then that technical service
21 our technical service is available. But from the standpoint
22 | of operating the equipment, there should be no problem, and
23 we have experienced no real difficulty in that after we
I
24 I have been there for some time and have had the opportunity
25 to instruct the people, the plant personnel.
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1 A. Cratty
2 MR. MAYO: Any other questions, gentlemen?
3 Thank you, Mr. Galloway.
4 MR. GALLOWAY: Thank you.
5 MR. BRYSON: The next statement that we have on
6 the Phosphorus Technical Committee report is a statement
7 prepared by Mr. Arthur H. Cratty, Commissioner, U.S. Depart-
8 ment of Agriculture, Great Lakes Basin Commission. Mr.
9 Cratty was available yesterday to present this, but could
10 not stay over.
11 The statement is 4 pages in length, and I think
12 it would be appropriate to read it into the record so that
13 the conferees have the benefit of what it says. He did not
14 leave sufficient copies for distribution.
15
16 STATEMENT OF ARTHUR H. CRATTY, COMMISSIONER,
17 U.S. DEPARTMENT OF AGRICULTURE,
18 GREAT LAKES BASIN COMMISSION,
19 EAST LANSING, MICHIGAN
20 (AS READ BY DALE S. BRYSON)
21
22 ! MR. BRYSON: Mr. Chairman and members of the
23 Lake Michigan Enforcement Conference.
24 I appreciate the opportunity to make a statement
25 to this conference. My statement relates to the report of
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1 A. Cratty
2 the Phosphorus Technical Committee, in particular to the
3 j section of the report entitled, "Non-Point Sources" which
4 begins on page 13 and continues through page 15.
5 My purpose is threefold: 1) to update the USDA
6 report presented at your February 1969 conference; 2) to
7 further explain the conservation programs of USDA, with
8 I particular reference to the Lake Michigan drainage area;
i
9 and 3) to correct some apparent misunderstandings stated in
10 the committee's report.
11 In 1969 we pointed out a definite need to: 1)
12 expand technical and financial assistance for installing
13 special measures for pollution control; 2) increase long-
14 term credit and cost-sharing for the installation of erosion
I
15 i control measures; 3) provide further assistance to local
i
16 government in effective erosion and sediment control pro-
17 grams in urban and industrial developments; 4) provide
IB additional financial and technical assistance for the
19 formulation of model regulations; and 5) the need for other
20 i authorities to control erosion along highways, streambanks,
21 ! lakes, and strip-mined areas.
I
22 i We are pleased to report that the recently enacted
23 Rural Development Act of 1972 contains provisions for long-
24 term contracts for cost-sharing of land treatment measures,
25 with particular emphasis on small watershed projects. This
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1 A. Cratty
2 means we can develop plans with landowners for installation
3 of conservation practices with assurances for cost-sharing
4 on a definite time schedule over a period of years. The Act
5 also broadens our authority in watersheds to deal with all
6 land, not just that related to water management measures.
7 Still further, it contains authority to include features
8 specifically to improve the quality of water in streams.
9 Procedures are now being developed to implement this new
10 authority.
11 We agree that sediment is a serious pollutant.
12 It is impractical, however, to assume that erosion can be
13 reduced to zero. A reduction by 70 to 75 percent of un-
14 treated rates is a practical limit.
15 Land use in the Lake Michigan Basin consists of
16 approximately 13.0 million acres cropland; 1.4 million acres
17 pastureland; 12.6 million acres woodland; and 5.2 million
1# acres urban and related uses a total of 32.2 million
19 acres. Conservation cropping systems have been applied on
20 30 percent of the cropland, 3.4 million acres; with .4
21 million acres supporting mechanical practices. About 44
22 percent of the cropland in the Lake Michigan Basin presently
23 has adequate conservation treatment. Approximately 375»000
24 acres of pastureland have been adequately treated. This
25 represents 27 percent of the pastureland. Four and five-
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1 A. Cratty
? tenths million acres of woodland have received treatment.
I
3 This represents approximately 36 percent of the forest land.
4 In view of these statistics, we believe the agricultural
5 programs in the basin have been very successful, and that
6 the soil conservation districts are to be commended for their
7 contributions through promotion of voluntary commitments of
8 landowners to a conservation program.
9 The watershed program is not yet a major factor in
10 the Lake Michigan Basin. Only 23 watershed applications are
11 on hand encompassing about 1.5 million acres, or 4 percent
12 of the basin. Two of the 23 potential projects have been
13 completed, and on these BO to 90 percent of the land treat-
14 ment measures have been applied. Contrary to the committee's
15 reporo, the emphasis in the watershed program, under Public
16 Law S3-566, has not changed from conservation measures to
17 "dams, drainage, and channelization." The first increment
IS in formulating project plans is adequate treatment of all
19 lands for watershed protection. This is supplemented by
20 structural measures needed to achieve agreed-upon objectives.
21 The Act has been broadened several times to make it more
22 responsive to the full range of environmental values.
23 The committee's report is also in error in stating
24 that the Act requires that conservation measures must be
25 applied on 75 percent of the watershed. The requirements of
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1 A. Cratty
2 the Act regarding land treatment are entirely related to the
3 protection of each retention reservoir. It requires that
^ local organizations shall "obtain agreements to carry out
5 recommended soil conservation measures and proper farm plans
6 from owners of not less than $0 percent of the lands situated
7 in the drainage area above each retention reservoir to be
8 installed with Federal assistance." The requirement referred
9 to by the committee for 75 percent application of erosion
10 control measures is for critical sediment source areas which
11 if uncontrolled would require material increase in the cost
12 of construction, operation or maintenance of the structural
13 measure. In the cases of critical sediment source, 75 percent
14 of the needed erosion control measures must be applied before
15 construction money is released. This requirement is contained
16 in the policies for administration of the Act and is more
17 restrictive than the Act itself.
18 Soil conservation districts in the Lake Michigan
19 Basin and throughout the Nation have for several decades
20 I worked diligently to prevent erosion and reduce sedimenta-
21 tion. In the judgment of many, their success and progress
22 has been noteworthy.
23 Soil conservation districts are responsible for
24 most of the conservation practices now on the land. I com-
25 mend them for the accomplishments as well as for their
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A, Cratty
2 I wisdom of initiating and carrying on such a vital program
3 since the late 1930's.
The non-point sources part of the report concludes
5 with a recommendation to require compulsory implementation
6 of conservation measures by landowners. It is not my intent
7 to argue for or against compulsory or regulatory provisions.
They may indeed have a place in conservation and pollution
9 control programs. As a matter of fact, several States now
10 have sediment and erosion control laws and I understand a
11 good number of other States have such laws under considera-
12 tion. I suggest that this conference seek the assistance
13 and counsel of USDA and soil conservation districts to move
14 cooperatively forward in the job of controlling erosion and
15 sediment. I am certain that USDA and soil conservation dis-
16 tricts would be pleased to cooperate.
17 I urge that the Phosphorus Technical Committee be
IS requested to reconsider their report to place agriculture
19 programs in the proper perspective and to correct the mis-
20 understandings it contains.
21 That concludes Mr. Cratty's statement.
22 MR. MAYO: Any comments, gentlemen?
23 MR. BRISON: Mr. Mayo, there is one additional
24 statement that arrived yesterday. This is directed to
25 Mr. Howard Zar, Chairman of the Phosphorus Technical Committe
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1 J. Garman
2 from Mr. Joseph Garman, President of the Michigan Soil Con-
3 Servation Districts, Incorporated.
4 This elaborates in greater detail on some of the
5 points that Mr. Cratty raises, and copies of these two
6 articles, or this information will be distributed to the
7 conferees later in the day.
d Let me read Mr. Carman's letter.
9
10 STATEMENT OF MR. JOSEPH GARMAN, PRESIDENT,
11 MICHIGAN SOIL CONSERVATION DISTRICTS, INC.,
12 MENDON, MICHIGAN
13 (AS READ BY DALE S. BRYSON)
14
15 MR. BRYSON: "Dear Mr. Zar:
16 "I have reviewed a draft of your Phosphorus
17 Technical Committee report. I cannot help but take exception
1# to some of the statements made in this report. I have
19 special concern about statements appearing on pages 13 and
20 14 dealing with non-point.sources of pollution. It seems
21 that the information is entirely negative in character and
22 tends to minimize the excellent soil erosion control work
23 that has been carried out by soil conservation districts
24 and watershed programs for many years. The report seems
25 to indicate that very little has been accomplished. Anyone
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318.
1 J, Garman
2 familiar with the program knows the erroneous nature of such
3 a statement. Just one example, and there are many: Prior
4 to soil conservation district activities, practically all
5 fruit orchards in Michigan were clean cultivated. It was
6 a mark of accomplishment not ' o have a weed or blade of
7 grass growing in the orchard. Erosion was widespread and
8 added great volumes of sediment to the water supply. Today
9 one will seldom see a clean cultivated orchard sod, mulch,
10 alternate middles and diversions are accepted and widely
11 used practices. Thousands of miles of grass waterways,
12 plantings on critical areas, pasture improvement, minimum
13 tillage are all significant erosion control factors.
14 One-quarter of a billion trees have been planted by soil
15 conservation district cooperators in Michigan alone. Many
16 of these plantings are on critical erosion areas.
17 "You do not make reference to the tremendous volume
18 of sediment accumulating in our water areas from many land
19 use developments such as highways, shopping centers, sub-
20 divisions, etc. We have research data showing that such
21 losses often result in several hundred tons of soil per
22 acre per year. About 1 year ago, a member of the Water
23 Resources Commission stated in reviewing sediment in the
24 Red Cedar River (a branch of the Grand River) that more
25 pollution occurred in the Red Cedar from the construction
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J. Garman
of the 1-96 freeway than occurred from agriculture in the
watershed throughout the entire period of history.
"I note a release from Michigan State University
Soil Science Department dated September 11, 'The research
data showed that there is little need for great concern
about phosphorus in either fertilizer or manure being able
to move down through the soil into drainage water. The
phosphorus from both sources was retained in the surface
horizons of the profile.'
"On page 14, you also made reference to PL- 566
projects. I don't believe that the statement 'conservation
measures must be applied on 75 percent of the watershed1 is
correct. This is true only on serious hazard areas. I
believe 50 percent of the land must be planned above struc-
tures. Also on page 14 it is stated that the '566' law has
been broadened to where emphasis is on dams, drainage and
channelization. We take exception to this statement. The
intent of the Watershed Act is to provide for flood pro-
tection and control and related agricultural water manage-
ment. This certainly requires land treatment, but in cer-
tain areas with level topography, channelization is a
necessity to handle flood waters. Likewise, impoundments
to hold back flood water and to provide recreation uses and
water storage is a valuable tool. You folks seem to forget
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1 J. Garman
2 that land used for food and fiber and to provide homes for
3 people is part of the environment, too.
4 "No reference was made in this report about the
5 enactment of soil erosion and sedimentation control ordi-
6 nances by many local units of government working with soil
7 conservation districts. This is spreading very rapidly in
8 our State, In fact, a statewide soil erosion and sedimen-
9 tation control bill is now in the process of being enacted
10 by our State Legislature.
11 "There are many aspects of this situation, However,
12 I believe that the above is sufficient to illustrate why we
13 believe the report is both inaccurate and misleading.
14 "Sincerely, Joseph Garman."
15 MR0 MAYO: Any comments, gentlemen?
16 I think that when we get to the point of discussing
17 the Technical Committee report, it might be appropriate to
13 at least have some commentary on the significance of tne
19 challenge that both of these statements issue to the
20 correctness of the report on the items dealing with the
21 controls on agricultural land.
22 We have two other reports.
23 Do you want to proceed with those?
24 jiflft. BRYSON: Early this summer, we received a
25 telephone call asking the Environmental Protection Agency
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1 ₯. Redmon
2 investigate the taste and odor problems that the city of
3 Green Bay was experiencing. As a result of this telephone
4 call, EPA did do some investigation into the problem, and
5 we have prepared a brief report on that investigation.
6 I would like to call upon Mr. Walter Redmon to
7 present that report at this time.
8 Following Mr. Redmon's report, the State of
9 Michigan has a report to present on that same subject.
10
11 STATEMENT OF WALTER L. REDMON,
12 AQUATIC BIOLOGIST,
13 U.S. ENVIRONMENTAL PROTECTION AGENCY,
14 REGION V, CHICAGO, ILLINOIS
15
16 MR. REDMON: Thank you.
-7
17 My name is Walter Redmon. I am an aquatic
biologist with the Environmental Protection Agency in the
19 Regional Office in Chicago
20 I will present a report on the specific incident
21 MR. MAIO: Would you speak closer to the microphone
22 Mr. Redmon?
23 MR. REDMON: I will present a report on the
24 specific incident at Green Bay and a little background, and
Mr. Fetterolf will present a more complete report on their
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W. Redmon
2 study the Michigan study.
3 The city of Green Bay, Wisconsin has, since 1957»
4 taken its potable water from the main body of Lake Michigan
5 near Algoma, Wisconsin. Raw water is taken from Lake Michigan
6 at two intakes located offshore at depths of 55 and 30 feet,
7 respectively, piped 16 miles to a very modern filtration
plant, then piped the remaining 10 miles to the city of
9 Green Bay. In the past, occasional flareups of short-term
10 duration of odor in the raw water have occurred, but per-
il sonnel of the Green Bay Water Department have in general
12 been able to control these with increased chlorination and
13 activated carbon.
14 In late June of this year residents of Green Bay
15 found their drinking water to have a very strong musty odor.
The Green Bay Water Department had begun extensive treatment
17 efforts, but previously adequate methods failed. Mr. Phillip
Utic, Department Manager, and his staff experimented with
19 many methods of treatment before choosing a combination of
20 potassium permanganate and activated carbon, which reduced,
21 but did not eliminate the odor. At the same time, Mr. Utic
22 contacted other water departments using the waters of Green
23 Bay or Lake Michigan. He found that the city of Two Rivers,
located a considerable distance south of Green Bay's water
25 intake, for the first time experienced similar problems
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1 W. Redmon
2 beginning July 4» a few days after odors appeared at Green
3 Bay.
4 Mr. Utic also found that this outbreak was pre-
5 ceded by several days of northerly winds, which tend to create
6 a north-south current along the west shore of Lake Michigan.
7 This fact indicates that the source of these odors was located
$ to the north of the Green Bay intake.
9 Since 1970, the cities which use Green Bay itself
10 as a water supply have been experiencing increasingly severe
11 taste and odor problems. A 1972 investigation conducted by
12 the Michigan Water Resources Commission provided consider-
13 able evidence that the problem was caused by actinomycetes
14 fungi. Geosmin, a metabolic by-product of these fungi was
15 identified in the affected water treatment plants. Geosmin
16 is a very potent organic compound which produces character-
17 istic musty odors at extremely low concentrations.
l£ EPA personnel first became involved on July 10,
19 1972. On July 13, and 20-21, water samples were collected
20 and taken to EPA laboratories in Cincinnati, Ohio. In both
21 cases, these samples proved too small for successful analysis
22 Drs. A. A. Rosen and R. S. Safferman, EPA scientists, who
23 have broad experience with tastes and odors in water, were
2^ consulted for guidance.
25 There is no adequate method of water treatment to
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1 W. Redraon
2 completely solve a major taste and odor problem of this
3 type. The methods being used by Green Bay personnel were
4 the best available. Research on water treatment methods to
5 remove odor compounds needs a much higher priority than it
6 currently holds.
7 The source of the problem remains only partially
& proven. Samples of activated carbon removed from the Green
9 Bay water treatment plant's filters and settling basin were
10 flown to Cincinnati in early August for analysis. Since
11 activated carbon collects and concentrates many organic
12 compounds, solvent extraction and chromatographic analysis
13 is the best method for confirmation of the odor causes.
14 The human nose is more sensitive for detecting organic odor
15 compounds than available analytical equipment. An experienced
16 investigator can identify many compounds at concentrations fa;'
17 below the sensitivity range of the best analytical equipment
1$ currently available.
19 Results of EPA chemical analysis did not positively
20 identify the presence of geosmin or any other known odor-
21 producing substance. There was a strong indication that
22 geosmin was present in the filter carbon, but in concentra-
23 tions too low for positive identification. The analytical
24 equipment used was the best there is. The chemists said
25 they could smell a musty odor typical of geosmin, but
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1 W. Redmon
2 couldn't make positive identification.
3 Following 2 days of westerly and southerly winds,
4 the odor level of Green Bay's raw water dropped to very low
5 levels on August 3, 1972, after about 5 weeks. The citizens
6 of Green Bay were greatly relieved, but those of us trying to
7 track down the source of this problem were temporarily
$ stopped.
9 The feeling of those investigating the problem is
10 that eutrophication of Green Bay due to inflow of organic
11 materials, and other nutrients, especially phosphorus and
12 nitrogen, is the cause of an increasing taste and odor problem
13 in the bay. Waters of Green Bay, which are discharged to the
14 main body of Lake Michigan, are then the logical source of
15 the problems recently experienced at Green Bay, and Two
16 Rivers, Wisconsin,water intakes along the western shore of
17 the lake.
18 Actinomycetes have been identified from samples
19 taken throughout Green Bay. These fungi exist on decompos-
20 ing organic matter such as dead algae. The investigation
21 conducted by the State of Michigan also revealed bottom
22 deposits of organic materials throughout Green Bay.
23 Green Bay exhibits many characteristics of rapid
24- eutrophication. Many large point sources of inadequately
25 treated wastes continue to discharge to the bay's tributary
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W. Redmon
streams. Until these pollution sources are controlled, taste
and odor problems in water supplies can be expected to remain
and continue their increase.
Our summary and conclusions were:
1. There is an increasing problem of taste and
odors in water supplies taken from Green Bay and nearby
portions of Lake Michigan. This problem has reached signif-
icant proportions at the city of Green Bay's intake near
Algoma, Wisconsin, and at Two Rivers, Wisconsin, in recent
months.
2. Investigations conducted during 1972 by the
Michigan Water Resources Commission indicate the presence
of actinomycetes fungi and their metabolic by-product,
geosmin, a potent cause of odor, in water supplies drawn
from Green Bay.
3. Odors which occurred in the city of Green
Bay's water supply were typical of geosmin. Analysis of
carbon extracts from the city's filtration indicated the
presence of geosmin at concentrations below those necessary
for positive confirmation.
4. Evidence presently available suggests a
definite link between the degraded water quality of Green
Bay and taste and odor problems experienced by the city of
Green Bay. It can be expected that periodic recurrences
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1 W. Redmon
2 will persist so long as pollution of Green Bay continues.
3 5. Treatment instituted by the Green Bay Water
4 Department was consistent with best presently available
5 technology; but there is no adequate method to treat this
6 important water supply problem.
7 The recommendations were:
g 1. Further investigations to confirm the source
9 of taste and odor problems in the Green Bay area of Lake
10 Michigan should be conducted. Investigations by the Michi-
11 gan Water Resources Commission have laid important ground-
12 work and should be expanded in conjunction with complementary
13 efforts by the Wisconsin Department of Natural Resources
14 and the Environmental Protection Agency.
15 2. Research on water treatment methods for removal
16 of odor-producing compounds must be greatly expanded. Such
17 problems are not exclusive to Green Bay. They occur through-
1S out the world. Many water supplies in the United States are
19 degraded in this way. Present water treatment technology
20 provides only partial remedy at drastically increased cost.
21 3. Michigan, Wisconsin, and EPA should intensify
22 enforcement efforts to abate sources of pollution to Lake
23 Michigan's Green Bay.
24 Thank you.
25 MR. MAYO: Any comments or questions, gentlemen?
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1 W. Redmon
2 MR. FRANGOS: Mr. Chairman.
3 I think that we would endorse the recommendations
4 contained in this report, and indeed I think that at least
5 as far as "1" and "3" are concerned, we can report to you
5 that we are following up on the investigations to see if we
7 can't more specifically pinpoint the causes of the taste and
g odor situation.
9 Certainly we are concerned not only about the
10 quality of water delivered, but certainly the increased cost
11 factors that go hand-in-hand with trying to control the
12 taste and odors.
13 I think we are intensifying our enforcement efforts
14 jointly. However,I am not so sure that there has been a
15 causal relationship identified here and, of course, that is
16 one of the things we will be doing as a followup. But I am
17 not so sure that even if we do indeed reduce pollutants to
lg Green Bay that we may necessarily reduce the frequency of
19 taste and odor problems. I am not sure that we could reach
20 that conclusion at this point in time.
21 MR. SCHRAUFNAGEL: As you perhaps know, the city
22 of Green Bay gives us water from Lake Michigan, and the Door
23 Peninsula separates Green Bay from the main part of the lake.
24 The taste and odor problems were not confined only
25 to the city of Algoma and the city of Green Bay; the taste
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1 W. Redmon
2 and odor problems were found at the same time in fact, the
3 initial investigation was made on the taste and odor problems
4 at the Marinette and Menominee, Michigan water supplies.
5 At this time, we feel that the relationship is
6 somewhat casual, and we would certainly want to investigate
7 it further before making the speculative conclusions that
8 are shown here.
9 MR. McDONALD: Mr. Chairman, I would like to make
10 a comment on the report alsojust give some background that
11 is not included in the report as to why we got in it at all.
12 The telephone call that Mr. Bryson referred to
13 was from a representative of the Lake Michigan Federation
14 in early July, thinking that the complaints on taste and
15 odor that were being made by the residents of Green Bay were
16 caused perhaps by the thermal discharges coming out of the
17 Point Beach nuclear powerplant. And we responded in this
13 instance really to rule out that possibility or rule it in,
19 and there is no evidence although Mr. Redmon did not
20 mention this in his report there is no evidence whatso-
21 ever that the taste and odor problems were caused by the
22 thermal discharge that is coming out of the Point Beach
23 nuclear powerplant.
24 Is that correct, Mr. Redmon?
25 MR. REDMON: I could go into a little more detail
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1 W. Redmon
2 there. Mr. Utic has been keeping wind direction records and
3 trying to relate these to the actual occurrence of taste and
4 odor problems. I think in a little less than a year there
5 have been four instances, although the other three were quite
6 small and lasted for only a few days, where taste and odor
7 problems occurred.
8 In each case, the wind direction was directly
9 correlated to the taste and odor problem. The wind direction
10 was from the north or northeast in each case where this hap-
11 pened, and it had to occur the wind direction occurred for
12 several days. We had several days of north winds, which
13 would instigate a southward current, and this preceded each
14 case of taste and odor problems that have been reported so
15 far.
16 There has been an abatement of this problem when
17 the wind direction changed for a period of several days and
1# pushed the currents back in the other direction, when the
19 currents of Lake Michigan started coming from the south,
20 which is the location of the nuclear powerplant in question.
21 MR. MAYO: Any other comments, gentlemen?
22 Thank you, Mr. Redmon.
23 MRC BRISON: Mr. Fetterolf, are you presenting
24 the statement for Michigan?
25 MR. FETTEROLF: Yes, Mr. Bryson.
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1 C. Fetterolf
2
3 STATEMENT OF CARLOS FETTEROLF,
4 CHIEF ENVIRONMENTAL SCIENTIST,
5 MICHIGAN WATER RESOURCES COMMISSION,
6 LANSING, MICHIGAN
7
& MR. FETTEROLF: Mr. Mayo, conferees, ladies and
9 gentlemen.
10 Historically, the Michigan cities adjacent to
11 Green Bay have utilized it as a raw water source with
12 virtually no reported unpleasant taste and odor occurrences.
13 Recently, the Michigan communities of Menominee, Escanaba,
14 and Gladstone have experienced a strong musty odor in the
15 water supply, "strong enough to drive you out of the
16 shower," in the words of one resident.
17 The initial occurrence was noted in the late
13 summer and fall of 1969 in Menominee. The following year,
19 1970, again in the late summer and fall, the city of
20 Escanaba, as well as Menominee., experienced this phenomenon.
21 Strong odors initially occurred in the late summer and early
22 fall, reached a maximum intensity in midwinter (December),
23 continued to be noticeable the remainder of the winter
2/«- months, and disappeared in early spring (April). This
25 annual pattern reoccurred in 1971 and odors in the raw
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1 C. Fetterolf
2 water are occurring now. The intensity of the odor, most
3 often described as musty, has increased from 1969 to the
4 present. Threshold odor number determinations now indicate
5 the presence of a musty odor in raw water throughout the
6 year.
7 Extensive, but temporary, water treatment modifi-
8 | cations are presently employed by the facilities in all three
I
9 communities. These additional processes double the chemical
10 costs of treatment and are not particularly effective in
11 eliminating the odor. These communities not only seek
12 immediate relief, but wish to determine their future potable
13 water treatment needs with respect to this problem. The
14 identification, then, of the musty odor sources and the
15 possibility of control in Green Bay would aid these communi-
16 ties in their long-range water supply planning.
17 City officials at Escanaba asked the staff of the
l£ Water Resources Commission for assistance in determining the
19 cause and extent of the odor problem in early 1972. Our
20 first water quality survey relating to the odor problem of
21 Green Bay was conducted in February and March 1972.
22 Survey I showed that odor was present throughout
23 the bay at all depths; algal densities were considered too
^ low to be the cause of the odor; geosmin was present on the
2-> carbon used by the water treatment plants as filtering
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1 C. Fetterolf
2 material.
3 Geosmin is a soluble, organic metabolite synthe-
4 sized by certain blue-green algal species and by certain
5 actinomycetes. Geosmin has a strong earthy-musty odor
6 similar to that detected baywide during the survey.
7 Actinomycetes are a group of fungus-like bacteria very
£ common and widespread in both land and water environments.
9 They are saprophytes, receiving their energy from nonliving
10 organic materials.
11 Actinomycetes are often associated with taste and
12 odor problems in water supplies. In Survey I, actinomycetes
13 were not identified, and I believe the reason they were not
14 identified was because we used a nonspecific culture medium
15 in the laboratory and our results were simply inconclusive.
16 Survey II, conducted May and June 1972, again
17 found odor present baywide algal densities again consid-
lS ered much too low to cause an odor problem; and the presence
19 of 15 to 200 colonies of actinomycetes per ml of water and
20 greater than $,500 colonies per ml of sediment. During
21 this survey, actinomycete-specific culture was used and the
22 bacteria responded well.
23 Survey III samples collected in August were cul-
24 tured in a more precise manner than the others and we are
25 now finding 60 to 1,560 colonies of actinomycetes per ml of
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I C. Fetterolf
2 water and up to 1,250,000 colonies per ml of sediment.
3 This increase in figures does not necessarily
4 represent a true increase in the counts of actinomycetes.
5 It is simply that we have gradually been refining our
6 analytical techniques and our culturing techniques.
7 To date we have not been able to correlate the
£ actinomycete counts with intensity of odor because our
9 initial cultural techniques were simply too unrefined.
10 Future work is planned on this problem as well as the prob-
11 lem of quantifying the concentration of geosmin in bay water.
12 A bacteriologist and chemist have worked part-time on these
13 problems, but more intensive effort is called for. To date
14 we are not claiming we have proved that actinomycetes or
15 geosmin are the cause of the odors, but we are very sus-
16 picious.
17 Michigan has occasional similar odor problems in
l£ Saginaw Bay and you have just heard of a related problem in
19 Lake Michigan at the Green Bay intake.
20 We are drafting a proposal for a 2-year research
21 grant which will permit us to gain further understanding of
22 this problem which can affect so many people of our State.
23 The proposal will include:
24 1. Refinement of culture techniques for actinomy-
25 cetes from both water and sediments.
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C. Fetterolf
2 2. Refinement of collection and extraction tech-
o niques so that concentrations of geosmin can be quantified.
3. Correlation of actinomycetes populations with
geosmin concentrations.
4. Correlation of actinomycetes and geosmin with
odor intensity of the water.
5. Comparison of actinomycete populations in
9 situations both similar and dissimilar to Green Bay in
10 selected portions of Michigan's Great Lakes waters.
6. Comparison of actinomycete populations where
12 odor problems occur and do not occur.
13 7. Identification of water and sediment qualities
14 which encourage actinomycetes growth with emphasis on organic
15 content of the sediments.
1$ 8. Correlation of actinomycete populations and
17 odor problems with limnological and other biological phenom-
ena.
19 9» Determination of organic carbon concentrations
20 in the bay and determination of the sources and annual
21 budget.
22 10. Finally, prediction hopefully of the
23 future odor problems in Green Bay, other estuarine water
24 supply sources, and in Lake Michigan proper.
25 Thank you.
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C. Fetterolf
MR. MAYO: Any comments or questions, gentlemen?
MR. SCHRAUFNAGEL: Carlos, will there be any
consideration given to current studies at the same time?
MR. FETTEROLF: I would think that was very
important. I said there wat o correlation between actino-
mycete counts and odor intensity, but with that odor present
baywide, we definitely have a trend to higher odors in the
vicinity of the southern end of Green Bay, and with the new
information about the north winds affecting the water supply
at Green Bay in Lake Michigan, it seems apparent that there
might b~ a massive water replacement occurring in Green Bay
so that the water mass from Green Bay is moved out to Lake
Michigan and down southward along the lower peninsular shore
to Green Bay. And so I would say that current studies are
certainly in order.
MR. MAYO: Any other questions, gentlemen?
I have one, Mr. Fetterolf.
In Mr. Redmon's statement, he commented on the
difficulty of a positive identification of geosmin. On the
carbon used at the treatment plant, in your statement, you
say flatout geosmin was present on the carbon.
MR0 FETTEROLF: When we first started doing this
work, we were filtering 50 gallons of bay water through
carbon and attempting to identify geosmin on the carbon.
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C. Fetterolf
We could detect an earthy-musty odor similar to geosmin but
we could not identify it from these samples.
However, when we took samples of the filter media
from the water treatment plant, I believe our chemists were
confident that they were identifying geosmin.
Would you correct me on that, Pete?
MR. BRYSON: Pete, why don't you come up to the
microphone.
10 MR. REDMON: I can support that a little further.
11 ' At the same time that the samples we just sent to Cin-
12 , cinnati were analyzed, a sample which had been sent
13 by the State of Michigan to Cincinnati in March, I believe
14 either March or May was analyzed along with these, and
15 there was positive confirmation of geosmin with gas chromato-
16 graph and mass spectrograph. There was definite analysis,
17 and identification of geosmin was there, and so I don't know
1 whether this has been actually confirmed in the past by Michi-
19 gan with mass spectrograph, but this has been done now.
20 And this was from an old sample that had been sitting in
21 the refrigerator for several months. There was a much
22 | higher concentration, and this was a sample from the
23 Menominee-Marinette area from the carbon filters there.
24 MR. BRYSON: Mr. Mayo, with respect to your com-
25 ment, the sample that was sent to Cincinnati was not large
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C. Fetterolf
enough to get into the detectability range, if I remember
!t right.
4 MR. REDMON: No, there is just a it is a little
5 different from that. The detection of geosmin is one thing;
6 positive identification with mass spectrograph is another.
7 They were able to detect a substance located at the proper
8 point in the chromatographic chart, shall we say, to be
9 identified as geosmin. However there was not enough of it
]0 present to go through the mass spectrograph analysis for
11 positive confirmation.
12 MR. MAYO: Thank you.
13 MR. FETTEROLF: Mr. Mayo, I would like to insert
14 in the record a statement from one of our staff's early
15 reports on this.
16 "The activated carbon obtained from the carbon
17 filters of various water treatment plants was analyzed by
1^ gas chromatography. The chromatogram so obtained was com-
19 pared with a chromatogram resulting from a known sample of
20 geosmin. The peaks,matched well indicating the presence of
21 geosmin in the carbon filters."
22 MR. MAYO: Thank you.
* Any other questions, gentlemen?
2/f MR. FRANCOS: Mr. Chairman.
25
I would just comment very briefly on some of the
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1 C. Fetterolf
2 work that we have undertaken. We have done some sampling
3 since the tail end of the summer. More recently we have
4 sampled about 70 stations on the bay, and these are presently
5 being cultured, but we hope to see if we can't get some
6 population estimate and perhaps a correlation of plankton
7 populations with perhaps other water quality parameters.
8 Interestingly enough, in some of our water
9 samples that we collected where there was no characteristic
10 odor at the time we initiated the culture, sure enough
11 those developed later. I am not sure what that means
12 with regard to Mr. Fetterolf's research proposals.
13 MR. MAYO: Any other comments, gentlemen?
14 I think it might be appropriate, at this point in
15 time, before getting back to the Technical Committee report,
16 to take a 15-niinute break and recess until 10:55*
17 (Short recess.)
1$ MR. MAYO: May we have your attention, ladies
19 and gentlemen?
20 The conferee from Illinois, Mr. Blaser, had to
21 leave the table for a few minutes; he indicated he would be
22 back very shortly and he suggested that we move right ahead
23 with the program.
24 Gentlemen, we have before us the report of the
25 Phosphorus Technical Committee, and the related commentary.
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Discussion - Phosphorus
2 I believe we can address our attention, at this point in
3 time, to both the committee report and the related supple-
4 mentary material that has been presented to the conferees.
5 You can proceed as you desire.
6 MR. PURDY: I would like to ask some questions of
7 Mr. Zar.
In the Technical Committee report on page 11
9 on the increased cost of moving from the SO percent to the
10 90 percent this states roughly a $10 per million gallons
11 increase.
12 The slide that was shown by Mr. Galloway indicated
13 that this would be true if the plant, say, I believe, were
14 in the neighborhood of 25 to 50 million gallons per day
15 that the smaller plant would be somewhat higher.
Are you using roughly this 40 percent increase in
17 cost when you go from the $0 percent to the 90 percent level?
MR. ZAR: The committee's estimate was based on
19 some figures prepared for it by the EPA Advanced Waste Treat-
ment Laboratory in Cincinnati. Perhaps we could have those
figures put before you.
22 MR. PURDY: I am just wondering if there is any
difference in this assumption of roughly a 40 percent increase
as indicated by this $10 per million gallons.
MR. ZAR: I think that they are fairly similiar.
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1 Discussion - Phosphorus
2 I can 't really resolve them.
3 MR. PURDY: The other question that I have relates
4 to the additional chemicals now that will be necessary if we
5 move from an SO percent to a 90 percent level. And is there
6 any concern on the part of the Technical Committee of the
7 increased dissolved solids that will be contributed to the
g lake so that we can remove additional phosphorus?
9 MR. ZAR: I donft know that the committee discussed
10 that issue specifically. There is a subsequent report
11 directed towards the dissolved solids problem. Perhaps
12 that would be the place to take that up.
13 MR. PURDY: I am concerned that we proceed on
14 these issues separately. On one hand, we say we should move
15 to a higher phosphorus treatment level, and then on another
16 issue we consider that separately, and say that we must
17 control the dissolved solids additions to the lake, that
18 this is increasing, that this also has an effect upon the
19 nutrient value of the Lake Michigan waters. So, therefore,
20 we must control the dissolved solids.
