U.S. ENVIRONMENT PROTECTION AOENGY
                                      For:  SEWERAGE  PROJECT WPC-m.-754
                                            NORTH SHORE SANITARY DISTRICT
                                            WAUKEGAN,  ILLINOIS
                                       By:  REGION  V
                                            CHICAGO,  ILLINOIS

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         FINAL ENVIRONMENTAL IMPACT STATEMENT
FOR:  Sewerage Project Number WPC-I11.-754
      Submitted by North Shore Sanitary District,
      Waukegan, Illinois
 BY:  Region V
      Federal Environmental Protection Agency

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                                 CONTENTS
SECTION                     .                           .                pAGE
  SUMMARY	  i

  INTRODUCTION	  1
      I.  DESCRIPTION OF APPLICANT'S PROJECT	  1
     II.  IMPLEMENTATION NEEDS 	  4
    III.  FINANCIAL ASPECT	:	  5
     IV.  NEED FOR ENVIRONMENTAL ASSESSMENT	  6
      V.  ADDITIONAL LOCAL BACKGROUND 	  &
THE TEXT OF THE ENVIRONMENTAL STATEMENT

  INTRODUCTORY CONSIDERATIONS 	  8
      I.  THE GREAT LAKES SYSTEM -*	  8
     II,  THE MISSISSIPPI RIVER SYSTEM-HEADWATERS OF THE ILLINOIS RIVER
            1.  The Des Plaines River Basin	H
            2.  The Skokie River Basin	14
    III.  LAND USE CONSIDERATIONS	19
            Facilities Location and Construction 	 20
            The Probable Impact of the Proposed Action on th&
              Environment —;	—	•	20
                1.  Waukegan	—:	—	20
                2.  North Chicago	22
                3.  Clavey-Road	22
                4 .  Gurnee	•	•>--	23
              Adverse Impacts Which Cannot; Be Avoided	*	24
                1.  Waukegan	24
                2.  North Chicago	24
                3.  Clavey Road	24
                4.  Gurnee'	•	'•	30
              Alternatives to the Proposed Action 	 30
                1.  Waukegan	^0
                2.  North Chicago	30
                3.  Clavey Road	'•	30
                4.  Gurnee	3^

     IV.  PUBLIC  OBJECTIONS TO PROJECT	1-	4°

RECOMMENDATIONS 	 46

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1.  nate^jxf^Statement ------ ----- ------------- - --------------- June  21,  1971

2.  Status of Environmental Statement ----------------------- Final
3*  List of Departments and Agencies From which  CpWientson_
    Draft Environmental Itnpact  Statement Have Been Received;  _!/

                         Federal

    Department of Agriculture
    Department of Commerce
    Environmental Protection Agency
    Department of Interior
    Department of Health, Education and Welfare  -
    Department of Transportation
    Department of Army
    Department of Housing and Urban Development

                          .State

    State of Illinois Pollution Control Board
    League of Women Voters of Illinois       •   • •
    Technical Institute of Illinois

                          Local

    North Shore Sanitary District
    Lake Michigan Protectors of the Srvironraent
    Businessmen for the Public Interest
    Northeastern Illinois Planning Commission
    Campaign Against Pollution
    Society Against Violence to the Environment
    Chicago Horticultural Society
    Students Organized for Survial
    Open Lands Project                       ,   .
    Forest Preserve District of Cook County, Illinois
  -  Lake Michigan Interleaguc Group Participants
    League of Women Voters of Glencoe, Illinois
    East Skokie Drainage District
    League of Women Voters of Highland Park, Illinois
    Village of Hodgkins
   • Riverside Lawn Improvement Association
    Environmental Defense Fund
    Deere Park Neighborhood Association
    kBBM-TV, Richard Kesterkamp, Editorial Director
    Congregation Solel
    Associated Allergists, Ltd.
    B'Nai Torah - Highland Park Reform Temple
    Trinity Church
    North Shore Radiologist, S. C.
    North Suburban Synagouge Beth EC
    Office of the Chairman-Board of Supervisors, "Waukegan


V'  Comments from all interested parties have been included in Appendix  A.

                            i

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U.  Type of Proposed Action	•	—	-Administrative

NARRATIVE

    On April 21, 1971 a Draft Environmental liipact Statement was released
by Region V, Water Program Office for a sewerage project involving a
construction grant application that was submitted by the applicant,
North Shore Sanitary District (NSSD), under Section 8 of the Federal
Water Pollution Control Act.  Mien completed, the sewerage project will
provide 55 million gallons per day (MGD) of sewage treatment capacity
to serve the eastern portion of Lake County, Illinois.

    Pursuant to guidelines prepared by the Council on Environmental
Quality and procedures developed in the Water Program Office, Environ-
mental Protection Agency, a final Environmental Impact Statement is
required to fulfill existing obligations under the National Environmental
Policy Act of 1969.  y                   -    ,

    A grant offer from the Regional Water Program Office was made on
April 22, 1970', to the NSSD to fund this project for improvement to
the water quality of the- area and meet anticipated treatment needs.  An
environmental assessment was -requested -of the applicant subsequent to
the grant offer and a full review of the project was then undertaken.
This final Environmental Impact Statement is the product of the previous
review and analysis of all conments received on the original draft                4
statement,                                                   •                     ™

    The eastern Lake County area,  at present,  has a sewered population     -•
of 200,000 individuals and by 1990 will have an estimated sewered
population of approximately 350,000 individuals.  It is basically  "
residential in character with light to moderate industry and commerce
located in this area.  Sewage treatment facilities now in operat'ion by
the NSSD consist of seven plants at sites along Lake Michigan and one*
treatment plant located on the Skokie River.

    In addition to requiring more capacity to meet present and antici-
pated needs of the population, the plants now operating on the Lake
Michigan shore must, by July 1, 1972, provide either additional and
improved treatment' or be phased out and have their discharges diverted
to inland rivers, by mandate of the Lake Michigan Enforcement Conference.
The present project calls for diverting inland about 29 MOD of sewerage
from the lakeside plants.
2/ Under subsequently adopted EPA procedures, effective 1971, W30 con-
   struction grants,are now required to have certified over-all water
   quality management plans for meeting area sewerage needs.  The plan
   will be required to designate sites for facilities and describe general
   capacity, concept and design.  This plan -will be discussed in a draft
   environmental impact statement and approved after comments are received
   and a final statement developed.  In implementing a particular aspect
   of the plan through an individual construction grant,  there will not,
   in most cases,  then be a need for a second environmental impact statement.

                             ii

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    The overall project of the NSSD, approved by the  Illinois Ehviron-
mental Protection Agency and endorsed by the Illinois Pollution Control
Board, calls for the construction of a new treatment  facility at Chirnee
and the expansion and renovation of present plants at North Chicago,
Waukegan and Clavey Road.  With the exception of the North Chicago
location, these plants will feature .advanced waste treatment (AWT)
and nutrient removal processes, thereby meeting the requirements of
applicable water quality standards. 2/     ,                          ,   ,

    The central intact of the project proposed by the District will
result from full expansion of the Clavey Road treatment plant to 18 MOD
and adverse effects are anticipated from the on site open retention
basin that will be used to hold excess collection sewer flows in large
open chambers during periods of wet weather, although other adverse
impacts are identified.  Located within 1$0 yards of the present treat-
plant units are several homes that are part of a much larger residential
development located in the immediate area.  The residents in and around
the area of the Clavey Road facility object strenuously to the retention
basin and plant expansion claiming that a probability for transmission
of harmful viruses and pathogenic bacteria exists as well as the con-
tinual escape of unpleasant odors..  In total, the full expansion of
the site would encompass h£ acres.  The.physical size of the plant will
not esthetically enhance the existing residential character of the
neighborhood.

    Within the close environs of the Clavey Road plant, there have been
built places of worship, a school, a golf course, and a large land
reserve that is being developed for a botanical garden which will add
appreciably to the conservation resource base of the general area.

COMMENTARY ON DRAFT STATEMENT      .            '

    The comments received indicate that the plant size at Clavey
Road and the question of covering for the retention basin are still
focal points of disagreement.  After reviewing our initial position •
   Advanced waste treatment will remove trace organics and residual
   suspended solids and will under design specifications achieve
   an effluent quality    in the range-pf_U mg/L biochemical oxygen
   demand (BOD) and 5 mg/L suspended solids (S3).  Nutrient removal
   will consist of nitrification - denitrification for nitrogen control
   and will be in part a function of the advanced waste treatment units.
   Waste pickle liquor is being studied by the District for achieving
   phosphorous removal.  However, should results indicate other phospho-
   rous removal techniques could be. more desirable, .their study and
   incorporation into the treatment process should be expeditiously
   carried out.  The Skokie River and Des Plaines River will serve as the
   .receiving waters and require such high degrees, of treatment by nature
   of their respective intrastate, and interstate water quality standards.
                              iif

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and the comments on the draft statement, we are persuaded that the
retention basin should be covered; we believe, however, that an 18 MGD
plant at Clavey Road is the most viable solution.

    Under the National Environmental Policy Act, EPA is charged with
adverting to health, esthetics, and land management in its decision-
making.  Given these considerations our draft statement proposed an
amendment in project design to provide a smaller 12 MOD plant at Clavey
Road and a larger plant at Des Plaines.  In determining a long-range need
for an.additional facility, it appeared to us. that NEPA goals, parti-
cularly- land-usage and esthetics would be furthered by a smaller Clavey
Road plant that could more likely be phased out over time$ thus committing
less acreage to industrial usage.  A small plant, moreover, was also in
our view less of a visual detraction in the Clavey community.

    After reviewing the comments on the draft statement we are persuaded
that our solution is not the best alternative.  First, the comments
suggest that the difficulty of acquiring land and financing a Des Plaines
site could be an obstacle.  Second, we are now convinced that it is no
more difficult to retire an 18 MGD plant than a 12 MOD plant.  On the
assumption then that there" will be a plant at Clavey Road, we cannot
say that there is a sigiifieant esthetic difference between a 12 MGD
and 18 MGD sewage treatment plant.

    Vie believe at this juncture a word is appropriate as to our view
of EPA's general NEPA obligation to further intelligent land-usage.
At the outset, it must be made clear that this is a statutory obliga-
tion and we must give land management values equal consideration to
other values in the environmental equation.  How it is weighed depends
on the circumstances and the comments.  Cn matters like land-usage
particularly we must respect State choices if it is clear that local
authorities have considered land management values.  We cannot, of
course, abdicate our own obligation to weigh these values independently,
but we can and will defer to local choices whenever they appear to have
adverted to the problem and reach a result that is in a zone of
reasonableness.  While land management concerns were not a primary con-
sideration in the State proceeding, they were not entirely overlooked and
the views of the State have been made known through the comments of
local  authorities.  The State's proposal for 18 MGD capacity at Clavey
Road is within the zone of reasonableness.

    The covering for the retention basin, also a matter of controversy,
represents a different problem.  The possibility of odors and aerosal
carriage of virus—however remote—is one that cannot be tolerated.
Experiments with new techniques show that there may soon be engineering
and design methods and landscape technique for odor control that would
insure that treatment facilities are unobtrusive.  We believe, however,
that the presumption here is that there be wholly adequate tested con-
trols  available.  Given all the evidence and the proximity of the Clavey
plant  to the Highland Park homes, the downwind tendency of the area, we
feel that  the retention basin should be covered.  This is not an Agency
position in favor of covering all cases, but simply a decision on the
particular facts before us.
                                 IV

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    We believe utilization of some advanced waste treatment processes
at Clavey Road is necessary in the immediate-future, as well as
provision for additional stormwater retention and/or treatment at
Waukegan and North Chicago. -~

    It is recognized that the effluent lagoon presently near completion
will serve for an interim period.of time to provide somewhat improved
treatment at the Clavey Road plant.  As such, it is advised that
operation of this lagoon be maintained only as long as deemed necessary,
and in any event, not beyond completion of the newly required advanced
waste treatment units.

    It is .further concluded that the NSSD must pursue obtaining another
site for construction of a sewage treatment plant on or near the Des
Plaines River so that areawide sewerage needs in 'the southern portion of
the District can be adequately handled beyond 1980.  The design of
such a facility should be of appropriate capacity and provide compati-
bility with the total environment of the general area.

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                       INTRODUCTION.


I.    DESCRIPTION OF APPLICANT'S PROJECT

           This project, located in eastern, Lake County, Illinois,

involves the construction of one new sewage treatment plant, expansion

and upgrading of three others, and the phasing out of five treatment

plants located on the Lake Michigan shoreline.  Figure 1 delineates the

total service area of the District, separate service areas within the

NSSD and the nine affected sewage treatment facilities.  The District

presently serves a population of about 200,000 people, who reside in

a largely residential environment.  Industrial development is concentrated
                                                                          y
in the vicinity of Waukegan .and North Chicago.

           The project, as submitted to the Water Program Office of the

Environmental Protection Agency, can be subdivided into two sectors as

follows.

      A.   The Northern Sector.  The lakeside secondary plants at North

Chicago and Waukegan are organically overloaded, and the latter is also

hydraulically overloaded.  Projected improvements include: 1) expansion

of the North Chicago plant, 2) additional facilities at the Waukegan

plant to provide primary, secondary, and advanced waste treatment,

nutrient removal, and chlorination, 3) additional interceptor sewers

in the area served by the Waukegan plant, V  U) a pumping station, force

main, 2/ and'sewer to convey the effluent from the Waukegan plant to the

Des Plaines River, 5) sedimentation and chlorination facilities to treat
I/ Interceptors are large sewer mains which collect sewage from smaller
   mains.

2/ Force mains are pipelines which convey pumped sewage.

                              1

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                    	•C"";x" ;i
                            'IT'" •  • j
                                                                         LEGEND
                                                               —-— PROPOSED FUTURE NSSD BOUNDARY
                                                                     SEWER DISTRICT BOUNDARY
                                                           BhC..." ^gi INDUSTRIAL  AREA
                                                                     30VERNMENTAL  AREA
                                                                     SEWER DISTRICT NUMBER
                                                           (RESIDENTIAL,INDUSTRIALJSEWER DISTRICT  ACREAGE
                                                           [1990,3010]  SEWER DISTRICT POPULATIONS
              '.-       .-,,.  - •.  :
                •« "I      >  \\   :'r  \
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                                                                              6POO   121)00 FT.
                                                                      NORTH SHORE SANITARY  DISTRICT
                                                                           LAKE COUNTY,  ILLINOIS
                                                                        REPORT ON SEWAGE DISPOSAL
                                                                             SUPPLEMENT  NO. 5

                                                                        SEWER DISTRICTS

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storm overflows y at Winthrop Harbor, Zion, Waukegan, North Chicago,

and Highwood, 6) a ~r: ce::agc treatment plant near Gurnee which will

discharge directly into the Des Plaines River and will provide primary,

secondary, and advanced waste treatment, nutrient removal and chlorina-

tion for sewage from Gurnee and vicinity, the Upper Skokie Valley,  and

North Chicago, and 7) pumping stations, force mains, and sewers to

convey the sewage to the Gurnee plant.


      B.   The Southern Sector. The original schedule provides for  the

phasing out of the five small, souther-most lakeside primary plants

(Lake Bluff, Lake Forest, Park Avenue, Ravine Drive, and Gary Avenue)

which are all hydraulically overloaded.  All storm overflows at these

locations will likewise be eliminated.  Other changes include: 1) adding

pumping stations, force mains, and sewers to convey sewage from the five

lakeside plants and the southern part of theDistrict to the Clavy Road

sewage treatment plant, 2) additional facilities at the Clavey Road

sewage treatment plant to provide primary, secondary and tertiary

treatment and chlorination for an average sewage flow of 18 M3D from

the souther sector of the District, U/  3) a pumping station, force main,

sewer to convey the effluent from the Clavey Road sewage treatment plant

to the Des Plaines River and U) sedimentation and chlorination facilities

to treat storm overflows at Clavey Road.

    Storm overflows occur in sewerage systems which "collect both sewage
    wastes and urban storm runoff in a common pipe.

 U/ An effluent lagoon is being constructed as part of the new facility
 ~"  with the original purpose of improving final effluent quality by
    two to three percent.  The lagoon was necessary to meet the  applicable
    water quality standards under provisions of the original project which
    have since been modified by the Illinois Pollution Control Board (IPCB').

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      C.   Discussion.  The degree of treatment for plants remaining in



operation will be upgraded to include advanced waste treatment in most



instances.  As the project was originally submitted to this office, only



two facilities - located in North Chicago and Highland Park (Clavey



Road) - will be retained that will not provide a high degree of treat-



ment.  North Chicago will provide pre-treatment before transfer to



another plant for additional treatment and nutrient removal.  The



Clavey Road facility would, by'the applicant's proposal, provide



secondary and tertiary treatment for waste flows from its own service



area as well as the additional was'tes diverted from the five lakeside



plants.  The plants which will be phased out do not provide secondary



treatment at present.  After the five lakeside plants are eliminated,



stormwater overflows will likewise be eliminated.



      D.   Present and Projected Capacities of Treatment Plants.  The



collection sewers which serve the Highland Park area discharge into three



plants - Park Avenue, Ravine Drive and Gary Avenue.  The City is taking



corrective measures to reduce infiltration into these sewers.  The



present total flow into these three plants often exceeds 3 MOD.  Thess



three plants, together with the Lake Bluff and Lake Forest facilities



will be discontinued and their wastes pumped to the Clavey Road plant.



The North Chicago plant's capacity of 3-35 MGD will be expanded to



U.26 MGD by 1990 and it will provide only pre-treatment before the flows



are pumped to the new Gurnee facility.  The Waukegan plant's capacity



is 9.5 MGD and it will be expanded to treat 20 MGD.  At the Clavoy

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Road plant, the design  capacity will be increased from the present

U.5 MID to 18 M}D.  The new Gumee facility will now have a capacity

of 17.25 MGD _5/.


      E.   Stream Loadings and Treatment Plant Discharges.  As noted,

there will be three major treatment plants discharging effluent into

two rivers.  The combined loading to the streams will total 1,831 pounds

per day of biochemical oxygen demand (lb./BOD/d) and 2,290 Ib./d of

suspended solids.  Specific discharges and relative loadings are identi-

fied below:

                                                 1990
       Location                Receiving      Flow Through
Sewage Treatment Plant (STP)    Waters           STP        Ib/BOD/d Ib/ss/d

1. Waukegan                  Des Flaines River   20  MGD      663     829

2. Clavey Road               Skokie River        17.8 "       593     7U2

3. Gurnee                    Des Plaines River   17.25"       575     719

                              Total to Des Plaines River     1,233  1,5U8

                              Total to Skokie River            593    7U2

      These figures reflect the calculated design effluent quality subsequent

to advanced waste treatment at each location and will be in coraplaince with

permissable stream loadings under applicable water quality standards.


II.   IMPLEMENTATION NEEDS
           The project resulted from requirements set by the Lake Michigan

Enforcement Conference and from the State-Federal water quality standards.
5/ The expansion in capacity is due to the inclusion of the Great Lakes
   Naval Training Center and a small industrial load which, since release
   of the draft statement, will now be tributary to the Gurnee facility.

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Interim chlorination facilities have been profiled at the seven lakeside

plants as directed.  Other pertinent requirements applicable to this

project are:  1) secondary treatment of effluents discharged to Lake

Michigan by July,1972, 2) phosphorus removal of effluents discharged

to Lake Michigan by December, 1971, 3) advance waste treatment and

chlorination of effluents discharged to the Des Plaines River where

necessary under interstate water quality standards, U) nutrient removal

of effluents discharged into the Des Plaines River and Skokie River by

1977, or sooner if practicable methods are developed, and 5) advanced

waste treatment and nutrient removal of Clavey Road effluents when

discharged directly to the Skokie River 6/.


III.  FINANCIAL ASPECTS
      On February k, 1970, the Illinois Sanitary Water Board- (now the

Illinois Environmental Protection Agency) certified this project.  A

Federal construction grant under Section 8 of the Federal Water

Pollution Control Act was offered for the project on April 22, 1970,

in the amount of £11,$50,000 and was accepted by the District on May 13,

1970.  The offer was based on project cost estimates related to a bond

referendum passed May U, 1968, of $3$ million and a 33^ Federal Grant.
6/ This requirement was ordered on March 31, 1971 by the Illinois
   Pollution Control Board after submission of the project applica-
   tion to this office.

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No money has been paid to the NSSD although such payment has been

requested.  Moreover, by Order dated Pebruary 11, 1971, by the

Commissioner of the Water Quality Office, EPA, Federal payments are

suspended until such time as the Clavey Road situation is resolved.

At present only $8.8 million worth of contracts have been signed

because of litigation proceedings involving the Clavey Road treatment

plant 7/.


17.   NEED FOR ENVIRONMENTAL ASSESSMENT

      The applicant's proposal is a large scale waste treatment plan

encompassing many sanitary facilities.  The impact of the project was

determined to be of significant magnitude to warrant an Environmental

Assessjnent.  The applicant was requested to prepare this assessment

and on December lU, 1970, the Environmental Assessment was received in

the Regional Office.


7.    ADDITIONAL LOCAL BACKGROUND

      Numberous groups have expressed support for the project as proposed,

including many State agencies and local communities.  The City of

Highland Park raised objections to the Clavey Road facility and on

January 6, 1970, the City's Plan Commission recommended - after extensive

hearings - that it  ... "cannot recommend approval of the petition: as >.

submitted by the NSSD." The City was concerned that adequate protection
 77 At  issue  in litigation are zoning, the validity 01 the bond issue,
   nuisance, air pollution, mandamus action, and civil rights were filed.
   On  November 3, 1970,  residents in the area of Clavey Road sewage treat-
   ment plant filed  a  complaint for injunction against the Secretary of
   the Interior and  the  Regional Director of the Water Quality Office,
   Region V, EPA to  prevent payment of Federal money to the project and to
   seek other relief as  deemed proper by the court.  This complaint was
   dismissed on June 8,  1971 pending the outcome of this Agency's final
   Environemntal Impact  Statement.
                            6

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 had not been provided at the Clavey Road plant against odors and

 possible airborne infection.


       Cn February 9,  1970,  the  City of Highland Park issued a special

 permit to NSSD conditioned  on providing specific measures for maximum

 airborne control.  Following litigation proceedings between the City

 and the District on ttiis matter,  the Clavey Road proposal was modified

 to include covers for the primary settling tanks 8/, aeration tanks and

 final  settling tanks £/ as  well as installation of detection and

 monitoring facilities at the Clavey Road plant.  The court, at that

 time,  declined to require covering of the proposed stormwater retention

 basin  IP/.  By later agreement,  the retention basin was modified to

 include a pre-sedimentation basin that would remove up to 80 percent of

 the solids received and would be  covered.  The retention basin would also

 have facilities to chlorinate any overflows and would contain recircula-

 tion equipment.
 8/ Primary settling tanks remove suspended organic  particles by gravity
 ~"  sedimentation.

 £/ These two processes are referred to as the  Activated Sludge process
    which reduces the organic content of sewage by forced aeration and
    gravity sedimentation.

IP/ A retention basin is storage  provided for excess flow above average
    flow during periods of wet weather.  This excess flow,  in the case of
    Clavey Road would result from the collection sewers in the communities
    which would route their wastes to the plant.  The combined sewage
    consists of domestic wastes,  urban storm runoff, and solids which have
     previously settled in the pipes or along gutters.  These wastes will
     be retained in the basin until such time as they can be routed through
    the normal treatment processes.  This practice gives high levels of
    treatment to storm runoff without increasing the size of the facility.

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      The five lakeside plants to be  phased out are in typical residential




areas. • The North Chicago plant site and immediate environs have scattered




residential development.  This plant is immediately north of the restrict-




ed Great Lakes Naval Training Center.  The Waukegan plant is built in an




industrial area near the lakefront directly east of the Waukegan metro-




politan area.  The proposed new plant site at Gurnee is rural in nature




and can be classified for use as open space.  There are some minor forested




tracts of land in the general area of the plant location.  The condition




around the Clavey Road facility exemplifies varying land use ranging




from open-spece forested areas to rather high intensity residential




development.  The environs near the CLavey Road facility will be the




subject of later discussion.






         THE TEXT OF THS ENVIRONMENTAL STATSMSNT






INTRODUCTORY CONSIDaRATIONS



      The service area of the applicant's proposal is geographically



located in proximity to the drainage divide between the Great Lakes and



the Mississippi River Drainage Basins.  In this broadest view, one must



consider the implications of diversions of waters from one basin into



the other.






I.    THE GREAT LAKES SYSTEM




      A.   The Probable Impact of the Proposed Action on the jJhvironment.




General concurrence has been reached, as exemplified by the Lake Michigan




Enforcement Conference, that the discharge of inadequately treated munici-




pal and industrial wastes into the Great Lakes System should be eliminated.

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In response to this requirement, municipalities along the south shore of

Lake Michigan have elected to further protect lake Michigan by diverting

their effluents from the Great Lakes Drainage Basin into the Mississippi

River Drainage Basin.  The impact of these diversions is to decrease

incrementally the natural flow through the Great Lakes System and to

increase the flow in the Mississippi System.  Lake Michigan cannot

easily flush itself under existing conditions and in time a review

should be made of the cumraulative impact of the total diversions, present

and projected, from the Great lakes System into the Mississippi River

Drainage Basin. lj/.  Lakes receive nutrient contributions from the

natural runoff.  In addition, man's concentrations of pollution have in

many cases resulted in the over-enrichment of lakes.  Lake Michigan is

currently receiving excess enrichment of human origin.  The applicant's

proposal will have the impact of diverting some of these concentrated

pollutants from the Lake and will result in only minor decreases in

natural nutrient contributions.


      B.   Any Probable Adverse Environmental affects That Cannot Be Avoided.

The question of diversion effects is one of the magnitude of the total

impact.  This in no way implies that the total diversions currently made
1J/ The Lake Michigan diversion allotment of 3,200 cubic feet per second (cfs)
    for the Illinois portion has already been established by Supreme Court
    ruling and we do not suggest here that a study be conducted at present,
    but suggest that a review be initiated at a later date to determine if any
    adverse environmental impacts have occurred.

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from the Lake or proposed should not be assessed in greater detail at

a later point in time.  If, in the future, the magnitude of the total

diversions is found to be detrimental to living systems in the Lake,

then changes in the amounts of diversion may be necessary.


      C.   Alternatives To The Proposed Action.  The obvious alternative

is to provide the necessary nutrient removal and return the reclaimed

water to the Lake.  In this event, the water would have to meet the appli-

cable standards set by the Lake Michigan  fiiforcement Conference or other

regulatory requirements.  However, the applicant and other municipalities

have chosen to remove the effluents from  the Lake T_2/.


      D.   The Relationship Between Local Short-Term Uses of Man's_Environ-       ^^

ment And The Maintenance and Enhancement  Of Long-Term Productivity.  The

applicant's plan will immediately improve the quality of the shorewaters

and thus will return the Lake shorewaters to full recreation use.  The

net effect of flow diversions with their  attendant nutrient eliminations

might, in the long-term, decrease the productivity of the Lake if the di-

version alternative is pursued by many municipalities along the entire Lake

Michigan shore.


      E.   Any Irreversible and Irretrievable Commitment of either natural

or physical resources.  The decision to divert the water is reversible.  The

proposed configuration of facilities could be utilized, with some modifi-

cation, if it becomes necessary in the future to return the water to the

Lake  system.
 12/ The applicant has  further  chosen to eliminate stormwater overflow  from
     the southern sector  of the project.
                              10

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 II.  THE MISSISSIPPI RIVER SYSTEM — HEADWATERS OF THE ILLINOIS RIVER




     A river environment is much different from that of a lake system.




 It is, for the most part, less stable and is subject to great variations




 in stream flows.  The instability creates an  environment suitable to




 the productivity of numerous living things.  Variation in stream flows




 thus is an important factor.






