PROCEEDINGS
Volume 2
Second Sessic
Minneapolis, Minnesoi
February 28, March 1 & 2O, 196
Conference
In the Matter off Pollution of the
Interstate and Intrastate Waters
off the Upper Mississippi River
and its Tributaries-Minnesota
and Wisconsin
U. S. Department of the Interior
Federal Water Pollution Control Administration
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CONTENTS
STATEMENT OP; PAQE
Lyle H. Smith, Conferee and Executive
Engineer, Minnesota Water Pollution
Control Commission (Continued) 315
Prank E. Hail, Federal Water Pollution
Control Administration, United States
Department of the Interior, Great
Lakes Region, Chicago, Illinois 387
City of Minneapolis, read by Gary Ginner,
Engineer, Minnesota Department of
Health 393
Arthur V. Dienhart, Manager of Engineering,
Northern States Power Company,
Minneapolis, Minnesota 398
Kerwin L. Mick, Chief Engineer and Super-
intendent, Minneapolis-St. Paul
Sanitary District, Minneapolis,
Minnesota 405
John P. Badalich, City Engineer, City of
South St. Paul, Minnesota 446
Cenex, Inc., read by G. Ginner 463
Otto Bonestroo, Consulting Engineer,
Village of Cottage Gove, Minnesota 465
Minnesota Mining and Manufacturing Company,
Chemolite Plant, Washington,
Minnesota, read by G. Ginner 469
Arnold Steffes, City Engineer, Hastings,
Minnesota 475
Rahr Malting Company, Minneapolis,
Minnesota, read by Donald J. Thimsen,
Minnesota Department of Health 485
Robert P. Hubbard, Assistant General
Superintendent, Cargill Corporation,
Minneapolis, Minnesota 489
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B
CONTENTS
(CONTINUED)
STATEMENT OP; PAGE
John J. Klein, Town Board of Supervisors,
Eagan Township, Dakota County, Minnesota 491
John M. Mason, North Suburban Sanitary
District 503
John G. Pidgeon, City Attorney, Bloomlngton,
Minnesota 520
City of Hopkins, Minnesota, read by D. J.
Thlmsen 533
Robert F. Peterson, Commissioner of Public
Works, St. Paul, Minnesota, read by
G. Ginner 535
Board of Water Commissioners, City of St.
Paul, read by D. J. Thimsen
Natural History Society, read by
G. Ginner
Mrs. William Whiting, President of the
League of Women Voters of Minnesota 545
John Pegors, Vice President, Clear Air,
Clear Water - Unlimited 615
Minnesota Conservation Federation, read
by D. J. Thirasen 6l8
Beaverbrook Sportsmen, Inc., read by
D. J. Thimsen 625
Thomas C. Savage, Vice President, Fort
Snelling State Park Association 629
First Unitarian Society of Minneapolis,
read by G. Ginner 631
Community Wild Life Club, Inc., St. Cloud,
Minnesota, read by G. Ginner 633
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CONTENTS
(CONTINUED)
STATEMENT OP: PAGE;
Sierra Club, Great Lakes Chapter, North
Star (Minnesota) Section, read by
D. J. Thlmsen 634
Northwest Airlines Sportsmen Association,
read by D. J. Thimsen 638
Arthur A. Ebert, President, Minnesota
Chapter, American Society of Sanitary
Engineering 641
Robbinsdale Sportsmens Club, Inc., read by
G. Ginner 649
Corps of Engineers, St. Paul, Minnesota,
read by William T. Sayers, Deputy
Project Director, Federal Water
Pollution Control Administration,
Twin Cities Project, Minneapolis,
Minnesota 651
Robert E. Scheible, Chief of Sanitary and
Electrical Engineering, Department of
the Army, Headquarters, Fifth United
States Army 655
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Second Session of the Conference in the Matter
of Pollution of the Interstate and Intrastate Waters of the
Upper Mississippi River and Its Tributaries in the States
of Wisconsin and Minnesota, convened at 9:00 a.m., on
Wednesday, March 1, 1967, at the Leamington Hotel, Minneapolis,
Minnesota.
PRESIDING:
Mr. Murray Stein, Assistant Commissioner
for Enforcement, Federal Water Pollution
Control Administration, Department of the
Interior.
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L. H. Smith
MR. STEIN: May we reconvene?
I would like to welcome all you people back.
Minnesota will continue.
I hope you all enjoyed yesterday. I do think,
though it nay not have been apparent, that we are getting
closer and closer together all the time with the conferees.
This is just the American process, I guess, of
arriving at conclusions. Sometimes it gets abrasive, but that
is the way we have always been, and if people didn't have firm
positions and didn't put them forward in that way, I don't
think we would make much progress.
With that, we will call on Minnesota again to
continue its presentation.
Mr. Smith?
CONTINUED STATEMENT OP LYLE H. SMITH,
CONFEREE AND EXECUTIVE ENGINEER, MINNESOTA
WATER POLLUTION CONTROL COMMISSION
MR. SMITH: Mr. Chairman, Conferees and Ladies
and Gentlemen:
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L. H. Smith
go into a review of the Federal recommenda-
tions, and these comments will follow the order of the recom-
mendations, if you care to refer to the summary, commencing
at the top of Page 27.
Under the General Recommendations, Protection
of Existing Water Quality:
The Commission agrees that there should be no
decrease in water quality. However, we would like to add,
"which could be detrimental to beneficial uses." Further
comments will be made later in my statement.
We feel that there was some discussion of this
yesterday and we feel that this should be clarified.
Under the paragraph of "Enhancement of Water
Quality," the Commission agrees that where water quality has
been unreasonably degraded by pollution, such water quality
should be enhanced to avoid interference with beneficial
uses. The uses given are essentially the same as specified
in some of the classifications already adopted by the Commis-
sion, although there is some change in the area.
In regard to the protection of water quality in
areas which are essentially in their natural condition, and
using as an example the dissolved oxygen levels set forth
in the table on Page 26 of the Summary, we believe that it
would be unreasonable to flatly prohibit any decrease of
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L. H. Smith
quality from present levels. In the final analysis, this
constitutes a zoning provision for all of the waters presently
of good quality and could prohibit any new municipal or
industrial effluents unless treated, so as to be virtually
equal to existing river water quality. We believe it would
be more desirable to use only a specific figure for the
dissolved oxygen and other characteristics which should be
maintained at non-pollutlonal levels, or to change the phrase
to read, "no unreasonable deterioration." The Commission
does not object to the use of standards which include a pro-
hibition on discharges where warranted by circumstances, but
we do not agree that it is appropriate to apply such standards
arbitrarily and indiscriminately to a stream resource,,,such as
dissolved oxygen, where it apparently has no rational basis
and will only prevent future development of the area without
regard to needed economic growth of the State.
We feel some clarification also is necessary con-
cerning the river flows upon which the oxygen levels are
based since the report recommends changing both from the
levels specified in the standards already adopted by the
Commission for certain reaches of these rivers. From our
evaluation, it appears that the Federal standards will not
enhance the quality of the reaches now affected by pollution,
but will in fact permit more degradation than is now allowed
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L. H. Smith
by the existing State standards. We do not have the staff
or access to the use of computers to confirm this in detail,
taking into account all possible variables, but it seems
quite certain that, for example, under the proposed Federal
dissolved oxygen recommendations of 3 mg/1 to be maintained in
the river below the Twin Cities at the 7-consecutive-day,
once-in-10-year low flow, more pounds of BOD could be dis-
charged to the river than under the existing State standard,
which requires 1 mg/1 to be maintained at the much lower
minimum daily flow occurring once in 20 years. We believe
the relaxation of the flow interval will more than offset the
apparently more stringent dissolved oxygen concentration. We
would appreciate having this matter resolved by the technical
staff of the Federal Water Pollution Control Administration
for the enlightenment of the conferees. If this cannot be
done today, we request that the matter of the dissolved
oxygen standards be left open until it can be resolved to
the satisfaction of those concerned.
The coliform standards recommended in the Federal
report are endorsed in full. They are virtually identical
with the standards the Commission has proposed for inclusion
in its Statewide water quality criteria.
The next paragraph is under "Treatment of Munici-
pal Wastes. This waa discussed In some detail yesterday.
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L. H. Smith
This recommendation requires that all munici-
palities and other Institutions which discharge sewage to
these waters provide at least secondary biological treatment
and continuous disinfection of the effluent. As a matter of
record, this has been the policy of the Commission for these
waters for many years and with very few exceptions such
treatment works have already been provided. We concur fully
with this recommendation, except for the manner In which
secondary treatment Is defined. We believe the recommendation
should not specify the percentage of treatment to be provided
for BOD and suspended solids reduction, but should Instead
specify allowable effluent concentrations.
This matter is part of the very foundation of
Minnesota's water pollution control program, and this Federal
recommendation Is a prime example of the lack of consideration
given to working with and supporting the policies of the State
agencies in these matters.
We must take very strong exception to this part
of the recommendation, and the related one regarding treatment
of industrial wastes where the principle of equal percentage
of treatment also is applied rather than the equal effluent
principle. The Federal Water Pollution Control Administra-
tion has been fully aware of the position of the Commission
on this matter for some time, because of the similar contro-
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L. H. Smith
versy which arose at the Red River of the North conference
in September 1965.
The definition set forth in this general recom-
mendation has no bearing directly on protection of water uses
or quality, but instead it would establish a policy regarding
the allocation of BOD discharges between various sources. As
such, it should have no place in these recommendations, since
it is not within the province of the Federal agency to allo-
cate the ass foliation capacity of these streams among the
various pollutlonal sources. Promulgation of this policy was
also suggested previously by the Administration on the Red
River of the North, although in a different guise, but after
much argument the matter was finally resolved in the Commis-
sion's favor. Resource allocations of this type are a State
responsibility and this recommendation is directly contrary
to the established policy of the Commission, which is to re-
quire all pollutlonal sources in a designated reach of river
to produce effluents of equal concentration. The policy is
of long standing and is based on an opinion of the Attorney
General which was requested by the State Board of Health
shortly after the Minneapolis-St. Paul Sanitary District was
originally established in the 1930«s by the State Legislature.
This very point of equal effluents versus percentage removal
was then at issue. Since being resolved in favor of equal
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L. H. Smith
effluents, this approach has always been Incorporated in
the programs and policies of the State pollution control
agency, first by the State Board of Health and later by the
Water Pollution Control Commission.
It is the contention of the Co»nission that such
a specific policy statement should be deleted and replaced
with a general statement to the effect that the allocation
of the assimilative capacity of the streams shall be done by
the States within the context of their established laws and
policies, and/or changed to a definition of secondary treat-
ment based only on effluent concentration. On the basis of
its own experience, covering more than twenty years in dealing
with pollution problems in Minnesota, the Commission believes
the equal effluent principle to be Just and simple of
application, and would not support any change In this policy.
We reiterate that we have no disagreement with
the stated allowable pounds of BOD which may be discharged to
the river from the aggregate of all of the sources, which is
the essential consideration as far as effect on water quality
is concerned. Our disagreement is with the proposed alloca-
tion. The latter lies solely within the Jurisdiction and
responsibility of the Commission and should, therefore, be
handled in accord with its policies.
The next paragraph deals with Reports on Municipal
Treatment plants.
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L. H. Smith
We are in accord with this recommendation. A
similar requirement is normally incorporated as a part of
standards adopted by the Commission.
MR. STEIN: Mr. Smith, this is a technical opera-
tion.
For the purpose of the record, I think it may be
clearer for people who read this, that if we are going to
have comment, to have some short comment here.
I think with reference to your first point on
the dissolved oxygen, this is the kind of technical operation
that we may have to turn over to a technical group to work
out.
I do not think there is any difference in what
we want to achieve here, and I think the challenge is to get
a formula that we can all agree With.
I think your points are well taken. I don't think
the Federal Government would want to take any view on this
without also getting the advice of the technical people from
Wisconsin, and, of course, we will, as we may have to here,
get some very specialized experts to work with you on this
information and get these worked out.
I Just want to flag that at this point in the
record, to aay that that point is well taken and we can look
at that.
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L. H. Smith
With reference to the next point you make on
the allocations within Minnesota, I would agree that this is
a State natter. However, the problem that we are faced
with here in the enforcement stage, or in the standard opera-
tion, la that there has to be a pretty full disclosure of what
the State is going to do for the allocation.
This is again a problem we have, where everyone
is providing treatment. I think Detroit would probably be
the best example to get away from here for the moment.
When we went out to Detroit, we found the river
pretty badly polluted. Then we went around to each industry
and city, and they all said they were providing fine treat-
ment. The question was, who was polluting the stream? Well,
we had to go through industry by Industry, and, of course, you
get the major automobile companies there, for example, and one
of the big four was doing fine, but the other ones we thought
were pretty bad and they had to be corrected.
I think we are going to wind up the same way here.
If we are going to protect the stream and we are going to find
out who is not going to do the job, the allocation must be
something, and I think once the State gives you that, this
could be adopted by the Federal Government, because the
Federal Government has the obligation, as I read our law, if
there is a violation after June 30th, to proceed against an
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L. H. Smith
individual polluter.
Unless we know what the allocation is, this
would make it not very equitable, and unless the State gives
us this allocation, we are going to be faced with the posi-
tion of having to do this ourselves.
Now, I think in the Red River of the North we
could work this out, and arrive, just as we arrived here, at
loadings which could go into the river, and the State and
we agree on the loadings.
Then we cane up with allocations for the Minne-
sota Industries and municipalities. I don't know whether
they liked it or didn't like it, but they thought it was
their prerogative to establish, and we said fine. They cane
up with those. As far as I know, this is satisfactory.
Again, this is a fundamental issue, but I think
we are going to have to have those rather shortly, Mr. Smith.
MR. SMITH: Well, we would be glad to work this
out with you in executive session.
MR. STEIN: Right.
MR. SMITH: I an sure we can.
MR. STEIN: Right.
MR. SMITH: May I go on?
MR. STEIN: Yes.
MR. SMITH: Paragraph 5 on Phosphate Renoval:
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L. H. Smith
The Commission agrees that all practicable
design and operation methods should oe used to remove phos-
phorus from the sewage and waste effluents.
No. 6, Monitoring of Water Quality.
We are in accord with this recommendation. The
Commission has had for many years a Statewide Water Quality
Sampling Program and has cooperated in the installation and
operation of several of the Water Pollution Surveillance
System stations in Minnesota. We shall be pleased to cooperate
within the limits of our resources in expanding our monitoring
program in this area.
No. lt Bypassing and Spilling of Wastes.
We are in agreement with this recommendation and
are confident that the current program of the Minneapolis-
St. Paul Sanitary District will substantially reduce this
problem in this area.
No. 8, Pretreatment of Wastes.
We are in agreement with this recommendation inso-
far as it is necessary to avoid interference with treatment
works or effluent quality control.
No. 9, Protection Against Spillage.
The agreement of the Water Pollution Control
Commission is exemplified by the adoption of Regulation WPC-4
relating to storage of oil and other liquid substances
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L. H. Smith
capable of polluting waters of the State, which to our
knowledge when adopted was probably one of the first of its
kind in the Nation. For the conferees' information, a copy
of this regulation is presented as Exhibit 1.
Paragraph 10, Combination Storm and Sanitary
Sewers.
The Commission is in accord with this recommenda-
tion and calls attention to the point that it does not ordi-
narily approve plans for combined sewers or extensions of
combined sewers. The recommendation for expansion of the
studies by the Minneapolis-St. Paul Sanitary District and
initiation of studies by South St. Paul is welcomed. Similar
recommendations were made at the time of the public hearings
which were held by the Commission in 1962 prior to adopting
standards for these waters.
I am sure the cities of Minneapolis and St. Paul
have statements which will indicate what progress they have
made in the separation of sewers.
Paragraph 11, Treatment of Industrial Wastes.
The Commission again here takes the same stand
that it had taken —
MR. STEIN: Mr. Smith, I want a point of clari-
fication.
What do you mean you don't ordinarily approve
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L. H. Smith
plans for combined sewers? Do you do this in extraordinary
circumstances?
MR. SMITH: There may be an exception where, for
a short period of time, a larger sewer may be used for both
purposes, which may later be used for sort of more sanitary —
this is very short.
MR. STEIN: This is just temporary?
MR. SMITH: That's all.
MR. STEIN: All right. Thank you.
MR. SMITH: Paragraph 11, Treatment of Industrial
Wastes.
The Commission does not agree with the use of
percentage as a definition of treatment. The same comments
made concerning treatment of municipal wastes apply in general
also to this recommendation. It is further pointed out that
basin industrial waste treatment on the raw waste means that
the base must be individually determined in each case, and,
further, will encourage industry to raise the raw waste
strength as high as possible in order to permit a high efflu-
ent concentration.
Consideration should be given to eliminating the
coliform requirements for Industrial wastes which are free
of sanitary sewage, unless the presence of pathogenic
organisms can be demonstrated.
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L. H. Smith
I believe there was a discussion yesterday, and
this was to be clarified.
Paragraph No. 12, Reporting of Industrial Wastes.
The comments made concerning reports by municipal
waste treatment plants apply to this recommendation also.
Such reporting is already being done by most of the major
plants.
MR. STEIN: Again, Mr. Smith, I think in the
Interests of saving time, we need some clarification.
On the question of chlorination of industrial
effluents, I think the recommendation was clear. Did you
come to an agreement in the Red River of the North on that
issue?
MR. SMITH: I don't recall that we did.
MR. STEIN: Are you going to chlorinate the
effluent?
I think Mr. Oeldreich is here and he has seen
that paper.
Now, basically, this is a fundamental issue that
is going to have to be considered by both States. It is
covered in the recommendation here. I don't want to go into
a long discussion, but I think you have raised this issue and
we have to consider this in the light of the industry
representatives who are here, and we may as well look at this,
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L. H. Smith
In the effluent from industrial plants, and we
found these particularly in potato wastes, pulp and paper
wastes and sugar beet wastes, there is a significant amount,
according to our bacteriologists, of pathogenic organisms,
even though sewage is not connected with it. That indicates
that these waste sources have to be disinfected before they
are discharged into the stream.
Now, I think if you want to do this, and this is
a technical point, we have Mr. Geldreich, the bacteriologist,
here.
This is a concept which is relatively new in waste
treatment and hasn't been paid too much attention to before.
The question was, why chlorinate and disinfect an effluent
from a plant processing organic material if it didn't come
into contact with sewage or domestic wastes of some kind?
Our scientists indicate that there are enough
disease-bearing organisms and they indicate that this should
be the procedure.
I think the conferees will have to deal with that.
If we need any further clarification before the conference is
finished, or before we are completed today, or whenever you
wish, or if the conferees want to ask Mr. Geldreich questions
on this as to the basis for the conclusions of our technical
staff, we remain ready; but this will be a very key question,
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L. H. Smith
it seems to me, that has to be resolved.
Thank you.
MR. SMITH: No, 13, Vessel Wastes.
The Commission agrees that this recommendation
is proper and presents as Exhibits 2, 3 and 4 copies of
Minnesota Statutes, Section 361.29, as amended, and related
criteria for the acceptability of marine sewage treatment
devices, and list of currently accepted devices.
The Commission has been a leader in this field
for many years, as you are no doubt aware. Based on our
experience, however, we do not believe it is realistic to
expect a State to exert control over watercraft not licensed
in that State, particularly in the continuing absence of any
Federal guidelines to promote uniformity among the States.
It is recommended that control over foreign shipping, and
Federally registered or documented craft preferably be
exercised by the responsible Federal agencies rather than the
States.
No. 14, Garbage and Refuse Dumps.
The Commission agrees in substance and offers as
Exhibit 5 a staff memorandum on water pollution control
practices relating to dumps, deposits and stockpiles dated
December 16, 1965. Solid wastes are also normally controlled
by standards adopted by the Commission. The question is
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L. H. Smith
raised, however, as to whether there may not be more reason-
able alternatives than removal of the contents of existing
dumps.
I am not sure whether this refers to dumps right
on the river bank where waterial can very easily be carried
in, or whether they are referring to dumps in the flood plain.
No. 15* Upstream Bacterial Control.
The Commission agrees with the recommendation
insofar as it relates to control of bacteria originating from
sewage or other disease-producing effluents. The Commission's
policy is that tributary waters and sources thereon be con-
trolled as necessary so that there will be no violation of
the standards of classified waters in any respect by reason
of such tributary discharges.
I would like to refer next to the specific
recommendations. These are contained, starting on Page 30.
Municipal Sources
Minneapolis-St. Paul Sanitary District to South
St. Paul — Maximum BOD and Suspended Solids Loadings.
The BOD loading of 68,500 pounds used in this
recommendation is based on river assimilation analysis and
intended to maintain the 3 mg/1 dissolved oxygen specified
earlier. As discussed previously, we feel that our existing
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L. H. Smith
design standards of I mg/1 of dissolved oxygen at a lower
base river flow would provide better water quality conditions
at the river flows used by the Administration than these
standards would.
The derivation of the 85*000 pounds of suspended
Boi-Laa IS UtH;X»»:r, l»uV poSSlbly WAS Calculated OH the SaBC
base as reaoval of BOD by 80 percent secondary treatment,
thus resulting in an effluent concentration of 50 mg/1. This
seems rather high for a modern secondary sewage plant efflu-
ent. The Commission has in the past used the figure of 30 mg/1
as being reasonably attainable by a well designed and operated
secondary treatment plant*
Mo. 2, which is on the top of Page 31, Maximum
Phenolic Loadings.
It is believed that with the extensive treatment
works already provided or under construction by most of these
sources there will be no serious difficulty in producing the
desired effluent quality, but we do question the justifica-
tion for changing the stream standard for this reach from the
existing 0.1 to 0.01 mg/1.
Ho. 3, By-passing at Minneapolis-St. Paul Sanitary
District.
We concur with this recommendation and as stated
previously are hopeful that recent construction will
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L. H. Smith
substantially reduce this problem.
MR. POSTON: Mr. Smith?
MR. SMITH: Yes, sir.
MR. POSTON: I note that you object to our use
of 50 milligrams per liter, but you say that the Commission
has in the past used a figure of 3© milligrams as being
reasonably attainable by a well designed and operated
secondary plant.
MR. SMITH: This is true.
MR. POSTON: Bhder your item earlier in the
report, you called attention to the fact that Hastings and —
was it Lake City?
MR. SMITH: That's right.
MR. POSTON: — have new plants, which will pro-
duce an effluent with 50. These are not yet under completion?
MR. SMITH: These are not completed. This is
right. These were gotten before the classification and the
standards. These are not in the classified section of the
river, and there may have to be steps taken to improve this.
MR. POSTON: You may what?
MR. SMITH: There may have to be steps taken to
improve this.
MR. POSTON: All right. Thank you.
MR. SMITH: The next paragraph is relative to the
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L. H. Smith
Hastings Plant.
Here again, the efficiency of the plant as deter-
mined by the Project staff was certainly well below design
levels and possibly was not representative of usual condi-
tions. The reasons for the poor showing, beyond simple
volumetric overloading, are not given, but we believe the
efficiency can probably be Increased in the interim before
the planned secondary treatment works are completed. In view
of the existing volumetric overloading, however, it is doubt-
ful that the indicated 30 percent efficiency can be attained.
There are still some industrial wastes going into
this primary treatment plant, and we feel whether we can
actually reach the 30 percent may be a question.
Under Industrial Sources-, Water Treatment Plants
of the City of Minneapolis:
We would like to know the basis for the 50 rag/l
concentration of suspended solids, as mentioned previously.
We are not aware of any other comparable sources of effluent
on this reach, but if It is based on comparison with the
capability of a modern secondary sewage treatment plant, it
might more properly be 30 mg/1, rather than 50.
Under Swift and Company, Armour and Company, and
South St. Paul Union Stockyards:
We do not object to this recommendation per se,
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L. H. Smith
but would like to point out that several of these outfalls
are submerged and may be very difficult to monitor and would
also call attention again to our previous comments concerning
conforms in Industrial effluents.
MR. STEIN: You certainly don't mean that when
you are talking about conforms. I can understand this from
sugar beets, that there might be a question, or from pulp and
paper mills, from potato plants. This is new and this is what
Mr. Geldreich referred to where he thought we should disinfect
this, but I never heard anyone ever come up with the notion
that we treat wastes from packing house plants of warm-
blooded animals different than the manner in which we treat
wastes from humans.
MR. SMITH: This is not implied, but there are
many sewers and some of these sewers may not contain patho-
genic organisms.
MR. STEIN: That may be, but the operation is
with Swift and Company, Armour and Company, and South St. Paul
Union Stockyards.
MR. SMITH: This is right, and wherever pathogenic
organisms are demonstrated there will be no question, but we
feel there are some of these where they may not be.
MR. STEIN: All right.
MR. SMITH: Northwest Cooperative Mills (now
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L. H. Smith
Cenex Inc.).
The comments made before regarding suspended
solids apply here also.
Foot Tanning Company.
This plant does not discharge to the Mississippi
River nor affect the Mississippi River, and should therefore
not be included. However, further treatment is necessary
and studies to that end are progressing. It is not clear to
ua what is meant by "in conformity with recommendations in
this report." A primary clarifier to replace the existing
settling ponds has been recommended, but to our knowledge
plans have not been prepared, presumably because questions
concerning further treatment have not yet been resolved.
Mayor Jelatis is here and could enlighten us on
this, if you would care for him to do so.
Specific Recommendations for the Minnesota River.
Green GUant Company.
The Commission is in agreement, but would recom-
mend that all sanitary sewage be diverted into the municipal
system for treatment.
American Crystal Sugar Company and Rahr Malting
Company.
The BOD loadings were based on river assimilation
studies and we have no disagreement with the permissible
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L. H. Smith
pounds of BOD. The policy of the Commission is to permit
no discharge under ice cover of waste exceeding the common
level for all sources in this reach. The sugar company has
already constructed a closed system for process wastes and
segregated the cooling water. When operating as designed,
this system should drastically reduce the BOD discharge.
These facilities were in operation this winter, but some im-
provements may yet be necessary to attain full efficiency.
MR. STEIN: At this point, I would like to take
this opportunity to say that if this is done the American
Crystal Sugar Company will be showing the way, and this has
been one of the great Improvements we have had through the
country in waste treatment methods dealing with sugar beet
wastes.
To give you a notion, it wasn't ten years ago
before we were striving to g«-t down to 12 pounds of BOD per
ton of beets, and then we finally got it down to 8. Then, when
we found t-hat that was too high, we tried to get these mills
to go down to 2. They said that was impossible.
Then they recently have come up with this closed
circuit operation, and we feel that the loading may get down
to a half a pound per ton of beets.
I think the American Crystal Sugar Company should
be commended for going ahead with this and showing the way as
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L. H. Smith
one of the plants that is going to do this Job. We hope that
this process will be incorporated in almost all the sugar
beet plants in the country, and it is really gratifying to
see that the company in this area has been one of the first
to install that in this country.
MR. SMITH: Northern States Power Company, Black-
dog Plant.
The derivation of the 90°P limit at 1,500 cfs
river flow is not known, but it appears to us that the 93°P
limit at the much lower flow specified in our standards would
provide ample and probably better control of heat releases.
Q
The question is, does the recommendation mean that 13.5 X 10
BTU/day is permissible for discharge to the river at all flows
less than 1,5OO cfs? We would also appreciate receiving the
comments of the Administration staff as to what in their
opinion would constitute a reasonable mixing zone for purposes
of monitoring the 90°p limit recommended for the river.
These are all of the comments that we have for
this particular section.
We would like to comment on the implementation
and enforcement of the final conference recommendations as
they are shaped.
Following is a brief statement of what this study
appears to mean to us and how we propose to proceed to carry
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L. H. Smith
out the recommendations.
On all those natters upon which there is sub-
stantial agreement, the Commission will proceed immediately
within its available resources and authority, without awaiting
the formal recommendations. For example, some enlargement
of our stream monitoring program can probably be undertaken
without delay, although for the long term more money and staff
will have to be provided by the Legislature. Also, a con-
certed effort will be made to review the situation with each
of the pollutional sources involved and attempt to persuade
them to comply promptly with the stated objectives on a
voluntary basis and with a minimum of legal action.
As is well known, some of the waters have already
been classified and have had standards established, and permits
have been issued for many of the sources. In some of these
cases voluntary action may be forthcoming; if not, legal action
will be authorized where applicable for violation and/or per-
mit requirements. Stipulations will be sought from the
various sources wherever these can serve the purpose of
obtaining compliance and avoiding further legal proceedings.
In order to comply with Minnesota laws, however,
and to assure a sound basis for possible revocation of per-
mits and/or Issuance of orders upon any recalcitrant sources,
it will be necessary for us to amend our existing classified-
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L. H. Smith
tions and standards for these waters, and also adopt classi-
fications and standards for the presently unclassified waters.
This we will promptly proceed to do, based on the Project
studies, the Commission's files and conference recommendations.
We strongly urge, therefore, that the conference summary and
recommendations be drafted, accepted by the conferees, and
Issued by the Secretary as soon as possible.
The necessity for modifying the existing standards
arises because conference recommendations, if similar to the
Administration report recommendations, will Include some
items not now included in our standards, and involve some
changes in other items and different geographic limits for
some classifications.
The conference study area includes substantial
reaches of waters not previously classified by the Commission.
We propose to use the data presented by the Administration
to supplement the Commission's information for the base upon
which to adopt classifications and standards. This, as with
revisions of the existing standards, will require holding of
public hearings on the part of the Commission. Early
conference recommendations are essential in order to reduce
the lead time for the hearings, upon which will depend the
scheduling of projects where permit revocations or orders are
required. The Commission plans to proceed simultaneously with
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L. H. Smith
the establishment of new or revised standards and the issu-
ance of necessary orders on all sources, including completion
target dates, thus eliminating the holding of separate
hearings for orders or permit revocations as would otherwise
be required by State law.
Holding hearings of this type, evaluating the
often conflicting evidence obtained, and preparing the sub-
sequent legal documentation is, under existing Minnesota laws,
a very complex and time-consuming procedure which may require
as much as six to nine months for completion. The procedure
cannot be started until the conference summary and recommenda-
tions are received. This being the case, it is recommended
that the first three phases of scheduling for construction
projects (i.e., a, b and c, as given in Paragraph 1 on Page 3^
of the Summary Report) not be included in the final recommenda-
tions of the conferees. There is no objection to the overall
target completion date of three years from the receipt of
the summary, but, in view of the necessary lead time mentioned
and the uncertainty accompanying the preliminary stages of
many projects, it is believed that it would be much better
not to fix specific deadlines for these stages. It is
suggested that an annual or aemi-annual reporting requirement
be inserted instead, so that all of the agencies concerned
will be kept informed of progress. By this method, lagging
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L. H. Smith
projects will be readily apparent to all, and possible em-
barrassment relating to unrealistic assessment of the time
needed for, or unforeseen delays in, preliminary stages will
be avoided. This has been the procedure used by the Commis-
sion and our experience demonstrates that it is a more
realistic approach when dealing with projects of many
different sizes and kinds and in all stages of planning.
MR. STEIN: Mr. Smith, I wonder if I may interrupt
you there.
I know this is going to take some discussion, but
let me throw something out to you.
I think we intended with reference to the interim
dates to have semi-annual progress meetings. Now, here Is
the problem that we have come into, and I think this is an
agreement that we have made with most of the States. As a
matter of fact, I am pretty sure even with Wisconsin, when
we have had other cases, we didn't have any trouble.
This is the philosophy of setting up these interim
dates. We feel that this helps us all, because even If you
go to a progress meeting, how do you know if a project is
lagging, or how would the people know if a project is lagging
unless it is Immediately apparent to all?
Now, if there is a good explanation for a project
falling behind, I don't know that it need present any
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L. H. Smith
embarrassment. I would like the Minnesota people to see
if we could not arrive at sone kind of an arrangement
where we could set up these interin dates on this kind of
thing.
For example, in the Lake Erie case, we arrived
at this notion. We had received interim dates from Michigan
that had their program started for one reason or another a
little before, but the other five States didn't quite have
these yet. The agreement was that at the first progress
meeting, which we are going to have in a few weeks in Buffalo
on Lake Erie, all the States come up with the interim dates
for their projects.
It may be that giving you six months or something
to come up with these would be the thing, But I do think, Mr.
Smith, that these interim dates are kind of essential for
us, and not only us, because I think we have an obligation
to keep the people informed, for the citizens, the press, and
the other media to know if we are doing the job, or the city
is doing the job. Otherwise, you have three years to wait,
and you are not quite sure about this.
Let me make this last point, because this has
been my experience in water pollution control. You can get
all the people concentrating on the problem just so often
at a meeting of this kind, and then, if you go away and
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L. H. Smith 344
nothing happens for three years, the pressure points are
suoh that the program nay lag, and lag so much that it becomes
irretrievably late if you don't pick it up.
Of course, we can overdo thia, but I think a
reasonable amount of interim dates in between will prevent
that. Very often, the interim dates prove more embarrassing
to the regulatory agency* and that includes us, more than
anything else, because the newspapers begin asking the
questions, and I am not reluctant to put that in.
I think it does us all some good.
MR. POSTON: Mr. Stein?
MR. STEIN: Yes.
MR. POSTON: I would like to say that in this
whole pollution picture, one of the major things that I think
has caused a lack of abatement of 'pollution has been the fact
that the polluters haven't really felt that they had to do
thia, and they had to do it by a certain time,
I think that until we set dates, until we specify
standards, until municipalities and industries realize that
they must do these things, they are going to lag. Their
business primarily isn't to abate pollution and to get rid
of their wastes; it is some other purpose, and until we set
time schedules and water quality standards, we are not going
to make anybody believe that we mean business.
DR. JELATIS: Mr. Chairman?
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L. H. Smith
MR. STEM: Ye*.
DR. JELATIS: I would like to ask a question
about something that I an not very clear on. That is, you
have heard the description of the procedure required by
Minnesota law of protracted hearings and notice which are
necessary in order for the Pollution Control Commission to
set the standards.
Now, this procedure for the stretches of the
river that are now not covered by standards, and for those
stretches which the standards would have to be revised for,
would require, under present legal hearing requirements, a
time that would certainly be longer than the six months
required or recommended for submission of preliminary plans
for remedial facilities.
Now, would the adoption of standards by this
conference automatically impose these as standards that apply
to the State, or would we still have to go through the formal
procedure of hearings?
MR. STEIN: Dr. Jelatis has asked a lot of
questions in that. Let me try to answer them.
No. 1, I don't want to be the definitive man who
is going to interpret Minnesota law. That is your Job. I
have read your law. I have read your law carefully, and I
have read your law with interest. I know the procedures
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L. H. Smith
you have to go through to classify the waters.
If you think that and the establishment of
standards mean the same thing, that is your law and you have
to interpret that.
The second is that this conference is not going
to establish standards. That is set up by another provision
in the law in all the States and the Federal Government.
What we are going to do is set up certain recom-
mended requirements for the clean-up of the waters in the
Twin Cities area, and we hopefully are going to come up with
a time schedule to do this.
What I am suggesting to you, and you know this
is something that we all have to work on together, is that,
generally speaking, we have found that setting up a time-
table, and I don't think we are going to have any trouble
with that, and setting up the requirements and a time
schedule and six months' progress plans, which indicate
whether we have these meetings or not, lead the way to getting
things done.
Let me tell you that this works as much with the
Federal Government as some others. In one of these operations,
we were to meet a time schedule which we didn't quite do. For
example, this involved a situation in Cleveland, and it came
six months and one day, and the Cleveland newspapers began
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L. M. Smith
rewinding us of this In ever-Increasing crescendo. You
know this helps, and I do think that by giving the people
and the press a schedule like this to check on us, we give
them some Indicia where they can Judge whether we are doing
our Job. I think this Is fair. So this Is the situation.
However, I do think the Minnesota people have
a lot of things to think over themselves. I can't tell you
how to run your State program, and how to run your law.
DR. JELATIS: Thank you.
MR. WISNIEWSKI: Mr. Chairman?
MR. STEIN: Yes.
MR. WISNIEWSKI: I would like, before the
conferees decide firmly on this question of interim dates, to ask
that they explore the enforceability of such a procedure,
and we could do that before we make a decision.
MR. STEIN: I agree with you on that.
MR. WILSON: Mr. Chairman?
MR. STEIN: Yea, Mr. Wilson.
MR. WILSON: Mr. Chairman, may I call attention
to this inescapable situation as far as the Minnesota Commis-
sion is concerned?
Under the Minnesota law, it is necessary for the
Commission to hold hearings before the adoption of standards.
Every standard is appealable.
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L. H. Smith
This, the necessity of adopting standards in
advance before enforcement orders can be issued, has
practically doubled and in many cases probably more than
doubled the time for getting the enforcement action against
specific sources of pollution, as compared with a system that
was enforced in Wisconsin before the adoption of standards
was required, where their State committee could issue an
immediate order for the ceasing of pollution, or the adoption
of remedial measures, without going through all the red tape
of adopting standards in advance.
After the Minnesota Commission, after holding
hearings lasting, I think, a total of eight days or so,
spread over a period of several months in 1962, adopted the
present standards for the stretch of the Mississippi River
between Anoka and the mouth of the St. Crolx, the most contro-
versial standard, the one applying to the St Anthony Falls
Pool, was attacked in court by the North Suburban Sanitary
District.
That resulted in a trial in the District Court
of Anoka County that lasted some eight days or more, a year
and a half ago, or a year ago last summer. Then the decision
of the Court did not come down for nearly a year. I guess
it was a full year before the District Court decided the case.
Then the Commission has taken an appeal to the
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L. H. Smith
Supreme Court from the adverse decision. The District Court
decided that the high standards which our Commission attempted
to apply in that case were unreasonable, and the Commission,
in order to sustain its standards, has taken an appeal to
the Supreme Court.
There Mill be a transcript in that case of over
1,000 pages. The reporter hasn't gotten it done yet.
According to all the experience, we shall not be
able to get a decision of the Supreme Court as to the validity
of that standard until some time next fall or next winter at
the very earliest.
Now, these are things which the Commission cannot
control.
The adoption of other standards by the Commission
has also been the subject of court attack, and in view of that
situation, and the fact that the adoption of this New York
standard system has multiplied the opportunities for court
attacks on the various points, it is virtually impossible for
the Commission to guarantee that it will issue an enforcement
order by a certain time in any specific case. Any such
declaration would have to be subject to the possibility that
the affected municipality or industry might attack first the
standards, and then suppose the standard is sustained and
the Commission issues an order, that order will also be
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L. H. Smith
appealable to the courts with like delay.
It seems to me that the moat that can be clone is
to depend on the past records of the Minnesota Commission of
attempting to deal with these problems with the utmost dili-
gence at its command, and that any attempt to impose hard and
fast deadlines would have to be made subject to modification
and recognition of these unexpected delays that may be en-
countered without fault of the Commission.
MR. SMITH: I would like to point out, Mr. Chairman,
that for a year the Commission has used just what you have
indicated, a time schedule; but in this case, where the lead
time is necessary as far as our standards are concerned, our
first six months date doesn't mean anything.
MR. STEIN: This may be, but I suggest that we think
about this.
I think Mr. Wilson has raised a point. Let me try
this with Minnesota, because, goodness knows, we are talking
about the whole program and we are here to try to get a State-
Federal program moving. We hope that you can reach all the
qualifications and permit the uninterrupted flow of the waters
of Minnesota, as well as the interstate waters of Minnesota.
But, Mr. Wilson, you are right. I think that New York has
abandoned that after fifteen years. They have classified
the streams. They have had some magnificent lawsuits. They
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L. H. Smith
have been up to the highest court in New York State, which
they call the Court of Appeals, two or three times, with
tremendous decisions.
The difficulty is when you get through classifying
all those waters, they found, lo and behold, that none of the
waters were any bit cleaner than when they started.
Now, the Governor there instituted this, and we
have been up there. There is a crash program for a clean-up.
They voted a billion dollar Statewide bond issue to give to
the cities, and, as far as I know, in New York State, we,
the Federal people, are working with them practically as one
staff now. There is no problem, but they went through this.
You don't have to go through fifteen years before this happens.
Now, the next point: I appreciate all Mr. Wilson
has said about this, and there is no finer lawyer in this
world than Mr. Wilson.
As T pointed out, when we first started, anyone
roughly in our generation who says he didn't learn the field
from Mr. Wilson isn't in the field. He was the mentor of the
law. This is all very true.
But I think, without prejudging, of course, or
presuming what the Secretary is going to say, there may be
one kind of judgment if you put in a standard and say it is
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L. H. Smith
accepted, or if it has been attacked in the courts and you
have done what you could do under your administrative
decisions, and then put it in the law. Goodness knows, we
have to preserve the right of court attack and court appeal
in every case. We are subject to it. The States are subject
to it. We would not give this up.
This is the thing that makes the program work,
that if anyone doesn't like what one of us stuffy, autocratic
old bureaucrats can do, he can take us to court, and this we
recognize.
However, the question here that we have to raise
is to look at your State law and see if you can set standards
on these streams.
Many of the States other than Minnesota have
held hearings in two, three, four, five, six parts of the
State, and have come up with criteria or are coming up with
criteria covering the streams of those States, which they
have every confidence will meet the Federal requirements.
Now, goodness, if any of these States come up
with criteria and someone takes them to court, and this is
beyond their control, this is part of the American system,
and I think this would have to be looked at, but I will again
make the plea to Minnesota to let's see if we can get with
'« and try to work this out.
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L. H. Smith
I think as a forward-looking and a progressive
State and a sophisticated State like Minnesota, in trying to
deal with Federal people, who I hope are trying to help and
accommodate you, we should be smart enough to be able to
resolve this problem for the benefit of all the people here,
rather than to have it resolved in a controversy, because if
we don't come to this agreement, I think this is a failure
on our part.
Let me say again we have a Federal law that we
have to live with, and you have your law to live with. We
both have complicated laws. I hesitate to blame a failure
of people getting together just on awkward laws.
Chester, we have lived with awkward laws all our
lives. If the failure happens, I am not sure that the people
that are looking out here won't think it is a failure of the
administrators, rather than the law.
DR. MARGRAVES: I would Just like to add, as I
said yesterday, that Minnesota has gone through all you havr
suggested so far.
We have held five hearings throughout the 5
We have our sets of criteria and standards all set.
only a matter of application.
i
During the night, I went through much *
Federal law, and I can't for the life of me see
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L. H. Smith
that each stream shall be classified in order to apply these
standards, so I think there is a very interesting legal — and
I am a medical man -- interesting legal aspect to this, as to
whether what we have already done wouldn't still let us come
in under the law, and then proceed and take care of the job.
MR. STEIN: I don't want to prejudge that now, but
in further support of what you said, Dr. Hargraves, I would
suspect that unlike Minnesota, there are about 30 to 35 States
in the United States who are not authorized to classify their
streams at all. They can set standards, but they cannot
classify. Up until recently you weren't, until you adopted
the New York system. Except for the New England States, New
York, North Carolina, Minnesota, I don't know that there are
any others. Very few of the other States have a classification
system.
DR. HARGRAVES: If I remember rightly, in reading
the hearings of Congressman Blatnik's Public Works Committee,
it took North Carolina five to six years to complete their
classification.
MR. STEIN: Let me get off the record.
(Discussion off the record.)
MR. WILSON: Mr. Chairman, may I add another comment,
xview of what Dr. Hargraves has said?
I »ade some comments yesterday on the unexpected
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L. H. Smith
I think as a forward-looking and a progressive
State and a sophisticated State like Minnesota, in trying to
deal with Federal people, who I hope are trying to help and
accommodate you, we should be smart enough to be able to
resolve this problem for the benefit of all the people here,
rather than to have it resolved in a controversy, because if
we don't come to this agreement, I think this is a failure
on our part.