21 It seems to me that we have got to make an analysis
22 of where we accomplish the greatest control, and if phosphoru
23 removal represents a means of controlling the algal growth
24 in the lake, then we must accept some additional dissolved
25 solids to do this.
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1 Discussion - Phosphorus
2 MR. ZAR: I belie v» that is correct.
3 I think that the Committee's view probably would
4 be that the phosphorus issue is a more critical issue at
5 least at this point in time, and we are bound to try to
6 achieve the phosphorus reduction at the same time that we
7 continue to worry about the dissolved solids issue,
B MR. PURDT: I think we must understand that at
9 this point in time because now, as Jimmy Vaughn's successor
10 might appear at future conferences and show a continuing
11 increase in dissolved solids, that by controlling phosphorus,
12 we are contributing to that dissolved solids increase, is
13 that not correct?
14 MR. ZAR: That is correct.
15 MR. MAYO: Are there any other comments, gentlemen?
16 MR. HERT: Mr. Chairman.
17 I'd say, yes, we have had these comments on the
13 agricultural sedimentation. I wonder if we could have those
19 available the person who did the preliminary work on this
20 aspect make a short statement on the accuracy of the
21 information that was in the committee report, if he is
22 in the audience.
23 MR. ZAR: That is fine.
24 MR. MAYO: Please introduce yourself, Mr.
25 LaVeille.
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Discussion - Phosphorus
MR. LaVEILLE: Yes. I am Will LaVeille, Agricul-
tural Waste Specialist for the EPA, Region V, here in
Chicago
The exact content of these two concepts we heard
read this morning the one from Mr. C ratty at the Great
Lakes Basin Commission and also Mr. Joseph Garman of the
Michigan Soil Conservation Districts, Incorporated the
details were unknown to me before this morning, so I have
quickly taken notes and I would like to start off by respond
ing directly to some of the statements that they made that
the report was inaccurate and possibly in error,
Mr. Cratty felt that there was a feeling within
EPA that the Soil Conservation Service efforts had not been
adequately recognized. I think that this is not true.
EPA
does recognize the efforts of SCS, of the U.S. Department
of Agriculture in general, and specifically in the great
work that they have done over the past years, since their
formation in the dustbowl days, in cutting down erosion
from the land.
The argument that we have, or the concern that we
have over the programs is not one of what they have done,
but maybe the fact it hasn't been enough.
There is a Great Lakes Basin Commission report
in various stages of draft right now that indicates and
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Discussion - Phosphorus
this report, by the way the specific volume that I am
referring to is Appendix 1&, the erosion and sedimentation
discussion.
5 It was done in part by the Soil Conservation
6 people themselves, and right on the first page of this
7 report, there is mention that only 75 to 30 percent of the
erosion that used to take place is still continuing. In
9 other words, to reverse that, between 20 and 25 percent of
10 erosion that used to occur has been halted by the SCS
11 efforts to date.
12 So in spite of the tremendous number of miles of
13 the branch waterways and terraces, in spite of the tremendous
14 numbers of areas and square miles of various conservation
15 plans, crop rotation, and the like that have been installed,
16 only 20 to 25 percent of erosion has been abated by these
17 measures. The Soil Conservation Service has, over the past
2 years as Mr. Cratty pointed out provided technical
19 assistance for installing special measures for pollution
20 abatement. Their technical workload has increased signif-
21 leantly over the past few years since the Agricultural
22 Conservation Stabilization Program. The Rural Environ-
mental Assistance Program has provided for cost-sharing
to assist farmers to install pollution abatement equipment
25
on the farms.
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1 Discussion - Phosphorus
2 The technical design and evaluation load has fallen
3 on the SCS and they have done an extremely adequate and capa-
^ ble job in these lines. They have provided assistance to
5 local governments and to the State governments in implement-
6 ing certain technical guidelines for erosion abatement. They
7 have worked with urban land developers. They have worked
with the county and the State highway departments to try to
9 get up-to-date,technically feasible, economically feasible
10 programs installed for abating pollution in road and hous-
11 ing development construction.
12 Mr. Cratty also pointed out in his letter that the
13 recent Rural Development Act provided for long-term con-
14 tracts for land treatment needs, and made the provision
1$ further through the SCS, they "can develop plans with land-
16 owners." I think this word, the verb "can" is probably
17 the hinge to the difference that the EPA and the Soil
-i cJ
I Conservation Service have on this.
19 The Soil Conservation Service can provide these
20 activities. There is no compulsion that the agencies that
21 receive their technical guidance and these suggestions or
22 recommendations for abatement actually install them. It
23
is purely a voluntary program.
24 Now, perhaps the Rural Environmental Assistance
25 Act will alter this and may contain enough of the financial
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1 Discussion - Phosphorus
2 inducement to make these programs more acceptable to the
3 land users, but to date it has been totally a voluntary
4 effort. I think this voluntary effort is exemplified by
5 the fact that only 20 to 25 percent of the erosion has been
6 abated.
7 The comment was made correcting the numbers that
8 were used in the Phosphate Committee's report about this
9 75 percent requirement for the completed structures before
10 the governmental money went out on these Public Law 566
11 programs.
12 This PL-566 program, by the way, is called the
13 Small Watershed and Flood Prevention Program. It is
14 specifically designed to hold the waters on the land rather
15 than letting them get into ;he streams where they overcharge
16 the banks and cause floods.
17 The explanation that I have heard most recently
13 is that in most cases only 50 percent of the structures
19 have to be applied, have to be constructed and in operation
20 before the Federal money is given. Mr. Cratty is correct
21 in pointing out that 75 percent must be applied in these
22 critical areas. But generally speaking only half the land
23 has to have these conservation measures applied which, in
24 some way, explains why many of the multiple-purpose dams
25 and reservoirs, the flood-retaining structures, silt up at
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1 Discussion - Phosphorus
2 a much faster rate than they were originally designed to do,
3 The Soil Conservation Districts, which are estab-
4 lished under a State charter, have also done an extremely
5 adequate job. This is getting the erosion and soil conser-
6 vation capabilities down to the local level. The Soil Con-
7 servation Districts are managed by elected landowners from
g that particular community. They are respected people. They
9 have the backing of the local people and therefore they can
10 get a job done much better than somebody at a Federal or a
11 State level can who does not have the implementation at
12 work to get down to the actual people that are involved
13 with it,
14 The Phosphorus Committee report also had a
15 recommendation for suggesting compulsory requirement for
16 certain erosion control measures before Federal funding
17 could be given out. The purpose behind this was to make
IS aware, make the public aware, of the lack of the voluntary
19 program's success. There are certain inducements that can
20 possibly be given out. These are being tried by various
21 U.S. Department of Agriculture agencies themselves right
22 now.
23 There is a pilot program going on right now down
24 in one of the southern Illinois counties to make the set-
25 aside acreage these farmers get paid for taking out of
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1 Discussion - Phosphorus
2 production to place those acres along the stream banks
3 and thereby leave these areas uncultivated.
4 If it is not cultivated; if it is not put into row
5 crop production, there is the decreased possibility of ero-
6 sion taking place. The U.S. Department of Agriculture, the
7 Agriculture Stabilization Conservation Service, is piloting
£ this program, and they report they have had quite a bit of
9 success. The farmers are willing to do this. They are
10 willing to set aside the acreage along the stream bank
11 rather than someplace away from the stream and thereby,
12 putting it right on the stream banks, they accomplish two
13 things: 1) they are getting their money for setting it
14 aside, and 2) also cutting down the direct erosion and
15 stream bank sloughage which causes so . ch of the sedimenta-
16 tion load.
17 I also think that the fact that many of the States
13 are considering erosion control legislation, and at least
19 two States have already enacted such legislation, is a
20 further indication that there is increasing awareness that
some sort of legal requirements and compulsory action might
be necessary rather than reliance totally on a voluntary
23 program.
Going to Mr. Carman's letter, the President of the
25 Michigan Soil Conservation Districts, he points out that the
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^ Discussion - Phosphorus
2 report seems negative in scope, and that the efforts of the
o SCS has been minimized. And, by way of clarification, I am
going to repeat that the Erosion and Sedimentation Committee's
5 own page 1 statement might seem to be a minimization of the
5 efforts to date,
7 He also makes the statement that we seem to be
g ignoring the amount of sediment that comes from some areas,
9 from some activities other than agriculture. And I agree
10 that in the final editing of this particular section in the
11 Phosphate Committee report that the emphasis was slanted
12 toward agriculture. This was not the intent. We recognize
13 the tremendous increased quantities of sediment that come
14 from urban construction, road building, and urban land
15 development, where the land is stripped, left to lay bare
16 without any cover for long periods of time, in many cases,
17 before the houses are put on and the land sodded. These
18 do contribute many, many times a normal amount of sediment
19 that would come from an agricultural piece of property.
20 The fact remains, however, that the ratios
21 between the land and urban development and those in agri-
22 cultural development could still be construed as placing
23 the largest load nationwide on the agricultural land use
24 activities.
25 Mr, Garman also refers to the Michigan State
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1 Discussion - Phosphorus
2 University report coming out in September that: MThe
3 research data showed that there is little need for great
4 concern about phosphorus in either fertilizer or manure
5 being able to move down through the soil into drainage
6 water. The phosphorus from both sources was retained in
7 the surface horizons of the profile."
8 I don't have the exact reference that he makes
9 here I am not sure which report he is referring to
10 but I do have a report dated 1971 no more specific than
11 that which is also from the Michigan State University,
12 specifically from the Agricultural Experiment Station, and
13 it is entitled "Nutrient Content of Drainage Water from
14 Agricultural Land." In this research report they give
15 details of tile drainage water the waters coming out
16 from under the agricultural land and in a number of
17 I think it is six different soil types and agricultur-
13 al crop conditions, in no case did they find that the phos-
19 phate content of this drainage water was less than 0.01 ppm.
20 In many cases it got three, four or five times that.
21 Now, it is true that 0.01 ppm is not very much
22 phosphorus, but when you extrapolate this, as was done in
23 the report, the amount could be 0.1 of a pound per acre,
2/f and over the 44,000 square miles of land in the Great Lakes
25 Basin, this could by extrapolation amount to 2,300,000
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1 Discussion - Phosphorus
2 pounds of phosphorus coming from the tile drainage,
3 Now, it is a technical point how much of this
4 phosphorus is available. I understand that this was brought
5 out in discussions yesterday afternoon. It is still open to
6 conjecture how much of the phosphorus that is dissolved,
7 or how much, for that matter, of the phosphorus that is
$ contained on the sediment particles in adsorbed form is
9 available.
10 However, I think it is hard to ignore the possi-
11 bility of 2,SOO,000 pounds of phosphorus the potential
12 for this quantity being in agricultural drainage waters.
13 I contend that it is not insignificant, and that it is a
14 matter that should be researched, as is the 2 million
15 pounds which is contained on the soil particles in their
16 adsorbed form.
17 The erosion and sedimentation discussion, in the
13 appendix from the Great Lakes Basin Commission study, con-
19 tained a number of maps indicating the relative rates of
20 sediment production and erosion quantities coming from the
21 various portions of the land in the Great Lakes, specifically
22 where Lake Michigan is concerned.
23 After a careful evaluation of these and calcula-
24 tions to indicate the relative weight of the sediment coming
25 from the various sub-basins in the Lake Michigan area, it
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± Discussion - Phosphorus
2 concluded that only something like 3*2 percent of the eroded
3 material that comes from the land actually reaches Lake
4 Michigan, but this quantity was in excess of 2 million
5 pounds.
6 Using a rule of thumb and this varies widely
7 depending upon which research paper you are reading and
£ who is doing the research and in which part of the country
9 there is typically 1 pound of phosphorus absorbed per ton
10 of sediment. So the numbers could possibly be as much as
11 2 million pounds of phosphorus reaching Lake Michigan in
12 the adsorbed state on sediment particles.
13 I think maybe this answers some of the questions
14 that were raised on those two comments.
15 Are there any more from the conferees?
16 MR. MAYO: Mr. Purdy.
17 MR. PURDY: In your comments relating to the con-
18 centration of phosphorus in the tile drainage, say, from
19 the tilled fields, do you have any information what the
20 content of phosphorus would be in the underground waters
21 from untilled fields?
22 MR. LaVEILLE: Yes, this report did contain some
23 information. It indicated that in most cases untilled soil
24 would contain about the same amount as the tilled materials,
25 at a minimum level. The tilled materials, however, would, ii
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1 Discussion - Phosphorus
2 most cases, contribute more, but never less than the natural
3 subsurface flow, and this number was approximately 0,01 ppm,
4 in their groundwater.
5 MR, PURDY: And our groundwaters do flow towards
6 the surface streams,
7 MR. LaVEILLE: Exactly,
g MR. PURDY: So that really this 2 million-plus
9 pound figure, as you calculated from tile underdrainage,
10 may not be 2 million-plus pounds contributed by agricultural
11 practices, but much of that would have gone through the
12 underground waters even if the fields had not been tilled.
13 MR, LaVEILLE: I think this would be the case for
14 those uncultivated portions of the basin. On fields where
15 manure had been applied, for example, they found consider-
16 ably higher amounts of phosphorus in the drainage tile
17 water.
18 There is a considerable quantity of animals in
!9 the Great Lakes Basin, and manure is applied to the land.
20 The manure would contribute excess amounts above the natural
21 drainage.
22 MR. PURDY: We have worked very closely with
23 Michigan State on these research projects and have contrib-
24 uted some money to them, and I have felt that you left the
25 impression that this 2 million pounds is something that
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1 Discussion - Phosphorus
2 could be controlled by some sort of change in agricultural
3 practice,
4 I do agree that where you have manure added to the
5 fields that you will have higher levels. But I don't think
6 that this 2 million pounds plus represents something that we
7 can get our hands on by changing agricultural practices; that
much of this is due to the contact of the underground waters
9 with natural soil conditions that contribute this phosphorus
10 to the groundwaters.
11 MR. LaVEILLE: What you say is true, but let me
12 add one point: The tendency, the trend toward higher pro-
13 duction from the agricultural lands, in many cases demands
14 that fields that had previously been saturated and not able
15 to be cultivated be put into production just to meet the
increasing demand for foodstuffs. Therefore, more and more
17 land is being tile-drained, and this does increase the amount
of flow under these agricultural fields. Whereas, in a
19 situation where there is more land use activity, more land
20 use management and this is a term that is being discussed
21 quite a bit these days if the land were managed so that
22 only those areas which are optimum for agricultural produc-
tion would be utilized, it would mean less use of tile drain-
age, and thereby cut down on the amount of drainage water
that is reaching the streams and you would be left with
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I Discussion - Phosphorus
2 mostly just the natural subsurface flow,
3 I agree that the conferees cannot change the progress
4 and trend in agriculture, but I merely offer this as an ex-
5 planation for the trend in which productivity is increasing
6 the burden on the streams and on Lake Michigan.
7 MR. PURDY: I am afraid I don't quite agree with
# your statement there either because actually acreage of till-
9 able land, at least in Michigan, is going down, at least part
10 of it due to encouragement by government to place farmlands
11 in land banks, and rather than going out to less productive
12 ground and making it tillable, we are encouraging agricul-
13 tural practices which will increase the production on the
14 remaining acreage so that the farmer makes himself a livable
15 wage.
16 But I think actually the volume of acres that are
17 being tilled has gone down, and that through our own govern-
l£ ment practices we are encouraging increase in production on
19 the land.
20 As we speak about underground drainage and the dis-
21 cussion of what can be accomplished in the way of municipal
22 wastewater treatment, if we would only look at the recycling
23 of nutrients now through application of wastewater effluents
24 upon the land, and recognizing that, in many cases, we are
25 going to be selecting some marginal land because that is land
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1 Discussion - Phosphorus
2 now that can be picked up at an economical cost and placed
3 into a land disposal system, and that to make that land usable
4 for that particular treatment practice, that we must go in
5 and underdrain that land so that it can now accept the waste-
6 water effluent and be cropped, what do you expect that par-
7 ticular proposal to do in the way of increased phosphorus
& contribution from underground drainage?
9 MR. LaVEILLE: The project you are referring to is
10 the Muskegon County project, which is one that the EPA
11 MR. PURDY: That is only one of many that are being
12 considered,
13 MR. LaVEILLE: And it is one of the largest ones.
14 There have probably been in excess of a thousand sites across
15 the country, probably since the turn of the century, where
16 there has been recycling of municipal and industrial wastes
17 to the land.
IS The projects that are adequately managed, from an
19 environmental and from an agricultural standpoint, would be
20 expected to add minimum probably not measurable quanti-
21 ties of phosphorus to the underground waters. This stresses,
22 of course, adequate management.
23 If the land is being used merely as a sink for
these wastes and the phosphorus and other nutrients are not
being removed, then it would be an environmentally damaging
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4
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10
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12
13
14
15
16
17
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Discussion - Phosphorus
project. The agricultural portion, where the crops are
utilizing the available nutrients from the recycling, when
they are harvested and removed from the site, they are in
effect removing the nutrient. It hinges on proper agricul-
tural management. This is probably the most important phase
of that type of an operation.
MR. PURDI: Do you have any, say, thoughts on that
system as it relates to producing a cash crop. Say if you
have the nutrients at pretty much even balance, do you think,
then, that you get maximum crop productivity off that acreage,
or do you think if you are going to manage that land for
maximum crop productivity that, then, you will have some
excess nutrients that will break through to that underground
system?
MR. LaVEILLE: That is a two-point question.
I think really that both systems have to be optim-
ized. In specific localities where the environmental balance
is more critical, a system like that would have to be managed
I with the environment in concern. If the system is in a less
critically environmental situation, it could possibly be
optimized toward the agricultural end. But in both cases
you are going to have to take both into consideration.
I think maybe what you are driving at is: If you
are anxious if a community is anxious to get rid of most
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1 Discussion - Phosphorus
2 of their wastewater and couldn't afford a large quantity of
3 land or the types of climate, cropping condition, soil condi-
4 tion and such that they couldn't raise an optimum crop, what
5 would be the alternatives? And I think in such a case you
6 would have to optimize the removal through agricultural
7 practices.
a MR* PURDY: Well, my point that I am really driving
9 at is that if that system is to work most efficiently for
10 pollution control, is that it must be managed for pollution
11 control and not for crop productivity and not to produce a
12 crop that will offset its operating cost, that it must be
13 managed for wastewater control, and that this may impinge
14 upon its value to produce a cash crop that will offset its
15 operating cost.
16 MR, LaVEILLE: Exactly.
17 MR. PURDY: Now, from the standpoint of soils that
IS are used in that system, a soil that will accept water rapidlj
19 of course, would be your first choice from the standpoint of
20 the amount of land that would be used, and the rate of
21 application. But will that particular type of soil enhance
22 the retention of the phosphorus or will it enhance the passag<
23 of that phosphorus through the soils to the underground
2^ system?
25 MR« LaVEILLE: If you get an extremely permeable
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1 Discussion - Phosphorus
2 soil site, one tending toward a sandy composition, the
3 material will pass through faster than many of the crops
4 that you could plant. There are some deep-rooted plants
5 that you could put on it which might extract more of the
6 nutrients by having the roots come down lower, but you would
7 run into more problems in a sandy soil than you would in a
& tight soil.
9 MR. PURDY: That, again, is, I think, another point
10 that we have to keep into consideration in that the normal
11 tendency is to seek a soil that will accept water readily,
12 and when we do that we enhance the possibility that this
13 will break through to the underground water.
14 MR. LaVEILLE: Right.
15 MR. PURDY: The only other comment that I have is
16 that, as we criticize a sister agency on its past performance,
17 I think we do so on the basis of, say, the public interest
13 and the wherewithal to do something today, and I think
19 maybe that sister agency could criticize pollution control
20 agencies in the same vein.
21 MR. LaVEILLE: They have.
22 JIR. PURDY: And that public interest is such and
23 the wherewithal to do something is much greater today
than it was yesterday, and I do believe that the Soil Con-
25 servation Service, as it relates to the erosion control and
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1 Discussion - Phosphorus
2 increased or better farm practices on agricultural land, that
3 they do have the expertise on how things should be donej
4 they do have the communication with the farmer; that there
5 are mechanisms in the Small Watershed Project for example,
6 the Environmental Impact Statement that we, as pollution
7 control agencies, can have some input to their programs;
8 and that we need to encourage them to consider in their
9 project those factors that we think are important.
10 MR. LaVEILLE: These points that you made are
11 exactly the ones that we have taken into consideration in
12 recognizing that we don't have the capability, the manpower,
13 the information delivery systems, to get down to the farmers,
14 the local level, where these erosion control or land manage-
15 ment systems can best be i. plemented,
16 The EPA has, instead, chosen to try to work through
17 memorandums of understanding with various U.S. Department of
IS Agriculture agencies. There is in force now a memorandum of
19 understanding with the Extension Service, which is the edu-
20 cational arm, through the universities, to initially the
21 first impact would be to educate the farmers on careful, on
22 safe pesticide control practices, now that some of the more
23 longlasting pesticides, like DDT, are no longer available.
2/«- So EPA is working through the Extension Service to try to
25 get some of our efforts down to the local people that will
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1 Discussion - Phosphorus
2 use them. We are also, on a regional level, working with t-he
3 Soil Conservation Service to try to get mutually directed
4 programs. Some of their Soil Conservation Service programs are
5 environmentally-oriented and some of our environmental pro-
6 grams are Soil Conservation Service-oriented to try to get
7 coordination between the two agencies' goals and directions.
$ MR. PURDY: Thank you.
9 MR. MAYO: Any other questions, gentlemen?
10 MR. FRANCOS: Mr. Mayo, I would just follow up on
11 Mr. Purdy's comments.
12 I sometimes get the feeling that the USDA and
13 EPA are somewhat similar to the Army and Navy the discus-
14 sion we had yesterday. I am not sure how much conversation
15 goes on between the two agencies, at higher levels. I am
16 encouraged at the last statement as to what is happening in
17 the Region.
18 But I think we get the feeling that perhaps the
19 agricultural community really isn't responding to the whole
20 environmental thrust. That may not be the case. But I don't
21 think this is being communicated to agencies and to the public
22 as well as it might be.
23 i think if we look at the Council on Environmental
2A- Quality report, that its major recommendations were concerned
25 about non-point pollution sources and problems.
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1 Discussion - Phosphorus
2 If you look at the kind of investment that we are
3 talking about assuming that legislation goes through
4 at least some people are talking about $24 billion of invest-
5 ment in pollution control.
6 I think the obvious question is that we ought to
7 look very closely at other pollution sources, if we are
8 talking about making these kinds of investments.
9 I would support the several questions that have
10 been raised in the committee report.
11 MR. MAYO: The point, I think, that ought to be
12 made is that this is a committee report. There was partici-
13 pation from EPA and the four States, and I think there is
14 at least the presumption that what is in the report reflects
15 the sensitive situation of those who participated
16 in its preparation. I am a little bit disturbed that we
17 find ourselves in a dialogue this morning that appears to
13 pit EPA versus the Department of Agriculture. I think
19 it is a rather inappropriate view of the situation. EPA is
20 not pitted against the Department of Agriculture, and I
21 want to make that position clear.
22 j Are there any other questions of Mr. LaVeille?
23 Thank you, Mr. LaVeille.
24 Gentlemen, in pursuing the Technical Committee
25 report, the committee does have a series of items in its
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1 Discussion - Phosphorus
2 summary on page 17 that the conferees might want to have at
3 least some measure of dialogue about; particularly important
4 in that summary is Item 2, in the form of a recommendation,
5 I suppose, that the maximum concentration of total phosphorus
6 in municipal and industrial effluents be set at 1 mg/1.
7 This would differ from the current conference report, I
# think, for &0 percent removal on a statewide basis, and
9 this is perhaps an item that the conferees might want to
10 have some commentary on in terms of the material that is in
11 the Phosphorus Committee report.
12 Do you have a question, gentlemen? Did you want
13 to pursue some of these questions at this time, or perhaps
14 to have that kind of a commentary take place in the Executive
15 Session?
16 MR. PURDI: I have one question that I would like
17 to ask the fellow conferees, to see whether or not we are
IS assessing the situation wrong in Michigan, or whether our
19 situation there is somewhat unique, or if this is something
20 that, in fact, exists throughout the four States that are
21 involved in the Lake Michigan Enforcement Conference.
22 And the dollar figures that I use may not be the
23 proper dollar figures, but I think the order of magnitude is
24 the right relationship, and that is: as we look at the
25 operating cost of an activated sludge treatment plant
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1 Discussion - Phosphorus
2 not debt retirement but operating cost and where, as a
3 rule of thumb, this might be for a medium-sized plant in
4 the neighborhood of $30 per million gallons of sewage
5 treated, and then as you move into &0 percent phosphorus
6 removal that you add an additional $30 to the operating
7 expense, not including schedule time, so that we now have a
$ total operating expense of about $60 per million gallons of
9 sewage treated, and as we discuss this moving into 90
10 percent, that we add roughly 40 percent additional chemical
11 cost, roughly another $12, or a total cost of $70 to $75
12 per million gallons of sewage treated, in the way of oper-
13 ating cost.
14 And although the polls show that environmental
15 issues rank in first, second, or third priority of all of
16 the issues that concern the public, that when municipal
17 officials are called before our Commission and asked to put
1$ in phosphorus removal, this additional operating expense is
19 something that they take on very reluctantly and sometimes
20 only if by force. And that when they go back home and raise
21 their rates to take care of this operating expense, it seems
22 as though their customers on the system say, "Who, me? You
23 have got to be kidding* Who is going to make a grant? Who
24 is going to share in this operating cost?11
25 And now we are talking about going up to, say, a
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1 Discussion - Phosphorus
2 further increase, and I anticipate that this will receive
3 the same reaction, and that as a pollution control agency
4 that would attempt to bring about this program that I can
5 see that we can only do it with difficulty with the present
6 attitude of the people that must pay the bills
7 I am wondering if my fellow administrators in the
g other States are experiencing that same problem, and if they
9 anticipate that the only way that we can move from BO to 90
10 percent removal is by extreme pressure placed upon the local
11 units of government by that State agency and by EPA.
12 MR. MAIO: Mr. Currie.
13 MR. CURRIE: The standard which was proposed by
14 the Technical Committee of 1 mg/1 is the standard adopted
15 by the Illinois Pollution Control Board on the basis of
16 considerable hearings which demonstrated to us that phos-
17 phorus is perhaps the most serious problem in Lake Michigan,
13 that it is deserving of the most urgent attention that we
19 can give, that technology is available at reasonable cost
20 for achieving that level. And on behalf of the Board, I
21 would certainly urge that the conference approve this
22 recommendation and that the other States adopt the regula-
23 tion, as we have in Illinois.
24 MR. FRANCOS: A point of clarification. You say
25 this applies for the Lake Michigan Basin, sir, is that your
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1 Discussion - Phosphorus
2 standing?
3 MR. CURRIE: Yes, that is right.
4 MR, FRANCOS: How many installations do you have?
5 MR. CURRIE: How many installations?
6 MR. FRANCOS: Yes, sir.
7 MR, CURRIE: Principally this means the North
8 Shore Sanitary District and the Federal installations in
9 that area.
10 MR. FRANCOS: Once that project inverts, Mr.
11 Currie, will the Sanitary District be required to meet the
12 1 mg/1?
13 MR. CUHRIE: They will not be discharging into
14 Lake Michigan at all any more, so they will meet the
15 standard by diverting out of the basin.
16 MR0 FRANCOS: What will they be doing, sir?
17 Where would that go? Where would the discharge end up?
IS What kind of treatment will that portion receive?
19 MR. CURRIE: That will depend on the standard
20 for the waters to which they discharge. In this case that
21 would be largely the Des Plaines River and the Chicago River
22 system which, according to the evidence presented to us, does
23 not have the same kind of a phosphate problem. But for any
24 discharge that is made or will be made to Lake Michigan or
25 any other water that has a similar phosphorus problem, then
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1 Discussion - Phosphorus
2 we think there ought to be phosphorus removal to the 1 mg/1
3 level.
4 MR. FRANCOS: But the North Shore Sanitary District
5 and the people it serves will not be charged a cost what-
6 ever that may be, however you can identify it for the
7 increment to get to 1 mg/1.
8 MR. BLASER: Yes, they will. Already this is being
9 done at the Waukegan plant. The remaining plants will be
10 doing this by December of this year, and they will continue
11 to do so until these are diverted away from the lake.
12 Roughly this means that the people in the North
13 Shore Sanitary District will be paying for the treatment at
14 all plants that will shift over to the Clavey Road plant
15 until 1974.
16 The Waukegan-North Chicago plant will continue
17 to 1976, meeting the standard of 1 mg/1 and paying for that
13 standard.
19 MR. FRANCOS: Well, let me just discuss the
20 situation as we view it in Wisconsin.
21 I think the point that Mr. Purdy perhaps raised
22 is whether you can finance whatever this cost is going to
23 be. It seems to me that the question that Mr. Purdy
24 raises is: Ought you do it? And I think we would be
25 inclined to look at the question as to whether it ought to
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1 Discussion - Phosphorus
2 be done. I think if we look at that question we automatically
3 get into a cost-benefit consideration, which I assume is what
4 the Illinois Pollution Control Board did.
5 Let me further add that at least the presentations
6 that were made to this conference yesterday afternoon and
7 this morning indicate two things: one, that indeed 1 rag/1
8 effluent is being met throughout the country, and the informa-
9 tion that I received doesn't give me the same degree of con-
10 fidence that that report indicated.
11 For example, Milwaukee was cited as being able to
12 achieve discharges down to concentrations of 0.5 mg/1, and
13 in our conversations with the Metro people, they said that
14 they could not absolutely guarantee that they could do this
15 365 days of the year. Beyond that, I think the impression
16 is that this can be achieved by simply increasing chemical
17 dosage, and I think you recognize this cost here as an
1$ important cost, but in some of our other facilities, we
19 understand that you can dose as much as you want and you
20 still aren't going to get it removed just by precipitation.
21 Indeed, you may have to go to some kind of a filtration
22 unit.
23 So, again, I think this is an important consider-
2^ ation in terms of the investments, operating costs, and a
2 5 cost-benefit consideration.
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1 Discussion - Phosphorus
2 If you look at the data tnat was presented to the
3 conference on what is happening, you get a mixed scene
4 certainly on the basis of two presentations that we had.
5 And I would have to say, at this point in time, that we are
6 not convinced that that incremental reduction is justified
7 at this point in time.
# MR. MAYO: Are there any other comments, gentlemen?
9 MR. McDONALD: Well, as the Federal conferee, I
10 would like to make a comment.
11 I think for a number of years, the fate of Lake
12 Michigan has been debated both from this forum and outside
13 the forum. It has been a mixed bag in terms of fate of
14 the lake. But it seems on the weight of all the evidence
15 that is in, if a mistake is going to be made, it certainly
16 is going to be made on the side of safety, and that is the
17 simple solution. But maybe a simple solution is what is
1& needed here.
19 We are not going to get the lake any better if
20 I we don't move now. We cannot correct the mistakes of the
21 past if we don't move forward at the present time.
22 One of the staff members of the EPA did a little
23 calculating on his own and, again, it is simple, but at
24 $75 per million gallons that is a little less than a penny
25 a day per capita. And a penny a day per capita, sitting in
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1 Discussion - Phosphorus
2 and of itself as an add-on cost for sewage treatment, seems
3 to me is an expenditure that we cannot afford to not make.
4 Why are we doing this? Well, we are doing it to
5 protect the lake. Results of increased nutrients in the
6 lake are well known, have been catalogued to this conference
7 and outside the conference in abundance. We have got several
8 experts here who could recite this case again, and recite
9 it specifically for Lake Michigan as to what will happen if
10 the lake continues to get overenriched.
11 So, from a Federal standpoint, speaking as a
12 Federal conferee, I think we ought to move on with the
13 adoption of this requirement as rapidly as possible.
14 MR. MAYO: I would like to make a comment. I
15 have been looking for an appropriate point to respond to one
16 of the comments that Mr. Dustin made last night concerning
17 EPA's posture as it relates to the control of phosphorus in
18 detergents, and I think there has been a long dialogue on
19 that.
20 In summary, briefly, as you recall, there was a
21 commentary on the findings on the part of the Surgeon General
22 expressing concern for the character and the hazards of the
23 replacements for phosphorus filler in detergents. And a
2Z»- followup commentary on the part of EPA which, in effect,
25 said that while there is no desire on the part of the Federal
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1 Discussion - Phosphorus
2 Government, at this point in time and in a sense of purely
3 justification on the part of the Federal Government at this
4 time to establish a national policy for the control of
5 phosphorus content in detergent, that those States or local
6 governments that find themselves moving in that direction
7 need to examine the alternatives very carefully for them-
& selves, and take whatever measures they feel are appropriate
9 to solve the eutrophication problems that are of significance
10 to that State or to that community. At no point, to my
11 knowledge, has EPA ever attempted to discourage a State or
12 local government from moving ahead with those programs of
13 phosphorus control in detergents which were felt to be
14 necessary to take care of State and local problems.
15 So that, it seems to me, in the situation of Lake
16 Michigan, with action already having been taken on the part
17 of Indiana Michigan has constraints on the phosphorus
IB content in detergents that the communities involved have
19 available to them at least in those two States some-
20 thing other than treatment alone as the basis for reduction
21 of phosphorus content in the municipal effluent, and that
22 the reaching of a maximum concentration of 1 mg/1 in the
23 effluent may indeed be arrived at by a variety of actions.
24 But what this conference ought to address itself
25 to is the reasonableness of the level of control of 1 mg/1,
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1 Discussion - Phosphorus
2 as has been recommended by the Phosphorus Committee, as being
3 necessary for the control of water quality in Lake Michigan,
4 and to leave to the community or to the groups of communities
5 as they may relate to an individual State, the alternatives
6 that are available to be used for arriving at that end
7 result. And that the conferees, in my opinion, need to
8 direct the weight of their decision toward the long-range
9 water quality conditions in Lake Michigan, even though this
10 might have a reasonably significant economic burden on the
11 municipal and industrial waste dischargers. Then let's look
12 at the weight of that requirement to give us the direction
13 for improving the technology in reducing the cost,
14 MR. PtJRDY: Mr. Mayo, with respect to the 1 mg/1
15 recommendation, if this conference determines, that such a
16 recommendation, in fact, is necessary to protect Lake Michi-
17 gan, then I think it should be adopted and that we should do
18 this.
19 In my discussion on the cost, though, we do see
20 citizen interest here today and throughout this whole confer-
21 ence proceeding, and the conferees taking that sort of action
22 that is determined necessary to protect the lake.