     The course of action proposed by the applicant will result in



 changes in the characteristics of two tributary streams and in changes




 in the environment surrounding the proposed construction projects.






     1.  TH5 DSS PLAINES RIVER BASIN.  The Des Plaines Basin has a




 drainage area of approximately 300 square miles above the proposed




points of effluent discharge.  A U. S. Geological  Survey gage located




 at Des Plaines, Illinois, indicates that the maximum stream flow has




been U,6?0 CFS and that there have been periods with no measurable




 flow during the period of record.  The average discharge for 2U years



 of record at this gage is 203 CFS.






     This river typically exhibits periods of extremely low flow in late




 summer,  fall, and perhaps through tha winter with periods of high flow




 in spring and early summer.  The wide variability in water level and




 flow creates a special type habitat and its associated biota;  nutrient



 levels may be critical.
                             11

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     A.  The Probable Impact of the Proposed Action on the Environment.




The applicant's proposal would divert the reclaimed water from the




treatment processes in the District to the Des Plaines River.  A total



of 83 CF5 would be discharged at three points in the Basin.  The




Waukegan plant would discharge 31 CFS (20MOJ) of reclaimed water.  The




proposed Gurnee facility would discharge 26.5 CFS (17.25 MGD) of simi-




lar reclaimed water.  The expanded Clavey Road facility would discharge




28 CFS (18 MGD) of tertiary effluent under the applicant's original




proposal.






     The results of discharge of these three effluents to the stream




will be to increase the minimum flow to approximately 83 CFS.  The char-



acter of the stream will change from a typically, seasonally dry stream




bed to a more stable situation.  The stream and its surrounding habitats




will be changed and it is conceivable that a different biota    will




develop.  The treatment processes selected to provide the high level of




treatment may, in part, determine the stable biota that will develop.
    The plant and animal life of a region.



    The possible receiving waters are Skokie River, Middle Fork or West



    Fork of the Chicago River, and the Des Plaines River.
                              12

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     B.  Any Probable Adverse  Environmental Effects That Cannot Be

Avoided.  The diversion of highly treated effluents into this stream

will result in an ecosystem less tolerant to pollution.  The existing

summer time biota is tolerant to drought.  Elimination of drought con-

ditions will result in an ecosystem which may be less tolerant to pol-

lution.  Therefore, bypassing or plant failures will have a. greater

impact on the clean water biota than it might have on the existing

organisms.  Another point is the introduction of increased quantities

of pesticides, nutrients, and other types of contaminants which were

not heretofore discharged through natural mechanisms to the Des Plaines

River.  However, such effects will probably be somewhat insignificant,

given the expected concentrations of contaminants not affected by the

treatment methods to be employed.


     C.  Alternatives To The Proposed Action.  It is obvious from the

preceding discussions concerning Lake Michigan that this stream could

be permitted to remain in its natural state if the effluents were not

diverted from the Great Lakes Basin.  If the effluents are to be di-

verted from the Lake, then any one of a number of small Illinois River

tributary streams    could be utilized as a receiving water.  All of

these streams would be affected in the same manner.
     D.  Relationship Between Local Short-Term Uses and the Maintenance

And Enhancement of Long-Term Productivity.  The applicant's proposal

represents a small diversion in flow which will greatly lessen the
lU)  The possible receiving waters are Skokie River, Middle Fork or West
     Fork of the North Branch of the Chicago River and the Des Plaines
     River.

                                  13

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quantities of phosphorus, nitrogen, pesticides, and other contaminants




entering Lake Michigan from North Shore Sanitary District facilities.



This reduction will improve the water quality of Lake Michigan.  To




protect the Des Plaines River advanced waste treatment is proposed.  The




principal result will be low flow augmentation of this stream, which




should enhance its long term productivity.






     E.  Irreversible And Irretrievable Commitments of Resources.  It



does not appear that any such commitments will occur for the reasons



suggested previously.






     2.  THE SKOKIE RIVER BASIN.  Skokie River has its headwaters




within the NSSD and is a small intermittent stream.  Its drainage area




at the U. S. Geological Survey gage at Lake Forest, Illinois, is ap-




proximately 13 square miles.  Maximum discharge at the gage was 321 CFS




and periods of no flow  have been observed.  The average discharge for




13 years of record is 9.6 CFS.  The existing Clavey Road facility dis-



charges its effluent into the Skokie River at a point approximately 7



miles downstream from the Lake Forest gage and approximately S miles




from the Skokie 's confluence with the north branch of the Chicago River.



This effluent might be characterized as an inadequately treated second-




ary effluent. -''   Its flow rate presently averages 6 MOD (9.3 CFS).
    This plant is currently overloaded, resulting in poor performance of




    the individual processes.
                                1U

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     The stream currently could be characterized as  a  small ditch.




Below the plant outfall the stream is filled with bottom deposits rich




in organic matter.  The existing biota is extremely  tolerant of pollu-




tion. __






     Approximately one-half mile downstream from the facility, the




Skokie River flows along a botanical garden.  This garden is a recrea-




tion and preservation area with small ponds and developed green areas




immediately adjacent to the stream banks.                        ,






     Still further downstream, the stream is impounded by a series  of



lagoons which are currently receptacles for large quantities of organic




matter resulting in the fcmation of ootton deposits.  The^e lagoons




have been used for boating as we 11 as other recreational au uivLr, Le'j,




but their continued intensive use is being jeopardized by the degreda-




tion of the quality of water.






     A.  The Probable Impact Of The Pix.pc^sed_Action  On The Environment.



The applicant's proposal would increase the capacity of the Glavey  Road



treatment plant to 18 MOD and would have diverted this effluent by  a



force main to a discharge point located on the Des Plaines River.






     By order of the IPCB,  however,  18 MOD (28 CFS)  will be released



into the Skokie River at Clavey Road.  Significant changes in the charac-




ter of the river will result by increasing the quality and quantity of




flow.  Average low flows would increase from 6 MOD (9.3 CFS)  to 18  M5D
                                15

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(28 CF3).  The discharge oT a high quality effluent into the Skokie




River will result in an enhancement of the water related esthetics in




this area.  The increased flow and the improved stream quality should




result in an expanded habitat favorable to the existence of a wider




variety of organisms.  As in the case of the Des Plaines River, this




discharge into the Skokie River would probably result in the develop-




ment of a clean water biota within the watercourse.  Similarly, this




biota is more sensitive to facility failures or changes in the water




quality of the stream.






     B.  Any Probable Adverse Environmental Effects That Cannot 3e




Avoided.  As previously discussed, two options are available, namely —




total elimination of effluent from Skokie River or the discharge of




sewage to the stream after receiving advanced waste treatment.  These




two options could result in two entirely different/ stream habitats and



their associated biotas.  The first option of total elimination would,



over a period of time, return the stream to its natural state.  The



adverse effects would be a transition period from its current status



to the status of a typical intermittent stream; the transition phase



might cause esthetically unpleasant conditions along the watercourse




which, while temporarily objectionable, would resolve themselves in




the long-term.
                               16

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     Implementation of the second option could have probable adverse




impacts through release of intermittent stonnwater overflows.  This




would have detrimental effects on the clean water biota that would




develop in the Skokie River.  Similarly, the effects of plant failures




would be detrimental to the clean water biota.






     C.  Alternatives To The Proposed Action.  Since the impact of dis-




charging effluent, after sufficient treatment, to the Skokie .River would




be to appreciably enhance the stream above its present condition, this




is considered to be a preferable alternative to the diversion of the



Clavey Road plant effluent to the Des Plaines River.  While enhancement



would also occur in the Des Plainer River, the net beneficial effect is




seen to be greater with discharge to the Skokie River.






     Conversely, the elimination of this effluent from the Skokie River




would, in time if no other contaminants were present, return the stream




to a near natural condition which could result in the re-establishment



of the natural biota typically present in the area.  This biota, accli-



mated to periods of no flow, can sustain itself under the wide range of



conditions that would normally exist.  Such a biota is,  of course, an




integral part of natural ecosystem.






     If the Skokie River receives the effluent, the biota which develops




could still be adversely effected by the stormwater overflows.  Infre-




quent shock loadings to the stream and the lagoons downstream could
                                17

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occur from the organic content, of such overflows.  An alternative to




this proposal is to permit the stormwater overflows after pre-treatment



and chlorination to be discharged to the lake.  However,  the retention




and treatment of stormwater overflow at the Claveo Road site as proposed




by the applicant is considered preferable because it will reduce the




nutrient loads entering Lake Michigan.






     D.  The Relationship Between Local Short-Term Uses of Man' s




Environment and The Maintenance And Enhancement Of Long-Term Productivity.



In the southern sector, the applicant is providing for short-term pur-



poses, protection not previously afforded to either the lake or stream



ecosystems.  In all likelihood, the long-term productivity of the stream




ecosystem will be increased by the addition of additional flows to the




Skokie River.  While minor detriment may occur from shock loadings, the




total effect will be to increase the productivity and the diversity of




organisms within this stream.






     E.  Any Irreversible And Irretrievable Commitments of Resources.



The proposed actions or their alternatives do not appear to be irrevers-



ible.  The effluent discharge point selection, while resulting in a



development of clean water biota in both instances, can be relocated if,




in the long-term, conditions indicate this to be necessary.
                              18

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                 III. LAND USE CONSIDERATIONS






     During the process of environmental impact evaluation, examples



of previous, unnecessary mistakes in land and water use often are



all too obviouso  Since the immediate and long-range goals of eval-



uating environmental impacts are to eliminate or to lessen deterior-



ation of the environment, attention must be given to land use



planning.  The scope of this planning has several related parts.  First



of all, the basic need is to insure the proper maintenance of life-



sustaining systems on this earth.  This basic requirement must be view-



ed in both its time and its space dimensions.  Previous sections of



this evaluation have reviewed some considerations pertinent to the larger



natural systems that are presently or will be impacted to some degree



by the applicant's proposed project - the Great Lakes and Mississippi



River drainage systems.  In this section the concern is for the local



aspects of the impacts of the construction and operation of a District



sewerage system.



     In terms of land use optimization, local development of sewerage



systems must be concerned with minimizing destruction of natural



resources and/or despoiling of the environment through adequate planning



and in the construction and operation phases of the project.  This



includes rebuilding of areas unavoidably damaged.   Local planning also



must be concerned with setting aside adequate areas to provide buffer



areas to potentially undesirable sites, such as sewage treatment plants.

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Included in this planning are the values of the placement of vegeta-




tion buffers and the significance of vegetation in  ameliorating day-




by-day conditions and, especially, unavoidable mishaps.  Considerations




of macro- and micro- meteorological aspects should be incorporated into




the selection of the facility site, in construction of facilities, and




in the arrangement and density of the vegetation buffer between the




outlying industrial and/or residential areas.




     Environmental protection demands special considerations during the




construction phase of sewerage facilities.  These are considered in some



detail in the following discussion.



Facilities Location and Construction




     The applicant's proposal will result in major environmental changes




at nine treatment plant locations and attendant interceptor routes.  In




addition, a new facility will be constructed that will also change the




environment in its area.




     A.  The Probable Impact of The Proposed Action On the Environment



1) Waukegan .  The expansion of the existing plant should have little



impact on the area surrounding the site.  The environment surrounding



the facility already has adapted to its presence.  Expansion and up-



grading should do little to effect this environment.  The local environ-




ment in the immediate area, especially the beaches, will be affected by




the storm water overflows.  As previously noted, these overflows will




occur infrequently.




     The Waukegan sewage treatment plant will be the site for a large
                             20

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scale sludge drying and incineration operation l6/.  The units  of


this process involve a sludge blending tank, two U£-foot diameter
                           X'-~~~~x
 sludge storage tanks, two (elutr^.ation tanks, four 10-foot diameter
                          	

 vacuum filters, two 22-foot diameter multiple hearth sludge


 incinerators, two ash lagoons and all related appurtenances.  The


 units have been designed to handle 29,81;0 pounds of solids per day.


 The sources that will contribute sludge are the Clavey Road, North


 Chicago and Waukegan treatment plants.  Each furnace will have an


 exhaust gas scrubber system that will receive all gases of combustion


 and discharge stack gases to the atmosphere containing not more than


0.2 grain of particulate matter per standard cubic foot of exhaust


 gas.  The Illinois Environmental Protection Agency issued a permit on


October 27, 1970, for the installation and operation of the above


facilities.  It is believed there will be no adverse impact from sludge


disposal operation at the Waukegan plant.


     As a supplement to the Waukegan sludge disposal method, there is


some effort being directed toward obtaining a land site for ultimate


disposal of sludge, but the environmental consequences, if any, of the


action cannot be measured at present,,  The construction of new inter-


ceptors in the service area will undoubtedly disrupt the normal human


life patterns along their routes.  The effect on the other life systems


on the routes are minimal as these are paved urban streets.
16/  These are processes used to reduce the sewage sludges to ash by

     burning the sludge in a furnace.
                                 21

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2)  North Chicago.  The expansion to the existing facility and



elimination of overloaded facilities should be a positive impact



on the environment.  The altered plant will provide only pre-treatment



before pumping of the sewage to the new Gurnee plant.  Odor problems



in the area should be greatly reduced resulting in improvement of



the esthetics in the surrounding area.  The arguments presented above



concerning storawater overflows are also applicable to the North



Chicago plant.  Interceptor construction will also disrupt the local



human life patterns.



3)  Clavey Road.  The present plant is located on a 20 acre site and



under the applicant's proposal the expanded facility will occupy



approximately 35 acres.  The applicant now owns a total of \£ acres at



Clavey Road.  The plant currently is surrounded by a mixed environment



consisting of private residences, churches, and recreational areas.



The physical presence of this enlarged facility will be more apparent,,



The inclusion of a large retention basin adds further to this situation.



     With expansion of the facility there should be a substantive



reduction in the existing odor problem.  The current facility is over-



loaded and may have been poorly operated in the past. 17/  The local



residents have been subjected to objectionable odors and have resisted



the plant's expansion.  (See Footnote 7.)  In the course of litigation



the possibility of airborne transmission of disease also has been



advanced as another impact.








17/  Either situation results in excessive odors.
                               22

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     Another impact, -which will result from the conversion of the



five lakefront plants to pumping stations, is creation of open-



space in five residential areas.  The elimination of inadequate



treatment at these sites should eliminate odor problems as well as



create open-space.  The elimination of stormwater overflows at these



plants will also enhance the lakefront in that vicinity and contribute



to an overall environment enhancement of this area.



     The construction of the major Middle Fork interceptor will not



disrupt the human life systems to any degree, largely due to the



selection of an interceptor route paralleling an existing interstate



highway.  The ecosystem along the route will be temporarily disturbed



during the construction process.  Human inconvenience will probably



be experienced during the construction of the southerly lakeside



interceptor.  The disruption will be more severe than that related to



the Middle Fork interceptor.  The construction of the force main from



the Clavey Road plant to the Des Plaines River would also result in



temporary inconvenience.  The route is through an area of intermittent



residential development and open space.



U)  Gurnee.  The new facility will have local impact on its rural



environment because of environmental changes associated with intensive



development of the planto  The site purchased by the District is



contiguous to land presently utilized for agricultural purposes; a



portion of the area is also open space with no development.   The inter-
                               23

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ceptor system will, of course, cause minor disruption of the area



during construction.



     B.  Adverse Impacts Which Cannot Be Avoided



1)  Waukegan.  The possibility for occasional discharge of inadequately



treated stonnwater overflows should be regarded as detrimental to Lake



Michigan and especially the local beach environment.   The applicant has



proposed pre-treatment and chlorination but it may be necessary to



provide additional retention capacity.



     The disruption caused by sewer construction is unavoidable if



the area is to adequately treat its waste.



2)  North Chicago.  Stormwater overflows will be detained in existing



facilities until they are pumped to Gurnee, where they will receive



treatment before discharge to the Des Plaines River.   This will result



in a minor adverse effect on the Des Plaines River but the applicant



has provided for a high level of treatment which should minimize the



overall adverse impact.



     Minor disruptions during sewer construction are unavoidable.,



3)  Clavey Road.  The expansion of the plant and construction of the



retention basin would have an adverse impact from physical presence,



possible odors, and potential airborne infection.  The proposed 18 MOD



facility will not add to the esthetic quality of the neighborhood,



which is a mixed residential and recreation area.  Odor problems will



largely result from the open retention basin.  Airborne infections



from such basins have not been acknowledged by all, but the possibility



for harmful emissions is known to exist.

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     The effluent lagoon will receive secondary effluent and serve

as a polishing pond producing a final effluent quality under design

conditions in the range of 92% removal of five day BOD and S3.

     The lagoon at Clavey Road was originally designed to provide

tertiary treatment before pumping to the Des Plaines River.  Upon

completion of AWT and with the use of the Skokie River as a receiving

water the lagoon will no longer be needed.  During the interim

construction period, the lagoon will be utilized in the treatment

process.

     Occasional mild odor emissions may occur from this lagoon during

wet periods when the plant cannot maintain normal levels of treatment

efficiency.  This is not considered a major adverse impact of the

long term Clavey Road project, as the utility of the lagoon will cease

upon completion of more sophisticated and desirable AWT processes.

     The environmental setting for the Clavey Road facility has changed

since its original construction.  Regardless of the actions which

created this change, it has occurred.  The plant is now in an unfavorable

setting but the practicality of the situation mitigates against its

discontinuation because the phasing out of the five lakeside plants

must occur before the July 1972, enforcement deadline.  These wastes

must be treated and Clavey Road provides the only possible site for

such treatment. l8/

     The case for phasing out the lakeside plants is convincing.

Among the problems with maintaining a lakeside location is the
l8/  The alternative means of providing this treatment will be explored
     in detail later in the section on Alternatives to the Proposed Action.

                               25

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unavailability of needed land to expand the existing lakeside



facilities or to acquire a large single iakeshore location.  There



is no environmental justification for their continued operation



and the decision to discontinue these plants is not questioned here.



     Projections of sewage flows have been made by the consulting



engineer for the District and this office*  A tributary flow to the



Clavey Road plant of about l8 MOD will occur in I960, assuming that



the major interceptor and sewers are built as now proposed.  A relief



plant will need to be constructed and on line prior to that time so



that additional flows can be given adequate treatment.  In the imme-



diate future at Clavey Road, treatment capacity of approximately 12



MOD is required.  Presently the Clavey Road facility is receiving



average daily flows of about 6 million gallons.  When the lakeside



plants are phased out, it is anticipated that the levels of stormwater



infiltration into the sewers may be somewhat reduced.  The result



would mean a minimum tributary flow to the Clavey Road plant from the



three Highland Park lakeside plants of nearly 2.7 MOD.  The Lake Bluff



plant would contribute 0.6 MOD and the Lake Forest plant would add



another 2 MOD.  In total, the sewage flow to the Clavey Road facility



would be approximately 11.3 MGD.  The maximum flow is dependent on



future development and infiltration control.



     The Clavey Road operation has in the past caused odor problems and



has inadequately treated its discharges.  The project now proposed by



the District will improve these conditions.  Control measures including
                                26

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covering of the presedimentation basin, primary, aeration and final



tanks as well as a sophisticated multiple deodorization system and



forced ventilation will effectively minimise the potential for odors



emanating from the plant.



     Further steps are necessary to insure that the operation and



expansion will minimize adverse impacts.  The Water Program Office is



concerned with the efficiency of operation and maintenance of the



facility once expanded.  Vherever human or mechanical error is a



probability, the best design for a treatment system is one that mini-



mizes to the highest possible degree the potential for human or



mechanical misdoing.  While the proposed plant will have other standby



units available, a malfunction of mechanical equipment related to



operation of the retention basin or presediraentation basin followed by



untimely corrective measures would in theory produce a very unpleasant



situation.



     The open retention basin without complete covering continue to be



an extremely controversial problem from the public health viewpoint.



The results of extensive testimony- by experts in the fields of aquatic-



microbiology, virology, and waterborne diseases indicates differences



of opinion as to the occurences of harmful organisms.  During lengthy



hearings in Waukegan conducted by the Illinois Pollution Control Board



in mid-November and early December,  1970,  no conclusive evidence was



given by these experts as to the presence or absence of emissions of



bacteria or viruses from open sewage treatment units.  Dr.  Deinhardt,



head of the Department of Microbiology of the University of Illinois
                               27

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Medical School, testified that in his opinion, no danger presently



exists.  Dr, Bertram Camow, Chief of the Section of Environmental



Health, University of Illinois, indicated in the Waukegan hearings



that adequate studies have not been performed and that conclusive



evidence to substantiate either position had not yet been produced.



The former Director of the Illinois Environmental Protection Agency,



Mr. Clarence KLassen, revealed that he was unaware of any serious



illnesses to sewage treatment plant operators in the State caused by



or attributed to their day-to-day activities in treating sewage.



     This office has studied the literature in this field and incon-



gruous results have been found regarding the probability for transmittal



of airborne viruses and bacteria.



     Appendix B contains pertinent articles that discuss health effects



owing to emissions from sewage treatment plants.  More notably,



Ledbetter and Randall found that..."Large numbers of potentially



pathogenic bacteria were collected from the air surrounding activated



sludge units, and many persisted for a considerable time and distance.



Significantly, the airborne enteric pathogens were greatly outnumbered



by bacteria of proved pathogenicity in the respiratory tract."  Included



in Appendix B are two articles prepared as rebuttal statements to the



District's Environmental Assessment regarding health effects from



sewage treatment plants.  In these statements, Dr. Martin Rogoff,



Manager, Microbiology, International Minerals and Chemical Corporation,
                              28

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Libertyville, Illinois, said that..."The argument that epidemio-



logical relationships have not been proven is not valid.  The work



has simply not yet been done."  Dr. Carnow, in the second article,



concluded that..."In regard to projected increase in the size of the



sewage plant and its impact on the community, there will be present



an increase in materials which will reduce the resistance of the



lungs to disease and cause considerable irritation to the respiratory



tract of many people in the surrounding community."  However, Dr.



Carnow did not context his statement in relation to closed treatanent



units.



     It is the belief of the Regional Water Program Office that no



conclusive evidence has been advanced to eliminate concern for potential



adverse health effects attributable to odors or pathogens resulting



from full expansion of the Glavey Road plant.



     We do not feel that the project as now proposed satisfies fully



the letter,  spirit or intent of Section 101-b (2) of the National



Environmental Policy Act of 1969* namely,  that the project will assure



for the residents in the immediate area of the plant..."safe, healthful,



productive,  and esthetically and culturally pleasing surroundings."



It may be that further study will prove that no health  hazard exists,



but the proximity of the plant to the Clavey homes dictates maximm



protection at this time.



     Complete covering of the entire retention basin offers the best



way to effectively minimize any adverse effects restQ-ting from poten-
                                29

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tial mechanical or human error.  Apart from health aspects,



deodorization facilities and emission controls as those proposed



by the District are deemed sufficient to meet the applicable Air



Quality Stajidards at the Clavey Road plant.



ii)  Gurnee.  The adverse iaipact of the new facility can be minimized



by proper concern for the buffer areas around the plant.  The



incorporation of the concepts presented in the Land Use Considerations



should prevent a recurrence of the problems encountered at Clavey Road.



Landscaping to de-emphasize the plant is recommended.  Consideration



should also be given to the placement of vegetation to change or other-



wise channel air currents.



     B.  Alternatives To The Proposed Action.



l)  Waukegan.  The alternative is to eliminate any opportunity for



stomarater overflows.  The applicant is advised to provide adequate



storage to eliminate the overflows.



2)  North Chicago.  The alternative is to provide retention basins for



the overflows at the Gurnee site.  This should be Implemented if



sufficient storage cannot be provided at the North Chicago facility.



3)  Clavey Road.  The Clavey Road facility, although designed for U.5



M3D, is now treating average flows of 6 MOD.  The proposed plant will



also receive wastes from the five lakeside plants that will be phased



out by mid-1972.  As a result, the flow to Clavey Road will be increased
                                30

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to about 11.3 MGD upon completion of the plant.  Since no facility

other than the Clavey Road plant will be available to accomodate

the projected phase out, Clavey must be designed to treat a minimum

sewage flow on this order.  A series of alternatives have been

evaluated by the Regional Office involving three different treatment

plant locations based on meeting the sewage treatment needs through

1990.  Plant locations considered are the Clavey Road site at the

present location, Des Plaines River site at the Lake-Cock County Line,

and the industrially zoned area, of Rondout immediately west of Lake

Eluff.  In selecting these three possible plant locations for comparison,

consideration was giver: to other sites,  but none were believed

feasible. 1_9/

     Detailed cost estimates associated  with the cost of development of

treatment plants and appurtenant facilities at each of the three sites

considered are contained in Tabip 1.  These estimates are based on the

assumptions that; 1) all flows would receive treatment to the extent of

primary, secondary activated sludge and  activated carbon absorption for

dissolved organic removal, waste pickle  liquor for phosphorus removal,

nitrification-derdtrification for ammonia removal and chlorination of

the effluent; 2) alternatives would be sized for the anticipated 1990

sewage flow of 30 MGD; 3) all sites would have provisions for a retention
19/ The evaluation of the alternatives involving the Clavey Road Treat-
    ment plant was prepared in February, 1971, and later refined.  Sub-
    sequently the results were discussed with the parties concerned in
    attempts to achieve resolution of the Clavey Road situation.  Several
    meetings were held with the NSSD and a local citizen group in an
    attempt to reach a decision on an environmentally and socially accep-
    table solution.
                                  31

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basin; U) all facilities would be covered, and 5) all estimates



are based on March, 1971, price levels.  The costs for retention



basin covering do not reflect new design, but do indicate measures



over and above the scope of the applicant's present project.



Deodorization equipment is also included.



     Table 1 shows that interim expansion would cost $luO million



even with a phase out of that facility.  This interim expansion to



12 MOD capacity at Clavey Road would be required since a major plant



at a second site could not be on line until possibly 1975.  It would



consist of the existing primary treatanent facilities, the conversion



of the lagoon under construction into an aerated lagoon, and the



chlorination units which are also under construction.  Activated carbon



units would be needed to provide the high degree of removal of organic



pollutants.



     A comparison of capital costs of alternative facilities shows that



the costs involving the Clavey Road and Des Plaines sites are within



$ii.O million of each other which shows a cost differential of seven



percento  Alternatives involving the 12 MOD aiid the 18 MGD capacity



plant at the Clavey Road site would have essentially the same capital



cost although the bigger capacity plant would defer the need for a second



plant at Des Plaines for about five years.  Table 1 also shows that



development at the Rondout site (options D & E) would cost about $1



million to $3 1/2 million more than comparable development at the Des
                                33

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Plaines site (option G & H) depending on the size of the facility.



The annual costs for operation and maintenance would be essentially



the same at both the Rondout and Des Plaines sites as shown in



detailed estimates contained in Appendix E.  Because of the economic



disadvantage at the Rondout site with no apparent offsetting environ-



mental or social effects, no further consideration will be given in



this report to development at the Rondout site.



     The review of capital cost in Table 1 thus reveals a feasible



alternative to the applicant's, namely,  alternative number U;  Clavey



Road plant with reduced capacity to 12 MOD, tertiary treatment and



nutrient removal,  complete covering and  deodorization and a 10 MG



retention basin.  This is utilized in combination with a 18 MOD plant



of similar design and a 20 MG retention  basin at the Des Plaines site.



     This alternative involves the addition of 7.5 MGD capacity to the



existing primary,  secondary, and disinfection facilities at the Clavey



Road plant.  The retention basins at both sites would be covered to avoid



the possibility of airborne infection.  The costs shown for the two sites



indicate that savings in relation to capacity would occur with the larger



retention basins at the Des Plaines plant.