Let me say again we have a Federal law that we
have to live with, and you have your law to live with. We
both have complicated laws. I hesitate to blame a failure
of people getting together just on awkward laws.
Chester, we have lived with awkward laws all our
lives. If the failure happens, I am not sure that the people
that are looking out here won't think it is a failure of the
administrators, rather than the law.
DR. HARQRAVES: I would just like to add, as I
said yesterday, that Minnesota has gone through all you have
suggested so far.
We have held five hearings throughout the State.
We have our sets of criteria and standards all set. It is
only a matter of application.
During the night, I went through much of the
Federal law, and I can't for the life of me see where it says
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L. H. Smith
that each stream shall be classified in order to apply these
standards, so I think there is a very interesting legal — and
I am a medical man — interesting legal aspect to this, as to
whether what we have already done wouldn't still let us come
in under the law, and then proceed and take care of the job.
MR. STEIN: I don't want to prejudge that now, but
in further support of what you said, Dr. Hargraves, I would
suspect that unlike Minnesota, there are about 30 to 35 States
in the United States who are not authorized to classify their
streams at all. They can set standards, but they cannot
classify. Up until recently you weren't, until you adopted
the New York system. Except for the New England States, New
York, North Carolina, Minnesota, I don't know that there are
any others. Very few of the other States have a classification
system.
DR. HARGRAVES: If I remember rightly, in reading
the hearings of Congressman Blatnik's Public Works Committee,
it took North Carolina five to six years to complete their
classification.
MR. STEIN; Let me get off the record.
(Discussion off the record.)
MR. WILSON: Mr. Chairman, may I add another comment,
in view of what Dr. Hargraves has said?
I made some comments yesterday on the unexpected
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L. H. Smith
effect of these requirements of the Federal law of certain
things to be done by June 30, 1967, and I want to point out
this:
It is an elementary rule of statutory construc-
tion, sustained by court decisions all over the country, and
by decisions of the United States Supreme Court, that every
law is to be given a reasonable construction in the light of
its purpose.
The purpose of the Federal Act, the purpose of
the Minnesota Water Pollution Control Law, is to get ahead
with the control of pollution as rapidly and effectively as
possible, and if a liberal interpretation of these provisions
of the Federal law such as has apparently been adopted by the
head of the Federal administration is going to frustrate those
purposes, It is not in accordance with the principles of
established statutory construction.
You will find many cases where the courts have
departed from the literal provisions of a statute in order to
construe It in furtherance of the advancement of its purposes,
and I want to repeat that if the present position of the
Federal Administration is that if the Minnesota Commission
does not by June 30th do certain things, which are apparently
impossible, and then the Federal Government has to come in
here and hold hearings and set up standards, It is simply
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L. H. Smith
going to delay the progress of the action program, which is
already going on under the Minnesota Commission. Instead
of advancing the purposes of the Federal law, it will delay
and defeat them.
For that reason, Mr. Chairman, I again urge that
there should be a reconsideration of this Federal decision,
and it should be done very soon, before any action is taken
at the current session of the Legislature that may upset this
program.
MR. STEIN: Mr. Smith?
MR. SMITH: May I continue?
MR. STEIN: Yes.
MR. SMITH: The ultimate disposition of many of
the matters involved herein will depend upon the action of our
State Legislature, which is now in session, or be heavily
Influenced by such action or lack of it. These include the
following:
a. Augmentation of the staff and resources
of the Commission, and/or reorganization thereof.
It is obvious that many of the tasks indicated,
such as extensive monitoring, intensive review of
works operation, liquid storage and solid wastes
programs, follow-through with standards and con-
struction schedules, etc., will require considerable
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L. H. Smith
staff over and above what the Commission has at
present. If the staff is not provided, the Com-
mission will have no alternatives but either to
turn its back on the needs of most of the other
parts of the State and other aspects of water
pollution control, or to default in its responsi-
bilities to this area.
b. New legislation probably will be needed
specifically authorizing the Commission to require
recovery of spilled wastes, such as oil, from
watercourses, and to extend its control into the
field of disposal of sewage arising from commercial
shipping, documented vessels and other watercraft
not licensed by Minnesota.
c. Creation of a metropolitan area sanitary
district responsible to the Commission, to provide
an integrated approach to construction and opera-
tion of waste disposal works for the entire area is
badly needed. The Commission has continuously urged
this concept for the past three sessions of the
Legislature. Hopefully it may come to fruition in
the present session if it is not lost in the con-
fusion engendered by the multiplicity of proposals
for solution of sewage disposal problems of the area,
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L. H. Smith
In concluding* the Commission would like to in-
dicate that they sincerely hope that this conference will
result in recommendations acceptable to all concerned, so as
to assure maximum support for the Commission's policies,
programs and objectives. Water pollution control is a
monumental task, as evidenced by the resources the Federal
Government has poured into it recently, but in order that our
efforts be fruitful, the whole-hearted cooperation of all
agencies, organizations and individuals involved is vitally
necessary.
That is the end of my statement.
I would like to submit for the record the exhibits
which I would like incorporated in the record.
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L. H. Smith
(The following exhibits were submitted for Inclusion In
the record.)
Exhibit 1
STATE OF MINNESOTA
WATER POLLUTION CONTROL COMMISSION
CHAPTER POUR: WPC 4
WPG 4 Regulation relating to storage or keeping of oil and
other liquid substances capable of polluting waters of the
State
(a) Definitions
(1) The definitions given in this section shall
obtain for the purposes of this regulation
except as otherwise specified or indicated
by the context.
(2) "Substance" means any liquid material which
might cause pollution of any waters of the
state if mixed therewith.
(3) "Safeguard" means a facility or device or any
system or combination thereof designed to
prevent the escape or movement of any sub-
stance or solution thereof from the place
of storage or keeping thereof under such
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L. H. Smith 360
conditions that pollution of any waters of the
State might result therefrom.
(4) "Site" means any tract or parcel of land, including
any constructed storage tank or artificial or
natural basin or containment facility, except under-
ground or burled tanks where any substance is
stored or kept and which is so located that the
escape or movement of such substance or a solution
therefrom from the site or into the underlying
ground might result in pollution of any waters of
the State.
(5) "Stored liquid material" means liquid material which
is within a container or containment device located
within the State other than a mobile type unit
while in transit, used for transporting said
material from one location to another.
(b) Prohibition of Storage or Keeping Substances without
Safeguards. No substance shall be stored, kept, or
allowed to remain in or upon any site without reason-
able safeguards adequate to prevent the escape or
movement of the substance or a solution thereof from
the site under any conditions of failure of the
storage facility whereby pollution of any waters of
the State might result therefrom. It shall be the
duty of every owner of such stored substances, or
other person responsible therefor, to obtain
from the Water Pollution
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L. H. Smith
Control Commission a permit for the use of
the Bite for the storage of liquid substances
as provided In Section d or Section e.
(c) Safeguards. Unless otherwise prescribed by
a permit issued under Section d or Section e
as hereinafter provided, every safeguard
shall comply with the requirements of this
section, and shall consist of the following
features.
(l) A continuous dike or wall entirely sur-
rounding the site of such dimensions and
construction that the emergency storage
volume thereby created will be equal to
not less than the total capacity of the
largest storage tank or other container
located within the area enclosed by the
dike and will hold securely all of the
aforesaid tank contents or any solution
thereof In case of any failure of the
container and the escape or movement of
the substance or solution from its con-
tainer or place of storage or keeping;
(2) A reasonably impervious bottom under the
entire site and enclosure of such construe-
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L. H. Smith
tlon or composition either natural or
artificial as to prevent in case of any
failure of the container the seepage,
percolation, or other movement of any
substance stored or kept on the site or
within the enclosure or any solution
thereof into the underlying ground In
such quantity that substantial pollution
of the waters of the state in the vicinity
might reasonably be expected to result
therefrom under conditions prevailing at
the site.
(3) Any alternative method of adequate safe-
guards submitted by owners of stored liquid
substances may be reviewed by the Water
Pollution Control Commission. Upon finding
that any such alternative safeguards are
satisfactory and that they will reasonably
protect any waters of the State against
pollution by the stored liquid, the Commis-
sion may approve the use of said alternate
safeguards In lieu of the above standards
and may thereafter issue a permit in accord-
ance with Section d or Section e hereunder.
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L. H. Smith
(d) Permits - Issuance on Application. On
application for a permit by the owner or
other person responsible for the keeping or
storage of any substance on any site the
Water Pollution Control Commission may require
plans showing the features and method of opera-
tion of existing or proposed safeguards in
accordance with these regulations. Such
plans must be accompanied by a certification
as to the adequacy of such safeguards. The
Commission may thereafter Issue a permit
therefor upon such conditions as it shall
prescribe to prevent pollution of any waters
of the State by such substance. Such permit
shall be subject to modification or revoca-
tion by the Commission In like manner as
provided by law for permits for the instal-
lation or operation of disposal systems or
parts thereof.
(1) Before the Issuance, denial, revocation
or modification of a permit by the Commis-
sion any person whose vested rights may be
adversely affected thereby shall, upon re-
quest therefor, be entitled to a hearing
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L. H. Smith
before the Commission for the purpose of
presenting evidence thereat.
Written notice of the hearing stating the
time and place thereof shall be given by
the Commission to any person known by it to
be directly affected by such action of the
Commission either personally or by registered
mall not less than 30 days before the date
of the hearing.
(e) Flammable liquids. Notwithstanding the pro-
visions of Section d, of these regulations* a
permit may be issued to owners of a flammable
liquid storage facility upon certification
by the Minnesota State Fire Marshal that the
requirements of the Minnesota State Fire
Marshal*s flammable liquids code as amended
and Section b of these regulations, have been
complied with and are currently being fulfilled,
(f) Inadequate Safeguards. In case the Commission
shall find that any substance is stored or
kept on any site without a safeguard, or
that any existing safeguard is inadequate,
it may by order require the owner or other
responsible person to immediately remove the
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L. H. Smith 365
substance from the site and to refrain from
further storage or Keeping of any substance
therein unless and until an adequate safeguard
Is provided as hereinbefore prescribed.
(g) Notice Concerning Loss. It shall be the duty
of the owner of a liquid storage facility or
other responsible person In charge thereof
to notify the Water Pollution Control Commis-
sion at Its office In the Minnesota Depart-
ment of Health Building at the University
Campus, Minneapolis, of any loss of stored
liquids either by accident or otherwise when
such loss Involves a liquid substance which
would be lively to enter any waters of the
state. Said notice shall be by telephone or
other comparable means and shall be made Imme-
diately upon discovery of the loss. The
notification shall include the location and
nature of the loss and other pertinent
information as may be available at the time.
(h) Violations. Violation of any provision of
this regulation shall be punishable as provided
by law.
(1) Application. This regulation shall not apply
to the disposal of sewage, Industrial waste.
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L. H. Smith
or other wastes under permits issued by the
Commission as provided by law.
Exhibit 2
STATE OP MINNESTOA
WATER POLLUTION CONTROL COMMISSION
AN ACT RELATING TO WATERCRAFT; PROVIDING FOR THE REGULATION
OF MARINE TOILETS AND THE DISPOSITION OF WASTES FROM WATER-
CRAFT, (Minnesota Statues 1961, Seotlon 361.29, as amended
by Chapter No. 313* Laws of Minnesota, 1963* as amended by
Chapter No. 273, Laws of Minnesota, 1965)
Section 1. (MARINE TOILETS). Subdivision 1.
(a) For the purposes of this section the term "wateroraft"
has the meaning given to it by Laws 1959» Chapter 592,
Section 2, Subdivision 1, and acts amendatory thereof.
(b) No person owning or operating a wateroraft or other
marine conveyance upon the waters of the State of Minnesota
shall use, operate or permit the use or operation of any
marine toilet or other similar device for the disposition
of sewage or other wastes, unless the marine toilet is
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L. H. Smith
equipped with a treatment device of a type acceptable to
the Water Pollution Control Commission of the State of
Minnesota. No person shall discharge into the waters of
this State, directly or indirectly from a watereraft, any
untreated sewage or other wastes, nor shall any container
of untreated sewage or other wastes be placed, left, dis-
charged, or caused fco be placed, left or discharged in or
near any waters of this State from a watercraft in such
manner or quantity as to create a nuisance or health hazard
or pollution of such waters, by any person or persons at any
time whether or not the owner, operator, guest or occupant
of a wateroraft or other marine conveyance.
Subdivision 2. The Water Pollution Control Commis-
sion shall upon request furnish a list of the types of
treatment devices currently available and considered ac-
ceptable for the purposes of this section for use with
such marine toilets. The commissioner of Conservation
shall furnish the sheriff of each county in the State of
Minnesota with a list of such treatment facilities accept-
able to the Water Pollution Control Commission of the State
of Minnesota.
Subdivision 3. On and after April 1, 1966, no
watercraft or other marine conveyance upon the waters of
the State of Minnesota shall be equipped with any marine
toilet unless also equipped with a treatment device
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L. H. Smith
acceptable to the Water Pollution Control Commission of
the State of Minnesota; provided, however, that this
requirement shall not be applicable to watercraft exempt
from licensing under Section 361.03, Subdivision 12.
Subdivision 4. Any treatment device designed for
use with a marine toilet, if in good working condition and
of a type acceptable to the Water Pollution Control Commis-
sion of the State of Minnesota, is presumed to comply with
the requirements of this Section,
Subdivision 5. The installation or presence of
a marine toilet in a wateroraft shall be indicated by the
owner upon application for licensing of the wateroraft or
marine conveyance, and no license for any such wateroraft
bearing a marine toilet shall be issued except upon certi-
fication by the owner of the installation of an acceptable
treatment device for use with such marine toilet.
Subdivision 6. A person who violates any pro-
vision of this Section is guilty of a misdemeanor.
Section 2. Notwithstanding the provisions of
any other law to the contrary, Minnesota Statutes 1961, Section
361.29 does not take effect until April 1, 1966, except on
the waters of the Mississippi River where Subdivision 3 of
said Section 361.29 takes effect on January 1, 1967.
«•*******
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L. H. Smith
Exhibit 3
STATE OP MINNESOTA
WATER POLLUTION CONTROL COMMISSION
Criteria for Acceptability of Marine Sewage Treatment Devices
For Use in Conjunction With Toilets on Pleasure Boats or
Other Small Wateroraft
June 23, 1966
1. Definitions; The following terms are hereby defined
for these purposes:
a. Marine Toilet - any toilet when on or within
a boat or other wateroraft subject to licensing
in Minnesota, as defined in Minnesota Statutes,
1961, Section 361.29, An Act Relating to
Wateroraft; ^j/ovidlng for the Regulation of
Marine Toilets and the Disposition of Wastes
from Wateroraft.
b. Sewage - all human body wastes in admixture
with water or otherwise as discharged from a
marine toilet.
o. Sewage Treatment Device - any device connected
to a marine toilet for the purpose of treating,
storing or disposing of the sewage discharged
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L. H. Smith
from the toilet.
d. Effluent - the mixture of fecal material,
urine, flushing water, disinfectant chemi-
oals, or other materials as discharged from
the treatment device.
e. MPN (most probable number) - a statistical
measure of the number of collfom group
organisms present in water or sewage as
defined in the latest edition of "Standard
Methods for the Examination of Water, and
Waste Water," APHA, AWWA, WPCF, and determined
in accordance with such methods.
f. Suspended Solids - the solid particles in
suspension in the effluent of the sewage
disposal device, determined in accordance
with "Standard Methods."
g. Chlorine Residual - as determined in accord-
ance with "Standard Methods."
2. General Objectives;
a. The sewage treatment device shall be con-
structed, Installed, and operated so as to
minimize to the maximum practicable extent
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L. H. Smith
possible nuisance conditions and health
and safety hazards associated with the
discharge of sewage or use of the marine
toilet and treatment unit.
b. Materials used shall be reasonably resistant
to corrosion under the conditions of use and
of ample strength for safe operation with any
commercially available marine toilet and type
of watercraft.
o. The unit shall be so constructed and Installed
as to avoid the escape of gases or obnoxious
odors into the boat, be relatively easy to
operate and maintain, and function automatic-
ally with the operation of the marine toilet.
d. The disinfectant chemicals used and the treat-
ment or disposal methods shall be such that
the effluent if discharged from the treatment
device to waters of the State will not be a
substantial source of pollution as defined
by law (Minnesota Statutes, Chapter 115), or
so that the effluent and manner of discharge
will not affect adversely any component of
on-shore sewage disposal systems, including
municipal or other sewage treatment works.
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L. H. Smith
The acceptability of a treatment device to
the Minnesota Water Pollution Control Com-
mission generally will be based upon certi-
fication by a consulting engineer registered
in Minnesota that the device (a full scale
prototype, or production unit substantially
equal to a stock unit chosen at random from
a dealer) was tested under conditions of
actual use, but not necessarily mounted in a
boat, for a period of two weeks with a mini-
mum of at least one defecation daily (and
preferably more), was found to be generally
satisfactory in construction and operation,
and that the unit and the effluent test
results meet the general and specific objec-
tives given herein.
Reliable information from other sources,
however, may be considered and upon favorable
evaluation by the Executive Engineer, the
subject device may be recommended to the
Water Pollution Control Commission for ac-
ceptance on the basis of substantial con-
formance with the criteria.
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L. H. Smith
3. Specific Objectives: The effluent of the marine toilet
and on-board sewage treatment device combination, when dis-
charged to surface waters, shall meet the following minimum
conditions:
a. Not more than 5$ (by weight) of the suspended
solids in the effluent shall be larger than
lA inch in any dimension, and at least 75/6
of the suspended solids in the effluent shall
be no larger than 1/8 inch in any dimension.
Solid materials readily recognizable as
being associated with sewage shall be re-
duced to a minimum.
b. A substantial chlorine residual shall be
present in the effluent at all times (if
chlorine is used as the disinfecting agent).
o. The conform group organisms in the effluent
test samples, after dechlorlnation and macera-
tion in a laboratory blender, shall not exceed
1,000 MPN/100 ml In more than 1O# of the test
samples, and the average of 10 consecutive
dally tests shall not exceed 500 MPN/100 ml.
4. New Developments: Consideration will be given to the
use of other disinfecting agents or methods of treatment
if test results demonstrate that the foregoing objectives
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L. H. Smith
can be met.
APPROVED by resolution of the Minnesota Water Pollution
Control Commission, June 23, 1966.
Robert N. Barr, M. D., Secretary
Water Pollution Control Commission
Datedj June 23, 1966
*********
Exhibit 4
STATE OP MINNESOTA
WATER POLLUTION CONTROL COMMISSION
Sewage Treatment Devices
for Installation on Pleasure Boats
or Other Small Wat ere raft
The Water Pollution Control Commission on the
dates indicated accepted the following devices for use In
conjunction with marine toilets on pleasure boats or other
small wateroraft for treatment of sewage, as required by
Section 361.29, Laws of 1961.
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L. H. Smith
1. "C-Chlor Mark 5"» manufactured by Carlson and
Son, 19 James Place, Metuohen, New Jersey,
(December 21, 1962).
2. "Marine Ghloj?lnator" , manufactured by Apollco
Corporation, 1391 Pierce Butler, St. Paul,
Minnesota, (April 18, 1963).
3. "Destrollet", manufactured by La Mere Industries,
Inc., Walworth, Wisconsin, (February 27, 1964).
This device Is accepted for use on pleasure boats
with the condition that the device and all fuel
tanks and other appurtenances be Installed and
maintained In compliance with applicable regula-
tions of the U. S. Coast Guard (Title 46 CFR
55.16) and any requirements of the Minnesota Fire
Marshal relating to the use of liquid petroleum
gas on boats. The device is not^ acceptable for use
on vessels operated within the U. S. Coast Guard
jurisdiction which are used in the carriage of
passengers for hire because the use of liquid
petroleum gas on such vessels is prohibited by
Coast Guard regulations. No statement Indicating
acceptance of the device by the Water Pollution
Control Commission shall be used in any advertising
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L. H. Smith
promotion or Bale of the device unless the state-
ment Includes, In the same size type, the
following: "Accepted as to pollution control
capabilities only and not evaluated as to safety
hazards."
"Mono-Marine Sanitation System", manufactured by
Monogram Industries, Inc., 8525 Steller Drive,
Culver City, California, 90231, (March 26, 1964).
This device Is accepted with the following condi-
tions so that there will be no discharges of
sewage from the system directly to waters of the
State;
a. The tank and/or outlet piping must be Instal-
led on the boat so that gravity discharge to
the waters will not be possible.
b. Individual tank discharge pumps on the boat
are prohibited in Minnesota waters.
c. Discharge of the tank contents may be done
only by dockslde or on-shore facilities and
the contents may be discharged only to ilsposal
facilities operated under a permit from the
Water Pollution Control Commission.
d. If relatively large quantities of such treated
tank contents are to be discharged to a
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L. H. Smith
disposal system in a short period, a surge
tank may be required to equalize the flow
and avoid possible detrimental "slug"
effects upon the sewage treatment works.
5. "Monomatio Marine Sanitation System," Model 1,
manufaetured by Monogram Industries, Inc., 8525
Steller Drive, Culver City, California, 90231,
(February 28, 1966). This device is accepted
with the same conditions given above for the
Mono-Marine unit so that there will be no dis-
charge of sewage from the system directly to
waters of the State.
6. "SANITANK"System, manufactured by PEFCO, Inc.,
1380 University Ave., St. Paul 4, Minnesota
(interim acceptance by Executive Engineer on
June 7, 1966, and confirmed by Water Pollution
Control Commission on June 23, 1966). This
device is accepted with the same conditions given
above for the previously accepted storage tank
devices (MonoMarine and Monomatic systems, No. 4
and 5 above, items a, b, c and d), so that there
will be no discharge of sewage from the system
directly to waters of the State, plus the following:
e. If the chemical additive does not prove to
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L. H. Smith
be effective in controlling odors at the
recommended dosage, the dosage shall be
increased or other chemicals acceptable to
the Commission shall be provided to ensure
nuisance free operation.
These devices are considered to be in substantial
conformanoe with the general objectives of the Criteria for
Acceptability of Marine Sewage Treatment Devices, Minnesota
Water Pollution Control Commission, dated June 23, 1966, with
exceptions noted above. Additional devices may be added to
this list at a later date, based upon submission of satis-
factory data by the manufacturer or other sources.
The test data required by the Criteria will in
general be used as a guide for the evaluation of such
devices, but consideration will not be limited thereto.
The Criteria may be revised at reasonable Intervals of
time on the basis of experience and new developments. In
the event of such revision, a new list of acceptable devices
will be Issued.
This list was prepared for the purpose of com-
pliance with the requirements of the Minnesota statutes,
(Section 361.29, Laws of 1961, as amended by Chapter 313,
Laws of 1963, and Chapter 273, Laws of 1965) relating to
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L. H. Smith
disposal of sewage and wastes from watercraft, and Is
not to be construed as an endorsement of these devices
for any other purpose.
Dated: June 23, 1966 Robert N. Barr, M. D., Secretary
Water Pollution Control Commission
#*#######
Exhibit 5
MINNESOTA DEPARTMENT OF HEALTH
DIVISION OP ENVIRONMENTAL HEALTH
SECTION OF WATER POLLUTION CONTROL
Water Pollution Control Practices Recommended
for Application for Dumps, Deposits and Stockpiles
December 16, 1965
In order to protect surface and ground waters
from pollution by refuse and other solid materials of a
pollutlonal character, It Is necessary to keep such ma-
terials and drainage therefrom separated from such waters.
The precautions which must be taken to achieve this will
depend primarily on the nature and location of the site
with respect to such waters, and the type of material dumped
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L. H. Smith
or stored,
The best location for a disposal or stockpile
site would be one above flood levels, far removed from
lakes, wells or local drainage courses, and having a sub-
stantial depth of relatively Impervious surface soil above
the ground water table. Such sites present few, if any,
water pollution problems and consequently do not usually
require special safeguards to protect the waters of the
State. The following sites are considered undesirable and
should be avoided whenever possible.
1. Areas where water is present at or near the
surface, such as sloughs or swamps.
2. Areas in river flood plains which are subject
to flooding.
3. Areas adjacent to lakes or streams which
drain to such waters.
4. Ravines or valleys which may at times carry
run-off or snow melt.
5. Areas near municipal or private water sup-
plies, either surface or underground.
In the event that any of the foregoing must be
utilized, safeguards adequate to protect the waters of the
State are required, and permits for construction and/or
operation must be obtained from the Water Pollution Control
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L. H. Smith
Commission as required by Sections 115.01 and 115.0? of the
Water Pollution Control Statutes. Construction plans and
fairly detailed project data must be submitted for review
and approval before the permits oan be granted.
Depending upon the situation, the safeguards
required may Include any or all of the following:
1. Diking around the site.
2. Diversion or containment of surface drainage.
3. Sealing of pervious soil or rock formations.
4. Covering of dumped or stored material to
minimize erosion and control drainage and
storm water percolation.
5. Regular supervision and control of operations.
6. Provision of an alternate disposal site.
Earth dikes should be constructed on stable
foundations In compacted lifts of relatively impervious
soils. Material containing large rooks, or excessive
quantities of gravel and/or broken stone, should be avoided.
Diking may be done annually to the maximum projected opera-
tional level for the year, if an adequate stockpile of earth
is maintained for covering in the case of a flood, or, if
desired, the dikes may be constructed in a single stage to
an elevation above the maximum recorded flood stage.
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L. H. Smith
Surface drainage, whether natural or resulting
from private or public works, preferably should be diverted
externally, but may be carried through the site in a water-
tight conduit, so that it will not under any circumstances
come in contact with the dumped or stored material.
The use of a site in a location where run-off
from the site itself may enter underground water supply
aquifers is not recommended. Areas of very pervious soil
or fragmented rock formations which either reach the
surface or lie close to the surface should be avoided,
otherwise artificial sealing of the bottom of the site
with such materials as clay, bentonlte, asphalt, synthetic
mats, etc., may be required to prevent percolation of con-
taminated run-off and leach waters into the underground
formations. In some oases, construction of special wells
or drains may be necessary to permit sampling and analysis
of the waters surrounding the site.
Except for the active face, refuse dumps and
sanitary landfills should be kept covered with relatively
impervious earth and graded so as to shed water from the
surface and drain it from the site without coming in contact
with refuse. The earth mantle should have a minimum thick-
ness of two feet to discourage burrowing animals. A stock-
pile of suitable earth should be on hand at all times in
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L. H. Smith
sufficient quantity for normal dally covering of the fresh
refuse, for over-winter use and for a reserve to provide
a ready source of cover material in the event of a flood
forecast. Other types of dumps or stockpiles may require
other kinds of cover or the use of other methods to prevent
excessive leaching or loss of material as may be indicated
by the prevailing circumstances.
The dumping of refuse should be supervised so
that the refuse is placed correctly in the fill, properly
compacted, and covered. Only one main access road to the
dump should be open to the public, and all other points of
access should be fenced unless other effective barriers
exist. The main access road should have a gate which can
be kept looked when a supervisor is not on duty. In general,
only solid or semi-solid refuse should be accepted for
disposal at a dump. Large quantities of liquids or materials
which may be highly flammable, explosive or toxic may require
special handling.
In situations where the site may not be accessible
during flood periods, or because of road restrictions or
other conditions, an alternate site should be provided to
serve during periods when the primary site is not usable.
The nature and operation of all manner of dumps,
deposits, or stockpiles must not only be controlled by the
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L. H. Smith
owner so as to avoid any actual or potential pollution of
any waters of the State, but should also be such as to
avoid causing a nuisance to others in the vicinity.
# * *
MR. STEIN: Thank you.
Are there any further comments or questions?
(No response.)
MK. STEIN: If not, I think this is a very
excellent statement, Mr. Smith.
I think you have raised many policy and technical
questions which I an sure will need very careful consideration
by the conferees if we are going to resolve this matter.
I do think that while they are fundamental as
to difference, with good will we can work out a formula which
will be acceptable to all, Wisconsin, Minnesota, and the
Federal Government.
DR. JELATIS: Mr. Chairman, I have a question
about a technical matter that has been brought up a number of
times here, and that is the BOD loading of the stream between
the MSSD plant and South St. Paul. There seems to be some
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L. H. Smith
question as to the compatabillty of the Federal Summary
recommendations of, I believe it is, 3 milligrams per liter
dissolved oxygen in a 7-
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L. H. Smith
MR, STEINs Let's start that 7-day thing first.
MR. PRINTZ: I think to better explain this I
will probably need to draw upon some of our staff that did
assist in the development of this, and the reason for its
selection.
The State has two basic criteria which I think
are quite clear. If you will allow me to proceed on this,
the first criterion has been established as 2 milligrams per
liter as a minimum at flows exceeded 90 percent of the time,
using as a basis of this calculation the mean monthly flows.
The second criterion to which the State has
referred as being more stringent is based on a 1 milligram
per liter minimum dissolved oxygen at flows exceeded 95 per-
cent of the time based on the minimum dally, as opposed to the
previous monthly flows.
The Federal recommendation is one which will uni-
formly apply throughout the entire study area and will not
change between river systems. That is a minimum, and again
I stress a minimum dissolved oxygen of 3.0 milligrams per
liter, based on a recurrence interval of 7 consecutive days»
flow, which would recur once every 10 years.
We feel that the allowable loadings which have
been determined on the basis of our flow and our knowledge of
the river's characteristics are more stringent than the
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L. H, Smith
State's criteria, No. 1; and we feel that there is very little
difference in the allowable loadings between our criteria and
the State's criteria, No. 2. We have recommended the 7-
consecutive-day once-in-10-year low flow period because of its
widespread application throughout the country.
There are other factors Involved in this, and for
an explanation of these factors, I would like to call upon Mr.
Prank Hall of our staff, who prepared the supplementary report
which you gentlemen have in your package of reports, the one
entitled "Hydrographic Studies," where an explanation of some
of this is given.
So, with that Mr. Hall, would you come forth and
give a further explanation of the reasoning behind the 7-
consecutive-day once-in-10-year low flow period?
STATEMENT OP PRANK E. HALL, FEDERAL WATER
POLLUTION CONTROL ADMINISTRATION, UNITED
STATES DEPARTMENT OP THE INTERIOR, GREAT
LAKES REGION, CHICAGO, ILLINOIS
MR. HALL: Mr. Stein, Conferees, Ladies and
Gentlemen: I think it is recognized that what is important
is the flow below which the criteria will be exceeded.
The question involves the method for defining this
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P. Eo Hall
flow, as I see it.
Now, when describing the method, this is an academic
question if you assume that both types of analyses are valid,
and they are, both the method that Minnesota uses, which I
will leave to them to describe, and the method that we use.
Now, why did we use the method we used?
Mr. Printz hit one or two of the points, but there
are three basic reasons why we used this.
First, the method used in the Federal Report is
widely used. The Federal Water Pollution Control Administration
uses this method nationwide.
Second, as utilized for the purposes of this report,
it provides a uniform measuring stick, that is, the definition
of the flow is consistent. The definition when applied to
different streams and different parts of the same stream, will
provide different flows. For example, if we call the defini-
tion "big," a big flow on the Minnesota River would be a
different value than a big flow on the Mississippi River, but
the point is, and the Federal Water Pollution Control Admini-
stration uses this reasoning, that the definition is uniform.
That is why we are using it in the report.
Finally, I have found, as have many of my colleagues,
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P. E. Hall
that this method Is more readily understood by both those
technical people working with the hydrologists and the non-
technical individuals.
MR. STEIN: Now you see the technical thinking
that we can get into. I think I can put this down as — I
hope I can and I am not going into the technical aspects — a
computation of the basis that they are dealing with compared
with dancing and walking.
I am all for it with the technical people. The
technical people have to come up with it.
To give you the notion, you are dealing with a low
flow. The computation, as I understand, they use in Minnesota
by and large is on the basis of 1 day in a 20-year period.
Wisconsin uses an average 7-day in a 15-year period. Our boys
are proposing 7 days in the 10-year period.
You shake all these up and you roll them out, and
I don't know.
(Laughter.)
This is the kind of argument you get. The issue
here, as I understand the basis of our argument here, is for
administrative needs to get acceptance, and not to get a
diversity of operations. Our boys are proposing the 7 in 10.
Obviously, I don't think the professionals have
zeroed in on any of these. For historical reasons I assume
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P. E. Hall
Minnesota has 1 in 20. For historical reasons, Wisconsin has
7 in 15.
This is always the case when we get this new wave
generation. These kids are grinding these computers and they
come up with something new. I don't know that this is a
fundamental issue. Are we ready to take the computation of
the new wave kids coming along, of the wave of future com-
putees, or do we want to go along with the old historical
things in the State.
On this issue, I don't think it makes very much
difference.
DR. JELATIS; I would like to comment on this just
briefly.
MR. STEIN: Yes.
DR. JELATIS: I am sure that the study group here
has made a computer model of the river flow.
MR. STEIN: Right.
DR. JELATIS: And from this model, I am sure they
can give us what the figures are on the Minnesota and the
Wisconsin and the Federal thinking, and how they could co-
relate, but I think that this ties in with a question that
you asked yesterday about 5 milligrams per liter.
I think this was stated by Mr. Prints, that 5
milligrams per liter would be exceeded 75 percent of the time,
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P. E. Hall
and you said, "Why not put this in as a recommendation?"
I wonder if later in the technical discussion we can't go
into this in a more refined way, and say 1 milligram per liter
for a certain percentage of the time, 5 milligrams, or what-
ever it is.
MR. STEIN: We will do that, and I think we can
arrive at a judgment.
Let me for Just one second get off the record.
(Discussion off the record. )
MR. WISNIEWSKI: Mr. Chairman, I would like to
correct one of your remarks.
MR. STEIN: Yes?
MR. WISNIEWSKI: You mentioned setting up the
formula that no State is less than another, and so forth.
I think the important thing to understand is that
all States get less than they should be getting because of
these formulas.
(Laughter;)
MR. HOLMER: Uniformly.
MR. STEIN: Well, off the record here.
(Discussion off the record. )
MR. STEIN: Is there anything else?
MR. SMITH: I have a large number of people who
wish to make presentations.
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392
May we have a short recesa?
MR. STEIN: We will recess for ten minutes, and
then we will go on with the presentations.
(Whereupon a recess was had.)
MR. STEIN: May we reconvene?
I will now ask Minnesota to call on their par-
ticipants.
Mr. Smith?
MR. SMITH: I would like to call on the people
who wish to make statements by following the list contained
on Pages 23 and 24 of the Report first, and then we will call
on those not listed specifically for different portions of the
report.
The first statement that I have is from the City
of Minneapolis.
Is there anyone here to give that statement this
morning?
(No response. )
MR. SMITH: If not, may I have this read?
MR. STEIN: I would say, if there are any state-
ments, it would be appreciated if a copy were given to the
reporter, if you have another copy. If you don't, then will
you give it to him at the conclusion of the statement?
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393
G. Ginner
STATEMENT ON BEHALF OF THE CITY OF
MINNEAPOLIS, READ BY GARY GINNER,
ENGINEER, MINNESOTA DEPARTMENT OF
HEALTH
MR. GINNER: For the record, my name is Gary
Ginner and I am with the Minnesota Department of Health.
I will read the statement.
CITY OF MINNEAPOLIS
STATEMENT FOR PRESENTATION AT THE FEDERAL
AND INTERSTATE CONFERENCE ON POLLUTION OF
THE MISSISSIPPI RIVER AT MINNEAPOLIS
FEBRUARY 28, 196?
The Public Works Department of the City of
Minneapolis is responding to the invitation of the Water
Pollution Control Commission with respect to the policy
of the City of Minneapolis concerning the problem of
pollution with reference to the Mississippi River as it
involves the city.
As the largest city on the Upper Mississippi
River Watershed, the City of Minneapolis has long recognized
and exercised its responsibility in the control and abate-
ment of water pollution and the protection of the Metropoli-
tan Area's water resources.
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G. G inner 394
In 1933, as the culmination of an extensive In-
vestigation of the pollution of the Mississippi River, the
City of Minneapolis Joined with the City of Saint Paul as
the major participants in the Mineeapolis-Salnt Paul Sanitary
District. The accomplishments of the Sanitary District in-
olude the engineering and construction of a major system of
interceptor sewers and treatment works which set the pattern
of downstream pollution abatement and waste treatment prac-
tices. Beginning operation in 1938* the Sanitary District's
primary sewage treatment plant has established an outstanding
record of successful and efficient operation, effecting a
significant Improvement in the past downstream river condi-
tions and maintaining reasonable levels of water quality.
In response to the surge of growth and development
experienced in the Minneapolis-Saint Paul Metropolitan Area
In the early 1950's, the Minneapolis-Saint Paul Sanitary
District in 1956 embarked upon a costly and extensive study
of the sewage works requirements of the metropolitan area.
With the preliminary investigation essentially completed in
June 1961, the District authorized a major expansion pro-
gram to the existing Pig's Eye Lake Sewage Treatment Plant.
This treatment plant expansion project, which has a total
estimated cost of $25,750,000, is now approaching completion
of construction. It Includes additional capacity for the
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395
0. GInner
growth and development of the two Central Cities as well
as the contracted suburban coamunltles which comprise a
sewered area nearly double that of Minneapolis-Saint Paul
proper. In addition, the new expanded treatment plant in-
cludes secondary treatment which will accomplish levels of
treatment substantially higher than that presently attained.
Supplementing the program of the Sanitary District,
the City of Minneapolis has instituted Independent programs
which have benefited long-range water pollution control
objectives. The city's program of replacing the original
combined sewer system with separate storm and sanitary
sewers has substantially reduced overflow of untreated sewage
to the river during times of rainfall and runoff. Over the
years, approximately $22 million has been expended on this
storm water separation program. An accelerated program has
been scheduled for the future years, and these projects are
being constructed as rapidly as financial resources permit.
The September I960 report of the engineering con-
sultants to the Sanitary District (Volume Three, Page 12-4)
shows that of the 27,710 acres of sewered area in the City
of Minneapolis, 15,847 acres (or over 5756) was served by
separate sanitary and storm sewers. Work completed since
this report was made, together with projects now being
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396
G. G Inner
built, will add approximately 4,000 acres served by separate
sewers. Increasing to over 70$ the total area having com-
pletely separated sewers. The conversion of substantial
areas of Minneapolis from a combined system to separate
sewers for storm water and sanitary sewerage has made it
possible for Minneapolis to convey through its system of
trunk sewers and interceptors the sanitary sewage from sur-
rounding suburban communities. At the present time there are
twenty-seven suburbs and agencies that use or have made
arrangements to use the Minneapolis sewer system.
In the spring of 1962 the State of Minnesota,
through its Water Pollution Control Commission and State
Board of Health, held formal hearings proposing "classifica-
tion of the Mississippi River and Its tributaries between
the Rum River and the St. Croix River and for the establish-
ment of Pollution Standards therefor." The City Council
authorized introduction of a statement favoring the proposed
classification. Standards proposed for the section between
the Rum River and St. Anthony Falls are essential to protect
the water supply of Minneapolis, St. Paul and the suburban
areas presently being served by the Minneapolis and Saint
Paul Water plants. The standards proposed for the section
between St. Anthony Palls and the Minneapolis-Saint Paul
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397
G. GInner
Sanitary Dlstriot plant "will when adopted and enforced be
of great benefit to the residents of the Metropolitan Area."
This stand, by the City of Minneapolis, in favor of the
classifioat ion and regulation of these two sections of the
Mississippi River waa taken with full knowledge and under-
standing of the obligations it was assuming.
In summary, the City of Minneapolis believes that
its record of past accomplishments, its policy of continuing
as rapidly as possible its storm sewer program, its coopera-
tion with the State Legislature, the State Board of Health,
and the Water Pollution Control Commission and suburban
communities is a commendable one and indicates clearly its
determination to Improve the quality of the water In the
river.
CITY OP MINNEAPOLIS
By Thomas A. Thompson (Signed)
Thomas A. Thompson,
Director of Public Works
By Keith M. Stidd (Signed)
Keith M. Stidd,
City Attorney
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A. V. Dienhart 39
MR. STEIN: Thank you.
Are there any comments or questions?
(No response. )
MR. STEIN: If not, thank you very much.
Mr. Smith?
MR. SMITH: The next statement Is from the
Northern States Power Company.
STATEMENT OP ARTHUR V. DIENHART, MANAGER
OP ENGINEERING, NORTHERN STATES POWER
COMPANY, MINNEAPOLIS, MINNESOTA
MR. DIENHART: My name is Arthur Dienhart and I
am the Manager of Engineering at the Northern States Power
Company, with headquarters in Minneapolis.
I will read for the record a statement on behalf
of the Northern States Power Company. The statement is as
follows:
Convinced that water is a vitally important
natural resource and asset in our service area, Northern
States Power Company sincerely supports the statutory policy
of Minnesota, "to provide for the prevention, control, and
abatement of pollution of all waters of the State, so far as
feasible and practicable, in furtherance of conservation of
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399
A. V. Dlenhart
such waters and protection of the public health and in
furtherance of the development of the economic welfare of
the State." We are further convinced that at the present
level of technology such State policy can be fully compatible
with the obligation of Northern States Power Company to
meet the rapidly growing power requirements of the public.
For this reason we supported the actions of
the Minnesota Water Pollution Control Commission in its
adoption of classifications and standards for reaches of
the Mississippi and Minnesota Rivers In the vicinity of the
Minneapolis-St. Paul metropolitan area and its proposal of
procedures for establishing such classifications and
standards State-wide. We firmly believe that specific
guidelines for the regulation of the use of waters by In-
dustry Is an essential aid to Industrial planning, particu-
larly to a public industry such as Northern States Power
Company, because construction of new facilities must be
completed on a schedule to meet public requirements.
The aforesaid action of the State Commission
covers to a large extent the same waters covered by the
recommendations of this conference. Located on these
waters are the three major generating stations of Northern
States Power Company, namely, our Riverside plant, High
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400
A. V. Dlenhart
Bridge plant and Black Dog plant, constituting a total
generating capacity of about 1.5 million kw. In connection
with such Commission action we have conducted, in coopera-
tion with the Commission's staff, a comprehensive series
of river temperature surveys and have filed with the Com-
mission the results of those studies. Studies have also
been made of other plant effluents to determine if the
standards were being met. All our plants are operated in
accordance with the applicable State standards. This in-
formation has also been made available to Federal agencies
to assist in studies for this conference.
We have reviewed the recommendations of this
conference and note that a specific recommendation has been
made that Northern States Power Company utilize the existing
cooling pond at its Black Dog plant to its fullest extent
during the summer at stream flows less than 1,500 cfs and
that during these periods the thermal addition to the
Minnesota River should not exceed 13.5 billion BTU per day.
Northern States Power Company will comply with this recom-
mendation in the operation of its Black Dog plant.
Northern States Power Company's policy of full
cooperation to control water pollution not only involves
proper operation of existing generating plants but the
design and construction of future plants which will in-
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401
A. V. Dieniiart
corporate modern facilities for the prevention of water
pollution.
To meet its growing power requirements Northern
States Power Company is presently constructing its King
plant at Oak Park Heights, Minnesota, on the St. Croix
River and its Monticello plant at Monticello, Minnesota,
on the Mississippi River. These large modern plants will
commence operation in 1968 and 1970, respectively* We
also recently announced plans to construct for 1972 opera-
tion a large plant on Prairie Island, upstream from Red
Wing, Minnesota, on the Mississippi River. In addition,
we also have plans to purchase a site for a future generating
plant above Carver, Minnesota, on the Minnesota River in
Scott County. We have held numerous conferences and dis-
cussions with the staffs of the Minnesota Water Pollution
Control Commission and the Department of Conservation in
order to assure that the -^ sign criteria of these plants
fully comply with the regulatory objectives of these State
agencies,
To assist in the design of the King plant, the
St. Anthony Falls Hydraulic Laboratory of the University
of Minnesota was retained to construct a model of the river
and study the thermal effects of the proposed plant upon
the river. As a result of this study, a submerged intake
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402
A. V. DIenhart
and a wide shallow discharge were designed to confine the
cooling water discharges to a shallow layer over the
surface of the river. A hold-up pond is being constructed
at that plant to retain ash transport water and demineralizer
effluents for settling and neutralization.