23 We do, in Michigan, see that same sort of citizen
24 involvement in making sure that our Water Resources Commission
25 takes that sort of action to require that the recommendations
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1 Discussion - Phosphorus
2 of this conference be required within the State.
3 Just one time though I would like to see an in-
4 force, concerted citiaen involvement before their own govern-
5 ing body saying: "Raise my water treatment rate so that we
6 can treat the sewage to the level that the State and the
7 conferees in this enforcement conference say is needed,"
& If this took place, I think we could accomplish
9 our objective in half the time, particularly if the cost is
10 largely that of chemical cost and does not involve State and
11 Federal grant participation. And I just don't see that
12 taking place, I don't see citizen involvement before their
13 local body saying: "Raise my water rates. I am willing to
14 take on 1-cent per day cost to have clean water in Lake
15 Michigan," And I don't see that taking place,
16 MR, McDONALD: Well, I would have a brief answer
17 to that, Mr, Purdy.
18 Admittedly, the cost of phosphorus removal for the
19 most part is not going to be eligible for Federal or State
20 grant participation.
21 On the other hand, the fact that you lament the
22 fact that the citizens don't jump up to declare themselves
23 in favor for higher expenditures, I think that your own State
24 when you passed the $335 million bond issue the citizens
25 were taxing themselves here, I think you passed that bond
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1 Discussion - Phosphorus
2 issue by is it 2 to 1?
3 MR. PURDY; Yes.
4 MR. McDONALD: You had a similar bond issue here
5 the largest in the whole Nation, other than the bond issue
6 passed by New York State the Illinois bond issue: $750
7 million. In fact, that was the second largest bond issue
3 ever passed in the United States. New York State passed a
9 billion dollar bond issue by an S3 to 17 percent margin. And
10 other States have passed such bond issues. The people have
11 voted directly on these bond issues, and I think they have
12 demonstrated time and again that they are willing to pay for
13 some of these solutions that have to be paid for.
14 Now, getting down into a local situation, when
15 the mayors come in to your Commission and I have read
16 your hearings time and again and I know the problems that you
17 are confronted with over there he certainly doesn't want
18 another $150 a day or another $300 a day. He just doesn't
19 come in to volunteer for that type of expenditure if he keeps
20 j getting more taxes.
21 But it seems to me that the responsibility of this
22 conference goes above and beyond the pressures that an
23 individual mayor or a city council sitting back on a tribu-
24 tary stream in the State of Michigan, or any other State,
25
' may be confronted with, not realizing the overall benefits of
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Discussion - Phosphorus
what that expenditure is going for. And maybe we have failed
in not demonstrating why these expenditures are needed,
although I fail to see what else can be done to predict
what will be the future of Lake Michigan if proper nutrient
controls are not instituted,
MR. PURDY: Mr. McDonald, I agree with you. I am
really asking for help: Continue the citizen interest in
| these conferences; continue the citizen interest in various
State regulatory programs. But I am also now asking for
their help in going back to their local community and making
our job easier.
MR. McDONALD: Well, I think you know and I think
I know, having been in this pollution business for some time,
that that just doesn't happen. I doubt if anybody sitting
in this room is going to go back and stand up before their
city council and say: "You know what I heard in Chicago? It
is going to cost you a penny per day more. I want you to
agree with your State Commission that you ought to have this
added expenditure
Tl
It just doesn't seem to happen that way, and
whether this is a popular decision locally or not, it seems
to me that there is a responsibility here above and beyond
that because this is what, I guess, they pay us for.
MR. PURDY: Yes. But this now means that when we
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Discussion - Phosphorus
consider the time necessary to implement this program it is
going to seem like it takes an undue length of time
MR. McDONALD: I know.
MR. PURDY: ~ because we are going to have to
kick everybody every step of the road.
MR. McDONALD: You are absolutely right. You know
I am very interested in what happened in the State of
Wisconsin in the last couple of months.
I think Tom Frangos, when he gave his report, showed
the very dramatic turnabout from the information that was
available to us in August, where he had a real number of
delinquent communities that were not going to meet the phos-
phorus control deadline for the end of 1972. And he came
into this conference and that was dramatically turned around
and you heard him from the podium yesterday.
Why did this happen? He said he thought it happened
because of the State and the Federal pressure that would
result in making these communities realize that these
agencies finally mean business. And I think that fact was
probably the instrumental fact, according to Mr. Frangos.
Maybe we need to be stronger in terms of'we mean business to
get this job done."
MR. SCHRAUFNAGEL: I believe that we in Wisconsin
have some reservations in the observance of the law, and
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1 Discussion - Phosphorus
2 that is the actual feasibility of maintaining the 1 mg/1 at
3 all of our installations.
4 As part of the engineering that goes into these
c processes, we recommend that they do some pilot work. A
6 number of them or practically all of them do this
7 pilot work, and in some of those communities, in their con-
g sultants' opinion, they cannot reach the 1 mg/1 regardless
9 of the amount of chemical that is added.
^g True, the city of Milwaukee and the Metropolitan
11 Sewerage Commission has its own pilot plant and gets concen-
12 trations down to 0.5 mg/1. But even at this installation,
13 if we asked the operators whether they can do it, whether they
14 can guarantee it every day, the answer is "No." They could
15 guarantee it at that installation perhaps on a monthly average
16 or a yearly average, but to guarantee it every day, no.
17 At other installations, where they have peculiar
lg type wastes, they claim they cannot reach the 1 mg/1 level,
19 and I think this was also brought out to a certain extent
20 by Dr. Barth yesterday. He cited some plants that were
21 getting 1.2 or 1.3 or 1.4, in addition to those that were
22 getting less than 1 mg/1.
23 MR. McDONALD: I excuse me.
24 MR. BLASER: May I add something from Illinois?
25 MR. McDONALD: Let me just add that one statement.
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1 Discussion - Phosphorus
2 I think that that point that Mr. Schraufhagel
3 raises is a very good point, that maybe this 1 mg/1 cannot
4 be demonstrated at every single plant, and maybe not at the
5 majority of the plants. But the issue that the conference
6 and that the conferees are faced with is whether we ought
7 to shoot for this as a goal, if nothing else.
8 It seems to me, again, if it cannot be reached
9 from a technical standpoint consistently, that is something
10 that we have to do ongoing work on while, at the same time,
11 trying to reach this 1 mg/1 as consistently as possible.
12 I cannot imagine anyone in the Federal or the
13 State regulatory agencies going after a community that
14 failed to meet the conference requirement or goal because
15 it was technically impossible to achieve that goal.
16 MR« MAYO: A point that seems to be of some con-
17 cern to you gentlemen is the 24-hour composite sample
13 requirement in the committee's recommendation.
19 Would it be reasonable to look at this from the
20 standpoint of an accounting for the 1 mg/1 average on other
21 than a daily basis; look at it from a weekly basis or a
22 monthly average basis, to provide for the vagaries of
23 operation, the opportunities for periodic or short period
24 upsets that might take place in any sewage treatment plant,
25 and yet accomplish the intent of the recommendation by having
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1 Discussion - Phosphorus
2 that level of constraints accounted for on a longer period
3 of time?
4 MR. BLASER: Mr. Chairman.
5 In listening to each of these points that is being
6 debated currently, that we have taken care of in Illinois
7 these are not new issues.
g Most people are aware that the Illinois standard-
9 setting procedure requires that formal public enforcement
10 hearings are held before the Pollution Control Board, and
11 that each element is debated openly and subject to cross -
12 examination. This was done on each of the questions that
13 are being discussed right now: the question of technical
14 feasibility; the question of cost; the question of need,
15 as far as Lake Michigan is concerned; the question of ban-
16 ning detergents on a statewide basis, and so on.
17 if it would be of any value to the conferees, I
18 could get photocopies of the Board's opinion, which sum-
19 marizes each of these points in some detail; and then further
20 if there is need to, it refers to the explicit testimony in
21 the record. I could have such copies here by this afternoon
22 if this would be of any help. (The document follows.)
23 And incidentally, Illinois, after all that evi-
24 dence, decided that it was technically feasible, that the
25 costs were reasonable, that the need was present in the lake,
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ILLINOIS POLLUTION CONTROL BOARD
April 28, 1971
)
in re )
) IR70-6
PHOSPHORUS WATER STANDARDS j
)
Opinion of the Board (by Mr. Dumelle):
1. Introduction
We like to believe that there is a time and place for
everything. The time to be serious about saving our place called
Lake Michigan is very quickly passing. It has been demonstrated
to the Pollution Control Board that we must enact measures which
will restrict the input of phosphates into the Lake now so that it
will not suffer the fate of Lake Erie, so that Lake Michigan will
not have its quality impaired beyond the present state, so that
Lake Michigan will not be lost as a "great" lake. To preserve
Lake Michigan as a source of public water supply, as a commercial
and sport fishing center, as an invaluable recreation area and as
a natural public possession of inestimable worth we must act now.
The first annual report of the President's Council on Environ-
mental Quality recommends that a concerted and comprehensive
attack be made on eutrophication. The report stresses three necessary
actions: 1)phase phosphates out of detergents as soon as feasible,
2)find better methods to control agricultural runoff, and 3) remove
from lakes more of the nutrients generated by towns and cities
particularly in urban centers and critical areas such as the
Great Lakes (R. 489).
With the enactment of the Environmental Protection Act, the
Illinois Legislature charged the Illinois Pollution Control Board
to "determine, define and implement the environmental control
standards" necessary to accomplish the purpose of the Act "to
restore, protect, and enhance the quality of the environment..."
iSec. 5(b), 2(b)]. The enactment of a water quality and effluent
standard to restrict phosphorus discharges into Lake Michigan is a
measure backed by that purpose.
Possibly the single most urgent concern we must have with
Lake Michigan is the question of accelerated eutrophication
that is, concern with the speed-up of the natural aging of the
Lake due to man's introduction of an abundance of nutrients in a
quantity fantastically beyond nature's input. As a rough but
dramatic analogy we can view nature's input of nutrients into Lake
Michigan as being enough to feed a suckling piglet while man's
activities, including agriculture, are pouring in a sufficient
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amount to sate a 500 pound hog. With final adoption of the phosphate
water quality and water effluent standard on January 6, 1971, the
Illinois Pollution Control Board has in effect declared that "We
must save Lake Michigan - no ifs, ands or buts - starting right now".
The section of this opinion headed Eutrophication has been
further subdivided to consider the following questions:
a. What is the present lake quality?
b. Why limit phosphorus?
c. At what level should phosphorus be limited?
d. What is the contribution of land-runoff?
e. Should phosphate detergents be banned?
2. Effluent and Water Quality Standard
The phosphorus standard adopted by the Board on January 6, 1971
originally proposed on August 19, 1970 in a somewhat different form.
As finally enacted this standard reads as follows:
PREAMBLE
Phosphorus is an element which is a nutrient for algae.
Present Federal and State policies for Lake Michigan include the
control and reduction of phosphorus in order to limit the production
of algae. Algae causes tastes and odors in water supplies and may
reduce dissolved oxygen in water. Algae is a nuisance to swimmers
and can reduce the enjoyment and property values of shore line
property.
The present standards for phosphorus in the water of Lake
Michigan are at levels which are thought to be those at which algae
blooms will occur and greater than present bulk water levels. The
new standard is 2/3 of the former standard. An effluent standard
is added to provide a control on phosphorus discharges to Lake Michigan,
1. Water Quality Standard. Existing Board Regulations
specifying water quality standards for Lake Michigan, Wolf
Lake and the Calumet River (lakeward of the O'Brien Locks)
are hereby amended to provide that the concentration of
total phosphorus measured on unfiltered samples in these
waters shall not exceed 0.02 mg/1 as phosphate (PC>4) or
0.007 mg/1 as phosphorus (P).
2. Effluent Standard. Except for unavoidable combined sewer
overflows during the interim period before their complete
elimination, no effluent to the waters of Illinois listed in
Section 1 above-, shall include phsophorus in excess of
3.0 mg/1 as phosphate (P04) or 1.0 mg/1 as phosphorus (P)
after December 31, 1971. Dilution of effluents shall not
be acceptable alternatives to treatment. Where water is added
to streams of waste water and cannot be reasonably separated,
then its quantity shall be measured and effluent concentrations
recomputed to exclude its diluting effect.
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3. Testing. All testing pursuant to the Regulations herein
provided shall be made using methods as listed in the publi-
cation "Methods of Chemical Analysis of Water and Wastes",
November, 1969 as issued by the U.S. Federal Water Quality
Administration.
4. Effective date. Except as specifically provided in Section
2 of these Regulations, the requirements of these Regulations
shall be met within ten days after filing with the Secretary
of State.
3. Eutrophication
The pollution problem or hazard presented by the introduction
of phosphates into water bodies, and in this case Lake Michigan,
is the enhancement or increased rate of eutrophication. Leading
authorities, including Dr. A.F. Bartsch have stated that the
problem of eutrophication is one of the chief concerns about
Lake Michigan. Eutrophication is the aging process of the Lake
in which the waters become more fertile and acquire a greater
ability to grow algae and other forms of unwanted living matter.
Eutrophication becomes a severe problem when the algae become so
preponderant that they color the water green and interfere in many
ways with the continued usefulness of the water. Considering
the undesirable effects of eutrophication, it may be regarded as
a severe form of pollution.
Human sewage and industrial waste are significant sources of
nutrients that contribute to the eutrophication of Lake Michigan.
Drainage from farm land is also an important source, a substantial
quantity of the nutrients come from manure that is spread on
frozen grounds which is subsequently flushed into streams during
spring thaws and rains. Runoff from urban areas is rich in
phosphate and nitrate. (Ex. 3, p. 4)
The abundance and species composition of planktonic, bacterial,
benthic and fish populations change as eutrophication progresses and
changes of this nature may be used to detect and measure the degree
and rate of eutrophication. Enriched lakes develop dense populations
of planktonic algae, commonly dominated by a few species of blue-green
algae. Lake Erie has already experienced the elimination of benthic
invertebrates and massive blue-green algae blooms. (Ex. 3, p. 4)
Dr. Bartsch has stated that some of the changes to look for are:
decrease in transparency of the water; increase of total dissolved
solids; loss of dissolved oxygen in the deeper layers; and changes
in bottom dwelling animals and microscopic plants. When eutrophica-
tion has not proceeded to an obvious and objectionable stage, it
becomes necessary to examine the combination of these more subtle
clues in order to sense the existing state of affairs. In many cases,
such scrutiny may reveal a forecast of things to come. Changes such
as the above are now appearing in Lake Michigan (R. 69).
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a. What is the present lake quality?
The testimony of Dr. Bartsch showed that extensive inshore
areas of pollution were found along the entire southern perimeter
of Lake Michigan. At various times swimming beaches have been closed
in Chicago and other areas when large mats of foul smelling algae
have been deposited on the beaches. The aesthetic character of Lake
Michigan has been impared by algae on many occasions. On a far more
practical level drinking water treatment plants have had their oper-
ation and efficiency impaired by short filter runs and tastes and
odors resulting from high phytoplankton. Such impediments to the
operation of these plants have lead to increased cost of water
treatment in Chicago and other cities (R. 24).
High concentrations of phosphorus favor the blue-green algae
which are capable of using nitrogen from the atmosphere as a source
of nutrition. These algae are particularly obnoxious because they
are more buoyant than other forms thus tending to form windrows and
produce especially obnoxious "pig pen odors" because of chemical
compounds peculiar to them. The seemingly inexhaustible supply of
algae that has washed ashpre in recent years has defied maintenance
attempts to keep some beaches usable during the entire recreational
period. Bathers and sunbathers must travel further to enjoy
their sport (R. 27).
Bottom animals serve as a vital link in the aquatic food web
by converting plant food into animal food for predatory fishes.
Changes in numbers and species of bottom animals consisting pre-
dominately of burrowing worms favors a community of fishes such as
carp and suckers that root for their food. An increase in worms is
a product of an increased food supply from sedimentation or organic
waste materials or dead algae. Changes in the kinds and numbers
of bottom animals are effects that are frequently a product of
pollutants; these changes result in damages to desirable aquatic
organisms, and may produce increased numbers of undesirable aquatic
organisms that interfere with the use that can be made of the water
(R.29).
Mid-Lake Area
Deep water areas of Lake Michigan are as yet unaffected by
the more intensive pollution observed in many in-shore areas. The
soluble phosphate content has been determined to be 0.02 mg/1 (PO^)
in deep water areas as an average with some concentrations going up
as high as 0.14 mg/1. Areas close to shore averaged 0.04 mg/1 with
some concentrations as high as 5.00 mg/1.
In-Shore Area
Inshore areas are primarily the shoreline areas which are used
for recreation, which extend out as far as one goes for water supply.
This may be out to a depth of approximately 10 meters or approximately
40 feet (R. 93).
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Massive areas along the perimeter of the southern half of
Lake Michigan are polluted to such an extent that large populations
of pollution tolerant sludgeworms occur (R. 36). For several years
the Chicago Park District has reported that beaches became fouled
with algae washed in from the Lake. The windrows of algae that
completely lined the beaches became foul smelling after a few
days exposure to the summer heat. Flies and other insects covered
the decaying mass (R. 46). These biological findings reflect the
deteriorated water quality of Lake Michigan and represent the gross
pollution resulting from the domestic and industrial waste dis-
charged into the Lake and the result of urban and rural land runoff
of nutrients (R. 50).
The facts revealed by these studies make up the story of
what has been happening to Lake Michigan in recent times. Many aspects
of the storv are far from clear but what is clear is that excessive
amounts of nutrients are present (R. 67).
In the words of Dr. Bartsch the condition of Lake Michigan
can be summarized as follows:
The tremendous mass of data gathered on the
physical, chemical, and biological status of Lake
Michigan indicate that the Lake, as a whole, is
beginning to show some early symptoms of accelerated
eutrophication.
The offshore, deep water areas of Lake Michigan do
not show substantial effects of pollution or the onset
of eutrophication forces. They do, however, exhibit
a combination of minor and subtle changes that
suggest that the real beginnings of eutrophication
are just around the corner.
In contrast to the offshore waters, the inshore areas
have changed drasticallv ... In recent years both
attached and free floating algae, ... frequently have
appeared in nuisance proportions at various harbour
and waterfront areas around the Lake.
The growth of such masses of algae is a direct response
to concentrated levels of nutrients brought into the
Lake by way of municipal sewage, land runoff, urban
drainage, industrial waste and other sources. In Lake
Erie growths of [algae] seem to have been aforerunner of
the more widely dispersed free floating or plankton
growths that now exist there.
In the southern end of the Lake there is ample
evidence of deterioration of chemical water quality
in areas adjacent to population centers. Total
inorganic nitrogen and soluble phosphate were found
to be highest here (R. 79-83).
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Dr. Bartsch concluded as follows:
While the deep water areas of Lake Michigan give only
a suggestion of creeping eutrophication, the Lake's
response to increasing nutrients in the inshore waters
is obvious and shows that the Lake can respond when
nutrients for plant growth are abundant. Lake Michigan,
as a whole, is now at an early stage in the eutrophication
process that was passed through by Lake Erie at some point
in the past. With increasing time, nutrient levels will
increase until finally the entire Lake becomes involved.
With certain reservations, Lake Erie can be viewed as
a prototype and a preview of what can happen in Lake
Michigan if nutrient bearing wastes input continues
unabated (R. 87).
b. Why limit Phosphorus?
Many nutrients are required for the growing of algae and
among these are carbon and phosphorus, nitrogen and others. The
easiest one to limit is phosphorus. The activities of people
account for a high proportion of the phosphorus input into troubled
lakes. This is a good reason to focus control on phosphorus.
Dr. Bartsch commented on carbon as a limiting factor. He
stated that briefly, the carbon theory is that if bacteria in the
Lake which have the capability of decomposing organic matter, in
doing so liberate carbon as carbon dioxide, then the supply of
carbon dioxide in the water is increased and is available to
algae for growth. Obviously this accelerates the eutrophication
process. The carbon theory implicates carbon as the culprit and
attaches little significance to phosphorus input. An important
tenet of the theory that carbon is the critical factor in the
process of eutrophication is the symbiotic relationship between
bacteria and algae; the relationship is the main thesis of the
Lange-Kuentzel-Kerr proposition. Dr. Bartsch stated that he
disagrees with this thesis and feels that the principal scientific
and limnological community is also in disagreement with the thesis.
The fundamental biology relating to algae, an abundance of which
signifies the most- xnerous characteristic of eutrophication,
requires that a nt er of nutrient elements are necessary to support
their growth. Ale ,. use up carbon in a ratio of 100 to 16 nitrogen
to 1 phosphorus atom.
Also to be considered is the fact that carbon and nitrogen
are very nearly ubiquitous while the same cannot be said for
phosphorus. That is, phosphorus can be kept out of the water more
easily than can either carbon or nitrogen. Lakes that have been
studied and seem to indicate that carbon may become the limiting
factor are not tvpical lakes, the kind generally thought of with
eutrophication problems. A more in-depth look at the question leads
one to the conclusion that for all practical purposes the controlling
element to consider is phosphorus (R. 278).
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Some lakes with high phosphorus content are not algae
bloomers because other elements, sometimes trace metals, are not
present. In Lake Tahoe nitrogen may be the limiting factor (R. 314) .
To ascertain the limiting factors one must look at all the
nutrients that are needed. If one of the nutrients, phosphorus, can
be limited, then it becomes the critical limiting factor. We do
not know with complete certainty what the limiting factor in Lake
Michigan is (R. 286). But it is manifestly evident that phosphate
has an effect on the algae population in Lake Michigan.
c. At what level should phosphorus be limited?
The generally accepted rule of phosphate in excess of
0.01 mg/1 as P as causing algae blooms appears to have been derived
from a paper published in 1947 by Clair N. Sawyer (Ex. 2). Before
undertaking any discussion of eutrophication and phosphate input
into water it should be noted that considerable confusion inevitably
arises as to whether one is expressing concentrations and inputs in
terms of phosphate (PO.) or phosphorus (P). Fortuitously the
conversion factor from phosphorus to phosphate is simply 3.
Conversely to change basis from phosphate to phosphorus is simply a
matter of dividing by 3. In this opinion the convention of expressing
concentration on the phosphorus basis is used unless otherwise noted.
If the availability of phosphorus is increased, algal growth
increases. Sawyer (Ex. 2) has demonstrated this although his data
has been misused. Sawyer stated that if the studied lakes were to
have a concentration of inorganic phosphorus at the level of
.015 mg/1 at the time of the spring overturn and an accompanying
concentration of 0.3 mg/1 of nitrogen objectionable blooms of algae
would result. Some observers have ignored the spring overturn
and others have interpreted these numbers to be somehow magic below
which there would be no algae and above which there would be an
abundance.
Mr. John Morris of the City of Chicago, Department of Environmental
Control recommended the setting of a water quality standard lower than
.02 mg/1 (PO.) . He stated that the proposed effluent standard of
1 mg/1 (P) does not appear to be adequate to protect Lake Michigan
from the threat of accelerated eutrophication due to the presence
of excessive amounts of phosphorus. It does not appear to reflect
the more stringent standards being considered elsewhere nor the
potential of current technology. He urged the Board to adopt an
effluent standard which recognizes and requires utilization of the
best available technology (R. 492).
The Lake Michigan and Adjoining Land Study Commission has stated
that the Lake should not be allowed to deteriorate beyond its present
phosphate level (R. 349). The Commission asserted that if the proposed
effluent standard, 1.0 mg/1 as P, were adopted and if current sources
of phosphate input were allowed to continue discharging at their present
rates water quality would deteriorate. The Commission urged
the Board to arrive at a standard which would
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not further degrade the Lake. Phosphorus removal technology is
available for use today the Commission asserted, and an effluent
standard of 1 mg/1 will still degrade the Lake .
It must be stated that the effluent standard of 1 mg/1
(as P) was not designed to meet the 0.007 mg/i water quality standard
because, as was stated in the original proposal, there was no way
of ascertaining that figure (R. 359) . The figure of 1 mg/1 was
proposed as representing the application of the maximum feasible
technology for phosphorus removal.
Phosphorus removal technology is both well known and
readily available. Phosphorus removal can be effected by either
straight biological removal, straight chemical precipitation or
combined biological-chemical removal. Other, less common processes
such as ion exchange, and electrodialysis are less feasible, but
available. Removal efficiencies in the range of 80-05 per cent
can be expected from the ordinary treatment methods. (R. 185-186).
The treatment method which can most easily be designed,
constructed and operated today is chemical removal by precipita-
tion and coagulation. The chemical removal process can be closely
controlled and efficiencies in excess of 90 per cent are readily
effected. (R. 190-192). An additional benefit accrues in the
removal process inasmuch as other pollutants are substantially re-
duced. Lime, alum, polyelectrolvtes and waste pickle liquor are
the most common chemical additives in use today. All four treat-
ment methods are straight-forward, reliable and easily controlled
to produce a predictable effluent quality. The choice of which
chemical agent to use is principally dictated by local considerations
such as availability of pickle liquor and sludge disposal requirements
Mr. Raymond E. Anderson, General Manager of the North
Shore Sanitary District discussed the District's experience in
using waste pickle liquor (spent hydrochloric and sulfuric acid)
which is trucked from a steel works in Waukegan to the Waukegan
treatment plant. The chemical is available at no cost, other than
freight costs, to the District; the steel mill is happy to be rid
of it as it alleviates a waste disposal problem for the mill.
Eighty percent removal of the 12-15 ppm of phosphate in the plant
influent is accomplished by addition to the sedimentation tanks
(R. 122-127).
Costs of phosphorus removal have been variously estimated.
At one end of the spectrum is the minimal capital and chemical use
and operating costs associated with the use of spent pickle liquor.
Dr. John Pfeffer, Professor of Sanitary Engineering at the University
of Illinois, testified that technology is available for removal of
phosphorus at the 90 percent level at the cost of less than 5g? per
1,000 gallons (R. 164-165). He further testified that treatment
with polyelectrolytes or lime are probably at the same cost level
(R. 182). As processes improve, the record of experience is length-
ened, and economies of scale are realized, it is anticipated that
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treatment costs will be much improved (R. 194-196). On another
basis it was estimated that removal of 50% of the phosphorus
in sewage could be accomplished at a cost iri the range of $.22
to $1.40 per person per year (R. 405, 419-422).
The analytical method of determining the phosphate content
of waste water and Lake Michigan water wa's another subject of
consideration for the Board. To facilitate the comparison of data
from an historical prospective, it is important that reports from
various years can easily be correlated. The Illinois Sanitary
Water Board's report of May 1970 indicated a change in analytical
technique as follows:
During 1968...the tests were performed on
unfiltered samples. It was decided prior to
the 1969 season that only soluble phosphates
should be measured. Therefore the 1969 sam-
ples were all filtered prior to analysis.
Such a change in laboratory methods can, and indeed has, resulted
in data which cannot be easily compared. The Board therefore felt
that the method or a choice of methods should be specified in the
standard.
Other testimony indicated that the ratio of total phosphorus
to that form of phosphorus available for plant growth varies widely
and it is therefore desirable to establish limits on the total
phosphorus rather than on that part of the -element that may be
available for immediate plant use. The appropriate phosphorus deter-
mination for water in which there is a substantial amount of suspended
soil particles is currently receiving further study. For Lake Michigan
the record shows that the standard should apply to total phosphorus and n( t
simply a portion of the phosphorus such as soluble or filterable phos-
phorus .
d. What is the contribution of land runoff?
One of the principal factors that affects the rate of
eutrophication is the extent to which nutrients needed by algae
enter the body of water. Under natural conditions unaffected by
man, the input of nutrients from the watershed runoff, and in
deposition from rain and snow is low. The aging process thus
proceeds at a low rate. Cultural developments on the watershed
such as the establishment of cities and various agricultural
activities accelerate the nutrient input leading to accelerated
aging (R. 71). The Lake is brought more rapidly to a high level
of fertility, and greater crops of algae and other plants are
produced than under natural influences alone (R. 73) .
Drainage areas that are primarily rural with intensive
agricultural activities can be expected to have runoff as the major
phosphorus input; as the land use changes from agricultural to
urban, the contribution of phosphorus from land drainage decreases
(R. 155-157) . In heavily urbanized drainage basins a major portion
of the phosphorus originates from waste water from municipalities
and industry. The FWQA study of Lake Erie indicated that approxi-
mately 2/3 of the phosphorus input into Lake Erie was attributable
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to urban sources. Clearly, control of municipal and industrial
discharges to Lake Erie would markedly reduce the eutrophication
effects. It must be noted that the Lake Erie basin is very small
and highly urbanized and in this regard contrasts strikingly with.
the Lake Michigan basin (R. 157).
Dr. Bartsch estimated that the annual input of phosphate
to the Lake from the soils of the Lake Michigan basin amount to
approximately 5,000,000 pounds per year. Another 10,000,000 pounds
comes from municipal and industrial waste (R. 74). Expressed as
phosphorus this would be a total annual input of. 5 million pounds.
Although this estimate of phosphorus input is frequently heard, it
is open to question and is currently undergoing re-evaluation. The
sources of the phosphate can be readily identified but quantification
of the phosphate input from each source is not easily made.
Mr. R. H. Harmeson reported that the annual phosphorus
input to Lake Michigan in 1963-1964 totaled 4,790,000 pounds while
the outflow was 262,000 pounds. The total input was estimated to
be about 1/3 (1,640,000 pounds) from soil in runoff and 2/3 (3,150,000
pounds) from municipal and industrial wastes. The population for 1960
in the Lake Michigan drainage basin was 4.2 million. This excludes
the large numbers of people living in the Chicago metropolitan area
complex since they are outside the Lake drainage area. The reported
phosphorus input calculates to a phosphorus input rate of about 0.7
pounds per person per year from the domestic-industrial source.
Using Harmeson's 1963-64 input data the extrapolated
estimate for 1970 is 5,650,000 pounds of phosphorus input into
Lake Michigan. Of this total 1.6 million pounds is estimated as
soil runoff and 3.9 million pounds as contained in waste effluents
and a comparatively miniscule 150,000 pounds as direct precipitation
contained in rain and snow. These figures are the result of using
an estimated annual usage rate per person of 0.7 pounds as
phosphorus.
Harmeson stated that the 1964 estimate for the input
rate from land runoff was 36 Ibs./mi. /year which he characterized
as a highly conservative rate. Sawyer's average for the Madison
Wisconsin area was 255 Ibs./mi. /year (R. 331-332).
The accuracy of these estimates of input rates is not
nearly so significant as the relative magnitude of the contributions
from various sources, the phosphorus input from waste effluent
compared to that from land runoff is a ratio of 2:1.
Mr. Harmeson also reported estimated phosphorus loading
using a more realistic input estimate of 4.0 pounds/person/year.
With this latter rate the 1970 input estimate totals 23.75 million
pounds with the soil runoff remaining the same at 1.6 million
pounds and the amount attributable to waste effluents being 22.0
million pounds (R. 335).
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It is interesting to note that using Sawyer's estimate of
255 Ibs./mi. /year for the land runoff figure results in a total
loading from this source of 11. 68 million pounds per year. When
juxtaposed with Harmeson's estimate of 22.0 million pounds of
phosphorus from industrial-domestic sources the ratio of 2:1 is
maintained.
A very recent analysis by Mr. Michael J. Schmitt
(Phosphorus and Phosphorus Input to Lake Michigan, unpublished
manuscript, 1971) reports a 1969 total input level of 15,282,222
pounds/year as phosphorus. This is more than 300% greater than the
input figure usually heard. No attempt is made to estimate the
important ratio of waste effluents to land runoff. The great
disparity in the various estimates of phosphorus inputs is a
lustily waving warning flag to all investigators pointing to the
fact that more definitive investigation is needed to more pre-
cisely ascertain both the actual amount of input and the relative
contributions of waste discharges and land runoff.
The disparity in the estimates also suggests that the
contribution attributed to land runoff may be grossly understated
and that indeed runoff may be the greatest contribution. This has
been suggested to the Lake Michigan Enforcement Conference with
the further suggestion that the Conference undertake an immediate
comprehensive survey of the-question.
e. Should phosphate detergents be banned?
The amount of phosphates discharged to Lake Michigan are
partly controllable and partly uncontrollable. If phosphates in
treated waste water are to be controlled, two methods are available;
(1) elimination at the source or (2)removal in the treatment plant
process. Waste detergents are a principal source of phosphates in
sewage. Steps have been taken locally and are being considered
nationally to ban the sale of detergents containing phosphates
(R. 120).
Mr. John Morris of the City of Chicago Department of
Environmental Control requested that the Board consider regulations
prohibiting the sale of detergents containing phosphates. He
introduced as an exhibit a copy of the Chicago ordinance banning
the sale of detergents containing greater than 8.7% (wt. % expressed
as P) of phosphates after February 1, 1971 (R. 492).
Mr. Theodore Brenner testified as a witness for the Soap
and Detergent Industry Association and Dr. Paul Derr testified for
FMC Corporation as a major producer of phosphates for detergents.
The Soap and Detergent Industry Association is an industry trade
organization representing well over 90% of the soap and detergent
production in the country. Mr. Brenner stated that the Association
is fully in support of any effort to control nutrient inputs into
lakes and other surface waters which may be endangered by accelerated
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cultural eutrophication. He stated that, where feasible all
wastes should be diverted from lakes and where diversion of
waste water is not possible improved waste technology should be
applied.
Mr. Brenner reported that the detergent industry has
accelerated its research efforts in the search for a phosphate
replacement. The program has first priority in several company
laboratories. He further stated that the most widely discussed
phosphate replacement material, NTA (nitrilotriacetate), has a
primary value in combination with phosphate in detergents. There
are other problems with NTA at the present time. NTA has not been
thoroughly tested as to its ultimate environmental safety and there
are indications that widespread use of NTA may have a more adverse
effect on our environment then use of phosphates.(R. 406).
Polycarboxylates were noted as another class of materials attracting
attention for detergent use although these materials may not have
the proper performance characteristics and they may not meet the
necessary biodegradability standards (R. 407) . Still other materials
which are talked about as a replacement for phosphates in detergents
are various forms of silicates. Sodium carbonates are also being
considered (R. 416).
Why not a return to soap? It was stated that this appears
to be impractical because (l)the supply of fats and oils is inade-
quate to furnish the needed raw materials, and (2)the performance
of soap in modern automatic washing machines is not on the same
level as detergents. The first synthetic detergent was marketed
in 1934, it contained no phosphate and was a failure.. Following
World War II phosphates and detergents were combined and from that
point they enjoyed a dramatic growth to the point that by the
early '50's, soap was virtually off the market place (R. 412).
Phosphates are unique in that they perform several functions in
detergent products and there is no single replacement material.