     Annual costs for operation and maintenance have been computed for



three points in time—1980, 1985, 1990.   A summary of these costs for



each of the principal plans are contained in Table 2.
                              3U

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                              TABLE 2

      COMPARISON OF ESTIMATED OPERATION AND MAINTENANCE COSTS
                    FOR PRINCIPAL ALTERNATIVES
Options (See Table 1)                                Annual Costs

  A&F                                        1973-1974,   $  906,000
                                             1975-1979,    1,475,000
                                             1980-1990,    2,172,000

  E&G                                        1973-1979,    1,241,000
                                             1980-1990,    2,164,000

  H                                          1973-1974,    2,000,000
                                             1975-1979,    1,226,000
                                             1980-1990,    2,140,000

     Table 2 reflects the difference in the costs for operation and

maintenance during the 1970's.  These estimates note the short-term,

higher costs of operation and maintenance associated with the temporary

facility at the Clavey Road site for option H in comparison with the

costs of a permanent facility at Clavey Road in the other two alternatives.

Alternative B&G would include lower operation and maintenance costs

throughout the 1970's because the second plant at the Des Plaines site

would not have to be in operation until the end of 1980.  Beyond 1980,

the unit costs for operation and maintenance for each of the three

alternatives would be essentially the same.


     Table 3 presents a summary of the total economic costs (capital

investments, operation and maintenance costs) for each of the plant costs.

It reflects the time-value of a flow of investments based on a 6 percent

annual interest rate,  '"ietailed evaluations of the anticipated

and maintenance costs have  been  discounted to 1971

-------
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for comparative purposes.  A comparison of the present worths of the




total costs of the three principal alternatives shows that Option B&G,




the Clavey Road plant with a capacity of 18 MGD and the Des Plaines




plant with a capacity of 12 MGD, would be the most economical solution.




Alternative B&G appears more attractive in that the time-value of




deferring the Des Plaines plant is recognized until 1980.  A&F and H




would be only about 9.5 and 14.7 percent greater than the most




economical alternative.







     For the Clavey Road facility, the adverse impacts can be avoided




partially in the future.  Selection of Option H would eliminate the




Clavey Road Plant after 1975.  This alternative would entail an




additional cost, in terms of the total economic costs shown in Table 3,




of $8.9 million.  This selection would further necessitate the




temporary construction of additional facilities at the present site.




Such facilities could well add to the environmental problems during




their use in the next four years.  The presence of an aerated lagoon




amplifies the question of airborne infection and could well increase




the odor problem.   The cost of covering the aerated lagoon was not




considered because the lagoon cannot function properly if covered.




From the above considerations it is apparent that the Clavey Road




facility must remain in operation.  The cost of discontinuance is




prohibitive and the environmental consequences during the phase out




are unavoidable.
                             -37-

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     The question can then be reduced to the assignment of capacity



to the Clavey Road plant.  The minimum capacity of 12 MOD was deter-



mined by the decision to close the lakeside plants.  The maximum was



determined by the agreement between the City of Highland Park and



NSSD which set the maximum capacity of 18 MOD.  The latter capacity



is the more economical of the two based on the values presented in



Table 3.



     An economic penalty of approximately $5.5 million will be incurred



if the 12 MGD capacity were chosen.



     The environmental impact of the plant's location could be minimized



to an extent if the project were to be built at the 12 MOD capacity.



It is estimated that an additional 3 to k acres of occupied space are



necessary for construction of the larger 18 MGD facility.  A continuing



stipulation is the covering of the retention basin in response to the



possible public health effects.  The size of the retention basin should



be consistent with earlier design parameters.  Further, the applicant



must provide for competent operation and maintenance and shall take



measures to blend the new facility into its surrounding.  In particular,



the possibility of constructing forest windbreaks and air channels for



odor control should be studied.



     The discharges from the Clavey Road plant have contributed in part



to degradation of the Skokie River and have had an adverse effect on the
                                 38

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Skokie Lagoons downstream.  The lagoons have experienced substantial



utility for recreation purposes, but the beneficial uses of this



resource have been endangered due to water pollution.  There is



considerable merit for providing advanced waste treatment at the



Clavey Road sewage treatment plant because of the water quality



enhancement to be obtained through low-flow augmentation.



     The possible adverse impact of Lake Michigan diversions has



been previously discussed and this project's contribution is regarded



as minimal.



     The above capacity recommendation will necessitate development



of the Des Plaines River site in the near future.  Care should be



taken in site selection to minimize the environmental impacts.



h)  Gurnee.  The proper care in site development, subsequent construction



and landscaping should be taken in order to minimize the impact of the



plant.  The environs surrounding the plant should be preserved to the



extent possible.  Care, if taken during initial phases of construction



and early operations, could alleviate many of the environmental short-



comings.
                                39

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IV.  PU3LIC OBJECTIONS TO PROJECT AND RESOLUTIONS






     A.  Applicant's Original Proposal As ContainedJEn Grant Applica-



tion,  The proceeding text of this Environmental Impact  Statement




references the major objections put forth by concerned parties.  Em-




phasis centered on the Clavey Road sewage treatment plant, and its pro-



posed expansion and improvement program.  Specifically the following




objections have been voiced regarding the Clavey Road project:






         1.  The area is no longer suitable for a sewage treatment




     plant, let alone for substantial expansion of existing facilities.






         2.  Adequate precautions have not been incorporated into the




     new facilities to eliminate concern over air pollution, odors, and




     air borne transmission of viruses and bacteria.






         3.  Inundation of bottom lands will occur during periods of




     wet weather in areas adjacent to the facility once it is expanded.






     Attempts to resolve the major differences took the form of numerous




public meetings, hearings and separate pieces of litigation at various



levels of judicial review.  Attempts by local residents near the Clavey



Road plant were unsuccessful for the most part in achieving a redirection




of NSSD priorities as to location of treatment facilities in the Southern



portion of the District.  Of significance was the fact that an ultimate




capacity limit of 18 MGD was placed on the Clavey Road installation,

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through agreement with the City of Highland Park and the NSSD.  There




were substantive modifications relating to item two of the above.  As




identified in the text, the basic treatment units will be covered, a




highly refined deodorization and air ventilation system has been in-




cluded and the land surrounding the plant will be landscaped to blend




environmental features.  There has been no satisfactory resolution of




item three as the topographic characteristics of the entire area, i.e.,




flood plain, portray a naturally occuring condition which should not be




materially altered as a result of operations at the Clavey Road location.






     B.  Draft Impact Statement.  All comments that have been received




by this office are contained in Appendix A.  They exemplify a broad




spectrum of viewpoints and generally reflect mixed reaction to recom-




mendations contained in the Water Program Office draft statement.  The



major items of concern have been categorized generally and are listed




below:






         1.  Implementation of the Water Program Office recommendation



     for restricted expansion of the Clavey Road plant would delay com-



     pletion of the project up to six years.   Also,  the discharge of



     inadequately treated sewage into Lake Michigan  from the District's



     lakeside plants would be continued for a considerable time,  thereby



     jeopardizing the quality of the shorewaters.
                                1*1

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         2.  The retention basin at Clavey Road did not warrant com-




     plete covering at this time.






         3.  An additional expenditure in the range 30 million to build



     a new treatment plant on the Des Plaines River is economically



     unsound and unnecessary.






     This office addressed itself to these objections as well as to




other minor comments and still favors the basic rationale inherent in




the draft statement.  That is to say, where possible, it is an environ-




mentally more acceptable solution to consolidate waste treatment, facilities




into as few locations as possible.  If this arrangement is unlikely, then



every precaution must be taken to lessen the adverse environmental




impacts attributable to the particular project.






     The basic tenet by which this office became concerned over the




total environmental impact of the M3SD project was through the National




Environmental Policy Act.  Clearly, this Act puts forth the requirement



that Federal Agencies whose actions may directly or indirectly affect



the environment must consider among other things, the fundamental con-



cepts of public health, esthetics, and land management.  This has been




done, both by the IPCP and Water Program Office of EPA, in this instance.



Our preliminary findings were not those of the IPC3, nor should they be




expected to reflect identical opinions, given the varying yardsticks by




which the N3SD project was measured.

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     Our interests here are common with those of the District and all




the people of Lake County, that is to expeditiously achieve the highest




levels of water quality with the least amount of environmental degreda-




tion in the process.






     There is in this matter, however, a question of rather deep import-




ance that heretofore was not satisfactorily aired.  Is there a signifi-




cant difference as to the adverse environmental impact between a 12 MOD




facility and an 18 MOD plant, given the unique features and conditions



on the Clavey Road facility as they now stand?  -ach of the objections




dd uiey relate to this question are addressed below.






     On the matter of timeliness in phasing out the five Lakeside plants




for discharge to inland watersheds, this office refutes claims that delays



would be incurred resulting from a 12 MOD capacity limit at  Clavey Road.




The question is one of time required to purchase a site and construct a



plant on the Des Plaines River so as to minimize potential hydraulic




overloading at Clavey Road.  Substantial delays could arise due to the




District's lack of "quick take" eminent domain power and the lack of




flexible statutory provisions allowing construction outside present




District boundaries.  As noted in the text, 12 MOD is the estimated



flow to Clavey Road upon phase out of the 5 smaller lakeside plants.



Additional flows would depend on intensity of future development and




the status of the Illinois Pollution  Control Board imposed sewer ban




on the District.  An interim solution could involve the use of chemical




coagulants and/or polyelectrolytes.  The Des Plaines  River plant would
                                 U3

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not effect the timing of immediate phaseout of the lakeside plants,




but could result in undesirable side effects at Clavey Road should its



construction be impaired.






     In regard  to objection number two the text of this statement dis-




cusses fully the pertinent factors.  In essence, the precipitant factor




leading to the Water Program Office position on complete covering of




the retention basin (given the unique requirements of this particular




project), was our evaluation of an obligation under the Natural Environ-



mental Policy Act of 1969.  The public health considerations cannot be




dismissed in this case.  Complete covering is necessary to insure that




maximum safeguards are provided to protect the immediate population from




possible odors and airborne infection.






     Objection  number three stems from a lack of understanding by many



people as to the areawide sewerage needs of the District.  To those so




inclined, it is submitted that what was proposed by this office is a



master wastewater management plan for this area to the year 1990.  Un-



like the NSSD proposal which would only be adequate to serve sewerage



needs in the Southern portion of the District to 1980, it becomes ob-



vious that additional expenditures are, in fact, required.  The Water




Program Office data quite realistically estimates what the needed addi-



tional treatment will cost.  In the last analysis, the longer the NSSD




waits to develop a Des Plaines River site, the higher the costs will

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rise and in all probability,  the more  difficult it,  will be to snc.irt;




the necessary land.






     The determination of relative  impact  on  the environment, yields the




conclusion that there is no  significant  difference  when conjl-ierinn '»




i;  KGD plant versus an 18 MOD operation, given  the  highest Jeve.i  of




environmental controls and safeguards  herein  identified for Lhe  i.iv.y




Road plant.

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RECOMMENDATIONS



     Based en the review and discussions contained in the preceding


Lext, the Wpber Program Office recommends:



     1.  The North Shore Sanitary District proceed with the total sewer-

         age project as originally proposed and outlined on pages 1 and


         '/ of this document, but with the following additions:



         a.  To meet environmental considerations, additional stonnwater

             retention and/or treatment be prcvided as necessary at

             tfaukegan and North Chicago.



         b.  The Clavey Road treatment plant  provide the necessary ad-

             vanced waste treatment unit processes for direct, discharge
                                                               (
             to the Skokie Paver and the retention oasin be covered to

             protect the local residents from objectionable odors and

             potential airborne infections.



     2.  The effluent lagoon nearing completion at Clavey Road be oper-

         ated and maintained only until such time as newly required

         advanced waste treatment units become operational.



     3.  The North Shore Sanitary District is advised to purchase a site

         for a treatment facility on the Des Plaines River near the Lake-

         Cook County Line and to find the means necessary to do so.  The

         site should be developed in the  near future for a treatment

         facility of appropriate capacity.

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U.  The North Shore Sanitary District is advised to limit environ-




    mental damage during construction and to restore disrupted areas




    to their former condition.






3'.  The North Shore Sanitary District is advised to landscape their




    facilities in a manner which will minimize the environmental




    impact cf the facilities on neighboring areas.  Buffer zones




    of vegetation should be created in the immediate proximity to




    treatment facilities.






6.  The Hater Program Office of the  U.  S.  Environmental Protection




    Agency is advised to initiate a study under controlled condi-




    tions to ascertain the possibility of airborne infection from




    sewage treatment facilities.
                               hi

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                      APPENDIX A
COMMENTS RECEIVED ON DRAFT ENVIRONMENTAL IMPACT STATEMENT

-------
 ALLEN J. ELL1CNDBR, LA , CHAIRMAN
OMN L. MCCl-FLLAN. ARK.
kfARREN S. MAGNUSON, WASH.
DHN C. STENNIS, MISS.
   O. PASTORE. H.I.
ALAN BIBLE. NEV.
ROBERT C. BYRD. W.VA.
GALE W. MCGEE. WYO.
MIKE MANSFIELD. MONT.
WILUAM PROXMIRC. WIS.
JOSEPH M. MONTOYA, N. ME
DANIEL K. INOUYE, HAWAII
CRNCSTF. HOU-INGS, S.C.
           MILTON H. YOUNG, N. DAX.
           KAHL E. MUNDT, 3. DAK,
           MARGARET CHASE SMITH, M.
           ROMAN L. HRUSKA, NEBR.
           GORDON ALLOTT, COLO.
           NOHRIS COTTON, N.H.
           CLIFFORD P. CASE, N.J.
           HIRAM L. FONO, HAWAII
           J. CALEB BOGO3, DEL.
           CHARLES H. PERCY, ILL.
           EDWARD W. BROOKI, MAM.
   THOMAS J. SCOTT. CHIEP CLERK.
   WM. W. WOODRUFF, COUNSKL.
COMMITTEE ON APPROPRIATIONS

  WASHINGTON, O.C. 20510
July 8, 1971
The Honorable  William D. Ruckelshaus
Administrator, Environmental Protection Agency
1626 K Street, N.W.
Washington,  B.C.   20460

Dear Mr.  Ruckelshaus:

When the  Region V Water Quality Office of the Environmental  Protection
Agency submitted  its  draft environmental impact statement  on April 23, 1971,
relative  to  the proposed expansion of sewage treatment  facilities in the
North Shore  Sanitary  District, we, who represent  the  citizens of  Illinois
directly  concerned in this matter, took exception to  portions of  that
statement.   The basis for our dissent has not changed but  has,  indeed, been
heightened by  the fact that each day's delay in solving this problem
results in a continued deterioration of the condition of Lake Michigan.

Inasmuch  as  we have already made known our views on the urgency of this
situation, it  should  not be necessary to now go into  great detail.  Never-
theless,  it  may be helpful to you in passing upon the regional  assessment
to have before you our combined statement in which we strongly  urge the
following:

    1)  That you  totally reject those portions of the regional  assessment
which would  limit  the Clavey Road plant to a capacity of 12  MGD;

    2)  That the March 31st order of the Illinois Pollution  Control Board
relating  to  the proposed construction of an 18 MGD plant at  Clavey Road be
supported by the  Environmental Protection Agency -- an  action which would
be in harmony  with the Congressional intent that state  programs to abate
pollution of interstate or navigable waters shall be encouraged and that
solutions to environmental problems be arrived at in a  spirit of  coopera-
tion between federal  and state agencies (33 U.S.C.A. §1160 (b)  and 42 U.S.C.A.,
§4331);

    3)  That the  severe economic hardship occasioned by  the  delay in
construction be carefully considered in determining a date for  the release
of federal funds  previously authorized for this project;

    4)  That the  200,000 residents of the North Shore Sanitary  District,
who would be most  directly affected by the continued pollution  of Lake
Michigan, be given the greatest consideration in the formulation  of your
final decision.

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Page 2
In bringing these matters to your personal attention, we are keenly aware
that a relatively small number of our constituents firmly hold to a
different view.  We fully expect that their interests will not be ignored
nor jeopardized by the development of the Clavey Road plant or other parts
of the NSSD project as designed, and as approved by the Illinois Pollution
Control Board.

In conclusion, we are aware that you are being called upon to resolve
difficult questions which have been presented in this instance, and we
wish to assure you of our cooperation to the end that the sewage collection
and treatment needs of the area may be served, and that Lake Michigan may
be preserved for the use and enjoyment of this and future generations.

Sincerely,
Charles H. Percy/vm
United States Senator
                 ZL*^*-*^   Y
Adlai E. Stevenson, III
United States Senator
Robert McClory
United States Representative

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ROBERT McCLORY                                                            MO,,=L-OFFICF BUIL...NO

 *2r . DISTRICT, ILLINOIS                                                               '  ! *"  " "^

                                                                           DISTRICT  OFFICE
 JUDICIARY COMMITTEE                                                            POST OFF.CE BuiLomo
                                                                         326 NORTH Gi Nfirr STRTT
   SUOCOMM.TTEES             ^ U il U i C X> 55 UU iljt VUIUVC'V 5&iU\r^3           WAUKEGAN ILLINO.S 600o5
    ANT1TRUiT                              _                                   (312) 336-455^
  SUBMERGED LANDS
of tije ®niteu ^tate^
 of
    «, 53.C. 20515
                                      iMay 7,  1971
          Mr. Francis T. Mayo
          Regional Coordinator
          Environmental  Protection Agency
          33 East Congress  Parkway
          Chicago, Illinois  60605

          Dear Mr. Mayo:

          On behalf of over 200,000 residents in the North Shore Sanitary
          District whose ecological and  economic wellbeing depends upon the
          immediate expansion of  sewage  treatment facilities *- and in the
          paramount interest of preventing  the spoilage of Lake Michigan --
          I take serious exception to  the draft environmental assessment
          prepared by the Region  5 Water Quality Office of the Environmental
          Protection Agency.

          In communicating  my views on the  proposed plan for sewage disposal
          by the North Shore Sanitary  District, I wish to comment very di-
          rectly and succinctly as follows:

                    1) The  prime  objective  of eliminating inadequately
                    treated  sewage from  Lake  Michigan (including some
                    untreated sewage effluents) would be substantially
                    thwarted by the alternative reconKnendations con-
                    tained  in the  Regional  Office draft report;

                    2) The  proposal for  establishing an additional
                    treatment facility along  the Des Plaines River at
                    some distance  from the  so-called Clavey Road plant
                    would require  detailed  studies and the development
                    of additional  engineering plans by enlarging the
                    borders  of the North Shore Sanitary District by ref-
                    erendum  or by  legislation to empower the North Shore
                    Sanitary District  to acquire rights of way as well
                    as a substantial area of  property abutting the Des
                    Plaines River;

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3) Tl"? subject of covers for the overflow basins
at .he Clavey Road plant was reviewed by personnel
of .he federal Water Pollution Control Agency more
th.an a yea:; ago and was determined to be unnecessary.
In any event, a recommendation made to the contrary
at this tine should also include a recommendation
t>or additional Federal funds be made available for
A) The proposed capacity of the Clavey Road plant
was negotiated by the North Shore Sanitary District
with the City of Highland Park prior to Federal in-
tervention in the project, and the 18 MGD capacity
was determined at that time as a minimum requisite
to serve the needs of the district -- both current
and projected;

5) The proposals set forth by the North Shore Sanitary
District were made pursuant to the negotiations refer-
enced above; and on March 31, 1971, the Illinois Pol-
lution Control Board rendered an opinion which speci-
fically ordered the construction of an 18 MGD facility --
"immediately and expeditiously;"

6) The draft recommendation of the Regional Office
contributes to an indefinite delay -- pending which
much needed new construction of homes (including
residential and multi-family dwellings for lower and
middle income groups, elderly citizens, minorities,
and others) will be deferred by order of the Illinois
Pollution Control Board;

7) It was obviously never intended by the Congress
that legislative measures aimed at protecting the
environment should be interpreted  in a manner which
prolongs pollution.  With respect  to "enforcement
measures" against pollution of interstate or navigable
waters Congress has specified:  "Consistent with the
policy declaration of this chapter, State and inter-
state action  to abate pollution of interstate or navi-
gable waters  shall be encouraged and shall not, except
as otherwise  provided by  or pursuant to court order  .  .  .
be displaced  by Federal enforcement action."  (33  U.S.C.A.
§1160(b))    In  this  instance, the  Regional recommenda-
tions would delay pollution abatement, stymie building
activities, and destroy state initiative.

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There are, of course, other additional arguments -- many of
which will be set forth in comments supplied by other persons
and agencies.  In my opinion, the concession made in Region 5's
draft summary of the Environmental Impact Statement that  'the
overall project is sound" is the paramount consideration which
should emanate from the federal level.  Efforts to thwart, cir-
cumvent, or override a state plan which has been scientifically
engineered for water pollution control, approved by the voters,
and ordered enforced by an agency such as the Illinois V.'ater
Pollution Control Board can only lead to the type of federal
intervention which frustrates state and local cooperation.

I am taking the liberty of attaching four communications which
I have received recently -- all of which emphasize the urgency
of an opinion consistent with the position taken by the Illinois
Pollution Control Board.

If you care to direct any questions to me, I shall be pleased to
hear from you.
                                     Sincerely,
                                     Robert McClory
                                     Member of Congress
RMcC/jwQ
cc:  Senator Charles Percy
     Senator Adlai Stevenson
     Governor Richard B. Ogilvie
     Mr. Viilliatn D« Ruckelshaus, Administrator
        Environmental Protection Agency

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  ALLEN J. ELLENDER, LA., CHAIRMAN
JOHN L. MCCLELLAN, ARK.
WARREN G. MAGNUSON, WASH.
JOHN C. STENNIS, MISS.
JOHN O. PASTORE, R.I.
ALAN BIBLE, NEV.
ROBERT C. BYRO, W. VA.
SALE W. MCGEE, WYO.
MIKE MANSFIELD, MONT,
WILLIAM PROXMIf»E, W1S.
JOSEPH M. MONTOVA, N. MEX.
DANIEL K. INOUYE. HAWAII
ERNEST F. HOLLINGS, S.C.
MILTON R. YOUNG, N. DAK.
KARL E. MUNDT, S. DAK,
MARGARET CHASE SMITH, MAINg
ROMAN L.. HRUSKA, NESR.
GORDON ALLOTT, COLO.
NORRIS COTTON, N.H.
CLIFFORD P. CASE. N.J.
HIRAM L. FONG, HAWAII
J. CALEB BOGGS, DEL.
CHARLES H. PERCY, ILL.
EDWARD W. BROOKE, MASS.
                                    COMMITTEE ON APPROPRIATIONS

                                      WASHINGTON D C  205 1 0
                                      WASHING 1 Of*. 1~/.O.  4UO I U
   THOMAS J. SCOTT, CHIEF CLERK
   WM. W. WOODRUFF, COUNSEL
May 11, 1971
Mr,  Francis  T.  Mayo
Regional  Coordinator
Environmental Protection Agency
33 East Congress  Parkway
Chicago,  Illinois  60605

Dear Mr.  Mayo:

I have had several discussions  with Representative Robert McClory
regarding the  immediate expansion of sewerage facilities  of the
North Shore Sanitary District and preventing spoilage of Lake
Michigan.

I have read Representative McClory's letter of May 7, 1971 to you
in which he takes  exception to the draft environmental assessment
prepared by the  Region 5 Water Quality  Office of the  Environmental
Protection Agency.

The  litmus test which should be applied  is to determine how over all
environmental control can be achieved.  In my judgment a delay is
unwarranted and unnecessary and is detrimental to reaching  the
objectives desired.

After considerable study I support the points Representative  McClory
makes in his  letter and join him in urging that the Environmental
Protection Agency take a position consistent with that taken by the
Illinois Pollution Control Board.

Sincerely,
 Charles H. Percy/ihb
 United States Senator

cc:  Governor  Pichard B.  OsilT"ie
     Mr. William D. Ruckelshaus

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       McCUORY
 IZTH DISTRICT, ILUNOIS

 JUDICIARY COMMITTEE

   SUBCOMMITTEES:
     ANTITRUST
   SUBMERGED LANDS

     MEMBER:
U.S. INTERPARLIAMENTARY
  UNION DELEGATION
of t&e ®mteb
 of
      ROOM 426
CANNON HOUSE OFFICE BUILDING
    (202) 225-5221

   DISTRICT OFFICE:
   POST OFF'CE BUILDING
 326 NORTH GENESEE STREET
 WAUKEGAN, ILLINOIS 60085
     (312) 336-4554
     , B.C.  20515
  May 21,  1971
        Mr.  Francis T. Mayo
        Regional Coordinator
        Environmental Protection  A.gency
        33 East Congress Parkway
        Chicago, Illinois  60605

        Dear Mr. Mayo:

        This morning  I received a copy of the letter which Mr.  Alfred W. Lewis,
        Attorney for  the Village  of Riverwoods, sent to  you regarding the Draft
        Environmental Impact  Statement prepared by your  office  on April 21, 1971.

        While I have  already  responded to the draft statement in my letter of May  7,
        I am adding this supplement to my position in  the firm  belief that if the
        region's recommendations  were carried out, the consequences would be devas-
        tating — not only for  the environmental protection of  Lake Michigan but
        also in terms of formulating any plan whatsoever which  would be acceptable
        to the people of northern Illinois.

        At this time  I would  only emphasize the comments made by Mr. Lewis which
        indicate that there would be very serious opposition from the citizens of
        the Village of Riverwoods and surrounding area should the federal recommenda
        tions be adopted.  I  would urge you, therefore,  to give very strong con-
        sideration to the response which you received  from the  President and
        the Board of  Trustees of  the Village of Riverwoods.

        In conclusion, I would  like to say that I greatly appreciate the efforts
        expended by your office to give full and fair  consideration to all of the
        citizens who  are concerned with the serious problems ccnfrenting our joint
        efforts to combat the spoil/1?;•• of Lake Michigan.   I am  hopeful, as you are,
        for an early  resolution to this dilemma — which,  I trust, will work the most
        good for the  greatest amount of people, and will inconvenience as few
        individuals as possible.
                                                   L
        RMcC/gc
        cc: Mr. Raymond Anderson,  North Shore
                               Sanitary District
            The Hon. Charles  Percy
            The Hon. Adlai  Stevenson
            William Ruckelshaus,  Administrator; EPA
                  Robert IicClo#

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  ^EIT Of

<.*'" M -111 \

"* Hi}1 -ill's * °     DEPARTMENT OF HOUSING AND  URBAN  DEVELOPMENT
        .?           360 NORTH MICHIGAN AVENUE, CHICAGO, ILLINOIS 60601
  °?-»«30 *•**

                             April 30,  1971
  REGION V

     .                                                             IN REPLY REFER TO:
                                                                         5M
  Regional Director
  Attention: Mr. Gary Schenzel
  Water Quality Office
  U. S. Environmental Protection Agency
  Room 410, 33 East Congress Parkway
  Chicago, Illinois 60605

  Dear Sir:

  This is in reference to Mr. Risley's  letter  of April 22,  1971 addressed  to
  Mr. Vavoulis regarding the Draft Environmental Impact Statement concerning
  the application of the North Shore Sanitary  District of Waukegan  for  a sewer-
  age project located in eastern Lake County,  Illinois (Sewerage Project Number
  WPC-I11.-754).

  HUD COMMENT
  Our general assessment of the Environmental  Statement reviewed is  that it
  is adequate.  We have benefited from  the observations of  local groups  (e.g.,
  The Committee to Save Highland Park) which contacted this office  to voice
  objections to this project in its original form and to submit to  us various
  documentation substantiating their position.  The most noteworthy  issues in
  opposition were raised in the areas (1) "airborne disease"  (comments made by
  Dr. Bertram W. Carnow, M.D., F.C.C.P.), an area of general  concern as  evidenced
  in the recommendation of your Agency, but not within HUD's  jurisdiction  "by
  law or special expertise", and of (2) alternative sites.