After extensive public hearings, the Minnesota
agencies Issued permits for the appropriation and discharge
of water from the King plant. These permits require cooling
towers in order to limit the temperature of the cooling
water discharges. The entire coal storage area will be
enclosed by a dike and its bottom will be covered with
impervious material for the purpose of preventing the
direct run-off of rain water from the coal area into the
river or ground. The permits provide for pre and post
operational monitoring of environmental conditions which
include extensive studies of river temperatures, algae,
macro invertebrates, fish, and chemical constituents of
the river. The other future plants of Northern States Power
Company will be designed and constructed with equal care
for the prevention of water pollution.
Northern States Power Company has entered into a
positive program of plant operation and costly construction
in order to fully cooperate with the efforts of governmental
agencies to protect the waters of the midwest.
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403
A. V. Dienhart
Respectfully submitted,
(Signed) D. F. MoElroy
Vioe President - Engineering
That concludes the statement. Copies have been
given to Mr. Lyle Smith for submittal to the formal record
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404
A. V. Dienhart
MR. STEIN: Are there any comments or questions?
(No response. )
MR. STEIN: Well, we have been hearing a lot
about the Northern States Power Company. I was up at Still-
water and am kind of familiar with that controversy.
I see you have several devices, cooling towers,
and so forth, and so on?
MR. DIENHART: Yes, sir.
MR. STEIN: How much above the water temperature
that is taken in will the water be when you discharge it, or
will it be pretty close?
MR. DIENHART: This will vary. The permit from
the State requires that at the point of discharge to the lake,
the temperature shall not exceed 86 degrees, and that is the
basis upon which the cooling towers and the discharge
structures were designed.
The degree of rise then would vary over the year,
depending, of course, upon the temperature of the incoming
water.
MR. STEIN: But you have a maximum discharge of
86 degrees?
MR. DIENHART: That is correct.
MR. STEIN: Is that at the point of discharge, or
do you have a mixing zone?
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405
A. V. Dienhart
MR. DIENHART: That is at the point where the
discharge enters the lake. There is no mixing zone provided
in the permit.
MR. STEIN: Thank you.
Are there any further questions?
(No response. )
MR. STEIN: Thank you very much.
Mr. Smith?
MR. SMITH: Next I would like to call on the
Minneapolis-St. Paul Sanitary District.
STATEMENT OP KERWIN L. MICK, CHIEF
ENGINEER AND SUPERINTENDENT, MINNEAPOLIS-
ST. PAUL SANITARY DISTRICT, MINNEAPOLIS,
MINNESOTA
MR. MICK: Mr. Chairman, Conferees:
My name is Kerwin L. Mick, Chief Engineer and
Superintendent for the Minneapolis-St. Paul Sanitary District.
The District feels that the Federal survey was a
very valuable project and it furnished a great deal of valuable
data for use in controlling the pollution of the waters in
this area.
We were somewhat disappointed in the publicity,
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406
K. L. Mick
you might say, that resulted from the summary report of the
survey, because there was no mention of any accomplishments
towards the solution of these problems on the part of the
District, or, for that matter, the Water Pollution Control
Commission.
Those points have already been brought out. We
felt that that was a mistake. They should have at least
recognized what progress has been made. The implication has
been created as a result of the publications in the press,
and has given the public the Impression, that nothing has been
done, and the facts do not support this impression.
We have here a nine-page statement and a three-
page summary that was approved by our board of trustees at
the meeting on February 27th. Copies of this statement have
been furnished to the conferees through the State Water Pollu-
tion Control Commission, and unless the conferees wish, I
will read the summary only, unless they wish me to read the
complete report.
MR. STEIN: Just the summary, if you would.
By the way, we are not cutting you off. If you
feel you want to read the entire report, the rostrum is yours.
MR. MICK; I am assuming that the conferees will
consider the complete report.
MR. STEINs Yes, and they will not just accept
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407
K. L. Mick
the summary. If you wish, the entire report will appear in
the record as if read.
MR. MICK: Thank you.
MINNEAPOLIS-SAINT PAUL SANITARY DISTRICT
STATEMENT TO THE
FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
U. S. DEPARTMENT OP INTERIOR
February 27, 1967
INTRODUCTION
The Minneapolis-Saint Paul Sanitary District has
a direct and predominant interest in the Federal Water Pollu-
tion Control Administration report on "Summary and Pollution
Abatement Recommendations." The District's concern in this
area is a twofold one] one phase is a responsibility to control
and abate water pollution through the provision and operation
of treatment works; and the other is a responsibility to provide
economical sewage service to more than a million customers.
As in the past, the District endorses reasonable
river water quality objectives which are commensurate with
downriver water uses. On the other hand, the District opposes
water quality standards and the consequent higher waste water
treatment requirements which fail to consider the coat of
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408
K. L. Mick
treatment in terms of the benefits attained. The District
urges a reasonable and realistic balance between the cost of
treatment and the results of treatment.
LIMITATION OP REVIEW OF REPORT
The Minneapolis-Saint Paul Sanitary District has
given preliminary review to the "Summary and Pollution Abate-
ment Recommendations" of the Federal Water Pollution Control
Administration. Because of the fact that copies of the com-
plete report were not made available and a very limited time
was allowed for the evaluation of the Summary Recommendations,
the District has been unable to fully determine the impact of
these recomwendations upon the interests of the District.
Accordingly, the District requests a postponement or extension
of this conference to permit a thorough assessment of the im-
mediate and long range effect. A recess of 60 to 90 days is
necessary following the availability of the complete report
for the purpose of a proper evaluation.
GENERAL PROGRESS TOWARD POLLUTION ABATEMENT
The Federal Water Pollution Control Administration
report gives the impression that the Minneapolis-Saint Paul
Sanitary District has no active program for the abatement of
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409
K. L Mick
pollution. The fact is that the District has made real and
significant progress toward the accomplishment of a pollution
control program on the Mississippi River which is compatible
with the recommendations of the Federal Water Pollution Control
Administration report.
Comprehensive Investigations and studies have been
conducted of the sewage works and water pollution problems.
Moreover, the District has undertaken a vast and costly program
of expansion of the main treatment plant at a total cost in
excess of $27.0 million, of which $13.5 million is already
completed and in partial operation. The District has not
dodged its responsibilities in the pollution abatement program.
Instead, it has proceeded on its own initiative without waiting
for threats of action by the State pollution control agency
and without assurance of financial assistance through Federal
grants.
Nor is this approach one of recent precedent as
far as Minneapolis and St. Paul are concerned. In 1933, the
District and the Twin Cities placed in operation a 52 mile
system of Interceptor sewers and a primary treatment with a
total cost of $15.7 million. The plant was the first treat-
ment plant serving a major population center on the Mississippi,
Missouri and Ohio Rivers. Nearly thirty years later, several
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4 09-A
K. L. Mick
of the major cities on the Mississippi River and Missouri
River are only now installing primary treatment facilities.
Over this same period, the District has spent an amount of
$21.3 million for operation and maintenance of its treatment
plant.
STUDIES AND INVESTIGATIONS BY MSSD
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409-B
K. L. Mick
With an awareness of the potential sanitation
and water pollution problems, the Board of Trustees of
the Minneapolis-Saint Paul Sanitary District authorized
in 1956 an extensive five year program of research and
investigation of the metropolitan area's sewage works re-
quirements.
During the period from 1956 to 1961, at a cost
of one-half million dollars, studies were conducted to
determine the most economical and satisfactory solution
to the sewage problem of the metropolitan area. In addi-
tion to the development of a long-range sewage works plan,
several related aspects were investigated which had a
direct and significant bearing upon the recommended solu-
tion. Two reports involved a statistical summary of the
past characteristics of the Mississippi and Minnesota
Rivers, the capacity of the rivers to assimilate pollution,
and the necessary degree of treatment to maintain dissolved
oxygen levels or to meet certain river water quality ob-
jectives. Another report presented the basic engineering
plans and estimates of cost of alternate sewage works
projects for an extensively enlarged area of service as
well as an evaluation of the adequacy of the existing inter-
ceptor sewer system to convey flows under anticipated future
conditions.
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410
K. L. Mick
Three separate reports were prepared relative to
the apportionment, allocation and distribution of the costs
of the sewage works projects among the component municipali-
ties.
Thirty-six months of pilot plant and large scale
demonstration plant tests were conducted under field condi-
tions of various treatment processes which could be utilized
in the expansion of main treatment works.
Another of the engineering reports covered the
establishment of a treatment plant design basis and recom-
mendations for the incremental enlargement of the main
sewage treatment plant at the Pig's Eye Lake site.
SEWAGE TREATMENT PLANT EXPANSION
Upon the completion of preliminary Investigation
of sewage treatment requirements, the Minneapolis-Saint
Paul Sanitary District Board of Trustees authorized in 1961
a major expansion program of the Pig's Eye Lake Sewage
Treatment Plant to accomplish secondary treatment. The
plant expansion was designed to serve the two central
cities and the 24 suburbs served by the system (in 1962)
based upon this service area's anticipated growth and
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411
K. L. Mick
development to the year 1980. The general design basis
was as follows:
Type of Prooess - High-Rate Activated Sludge
Sewered Population - 1,545,000 Persons
Industrial Population Equivalent - 1,065,000 Persons
Total Population Equivalent - 2,610,000 Persons
Average Annual Flow Thru Plant - 218 million gallons per day
Removal of Suspended Solids - 85 percent
Removal of Pollutlonal Load With
Basic Treatment Prooess (BOD) - 75 percent
Control of Effect of Pollutlonal
Load by Supplemental Methods - As required to meet river
water quality standards
Destruction of Bacteria as
Measured by Conform Indicator
Organisms - 99 percent
The secondary treatment facilities form one part
of a long-range plan for the Incremental expansion of the
District plant. The site and arrangement of the treatment
units has been adapted for the future expansion of the plant
to a capacity of more than 400 million gallons per day on
the basis of the High-Rate Activated Sludge Process or the
Step Aeration Prooess.
At the time of the design of the treatment plant
expansion, no river water standards existed for the
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412
K. L. Mick
Mississippi River In the vicinity of Minneapolis and St.
Paul. Accordingly, the design was based upon a statement
of requirements issued by the Minnesota State Board of
Health In 1928. The statement provided essentially that
the pollution of the river should be restricted to such an
extent that the public health hazard would be reduced to a
minimum, that the health of livestock: would not be endangered,
that the public nuisance would be eliminated, and that fish
life in the river, at least below the mouth of the St. Crolx,
would not be jeopardized.
Classification and standards for the Mississippi
River subsequently adopted by the Minnesota Water Pollution
Control Commission in March of 1963* after the commencement
of the construction of the treatment plant expansion, pro-
vided for the maintenance of certain minimum dissolved
oxygen levels in the river water and a restriction upon the
concentrations of other contaminants. Compliance with
these standards will be accomplished with the High-Rate
Activated Sludge process plant as designed, with the oc-
casional employment of supplemental methods. Supplemental
methods which have been investigated and appear promising
include effluent aeration, river aeration, and effluent
chlorinatlon.
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K. L. Mick
TREATMENT PLANT CONSTRUCTION
Construction of the plant addition began In 1962
with the award of a oontraot for the relocation of more
than one mile of the main line tracks of the Chicago Great
Western Railway Company in order to provide a site for the
secondary treatment works. Twenty-six more construction
contracts have been awarded since the first one, totaling
over $24.0 million. Of the contracts which have been
awarded, twenty-two are essentially completed, including
the major contracts for secondary aeration and final sedi-
mentation tanks and the air compression system.
Listed below are the major contracts, the ap-
proximate amounts, and the present stage of completion of
the plant expansion program.
Approximate Percent
Project Cost Completion
Railroad Relocation $ 109,000 100
Site Clearing and Demolition 145,000 100
Garage and Warehouse 187,000 100
Aeration Compressor Equipment 395/000 100
Dike Construction 199,000 100
Aeration Tanks-Gallery-Final Tanks 8,263,000 100
Diesel Electric Generator 85,000 100
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414
K. L. Miok
Approximate Percent
Project Cost. Completion
Boiler Room and Shop Addition $ 414,000 100
Compressor Building 2,031,000 100
Administration Building 566,000 130
Instrumentation and Control System
(Ph.l) 216,000 100
Sludge Vacuum Filtration Equipment 700,000 75
Sludge Incineration Equipment 2,122,000 85
Filtration and Incineration Building 5,036,000 75
Chlorine Contact Channel 312,000 100
Sludge Concentration Tanks 343,000 100
Screen and Grit Chamber Modifications 839*000 50
Sludge Thickening Tanks 2,202,000 10
Miscellaneous 100,000 100
Total $24,264,000
The progress that the Minneapolis-Saint Paul
Sanitary District has made is evident from the above tabula-
tion. Sludge disposal works are scheduled for completion in
the fall of 1967. With the completion of the remaining
construction projects, the construction cost Is estimated
at approximately $27.0 million.
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415
K. L. Mick
TREATMENT PLANT OPERATION
Secondary treatment facilities were initially
placed in operation in April 1966 and are presently in
partial operation pending completion of the enlarged sludge
disposal works. During the summer of 1966, the secondary
plant was operated over a three-month period at removal
efficiencies in excess of the design basis. The limited
operation of the secondary facilities to date has demon-*
strated that the new works are fully capable of treatment
in compliance with the design removals and that the sewage
and Industrial wastes of this metropolitan area are amenable
to treatment by either the High-Rate or Conventional
Activated Sludge Process.
COMMENTS ON GENERAL RECOMMENDATIONS
Relative to the classification and water uses
proposed in Item No. 2 of the General Recommendations,
Enhancement of Water Quality, for the segment of the
Mississippi River downstream from the Minneapolis-Saint
Paul Sanitary District treatment plant, the District's
position is one of limited concurrence. Water uses
enumerated for this section of the river correspond in
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416
K. L. Mick
principle to the classification and Standards of the State
of Minnesota Water Pollution Control Commission. The State
designation of water uses are those which may be realistically
obtained downriver from a major center of population and in-
dustrial activity.
To achieve and maintain the enhancement of water
quality and the proposed water uses for the Mississippi River
between the District plant and Lock and Dam No. 2, the District
endorses the prevailing Standards of the State of Minnesota
Water Pollution Control Commission as adopted in 1963 and
opposes the more restrictive Federal Water Pollution Control
Administration recommendations. The existing State standards
are reasonable, adequate, and consistent with present and
possible future downstream water uses.
Further, the District urges the extension of the
zone of lower DO requirements downstream from Lock and Dam No.
2 to the mouth of the St. Croix River.
Item No. 3 of the General Recommendations, Treatment
of Municipal Wastes, establishes a minimum level of treatment
efficiency for all plants regardless of their location or the
concentration or character of the influent waste.
In the Minneapolis-Saint Paul Metropolitan Area
situation, where major rivers course through the highly populated
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417
K. L. Mick
areas, it is only reasonable that a lower level of treatment
be required at a plant site downstream from the center of
population. Imposing a uniform level of treatment, as measured
by the conventional indices, for all plant locations falls to
recognize the significance of the Inability of the secondary
biological treatment processes to remove various of the newer
chemical contaminants.
Implementation of this restrictive feature of the
recommendations will saddle the Minneapolis-Saint Paul Sanitary
District with the financial burden of another expansion of
the main treatment plant before it is necessary. A preliminary
investigation indicates that to meet this effluent quality on
a continuous basis will necessitate the employment of the
Step Aeration Process at the District treatment plant. An
additional expenditure of approximately $10.0 million will be
required for the first phase of these treatment and sludge
disposal works, based upon a design period and loading which
corresponds with the plant expansion presently underway. In
addition to the large capital cost involved, higher operating
costs will be incurred to the extent of $300,000 per year.
Adoption of this measure precludes the employment
of supplementary methods of treatment such as heavy chlorina-
tion and aeration of the river to restore oxygen resources,
which our studies have shown to be decidedly more economical
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K. L. Mick
than conventional processes to meet short duration treatment
requirements.
More than one interpretation can be made of the
intent of the General Recommendations relative to the appli-
cation of the coliform guide value of 5,000 per 100 ml
required by Guide B. On the basis of the wording maximum
concentration "for any one sample," the proposed limitation
is unreasonably restrictive and actual compliance would be
virtually Impossible. River water upstream from Minneapolis
at the water intakes does not consistently meet this require-
ment. Obviously, the Intent of the report is "average" con-
centrations as stated in the case of Guide C - Source of
Water Supply.
Chlorination on a year around basis as included
in the report recommendations is not consistent with the
stated river water uses of limited body contact recreational
activities and commercial shipping. Both of these activities
are limited by the climate and the resulting ice cover to no
more than one-half of the year. Chlorination at the heavy
dosage required to maintain the coliform Guide B level during
winter months causes a substantial expenditure toward pollu-
tion abatement without accomplishment of any real benefit.
The cost of effluent disinfection is nearly
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K. L. Mick
proportional to the duration of its employment. Our
estimate is that the continuous chlorination cost will be
approximately $360,000 per year while the cost of four
months of chlorination will be approximately $150,000. It
is the Minneapolis-Saint Paul Sanitary District"s position
that the expenditure for chlorination outside of the recrea-
tional season is not justified in terms of the benefits to
downriver users. Chlorination of the plant effluent to
these low levels of coliform would be negated by overflows
from the combined sewer system at times of heavy rainfall.
Even with complete separation of the sewers, there will be
heavy coliform contaminations from the runoff discharged
from the storm sewers.
COMMENTS ON SPECIFIC RECOMMENDATIONS - MISSISSIPPI RIVER
The Minneapolis-Saint Paul Sanitary District is
definitely opposed to this three sentence paragraph because
of its implications and effect on the best and most economi-
cal solution of this Metropolitan Area problem. It relates
to conditions in the Hasting's pool, and recommends a
minimum dissolved oxygen level of 3.0 mg/1 under stated mini-
mum discharges of the river in this section. The paragraph
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K. L. Mick
of the recommendations continues - "To attain this, combined
wastes loads from these sources should not exceed 68,500
pounds/day of 5 day BOD". A maximum suspended solids
loading of 85,5°° pounds/day is also recommended. The
purpose of the inclusion of this paragraph appears princi-
pally to be related to the maintenance of dissolved oxygen
levels in this pool.
The effect of this provision is to require a
higher degree of treatment in this section of the river than
in other reaches. For example, a minimum of 80 percent BOD
and suspended solids removal is required for other sections,
but the limitation of 68,500 pounds/day of 5 day BOD (equal
to 400,000 population equivalent) would require a BOD re-
moval of 90 percent in 1980 and 94 percent In the year 2000.
This section of the river by its very nature, downstream
from the population center and flowing through highly
industrialized areas, should allow for a lower quality of
water when compared to other sections, as the present
Minnesota Water Pollution Control Commission's Standards
provide.
The District requests the elimination of this
paragraph from the recommendations for the following
additional reasons:
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K. L. Mick
1. Whereas the quality standard of 3 mg/1 of dissolved
oxygen under certain stated flows, and the 80 per-
cent BOD removal are "judgment" selections, the
stated allowable effluent pollutional limit of
68,500 pounds of BOD per day (400,000 population
equivalent) is a calculated value based on a large
number of assumptions and technical uncertainties
which go beyond the other standards and requirements,
In addition to uncertainties in the mathematical
calculations, assumptions had to be made in a number
of factors which affect river assimilative capacity
to arrive at this arbitrary number. These include
among others, temperature, DO and BOD levels of
incoming rivers, channel depth, reaeratlon and
deoxygenation constants and rates, river discharges,
and water supply extractions. Many of these are
dependent on future decisions and actions of groups
concerned with this problem.
2. One of the assumptions that was made in the calcula-
tions was that the plant effluents would contain
zero dissolved oxygen. This Is a very conservative
assumption as shown by Progress Report 165-S pre-
pared as part of University of Minnesota -
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K. L. Mick:
Minneapolis-Saint Paul Sanitary District cooperative
research program. This report shows that under
summer conditions the existence of 4 mg/1 of DO
in the plant effluents would Increase the assimila-
tive capacity of the river at this point by 10 per-
cent (7100 Ibs. of BOD = 42,000 population equiva-
lent). Effluent sampling has Indicated that 4 mg/1
is a reasonable expectancy by natural means. This
could be augmented by mechanical aeration of the
effluent to further Increase the receiving capacity,
to values double the above if the effluent were
saturated. The above Is a significant item and
shows the effect of but one factor on which assump-
tions were made.
3. The employment of this arbitrary "rule" completely
negates the many auxiliary methods which are avail-
able and which have been used in the U. S. and
foreign countries to augment DO resources. In
addition to "in-plant" effluent aeration and chlorin-
atlon for BOD removal and retardation, the river's
resources can be augmented by river aeration at
hydro-plants, mechanical surface aeration and aera-
tion at dams by low flow augmentation. Many of
these methods can accomplish the same objective-
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K. L. Mick
maintaining minimum DO levels at the critical
point - much more economically than the seemingly
simple expedient of requiring a higher degree of
treatment.
4. The report refers only to Minneapolis-Saint Paul
Sanitary District and South Saint Paul effluents
in setting the 400,000 population equivalent value.
The only reference to other pollutional loads Is
that the several lower industrial effluents to the
Hast ing's pool are small (1 or 2 percent),, This
is not likely to be so in the future. Are they
to share in this allowable limit, or are they neg-
lected as a pollutional element?
5. A further question arises as to the application of
the above limit in the apportionment of this assimi-
lative capacity. The present major industrial load
is from an industry with a large seasonal variation
in load, with usual low loads in August and Febru-
ary. Who now is going to apportion this capacity?
The calculations to arrive at pollutional loads and
assimilative capacity are based on average annual
mass loads.. Growth, particularly of Industries
which are a key to this pool, is time dependent.
6. In the matter of this apportionment, the report does
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K. L. Mick
not oome to "grips" with the key economic and
legal question, i.e., are all users of this appor-
tioned capacity to provide the same quality of
effluent in mg/1 or are they to provide the same
degree of treatment in percent? The decision, in
this case is of great importance.
7. The Board of Trustees of the District and its engin-
eers have consistently held to the judgment that the
best solution to the water pollution problem of this
Metropolitan Area was in collection and treatment
at one or more plants downriver of the centers of
population. The use of this arbitrary capacity
limitation of 400,000 population equivalent, without
provision for the use of augmenting alternatives,
encourages those who propose upriver plants, to
the detriment of water quality through the centers
of population.
8. In conclusion it IB recommended that this paragraph
be stricken because It has no sound basis, is inde-
fensible, and is likely to lead to protracted liti-
gation.
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K. L. Mick
SCHEDULE OP REMEDIAL PROGRAM
Although not acknowledged in the FWPCA report,
the Minneapolis-Saint Paul Sanitary District began the remedi-
al program toward further control and abatement of pollution
in 1962 with the commencement of a $27 million program of
expansion at the Pig's Eye Lake treatment plant. As indi-
cated previously in this statement, the facilities for the
High-Rate Activated Sludge Process secondary treatment are
completed and are in partial operation. Construction is well
under way of the sludge disposal works which accompany the
expanded treatment units.
While the secondary treatment plant expansion
has been fully utilized for test periods and the District is
assured that treatment will be accomplished at least equal to
the design basis, there has been no opportunity for an evalua-
tion of the effect of the much Improved levels of treatment
on the river water quality. Until a complete evaluation is
made of the full plant performance, the necessity for further
expansion is not apparent.
Based upon the accomplishments of the Minneapolis-
Saint Paul Sanitary District and in recognition of the status
of its plant expasion program, the District requests a
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K. L. Mick
modification to the Schedule of Remedial Program to permit
a full evaluation of the effect of new plant on the Mississippi
River before proceeding further with any additional improve-
ments.
SUMMARY
1. Introduction
The Minneapolis-Saint Paul Sanitary District has
a direct and predominant interest in the Federal Water Pollu-
tion Control Administration report on "Summary and Pollution
Abatement Recommendations." The District has both a
responsibility to control and abate water pollution through
the provision and operation of sewage treatment works and a
responsibility to provide economical sewage service to more
than one million customers.
While the District endorses reasonable river
water quality standards which are commensurate with downriver
water uses, it opposes recommendations or standards which fail
to consider the cost of treatment in terras of the benefits
attained.
2. General Progress Toward Pollution Abatement
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K. L. Mick
The PWPCA report gives the impression that the
District has no active program for the abatement of pollution.
The fact is that the District has made real and significant
progress toward the accomplishment of a pollution control
program which is compatible with the recommendations of the
PWPCA report.
During the period from 1956 to 1961, at a cost of
one-half million dollars, comprehensive investigations and
studies were conducted by the District to determine the most
economical and satisfactory solution to the sewage problem
of the metropolitan area.
In 1962, the District commenced the construction
of a $27 million program of expansion of the main treatment
plant to accomplish secondary treatment with the High-Rate
Activated Sludge Process. Twenty-seven construction contracts
totaling over $24 million have been awarded. Twenty-two
projects, at a cost of $13.5 million, including the secondary
aeration and final sedimentation tanks, are already completed
and in partial operation.
Secondary treatment facilities were initially
placed in operation in April 1966 and are presently in partial
operation pending completion of enlarged sludge disposal
works. The operation of the secondary facilities to date has
demonstrated that the new works are fully capable of treatment
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K. L. Mick
in compliance with the design basis.
These facts show that the District has not dodged
its responsibilities in the water pollution control program.
Instead, it has proceeded on a vast and costly program of
treatment plant expansion on its own initiative, without
waiting for threats of action by the State pollution control
agency and without assurance of financial assistance through
Federal grants.
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K. L. Mick
I will say that the State Water Pollution
Control Commission has suggested that we should be thinking
about expanding the plant and studying it for the future, so
we did do that. That was a verbal statement on their part.
We have also since received a Federal grant. After applying
for three years in a row, we finally received a Federal grant
on the facility now under construction.
3. Comments on General Recommendations
To achieve and maintain the enhancement of water
quality and the proposed water uses for the Mississippi River
between District plant and Lock and Dam No. 2, the District
endorses the prevailing Standards of the State Water Pollution
Control Commission as adopted in 1963 and opposes the more
restrictive FWPCA recommendations. The existing State Standards
are reasonable, adequate, and consistent with present and
possible future downstream water uses.
Now, I understand there is some question whether
these figures are going to mean anything from the discussion
this morning. That shows the difficulty we have had in only
the two weeks that we have had this report, and only a summary
report. It has been impossible to completely reevaluate the
impact of the Standards.
Item No. 3 of the General Recommendations,
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K. L. Mick
Treatment of Municipal Wastes, establishes a minimum level
of treatment efficiency for all treatment plants, regardless
of their location or the character of the influent wastes.
Implementation of this restrictive feature of the recommenda-
tions will saddle the District with the financial burden of
another expansion of the main treatment plant before it is
necessary. A preliminary investigation indicates that to meet
this effluent quality on a continuous basis will necessitate
the employment of the Step Aeration Process at the District
treatment plant. An additional expenditure of approximately
$10 million will be required for the first phase of these
treatment and sludge disposal works, based upon a design
period and loading which corresponds with the plant expansion
presently under way. In addition to the large capital costs
involved, higher operating costs will be incurred to the extent
of $300,000 per year.
Chlorination on a year-around basis as included
in the report recommendations is not consistent with the
stated river water uses of limited body contact recreational
activities and commercial shipping. Both of these activities
are limited by the climate and the resulting ice cover to no
more than one-half of the year. Chlorination at the heavy
dosage required to maintain the coliform Guide B level during
winter months will cause an extra expenditure of approximately
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K. L, Mick
$200,000 per year toward pollution abatement without accomplish-
ment of any real benefit. There are no public waters to protect
below it. It is the Minneapolis-Saint Paul Sanitary District's
position that the expenditure for chlorination outside of the
recreational season is not justified in terms of the benefits
to downriver users.
4. Comments on Specific Recommendations — Mississippi
River.
The District is definitely opposed to the Specific
Recommendations - Mississippi River, because of the implica-
tions and effect on the best and most economical solution to
this metropolitan area problem. This provision of the recom-
mendations limits the combined waste load of the effluents of
the District and South Saint Paul treatment plants to 68,500
pounds/day of 5-day BOD and 85*500 pounds/day of suspended
solids.
The effect of this provision is to require a higher
degree of treatment in the Hastings pool than in other up-
river reaches of the Mississippi River. Instead, this lower
section of the river, downstream from the population center and
flowing through industrialized areas, should allow for a lower
quality of water. Further, the employment of this arbitrary
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K. L. Mick
rule completely negates the many auxiliary methods that are
available to augment DO resources at less cost than conven-
tional treatment, and I should add, during periods of unusually
low flow.
The Board of Trustees of the District and its
engineers have consistently held to the judgment that the best
solution to the water pollution problems of this metropolitan
area was in collection and treatment at one or more plants
downriver of the centers of population. The use of this
capacity limitation encourages those who propose upriver treat-
ment plants, to the detriment of water quality through the
centers of population.
In conclusion, it is recommended by the District
that this paragraph be stricken because it has no sound basis,
is indefensible, and is likely to lead to protracted litigation.
5. Schedule of Remedial Program
Although not acknowledged in the PWPCA report,
the District began the remedial program toward further control
and abatement of pollution in 1962 with the commencement of
a $2? million program of expansion at the Pig's Eye Lake treat-
ment plant. The facilities for the high-rate activated sludge
process secondary treatment are completed and in partial opera-
tion and construction is well under way of the accompanying
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K. L. Mick
sludge disposal works.
Based upon the accomplishments of the Minneapolis-
Saint Paul Sanitary District and in recognition of the status
of the plant expansion program, the District requests a modi-
fication to the Schedule of Remedial Program to permit a full
evaluation of the effect of the new plant on the Mississippi
River before proceeding further with any additional improve-
ments.
In other words, we would like to complete our
present plant expansion, evaluate its performance and its
effect on the river, and redetermine the many assumptions that
have been made on the river, such as the effect of effluent
on the river, so that we will then be in a better position to
know what we would have to do to comply with any further
requirements that may be established for the river standards.
MR. STEIN: Thank you, Mr. Mick.
Are there any comments or questions?
DR. JELATIS: Mr. Chairman?
MR. STEIN: Yes, Dr. Jelatis.
DR. JELATIS: I feel that I have to comment on
this, because we have testified at previous hearings as being
from a downriver community, that we would like to see the
highest possible standards established and maintained in the
sections 01 the river above us which affect the river quality
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K. L. Mick
below the plant effluents all the way down into Lake Pepin.
The Summary Report points out that the river
bottom conditions in Lake Pepin are exclusively organic sludge.
There is some sand aixed with the organic sludge in a portion
of the river — I believe it is near Lock and Dam No. 3 —
perhaps because there is more rapid river flow.
Now, we very much appreciate the improved treatment
facilities that are being put in by the Minneapolis-Saint Paul
Sanitary District, but we cannot escape the feeling that these
facilities have always been put in on the basis of crisis, and
a little bit too late, not properly anticipating the future
demands.
As to the statement of costs, what is the popula-
tion area served now by the Twin Cities Sanitary District, the
number of people?
MR. MICK: At present we have one and a quarter
million persons connected to the plant.
DR. JELATIS: I believe in the main report you
point out that the sewered population is about one and a half
million. This is considering growth through I960?
MR. MICK: Yes.
DR. JELATIS: Well, just commenting on the statement
you make that it has proceeded on a vast and costly program of
treatment plant expansion without financial assistance, this
is very fine, but when you consider this on a per capita basis,
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K. L. Mick
$30 million even over one and a half million population is
about $20 per capita.
MR. MICK: We don't wish to make the point that
that is an excessive cost for our expansion.
DR. JELATIS: Well, I would just like to point out
that many smaller communities with much smaller populations of
10,000 to 20,000 have been spending up to $150 or $200 per
capita for construction of plants, and we feel that perhaps
until the per capita expenditures for sewage treatment are at
a higher level than what you propose, that it is not an
inordinate cost to a relatively affluent metropolitan district.
MR. MICK: Your figures of $150 to $250, I believe
were based on dollars per capita for plants in smaller towns,
probably including the sewer system. If we included the sewer
system in the Twin Cities, the expenses per capita would be
somewhat similar.
We do not really oppose the standards at all,
because it Is Just a question of whether the Federal or the
State are the least restrictive. They are both compatible.
Also, I would like to point out that the sludge
deposits that you have mentioned are the result of many years
of primary treatment only both in our plant and not much more
than that in the South St. Paul plant, and both our plant and
the South St. Paul people are planning extensive improvement,
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K. L. Mick
and will be required to make extensive improvements as a
result of this survey, so that we feel that as soon as our
plant goes into full operation and the South St. Paul plant
completes their proposed program, it will no longer be
accumulating organic deposits. It will take a few years to
get rid of them.
However, I remember back when our primary plant
went into operation in 1938* there was an extensive sludge
deposit in the area of St. Paul, and it had been called a
cesspool by some. It was not true. It was not that bad, but
it was a cesspool before any treatment was installed at all.
We have motion pictures to prove that. We have sludge coming
out of the river and the gas lifting the sludge deposits, but
that condition cleared up within one year after our primary
treatment went into operation, so you will not be bothered by
those sludge deposits for a long period of time after the
additional treatment is installed.
DR. JELATIS: Yes. We understand certainly that
there has been improvement and are grateful for the improved
facility you are putting in, but I think there is also no
question that the assimilative capacity of the river does not
increase in keeping with population growth, and as the popula-
tion growth continues to expand, and it is projected in the
year 2000 there may be three million people in this area.
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K. L. Mick
MR. MICK: We recognize in the main body of this
statement that the requirements of the survey, at least, if
they are adopted by the conference, would require that we put
in 90 percent treatment by 1980 and 94 percent by the year 2000.
DR. JELATISj Thank you.
MR. STEIN: Are there any other comments or
questions?
MR. WILSON: Mr. Chairman?
MR. STEIN: Yes.
MR. WILSON: I would like to repeat something that
I said yesterday, and that is that provision for anticipation
of future population growth is going to depend on many things.
And this is primarily because with reference to the future
population growth of the seven-county metropolitan area, in
principle,Increases in that population are not taking place
within the central cities of St. Paul and Minneapolis, which
now compose the Minneapolis-St. Paul Sanitary District.
The only authority that that District has for
taking care of the sewage of these rapidly expanding suburbs
is by contracts, and that is a very unsatisfactory method of
financing the construction of the very expensive interceptor
sewers and other works that must be provided for in advance
of the actual population growth in order to avoid future over-
loading. For that reason, recognition must be given to the
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K. L. Mick
fact that the last three Legislatures have disregarded this
problem.
Instead, the Legislature of 1961 created the North
Suburban Sanitary Sewer District within this metropolitan
area, composed of six communities north of the Twin Cities,
with a then population, I think, of nearly 60,000, which is
rapidly increasing. The creation of this District within the
area that should have been included in an enlarged metropolitan
district has created many complications.
This District has been literally a thorn in the
flesh of the Minnesota Water pollution Control Commission
(Laughter). The first thing it did after its creation was
to contest the authority of the Minnesota Water Pollution
Control Commission and the State Board of Health, in which the
North Suburban District lost out. The Court held that the
District was subject to the authority of the Minnesota Water
Pollution Control Commission, as well as the State Board of
Health, in the matter of requirements for compliance with the
construction of a sewage treatment plant and other facilities.
The result of that was that the North Suburban
District proceeded with the construction of its local sewerage
system, for which there was extremely urgent and immediate
need, and nobody would quarrel with the importance of getting
ahead with that project as rapidly as possible.
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K. L. Mick
The issue was precipitated later, as I have
already mentioned, over the standards established by the
Water Pollution Control Commission when the North Suburban
District wanted to construct a sewage treatment plant with
an outlet below the Minneapolis water intake on the St. Anthony
Palls pool, and that is what has tangled the Water Pollution
Control Commission up in litigation, now on the way to the
Supreme Court. As I said before, it probably will take another
year to get a final decision.
This is just an example of the way the Minnesota
Legislature has trifled and temporized with this program, in-
stead of doing what it should have done in 1961 in accordance
with the recommendations of both the Water Pollution Control
Commission and the Board of the Sanitary District, enlarging
the Sanitary District so that it could have dealt adequately
with these expansion programs.
They delayed action on that, and action is still
being awaited at this session of the Legislature that will
provide an ultimate solution to the important problem that
Mayor Jelatis has called attention to — that is to say,
anticipating the future needs before a crisis occurs.
MR. MICK: I might further comment on Mr. Wilson's
remarks to the extent that when we proposed the design for the
plant expansion, the only authority we had was to serve the
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K. L. Mick
two central cities and the 24 suburbs that were actually under
contract at that time.
Presently we have 39 under contract, and we still
have no authority to design any facilities. The plant is
designed for 1980 to expect a load from those 24 suburbs.
We now have 39 connected to them. We would have to expand
the plant presumably before 1980.
MR, STEIN: Thank you. I have three comments. The
first one I am going to make with trepidation, Mr. Wilson.
I have been coming here for years and hearing about the need
for the Legislature to set up this central metropolitan
district, and I have followed some of the controversy, etc.
What I find here is the same kind of situation we have been
finding in recent years — five or six different bureaus
competing in a short legislative session.
It seems to me, from an outsider's point of view
and having had a considerable amount of experience with State
Legislatures as well as Federal legislation, that if you are
going to get a bill like this through one of the first steps
you have to take is to get the vast majority of the people
behind one measure that they can agree on and let it go.
With all of these bills before the Legislature on a
relatively complicated issue, I don't know that it is
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K. L. Mick
productive to put the blame on the Legislature. What do
you get? You go through another session where they are
adjourned, and we don't have the mechanism.
My next comment on another field is, I would say,
Mr. Mick, that you have stated you don't know whether the
requirements that we would have or the ones that the State
has are more lenient or not; you did not get the report in
time; and then you say on this issue that getting the report
six months in advance wouldn't help resolve it. What has to
be done is to have a computer arrangement with past records
put into a machine.
It is not readily apparent which is the more re-
strictive, and that is what we hope we are going to do* I
think you have analyzed the report, but this short time had
nothing to do with this analysis. Unless you had all these
records and computer time, I don't think you would have come
up with the answer either.
MR. MICK: We did some computer work, too, on
that analogy, but we didn't have time to complete it.
MR. STEIN: Yes. Now, I understand all your points,
but on one of those, what do you mean by the statement that
there are three methods now available to augment the dissolved
oxygen resources at less cost?
MR. MICK: You see, our river is rather — I don't
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K. L. Mick
know whether it is unusual or not, but it has an extreme range
of flow, and we have some low flows that occur once in a long
time.
MR. STEIN: Yes.
MR. MICK: And to require a complete installation
of treatment, to take care of these extreme low flows, is much
more expensive than to provide some auxiliary mechanism that
you temporarily use. You might call it a super-chlorination
of the effluent, which some data done for us by the University
of Minnesota in our research agreement with them indicated that
we could obtain about two parts per million BOD reduction for
every part of chlorine that we added, and that might tide us
over some of these critical low periods.
Another method is direct aeration of the river, or
a dam, such as we have worked on, which I believe has been
mentioned here before, and aeration through hydraulic power
installations, and so forth.
MR. STEIN: I see what you mean.
I might say, at least with the experience that I
have had throughout the country, the results of super-ehlorina-
tlon or aeration in a river have not been too successful.
We do a fairly good job in the pulp and paper
industry with aeration in lagoons, but that aeration in the
river is kind of like putting bubbles in a fish tank. They
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K. L. Mick
are dissipated. In a few seconds they cone up. Some people
have told us that we do more good by breaking the surface
tension and letting in surface oxygen than by putting air
into the river.
So far we have not been very good at this kind of
thing.
MR. MICK: We have done some work on that in the
University on a pilot plant scale,
I understand the Sanitary District of Chicago is
installing a number of aeration points like that. They have
had it in their budget, anyway.
MR. STEIN: Well, you know, dealing with the
Chicago situation again, what you have is a real slack water
canal and, in effect, a lagoon.
As I say, aeration has worked in a lagoon, but
when you deal with a river with a natural bottom and a flow,
this is part of the art I don't think we have mastered yet.
MR. MICK: It is the periods of extreme low flows
that I am speaking about. The river above Hastings Dam is
practically like a lake at very low flows.
MR. STEIN: Thank you.
Are there any comments or questions?
MR. WILSON: Mr. Chairman?
MR. STEIN: Yes, Mr. Wilson.
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K. L. Mick
MR. WILSON: I should like to add another word
in view of the Chairman's comments on the responsibility of
the Legislature.
I think it is fair to say that the Minnesota
Water Pollution Control Commission has done its utmost to
establish and maintain, against attack, the highest standards
that can be justified on the facts for the section of the
river which is most important in this matter in this metro-
politan area.
I think it is also fair to say that this
Minneapolis-St. Paul Sanitary District has done its utmost
within the limits of its financial and legal capacity.
It would be utterly futile for the Minnesota Water
Pollution Control Commission, or, for that matter, the Federal
Water Pollution Control Agency, to issue any orders to this
Twin Cities Sanitary District to do any more than it has done,
because it would be beyond its financial and legal capacity.
Perhaps the Federal agency might try to issue
orders to the Minnesota Legislature. How far they would get
with that I do not know.
But, as I said yesterday, the key log in this Jam
is in the lap of the Legislature. There is no way to prevent
a multiplicity of bills. Anyone who has legislative experience
at all knows that. Every member of the Legislature, of which
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K. L. Mick
we have one of the largest in the country, is privileged to
introduce a bill on every subject.
The features of these sanitary district bills
with respect to representation and financing are extremely
controversial, and the settlement of those controversies is
absolutely in the hands of the Legislature.
Neither the Minnesota Water Pollution Control
Commission nor the board of trustees of the Sanitary District
can decide or settle those questions of who is to have
representation on the board of trustees of an enlarged Sanitary
District, or how that District is to be financed.
Those questions are solely within the power of
the Legislature and that is where the responsibility lies.
MR. STEIN: Maybe we will let it stay there.
Let me try this once again, Mr. Wilson. I hope
I am going to be very short.
I am not talking about orders to the Legislature.
As a matter of fact, this is one thing I think the statements
here can bear out, and the record will show who is making
the exhortation about the Legislature. Nor did I talk about
any man or member of the Legislature having his authority
restricted in introducing a bill.
What I am saying is that the Twin Cities area is
like any other city. In order to get one of these districts
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K. L. Mick
through, you have to get a coalescing of the citizens of the
area around a specific proposal, complicated as it is.
This was so in Chicago; it was so in Kansas City;
it was so in St. Louis; it was so in Seattle; and I suspect
before you get a viable district here along the lines you are
saying, this is so here.
I know that the job of getting people together is
not an easy one, but this is a prerequisite, and the way to do
this is not by ordering anyone, but by convincing them. It
seems to me what may be lacking in this area is a single plan
or bill where you have the majority of the people supporting
and recognizing that this is the bill that you want.
I have found, in the last analysis, that the
public officials, including us, generally give the people about
what they want.
Are there any further questions?
(No response. )
MR. STEIN: If not, Mr, Smith, would you call for
your next statement?
MR. SMITH: I would like to call on the City of
South St. Paul.
STATEMENT OP JOHN P. BADALICH, CITY
ENGINEER, CITY OP SOUTH ST. PAUL, MINNESOTA
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44?
J. P. Badalich
MR. BADALICH: For the record, my name is John
Badalich, City Engineer, City of South St. Paul.