They soften water, they are anti-redeposition agents, they emulsify
oils, and they adjust alkalinity. The phosphate portion of the
detergent is an extremely important part of the product (R. 431).
Although in considering the phosphate problem, the Board
initially proposed only a water quality and effluent standard, the
Board made clear during the hearing that matters such as a ban on
phosphate containing detergents was another avenue which could and
should be considered. The fact that the State of Illinois has a
very limited number of phosphate dischargers into Lake Michigan was
an important consideration in considering a phosphate detergent
ban. The phosphate discharges to Lake Michigan from Illinois are
limited, being confined almost exclusively to the discharges from
the North Shore Sanitary District. The Sanitary District is
presently experimenting with the use of waste pickle liquor from
a steel company for phosphate removal in its waste water (R. 122).
Results of full plant scale application indicates phosphate reduc-
tions on the order of 80% to be readily attainable. It appears
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that the use of pickle liquor may be the answer to the North
Shore Sanitary District meeting the phosphate removal requirements.
Further, the North Shore Sanitary District has plans to divert
away from Lake Michigan by early 1973. At that time most of the
phosphate into Lake Michigan will be coming from Indiana, Wisconsin
and Michigan (R. 360).
Dr. Bartsch stated that consideration should be given to
banning phosphates in detergents. Curtailing the input from all
sources and not only of all of the sources of waste which are
treated should be the rationale. Inputs of phosphorus are additive
in terms of the various sources that are involved. As regards
qualifications to the banning of phosphates from detergents,
Dr. Bartsch said that we would not want to replace it with an
element or a compound or a substance which has a substantial
deleterious effect on the environment like phosphates.
There is no question that the Board has the power to
outlaw the sale or use of phosphate detergents under Section 13
of the Environmental Protection Act. Because the Board has decided
not to impose a ban on phosphate detergents with this regulation
does not mean that it will not do so at another time. The Board
presently has before it a citizen's petition pursuant to section 28
of the Environmental Protection Act which seeks to ban the sale
of all detergents or other cleaning products containing phosphorus
throughout the entire state after June 1, 1972.
4. Summary and Conclusion
Perhaps the most succinct and cogent statement of the
rationale underlying the adoption of the water quality and effluent
standard for phosphate is the explanatory statement which accompanied
the original proposal:
Phosphorus is an element which has been implicated
in the excessive growth of algae in fresh water lakes.
The algae grows, dies and in decomposing robs the
water of necessary dissolved oxygen. In addition,
algae is a nuisance on beaches to swimmers and to
water treatment plants.
The proposed water quality standard for phosphorus is
2/3 of the present standard and is at the same level
as the bulk waters of Lake Michigan. Since the existing
phosphorus water quality standard is not at the danger
level for algae blooms, it is prudent to tighten this
standard.
The consideration of a phosphorus limitation of input
into Lake Michigan was one of the first matters considered by this
new governmental agency, the Illinois Pollution Control Board. The
urgency attached to this matter was not misplaced. To prevent
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Lake Michigan from becoming another Lake Erie, to preserve our
beautiful Lake, we must take this action now bv restoring the
inshore areas of Lake Michigan to an acceptable state and
preserving the offshore waters in their present state of purity.
We must keep all nutrient input from all sources at the lowest
possible level consistent with feasibility and reasonableness.
The offshore waters of Lake Michigan are now of high
quality. They are just beginning to show slight, subtle changes in
the direction of eutrophication. Localized inshore waters are now
eutrophic and have lost their usefulness for many desirable purposes.
If forecast of future chemical input materializes, eutrophication
processes will be accelerated. Problems in inshore areas will
then become even more distaste.ful and costly and they will gradually
involve the offshore waters. Accelerated eutrophication can be
prevented if actions to slow down nutrients input are taken
soon enough. The Lake Michigan campaign can be largely a preven-
tive one. Therefore, more effective and economical than a totally
restorative program. All controllable nutrient input should be
stopped (R. 91).
To save our lake, to preserve its present quality from
further deterioration we -must rein-in the present galloping eutrophic-
ation in the near-shore areas. Ample testimony has been presented
before the Board which emphasized that the most feasible way of
doing this at this time is to limit the input to the Lake of the
essential nutrient, phosphorus.
Dr. Bartsch in stressing the importance of keeping
nutrients out of the lake put it this way:
If you like this Lake the way it is, then you ought
to quit insulting it with all this junk you are putting
in; and if you keep the level down to the lowest you
can, maybe you can even turn it back in time (R. 305).
I dissent:
y
I, Regina E. Ryan, Clerk of the Illinois Pollution Control Board, certif
that the Board adopted the above opinion this 28 day of April, 1971.
" 1 / 7
Jfi. Ryan,
Illinois Pollution Control Board
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ILLINOIS POLLUTION CONTROL BOARD
April 14, 1971
PHOSPHATE WATER STANDARDS
Supplemental opinion (Samuel R. Aldrich, Board Member)
There are a few sections of the opinion with which I do not concur.
Page 1. Rate of phosphorus inputs
The opinion states that man's activities including agriculture
have greatly increased nutrient additions to the lake. This is not
supported by studies by the Illinois State Geological Survey of
bottom sediments in southern Lake Michigan. The top 1 inch or
less of bottom deposits averages no higher in phosphorus than the
layer immediately below or of several other more deeply buried
layers representing deposits many thousandsoof years old. If
the sewage from Chicago were being discharged into Lake Michigan,
which it is not, the phosphorus input would be very large indeed.
It is my opinion that, with the possible exception of increased
animal wastes, the introduction of agriculture has h,ad little
effect on the phosphorus available for accelerated eutrophication.
When grass, leaves, and weeds are left entirely on the surface as
in the virgin condition, soluble organic phosphorus compounds
resulting from decay are more likely to be carried off into surface
waters than when crop residues are incorporated into the soil
through farming practices. I feel that this explains the unex-
pected concentrations of phosphorus in bottom sediments previously
described.
Page 9. The proper method for determining phosphorus in water.
The opinion states that total rather than filterable phosphorus
is the proper method to assess potential for eutrophication. I
agree that this is the correct method for Lake Michigan. Filterable
phosphorus by itself fails to measure the phosphorus that is tempo-
rarily bound within the tissues of living and dead organisms in-
cluding higher plants that are in suspension and thus included in
the water sample. There is, of course, an additional reserve in
the form of dead plant residues and phosphorus loosely held in
bottom deposits.
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Total phosphorus is not a suitable measurement on the streams of
Illinois in which there is an appreciable amount of suspended soil
particles. Much of the phosphorus that is associated with soil
particles is unavailable or only very slowly released into water.
Although this subject urgently needs additional research, it
appears likely that a given amount of phosphorus attached to soil
particles will support only 1/4 to 1/7 as much algal biomass growth
as the same amount of phosphorus in soluble phosphorus compounds
(R. M. Gerhold and J. E. Thompson, 1969).
Several soil scientists who are authorities on phosphate chemistry
suggest that soil sediment-associated phosphorus is 10 to 30 percent
as available for supporting eutrophication as phosphorus in solution.
Samuel R. Aldrich
Member, Illinois Pollution Control Board
1, Regina E. Ryan, Clerk of the Illinois Pollution Control Board
certify that Dr. Samuel R. AldricJi submitted the /ibove^opinion on
14 of Aoril 1971.
___,
Rediria E. Ryan
Clerk, Illinois P
171
oll
ution Control Board
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380
Discussion - Phosphorus
and we do have, as I said, the written opinion of the Board
and the supportive testimony.
4 MR. MILLER: Mr. Chairman.
5 MR. MAYO: Mr. Miller.
6 MR. MILLER: I think that Mr. Purdy raises some
pretty good questions and questions that mayors of the cities
have raised with us when we have required them to go to 80
percent phosphorus removal, and it is sometimes difficult,
10 when you have just gone around and are now completing the
11 80 percent, to come back and say you have to go to 90 or
12 l mg/1.
13 Mr. Hert and I had some discussion of this this
14 morning. He raised this question, and my concern is: What
15 is necessary for the protection of Lake Michigan? And if
16 it is the maximum feasibility as far as removal of phosphorus
17 is concerned, then I think this is what we have to go to.
I am sure, as Mr. Schraufnagel and also Dr. Earth
last night point out, that there are things that affect the
20 removal process, and we may not at all plants be able to achiajve
21 1 mg/1. And I can come back to Mr. McDonald and agree with
22 him that we make a determination but sometimes it makes a.
23 difference who determines what is technically feasible and
what is not technically feasible.
25 But I think the crux is: Is it necessary to
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Discussion - Phosphorus
maximize? And, on the basis of what I have heard, I believe
that it is, and as much as I would like to have the support
of all of the citizens in rising up and asking for this, I
little think that they will, and that we, in Indiana at
least, would, even though we are in the first round and not
completed on this, be going back to the citizens and the
cities to maximize phosphorus removal and hopefully, as a
goal, the 1 mg/1.
Now, I think we do need more study in this area to
11 come up with the different types of plants and the effects of
various industrial wastes that it may have, and that would
apply as to whether we can achieve this in all of the plants
or not.
MR. PURDY: Mr. Chairman.
I think we in Michigan have recognized that an
SO percent removal, as a criterion, would be an interim
step, and that at some point in time an effluent requirement
would be established. We are discussing that sort of
effluent requirement today.
I am certain it is going to be difficult to go
back before we have even accomplished the SO percent.
But as to our yardstick of measuring have
we maximized the operational facilities to accomplish the
best in phosphorus removal? I, too, have concern about
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1 Discussion - Phosphorus
2 reaching the 1 mg/1 on an average 24-hour basis or maybe even
3 on an average month. And in some instances we may be able
4 to do even better with the same chemical cost.
5 I am not sure how we should measure if we maximize
6 our ability to do this. But one thought would be to determine
7 that those facilities were, in fact, feeding the proper
8 chemical dosage, such as recommended by Dr. Earth, at 1.5
9 to 1.7 mole ratio of metal ion to phosphorus, and then, in
10 addition to that, he gave what he considered to be key design
11 parameters for the sediment facilities.
12 Rather than using that, I think we ought to have
13 some advice from Dr. Barth as to what he considers a proper
14 effluent concentration of suspended solids now, if this is
15 10 or 15 or whatever it might be. Then if we have that as
16 proper chemical dosage and have reduced the suspended solids
17 level down to this recommended level, could this, then, be
13 considered a yardstick of maximizing the phosphorus removal
19 with the objective of reaching the 1 mg/1 level? I think
20 that, in many instances, we are going to have to go beyond
21 central settling, and we are going to end up with consider-
22 able capital costs in the way of filtering equipment.
23 MRe FETTEROLF: Mr. Chairman.
24 There is an old economic statement that there is
25 no such thing as a free lunch, and Barry Commoner applied
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1 Discussion - Phosphorus
2 this to ecology. And in line with what Mr, Purdy was saying,
3 if we have 10 mg/1 of phosphorus in treated sewage effluents,
4 and we come to an #0 percent removal, essentially that leaves
5 us with 2 mg/1 of phosphorus,
6 In order to get down to 1 mg/1, which would be the
7 accomplishment of the 90 percent removal, it is going to
8 require probably an additional 3 mg/1 of ferric chloride
9 applied, which results upon an added 1.5 mg/1 of chloride
10 to the discharge.
11 Now, yesterday you heard Michigan talk on the
12 Status of Compliance report relative to chloride removal
13 in control of discharges to the lake.
14 In 1972, it had a total of 2,400,000 pounds per
15 day discharged at the six identified point sources who were
16 working very hard on this to get this down. It is now
17 down by the end of 1973, it will be down to 305,000
18 pounds per day.
!9 Just from some quick figuring, to go from #0 to
20 90 percent, we are going to be adding some 2 million pounds
21 per year of chlorides to achieve the reduction of the
22 additional mg/1 of phosphorus. So it isn't all clear sail-
23 ing on the additional 10 percent removal,
2Z»- MR. McDONALD: You say 2 million a year will be
25 added? What are Michigan sources putting in per year now?
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1 Discussion - Phosphorus
2 MR, FETTEROLF: Much more than that,
3 MR. McDONALD: How much roughly?
4 MR0 PURDT: In my report yesterday I think I men-
5 tioned that the 1963 figure was something like 4 million
6 pounds a day, and we are down to 2 million pounds a day now,
7 and when the control program has been completed, we will be
g in the neighborhood of 800,000 pounds per day.
9 MR. McDONALD: Per day. And Mr. Fetterolf is
10 talking 2 million pounds per year?
11 MR, FETTEROLF: Which is not in the same ballpark,
12 but it is something to consider.
13 MR. McDONALD: Well, it is not anywhere near the
14 same ballpark.
15 MR. MAIO: Gentlemen, in the normal procedure of
16 the conference activities, with a recommendation of this kind,
17 the conferees, at their discretion, might incorporate that
IS kind of a recommendation as part of the conclusions of the
19 conference. The recommendations, then, would be contained
20 in the summary and conclusions that would be issued by the
21 Administrator.
22 The fact that the recommendation is in that summary
23 and conclusions doesnft eliminate the need for the States
24 individually, then to the extent that they don't already
25 have comparable requirements to return to their respective
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1 Discussion - Phosphorus
2 pollution control agencies and to put this issue before the
3 agency, with whatever public review and debate would be
4 appropriate. So that the conference recommendation doesn't
5 exclude the opportunity for local people whether they be
6 municipal interests, industrial interests, or conservationist
7 groups to have an adequate dialogue on the reasonableness
8 of that kind of a requirement in the State water quality
9 standards.
10 So I think the conferees can indeed be on reason-
11 ably firm ground that a recommendation of that kind in the
12 conference certainly does not deny the opportunity for
13 additional and perhaps very substantive dialogue on those
14 issues when they come before the State water pollution
15 control agencies. And certainly there ought to be available
i
16 at that occasion whatever technical support EPA can provide,
17 and whatever support can be reasonably generated from those
IS interests who are willing to speak to the water quality
19 issues in Lake Michigan versus the aspect of associated
20 costs,
21 MR. PURDY: Mr. Chairman, I am inclined to feel
22 nke Mr. Miller tha£ it is time for an effluent requirement
23 on phosphorus removal. Following some of the testimony
24 yesterday, we should apply the best control possible on
25 phosphorus removal.
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1 Discussion - Phosphorus
2 I am concerned as to how we measure that we have
3 applied the best control possible.
4 I am concerned about at this point in time
5 saying that it will be accomplished by a certain date,
6 1, I would like an opportunity to review in
7 detail, on specific installations, what this might be in the
way of additional capital expenditures for those plants, if
9 any.
10 2. I would like to be able to relate this to a
11 construction grant program and the amount of funds that are
12 available for the State of Michigan, if there is a con-
13 struction grant program.
14 3. I would like to be able to relate this to the
15 requirements that there might be in a new Federal bill for
16 certain minimum levels of treatment throughout the State,
17 4. I would like to be able to relate this to the
other enforcement requirements that we have in the State
for example, the Lake Erie Enforcement Conference.
20 So that, with those uncertainties, I am reluctant
21 to, at this point, say that I am ready to set 1973, 1974,
22 or 1975, as a date to accomplish this. I think we need to
assess this, and do it as rapidly as possible. But I don't
think that we can divorce a construction grant program from
our enforcement activities anymore.
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Discussion - Phosphorus
MR. BLASER: Question on the International Joint
Commission agreement coming ultimately from Canada as well
as the United States. Was there not provision for 1 mg/1
in that? As I understand that, did not the States concur
on that, or to what extent is the position different here
than in the IJC situation International Joint Commission
proposal?
MR. MAYO: Well, by way of comment, Mr. Blaser,
the U.S. -Canadian agreement established as an objective
1 mg/1 in sewage treatment plant effluents for plants, as
I recall, larger than 1 million gallons per day. The
agreement was signed by the two governments with the States
being very intimately involved in the whole discussion and
a good deal of the negotiation process.
The agreement isn't binding on the States as
signators, since they were not signators. But the agreement
does reflect the positions of the two Federal Governments
in setting those objectives. Each government, then, in
turn, assumes the responsibility of going back to the States
on the U.S. side, the Province of Ontario on the Canadian
side, and seeking to get incorporated into the day-to-day
water pollution control practices of the individual States
comparable requirements, or requirements that are compatible
with the objectives identified in the agreement.
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Discussion - Phosphorus
One of the responsibilities that EPA then assumed,
as the consequence of the agreement, was to establish the
4 dialogue with the States that would seek to bring into the
5 State water quality standards those changes that might be
6 necessary in order to make these State water quality stan-
7 dards compatible with the objectives of the U.S,-Canadian
agreement, and that dialogue has been initiated,
9 What we are talking about today is quite directly
10 related to the objectives that were established by the two
11 governments in the agreement. And I think that the commen-
12 tary here is quite significant in terms of our efforts to
13 move ahead collectively with the States and get that
14 objective in this case, the phosphorus objective in
15 the agreement translated into the water quality standards of
16 the individual States.
17 MR. PURDYs Mr. Mayo, is not the agreement
objective just covering the Lake Ontario and Lake Erie
19 waters at the present time, and is not the agreement on
20 the remaining international waters to be determined at a
21 later point in time by joint agreement between the U.S.
22 and Canada?
23 MR. MAYO: Yes, the agreement sets up provisions
24 for study of the upper lakes and the establishment of
25 objectives for the upper lakes. Yes, that is correct.
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389
Discussion - Phosphorus
MR. PURDY: But the agreement, at the present
time, of 1 mg/1 of sewage treatment plants of over 1 million
gallons per day, covers Lake Erie and Lake Ontario?
MR. MAYO: And the associated boundary waters.
MR. PURDY: But not Lake Huron and Lake Superior.
MR. MAYO: Well, it doesn't, because the studies
that led up to the agreement, the lower lakes studies and the
report associated with the developed recommendations were
specific for those waters.
MR. PURDY: If we should come up with something
different than that today for Lake Michigan, it would not be,
at this point in time, a violation of the agreement.
MR. MAYO: I don't think it would.
MR. BRYSON: I think there is a comment that needs
to be made at this point: that we appear to be settling in
on a difference between 80 percent removal and 90 percent
removal.
If I recollect a couple of the sessions of the
committee meetings that I sat in on, we are not talking
that kind of a difference.
Let me get Howard Zar back up here to explain the
committee's reasoning on the difference between 1 mg/1 and
the 80 percent removal that is currently in effect.
MR. ZAR: Correct. The 80 percent removal
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1 Discussion - Phosphorus
2 requirement, which is presently in force, is a basinwide
3 requirement, and the smaller sewage treatment plants are
4 excluded generally in the application of this regulation
5 by the States. So that when you apply the regulation to
6 the plants that need to accomplish this treatment, you are
7 talking about something like #3» #4 percent treatment, or
8 perhaps more, that these plants have to do.
9 In the application of the 1 mg/1 requirement,
10 smaller plants would also be excluded, and if you take and
11 apply this 1 mg/1 restriction to these remaining plants
12 on a basinwide basis, you would be getting #7 percent.
13 So you are talking about the difference between #0 and #7
14 percent, perhaps, basinwide, or $3 and 90 percent at the
15 sewage treatment plants that have to do this treatment.
16 So there is perhaps a 7 percent difference instead of a 10
17 percent difference, and perhaps that explains the slightly
1& lower cost that the committee uses compared with those that
19 Mr. Purdy mentioned earlier.
20 MR0 BRYSON: Seven percent on the outside. It
21 could be as low as 3 to 4 percent.
22 MR. ZAR: Presumably.
23 There is another perhaps misimpression. Mr.
2/*- McDonald used the figure of 1 cent per capita per day. I
25 think that we talked about that back there, and that
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1 Discussion - Phosphorus
2 referred to the total treatment cost for phosphorus and
3 everything; whereas, if you take a cent per thousand
4 gallons
5 MR. McDONALD: I think that is what I said, Mr.
6 Zar, that that was the total cost: $75 per million gallons.
7 MR. ZAR: Okay. I'm sorry. It wasn't clear back
8 there.
9 Perhaps I should make it clear that the cent per
10 thousand gallons works out to about a tenth of a cent per
11 capita per day for this additional phosphorus treatment
12 we are talking about.
13 MR. McDONALD: That is a good point. Now we are
14 down to a tenth of a cent.
1$ MR. MAYO: Do you want to continue this dialogue,
16 gentlemen, or do you want to get back at it when we get into
17 Executive Session and begin to look at specific recommenda-
18 tions?
19 MR. FRANCOS: Well, I would like to continue for
20 a few moments. And one of the things that troubles me
21 about setting the suggested limitation of doing this by
22 December of 1972 is that correct? Is that the interpre-
23 tation?
24 Well, that first sentence on page 12 is a little
25 ambiguous. Is there a time statement indirectly made?
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1 Discussion - Phosphorus
2 MR. ZAR: There is not.
3 MR. FRANGOS: There is not.
4 Does the fact of setting this kind of effluent
*> limitation cut down on the flexibility of operating a
6 program? And it seems to me that 90 percent or 88
7 percent is not a magic figure, and I think my position at
8 this time is that we don't use BO percent as being the
9 maximum that we would require of our communities, but rather
10 would ask that they maximize efficiencies with the facilities
11 that they are now going to install or have installed.
12 Quite frankly, I don't know the detailed effect
13 of setting this kind of a limitation as stated in the report
14 on a number of our communities in Wisconsin. And until I
15 do, then I don't see how we could go along with the kind
16 of a recommendation that is stated on page 12. And, further,
17 I really don't think that we want to sign off on a recommends
13 tion, take it back, and then back off.
19 MR. MAYO: Well, as has been the custom at the
20 conferences, Mr. Frangos, when we get into Executive
21 Session, the conferees will generally have a set of recom-
22 mendations before them to speak to. I think it might be
23 appropriate at that time to get into the discussion of what
24 might be a reasonable implementation date that would be
25 related to a recommendation dealing with the 1 mg/1
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1 Discussion - Phosphorus
2 maximum concentration of total phosphorus in the sewage
3 treatment plant effluent and get at the issue at that time
4 in terms of a specific recommendation,
5 MR, FRANCOS: It sounds good to me. It is getting
6 to be lunch time,
7 MR, MAYO: As far as the conferees are concerned,
B if you feel you have had sufficient commentary and dialogue
9 on the phosphorus issue that we can --
10 DR. KITCHEL: Mr, Chairman, I think we are all in
11 agreement that to eliminate phosphorus or limit it to the
12 lowest reasonable level is the desirable goal.
13 Our troubles in Michigan do not stem from agency
14 activities or problems; I think all our confusion comes
15 from Congress.
16 MR. MAYO: Do you feel that that confusion is
17 confined to Michigan? (Laughter)
IB DR. KITCHEL: It was remarked here a little bit
19 earlier that there is no such thing as a free lunch and yet
20 Congress insists on describing that terrific free lunch
21 they are going to set out and now they are proposing to
22 increase it.
23 I think the judicious application of "the carrot anjd
i
24 the stick" is the way we will achieve these things. And
25 right now,when we don't know what this carrot is going to
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1 Discussion - Phosphorus
2 look like the rest of this year or next year, we are in a
3 position where it is difficult to fix on goals, particularly
4 on a time schedule.
5 So while I would agree that the 1 mg total
6 perhaps stated a little differently than it is here is
7 reasonable; it is feasible; to put a time sequence on it
B right now is practically impossible.
9 MR. McDONALD: I would say to that, before we
10 get into the Executive Session discussion, if we don't have
11 a deadline date by which to do it, that the recommendation
12 is going to be strictly advisory, recognizing exactly what
13 you say, Dr. Kitchel, that it is difficult not knowing what
14 new legislation may offer.
15 Nevertheless, in the context of where we are
16 today, where we are meeting today, the recommendations we
17 have to come up with, it seems to me we have to talk in
IB terms of a deadline an agreed-upon deadline to do what
19 has to be done.
20 MR. PURDY: I can't let it drop.
21 I have felt for the last year and a half that
22 Congress must .act on the construction grant program and
23 put some sense in where we are going. They have failed
24 to do that.
25 I can't see why we are under any greater
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1 Discussion - Phosphorus
2 compulsion to act and set a deadline certain, at this point
3 in time, in the absence of some definition from Congress.
4 I have felt that it was just impossible that Congress could
5 hold back $350 million of last year's appropriation. It
6 could be building $700 million worth of sewage treatment con-
7 struction in this country today. But yet it has been held
8 back as a carrot to pass new legislation, and I don't see
9 where we should be compelled to act on a date certain any
10 more than Congress is compelled to act on a definition of
11 the construction grant program.
12 I do feel that we have to set a time. I don't
13 think that we can set the time until we have had an oppor-
14 tunity to see where we are going in the construction grant
15 program, and that we must tie our enforcement efforts to
16 the future construction grant program.
17 MR. MAYO: With that commentary on the part of
Mr. Purdy, I think it would be appropriate for us to leave the
19 phosphorus item on the agenda, at this point, and return to
20 it in the format of the Executive Session and the consider-
21 ation of specific recommendations. If that is agreeable
22 with the conferees, we can recess for lunch at this time
23 and return at 1:45 and proceed with the portion of the
agenda that deals with the pesticides issue.
25 (Noon recess.)
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1 L. Lueschow
2 WEDNESDAY AFTERNOON SESSION
3
4 MR. MAYO: Gentlemen, I think it is important that
5 we get started. Mr. Blaser may not be here for another few
6 minutes.
7 The next item on the agenda, Item 4, deals with
the reports of the Pesticide Committee and subject matter
9 | of pesticides, PCB's, phthalates, and heavy metals.
10 I will turn this over to Mr. Bryson to proceed
11 with the identification of those who will be making the
12 individual reports for the Pesticides Committee.
13 MR. BRYSON: The Pesticides Committee will consist
14 of three parts: 1) the report on pesticides, 2) the report
15 on PCB-phthalates, and 3) the report on heavy metals.
16 The first portion, the pesticide report,will be
17 given by Mr. Lloyd Lueschow from the State of Wisconsin.
19 STATEMENT OF LLOYD LUESCHOW,
20 CHIEF, LABORATORY SERVICES,
21 WISCONSIN DEPARTMENT OF NATURAL RESOURCES,
22 MADISON, WISCONSIN
23
24 MRo LUESCHOW: The Lake Michigan Enforcement
25 ; Conference Pesticide Committee was created in 1963 to
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1 L. Lueschow
2 function as a technical advisory unit to the conference.
3 The committee issued a summary review report and a series
4 of recommendations in November 196#.
5 The participating States, the Environmental Pro-
6 tection Agency, the Bureau of Sport Fisheries and Wildlife,
7 and the Wisconsin Alumni Research Foundation all collaborated
g in meeting the basic outline accepted by the conferees in
9 February 1969. The committee hereby offers conclusions and
10 recommendations for the consideration of the conferees*
11 1, The analysis of water samples from the open
12 waters of Lake Michigan strongly suggests a real and inherent
13 variability that makes water sampling for the purpose of
14 developing general residue levels impractical. The concen-
15 trations present challenge the limit of detectability of
16 the analytical methods employed. Several laboratories
17 recorded substantial analytical discrepancy when analyzing
18 split samples, thereby further complicating interpretation
19 of results.
20 2. After cautious interpretation of the data,
21 the committee generally agreed that the most likely con-
22 cent rations of DDT in open lake waters were between 1 and 10
23 parts per trillion. Those analyses that revealed unusually
24 high levels of pesticide were probably the result of arti-
25 facts such as surface scums of floating oils, suspended
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1 L. Ltieschow
2 debris or in-laboratory contamination.
3 3. The data accumulated by municipal water intake
4 sampling strongly suggest concentrations of chlorinated
5 hydrocarbon pesticides in the inshore waters were higher
6 than in open lake waters and much more variable. The biologi-
7 cal accumulation potential is, therefore, greater in inshore
g waters since most of the important biological representatives
9 spend an extended period of time within these inshore water
10 areas.
11 4. Tributary streams to Lake Michigan discharge
12 chlorinated hydrocarbon pesticides into the lake. Urban and
13 fruit-growing areas are the more significant contributors of
14 pesticides to the lake than are diversified agricultural
i
15 areas.
16 5« Dieldrin levels in tributary streams and lake
17 waters were generally at the limit of detectability, 1 part
18 per trillion or less.
19 6. Most sewage treatment plant discharges con-
20 tained less than 10 parts per trillion DDT. For those plants
21 with more than 10 parts per trillion total DDT, there were
22 likely point sources. However, in the city of Milwaukee, no
23 point source was found. The Milwaukee system is so complex
24 that it is virtually impossible to eliminate all potential
25 } sources by field investigation. Sewage treatment plants
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1 L. Lueschow
2 with dieldrin concentrations above the detectable levels also
3 had identifiable point sources.
4 7, Lake Michigan waters contain many substances
5 that are extractable and measurable by commonly used methods
6 for pesticide analyses and are, therefore, potential inter-
7 ferences in typical pesticide analytical procedures. The
8 polychlorinated biphenyls constitute a complex of such sub-
9 stances that are present in Lake Michigan. Phthalate esters
10 more recently have been identified at detectable levels,
11 These chemicals are present in greater concentrations in
12 biological and wastewater samples than in open lake waters,
13 The polychlorinated biphenyls are present in sufficient
14 quantity, with sufficient evidence of biological impact, to
15 warrant an independent evaluation,
16 S. Biological sampling with sentinel organisms
17 (clams) reflected unusually high pesticide concentrations
IS and sources. Subtle concentration differences that might be
19 brought about by a relatively small discharge relative to
20 the stream could not be detected by clam analyses. Resident
21 arthropods generally contained higher levels of DDT and its
22 analogs than sentinel clams. Resident fish appeared to be
23 the most reliable biological monitor.
24 9. The biological magnification of chlorinated
25 hydrocarbon insecticides in sport and commercially valuable
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1 L. Lueschow
2 species of fish suggests that fish should be used to reflect
3 concentration trends in the lake water. It is believed that
4 the residue levels established during the last 2 years will
5 be adequate to serve as a base line to establish the trend
6 in future years. It seems unlikely these trends can be con-
7 veniently established by water sampling because of analytical
8 and sampling complications.
9 10. The levels of DDT in sport and commercially
10 valuable species of fish exceed the 5 parts per million action
11 level established by the Food and Drug Administration, essen-
12 tially preventing sale of Lake Michigan fish. Other chlor-
13 inated hydrocarbon pesticides do not exceed the established
14 residue tolerances, although dieldrin levels approach the
15 action limit. Exotic chemicals other than chlorinated hydro-
16 carbons were not measured in this study.
17 I should elaborate on that just slightly in that
IS they were looked at in the original evaluations and residues
19 in the lake water were not observed. It was reported in the
20 November 196S report that that did not imply that they should
21 never be looked at; it only meant that we had other problems,
22 more pressing at the moment, than those problems with DDT
23 and dieldrin,
24 11, The four States in the Lake Michigan Drainage
25 Basin have adopted legislation authorizing various pesticide
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1 L. Lueschow
2 use control programs. Wisconsin, through basic legislation
3 and subsequent rules, has essentially prohibited the use of
^ chlorinated hydrocarbons that have been found in Lake Michi-
5 gan. Michigan and Indiana have adopted adequate use control
6 legislation but the rules have not yet been promulgated,
7 Illinois has a legislative restriction on DDT but not on
g other chlorinated hydrocarbons, Michigan, Illinois, and
9 Indiana have adopted legislation regulating commercial
10 pesticide applicators, Wisconsin legislation regulating
11 commercial applicators is still pending,
12 12. The effect of the pesticides in Lake Michigan
13 on fish reproduction potential is not resolved as yet. This
14 concern in part generated the establishment of a technical
15 committee to review pesticide pollution in the lake. Both
16 Wisconsin and Michigan are able to hatch and rear coho fry
17 in adequate numbers to sustain the anadromous fish stocking
18 program using Lake Michigan brood fish. The effect on
19 natural reproduction in lake trout is not known.
20 13. The pesticides in Lake Michigan through
21 biological magnification may have a potential effect on both
22 domestic and wild animals that eat fish or other organisms
23 from the lake, Hazards to wild bird populations and mink-
24 ranching operations are being investigated. Preliminary data
25 suggest that exotic chemicals including chlorinated hydrocarbob
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2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
IB
19
20
21
22
23
24
402
L. Lueschow
insecticides produce measurable changes on reproductive
potentials«
Recommendations
1. Fish sampling for pesticide residues should be
established in accordance with the Bureau of Sport Fisheries
and Wildlife and commercial fisheries' recommendations.
This monitoring should be conducted within the Federal
structure or should be contracted to an agency with the
ability both to collect and process the collections from the
entire lake. Analyses and sampling must be performed in the
same way in order to compare data or correlation data must
be established if new collection or analytical techniques
are used
o
20 A water quality monitoring program should be
initiated for inshore waters in order to determine whether
the pesticide burden of fish is related to the pesticide
concentration of inshore waters,
3. The conferees should insist on adequate legis-
lation to record pesticide usage of other than the chlorin-
ated hydrocarbons*
4, As with pesticides, the discharge of polychlor-
inated biphenyls, phthalates and other persistent chemicals
should be abated to prevent accumulations of these persistent
compounds in Lake Michigan* Particular attention should be
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403
L. Lueschow
devoted to possible replacements for chlorinated hydrocarbons
such as toxaphene, methoxychlor, chlordane and benzene hexa-
chloride,
5 5, The levels of metal contamination of Lake Mich-
6 igan water and/or fish should be clearly established at this
7 time so that residue trends can be assessed in the future*
6. Polychlorinated biphenyl concentrations should
9 be ascertained for water and fish. Control programs for polyj-
10 chlorinated biphenyls and other exotic chemicals should be
11 initiated. That is the end of the statement,
12 MR. MAIO: Gentlemen, you have before you the
13 statement that was just presented as well as the published
14 materials that were contained in the distributions made to
15 the conferees prior to the conference,
16 (The document entitled "An Evaluation of DDT and
17 Dieldrin in Lake Michigan" is on file at U.S. EPA Headquarter|s,
Washington, D.C., and Region V Office, Chicago, Illinois.)
19 MR. MAYO: The Technical Committee representatives
20 Who are here are available for discussion of any questions or
21 comments or concerns that you may have.
22 MR. PURDY: Mr. Lueschow mentioned that Conclusion
No. 11 might need updating. The Department of Agriculture has
2/»- adopted Rule 632 to implement Public Act 233 of 1959, as
^ amended, which relates to the regulation of commercial
L
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2_ L. Lueschow
2 applicators; and Regulation 633 to implement the Public Act
3 297 of 1949, as amended, the Economic Poison Control Act, so
^ that the regulations for both of those pieces of legislation
5 have been adopted and are now in effect.
6 MR. LUESCHOW: The status of legislation is that
7 of a fluid situation since this was written 4 or 5 months
$ ago, and I am sure the legislation can and has proceeded
9 in some cases and will continue to do so.