  In the latter area it has been alleged that  a more appropriate alternative
  site for the plant should have been selected.  This brings  in the  issues of
  the propriety of land use and zoning  and consistency with comprehensive  plan-
  ning.  On this issue HUD has jurisdiction by law and special expertise,  relying
  heavily on the recognized areawide planning  organization  (APO) for a  substan-
  tive position.  The Northeastern Illinois Planning Commission (NIPC)  is  the
  APO for the area including the project area.  NIPC endorsed the subject  pro-
  ject in its original form as consistent with the areawide comprehensive  plan.
  Therefore, HUD, in the absence of evidence of flagrant violations  in compre-
  hensive planning fundamentals, expresses no  objection to  the proposed  project
  subject to the exceptions noted in your recommendations.  This view is supported
  by the conclusions reached by state and local agencies that prompt expansion
  of treatment facilities is necessary  to prevent further pollution  problems and
  insure proper development of the project area.

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                                                                             2.

HUD RESERVATIONS
We recognize that some general land use plans (especially in large multi-county
areas) do not contain sufficient detail to indicate the desired location of
future sanitary treatment plants.  In such cases, an APO statement that a given
proposed location is consistent with the comprehensive plan may not be an en-
dorsement of a given proposal as best or most appropriately located.   There
was evidence submitted by local groups suggesting that NIPC's endorsement of
the project as originally proposed was ambiguous and based upon insufficient
data.  Under the circumstances of your recommended modifications in the pro-
ject, we suggest that NIPC's further comment upon the project be solicited.
This issue remains a local matter in which HUD's interests may best be served
by local resolution of conflicting considerations.

                                Sincerely,

                                   "       /       "^
                                                          s

                                Edward M.  Levin, Jr.
                                Environmental Clearance Officer

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                   DEPARTMENT OF THE ARMY
              NORTH CENTRAL DIVISION, CORPS OF ENGINEERS
                        536 SOUTH CLARK STREET
                        CHICAGO, ILLINOIS 6O6O5
NCDPD-ER
Regional Director
U. S. Environmental Protection Agency  Region V
Attn:  Mr. Gary Schenzsi
Water Quality Office
Room k-LO,  23 E. Congress  Parkway
Chicago, Illinois  60605
Dear Sir:

This is in reply  to  your  letter to Col.  J.  E.  Newman,  Exe:ati'-e Director
of Civil Works, Office  of the  Chief o;  Engineer.;,  Wa.;hin,;t;:-., D. C.
dated 22 April  1971-  You request commentc  or.  a Draft  Environmental
Impact Statement  for a  proposed sewerage project cy ~ne ?;crth Shcr-:
Sanitary District of Waukegan,  Illinois.

The draft environmental statement has  ceen  r:"i:-..3rj and 1; .on: id'i'--'l
satisfactory.  We do feel that  this and future -3i" -?rsions -./ill in:ieac;e
flooding on  the Des  Plaines  River.   Seme communifie: nov suffiling from
flooding will certainly be affected cy  these di^er;Ljnc.  Flood ;-c
studies underway  in  the Chicago District may help  tc alleviate tnis
problem.
                                    JAMES  W,  GILLAN35
                                    Colc-."ol,  Corp.7 of Engineer.-
                                    ""•;•'.'.,.  r;ivi:-i^n Engineer i;-
                                    C - ;ii  I\.r.ctio,'.s

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                 OFFICE  OF THE SECRETARY OF TRANSPORTATION
                            WASHINGTON, D.C.  20590
ASSISTANT SECRETARY
      Regional  Director
      Water  Quality Office
      U.  S.  Environmental Protection
        Agency, Region V
      Attention:   Mr.  Gary Schenzel
      Room 410
      33  East Congress Parkway
      Chicago,  Illinois  60605

      Dear Sir:

      Thank  you for sending us a copy of the draft environmental  impact

      statement for a sewerage project in eastern Lake County,  Illinois,

      Since  it  appears that this project has no transportation  implica-

      tions,  we have no comments to offer on the draft statement.

                                        Sincerely,
                                  i      Herbert F. DeSimone
                                  Ji v~\  Assistant Secretary  for
                                  ,'•'     Environment and Urban  Systems

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            DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

                         OFFICE OF THE SECRETARY

                           WASHINGTON, D C  20201
Mr. Clifford Risley, Jr.
Acting Regional Director
Water Quality Office
Environmental Protection Agency
Chicago, Illinois  60605

Dear Mr. Paisley:

This is in response to your letter of April 22 requesting comments
on the Draft Environmental Impact Statement for a sewerage project
located in eastern Lake County, Illinois.

The project consists of construction of a new sewage treatment facility
at Gurnee, Illinois, and expansion and renovation of present plants at
North Chicago, Waukegan and Clavey Road.  These plants will feature
tertiary treatment and nutrient removal.

Tne effects of  construction of this project will fall primarily in
the area of water quality which is now a responsibility of the
Environmental Protection Agency.  We have discussed this project
briefly with staff members of that Agency, and will defer to their
comments and recommendations.

The opportunity to review this Draft Environmental Impact Statement ^  ~
is appreciated.                                         s          ^,_' ..

                                    Sincerely yours,  ,-'
                                                         .._
                                    Roger O. Egeberg, M/b.
                                    Assistant Secretary
                                       for Health and Scientific Affairs

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           United States Department of the Interior

                       OFFICE OF THE SECRETARY
                        WASHINGTON, D C.  20240

                                           JUN   8  1S71
Dear Mr.  Risley:

On April  22,  1971 you requested our comments  on  the  draft  environmental
statement prepared by the Environmental  Protection Agency  for the North
Shore Sanitary District's proposed sewage  project in eastern Lake County,
Illinois.

This report has been reviewed by various units of this  Department having
special expertise in fields covered by the draft statement, and their
comments  are  included in this letter.

We are impressed with the thoroughness of  the draft.  The  Water Quality
Office should be commended for its concise appraisal of the positive and
negative  environmental effects of the  project.   If the  program is carried
out as proposed,  the net environmental effect should be most beneficial.

During our review one question arose which the draft statement did not
address.   We  submit this for your consideration. The draft states that
under the mandate of the Lake Michigan Enforcement Conference the sewage-
treatment plants in Lake County now discharging  effluent to Lake Michigan
must by July 1, 1972 either divert these effluents to inland rivers or
substantially upgrade them through additional treatment.   The proposed plan
would accomplish the former.  In the event that  the  proposed facilities are
not ready to begin operation by July 1,  1972, it is  not clear what will be
done with Lake County's sewage.  Will  treated sewage continue to be dis-
charged to Lake Michigan or will partially treated and  untreated sewage be
discharged to the Des Plaines River basin  with obvious  adverse impact?  It
is our understanding that construction of  the key treatment plant in the
system has been delayed by litigation, and that  it is possible that the
July 1, 1972 deadline for start-up may not be met.   We  suggest that this
eventuality be discussed in the revised environmental statement,

While no primary recreation benefits would result from  the project, the
proposal  would improve the water quality of Lake Michigan  and the Des
Plaines and Skokie River basins, thus  increasing recreational opportuni-
ties.  The statement recognizes that a limited amount of open space would
be created as the five plants are phased out  and utilized  as pumping
stations.  We feel that assurances should  be  given to insure that these
lands remain in open space in the future.   In this regard, we suggest

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that the applicant contact Mr.  Matthew L.  Rockwell, Executive Director,
Northeast Illinois Planning Commission,  400 West Madison Street, Chicago,
Illinois 60606, and Mr.  Henry N.  Barkhausen, Director, Department of
Conservation, 102 State  Office Building, Springfield, Illinois 62706.  They
would be in the best position to assess  the recreational potentials of
these sites and make recommendations for the public use of these areas as
they are phased out.

The environmental statement should further indicate that the National
Register of Historic Places was consulted and that the development will
not have any adverse effect upon important 'Historical and archeological
resources, if that is the case.  Also, the State Liaison Office should be
consulted to determine whether the project would have an effect on prop-
erties being considered for nomination to the National Register.  The
results of such consultation should be reflected in the statement.

We appreciate the opportunity to review the draft statement and offer
comments.

                                    Sincerely yours,
                                    Secretary of the Interior
Mr. Clifford Risley, Jr.
Acting Regional Director, Region V
Environmental Protection Agency
33 East Congress Parkway
Chicago, Illinois 60605

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OTTIOHAI. FOWW NO. !«
MAT INI EDfTION
SSA milt (41 em) 101-1I.«
                                                  DATE:  Mav 20'
        UNITED STATES GOVERNMENT

        Memorandum

TO    :  Francis T. Mayo
         Interim Regional Coordinator,  EPA

FROM  :  F.  Donald Maddox, P.E.
         Acting Regional Representative,  EWH

SUBJECT:  Review of "Environmental Assessment Study" prepared by Committee to
         Save  Highland Park
 At Mr.  Marshall's request, I have reviewed  Appendix B of the subject
 Assessment  Study.  My review indicates that the health effects of
 concern are not related to public drinking  water supply, although
 potential pollution of ground water by seepage from the planned
 lagoons is  mentioned by Dr. Rogoff's statement on  "A Microbiological
 Viewpoint."

 Of primary  concern, as expressed by Dr. Carnow's statement, are the
 gaseous pollutants and the particulate pollutants, including aerosols
 containing  bacterial and viral pathogens, which may be emitted by
 the plant.   An evaluation of the accuracy and reliability of the
 statements  made regarding the health effects of possible airborne
 pollutants  would be most appropriate from the expertise available
 through Mr. Van Mersbergen's officeo  We understand that Mr. Van
 Mersbergen  has received a copy of this document for review.
         Buy U.S. Savings Bands 'R.tgularly on the Payroll Savings Plan

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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Washington, D. C. 20250
Regional Director
Water Quality Office
U.S. Environmental Protection Agency
Region V
Room 410, 33 East Congress Parkway
Chicago, Illinois   60605

Attention:  Mr. Gary Schenzel

Dear Sir:

The draft environmental impact statement for a sewerage project located
in eastern Lake County, Illinois, which was sent to Dr. T. C. Byerly
with a letter dated April 22, 1971, was forwarded to the Soil Conserva-
tion Service for review.

The data submitted with the impact statement shows that interested
agencies have made a thorough review and comments on the "Environmental
Assessment."

Our only comment is concerning Item 3 of the recommendations on page 37.
The impact statement refers to limiting environmental damage during con-
struction.  This is a very broad and all inclusive recommendation.  In
our opinion, this should be more specific.  The three items listed in
Mr. William Q. Kehr's letter of December 29, 1970, from the EPA Solid
Wastes Office should be included in these recommendations to specify the
types of environmental damage in mind during construction.

We are pleased to see that our State Conservationist for Illinois,
Mr. Howard W. Busch, has had an opportunity to review the environmental
assessment for this project.

We appreciated the opportunity to review this environmental statement.

Sincerely,

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                     O7?:SS 0? THE A3S5STASMT SECRETAHY C~ CC"
                     Washington, D.C. 20230
                                                    /!   '
                                                        / I  '  ' .
                                                    > '•>' -  .  /
May 11,  1971
                           Reference ;     Sewerage Project No. WPC
                                          111. 754, North Shore
                                      	Sanitary District	
                                      	Waukegan, Illinois
                              Dated:	April 21. 1971	"__
                         DoC-Document Control Number: 7105.10
Mr.  Clifford Risley, Jr.
Actg. Regional Director
Region V
Environmental Protection Agency
33 East Congress Parkway, Rm 410
Chicago,  Illinois 60605

Dear  Mr. Risley:

Your request for review of the  referenced  document  has bee"
received by  this office.  In order to assure proper evs.lv/ -
ticn by  all  appropriate agencies within the  Department c::
Commerce, we shall require  3 additional copies of  this
draft  statement.  Our comments,  if any, will be  forthcoming
30 days following receipt of these copies.
We request  that in the future all environmental impact
statements  directed  to any agency of the Department of
Commerce. __for__c^mment be.. tr-ransmltfced in 15  copies  to the_
Deputy Assistant Secretary  for  Environmental Affairs for
review and  further^distribution as appropriate.

Sincerely,
Sidney R.  Caller  '-^.J
Deputy Assistant Secretary
tor ;Environmental Affairs

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                ENVIRONMENTAL PROTECTION AGENCY
                    Office of Air Programs
   411 West Chapel Hill Street,  Durham,  North Carolina 27701
                        May 27,  1971
Mr. R. J. Schneider
Acting Regional Director, Region V
Office of Water Programs
Environmental Protection Agency
33 East Congress Parkway - Room 410
Chicago, Illinois 60605

Dear Mr. Schneider:

Mr. Joseph J. Sableski of our Division has reviewed your Environ-

mental Impact Statement for North Shore Sanitary District,  Chicago;

enclosed are his comments with which I concur.
                                   S. David Shearer
                                   Chief, National Source
                                   Inventory Section,  DAT
Enclosure

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                        ENVIRONMENTAL PROTECTION AGENCY

                               Office of Air Programs
Reply to
 Attn of:                                                              Date

 Subject:    Review  and  Comments  on  Environmental  Impact Statement
          for  North Shore  Sanitary District, Chicago

   To:   .Dr.  David S.  Shearer, Chief
          National Source  Inventory Section
          Division of Applied  Technology


          As requested, we have reviewed the Draft Environmental  Impact Statement
          and  appendices for modifications to tne treatment plants of the North
          Shore Sanitary District in Waukegan,  Illinois.

              Estimate  of  the  Situation

              According to our understanding of the impact statement, the air
              pollution problem arises from plans of the  NSSD to  increase the
              size of the  Cleivey Road Sewage Treatment Plant from  its present
              4.5 MGD capacity to 18 MGD.  Over the years, homes  have been
              built to  within  150 yards of the  present facilities, and these
              homeowners now object to the expansion of the plant.  They have,
              in  fact,  initiated legal action pursuant to which testimony has
              been  given that  odors from the plant will be a nuisance, that
              emissions of airborne viruses and pathogenic organisms will
              occur,  ana that  S0? concentrations from incineration of sewage
              gases will be excessive.

              The impact statement shows that the MSSD proposes to cover
              virtually every  possible source of odorous  emissions, ventilate
              the sources, and either scrub the gases with permanganate
              solutions or incinerate them.  In addition, NSSD proposes to take
              ten separate actions, in Section  5 of the Appendix,  to reduce
              emissions.  Among these actions is a proposal to remove hydrogen
              sulfide from the sludge gas by passing all  gas through iron
              sponge  purifiers before burning.

              Evaluation of Problem Areas

              In  his  doctoral  thesis entitled,  "The Emission, Identification,
              and Fate  of Bacteria Airborne from Activated Sludge  and Extended
              Aeration  Sewerage Treatment Plants", Paul Kenline reports that
              bacterial concentrations in air from such plants decrease rapidly
              with distance from the plant.  For example, contamination of the
              surrounding  air  extended to approximately 65 feet downwind of
              aeration  tanks under average conditions existing during sampling
              around  an activated sludge plant.  For more adverse  conditions,
              contaminants extended out to approximately 200 feet.  These
              findings  were for an uncontrolled plant.

-------
Page 3 - Dr. David S. Shearer
    odorless, or have a milder, much less offensive odor than the
    original compound.

    The literature does contain references to the use of permanganate
    scrubbers for odor control from tallow manufacturing: the drying
    of animal proteins, fats, blood, and feathers; varnish cooking;
    chicken processing; and the processing of animal hides,

    While three different oxidation reactions can take place, depe.i.'ing
    on the pH of the solution, probably the most effective reaction is
    that taking place from pH 3-11.

                     Mn04" + 4H+ + 3e~ -> Mn02 + 2H20

    The solutions are non-corrosive, and the MnCL formed is insoluble,
    and therefore not a water pollutant, as mignt be the case with
    other manganese salts formed at other pH's.

    Conclusions

    While the literature does not reveal the effectiveness of per-
    manganate scrubbers in killing airborne infectious agents, it
    would seem reasonable to believe that a powerful cxidizing agent
    would have such an effect.  In addition, the thesis by Dr. Kenline
    shows that the infectious agents are not dispensed in significant
    quantities from uncontrolled plants.  It is probably, therefore,
    that no oiological contamination will take place from this plant
    where all sources are covered and vented to controls.

    From the literature, it appears that the scrubbers should eliminate
    odors provided that:

        a.  The pH of the scrubbing solution is controlled between
            8 and 9 by use of a buffered solution (e.g. bicarbonates
            or borates).

        b.  Since the absorption time for the odorous compound to get
            into^solution is often the  rate-controlling step, a
            percKed tower should be used to  create  surface area.
             (This is  the type NSSD plans to  use.)

        c.  The KMnCL solution strength  should be maintained  between
             1 percent and 3  percent.  Concentrations of 0.001 percent
             to 0.1 percent are reported  to  be  ineffective.

        d.  While not a  reauirement,  the NSSD  may find that  a water
             scrubber  installed before the  KMnCL  scrubber  may  reduce
             the permanganate  requirements  and  hence,  the  operating
             costs, considerably.

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Page 2 - Dr. David S. Shearer
    The practice of hooding, or enclosing in buildings,  the various
    sources in a treatment plant is not a common one.   I  have,  however,
    seen several plants equipped with hooding, to some extent.   While
    it is not possible to judge with certainty from the  block flow
    diagrams in the impact statement the adequacy of the  ventilation
    rates at each source, the overall system does ssam to account for
    all significant sources of odorous pollutants.   In general,  the
    system seems well -designed and makes allowance  for extra purging
    of tanks.

    Since incineration of odors is a more positive  control  than
    scrubbing, the NSSD was wise to choose this type of control  for
    handling the most odoriferous gases in the plant,  those from
    sludge thickening, storage, and loading.  In this  connection,
    the 50 CFM from liquid sludge loading looks like it may be
    inadequate, as such operations usually must allow for inspirated
    as well as displaced air.

    The fume oxidizer should be a direct flame afterburner, operating
    at no less than 1200°F and having a residence time of at least
    0.3 second.  Catalytic afterburners are frequently a  source  of
    trouble and are well to avoid.
Kp
in
    Since the NSSD is to install  iron sponge purifiers  to remove
        in the sludge gas, which  I  presume they will  use  as  a  fuel
       the oxidizer, the effluent should not contain  excessive quan-
    tities of sulfur dioxide.   At least, other applications  I  have
    seen of this technique have been successful, so that  this  application
    could be made to work satisfactorily also.  If the  sponge  is
    regenerated, the process should be conducted so as  not to  allow
    the collected sulfur gases to escape to the atmosphere.   Incin-
    eration under the conditions  specified should kill  all pathogens.

    The problem of evaluating  the scrubbers is more involved.   While
    incineration would be the  most effective treatment, there  will
    be approximately 80,000 CFM,  in total, to be treated.  Clearly,
    because of the large volume of gas to be handled, scrubbing,  if
    it is effective, is to be  preferred over incineration for  eco-
    nomic factors alone.

    Sewage odors result from the  decomposition of nitrogen or  sulfur
    containing organics to amines,  indoles, mercaptains,  and various
    other odorous products.  The  odors associated with  these com-
    pounds are often related to the functional group  in the  molecule.
    The chemical bond by which these groups are attached  to  the rest
    of the molecule is often unsaturated and so susceptible  to
    attack by oxidizing agents, of which potassium permanganate is
    one of the most powerful.   The resulting products are often

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Page 4 - Dr.  David S.  Shearer
    The incinerator should perform satisfactorily  if  it  is  of  the
    direct flame type; temperatures exceed  1200°F,  residence time
    exceeds 0.3 second; and good flame  contact  and  turbulence  is
    maintained within it.
    Joseph J. Sableski, Chief
    Combustion and Incineration Section
    Industrial Studies Branch
    Division of Applied Technology

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BOARD OF TRUSTEES
f-'es/dfnt, Robert P. Will, Winthroa Harbor
W-lliam T. Jones. Highland Park
treasurer, Ross A. Granna. Waukegan
Oonalef L Wylie, Lake Forest
       . Richara D New!and. Waukegan
                                                  _t7   7           *i      J* i  '  A
                                             UOrtfl SflOTC SdnUdTy U,lSlTlCt

SECRETARY-GENERAL MANAGER, RAYMOND E. ANDERSON / DAHRINGER ROAD, WAUKE3AN, ILLINOIS 50085 / Telephone: 312/S23-6060
A TTORNEY
Murray R. Conze/man

SUPERINTENDENT OF MAINTENANCE
Joseph J. Debevic

CHIEF ENGINEER                                                  MaY 13, 1971
H. W. flyers
            Mr.  Gary Schenzel
            Federal Environmental Protection Agency
            33 East  Congress Parkway
            Chicago, Illinois   60605

            Dear Mr.  Schenzel:

            Pursuant to the direction of the Trustees of the North Shore Sanitary
            District I am enclosing herewith  the Comments of the District with
            reference to your Draft Environmental Impact Statement dated
            April 21,  1971  and released April 23,  1971.  If you need further
            copies, please  advise.                             i
                                           Yours very truly,
            Enclosure
            MRC:bw                       Murray R. Conaelman
            Murray R.  Conzelman
            Attorney  for North Shore Sanitary District
            33 North  County Street
            Waukegan,  Illinois   60085
            MAjestic 3-1010
                    WATER POLLUTION CONTROL FOR THE LAKE MICHIGAN AREA OF LAKE COUNTY. ILLINOIS

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              COMMENTS OF NORTH SHORE SANITARY DISTRICT
              ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
                FOR SEWERAGE  PROJECT NO. WPC-ILL.-754
       Under date of April 21, 1971, the Water Quality Office Region V of the

Federal Environmental Protection Agency issued its Draft Environmental Impact

Statement concerning Sewerage Project No.  WPC-I11. -754 submitted by North

Shore Sanitary District. That Statement  provides that thirty days are available

for comment following release of the Statement,  which occurred April 23,  1971.

       The following constitutes the comments upon the Statement by the North

Shore Sanitary District. The comments of the District are divided into two major

parts.  The first part concerns the effect of the Statement as a whole on the project

of the North Shore Sanitary District and the  second  part points  out the technical

errors in the Statement.


       SECTION 1:  EFFECT OF STATEMENT AS  A WHOLE.

       On March 31, 1971,  the Illinois Pollution Control Board entered an Order in

its cause No.  PCB 70-7, 12,  13, 14, The League of Women Voters of Illinois, et al v

North Shore Sanitary District. A copy of this Order is attached to these Comments

marked Exhibit 1.  The Order followed six days  of public hearings before the Illinois

Pollution Control Board at which the entire project  was thoroughly discussed.

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       In the Order the North Shore Sanitary District is required to do the follow-




ing things:




               1.  To cease and desist from polluting the waters of Lake Michigan




and the waters of the Skokie Drainage Ditch to the extent reasonably possible until




the construction of additional facilities which are required hereunder.




               2.  To cease and desist from polluting the air at or near its present




facilities to the extent reasonably possible until the  construction of additional facilities




which are required hereunder.




               3,  To immediately and expeditiously  complete its proposed expansion




facilities.  Specifically the District was ordered to proceed  with the expansion of  its




Clavey Road Plant to 18 million gallons per day capacity with advanced treatment  and




to discharge the effluent from this plant into the  Skokie Drainage Ditch even after




expansion.




               4.  To prohibit new connections and extensions of the sewer system until




the District can demonstrate that it can adequately treat the wastes from these new  sourc




       The Federal Impact Statement aforesaid provides different requirements as




follows:




               1.  The District  is ordered to expand  its Clavey Road Plant to only 12




million gallons  per day capacity instead of 18.




               2.  The District  is ordered to re-evaluate the capacity of its  retention




basin at  its Clavey Road Plant and to cover the entire retention basin.




               3.  The District  is ordered to purchase a site for treatment facilities on




the DesPlaines River near the Lake - Cook County Line and immediately build a new




facility with a capacity of approximately 18 million gallons per day at that location.

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              4.  The District is ordered to build additional storm water retention




at Waukegan, North Chicago and the lakeside pumping stations.




       The Trustees of the North Shore Sanitary District have directed their engineers




to carefully study the Environmental Impact Statement and to analyze the effects of that




Statement upon the current program of the District.  Based upon that analysis the




Trustees' findings are as follows:




              1.  If the treatment plants at  Lake Bluff,  Lake Forest and the three lake




front plants in Highland Park were abandoned today and that flow added to the present




flow at Clavey Road, the present flow at Clavey Road would be 12. 1 million  gallons per




day.  The Federal limitation of 12 million gallons per day  would not be adequate and the




expanded plant at  Clavey Road would be overloaded the day it was completed.  As a re-




sult, pollution would continue and the embargo  placed by the State of Illinois on further




connections to the system  would not be lifted at that time but would wait until the new




18 million gallons per day plant would be built on the DesPlaines River.




              2.  The estimated initial cost of providing the additional facilities re-




quired by the Federal Impact Statement at Clavey Road and at the DesPlaines River is




between 25 and 30 million  dollars.  This figure is arrived  at by using the estimates




used by the Federal authorities as follows:  It is estimated that  the cost of a 18 million




gallon per  day plant at Clavey Road would be $20, 444, 000.00.  The middle fork-sewer




is estimated to cost $11, 324,000.00,  or a total of $31, 768, 000.00.  Subtracting the




cost of the cover on the retention basin, which  is $4,000,000.00, there  is a  net total




of $27,768,000.00.  The estimated cost of a 12 million gallon per day plant  at Clavey
                                        -3-

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Road is $13, 566,000.00,  and the estimated cost of a 18 million gallon per day




plant at the DesPlaines River is $39,854,000.00, for a total of $53, 420, 000. 00.




Deducting the  preceding net balance of $27,768,000.00, there is a net difference




of $25, 652, 000. 00, which would be the difference between the two proposals at




March,  1971 construction cost levels.  Based upon our experience, an inflation




factor of from 10 to 15 per cent per year should be added because it is obvious




that  the facilities were not built in March, 1971.  As a result, the estimated initial




difference  between the District's proposal and the  Federal proposal is between 25




and 30 million dollars.




       In other words, the cost of obtaining the present Federal Grant of 11. 55




million  dollars to the taxpayers of the North Shore Sanitary District would be from




25 to 30 million dollars.  In  addition,  the present overloaded conditions of the




sewage treatment facilities of the District would not be relieved until such time as




a site could be acquired and  a new sewage treatment plant built on the DesPlaines




River,
                                        -3A-

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              3.  The area on both sides of the DesPlaines  River for a distance




of a quarter of a mile North of the  Lake - Cook County Line was subdivided many




years ago into the Columbian  Gardens Subdivision comprising hundreds of fifty




foot lots owned by various individuals.  The area North of Columbian Gardens for




a distance of about a half of a mile on both sides of the DesPlaines River lies within




the Village of Riverwoods, a substantial residential community.  There are no sewage




treatment plants in the area.  It is estimated  that a minimum of three years would be




required to obtain a suitable site.  This is a conservative estimate because the North




Shore Sanitary District does not have so-called "quick take" eminent  domain powers




and cannot acquire title to property until an entire domain procedure  has been com-




pleted.  Obviously numerous parcels of land will extend the  time for land acquisition.




        In addition, the District has no  funds to acquire property and its present bond




funds cannot  be  used for purposes not contemplated in the bond issue, nor can they be




used outside  of the District and the area of the DesPlaines River is outside the North




Shore Sanitary District.   Assuming these problems  could be eventually solved, it would




take an additional  three years to design and construct a plant, so that at the very




minimum, assuming no further delays  or litigation, it would be at least six years be-




fore a new plant could be completed.




        The Federal requirement that the retention basin at the Clavey Road Plant be




re-evaluated and completely covered presents an anomaly.  The requirement that the




basin be covered was found to be unreasonable by the  Circuit Court of Lake County,




Illinois after an extensive trial on the question and this Court's decision has recently
                                        -4-

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been upheld by the Appellate Court for the Second District of Illinois,  (Licata, et

al v. North Shore Sanitary District, Appellate Court, Second District,  Nos.  70-

133 and 70-162).  Over a year ago the Federal Water Pollution Control Agency re-

viewed this requirement and determined that the cover was not necessary.  The  City

of Highland Park, upon a review, has found that it is only necessary to cover the

presedimentation portion of the retention basin and not the whole basin,  and finally,

the Illinois Pollution Control Board has found that  it is not necessary to cover the

entire retention basin.