Our purpose in appearing at this particular
conference is not to argue the merits or demerits of this
particular summary, but we would like to bring to the atten-
tion of the conferees the progress the City of South St. Paul
has made in the past two years.
Since the previous report of the City of South
St. Paul to the conferees of Minnesota, Wisconsin and the then
Federal Public Health Service at a similar pollution conference
held in St. Paul in February of 1964, the City of South St.
Paul has continually since that date recognized its responsi-
bility with respect to sewage collection and treatment by
initiating and completing detailed engineering studies for
further improvements to the sewerage system and the Municipal
Sewage Treatment Plant. Following the completion of these
engineering studies and plans and specifications for stage
construction of these improvements, the city has also initiated
steps for immediate construction of these improvements which
will be brought out in further detail in this report.
At this point, I would like to interject with
reference to some of the remarks of Mr. Wilson yesterday, and
also for the record, that the City of South St. Paul also on
its own initiative, back in 1940, constructed a municipal
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J. P. Badalich
sewage treatment plant for the treatment of municipal and
packing house wastes. Thia was the year following the con-
struction of the Minneapolis-St. Paul Sanitary Plant.
Regressing for a moment and after the completion
of a waste stabilization pond that further treated the
effluent from the main sewage treatment plant, which was
constructed in 1963* a very significant increase in the degree
of treatment was accomplished.
Operating records from February 1963 through March
of 1966 showed that the South St. Paul Sewage Treatment Plant
processed approximately 12.7 million gallons of sewage daily,
consisting of an average flow of 14.15 wgd for weekdays, and
8.70 mgd for Sundays and holidays.
The overall average removal in pounds of BOD was
increased to 84.3 percent. The overall removal of suspended
solids was an average of 90 percent. Prom these results it is
shown that an overall efficiency in our sewage treatment opera-
tion has increased well over 50 percent. In BOD removal alone
through use of the stabilization pond, the BOD loading to the
river decreased in excess of 60 percent over the amount
previously discharged from the main plant.
The Federal Water Pollution Control Administration
publication which we are reviewing this morning Indicates on
Table 2, based on data collected during the survey period from
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449
J. P. Badalloh
June 1964 to October 1965, that the South St. Paul Sewage
Treatment Plant showed a removal efficiency of 79 percent
in BOD and an 89 percent removal in total suspended solids.
Data recorded just recently, following volumetric
reductions in sewage and greater overall efficiency at the
sewage treatment plant, indicated an average BOD removal of
87.2 percent and a suspended solid removal of 95.3 percent.
This data is attached to this report.
On October 19* 1964, following several meetings
with the Minnesota Water Pollution Control Commission and
the engineering staff of the State Board of Health, the City
engaged the engineering firms of Banister Engineering of
St. Paul and Greeley & Hansen of Chicago, to make a prelimin-
ary study and report of the necessary improvements to the
municipal sewage treatment facilities of the City. This
very complex report entitled "South St. Paul, Minnesota
Report of Sewerage and Sewage Treatment" was completed by
the aforementioned engineering firms on February 16, 1965.
This preliminary engineering report was presented to the
City Council, the MWPCC, and the packing industries for
their review and comment.
This engineering report recommended (1) improve-
ments to the existing treatment facilities so as to provide
capacity for present and estimated future flows and organic
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450
J. P. Badalioh
loads; (2) recommended additional sewage treatment facili-
ties to meet effluent standards as set forth by the MWPCC;
(3) recommended sludge disposal facilities to provide sani-
tary and nuisance-free disposal of sewage solids and paunoh
manure; and (4) recommended improvements to the intercepting
sewer facilities so as to separate storm water runoff from
industrial sewage. The estimated cost of these improvements
based on today's price index is $7*606,000.00. After a
review of this report was made by all concerned, the MWPCG
at their March 26, 1965 meeting, commended the City of
South St. Paul on their progress on further attacking the
problem of water pollution. The Commission at this time
indicated that the City begin preparation of final plans
and specifications for the proposed first stage improvements
and also suggested that we apply for a Federal grant under
Public Law 660 after July 6, 1965.
In the meantime, this report was being thoroughly
studied by the packing house interests of the City and the
impact of this report would have on these industries being
the major contributor to our total sewage load.
Following the review of this report by the major
wet industries, these industries immediately Initiated studies
on in-plant improvements In their own facilities in order to
reduce volume and strength of their wastes. The effect of
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451
J. P. Badalioh
this report was such that In the period of a few weeks,
thru conservation of water within the packing house com-
plexes, a volumetric reduction of 2 million gallons per day
in sewage effluent was achieved, along with a significant
reduction in BOD.
The industries also employed the firm of Toltz,
King, Duvall, Anderson and Associates of St. Paul (TKDA) to
make an engineering study as to the possibility of pre-
treatment of the packing house wastes and other in-plant
methods of reducing flow and strength of sewage discharged
from their facilities.
It was therefore agreed by all concerned and also
by the Commission, in July of 1965, that the proposed studies
for methods of pre-treatment of packing house wastes by
TKDA would be completed in November of 1965.
In the meantime, the City of South St. Paul on
June 25, 1965, made application to the MWPCC for a Federal
grant for sewage treatment Improvements under P.L. 660.
These improvements, totaling approximately 2.8 million
dollars, consisted of the construction of an additional
Interceptor sewer, lift station and first stage Improvements
at the sewage treatment plant, as outlined in the "Report
on Sewerage and Sewage Treatment, February 1965", by Greeley
& Hansen and Banister Engineering Company.
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452
J. P. Badalich
Following the submission of this application to
the Commission, we were informed on August 25, 1965, by the
Commission that the final priority rating of our application
was No. 33 of 38 communities applying for Federal financial
assistance. Only municipalities with priority ratings from
1 thru 18 would receive Federal grant.
On or about February 15, 1966, the City received
from the industries their report entitled "Report on Waste
Water Plant Expansion for South St. Paul, Minnesota/1
prepared by the engineering firm of TKDA, which report was
forwarded to the Commission for review and comment. Follow-
ing the receipt of the TKDA report and review by the City
and our consulting engineers, representatives of the City,
Including Mayor David G, Hardman and City Attorney Roger
Miller, met with the Commission on April 28, 1966, to dis-
cuss and formulate the City's program for first stage con-
struction of Improvements to the sewerage and waste treatment
facilities of the City.
Following this meeting on April 28, 1966, the
Commission directed the City, by letter dated May 9, 1966,
to proceed under an adopted time schedule for the planning
and construction of the first stage Improvements, involving
construction of a new Industrial waste interceptor sewer
and additional units at the existing municipal sewage
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453
J. P. Badalich
treatment plant.
Therefore, on May 16, 1966, the City Council, by
resolution, engaged the consulting engineering firms of
Greeley & Hansen of Chicago and the Banister Engineering
Company of St. Paul to prepare final plans and specifica-
tions for construction of these first stage improvements,
said plans and specifications to be completed on or before
December 1, 1966.
Also after the receipt of the Commission's letter
of May 9, 1966, outlining their recommendations to the
City, the packing industries of the City undertook: a program
within their plants for reducing the volume and strength of
wastes discharged to the municipal treatment plant. This
program is currently underway and results and tests have
shown a significant decrease in wastes being discharged from
the packing Industries.
In the meantime, the City again applied to the
Commission on June 29, 1966 for Federal assistance under
P.L. 660. The application was for construction of the
waste Interceptor sewer and first stage expansion at the
sewage treatment plant.
The first stage improvements would consist of
constructing a new and separate interceptor of the same
capacity as the existing interceptor so as to convey all
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J. P. Badalich
packing house wastes to the sewage treatment plant for
treatment at all times. There would be no by-passing of
these diluted industrial wastes to the river during periods
of storm water runoff. The sewer construction would then
leave available in the existing interceptor sewer additional
capacity to receive approximately 5 times more storm water
runoff or combined sewage for conveyance to the sewage treat-
ment plant for treatment. Along with this proposed Inter-
ceptor sewer, a 25 mgd capacity pumping station is also
being provided.
The balance of the first stage improvements consists
of additions to the existing sewage treatment plant to Im-
prove the effectiveness of primary treatment, Increase the
hydraulic capacity of the plant and Improve the overall
reliability of our existing installation. These first stage
improvements are estimated to cost approximately 2.5 million
dollars.
On September 6, 1966, the City was Informed by
the Commission that the final priority rating of our appli-
cation was No. 16 of 35 communities that applied for Federal
assistance. Only municipalities with priority ratings of
from 1 thru 10 would be certified for Federal grant.
Following this turn-down for Federal assistance,
the City applied directly to the United States Department
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455
J. P. Badalloh
of the Interior, Federal Water Pollution Control Adminis-
tration (FWPCA) and the Department of Housing and Urban
Development, but were again turned down for Federal assis-
tance because our project was not approved and certified
by the State agency.
Subsequent to this application, the City was in-
formed and encouraged by certain people in the FWPCA to make
application to the Federal Government for a demonstration
grant pursuant to P.L. 89-753* "Clean Water Restoration Act
of 1966,'" dated November 3* 1966. The project contemplated
would encompass to a large extent our first stage improve-
ments and the interceptor sewer arid would demonstrate an
Improved method of controlling the discharge from sewers
which carry both storm waters and sewage. This proposal is
currently being considered by the FWPCA. The FWPCA is also
currently considering a federally sponsored program at the
South St. Paul Sewage Treatment Plant, under their grants
for research and development, relating to the effective use
of chemical treatment, or polymers, in treating heavy indus-
trial or packing house waste, domestic sewage and combined
storm-sanitary sewage. Approval on this demonstration grant
is expected on or about March 15, 1967.
I would like to observe also that it would then
determine the second stage Improvement, which would possibly
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456
J. P. Badalich
restrict the anaerobic digestion, but with the use of these
polymers we might be able to cut this expansion substantial-
ly.
Backing up for a moment, the City just recently
reviewed the completed plans and specifications for this
first stage construction, prepared by our consulting engineers,
Greeley & Hansen of Chicago, Illinois and Banister Englneer-
ing Company of St. Paul. The necessary revisions are being
made to these plans and specifications, following a confer-
ence of city personnel and the consulting engineers held on
Friday, February 3, 196?.
At a special meeting of the City Council, held on
Monday, February 6, 1967 following their regular session,
the City Council was brought up to date on the progress and
planning of this first stage sewage treatment plant improve-
ment. Also discussed were matters regarding the City's
proposed program with the Federal Water Pollution Control
Administration. Following this discussion, the City Council
passed a resolution regarding the advertising of bids for
the construction of these first stage improvements, pending
approval of the plans and specifications by the MWPCC.
The resolution of the City Council reads as
follows:
"RESOLVED, that the City of South St. Paul transmit
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457
J. P. Badalloh
to the Water Pollution Control Commission plans and speci-
fications for construction of Phase No. 1 as previously
outlined to the Commission for review and recommendation.
RESOLVED FURTHER, upon receipt of approval of
plans and specifications, the City shall advertise for bids
for the construction of the interceptor sewer portion and
subject to Grant approval by the Federal Water Pollution
Control Administration of the Department of the Interior of
pending Grant application, the City will undertake the con-
struction of the other items of Phase No. 1, subsequent to
the approval of the Grant, which approval is expected on or
about March 15, 1967,"
Adopted by the City Council this 6th day of
February 1967.
7 Yeas
0 Nays
Here again, I certainly think: from the foregoing
facts and figures, that the City of South St. Paul is one
unit of government that has clearly demonstrated its desire
to meet its needs and responsibility in respect to sewage
collection, treatment and disposal.
On the matter of combined sewer overflow, the City
of South St. Paul, like the cities of St. Paul and Minnea-
polis, being one of the older municipalities in the
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J. P. Badalloh
metropolitan area, has a. combined sanitary and storm sewer
system remaining In approximately 55 percent of the City.
Since 1955 and to date, the City has expended in excess of
2.5 million dollars in construction of separate storm
sewers in an effort to eliminate the combined sewerage
system.
As shown on Page 11 of the Summary report
referred to at this conference, a very substantial amount
of oxygen consuming contaminants and suspended solids are
being discharged annually to the Mississippi River because
of this overflow system.
I previously indicated In this report the city's
immediate go-ahead on the construction of an interceptor
sewer to handle all Industrial wastes. By the construction
of this interceptor sewer, this will eliminate completely all
bypassing of industrial sewage to the river during periods
of storm runoff and, in turn, afford additional capacity in
the existing Interceptor sewer for transporting approximately
5 times more combined sewage, consisting of only domestic
sanitary sewage and storm water to the sewage treatment plant
for treatment by sedimentation and chlorlnation0 It is
estimated that the amount of pollutants, both BOD and sus-
pended solids, now being discharged annually to the river
will be reduced 75 percent or more by this improvement.
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459
J. P. Badalich
It should be pointed out here, that in the 27
years the City of South St. Paul has been treating sewage
we have worked in close harmony with the MWPCC and our big
brother 3^ miles upstream, the MSSD. We have also just
recently experienced an excellent working relationship with
the FWPCA. We certainly concur in the necessity for com-
bining the knowledge, experience and machinery of local,
state and Federal authorities in a unified effort in combat-
ing this problem of water pollution.
In conclusion, I wish to thank the conferees for
affording the City of South St. Paul this opportunity of
being heard on this matter of water pollution and the part
we are contributing to its solution in that portion of the
Mississippi River affected by the treated discharge from our
sewage treatment plant facilities.
Thank you.
MR. STEIN: Thank you very much.
This appendix will appear in the record.
MR. BADALICH: Thank you.
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460
J. P. Badalich
APPENDIX TO ANALYTICAL DATA
The following indicates plant efficiency for
months of complete plant operation with anaerobic stabili-
zation pond from September 1965 - February 1967.
December 1965 - Pond drained for construction of the flood
control dike construction.
August 1966 - Limited operation of pond.
December 1966 - Pond resumes complete operation.
(Killing Days)
September 1965
October 1965
November 1965
January 196?
February 196?
Average
Plant Influent
5 day BOD in
1000«s of Ibs.
137.2
141.2
146.9
135.2
120.4
136.2
Suspended
solids
Plant Effluent
5 day BOD in
1000 's of Ibs.
16.1
14.3
13.3
25.4
17.3
17.3
Suspended
solids
$ Reduction
88.2$
89.^
92.3$
81.3$
85.6$
87.2$
September 1965
October 1965
November 1965
January 1967
February 1-15> 1967
Average
1000's of Ibs. 1000's of Ibs.
116.7 4.3
122.2 5.1
121.5 7.9
90.4 3.9
86.1 3.6
107.4 5.0
96.6$
95.7#
93.4$
95.8$
95.9$
95.3$
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461
r, -
J. P. Badallch
Set tie able : Set tie able % Reduction
solids solids
MlTl
September 1965
October 1965
November 1965
January 196?
February 1-15,1967
Average
*Refleots Fall turnover In pond but caused no increase In
BOD Indicating that this was stabilized solids.
Ml/L
13.2
17.4
14.4
15.2
167 13.9
14.8
Ml/L
Trace
.7*
1.4*
Trace
Trace
.4
99^
96.0$*
90. 0#*
99/#
99/$
97.4
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462
J. P. Badalich
MR. STEIN: Are there any comments or questions?
MR. WILSON; Mr. Chairman, I would like to say
that I am glad to endorse Mr. Badalich's statement regarding
the enterprise of the City of South St. Paul in joining
along with the cities of St. Paul and Minneapolis in proceed-
ing to construct the sewage treatment plant before there was
any Water Pollution Control Commission, or before there was
any Federal Water Pollution Control Agency, largely in response
to the action that was taken by the State Board of Health in
urging them to get ahead with this job.
Minnesota was fortunate in having the three largest
cities, along with the City of South St. Paul, where we had
one of the very large sources of industrial waste, proceed on
their initiative in those early years, and it was of great
assistance to our Pollution Control Commission to point to
their example in getting the smaller ones to come along with
construction of the sewage treatment plants.
Now, in later years, of course, the population
explosion has caught up with these large centers and greatly
intensified their problems, and I think this is evident from
what has been brought out at this hearing, that they are
proceeding with very great diligence in attempting to deal
with them.
MR. STEIN: Thank you, Mr. Wilson.
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463
Cenex, Inc., by G. Ginner
Are there any further comments or questions?
(No response. )
MR. STEIN: If not, thank you very much.
Mr. Smith?
MR. SMITH: I would next like to call on Cenex,
Inc.
Is there anyone here to read their statement?
(No response.)
MR. SMITH: Mr. Ginner, would you read this
statement, please?
STATEMENT OP CENEX, INC., READ BY MR.
GARY GINNER, ENGINEER, MINNESOTA DEPART-
MENT OF HEALTH
MR. OINNER: STATEMENT TO FEDERAL WATER POLLUTION
CONTROL ADMINISTRATION.
We have read the "Summary and Pollution Abatement
Recommendations for the Upper Mississippi River and Major
Tributaries" as prepared by the Federal Water Pollution
Control Administration — Twin Cities -- Upper Mississippi
River Project, with great interest. This is a very compre-
hensive report and it is obvious that considerable effort and
time was expended in its preparation. Because of the time
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464
Cenex, Inc., by 0. dinner
involved we were particularly interested in making a state-
ment to advise you of the changes we have made since the data
was collected for this report.
You will note that the data reports two samples
for Northwest Cooperative Mills, which, incidentally, is now
Cenex, Inc. One sample was taken from the compositing pond
and the other was reported as pond leakage. Since these samples
were taken, we have made some drastic changes in handling storm
runoff, snow melt, etc., through the compositing pond.
The original construction of the compositing
pond had a common dike between it and the gypsum disposal
pond. A new dike has been built parallel to this common dike
which in effect forms a continuation of the seepage trench
along the base of the west side of the gypsum pond. This new
trench is continuous with the previously built trench on the
north side of the gypsum pond. Equally as important, the new
dike isolates the compositing pond from gypsum pond seepage,
which prevents contamination of the storm runoff.
A timber and earthen dam with two gated plastic
pipe bypasses was constructed at the outflow weir of the
compositing pond to prevent flow to the river when the runoff
is not acceptable. One gated line was installed to discharge
this water to the seepage trench if it is not suitable for
discharge to the river.
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465
Cenex, Inc., by G. Oinner
Water we are permitted to discharge to the river
such as cooling water, overflow from the fire water basin,
etc., is now piped to the outflow weir from the compositing
basin and continuously monitored by a recording pH meter
provided with alarms. This piping is arranged so the flow
can be discharged to the compositing pond if for any reason
it should become unsuitable for discharge to the river.
Our gypsum disposal pond is completely isolated
from seepage to the river and our compositing pond is now an
entirely closed system.
CENEX, INC.
/s/ L. B. Edsall
Technical Manager
MR. STEIN: Thank you.
Are there any questions or comments?
(No response. )
MR. STEIN: If not, thank you very much.
Mr. Smith?
MR. SMITH: Next I would like to call on the
Village of Cottage Grove, Mr. Bonestroo.
STATEMENT OP OTTO BONESTROO, CONSULTING
ENGINEER, VILLAGE OP COTTAGE GROVE,
MINNESOTA
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466
0. Boneetroo
MR. BONESTROO: I am Otto Bonestroo, Consulting
Engineer. Apparently the counsel isn't here today, so I will
read the statement that the Village of Cottage Grove has
prepared for the record.
I think for the record it might be well to show
where we are situated (indicating). This is a village
actually located below St. Paul Park. It is not designated
on the map.
The most critical segment of the Mississippi
River covered under the Federal study passes through the
Village of Cottage Grove. The village has for some time been
aware that conditions of poor sewage treatment efficiency,
direct by-passing of raw sewage and combined sewer overflow,
existed upstream. The full impact of the severity of the
problem has been emphasized in this latest report far beyond
that realized heretofore. Additions of pollutants to the
river have been allowed above all reasonable limits and we
afe gravely concerned that measures be taken immediately to
improve this situation. We are also concerned that improved
water quality be maintained in this and all other river seg-
ments under anticipated sewage effluent discharges, including
the tremendous future increases expected.
We approve of and wholeheartedly applaud a program
whereby the river quality will be maintained above the minimum
standards proposed. A very crucial aspect is the matter of
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467
0. Bonestroo
enforcing these standards, since the present conditions
obviously are violating present established standards on the
river. It appears that the greatest concern for the river
quality downstream from the largest contributing points does
not emanate from the contributors themselves. Monitoring of
the river quality to assure conformance with the standards
appears justified.
Although the village considers the establishment
of the proposed minimum standards to be necessary, we feel
that this does not indicate an acceptable condition under
normal flows and operations. In addition to the proposed
minimums, the highest concentrations of dissolved oxygen
obtainable by the continuous operation of all units of the
treatment facilities in the upstream portion of the river should
be maintained at all times. There is no place in a pollution
abatement program for a decrease in treatment efficiency or
the unnecessary bypassing of sewage at any time, even though
the minimum pollution standards are being met. It is our con-
tention, then, that the highest sewage treatment efficiencies
consistent with the practical limitations of treatment methods
should be required.
Respectfully submitted,
Mayor and Village Council
Village of Cottage Grove.
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468
0. Bonestroo
I would like to point out also for the record
that Cottage Grove does have complete treatment.
MR. STEIN: What do you mean by that?
MR. BONESTROO: Activated sludge secondary.
MR. STEIN: Do you chlorinate your effluent?
MR. BONESTROO: Yes, they do.
MR. STEIN: All year round?
MR. BONESTROO: As far as I am aware of, yes.
In addition to that, we are now making a compre-
hensive study on proposed expansion of the facilities to meet
the increase of population.
MR. STEIN: Well, I know you can't speak for
the Mayor, but as I read his philosophy here, it seems to
me that this notion of St. Paul not wanting to chlorinate its
effluent during the winter months, and the view of the Village
of Cottage Grove to maintain the highest quality of water
coming down at all times, may run into a little conflict.
This is precisely the kind of thing I think the
conferees are going to have to wrestle with, and we like to
have that brought out.
Thank you very much.
MR. BONESTROO: You are welcome.
MR. STEIN: Are there any further comments or
questions?
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469
MMM Company, by Q. Ginner
(No response.)
MR. STEIN: If not, thank you very much. Mr. Smith.
MR. SMITH: The next statement Is of the Minnesota
Mining and Manufacturing Company, Mr. Ginner?
STATEMENT OP MINNESOTA MINING AND MANU-
FACTURING COMPANY, CHEMOLITE PLANT,
WASHINGTON COUNTY, MINNESOTA, READ BY
GARY GINNER, ENGINEER, MINNESOTA DEPARTMENT
OP HEALTH
MR. GINNER:
STATEMENT REGARDING POLLUTION CONTROL FACILITIES
MINNESOTA MINING AND MANUFACTURING COMPANY
CHEMOLITE PLANT
WASHINGTON COUNTY, MINNESOTA
BEFORE THE SECOND SESSION OF THE CONFERENCE
CONCERNING INTERSTATE AND INTRASTATE POLLUTION
OF THE UPPER MISSISSIPPI RIVER
FEBRUARY 28, 196?
The 3M Company plant, located on the section of
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470
MMM Company by 0. Oinner
the Mississippi River under consideration in this conference,
is known as the Chemollte plant. It is located in Cottage
Grove Township in southern Washington County, on the north
bank of the Mississippi River. The plant is approximately
three miles above the Lock and Dam No. 2 at Hastings,
Minnesota, and about 19 miles below the Minneapolis-St. Paul
Sanitary District Sewage Treatment Plant.
The company has been active in pollution control
ever since the Chemolite plant began operations in 19^7. The
process waste water was first discharged to holding ponds
constructed prior to 1950. In 1955 waste water was treated
in a skimming and settling tank and an oxidation pond, before
discharge into the Mississippi River. The sanitary sewage
has always been segregated from the process waste and treated
separately.
In 1962, new additional waste treatment facili-
ties were constructed to expand and modify the existing
facilities. These facilities, which are presently being used,
consist of skimming and settling tanks, sludge concentration
tanks, oxidation pond, neutralization facilities, and neces-
sary pumping and piping appurtenances. Plans and specifica-
tions for construction of these facilities were approved by
the Minnesota Water Pollution Control Commission before they
were constructed. This information was also presented by
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471
MMM Company by G. Ginner
written statement to the first conference concerning inter-
state pollution of the Upper Mississippi River on February 7,
1964. Results of laboratory analysis of the waste water
being discharged to the river are compiled and periodically
submitted to the Water Pollution Control Commission.
In August 1966, construction of an addition to the
existing facilities was started. These new facilities, based
on three years of research, are a modification of the acti-
vated sludge process and consist of an equalization and
neutralization tank, aeration unit, two settling tanks, a
pump house, and necessary appurtenances such as pumps, air
blowers, piping and flow measuring devices. The plant will
be completed and in operation by October 15, 1967. The
operation of the facilities and discharge of effluent will
comply in all respects with the Water Pollution Control
Commission's regulations regarding Classification and Standards
for the Mississippi River and tributaries from the outfall of
the Minneapolis-St. Paul Sanitary District sewage treatment
plant to Lock and Bam No. 2 near Hastings, which were adopted
in March 1963. Plans and specifications for construction of
these facilities were approved and a permit for construction
and discharge was issued by the Minnesota Water Pollution
Control Commission on July 28, 1966. Results of laboratory
analysis of the waste water discharge will be submitted to the
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472
MMM Company by G. Ginner
State on a monthly basis.
We have reviewed the summary report on pollution
abatement recommendations for the Upper Mississippi and
major tributaries prepared by the Federal Water Pollution
Control Administration. Based on our design calculations,
we anticipate that the effluent that will be discharged from
our treatment facilities to the Mississippi River will meet
the river standard as recommended in the report. However, we
feel that the general recommendation that all industries, in-
cluding the 3M Chemolite plant, "provide treatment sufficient
to produce an effluent containing no more than 20 percent of
the mass of 5-day (20°C) BOD and suspended solids originally
contained in the untreated process waste" is not a river
standard, but only an implementation of the proposed standard,
and in this case it does not represent an equitable evaluation
of the proposed river standard. If a river standard is to be
used, and we agree that it should be, then the Implementation
of that standard should be based on the natural assimilation
resources of the river when determining the degree of treat-
ment each individual user is required to provide. The cost
of providing and operating adequate waste water treatment
facilities has become a significant part of a manufacturing
plant, and, therefore, it should be approached on a tech-
nically sound basis.
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473
MMM Company by 6. dinner
The existing river standard adopted in March
1963 is implemented by using the so-called "equivalent treat-
ment" which we feel is not related to the natural assimilation
of the river and not based on sound available scientific
knowledge. For the same reason, we are opposed to any recom-
mendation that establishes a uniform limitation for an entire
section of a river on Individual effluents that is not
directly based on the natural assimilation capability of
the river.
We strongly urge the Chairman and conferees of
this conference to review this proposal and consider the
natural resources of the river in this section when the degree
of treatment for each individual user is established.
The 3" Company wishes to extend its appreciation
for this opportunity to submit this statement to the conference.
MR. STEIN: Thank you.
There is no one from the 3M Company here?
MR. SMITH: Apparently not.
MR. STEIN: I think we have identified their
problem, but with reference to the point about the assimila-
tive capacity, I don't know.
What surprises me is that companies can come up
with these up-to-date devices for the market, and yet have
these old-fashioned theories when it comes to this.
-------
I will say that their major point is well taken,
that their effluent requirements should be tailored to a
specific plant, and I don't know that we necessarily have to
get into the rationale.
Do you have any comments?
DR. JELATIS: I was just going to comment on
the same thing, Mr, Stein.
Relating the degree of treatment to assimilative
capacities of streams I think is rather old-fashioned, and I
think it is becoming recognized more and more that part of
the cost of doing business should be the treatment of effluents
to the highest degree possible. I think this is the criterion
which should be used, rather than try and dump it into a
stream and let it assimilate as best it can.
MR. STEIN: Thank you.
I think we are getting rather close to our lunch
time.
Our present schedule calls for us to hear every-
one. We will be here to hear everyone.
In order to do that and not exhaust the panel, and
our reporter particularly, because he has to keep up with it,
we will recess for lunch now.
Let's see if we can get back here at 1:35. We
will stand recessed until 1:35.
(Whereupon, at 12:20 p.m., a luncheon recess was
taken.)
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475
A. Steffes
AFTERNOON SESSION
(1:40 p.m. )
MR. STEIN: May we reconvene?
Mr. Smith?
MR. SMITH: I would like to call on a representa-
tive of the City of Hastings next.
Is Mr. Steffes in the room?
STATEMENT OF ARNOLD STEFFES, CITY ENGINEER,
HASTINGS, MINNESOTA
MR. STEFFES: Good afternoon.
Ladies and Gentlemen, Members of the Commission:
My name is Arnold Steffes, and I am City Engineer
of the City of Hastings, and I wish to present the following
statement:
The City of Hastings, Minnesota, has a direct
interest in the Federal Water Pollution Control Administration
"Report on Summary and Pollution Abatement Recommendations."
The City of Hastings' concerns with regard to
these recommendations are as follows:
Page 29 of the General Recommendations, Item 3*
Treatment of Municipal Wastes.
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A. Steffes
The requirement that the treatment is to produce
an effluent containing no more than the percentages stated
under this heading, does not take into account the effluent
load from various plants upstream from the City of Hastings.
The restrictions placed on the coliform guide,
value of 1000/100 ml, as a maximum concentration for any one
sample, is unreasonable and virtually impossible. The guide
value should be stated in terms of average concentration
rather than maximum concentrations.
Continuous chlorination will greatly increase the
operation and maintenance costs. It is the City's position
that chlorination during the recreation season is justified,
but chlorination outside the recreation season is an unjusti-
fiable expenditure of public funds in terms of benefits to
users of the river.
Our estimate of the cost differential between the
four-month recreation season and continuous chlorination is
$5*600.
Page 31 of Specific Recommendations, Mississippi
River, Municipal Sources, subheading, Hastings Plant, Para-
graph 4.
The City of Hastings objects to the statement that
practically no treatment is provided. Records over the number
of years indicate consistently that a much greater removal
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477
A. Steffea
than the 5 percent stated in the report has been obtained.
Tests conducted by an indpendent laboratory indicate BOD
removals of 15 to 20 percent.
It is doubtful that the minimum dissolved oxygen
level of 5 mg/1 can be maintained at all times between Lock
and Dam No. 2 and the Chippewa River, unless steps are taken
upstream to reduce the pollutional loads on the river. The
city takes the position that little or no improvement in
water quality between Lock and Dam No. 2 will be realized
until the Minneapolis-St. Paul Sanitary District and the City
of South St. Paul have in operation adequate waste water treat-
ment facilities.
The City of Hastings presently has a Federal
Water Pollution Control Administration grant for the construc-
tion of additions and alterations to their existing sewage
treatment plant to provide for additional treatment. The
additional treatment is provided by installing secondary
treatment designed by adding modified activated sludge treat-
ment which can be revised later to provide for step aeration,
increasing the degree of treatment as required. The comple-
tion of the sewage treatment plant is scheduled for January
15, 1969. Bids will be received for this project on March
16, 1967.
These are now out in the contractors' hands for
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478
A. Steffes
bidding. Depending upon the action taken here by the
Federal Commission, it may be necessary to extend the date
of bidding for the additions to the Hastings sewage treatment
plant. However, this would produce no effect upon the comple-
tion date as scheduled.
This report is signed by L. Michael Kelly, Mayor,
City of Hastings, and attested to by Wallace H. Erickson,
City Clerk.
MR. STEIN: Thank you.
I wonder if that modified active sludge you have
now meets the Minnesota requirements.
MR. STEPPES: The plans and specifications for
the additions to the Hastings sewage treatment plant have
been submitted to the State Board of Health. They were
designed upon the criteria given us by the Minnesota Water
Pollution Control Commission. The designs have been approved
by the United States Public Health Administration.
MR. STEIN: I recognize all that, but is your
effluent at 50? Does it meet the requirements of 50?
MR. STEPPES: Yes.
MR. STEIN: 50?
MR. STEPPES: At present the plans which are out
for bids will meet the 50.
MR. STEIN: 50, but Minnesota just said that
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479
A. Steffes
50 wasn't good enough. They wanted 30.
MR. STEPPES: That Is the statement I made, which
was not in the report which I ad libbed, that if that change
is necessary we are willing to meet with the Water Pollution
Control Commission and see what the requirements will be.
They have to establish the requirements before we can design
it.
MR. STEIN: Minnesota indicates that the change is
necessary going down from 50 to 30.
MR. STEPPES: They did not indicate that up to the
time that the U. S. Federal Water Pollution Control Commission
MR. STEIN: We heard it here today. I don't think
we are going to pursue Minnesota on that. If you are just
doing 50 and they want 30, maybe you ought to just get talking
to them as soon as you can.
MR. STEPPES: I cannot here speak for the council
of the City of Hastings at the moment. However, I can say
this: That I have been contacted by the Chairman of the
Sewage Commission of the City of Hastings to ask for a review
of the plans in the light of what the results of this meeting
will be, and I do believe that it is the general consensus
of the council of the City of Hastings that they will be
willing to abide by the requirements.
MR. STEIN: Now, there is Just one other
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480
A. Steffes
information question.
You say: "Records over the number of years
indicate consistently that a much greater removal than the
5 percent stated in the report has been obtained."
How much over the 5 percent have you obtained?
MR. STEFFES: 18 to 20 percent. The last
results that we have had made by an independent laboratory
gave us 18 percent removal.
You must realize that our plants were designed
and constructed in 1953, and based on the population of 7,000.
The City of Hastings has had a much more rapid growth than
the projected population, and we will admit that our present
plant is at the design capacity.
MR. STEIN: That's right. You know, again, when
we talk about "much greater than 5 percent," 18 percent may
be much greater than 5. When we were talking in terms of
removal of 90 percent or secondary treatment, somewhere in
the vicinity of 80 or 75, when we get down to 18 as related
to 5, I don't know that we really have disinfected sewage
treatment.
MR. STEFFES: We don't contest that. We are not
contesting that as an argument. We realize that.
If we had not realized that, we would not have
made an application to the Federal Water Pollution Control
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481
A. Steffes
Agency for a grant.
MR. STEIN: I recognize that. I an just clari-
fying your statement. You indicate here that consistently
a much greater removal than the 5 percent stated in the report
has been obtained. If you raised that by another 300 percent,
which you probably have, you still are not doing very much.
MR. STEPPES: I don't follow your question, Mr.
Stein.
MR. STEIN: The question here is if we are
dealing in terms of a range between 5 percent removal and 18
percent removal, I don't know that we are really dealing in
meaningful terms of effective water pollution control.
MR. WISNIEWSKI: Mr. Chairman, I can't understand
what point you are trying to make.
They are proposing to place the plant up for bids
and proceed with construction.
Let's move on to the next item instead of having
a quarrel about whether 5 percent or 18 percent is being
accomplished. Let's move along in this thing.
MR. STEIN: I don't know that there is any
quarrel, Mr. Wlsniewski.
MR. WISNIEWSKI: They said they are going to
build a plant. Let's move on. They have a Federal grantj
they want to use it and put it to work.
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482
A. Steffes
Now, let's not stretch this hearing.
MR. STEPPES: That is a very good point, and
that is the point that the City of Hastings and the Council
of Hastings and I, as the City Engineer, wish to leave with
the body, and also for correction, as far as any newspaper
publicity is concerned, that the City of Hastings has not been
producing an effluent of 5 percent removal — they have been
producing a better effluent — and also, keeping in mind that
the treatment plant was designed beginning with 1937 and it
finally came to an accomplishment in 1953. It was designed
according to State and Pederal standards at that time.
It is only a primary plant, and as a primary
plant it has reached its peak capacity, and I think that a
reduction of 18 to 20 percent is not a bad record for a
primary plant.
That is the point that I wish to make. I don't
wish to argue the point, but I wish to present it to clarify
the record.
MR. STEIN: All right. Thank you.
Are there any further comments or questions?
(No response.)
MR. STEIN: Mr. Smith?
MR. SMITH: The next statement will be from the
American Crystal Sugar Company.
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483
Am. Crystal Sugar Co., by G. Dinner
Mr. Ginner ?
STATEMENT OF THE AMERICAN CRYSTAL SUGAR
COMPANY, CHASKA, MINNESOTA PLANT, READ BY
GARY GINNER, ENGINEER, MINNESOTA DEPART-
MENT OF HEALTH
MR. GINNER: This is dated February 27, 1967.
AMERICAN CRYSTAL SUGAR COMPANY
CHASKA, MINNESOTA PLANT
On March 18, 1965* we confirmed by letter to the
State of Minnesota Water Pollution Control Commission, our
intention to construct treatment facilities for our waste
water from our Chaska plant.
Our original planning was for the construction of
holding lagoons, providing sufficient suitable land could be
purchased. Negotiations for the land in question failed. It
was then decided to construct a closed loop system for our
beet fluming water and segregate the other in-plant waters so
that water pumped for cooling could be returned direct to the
river or to our river pumping station.
The installation as constructed cost $250,000.
It includes a new waste water pumping station, waste water
screening facilities (Tyler Ton Cap Screen No. 554, .054 width
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484
Am. Crystal Sugar Co., by G. Ginner
of opening), 100 ft. diameter Eimco clarifier with mud pumps
and a mud pond slightly under 15 acres in size. Due to
various construction delays, the system was not placed in
operation until December 8, 1966. Some operational diffi-
culties were encountered; some were overcome, while others
entail more study and changes.
Although our new waste water treatment facili-
ties were in operation only during the latter part of our
1966-67 operating season (67 days), we have reason to believe
that the system will meet the General Recommendations set
forth under Item 11, Page 30, and Item 2, Page 32 of the
Summary and Pollution Abatement Recommendations for the Upper
Mississippi River and Major Tributaries, Federal Water Pollu-
tion Control Administration, Twin Cities - Upper Mississippi
River Project.
MR. STEIN: Thank you.
Are there any comments or questions?
(No response.)
MR. STEIN: If not, Mr. Smith?
MR. SMITH: Our next statement is from the Rahr
Malting Company.
Mr. Thimsen?
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485
Rahr Malting Co, by D. J. Thimsen
STATEMENT OP THE RAHR MALTING COMPANY,
MINNEAPOLIS, MINNESOTA, READ BY DONALD
J. THIMSEN, MINNESOTA DEPARTMENT OP HEALTH
MR. THIMSEN: My name is Donald J. Thimsen and I
am from the Minnesota Department of Health. I an reading the
statement from the Rahr Malting Company. This statement is
from Mr. C. R. Alt of the Rahr Malting Company, and is dated
February 24, 1967.
This letter is addressed to Mr. Robert N. Barr,
M.D., Secretary, Minnesota Water Pollution Control Commission,
Department of Health, University Campus, Minneapolis, Minne-
sota 55440.
Dear Dr. Barr:
We acknowledge your invitation to attend the
conference on water pollution control scheduled for Tuesday,
Pebruary 28, at the Leamington Hotel, Minneapolis. The
writer will attend this session, and consulting engineers
retained by our company will also be there. In lieu of making
a personal presentation, we submit this statement.
Our company is in complete accord with the broad
objectives of the Minnesota Water Pollution Control Commission
with respect to reduction of pollution. It is a basic policy
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486
Rahr Malting Co., by D. J. Thimsen
of this company to cooperate fully with public authority.
In order to conform to standards now set for the Minnesota
River, our planning has been updated. We have met with
officials of the City of Shakopee on several occasions, and
have also met periodically with representatives of the
Minnesota Water Pollution Control Commission to keep them
currently informed of progress being made on our program.
The treatment of effluent from our Shakopee,
Minnesota, plant has had our attention over a period of many
years. In constructing additions, plant design made provision
for separation of cooling water from other effluent. Outside
engineering counsel has been retained to advise us on these
matters.
Our company cooperated with Toltz King and Day,
Inc., of St. Paul, when they were engaged by the City of
Shakopee to provide primary sewage treatment for that
community. Their report of February 26, 1957* prepared for
the city, envisioned future inclusion of malting company
wastes at such time as secondary treatment would be provided
for the community. When interceptors were installed in
Shakopee, at the intersection of Clay and Spring Streets,
they were sized to handle wastes of our plant at that Juncture.
During the period October 15-17* 1963, the
Minnesota Department of Health conducted an extensive survey
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487
Rahr Malting Co., by D. J. Thimsen
of our plant effluent and Issued a report of their findings.
Our personnel cooperated in this study, providing information
so that there could be a determination of volume averages
to be anticipated over an extended period of time.
During recent years certain screening devices in
the malting plant have been replaced with equipment of im-
proved design to reduce the volume of raw materials leaving
the plant as waste.
Other in-plant modifications included extensive
piping changes, making it possible to completely separate
plant effluent to a point at the plant boundaries, in con-
templation of further extension when secondary treatment is
available.
It was deemed prudent to defer specific planning
for construction until classification and standards for the
Minnesota River had been established in November 1965. Sub-
sequently, the City of Shakopee engaged the firm of Bonestroo,
Rosene, Anderlik and Associates of St. Paul, Minnesota, as
consulting engineers to study the sewage treatment problems
and needs of the Shakopee community, including Industry. Our
company has cooperated fully with these engineers, and has
also retained their services for counsel, engineering, design,
and to supervise construction of those facilities which we
consider the responsibility of our company.
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488
Rahr Malting Co., by D. J. Thimsen
Rahr Malting Company has now awarded a contract
for construction on its property of a holding tank and
screening device to accomplish two things in particular. The
holding tank will make possible the release of processing
water on a relatively steady flow basis throughout 24 hours
of each day. This will significantly reduce the required
size of secondary treatment facilities. The screening device
will remove suspended solids which would otherwise be run into
the community treatment plant.
Further treatment of these process wastes is
dependent upon provisions for secondary treatment. We believe
it is desirable to have a single treatment operation to serve
the total needs of the Shakopee community.
The consulting engineers are now completing a
comprehensive study to assemble the information needed to
plan for such facilities. We assure your office, and the City
of Shakopee, of our complete cooperation in carrying this
program through to a satisfactory conclusion.
Respectfully submitted
/s/ C. R. Alt
MR, STEIN: Thank you.
Are there any questions or comments?
(No response. )
MR. STEIN: If not, Mr. Smith?
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489
R. P. Hubbard
MR. SMITH: The next statement I have is from
Cargill, Inc.
STATEMENT OP ROBERT P. HUBBARD, ASSISTANT
GENERAL SUPERINTENDENT, CAROILL CORPORATION,
MINNEAPOLIS, MINNESOTA
MR. HUBBARD: I am Robert Hubbard, Assistant
General Superintendent of Cargill Corporation, I have a
brief statement of what we have done. It was first brougnt
to our attention when the original survey was started, and
this is the statement for the record:
Tests of discharged water from our Port Cargill
plant during the period 10/24/64 to 1/14/65 showed the BOD
varied from 23.6 PPM to 1,30? PPM. Investigation of possible
pollutants determined that a major source was a wet dust
collector at the soybean plant from which dust-laden water
was discharged to the river. It was determined the unusually
high periods of pollution were the result of a pilot plant
practice of washing mistakes and spills down the floor drains,
not a septic system, but an overflow, which then discharged
to the river.
The following corrective action has been
effected:
1) A fabric dust filter was purchased and
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490
R. F. Hubbard
installed as of October 1966 at the soybean plant.
This filter has no water discharge.
2) Although the pilot plant is now shut
down, the practice of washing spills to the floor
drain has been eliminated and any future spills
would be drummed for disposal.
Tests of the stream as made by the Twin City
Testing Company in January and February of 1967 showed the
following:
BOD - 5-10 PPM
Undissolved Solids - Negligible
pH - 7.6.
This concludes the statement.
MR. STEIN: Yes. Are you in compliance with
the Minnesota requirements now?