10 MR. MAYO: Mr. Bryson.
11 MR. BRYSON: Mr, Lueschow.
12 MR. LUESCHOW: Yes.
13 MR. BRYSON: Can you give the conferees some sort
14 of a feel for what reduction in loading into the lake has
15 occurred since the pesticide program started a couple of
16 years ago?
17 MR. LUESCHOW: Not really, in that when we first
13 got the charge of the conferees to abate pesticides or to
19 review the status of pesticide inputs, most point sources
20 had already been under enforcement action* The pesticides
21 that were getting into the lake were essentially of a dif-
22 fuse nature at least the dieldrin and DDT that we were
23 principally concerned with. They were coming from diffuse
24 sources agricultural runoffs, sediment carried rather
2? than a nice precise point discharge.
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1 L. Lueschow
2 Obviously the most difficult item of discharge was
3 to determine the poundage coming in from the diffuse sources
4 to river systems,
5 I think the States instead of waiting for this
6 type of data just said, it is undesirable. And instead
7 they essentially banned the use of the two products that were
8 showing up.
9 So even though it was getting in then and is get-
10 ting in now, to calculate poundage was difficult then; it is
11 as difficult now; but it seems like the best enforcement pro-
12 cedure has taken place. In other words, it is not used.
13 So it must slowly die away from whatever concentration it
14 was.
15 MR. BRISON: That leads to the next question:
16 Does the committee have any feel for how long a period that
17 die-away is going to mean? Are we talking 10 years, a
1# decade, decades?
19 MR. LUESGHOW: Certainly not land-contributed
20 diffuse source contributions. We are talking about an
21 extended period of time. These materials have been incor-
22 porated into the soils over a long period of time and are
23 going to continue to wash away.
24 i do feel that within the first 4 or 5 years a
25 substantial decrease in contribution should take place, and
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406
1 L. Lueschow
2 particularly a substantial decrease in the available in
3 other words, the nonadsorbed type chlorine hydrocarbons
4 should take place; a substantial decrease should take place*
5 I am offering you my feel of that data at this point.
6 MR. MAYO: In the committee's Conclusion Ho. 10,
7 you comment on the fact that M... valuable species of fish
g exceed the 5 parts per million action level established by
9 the Food and Drug Administration ....".
10 Do you see any early opportunity for those levels
11 of DDT in fish to be reduced below the action level if indeed
12 we are faced with a very slow die-off rate?
13 MR. LUESCHOW: It has generally been assumed that
14 the die-off rate of pesticides in the lake is very, very slow.
15 However, Dr. Lee yesterday brought up some interesting con-
16 siderations initially that I am not sure we of the Pesti-
17 cides Committee had fully appreciated in that if the
18 chlorinated hydrocarbons that we are dealing with are
19 markedly insoluble, and they may have several resemblances
20 due to this insolubility with phosphorus if this holds
21 true, then you might expect the same kind of a die-away
22 pattern that Dr. Lee is predicting for phosphorus.
23 Now, we cannot really establish that phosphorus
24 is indeed going to be or excuse me that the pesticides
25 are indeed going to behave exactly like phosphorus, but it
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1 L, Lueschow
2 shouldn't be too far from it, and if that is the case, then
3 we should have a moderately rapid die-away of the currently
4 heavy hydrocarbons currently existing in the lake back to a
5 level that represents the new input consistent with legisla-
6 tion that has essentially banned the use of these products.
7 MR. McDONALD: Mr. Lueschow, what is the general
8 reliability of the analytical techniques for testing for
9 pesticides at low levels on a consistent basis?
10 MR, LUESCHOW: As they exist in the Lake Michigan
11 water?
12 MR. McDONALD: Yes.
13 MR, LUESCHOW: Analytical reliability is terrible,
14 at the 1 part per trillion limit of detectability.
15 MR, McDONALD: Well, your recommendation, or the
16 committee recommendation suggests the program of apparently
17 rather extensive water quality monitoring.
IS MR. LUESCHOW: Not extensive water quality raoni-
19 toring, sir. We do face up to the question of the difference
20 I in concentrations in the inshore waters and open waters.
21 We suggest fish monitoring as a method of evaluating the
22 die-away in the lake, and the fish monitoring, of course,
brings the concentration through a magnification process
into the realm of reasonable analytical reliability. We are
not promoting an extensive program on water monitoring.
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1 L. Lueschow
2 MR. McDONALD: So you are not taking a technique
3 that is so variable that it doesn't mean too much.
4 MR. LUESCHOW: That is right. We have tried to
5 rule this out. In fact, it was our efforts to establish
6 these low levels that led us to this conclusion.
7 MR. MAYO: But you wouldn't be addressing yourself
to monitoring for the presence of these pesticide materials
9 in water in the nearshore area.
10 MR. LUESCHOW: In some nearshore areas, that is
11 correct. I think there can be some selection there, too.
12 MR. MAYO: Selection being related perhaps to the
13 locale of urban development
14 MR. LUESCHOW: That is correct.
15 MR. MAYO: the location of major tributaries
with significant waste loads?
17 MR0 LUESCHOW: That is right. That is exactly
right.
MR. McDONALD: What is taking place, in your
judgment, to improve the analytical techniques? Is there
anything on the horizon to make them more precise, more
22 reliable?
23 MR. LUESCHOW: Well, since this committee began
its deliberations, there has been a tremendous improvement
2 5 in analytical reliability strictly in identification. Our
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409
1 L. Lueschow
2 earliest analyses were subject to considerable identification
3 error. The development of mass spec resolved this to a
4 certain extent. There has been good analytical progress in
5 separating some of the artifacts that we had been observing
6 and sometimes including in the pesticide complex and sometimes
7 not.
g I see nothing in the immediate future that offers
9 any better judgment than the I part per trillion limit of
10 detectability in water.
11 MR. McDONALD: Who is doing most of the work on
12 this to improve the techniques? Where is it concentrated?
13 MR. LUESCHOW: Most of that work a good share
14 of it I am not familiar with the people that are doing
15 that type of work.
15 MR. McDONALD: I wonder if anyone on the committee
17 knows that; if anyone is here that could maybe give more
IS information on the analytical techniques that may be on the
19 horizon.
20 If you are going to start an inshore sampling pro-
21 gram, you have inherent problems with your techniques,
22 right?
23 MR. LUESCHOW: The inshore sampling program is
24 not is recommended not because I don't think there are
25 problems with analytical techniques. There the concentration
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1 L. Lueschow
2 in many cases in most cases went 10 parts per trillion
3 in many cases went 50, This isn't posing us any real ana-
4 lytical problems. The difficulty in inshore sampling is the
5 fact that you don't have a uniform distribution of the
6 product. You have wave action, and so forth. But the con-
7 centrations in inshore waters are high enough so that
B analysis really isn't our problem. It is the number of
9 analyses.
10 MR. MCDONALD: Okay.
11 MR. LUESCHOW: I don't think we really need
12 additional sensitivity in this particular case, which is
13 dawning on me that that is what you have been alluding to
14 here, and I don't think that is really what is necessary.
15 MR. McDONALD: Why do you say that? Why don't
16 you need additional sensitivity?
17 MR. LUESCHOW: Well. Okay. Don't get me wrong.
IB If we had additional sensitivity good realiable
19 analytical techniques for open water we might indeed
20 recommend open water sampling. I think there is an adequate
21 alternative to that which is open water fish sampling.
22 MR. McDONALD: Would you ever need open water
23 sampling if you did open water fish sampling to complement
24 your program?
25 MR0 LUESCHOW: Well, it would certainly be nice,
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1 L« Lueschow
2 but I don't really see it as a necessity at this time, I
3 think there is a way around it.
4 MRa PURDY: Mr. Lueschow, there has been a fish
5 monitoring program for quite sometime; quite a little data
6 has accumulated.
7 Does this data show any indication at all of a
S trend developing from action that has already been taken to
9 limit the usage of DDT and dieldrin within the basin?
10 MR. LUESCHOW: The data that currently exists was
11 presented to the Five-State Interdisciplinary Committee by
12 representatives of the Fish and Wildlife Service a month or
13 so ago and, at that time, the data suggested didn't
14 establish suggested that there has been a reduction in
15 the concentration in fish, further suggesting this would
16 represent bioreduction of the water and reduction in the
17 input. It does not establish it. We haven't gone that
IS | far.
19 MR. MAYO: Any other questions, gentlemen?
20 MR. BRYSON; I have an additional question, Mr.
21 Mayo.
22 Mr« Lueschow, who would you envision undertaking
23 j and implementing some of these recommendations that the
2^ committee has come forward with for example, No. 1.
25 "Fish sampling for pesticide residues should be established
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412
1 L. Lueschow
2 in accordance with ..." etc., etc,
3 MR. LUESCHOW: The committee refused actually to
4 establish who should do it. I think the general consensus
5 or feeling was that it should be the Fish and Wildlife
6 Service, particularly the Ann Arbor laboratory which has
7 the capacity and the facilities to do it and has been doing
8 it in the past.
9 MR. BRYSON: How about No. 2 then, a water quality
10 monitoring program.
11 MR. LUESCHOW: The committee, again, did not take
12 a position on that. In that particular case I can offer
13 only a personal position that it would have to be done by
14 the States and municipalities on selective sites. I say
1$ municipalities because they are the ones that are like
16 Chicago that has a large urban input in a specific area,
17 or something of this nature.
IB MR. BRYSON: Supplemented with the State monitor-
19 ing program?
20 MR. LUESCHOW: Yes.
21 MR. BRYSON: How would you envision No. 5 being
22 implemented?
23 MR. LUESCHOW: I am not in a position to suggest
24 any type of waste treatment. That recommendation was based
25 on the fact that here we have very similar compounds or
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1 L. Lueschow
2 at least one of them was very similar to the pesticide ques-
3 tion and if there are ways of abating it within the realm
4 of economic reason, you should proceed with this type of
5 approach.
6 I do understand that there are techniques available
7 for reducing items like polychlorinated biphenyls, but I
g don't really try to promote any one of them.
9 MR. BRTSON: The reason I asked this is the
10 conferees represent the regulatory agencies around the
11 State -~
12 MR. LUESCHOW: Sure.
13 MR. BRYSON: or around the lake, and they are
14 charged with implementing an abatement program. If the
15 committee develops a series of recommendations, I think
16 there would be great frustration on the part of the con-
17 ferees in not being able to get a handle on how to go for-
l£ ward to do something about the recommendations. That is why
19 I am trying to zero in on the recommendations.
20 MR. LUESCHOW: In this particular report, we
21 recognize the difficulties proposed by the present poly-
22 chlorinated biphenyls. At least it was followed up with
23 additional work by the Pesticide Committee which will be
24 reported on further along in this investigation, and we are
25 still not to the point, I don't think, of being able to
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1 L. Lueschow
2 recommend a technique for abatement on these particular
3 products, if indeed that is desired from the Pesticide
4 Committee,
5 Actually the Pesticide Committee was not consti-
6 tuted in such a way to address itself to that particular
7 aspect of the challenge. They were ecology-oriented, not
waste treatment-oriented.
9 MR. BRYSON: In other words, you determine the
10 problem and hope that somebody will come up with a method.
11 MR. LUESCHOW: We are continuing to face up to
12 this, but we aren't as far along with this particular
13 aspect of the question as we are with the dieldrin aspect
of it. It was a Johnny-come-lately question really.
15 MR. MAYO: In Recommendation No. 4, the committee
16 addressed itself to the need for attention to the possible
17 replacement for chlorinated hydrocarbons, such as toxaphene,
methoxychlor, chlordane, and benzene hexachloride.
19 Did the committee give any consideration to
20 available replacement material?
21 MR. LUESCHOW: No. This aspect of the recommenda-
tion was brought out because at the time that the committee
began its deliberations, early samples were taken to
determine exactly what pesticides we were dealing with as
residues. We determined the ones we were dealing with were
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1 L. Lueschow
2 as residues relating to technical residues were
3 dieldrin and DDT.
4 After we were convinced we could achieve reduction
5 in the lake by abatement procedures, then it became obvious
6 that even though these particular products could not be
7 detected at that time and I don't think at this time
8 since the products we were concerned with were being reduced,
9 the four products listed were potential replacements and
10 they, then, might get such extensive use we could begin
11 detecting them sometime in the future. And we feel that
12 we should watch for these four particular ones at least,
13 which we are continuing to do, by the way.
14 MR, MAYO: At the present time, is there any
15 quantitative evaluation in terms of the amounts of these
16 materials that are being used in the lake?
17 MR. LUESCHOW: I don't think so; no, sir. But
13 that is one of the reasons we put forth another recommenda-
19 tion, No. 3, which said: "The conferees should insist on
20 adequate legislation to record pesticide usage of other
21 than the chlorinated hydrocarbons." And that includes all
22 pesticides, in other words.
23 MR. MAYO: Are there any other questions, gentlemer^?
MR, FETTEROLF: Mr. Chairman.
i would like to know if there is going to be a
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2 report given on phthalates and PCB's.
3 MR. MAYO: Yes.
4 MR. FETTEROLF: All right. Fine.
5 MR. MAYO: Thank you, Mr. Lueschow.
6 MR. BRYSON: The next agenda item will be the
7 report on PCB's and phthalates. I would like to call upon
Dr. Donald Mount, the Director of the National Water Quality
9 Laboratory at Duluth, to present that report.
10
11 STATEMENT OF DR. DONALD MOUNT, DIRECTOR,
12 NATIONAL WATER QUALITY LABORATORY,
13 U.S. ENVIRONMENTAL PROTECTION AGENCY,
14 DULUTH, MINNESOTA
15
16 DR. MOUNT: My name is Donald Mount. I am Director
of the National Water Quality Laboratory, EPA, Duluth,
Minnesota.
19 Mr» Chairman, if it is agreeable with you and the
conferees, I would propose that we submit the PCB and phthalate
report, as you have in your handout, into the record as thoug
22 read, and then I would just make a few comments and highlight
some of the points, if that is all right with you.
MR. MAYO: Any objection, gentlemen?
(The document above referred to follows in its
entirety.)
h
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REPORT OF
THE PESTICIDES TECHNICAL COMMITTEE
TO
THE LAKE MICHIGAN ENFORCEMENT CONFERENCE
ON
PCB AND PHTHALATE
SEPTEMBER 1972
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POLYCHLORINATED BI-PHENYLS (PCB)
PCB residues related to fish species important in Lake Michigan were
measured prior to 1971 by the Wisconsin Department of Natural Resources,
the Michigan Water Resources Commission, and the Great Lakes Fisheries Labora-
tory at Ann Arbor, Michigan. The limited data were confirmed by the F1sh
Pesticide Laboratory at Columbia, Missouri using mass spectrometry.
In the March 23, 1971, progress report of the Lake Michigan Interstate
Pesticide Committee, Dr. Mount mentioned to you that a grant agreement had
been developed with Dr. Gilman Veith at the University of Wisconsin to parti-
cipate in a study designed to further examine the PCB problem in the Lake
Michigan basin. Since that time, the grant was funded by the Federal
Environmental Protection Agency (EPA) and Dr. Veith has completed his portion
of the study including positive identification through perchlorination and
mass spectrometry of the important isomers of Lake Michigan PCB residues.
As a result of Dr. Veith's isomer characterization, hopefully it will now be
possible to identify important Lake Michigan basin PCB sources.
The National Water Quality Laboratory in Duluth and the Bureau of Sports
Fisheries and Wildlife Pesticide Laboratory are also both presently conducting
independent bioassay and related tests to determine the toxicity and metabolic
uptake of PCB in aquatic organisms. Research to date indicates that substitu-
tion on the bi-phenyl nucleus with intermediate numbers of chlorine atoms
produces the more toxic PCB and that the PCB concentration or biological magni-
fication factor from water to tissue is extremely large, as high as 200,000
in fathead minnows chronically exposed to Arochlor 1242 and 1254 for eight
weeks. Theoretically this can be expected since PCB is a non-polar, fat soluble,
aromatic hydrocarbon which is not readily degraded in zoological systems. In
addition the research to date suggests strongly that PCB residues in adult
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Atlantic and Pacific salmon can cause TOO percent mortality in salmon offspring,
and that these residues can be produced by chronic exposure to PCB in water
in the low parts per trillion (pptr) range. This extreme chronic toxicity 1s
not surprising considering the extensive biological magnification of PCB and
its resistance to enzymatic degradation.
The Federal Food and Drug Administration has selected an action level
of 5 ppm PCB for fish flesh. Unfortunately, I must report to you that 1n
certain Lake Michigan species, particularly the coho salmon and lake trout,
this level is presently being exceeded, with residues as high as 20 ppm.
Research by Ringer and Aldrich at Michigan State University indicates poor
reproductive success for mink placed on a diet of 30 percent Lake Michigan
coho. Control tests with ocean fish and the aromatic hydrocarbons dieldrin,
aldrin, and PCB definitely place the poor reproductive success of the mink
upon PCB. Diets spiked with 1 ppm PCB resulted in 33 percent decreases in
mink litter numbers. Diets spiked with 5 ppm PCB resulted in 85 percent
decreases in litter numbers. In diets spiked with 30 ppm PCB all adult mink
died in a period of 2 to 4 months.
Research by Hoopingarner and Samuel, also at Michigan State University,
on Chinese hamster cells showed a 24-hour, 90 percent cell kill at 50 ppm
Aroclor 1016 as compared to the control. At 25 ppm Aroclor 1016 the cell kill
during the same period (24 hours) was 50 percent.
Both the States of Wisconsin and Michigan have conducted cursory sur-
veillance of municipal sewage treatment plant effluents for the purpose of
elucidating background levels of PCB. These surveys have shown that effluents
from large cities - cities with extensive industrial discharge to municipal
sewer systems - average approximately 200 pptr PCB. In smaller cities where
the sewage treated is largely domestic in nature, the effluent PCB level
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averages less than 50 pptr. The State of Michigan has isolated several major
PCB sources in the Bay city, Mt. Clemens, and Detroit areas, and is presently
doing further investigative work elsewhere. The isolated PCB sources include
process consumers of hydraulic and heat transfer fluids including automotive
manufacturing installations, apartment complexes, and certain hospitals.
The committee believes that PCB is a significant pollutant in the Lake
Michigan basin, and that it is imperative that present PCB levels in Lake
Michigan be minimized if not eliminated. Future loss of PCB to the environ-
ment should be drastically reduced as a result of use restrictions presently
in effect at the Monsanto Chemical Company, the only domestic producer of PCB.
Monsanto has curtailed the sale of PCB for uses in which disposal of the end
products could not be controlled, as with plasticizers. Large quantities,
however, are still being synthesized for use as dielectric fluids in electrical
capacitors and transformers. The committee has not presently determined the
import extensiveness of foreign produced PCB. If this source of PCB shows signs
of becoming significant, its import can be regulated under Section 114(c) of
the Toxic Substances Act of 1972 now before Congress.
Presently, no state in the Lake Michigan basin has regulations governing
the discharge of PCB. Michigan and Wisconsin, through respective Departments
of Natural Resources, discourage the industrial use of PCB, however, these
agencies can offer no alternative.
The committee recommends to the Lake Michigan Conferees that comprehensive
surveillance by the States be initiated to determine PCB trends in the aquatic
environment, and to determine whether the present policy of eliminating PCB
discharges to the environment 1s effective. The surveillance program to be
accomplished by the States should include sampling of municipal sewage treat-
ment plants, industries, domestic water intakes, and fish. Furthermore, because
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of the persistence of PCB in the environment, and its extreme toxicity, the
committee recommends that results of the surveillance be presented to the
Conferees by September 1973, along with any measures instituted by the States
to control the problem.
PHTHALATES
Phthlate esters are widely used as plasticizers, particularly in
polyvinyl chloride (PVC) plastics. The most common phthalate ester plasticizer
is di-2-ethylhexyl phthalate. Total phthalate ester production was reported
to be 8.4 X 108 Ibs. in 1968. PVC plastic formulations may contain 30-60 parts
per hundred of phthalate ester plasticizer. Since the plasticizers are not
chemically bound to the plastic resin, they are easily lost to the atmosphere
or to liquids coming into contact with the plastic product. Other phthalate
esters are used as insect repellents and in pesticide formulations to retard
volatilization.
The occurrence of dialkyl phthalate residues has been established in the
aquatic environment, principally in samples of water, sediment, and aquatic
organisms from industrial and heavily populated areas. Based upon State of
Michigan experience the concentrations of phthalates in wastewaters have been
an order of magnitude greater than PCB. The Water Resources Commission estimates
the Michigan phthalate environmental loss to be over 60,000 pounds per year.
Generally, research work on phthalates is proceeding more slowly. Data
to determine status of environmental presence and effect are scarce. Contracts
have been awarded to Union Carbide of Tarrtown, New Jersey. This facility is
extremely competent to perform the full aquatic life cycle bioassay and residue
tests as required by the contract. Data from this study will be available
within a year after initiation of the study. In addition to the contractual
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work, the Bureau of Sports Fisheries and Wildlife Fish Pesticide Research
Laboratory at Columbia is continuing research into chronic effects in fish
and invertebrates, potential toxic phthalate metabolites, and more comprehen-
sive analytical methods for phthalate and phthalate metabolite characterization.
Full life cycle bioassays using fathead minnows as test animals are now 1n
progress and chronic toxic effects will be evaluated by measuring spawning
success, egg hatchability, and survival of young.
The committee's initial concern with phthalates as expressed to the
Conferees earlier was based upon residue tests performed by the Bureau of Sports
Fisheries and Wildlife on fish initially analyzed by the U.S.Department of
Agriculture (USDA). USDA reported that the edible portions of those fish con-
tained 20 to 30 ppm toxaphene. Using more sophisticated and precise analytical
procedures, the Bureau of Sports Fisheries and Wildlife determined that the
USDA "toxaphene residues" were in reality approximately 40 percent toxaphene
20 percent PCB, and 40 percent phthalate.
Research on phthalates to date indicates that residue levels are higher
in cultured fish than fish taken under natural conditions. However, study
fish caught in streams draining highly industrialized areas, such as the
Hudson and Ohio Rivers, are also high in phthalate residues indicating extensive
waste discharges to these streams. This indication is reasonable since
evaluation of the study data leads to the conclusion that while under continuous
exposure phthalate esters are biologically magnified and retained, when water
residues decline, tissue residues expeditiously decline approximately 60 percent
in three days for daphnia. Theoretically this can also be expected since the
phthlates have greater polarity then PCB and are amenable to metabolic-
enzymatic degradation. Finally, the study data indicate that the acute toxicity
of phthlates to aquatic life apparently is relatively low although life cycle
chronicity tests show that as little as 3 ppb phthlate reduces reproduction in
Daphnia by 60 percent.
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In a State of Michigan study, 36 sewage treatment plants were sampled
and it was determined that the average phthlate concentration in the effluent
was 15 ppb with most of it being di-2-ethylhexyl phthalate. Ten plants were
in excess of 10 ppb and 2 plants were as high as 100 ppb.
In a cursory State of Illinois study, limited to the highly residential
areas of the North Chicago suburbs and as far North as Waukegan, 28 water, 17
sediment, and 32 fish samples were analyzed for phthalate. The water samples
contained less than 1 ppb, sediment less than 300 ppb, and the fish less than
1500 ppb. As in the Michigan study, most of the Illinois phthlate was in the
di-2-ethylhexyl form.
Based primarily upon chronicity bioassay, the committee feels it is
necessary to re-affirm our initial concern with environmental phthalate con-
tamination and to recommend to the Conferees -that comprehensive State surveil-
lance of municipal sewage treatment plants, industries, domestic water intakes,
and fish be initiated to determine phthlate trends in the aquatic environment.
In addition, the committee recommends that the Conferees request the Federal
Food and Drug Administration to further evaluate the problem to determine
whether an action level for fish needs to be set.
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2 MR. MAYO: Please go ahead on that basis, Dr.
3 Mount.
4 DR. MOUNT: I think just a word or two about the
5 history of this PCB question should be brought out here,
6 and that was that, I believe in the spring of 1970, the con-
7 ferees asked the Pesticide Committee to look into the ques-
3 tion of PCB's in Lake Michigan.
9 We had a meeting subsequent to that request, and
10 we found ourselves faced with several problems. One was,
11 at that time, there was not sufficient analytical capability
12 to measure PCB's, and I would remind you that this is not a
13 single chemical but a whole family of chemicals, and it is
14 not an easy measurement.
15 Secondly, we had no idea what level in the
16 environment was significant, and therefore we didn't know
17 what level we ought to be looking for in the environment.
1# So it was agreed that we would do two things:
19 1) first of all, the Duluth Laboratory, and also the Fish
20 and Wildlife Lab in Columbia, Missouri, would press forward
21 with toxicity work to find out what levels were important;
22 and 2) secondly, we would fund a grant, which we subse-
23 quently did, at the University of Wisconsin, to measure
24 PCB levels in Lake Michigan in the fish in particular,
25 and specifically to look at what isomers were present in
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the fish as a possible clue to which of the formulations of
Aroclor were most important and where they might be coming
from.
We have nearly completed the work on the toxicity
of PCB's and, in summary, I can simply say that most of the
PCB's that are in common usage have adverse biological effects
on organisms that are like, or are in Lake Michigan at concen-
trations in the range of 0.5 to 10.0 micrograms per liter or
parts per billion. These are direct adverse toxic effects.
More importantly, however, the PCB's have turned
out to be the organic of the organic chemicals that we
have studiedthey turn out to be more concentrated in
biological organisms than any other chemical we have looked
at. They exceed DDT.
We are finding that fish living in water concen-
trations that are completely harmless from the standpoint of
direct toxicity are concentrated in the body of the animals
in the order of 200,000 to 250,000 times. This has impor-
tance to the conferees and to all of us in that we are going
to see high residues in the fish and other aquatic organisms
from extremely low water concentrations.
We can say, at the present time, I think, rather
confidently, that concentrations in the water in the range
of 10 to 15 pptr in nanograms per liter are sufficient to
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1 D. Mount
2 cause the animals to exceed the 5 ppm maximum level as
3 established by the Food and Drug Administration. This, then,
4 I think, establishes the level to which we must regulate
5 PCB's in the environment at least to that level.
6 As far as the results of the work to find out where
7 they are coming from, as indicated in the report, the States
8 have made surveys in various places and have, in fact, found
9 sources of PCB's, particularly in industrialized areas, and
10 in the grant work at Wisconsin, concentrations up into the
11 hundreds at least over 100 ppm have been found in
12 fish in tributaries where PCB's are commonly discharged.
13 The fish in the lake, as indicated in your report,
14 are exceeding the 5 ppm maximum level, in many instances.
15 While the final report is not in hand yet I should
16 mention that these are conclusions which the author of that
17 report has given me verbally the report shows that there
IS is apparently not a great difference in the PCB concentra-
19 tion in fish from various parts of the lake. It shows that
20 the larger fish have much more PCB's in them than the
21 smaller fish, and this is thought to be related to the fat
22 content of the larger fish; the larger fish having a higher
23 fat content tend to have a higher PCB concentration. It
24 all fits into the same pattern as we have seen with some
25 of the chlorinated hydrocarbon pesticides.
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1 D. Mount
2 I need not well, it ±s not within my expertise
3 to talk about the policies that have been implemented either
4 by the Federal Government or the State in terms of control
5 of PCB's, But the committee is much concerned that while the
6 domestic production and sale of PCB's has been curtailed sub-
7 stantially, we recognize, as far as the committee knows at
# least, there have been no controls instituted over the
9 importation of foreign PCB's. Therefore, it is the
10 committee's feeling that we dare not relax in the monitoring
11 program for PCB's, both in terms of locating sources and
12 inputs as well as the trend of concentration in the fish in
13 the lake,
14 Because of the analytical difficulty of measuring
15 PCB's, particularly in water of extremely low concentrations,
16 it is the committee's feeling that these, too, should be
17 watched through looking at residues in fish, and that this
13 is a definite need in order to find out whether or not
19 whatever controls the States and the Federal Government do
20 institute on PCB's are effective.
21 Would you like me to go on to phthalates or pause
22 for a minute on PCB's?
23 MR» MAYO: Let's stop here for a moment,
24 MR, PURDY: I have a comment with respect to the
25 report, as presented, and that is that presently no State
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1 D. Mount
2 in the Lake Michigan Basin has regulations governing the dis-
3 charge of PGB.
4 I wouldn't want to leave the impression that PCB's
5 cannot be controlled with the existing legislation, although
6 no specific regulation may have been adopted, that under the
7 broad coverage of most water pollution control laws, that
8 when a problem has been defined, that there is an avenue
9 available to the States so that they can take action to
10 correct that problem0
11 With respect to Michigan, under our critical
12 materials that Michigan has established, polychlorinated
13 biphenyls is a critical material that requires annual
14 reporting, if you use it within your process.
15 Then, from the standpoint of no alternative to the
16 use of a PCB, again, I wouldn't like to leave that stand
17 in that there are hydraulic fluids available: phosphate
IB esters, and combinations of phosphate esters and biphenyls,
19 that can be used as a substitute. And wherever we now find
20 polychlorinated products used as hydraulic fluids, whereby
21 they can escape to the water environment, that we are
22 requiring that these substitutes be used, and that the use
23 of the polychlorinated biphenyls be phased out, period.
24 So 1 wouldn't like to leave those that use
polychlorinated biphenyls with the idea that they can
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2 continue to use them because no regulation has been adopted.
3 There is a way of getting a handle on it, and there are
4 substitutes that they can use.
5 MR. MAYO: Dr. Mount, in your comments, you remarked
6 that there has been restriction in the sale and use of
7 domestically produced PCB's, but that there are no apparent
8 constraints at the present time on the importation of PCB's
9 from outside the United States.
10 Did the committee tend to come to any conclusion
11 dealing with the urgency for national legislation to be
12 drafted to control or at least account for the importation
13 of materials such as PCB's?
14 DR. MOUNT: Well, not in the committee meeting,
15 but in the meeting we held in Duluth this spring on PCB's,
16 Dr. Buckley from R and M headquarters, told us that it
17 was the feeling of headquarters that the Toxic Substances
13 Control Act, I believe, which is in the process of being
19 enacted or being voted on, would be applicable to such
20 products as PCB's from foreign sources. Other than that,
i
21 I know of no particular discussions about it.
22 MR. MAYO: Well, with that background on your
23 part, to the extent that the Act will be applicable to
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24 materials such as PCB's, do you think there is some sense
25 of urgency to proceed with the enactment of that kind of
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D. Mount
2 legislation?
3 DR. MOUNT: Yes, I think there definitely is.
4 MR. BRYSON: Dr. Mount, is the problem of analysis
5 as evident to PCB's as it is in pesticides?
6 DR. MOUNT: Yes, I think the difficulty of analyz-
7 ing for PCB's is even worse than DDT, but the concentrations
8 in biological tissue are so high, and from what I can gather
9 in talking with Dr. Stallings at Columbia, and some of the
10 other chemists, the marriage of G. C. mass spectrophotometer
11 and the computer software programs that go with it have made
12 it such that the measurement or estimation of the quantity
13 of PCB in tissues at the levels they occur at is precise
14 enough for our need. After all, we are looking for concen-
15 trations up in the part per million range in the tissues.
16 This does not pose the difficulties of analytical
17 measurement that are posed by measuring part per trillion
concentrations in the water.
This, in fact, is in the same category and is the
same reason why the committee, in 1968, recommended to this
conference that the point of control be on the tissue rather
22 than in the water.
23 There was another reason and that was we didn't
^ know what water concentration was significant at that time
and I guess that is still the case with DDT. I think we
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2 have a better control on DDT now in that regard. But in
3 either event the organism is serving as a concentrated device
4 in making the analysis more simple* It has the added advan-
5 tage that what is in the organism you know as the biological
6 activity is biologically inactive; whereas, measuring it in
7 the environment you don't always know this.
8 MR. BRYSON: So that means, when you talk about
9 "aquatic environment" on page 3 of your statement which
10 reads: "The committee recommends to the Lake Michigan con-
11 ferees that comprehensive surveillance by the States be
12 initiated to determine PCB trends in the aquatic environment
13 ..." you are talking about the fish as opposed to water
14 concentrations.
15 DR. MOUNT: Well, I think we are talking about the
16 fish in the lake, but I think we are talking about effluents
17 contributed to tributaries. It seems to me that this is
IS the point of control or the point of finding out where to
19 control by looking at their sources, and they are at high
20 enough levels, generally speaking, in the waste effluents
21 to be measured.
22 MR. McDONALD: What type of reduction, Dr. Mount,
23 occurs, say, in an ordinary activated sludge sewage treat-
24 ment plant?
25 DR. MOUNT: I have no knowledge of that, Mr.
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2 McDonald.
3 MR. McDONALD: Do you have any knowledge or can you
4 make any conjecture on levels of fish mortality that are
5 fairly directly attributable to PCB's and DDT?
6 DR. MOUNT: As much as we know at the present
7 time about the concentration of PCB's in Lake Michigan water
g and from what we know about the toxicity, about the only
9 conjecture one can come to is that there should not be any
10 direct toxicity or adverse effects.
11 Now the one point which is not clarified yet and
12 for which we should have some reasonably good answers
13 should have been this fall but because the animals didn't
14 cooperate it is going to be next fall we will know, I
15 think, whether or not PCB's are passed on in the eggs of
16 fish and are absorbed at the time or are taken up at the
17 time the yolk sac is absorbed and causes the mortality in
IB the fry, much like has been ascribed to DDT. Now if that
19 is happening, then my statement that there have not been
20 direct adverse effects would not be true.
21 I should also mention that work recently by some
22 people at Michigan and I believe some other workers,
23 too has reasonably clearly shown that the failure of an
24 increased production is most likely ascribable to PCB's and
25 not to DDT or dieldrin.
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1 D. Mount
2 MR. McDONALD: In terras of toxic substances that
3 go into Lake Michigan, where would PCB's rate, in terms of
4 mortality, in your judgment?
5 DR. MOUNT; In terms of mortality in the lake.
6 MR. McDONALDs Would it be number one on the list
7 of toxic substances?
DR. MOUNT: No, I don't think it is number one.
9 MR. McDONALD: Where would it be relatively?
10 DR. MOUNT: Somewhere in the middle.
11 MR. McDONALD: Somewhere in the middle. What
12 would rank ahead of it?
13 DR. MOUNT: I think this is too much conjecture
14 really right now because we have very little knowledge of
15 ! the organics that are going into that lake. There must be
many of them. And whether they persist or not, I don't think
17 we know. We know that there are a great many peaks that
appear on the gas chroiaatograph, when one looks at sewage
treatment plant effluent, and until we know what those are,
there is no point in trying to decide which one is more
r>-\
^ important.