       As  a result of the Environmental Impact Statement,  the North Shore Sanitary

District is in a dilemma and cannot comply with the  Illinois Pollution Control Board

Order and the Environmental  Impact Statement at the same time because they have

basic differences.  The District cannot afford the Federal Grant offer and would have

to spend far more to comply with the conditions than it gets from the Federal govern-

ment.  If it attempts to comply with the requirements of the Federal Impact Statement

it will substantially  postpone the day when the pollution of Lake Michigan can end and

any further connection to the District's facilities can be made.  The life of Lake

Michigan may not last that long and the economic effect of a six year ban on consh i

tion in the  North Shore Sanitary District would be catastrophic.

       SECTION 2:  TECHNICAL ERRORS IN DRAFT ENVIRONMENTAL
       IMPACT STATEMENT.

       The North Shore  Sanitary District does not desire to pick apart the Draft

Environmental Impact Statement and tne following comments are limited to correct-

ing those errors of substance which affect the judgment made.
                                        -D-

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       Paragraph 2 on page i indicates that the Grant offer was made on April 22,




1970.  It does not  indicate the fact that this offer was accepted by the North Shore




Sanitary District on May  13, 1970, nor does it indicate that the Federal regulations




requiring an environmental assessment did not become effective until October 1,




1970.




       Throughout the Draft Statement the phrase  "supplemental treatment" is used.




It is felt that a more definitive term is "advanced wastewater treatment".




       Throughout the Statement the District is described as being largely residential.




This is not the case since in the Northern sector and specifically in the Waukegan -




North Chicago area there are substantial concentrations  of heavy industry, whereas




in the Southern sector the area is largely residential.




       On page 5  it is stated that the Planning Commission of the City of Highland




Park recommended "That no Special Permit be granted for the expansion of the Clavey




Road Plant".  In fact,  the exact language of the Planning Commission was  ". . .the Plan




Commission cannot recommend approval of the Petition as submitted by the North Shore




Sanitary District".




       Subsequently the  City of Highland Park did,  in fact,  grant the Special Permit




subject to conditions.  These conditions have been fully litigated and the project of the




District will comply with all of those conditions found to be valid by the Circuit Court,




the Appellate Court and by the Illinois Pollution Control Board.




        On page 10 the Statement considers the probable impact of the District's




project on the Mississippi basin.
                                        -6-

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       On page 38 it advises a broad impact study of the environmental consequences




of diversions of water from one watershed to another.  The North Shore Sanitary




District has had a diversion allocation from Lake Michigan for two and one-half years




pursuant to Order of the Supreme Court of the United States.  The project  of the




District is contingent upon the diversion of Lake Michigan and that question is settled.




If it is necessary to re-evaluate diversion, then it will mean that the last two and  one-




half years has been wasted  and that the District must start all over again with its  pro-




gram. These matters have been resolved and should not be reviewed.




       Paragraph B on page 12 concludes that diversion of effluent into the DesPlames




River will downgrade the quality of the water.  This is not  the fact.  In fact,  the quality




of the water will be upgraded.   Upgrading the quality of any stream inherently results




in the growth of less pollution-tolerant organisms  and is obviously not "an adverse




environmental effect".




       Paragraph C on page 12 contemplates that the effluent from the North Shore




Sanitary District will be the only discharge to the DesPlaines River.  This is not the




fact since the DesPlaines River is  not now  "in its natural state" and it is presently




receiving and will continue to receive other effluent from growing communities witinj;




the DesPlaines River watershed.




       The second paragraph on page 14  states that the Skokie  Lagoons were formerly




used for swimming and boating but that their  use has been curtailed.  The  fact  is that




the Skokie Lagoons were never used for swimming and that their use for boating has




greatly increased  over the past years and is at  its height today.
                                        -7-

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       The first paragraph on page 16 deals with discharging the effluent from




Clavey Road into the  Skokie River.  That, in fact, has been ordered by the  Illinois




Pollution Control Board.




       The so-called inconsistency described on pages 16 and 17 of the Statement is




not in fact  inconsistent  since the two approaches, the first at the Northern end of the




District and the second at the Southern end of the District simply recognizes the fact




that these are different areas.  At the Northern  end of the District  there is heavy




industry and the  Southern end of the District  is largely residential.  The areas are




different and the project treats them differently.  This is not  inconsistent.




       In paragraph A on page 19 again the so-called '"inconsistency" is pointed  out




and it is noted that storm water overflows in the Waukegan area should not  be  allowed




to continue.  As we have already said this is a different area and consists of different




land uses.   In addition, the proposal of the North Shore Sanitary District in this  area




meets all Federal and State water  quality standards and there is no evidence that




occasional overflows of treated storm water  will have a significant adverse effect on




the environment.  It is  unreasonable to request the District to do more than comply




with Federal and State standards to qualify for a Federal Grant.  The District makes




the same comment with reference  to paragraph  1 on page 22 and states further that




the retention is not ''seemingly inadequate" but will,  in fact, comply  with all Federal




and State standards.  In addition, the District is exceeding  existing State and  Federal




standards  at the Southern sector.  The footnote  on page 9 of the Impact Statement




does not,  but should, state that this is not a Federal  requirement but that the District




is doing it  anyway.

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       The statement at the bottom of page 22 that "Possible air-borne infection




may also result from an open retention basin" ignores the testimony of Dr.




Deinhardt and Mr.  Klassen set forth at page  25 of the Statement.  Dr.  Deinhardt




testified that there is no danger from air-borne  infection and Mr. Klassen testified




that in all the history of sewage treatment in Illinois there has been no case of a




person working in the treatment plants becoming ill as a result of his employment.




In addition, even Dr. Carnow testified there  is no danger of air-borne  infections




from quiescent bodies of sewage, but that the problem could arise from bodies of




sewage  under aeration.  Therefore,  it follows that no problem can arise from the




retention basin because the wastewater in the retention basin is quiescent and not




aerated.




       The Metropolitan Sanitary District of Greater Chicago operates a 400 million




gallon per  day plant in the Village of Skokie.  This plant is in a residential area  and




has no covers at all. The Metropolitan District also operates the famous Stickney




Plant, which is  the world's largest sewage treatment plant.  It has a capacity of




1 billion gallons per day but it does not have  any covers.  If  Dr,  Carnow's specula-




tions are to be seriously taken, then these plants should be covered or abandoned




and yet  neither the  Federal nor the State  government have made any such requirements




If they do not constitute a substantial hazard  to health, then obviously a 18 million




gallon per  day plant at Clavey Road  constitutes no hazard.




       The statement in the third paragraph  on page 23 that  a capacity of 12 million




gallons  per day would be adequate for the next several years at  Clavey Road is in-




correct. In fact, the actual flow at the Clavey Road Plant if the lake front plants in




Lake Bluff, Lake Forest and Plighland Park were added was  12, 1 million gallons pei

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day in 1970.  Therefore,  if the Clavey Road Plant were expanded to 12 million




gallons per day it would be overloaded the day it was completed.  The new plant




would downgrade the environment, and it would violate the Environmental Pro-




tection Act of Illinois.  This would continue until such time as a new plant could




be built elsewhere to receive the additional effluent.




       The statement at the bottom of page 23 and the top of page 24 that the levels




of storm water infiltration will be substantially checked when the lakeside plants are




phased out is incorrect.  There is no assurance that infiltration will be checked and




that is the reason the retention basins are necessary to retain the storm water  that




infiltrates so that it can be treated and not  discharged to Lake Michigan without treat-




ment.




       The quote from Dr. Carnow on page 26 regarding an increase in materials




ignores the fact that a large portion of the  expanded Clavey Road Plant is proposed




to be  covered.   In fact, the gist of Dr. Carnow's testimony was that he did  not  know




whether there was a hazard from air-borne virus and bacteria but that no sewage




treatment plant should be built until this  could be determined.  Obviously sewage




treatment cannot wait for this research  if Lake Michigan is to live and if the North




Shore Sanitary District is to carry out the orders of Court and the Illinois Pollution




Control Board.




        The statement on  page 30 that a new plant could be  built  at the DesPlaines River




by 1974 is not realistic.  As we have  pointed out  land acquisition will take longer  than




that,  the  property is not now in the North Shore  Sanitary District, and there are no




funds available to build this new plant.  The North Shore Sanitary District does not have




the so-called  quick Lake  condemnation  power and the District  could not put a  new




plant in that  location for a minimum of six years.







                                        -10-

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       The first full paragraph on page 31 indicates a "feasible alternative" by




limiting the expansion at  Clavey Road to 12 million gallons per day.  As we have




pointed out before this is not  "feasible".  In addition, this finding ignores the fact




that chlorination facilities are already under construction at Clavey Road with a




design capacity of 18 million  gallons per day.  A change in these facilities  will




cause further delays and  increase the cost of the plant under any alternative.




       The second full paragraph on page 36 recommends immediate development




of the DesPlaines River site with care taken in site selection.  The drafters of the




Federal Report have obviously not made any study of this question and  as pointed




out in these comments the selection of a site on the DesPlaines River is  very difficult,




costly and time consuming.  This recommendation may well transfer the controversy,




the need for an environmental assessment and an environmental impact from Clavey




Road to the DesPlaines River.  The problem will not be solved.  It will simply be




delayed,  its costs increased and its site transferred.




       The requirement of paragraph l(a) on page 37 that additional storm water re-




tention be provided at Waukegan, North Chicago and the lakeside pumping stations




exceeds Federal and State water quality standards.  The  District  is already proposing




facilities  which will meet all  such standards.




       The District's project already precludes discharge of storm water at the lake-




side pumping  stations at Lake Bluff,  Lake Forest and Highland Park.   Therefore,




there is no reason for retention  facilities at these "lakeside pumping stations" because




there will be nothing to retain.
                                         -11-

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       The requirement of paragraph 2 on page 37 relating to the new site on the




DesPlaines River has already been covered.  This site cannot be "immediately




acquired" and it cannot be "immediately developed".  The District has no funds




for this project and the property is not located within the District.




       The District has already complied with the provisions  of paragraph 3 on




page 37 requesting that reasonable care be taken during construction to limit




environmental damage.  One of the conditions of the permit  issued by the City of




Highland Park which the Courts found to be valid required the District to make




every reasonable effort during construction to comply with standards.  In addition,




the Order of the Illinois Pollution Control Board requires this compliance to the




extent  reasonably possible.




                                     CONCLUSION




       In conclusion the North Shore Sanitary District is unable to comply with the




new requirements contained in the Draft Environmental Impact Statement because it




is under Order of  Court and under the Order  of the Illinois Pollution Control Board to




do something different.




       The impact on the environment of an 18  million gallon per day plant at Clavey




Road is not significantly greater than that of a 12 million gallon per  day plant, and a




12 million gallon per day plant at Clavey Road will not solve the problem of overload-




ing.




       It is impossible to build a new 18 million gallon per  day plant on the DesPlaines




River  in less than six years and this assumes that property can be acquired and that the




District  will have  funds to acquire the property and build the plant.  The District pre-




sently  has no such funds, nor does it have any authority to raise funds for that purpose.







                                        -12-

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       The additional initial cost of complying with the new Federal require-

ments is estimated to be from 25 to 30 million dollars, whereas the total amount

of the Federal Grant is  11.55 million dollars.  Acceptance of the Federal Grant

with its new conditions would delay the project of the District at least six more

years.  Lake  Michigan and the people of the North Shore Sanitary District cannot

wait for six years.

       The District respectfully urges that the Impact Statement be modified in

accordance with the Orders of Court and the Illinois Pollution Control Board so that

the District may proceed expeditiously with its project to protect its citizens and

the life of Lake Michigan.
                                             NORTH SHORE SANITARY DISTRICT, A
                                             Municipal Corporation of Illinois
                                        -13-

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                           STATE OF ILLINOIS

                          TJOIV COiVTHOJ^  HB-DAKJJ

                    189 WEST MADISON STREET SUITE 9OO

DAVID P. CURRIE.C-AIRMAN         CHICAGO, ILLINOIS 6OSO2                 TELEPHONE
SAMUEL R.ALDRICH                                                312-793-3620
JACOB O. DUMCLLE
RICHARD j. KISSEL
SAMUEL T. LAWTON.JR.
                            May 20,  1971
Mr. William  Ruckelshaus
Administrator
Environmental Protection Agency
1626 K Street
Washington,  D.  C.   20460

          Re:   Draft  Environmental Impact Statement

                Sewerage  Project Number WPC-111.-754
                Submitted by North Shore Sanitary District,
                Waukegan, Illinois

Dear Mr. Ruckelshaus:

     On April 21,  1971,  the Water Quality Office, Region V, Federal
Environmental Protection Agency issued a Draft Impact Statement
concerning the  proposed  improvements to be made to the entire  sewage
treatment system  of the  North Shore Sanitary District.  According  to
the Draft Statement,  any person is entitled to file comments about
the report within thirty days after its issuance.  This letter is
submitted as the  fully approved comments to the report by the  State
of Illinois  Pollution Control Board.

     It is the  opinion of the Board that the Draft Statement should
not be finally  accepted  by the Administrator, but rather the North
Shore Sanitary  District  should be authorized to proceed with its
expansion program which  is in substance detailed in the enclosed opinion
of the Board which opinion was issued on March 31, 1971, almost one
month prior  to  the issuance of the Draft Statement.  The Board has
since held two  days of hearings (April 29 and 30) to determine the
exact, detailed nature of the District's expansion plan, the timetable
for completion, the costs involved and the availability of  interim
measures  to  reduce the pollutional effect of the District's discharges
on Lake Michigan.  Another order of the Board is expected in the next
few weeks.   This  letter  will attempt to outline some of the major
deficiencies of the Draft Statement.

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Mr.  William  Ruckelshaus
May  20,  1371
Page Two
      Of  prime  concern  to  this  Board is  that the project of the District
 proceed  with the  utmost haste.   As  the  enclosed opinion details,  Lake
 Michigan,  and  particularly  the shore water area to which the District's
 inadequately treated sewage is  discharged, is  polluted.  This situation
 will  continue  for so long as  the District discharges  its wastes into
 the Lake;  therefore, the  District must  remove  its  wastes discharges
 from  the Lake  as  soon  as  possible.   Until the  Draft Statement was made
 public,  this Board's order  seemed to be the final  determination by
 courts and  administrative agencies  as to what  the  District should do.
 Now with an entirely new  direction  from yet another agency (the
 Federal  EPA) the  District is  out in a real, and uncalled for, quandary.
 The mere issuance of the  report has done nothing mere than add to
 the confusion  and controversy  surrounding the  expansion program of
 the District,  and as a result,  delay the project.   The entire expansion
 program  of  the District which  contemplates completion by 1974 is  based
 on quick approvals by  both. the  Federal  and State governments.  With
 the unnecessary confusion of  this Draft Statement, the Federal approval
 does  not appear forthcoming—thereby causing exnensive delay.

      Perhaps before the frustration and anxiety of the Board and  the
 majority of the people living  in the District  can  be  understood,  a
 brief history  of  the District's plans should be given.  In 1963,  the
 District was advised by its  consulting  engineers that its plants
 were  either inadequate at that time or  would be inadequate in the very
 near  future.   The District  began planning for  expansion at that time,
 but since  diversion of Lake  Michigan water was  part of its overall
 plan, the  District was told  by  the  attorney reoresentina the State
 of Illinois in the then pending Lake Michigan  diversion case, that
 the District should not proceed publicly with  any  plans to expand its
 facilities  while  that  diversion case was pending.   In 1967, when the
 diversion  case was finally  decided  by the Supreme  Court of the United
 States,  the District was  given  the  "go  ahead"  to start its expansion
 program.  The  District established  a plan at that  tine and took it
 to its constituency in the  form of  a S35 million bond issue.   The bond
 issue was  approved by  the voters of the District in 1968, and the
 District tried to start to  implement its expansion program.   This was
 not to be,  however.  At that  point  in the history  of  the District's
 attempt  to  implement its  expansion  program began probably the most
 litigious  period  in the life  of any municipality,  let alone a
 sanitary district.  The District has been subjected to at least eight
 lawsuits or administrative  proceedings.   A detailed outline of these
 suits appears  in  the enclosed  opinion of the Board.   (See pages 25
 and 26.)  The  results  of  the  delay  have not only affected the waters
 of Lake  Michigan  and the  Skokie River,  but have substantially
 increased  the  cost of  the expansion facilities.  In 1967, it was
 estimated  that the expansion  facilities would  cost $65 million.
 Recently the District  estimated that the expansion would cost $95 million
|With  some  additional facilities.  Further delay will  add to the cost.
                                             ,
 increased  by  about  1%.   On  that  basis  a  delay  of  even  six  months
 could  mean an additional cost  to the  pecole  of the  District of  almost

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Mr. William Ruckelshau:
May 20, 1971
Page Three
$5 million.  Any delay, no matter how little, can seriously affect
the cost of the expansion, and more importantly, it can affect the
quality of water in Lake Michigan, and the Skokie River.

     Speed in completing projects of the nature contemplated by the
District is not necessarily the prime factor in matters such as these.
Certainly, the expansion project must make environmental sense.  We
think that the expansion as contemplated by the District, and changed
by this Board after a full public hearing makes that kind of total
sense.  The present plan of the District is a good one.  Very
basically, as outlined in the Draft Statement, the District's
expansion program, wnen and. if completed, will include tertiary
treatment, nutrient removal, and adequate chlorination at all of its
facilities.  Mo wastes will be discharged into Lake Michigan, except
on fare occasions when the retention basins at the various plants
can't handle the excess water during times of heavy rainfall.  Two
of the plants (Waukegan and Gurr.ee) will discharge into the Des Plaines
River, and the third, the Clavey plant, will discharge into the Skokie
River.  The total effluent which the plants will be able to handle
will be 48 million gallons per day on an average basis.  If the plan
proposed by the Draft Statement were sound and reasonable this Board  (4fc
would adopt it.  The simple truth is that it is not.  It is inconsistent
on its face and should be rejected.

     How is the Draft Statement in error?  First, the entire basis
of the Statement is that the District's total capacity, even when the
expansion program is complete, will be inadequate to handle the sewered
population in the year 1990.  While the drafter of the report does
not state that this is the major oremise on which the reoort is based,
it is obvious that it must be since the Draft Statement calls for
the addition to the system of 12 million gallons per day capacity to
the system.  In recommending that the additional capacity be put on
line, the Draft Statement should unequivocally justify that that addi-
tional capacity is in fact needed in the foreseeable future.  It
doesn't:  The 1990 sewered population set forth in the Draft State-
ment is estimated to be 350,000.  Using the customary figures that
each person contributes approximately 125-150 gallons per day to a
sewage treatment plant, this would mean that the average waste flow
to the District's plants would be between 43.75 and 52.5 million
gallons per day, with the average being about 48 million gallons per
day.  This is the exact average flow which the present plans of the
District contemplate being handled by the expanded plants of the District
Every pollution control agency should always demand greater and
better treatment, but not in the case where that plan delays plans
which are more than adequate, and not where there is an unreasonably
significant increase in cost in requiring that additional capacity.
The additional capacity is simply not justified.

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Mr. William Ruckelshaus
May 20, 1971
Page Four
     Second, the additional facilities add over $33 million to the
already high cost of the expansion project.  This figure is determined
by reviewing the figures presented in the table of costs made a
part of the Draft Statement.  The estimated cost for a facility at
Clavey with 18 mgd capacity is $20.44 million.  The total cost of an
IS mgd plant on the Des Plaines  ($39.85 million) and a 12 mgd plant
at clavey  ($13.56 million)  is $53.42 million, thus the difference
between the District plan and the Draft Statement plan is $33 million.
It is our understanding that the maximum federal contribution to the
District's expansion program is about $33 million, therefore, if the
District merely does what it has planned and been ordered to do by
this Board, the loss of federal funds will have little impact as long
as the Federal Government insists on the District building more
capacity than is needed.  If the Federal funds are used, they will
only be used to construct facilities ordered by the Federal plan and
thereby have no impact on the total project.

     Third, the Draft statement admits that presently there is no
indication of a health hazard as a result of air borne diseases from
the sewage treatment plant.  Certainly, speculation in the scientific
community is that there may be some problem from biological sewage
treatment plants, but the proof is non-existent.  Since their inception
sev/age treatment plants have been located in areas whprp ppnplp live-
The plants must be where people are whether it be in a residential
area, or an industrial area  (where people work), because the plant
treats the waste of people.  Yes, we agree that additional study
must be done to determine what, if any, effect there is between the
plants themselves and the transmission of viruses and bacteria.  These
studies may in fact dictate that plants should be completely covered
and located in areas where people do not exist.   But that conclusion
is mere speculation at this point.  To require as a result of the
speculation of a few scientists that substantial sums of money be ex-
pended, and the Lake be sacrificed, is almost a criminal act.  Further,
if we assume, as the Draft Statement purports to indicate, that care
and caution must be taken in locating treatment plants in residential
areas because of the possible transmission of viruses and bacteria
from the plant to those living in the locality,  we must still disagree
with the conclusions of the Draft Statement—which are reduce the
volume the plant can handle and cover the detention basins.  If a
virus and bacteria problem exist, what significant thing is accomplishes
by reducing the size of. the plant from 18 to 12 mgd?  None is demon-
strated in the report because there are no logical reasons which can
demonstrate any differences.  If the problem really exists, isn't the
alternative that all plants in all parts of the United States be moved
from places where people live and work?  Why stop at the Clavey Road
plant—what about the plants of the Metropolitan Sanitary District
of Chicago, the City of Detroit, the City of New York, etc., etc?

-------
Mr. William Ruckelshaus
May 20, 1971
Page Five
Shouldn't they all be noved if the problem is a real one?  --  These
questions focus on the fact that if the Draft Statement is adopted,
a dangerous precedent is being set, without scientific input and proof.

     Fourth, the estimated average volume of waste going into the
Clavey plant will be when the new sewers are installed, 11.3 mgd.
Yet, the Draft Statement would require the Clavey plant to be reduced
in size from the presently contemplated 18 mgd to 12 mgd.  A larger
facility (18 mgd) would be built on the Des Plaines to handle the
excess waste water.  Until that larger facility would be built however,
(which according to the Draft Statement could not be done earlier
than 1974)  the Clavey plant would not be of adequate size to handle
11.3 mgd on the average.  Even worse, the District's consulting
engineer recently estimated that the average flow to the Clavey
plant upon completion of the presently contemplated sewer system
bringing wastes to that plant will be 12.1 mgd. Thus, on many days
the Skokie River would receive inadequately treated wastes.  This is
indeed an unacceptable interim measure.

     Fifth, one of the recommendations in the Draft Statement is that
the EPA  (Federal) initiate "a broad impact study of the environmental
consequences of diversions of water from one watershed to another."
What this apparently ne^nq is that the EPA should open up the Lake
Michigan diversion case — if it could be done — to look at its "environ-
mental consequences."  Since that is a U.S. Supreme Court decision,
we suggest that review of that decision is not available at the
whim of the Federal government.  That case was tried over a long
period of time with extensive expert testimony--Does the EPA (Federal)
now suggest it was or could be wrong, and therefore should be opened?

     Finally, two specific errors in the Draft Statement should be
called to your attention.

     1.  On page 13 of the Draft Statement the following appears:

         "... Clavey Road facility discharges its effluent into
         the Skokie River at a point . . . approximately 5 miles
         from the Skokie's confluence with the Illinois River."
         (Emphasis supplied).

We should point out that the Illinois River begins at the confluence
of the Des Plaines  and Kankakee River at least 60 miles from the
discharge pipe of the Clavey plant.  What the author undoubtedly
meant to say was the "confluence with the Chicago River".

     2.  On page 14 of the Draft Statement the following appears:

         ".  .  .  the IPC3 has rules . . . that an effluent from the
         Clavey  Road facility must be given tertiary treatment before
         discharge into  the Des Plaines River" (Emphasis supplied) .

-------
Mr. William Ruckelshaus
May 20, 1971
Page Six
As can be easily seen by the Board's order which is made a part of
the enclosed opinion, we specifically held that the*Clavey facility
must discharge its effluent into -the Skokie River. ™

     For all the reasons stated in this letter plus the reasons stated
in the enclosed opinion, we ask that the Administrator not accept
those provisions of the Draft Statement which are inconsistent with
the recommendations and orders of our Board.  We look forward to the
Administrator's decision coming in the very near future and being in
accordance with the recommendations and orders of this Board.
RJK:bt

Encl.

-------
        •jnese comments  are addressee,  ^.o  ,_ne Draj.^. Envircnm.en^-c.J.




     menc issued by  the Water Qualify  Office,  Region V  of  che



          vironmental Protection Agency  for Se'./age Project Xumber
                   ^.^--^e "co  w^* — jTi-x  w-~ic*« ^_.* — •-'/ w**.e j_ — IT s ^  c*j_ci— «— c..**








A"'s.".cw/ \.~culd. oe a rr.odei or exceJ-_£i"ce ar.c. an exar.ipj.e ror ocners




•co foilov,".   I c ir.s'ceac. ^s  a disgrace.   Dsca^lec racts W.LI.J- oe




se- ford',  nereir. in the hope cnac che final stater.enz will over-




      he gross deficiencies of  che draft statement  and will se



      ir.g  v.'hich che Federal Govern~ent can point to with pride.



      nt: Federal DiSuriCu  Court:  case (ZD? v. Corps  of Engineers)



              t chis report and  all others must: ba attached to t:he



              anc nr.us-c receive  che Federal Environmental agencies '
cor.e
   een
         or
    c
        The  draft st a. cement makes  three key changes



          rch Shore Sanicary District all involving  cha Ciavey Road




          hey are ('-') the plant  is  too large for a residential




          ocd and chus should  oe reducec rrom a capacity o~ -b



-------
retention basins must, be reduced  frorr.  their  20 million  gallon size



-co a lessor size (10 million gallcr.s was orally  suggested' by  the



draft s-cauewLent' s author) and  (2) the  Clavey Road Plant's reten-



tion bas^.-i. iv.ust be covered and (3)  an 18 million gallon  plant



should be promptly built on the Des Pli.ir.es  River with  covered re-



tention basins,  "he League objects to these changes  for  the  facts



do r.ot support thcirr..  further the League objects to the Federal



Lnvironr.cntal Protection Agency halting grant funds to  the portions



of the North Shore Sanitary District's plan  to which  the  Federal



Goverr.iv.cn t doas not object.  The delay caused by the  Federal



Government' s withholding funds granted to the North Shore Sanitary



Di^virict over a year ago is quite serious.   In the Illinois Pollu-



tion Control Board hearings on this subject  it was brought out



that presently bacteria discharged in Lake Michigan and the



Skokie Lagoons frorr. sewage which cannot be properly treated by



the overloaded facilities of the Xorth, Shore Sanitary District



are causing a clear and present danger to the health  of boaters



and swimmers from private beaches.  Further,  the health hazard



has forced the closing of all public beaches in  Lake  County,  Illi-



nois and still further the chemicals in the  waste from  this sani-



tary district is leading Lake Michigan close to  a point of no re-



zurn in the euthrophication process.   So testified Dr.  Eugene



Stcermer of the Great Lakes Research Center  at the University of



Michigan.  He stated it would take Lake Michigan over a hundred



years co flush itself of these chemicals.  New types  of algae which

-------
show new ar.ci more serious degradation of  the _,ake have been  spotted



this year off the shore of the area served by the North  Shore  Sanitary



District.