MR. HUBBARD: Pardon?
MR. STEIN: Are you in compliance with the
Minnesota requirements, or do they require more?
MR. HUBBARD: I am not sure we are aware of the
exact requirements for our discharge.
MR. SMITH: I believe they are in compliance. Yes.
MR. STEIN: All right. Thank you.
Are there any further comments or questions?
(No response.)
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491
J. J. Klein
MR. STEIN: Thank you very much.
MR. SMITH: The next statement is from Eagan
Township.
STATEMENT OP JOHN J. KLEIN, REPRESENTING
THE TOWN BOARD OP SUPERVISORS, EAGAN
TOWNSHIP, DAKOTA COUNTY, MINNESOTA
MR. KLEIN: I would like to introduce myself. I
am John Klein of the Town Board of Supervisors of the Eagan
Township, and I would like to locate it on the map.
It is right in this area here (indicating).
Eagan Township is 3^.5 square miles in area, and we are
located 9 miles from downtown Minneapolis and 7 miles from
downtown St. Paul and 2 miles from the airport. Because of
our location, there is great acceleration in development in
Eagan Township of both residential and commercial and
industrial, and for that reason we are doing everything we
can to prepare for this growth.
We are presently about 7,500 in population. The
NPC projections for 1975 indicate it will grow over 10,000
people in the next eight years, and our future projected
population is between 100 and 112,000.
We are about three-fifths the size of St. Paul
in area.
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492
J. J. Klein
We have a statement here that I would like to
read.
As one of the communities vitally concerned with
the future condition of the Minnesota River, Eagan Township
appreciates the opportunity to comment on the recently com-
pleted river quality study and the proposed minimum river
quality standards.
Eagan Township is a rapidly growing suburban area
with approximately three miles of frontage on the Minnesota
River. This entire area is within that length of the Minne-
sota River now shown to have the most pollution. Prompt and
positive action is necessary to restore this section of the
river to a condition continuously acceptable for navigation,
pleasure boating, fishing, stock and wildlife watering,
irrigation, and maintenance of rough fish life.
The minimum standards recommended in this study
represent a significant improvement and provide a practical
level which can be attained. However, we do not feel that
the establishment of these standards should be taken to
represent the desirable conditions under normal river flow.
In addition to satisfying the minimum standards proposed, all
treatment facilities on the river should be operated continu-
ously at the highest degree of treatment consistent with their
design. Normal operation should include maintaining the level
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493
J. J, Klein
of dissolved oxygen in the effluent at the highest practical
level, continuous efforts to maintain BOD and bacteria count
at the lowest levels and the removal of all possible objec-
tionable solids.
We approve of the proposed Federal standards
which, while requiring a satisfactory level of purity, do
not represent a prohibition of the discharge of a highly
treated sewage plant effluent into the Minnesota River. With
adequate design and operation, properly placed regional sewage
treatment plants can provide treatment of the sewage from
adjacent municipalities and still maintain these river quality
standards on the Minnesota and Mississippi Rivers.
Equally important as the establishment of proper
river quality standards is the enforcement of them. It is
suggested that careful consideration be given to the develop-
ment of an adequate staff anl checking procedure to Insure
that river quality standards are continuously maintained.
Treatment plants must be operated satisfactorily and maintained
or improved as indicated by continual routine testing. Long-
range planning for constant upgrading of treatment techniques
should be encouraged. The enforcement and Implementation of
this program can best be carried out by a properly staffed
and organized State of Minnesota agency.
Very little pollution is being contributed to the
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J. J. Klein
Minnesota River by present development in Eagan Township.
As the area grows, we will do everything within our power to
cooperate with the State program of pollution abatement and
to minimize pollution discharged into the river.
Respectfully submitted,
Eagan Township, Minnesota.
MR. STEIN: That is kind of a downstream community.
Let me ask you this question specifically here: Have you
thought about the year round disinfection of the effluent?
Have you heard this controversy, or are you familiar with it?
MR. KLEIN: I'm sorry, sirj I can't hear you.
MR. STEIN: You can't hear me?
MR. KLEIN: No.
MR. STEIN: I refer to your statement. You want
effluent at the highest practical level.
Now, the question we have and that the conferees
are going to have to consider is whether they are going to
require any disinfection of the effluent, and whether they
are going to require that on a year round basis, or just
during the recreational season.
Do you have any views on that?
MR. KLEIN: I would prefer to have any of these
technical points answered by our consulting engineer, and he
is here in the audience, if you would like him to answer those.
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495
J. J. Klein
MR. STEIN: I don't know that this is a technical
point. The difficulty that we have is trying to translate
the views that you have into this.
Let me again give you the position, and this was
the position taken by the St. Paul District. The recommenda-
tion made by the Federal conferee was that secondary treatment
be provided, and I am sliding over that without getting into
what secondary treatment is, plus year round chlorination of
the effluent.
The St. Paul District man indicated that they
thought that chlorination of the effluent, disinfection of
the effluent, should just take place during the summer season,
or during the recreation season, or certainly not during the
non-recreation season.
You have pointed out that we have to have a
removal of the effluent at the highest practical level and
bacteria counts at the lowest levels.
Now, I wondered if you had thought this question
through. If you haven't, you haven't.
MR. KLEIN: Well, the only thing that we say is
that we are willing to go along with this disinfection during
these low levels, but what we meant by this "highest practical
standard" was that it should be on a year round basis wherever
that may be deemed to be necessary by the Water Pollution
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496
J. J. Klein
Control Commission.
What we do object to is total prohibition of
discharging into the river, and that is why we say "highest
practical."
MR. STEIN: All right. Thank you.
MR. SMITH: Mr. Stein, the Commission has issued
a variance. This section did contain a prohibition and they
have Issued a variance, and Eagan Township has that variance
to establish two aerating ponds, and the question here is
whether they go beyond that prohibition or not.
DR. HARORAVES: I want to eliminate your diffi-
culty.
You do not get over to the Mississippi, do you?
MR. KLEIN: No, sir. Our natural drainage area
is into the Minnesota.
DR. HARORAVES: It is three miles along here.
One of the difficulties, of course, that arises
is a difference in philosophy and desirability as to whether
to use for effluent streams that pass through major cities
and have plants on them, or have it all brought down to one
plant.
We issued a variance so they could put in two
temporary ponds. I am sure the future is going to hold the
answer. It is all in the courts yet, with all of these, but
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497
J. J. Klein
the question is whether they will have a plant, and so on,
and discharge in here (indicating), or whether it can be
carried over there (indicating).
I think I have stated it right. There are cer-
tain groups that would like to have separate plants on the
Minnesota River. This Sanitary District is growing up, and
the plan is to carry Interceptors down to all of these areas,
and pick it up and bring it down to Pig's Eye, if this part
of the plan is approved by the people of the State, or whoever
is going to be making decisions.
At the present time, we bring this back to a
metropolitan sanitary district versus a number of districts.
MR. KLEIN: Dr. Hargraves, we feel that we can
sympathize with this philosophy to a point. If we are going
to be 4 million people in the metropolitan area by the year
2000, we feel certainly that bringing this second river under-
x
ground from Shakopee to Pig's Eye and discharging it at that
point, we will be discharging a higher degree of sewage into
the river at one point which will then be carried past
communities with populations projected in excess of what St.
Paul is presently populated at, so tnere seems to be a bit
of paradox in that philosophy that we along the Minnesota
River have a total prohibition standard, because they don't
want this carried past major concentrations of people. Yet,
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498
J. J. Klein
the answer that we have been given to this is to pipe it
to Pig's Eye, dump it in the river there, and run it past
areas which will be populated in excess of what St. Paul is
now.
This is where the conflict comes. We feel that
we can maintain a high degree of treatment in Eagan Township.
As a matter of fact, the studies which we have
made seem to support this. They definitely support it. They
prove that we can do a more efficient job of treating. We
can have more flexibility with these regional plants, and
they are more economical, and so we have taken the position
of supporting regional plant concepts.
Furthermore, we believe that some place along
the line we are going ,to have to face up to the regional
plants, because there is a practical limit that we can extend
pipelines from one plant, and so we are trying to approach
thia thing with a minimum possible pollution to our streams.
We feel that this is the answer.
There is disagreement on this, and it is a
matter of difference in philosophy, but we are very strong
in our position on this thing, and we feel that we have had
it supported by an extensive study which we had made.
DR. HARQRAVES: I Just wanted to have it brought
out that this is the very knotty problem, and certainly there
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J. J. Klein
are excellent arguments on both sides as to how it is best
settled.
MR. STEIN; Mayor Jelatis?
DR. JELATIS: Mr. Chairman, this indeed brings
up a philosophical problem. While I am sure that we all
concur in the objectives as stated by Eagan Township, what
comes into question is the best way to achieve them.
I think this is brought out in the Summary Report,
not as a conclusion, but it is one of the observations relat-
ing to the metropolitan area, in which you said that planning
an action to alleviate metropolitan problems of sewage collec-
tion, treatment and disposal can be handled best by a single
authority.
This is on Page 22, and the conclusion, I think,
states that whether the best solution lies in the use of one
or several plants, the important point is that all sewage
facilities be planned as part of an integrated system, en-
compassing the entire metropolitan area.
Now, the question whether properly placed
regional plants can provide better treatment than a single
one I am sure is still an open question, but the question of
adequate maintenance of treatment standards and continual
quality I am sure can be perhaps better administered under
a single agency that can have the staff and equipment to do
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J. J. Klein
a more thorough job than a number of relatively small plants.
MR. KLEIN: We haven't been opposed as such to
a single agency which might have control over this , but we
do take the position as to whether it will be a one-plant
concept or regional or district plants, and also how the cost
allocations will be applied to those areas being served by
either the one plant or the regional. This is where the
conflict comes.
This also is why there is so much confusion,
if you want to say that, at our State legislative level.
These people are sitting on volumes of engineer-
ing reports. I doubt if any one of our legislators has even
had time to really go through all of these reports that they
have been given, and it is a very difficult task.
MR. STEIN: I think this comes to the nub of the
question. I ask you all to look at this.
I know there will be no conflict to indicate that
this is a problem faced by many, many metropolitan areas.
The question is whether you have a central authority where
from the core city they work out with all the other cities,
and they sign contracts, and you put it in, or whether you
in the smaller communities are in effect on the board of
directors and can call the shots, or you are going to go
independently.
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J. J. Klein
Now, my suggestion here, and this Is always
the nub of these questions —
MR. KLEIN: Well, Mr. Stein, you say that one of
the things that Is plaguing you as far as proper legislation
on these levels Is concerned is how this one central authority
will be established, and how the representation on that
authority will be arrived at.
Certainly we feel that there should be two
factors taken into consideration in forming representation
on this one central authority if there is one established,
and because the suburban areas are going to realize three-
quarters possibly of the growth in the metropolitan area over
these next thirty-five years, why, we feel that this should
be a significant factor in establishing representation on
these committees.
MR. STEIN: Let me make this clear. I don't
think Wisconsin or the Federal Government really have any
business in telling you in Minnesota how to set this up.
The problem that we are both going to have is
knowing that if you haven't got this setup, we are going to
have a problem in getting this going, and I think it behooves
the Minnesota group to get together and get together pretty
fast, because in the absence of a clear-cut operation, you are
going to really leave us no alternative than to go into it
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J. J. Klein
source by source and demand pollution control. I don't know
that this is going to be the most economical way.
Whichever way you go, I think you should have
an integrated system and something that is going to be of
least cost to you and easiest to manage, and give you full
authority to run this.
Now, we don't have much time on this, and I am
very glad for your contribution here. Again let me say this:
This is a situation where you are Just going to have to sit
down with your neighboring cities and your State administra-
tion and work out for yourself and do it.
Now, I don't want to speak for the conferees, but
as far as the Federal Government is concerned, anything you
present to us that will do the job we are going to buy. Some-
times the cities and these metropolitan areas come up with a
plan which we don't think is the most economical, but we
figure if they want to spend 10 or more million dollars and
do it this way just to dovetail their political subdivisions
together, this is all right with us.
However, as I say, the time is now when something
has to give to work this out.
MR. KLEIN: We are hoping that it will, sir, and
we are hoping that we will see something fruitful come out of
this session.
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J. M. Mason 503
Thank you.
MR. STEIN: Thank you. Mr. Smith?
MR. SMITH; The next statement is the statement
of the North Suburban Sanitary Sewer District.
STATEMENT OP JOHN M. MASON ON BEHALF OP
THE NORTH SUBURBAN SANITARY SEWER DISTRICT
MR. MASON: Mr. Chairman and Members of the Panel:
My name is John Mason. I am an attorney and I
represent the North Suburban Sanitary Sewer District.
That District is roughly represented by the
shaded portion on the map here above Minneapolis and St. Paul
and below Anoka.
The North Suburban Sanitary Sewer District,
known as the "NSSSD," is a political subdivision of the State
of Minnesota. It is organized for the purpose of preventing
water pollution and providing a modern sewage disposal system
to residents of its service area. At present it provides
sewage collection service to residents of Coon Rapids, Pridley,
Elaine, Spring Lake Park, Moundsview and Shoreview. Later in
1967 it will also serve Circle Pines and Lexington.
THE SPECIFIC RECOMMENDATIONS
Inasmuch as the Specific Recommendations in the
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J. M. Mason
Summary do not relate directly to the North Suburban Sanitary
Sewer District, we shall make no comment on that portion of
the Pollution Abatement Recommendations of the Federal Water
Pollution Control Administration.
T HE GENERAL RECOMMENDATIONS
We recognize that it is neither the purpose nor
the intent of this conference, nor is this conference
permitted, to adopt general water quality standards. We
shall, therefore, make our remarks concerning the General
Recommendations very brief, and shall not comment on all of
the recommendations.
Reports
The North Suburban Sanitary Sewer District would
agree that systematic reports by municipal treatment plants
would be of great benefit. These reports would not only be
valuable for purposes of comparing effectiveness of treat-
ment of various sewage treatment plants, they would aid in
determining the source of any pollutional load on the
receiving waters.
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J. M. Mason
The North Suburban Sanitary Sewer District plans
to build a modern sewage treatment plant which would dis-
charge Into the Mississippi River below the head of navi-
gation. This will be a modern secondary sewage treatment
plant utilizing the activated sludge process and disinfecting
the effluent. It will yield an effluent discharge providing
DO levels even higher than contemplated by the Federal
Water Pollution Control Administration report, and which
will also meet the coliform requirements. The District
would be most pleased if reports of its operation were
compared with those of other plants in operation. These
comparisons would be fruitful in securing higher quality
effluent.
River Zoning
The head of navigation on the Mississippi River
now extends to the Soo Line Bridge, above St. Anthony Falls.
It would seem inconsistent with the policy of encouraging
river navigation to suggest that the entire portion of the
Mississippi River from Anoka to the Minnesota River be
used for swimming, skin diving and water skiing. This
portion of the river includes Lock and Dam No. 1 and the
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J. M. Mason
new locks at St. Anthony Falls. The latter were constructed
at great expense to the Federal Government and local govern-
ments, for the purpose of extending the head of commercial
navigation to the Soo Line Bridge. It would appear more
realistic and more consistent with present and anticipated
uses of the Mississippi River if the first "zone" terminated
at the head of commercial navigation rather than at the
artificial point presently contemplated. While it is no
doubt convenient to divide the river into segments based
on natural observable points such as confluence of rivers
or waterfalls, to do so can lead to oversimplification of
the solution to the problems.
The North Suburban Sanitary Sewer District believes
that the real solutipn to the problem of water pollution
in the metropolitan area is the construction of treatment
plants discharging at various points in the area, rather
than concentrating the load at the one plant currently
favored by the Minnesota Water Pollution Control Commission.
The present discharge of the overloaded Minneapolis-Saint
Paul Sanitary District ("Pig's Eye") plant is the acknowledged
principal cause of the unsatisfactory conditions revealed
by the Federal Water Pollution Control Administration's
report. To exaggerate the problem by transporting to
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J. M. Mason
Pig's Eye all of the additional sewage which may be expeoted
to be generated in the fast growing suburban areas north,
northwest, west and southwest of the Twin Cities can scarce-
ly have any effect other than to abandon the river down-
stream from Pig's Eye, and to restrict the solution to
cleaning up all of the waters of the State.
For the foregoing reasons, the use classifications
for the Mississippi River above the head of commercial
navigation should not be the same as the use classifications
below that point.
CONCLUSION
The North Suburban Sanitary Sewer District welcomes
efforts aimed at improving the quality of waters of the
nation, and making full use of all such waters. It pledges
its cooperation toward that end.
This concludes the prepared statement of the North
Suburban Sanitary Sewer District.
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J. M. Mason 508
Mr. Chairman, in addition to the formal state-
ment which I have presented, I believe it is necessary to
correct any wrong conclusion which may be drawn from state-
ments by Mr. Wilson about the position of the North Suburban
Sanitary Sewer District on the standards which have been set
for the Mississippi River by the Minnesota Water Pollution
Control Commission, and the court decision on the standards.
Otherwise, I believe this conference may misunderstand one
of the important facts under consideration. Perhaps Mr.
Wilson will agree with this clarification, because, like me,
he is a lawyer.
While we may agree that doctors can think
biologically and ecologically, lawyers are restricted to
thinking logically.
(Laughter. )
I believe Mr. Wilson said that the Water Pollution
Control Commission is appealing to the Minnesota Supreme
Court from a decision upsetting the water quality standards
established for the Mississippi River. This is not correct.
What was principally argued by the North Suburban
Sanitary Sewer District, and what was decided by the Court,
was that the absolute prohibition of the discharge of any
effluent from any sewage treatment plant, regardless of
compliance with qualitative water standards, was not within
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J. M. Mason
the powers granted to the Commission by the Legislature, nor
was it a solution of the problem of water pollution. The
remaining standards were affirmed and would take effect
immediately, were it not for the appeal by the Water Pollution
Control Commission.
The North Suburban Sanitary Sewer District's
position is that a total prohibition of the thing to be
regulated is not a standard on which any meaningful regula-
tion can be based, and presents a roadblock in the path of
solving sewage disposal problems of the metropolitan area.
I think that our position may have been more accurately
described in one of Mr. Wilson's earlier statements, that the
Legislature has so far declined to take the course urged by
the Commission: to expand the Minneapolis-St. Paul Sanitary
District to collect more sewage to add to the problem at
Pig's Eye.
I might add parenthetically that the decision of
the Court rejecting the absolute prohibition established by
the Water Pollution Control Commission was not rendered under
the Rosenmeier Act, but under laws which existed before the
Act was passed, and which are still in effect.
I trust that the view expressed by Mr. Wilson
that our North Suburban Sanitary Sewer District has been a
"thorn in the side" of the Water Pollution Control Commission
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J. M. Mason
is not shared by the persons duly appointed to that
Commission.
The sole purpose of the North Suburban Sanitary
Sewer District is to work toward improvement of water quality.
It is not the North Suburban Sanitary Sewer District, but
the Commission, which has allowed the Pig's Eye plant to
continue to destroy the river downstream from the plant. If
the North Suburban Sanitary Sewer District proposal provides
a constant reminder of the deplorable conditions between Pig's
Eye and Hastings, not permitting the Commission to close its
eyes to that problem, we are proud to be known as a "thorn
in its side."
The North Suburban Sanitary Sewer District was
unaware that Mr. Wilson would choose to make his unwarranted
attacks on its efforts at averting pollution. It therefore
requests an opportunity to submit and present a detailed and
documented report of the activity of the North Suburban
Sanitary Sewer District aimed at pollution control.
We are sure that no objective observer would con-
sider the North Suburban Sanitary Sewer District an enemy of
clean water. Instead, the facts clearly establish that the
roughly $20 million already spent by the North Suburban
Sanitary Sewer District and its member communities on abate-
ment devices has substantially alleviated pollution problems
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J. M. Mason
of its area. The effect of this substantial expenditure has
been to insure that wastes are not discharged into the
Mississippi River above the Minneapolis and St. Paul water
intakes, but rather collected for discharge at some point
downstream from these Intakes.
If the Water Pollution Control Commission serious-
ly fears loss of local control over standards, it may fulfill
the responsibilities of the State for establishing standards
in the metropolitan area, and avoid the entrance of the
Federal Government by a simple act. The qualitative standards
already established by the State for the metropolitan area
can take effect immediately if the Commission will abandon
its insistence on absolutely prohibiting discharges of treated
effluent and its claim of power to prohibit such discharges
without regard to standards.
MR. STEIN: Do you want to submit that report
to the State or to the conferees?
MR. MASON: I beg your pardon?
MR. STEIN: To whom do you want to submit that
detailed report?
MR1. MASON: We would like to submit it to the
Chairman.
MR. STEIN: How soon can you have it in?
MR. MASON: I will have to consult with the
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J. M. Mason 512
engineers.
MR. STEIN: We will keep the record open. Can
you have it in a week?
MR, MASON: I believe we could.
MR. STEIN: All right. Why don't we try a week?
Did you want to answer that, Mr. Wilson, or do
you have a comment?
MR. WILSON: Mr. Chairman, as one lawyer to
another, I certainly would say to Mr. Mason that I haven't
the slightest objection to his submitting any arguments or
material that he wishes in behalf of the North Suburban
Sanitary Sewer District.
The problems of that District have been very
serious, and certainly have been fully recognized by the
Commission.
Mr. Mason's connection as attorney for that
Commission does not go back to the beginning, when the contro-
versy first developed between that Commission and the
District, and that District attempted to evade the authority
of the Commission, and perhaps my remark was a little sharp
when I said that that District was a thorn in the side of
the Water Pollution Control Commission. However, I do not
think that it was out of place because it caused the Commis-
sion to spend a substantial amount of time and effort in
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J. M. Mason
litigation that could have been much more effectively spent
on constructive water pollution control activities.
There are many aspects of the record in that
case which involve several hundred pages of hearing testimony,
and I think about 1,000 pages of trial testimony, which would
be entirely out of place to discuss here, because they have
no bearing on the issues before this conference.
Whether Mr. Mason wants to submit the statement
to the Chairman of the conference is perfectly all right
with me, and I may have something further to say after I read
that statement.
(Laughter.)
MR. STEIN: Yes.
Mr. Mason, I wonder if we could get Mr. Printz
or one of these people up with you on a colloquy, because I
think you have raised a significant question here, and I am
not sure if we really have the issue framed.
You say:
"It would seera inconsistent with the policy
of encouraging river navigation to suggest that the
entire portion of the Mississippi River from Anoka
to the Minnesota River be used for swimming, skin
diving and water skiing."
Now, if we come to different conclusions on that,
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J. N. Mason
this is a significant departure, and I wonder, Mr. Printz,
do you stay with our original recommendation? I wonder if
you would come up here, and let us try to frame this for the
conferees, because I think this is a very significant point.
MR. PRINTZ: Yes, Mr. Chairman, we very definitely
feel that that reach of the river all the way from the
vicinity of Anoka down to the North Suburban Sanitary Sewer
District ought to be available for body contact, or what we
call our collfom Guide A, the reason being that there is
limited practice now of those waters for whole body contact.
As I Indicated in my formal presentation yesterday,
there are uses made of these waters which don't show in those
particular figures of the report. Below the extensive whole
body contact zone listed in the figures, there are whole body
contact uses made of those waters, the same as there are near
the University Landing below St. Anthony Falls.
We feel that the fact that the waters are open for
navigation — there is a navigation channel — should not
preclude the use of those waters for whole body contact.
We might also point out that in Lake Pepln we are
also calling for whole body contact, and this is a heavily
navigationally used river, so we would not yield in our
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J. M. Mason
recommendations. The fact that we have limited usage now
seems to mean to us that there will be a greater usage of
this in the future.
MR. STEIN: In order to give you the last word
on this, Mr. Mason, in rebuttal, the position we have had
in other rivers, such as the Missouri, has been when the
Corps of Engineers has put in a navigational channel, they in
effect had a series of pools, and they have opened these for
recreation, for boating and swimming.
If this is not the case here, I would like to get
your view, because the conferees surely will consider this,
and this is a new point.
MR. MASON: Substantial evidence on this very
point was presented in the case before the District Court in
Anoka in the trial of the appeal from the standards, in which
a verdict was rendered in favor of the District.
It is the position of the District, and one which
differs from the position of the Federal Water Pollution
Control Administration, that the uses are inconsistent.
I am not prepared personally to present all of
the facts on which that conclusion is based. The facts are
simple enough to know, that you cannot have skin diving in
the same area that you have commercial navigation, where a
person could be injured by the commercial navigation. The
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J. M. Mason
same would be true of the water skiing.
Now, I don't pretend that that la at all a
beginning of a problem, but I am submitting the view —
MR. STEIN: But the State has a different view.
MR. MASON: The State has had a different view
from the North Suburban Sanitary Sewer District on a number
of matters.
MR. STEIN: Well, I am glad to have this, and I
think maybe we should have this.
MR. MASON: We will add this to our report.
MR. STEIN: My experience has been in other parts
of the country, and this includes Alaska and Hawaii, that
commercial navigation and skin diving are not at all incom-
patible. As a matter of fact, particularly on the rivers,
where the river is made available for commercial navigation,
we often tame what is relatively a wild river and a dangerous
river, dangerous for boats and dangerous for humans. When we
get that channelized and we put the locks in, in effect you
have a lake, and then we have this concept of multiple use.
Now, if this is inconsistent and you have any
points, I think again we should get these pretty soon in
order to consider them.
MR. MASON: We would be happy to present them.
I don't suppose you are suggesting here, Mr.
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J. M. Mason
Stein, are you, that this was a wild river?
MR. STEIN: No. When I was talking in terms
of a wild river, I didn't mean in terms of art.
Let me again give you the Missouri. It used to
be that it took a really brave, foolhardy man to hop into
that roaring Missouri River and try to swim in it and get
out, because the chances were he would not be seen again.
The Missouri River was lined up for navigation,
and we had a series of pools. The river was channelized in
many places and became calm. In those places we could run
small boats, people could go swimming, and I know the river
is so muddy that I guess skin diving would be unproductive,
but we did have water skiing. In other words, the commercial
navigation opened that up to the body contact sports.
This has happened in many other places. That is
why I am trying to get the issue on why you think they are
incompatible. It seems to have worked the other way.
MR. MASON: Well, as I say, I am not qualified
to give an answer to that, but we will add that to our
statement.
MR. STEIN: Thank you.
MR. WILSON: Mr. Chairman.
MR. STEIN: Yes, Mr. Wilson.
MR. WILSON: I would like to make an additional
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J. N. Mason
comment.
MR. STEIN: Will you talk louder, Cheater, please?
MR. WILSON: We have conveyed an erroneous im-
pression in saying that this was an arbitrary standard, because,
like all city zoning ordinances, this standard contained a
variance clause under which the North Suburban Sanitary Sewer
District could have applied for and obtained a variance from
the standard upon a showing of hardship, the same as property
owners may do under city zoning ordinances.
The lower court chose to disregard that variance
clause as relieving the absolute prohibition of the standard
Itself. That is one of the issues that will be subject to
determination by the Supreme Court on the appeal taken by
the Commission.
Bear in mind that, in the first place, the North
Suburban Sanitary Sewer District took the original appeal
from the standard adopted by the Commission to the District
Court. Then, when the District Court decided adversely to
the Commission, the Commission has appealed to the Supreme
Court for a final decision.
My principal purpose in citing that case, as well
as the previous case in which the North Suburban Sanitary
Sewer District sought exemption from the authority of the
Commission, is to show that in the situation in which the
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J. M. Mason
Minnesota Commission is placed by our law, where the adop-
tion of a standard is necessary before an enforcement order
can be issued, it practically doubles the difficulty of the
Commission and requires the application of a tremendous
amount of time and energy and money by the Commission and its
technical and legal staff through the holding of hearings
and the carrying on of litigation, in the case of these
appeals, which is not necessary in those cases where, as
under the Wisconsin law, the adoption of standards is not
prerequisite to the enforcement.
My purpose in emphasizing this point is to appeal
to the head of the Federal Water Pollution Control Agency to
give due recognition to this inescapable condition in which
the Minnesota Commission finds itself through no fault of its
own; whereas this situation does not obtain in Wisconsin or
other States that are not subject to that necessity of adopt-
ing a standard before the issuance of an enforcement order.
We think that due recognition should be given to that situa-
tion in the application of these terms of the Federal law, in
view of the unavoidable delays to which the Commission is
subject in applying those requirements of the Federal law as
to what must be done by a certain time in order to have the
approval of the Federal Water Pollution Control Administration.
MR. STEIN: Thank you, Mr. Wilson.
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J. G. Pidgeon 520
Are there any comments or questions?
(No response.)
MR. STEIN: If not, Mr. Smith?
MR. SMITH: The next statement will be from the
City of Bloomlngton.
Mr. Pidgeon?
STATEMENT OP JOHN G. PIDGEON, CITY
ATTORNEY, BLOOMINGTON, MINNESOTA
MR. PIDGEON: Mr. Chairman, Conferees:
My name is John G. Pidgeon. I am City Attorney
of the City of Bloomlngton.
Bloomington; for your information, is located on
the south boundary on the Minnesota River from about Mile
one-half to about Mile 13.5. I't is on the north side of the
river. It is a city of about 39-i square miles, with about
72,000 people. That is up from 12,000 at its incorporation
date, 1^ years ago.
It should first be stated that these remarks can
only be attributed to me because the city received only one
copy of the document last Friday and there has not been time
sufficient to permit the governing body to circulate, read,
discuss and arrive at conclusions relative to its contents.
With all due deference and respect for the
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J. G. Pldgeon
obviously dedicated and sincere persons constituting the
membership and staff of the Minnesota Water Pollution
Control Commission, and despite recognition and admission
that, relatively speaking, we are Johnny-Come-Latelys to
this problem, Bloomington Is one of those seemingly con-
tentious communities which have disagreed with the Minne-
sota Water Pollution Control Commission's standards and
have disagreed with what we consider to be grossly unfair
expansion plans for the Minneapolis St. Paul Sanitary Sewer
District.
The recommendations of the Federal Water Pollution
Control Administration seem generally reasonable and fair.
On page 27 of the General Recommendations, para-
graph numbered 1 is the recommendation that "There be no
further decrease in quality of any of the waters within the
Study Area — At first I assumed that this might be con-
strued as support for the position of the Minnesota Water
Pollution Control Commission as contained and stated in its
standards applicable to that portion of the Minnesota River
between Shakopee and the confluence with the Mississippi.
The so-called standard, with which Bloomington takes issue,
as did the previous speaker on behalf of the NSSSD, pro-
hibits the discharge of major quantities of treated sewage
into this portion of the river. If the quoted
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J. G. Pidgeon
recommendation is intended to support that so-called standard,
then I believe it should oe clarified to state that support
more explicitly.
However, on reflection, and considering the maximum
waste loadings for the stretch of the river, Page 32, paragraph
numbered 2, under "Specific Recommendations, Minnesota River"
it seems that under these recommendations the discharge of
effluent into the Minnesota River can be accommodated for
some years to cone.
Most persons seem to agree that the year 2000
population equivalent for this area which would naturally
drain to this segment of the river, Shakopee to the Mississippi,
is about 700,000. With treatment at 90 percent (5-day (20° C)
BOD and suspended solids) plus continuous disinfectant, the
12,000 pound total allowable waste load can be met. With 95
percent removal which the engineers say is feasible, the
6500 pound total allowable waste load can be met for this
population equivalent.
Assuming control and treatment of the discharges
from American Sugar and Rahr Malting Company, the engineers
are confident that the recommended dissolved oxygen levels
can be maintained.
Another statement which seems to leave the door
open for so-called regional treatment plants is that on
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J. G. Pidgepn
page 22 wherein the statement is made that "Whether the
best solution lies in the use of one or several plants is
irrelevant."
That statement seems to contemplate that regional
plants are an acceptable solution Insofar as the Federal
Recommendations are concerned and it is assumed that, once
coming here, there is as much concern for the health of
the people of Minnesota as for those of Wisconsin.
As a general principle, that statement may be
accurate. However, considering actual local facts, It
seems questionable. New plants could be built so that they
would not be subject to periodic flooding as is presently
the case with the MSSD plant. New plants, so the engineers
tell me, can be built without the bypass. Tertiary treat-
ment, if and when that is called for, can more convenient-
ly and expeditiously be added. There would be less waste
loading at one single point and thus the natural assimila-
tive capacity of the rivers can be better utilized. After
having read the document entitled Solving Our Water Prob-
lems — Water Renovation and Reuse published by the Federal
Water Pollution Control Administration, August 1966, which
seems to point the way in years ahead, it seems to me, an
uneducated laymen in this field, that the Advanced Waste
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J. G. Pidgeon
Treatment, which they call AWT, techniques can be more
readily applied to the regional plants and their applica-
tion upstream from a great part of the densely populated
metropolitan area would be more beneficial to the streams
and to the people.
As stated, absent a clarification, it is
assumed that new municipal treatment plants on, for
example, the lower Minnesota River, are not excluded by
General Recommendation No. 1.
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J. G. Pidgeon
MR. STEIN: Thank you.
Are there any comments or questions of Mr.
Pidgeon?
DR. JELATIS: Mr. Chairman?
MR. STEIN: Yes, Mayor Jelatis.
DR. JELATIS: I think if you look on Pages 31 and
32 of the Specific Recommendations for the Minnesota River,
you will find that there are no specific recommendations
given under municipal sources, and the quotation that has been
given here comes from the industrial sources and applies only
to the American Crystal Sugar Company and Rahr Malting
Company.
MR. PIDGEON: It seems to me, if I may say, that
as I interpret this document, American Crystal Sugar and
Rahr Malting, and any other industrial uses, would have to
upgrade to meet the general recommendations. If they do
f-.hat, then thJn loading into the river should make it possible
/or the 700,000 population equivalent which is expected in
this stretch of the river by the year 2000 to use this waste
loading.
I would assume that those plants would be in-
cluded in that population equivalent.
As I say, if I am wrong, I would like to know it.
MR. STEIN: Yes. Well, I am learning a lot here
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526
J. G. Pidgeon
from you people.
I think we are faced with a new situation. Let
me give it to you as I see it from your testimony and the
testimony of the previous speaker.
Before this, when we were setting up these metro-
politan area operations, we generally had the core city kind
of taking the lead and spinning it out to the suburban
communities.
I think everyone knows what happened in the
United States in the last few years. This is one of the
first ones where we are getting into a little more complicated
operation — where we have all these communities — and you
are one of them -- who want to have a voice in this and not
just tie in necessarily to the core city.
When we talked in terms of the other cities all
over the United States where they had the metro system, at
least the plans for the system were developed and the commit-
ments were made before the developments happened.
We have a very difficult problem here that we are
going to have to consider, and this is cumulative.
This is why it pays to get out of Washington and
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527
J. G. Pldgeon
hear all of this, because it never hit me the way it hits
me now, though it should have been obvious. I should have
known this. I think this presents a very interesting
problem.
I have one technical point to ask you. Why do
you think that advanced treatment plants can be handled
better regionally than in a main plant?
MR. PIDGEON: Well, they are going to be smaller,
for one thing.
In that huge plant, as I understand the pilot
plant, if that is what it is, that you have in that New York-
New Jersey area, that is in the 20 to 30 million gallon per
day capacity — I am not certain of that, but that is what I
understand.
MR. STEIN: Let me give you the views that we
had on that.
Again, as you know, we are exchanging information
and I have an open mind on it.
Our thought and our assumption was that when we
got into this complicated stuff in advanced waste treatment,
the processes may be so complex we may need the Ph.D.'s and
the computer guides and the highly trained technical people
and the notion of having individually operated plants — and
I am not talking about regional plants — might be obsolete
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528
J. Q. Pidgeon
because we just would not be able to get the trained per-
sonnel to do it.
I am not throwing this out, except that I would
like to get your views on this.
If you have a central authority, the wise thing
to do might be to have several regional plants, but you would
have a core of highly trained technical people that would be
able to handle the advanced waste treatment.
Goodness knows, sir, when you are faced with the
problems that we have in these small-town plants not being
run or operated under the most simple principle, when we think
in terms of getting something as complicated as the advanced
waste treatment plants, sometimes we shudder to think of
where the people are coming from. I would like to get your
thkining on that.
MR. PIDGEON: Well, the plant that we are
pushing for, if you will, for the three communities, is
designed for 325,000 people in the year 2000. That is sub-
stantial. We are talking about probably the second largest
plant in Minnesota. That is what we are talking about.
We think that a plant of that size and capacity
probably would be able to employ the necessary technical
personnel.
Now, we are proceeding in the legislature, Just
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529
J. 0. Pidgeon
for your Information, to try and get such a. plant. At the
same time, we are proceeding In an alternate route, and that
la we are pushing our own version for one of those of a
metropolitan system, and personally we have no desire to
add any empire to our little city down there. We would Just
as soon be happy if we can get equal representation and equal
economic factors.
If we get a fair bill, we would juat as soon
have them take over our area — I shouldn't say "just as
soon" -- we do prefer our own, but almost just as soon.
We recognize that we are part of the metropolitan
area and that it is a major factor there.
MR. STEIN: Thank you.
You know, it seems very anomalous —
MR. PIDGEON: By the way, if I may interrupt?
MR. STEIN: Go right ahead.
MR. PIDGEON: You asked about why we wanted a
regional plant. One big reason is that every time we have a
flood, and we have them pretty often up here, still that
Minneapolis-St. Paul Sanitary District plant is out of commis-
sion. The last big flood we had it was out for some sixty
days, or so.
Bloomlngton is presently connected by >ay of the
City of Rldgefield, by way of the City of Minneapolis, by way
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530
J. 0. Pidgeon
of MSSD interceptors to that plant right now. We had the
privilege of paying the bill for treatment during that
sixty-day period that they were letting it all flow down the
river.
(Laughter.)
By the way, we are not getting off the line by
our own choice either. They have no room for us after about
1970. We have to get off.
MR. STEIN: Again, this la simple, but let me make
just one remark.
You know, it seems funny that the industries
these days which have been trying to treat their wastes from
time immemorial are looking for ways to hook up with the
municipal plants, because once they hook up with them they are
absolved from the legal and technical responsibility of treat-
ing their wastes.
Maybe this is a phase that we are going through in
American life. If it is, I think we have to recognize it if
we want clean streams and work with industry. I think we should
recognize that you have a little different problem here and are
trying to do this at a different point in time than the other
metro systens were developed. It is going to take some
really imag.native thinking and good will on our parts to get
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531
J. 0. Pidgeon
that going.
MR. PIDGEON: We are not quite that insolent.
We had two years ago at the last Legislature agreed to
support a metropolitan bill if we could find one that was
fair to us.
Now, it all depends upon whose definition it is,
I guess, but we don't just want to run a treatment plant for
the sake of doing it, or for the sake of adding personnel,
or any such thing, but we do want a fair shake with equal
representation.
MR. STEIN: Right. I am sure that is what the
issue is.
MR. PIDGEON: That is what everybody wants, but
they have different definitions.
MR. STEIN: Yes, sir. Thank you very much.
MR. ODEGARD: With reference to this statement
that there shall be no further decrease in quality, this
point has come up several times now.
I would like to have a clarification of the
meaning of that.
MR. STEIN: Mr. Prints, would you want to answer
that?
MR. PRINTZ: Mr. Chairman, as I indicated yester-
day in our prepared text, the recommendations were prepared
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532
J. 0. Pldgeon
bearing in mind the guidelines for establishing water
quality standards for interstate waters. These guidelines
were issued by the Secretary of the Interior May 10th, at
the time we moved over to the Department of the Interior.
I would like to quote from Policy Guideline No.
1, which states:
"Water quality standards should be designed
to enhance the quality of the water. If it is
impossible to provide for prompt improvement in
water quality at the time initial standards are
set, the standards should be designed to prevent
any increase in pollution. In no case will
standards providing for less than existing water
quality be acceptable."
The background behind this is that pollution in
this country has gone far enough that we have established a
base line. The base line is the existing water quality. If
others are to come in, there should perhaps be additional
treatment elsewhere, so that we can maintain existing water
quality, the purpose of the Act being twofold, one, to up-
grade, and the other to preserve.
MR. ODEGARD: Would this prevent the establish-
ment of new industries?
MR. PRINTZ: We don't feel so.
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533
City of Hopkins, D. J. Thimsen
MR. ODEGARD: Well, this is what I am trying
to close in. Part of the standards are suspended solids,
and if you are not going to permit any increases in suspended
solids, it would have to be 100 percent treatment.
MR. PRINTZ: You say if there are not to be any
increases in suspended solids you would need 100 percent
treatment, or you would need treatment so that the effluent
would be equivalent to the quality of the waters presently in
existence?
MR. ODEGARD: Yes.
MR. PRINTZ: May I leave with you a copy of these
guidelines (handing same to Mr. Odegard)?
MR. ODEGARD: Thank you.
MR. STEIN: Thank you.
Mr. Smith?
MR. SMITH: I have next a statement from the City
of Hopkins.
STATEMENT OF THE CITY OP HOPKINS, MINNESOTA,
AS READ BY DONALD J. THIMSEN, MINNESOTA
DEPARTMENT OP HEALTH
MR. THIMSEN: This is a statement dated February
24, 1967, by R. L. Brubacher, City Manager.
STATEMENT BY THE CITY OP HOPKINS, MINNESOTA
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534
City of Hopkins, D. J. Thimsen
For the Conference in the matter of Pollution
of the Interstate and Intrastate Waters of the Upper
Mississippi River and its Tributaries, convening Tuesday,
February 28, 1967* at 9:30 a.m., in Minneapolis, Minnesota.
The City Council of the City of Hopkins wishes
to take this opportunity to compliment the Study Group and
its Director, Dr. Albert Printz, Jr., on their study of the
270 miles of the Upper Mississippi River and its major tribu-
taries. We feel the study was very objective and attempted
to reflect a true picture of the conditions of the 270 miles
of river included in the study project.
As interested and concerned residents of the
area involved in the project study we sincerely hope that
the Commission will continue its efforts to improve the
quality and recreational possibilities and natural beauty
within the study project. We sincerely hope that the con-
ferees will give serious consideration of high rate phosphate
and nitrate removal treatment requirements of all wastes dis-
charged to these rivers. The conservation and improvement
of all our natural resources is a concern of all citizens and
we urge the conferees to proceed with their further studies
and abatement programs as speedily as practical.
We appreciate the opportunity to present our
statement to the distinguished panel.
-------
City of Hopkins, by D. J. Thimsen 535
Sincerely yours,
/s/ R. L. Brubacher
City Manager
MR. STEIN: Thank you very much, sir.
Are there any comments or questions?
MR. DAMON: Where is Hopkins?
MR. STEIN: Where is Hopkins? Could you locate
it on the map, please? Would you come up?
MR. THIMSEN: It is located just west of
Minneapolis, right about where the "N" is here.
MR. STEIN: Thank you.
Mr. Smith?
MR. SMITH: The next statement is from the
Commissioner of Public Works of the City of St. Paul.
Is there anyone here to read this statement?
(No response. )
MR. SMITH: Mr. Ginner?
STATEMENT OF ROBERT P. PETERSON, COMMIS-
SIONER OP PUBLIC WORKS, ST. PAUL, MINNESOTA,
AS READ BY GARY GINNER, MINNESOTA DEPARTMENT
OP HEALTH
MR. GINNER: Statement of Robert P. Peterson,
Commissioner of Public Works, Saint Paul, Minnesota, dated
February 28, 1967.
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536
R. F. Peterson by G. Glnner
The City of Saint Paul on February 7r 1964,
presented to the first session of this conference a state-
ment of views and activities concerning sewerage and the
Mississippi River in the Saint Paul area. That previous
statement expressed very well our views and objectives and
recognized our responsibilities as one of the communities
located along the Mississippi River. As set forth in this
previous statement, we have a great deal of Interest and
concern that our water resources be adequately protected and
preserved. We are willing and anxious to cooperate with
others to the greatest extent possible and financially
feasible to attain these objectives.