22 MR. McDONALD: So you are saying that you know
there is a lot of PCS going in, but it is hard to pinpoint
all of the effects.
25 DR. MOUNT: That is right.
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1 D. Mount
2 MR. McDONALD: Thank you.
3 MR. MAYO: Mr. Purdy.
4 MR. PURDY: I would like to phrase that question
5 in a somewhat different fashion. In view of the action
6 level that has been established by the Food and Drug Admin-
7 istration on the public health aspect consumption of this as
$ a food product, and in view of the relative magnitude of the
9 concentrations of PCB's versus DDT, dieldrin, and so forth,
10 and in view of the action that has already been taken to
11 limit DDT input and dieldrin input into Lake Michigan, do
12 you feel that the PCB is in the first priority of attention?
13 DR. MOUNT: I think that is a different question
14 entirely because now we are asking the question: How is it
15 important in terms of the residue that is there, from the
16 human consumption point of view? And simply because many
17 of the fish that have been analyzed in Lake Michigan are
13 over that action level that by definition makes it a problem
19 as far as the sale of those fish are concerned. And other
20 than DDT and PCB's, I do not know offhand of another chemi-
21 cal which is exceeding an action level or a tolerance level
22 that has been established well, I should mention dieldrin,
23 too that is exceeding an action level established by the
Food and Drug Administration.
2 5 On the other hand, I think it only fair to point
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out that action levels will not be established on these
materials unless there is an indication of a problem or
unless someone requests them, as I understand it.
MR, PURDY: But in view of what already has taken
place and as I understand it, the PCB level is higher
in fish than the DDT level that rather than wait for a
monitoring program to indicate the trends of what is going
to happen to the PCB levels, we ought to be taking some
action today.
DR. MOUNT: That is exactly what I had tried to
say and perhaps didn't do it well enough. I don't think we
rest easy that the policies that we have in existence right
now are going to do it without being certain that they will.
And we believe we can do this by following what is in the
fish and also the discharges, and proceed in taking whatever
action is necessary based on the findings of that.
I think that also there is another advantage in
following the trend of PCB's and DDT, for that matter, in
Lake Michigan, and that relates back to Dr. Lee's comments
of yesterday and his model of phosphorus.
We know very little about the purging rate of such
material in the lake, and here is a case where we have a
chance to find out what is going to happen, because we
have a rather sudden shift off of the input of DDT and
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r diet or understand how a material will disappear from the
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apparently we will have a substantial reduction, at least
in PCB's, and this will make it much more possible to pre-
lake after the input is shut down. It will help in future
problems.
MR. MAIO: Any other comments, gentlemen?
MR. FRANCOS: Yes, Mr. Chairman.
Just a comment, that we, in Wisconsin, have
parallel legislation to that of Michigan with respect to
surveillance and reporting, and that we are now in the
process of developing rules and regulations and getting our
program off the ground. But we also anticipate a more pre-
cise review of the use in the State of PCB's, also high on
the list, and we will be requiring a reporting of the use
and a materials balance analysis by those users.
Perhaps the question should go to you, Mr. Mayo,
but I do recall that within the past several months that
an Inter-Agency Federal report issued what might be called a
j policy statement on the use of PCB's.
Could you help us out on that? Are you familiar
with that report or exactly what the purpose of that report
was or what the report said?
MR. MAYO: Well, the purpose of the report, as
an Inter-Agency Federal report, was to examine the extent
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to which PCB's exist in the environment, to try to recog-
3 nize its importance as an economic chemical, and to suggest
4 what actions might be desirable to control the further
5 introduction of PCB's into the environment, what might be
6 reasonable to expect to be the eventual fate of those PGB
7 materials that were already in the environment.
I may reach back a little bit and try to recall
what some of the principal conclusions of that report were.
10 I think they went about like this: that the presence of
11 PCB in the environment was more adequately established in
12 the water environment than in the land environment; that
13 its presence in fishes and in birds and small animals
14 that rely on fishes for diet was pretty well established;
15 that there was, at that point in time, no substantial
16 evidence of the occurrence of PCB's in upland birds and
17 animals that did not have a substantial reliance on fish
or aquatic life for their diet. So that the presence of
19 PCB in the environment seemed to be more importantly
20 I related to the water environment than the land environ-
21 ment.
22 Second, that the PCB materials had some fairly
23 outstanding characteristics in industry that were not
24 readily replaceable particularly with respect to certain
25 electric components and that it would not be unreasonable
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2 to continue to use PCB's for those select purposes where
3 there was virtually no opportunity for them to be introduced
4 into the environment.
5 As I recall, the report also recommended that other
6 uses of PCB's be discontinued. The report recognized that
7 in the United States or at least in the northern herais-
g phere the northern half of the western hemisphere, the
9 only production of PGB's was by Monsanto Chemical Company,
10 and that Monsanto, by virtue of a sales policy, had
11 restricted the sale of PCB's only to those users whose
12 needs were rather specific to the unique properties of
13 PCB materials, and for which there was no presently iden-
14 tified reasonable substitute.
15 It was mentioned that the PCB sales had been
16 reduced dramatically by Monsanto since 196£ although I
17 can't recall what the figures were. It also recognized
IS that PCB's were being manufactured in Europe and Japan,
19 that they will probably be manufactured in South America,
20 and that, at this point in time, we have no adequate inven-
21 tory of the extent to which PCB's were being imported into
22 the United States, nor did we have any inventory of where
23 those PCB's that might be imported were being distributed,
24 or the extent to which they were being used, or the uses
25 to which they were being put, and recommended the passage
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1 D. Mount
2 of the pending hazardous substances legislation currently
3 before the Congress.
4 It also suggested that we had little choice, as
5 far as the water environment is concerned, other than to
6 rely on the slow degradability of the PCB's; that we should
7 look toward a zero level of PCB's in industrial and munici-
£ pal waste discharges, and that the as I recall action
9 or that the level of control of PCB's in the water environ-
10 ment be somewhere in the neighborhood of either 0.01 or
11 0.001 ppb. I am reaching back to some of those numbers,
12 but those were essentially the features of the report.
13 MR. FRANCOS: Thank you. That is a pretty good
14 recall.
15 MR. MAYO: That was one of the few I read.
16 Any other questions, gentlemen? If not, we can
17 move on to the other portion of your report, Dr. Mount.
13 MR, FETTEROLF: Just one question, Mr. Mayo.
19 You read us the recommendations that were in the
20 report. Has EPA adopted those recommendations as a policy?
21 ' MR« MAYO: Well, the pending legislation is the
22 key to the accomplishment of the recommendations that were
contained in that report, and that is the issue that is
presently before the Congress, and it perhaps would not be
out of place for this conference to comment on the urgent
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1 D. Mount
2 need for the passage of that legislation.
3 MR. FETTEROLF: Well, at the present time, we see
4 residues of PCB in fish in various areas, which the FDA
5 has identified as being well above the action level, and I
6 think it is certainly the responsibility of the conferees
7 to push for this legislation so that a policy decision can
g come out of it of what action should be taken.
9 MR. MAYO: Just so long as we don't try to legis-
10 late against the extent to which fish can take up PCB's.
11 Any other questions on the PCB issue, gentlemen?
12 Would you proceed, Dr. Mount?
13 DR. MOUNT: Now, in regard to the phthalates, I
14 think it was again in March of 1971, at this conference,
15 that I mentioned that the occurrence of phthalates in Lake
16 Michigan water and these were identified by the Fish
17 Pesticide Research Laboratory in Columbia, Missouri, who
13 were in the process of looking in detail at some of the
19 water samples from Lake Michigan in connection with the
20 pesticide work on DDT and dieldrin and they reported
21 that there were higher concentrations of phthalates in the
22 Lake Michigan open water than there were of DDT.
23 After the conference was over, I took the first
24 opportunity, which came around in the next fiscal year,
25 around the fall of 1971, and we wrote specifications for
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1 D. Mount
2 a contract, which was subsequently awarded for, I think,
3 about $150,000 to look at the toxicity of phthalates on
4 aquatic life because, again, we found ourselves in the same
5 position with phthalates that we were several years ago
6 with PCB's, and that was we had no notion of what concen-
7 tration of phthalates was important
MR. MAT04 Excuse me, Dr. Mount.
9 There is an awful lot of background noise from
10 the audience, and I am confident some of the people in the
11 rear are having difficulty hearing.
12 Please go on.
13 DR. MOUNT: We did not know what levels of
14 phthalates to look for in a monitoring program and so we
15 have initiated this work. I also had discussions with the
Pesticide Laboratory in Columbia, Missouri and they quite
17 willingly agreed to work with them in-house as well.
At the present time, we are still in the position
of not knowing the levels that are harmful to various kinds
20 of aquatic life except for Daphnia magna* That work was
21 completed at Columbia by Dr. Schoettger's lab and they found
22 that concentrations as low as 3 micrograms per liter
which would be 3 ppb affected the growth and reproduction
and death of the magna. That animal is very characteris-
tically one of the most sensitive animals to the organic
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1 D« Mount
2 chemicals, although one cannot generalize to everything
3 from that one animal alone.
4 Our tests that will be concluded in the fall
5 months of this year should give us a reasonably good idea
6 of what levels of phthalates are going to be harmful to
7 various types of aquatic life.
Again, I would remind all of us that the phthalates
9 are not a single compound but a series of compounds, and
10 some of them are chlorinated compounds, and it is highly
11 likely, based on past experience, that some of them will
12 be much more toxic than others.
13 There are several which constitute the major
14 poundage of production in the United States, and these are
15 included, and the work is being performed.
16 The information about the findings in the various
17 States is all second-hand to me and perhaps the States
themselves should comment on that. I would just call your
attention to the statement at the top of page 6, which
20 indicates that at least in Michigan some 36 treatment
21 plants were sampled and they found 10 plants in excess of
22 10 ppb and 2 over 100 ppb, and I suppose that comparable
concentrations have been found in other States or will be
2/»- found.
The point I wish to make basically about
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1 D» Mount
2 concentrations is that the phthalates, unlike PCB's and DDT,
3 have been found in concentrations in sewage treatment plants
4 which are directly toxic to some forms of aquatic life, and
5 I think this should add some degree of urgency in getting
6 them up and finding out where they are coming from and how
7 high they are.
g As I have indicated, I think by Christmas we
9 should have a fairly good handle on what level we ought to
10 be looking for. In talking with Mr. Lueschow, who in turn
11 talked to his chemist, it appears that the detection levels
12 in the range of 0.05 micrograms per liter are not unreason-
13 able levels to go for at all and it would appear that this
14 ought to be low enough for our additional efforts in
15 monitoring.
16 There is very little known about the mammalian
17 toxicity of phthalates other than the acute toxicity and
l£ there it is very nominal.
19 There was a meeting on phthalates held in North
20 Carolina and sponsored by the National Institute of Environ-
21 mental Health scientists that was just last week, I
22 believe. I had a representative from my staff there, and
23 I have a number of the abstracts of papers that were given
24 and the essence of it all is that it takes thousands of
25 milligrams per kilogram to be acutely toxic to mammals. And
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-, D. Mount
2 this was a relatively nontoxic compound compared to some of
3 the hydrocarbons, for example. This tells us nothing, however
about the toxicity to aquatic life and so we can make no
5 extrapolations, at this time, about that.
6 Neither, as far as I know, is there much information
7 about the persistence of phthalates in the aquatic environ-
3 ment or in any other environment. I think there is a feeling
9 among some of the chemists I have talked with that they are
10 likely to be less persistent than PCB's, but nevertheless
11 their presence in some places certainly indicates that they
12 last for some important period of time in the environment.
13 So I think this perhaps is not a very satisfying
14 report as far as the conferees are concerned in terras of
15 action, but I think we are well on our way now to having a
16 better handle on what we ought to be doing.
iy I would also underline the last sentence on page
lg 6 which indicates that the Food and Drug Administration
19 and, by the way, we checked this again yesterday has not
20 established any action levels on phthalates and so we have
21 no guidance in that direction as we have had for DDT and PCB'
22 || MR. MAYO: Any comments or questions, gentlemen?
23 MR. BRYSON: As a result of the committee's work
24 maybe I should direct the question to the States did
25 any of the States initiate a program of monitoring of their
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1 D. Mount
2 sewage treatment plants?
3 MR. HERT: I would say Indiana has not, but I
4 talked with our laboratory director who needs to get some
5 more instrumentation in order to be able to do this, and he
6 is proceeding to gear up to do analysis on wastewater
7 treatment plants.
g MR. PURDY: In Michigan, it is one of those
9 critical materials upon which we receive reports of its
10 usage. We have had a monitoring program to establish the
11 fact that it is indeed reaching the environment. We are
12 continuing that program, and we are now looking to see if
13 the presence of phthalates in those places wnere we now
14 find it is from a point source or from diffuse sources. And
15 I am concerned, in this case, that once again, like DDT and
16 dieldrin, that we are apt to find that due to the usage of
17 the phthalates that it is from diffuse sources rather than
1$ from point sources, and that our ability to limit its
19 entrance into the environment probably will be bent upon
20 banning its use. And in view of its wide usage particu-
21 larly in the plastic formulations and I don't know if
I
22 I there is a substitute it may be harder to ban its usage
23 than it has been to ban the usage of DDT, dieldrin and
24 PCB's.
25 DR. MOUNT: If I may comment to that point, not
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-j_ D. Mount
2 disagreeing with what you have said but, I guess, going a bit
3 further I think it is very important that we not jump off
4 of the deep end because we have found another organic
5 chemical in the water; and neither do I believe that in every
6 case banning a material is the answer to the problem because we
7 may very well go to a chemical that is worse than the one
g we have banned. And we have every indication, at the present
9 time, that the phthalates are not nearly as toxic as the
10 PCB's, and the chlorinated hydrocarbons, and for this reason
11 I think "caution" is the word, at this point. Certainly I
12 think we should reduce the input of any foreign organic
13 chemical where it is not a necessary input but, apart from
14 that, I think we ought to be sure that we have a problem
15 before we move too rapidly on this thing. That is why I
16 think the first step is to find out what concentrations
17 are there, and we are already finding out what concentrations
lg are ecologically important.
19 There are a wide variety of uses of phthalates
20 some extremely important ones in plasticizers and I
21 think it would be foolish to move or to even talk about
22 j banning, at this point, until we know if we have a problem.
23 MR. SCHRAUFNAGEL: Wisconsin has checked about 25
24 I municipal sewage treatment plants and finds that the range
25 is from 2 to 4 ppb.
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D. Mount
2 DR. MOUNT: One of the things that makes me feel
o that the phthalates may not be highly toxic to aquatic life
is that in all of the aquatic laboratories such as my
own and the one at Columbia, and other places -- we have
5 been using plastic tubing and other types of plastic con-
7 tainers which the water flows through, and our fish are
living in, and the leaching rate of the phthalates from the
9 plants that get into the water is not a slow one at all and
10 we have not experienced any trouble, which leads me to
11 believe that they may not be particularly toxic to aquatic
12 organisms. This is kind of "around-t he-barn" reasoning
13 but it is better than none, at this point, I guess.
14 MR. McDONALD: Don, would this be the reason why
15 the cultured fish reflect higher levels than the natural
16 fish?
17 DR. MOUNT: Yes, I think that is one. But I have
talked with Dick Schoettger about that problem or that
19 finding, and I think he feels that it is because of the
20 handling of the food that they are eating, and I can't
21 elaborate on it any further than that. But he believes the
22 source is in the food the fish are eating rather than from
23 -the containers, and that sort of thing.
24 DR. KITCHEL: Dr. Mount, you mentioned a
differential toxicity in chlorinated and nonchlorinated
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1 D. Mount
2 phthalates. Is there any indication that there is sufficient
3 spread in this that we might be able to tolerate the non-
4 chlorinated phthalates and eliminate the chlorinated
5 phthalates?
6 DR. MOUNT: Well, I think that is a distinct
7 possibility. Let me make certain though that I clarify the
& record to say that I only said that I suspect based on
9 experience with other materials that there is likely to
10 be a big difference, and further evidence of that is that I
11 believe that it is one of the chlorinated phthalates that
12 is used as an insecticide for apparently very limited
13 application.
14 So, on that basis, I think that is highly probable,
15 and I think it is also probable, based on our experience
16 with some of the other herbicides, that the phthalic acid
17 is going to be much less toxic than the esters of phthalic
lg acid.
19 MR. PURDY: Mr. Mayo, with respect to the
20 recommendation of the committee that the conferees request
21 the Federal Food and Drug Administration to further evalu-
22
ate the problem and determine whether an action level for
23
J fish needs to be set, I am in agreement with that; but, in
O I
addition to that I think the conferees should also ask that
25
EPA continue its work and do whatever is necessary to
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1 C. Fetterolf
2 evaluate the ecological significance of the phthalate dis-
3 charge to our surface waters and see if an action program
4 is necessary.
5 DR. MOUNT: Mr. Chairman, before you respond to
6 Mr. Purdy's question, might I correct the statement that I
7 made just a minute or so ago. That chlorophthalate I was
# referring to is used in herbicides rather than insecticides.
9 MR. MAYO: I think that would not be an unreason-
10 able recommendation for the conferees to come to and ought
11 to be part of the business of the Executive Session.
12 Are there any other questions or comments to be
13 directed to Dr. Mount?
14 Thank you, Dr. Mount.
15 MR. BRYSON: The final section of the Pesticide
16 Committee will be a report on heavy metals, and this will
17 be presented by Mr. Fetterolf.
18
19 STATEMENT OF CARLOS FETTEROLF,
20 CHIEF ENVIRONMENTAL SCIENTIST,
21 MICHIGAN WATER RESOURCES COMMISSION,
22 LANSING, MICHIGAN
23
24 MR. FETTEROLF: Mr. Chairman, conferees, ladies
25 and gentlemen.
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j_ C. Fetterolf
2 As Mr. Lueschow told you, the Lake Michigan Inter-
3 state Pesticide Committee was created in 196S. Its responsi-
4 bilities have been considerably broadened by the charges of
5 the conferees, and it is now functioning really as a toxic
6 substances advisory body,
7 This report deals with selected trace metals which
£ may be of biological significance in Lake Michigan,
9 Scientists have been studying the effects of these
10 metals on aquatic ecosystems for many years. While some of
11 the committee members have been deeply involved in such studies
12 on a local basis, we have discovered that it was becoming
13 increasingly clear that no one was looking at the general
14 situation with respect to metals in Lake Michigan.
15 With this question in mind, the committee asked
16 each State member in 1971 to submit selected trace metal
17 data for Lake Michigan and its tributaries. These data sub-
18 missions comprise this report.
19 Basically the report is concerned with the exist-
20 ! ing knowledge of selected trace metals in the water, sediments:,
21 and aquatic life resources of Lake Michigan and its tributar-
22 j ies. Some information is also presented on the sources of
23 these metals from industries, municipal sewage treatment
24 plants, and atmosphere and fallout,
25 It will be obvious to the reader that more
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444
1 C. Fetterolf
2 information is needed.
3 In addition, the committee included a synopsis of
4 much literature on selected trace metals. The committee
5 believes that this report is sufficiently representative of
6 exist ing knowledge that it warrants the conclusions and
7 recommendations drawn.
g The metals selected are those which may, even at
9 very low concentrations, cause problems to aquatic life or
10 humans.
11 Although data are available from many different
12 sources, no attempt is presently being made to monitor the
13 overall conditions within the Lake Michigan Basin. Little
14 is known about the sources and amounts of metals now enter-
15 ing the lake. For example, airborne emissions from power-
16 plants, steel mills, and incinerators may be contributing
17 significant amounts of some metals to the lake environment.
IS More study should be encouraged so that reliable estimates
19 can be made and the true significance of airborne emissions
20 established.
21 While data are available on water concentrations
22 of heavy metals in Lake Michigan and its tributaries, the
23 levels of sensitivity and number and frequency of samples
24 are inadequate to establish present conditions and contri-
25 butions. Zinc occurs in high enough concentrations so that
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C. Fetterolf
it is detectable using present analytical techniques. Copper,
cadmium, nickel, lead and chromium, are generally below
detectability in Lake Michigan. Heavy metals in both Indiana
5 and Michigan tributaries are often below the level of detect-
ability, and little information is available from Wisconsin
tributaries.
Recent data indicate that the Grant River may be
a significant source of copper, nickel, chromium, and zinc
10 to the southern basin of the lake.
11 Generally, however, analytical sensitivities for
12 metals in water samples must be improved before any meaning-
13 ful conclusions about the actual heavy metals concentration
14 in Lake Michigan and the contribution of the tributaries to
15 these levels can be established. Furthermore, tributaries
16 must be sampled at various flow stages to enable an estimate
17 of sources and mass balance to be made. It is imperative that
sufficient data be obtained to determine if metals concen-
19 tration in Lake Michigan is increasing in order to predict
20 whether harmful levels are likely to be reached given present
21 input levels.
22 I Heavy metals usually are found in sediments at
much higher concentrations than in the overlying water, but
adequate information is lacking as to the ecological signif-
25 icance of these accumulations in varied environments.
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^__ 446
1 C. Fetterolf
2 Metals in sediments are potentially available for uptake by
3 some organisms and may accumulate through the aquatic food
4 chain. Since the information available does not permit us
5 to reliably predict whether or not various metals will be
6 reconcentrated in aquatic organisms from bottom sediments,
7 such deposits must be viewed with concern,
# The data indicate that mercury, lead, zinc,
9 chromium, copper, and arsenic are accumulating in the upper-
10 most sediments of the deeper regions of southern Lake
11 Michigan. These uppermost sediments, of course, are the
12 most recently deposited ones. The trace elements which show
13 little or no accumulations in the top layers of sediment are
14 boron, cobalt, beryllium, lanthanum, manganese, nickel,
15 scandium, and vanadium. Significant areas of concentration
16 of chromium, mercury, arsenic, copper, lead, and zinc occur
17 off Grand Haven and Benton Harbor in Michigan; off Waukegan
l£ in Illinois; and in the center of the lake near the
19 Illinois-Wisconsin border.
20 Studies by the Illinois Geological Survey show a
21 good correlation with organic carbon distribution in sedi-
22 ments and concentrations of certain elements. These correla-
23 tions suggest that elevated levels of certain metals in top
24 sediments are the result of man's recent activities in the
25 watershed surrounding Lake Michigan and perhaps are related
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10
11
12
13
14
15
16
17
19
20
21
_ 447
C. Fetterolf
to increased biological productivity.
Further studies of metals in sediments by the State
of Michigan and the U.S. Geological Survey have clearly
established that municipal and industrial discharges are
important sources of metals.
Not enough is known about heavy metals in tribu-
tary sediments and their movements to calculate a poundage
input of heavy metals to Lake Michigan from sediments.
Since the significance of metals in sediments is unknown,
monitoring of stream and lake sediments is necessary to
locate contaminated areas and sources of heavy metals to
the Lake Michigan ecosystem. The existing potential "hot
spots11 should be watched carefully for problems such as the
one which developed over the methylation of mercury in
sediments by bacteria. The sources of heavy metals should
be controlled so further deposition is eliminated or
decreased.
It appears that except for mercury, metal residues
in fish do not exceed concentrations that are likely to be
selected if Food and Drug Administration action levels were
22 to be established.
23
Data on the acute toxicity of metals, using Lake
Michigan water and fish, are not available. However, it is
possible to estimate the probable safe ranges using existing
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1 C. Fetterolf
2 bioassay data to estimate the 96-hour TLm values for Lake
3 Michigan fish and water.
4 Estimates of probable safe ranges for Lake Michigan
5 fish are given for copper, nickel, zinc, cadmium, and
6 chromium. Estimates of probable safe concentrations for
7 other metals must be based on 1/100 of the 96-hour TLm until
£ data are available upon which better predictions can be
9 made.
10 The committee's recommendations:
11 l. There is an urgent need to establish acute
12 toxicity levels for selected metals using Lake Michigan water
13 and various life stages of Lake Michigan fish. Such informa-
14 tion will make it possible to establish recommended safe
15 levels for selected metals in Lake Michigan. Until this
16 information is available, we must use available bioassay
17 data from the literature to establish probable safe ranges.
18 2. The States should report regularly on the
19 inputs of metals to the Lake Michigan Basin, based on
20 information obtained from industrial permit programs and
21 tributary monitoring. Sewage treatment plant effluent
22 should also be monitored to determine the input of metals
23 from this source.
24 3. Analytical and field methods must be standard-
25 ized for all heavy metals research programs to insure the
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449
1 C. Petterolf
2 data obtained are accurate and precise and contribute to the
3 body of comparable data. The Interstate Pesticide Committee
4 has taken a step toward resolving this problem by having a
5 meeting on August 23 and 24 of the working chemists from
6 agencies represented on the committee.
7 4. An attempt should be made to determine the
3 contribution of airborne emissions of metals to the waters
9 of Lake Michigan and its tributaries.
10 5. While the committee feels that the present
11 levels of selected trace metals are not a problem at this
12 time, the Food and Drug Administration guidance should be
13 obtained to establish acceptable levels of these metals in
14 fish.
15 6. Levels of selected trace metals in Lake
16 Michigan waters and fish should be clearly established at
17 this time. A program to monitor changes in these levels
13 and to establish future trends is also needed. This, of
i
19 course, can be tied in with the pesticide and PCS monitoring
20 programs.
21 7. An effort should be made to understand the
22 I ecological significance of metals in sediments. The
potential impact of such compounds as NTA, one proposed
2^ | substitute for phosphorus in detergents, of the metal
2 5 deposit in sediments should also be explored.
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1 C. Fetterolf
2 That concludes our report, Mr, Chairman.
o (The complete "Report on Selected Trace Metals in
/j. the Lake Michigan Basin" by the Lake Michigan Enforcement
5 Conference Pesticides Technical Committee is on file at EPA,
6 Headquarters, Washington, D.C., and EPA Region V Office,
7 Chicago, Illinois.)
g MR. BRYSONs The next item on the agenda is the
9 Chloride Report. At the last session of the conference, the
10 conferees entered into a discussion on the question of chloridje
11 dischargers into Lake Michigan. As a result of that discussion,
12 they concluded and recommended the following:
13 "The States will provide to the conferees a listing
14 of all identifiable chloride sources of significance in the
15 conference area. The Federal conferee, after consultation
16 with the States on measures for control of chlorides, will
17 make a proposal for chloride control at the next conference
18 session. The Federal conferee will also provide to the con-
19 ferees a State-by'-State resume of the water quality standards
20 on chlorides. This report will also show the relationship of
21 the standards to the existing water quality."
22 EPA has concluded its report in response to this
23 conference recommendation,
24 At this point, I will call on Mr. Gary Schenzel
25 to present that report to the conferees. Mr. Schenzel.
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451
G. Schenzel
STATEMENT OF GARY SCHENZEL,
U.S. ENVIRONMENTAL PROTECTION AGENCY,
ENFORCEMENT DIVISION,
CHICAGO, ILLINOIS
MR. SCHENZEL: Thank you, Mr. Bryson.
9 My name is Gary Schenzel, U.S. EPA, Enforcement
10 Division, Chicago.
I have prepared a brief overview of the chloride
12 issue for presentation today; however, I request that a copy
13 of the full chloride report be placed into the record.
14 (The document above referred to follows in its
15 entirety.)
16
17
19
20
21
22 j
23
24
25
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REPORT OF
THE ENVIRONMENTAL PROTECTION AGENCY
TO
THE LAKE MICHIGAN ENFORCEMENT CONFERENCE
ON
CHLORIDE
SEPTEMBER 1972
-------
The third session of the Lake Michigan Enforcement Conference
asked the State Conferees to submit a list of all significant, identi-
fiable chloride sources in the Basin, along with ideas for chloride
control. The Federal Conferee was requested to provide a resume of
State chloride standards, an estimate of the present chloride level
in the Lake and, in cooperation with the States, proposals for
chloride control at the fourth conference session.
A major reason for urging control of chloride discharges is to
help limit the build-up of Total Dissolved Solids (TDS) in Lake Michigan.
The Great Lakes Water Quality Agreement recently signed by Canadian and
U. S. officials requires the control of TDS to help protect the aquatic
environment of the International Great Lakes from further degradation.
In compliance with this agreement, and to maintain existing TDS levels
in Lake Michigan, the control of chloride is not only desirable, but
mandatory.
The strategy underlying the Conference discussion and recommendations
was to control large point sources of chloride discharge rather than to
initiate a comprehensive program to limit all point and diffuse sources.
The conferees identified two major areas in the Lake Michigan basin which
have large point sources of chloride. These were the Manistee-Ludington
area in western Michigan, and the Calumet area in Indiana.
This report follows the direction set by the conference. It con-
centrates on the State efforts to control large sources of chloride,
summarizes existing chloride levels in the Lake, relates water quality
standards and the existing water quality, and identifies measures to
further control chloride discharges.
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- 2 -
RELATIVE IMPORTANCE OF THE CHLORIDE PROBLEM
The chloride concentration in nearly all areas of Lake Michigan
is not high enough now to seriously interfere with water use. Nor will
the level increase greatly in the next fifty years to become a major
water quality problem. In 1965, Ownbey and Will eke1 reported the
average chloride concentration to be,7 mg/1, predicting an increase
to 12 mg/1 by the year 2020, based on projected growth in population
and industry in the basin. The authors concluded that this slow rate
of chloride build-up was not a threat to the Lake water quality.
However, noting a major contribution from the salt producing companies
in western Michigan, they suggested control of these sources if a
chloride discharge reduction became necessary.
A more recent paper by O'Connor and Mueller2, which is based
in part on the Ownbey data, presented a chloride model for all of the
Great Lakes. It too predicts a slow increase in chloride concentration
in Lake Michigan. In addition, the O'Connor model semi-quanitatively
predicts the effect on water quality of reducing industrial chloride
loadings. This study reported that complete control of industrial
loadings would reduce the chloride concentrations by 1 mg/1 by the
year 2020.
Since chloride is a conservative material, it is not de-
graded once it enters the Lake. The only removal process is to allow
it to flow naturally to the lower Great Lakes. The large volume in
relationship to the tributary inflow gives Lake Michigan a detention
time of nearly 100 years. Control measures, therefore, would not show
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- 3 -
effects for a significantly long period of time. Because of these facts,
it is better to keep chloride out of the Lake rather than apply control
measures after the concentration has become too high.
If recent sampling data is representative of a trend in chloride
concentration, then the rate of chloride increase in Lake Michigan is
more rapid than predicted by Ownbey. Rather than the 7.5 rng/1 level
predicted for 1970, the concentration in that year, by actual survey,
was close to 10 mg/1. It is the conservative nature of chloride, along
with the long detention time for the Lake that makes this more rapid
increase subject to concern.
TOTAl DISSOLVED SOLIDS & CHLORIDE CONTROL
Chloride is important since it is a major component of Total
Dissolved Solids (TDS) from man-made sources. In addition, chloride
serves as an indicator for TDS control. Reduction of chloride from
large point sources would also reduce other ions which are part of TDS.
Historically, levels of TDS in tha lower Great Lakes have
climbed rapidly. In 1920 the level >;as 145 mg/1 in Lake Erie. The
level had reached 185 mg/1 by I9603. A somewhat similar increase has
been observed in Lake Michigan. In the 90 years between 1870 and 1960,
the TDS level there rose 30 mg/1 to its present level of 160 mg/1 \
The United States and Canada have long been concerned with
deteriorating water quality in the International boundary waters of
the Groat Lokes. Recently, the two lountn'ps signed the "G>re?t Lakes
Water Quality Agreement" which defines water quality objectives to
protect and upgrade the water. In signing this Agreement, both
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countries recognized the need to limit the build-up of IDS. Control
of chloride in Lake Michigan, which is a tributary to Lake Huron, is
an important part of fulfilling the Agreement, since annex 1,
section l(c) limits the level of IDS in Lake Huron to current levels
pending further study.
CHLORIDE SOURCES IN THE LAKE MICHIGAN BASIN
The conference requested the States to provide a listing of all
identifiable chloride sources of significance in the Lake Michigan
basin. The information supplied in response to that request is given
in Table A. A discussion of the information follows:
Wisconsin
Wisconsin submitted information on chloride concentrations in
major tributaries of the State within the Lake Michigan drainage basin
for the winter months (December to March, 1969 water year). From this
data, EPA has calculated the approximate yearly loading to the Lake from
these tributaries. Since only the winter chloride concentrations and
tributary flows were available, the calculated loading is actually the
total for only four months. Because the four-month loading is used as
the approximate yearly load, the latter figures are probably under-
estimates. The Fox River is by far the largest tributary source from
Wisconsin to Lake Michigan. The greatest input to the River is in the
lower Fox region.
Illinois
The minor chloride point sources in the Illinois portion of the
Lake Michigan drainage basin do not need immediate control.
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TABLE A
WISCONSIN
Tributary Mean Cone.
(mq/1)
Fox
Green Bay 13.6
Omro 5.1
Milwaukee
Machinery Bay 49.5
Brown Deer 37.5
Root 77.3
Other Wise. Rivers _
Subtotal
Mean Flow
Dec. to war.
(cfs)
4741
330
143
Approximate
Loading
(#/year)
106 X 106
32 X 106
18 X 106
40 X 106
196 X 10&
ILLINOIS
Tributary or Source Mean Cone.
(mg/1)
Pettibone Creek 54
Domestic Waste 10
Water
Abbott Labs 25
U.S. Steel (Waukegan)
Subtotal
Mean Flow
(mgd)
2.0
40.0
15.0
5.6
Loading
(#/year)
0.33 X 106
1.2 X 106
1.1 X 106
2.0 X 106
4.6 X 106
MICHIGAN
Source Flow
(mgd)
Loading from Tribs. 12,000
(includes indirect
point sources)
Indirect Point Sources
to Lake
Dow Chemical (Ludington)
Morton Salt & Chem. (Manistee)
Hardy Salt (Mam'stee)
Hooker Chemical (Montague)
Std. Lime and Ref (Mam'stee)
Direct Point Sources
Dow Chemical (Ludington)
Std. Lime & Ref. (Manistee)
Subtotals
Maximum
Loading
(#/day)
0.088 X 106
0.237 X 106
0.12 X 106
0.221 X 106
0.50 X 106
1.97 X 106
1.00 X 106
4.136 X 106
Loading
(#/year)
1,004 X 106
719 X 106
365 X 106
2,085 X 100
INDIANA
Source
Bethlehem Steel (Chesterton)
Atlantic Richfield (East Chicago)
American Oil Co. (Whiting)
Youngstown Sheet & Tube (East Chicago)
U. S. Steel (Gary)
Inland Steel ( East Chicago)
Subtotals
Loading
(Ibs/ year)
6.79 X 106
4.31 X 106
5.52 X 106
47.54 X 106
28.08 X 106
39.49 X 106
131.73 X lOb
TOTAL CHLORIE LOADING TO LAKE MICHIGAN
2,421 X 106
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Michigan
Michigan reported direct and indirect point sources plus the
average loading from its tributaries to the Lake. To calculate the
total yearly load, the amounts of chloride from the direct point
sources and tributaries were added together. Since the loading
figures for the point sources were maximum values, the yearly loading
total may be an over-estimate. On the basis of the figures given in
Table A, the Michigan point sources contribute about 40% of the total
chloride loading to the Lake. However, those figures show the loading
situation as of June 1971. Since that time, Michigan has started an
extensive control program. The details of this program will be dis-
cussed in detail later, but its results are summarized in Table D.