        The author of the drart statement  states  that  the  prc _




Clavey Road plant expansion should be  limited  to  a  12  million gallon




per cay (2-.GD)  capacity instead of an 13 XGD  capacity.   Me  states




that an 13 2-1GD plant would be just too large for  a  residential




neighborhood.   Yet, he does not indicate the difference in the




physical size of the two plants.  I-Ie probably  never attempted




to ascertain this and, therefore, his  conclusions are  subjective




ratner i_nan oc~ec_ive,  rurtner, ne i9'^.ores  tne tact tnat  .Lane.—
a large suner strip between tne p_ant  and tne ncrr.es  that  cou—c  oe




planted with trees and bushes so as  to  generally hide the  plant



frora the hor.es.  The plant will be a one  story plant  zo  this  should



not be too difficult especially since the hones in  the area  are



nostiy one story ranch style hor:.es .  The  proposed covering or




the retention basins adds a physical presence which otherwise




would go unnoticed.  That covering is unnecessary as  we  herein will




point cut.  Further, the covering, if raade, will not  be  so high




as cannot be obscured by trees and bushes.  The engineer for  the




North Shore Sanitary District stated that proper landscaping  would1

-------
appendix of the draft statement should be consulted to view the area



around the plant and its proximity or lack thereof to houses.  That



picture will also show how traffic to -he plant does not go through



residential streets but goes in and out a large private drive from



a main Highland Park street which is an exit street for an express-



way which is a two minute drive from the plant.



        The League also believes that the Federal Environmental



Protection Agency should not be acting as a local zoning board regard-



ing the size of buildings to be built.  The U.S. Water Pollution Control



Act. as amended states clearly in Section l(a)  that "it is hereby



declared to be the policy of congress to recognize, preserve and



protect the primary responsibilities and rights of the States in



preventing and controlling water pollution."  Other laws and regu-



lations state that local authorities are not to be preempted if they



have made a reasonable backed determination of an essentially local



problem.  A federal official of the Chicago Regional Office recog-



nized this when he testified before the Illinois Pollution Control



Board (at page 707 of the transcript)  as follows:  "Big Brother



sitting in Chicago or Washington has not tried to interfere on



where you are going to locate a particular treatment plant.  The



Federal Government does not participate in site costs nor has it



participated in site selection.  The question of sire selection



from its inception...is an obligation and responsibility of the



local regulatory agency in addition to being a very strong res-



ponsibility of the state water pollution control agency and by

-------
the time we receive a grant application the question of site




selection whether for a new plant or for expansion is the type




of question that should have been resolved".   The question of the site




for an 18 MGD plant was resolved between the North Shore Sanitary




District and the City of Highland Park in a court settlement and




the Clavey Road plant is located in Highland Park.




        Further, the Federal Government recognized that a local




regional planning agency should review the plans of the North




Shore Sanitary District.  The Federal Government authorized an




additional 10% in funding if the regional planning agency approved




the plans of the North Shore Sanitary District.  That planning




agency was the Northeastern Illinois Planning Commission which



wrestled with the Ciavey Road Plant question for a long time




before deciding to approve the North Shore Sanitary District's




plans.  This planning commission's final decision is somehow



ignored by the author of the draft statement who also gives little



consideration to the approval of the Lake County Regional Planning



Commission, and of the Illinois Environmental Protection Agency both of



which studied the problem.  The author also places himself above



the Courts of Lake County which considered the new plant after




hearing evidence and places himself above the Illinois Pollution Control




Board which held extensive hearings during which said author walked




in and out.  Such attempted preemption of the functions of state




and local agencies, commissions and courts is improper when these




bodies have strenuously and carefully considered the problems and




have independently reached the common conclusion that the North








proper.

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               THE REDUCTION i:\ SIZE OF THE CLAVEY
               PLANT AS SUGGESTED IN THE DRAFT STATE-
               MENTS IS WRONG AND WOULD HAVE HARMFUL
               EFFECTS.
        The author of the draft statement states that the Clavey Road

plant should be reduced from 18 MGD t« -- MGD and the retention

basins should be reduced from 20 MGD to about 10 MGD (he stated 10

MGD orally).   Ee stated that this size plant would suffice until

an IS MGD plant would be built on the Des Plaines River.  This 13

MGD plant was not contemplated by the North Shore Sanitary District

and even if it built, with condemnation problems, drafting pro-

blems etc., that plant's operation would be delayed for a long time.

The author of the draft statement contemplates operation during

or after 1974 which the League feels is being highly optimistic.

Based on current flow figures an 18 MGD plant with 20 MGD retention

basins are needed now.

        The author of the draft statement presurr.es that the current

average flow to the Clavey plant from diverted plants and from

areas it now serves would be average 11.3 MGD.  In testimony on

March 30, 1971 before the Illinois Pollution Control Board, the North

Shore Sanitary District states, based on 1970 year's figures, that

an average of 6 MGD would be diverted to the expanded Clavey Road

from the five lake front plants which are to be closed added to an

average of 6.1 MGD from the area it now serves for a total average

of 12.1 MGD.   With this average flow the 12 MGD plant and the 10

MGD retention basin would soon be overloaded.  However, in March

of 1971, the Clavey Road plant, according to that testimony was

-------
receiving an average flow of T.I XGD instead of the 1970 average

flow of 6.1 MGD which would cause a total of 13.1 XGD on an average.

But this average doc  not include the flow currently received from

Ft. Sheridan (which - ._y or may not stay in use) which averages be-

tween .5 and .7 XGD overloading the 12'XGD plant. However/ it must be

recognized that a plant cannot merely be built for average flow.

It must be able to handle peak flows.  Testimony was given in

the Illinois Pollution Cont.ro 1 Board hearings that based en ex-

perience the 13 XGD plant with 20 XGD retention basins was ex-

pected to overflow at least once in its first year of operation

and would be filled to capacity on several other days that year.

How can we then cut the size of the plant by 1/3 and the retention

basin by 1/2.  And let us look at maximum flow figures.  Flow fi-

gures from the five lake front plants reach 9 KGD especially in

the spring rather than the 6 MGD considered by the author of the

draft statement.  The League requested maximum flow figures for

the five lake front plants from Greeley and Hanson, and the North

Shore Sanitary District's engineers.  In a letter dated May 14,

1971 they stated the following:

        "The design maximum flows at the lake front pump-
        ing stations, determined by observation of actual
        conditions and water levels at times of peak flows
        and analysis of th.e hydraulic conditions are as
        follows:

               Lake Bluff        16.0 MGD
               Lake Forest        9.3 MGD
               Gary Avenue       20.5 MGD
                                 45.8 MGD"

The two other lake front plants were not mentioned in that

letter.  That letter also stated that 23 XGD flows were received

at Clavey Road at various times.  From observina records of

-------
Sanitary District f.or the Clavey Plant, it is noted that in May



and early June of 1970 there was one flov; of 16.21 MGD, one of




16.42 MGD, one of 16.39 MGD, one of 18.04 MGD, one of 19.26 MGD




and one of 25.74 MGD.  Some of these flows were back to back.  On



June 8, 1369 there was a flow  .or just the Clavey area of 23.08




followed on June 9,1-.     a flow for that area of 21.80.  In




light of the above a 12 MGD plant with a 10 MGD retention basin would




be obsolete when built.



        If the Clavey plant is overloaded when built, the unfortunate



necessity of a building ban in the Highland Park area due to over-




loaded sewage plants would continue harming that area.  Robert Hart-




ley of the Chicago Regional FWQA office testified under subpoena




before the Illinois Pollution Control Board  (at pages 237-39 of the




transcript)  that the Federal Government would only permit bypass-




ing in an emergency under present regulations.  He said that if a




sanitary district had reason to suspect that at certain times of




the year there would be heavy rainfall, they would have to enlarge




facilities to handle that rainfall.  From the figures we have an 18



MGD plant with 20 MGD retention basins is necessary to handle the



flow that the expanded Clavey plant will have to handle.




        The author of the draft statement also underplays the area



which the Clavey Plant empties into namely a flow by the 300 acre




Botanical Gardens,(a park to be enjoyed by tens of thousands when




it is complete)and the Skokie Lagoons.  The Skokie Lagoons cover




700 acres of land downstream from the Clavey Plant.  They were




dredged.  They used to be filled with bass, sunfish and carp.  Then

-------
 is t:ie ^_avey pj_ant oecame over^caaec the cass ar.ci percn pensnea.
 .ast winter -\ationai Geocrrauhic gave national coverace to a. fish
on water whose oxygen was depleted by oxygen consuming organic
waste frcrv. the Clavcy sewage plant, the main source of such waste.
Francis Mayo, Acting Coordinator of EPA Region V was quoted in
char article on other matters and must have been aware of that kill.
Some fishing is still done in these lagoons.  People sail and canoe
on -char:,.  Luring the summer people picnic there.  But the numbers
of these people have been declining over the last years due to
sewage in the water from the overflows from the Clavey plant.  A
700 acre recreation center is going to waste and it is passed over
                                   t
in contact wth the water can  ecome diseased due to its not  eng
treated.  The Illinois Pollution Control Beard considered this
problem and  said that the 18 MGD effluent with tertiary treatment
would flush  these lagoons and make this 700 acre recreation spot
blocra again.  However, if the Clavey plant is restricted to 12
XGD it will  not handle ail wastes and shameful pollution of the
Skokia Lagoons will continue.  Some people from the poor areas
of Chicago used to come here to enjoy the beauty of life as did
thousands of other people who used the lagoons.  One of the poorer
people was quoted in the Chicago Tribune on February 28, 1971 as
saying  that  what is being done to  the Skokie Lagoons is theft from
him and his  family.  It is, so is the continued fouling of the Lake.

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               TNE FORCED EXPENDITURE OF MILLIONS OF DOLLARS
               TO COVER RETENTION BASINS DUE TO SUPPOSED ODORS
               AND SUPPOSED VIRUS DANGERS IS WRONG BECAUSE
               SAID_DANGERS KILL NOT EXIST.


        The author of the draft statement believes that the retention

basins on the Clavey plant and on his proposed Des Plaines Plant

should be covered due to odor and disease problems.  The covering of

a 20 MGD retention basin was estimated by the engineers at the

Illinois Pollution Control Board Hearing to be 2-1/2 million dollars.

A covering for a 10 MGD retention basin would cost in excess of

$750,000.  If hazards cause the covering at these plants, ail similar

plants should be covered.  Facts indicate that the covers will not

be necessary at the expanded Clavey Road plant.  The author of

the draft statement confines himself to odor problems and disease

problems involving the retention basins because he recognizes the

sophisticated system involving catylitic (now thermal)  combustion,

oxidizing with alkaline permanganate, negative pressure to prevent

leaks out of the buildings, forced air and many other protective

measures to stop odor and other contamination.

        The author of the draft statement wants the retention

basins covered because "a malfunction of mechanical equipment

related to the operation of the retention basin or presedimenta-

tion basin followed by untimely corrective measures would in theory

produce a very unpleasant situation.

        To place this situation in its true light we must point

cut certain facts.  First, these basins would be used about 18-20

times a vear if the -slant was an lo MGD -iar.t.  Their use prevents
                                 10

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bypassing wh:_ch is against Federal po'S'icy.   The covered prssedimen-




tation basin would be the basin used 13-20  times a year according




to tne testimony DV t.ie .\Grtn b.iore Sanitary District.  Tnat casm



is covered.  Tests have shown that the effluent received by this




plant is positive in oxygen content which is a factor against odors.




The effluent receives chlorine, is held 45  minutes by which time




it was estimated that 90% of the solids had been settled out.  The




cnlorine tnen can worx oetter on oactena,  odor causing agents / anc.




virus.  It was estimated that if the plant was 18 MGD, the initial




filling of the covered presedimentaticn basin would cause the reten-




tion basins to be used only 12-14 times a year.  There would be two




retention basins, each of 1C MGD capacity.   The second basin would




be needed only 2-4 times a year.  If the flow is more than the capacity




of the presedimentation basin it is first chlorinated and 90% of the




solids are removed in that basin before the diiluted storm water goes




to the retention basins.  Provision is made for the effluent in




the retention basin to be recirculated and rechlorinated to keep



odors under control.  The settling-time and chlorination would kill



bacteria and virus in the retention basin.   The continuing recircula-




tion and chlorination aids this.  Immediately after use the retention




basins  (which are lined in cement) are cleaned.  Heavy chlorination




plus prompt cleaning would keep pests away though other methods could




also be used if needed without the necessity of covering the basins.




 (Presently the- untreated sewage flows from the plant causing odors




and surprisingly not causing rat problems.   This would be remedied




by the  new plant if it were large enough) .

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        The system just described should keep odors down.  The



equipment is simple.  All equipment is duplicated so if there is



a malfunction the problem could be corrected.  The plant is con-



stantly manned and the odor would be detected.  The recirculation



facilities would enable correction.  Add all this to the fact that



the open retention basins would be in use 10-12 times a year and the



likelihood  of odor problems is almost impossible and subject to




quick correction.  It is not justification for spending up to 2-1/2



million dollars covering the Clavey retention basins and spending



millions of dollars covering other retention basins.



        As far as gases from the plant are concerned, Dr. Carnow



indicated some worry which was quoted by the author of the draft



statement.  However, Dr. Carnow indicated that he was talking about



general sewage plants and not talking about the specific engineering



of the expanded Clavey plant.  He stated that the sulphur emissions



as stated in Dr.. Quon's letter could be harmful.  What he did not



know was that due to Dr. Quon's recommendations the sulphur emis-



sions would go through catalytic combustion which would sharply reduce



any harmful emissions below levels which when combined with the



levels in the air around tiie plant would be below the level to cause



harm.  Dr. Friedman, 'a witness for the Clavey neighbors, estimated



that plant would emit gas equal to a seven room house burning high



sulfur coal.  Even that quantity is questionable as on the high



side.  Dr. Quon calculated other emissions (See p. 76 of the appen-



dix to the draft)  and if they are compared with the proposed federal



emission standards, they will be found well below the harmful



level.  Other concerns of Dr. Carnow like iron particulate matter
                                 12

-------
are many pathogenic viruses in sewage.  But their presence does



not cause disease.  A method of transmission is not



related to the retention basin by these articles (unless someone



would drink that water which is not likely).  The next article is



by Martin Rogoff, ?hD who we learned works principally in the area



of soil microbiology.  His comments on ground water supply are



irrelevant since such is not used in the Clavey area.  He also



shows that sewage contains pathogens.   He indicates that they can



be transferred by aerosols and indeed this has been indicated in



laboratories where a virus is transmitted by aerosols.  But what



process in the retention basin causes aerosols?  There is no bub-



bling.  Rogoff in his article attributes statements to Dr. Deih-



hardt which Dr. Deinhardt allegedly made in the Illinois Pollution



Control hearing.  If the author of the draft statement bothered to



check the transcript of that hearing he would find that those



statements were never made and, further, Rogoff's comments on



immunization by aerosols are irrelevant.  Next came Dr. Carnow's



statements, but Dr. Carnow in the hearing before the Illinois



Pollution Control Board stated that other than droplets, he did



not know of methods of virsus transmission in the air.  Dr. Carnow



refers to transmission by aerosols in the appendix to the draft



and again we do not have aerosol formation in the retention



basin.  Dr. Carnow on pages 204-5 of the appendix states he bases



his ideas in this area from studies with a Dr. Lorenzo at Cook County



Hospital.  Dr. Lorenzo when contacted said that  the studies involved



what size aerosols were absorbed by the lung and had nothing to do
                                14

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in the. air do not exist in harmful quantities in the Clavey resi-



dential area and do not cause harm since sulfur emissions have



been cut down.




        Regarding the fear of bacteria and virus going into the



air from the retention basin, that fear is unfounded.  It is only



mentioned by the author of the draft statement because he did not




bother to analyze what he was dealing with.  That failure is terrible,



The articles cited on page 109-216 are all irrelevant.



        The abstracts cited do not deal with the problem at Clavey



nor do the articles.  The problem at Clavey deals with retention



basins which do not have bubbles and which do not involve the



trickeling fillers.  The Ledbetter article at page 119, deals with




bac-ceria from bubbles in an activated sludge plant.   When bubbles



in that process collapse a verticle jet of water rises from what



was the bottom of the bubble cavity.  The jet becomes unstable and



breaks into small drops which go into the air.  The droplets may



have bacteria in them from the water.  However/ at Clavey this



happens in an enclosed room.  It does not occur in the retention



basins.  Similarly, the "Science" magazine article at page 133 of



the appendix to the draft says that water droplets thrown into



the air by a trickling filter may have bacteria in the droplets



and can be carried by the wind.  Albrecht on page 112 of -he appen-



dix also dealt with trickling filters.  But there is no trickling



filter to throw water into the air from the retention basins at



Clavey.  The Vernon article on page 137 of the appendix and the



Berg article on page 145 of the appendix merely show that -chare
                                 13

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with pathogen transmission by aerosols.  Dr. Carnow's testimony



is generalized and is difficult to apply to the retention basins



which are discussed in the draft.  Dr. Carncw's statements on gas



were discussed above.  Dr. Carnow admitted in the oroceeding before



the Illinois Pollution Cor.'crol Board that he did not know if rhe



Clavey Plant would cause harm.  It is terrible that the author o~



the draft statement causes a multimillion dollar expenditure based



on these articles.  He admits that he had no tests conducted.  The



matter he is dealing with is not new or unique.  His use of these



articles was very poor and unexcused.



        The author of the Leagues comment has examined over 50



medical articles on transmission of bacteria and virus "by air".



When the term "by air" is used, it refers to droplets or aerosols



(also known as droplet nuclei) and sometimes dust.  The Leagues'



witness Dr. Deinhart, when he said that bacteria and virus was not



carried by air meant literally that the gas in the air above would



not transmit bacteria and virus.  He did not mean that droplets or



aerosols did not transmit virus.  No tests have ever shown virus



or bacteria transmission through the air unless it were carried by



a water droplet, an aerosol or in certain cases dust.  Droplets,



because of their weight, do not travel far.  Aerosols, because they



are light, travel farther.  It should be noted that the prominent



Br-itish Medical magazine Lancet  (1959, p 1196-1200) showed how



germs carrying aerosols were set loose when one flushed a toilet.



However, though such aerosols may carry germs doesn't mean that they



will necessarily transmit them.  Thac is being studied.  Srudies



indicate that pathogens carried by v/ater particles in the air have
                                 15

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have a short average life span.  Some illness including hoof ar.d



mouth disease have been traced to aerosols.



        The main point here is that there is no mechanism such as



bubbles to cause aerosols to be forr.ed in the retention basins.



A windbreak of trees and bushes cou_a be used to alleviate fears



that a strong wind could carry droplets.  Wind blowing horizontally



generally would cause almost no problems even without a wind break.



There is no dust because of immediate cleaning after use and Dr.



Carnow at page 652 of the hearing before the Illinois Pollution



Board said such cleaning would stop problems.  It must aIso be



realized that the water we are talking about is chlorinated, it



has had settling time, it is diluted and 90% of the solids have



been settled out so chlorination should be effective against bacteria



and viruses.  So besides the fact that articles indicate that



there is no proof or indication that bacteria or virus merely leave



water on. their own and go into the air or are transmitted by



gases from evaporation, the chlorine in the water we are dealing



with should have killed most virus and bacteria.  When you add to



these factors the slight use of the retention basin, you should



not have a requirement that millions of dollars should be spent



covering the retention basin.  Heavier chlorination might be re-



quired.



        Again the Clavey plant is not unique (see attached pictures :•"



Hanover Park).  The people around the Clavey Plant are better pro-



tected than most plants.  The author of the draft statement did



not question the effluent lagoon for water with secondary treat-

-------
menr.  Thar will be closed and is temporary to add further reduction

of BOD.  With the degree of treatment the water should be fairly clean

since activated s"  :"ge treatment removes up to 95  of virus.   The

bubbles here according to testimony before the Pollution Control

Board are 1/64 of an inch large.  These are too small to cause pro-

blems of particles  going into the air.


               POOR PLANKING CAUSED THE RECOMMENDED PLANT
               ON THE DBS PLAINES RIVER BE BUILT AS SOON
               POSSIBLE
        The recommendation that an 18 MGD plant be built on the

Des Plaines River was based on a guess and not on real planning.

No atrempr was made to find out if there were available sites and

if people would not tie up that plant with court suits.  Meanwhile,

too small a plant is recommended for Ciavey.

        Further, the author of the draft did not consider other

sewage plants on the Des Plaines River.  As was pointed out by both

the United 3rates Department of Commerce and the Unired States

Deparrmenr of Agriculture on pages 85 and 93 of the Appendix, there

are some flooding problems on the Des Plaines River.  The aurhor

of rhe drafr statement ignores this and ignores the concepts of basin

and regional planning.  The Gurr.ee and Waukegan Plants will add 30

MGD to the Des Piaines.  Tne O'Hare plant and the Salt Creek Plant

of rhe Chicago Metropolitan Sanitary District will add 78 MGD to

that stream.  Can that river afford the 18 MGD plant rhat is proposed

ir. the draft statement?  Shouldn'r we wait to see how those plants

affect rhe river?  Should the 6 MGD be taken from Ciavey to the Des

Piaines River when crher areas on rhe Des Plair.es River may need

thar capaciry whereas the North Shore Sanitary Disrricr is the only

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District really using the Skckie River?  These vital questions were



ignored by the author of the draft statement.



        That author also ignores the fact that by immediately build-



ing a plant not needed till 1930, one looses out on gaining technolo-



gical advances made during the next five to eight years.  Possible



be-c.-c.er methods of treatment will be sacrificed.  Many technology break



uhroughs are on the threshold.   Uinox would enable a smaller plant



to be built in the future.  The Army Corps of Engineers is working



en a diversion system where water would be pumped 100 miles away to a



rural area.  It would be used to recharge the ground with phosphates



and nitrates, iz then would be filtered through sand, filtering out



viruses and it would recharge the ground water.  Denitroficarion, am-



monia stripping, columner nitrate reduction, the biodize system,



reverse osmosis, ion exchange, electrodialysis, clarification absorb-



tions,  use of organic polymers, ultra filtration, phosphate removal



and many many more new and exciting processes are being developed



with FWQA aid.  Should these be foresaken by building a plant before



it is needed?



        The project cost estimate for the Clavey Plant with ter-



tiary treatment at 18 MGD including an inflation factor through



construction is $19,046,000.  These costs were filed with the Illi-uo ;..



Pollution Control Board and included tertiary treatment.  The



North Shore Sanitary District should not have to spend $54,420.00



instead for a project that could cause flooding,would forsake future



technology, is not needed and which may not be proper in light of



new additions to the North Shore Sanitary District or mergers
                                 18

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between sanitary districts which could occur in the next five years.


                              CONCLUSION

         The original plan for Clavey Road has the approval of all

local Leagues of Women Voters in ths XOrth Shore area except the

Highland Park LZague which neither supports nor opposes it.  Many

environmental groups also favor this position.  The position taken

in the draft statement ignores the desires of these groups.  It

was written in close contact with the Clavey Road residents without

consulting other interested citizen groups.  The League of Women

Voters was told the plan only after it had been tentatively agreed

on and only after the League confronted its author.  We are dealing

here with the rights of thousands of residents along Lake Michigan

shore who use the lake and the Skckie Lagoons.  Their interests must

be protected.

         We favor only an 18 MGD plant at Clavey Road as was originally

planned with a 20 MGD retention basin which is not covered.  The

facts do not require otherwise.


                                  Respectfully,
                                  Richard M. Kates
                                  Attorney for the League of Women
                                    Voters of the State of Illinois
Room  800
120 West Madison
Chicago, Illinois 60602
                                 19

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                           RICHARD  M.  KATES
                           Attorney z- Law
                          120 West l-ladison Strec-c.
                        Chicago,  Illinois 60502
                             (312) 346-C1-C5
                              May 25,  1371
Mr. Prances •_. Mayo
United. 3races  of America
Environmental  Projection  Agency
Region V
Water Quaiizy  Office
33 East Congress Park'.ray
Chicago, Illinois  60505

Dear Mr. Mayo:

        Pursuant to the authority contained in the _ ;tached iezter
sent by your acting regional  director giving the Leagus zhrough
May 25, 1971 to submit comments to your office on the i:or~h Shore
Draft Environmental Staze~.er.-c,  we hereby request and require that:
the enclosed Appendix be  attached to cur comments which were de-
livered to your office on May 2-., 1371.  This letter is being hand
delivered to you on May 25,  1971.

        This Appendix is  also being attached to the ccrrjv.er.u:. of
the League of  Women Voters of the Stata of Illinois which are being
delivered by the request  of certain o-chcr interested persons and
officials.  If the time period is open for any citizenrs group,
please inform  us because  we may wish -co use any such opening.  We
.do believe that the record is closed.

        A copy of  this letter with -che original photographs is being
sent directly  to Mr. Schenzel.   Please excise -che high degree of for-
mality which I am  using in this rr.a-c-cer.  Ic is no reflection on any
member of your scaff.  It is  merely an a-c-corney' s caution.

                                    Sincerely,
                                    Richard M. Kates
 RMKism
 Enclosure

 cc:   Mr.  Schenzel

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                              APPENDIX A




                            DR.  D5INHARST






        The purpose of this paragraph is to state some of the quali-




fications of Dr. Deinhardt, who  served as zhe League's witness and




advisor regarding methods of transmission of bacteria and virus.  Dr.




Deinhardt holds a Doctor of Xedicir.e Degree (Summa Cum Laude) ; he is




the Chairman of and Professor in the Department of Microbiology of




-he University of Illinois Graduate Schools and Xedicai Schools;




Chairman of the Department of Microbiology az the massive and nation-




ally known Rush Presbyterian Sz  Luke's Medical Center complex in



Chicago, Illinois; consultant to the Board of Health of the City of




Chicago; member of zhe U.S. Surgeon General's Advisory Committee on




general medicine; special cor.suitar.z, National Instituze of Health;




associaze member Commission on Viral Infections, United States Armed




Forces Epidemiological Board.  He has published more than 50 articles




in nazionally known medical and scientific journals including the



Journal of Imunology, the American Medical Associate Archives of



Internal Medicine, zhe Journal of Virology, zhe Journal of Experimen-



tal Medicine and zhe American Journal of I-Iygiene.
        Ihe aztached pictures are of the Hanover Planz of zhe Chicago



Metropolitan Sanitary Districz.  They were senz by that distric


               - - ~ e 4- ^ JT J- •„
                     f the League of "vomen Voters of zhe State or
Illinois for "oiczures of one of their waste treatment olanzs wh^cn

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                              area.   j.c  is  cur  unoerstanding i_naL. tne



Prcsider.c of tlie "Jr. iced S-azcs has  vis iced that plant as  an exarr.ple of



a:i updated rreatraent plane.   The  covering  or.  the Xorth Shore Sanitary



District Plane is ::.ore complete -char, ehat  on  zhe Hanover  Plant.   There



is no indication of any disease in  -che  area of the Hanover Plant which



was caused by -che plane.  If  you  will examine  the pictures, you will



noee that ehere is a school immediately next  to plant facilities and



there is a walk through the open  facilities of the plant  to rhae school.



The close proximity of the children eo  che plane has  lead ec no notice-



able disease problems.  This  plane  is smaller  than  the proposed Xorth



Shore Plant, bue ies proximiey  eo  the  children is  exceedingly closer.

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      Technical  and  Engineering Comments
                        by
Lake Michigan  Protectors  of the Environment, Inc
 (formerly Committee to Save  Highland Park)
                     On  The
     Draft Environment Impact Statement
                       for
      Sewage Project  No.  WPC-III.-754
        North Shore Sanitary District
         Eastern Lake County, Illinois
                   Released by
   Federal  Environmental Protection Agency
              Water Quality  Office
              Great Lakes Region
                 April 23,  1971
                                   Amos Turner
                                    Registered Professional  Engineer^
                                    Illinois  License  No.  19471
                                    May 21,  1971

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                              INDEX






                                                    Page No.