As for detailed comments on your report entitled
"Summary and Pollution Abatement Recommendations for the
Upper Mississippi and Major Tributaries," I wish to point
out that the sanitary sewage waste from our municipal sewer
system Is handled and treated by the Minneapolis-Saint Paul
Sanitary District. This organization either has or will
present to this conference a detailed statement on its
activities. The City of Saint Paul has worked closely with
the Minneapolis-Saint Paul Sanitary District and concurs with
the comments and recommendations of this Sanitary District.
I might add, however, that we in Saint Paul were
somewhat disappointed that recognition was not made in
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537
R. F. Peterson by G. Ginner
your report of the 27.1 million dollar Improvement to
the Minneapolis-Saint Paul Sanitary District's sewage
treatment plant, even though this plant modification was
conspicuously under construction during your survey period.
The placing of this plant improvement in operation will have
a dramatic effect on pollution conditions, particularly those
portrayed in Figures 9 and 10 following Page 7 of your
report.
In addition to the operation of the treatment
plant, a matter of considerable concern to us, as well as
others, is the occasional overflow from the combined sewer
system. During the course of the year, some 4 percent of
sewage does overflow through the operation of the overflow
regulators during periods of high storm water flows. As
was indicated in our report of 1964, the rebuilding and
operational changes in these regulators is underway. In
order to aid in the coordination of the betterment program
and to simplify the financing of it, both Minneapolis and
Saint Paul have transferred responsibility for the regulators
to the Minneapolis-Saint Paul Sanitary District in order to
minimize the overflow of raw sewage from these regulators.
The Minneapolis-Saint Paul Sanitary District is developing
concepts and procedures which are relatively new. A
Federal demonstration grant has been obtained from the
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538
R. F. Peterson by G. Ginner
Federal Water Pollution Control Administration. This pro-
gram will ultimately involve some two million dollars of
expenditures financed by the cities of Minneapolis and
Saint Paul and we are confident that its completion will
bring about significant Improvements in pollution control.
In addition to collaborating and supporting the
treatment plant and regulator improvements, it is the
continuing goal of the City of Saint Paul to replace com-
bined sewers with separate storm and sanitary systems.
Wherever the opportunity occurs whether in redevelopment
or relief sewer construction, new systems are designed
as separate sewers or are designed to be compatible or
adaptable to separation at some future date. Sewers being
constructed in the few remaining unsewered areas in the
city are designed as separate systems. Complete separation
of all of the presently sewered areas is a very costly
undertaking and one that appears to be beyond the financial
capabilities of the city at this time. However, we do plan
to continue these activities to the maximum extend possible
and many millions of dollars are being spent for this sewer
work, all as set 'forth in our 1964 report.
In closing, Mr. Chairman and ladies and gentlemen,
I would like to again emphasize that we are very much
aware of the problem of maintaining proper river water
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539
R. P. Peterson by G. Ginner
qualities in the Mississippi River. Saint Paul has and
will continue to cooperate with other interested parties
in controlling and reducing water pollution to the greatest
extent that we can.
Thank you very much.
/S/ Robert P. Peterson
-------
Board of Water Commissioners, City
of St. Paul, by D. J. Thimsen
MR. STEIN: Thank you.
Are there any comments or questions?
(No response. )
MR. STEIN: If not, Mr. Smith?
MR. SMITH: I have one more from the Board of
Water Commissioners of the City of St. Paul.
Is there someone here to read this statement?
(No response.)
MR. SMITH: Mr. Thimsen?
STATEMENT OP BOARD OP WATER COMMISSIONERS,
CITY OP ST. PAUL, AS READ BY DONALD J.
THIMSEN, MINNESOTA DEPARTMENT OP HEALTH
MR. THIMSEN: Statement of the Board of Water
Commissioners of the City of St. Paul.
For presentation by Mr. Clifford W. Hamblin,
(Jeneral Manager, St. Paul Water Department, February 28,
1967, at 9:30 a.m., at the Leamington Hotel, Minneapolis,
Minnesota, at the second session of the Federal-State con
ference in the matter of pollution of the interstate and
intrastate waters of the Upper Mississippi River and its
tributaries.
Mr. Chairman:
-------
Board of Water Commissioners, City
of St. Paul, by D. J. Thimsen
The Board of Water Commissioners of the City of
St. Paul, whose responsibility it is to provide a potable
water to the population of St. Paul and all adjacent suburbs
thereto, are most vitally concenerd with the sanitary quali-
ties of the Mississippi River and its tributaries. The
Mississippi River and waters of the Rice Creek watershed, a
tributary of the Mississippi River, are utilized as sources
of the St. Paul water supply system. Our intake on the
Mississippi River is located in the City of Pridley and on
the Rice Creek watershed in the Village of Centerville on
Lake Centerville. We believe it imperative that all possible
means be taken to control pollution above these intakes to
safeguard against any sanitary hazard that could be harmful
to our water supply system.
The Federal Water Pollution Control Administra-
tion's Summary Report recommends that wastes such as sludge
from our water treatment plant which discharges into a
municipal sewerage system be pretreated to avoid any detri-
mental effect on waste treatment operation. We are pleased
to report that the Board of Water Commissioners completed a
construction project in the fall of 1966 by which the sludge
lagoon dikes were raised to an elevation sufficient to give
us approximately five years more of sludge and storage
-------
542
Board of Water Commissioners, City
of St. Paul, by D. J. Thimsen
capacity. The overflow elevation has been raised. This
allows maximum sedimentation of sludge solids in the lagoon
before the supernatant overflows into the sewerage system.
The effective life of the lagoon, of course, can be extended
by excavation of dried sludge from the lagoon with truck
haulage to the dump sites. In addition, the Board has sub-
mitted an application to the United States Department of
Housing and Urban Development for a grant to aid in the
financing of major improvements at the water treatment plant,
including facilities for reclaiming filter backwash water and
lime recovery from sludge. In this regard a preliminary
engineering report has been completed on such facilities.
Notification of grant approval will enable us to authorize
immediate preparation of construction plans and contract
documents followed by actual construction.
Provision of filter backwash water reclaiming and
lime recovery will satisfactorily provide for all wastes from
the plant for the foreseeable future.
MR. STEIN: Thank you.
Are there any comments or questions?
(No response.)
MR. STEIN: If not, we will stand recessed for
ten minutes.
-------
Natural History Society, by G. Glnner
(Whereupon a recess was had.)
MR. STEIN: May we reconvene? I think we may be
approaching the last lap.
Mr. Smith?
MR. SMITH: Are there any other industries and
municipalities represented here who wish to make a statement
who have not been called upon?
(No response.)
MR. SMITH: If not, we have some civic organiza-
tions and sportsmen's clubs who have indicated that they wish
to make a statement.
The first one is the Natural History Society.
Is there, someone here to read their statement?
(No response. )
MR. SMITH: Mr. Ginner?
STATEMENT OP THE NATURAL HISTORY SOCIETY,
AS READ BY GARY GINNER, MINNESOTA DEPART-
MENT OF HEALTH
MR. GINNER: For the Conference on Pollution
of the Interstate and Intrastate Waters of the Upper
Mississippi River and Tributaries (Minnesota-Wisconsin).
Called Tuesday, February 28th, 196?, at 9:30 a.m., in
Minneapolis, Minnesota.
-------
Natural History Society, by G. Ginner
We the members of the Natural History Society
have habitually opposed the contamination of air, water and
soil by unwise use of chemicals and indiscriminate dumping of
household and industrial wastes. It is our belief that com-
prehensive research must be conducted to prevent unnecessary
pollution of these most important natural resources for the
good of all living things. Further we believe that a massive
attack by local, State and National governments coordinated
with individual and industrial effort must be made to alle-
viate scandalous dimension of the present pollution. We
believe that standards must be established to protect the
populace of these United States as evidenced in the pollution
of both air, water and soil in the State of Minnesota, and
specifically in the Watershed of the Mississippi and its
tributaries as herein designated.
In view of the seriousness of phosphate and nitrate
contamination of these waters we recommend a special process
for their removal from all waste discharged into these
waters. In view of the recreational potential of these
waters and the necessity to*»intain the purity of these
waters at such a level that human, fish and wildlife may
safely use them we strongly urge that such steps be taken
to maintain that purity. We believe that a deviation from
these standards is both undesirable and unnecessary and that
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545
Natural History Society, by G. Ginner
the responsibility rests squarely upon citizen and govern-
ment and pledge that we will assist the agency or agencies
responsible for such standards.
We feel privileged to make this statement and
acknowledge our responsibility in arriving at a desirable
end so badly needed now and in the future.
Dr. Clayton G. Rudd, President
/S/ Clayton G. Rudd
MR. STEIN: Thank you.
Are there any comments or questions?
(No response. )
MR. STEIN: If not, Mr. Smith, will you continue?
MR. SMITH: The next statement is from the League
of Women Voters.
Is someone here to present that statement?
STATEMENT OP MRS. WILLIAM WHITING, PRESIDENT
OP THE LEAGUE OP WOMEN VOTERS OP MINNESOTA
MR§. WHITING: I am Mrs. William Whiting,
President of the League of Women Voters, and I have a state-
ment prepared by our Water Resources Chairman, Mrs. Mann.
I believe you have copies of it.
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546
Mrs. Wm. Whiting
The League of Women Voters of Minnesota would
like to thank: the Minnesota Water Pollution Control Commis-
sion for the invitation to participate in this conference.
That members of the League of Women Voters have had a
continued Interest in water resources for the past ten
years is well-known to most of the people here today.
Recently, League members nationwide participated
in further study of water resources, focusing their atten-
tion on the problems of industrial pollution abatement.
Study and discussion by local Leagues built up an impressive
amount of information on what members think about the many
aspects of water pollution control.
Realizing that there are over 6,000 women in
local Leagues in Minnesota alone who are asking questions,
going on tours and discussing water resource problems with
their families and friends as well as with other League
members, it could be said that there is an aroused public
interest in this field. There was not a tendency to blame
someone for pollution, for members obviously recognized
that the time for finger-pointing is past and the time for
action is now.
As a result of member consensus, the following
statement of position on Federal financial assistance to
industry to expedite control of water pollution was released
-------
Mrs. Wm. Whiting
by the League of Women Voters of the United States in
January 196?.
"The League of Women Voters of the United
States supports limited Federal financial
assistance to industry as a means of expediting
abatement of water pollution.
Although the League thinks that costs of
pollution abatement are a responsibility of
the polluter, it acknowledges that some help
should be made available because of the urgency
and immediacy of the problem and the immense
costs involved. League members agree that:
1......strict enforcement of anti-pollution
measures should accompany financial assistance
2......duration and scope of assistance should be
limited.
3 criteria for assistance should include
consideration of financial need of the
company, economic base of the community,
area stream standards, extent and complexity
of the pollution problem of the company and
region."
(National Voter, League of Women Voters of the
U.S., Vol. XVI, Feb. 1967.)
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548
Mrs. Wm. Whiting
Prom the comments of Minnesota Leagues, it was
obvious that members were concerned that water quality
standards be enforced and that the several levels of
government work out the most effective manner possible for
setting and enforcing standards.
A majority of the Leagues checked out their own
communities to determine the status of local municipal and
industrial waste treatment facilities. Some were pleased
with the progress that had been made, others were not so
happy. Members of the Red Wing League of Women Voters met
the challenge of the local editor and took a trip by barge
up the Mississippi to St. Paul. This was reported in a
full-page newspaper article with pictures. It was orobably
a wise decision not to do this by canoe as was originally
suggested. The Summary Report of the Task Force supported
that decision.
In the Twin Cities metropolitan area, Leagues
reviewed proposals for a metropolitan sanitary district.
No decision was made about such details as how this should
be financed. It was apparent, however, that League members
recognized that there must be some coordinating body
established. This has been discussed here all day. This
same idea is expressed very well on Page 22 of the Summary
and Pollution Abatement Recommendations under Metropolitan
Problems.
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549
Mrs. Win. Whiting
Because it is recognized that the enforcement
of pollution control is a tremendous task whether it is
done at the State or Federal level, the League of Women
Voters testified before the Appropriations Committees of
the Minnesota Legislature supporting adequate funds for
staffing the Water Pollution Control Commission. Until
budget requests are realistically met, demands for im-
proved water quality and stricter enforcement by the
public and by law cannot be carried out. Even more basic
to these decisions is a lack of Information regarding al-
ternatives. What effect the standards will have in respect
to demands for recreational needs in the metropolitan area
is an example. We turned to agencies staffed by engineers
to take care of polluted water. Now we are beginning to
ask about the total regional impact of pollution, the real
economic and amenity costs of it. There has appeared to
be little comprehensive analysis. Perhaps the engineers
feel they have more than enough to answer without taking
on these additional responsibilities, but who then is to
provide this information.
There are increasing and varied demands for
clean, open water, that suggest far heavier demands in
the years Immediately ahead. There is a growing and deep-
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550
Mrs, Wm. Whiting
rooted concern about the quality of our environment and
the threats to this quality from the wastes of an expanding
technology. With the increased affluence of our society
there has been a recognition of the values of preserved
outdoor amenities and aesthetically attractive surround-
ings. To complicate the matter further, there is still
a marked movement of the population to metropolitan areas,
Increased demands for material goods, and increased leisure
for recreational pursuits. The continued strengthening
of pollution control legislation attests to the concern
of the people that something has to be done. It appears
it is time for effective action. We can no longer treat
water as a free good that Is used but once and discarded.
In the field of water pollution, people are in need
of information, of alternatives. Public support behind
pollution control orders will prove to be the most effective
sanction. It is in this arena of activity the League of
Women Voters, through membership education and interest,
will continue to contribute toward improvement of water
quality. Thank you.
MR. STEIN: Thank you. Do you want the rest of
these statements inserted in the record?
MRS. WHITING: Yes. That is why we presented them.
MR. STEIN: These will be inserted as if read.
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551
Mrs. Wm. Whiting
(The following documents were submitted for
inclusion in the record:
LWV of Minnesota, State Organization Service, U. of M.,
Minneapolis, Minn.
EXCERPTS FROM REPORTS OP LOCAL
LEAGUES OP INDUSTRIAL POLLUTION IN THEIR COMMUNITIES
Owatonna; Our city engineer said our industrial
pollution was well naken care of. Industry can dump a cer-
tain amount of waste into local sewage plant. If they go
over the amount allowed they are assessed by the city.
Local plants use chemicals to treat waste and some plants
have built area dumping lots near their plants. Industry
pollution is being checked constantly by city engineer.
Our local sewage plant has been adequate but we are adding
another new addition.
Wlllmar ; The pollution of the lakes by the
railroad, state hospital and home owners has been stopped
and for quite a while. All business and the State Hos-
pital use the Municipal Sewers. There are two businesses --
Central Dairy and Farmers Produce that use a great volume
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552
Mrs. Wm. Whiting
of water in their business and dump a great quantity of water
(I would guess quite pure) into the storm sewer system and
thus get a reduced commercial rate. Business that uses water
for air conditioning in the summer has its water rate adjust-
ed. Business and private home owners and renters pay a sewer
charge based on the amount of water they use for selected
months of the year. The sewer plant is becoming too small
and there are plans in the future to expand it and move it
as the new junior high school will be built in the farm land
across the road. There are large areas which have septic
tanks which will no doubt be joined to the city sewer system.
There are no large problems as to my knowledge.
St. Paul- Probably the worst example in this city
is the sewage discharge from the meat-packing plants in South
St. Paul. This sewage is given only primary treatment before
going into the Mississippi River. No solution to this situa-
tion appears to be developing at present.
Edina; I asked George Hite, our Village Engineer
for Edina, if there were any cases of industrial pollution in
Edina. At this time, there are no industrial polluters in
Edina. A few years ago there was a problem with a dairy, but
this was resolved when the dairy was connected to the munici-
pal system. Edina has 13 wells providing water. Edina con-
tracts with the Minneapolis-St. Paul Sanitary District for
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Mrs. Wm. Whiting
sewage removal. Mr. Kite stated that the Village did not
mind the present charges for sewage disposal but did dislike
the lack of representation.
Anoka; No industrial pollution. Anoka State Hos-
pital (on Rum River which drains into the Mississippi) was a
major offender until 1956 when it went into the City of Anoka
secondary treatment plant.
The City of Anoka faces a necessary expansion of
its plant. Anoka takes care of the State Hospital, Mercy
Hospital in Coon Rapids, and the village of Champlin also.
A study group has reported and no doubt concrete plans will
be forthc oming.
Coon Rapids; No known industrial pollution.
Member of N.S.S.D. Coon Rapids is being sewered via intercep-
tors to Pigs Eye. 1/3 is now sewered and no date for comple-
tion but work is proceeding and plans are laid out for the
entire city that can be feasibly sewered.
St. Anthony Village; Our sewage is transported
to Pigs Eye - felt there was need for more favorable or fair
way of costing for any community, not necessarily only our
own. Ideally, effluent charges would be most fair when and
if possible.
Silver Bay; We are very fortunate not to have
a pollution problem in our community.
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55**
Mrs. Wra. Whiting
Northfield: We did a brief survey of our Canon
River situation, talking with the City Engineer, County
Planning and Zoning and Health officials, local businessmen,
and members of interested groups. All industries in North-
field are connected to the municipal sewage treatment plant,
so that there is no local problem. The river, however, is
polluted from various sources upstream, and we suffer from
their folly. As of now we have only been able to write a
few letters of protest as individuals. If we decide to do a
local study on this, of course, much more will be done.
St. Cloud; The St. Cloud area Metropolitan Planning
Commission, St. Cloud Health Dept., and League of Women Voters
sponsored an Environmental Health Study, just recently com-
pleted. Included in this study was a survey of all water and
sewer systems, contamination, and systematic recording of all
pollution, private, governmental, and industrial, along the
Watab, Salk and Mississippi Rivers. The results of this
survey were used in our discussion, and will be published
within the next couple of months, with recommendations hope-
fully being acted upon at that time.
Worthington; Worthington completed a new sewage
disposal plant about 3 years ago without any State or Federal
assistance. This modern plant combines both primary and
secondary treatment of the effluent.
We have two major industries, Armour's and
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555
Mrs. Wm. Whiting
Campbell Soup. The City spent $500,000 more just building
lagoons and a sewer line for Armour's which processes hogs.
The retirement of cost, maintenance and operation of the
disposal plant is paid by the users. Private individuals
pay monthly 75 percent of their average water bill for the
months of January through March. Commercial establishments
pay a straight 75 percent of their monthly water bill.
Armour's and Campbell Soup pay 50 percent of their monthly
water bill. Since they use two-thirds of the water pumped
each day, they pay a major part of the operation. The sewage
of these companies goes through grease pits where the grease
is skimmed off before the effluent enters the disposal plant.
This has been a reasonably satisfactory solution to the local
problem.
New Brighton; There have been reports at various
times of pollution of Long Lake by rendering plant and/or
land fill dumps. Local government has ordered this stopped.
Most of the village Is served by sanitary sewers.
Albert^ Lea; Albert Lea has adequate sewage
treatment now. A study made by local Interested citizens,
state and local authorities several years ago has resulted
in dredging of the lake and the establishment of a sewage
system in a new housing area. Our largest industry, the
Wilson plant, has its own excellent treatment plant,
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Mrs. Wm. Whiting
established as a result of local pressure and the State
WPCC. If Albert Lea grows our treatment plant will not be
adequate and there are some outlying areas of pollution
now.
Bemidji; There is no particular problem in the
local system. The disposal plant is adequate up to a
20 percent population increase. An additional fill would
bring the sewerage disposal up to peak position.
Perhaps private homes on the lake shore of
Lake Bemidji could raise the bacterial count.
A study of the Nu-Ply Corporation Report Is at-
tached to this sheet which shows, at present, no industrial
pollution.
Most "polluters" are private citizens.
Arden Hjlls; Ours is the problem of the Metro-
politan Sanitary Sewer District. Shorevlew area has very
little industry. We are as a group studying the publication
Metropolitan Sanitary Sewer District in 196?.
Frldley; Frldley residents are making sure
safeguards will be taken to protect and maintain the natural
beauty of Rice Creek as It flows five miles through Fridley
into the Mississippi River. Concerned citizens began dis-
cussing the problem of water control last spring when the
water level went higher than It had for over sixty years.
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Mrs. Wm. Whiting 557
At a recent organizational meeting, by laws for* the Rice
Creek Association were adopted and officers elected.
The association, which is limited to Pridley
residents, formally declares its purpose "to preserve,
maintain, protect and promote the natural beauty and con-
stant uniform flow of Rice Creek." However, It seriously
is considering the need for a watershed district to help
eliminate uneven and excessive run off from upstream areas.
The Rice Creek Watershed District, if created, would most
likely Include some 25 communities, taking in 190 square
miles.
Golden Valley; Golden Valley, according to
the village engineer, doesn't have a water pollution prob-
lem. We have no industries that discharge effluent of any
great quantity into our city sewer system and there aren't
any streams large enough to be used for carrying away waste,
Austin: Austin has no Industrial sewage prob-
lem because the Geo. A. Hormel Co., our biggest industry,
is paying two million dollars for a sewage treatment plant
for the city. The city built it and by so doing the Hormel
Company does not have to pay property taxes on the plant.
Our worst problem is the pollution of several streams by
cess pools and direct drainage from out of city limits
homes. These are gradually being cleaned up as new areas
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558
Mrs. Wm. Whiting
are brought Into the city. Strict enforcement of present
laws would help speed up this trend. Until the streams are
free of sewage, our one lake is unfit for recreation.
Columbia Heights; We have no industrial water
pollution. City officials have watched closely air pollu-
tion. Recently they requested Cargill to use equipment to
stop flax dust.
Moorhead; We are just now building a municipal
fddition to our sewage disposal plant (mechanical) with a
Federal grant of 1/3 of the cost. One of our offenders,
a creamery, will be included under the municipal facilities,
and will pay user charges. Another offender, a sugar beet
plant, will not be included, as it is outside of the munici-
pal plant's limits, and so will continue its systematic
method of polluting our river. This influences our strong
attitude about enforcing the laws currently on the books
rather than inducing the companies to comply.
Hibblng-(Chisholm); Hibbing has no problem at
this time.
Chisholm just corrected their raw sewage dis-
posal.
Was told our neighbor to the west, Nashwauk,
empties raw sewage in a lake.
Granite Falls; Local problems are handled by
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559
Mrs. Wm. Whiting
local taxes and our industrial plant. Plews Oiler Company
has their own controlled system which partially purifies
water before it goes into the municipal system.
Brooklyn Center; Brooklyn Center does not have
an industrial pollution problem. If in the future industrial
waste should become excessive, local ordinance requires pre-
treatment of sewage.
(Brooklyn Center has a contract with the Minnea-
polis - St. Paul Sanitary District. Industry uses this
disposal system.)
* *
LVJV of Minnesota, State Organization Service, U. of M.,
Minneapolis, Minn. 55^55
EXCERPTS FROM REPORTS OF LOCAL LEAGUES
ON A STUDY OF POLLUTION ABATEMENT INCENTIVES
From the consensus reports on the national
consensus it appears that the role of the state was seen as
mainly enforcement and setting water quality standards.
Nearly all members agreed that the state needed
a stricter enforcement program. It was suggested that more
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560
Mrs. Wm. Whiting
personnel be hired for the W.P.C.C. Approximately 1/3 of
the units recommended an effluent charge. They felt that
an effluent charge would compel industries to install pollu-
tion abatement equipment. Also, the money collected could
be used to finance municipal treatment facilities for indus-
trial wastes.
Some felt that the state needed more uniform
standards of water quality. There was a strong feeling that
the members wished to keep control of the water pollution
problem at the state level rather than at the Federal level.
Members recognized the difficulty here as In-
volving competition between states for Industry. Although
we view the problem of pollution on interstate waterways as
a national concern, three of five units thought the state
should consider some type of tax relief or incentive.
We did, however, include the role of the state
in the over-all problem of pollution abatement in our dis-
cussion. The general feeling was in favor of greater
coordination and cooperation between Federal, state and
local agencies with special emphasis on planning for River
Basin or Water Management districts, representing all areas
of the state.
Strict enforcement at all levels as soon as the
water standards are set. Those in favor of aid by government
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561
Mrs. Wta. Whiting
felt that this should be at the Federal level for uniform-
ity, with state cooperation.
We advocate uniform state legislation and good
enforcement policies. It was suggested the pollution
problem be alleviated through existing state and Federal
agencies, rather than creating a new separate devl. Legis-
lation to prohibit raw sewage from ships and boats on
Minn.'s waterways is in order. Perhaps realistic, higher
user charges to both domestic and industrial users would
help to preserve this dwindling, precious commodity.
Recognition via the news media should be devoted to those
industries successfully making gains in pollution control.
We all felt that Federal control would provide
consistent treatment to all companies, would eliminate the
threat of losing industry to other locations, and would
provide an enforcement agency for the states. We did not
have enough time to develop the state's position but all
felt that the Water Pollution Control Commission should
work to its fullest capabilities.
Enforcement legislation should be on uniform
Federal basis.
Standards for water pollution control should
be in effect in all intra-state waterways.
Members felt that stricter enforcement of
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562-
Mrs. Wm. Whiting
present laws and regulations would force industry in our
state to clean the water they use.
We feel Federal 'feticks" are mandatory. State
may participate under the Federal organization and enabling
legislation.
* # *
LWV of Minnesota, State Organization Service, U. of M.,
Minneapolis, Minn. 55^55
STATEMENT PREPARED BY THE LEAGUE OF WOMEN VOTERS OF
MINNESOTA FOR THE SUBCOMMITTEE OF THE MINNESOTA SENATE
FINANCE COMMITTEE HEARING ON THE 196?-9 BUDGET OF THE
MINNESOTA DEPARTMENT OF HEALTH
The League of Women Voters of the United States
has been concerned with the problems of water management
since the topic was first placed on its national study
agenda in 1956. Our members have worked to support com-
prehensive long-range planning for conservation and develop-
ment of water resources and improvement of water quality.
In order to better understand the intergovernmental prob-
lems of water resource planning, we have twice published
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563
Mrs. Wm. Whiting
studies in Minnesota surveying the work of the Water
Pollution Control Commission (KNOW YOUR RIVER BASIN
SURVEY, I960; ON THE WATERFRONT, Mpls. League, 1965). We
have followed with Interest the Commission's efforts to
establish quality standards for our interstate waterways
as required by the Federal Water Quality Act of 1965* for
which our League lobbied in Washington.
Representing the 69 Leagues of Minnesota, we are
today concerned with the problem of adequately financing the
work of the Water Pollution Control Commission's staff in
the Department of Health. In 1965, the staff's wide range
of charges included study of the quality of waters in the
state; review of plans and issuance of permits for construc-
tion and operation of municipal and industrial waste disposal
facilities; investigation of pollution reports; administra-
tion of certain grant provisions of the Federal Water Pollu-
tion Control Act; and cooperation with local, state and
Federal agencies concerned with state water pollution prob-
lems. Even at that time these duties proved too numerous
for the budgeted staff of 35 to maintain frequent and regular
surveillance of water quality conditions throughout the
state.
With the passage of the Federal Water Quality
Act of 1965, the duties of the Commission were expanded to
-------
564
Mrs. Wm. Whiting
provide for adoption and Implementation of water qualify
criteria for interstate waters. Such criteria are to be
established by June 30, 196?. Although the Water Pollu-
tion Control staff obtained money to support 5 new positions
between 1965 and 6? from a Contingency Fund through the
Legislative Advisory Committee, the enormous amount of time
required to make background studies and conduct hearings for
the establishment of water quality criteria has continued to
deny coverage of the Commission's legislated range of activi-
ties. Standards have now been set for portions of the
Mississippi River and for the Minnesota, Red, and Rainy
Rivers, but much is left to be done to complete the job and
the problem of Implementing those standards which have been
set has not been covered.
Data compiled in 1964 by the Public Administration
Service, Chicago, under contract with the U. S. Department
of Health, Education and Welfare show that the minimum
staff necessary to operate the Minnesota WPCC would number
58. Desirably, the staff should number 104. These figures
were recommended before the 1965 Water Quality Act enlarged
the Section's obligations.
In the requested budget of the Department of
Health for the 1967-9 biennium, the Section on Water
Pollution Control asks for funds to support a total staff
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565
Mrs. Wra. Whiting
of 65. The Governor's recommended budget grants funds
which would support only the 35 persons employed by the
Section in 1965. It would, according to the Section's
Executive Engineer, not cover the 5 positions recently
authorized by the Legislative Advisory Committee.
Of the 40 positions authorized at the end
of 1966, 13 positions are now vacant, primarily because
the Commission is unable to meet salary competition.
Because of lack of budgeted funds, the Civil Service has
not allowed flexibility in setting initial salaries at higher
steps than classified, thus lowering the Section's competi-
tive status in hiring professional personnel vis-a-vis both
Industry and pollution control agencies in other states.
According to the February 10, 1967 Minneapolis
TRIBUNE, a long-awaited study of the Twin Cities area, Upper
Mississippi River Basin by the Federal Water Pollution
Control Commission will be published February 28 in conjunc-
tion with a Federal pollution enforcement conference in
Minneapolis. The study Is reported to recommend a three-year
timetable for cleaning up the rivers from Mankato and Anoka
to Red Wing which are "now too polluted for even limited
human contact activities such as boating... If this timetable
is adopted by the conference and the Secretary of the
Interior, it will be returned to the WPCC and its Wisconsin
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566
Mrs. Wm. Whiting
counterpart, which must then act to insure that the pro-
posed water quality standards are met." . . . "if the
state agencies fail to act, the Federal government can
intervene."
The League of Women Voters feels that it is
pointless to assign additional responsibilities to the
Commission without increasing funds to hire the people to
do the work. We urge that the Minnesota Legislature grant
the Water Pollution Control Commission and its staff the
funds to enable it to properly accomplish its tasks, of the
utmost importance to the health and welfare of our citizens
and to the attractiveness of the state as a national
recreation area.
# # *
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567
A METROPOLITAN
SANITARY
DISTRICT
IN
A Review of Past and Present Proposals For A
Twin Cities Metropolitan Sewage District
October 1966
Prepared by the Ad Hoc Metropolitan Water Resources Committee
of the Minnesota League of Women Voters
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568
Mrs. Wm. Whiting
The League of Women Voters of the United
States has been concerned with the problems of water
management since the topic was first placed on its national
study agenda in 1956. In I960, the national position was
stated by its members as follows:
"Support of national policies and pro-
cedures which promote comprehensive long-range
planning for conservation and development of
water resources and improvement of water
quality. Among these policies are: a) better
coordination and elimination of conflicts in
policy at the federal level; b) machinery
appropriate to each region which provides
coordinated planning and administration; c) cost
sharing by government and private interests in
relation to benefits received and ability to pay."
The League has strongly emphasized within this
position the importance of citizen participation in consider-
ation of alternative plans for water development. The people
who will have to live with the resulting development should
be able to make choices before irrevocable decisions are
made. This study of metropolitan sanitary district proposals
for state legislation has been prepared to enlarge the
understanding of all Minnesotans concerning some of the
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569
Mrs. Wm. Whiting
available methods of satisfying metropolitan sewerage
need s.
INTRODUCTION
Since the creation of the Minneapolis-St. Paul
Sanitary District (MSPSD) by the 1933 State Legislature, the
Twin Cities have been provided with sewage disposal facilities
ahead of those in other large Mississippi River cities. The
rapid growth rate of the Twin Cities metropolitan area, how-
ever, now requires the extension of equally good disposal
systems to unsewered suburban areas.
The authorized limits of the present MSPSD are
those of the two core cities, Minneapolis and St. Paul. Areas
adjacent to the cities may contract with either city or the
District for disposal service. At present, there are 39 such
contracting areas. These contracting communities are not rep-
resented on the governing board of the District, and therefore
cannot resolve fee inequity except through the courts.
The Twin Cities metropolitan population is
estimated to be 4,000,000 by the year 2000. At least 77
suburbs will require new or expanded sewage treatment facili-
ties by that date. Concerned parties have seen that required
expansion should be undertaken by a responsible agency
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570
Mrs. Wra. 'Whiting
representative of the total area which would insure a
coordinated, long-range program of safe and proper waste
disposal in waters which are continually overtaxed by multiple
uses. Such an agency should select those plans for expansion
which result in the least cost to the metropolitan area as a
whole and affect the area in a uniform manner.
An incentive for cooperative planning has
recently been provided by the Federal Water Quality Act of
1965. A 10 percent bonus in Federal grant funds is available
under the Act for community sewage works construction "that
is part of a comprehensive metropolitan development plan."
Proposals for state legislation establishing a
metropolitan sewerage agency have been advanced and defeated
before each session of the Minnesota Legislature since 1961.
In preparation for the '6? legislative session, sewer study
committees and civic groups in the core cities and suburbs are
aligning themselves behind specific proposals. Based on the
experience of past sessions, there is little possibility for
passage of sewage district legislation until l) a clear
majority of metropolitan legislators agree on basic formulas
concerning the financing, administration and geographical area
of a metropolitan sanitary district; and 2) legislators from
the state as a whole are stimulated to take action on the
metropolitan sewerage problem.
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Mrs. Wm. Whiting 571
HISTORY OP METROPOLITAN SANITARY DISTRICT PROPOSALS
In 1927* the Minnesota State Legislature
created the Metropolitan Drainage Commission to investigate
and recommend alternative solutions for the abatement of
pollution caused by the discharge of untreated sewage Into
the water courses of the area. All of the early trunk
sewers, some dating back to l8?0, were routed directly to
the river. By 1930 the total outflow capacity of all out-
lets in the Twin Cities area was two and one-half times the
average flow of the Mississippi River.
The Drainage Commission studied some forty
alternative projects. The project selected as most desir-
able was a system of Intercepting sewers (intercepting=serv-
ing more than one area) terminating at a single treatment
plant for both cities, located downriver from the center of
population at Pigs Eye Island in Southeast St. Paul.
The Legislature in 1933 established the
Minneapolis-St. Paul Sanitary District to provide the system
of sewage collection and treatment recommended by the Drain-
age Commission. From 1933 to 19^0, the District expended
over 10 million dollars for the construction of those works
which today would cost over $50 million. The facilities
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572
Mrs. Wm. Whiting
constructed at that time were designed to serve only about
122,000 acres as compared with the present area of about
250,000 acres. Primary treatment removing an estimated
35 percent of the "pollutional load" of the sewage was
effected before the effluent (residue) flowed into the
Mississippi. The District was, and is, governed by a Board
of seven trustees: three from each central city and one
appointed by the Governor as a member outside the District.
The post-World War II housing boom so rapidly
increased the size of the metropolitan community in both area
and population that the design boundaries which originally
were thought to be adequate until 1970 were surpassed in the
late 19^0's. In addition, many of the suburban fringe com-
munities developed without regard for the availability of
public sewerage systems. This growth created an urgent need
for additional sewer capacity with a backlog of homes which
were struggling to get by with individual disposal systems,
often in soil conditions which would not support this means.
(Between April, 1959, and December, 1961, Department of
Health surveys revealed that in 39 suburbs 47.5 percent of
private home water wells showed evidence of contamination by
sewage). As communities began contracting for MSPSD service,
Minneapolis found it necessary to undertake major construc-
tion projects for the exclusion of storm water (street and
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Mrs. Wm. Whiting 573
roof drainage) from its major trunk and interceptor sewers
to provide capacity for additional amounts of suburban
sewage.
The "design flow" of the Pigs Eye plant of
134 million gallons a day was reached in 1952, fourteen years
after the plant went into operation.
The Five-Year Study
In 1956, the Board of Trustees of the Sanitary
District authorized a five-year $500,000 program of research
and investigation to determine the requirements until the
year 2000 for metropolitan sewage works expansion.
The approximate dimensions of the area studied
were 3^ miles north and south and 30 miles east and west, an
area of over 1,000 square miles. In addition, the studies
included a 114 square mile area surrounding Lake Minnetonka.
Eighty-two separate city, village or township units were
situated within the main study area, with 21 more in the
Lake Minnetonka Area.
To facilitate the development and presentation
of a plan of sewage works projects, the area was divided into
six major units referred to as regions (seen on map on
page 567). The regional limits were based on such factors as
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574
Mrs. Wm. Whiting
topography, political boundaries, expected direction of popu-
lation growth, and location and capacity of existing works.
The more than 200 combinations of projects con-
sidered under the Five-Year Program were finally resolved into
four alternative Metropolitan projects. Two of these projects
were based on conveying the area's sewage to one central treat-
ment plant at the Pig's Eye Island location, while the other
two involved using one or two regional plants on the Mississ-
ippi and Minnesota Rivers in addition to the central plant on
the lower river. The Lake Minnetonka Region was excluded from
consideration as part of a metropolitan district in these final
reports (see section on Geographical Area of the District,
page 15). No consideration of political reorganization of a
district board in order to give equitable representation of
the regions was reported in the published results of the Five-
Year Study, September, 1960.
As the Pive-Year Study was concluded, the 1961
Legislature voted on a bill which would have created an ex-
panded Metropolitan Sanitary District. The bill passed the
House but died in the Senate. Recognizing, however, the
crucial needs for sewerage systems in the suburbs, the 1961
Legislature passed a bill which enabled a group of five
northern suburbs (Blaine, Coon Rapids, Fridley, Mounds View,
and Spring Lake Park) to form their own regional Sanitary
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575
Mrs. Wm. Whiting
District (NSSD - Northern Suburban Sanitary District,
further described on pp. 15, 11, 18).
With the failure of the 1961 metropolitan bill,
the Trustees of MSPSD decided to proceed with the improve-
ments necessary to handle present and future demands of
the area the District was then serving: the two central
cities and 24 contracting areas. In 1962, a $22.8 million
expansion was begun at the Pig's Eye plant. Operational in
1966, it provides secondary treatment (biological treatment
of sewage after primary sedimentation treatment) with high-
rate activated sludge process. This treatment Increases
the removal of the "pollutlonal load" from 35 percent to
75 percent. Destruction of coliform bacteria (counts of
which are used as a standard Indication of pollution) has
increased from 50 to 99 percent.
The Comprehensive Sewage Worths Plan
In the 1963 Legislature a bill creating a
metropolitan sanitary district was introduced again, this
time with the backing of a governor's advisory committee
on metropolitan problems. The Legislature, however, in-
stead passed the 1963 Ashbach Act, sponsored by Representa-
tive Robert Ashbach of Arden Hills. The Act required the
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576
Mrs. Wm. Whiting
central cities to submit, through the Minneapolis-St. Paul
Sanitary District, a Comprehensive Sewage Works Plan for
the Metropolitan Area with a construction schedule, cost
estimates and possible financing methods. The plan must
be published by October 1964, and be reviewed and amended
as necessary by the Minnesota Water Pollution Control Com-
mission before presentation to the '65 Legislature.
The 1964 MSPSD plan, approved by the City
Councils of Minneapolis and St. Paul, included the following
provisions: (based on a design year of 2000)
1. A collection area of 900 square miles
would be served by expanded Pig's Eye
treatment facilities. The completed
plant could handle 400 million gallons of
sewage a day, with full secondary
treatment.
2. The present contract system and govern-
mental structure of MSPSD would continue.
Suggestion was made, however, that
contracting communities Join to form
regional districts for contracting
purposes.
3. Construction costs would amount to
some $145 million. Pig's Eye requiring
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577
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579
Mrs. Win. Whiting
$18.2 million beyond the $22.8
million spent on the 1962-65 pro-
vision for secondary treatment and
expansion.
4. For construction within a community,
the community itself would determine
the financial arrangements. Construc-
tion costs of common, or interceptor,
sewers should be proportioned to each
community based on use (flow), community
property value, and on total developable
acreage in the community. Costs and
maintenance of Pig's Eye plant would be
based on annual sewage flow.
It is important to note the domination of this
plan by the single-plant concept. Two of the original six
regions considered in the Five-Year Study were at this point
eliminated from consideration because they didn't fit into
the Pig's Eye network: the Southeast region including
South St. Paul, with its own treatment plant, and the Lake
Minnetonka region. One major reason for scrapping the
regional plant alternatives suggested in *6l by the Five-
Year Study lay in the publication in 1963 of stream stand-
ards for the Mississippi River from Anoka to Hastings by
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580
Mrs. Wm. Whiting
the Minnesota Water Pollution Control Commission. The
first in a system of standards published by the Commission
to conform with Federal interstate streaw regulations,
these standards state olearly that no major amounts of
treated sewage effluent oan be discharged into the river
from Anoka to the St. Anthony Palls in Minneapolis — which
would presumably eliminate the possibility of constructing
a regional plant for the north suburban area. Minnesota
River standards published during the last year state that
no major quantities of treated sewage effluent oan be dis-
charged into the Minnesota from Shakopee to the mouth of
the river, which precludes the use of regional plants in
most of the southwest suburban region. Suburban arguments
and court oases taking issue with these standards are dis-
cussed on pages 17 and 18.
Early in the 1965 session of the State Legisla-
ture, a bill proposing a metropolitan sanitary district,
called the '65 Ashbach Bill, was introduced in the House of
Representatives. At the same time, the Water Pollution
Control Commission made known its recommendations on the
MSPSD plan to the legislature, in accord with the provisions
of the '63 Ashbach Act, The Commission declared its
agreement with the engineering plans of the District, but
returned the finance and cost apportionment plan to the
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58l
Mrs. Win. Whiting
oities with the recommend at ion that a single, area-wide
metropolitan sanitary district be proposed to the Legis-
lature. The Commission further recommended that all
capital costs of this district be financed by bonds to
be repaid by an ac[ valorem tax on all real property within
the enlarged district and that all operation and maintenance
costs be met by a service charge to users of the system.
The core cities declined to change their
position after hearing the WPCC recommendations, reiterat-
ing the original finance and apportionment proposals of
the MSPSD plan as written into the House Ashbach Bill.
Undoubtedly lack: of time for further comprehensive study
before the end of the session contributed heavily to the
cities' "stand-pat" position.
In the closing days of the session, the Ashbach
Bill was passed in the House. The bill was then sent to
the Senate where it was radically amended by the Senate
Civil Administration Committee. As proposed by Senator
Wayne Popham of Minneapolis, and inspired by the results
of a Citizens League "Report on Metropolitan Sewerage
Needs" published in April, the amendments simplified the
bill's financing and cost apportionment procedures. The
final bill, however, did not pass the Senate. Since the
specific provisions of that '65 amended Ashbach Bill will
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582
Mrs. Wm. Whiting
be considered among the major alternatives for sanitary
district legislation in the '67 Legislature, they will
be discussed in the following sections which contrast
present district proposals on the basis of financing,
administration, etc.
FINANCING A SANITARY DISTRICT
The financial framework of the proposed
Metropolitan Sanitary District (MSD) has become a major
stumbling block: to the establishment of such a district.
When a MSD is created, money must be collected
for:
1. Capital Costs - that is, the expense
(principal and Interest) of new inter-
ceptor sewers or the expense of disposal
plant expansion.
Also included here might be the
expense necessary to purchase existing
sewage facilities for use under the new
MSD. For the most part, this would amount
to "buying out" the present Mlnneapolis-
St. Paul Sanitary District.
2. Year to Year Operational and Maintenance
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583
Mrs. Wm. Whiting
Costs - e.g., maintenance of the lines,
plant treatment oosts, staff salaries.
General Methods of Financing
There are two basic methods of collection in
use today, either of which, or a combination thereof,
might serve as the financial backbone of a MSD.