Indiana
There are some significant point sources from Indiana. Several
steel companies have, in the past few years, controlled chloride dis-
charges by deep well injection of chloride containing pickling acid.
The figures in Table A reflect the effects of this control. However,
EPA believes that further control is desirable.
Total Chloride Loading to Lake Michigan
The total chloride loading to the Lake is approximately
2,400 x 106 Ibs/year, with the most important loadings coming from
the brine area in western Michigan. This total over-estimates the
contribution made by the brine industries, but under-estimates the
amount of background rural and urban runoff.
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The loading figure is more than twice that used by Ownbey.
According to his figures, of the total of 1,191 x 106 Ibs/year,
660 x 106lbs/year came from industrial sources. In contrast to his
estimate, the data supplied by Michigan show that until recently
two industrial sources discharged 1,084 x 106 Ibs/year. Clearly,
the projections made in 1965 under-estimated the effect of industrial
discharges.
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WATER QUALITY STANDARDS AND THE AMBIENT LAKE QUALITY
Table B summarizes the current Federal-State water quality
standards for chlorides in Lake Michigan.
Illinois
Indiana
(Lake Michigan)
(Inner Harbor)
Michigan
TABLE B
STATE CHLORIDE WATER QUALITY CRITERIA
Shall not exceed 12.0 mg/1
Single value shall not exceed 15 mg/1
Monthly average shall not exceed 10 mg/1
Single value shall not exceed 30 mg/1
Monthly average shall not exceed 20 mg/1
Desirable monthly average shall not
exceed 10 mg/1
Permissible monthly average shall not
exceed 50 mg/1 (measured at public
water supply intake)
Wisconsin No standard designed to limit Chloride.
(Wisconsin does use the PHS drinking
water standard of shall not exceed
250 mg/1 in the drinking water supply
after treatment.)
In addition to the numerical criteria summarized above, all four
States have anti-degradation statements which require water quality to be
maintained at existing levels.
For the purpose of comparison, EPA has assembled recent data on the
ambient chloride level in Lake Michigan (Table C). Extreme values from
stations near the Manistee-Ludington area of Michigan have been omitted.
TABLE C
SOURCE OF DATA
GROSS MEAN
CHLORIDE CONCENTRATION
RANGE
OF VALUES
Ownbey (1965)1
Envir. Research Groups (1969-70)5
FWQA (1970)6
Milwaukee Water Intake (1971)
Chicago Water Intake (1971)
7
11
9.8
8.4
9,6
9-15
8-15
7 - 11
7 - 13
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The values listed in Table C indicate that the chloride level
in Lake Michigan is increasing faster than had been anticipated. For
example, Ownbey believed the Lake chloride concentration would not
reach 9.6 mg/1 until year 2000. Based on the data reported here,
the concentration may already be close to, or greater than that value.
The major rationale for limiting chloride discharges is a
desire to keep down the level of a potentially serious pollutant. The
antidegradation statements in the Federal-State standards serve as a
basis for this course of action. However, given a large number of
small man-made sources combined with an existing background from land
run-off, the chloride level in Lake Michigan will continue to rise.
The numerical criteria should be set at a chloride level near to that
existing in the Lake. They should be close enough to be criteria
with meaning, but far enough above the actual concentration to allow
for an inevitable yet acceptable rate of increase.
EPA believes the chloride criteria for the States of Michigan
and particularly Wisconsin are set too far above the existing concen-
tration. These values should be set closer to the existing quality and
more in line with other State criteria.
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CURRENT ABATEMENT EFFORTS
Since January 1971, the State of Michigan has signed stipulations
with the major salt and chemical industries in the Manistee-Ludington
area. Company action in compliance with these agreements has
achieved the following results:
Hardy Salt Company - Manistee
The Company has completed facilities to recover all brine
from backwashing the brine wells. The discharge of
chlorides and solids from the thickner has been eliminated
utilizing a closed settling and recycling system. Also,
facilities have been completed for recovering the wet salt
for process reuse. The facilities for completing the final
stage of the program were held up this spring. However,
completion is expected by October 1, 1972. Present chloride
discharge in excess of State stipulation is to a closed
lagoon system. These wastes will be disposed after deep
well injection facilities are completed in October. Total
chloride loading then will be 30,000 Ibs/day.
Morton Salt Company - Manistee
Injection system is now completed, but lack of operating
data makes it difficult to determine current loading. Prior
to operation of the injection system the load was 19,000 Ibs/day
as a result of other control measures. The state limit is
an average of 12,000 Ibs/day and 18,000 Ibs/day maximum.
Morton Chemical Company - Manistee
Construction was to be completed by June 1, 1972. However,
due to delays in equipment delivery and obtaining building
permits, the Company now expects the completion of the
facilities by September 1, 1972. The maximum chloride
loading after that date will be 22,800 Ibs/day. Currently
the discharge is 40,000 Ibs/day.
Standard Lime and Refractory - Manistee
Construction of the Phase I facilities is underway and is
expected to be completed by the September 1, 1972 date
contained in the Stipulation - the loading then will be
1,127,000 Ibs/da'y. Phase II of the program which will
reduce the chloride discharges loading to 307,600 Ibs/day
is scheduled for completion by December 1, 1973. Present
loading is 1,870,000 Ibs/day.
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Dow Chemical Company - Ludington
Construction of the piping arrangements and deep disposal
well is underway with completion expected by the December 1,
1972 required date. The discharge is now about 30 to 40
thousand Ibs/day into Pere Marquette Lake, and 600 to 700
thousand Ibs/day into Lake Michigan. After December 1972,
the total load will be limited to 380,000 Ibs/day.
Hooker Chemical Company - Montague
The Company has submitted and received approval of their
preliminary engineering report. Hork on the plans and
specifications is progressing with submission of such
expected by the required December 1, 1972 data. Com-
pletion is scheduled for September 1, 1973. The loading
at that time will be 52,650 Ibs/day.
The substantial reduction in loadings is summarized in Table D.
Overall, the chloride discharge for this group of industries on
January 1, 1973 will be only 40% of the discharge as of June 1971.
TABLE D
PROGRESS IN CONTROLLING MICHIGAN
POINT SOURCES OF CHLORIDE
Source
Hardy Salt
Morton Salt
Morton Chemical
Morton Salt and
Chemi cal-Combined
Discharge
Standard Lime and
Refractory
Dow Chemical
Hooker Chemical
Peak Loading
as of June 1971
(Ibs/day)
120,000
12,000
50,000
175,000
1,500,000
88,000 To
Pere Marquette Lake
1,970,000 To
Lake Michigan
221,000
Present Estimated
Loading
(Ibs/day)
30,000
12,000 ave.
19,000 max.
40,000
1,870,000
40,000
700,000
221,000
Planned Loading
Required by State
(Ibs/day)
30,000 max.
12,000 ave.
18,000 max.
22,800 max.
Above Limits Include
this discharge
1,127,000 by Sept. '72
307,600 by Dec. '73
380,000 max.
52,650 max.
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POSSIBLE METHODS OF CHLORIDE CONTROL
From Industrial Sources: Since a few large industries contributed
so much to the chloride problem, they were a logical choice on which
to focus for control. Primarily through in-plant controls, recycling
of process water and a different location for the ultimate disposal
chloride, these industries will have achieved about 60 percent
reduction in chloride load to the Lake between January 1971 and
June 1973. This reduction is in addition to some control negotiated
between the industries and Michigan prior to 1971.
Other industries can use similar methods of control. However,
because of increasing demands for better wastewater treatment,
chloride loadings may increase even with efforts to control them.
Physical-chemical methods of treatment increase chloride levels during
treatment in return for lower levels of more serious pollutants. There
is a trade-off between good control of these more important pollution
parameters and higher levels of chloride and other dissolved solids.
From Run-off: Another major cultural source of chloride is that amount
added to urban run-off through the use of highway de-icing salt. Data
supplied by Wisconsin indicates that the mean chloride concentration in
a river as it passes through an urban area may double due to run-off
containing the salt. However, there are no basin-wide estimates of the
chloride concentration in urban run-off.
Control of chloride in urban run-off seems to be a matter of
metering salt application to limit the amount applied to the minimum
necessary to de-ice the streets. Salt stockpiles may be centralized to
reduce the number of sites. The salt pile can be protected from rainwater
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and surface drainage. Retention basins can collect concentrated brine
that does manage to leave the salt loading areas.
While urban run-off may be a major source of chloride, storm water
treatment methods now being studied for use in controlling BOD and
nutrients probably should not be designed specifically to include
chloride treatment. The effects of BOD and nutrients are much more
serious than those of chloride. Since chloride is not biologically
degradable or removed from water by geological processes, it is more
logical to control its discharge by handling and use regulations
rather than through water treatment.
Ultimate Disposal: Ultimate disposal of chlorides remains a problem.
Even if brine waste is concentrated to reduce the volume of waste,
unless there is in-plant recovery the same amount of chloride is left.
Presently, deep well injection is being used for the brine wastes in
western Michigan. While EPA does not approve of deep well injection
as a generally acceptable method of ultimate disposal, in this case
returning the salt to a brine field area seems acceptable since there
have been assurances that underground contamination of existing fresh
water supplies will not occur.
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SUMMARY
The chloride level in Lake Michigan is not high enough at present
to interfere with use of the water. Although the rate of increase in
concentration appears to be more rapid than was previously predicted,
specific control of chlorides should generally be limited to the large
industrial sources, and to whatever extent possible, de-icing salt in
urban run-off.
After Michigan industries are brought into compliance with State
stipulations, EPA believes there will be significant improvement in
water quality near the points of discharge. However, the numerical
criteria for the States of Michigan and particularly Wisconsin are
substantially less restrictive than existing water quality. These
criteria should be lowered to bring them more in line with those of the
other States. The antidegradation statements included in the Federal-
State standards do serve to protect existing water quality.
Michigan, the State with the most significant chloride point
sources, has made a good effort at controlling these sources. The
average reduction in chloride discharge is expected to be 60% for the
period between January, 1971 and January, 1973.
Urban run-off, industrial waste; and waste treatment processes
continue to be most important sources of chloride. Certainly excess
applications of de-icing salt should be eliminated and better controls
initiated to protect against slug loads to receiving waters during wet
weather from salt storage. Large industiral sources may have to provide
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further treatment to remove chloride and IDS, and to this extent,
should be evaluated at a later date to determine if additional
controls will be necessary.
Control of chloride discharges in Lake Michigan is one of the
best methods available to limit the increase in IDS to protect the
water quality of the International Great Lakes.
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NOTES
1. Ownbey, C.R. and Willeke, Q.E., "Long Term Solids Build-up in Lake
Michigan Water." Pub. No. 13, Great Lakes Research Division, the
University of Michigan, 1965.
2. O'Connor, D.J., and Mueller, J.A., "A Water Quality Model of Chlorides
in Great Lakes." J. Am. Soc. Civ. Eng., San. Eng. Div., SA 4, Aug. 1970
p. 955.
3. Lake Erie Report, U.S. Dept. of Interior, Federal Water Pollution
Control Agency, Aug. 1968, p. 33.
4. Beeton, A.M., "Eutrophication of the Laurentian Great Lakes", The
University of Wisconsin Magazine Fall, 1970.
5. Copeland, R.H., and Ayers, J.C., "Trace Elements Distributions in
Water," Report by the Environmental Research Group, Inc. May 1972.
6. Federal Water Quality Administration, Lake Michigan Open Lake Cruise,
Summer 1970.
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i
1 G. Schenzel
2 MR. SCHENZEL: The third session of the Lake Michi-
3 gan Enforcement Conference asked the State conferees to submit
4 a list of all significant, identifiable chloride sources in
5 the basin, along with ideas for chloride control. The Federal
6 conferee was requested to provide a resume of State chloride
7 standards, an estimate of the present chloride level in the
8 lake and, in cooperation with the States, proposals for
9 chloride control at the fourth conference session.
10 This report followed the direction set by the
11 conference.
12 RELATIVE IMPORTANCE OF THE CHLORIDE PROBLEM
13 The chloride concentration in nearly all areas of
14 Lake Michigan is not high enough now to seriously interfere
15 with water use. In 1965, Ownbey and Willeke reported the
16 average chloride concentration to be 7 mg/1, predicting an
17 increase to 12 mg/1 by the year 2020.
13 If recent sampling data is representative of a
19 trend in chloride concentration, then the rate of chloride
20 increase in Lake Michigan is more rapid than predicted by
2i | Ownbey. Rather than the 7.5 mg/1 level predicted for 1970,
22 the concentration in that year, by actual survey, was close
to 10 mg/1. It is the conservative nature of chloride, along
with the long detention time for the lake that makes this
more rapid increase subject to our concern here today0
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1 G. Schenzel
2 TOTAL DISSOLVED SOLIDS AND CHLORIDE CONTROL
3 Chloride is important since it is a major component
4 of total dissolved solids (TDS) from man-made sources. In
5 addition, chloride serves as an indicator for TDS control.
6 Reduction of chloride from large point sources would also
7 reduce other ions which are part of TDS,
8 The United States and Canada have long been concerne^L
9 with deteriorating water quality in the international boundary
10 waters of the Great Lakes. Recently, the two countries signed
11 the "Great Lakes Water Quality Agreement" which defines
12 water quality objectives to protect and upgrade the water.
13 In signing this agreement, both countries recognized the need
14 to limit the buildup of TDS.
15 CHLORIDE SOURCES IN THE LAKE MICHIGAN BASIN
16 The conference requested the States to provide a
17 listing of all identifiable chloride sources of significance
IS in the Lake Michigan Basin. A discussion of this informa-
19 tion follows:
20 Wisconsin
21 Wisconsin submitted information on chloride concen-
22 trations in major tributaries of the State within the Lake
Michigan drainage basin for the winter months (December to
March, 1969 water year). From this data, EPA has calculated
the approximate yearly loading to the lake from these
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454
G. Schenzel
tributaries. The Fox River is by far the largest tributary
source from Wisconsin to Lake Michigan.
4 Illinois
5 The relatively minor chloride point sources in the
Illinois portion of the Lake Michigan drainage basin do not
appear to need immediate control from a chloride reduction
standpoint.
9 Michigan
10 Michigan reported direct and indirect point sources
11 plus the average loading from its tributaries to the lake.
12 On the basis of the figures given, the Michigan point sources
13 contribute over SO percent of the total chloride loading to
14 the lake as of June 1971. I would point out that this is a
15 correction from some of the copies that you may have. Since
16 that time, Michigan has started an extensive control program.
17 Indiana
There are some significant point sources from
19 Indiana. Several steel companies have, in the past few
20 years, controlled chloride discharges by deep well injection
21 of chloride containing pickling acid. However, the EPA
i
22 believes that further control is desirable.
23 TOTAL CHLORIDE LOADING TO LAKE MICHIGAN
24 The total chloride loading to the lake is approxi-
2 5 mately 2.4 billion pounds/year, with the most important
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3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
455
G. Schenzel
loadings coming from the brine area in western Michigan,
The loading figure is more than twice that used by
Ownbey, Clearly, the projections made in 1965 underestimated
the effect of industrial discharges.
WATER QUALITY STANDARDS AND THE AMBIENT LAKE
QUALITY TABLE B
The following is a listing of chloride standards,
State-by-State:
STATE CHLORIDE WATER QUALITY CRITERIA
Illinois Shall not exceed 12.0 mg/1.
Indiana Single value shall not exceed 15
(Lake Michigan) mg/1. Monthly average shall not
exceed 10 mg/1.
(Inner Harbor)
Michigan
Wisconsin
Single value shall not exceed 30
mg/1. Monthly average shall not
exceed 20 mg/1.
Desirable monthly average shall not
exceed 10 mg/1. Permissible monthly
average shall not exceed 50 mg/1
(measured at public water supply
intake).
No standard designed to limit
chloride. (Wisconsin does use the
PHS drinking water standard of "shall
not exceed 250 mg/1 in the drinking
water supply after treatment.")
All four States have antidegradation statements
which require water quality to be maintained at existing
levels.
The present lake values also indicate that the
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^ . 456
1 G. Schenzel
2 chloride level in Lake Michigan is increasing faster than had
3 ! been anticipated,
4 The major rationale for limiting chloride dischargee
5 is a desire to keep down the level of a potentially serious
6 pollutant. The numerical water quality standard criteria
7 should be set at a level near to the existing chloride level
8 in the lake.
9 EPA believes the chloride criteria for the States
10 of Michigan and particularly Wisconsin are set too far above
11 the existing concentration.
12 POSSIBLE METHODS OF CHLORIDE CONTROL
13 From Industrial Sources; Since a few large
14 Michigan industries contributed so much to the chloride
1$ problem, they were a logical choice on which to focus for
16 control. Primarily through in-plant controls, recycling of
17 j process water and a different location for the ultimate
disposal of chloride, these industries will have achieved
19 about 60 percent reduction in chloride load to the lake
20 between January 1971 and June 1973.
21 From Runoff: Another major cultural source of
||
22 chloride is that amount added to urban runoff through the
23 use of highway de-icing salt. Data supplied by Wisconsin
indicates that the mean chloride concentration in a river
as it passes through an urban area may double due to runoff
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^______ 457
1 G. Schenzel
2 containing the salt.
3 Control of chloride in urban runoff seems to be a
4 matter of metering salt application to limit the amount
5 applied to the minimum necessary to de-ice the streets. Salt
6 stockpiles may be centralized to reduce the number of sites.
7 The salt pile can be protected from rainwater and surface
g drainage. Retention basins can collect concentrated brine
9 that does manage to leave the salt loading areas.
10 Ultimate Disposal; Ultimate disposal of
11 chlorides remains a difficult problem. Presently, deep well
12 injection is being used for the brine wastes in western
13 Michigan. While EPA does not approve of deep well injection
14 as a generally acceptable method of ultimate disposal, in
15 this case, returning the salt to a brine field area seems
16 acceptable, since there have been assurances that under-
17 ground and surface contamination of existing freshwater
IB supplies will not occur.
19 Let me summarize this report by reiterating some
20 of its findings and conclusions.
21 The chloride level in Lake Michigan is not high
22 enough at present to interfere with use of the water.
23 Although the rate of increase in concentration appears to
24 be more rapid than was previously predicted, specific
25 control of chlorides should generally be limited to the large
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453
1 G. Schenzel
2 industrial sources, and to whatever extent possible, de-icing
3 salt in urban runoff.
4 After Michigan industries are brought into compli-
5 ance with State stipulations, EPA believes there will be
6 significant improvement in water quality near the points of
7 discharge. However, the numerical criteria for the States
8 of Michigan, and particularly Wisconsin, are substantially
9 less restrictive than existing water quality. These criteria
10 should be lowered to bring them more in line with those of
11 the other States. The antidegradation statements included
12 in the Federal-State standards do serve to protect existing
13 water quality, but tightening numerical criteria is
14 necessary to meet the intent of the antidegradation clause.
15 Michigan, the State with the most significant
16 chloride point sources, has made a good effort at controlling
17 these sources. The average reduction in chloride discharge
l^ is expected to be 60 percent for the period between January
19 1971 and January 1973.
20 Urban runoff, industrial waste and waste treatment
21 processes continue to be most important sources of chloride.
22 Certainly, excess applications of de-icing salt should be
eliminated and better controls initiated to protect against
slug loads to receiving waters during wet weather from salt
storage. Large industrial sources may have to provide
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3
4
5
6
7
9
10
11
12
1.3
14
15
16
17
19
20
21
22
23
24
25
459
G. Schenzel
further treatment to remove chloride and TDS, and, to this
extent, should be evaluated at a later date to determine
if additional controls will be necessary.
Control of chloride discharges in Lake Michigan is
one of the best methods available to limit the increase in
TDS to protect the water quality of the international
Great Lakes,
Mr. Chairman, this concludes my statement on the
Chloride Report.
MR. MAYO: Any comments or questions, gentlemen?
MR. PURDY: Mr. Chairman, on the Chloride Report
itself, on page 10 of the report, where it shows that the
Morton Salt Company has 19,000 pounds per day, this should
be recorded as prior to the operation of its injection system
The company's August 1971 report showed an average
chloride discharge of 57,300 pounds per day. The 19,000
pounds per day reported here is a load figure after com-
pletion of the injection system but before all of the
operating problems of that injection system were corrected.
So that its initial load was 57,000 pounds rather than
19,000.
And on page 11, for the Morton Salt Company,
that 12,000 pound peak June 1971 loading should be 57,300
pounds per day.
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460
1 G. Schenzel
2 Our operating report for Standard Lime and
3 Refractory for July of 1972, 1,555*000 pounds per day.
4 Yesterday, when I gave our report, I indicated
5 that the reduction at the end of 1973 would be an &0 per-
6 cent reduction. We are not in disagreement on this figure,
7 are we? You report 60 percent by June of 1973
g MR. SCHENZEL: I think it would be similar. If
9 we multiplied SO times $0, we are talking somewhere in the
10 60, 65 ~
11 MR. PURDY: This is total tributary as well as
12 point sources.
13 ME. SCHENZEL: Fine. I believe we are in agree-
14 ment there.
15 I might point out, Mr. Purdy, that we were
16 obviously communicating with your office in the development
17 of these figures that since that report has been prepared
IS there probably has been some updating on the figures based
19 on the operation.
20 MR. PURDY: From the standpoint of the standard,
21 when you are speaking of being substantially less restrictive
22 ! than the existing water quality, you are not talking about
23 the desirable monthly average shall not exceed 10 mg/1,
2A- you are talking about the permissible of 50.
25 MR. SCHENZEL: That is correct.
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5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
^___ 461
G. Schenzel
MR. MAYO: Mr. Miller.
MR. MILLER: Mr. Chairman, I think this is one of
the items that we should make very clear. That while
there are some terms used, such as recycling recycling
is not really going to reduce the amount of chlorides that
are discharged to Lake Michigan because, being an organic
chemical, when the water or waste is being recycled
once we reach equilibrium in the blowdown the amount
we put in each day is going to be in the blowdown, and it
will be discharged to the wastewater stream.
So that unless we come up with some method such
as Michigan has talked about in deep well disposal to pull
these out of the system entirely and put them in some other
place besides in the wastewater stream, we are not going to
be able to handle them and reduce the loads going to Lake
Michigan other than to eliminate the source of the chloride
entirely. In many instances, this will not be possible
to do, and I think that many people lose sight of this fact.
They use recycle as a possibility of reduction. But cer-
tainly the soluble salts, such as chlorides, are not going
to be reduced in the discharge to a watercourse by a
recycle system. And I think that we have this problem in
some of the industries that are listed in the table for
Indiana. Some of them are now on recycle systems and the
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1 G. Schenzel
2 amount of chloride that is reported there is the amount that
3 occurs from the daily amount contributed to the system which
4 must be removed to keep it in balance.
5 MR. BRISON: Mr. Purdy, can I ask you to give us
6 a brief description of the control program your companies
7 are using in terms of the deep well injection?
B MR. PURDY: Well, I think, in this case, we have
9 to understand the industry, and the fact that the brines
10 and the chlorides recently came from the ground. It is
11 not a process waste that generated the chlorides within
12 the process. And in this case the industry is taking a
13 brine solution out of the ground; they are removing bromine
14 and magnesium a form of hydroxide and then they have
15 the remaining tail brines at rather high concentrations,
16 that when properly separated within the plant, they can
17 then be returned to the underground for measurement,
18 In the Manistee area, we have some particular
i
19 problems in that there are a number of old holes in the
20 ground, plugging really unknown, so that we have to be
21 careful where we reinject those brines. But rather than a
22 i waste disposal process, we, in Michigan, are looking at
23 this as a conservation of our natural resources. And
those waste brines today are being returned to their original
storage location for future use if at some time in the
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1 G, Schenzel
2 future a use is found for those remaining brines as a
3 resource.
4 MR. MAYO: Is it practical to look forward,
5 sometime in the reasonable future, to virtually 100 percent
6 of that brine being returned to the ground?
7 MR. PURDY: I don't believe that we can look for
£ 100 percent, in that in the process certain dilution water
9 is added, and then you then have some high volume low
10 chloride waste, and that this high volume cannot be returned
11 to those ground formations without pressurizing the formation:;
12 to the extent that we may have contamination of potable water
13 supplies.
14 Certainly we are looking at the water concentra-
15 tion measures throughout the entire process, so that you
16 Can keep the tail brines in the concentrated form and can
17 return the maximum volume to the underground formation.
13 In fact, we have requested the industries and
19 they have cooperated in, say, joining together their brine
20 supply, where one industry may take only the bromine out
21 and not be interested in the other; that tail brine, then,
22 is sent on to the next industry for removal of the magnesium*
So that we only have one well rather than two wells.
24 MRa BRYSON: Are any additional controls planned
once the companies are in compliance with the stipulations
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1 G. Schenzel
2 you have with them now? For example, Dow's runs out December
3 1, 1972. Are you looking for additional controls past that
4 time?
5 MR. PURDY: Well, in view of, say, the total solids
6 problem, not necessarily in Lake Michigan, but in the entire
7 Great Lakes system Lake Erie, Lake Ontario I think it
8 behooves us to attempt to get our finger on every source
9 that we can and reduce it to the maximum extent possible,
10 When we reach our objective, why certainly I think
11 that there will be continuing review of plant operations,
12 evaluation of processes, and where possible additional
13 reductions will be made.
14 MR. MAYO: Mr. Schenzel, in the very first sentence
15 of the summary on page 14, the observation is made that:
16 "The chloride level in Lake Michigan is not high enough at
17 present to interfere with use of the water."
IB Harking back to a portion of Dr. Stoermer's com-
19 mentary yesterday, he at least reflected that there appeared
20 i to have been some significant shift in algal species in the
21 nearshore waters of Lake Michigan, perhaps as a consequence
22 [ of increase in chloride level. And I am wondering whether
23 any of the conferees perhaps Mr. Fetterolf would be
24 willing to make some observations on that point.
25 MR. FETTEROLF: I would be glad to observe that
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G. Schenzel
I see Dr. Powers out in the audience who might be able to
make a comment on that.
I have no comment, Mr. Mayo.
5 MR. MAYO: I don't want to press the issue. I did
6 want to at least recognize the fact that Dr. Stoermer did
7 make that reference, and I am wondering if it is worth any
8 discussion.
9 MR. FETTEROLF: The question is Stoermer referred
10 to a shift in algal species when there was an increase in
11 chloride levels accompanied by total dissolved solids
12 increases whether this current level of 6 to 12 mg/1
13 chloride is in that ballpark where you could look for
14 stimulation of algal growth, or whether the observed concen-
15 trations in Europe were much greater.
16 DR. POWERS: I am Charles Powers from the National
17 Eutrophication Research Program, EPA, Corvallis, Oregon.
Mr. Fetterolf, I think you have really called on
19 the wrong man this time because I am not a very good algal
20 physiologist.
Although I did take exception to some of the
22 interpretations that Dr. Stoermer to some of his obser-
^ vations yesterday I do have a great deal of respect for
him as an algal physiologist and taxonomistj and if he feels
that the present chloride levels in the lake are sufficient
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3
We do know that as nutrient levels increase in
c
9
10
11
12
13
14
15
16
17
19
20
21
22
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466
G. Sahenzel
to possibly bring about some percentages of increase, I
think that this might possibly be correct.
lakes not only chlorides but nutrients such as nitrogen
and phosphorus as they increase, we do know that different
forms of algae will become dominant. We are not really sure
why these changes occur, but as a lake becomes more eutrophic,
we do know that diatoms do not necessarily disappear, but we
know that the green and the blue-green algae will attempt to
appear in greater numbers; and, at various times of the
year, the blue-greens and the greens then become the dominant
forms, whereas previously the diatoms have been dominant
throughout the season.
We do know, however, that if one brings about
changes in these nutrient concentrations, that the algal
forms may change back again. I can think of one small lake
on which we have carried out some experiments in which
blue-green algae were very dominant. In fact, practically
nothing else grew. And I have had fun finding here recently
there is a precipitating cause of it. And as a result of
aerating the pond we were able to shift the algae from
blue-greens almost entirely to green algae.
I think that one should not feel that if the
chlorides have indeed brought about a shift in algal
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46?
1
2
3
4
5
6
7
12
'
20
G. Schenzel
species that it is necessarily an irreversible shift and
I am kind of weaseling here, but I think that is about all
I feel I am qualified to say.
MR. MAIO: Thank you.
Any other questions, gentlemen?
MR. McDONALD: Yes, Mr. Mayo.
Mr. Purdy, while those are going to be substantial
reductions by 1973 of chlorides, just some very rapid calcu-
lations indicate that you still have an enormous poundage
going into the lake in a relatively concentrated area in
Michigan. It looks like after your program is completed
you still have at the end of 1973 some roughly 300 million
pounds going in per year into the lake.
I am wondering whether, in view of the fact that
each of these companies is subject to the Refuse Act Permit
Program, as it now stands, and any legislation that is
currently pending in Congress regarding permits, which calls
° for, at first blush, the best practicable waste treatment
control currently available whether this is, in your
21
judgment, determination of the control program based on
22
these stipulations whether this would constitute the
23
best practicable control currently available.
24
25
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463
21
22
23
25
G. Schenzel
1
2 MR. PURDY: Well, these companies will come under
3 the agreement that we signed,on reviewing the Refuse Act
4 Program discharger permit requirements. And, at this point
5 in time, I can't say whether they will or will not come
within the guidelines that your Agency has put out for
7 this particular type of operation. As soon as they are
out, we will be reviewing this in accordance with our
9 agreement, and we will be proceeding to establish those
10 requirements in accordance with our
11 MRo McDONALD: Well, I'm not sure that these will
12 be out in the immediate future, and in accordance with the
13 agreement, if they are not out, we are going to have to
14 operate under the best premise, I think, jointly, of
\
15 determining maximum control of each of these companies.
16 MR. PURDY: Well, in accordance with our agreement,
17 if those guidelines do not appear for that particular
industry, we will be reviewing this process with your
i
19 !j people so that we are in agreement that they have, in fact,
i
20 j established the best practical control procedure.
MR. McDONALD: Let me ask you if you can tell us
what additional control techniques elimination techniques
are available beyond disposal?
24 || MR. PURDY: If I could answer that question, we
wouldn't have requested it as a part of this process
-------
^_ 469
1 G. Schenzel
2 other than evaporation or reverse osmosis, I don't have
3 really an answer.
4 MR, McDONALD: And these limits particularly
5 for Standard Lime Refractory and Dow Chemical were set on
6 what basis?
7 MR. PURDY: Looking at their process, grabbing
$ onto every gallon of concentrated brine that we could and
9 placing that back underground.
10 MR. McDONALD: And you are confident to squeeze
11 every bit of it you can.
12 MR. PURDY: At the present time, yes.
13 MR. MAYO: Any other questions?
14 MR. SCHENZEL: Mr. Chairman, I had one additional
15 question I would like to direct to the conferee from Illinois
16 I would like to emphasize the Table A on page 5,
17 and on Table A on page 5 request of the Illinois conferee:
IB Is there any additional industrial dischargers that he
19 feels should be placed on that list, or is the list now
20 complete as you see it there?
21 MR. BLASER: It is complete as we see it there.
22 "Domestic Waste Water" picks up several industrial sources,
23 and "Pettibone Creek" picks up several, and they are all
24 included there.
25 MR. SCHENZEL: Do you have any information on
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470
G. Schenzel
2 U.S. Steel (South Works), for example, which may be dis-
3 charging chloride that is finding its way into Lake Michigan?
4 MR. BLASER: To the best of our knowledge, it does
5 not. They are well on their way to a closed-cycle system,
6 and any discharges that they would have in the final
7 analysis out of that would go to the Metropolitan Sanitary
District.
9 ! MR. SCHENZEL: But they, in fact, could be dis-
10 charging but you are saying in the long-term of things they
11 will be eliminated?
12 ! MR* BLASER: That is right. They may be, but to
13 the best of our knowledge are not.
14 MR. MAYO: Any other comments or questions,
15 gentlemen?
16 MR. MILLER: Mr. Chairman, I do have one person
17 who would like to comment, if we are down to public com-
ments.
19 MR. MAYO: On chlorides?
20 MR,, MILLER: On chlorides.
i
21 I MR. MAYO: Yes. Do you want to introduce that
22 I
t-^ \ individual?
I
23 MR. MILLER: Do you want me to call them?
i
24 | I have Patricia O'Guin, of Valparaiso, who would
i
2 5 like to speak on chlorides.
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4
o
9 !
10
11
12
P. OsGuin
MR. MAYO: Would you please introduce yourself?
STATEMENT OF PATRICIA O'GUIN,
COMMITTEE TO PUBLICIZE CRISIS BIOLOGY,
INDIANA UNIVERSITY,
BLOOf.l.v . , INDIANA
MISS O'GUIN: My name is Patricia O'Guin. I am
representing the Committee to Publicize Crisis Biology from
Indiana University at Bloomington, Indiana.
Just to reiterate what EPA recommended to this
conference* the chloride report of the Environmental Pro-
tect: - > Agency to this conference outline -> the major reason
15 j! for xirgin-;, conv-rol of chloride discharges i. ^ -r ''-.: help
limit the o'.r""! clar of ^ntr/l Dissolved Solids (TDP'- in Lake
c; . .1?: '.."- %h" ; "i ~s i".ve , ii.
.). ."i,-.,, -tr much ia^r,. . ,
.if, . r,-L')iJ.jv L*-: CO;'.i-Hfj a if1 - */eni>\alj.y sur ou^ poi.o.u -ai^L
A \-jr ci'.":v' ui -T ' ' 'hlo ",de ic- that arrovr .
-------
10
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12
13
14
15
16
17
18
19
472
P. O'Guin
removed from water by geological processes, it is much more
logical to control the discharges through handling and use
regulations rather than through water treatment, EPA's
specific recommendations to the conference is stated in the
following words:
"Control of chloride in urban runoff seems to be
a matter of metering salt application to limit the amount
applied to the minimum necessary to de-ice the streets.