     Abbreviations                                          2,




1.0   Introduction                                             3.




     1 . 1     General                                        3.




     1.2   Present  Expansion Program                      3.




2.0  Recommendations                                       6.




     2.1   Additional Stormwater Retention                  6.




     2.2   Size of the Clavey Road Plant                   7.




     2.3   New,  18MGD plant on  the  Des  Plaines           9.




           River




     2.4    Retention basin at Clavey  Road                 9.




     2.5   Environmental damage during                     9.




           construction




     2.6   Effluent Lagoon                                   9.




     2.7   Chlorine handling                               10.




     2.8   Landscaping                                    \]t




     2.9   Study  of environmental  consequences of         11,




           diversion  of water from one watershed to




           another




     2.10 Study, including monitoring, of air  pollutants    11.




           gernrs, viruses and possiblHy  of air borne




           infections




3.0  Conclusion                                           12.
                                    1 .

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                        ABBREVIATIONS
FWQO             Federal  Water  Quality  Office
G  &c H             Greeley  and Hansen  Engineers
GPD               Gallons per  Day
HP                 Highland Park
I  94                Interstate 94
IPCB               Illinois Pollution Control Board
INT                Interceptor  (Gravity)
LMPotE            Lake  Michigan  Protectors  of the Environment, Inc
                    (formerly Committee  to Save Highland  Park,)
MG                 Million Gallons
MGD               Million Gallons  per Day
MSD               Metropolitan  Sanitary District of  Greater Chicago
NIPC               North-, eastern Illinois  Planning Commission
NSSD             North  Shore Sanitary  District
REC               Recommendations
STP               Sewage  Treatment Plant
                                   2.

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1 , o      Introduction

1 .1      General


         The Federal  Water Quality Office  (FWQO)  Great Lakes Region has
         conducted an  Environmental  Impact Study of the proposed expansion of
         Sewage  Treatment Facilities in  Eastern Lake County.  The study
         was conducted in conformance with the National Environmental  Act
         of  1969,  Public  Law  91-190 which includes the following, statement:

         "..it is the continuing responsibility of the  Federal Government to
          use all  practicable means. . . .to the  end that the Nation may-.  . .
          (2) assure for  all Americans  safe,  healthful,  productive,  and
          esthetically and  culturally pleasing surroundings..."

         The study  was conducted in accordance with Interim  Guidelines pre-
         pared by the  Council  oh Environmental Quality.  FWQO reviewed data
         and comments submitted  by the  LMPotE,  NSSD and  a  number of
         Federal  and State agencies.  Public  objections to the proposed expan-
         sion from the clergy,  groups of  doctors and other civic groups were
         considered.

         The study  considered environmental effects  and alternates to the pro-
         posed action.   The preliminary "Draft Environmental  Impact Statement"
         was released on April 23,  1971.  Section  No.  2.0  through 2.10 of
         this report contains LMPotE  technical,  engineering evaluation and
         comments.   Section No.  3  contains conclusions,

1 . 2      Present  Expansion  Program

         In  1967 the  NSSD  and  G  &1 H conducted a number of studies  con-
         cerning  expansion  of sewage  treatment facilities in  eastern Lake
         County.  Although  an existing 4.5  MGD plant at Clavey Road  has
         been  emitting odors,  air  pollutants and  possible  germs and viruses
         into an immediately  adjacent residential area,  an alternative to  Clavey
         was never  considered.   G  & H  concluded  their  studies  and  recommerv.,'
         ed  the  quadrupling  of  the  Clavey Plant  (from 4.5 MGD  to 18 MGD),
         and building at Clavey an open,  approximately 6 acre, retention basin
         and an open,  approximately  6 acre, effluent lagoon.    Other  recommen-
         dations included a  new plant within the corporate limits of the Village
         of  Gurnee,  (the  plant was subsequently moved  into an unincorporated
         area because of  objections of local residents) and  expansion of  faci-
         lities at Waukegan,  North Chicago  and Highwood.   A $35,000,000
         bond referendum presented  to and  passed by the voters mentioned,
         in  general,  the proposed  expansion and the new facilities, but  did
         not offer  any  details.

         A  number  of  court  cases were instituted by LMPotE  of which  (2)
         two have been supported  by School Board  108, as the  children  attend-
         ing 108  schools live and study in the  immediate vicinity of the Clavey
         Road Plant.   District 108 also  owns  property near the  plant.   The
                                          3.                                    (C

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outcome of the different court cases  was the  covering of the primary,
aeration and  final  tanks and  the presidementation  portion  of the reten-'
tion basin  and the prevention  of emission and monitoring  of air pollu-
tants.  A  subsequent  agreement between the  City of Highland Park
and the North Shore  Sanitary District  limits  the  size  of  the Clavey
Plant  to 18 MGD ,  with the provision that the District  will not aquire
any additional land in  Highland Park and will not build another plant
in Highland Park,   A number of  cases are  still pending  in courts,
effectively  preventing the district from committing  funds beyond  the
$8,800,000 committed up  to  now.

Most of the commitments by  the NSSD  until the present  time have
been made for facilities at Clavey  and/or leading to Ciavey,  to
establish  a "Fait Accompli"   and to  force the enlarged facil'ity  upon the
residents.  Construction should have been  started at Gurnee,  Waukegan,
and North Chicago, where there was no controversy and  no objections
and where the NSSD  could have  built  without danger of being over-
ruled  by  a court with  jurisdiction.

IPCB held hearings on the proposed expansion as  a result  of  a
complaint by  the League of Women Voters  of Illinois  (except  the
League of Women Voters of Highland Park who  did not  take a stand
on  the Clavey Road controversy)  and complaints from a number of
Highland  Park residents.     The board  issued its,  '"final" order  on
March  31 ,  1971 basically reaffirming the planned expansion by the
NSSD with  the  following  exceptions:

a.    NSSD  was  ordered (IPCB  Item  No. 3)  to issue  $50,000,000
      General  Revenue bonds, and if required, $85,000,000.   This
      portion  of the order is being  appealed by  NSSD ,  who  claims
      that it is unconstitutional.  The issuance  of  General Obligation
      Bonds     is   unfair to taxpayers  in eastern Lake  County vvho
      voted  for the  1968 $35,000,000 bond referendum,  in the belief
      that additional matching funds, will  be  available from State
      and Federal  Agencies.         It is unfair  to impose an  additional
      burden  upon  the  average taxpayer,  just  because !RCB  takes
      objection to the FWQO recommendations,  which  wtould benefjt
      all and  hurt no one.

b.    NSSD was ordered  (IPCB  order Item  No. 7)  not to
      perrriit  new sewer connections  to  overloaded facilities,  thus
      effectively bringing all  construction  in the area  to a  grinding  halt,
      This part of  the  order  is being appealed by the  Lake County
      Builders Assn , &  Lake County Constructors  Assn .   A review
      was  asked for by the Waukegan - North  Chicago  Chamber  of
      Commerce, Zion -  Benton Chamber of  Commerce  and Lake
      County  Building Trades Council.   The plaintiffs  claim thai they
      were  not part  of  the proceedings and  that ''work  stoppage causer:
      by item  7 of  IPCB  order would result in  wide spread unem-
      ployment of construction industry related labor  in the NSSLJ
      boundries,  cause  financial ruin and bankruptcy  of a threat  numbe
      of individuals and corporations  engaged in the construction industr
      cause   financial  ruin and bankruptcy of  a  substantial -u;mr e-  of   :"
      dividuals 5> corp.  who have invested in property  to  be  developed  '*

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       have  subjected themselves to  binding  contractual  commitments
       relating  thereto,  all to the vast economic detriment  of persons
       residing within the NSSD".

c.     Clavey Road  Plant  shall discharge the effluent into  the  Skokie
       ditch  and not  into the  Des Plaines river,  thus requiring an
       Advanced  treatment plant.    On August 20,  1970 or  9  months
       ago LMPotE  had asked not to  issue  a building permit for  the
       Effluent  Lagoon because it would not  meet State standards for
       discharge  into the Skokie ditch .  Our request was disregarded
       and construction  started.   NSSD  has estimated  that it  has spenf
       about  $300,000 on the lagoon through April,  1971.    NSSD
       would not  commit itself  to a phaseout  of the  lagoon, as rsoon as
       the Advanced plant  goes into  operation.   The City  Council  of
       HP has requested the discontinuance  of the construction of the
       Effluent  Lagoon and asked its consultant Mr.  Vinton  Bacon to
       prepare an  engineering report  to show  that the lagoon  is  not
       needed.

d.     The individual  complainants, except the  League of  Women  Voters
       of Illinois, were  ordered by the board  (IPCB order  item  no,  8)
       to "cease  and desist from prosecuting any further  actions" ,
       except to appeal  the IPCB order.  In the opinion of the writer
       this part of  the order,  is unconstitutional, because  it  deprives  the
       claimants of their basic rights to  seek justice  in  courts  of  law
       as assured  by the Bill  of Rights  of the  Constitution of the  United
       States.

The following facts which  came to light  at an IPCB  hearing 30 days
after  IPCB  "final"  order,  on  April  29 and  30,  1971  are  of particular
interest.

a.     IPCB  did  not admit the FWQO Draft  Environmental Impact
       Statement  into  evidence because the "FWQO Statement  dis-
       agreed with  the IPCB  order."   Another formal  request has
       been  made  by  LMPotE and is being  considered  by  IPCB  .

b.     IPCB  did  not admit additional  medical  data  and data on  health
       hazards, submitted  prior  to IPCB order.

c.     After  admission by  G  &  H that  Clavey Plant,  if  expanded  in
       accordance  with  IPCB  order  to 18 MGD ,  would be overloadc
       by 1980, the IPCB  did not  allow  a discussion  on remedial act:o
       Specifically  IPCB did  not allow a  discussion of  Alternate Sites,
       of  a  need to  build another plant elsewhere  and to reroute  the
       Middle Fork  Intercepter,  now  estimated  at  $10,200,000.

d.     The  IPCB  did not  allow a discussion  on covering  the retention
       basin .

e.     The  IPCB  did not  allow into  evidence a  letter  from the Mayoi~
       of  HP requesting  stopping of  the construction  of the Effluent
       Lagoon.
                               cross  exam, net
       monitoring of H2S,SO?  anj  Chlorine Gas, hut not of of" er
       pollutants, as  has been ordered  by a circuit court.   T*>e  ' r-:>"
       did  not  order the district to  monitor other  pollutants.

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      g.      The total program,  including diversion of the Lake  Rron!
             Plants, was  estimated by G £*  H  in June,  1968 at $9,930,000
             (see Application  to NJPC ,  project  068^.   The  Program was
             estimated by   CPreeley f# Hersen o- April  23.  '•""?]
             $95,270,000  or  approximately  ten  ( 10)  fimes as  m^'-••-> .   And
             at Clavey,  the program  provides  for  1990  need"--  c.-<  "oi 'or
             1990 needs as contemplated all  the  time.

      LM"otEr. a<-d/or  the individual claimants  na.e appealed ine 1PCE3  order
      because of the  reasons described in  the above paragraph,*  a-g above &  d
      of  the  proceeding  paragraph and other facts  too numerous to mention.

2.0   Recommendations
      The  specific   recommendations contained  on pages "37  and 38  of  the
      FWQO  "draft"  have  gone a  long  way to satisfy  the  letter, spirit  and
      intent of section 101  of  the National  Environmental Policy Act  of
      1969, namely,  assuring the  residents in the immediate  area  of the
      plant. . .  "safe, healthful,  productive  and esthetically  and culturally
      pleasing surroundings''.   We commend  the  FVvOO for  an objective
      and unbiased study and evaluation of a  complex  problem, and  for  the
      specific recommendations,  which  increase the  degree  of safety established
      by State  Environmental agencies, by State Courts,  by NSSD and
      G- £c  H .    None of the  suggestions,  and comments contained herein
      should be misconstrued  by anyone, as opposfng  or disapproving  the"
      basic intent  of the PWQO, in  providing  maximum~sareTyand  protection
      to the people and  to  the enyipdnment, commensurate with cost
      consider ations .

      In order  that the people living near  Lake  Michigan are assured  of tt «-
      high  qualilv  of the water that they drink and swim in.   and that the
      Sewer  Connection ban  is lifted,  securing  employment  and preventing
      hardships  to  thousands  of families in eastern  Lake County,   (ne expan-
      sion  and/or  the construction of new  sewage treatment  facilities in  the
      NSSD  district  should   proceed,  but with  (he following exceotions .

2 . 1   Additional  Siormwater Retention  ( FWQO  ^ ec .  it. Nip.	1 a )

      O &•  H  admitted at IPCB  hearing  on April  29  and 30,   1971  that
      overflows  of  raw  sewage into Lake  Michigan will continue.   F'A'QC
      recommendation,   item 1a, to provide additional stormwater retention
      at Waukegan,  North  Chicago,  and the lakeside pumping  stat'ons ,  if
      properly  sized,  would eliminate any  discharges  of raw sewage i'Mo
      the  lake.

      Tfie  location  of retention basins at the lakeside pumping  station is
      preferred  because most of the infiltration  of stormwater  into  the
      sanitary system occurs in the older,  lakeside,  portions  of North
      Shore cities.    Pumping stations  would not have to  be sized  for
      transient  flow but  for steady state, dry  flow, conditions.  The savings
      in cost  could be used   to provide maximum safety.  The basins
      could be  either underground or covered,  with proper  ventilating  and
      air  pollution control  devices  and  proper landscaoing.
                                         6.

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      If a retention basin  is  located  at  the  Gary  Avenue  pumping station,
      the  retention  basin at Ciavey Road could  be eliminated or  reduced
      to a maximurr 5  MG size.

2 . 2   Size  of the Ciavey  Road Plant  (FWQO R ec._  Item No.  1b)

      This  item  has become  the single most  controversial issue.   Some
      people and groups,  living away  from either Ciavey Road or  Highland
      Park  have objected  to  a reduction  of the  Ciavey  Road Plant  because
      of misinformation and erroneous  assumptions.

      The facts  are as  follows:

          The reduction of the Ciavey Road Plant would not  cjglay the di-
          version of  the Lake front  plants, if anything  it will  speed  it up.

          NSSD construction  schedule of April  28,   1971  indicates
          Summer  of  1973 as the earliest  possible date when  the  following
          portions  of the  project will be  completed.

          1 .   Lake front  intercepting  sewers

          2.   Additional treatment facilities at Ciavey Road

          3.   North Chicago Plant additions

          4.   Waukegan additional treatment  facilities

          5.   Middle Pork Sewer

          6.   Gurnee - secondary facilities  (November 1 ,  1973)

      The projected completion  date  of  engineering for  additional  treatment
      facilities  at  Ciavey Road is  July   1 ,  1971 .   The reduction  in size  of
      the  facilities  should result in less time  required to complete drawings
      and  specifications.   An allowance of  4  months  for bids and award  of
      the  contract  could be reduced  to  2  months.   The construction of a
      reduced  (in  size)  lacility would  not have to take  21  months but could
      be  shortened  almost  in proportion to  the  reduction in  size.

      The IPCP  order  is  being appealed by  the NSSD, the Lake County
      Builders Assn.  and  the  Lake  County  Constructors Assn. and
      LMPotEE.    A review  was  asked for by the Waukegan -  North  Chica^
      Chamber  of  Commerce,  Zion  -  Erenton Chamber of Commerce  and
      Lake  County  Building Trades  Council.   The   issuance of  the
      $26,200,000  ($35,000,000 less  $8,800,000) is being  held  up because
      of pending  litigation.     NSSD  has  not  obtained all   easements  re-
      quired for  the Lake  front Intercepting Sewer,

      The diversion of the lake front plants will  not  take place  by July  1 ,
      1972 and  as  it was  shown in the preceeding paragraph ,  it may  not
      even take  place  in the  Summer  of  1973.

      In order that  the diversion does  take place  at the earliest  possible
      date,  the  final FWQO recommendations will have to be accepted by
      NSSD and L.VPotE.  When and if this happens,  all  litigation byLMPotE
      will  be dropped  and  a  spirit of co-operatio^ established,  which may it
      fluence the  other  interested  parties  to drop  their  litigation.

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FWQO statement that  "the plant (Clavey Road) is nowin an unfavorable
setting" backs up  the  convictions and  arguements of  LMPotE,  which
were made years ago,  when there was still  time  to take  corrective
measures  to  build another plant in a more suitable location and ul-
timately phaseout the Clavey  Road plant.   LMPotE seriously questions
whether the well being of tbe people living in the area  of  the Clavey
Road plant should be  jeopardized,  whether the people should be ex-
posed  to potential  health hazards and  whether  irretrievable ecological
damage should  take  place at  Clavey,  just because the trustees of NSSD
have steadfastly refused to listen to reason.   If it l»  now too  late to
abandon the Clavey  Road Plant altogether,  then at least it should be
kept to an absolute  minimum, so  that it  could  be phased  out at  some
future  date.

Recognizing the present need to  divert  the lake front plants and having
a concern for all  people living on adjacent lands to Lake  Michigan and
trying  to prevent hardships to  thousands of workers and their  families
and to builders  in eastern Lake  County,  LMPotE agrees in  principle
to expand  the Clavey  Road plant provided that the "latest  State of  the
Apt is assured" and that the plant is  kept to  the smallest  possible size.

The Clavey Road Plant is serving  areas extending to Grand Avenue  in
Waukegan  and including  Gurnee, Park  City and North  Chicago.  The
average flow is 6 MGD or less.   G  &1 H  testified in front of the IPCB
that average  flow  of the 5 lake front plants is  4 MGD.    The  diversion
of the  lake front plants to Clavey,  as was shown  above,  can not take
place prior to operation of the secondary facilities at Gurnee.   Thus
diversion of sewage from the Village  of Gurnee,  Park City and North
Chicago,  north  of 12th Street  to Gurnee S.T.P.  will  reduce  the
flow to Clavey by  at least 2  MGD.    Now that there is  a ban  on nevs
sewer connections,  an  increase  in MGD in the area  is not expected
until 1974,  when the expansion project  is completed.

Until  1974, when  the  Des Plaines plant could  go into  operation Ciavey
would  have to handle  the following flows:

    Present                      6MGD
    Less  Gurnee,  Park City
    parts  of  North Chicago      2MGD
    Subtotal                      4MGD
     Plus flow from  5  lake
    front plants                  4MGD
    Total                         8MGD

The effective ability  of an Activated Sludge Plant to  treat  sewage
could be  increased by 30 to  40% by the use of commercially  available
Coagulant  Chemicals,  in primary  and final tanks,  without  a loss in
efficiency, as long as  sludge handling facilities are adequate or the
sludge hauled away.

Using  the  conservative 30% figure,  the  present 4. 5MGD Clavey S.T.P.
could handle  6MGD , by the  use  of  Coagulant Chemicals,  by  September
1,  1971 when  the additional  sludge  handling facility is  scheduled for
completion.   A  6MGD STP  could handle  up to 8 MGD,  which is the
projected  now  at Ciavey by  1974.
                                  8.

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      The projected population of  Highland Park  and HIghwood in  year 2000
      will be  about 60,000.   Allowing  150 gallons per  day per person,  the
      size of  the  Clavey  Road STP, unless  it  is phased  out by then,
      would have to have a  capacity of  9MGD.    Handling Highland Park
      and Highwood, would  correspond  to a  1947 Official City  Plan of H.P0.

      Summarizing, Clavey  should be  expended to 6MGD , and coagulant
      chemicals should  be used when needed.  The plant should be phased
      out,  at  some future date,  because it is incompatible with  the area.   If
      for  some reason,  the  Clavey Road plant  is not phased out,  then an
      increase to 9MGD  would have to  take  place in the  early 1980's.

2.3   New,  18MGD Plant on  the  Des  Plaines River (FWQO Rec . It. No .  2)

      The Des Plaines River location has been considered  for a  STP
      by Lake County Regional  Planning Commission in their long range
      plan.   The specific site considered is  probably located between Milw-
      aukee Avenue and  the Des  Plaines River near a Sanitary landfill
      area.   The area is devoid  of  homes and residences and the environ-
      mental  impact  is negligible in comparison  to Clavey  Road.

      Should  the  NSSD  trustees  object  to this  location because it  is  outside
      their district,  then  they  will  have  to come up with an  equivalent area
      somewhere in the  southwestern portion of the  district.

2.4   Retention Basin at  Clavey Road  ( FWQO  Rec.  Item No.   1b)

      As  it was shown above, the stormwater  retention basin  at Clavey
      Road should  not exceed 5 million  gallons  capacity.   It should be
      completely covered or built  underground,  be provided with the  most
      advanced control  equipment  to  eliminate air  pollutants and odors anr!
      possible viruses ,  germs  and air borne infections , be  located far
      away from  Clavey  Road  and from residences  and be  completely
      obscured by  landscaping.   The presidementation  portion  of the covered
      basin could be disposed of,  if  some means  of  agitation  are provided.

2.5   Environmental damage during  construction (FWQO  Rec.  Item No.  3)

      The  restoration of  disrupted  areas during and because of construction
      may  be an  impossible  task  as  many of  the  trees  removed were very
      old.  It will  take many years  for  new  trees to  replace the old ones,
      particularly  in the  area  of the  Village of the Woods, where  numerous
      trees and other vegetation was removed to  make  space for  the
      Effluent Lagoon.

      FWQO  recommendation to limit environmental damage  during  construction
      and to  restore disrupted areas to their  former  condition  is highly
      commendable  and  should be  complied with .

2 . 6   Effjuent Lagoon

      The  history  of the  Effluent Lagoon v,r^
      mental,  ecological  damage to the  area  of  the VMr-Kj*- o* 'he Vv'oo.-Js
      could have  been  avoided and the  taxpa\e^s  vvouul '"«• r   n <" •.; $300.000
      to $400,000.

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      The lagoon would provide some additional  treatment,  to the present
      secondary Effluent,   The  Lagoon  could  not  increase  the capacity  of
      the  plant, nor  can it  be used ss a  retention  basin,   it's effect  on the
      quality of  water  in the  Skokie  ditch would be  very  limited, as most
      of the  damage is done  by  raw  sewage overflows, after and during
      rainfalls, and  not by the quality of  the  secondary effluent.

      Effluent  lagoons  are  used  in areas where  land values  are very low.
      In accordance with established  10  Slate  standards,  Jhev  should be
                                                           '     *
      located far  away from  habitation.

      The decision  to  use  the Lagoon at Clavey was  based  on» economic
      considerations as the effluent lagoon and  forced  main  to the Des
      Plaines  River were  less  expensive  than  a tertiary plant at Clavey.
      (^or references see O- £>• H Studies in  1967).

      An  advanced  treatment  facility  will  be  built at Clavey.   It  could be-
      come operative not or  November  1 ,  1974  as shown on NSSD sche-
      dule of 4/28/71  but  sometime ir 1973,  as  will be shown in an en-
      gineering report  to be  prepared by  Mr.  Vinton  Sacon for  the City
      of H.P. .

      Rather than  to spent  additional  $300,000  to $500,000  of taxpayers
      money for a facility  considered interim by  the  I PCS,  a much  smaller
      i".<. est'^ent in  coagulant  chemicals would  considerable  improve  the
      efficiency of  the  presently  overloaded plant.  The result 'would be an
      effluent of  much  higher  quality  at a lower cost.

      LMPctE  demands, that the construction  of the Effluent Lagoon is
      stopped  immediately  and that the area  is  restored,  as  close as
      possible, to  it's  original condition,   thus providing a  natural  buffer
      zone for  the homes  and people in  the  Village of  the Woods  subdivision,
      -->ow located  across  the road from  the  lagoon.

2 . 7   Chlorine  Handling

      CMorine  Institute's pamphlet  on "Facilities  and Operating Procedures
      for  Chlorine Storage"  states in P.  2.1  C-eneral  Area, ''Where
      practical,  tanks  should be located  away  from  densely  occupies areas.1
      As  chlorine  gas  Is poisonous and  the  chlorine ton cylinders would  be
      located outdoors  about   150  feet away from homes,  the use  of  Sodium
      H vpochlor ite  in lieu  of   liquid chlorine  is  imperative.    Dr. Quon .  con-
      sultant to tn e City of H.P.  recommended  the use of sodium: hypoch-
      lorite at *-is  first meeting  with  the  City fathers July  7, 1970.   VSD
      is using scc'i'.m  hypochlorite solution at all of its plants.   NSSC1 is
      using  i!  at the 5  lake front plants.   The  City of Chicago does not
      aMow c-lori^e within 1/9  of  a mile of  hom.es.    The  3uilding Officials
      Conference oi America E3asic Pire Prevention Code,   adopted by the
      Citx of H ca .-> ,  or d' -ance requires a 1 '"'our fireproof  building  for
      Storage  Ot chlorine.

      S jmmar iz ing ,  the use  of  Sodium M \ poch lor ite  is  imperative in I'eu
      of  liquid chlorine.

-------
2.8   Landscaping  (^WQO  Rec.  Item No. 4)
      Landscaping  should be done in a manner  that it  will completely
      obscure the facility from residences, churches and pedestrian and cars
      travelling on  Clavey and Lake Cook Roads.   The  PWQO recommenda-
      tion is commended  highly.

2,9   Sjudy  of  environmental consequences ,  of diversion  of water  from  one
      watershed to another  (PWQO  Rec.  Item No. 5a).

      This study  will be  of  tremendous importance to  conservationists
      concerned with possible upsetting of the  laws  of  nature  b^y not returning
      water  to  the  watershed  from where the  water originated.

      The  decision to  divert all  flow of sanitary and industrial wastes  away
      from Lake  Michigan and possible future  requirements to divert land
      runnoffs  from  the lake was  made to stop the eutriphication of the
      Lake.   The  long range effects of diversion  into  the rivers  emptying
      in  the  Gulf  of  Mexico could  be detrimental .As soon asthe eutriphication
      of  the  Lake has been  stopped  and reversed  and  once the effect  of
      different  substances on the lake and its aquatic life are  known and are
      controlled,  or found not detrimental,  a decision may be reached to
      redivert  the flow  into Lake  Michigan.  A  PWQO  study  of the problem
      is  commended highly.

2.10   Study  including monitoring of Air  Pollutants,  Germs  Viruses	and
      possibility of air _borne infection (PWQO Item  No.  5b)

      Although  monitoring is not specifically mentioned  in PWQO recommenda-
      tion,  LMPotE assumes  that monitoring,  alarm and recording will  be
      made  of  air  pollutants,  viruses,  and germs.

      G  E> H testifying in  front  of  1PCB on April 29  & 30 , 1971  admitted
      that the only pollutants that will be monitored  will  be:   Hydrogen
      sulphide  (HjS),  Sulphur  Dioxide (SO£) and chlorine gas.

      If  monitoring is to be of  value, then  it  should  be  complete, and both
      inside  and around th plant.

      T>->e pollutants to  be monitored  should include  H ^> , mercaptans,
      Carbon aisuifide,  SC^,  SO-j ,   Sulfuric acid,  NO2 ,  bacteria  and
      viruses.   Moritorinq the  mercaptans in addition to  hydrogen  sulfide is
      essential . since  the\ are organic  sulfur  compounds  with  odor thresholds
      of  approximately 100 tiroes lower  than  hydrogen sulfide.   Therefore,
      hydrogen sulfide readings  could be  low  and  yet the  area could be
      experiencing odors  due  to the  mercaptans  and carbon disulfide.   The
      latter  two would be undetected  with  the presently planned monitoring
      system.   The nitrogen oxides  should also  be  monitored  since nitrogen
      compounds  are formed in  the  digestors.   These  compounds  can  be
      oxidized  by  combustion to  nitrogen oxides which  would  be emitted  to the
      atmosphere.

      The above  comprehensive study ,  the first  of  its kind will benefit  not
      only Highland  Park residents,  but ail mankind.