,A. Funds may be collected according to "use," I.e.,
the dry weather volume of sewage flow from any
area as compared with the total volume of flow
for the entire district. Other factors, such as
strength of the sewage and flow characteristics,
may be considered along with the volume when
payment rates are determined. This rate amounts
to a service charge.
This method of payment is equitable in that
those who make the most use of the facilities also
pay the greatest share. It may be considered un-
fair in that owners of vacant property may not
share in payment for lines that enhance the value
of their land. (This would depend on the local
method of collection employed by a municipality
to meet its use-charge obligation. If a property
-------
584
Mrs. Wm. Whiting
tax is used locally, vacant property owners would
share in payment.) It is regressive in that
families of low income pay a proportionately
larger share of their income for service.
Public officials may prefer such a charge
as it adds nothing to taxes, requires no popular
vote, is free of debt limitations in bonding and
brings revenue from tax-exempt property. A pay-
ment system based on sewage flow could call for
close monitoring of Industrial use. An appropriate
charge could then be made to each Industrial plant,
based on the volume and strength of its effluent.
B. Funds may be provided by a general tax - specifi-
cally, an ad valorem property tax throughout the
whole district.
Proponents of area-wide taxation say that
community-wide benefits should be supported by
general taxation. Since a property tax may be
listed as an exemption on individual tax returns,
state and Federal, there could be a considerable
total savings In income tax to district homeowners.
Critics of area-wide taxation point out that
there Is no distinction between user and non-user,
public and Individual benefits, and that there is
-------
585
Mrs. Wm. Whiting
no revenue from tax-exempt property.
Taxes are most frequently used throughout
the country to meet oosts of Interceptor sewers
and treatment plant construction.
Present Collection System of MSPSD (Minneapolis-St. Paul
Sanitary District).
Yearly operational expenses are divided between
the core cities (Minneapolis and St. Paul) on the basis of
the percent of the total flow each has contributed to the
Pig's Eye plant. Each core city, then, determines the
percent of flow contributed to it by each of its contract-
ing areas. Each contract area pays a service charge to the
core olty based on this usage. In addition, the contract
charge rate reflects the cost of lines necessary to connect
the outside area with the core city system. Costs to the
core cities for expansion of Pig's Eye facilities are also
reflected in the rates quoted contract areas.
Proposals for payment under a new MSP (Metropolitan Sani-
tary District).
A. Operation and Maintenance Costs. In all
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586
Mrs. Wm. Whiting
proposals studied, It Is recommended that
year-to-year operation costs be paid on the
basis of current use. The Popham amended
1965 Ashbach Bill provides that "strength" as
well as flow of sewage be considered In deter-
mination of any rate.
B. Capital Costs. This section deals with specific
proposals and arguments for each of the two
methods of collection as they pertain to
Minneapolis, St. Paul and their suburbs.
Following this, the question of the necessity
of purchase by a new MSD of the existing sewer
network is considered.
Since some proposals deal differently with
the cost of Interceptors as opposed to the cost
of disposal plants, these differences are out-
lined in Table I.
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"USE" BASIS. Both the Popham amended Ashbaoh Bill
and the 1965 Citizens League "Report and Recommenda-
tions on Twin Cities Metropolitan Area Sewage Needs"
propose collection on the basis of use either current
or in the design year 2,000.
The distinction between "use in the design year"
and "current use" is Important. In the design of an
interceptor, allowance in size must be made so that
the interceptor will be adequate as suburban popula-
tion and usage increase. To proportion the cost of
these oversize Interceptors by current use would be
to charge the Initial users unduly; an area not
presently "hooked-up" would not pay its share for the
oversize Interceptor designed for its use at a
later date.
Proponents of the use basis of collection con-
tend that: a charge for new interceptors based on
ultimate usage insures that each area will be paying
its fair share on a common basis; the factor of
distance from the treatment plant will not be con-
sidered so that outlying areas will not be unfairly
penalized with the cost of the longer interceptors;
the method of apportioning costs is direct and
simple; since treatment plants are constructed in
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589
Mrs. Wm. Whiting
stages as use demands, a current use formula is
reasonable, simple and advantageous from the stand-
point of equity.
2. TAX BASIS. The St. Paul Sewer Study Committee has
issued "Recommendations on Financing a Metropolitan
Sewer District" (July 1966) in which they favor
the issue of Type II bonds with annual principal and
Interest payments supplied by an ad valorem tax on
all real property throughout the district, whether
presently sewered or not. In a memorandum of
March 15, 1965, the Water Pollution Control Commission
had recommended that such a tax be levied to pay the
capital costs of a MSD. Property will benefit from
the construction of the facilities, hence the proper-
ty tax. Type II bonds are repaid in increasing
annual payments. The millage rate could remain fair-
ly uniform (3.77 mills in 1970; 5.44 mills In
2,000) because property values are expected to in-
crease to help meet the annually increasing cost of
repayment.
Arguments for this method state that: since
the impact of decisions by the district board will
affect the entire area in a uniform manner (e.g.,
determination of the millage rate), the board will
-------
590
Mrs. Wm. Whiting
more likely act for the welfare of the "whole"
at the least cost to the whole; no area will be
charged more than another for service on the basis
of distance from a treatment plantj the collection
method Is simple to calculate and required no
additional collection agency; assuming that presently
sewered areas will receive compensation from the
purchase of their facilities by a MSD, no one area
will feel the financial Impact in excess (e.g.,
Minneapolis has a high realty value, but also stands
to receive the lion's share of the credit which
would result from the acquisition by a MSD of the
existing facilities).
The lack of uniform property valuation pro-
cedures throughout the area may be a flaw in the
tax basis approach. While it may be felt that this
is a flaw in an assessment system that requires
correction, it does detract from a payment plan
based on a property tax.
Under either plan, the capital costs of a MSD
would be "lumped" and the total cost would be divided among
the participating areas on a common basis. If, on the other
hand, each area paid back exactly the cost of service to It,
some areas distant from a treatment plant would be heavily
-------
591
Mrs. Wm. Whiting
charged. (The cost of the longer and larger interceptors
required would be a key factor.) If distance from a treat-
ment plant is eliminated as a factor in fee determination
by lumping capital costs and dividing them on an overall
basis, then some areas (close to treatment plants) might
object that they are paying more than necessary for their
service alone. Proponents of the tax basis contend that a
property tax would eliminate controversy that might arise
along this line when use rates are established. In either
case, is it unreasonable to expect that an area might pay
for more than its service alone when it will benefit from
the proper sewage disposal of an entire district in many
ways (e.g. safety in water intake, scenic beauty)?
Acquisition of Existing Facilities.
The plans studied thus far assume the necessity of
the purchase of existing facilities by the new MSD.
The cost or present value of the existing network
would be figured as follows:
Present worth = Replacement cost - Depreciation .
Depreciation is based on a 40 year life for
treatment plants and an 80 year life for
interceptors.
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592
Mrs. Wm. Whiting
The question arose as to whether or not the cost
of acquisition should include that part of the network
which was originally paid for with Federal grants. WPCC
felt that no Federal grant deduction on present value should
be made; the Popham amended Ashbach Bill is written in
agreement with this. The Citizens League felt that some
portion, not to exceed half, of the Federal grants might be
deducted. The St. Paul Sewer Study Committee would deduct
all Federal grants from the original costs.
Not only the core cities, but their contracting
areas would receive recompense for their part in ownership
of existing facilities. The amount of money due any city
or area might be used as a credit against its part of the
costs of a new MSD and may be an important consideration.
There are some suburbanites who question the neces-
sity of this "buying out" obligation. An urgent need for an
areawide solution might be met in another manner. The new
MSD might "purchase" existing facilities for, say, one dollar,
Outstanding revenue bonds for plant improvements could be
paid by use charges or by property taxes. Cost for inter-
ceptors would continue to be paid by assessment against the
area benefited. Future developers would be required to put
in necessary sewers and include the cost of this in the
price of the buildings. User charges would be uniform.
Industrial charges would be figured individually. Aside
-------
593
Mrs. Wm. Whiting
from saving many thousands of dollars for the total district,
this plan would eliminate disputes over reimbursement
formulas.
As a reference for this argument that existing
facilities should be turned over without charge to a new
sanitary district, Bloomington officials have mentioned
that when school districts are formed, no payment Is made
by them for existing school buildings, etc., of their mem-
ber communities. Another argument is that those persons who
paid for the existing facilities are not the same people who
would be reimbursed for their cost. Convincing the core
cities that no reimbursement should be forthcoming could be
difficult.
Some other mention might be made of specific area
Interests. St. Paul, with heavy industry and a large volume
of sewage flow, might be expected to favor a property tax
basis. Minneapolis, with high realty value and an advanced
program of storm-sanitary sewer separation that decreases
sewage volume, might well reject the tax basis. The
following is taken from material from the St. Paul Sewer
Study Committee Report as an illustration of the specific
Interests of various parties to the current controversy.
-------
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595
Mrs. Wm. Whiting
ADMINISTRATION OP A METROPOLITAN DISTRICT
Wide division on financing has taken the spot-
light in the last three years, obscuring controversy on
the organization of a sanitary district administration.
Solutions to this problem will also have to be found before
passage of a bill can be assured. Proposals In this area
are as diverse as financial plans and compromise will
probably be needed to provide the best form of expert yet
democratic control.
The Water Pollution Control Commission proposed
In 1965 that representation on a district board be based
on population and be adjusted periodically to provide for
fluctuation of population. WPCC calculates that the growth
In population from 1966 to 2000 will be such that the core
cities' share of total district population will shift from
the present 55 percent to 30 percent.
The Citizens League supports basing the membership
of a district Board on population. More specifically, it
has stated that it would be preferable if neither central
cities nor suburban municipalities has an absolute voting
majority on the governing board; that the size of the board
should not be unduly large, preferably not In excess of
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596
Mrs. Wm. Whiting
eleven members; that voters should not elect members of
the Sanitary District Board; that the governing bodies of
the component municipalities should appoint the members of
the board; that the suburban area be divided into separate
appointing districts rather than appointing members at
large; and that members of the board should not be employees
of an elected governmental body.
The '65 amended Ashbach Bill proposes that the
cities of Minneapolis and St. Paul each have three trustees
on an initial eleven man board. Two members would be
appointed from the state at large by the Governor. Each
suburban region (Northwest, North and Southwest) should
have one representative. Representatives would serve four-
year terms. The suburban representatives would be elected
at a convention of municipal representatives from the com-
ponent communities within each region.
According to the Ashbach Bill, the governing board
may Increase over the years to a number not to exceed 15 in
the following manner: whenever the population (based on
Federal census) of a suburban unit Increases by 135*000*
the unit may elect an additional trustee. At the same
time, when the combined suburban population equals or exceeds
the combined core city population, the number of trustees
from the state at large shall drop from 2 to 1. Thus the
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597
Mrs. Wm. Whiting
"final" board would consist of the following representa-
tives: core cities, 6; at large, 1; suburbs, 8. If we
expect, as the wPCC does, that the core cities' population
will be 30 percent of the district in 2000, it is apparent
that their representation (6/15 on the board will be dis-
proportlonately large.)
The following questions should be considered:
1. Should the representatives be elected or appointed?
2. Should there be weighted voting by the repre-
sentatives on the board according to either
population of a region or according to sewage
effluent volume of the region?
3. What Is the largest number of members for an
effective but still representative board?
4. Is representation by one man of an enormous geo-
graphical area made up of up to 15 communities
feasible, especially if the representative is
a layman?
5. Should there be a combination of professional
and laymen on the board, or exclusively either?
6. Are the boundaries of the proposed suburban
regions (shown on map, p.56?) consistent with
watershed drainage areas? If the Sanitary
District were to expand later Into areas of water
-------
Mrs. Wm. Whiting
conservation and zoning for beneficial water
use, prior division according to natural drainage
areas would make such activity more feasible
and simple to administer.
7. How do recent court decisions indicating that a
governmental unit with taxing power must be
controlled by representatives closely reflecting
the population of their constituencies affect
plans for a Sanitary District board?
Pressure on the Legislature to set up a
multi-purpose metropolitan district has been growing.
Sewerage is only one of several services that might be
handled on an area-wide basis. Planning, transit, air
pollution control, and a zoo are among services most fre-
quently mentioned.
Specific proposals for a Metropolitan Area
Services Council have been put forth by the Minneapolis
Chamber of Commerce. That organization has suggested that
metropolitan representatives from seven counties (Anoka,
Carver, Dakota, Hennepin, Ramsey, Scott and Washington)
should be elected from recently reapportioned senatorial
districts. The Council would elect Its own chairman and
executive committee and would be empowered to hire a
director and staff. The Council would be created by the
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599
Mrs. Wm. Whiting
State Legislature, and its authority and responsibilities
determined by the state.
Representative Ashbach has proposed for
the State Legislature an alternative to the senatorial dis-
trict method of representation. He has suggested that a
twenty member board have responsibility for coordinating
and planning metropolitan affairs. One official would be
elected from seven counties, two each from Minneapolis and
St. Paul and one from suburban Ramsey County. The remainder
of the board would consist of one municipal official from
each of the seven counties, and one School Board representa-
tive from the entire area.
Proponents of multi-district legislation are
looking for & single solution to a number of metropolitan
problems. Others feel it is more practical to deal with
each problem on an individual basis and let coordination
com*? later. The special needs of a sewage program would
probably still require formation of a separate sanitary dis-
trict board under a multi-district administration.
GEOGRAPHICAL AREA OP A METROPOLITAN SANITARY DISTRICT
There are four large areas which geographi-
cally would seem to fall in a Metropolitan District plan,
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600
Mrs. Wm. Whiting
but whose Inclusion is, In fact, in doubt at present.
Two of these areas, the North Suburban
Sanitary Sewer Distrlot and the Southwest communities of
Blooraington, Eagan Township and Burnsvllle, are included in
the limits of service as written in the amended 1965 Ashbach
Bill and are currently contracting areas of MSPSD. Both
prefer to decline admission into a district that proposes
to transport and treat all sewage at one treatment plant
(Pigfs Eye). The "Regional versus Single Plant" controversy
has been hotly debated and the Issues closely studied. A
separate section of the paper deals with this controversy.
Two other areas, the Lake Minnetonka region
(west of Deephaven) and the Southeast region including
South St. Paul have been eliminated from consideration
since 1964, although they were originally included in the
Five Year Study for a Metropolitan Sanitary District. As
the single plant concept has dominated the engineering
plans for a district, only the areas feasibly served by
the Pig's Eye plant have been included in these plans.
Both the Lake Minnetonka region and the
Southeast region present serious pollution problems. There
are now six treatment plants sending effluent into Lake
Mlnnetonka, located in Excelsior, Wayzata, Orono, Mound,
Langdon, Maple Plain and Long Lake. As these communities
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6oi
Mrs. Wm. Whiting
continue to grow, it is inconceivable that they can all
continue to discharge effluent into the lake without
harmful effect on its water quality. Algae growth fed
by chemical nutrients remaining in sewage effluent is
already a local nuisance. Unless some more economical
method for removal of objectionable chemicals in sewage
can be developed, the WPCC suggests that communities on
the south side of the lake may have to discharge their
effluent south to the Minnesota River near Chaska (above
Shakopee) and the communities on the west and north may
have to discharge effluent west to the Crow River.
When the first sanitary district legisla-
tion was passed in 1933* South St. Paul was eliminated
from the plan presented to the Legislature because it
created too large a financing problem. It then had a
population of only 10,000 but had sewage equivalent to a.
population of 250,000. It still has slaughtering and meat
packing plants, and to them have been added oil refineries
and chemical plants. It still has combined storm-sanitary
sewers which now bring into its treatment plant each day
raw sewage equivalent to that of a population of 818,000;
approximately 50 percent of the "pollutional load" of the
sewage is removed at the South St. Paul plant.
Recent developments such as the permission
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602
Mrs. Wm. Whiting
given by the Water Pollution Control Commission to
Burnsvllle, within the metropolitan district planning
area, to expand its temporary plant discharging into the
Minnesota River seem to weaken the single plant concept
for presentation in the '67 Legislature. It would seem
that if the district is to control any plants other than
Pig's Eye, then it should also control the plants of the
Southeast and Lake Minnetonka regions. South St. Paul has
suggested its Interest in joining a metropolitan sanitary
district, with the proviso that It be given representation
on the basis of its volume of sewage effluent rather than
on population, or at least be given one representative on
the district board.
This year 37 communities in Minnesota re-
quested 7 million dollars in Federal aid for municipal
treatment plant construction. The Water Pollution Control
Commission states that a maximum of $1.9 million will be
granted to the state, and, since It assigns priority
ratings to the requests, states that the funds will be
divided among a probable 10 municipalities. South St. Paul
has applied for funds but has never received priority status.
The advantage of accumulating as many municipalities as
possible in one request is obvious? not only does the
Federal Government grant a 10 percent bonus for
-------
603
Mrs. Wm. Whiting
construction that It part of a comprehensive metropolitan
plan, but It has recently passed legislation eliminating
percentage ceilings on grants for large cities under such
a plan.
South St. Paul with its large number of
Industries and Lake Mlnnetonka with its great recreational
value for metropolitan dwellers seem particularly valuable
to the state as a whole. Many supporters of a metropolitan
district say the advantage of this approach is that it can
average out the problems of the communities within it,
whether they be Lake Mlnnetonka's great distance from a
reasonable sewage outfall or South St. Paul's high volume
of Industrial effluent. There seems to be no reason why a
metropolitan district could not oversee a network of regional
plants as well as a single one.
No sanitary district proposal has included
the entire 7 county metropolitan area described by the
proponents of a multi-purpose metropolitan district (see
P.567 ). Perhaps consideration should be given to equating
the boundaries of a sanitary district with those of the
area represented on a metropolitan services council.
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604
Mrs. Wm. Whiting
REGIONAL VS. SINGLE SANITARY DISTRICT TREATMENT PLANTS
One of the most controversial questions
involved in a study of the sanitary sewer district prob-
lem is the single plant concept versus that cf regional
treatment plants. The two factors most discussed in a
single versus a regional plan are cost of construction and
maintenance and quality of effluent. There is a dispute of
facts on these two points by the parties involved.
The WPCC and the Citizens League both favor
the single plant plan and conclude it would be cheaper in
the long run. The North Suburban Sanitary Sewer District
favors the regional plan and estimates it would cost less.
The Bloomlngton group (which Is made up of the city of
Bloomington, the village of Burnsvllle and Eagan Township)
also favors the regional approach and feels It would be
cheaper.
According to the Citizens League report, "in
order to provide for projected year 2000 sewerage needs for
the northwestern and southwestern regions, construction
costs totalling $100.3 million will be required under a
system of four upstream treatment plants. The total
construction costs of providing the necessary sewerage
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605
Mrs. Wm. Whiting
works for these two regions under the single downstream
plant system would be $116.9 million. Thus the excess
construction costs under a single downstream plant system
would total $16.6 million." (Citizens League Report, p. 6,
Item A)
All of the parties concerned seem to agree
that Initial construction costs under the regional plan
would be cheaper. Where the cost of operation and
maintenance is considered a conflict appears between the
NSSSD, the Bloomington group and the figures given in the
Citizens League report.
The Citizens League Indicates that "cumula-
tive operation and maintenance costs to the year 2000 under
the upstream plant system will total $49.3 million. Com-
parable operation and maintenance costs to the year 2000 und-
er the single downstream plant would total $31.6 million.
The net saving under the single downstream plant system
would amount to $17.7 million. Therefore the excess
construction costs of $16.6 million under the single
downstream plant system are more than fully offset by the
$17.7 million savings in operation and maintenance costs
to the year 2000. After the year 2000, these savings in
costs of operation and maintenance under the single
downstream plant system would widen the cost differential
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606
Mrs. Wra. Whiting
In favor of the single downstream plant system." (Citizens
League Report, pp. 6 and 7, Items B and D)
The NSSSD agreed "there is a difference
in cost of operation and maintenance, but it is nowhere
near the magnitude claimed. . ." (NSSSD Brief, p. 49)
The NSSSD contends that "the primary difference in the
oost of operation and maintenance is the result of
providing only 75$ treatment by means of a high rate
activated sludge plant, (Pig's Eye), as opposed to the
90-95$ treatment in the conventional activated sludge
plant proposed by the NSSSD." (NSSSD Brief, p. 46) In
direct opposition to this statement, the Citizens League
states that "we have revised upward the costs of a down-
stream plant system to reflect 90$ treatment at the Pig's
Eye plant to be attained by 1980" and have therefore based
cost comparisons on equal quality factors. (Citizens
League Report, p. 7)
The Bloomington group also states that they
plan "a much higher degree of treatment (95$) than that
proposed by the Mlnneapolis-St. Paul Sanitary District
Plant at Pig's Eye (75$)." (Comments by Bloomington Director
of Public Works, Lower Minnesota River Sewerage Plan
Summary, Nov. 22, 1965, P. 2) The Bloomington group con-
tends that the time schedule does not correspond with
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607
Mrs. Wm. Whiting
the sewerage needs of the region involved and that the
southwestern regions share of cost based on capacity
would be more, under the single plan, than if they had
their own plant.
Concerning water pollution control, both
the proposed NSSSD plant and the plans for a plant from
the Bloomington group have given evidence that their
effluent will be "as clean and pure" (NSSSD Brief, p. 53)
as the standards adopted by the WPCC require. Both groups
also pointed out that with the high degree of treatment
given at their proposed plants, the effluent put into the
river would be of better quality than the river water as
It now exists.
The only WPCC standard that these two groups
could not meet is the prohibition of any discharge of
effluent (treated or untreated) into the Mississippi or
the Minnesota Rivers In regions where they proposed plants.
The Citizens League report indicated that they felt the
quality standards could be maintained most of the time by
regional plants. They were concerned, however, over
meeting the standards during periods of low flow. They also
expressed concern over the risk to Minneapolis drinking
water if the NSSSD plant were built one mile above the
Minneapolis water Intake plant as proposed.
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608
Mrs. Wm. Whiting
The NSSSD Is presently waiting for a
decision from the Anoka County Court of Appeals on the
validity of the WPCC prohibition standard. The NSSSD
has not been oonsldering membership in a metropolitan
system and probably will not, until a decision is made
by the court. It is likely that if the Court of Appeals
rules against it, the NSSSD will take its case to the
Minnesota Supreme Court.
The Bloomington group has Included in its
study the possibility of membership in a metropolitan
system. The League of Women Voters of Bloomington has
posed an interesting question on this points "Does a
metropolitan solution have to include a monolithic single
plant concept? Does construction of a regional treatment
plant destroy the concept of a metropolitan district?"
ADDENDUM ON STATE AIDS
Although not directly relevant to the
subject of a metropolitan sanitary district, the possibility
that state loans or grants may aid the financing of new
plants, interceptors, etc. in a metropolitan district
should be considered.
The U. S. Advisory Commission on
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609
Mrs. Wm. Whiting
Intergovernmental Relations recommends that states enact
legislation to provide grants for capital development
to supplement Federal aid and to provide incentives in
the form of low cost loans, bonuses or matching grants
for regional treatment plant construction. Direct state
grants are given for planning in four states, for construc-
tion in eleven states and for construction loan funds in
nine states.
In Its proposals for the 1967 Legislature,
the Water Pollution Control Commission has advised that
the state consider a program of matching construction
grants to supplement or extend Federal grants. It has also
suggested that the state consider establishing a revolving
loan fund to be used for financing at a low interest rate
engineering reports, construction plan and specifications.
BIBLIOGRAPHY
Advisory Commission on Intergovernmental Relations
"Alternative Approaches to Governmental Reorganization
in Metropolitan Areas," Commission Report, A-ll (June 1962)
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610
Mrs. Win. Whiting
"Intergovernmental Responsibilities for Water Supply
and Sewage Disposal in Metropolitan Areas," (1962)
Bloomlngton Council Meeting, Unapproved Minutes of
adjourned meeting Council Chambers, (Nov.,22, 1965)
Chamber of Commerce of Minneapolis
"Recommendations for the Formation of a Multi-Purpose
Metropolitan District," (Sept. 1966)
Citizens League
"Twin Cities Metropolitan Area Sewerage Needs," Report
and Recommendations (April 29, 1965)
Kirk, J. Thomas, Practical Plan for Pollution Prevention,
Henepin County Water Forum on "Pollution Solution,"
sponsored by CLIC and the Minneapolis Chamber of
Commerce, (June 1966)
League of Women Voters of Minneapolis, "On the Minneapolis
Waterfront," Section Three (Got. 1965)
Minneapolls-St. Paul Sanitary District, "Comprehensive
Sewage Works Plan," Summary Report (1964)
Minnesota Water Pollution Control Commission,
"Classification and Standards,"
Chapters One through Three, For the Mississippi
River and Tributaries from the Rum River to Look
and Dam #2 near lias tings (March 28, 1963)
-------
Mrs. Wm. Whiting 611
Chapters Five and Six, For the Minnesota River
and Tributary Waters from Carver Rapids to the
Junction with the Mississippi, (Nov..2, 1965)
Statement on Legal and Administrative Problems in Water
Pollution Control Which May be the Subject of State
Legislation. Prepared for Joint Meeting of Sub-Comm.
on State Depts., Senate Civil Administration Comm., and
the Sub-Comm. on Water Resources, Senate Public Domain
Committee (June 17, 1966)
"Comprehensive Sewage Works Plan for the Minneapolls-
St. Paul Metropolitan Area," Report, (December 1964)
Memorandum to Committee on Metropolitan and Urban
Affairs, State House of Representatives. Comparison
of provisions of Ashbach Bill with Recommendations of
WPCC on Metropolitan Sewage Disposal, (March 15, 1965)
Quarterly Report, (April 1 - June 30, 1966)
National Association of Counties Research Foundation,
"Water Pollution Control," Community Action Guide for
Public Officials, Reports #1 - 1CT, (1965)
North Suburban Sanitary Sewer District vs. the Water
Pollution Control Commission of Minnesota, Trial
Memorandum and Reply Memorandum, (1965)
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612
Mrs. Wm. Whiting
Public Health Service, Division of Water Supply and
Pollution Control, Region V, U. S. Department of
Health, Education and Welfare, "Report on Pollution
of the Waters of the Upper Mississippi River and
its Significant Tributaries, Mlnneapolis-St. Paul
Metropolitan Area," by J. M. Rademacher, Senior
Sanitary Engineer, (February 1964)
Rlgert, Joe, "St. Paul Proposes Sewer System Plan for
Six-County District," Minneapolis Tribune, (July 31*
1966)
St. Paul Sewer Study Committee, "Recommendations on Financing
a Metropolitan Sewer District," (July 1966)
Thimsen, Donald J., Enhancement of Water Quality Through
Sewage Treatment, Hennepln County Water Forum on
"Pollution Solution," sponsored by CLIC and the
Minneapolis Chamber of Commerce (June 1966)
Tolz, King, Duvall, Anderson and Associates, Inc., "Expan-
sion of Sewage Works In the Minneapolis-St. Paul
.Metropolitan Area," Report sponsored by MSPSD,
(Sept. I960)
Twin Cities Metropolitan Planning Commission, 1966 Population
Estimates, Information Bulletin #3, (July 19, 1966)
-------
63 Mrs. Wm. Whiting 6l3
Wolfe, Kenneth, The Community Decision, Hennepin County
Water Forum on "Pollution Solution," sponsored
by CLIC and the Minneapolis Chamber of Commerce,
(June 1966)
Minnesota House of Representatives Pile #59^, 1965, as
amended, A Bill for an Act Relating to Water Pollu-
tion and to the Prevention, Control, and Abatement
thereof by Treatment and Disposal of Sewage and
Wastes in the Metropolitan Area, (1965 Ashbach Bill)
U. S. Department of Health, Education and Welfare, The
Water Quality Act of 1965, PL 89-234.
The bibliography for the 1965 publication
of the Minneapolis League of Women Voters, "On the
Minneapolis Waterfront," is a general listing of
publications concerning Twin Cities water resources prob-
lems. This bibliography lists only those publications
specific to recent MSD proposals.
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614
Mrs. Wm. Whiting
MR. STEIN: Are there any questions or comments?
MR. POSTON: I would like to say that at every
one of these conferences that I have attended or participated
in, the League of Women Voters has come through with a pro-
found statement, and has shown by the statement the extent
to which they have studied the problem.
Recently the League of Women Voters came out with
a new book.
MRS. WHITING: That's right.
MR. POSTON: And they are to be commended for
the influence that they are exerting on this overall program.
MRS. WHITING: Thank you. We appreciate the
opportunity for citizens to be heard like this.
MR. STEIN: I know this may be some shock to the
engineers, but I don't think we can say, as you do indicate,
they are all to blame for this.
You know, if you look at the nine people up here,
only four of the nine, I think, are engineers, and the rest of
us have to bear the blame for any inaction. This is not one
professional group.
MRS. WHITING: Thank you.
MR. STEIN: Thank you.
Mr. Smith?
MR. SMITH: The next statement will be by Clear
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J. Pegors 615
Air, Clear Water - Unlimited.
STATEMENT OF JOHN PEGORS, VICE PRESIDENT,
CLEAR AIR, CLEAR WATER - UNLIMITED
MR. PEGORS: Chairman Stein and Conferees:
Clear Air, Clear Water - Unlimited is a group of
citizens living on the rivers under study at this time.
My name is John Pegors. I am Vice President of
the organization. Our statement is as follows:
Clear Air, Clear Water - Unlimited appreciates
the opportunity to submit a statement of praise for the
Upper Mississippi River Project Study and to make further
recommendations for limiting pollution on the upper Mississippi
and major tributaries. It is the feeling of our organization
that the remedial recommendations are not as severe as
idealists might suggest. But we accept the general spirit
of the recommendations in the Interest of need for immediate
progress.
Clear Air, Clear Water - Unlimited has a member-
ship of more than 500 citizens living along or near the upper
Mississippi and the Minneapolis and St. Crolx Rivers. The
organization has been concerned since its formation eleven
years ago that the pollution problems prevailing in the
Minnesota and Mississippi Rivers were being compounded wit
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616
J. Pegors
proper checks to safeguard the health and rights of the
public. We also have been and continue to be concerned about
the potential for pollution posed by construction of major
electric generating plants, both planned and in progress,
along the three rivers. Therefore, we believe the effective-
ness of the Upper Mississippi River Project could be enhanced
with the addition of the following recommendations:
1. Temperatures of effluents discharged into
streams be kept at 83 degrees Fahrenheit or lower. The pur-
pose of this recommendation is to avoid the potential for
disruption of aquatic life.
2. All waters be monitored for the effects of
pesticides as a protection against improper use and potential
harm to human health.
3. Both atmosphere and waters be monitored for
radiation levels, along with a total prohibition on the dis-
posal of radioactive wastes in the upper Mississippi and its
tributaries. This recommendation is directed at all users
of radioactive material since there are no known safe levels
of radioactive pollution, and since such pollution Is known
to have carcinogenic and genetic effects.
4. The two following sections of rivers be up-
graded to the extent that they are suitable habitat for
Group I flan:
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617
J. Pegors
A. Mississippi River from the Mlnneapolis-
St. Paul Sanitary District main treatment plant to
Lock and Bam No. 2.
B. Minnesota River from Chaska to the
confluence of the Mississippi River.
These recommendations are made in view of the
great recreational potential and important health considera-
tions involving these rivers which flow at the very doorstep
of a metropolitan population center.
Clear Air, Clear Water - Unlimited is a great
deal less than satisfied with the prospect that the remedial
program timetable stretches over three years. Our organiza-
tion believes that the public interest has already been set
aside too long. But in the interest of immediate progress,
we will accept the recommended timetable, which we feel to be
more than ample for the necessary construction.
In their deliberations following the conference,
the conferees are requested to accept the recommendations of
the Upper Mississippi River Project with the modifications
and additions noted above.
Respectfully Submitted
Board of Directors
Clear Air, Clear Water - Unlimited
Rural Route 1
South St. Paul, Minnesota
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618
J. Pegors
Thank you, Mr. Chairman, for the opportunity.
MR. STEIN: Thank you.
Are there any comments or questions?
(No response.)
MR. STEIN: Mr. Smith?
MR. SMITH: The next statement is from the
Minnesota Conservation Federation.
Is there someone here to read that?
(No response.)
MR. SMITH: Mr. Thimsen?
STATEMENT OP MINNESOTA CONSERVATION
FEDERATION, AS READ BY DONALD J. THIMSEN,
MINNESOTA DEPARTMENT OF HEALTH
MR. THIMSEN: Statement by Minnesota Conservation
Federation Pollution Committee.
For the Conference in the Matter of Pollution of
the Interstate and Intrastate Waters of the Upper Mississippi
River and its Tributaries (Minnesota-Wisconsin), February 28,
1967 - 9:30 a.m., Leamington Hotel, Minneapolis.
The Minnesota Conservation Federation appreciates
the opportunity to study the summary of the Federal recom-
mendations for pollution abatement for the upper Mississippi
River and its tributaries. As our organization has been
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619
Minn. Conservation Federation, D. J. Thlmsen
extremely Interested in pollution problems for many years,
at our annual Assembly in September 1966, the following
resolution was passed unanimously by delegates from each
of our affiliated organizations.
WHEREAS, pure air and pure water are vital to
health, recreation and survival of the American
way of life and are currently of national concern
and,
WHEREAS, we are informed that the present laws
are adequate if properly enforced to correct any
pollution problems pertaining to water in our
State and,
WHEREAS, we have been informed that approximately
400 communities have no disposal treatment plants
and many other existing plants are not operating
efficiently and that a number are operating only
eight hours per day and,
WHEREAS, we are informed that the Pollution Com-
mission has not been granted a sufficient budget
in order to engage the services of sufficient
qualified personnel to properly supervise the
installation of disposal plants and to properly
check the operation of these plants periodically,
WHEREAS, the Minnesota Conservation Federation has
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620
Minn. Conservation Federation, D. J. Thlmsen
for a number of years supported strong pollution
laws and as a result of this support should assume
the responsibility of bringing to the public at-
tention pollution problems which exist throughout
the State and should assist In any way possible
by reporting these pollution problems,
NOW THEREFORE BE IT RESOLVED that the Minnesota
State Legislature be requested to appropriate
sufficient funds for the use of the Pollution
Commission in order that It can engage the services
of the necessary qualified personnel to meet the
requirements of the present Minnesota State laws
and Federal laws.
NOW THEREFORE BE IT RESOLVED that the Minnesota
Conservation Federation establish a pollution
committee within the Minnesota Conservation
Federation membership, said committee to be ap-
pointed by the president, and be It further re-
solved that each member organization appoint a
pollution committee to work in conjunction with
the State committee by surveying their surrounding
area to determine existing and potential pollution
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621
Minn. Conservation Federation, D. J. Thimsen
problems and to report their findings in detail
to the State committee. The State committee
will review the facts and in turn, if they deem
it advisable, will report the results to the
Pollution Commission.
RESOLUTION FROM THE NATIONAL WILDLIFE FEDERATION
Unanimously passed by delegates from 49 States
in annual meeting, March 1966. The National Wildlife
Federation continues to emphasize its belief that contamina-
tion of the air, water, and land resources, both from unwise
disposal of wastes and from the deliberate application of
chemicals, is the most pressing problem of the time. In
view of demands from the expanding human population, it
Is urgent that massive attacks must be launched by Federal,
State, and local governmental agencies to control water
and air pollution and set standards of quality which will
allow public waters to be used for all beneficial purposes,
including fish and wildlife and recreational pursuits
rather than reserving them for waste assimilation. In-
dustries must be encouraged to regard pollution control as
a normal cost of production and pricing. Accelerated and
expanded research must be pursued toward the goal of
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622
Minn. Conservation Federation, D. J. Thimsen
developing methods of pest control less harmful than the
persistent chemical poisons which present hazards to large
numbers of beneficial creatures.
In our opinion, after studying this comprehensive
report, it makes one ask, "How could this pollution mon-
strosity occur, here in Minnesota in this day and age, of
24-hour a day news coverage, besides all of the well-meaning
organizations so vitally interested in all types of pollu-
tion?"
It sorely points up the following facts:
1. Lack of budget for the Pollution Commission.
2. Lack of press relations.
3. Failure of, responsibility of, on the part of
our elected and appointed officials to get this
Information to the public — as guaranteed by our
Federal Constitution amendments — freedom of the
press.
4. The glaring fact that the Minneapolls-St.
Paul Sanitary District and South St. Paul are
the prime culprits of pollution. Approximately
98 percent of the entire area.
5. Immediate steps could be taken by the
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623
Minn. Conservation Federation, D. J, Thimsen
authorities to correct this problem by advancing
the states of sewage treatment.
We urge the conferees to give serious considera-
tion to the upgrading immediately of the entire Mississippi
River Basin from Federal recommendations Pages 26 through 28.
Under Item B, Page 28, we recommend maintenance
of habitat for Group I fish for the entire Basin.
Under Item C, we recommend whole body contact
for the entire Basin.
Under Item 10, Page 30, we recommend storm and
sanitary sewers to be completed within 24 months. Studies
to continue for means of continual upgrading of all
standards.
Prepared by the Pollution Committee
(Signed) R. C. Johnson
H, C. Johnson, Chairman.
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624
Minn. Conservation Federation, D. J. Thimsen
Mr. Chairman, I would like to make one comment
on one of the "whereases."
"Whereas, we have been informed that approxi-
mately 400 communities have no disposal treatment
plants and many other existing plants are not
operating efficiently, and that a number are operat-
ing only eight hours per day,"
there is reference made here to 400 communities, and I am
sure we do not have 400 communities without treatment.
MR. STEIN: They are not here to answer this, are
they?
MR. THIMSENJ I beg your pardon?
MR. STEIN: They are not here to answer this?
MR. THIMSEN: No.
MR. STEIN: Are there any further comments or
questions?
MR. SMITH: I have the same comment M£. Thimsen
had. I am certain we don't have 400 communities without
treatment.
MR. STEIN: I have a question as to the constitu-
tional interpretation, but I won't raise that here.
MR. POSTON: You are talking about freedom of
speech?
MR. STEIN: Speech shall be guaranteed, but that
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Beaverbrook Sportsmen, Inc., by D. J. Thirasen 625
is of no point here,
Mr. Smith?
MR. SMITH: . The next group I have is the Izaak
Walton League.
Is Mr. Sullivan here?
(No response.)
MR. SMITH: The next statement is from the
Beaverbrook Sportsmen, Inc.
STATEMENT OP BEAVERBROOK SPORTSMEN, INC.,
AS READ BY DONALD J. THIMSEN, MINNESOTA
DEPARTMENT OP HEALTH
MR. THIMSEN: This statement is in the form of
a letter dated February 21, 1967, from James Pettman, Chair-
man of the Pollution Committee, Beaverbrook Sportsmen, Inc.
It is addressed to Mr. Lyle H. Smith.
Dear Sir:
I received an invitation from Robert N. Barr,
M.D., to attend the Peb. 28th conference at the Leamington
Hotel. I cannot attend and give a full report on our commit-
tee activities, as we are still in the process of self-
education and fact-finding in our area. We do not have police
powers to enter and check hidden sources of pollution, but we
are endowed with our natural senses — sight-hearing-touch-
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626
Beaverbrook Sportsmen, Inc., by D. J. Thimsen
smell-speech-plus self-preservation and curiosity.
Under curiosity, we would like answers to the
following questions:
1. When the Mississippi flooded the Pig's Eye
dump, how pure was the water that reentered the river?
2. The supply of snapping turtles in Shingle
Creek (here in Brooklyn Center & North Mpls.) is quite ade-
quate, but where are the minnows and crayfish going?
3. When creosote enters a water table, does it
stop at city or village limits?
4. When industrial solvents are dumped into the
earth, do they eventually enter the nearest river by way of
convenient storm sewers?
5. When coke and asphalt plants eject their
goodies, is it possible that rain and fog will wash them into
the river (minus what we absorb)?
6. Hard detergents are wonderful for washing the
first time. Does the next user appreciate having them come
through his water tap?
7. Why are potent poisons sold to be used by
amateur bug slayers? A pound is good, so a ton must be
wonderful.
8. Do all doctors have the time, skill and
laboratory facilities to diagnose incipient poisoning from
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627
Beaverbrook Sportsmen, Inc., by D. J. Thimsen
our wonderful pesticides, Insecticides, etc.?
9. Is it true that vegetarians have half as
much residual poisons in their systems? Watch the carrots,
boys] They are reputed to be the most efficient collector of
poisons among the vegetables.
10. Are we to establish a wonderful new world of
plenty and be only half alive to enjoy it?
11. Will a cure for cancer catch up with all the
carcinogens?
12. Does the fact that areas are competing for
industry affect the enforcement of restrictions on these same
industries?
13. When a fertilizer plant emits its wastes,
do the plants, shrubs and trees in the vicinity take a new
lease on life?
14. Our municipal and village laws on pollution
are quite imposing. Do we need money and well equipped,
trained personnel to enforce them?
15. Is it possible that individuals and corpora-
tions could possibly stall with the threat of a $100 fine
over their heads?
16. Who will bell the cat? The village, the
county, the State or the Federal Government? Could they
possibly unite?
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628
Beaverbrook Sportsmen, Inc., by D. J. Thimsen
In closing, let us Join together and send our
best to friends and neighbors downstream.
Sincerely,
/s/ James Pettman
Chairman Pollution Committee
Beaverbrook Sportsmen, Inc.
P. S. An aroused public can best make its wishes shown at
the polls.
(Laughter and applause.)
MR. STEIN: Thank you for reading this.
You know, I am going to take this home. Where he
talks about our natural senses and listed them and listed the
sense of speech as one, I've got to show that to my wife
(Laughter).
Thank you.
Are there any comments or questions?
DR. JELATIS: Mr. Chairman, as one of the down-
stream recipients of the pests, I say I appreciate this, as
all of the concern of the Natural History Society and the
League of Women Voters, Clear Air, Clear Water, and the other
people who are concerned enough to speak here.
I hope that they speak equally vocally before the
Legislature and support some activities, and support addi-
tional funds that the people would have to enforce the
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629
T. C. Savage
regulatione.
MB. STEIN: Thank you.
Mr. Smith?
MR. SMITH: The next statement Is from the Port
Snelling State Park Association, Mr. Savage.
STATEMENT OP THOMAS C. SAVAGE, VICE
PRESIDENT, PORT SNELLING STATE PARK
ASSOCIATION
MR. SAVAGE: I am Thomas Savage, the Vice President
of the Port Snelling State Park Association, a citizens'
group.
At the Federal Conference in the matter of the
Pollution of the Upper Mississippi River and Tributaries in
Minneapolis on February 28 and 29, 1967.
Port Snelling State Park, as established by the
1961 session of the Minnesota Legislature, comprises 2,450
acres of land on both sides of the Minnesota River, extending
some four miles upriver from its mouth and including land on
the south side of the Mississippi River upriver from the
junction of the two watercourses. The total amount of
frontage on the Minnesota River -- including both sides —
including Pike Island — and including both the present
channel and the new channel currently being established by
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630
T. C. Savage
the U. S. Corps of Engineers -- is 14-3/4 miles; the frontage
on the Mississippi River is just over 2 miles. When the land
acquisition and the development of this park is completed, it
will be one of the major recreational areas of the Twin
Cities. Included among the recreational activities of the
park will be such sports as pleasure boating and canoeing,
fishing, the observation of waterfowl and wildlife, and the
esthetic enjoyment of the rivers by hikers, picnickers and
others.
Another much larger State park -- Carver State
Park — is being proposed at the current session of the
Legislature — to consist of some 18,000 acres located on
the Minnesota River both above and below the town of Jordan.