Salt stockpiles may be centralized to reduce the number of
sites. The salt pile can be protected from rainwater and
surface drainage. Retention basins can collect concentrated
brine that does manage to leave the salt-loading areas,"
In addition to these recommendations by EPA| I am
urging this conference to recommend the study of viable
alternatives to road de-icing salts for many reasons besides
reducing the Total Dissolved Solids in Lake Michigan,
In brief, the use of de-icing salt, which has
increased 1800 percent since 1940 according to the salt
20 manufacturers, is polluting our groundwater and aquifers;
21 i
killing trees, shrubs, and grasses; poisoning wildlife and
22 1 endangering persons with certain health conditionsj corrod-
23
24
25
ing cars, concrete, roads, and bridges; even producing a
new form of air pollution. And, the researchers say, the
effects of salt are cumulative a fact not realized before -
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^_____ 473
I P. O'Guin
2 and in some cases are already irreversible.
3 Furthermore, the two main arguments for salting
4 for snow and ice control, instead of sanding and plowing, can
5 be shown to be false. According to the National Safety
6 Council, accident statistics show that in 1969 only 2.4
7 percent of all fatal and 5 percent of all nonfatal accidents
3 occur under snow and ice conditions. There is instead a
9 direct correlation between dry pavement, increased speed of
10 travel and high accident rate: Si.6 percent of all fatal
11 and 75.6 percent of all nonfatal accidents occurred on dry
12 pavement in 1969. Accidents under snow and ice conditions
13 also tend to be fatal less often and are less expensive
14 "fender benders" in terms of repair. The "bare pavement
15 policy" should be replaced by a "public safety and mobility"
16 policy of plowing, sanding, and driver education and informa-
17 tion concerning winter driving conditions.
l£ It is questionable whether the use of heavy salting
19 and no sanding is economical. The town of Burlington,
20 Massachusetts, which banned salt, saved considerable money
21 by reverting to sanding and plowing only, in spite of in-
22 creased spring cleanup costs. True costs to taxpayers must
23 also include salt damage to cars, footwear, water supplies,
24 trees, pets, and property values.
25 Perhaps the most significant accident statistics
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474
1 P. O'Guin
2 are those regarding the salt ban in Burlington in 1970.
3 Although Burlington's population is 25,000, the city attracts
4 thousands of cars to its industries and the Burlington Mall.
5 Winn Street handles 22,000 cars daily in Burlington. In 1970,
6 with unsalted roads, Burlington's nonfatal accident rate went
7 down 4»7 percent, and its property damage accident rate
& decreased 2.1 percent over 19&9's figures for salted roads.
9 Newton, a nearby town with a traffic flow pattern equal to
10 that of Burlington, experienced a 14«1 percent increase in
11 nonfatal accidents, a 14 percent increase in property damage
12 accidents. Fatalities increased from 2 to 7. All of this
13 in spite of the fact that Newton continues to increase
14 salting to 9,^33 tons in 1970.
15 Groundwater pollution in Massachusetts has been
16 steadily increasing at the same time salt use has increased.
17 A chloride count of more than 250 ppm renders water unfit for
1$ human consumption according to the U.S. Department of Public
19 Health. Because of salt pollution of wells from roadway
20 de-icing salts, Burlington and many other cities in
21 Massachusetts have had to close wells and seek water else-
2^ where.
s*i o !
Salt damage to trees is also cumulative, and both
i
2L '
^ j sodium and chloride are responsible for the rise in maple
i
25
deaths in New England. Salt-injured trees show the same
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475
P. O'Guin
2 basic symptoms as drought-stricken trees: growth retardation,
3 marginal leaf scorch, twig dieback, and eventually death,
4 In addition to salt damages in corrosion of cars,
5 house siding, driveways, footwear, etc., there is evidence
6 that salt corrodes concrete, bridges, and underground pipe-
7 lines. Non-air-entrained concrete (less than 2 percent air)
deteriorates rapidly when road salts are used and usually
9 requires repairs after only two winters of use. Bridges are
10 especially susceptible to damage in the winter because both
11 the upper and lower sides are exposed, causing the bridge
12 deck to freeze faster than ordinary pavement. Ice accumu-
13 lates quicker and stays longer. As a result, more salt is
14 needed to keep bridges clear, and more deterioration occurs.
15 The structural steel embedded in the concrete on bridges is
made vulnerable once the concrete cracks. Often a bridge
17 has to be completely resurfaced after only 1 year.
Much of the previous data was taken from a study
prepared by Mrs. Carolyn L« Whittle of Newtonville, Massa-
20 chusetts, entitled "The Case Against the Use of Highway
21 De-icing Salts." Although the report was prepared specifi-
22 cally for the town of Newton, Massachusetts, it contains
' information that is applicable to any community.
2l* In light of these facts, we urge the States in
25
this conference recommend to their localities in the Lake
-------
476
P. O'Guin
Michigan Basin that they study:
1. just exactly how the use of road salt is con-
tributing to chloride loadings in their drainage systems;
2, what feasible means of controlling pollution
from road salts are available,
7 3. especially including the alternatives to the
use of de-icing road salts.
And that the States report on the results of studies
10 for their localities on these three points as well as any stepj
I
11 the localities have taken to reduce chloride pollution from
12 the use of de-icing salt to the next enforcement conference.
13 Thank you. (Applause)
14 |l MR. MAYO: Are there any questions, gentlemen?
j
15 MR. FRANGOS: Mr. Chairman.
MR. MAYO: Mr. Frangos,
MR. FRANGOS: Perhaps this might be an appropriate
time to hear a public statement on the reports that we just
heard this afternoon from Wisconsin.
20 l At this time, is Mrs. Dahl here?
21 | MR. MAYO: Would you introduce yourself, please?
22
23 |
24
25 I!
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6
7
MRS. DAHL: I am Miriam Dahl. I am from the
9
10
11
13
15
-i g
477
M. Dahl
STATEMENT OF MIRIAM G. DAHL,
WISCONSIN STATE DIVISION,
IZAAK WALTON LEAGUE OF AMERICA,
MILWAUKEE, WISCONSIN
Milwaukee area. I work in conservation with the Izaak Walton
League and represent the Clean Water Committee in the State
Division of Izaak Walton League.
I have asked to be heard today not because I want
to speak directly to any one of these things but because I
have what I would like to interject into this conference as
a possible change of approach from all of the multiple prob-
lems which have been outlined in the 2 days I have spent
listening.
May I say that, as are the doctors, we have been
" concerned with treating the results, not the causes. These
20
things are not written in your statement, they are additions
21
which I am making ad lib if you don't mind.
22 '
I would like to comment, as a preface, that we
23
spend hours, use countless miles of legislative gauze and
pi
millions of dollars mopping up the pus from the running
25
sores caused by our growing environment. It is time to look
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12
13
14
16
17
IB
19
20
21
M. Dahl
at the causes and to cut out the sources responsible for the
multiple affroni, to the health of our vital resources. It is
for that reason that I. should and for your courtesy
that I should like to give this thought to you for consider-
ation. It is possible that from these thoughts will come
some of the solutions which seem so far away at this point,
We ought to remember that waste disposal is not
new; it has been with us as long as man has existed. Concern
over these problems is not new either. The problem has just
grown like Topsy with the expansion of our economy as the push
for money led to waste of resources. The problem is not
local. It is regional and international as well, leaving
vast waterways full of debris of every description. Seeking
15 !| for solutions to this problem is likewise not new.
One of the first books was written by a Mr, Dahlberg
I believe his initials were G. L. it was written and
published in 1920. It is worth reading; it is worth rereading
It doesn't hurt us to go back to the past to see where we want
to point our trails into the future. 1920 is over a half
century ago that is 50 years and a goodly part of my
22 ' life.
3 I! Consistently ignoring the problem has not made it
or
go away. Now we are faced with a survival problem if it
continues. We insist on throwing mercury, PCB's, phosphates,
-------
479
1 M. Dahl
2 chlorides, sugars, every conceivable type of waste, into our
3 already overburdened waters. We threaten our own existence
4 by this practice of poisoning ourselves.
5 Traditionally our solution has been dilution. Now
6 we must think of new patterns of disposal and reuse of
7 materials. The method of disposal of any nonusable resource
8 can be on land as well as in the water. Reuse of phosphates,
9 for example, would be a benefit on land. It is a hazard in
10 the water. Chlorides can be replaced into the holes left by
11 its removal -- and this was just said. And perhaps in line
12 with that, at this point I might interject again that I
13 am acquainted, as I think you are, with the movement in Cedar
14 Rapids where the people there are faced with a pickle liquor
15 from a metals industry upstream and with the discharges from
16 the large Quaker Oats downstream. The Director of Public
17 Works decided to build a 10-mile I think it was 10-mile
IS pipe so that it connected the two, and the two were thereby
19 canceled out or neutralized,
20 These things certainly could be done here. Extra
21 chloride liquor from Michigan can be used with U.S. Steel.
There are many kinds of combining various chemicals so that
^ they can be neutralized. I am not a chemist. I wouldn't
2L I
know all of the answers. But as a housewife who has had to
? c
make do for many years, I do know there are ways if we will
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12
13
14
15
16
17
19
430
M. Dahl
find them. This is part of what I am asking you to do. Take
a new look at this kind of thing. Recycling has come of age
and we had better catch up with this idea before it runs away
from us.
In brief, let us, beginning now, work on the concept
of putting our wastes to work and using no I repeat, no -
waterways for disposal. This can be done if we will do it.
It can work if we will try it. It is a revolutionary thought
at this point, but all the tests applied result in a great
plus for the method.
We hope that this meeting of conferees will accept
this revolutionary method of disposal and work out the details
with dispatch so that the change can occur within the next
year to a recycling concept with disposal of wastes on land.
Nothing going into our waterways, everything possible being
used and used again, with final disposal of any wastes, which
should be minimal, going into repositories or landfills where
they can be used for some other purpose than their original
O f~\ \'
use when the time comes for that.
This may call for drastic overhaul of present
22 !
practices, laws regulating disposal, fines or alternatives
23
for noncompliance for industrial, municipal and individual,
24
25
but it will work if it is used. The alternative to this is
further and more intense pollution of water until we have the
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5
6
7
9
10
11
12
13
14
15
16
17
19
20
4&L
M. Dahl
problems of Europe, Asia and other international areas, or
worse. This can be solved on a regional or national basis,
but let us begin now.
Respectfully submitted, Miriam Dahl.
And, if I may, as an afterstatement, make this
suggestion to you, it seems that we are completely neglecting
one of our prime resources in this country our youth.
I know that there were young men, young women in
chemical research in their high school areas. One of them
found a breakdown method, with the approval of his teacher,
who didn't think that anything would come of it. But the
young man found a breakdown method for the hard chain deter-
gents. It never came to anything, but he found it.
Our youth are a veritable gold mine of ideas, of
the verve, the wish to go ahead. Why don't you invite them
into your conference? Why don't you send out into the schools
and suggest that these people do something of this sort of
work, or get the ideas from them? Why don't you have if
you want to a contest? But use those young ideas. This
is one of the ways in which you can move forward in a very
22
much more rapid manner than is possible from just sitting and
discussing this among one age group.
f\ \
And I do thank you.
25
MR. MAYO: Any comments or questions?
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7
8
10
11
12
13
14
15
16
17
IB
19
20
21
22
F. Mayo
We are at that point in the program where we had
hoped to be along about noon, and that was to give us an
opportunity to move into Executive Session to consider
recommendations relative to the material that has been
presented before the conferees up to this time.
As I mentioned this morning, our plan was to stop
sometime between 4:00 and 5s 00 o'clock. We are obliged to
leave this room no later than 5:00, and I would like to have
some sense of feeling from the conferees as to whether you
would like to move into Executive Session between now and 5iOO
in order to begin consideration of the recommendations, or
whether you would prefer to recess now and move into Executive
Session at &:30 tomorrow morning.
Any comments, gentlemen?
MR. BLASER: I would just as soon we commence an
Executive Session at 8:30 tomorrow morning, or earlier if
you want, rather than go on at this time.
MR. FRANCOS: Well, I think I would agree with
that, but I would like to get some feeling about the schedule
for tomorrow. And surely we are going to be very
crowded, and I am just wondering how available is this room
in the late hours of the afternoon tomorrow?
2L '
^ MR. MAYO: It is available tomorrow and Friday.
25 I
' n MR. FRANGOS: I didn't ask about Friday, Mr. Mayo.
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-I W. Blaser
2 (Laughter)
o MR. MAIO: I am being very concerned for Mrs. Hall
i and the consequences of running until almost 7:30 last night.
c I think we need to be alert to that as we proceed tomorrow.
£ One of the things we indicated doing earlier was
7 to look at the corrections in the Status of Compliance Report
$ material. I understand that Mr. Kee has that material avail-
o, able, and a review of it might be substantive to an Executive
10 Session.
11 MR. BLASER: Mr. Chairman, Illinois promised to
12 provide a revised list. If you recall yesterday, I described
13 that we had measured compliance against the Illinois dead-
14 lines rather than Lake Michigan Enforcement Conference dead-
15 lines. I have the full revised list available for all con-
16 ferees and anyone else who is interested.
17 (The documents above referred to follow in their
IB entirety.)
19 MR. BLASER: In addition, there are additional
20 I materials in there including a copy of our thermal regula-
21 tions. Further copies of thermal regulations will be at the
22 back desk on the way out.
23 (The document above referred to is on file at
24 U.S. EPA Headquarters, Washington, D. C., and Region V
25 Office, Chicago, Illinois.)
-------
September 19, 1972
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-------
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
LAKE MICHIGAN ENFORCEMENT CONFERENCE
FOURTH SESSION SEPTEMBER 19, 1972
The importance which Illinois places on maintaining high water quality in Lake
Michigan dates to the establishment of the Metropolitan Sanitary District of
Greater Chicago in May of 1889 and is brought current by the attitude of our
Pollution Control Board. In its opinion, which accompanies the Illinois Water
Pollution Regulations adopted March 7, 1972, they establish the principle that
Lake Michigan is a high quality water deserving of special protection. The
Metropolitan Sanitary District of Greater Chicago also has spoken to the
protection of Lake Michigan as witnessed in their Sewage and Waste Control
Ordinance, Appendix A wherein they state " except that no sewage, industrial
wastes or other wastes of any kind may be discharged into the waters of Lake
Michigan". In keeping with this Illinois doctrine to protect Lake Michigan,
the following action has been taken within the State of Illinois with respect
to the recommendations of the conferees of the Lake Michigan Enforcement Con-
ference originally convened March 1968.
1. Municipal Waste Treatment Within the Jurisdictional Boundaries of
the Metropolitan Sanitary District of Greater Chicago, there is no
discharge of municipal wastes to Lake Michigan. All of municipal
waste in the district is diverted for treatment and discharge into
the Illinois River Basin. The North Shore Sanitary District operates
the only municipal waste water treatment facilities which discharge
an average daily flew of 21.4 million gallons to Lake Michigan. These
facilities are located at Waukegan, North Chicago, Lake Forest, Lake
Bluff and Park Avenue, Ravine Drive, Gary Avenue in Highland Park.
-------
-2-
The North Shore Sanitary District is currently engaged in a 116
million dollar project to upgrade these facilities and divert the
effluent from the Lake Michigan Basin to the Des Plaines River
water shed. These projects were originally scheduled for completion
in July 1972 but due to extensive litigation completion is not ex-
pected until fall of 1974. In support of this project there has
been a total of 51.7 million dollars of State and Federal Grant
money offered to the North Shore Sanitary District. The Sanitary
District reports over 40 million dollars in construction work under
contract or already completed with an additional 21 million dollars
of construction work in the plan and specification stages.
Specifically for each.;plant -
A. Waukegan currently provides secondary treatment for only
about two-thirds of the average daily sewage flow. The remain-
ing one-third receives primary treatment and disinfection prior
to discharge to the Lake. These facilities, while currently
being upgraded, will not be complete by December 1972 and
therefore is not considered in compliance with the recommenda-
tions of the conferees.
B. North Chicago - This facility provides secondary treatment
and disinfection currently and is considered in cpmpliance.
C, Lake Forest - Is a primary treatment facility which will be
discontinued with the flows diverted to the upgraded Clavey
Road wastewater treatment facility. While construction on the
pump station, force main is nearing completion connection
cannot be made until the treatment facilities at Clavey Road
are upgraded. Completion is scheduled for 1974, in the mean-
-------
-3-
time this facility is considered not in compliance with the
Enforcement Conference requirements.
D. Lake Bluff - This is a primary treatment facility also to be
removed from service with wastewater being diverted to the
Clavey Road interceptor and wastewater treatment system.
Connection cannot be made until the Clavey Road facility is
complete in 1974 and therefore the facility is not considered
in compliance with the Conference requirements.
E. Park Avenue, Ravine Drive and Gary Avenue in Highland Park
are three primary treatment facilities all of which will be
discontinued with the flows diverted to the Clavey Road
treatment facility in 1974. In the meantime primary treatment
effluent continues to be discharged to Lake Michigan and is
considered not in compliance with the Conference recommendations.
Summarizing approximately half of the twenty-one million gallons per day
average flow tributary to the wastewater treatment facilities of the North
Shore1Sanitary District receives secondary treatment prior to discharge to Lake
Michigan. The remaining half receives only primary treatment and disinfection.
Upon completion of the North Shore Sanitary District projects there will be no
known source of municipal waste being discharged to Lake Michigan within the
jurisdictional boundaries of the State of Illinois.
2. Disinfection - All(^seven municipal wastewater treatment facilities
provide effluent disinfection prior to discharge to Lake Michigan
and are therefore considered in compliance with the Conference
recommendation.
3. Phosphorous Reduction - The recommendation of the Conference was for
80% reduction by December 1972. Our Pollution Control Board in a
matter identified as R 70-6 Phosphorous Water Standards established
-------
-4-
effluent standards of 1.0 mg/1 phosphorous as P for waste-,,
treatment facilities discharging to Lake Michigan. In response to
these requirements, North Shore Sanitary District has installed
phosphorous reduction facilities at its Waukegan facilities and
is in compliance currently with the 1.0 mg/1 standard. Equipment
is currently being installed at the remaining six wastewater
treatment facilities with operation scheduled prior to December
31, 1972. We therefore consider the wastewater treatment facili-
ties in Illinois to be in compliance with the recommendations of
the Enforcement Conference on the matter of phosphate reduction.
4. Combined Sewers - There are limited combined sewers within the
North Shore Sanitary District facilities which overflow to Lake
Michigan. At two sites Gillette Avenue and Water Street in
Waukegan screening devices with disinfection facilities are under
construction with completion anticipated prior to December 1974
and therefore in compliance with the recommendations of the
conferees. Due to extraneous flows in this sanitary sewers tri-
butary to the North Shore Sanitary District wastewater treatment
facilities, there are overflows at the treatment plant sites. These
overflows currently all receive disinfection. The North Shore
Sanitary District construction project will include provisions for
handling these extraneous flows. These facilities will be complete
prior to the conferees deadline of December 1977 and are therefore
in compliance with the Conference recommendations.
5. Industrial Wastes - Of the four industries discharging to Lake
Michigan within Illinois, three are in compliance with the recom-
mendations of the conferees to upgrade industrial wastewater
-------
-5-
treatment facilities. The Illinois Environmental Protection Agency
currently has an enforcement case pending against the fourth
industry. The industries considered to be in compliance are U.S.
Steel South Works, U.S. Steel Waukegan Works and Abbott Labora-
tories. The total average daily flow discharging to Lake Michigan
from these three facilities is approximately 180 million gallons.
The fan'iity cr-r-i^^yp.j to be not in compliance is the Fansteel
Metallurgical Corporation discharging an average daily flow of
2 million gallons. Therefore, more than ninety-eight and a half
percent of the industrial wastes discharging to Lake Michigan is
considered to be in compliance with the recommendations of the
Enforcement Conference. It should be noted however, that the
Illinois Water Pollution Regulations establish numerical values for
many chemical constituents. These values are more stringent than
the recommendation of the Conferees. Therefore, while the facilities
might be in compliance with the recommendations of the Lake Michi-
gan Enforcement Conference, it is conceivable that they are not
in accord with current Illinois recommendations. It should be noted
in the tabular Status of Compliance that Abbott Laboratory is
considering tertiary facilities and diversion to the North Shore
Sanitary District System; U. S. Steel Waukegan Works is currently
engaged in engineering studies to upgrade their facilities; and
U.S. Steel South Works is engaged in a project which will provide
for recycling most of the industrial waters.
-------
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D. Kee
2 MR. MAYO: Thank you, Mr. Blaser.
3 Mr. Kee.
4 MR. KEE: Thank you, Mr. Chairman. I might indi-
5 cate that Jim McDonald told me that I am going to keep doing
6 this until I get it right, so I beg your indulgence as we
7 go through it.
What I am going to do briefly is go over the
summary tables that I presented yesterday that summarized
10 the data on Status of Compliance. It has been updated by
11 the presentations made by the individual State conferees
12 yesterday and by our own Federal Activities Branch.
13 (The document above referred to follows in its
14 entirety.)
I'l
15 |i Beginning with Table 1, which is the summary of
i
16 the present status of phosphorus removal, for which there
17 were only a few changes-these include the deletion of one
i
18 | municipality which was erroneously listed for Indiana;
11
19 i that is, Whiting, Indiana, and the addition of two new
i
20 communities which Wisconsin added to their list, the
2i 'i Holland Sanitary District and Oconto Falls this table
i!
oo
';l is not changed other than for that fact.
il
f\ f\ I
3 ;j In Table 2, the summary of industrial waste con-
trol, the only change is the change in the Illinois
25
-------
LAKE MICHIGAN ENFORCEMENT CONFERENCE
REVISED TABLES
OF
STATUS OF COMPLIANCE REPORT
SEPTEMBER 20, 1972
-------
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-------
Supplement to Status of Compliance
Report - September 20, 1972
TABLE 6
LAKE MICHIGAN ENFORCEMENT CONFERENCE
ANTICIPATED PHOSPHORUS REMOVAL DEADLINE DELINQUENTS
ILLINOIS
None
INDIANA
Angola
Gary
Goshen
Hobart
Mishawaka
South BendUC
NOTE: This table is based
upon updated information
presented at the Conference
session on September 19,
1972. The list must be
considered as tentative
and subject to confirmation
after the December 1972
deadline date.
MICHIGAN
Albion
Allegan
Andrews University--UC
Berrien Springs
Bronson
Charlotte
Delphi Twp.
Dowagiac
Eaton Rapids
GladstoneUC
Grand HavenUC
Grand Ledge
GrandvilleUC
Hillsdale
Ionia
Iron Mountain
-Kingsford
Iron River
Lowell
Ludington-UC
Manistee
Manistique
Marshall
Mason
MenomineeUC
Michigan Reformatory
New Buffalo
Niles
Otsego
Paw PawUC
Plainwell
PortlandUC
South HavenUC
Spring LakeUC
Vicksburg
WyomingUC
Zee! andUC
WISCONSIN
DePere
Kewaunee
Portage
Holland Sanitary District
Oconto Falls
Shawano Lake San. District
FEDERAL INSTALLATIONS
Fort Sheridan
Great Lakes Naval Training
Center
UCUNDER CONSTRUCTION
-------
Supplement to Status of Compliance
Report - September 20, 1972
TABLE 7
LAKE MICHIGAN ENFORCEMENT CONFERENCE
ANTICIPATED PHOSPHORUS REMOVAL STATUS -
STATE
Illinois
Indiana
Michigan
Wisconsin
Federal
Installations
BASIN TOTAL
SUBJECT TO REQUIREMENT
Sources Served
Population
7 114,000
100%
17 579,000
100%
75 1,354,000
100%
45 1,840,000
2 45,000
100%
146 3,932,000
100%
DECEMBER 1972
ANTICIPATED TO BE
IN COMPLIANCE
Sources Served
Population
7 114,000
100%
11 161,000
29%
39 1,066,000
89%
39 1,800,000
98%
0 0
0%
97 3,141,000
80%
NOTE: This table is based upon updated
information presented at the Conference
session on September 19, 1972. The list
must be considered as tentative and
subject to confirmation after the
December 1972 deadline date.
-------
X D. Kee
2 dischargers: the addition of one to the "In Compliance"
listing, and a corresponding subtraction of one from the
"Behind Schedule" column.
5 MR. BLASER: Before you do that, may I interrupt?
6 This still doesn't reflect it accurately.
7 The document we have handed to you it should
show five subject requirements; four in compliance and one
9 behind compliance. That is Fansteel which is behind
10 schedule.
11 U.S. Steel at Waukegan should also show "In Com-
12 pliance."
13 The material we handed out just now revised that.
14 MR. KEE: Okay. I think if we turn to Table 3,
15 probably that would be more clearly indicated. What you
16 are indicating is that the U.S. Steel (Waukegan Works) in
17 the opinion of the State of Illinois and the South Works
both presently meet the adequate treatment requirements
19 established in 196$ by the conference.
20 MR. BLASER: By the conference, that is right;
21 not necessarily by the PCB regulations for the State.
22 MR. McDONALD: Well, I think that distinction, Mr.
Blaser, is very important, and that is they may meet the
conference requirements, which were not quantified at the
time as to the amount of reductions that had to take place;
-------
Supplement to Status of Compliance
Report - September 20, 1972
TABLE 7
LAKE MICHIGAN ENFORCEMENT CONFERENCE
ANTICIPATED PHOSPHORUS REMOVAL STATUS -
STATE
Illinois
Indiana
Michigan
Wisconsin
Federal
Installations
BASIN TOTAL
SUBJECT TO REQUIREMENT
Sources Served
Population
7 114,000
100%
17 579,000
100%
75 1,354,000
100%
45 1,840,000
2 45,000
100%
146 3,932,000
100%
DECEMBER 1972
ANTICIPATED TO BE
IN COMPLIANCE
Sources Served
Population
7 114,000
100%
11 161,000
29%
39 1,066,000
89%
39 1,800,000
98%
0 0
0%
97 3,141,000
80%
NOTE: This table is based upon updated
information presented at the Conference
session on September 19, 1972. The list
must be considered as tentative and
subject to confirmation after the
December 1972 deadline date.
-------
D. Kee
dischargers: the addition of one to the "In Compliance"
listing, and a corresponding subtraction of one from the
4 "Behind Schedule" column.
5 MR. BLASER: Before you do that, may I interrupt?
6 This still doesn't reflect it accurately*
7 The document we have handed to you it should
show five subject requirements; four in compliance and one
9 behind compliance. That is Fansteel which is behind
10 schedule.
11 U.S. Steel at Waukegan should also show "In Com-
12 pliance."
13 The material we handed out just now revised that.
14 MR. KEE: Okay. I think if we turn to Table 3»
15 probably that would be more clearly indicated. What you
16 are indicating is that the U.S. Steel (Waukegan Works) in
17 the opinion of the State of Illinois and the South Works
both presently meet the adequate treatment requirements
19 established in 1968 by the conference.
20 MR. BLASER: By the conference, that is right|
21 not necessarily by the PCB regulations for the State.
22 MR. McDONALD: Well, I think that distinction, Mr.
23 Blaser, is very important, and that is they may meet the
conference requirements, which were not quantified at the
2 ^ time as to the amount of reductions that had to take place;
-------
Supplement to Status of Compliance
Report - September 20, 1972
TABLE 7
LAKE MICHIGAN ENFORCEMENT CONFERENCE
ANTICIPATED PHOSPHORUS REMOVAL STATUS -
STATE
Illinois
Indiana
Michigan
Wisconsin
Federal
Installations
BASIN TOTAL
SUBJECT TO REQUIREMENT
Sources Served
Population
7 114,000
100%
17 579,000
100%
75 1,354,000
100%
45 1,840,000
2 45,000
100%
146 3,932,000
100%
DECEMBER 1972
ANTICIPATED TO BE
IN COMPLIANCE
Sources Served
Population
7 114,000
100%
11 161,000
29%
39 1,066,000
89%
39 1,800,000
98%
0 0
0%
97 3,141,000
80%
NOTE: This table is based upon updated
information presented at the Conference
session on September 19, 1972. The list
must be considered as tentative and
subject to confirmation after the
December 1972 deadline date.
-------
48$
1 D. Kee
2 dischargers: the addition of one to the "In Compliance"
listing, and a corresponding subtraction of one from the
4 "Behind Schedule" column.
5 MR. BLASER: Before you do that, may I interrupt?
6 This still doesn't reflect it accurately,
7 The document we have handed to you it should
show five subject requirements; four in compliance and one
9 behind compliance. That is Fansteel which is behind
10 schedule.
11 U.S. Steel at Waukegan should also show "In Com-
12 pliance."
13 The material we handed out just now revised that.
14 MR. KEE: Okay. I think if we turn to Table 3,
1$ probably that would be more clearly indicated. What you
16 are indicating is that the U.S. Steel (Waukegan Works) in
17 the opinion of the State of Illinois and the South Works
both presently meet the adequate treatment requirements
19 established in 1968 by the conference.
20 MR. BLASER: By the conference, that is right}
21 not necessarily by the PCB regulations for the State.
22 MR. McDONALD: Well, I think that distinction, Mr.
Blaser, is very important, and that is they may meet the
conference requirements, which were not quantified at the
time as to the amount of reductions that had to take place;
-------
436
1
2
3
4
5
6
7
a
9
10
11
12
13
14
16
17
19
21
D. Kee
neither were there effluent limitations. And what you are
saying is that the minimal conference requirements, by your
judgment
MR. BLASER: Substantially so, yes.
MR. McDONALD: However, this does not mean that
they meet the effluent limitations imposed upon them by the
State of Illinois.
MR. BLASER: Right.
MR. McDONALD: Or the Refuse Act Permit Program;
any limitation that may come out as a result of that.
MR. BLASER: Correct.
MR. KEE: There is an additional distinction, I
think, to be made here, Mr. McDonald, and that is the fact
15 i that it is my understanding that the recycling program at the
South Works has proceeded to the point that the north bank
of their blast furnaces has gone to complete recycling, and
that this is a substantive advancement. It is something that
is quantifiable. I am not sure in determining, within my
20 ii knowledge of the Waukegan Works, as to what exactly has been
done at the Waukegan Works to bring this discharger into
! compliance with even the adequate treatment require-
23
^ il ment.
i
O I '
I Maybe Carl would like to speak to that.
25 !
' MR. BLOMGREN: Mr. Kee, the Waukegan Works is
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currently now hauling 35,000 gallons a day of spent pickle
liquor and other wastes to the Gary Works for deep well
injection, and they have also been engaged for the last 4 or
5 years in extensive repiping internally to increase the
percentage of waste pickle liquor that is being hauled
away. It reduced their total pounds of iron that they dis-
charge from something like 9,600 pounds a day back in the
early sixties to a range of 100 pounds a day right now.
10 MR. KEE: Thank you, Carl.
11 On Table 4, the only change is the deletion of
12 Clintonville from the list of those who do not meet the dis-
13 infection or who are not presently providing disinfection.
14 Table 5» Summary of Combined Sewers Problem,
15 reflects the addition of 13 additional sources in the State
16 of Indiana added to the existing 2 that had been listed.
17 This raises the served population of affected sources con-
siderably in the overall listing.
19 MR. PURDI: Mr. Kee.
20 I MR. KEE: Yes, Mr. Purdy.
21 MR. PURDY: I reported yesterday the three for
Michigan does not represent the complete list. There will
be additions to thatc I can't tell you how many.
MR. KEE: Okay. Thank you.
MR. BLASER: As far as Illinois is concerned, on
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D. Kee
the combined sewer, both sources have facilities scheduled
for construction to meet the compliance date. They are not
currently in compliance but they are on schedule.
MR. KEE: Thank you.
Presently we have no interim dates the conference
doesn't so all we are faced with is determining"in compli-
ance" as opposed to not being in compliance.
Are there any more comments on any of the tables
up to this point?
I will move on to Table 6, where there is really
a very significant change. In fact the table has been changed
to reflect the information provided yesterday on anticipated
phosphorus removal deadline delinquents as opposed to the
earlier listing of those which were merely behind schedule.
And I think I should point out the note on this table, that
the table is based upon updated information presented yes-
terday, and that the list must be considered as tentative
and subject to confirmation after the December 1972 deadline
date, of course.
Then, Table 7 summarizes in statistical form the
information from Table 6, and it gives a breakdown, includ-
ing population, which is very important, because although some
of these lists look long, many of them are smaller communities
^ and the impact, of course, is not as great if you have many
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2 smaller communities off schedule than if you had had a few
3 larger communities. I think this is particularly shown in the
4 case of Michigan where although 39 communities are indicated
5 as likely to not meet the deadline, it is anticipated that a
6 full $9 percent of the population served will be in communi-
7 ties that have phosphorus removal facilities on line by the
3 deadline.
9 The basic control, coincidentally and I had no
10 control over this turned out to be BQ percent of the
11 population served will have facilities providing some level
12 of phosphorus removal by the deadline. I think it is impor-
13 tant to point out that that BO percent is completely unre-
14 lated to the SO percent of phosphorus removal requirement
15 and it just happened to be that way coincidentally.
16 But the fact is that, at the present time, a sig-
17 nificant proportion of the population is anticipated to have
1# phosphorus removal on line by the deadline date, and that is
19 a considerably different position than I gave yesterday when
20 I got up here with information based strictly on the matter
21 of whether or not the communities were behind schedule.
22 Of course, we have a lot of monitoring to do in
23 the next 3 months to make sure that this anticipated level
actually occurs and that will be one of the things that we
will be looking forward to doing in the next 3 months.
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MR. MAIO: Yesterday, you commented, Dave as I
understood the commentary from the two representatives from
4 I1 the Great Lakes Naval Training Station and Fort Sheridan, I
got the impression that interim phosphorus removal facilities
might not be available in at least one of them before the end
of the calendar year. Am I incorrect?
MR. KEE: I had the impression it was both of them
9 j' and I think that was confirmed by Don itfallgren. But there
10 !| is a meeting going on at Great Lakes with our technical
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representatives and representatives of both Fort Sheridan
and the Great Lakes Naval Training Center to try to expedite
this matter, and I hope that we will be able to see a change
in that situation.
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now, and that is that they indicated, I think, a June 1973
deadline, and we are going to try to get it turned around.
MR. MAYO: Thank you.
Any questions, gentlemen?
Before we actually recess, there has been a request
to explain how the Executive Sessions are handled at the
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' Enforcement Conference.
The Executive Sessions are such that they involve
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an interchange between the conferees to discuss the prepara-
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tion of conclusions and recommendations that will flow from
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the conference. The exchange is exclusively between the
conferees. The session will be in public. The public, how-
ever, will not be participating in the dialogue that takes
place between the conferees.
With that, we will recess to get together for an
Executive Session at $;30 tomorrow morning in this room.
(Whereupon, the conference adjourned at 4:35 p.m.)
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.S.Government Printing Office: 1974 751-197
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