To enable Port Snelling State Park and Carver State Park, if
and when established, to offer the greatest number of water-
related activities to both our residents and to the many out-
of State tourists who are certain to use their facilities, it
is essential that the water quality of the lower stretch of
the Minnesota River and the metropolitan section of the
Mississippi be improved substantially. The directors of the
Port Snelling State Park Association sincerely hope that the
conferees give serious consideration to the anticipated
heavy recreational use of these sections of the rivers when
their final recommendations are adopted.
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631
First Unitarian Soc. of Minneapolis, G. Dinner
Thank you.
MR. STEIN: Thank you.
Are there any comments or questions?
(No response.)
MR. STEIN: If not, thank you very much.
Mr. Smith?
MR. SMITH: The next is the statement by the
Pollution Control Unit of the Social Concern Committee, First
Unitarian Society of Minneapolis.
STATEMENT OF POLLUTION CONTROL UNIT OF
THE SOCIAL CONCERN COMMITTEE, FIRST
UNITARIAN SOCIETY OF MINNEAPOLIS, AS
READ BY GARY GINNER, MINNESOTA DEPART-
MENT OF HEALTH
MR. GINNER: Statement by Pollution-Control Unit
of the Social Concern Committee, First Unitarian Society of
Minneapolis.
Our purpose here is to urge taking the strongest
possible measures to clean up the 270 miles of rivers covered
by the study presented today.
We all contribute to pollution, although nobody
favors it. We don't really want to be a dirty society, but
simply can't stop the outpouring of waste that fouls our
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632
First Unitarian Soc. of Minneapolis, G. Glnner
world. So we welcome today's conference as a step toward
deciding on a course that will restore and guard our nearby
rivers system. Let us be sure we do enough for that purpose.
The cost will be high -- in money, self-discipline,
and strenuous persuasion.
Municipalities are big offenders, and they do not
spend money lightly. Some businesses have been appallingly
irresponsible in their use of our rivers to dump massive
amounts of damaging waste; and they still persist and will
persist until we can force them to halt.
Each of us, in one way or another, as taxpayer
or stockholder, has a small immediate selfish interest in non-
action in this effort at reversal. Each of us has a tremendous
enlightened self-interest in doing as much as is needed to
make these rivers clean and beautiful again.
Keith Emery, Chairman
Pollution Control Subcommittee
First Unitarian Society of Minneapolis,
Minnesota.
MR. STEIN: Thank you.
Are there any comments or questions?
(No response. )
MR. STEIN: If not, Mr. Smith?
MR. SMITH: The next statement is from the
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633
Community Wild Life Club, St. Cloud, G. Ginner
Community Wild Life Club, Inc., of St. Cloud.
STATEMENT OP THE COMMUNITY WILD LIFE
CLUB, INC., ST. CLOUD, MINNESOTA, AS
READ BY GARY GINNER, MINNESOTA DEPART-
MENT OF HEALTH
MR. GINNER: This is dated February 25, 1967,
and reads:
Statement for Federal hearing, February 28, 1967,
by Community Wild Life Club, Inc., St. Cloud, Minnesota (700
members).
1. We have had inquiries from Twin City groups
concerning the potential use of the Mississippi River from
above Anoka to Brainerd as a recreational area. We, in St.
Cloud, realize the increasing population pressures and uses
that will be placed on water-based activities. We ask that
the Minnesota River from Mankato to its mouth be used for
whole body contact recreational use.
2, The Masonic Home on the old Shakopee Road
is mentioned in your report as polluting the Minnesota River.
This home has a resident population of 200 people, Bto where
in this report do we find mention of pollution from private
homes along the rivers both in and out of municipalities.
Forty homes, with an average of three to five members per
-------
Community Wild Life Club, St. Cloud, G. Dinner
family, could produce an effluent equal to the Masonic Home.
Our survey of the Mississippi River area from Anoka to
Brainerd shows several hundred homes, many of which are dis-
charging untreated sewage into the water. (We have compiled
logs on three such areas. )
In view of your General Recommendations #1, Page
27, and #3, Page 30, we believe an additional recommendation
is needed to cover this source of pollution.
/a/ Don Andrews
Gerald Henningsgaard
Co-chairmen, Water Pollution Committe
St. Cloud Community Wildlife Club
St. Cloud, Minnesota
MR. STEIN: Thank you.
Are there any comments or questions?
(No response. )
MR. STEIN: If not, thank you very much.
Mr. Smith?
MR. SMITH: The next statement is from the Sierra
Club, Great Lakes Chapter, North Star Section, Minnesota.
STATEMENT OP THE SIERRA CLUB, GREAT LAKES
CHAPTER,NORTH STAR (MINNESOTA) SECTION, AS
READ BY DONALD J. THIMSEN, MINNESOTA DEPART-
MENT OP HEALTH
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635
Sierra Club, by D. J. Thimsen
MR. THIMSEN: This is a letter dated February
27, 1967, addressed to Mr. Murray Stein, Federal Water Pollu-
tion Control Commission, Department of the Interior, Washington,
D. C.
Dear Sir:
We of the North Star Section of the Sierra Club
wish that the following statement be entered into the record
of the hearing conference in the matter of pollution of the
interstate and intrastate waters of the upper Mississippi
River and its tributaries (Minnesota and Wisconsin):
Through the 19th Century, Americans found abundant
clean air and water. Regardless of conditions they may have
earlier been accustomed to in Europe, they undoubtedly came
to expect as a right the abundance of all natural resources
of the United States. In this overwhelming abundance, the
thought of conservation occurred to no one but a very few
visionaries. Likewise, with our many and ample rivers, dis-
posal of wastes seemed no problem. Each man dumped his little
bit into the river and saw it vanish.
With increased population, this condition of
abundance disappeared. Today, an objective look can only show
we do not have unlimited natural resources. We do not have
unlimited clean airj polluted air is killing human beings
now. We do not have unlimited clean water; cities over the
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636
Sierra Club, by D. J. Thimsen
entire Nation are forced to great pains and expense to find
water that is not laden with others' sewage and refuse.
However, men's attitudes have not changed. The
ingrained habits of the past are still with us, and Americans
are still conditioned to the concept of bountifulness. With
our population still increasing, it is obvious to all that
these habits must change eventually. We of the Sierra Club
believe that the time for change is now. We further believe
that an overwhelming majority of the citizens would, on
reflection, agree with us.
The oil dumpings in the Minnesota River that
precipitated these hearings were dramatic examples of grossly
inexcusable accidents. However, no less damaging, and far
more insidious, is the day-by-day influx of pollutants from
practically all municipalities and industries. It is this
pollution that must be ended. Europeans are now beginning to
recognize this, as witness the organization in the Ruhr Basin
of Germany. Although the political methods used along the
Ruhr would be unacceptable in this country, they do illus-
trate that rivers in industrial regions can be kept clean,
at costs that are not excessive.
The recommendations of the upper Mississippi
study represent another solution. Implementation of these
recommendations will help to turn the tide of increasing
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637
Sierra Club, by D. J. Thimsen
pollution in this region. It will, at reasonable cost to
all concerned, serve as a start on the road to the clean
rivers that we believe we citizens of the United States still
have a right to expect. Therefore, the Sierra Club strongly
encourages acceptance of these recommendations.
Sincerely,
Carl W. Ehrman, Conservation Chairman
400 Maple Avenue, N.E.
Minneapolis, Minnesota 55*132
Executive Committee, North Star Section:
Mrs. Ann Hooke, Chairman
Mrs. Marilyn Anderson
Mr. Gerald R. Ault
Mr. Donald R. Caster
Mr. Walter N. Clauson
Mr. Carl W. Ehrman
Mr. Chauncey Greene
Mr. Robert D. O'Hara
MR. STEIN: Thank you.
Are there any comments or questions?
(No response.)
MR. STEIN: Thank you very much.
Mr. Smith?
MR. SMITH: I have one more statement from the
Northwest Airlines Sportsmen Association.
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638
N.W. Airlines Sportsmen Assoc., D. J. Thimsen
STATEMENT OP THE NORTHWEST AIRLINES
SPORTSMEN ASSOCIATION, AS READ BY
DONALD J. THIMSEN, MINNESOTA DEPART-
MENT OP HEALTH
MR. THIMSEN: This is a statement submitted by
Willard Zell, Conservation Officer, Northwest Airlines Sports-
men Association, and also co-signed by Gene Hedegaard,
Secretary, 10318 York Lane, Minneapolis, Minnesota.
Gentlemen:
We are grateful for the opportunity to have been
able to review the summary of this Twin Cities Upper
Mississippi River Project Study and being able to attend this
conference.
As conservation officer for the Northwest Airlines
Sportsmen's Association, I have been requested by our members
to make the following statement for them.
Our present membership totals 96 members, of
which a majority are airline employees in various capacities
with the airlines. The purpose of our group is defined in
our by-laws, which read, "The purpose of this non-profit
organization shall be to encourage citizens of our community
to actively participate in the organization of all field
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639
N.W. Airlines Sportsmen Assoc., D. J. Thimsen
sports in their community and to strive for a united effort
to further by educational and implementive programs, the con-
servation of our natural and recreational resources."
We are affiliated with the Minnesota Conservation
Federation and the National Wildlife Federation. As affili-
ates of these organizations, we actively participate in the
formation of its policies by submitting and voting on resolu-
tions which guide their activities.
We do not appear before this conference with any
graphs, charts, maps or bundles of data, nor do we make any
claims of great engineering, scientific or biological
knowledge.
We are here before you as a citizens group with
a sincere interest in one of our most precious resources --
water.
It has been in the past and it will be in the
future the policy of this group to work for and support any
movement which will assure us that this resource will be
maintained to the highest degree.
Why, for instance, should we accept a recommenda-
tion which according to this study report would provide main-
tenance of habitat for game fish only in specific segments
of these rivers, such as the Minnesota River from Mankato to
Chaska. What about from Chaska to the mouth of the Minnesota
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640
N. W. Airlines Sportsmen Assoc., D. J. Thimsen
at the Fort Snelling State Park? Why not adequate habitat
for game fish in all segments? We wonder how fish would be
able to, in migration, be able to distinguish a demarcation
line.
Why not whole body contact recreational activi-
ties for all segments? Certainly this is possible, and what
esthetic enjoyment would there be to view a river and to know
that below the surface runs water in which only decay and
filth can survive?
Gentlemen, we therefore respectfully request
that the water quality standards for the entire study area
be such that they will support the portions of the water uses
as defined in Items B through M on Page 28 of the Study
Summary.
If this requires our municipalities and Institu-
tions to have secondary treatment plus sewage disposal plants,
or our industry to have adequate waste treatment facilities,
or power plants to have proper cooling equipment, or any other
requirement that may be necessary, let's work toward that goal
before these pollution problems turn into chaos.
In conclusion, we would like to say we believe
these things can be achieved and are sure that all citizens
would support them, if only they would be so informed of the
facts.
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A. A. Ebert
MR. STEIN: Thank you.
Are there any comments or questions?
(No response. )
MR. STEIN: If not, Mr. Smith?
MR. SMITH: I have a statement by the Minnesota
Chapter of the American Society of Sanitary Engineering.
STATEMENT OP ARTHUR A. EBERT, PRESIDENT,
MINNESOTA CHAPTER, AMERICAN SOCIETY OP
SANITARY ENGINEERING
MR. EBERT: Mr. Stein and Conferees:
I am the President of the Minnesota Chapter of
the American Society of Sanitary Engineering.
The Minnesota Chapter, American Society of
Sanitary Engineering, appreciates the opportunity to analyze
the Summary and Pollution Abatement Recommendations for the
Upper Mississippi River and major tributaries. We are also
appreciative of the invitation to submit a statement concern-
ing the recommendations.
In our judgment, the study of the 270 miles of
the upper Mississippi River and major tributaries is a highly
satisfactory completion of the duties assigned the study
group and reflects credit upon its Director, Dr. Albert
Printz, Jr., and his colleagues. The study was conducted
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642
A. A. Ebert
with a high degree of objectivity and desire to reflect a
true picture of the conditions in the 270 miles of river in-
cluded in the study project.
As interested, concerned residents of the areas
involved in the Upper Mississippi River Project Study, the
Minnesota Chapter, American Society of Sanitary Engineering,
believes the effectiveness of the study project could be
increased markedly with no added hardship to persons, firms,
and communities. We therefore urge adoption of the following
additions to the recommendations:
A, Due to the high rates of fertilization in the
rivers included in the project study, we respectfully request
the conferees to give serious consideration to inclusion of
high-rate phosphate and nitrate removal treatment requirements
for all waters discharged to these rivers.
B. We earnestly recommend the inclusion by the
conferees of an effective, high quality mandatory training
plan and certification program for all sewage treatment plant
personnel employed in the plants discharging wastes to the
rivers included in the study project.
C. In order to alleviate thermal pollution in
the project study river basins, we request the inclusion of
discharge water cooling facilities of sufficient capacity
to maintain condenser wastes at temperatures not to exceed
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643
A. A. Ebert
83 degrees Fahrenheit at all times.
D. We urge the Conferees to give serious consi-
deration to the highly desirable up-grading of three sections
of the study project rivers.
1. Mississippi River: Minneapolis-St. Paul
Sanitary District to Lock and Dam Number 2
to be included as a habitat for Group 1
fish (page 28, section b, in Recommendations).
2. Mississippi River: Minnesota River to Lock
and Dam Number 2 to be included as a whole
body contact recreational activity area
(page 28, section c, in Recommendations).
3. Minnesota River: Mankato to confluence of
Mississippi River to be included as a whole
body contact recreational activity area
(page 28, section c, in Recommendations).
E. We respectfully request the Conferees to
advance the timetable of the Remedial Program to 24 months
instead of the 36 months contained in the Recommendations.
In their deliberations following the Conference,
the distinguished Conferees are respectfully requested to
include the preceding recommendations as a means of expediting
the enhancement of the ecological systems in the river
basins under study.
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A. A. Ebert
Thank you.
MR. STEIN: Thank you, air.
You know, since this is part of an educational
approach, Just let me make two points —
MR. EBERT: Pardon me?
MR. STEIN: Just let me make two points.
The first is that several people have come up
with this 83 degree temperature, and the Minneapolis-St. Paul
Sanitary District indicated what temperature, 86? I am not
sure, but this la something you want to check, whether the
water naturally doesn't go above 83 at times in these rivers
even if you put nothing in it.
The other point is that I am as firm as the next
one on as rapid a time schedule as possible.
There have been several people who have criticized
this three-year proposal. Generally speaking, it has been
our experience that it takes as long to design the plant and
get the financing arranged and do all that work as it does to
construct. In other words, if it takes a year to build, it
takes a year to get your design and paper work. It doesn't
pay to build unless you are doing it right.
Now, I say this Just advisedly. If we were
running a dictatorship here; if we had all the power and
all the money in the world; if right now we pressed the
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645
A. A. Ebert
button to get this thing going and threw in all the resources
and we didn't care about the costs; if we could do this all
now and had a crash program like that, as if we were going
to move in developing the atomic bomb or something; if we did
it in two years, we would be lucky.
We know we do not have that here, so the question,
I think, is to come up with a realistic time schedule.
Again, I am not trying to change anybody's mind.
In my opinion the setting of too rigid a time schedule is
even worse than setting one which is too lenient. Here is
what happens: When you set coo rigid a time schedule that
can't be met and the time passes, you are beyond it, and
then no one pays attention to the order.
The point is you have to try to set a realistic
time schedule.
As one of the people here, I ask you to go back
in your organization and examine this time schedule, because
I do think that the scientific people here have made, as
far as I can see, as tight a recommendation as could reason-
ably be held.
Maybe this is a little unrealistic, and to be
unrealistic we have lost the battle.
Are there any further questions or comments?
(No response. )
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646
A. A. Ebert
MR, STEIN: Thank you very much.
Mr. Smith?
MR. SMITH: Are there any other civic organiza-
tions or sportsmen's clubs that I have missed?
(No response. )
MR. SMITH: Apparently this is all.
MR. STEIN: We will turn to Wisconsin.
MR. WISNIEWSKI: Mr. Chairman, you have a couple
of letters there from Wisconsin people, I believe.
MR. STEIN: Yes. Did you want to put these in
the record?
MR. WISNIEWSKI: Yes.
I would like to read into the record a letter
from Mr. Jack Nelson, Supervisor of Ellsworth, Wisconsin,
addressed to Mr. Murray Stein, Water Pollution Control
Conference, Minneapolis, Minnesota:
"Dear Mr. Stein:
"The Pierce County Board of Supervisors accept
and endorse the recommendations of the Federal Water
Pollution Control Administration on the Twin Cities-
Upper Mississippi River Project with the provision
that the standards be maintained and improved as
advancing technology permits.
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647
"Very truly yours,
Jack Nelson, supervisor
/s/ Jack Nelson"
I have another letter addressed to Mr. Stein
from Bay City, Wisconsin, which reads:
"The Village of Bay City and the Wisconsin
Cons a*vatlon Congress accept and endorse the
recommendations of the Federal Water Pollution
Control Administration on the Twin Cities-Upper
Mississippi River Project with the provision that
the standards be maintained and improved as ad-
vancing technology permits.
"Very truly yours,
/s/ Lloyd V. Spriggle"
I would like to have these included in the record,
MR. STEIN: Thank you.
MR. WISNIEWSKI: Are there any other people from
Wisconsin communities here who would like to enter a state-
ment?
(No response. )
MR. WISNIEWSKI: If not, are there any from
Wisconsin organizations or industries who would like to enter
a statement?
(No response.)
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648
MR. WISNIEWSKI: There being none, we have no
further comment.
Mr. Odegard would like to make a comment.
MR. STEIN: Yes.
MR. ODEGARD: I would just like to make one little
correction for the record.
Technically I am apparently designated as a
conferee from Wisconsin. I am from the Minnesota-Wisconsin
Boundary Area Commission.
There was no way under the existing law for me
to be appointed by the Federal Government or by the two
States, so Wisconsin took the opportunity, or gave me the
opportunity by designating me as a Wisconsin member, but I
want it understood that we are acting in our regular capacity
as an interstate compact position interested in air pollution
and water pollution and regional development for the whole
boundary area. We are truly interstate and have about the
same interest as the Federal Government in this case.
DR. HARGRAVES: Mr. Chairman, I, as the Chairman
of the Minnesota delegation, want to correct my error, because
I told Mr. Odegard this would be one of the early things that
I would say, but it slipped away from me, so it will perhaps
be the last thing I will say. However, we are happy to have
Mr. Odegard among the conferees representing Wisconsin as
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Robblnsdale Sportsmens Club, 0. Ginner
well as Minnesota.
MR. STEIN: Mr. Smith?
MR. SMITH: Mr. Stein, I have one more statement.
This is from the Robbinsdale Sportsmens Club, Inc.
STATEMENT OF THE ROBBINSDALE SPORTSMENS
CLUB, INC., AS READ BY GARY GINNER,
MINNESOTA DEPARTMENT OP HEALTH
MR. GINNER: This is dated February 28, 1967.
To Conference in the Matter of Pollution of Upper Mississippi
River and its Major Tributaries
Federal Water Pollution Control Administration
U. S. Department of Interior
Mr. Chairman and Members of the Conference:
The Robbinsdale Sportsmens Club, with members
from many communities in Hennepin County, wishes to thank
this conference for the invitation to present a statement at
this important hearing.
Our club's 26-year history in conservation
activities has kept us aware of the constantly degrading
quality levels of our river systems. We are not technically
qualified to present facts and statistics about water
standards, but we feel we can offer some comments from the
layman's point of view.
Ideally, we would suggest our rivers be controlled
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650
Robbinsdale Sportsmena Club, G. Ginner
sufficiently to provide water usable along their entire
length for (l) human consumption (after treatment) and (2)
recreational activities including swimming and sport fishing.
The assumption on the part of water users that
they are free to abuse the quality of our water resources
without penalty must be declared wrong. Penalties for such
abuses should be established immediately to provide, in
effect, a "water abuse tax" of sufficient magnitude to make
it desirable and an economic necessity for water abusers to
discontinue their offensive practices.
The Recommendations of the Federal Water Pollu-
tion Control Administration released in January 1967 are the
minimum acceptable standards to be established. Upgrading
of these recommendations shall be made as quickly as possible
as time and knowledge of this major problem permit.
Respectfully submitted
/s/ Lenny Hockert
President.
MR. STEIN: Thank you.
Are there any comments or questions?
(No response.)
MR. STEIN: If not, Mr. Smith, does that conclude
the presentation by Minnesota?
MR. SMITH: Yes, that concludes it.
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651
Corps of Engineers, Win. T. Sayers
MR. STEIN: Is there any more from Wisconsin?
MR. WISNIEWSKI: No.
MR. STEIN: As you know, we changed the order to
accommodate the people who came, and Mr. Poston, I believe,
still has some Federal representatives.
Mr. Poston?
MR. POSTON: We had several Federal agencies who
were here yesterday to give statements.
I believe Mr. Ryder of the Corps of Engineers is
here to read a statement of Colonel Hesse, the District
Engineer of the Corps of Engineers in Minneapolis.
Is Mr. Ryder here?
(No response. )
MR. POSTON: He was here. Because he isn't here,
I will ask Mr. Sayers to read this statement.
STATEMENT OF THE CORPS OF ENGINEERS, ST.
PAUL, MINNESOTA, AS READ BY WILLIAM T.
SAYERS, DEPUTY PROJECT DIRECTOR, FEDERAL
WATER POLLUTION CONTROL ADMINISTRATION,
TWIN CITIES PROJECT, MINNEAPOLIS, MINNESOTA
MR. SAYERS: Statement of Corps of Engineers, St.
Paul, Minnesota, for Conference on Pollution of the Upper
Mississippi River, Minneapolis, Minnesota, 28 February 1967.
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652
Corps of Engineers, Wm. T. Sayers
1. The Twin Cities Upper Mississippi River
Project, Federal Water Pollution Control Administration in
a report on pollution abatement recommendations for the
upper Mississippi River and its major tributaries recommended
that:
a. Present plans for improvement or replacement
of inadequately sized sanitary treatment facilities at the
locks and dams on the Mississippi River in this district be
continued.
b. At stream flows of 7,000 cubic feet per
second (cfs) or less (as measured at the St. Paul gage), as
much water as possible be passed over bulkheads before the
Tainter gates at Lock and Dam No. 2 at Hastings, Minnesota,
Mile 815.2. At flows of 3,000 cfs or less, the equivalent
of the inflow to Pool No. 2 should be passed over the bulk-
heads .
c. A planned schedule of analyses be continued
on effluent from the waste treatment facilities of the
Dredge WM. A. THOMPSON so as to insure adequate removals
prior to overboard discharge of effluent.
2. At the present time, the sanitary treatment
facilities of only one of the thirteen locks and dams on the
Mississippi River in this district (Lock and Dam No. 9 near
Lynxville, Wisconsin, Mile 64?.9) is considered inadequate;
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653
Corps of Engineers, Wm. T. Sayers
and improvement and/or replacement of these facilities are
scheduled in 1967. Of the remaining twelve locks and dama,
two sites (the control station at Upper St. Anthony Palls
locks at Minneapolis, Mile 853.7, and the control station
and the two dwellings at Lock and Dam No. 10, Outtenberg,
Iowa, Mile 615.1) are connected to the adjacent city-owned
systems. The remaining ten locks and dams are equipped with
sanitary treatment facilities consisting of septic tanks,
cesspools, and dry wells. Such facilities are considered to
be operating adequately in treating sanitary wastes and in
discharging inert effluents into the river.
3. Operation of Lock and Dam No. 2 as outlined
in Paragraph la. above has been carried on since the winter
of 196^. This program has not created any operational prob-
lems, although the bulkheads were lost during the 1965 flood
and were later replaced. At the present time, storage of
the bulkheads on the dam's bridge limits to some degree the
working area at the site.
4. Analysis of the effluent from the sanitary
facilities of the dredge WM. A. THOMPSON while in operation
is being continued to insure adequate treatment and removal
of pollutants prior to discharge in the river. Installation
of sanitary sewage treatment facilities on barges 719 and
761, and on the Derrickboat 767 is in progress and should be
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Corps of Engineers, Wm. T. Sayers 654
completed on about 1 May 1967.
5. In summary, the installations and floating
plant under the direction of the Corps of Engineers, St.
Paul District, on the Mississippi River, do not contribute
to the pollution of the waterway. This office will continue
to monitor our installations and floating plant to insure
efficient operation of the sanitary facilities and will
cooperate fully in any pollution abatement program.
MR. STEIN: Thank you.
I wonder if you fellows know what kind of
installation the Corps is putting on their boats? I don't
know if you can answer that.
MR, POSTON: I think he can.
MR. SAYERS: The dredge WM. A. THOMPSON has
extended aeration treatment facilities on it. They were
placed in operation, to my knowledge, I believe, early last
year, and they have been operating all summer. Also, to
my knowledge they have been operating satisfactorily.
MR. POSTON: This doesn't include chlorination
too?
MR. SAYERS: I am not certain.
MR. STEIN: Well, how about those other two
barges?
MR. SAYERS: I am not familiar with the operation
of the barges.
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R. E. Scheible 655
MR. STEIN: All right. Thank you.
MR. POSTON: Are you ready for the next?
MR. STEIN: Yes.
MR. POSTON: Mr. Scheible of the U. S. Army
Fifth Army Headquarters.
STATEMENT OP ROBERT E. SCHEIBLE, CHIEF
OF SANITARY AND ELECTRICAL ENGINEERING,
DEPARTMENT OF THE ARMY, HEADQUARTERS,
FIFTH UNITED STATES ARMY
MR. SCHEIBLE: Mr. Chairman, Conferees, Ladles
and Gentlemen:
For the record, I am Robert E. Scheible. I am
Chief of Sanitary and Electrical Engineering for Headquarters,
Fifth United States Army.
I will first read a letter from Headquarters,
Fifth U.S. Army, signed by Captain J. M. Roberts, Assistant
Adjutant General, for the Army Commander:
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656
R. E. Schelble
DEPARTMENT OF THE ARMY
HEADQUARTERS FIFTH UNITED STATES ARMY
1660 East Hyde Park Boulevard
Chicago, Illinois 60615
In Reply Refer to: 27 February 196?
ALFGD-EU
Conferees of the Conference on
Pollution of the Interstate Waters
of the Upper Mississippi River
Leamington Hotel
10th Street South & 3d Avenue South
Minneapolis, Minnesota 55^01
Gentlemen:
The inclosed statement covers this headquarters
activities in regard to pollution abatement and control in
the Upper Mississippi River Basin and in regard to actions
recommended by the Federal Water Pollution Control Admini-
stration affecting various U. S. Army NIKE site facilities
in this basin.
Subject statement is submitted pursuant to the U.S.
Department of the Interior Notice to Federal Agencies on
the reconvening of the conference and pursuant to the Summaiy
and Pollution Abatement Recommendations referenced in this
notice.
Sincerely,
1 Incl (Signed) J. M. Roberts, Captain, AGC
Statement Asst. Adjutant General
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657
R. E. Schelble
The statement Is as follows:
Headquarters Fifth United States Army welcomes
the opportunity to participate in this conference covering
the very Important matter of water pollution abatement in
the Upper Mississippi River Basin. In this regard, this
headquarters will continue cooperating to the fullest extent
possible with the Federal Water Pollution Control Admini-
stration as well as the Minnesota and Wisconsin Water Pollu-
tion Control Regulatory authorities in implementing all
needed actions. Directives covering this cooperation have
been established by the Department of Defense and the
Department of the Army and include Department of Defense
Directive 5100.50, Army Regulation 420-46, "Water & Sewage,"
and Army Regulation 11-21, "Environmental Pollution Control."
The basic water pollution control policy of this
headquarters requires that operation and maintenance of all
sewage treatment facilities under its command be at the
highest possible level. Performance at a level lower than
that reasonably attainable from the existing facilities is
unacceptable to this headquarters. The facilities will,
of course, be operated to meet all published performance
standards of the Federal Water Pollution Control Administra-
tion and the Minnesota and Wisconsin Water Pollution Control
Regulatory authorities.
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658
R. E. Sohelble
The primary prerequisite for meeting these per-
formance levels and standards, since adequate treatment
facilities already exist, is well trained operators. To
further improve the skill levels of each site man, this
headquarters is planning to supplement the training made
available by the Minnesota and Wisconsin regulatory authori-
ties by conducting its own short course, specifically
orientated to operation, maintenance and laboratory testing
of the NIKE site facilities. The net result should be a
further improvement in the already generally satisfactory
level of performance.
In regard to the general recommendations, this
headquarters basically concurs with their intent] however,
they imply that this headquarters is not now In compliance
with these recommendations. This is incorrect as follows:
a. Recommendation No. 1 states that a minimum
of one hour per day must be devoted to sewage
treatment, Implying that this Is not now being
accomplished. Each site man already spends about
five hours per week in operation and maintenance.
Since some laboratory testing is being accomplished
off-site at local municipalities, the time spent
in this regard must be added to that spent on-slte.
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659
R. E. Schelble
The time spent on both of these items approximates
the recommended one hour per day. This head-
quarters, however, feels that the imposition of
an arbitrarily determined amount of time is not
justified. The criteria for determining whether
adequate time is being devoted to sewage treatment
should be whether, in fact, operation and main-
tenance is at a satisfactory or unsatisfactory
level. During the recent inspection 27-28 October
1966 by a representative of the Federal Water
Pollution Control Administration and a representa-
tive of this headquarters, it was observed that,
with minor exceptions, operation and maintenance
were at a satisfactory level. It is therefore
concluded that adequate time is being devoted to
operation and maintenance and recommendations In
regard to these areas should be limited to de-
ficiencies t'mt, in fact, exist. This head-
quarters will continue to devote the necessary
time to operation and maintenance, and laboratory
testing, whether this time requirement is more or
less than one hour per day.
b. Recommendation No. 2 states that all
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660
R. E. Soheible
facilities should be operated to achieve their
designed removal efficiencies. This implies
that all treatment facilities were not achieving
their designed removal efficiencies when, in
fact, only one of the four treatment facilities,
namely, MS-90, Bethel, Minnesota, was not per-
forming up to its designed ability. Changes in
operational methods, primarily continuous re-
clrculation, have been made to improve treatment
performance at this site. Recommendations to
accomplish what Is already being accomplished
appear inappropriate and, again, recommendations
should be limited to specific problems where they
exist.
c. Recommendation No. 3 requires certain minimal
laboratory testing. No indication is made of the
fact that limited laboratory testing was being
accomplished at all sites as follows:
(1) Imhoff cone settling tests are being
generally accomplished at the recommended frequency;
(2) BOD tests on a two-to-four-time per
month basis are being performed in lieu of relative
stability. This headquarters feels that the
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661
R. E. Schelble
relative stability test Is of little value and
would prefer the considerably more useful BOD
test on a lesser frequency. It has already been
indicated that some laboratory testing is being
performed by local municipalities due to limited
testing facilities at the NIKE sites. This
approach is, however, extremely costly and each
site Is therefore planning to purchase one auto-
matic BOD analyzer, which will permit even more
frequent analysis for BOD on both effluent and
Influent;
(3) chlorlnation tests would, of course,
only apply to those sites practicing chlorlnation.
In view of the extremely low flow from these sites,
usually less than 0.01 MGD, twice weekly tests for
chlorine residual would appear appropriate;
(4) activated sludge testing is not applicable
to these sites since only one package-type
activated sludge plant is provided, since this
plant is so lightly loaded that a biota cannot
be sustained and, therefore, laboratory testing
for sludge index and dissolved oxygen would not
affect plant performance or cause any operational
changes to be made, and since the polishing lagoon
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R. E. Schelble
following this package plant is of such capacity
that overflow into a natural water course does
not occur.
In regard to specific recommendation No. 1 for
MS-40, Farmlngton, Minnesota, which requests termination
of the present discharge to the roadside ditch with con-
current extension of the outfall sewer, the Corps of Engineers,
during the early stages of construction of this site,
obtained a permit from the Dakota County Highway Department
to install this sewer on county property. Since the permit
application included drawings showing the affected area,
all of which was within the road right-of-way, and since
no approval was requested for sewer construction within
the right-of-way beyond the road intersection, it is con-
cluded that subject permit Included approval to discharge
into the roadside ditch. Also, paragraph 6.3 of the
Minnesota State Department of Health Standards for Sewage
Treatment permits such discharges when appropriate. Since,
during the Inspection Indicated above, both participants
made a careful, detailed inspection of this ditch, and
since no evidence of any pollution,, or even of a treated
sewage effluent, was observed, and since the functional
use of this ditch was obviously not being impaired, it is
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R. E. Sohelble
concluded that this discharge is appropriate. Although a
permit has already been issued, an after-the-fact approval
of the Minnesota State Department of Health will be re-
quested to ensure completeness of the record. In view of
this, the suggested time table on Page 34 of the recommenda-
tions is not applicable.
In regard to the specific recommendations for
chlorination at MS-40 and MS-90, it is questionable if
disinfection will be required to meet standard 3c shown on
Page 34 of the recommendations. Standard 3d would not
apply since the receiving streams are not used for whole
body contact activities. Currently the treatment facilities
are operating at about 10 to 20 percent of the original
design capacity. This necessitates substantial reclrculation
rates to properly maintain facilities. This, of course,
produces an exceptionally high degree of treatment, with
corresponding collform reductions, and it appears possible
to meet standard 3c without chlorination. Testing will
be Instituted to verify this position. Should this position
be incorrect, existing chlorination facilities at MS-40 and
MS-90 will be activated and operated in compliance with
standard 3c.
SUMMARY
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R. E. Scheible
1. This headquarters will continue to devote
the necessary time to sewage treatment activities.
2. This headquarters will continue to operate
the facilities to achieve their designed removal efficiencies.
3. With the approval of the conferees, laboratory
testing as indicated above will continue to be routinely
accomplished.
4. Formal, after-the-fact approval of the MS-40
discharge to the roadside ditch will be requested.
5. Chlorination requirements will be evaluated
by the laboratory control and chlorination facilities at
MS-40 and MS-90 will be activated if necessary.
Thank you.
MR. STEIN: Thank you.
Are there any comments or questions?
MR. POSTON: I might say thank you, Mr. Scheible,
and I am very happy to note that the facilities, of course,
will be operated to meet all the public performance standards
of the Federal Water Pollution Control Administration and
the Minnesota and Wisconsin Water pollution Control regulatory
authorities.
I am sure that the conferees will meet here and
will come up with summaries, which, if they are in unison,
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R. E. Scheible
will be published by the Secretary, and a copy will be
submitted to you.
MR. SCHEIBLE: And we will meet those.
MR. POSTON: Yes, sir. Thank you.
MR. STEIN: Are there any further statements, Mr.
Poston?
MR. POSTON: Are there any other Federal agencies
here who have a statement?
(No response. )
MR. POSTON: I know that the Atomic Energy
Commission was here and the Housing and Urban Development
Department were represented here yesterday. I don't know
whether they are here and wish to make a statement at this
time or not.
If not, this is all of the Federal presentation.
MR. STEIN: Are there any more from the States?
(No response. )
MR. STEIN: If not, we have been consulting with
the conferees. I think this has been a very productive
session in getting all the information and reviews on the
table. The conferees are going to give very careful con-
sideration to this material.
Now, in view of commitments of tne conferees,
particularly some of the Wisconsin conferees, it was decided
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666
that the conferees would recess, and we will reconvene
in executive session in Minneapolis on March 20th of this
year. It probably will be at nine o'clock, unless the
conferees subsequently decide on some other time.
At that time the participation in the conference
will be done by the conferees and their staffs, but we are
not going to go into hiding, because we do business where
everyone can see us.
In addition to that, I think it has become
evident that if we are going to get a real meaningful report,
we have to give our knowledge to certain technical problems
between now and then. Therefore, I think we would like to
have a technical committee representing the States and the
Federal Government.
This technical committee probably should be
headed by Mr. Wisniewski, Mr. Printz and Mr. Smith and their
staffs for the three groups represented at this table.
There are at least three problems that I have
identified which should be resolved:
1. We have to come up with a uniform decision
on how we would decide BOD rates are going to be determined,
whether this 7-day every 10 years, or 1-day every 15 years,
but let's try to resolve that.
I think we did this with Minnesota and came to
a resolution on the Red River of the North. I really do
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667
think we have to and should try to work that out, and if
the conferees feel they will need any data and computer
time or hydrologists to work on that, possibly within the
next few days you should decide that, so that when the
technical committee meets you will have this data.
Also, I believe it would be helpful if we could
iron out this notion of dump sanitary land fills on flood
banks. It would be very helpful if the technical staff did
come up with a recommendation that we can all live with on
that. I don't think there is any difference in what we want
to do.
The third point may be a matter of formulation,
but this is a question of coming up with an approach that
the conferees can consider on secondary treatment. Referring
to this notion that both States took issue with and that I
had a little problem with of that 80 percent removal and
secondary treatment, I think if we can get a formulation
of that which will be acceptable for the conferees to proceed
on, it will be helpful.
There may be other technical problems which we
may want to identify now or later, but hopefully we should be
ready to go on those.
I think we will have to use the recommendations
of all the conferees and the other people who made recommenda-
tions and suggestions for modification and consider those
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668
when we meet on March 20th.
Are there any further statements or questions?
(No response. )
MR. STEIN: Does anyone in the audience feel
that he wants to say something before we recess the
conference?
MR. BADALICH: Mr. Stein, would it be permissible
to submit supplemental data to the Commission?
MR. STEIN: Let me say this: I have given this
to one party. We are going to keep the record open for a
week.
Off the record.
(Discussion off the record. )
MR. STEIN: Are there any further comments?
MR. POSTON: Mr. Stein, it is clear that any of
the conferees who have items that they want considered by
the technical committee will submit them to their particular
representatives ?
MR. STEIN: Yes. I hope this is so. This is
not so extremely complicated as to cause a limitation on the
technical committee, but these are three of the areas that I
have identified.
As a matter of fact, the more there is for the
technical committee to resolve, the nicer the executive
session is going to be, and the sooner we will be able to
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669
get out to enjoy the pleasures of Minneapolis.
However, I would wish you take your mandate as
a broad mandate, and anything you fellows can agree on we
would be delighted to have.
Are there any other comments or questions?
A VOICE: Mr. Chairman, after the executive
session will there be another public session?
MR. STEIN: We are not going to exclude the
public from the executive session. We are not going to call
on you.
There is nothing that we are going to do here
that we don't do in the open. We have discussed this with
the representatives of both States. We are all public
agencies doing a public job in a public manner, and we are
delighted to have you sit in and see how good or how bad
we are, and look at us.
Are there any other comments or statements?
(No response.)
MR. STEIN: If not, thank you all for coming.
At the end of the public session, of course, we
will make an announcement.
We stand recessed until March 20th.
(Whereupon, at 5:05 p.m., an adjournment was
taken until Monday, March 20, 196?. )
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670
(The following statements were submitted after the
close of the hearing for inclusion in the record:
ST. CROIX RIVER ASSOCIATION
Rivercrest Road
Route 5
Stillwater, Minnesota 55082
March 3, 196?
Mr. Murray Stein, Chairman
Federal Water Pollution Control Administration
U. S. Department of the Interior
633 Indiana Avenue, N.W.
Washington, D. C.
Dear Mr. Stein:
Your recent "Report on Pollution of the Upper
Mississippi River and Major Tributaries" has revealed the
unfortunate extent of the degradation of the major riverways
of our region.
The St. Croix River Association, with a membership
of almost 150 people living for the most part in the St.
Croix River valley or who live in the Twin City Metropolitan
area but are interested in the River, has during the more
than 50 years of its existence traditionally concerned itself
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671
with both the esthetic values and the water quality of the
St. Croix River.
We have, however, become Increasingly aware that
the fate of the Mississippi and the Minnesota Rivers will
be the fate of the St. Croix unless the most strenuous
efforts are made to reverse the trends of the present use
of our rivers as municipal and industrial dumping grounds for
heat and waste. We are vitally concerned that the St. Croix
River does not go through the horrible cycle of death and
effort's at rebirth that the Mississippi River has.
The extensive technical data in the report Identi-
fying the kinds of and location of the sources of pollution
provide a critical first-step in remedial action to eventually
correct this problem. I am certain that your emphasis on
joint action by municipalities, the state and the Federal
government will receive strong support from our members who
have long felt that the region has the resources to deal with
the problem but lacked the will to organize a suitable program
of abatement.
Your report and insistence for action under the
law merits the gratitude and support of the entire region.
Yours very truly,
/s/ C. R. Humphries
C. R. Humphries
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672
President
St. Croix River Association
* # #
Statement of the Bureau of Commercial Fisheries,
Department of the Interior, as part of record of
the PWPCA Conference in the Matter of Pollution
of the Interstate Waters of the Upper Mississippi
River, Minneapolis, Minnesota, February 28, 1967
The safeguarding and perpetuation of the fishery
resources of the Nation is a major responsibility of the
U. S. Bureau of Commercial Fisheries (Fish and Wildlife Act
of 1936), Any practice or series of events which threatens
fisheries directly or militates against the well-being of
natural stocks even in the most subtle manner is of primary and
overriding concern to us, we have pointed out repeatedly that
changes are occurring in the Nation's aquatic environment —
changes that seriously threaten fishery resources and tend to
deface the value and utility of this promised land. No single
group or individual is responsible for these changes. It is
the small addition contributed by one, compounded with those
contributed by others that results in creeping ruination of
a stream, a lake, or a major river.
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673
The commercial fishery of the Upper Mississippi
River represents the largest discrete fishery on the inland
waters of the United States outside of the Great Lakes.
Landings of catfish, buffalo fish, sheepshead and carp,
averaging almost 12 million pounds annually, supply a large
portion of the demand for fresh water fishery products in
the Upper Mississippi Basin and surrounding areas. Over
1600 fishermen are dependent on the River for at least a
portion of their income.
The effects of poor water quality on the commercial
fishery is uniquely critical. The more obvious signs of
gross degradation of the aquatic environment including
deficiencies in dissolved oxygen, major changes in bottom
fauna and the like, are clearly detrimental to the fishery
through direct reductions of fish populations. A more subtle
aspect involves the tainting of fish flesh and the develop-
ment of unpleasant taste and odor qualities due to the
presence of such pollutants as oil wastes and phenolic com-
pounds. This qualitative aspect is particularly important
to an industry whose products are distributed directly to the
consumer from the point of harvest. Also, fish products
from the River are competing on the market with other fish
and meat substitutes where the consistent maintenance of
quality is a significant factor. The tainting of flesh
frequently renders River fish unacceptable to the consumer
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674
and there is little the fisherman can do to correct the
situation.
As a result the commercial fishery below St.
Louis has been severely curtailed due primarily to the
qualitative effects of water pollution. Basically, adequate
fish populations are present to support the fishery. A
similar situation has been pointed out by the Minnesota
Conservation Department at the 196^ Pollution Conference on
the Upper Mississippi River held at St. Paul. Frequent off-
flavor qualities of the catch from Spring Lake in Pool 2
have reduced selling prices and forced buyers to place fish
in holding ponds until these flavors have disappeared. A
further movement downstream of these conditions would have
serious effects on the fishery of Lake Pepin. This pool is
one of the most important on the River, exceeding all others
in average annual landings, and representing 10 to 15 percent
of the commercial catch on the River.
The Bureau of Commercial Fisheries is now completing
an extensive study of the Upper Mississippi Basin fishery
through its participation in the Corps of Engineers Upper
Mississippi Basin Comprehensive Survey. This study indicates
the central importance of the Mississippi River in the over-
all future development of the Basin's fishery, particularly
in supplying regional demand for catfish. We therefore
are extremely interested in the future course of water
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675
quality on the River and its tributaries. This interest
has been implemented in our recent comments on the proposed
water quality standards of the State of Minnesota, which we
have submitted to FWPCA. We stand ready to continue further
active participation in any and all future attempts to main-
tain and improve the water quality in the Upper Mississippi
Basin. )
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