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3.0   Conclusion
     The  two (2) principal parties in  conflict   NSSD and LMPotE  have
     to resolve  their differences so that Sewage Treatment facilities in
     eastern Lake Count/, Illinois &re built  and/or  expanded,  at  an
     earliest possible moment.

     The  conflict  can be resolved  either by  litigation in  State  and Feder-al
     courts  for  a number  of years, or by a reasonable agreement, sanc-
     tioned by Federal  and State Environmental'agencies  and Courts.

     LMPotE prime  concern  is  the well being  of the greatest" number  of
     people,  and  the protection of  human and constitutional rights  of  the
     people  involved.

     The  FWQO  Final  Environmental  Impact Statement, if modified  as
     recommended in Paragraph 2.0  through Paragraph  2,10  will provide
     a  reasonable base for an agreement  and will be directly responsible  for
     resolving a very complex problem, for the benefit  of  the people.

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360  Charal Lane
Highland  Park,  Illinois 60035
May 24,  1971
Mr. Gary Schenzel
Water  Resources  Planner
Planning  Branch
Environmental Protection Agency
Water  Quality  Office
R oom  410
33  Weat Congress Parkway
Chicago,  Illinois 60605
                               RE:   Technical &  Engineering Comments
                                      on the Draft Environmental Statement
                                      Sewage  Project No.  WPC-I1L- 754
                                      North Shore Sanitary District
Dear Mr. Schenzel:
      Enclosed  please find 3  (three)  copies of our technical  and
engineering comments on your  preliminary statement,  which  was
released April  23, 1971.   We  commend  highly your  efforts to
satisfy the letter,  spirit and intent of  section  101 ,  of  the  National
Environmental Policy Act  of  1969.   Our comments  and suggestions
should not be misconstrued as  opposing or disapproving your
basic intent to provide maximum safety and protection to  the
people and to the  environment.

      We trust that you will adopt  our comments and  suggestions,
so that  your final draft,  complying fully with the 1969  Environ-
mental Act, will provide a  base to resolve this  complex  Issue
to the benefit  of  the people.

      For your   reference, we are enclosing  copies  of resolutions
passed  by the following Civic and Environmental  groups, which
will be  directly   affected  by your  final recommendations.

1  .    Committee  to Save Highland Park (Now Lake  Michigan
      Protectors of the Environment)  representing over  300
      families.

2.    Environmental Control Commission  of Highland  Park

3.    Board of Education  School  District  108  of Highland Park

4.    Deere Park  Neighborhood Association of Highland  Park

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Page 2
May 24,  1971
Mr.  Gary Sohenzel
Environmental  Protection  Agency
5.    (CAP)  Campaign Anti-Pollution of Chicago,  III.

6.    (SAVE) Society  Against  Violence to  the  Environment,  Chicago.
      and North Shore

7.    North Shore Radiologists,  S.C.,  Evanston, Illinois

      The  Clergy of  Highland Park and  Highwood  and other local
Civic groups  will be contacting  you directly.  Under separate cover
you will  receive our groups comments including  concern for a health
study, which  should  take  place  prior  to  release  of a final statement.

      We pray that your final recommendations,  provide the maximum
safety to the people and to the environment  in the area.
Sincerely yours,
Arpos  Turner,  P.EE.
Director
Lake Michigan Protectors  of the Environment

AT:pk

cc:  Hon. Senator C. H.  Percy
     Hon. Senator A. EL.  Stevenson,  111
     Hon. Governor R. B. Ogflvfe
     Hon. l_t.  Gov.  P. Simon
     Hon. Atty General W. Scott
     Hon. Congressman R. McClory
     Hon. K. Bernfng
     Hon. J.  H.  Klelne
     Hon. G. W. Llndberg
     Hon. D. M. Pierce
     Hon. R. R. Coles
     Hon. R. J.  Geraci
     Messrs:  W.  Ruckelshaus,  D.  Dominick, A. J.  Barnes, F.  T.  Mayo,
     W. Blaser,  R.  J. Kissel, M. Schneide^man,  J. V. Karaganfs
     Drs: D. P. Currie,  F.  D.  Yoder,  J.  F.  Pfeffer

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             1?oi  NT. Gary
                                          33
                                          Chicago,  Illinois
   b«ing members of the Committee to Save Highland park  (Persons who  are
 amedlately affected by the enviroraental impact of the Clavey Road  Sewage  Trea
ment Plant) do hereby state the following!

"We have waited so long for truly a objective study of the Clavey Road Sewage
Treatment Plant in Highland park, Illinois, embracing a  grand view  of the  Grea
Lakes Water Quality Control Problems.  We commend your preliminary  draft and
urge you to preset Its scientific findings ngalnst local political greed  and
mis-information.  We beg your office to make the best decision on our behalf
and protect our HEALT;T. WELFARE. ANT HAPPINESS A3 HUKAK  BEINGS DIRECTLY
AFFECTED BY YOUR FINAL DECISION.

             Stanley f-resler
             5 '^ e 1 ^ o n 8 °> c r 38 n
             Sheldon Be^n
             San aosscv
             Arthur Salt
             Alan i^elson
             Heyman(Jerome)
             Albert fllssen
             John R.  .-?ss
             S«rl Liner.
             Meyer Schwachman
             Sidney Shapiro
             Ronald Mier^nberor
             Robert Don
             Malcol'C .'Jachbar
             Jay Caplan
             Lester Erower
             Jerome Kiefus
             Jeral^ Miller
             Robert Hirsc>
             Herbert Leviton
             Paul Brown
             Arthur Sosensteln
             Kirsch
             Joseph Stone
             Herbert Srheonbrod
             Maynard Rowe
             Alex Poll»k
             , Richard Lewis
             Sruoe ?lu"nenthal
             '•/illiam C»in
             Joseph Rubin
             Herbert Loeb III
             Jerrold
             Michael
             Morton Simons
             , Sheldon
             Henry Newman
             Sidney Feskin
             Robert Zelekow
             WilliAm Meltzer
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                            Page  5
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-------
v •  "''
,' „                     "The ECC recommends to the City Council of
                       Highland Park that the City officially sup-
                       port the following recommendation and send
                       a letter of intent on this matter to the
                       Federal Water Quality Administration Office
                       of the United States Environmental Protection
                       Agency before May 22, IS71.

                          1.  All possible air pollutants be monitored.
                          2.  The effluent lagoon will be eliminated in
                              favor of the advanced sewage treatment
                              facilities.
                          3.  The storm retention basins be completely
                              covered.
                          H.  Trees and vegetation be planted to pro-
                              vide a buffer zone.

-------
        the Board or rdjcarior. of School District 108 is
concerned vith the he
-------
                           DONALD  N. MANN

                               ATTDHNCY AT LAW
                             lit SOUTH OCCflC »ABK 0«IV«

                         HIOHLANO  (»AH1C. ILLINOIS  «Oa3»
                                 lOkKwooo 9*>3O5
May
                                         1971
Knvirrm*»pt.a1  h-otaction Agency
Water 'Jus ! ity  Office
Room (HO
11 West Congress  Parkway
Chicaro,  Illinois  6060$'

ATT: Mr.  Gary  W. Schenzel
     Water Resources  ^lanner - Pi anninp Branch

Dear Mr.  Schenzel:

By action of the Board of Directors of the ^eere Park Npirhhorhood
taken on  Wednesday, May 19,  1971 we wish to po on r«cord  as  favoring ih*
FEDERAL WATER  QUALITY OFFICE draft as to the matter on Clavey  Road in
Highland  *ark,  minois.

We believe such action is necessary to preserve not only  the coimunity
but also  the total ecolopy of the area.

                  srt  and help in anyway possible.
                               /
                               VR PARK. NEHBRHD.

-------
                           60O west fuilerton ase.
                           Chicago, Illinois 60814^

                                            929 2922
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-------
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-------
                NORTH  SHORE  RADIOLOGISTS,  S.  C.

                       2500 RIOGF AVE  SUirc 203

                       E V A N 5 "" O N   ILLINOIS  C C 2 0 1

                           T t L E. P H o N c H 6 '< - 4 t, e, d
   T v, H P* ' s- ,  M  .

• L- W K Q A ! ' /  fc.^  :
                                             Hay 17, 1971
  Eav1ro«watal  Prota, Illinois   606K
           V.
        Kttoercn Plarmer
           Branch
                                                           S.T.P.
                                                       Water QMHty Off1«*
                                                             Drift
  tad
      before me a espy of v»ur C1av«y Road draft,   I support tfeac*
        that
              a  12 H60 pUnt Is still  tso Ur^, md that a ttef1n1t«
  H»k p«t«nt
-------
lUt>  iri  x/ tilth!ixon  xl I'i'i'l    •    rliiniiiii,  i/liinii*  t)OI>t)()
 \STKI!.\   IU  '
N'ii   COM.MiS
                                                                            WALCEVAR A  P.'.-
                                                                                   Sec.'€
                                        May 10, 1971
           Mr.  Gary Schenzel
           Regional Director
           Water Quality Office
           U.S. Environmental Protection Agency
           Region V
           33 East Congress Parkway
           Room 410
           Chicago, IL  60605

           Dear Mr. Schenzel:

           In accordance with your request of April 22 ,  please find a copy
           of our comments  on the Draft Environmental Statement recently
           forwarded to us.
                                                Sincerely,
           MLR.-im
           Encl.
                                                Matthew L. Rockwell
                                                Executive  Director
 "' f P-S-v'">CK. A'tarney   !RA J  BACh Prp<; L;'^,i
  r . -TO, MjyC' ol is Grange   fPED '.' 0' '\'nt  '.'
 .'. ^- v_l C/^-rdgo Co^i-^ri^ ;"inr r r' P/^nn-,"^   f  .-P
  ,.',f r ! 'Ters  •  HERVAN L OLIVO, W C.-./ ". ? ',=>

-------
                   North Shore Sanitary District Plan

  Evaluation of Water Quality Office, Environmental Protection Agency

                      DRAFT IMPACT STATEMENT
1.  Purpose - The purpose of this memorandum is to review the referenced
Impact Statement transmitted to us by letter dated April 22, 1971, which
consisted of the draft Statement itself and appendices A thru E.

2.  Scope - The report covers the entire plan of the North Shore Sanitary
District (NSSD) .  However,  the only reasons for the report itself are the
diverse opinions concerning the Clavey Road wastewater treatment plant.
Accordingly,  these comments will restrict themselves to that facility.

3.  Size - The  Clavey Road plant now handles between 5.5 and 6.0 MGD
as an annual average during the past two years.  The original  plan called
for the expansion of  this facility, with the diversion of the wastewater
loads to it from five  other existing plants  located on the lakefront.  The
plans were to provide for future growth as well and for a higher degree of
treatment  to meet current and proposed water quality standards.  The NIPC
Regional Wastewater Plan envisions that by 1990 ihe load coming to the
plant  would be  28.9  MGD, and by the year 2010, 35.7 MGD.  However,
by mutual agreement between the  NSSD and local officials, after a series
of legal and administraiive actions, the NSSD agreed to restrict the ulti-
mate capacity to 18.0 MGD. This decision implied the obligation to con-
struct the required extra capacity elsewhere in the system.

      a.  The five lakeside plants which  are to  be abandoned have
      experienced annual average loads during the past two years
      which ranged between 6.0 MGD and  6.6 MGD.  Accordingly,
      if these loads  were instantaneously transferred to the  Clavey
      Road facility,  the current load would be between 11.5 MGD
      and 12.6 MGD.

      b.  The Clavey Road  plant  is being expanded to 18.0 MGD
      but will not be ready for use until sometime in mid-1973.  If
      allowances for normal growth in the area are included,  the
      required capacity at that time will be higher than the current
      load, giving due consideration to sewer permits already is-
      sued.  At the  same time, cognizance is taken of the Illinois
      Environmental  Protection Agency ban against any additional
      sewer connections,  an action which  was recently taken.
      Thus, the question of wastewater loads by mid-1973 becomes
      somewhat academic, but certainly will be  on the order of
      12 MGD.

-------
      c.   The draft Impact Statement includes the finding that the
      expansion of the Clavey Road plant should be limited to 12.0
      MGD.  The rationale is that this size will permit the plant to
      accommodate  the current load now being treated at Clavey
      and the five lakefront plants.

      d.   The lead  time necessary for starting  planning and finally
      constructing a supplementary plant elsewhere will be further
      lengthened by whatever delays  are incurred before a  final
      decision  is reached on the ultimate size of the  Clavey Road
      plant.

      e.   It is good engineering and  economics to construct muni-
      cipal wastewater treatment facilities so as to accommodate
      future (forecast) wastewater loads.  For permanent facilities,
      a design  period of fifteen to twenty years  in the future is
      acceptable.  Construction to accommodate merely the immedi-
      ate loads is rarely,  if ever,  done and thus would be  contrary
      to  good judgement and past experience.

      f.   The NIPC Regional Wastewater Study, which was made
      prior to the adoption of the Regional  Wastewater Plan,  gave
      due consideration to all of the factors which have been pre-
      sented  in this Impact Statement.  After a  number of confer-
      ences with affected municipal governments, public officials
      and private groups,  and  after a series of public meetings  and
      hearings, the Plan was adopted on March  3, 1971.  It calls
      for a size of 18 MGD.

      g.   It is  concluded that no information has been revealed in
      this Impact Statement which would lead to a reduction in this
      capacity.

4.  Environment - Our studies took cognizance of the past problems of
odors and other related nuisances associated with the operation of the
Clavey Road plant.  We found that these resulted from a variety of rea-
sons which ranged from  inexperienced employees working  on newly con-
structed  (or expanded) facilities, equipment breakdowns,  etc.,  to the
actual overloading of the plant itself.  It would be an irrational  conclu-
sion that these  occurrences could be guaranteed not to ever occur again.
However, it can be  said that they can be reduced to a  minimum by public
pressure  (such  as is currently existing), by the new water  quality stan-
dards and by  stricter enforcement procedures,  together with better training
of employees, redundancy in critical equipment and the eliminatior- or
reduction in plant overloading.  We sympathize with the nearby  residents

-------
who have had their sensibilities insulted during the  past.  At the same
time,  we should call attention to the fact that in at least two areas  in our
region,  wastewater treatment plants have attracted urbanization literally
up to the fence and property lines of recently constructed wastewater
treatment plants.  The Metropolitan Sanitary District of Greater Chicago
Hanover plant is one example.  Perhaps more dramatic is the South Naper-
ville ,'lant,  which is currently being expanded and upgraded.  Concurrently
with the work now underway, townhouses and apartments are being con-
structed directly across the street from the plant,  a  distance of less than
one hundred feet.  Other townhouses are being  constructed directly  across
the West Branch of the DuPage  River, which the plant site abuts.  The
conclusion that residences in the immediate vicinity  of treatment plants
are not  automatically ruled out  is self-evident.  The  fact that developers
and occupants are currently doing this elsewhere is  prima facie evidence.
It is further concluded that any delays in diverting the wastewater efflu-
ents from Lake  Michigan will have  a continuing adverse  impact  on the
enjoyment of Lake Michigan as a recreational site and a source of potable
water,  by a far larger number of people who already have been denied  this
use for  a number of years,  or who have had to pay a premium.

5.  Participatory Democracy -  Decisions such as these,  in the past,  have
usually been made on the basis of technical engineering judgements and
sound economics.  Within recent years,  it has  been necessary to consider
environmental and sociological impacts.  Decisions in these latter fields
are recognized  as  being based on political and  emotional reactions of  the
affected persons.  This is rightfully so,  since exact  quantitative measures
are impossible  to achieve.  Consistent with the aforegoing new approach,
it has been recognized that the ai.ected persons should have a voice in
influencing th.  -inal choice or decision.  Hence,  the phrase "participatory
democracy".  I  -he NSSD area, the people in the entire District have
spoken  and made their choices  known by a favorable  bond referendum  sup-
porting  the financing of the  system as  is currently being espoused by  the
officials of that District. In the  closer area of  Highland Park itself,
elected officials have  reacted by negotiating the reduction in size of the
plant,  limiting  it to 18 MGD and calling for the installation or construction
of other safeguards and controls.  The objections  to the  system as  currently
envisioned are  limited to a small group of persons who are directly affected.
The basic principles of democracy call for the exercise of governmental
decisions by those directly affected or through their elected officials.  It
appears that this has been done in the NSSD.   Unfortunately, the decision
is unacceptable to a few.

-------
GORDON SHI-.KVMN
 President
ALI\\S»ER POLIKOFF
 Fxecuuve Director
MARSHALL PATNF.R
 General Counsel
DAVIO DINSMORE
 Director i
-------
Water Quality Office                  May 24, 1971
                                          Pacre Two
       As disclosed in testimony before the Illinois
Pollution Control Board, North Shore Sanitary District
records show a measured flow of 12.0 mgd during the
summer of 1969 (the five lakefront plants plus Clavey
Road) and 12.1 mgd during the summer of 1970.  Increased
flow resulting from new construction since the summer
of 1970 is of course to be anticipated.  Indeed, the
Draft Statement itself states that the Clavey Plant
must be designed to treat a "minimum sewage flow of
12 mgd."  (p.28, emphasis added.)

       The Draft Statement estimates that additional
recommended capacity  (in the amount of 18 mgd) can be
provided in a new facility to be located near the Des
Plaines River within  "the next several years."   (p. 23.)
It appears to us that the Draft Statement's assumptions
in this regard are unrealistic and fail to take account
of facts which make the realization of the Des Plaines
Plant objective, within the assumed time period, highly
unlikely.

       The North Shore Sanitary District does not at
present own land on the Des Plaines River; property in
the  area suggested by the Draft Statement - near the
County Line - has already been subdivided, with the
consequence that many different owners of real estate
are  involved; the area is at present outside the
territorial jurisdiction of the Sanitary District; and
the  Sanitary District does not have a "quick taking"
power under Illinois  law.  For these several reasons, the
land acquisition process is likely to be lengthy.
Experience suggests that it may take at least several
years.

       Assuming that plans and specifications are prepared
while land is being acquired, construction would still
take several additional years.  It thus appears that a new
facility at the Des Plaines Location might not be made
available within less than six years.  Even this time
frame may be optimistic because the resolution of some
of the difficulties,  for example, the legal question
with respect to territorial jurisdiction, is not
predictable.  Accordingly, even assuming the desirability
of constructing an additional facility on the Des Plaines
River as recommended by the Draft Statement, such a
"relief plant" could not be counted on to be available in
less than six vears . and oerhaos not then.

-------
Water Quality Office                  May 24, 1971
                                        Page Three
       It follows that the Clavey Road expansion must
be large enough to handle anticipated flow without
"relief" for at least the next six years.  As noted
above, that flow will be in excess of 12 mgd at the time
the Clavey expansion is completed.  It will increase
thereafter.  The Draft Statement itself suggests that
even an 18 mgd Clavey Plant would require "a second
plant at Des Plaines" in about five years.  (p.30.)  If
the flow at Clavey is expected to be 18 mgd within 5 years,
it is difficult to see how a facility of lesser capacity
than that can be recommended now.*

2.  Retention Basin Capacity at Clavey Road

       The Draft Statement rightly rejects the discharge
of stormwater overload into Lake Michigan from the
northern end of the Sanitary District territory.   (p.27.)
*The consequence of overloading a Clavey Road Plant
 expanded to only 12 mgd must be a discharge of inadequately
 treated effluent either to Lake Michigan or to the Skokie
 drainage area.  The former possibility is not to be
 countenanced for the reasons set forth in the brief,
 previously submitted to the Illinois Pollution Control
 Board by Businessmen for the Public Interest, a copy of
 which is attached hereto.  We will not in these comments
 repeat the brief's observations respecting the critical
 condition of Lake Michigan but respectfully refer the
 Water Quality Office thereto.  We believe it to be plain
 that the critical condition of Lake Michigan, poised
 as it may be at the breakpoint of irreversible degradation,
 renders this alternative completely inadmissible.

    Discharge of the overload through the Skokie drainage
 ditch is also extremely undesirable, and would mean
 continuing environmental degradation to the Skokie Lagoons
 area.

    The Draft Statement also says that when the Highland
 Park lakeside plants are phased out, the "levels of
 stormwater infiltration into the sewers will have been
 substantively checked."  (p.24.)   No evidence is referred
 to to support this conclusion.  Independent inquiry of
 Highland Park officials suggests that it is overly
 ODtirnistic.

-------
Water Quality Office                  May 24, 1971
                                         Page Four
The same principle of course applies at the southern
end of the District, and retention basin capacity
large enough to handle stormwater overflow must
therefore be provided.

       The Draft Statement suggests a reduction in
the capacity of the retention basin at Clavey Road
from twenty to ten million gallons, subject to
reevaluation.   (p.31.)  It seems quite plain that,
for the reasons given above, the smaller retention basin
capacity will not be adequate to handle the anticipated
stormwater overflow.  Indeed, if the treatment capacity
of the Clavey Plant is to be "shaved" close to the
anticipated maximum load, it is especially important
that retention basin capacity be sufficient to provide
for larger than projected flows.

       (Without explanation, the Draft Statement, while
recommending a 33-1/3% reduction in the capacity of the
Clavey Plant,  recommends a 50% reduction in the capacity
of the retention basin.  The disproportion seems
unjustified.  And although additional retention basin
capacity is recommended at the lakefront sites (p.37),
there is inadequate discussion of this possibility and
strong doubt as to the advisability of such a step.  It
is questionable, for example, whether sufficient land
area exists and even if it does, whether retention basins
are an appropriate use for lake front land.)

3.  Health Concerns

       It seems clear that were it not for the health
concerns expressed in the Draft Statement the proper
course of action would be to expand the Clavey Plant at
this time sufficiently to handle anticipated future flows
with a safe margin of error.  The health concerns are
undoubtedly the principal reason for the Draft Statement's
recommendation that the projected size of the Clavey
Plant be reduced.

       It cannot be said with absolute scientific certainty
that the concerns respecting health are without any
foundation.  It can be said, however, that the operation
of a much larger facility of the Metropolitan Sanitary
District of Chicago in a residential area on the north
side of Chicago for many years has not produced any known

-------
Water Quality Office                  May 24, 1971
                                         Page Five
health problems.  The sheer size of this facility,
400 mgd as compared with the proposed 18 mgd for
Clavey (operated, incidentally, with completely
uncovered retention basins as contrasted with the
partially covered basins proposed for Clavey),
suggests that the health concerns may be unfounded
or minimal.  In any event, if future research should
prove otherwise, the covering of retention basins
could then be required.

       While health concerns are of course paramount,
health concerns arise from a continued overloading
of the Clavey Road facility as well.  The consequence
of such overloading, as noted, is to discharge
inadequately treated sewage into the public's waters,
producing a health concern of a sort which is well
documented and scientifically established, as contrasted
with theso far undocumented and unestablished concern
referred to in the Draft Statement.*  If, as we believe,
the practical choice which the District faces is to
continue to overload the Clavey Plant for some years
or to build adequate capacity into that Plant now, the
known facts concerning health concerns seem to dictate
the latter course.
       There are many additional aspects of the Draft
Statement about which it would be appropriate to comment,
e.g.,  the likelihood that revision of plans now will
delay completion of the Clavey Plant expansion and thereby
delay cessation of discharges to Lake Michigan.  However,
we have deliberately confined these comments to what seem
to us to be a few observations which, taken together,
*The evidence respecting airborne transmission referred
 to in the Draft Statement appears to relate to the
 activated sludge process, not to waters which are
 quiescent as they will be in the Clavey Plant retention
 basin.

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Water Quality Office                  May 24, 1971
                                          Paqe Six
strongly indicate that revision of the Draft
Statement is required.  As our amicus brief to the
Illinois Pollution Control Board indicates, the
supervening environmental concern at this ~ime must
be for the condition of Lake Michigan.  In our
view, for the reasons given above, this consideration
dictates the present expansion of the Clavey Road
facility substantially as originally proposed.

                   Very truly yours,

                   BUSINESSMEN FOR THE PUBLIC INTEREST
                   EY
                             Alexander P
                            David Dinsmore Comey
ALP:eo
Enc.

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                     ARGONNE  NATIONAL LABORATORY
                                                           May 24, 1971
      Mr. R. J.  Schneider
      Regional  Director
      Water  Quality Office
      U.  S.  Environmental Protection Agency,  Region V
      33  East Congress Parkway,  Room 410
      Chicago,  Illinois  60605

      Dear Mr.  Schneider:

             This  is in  reference to the Draft Environmental Impact Statement
      prepared  by  your office for the NSSD Sewerage Project Number WPC-I11.754.

             In general,  I  find  the impact statement to be accurate and agree
      with your recommended modifications for the project.

             The relatively small marginal costs which you associate with your
      proposed  modification of the Clavey Road facility appear to be justified
      in  terms  of  improved  air quality in the immediate vicinity of the plant
      and in terms  of improved water quality  downstream of the plant.

             I  would like to suggest that the Water Quality Office consider a
      detailed  water quality monitoring program for the Skokie River.  The
      Skokie River  represents a  "managed environment" and offers an excellent
      opportunity  for evaluating on a small scale the benefits to be derived
      from improved waste water  management practices.

                                   Sincerely yours,
                                  Joseph G.  .Asbury
                                  Center for Environmental Studies
      JGA:nck
9700 South Cass Avenue, Argonne, Illmo's 60439 T-ifc

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find fault with the Committee, vie have in the past ourselves.
However, in our hearts we know we could never fault these
people for their purpose, We believe that every person has a
basic, undeniable right to a clean and unpolluted environment.
If those residents had not united and cried out their rights
would have been violated with the presence of an air polluting
sewage plant in their back yard.

     Unfortunately, our group has also in the past found fault
with the North Shore Sanitary District. The district is too
often motivated by economic considerations and have a tendency
to "cut corners." This is why we are so thankful for the Water
Quality Office stepping in with an impact statement. We believe
the report, if adhered to, will assure us of a safe plant at
Clavey Road.

     We realize that there is oppos'.tion to the report. The
Illinois Pollution Control Board, a just and honorable board,
approved the NSSD's expansion plans( adding tertiary treatment).
We are afraid, however, that the control board gave the district
too much leeway on what the district is abls to daoide to do.

     The city of dighland Park has also not officially supported
the impact statement although neither do they support the control
board's ruling. The city wants to remain neutral and just
doesn't want to offend anybody. It's understandable of course
but it's just so frustrating, so depressing to see politics
getting mixed in with efforts to stop pollution,,

     Please sir, we appeal to you, stick to your report. 3e
above politics and act honorably. Our city, caught in between
in this conflict, has sincerely tried to act as mediator and
to do what is right for the people, However the city just
doesn't have the power or influence to bring this messy and
damaging conflict to a close, Y.ou do. Because j on sir, have the
ultimate tool for leverage, the almighty dollar. We urge you
to make these points non-negotiable: a covered storm retension
basin, no effuent lagoon, advanced water treatment facilities
adequate for the Skokie Lagoon, restoration of any of the
landscape damaged duyirg constuction, and a sewage plant as
small and safe as p~ Jble.

     In closing I want to say this. Next fall for the first
time in our nation's history a new class of citizens will have
the vote, 13 year-olds. For years now students have lashed
out against the system they have so much disdain for. Next year
I, like millions of other college students, will have my first
chance to participate in our political system with a vote. We
students will have an unprecedented opportunity to bring about

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                                  600 west fullerton ave.
                                  Chicago, Illinois 6081^
                                                        ^•N ^"^ j**"\ f*<*. Jf~^ S~>- •*"
                                                        QOO vQ^t
                                                        tj&*y #do
-------
                      -3-
vast new reforms for the good of this nation. Will our idealism
for change be converted inte constructive efforts to make
©ur government respond of will our hopes be soured by a view of
government as corrupt and unrepresentative. Don't you see sir,
whether of not I cast a vote of a brick nest year could very
depend on your decision.

-------
                   GARDNER, CARTON, DOUGLAS, CHILGREN & WAUD
JAMES H DOUGLAS
ARTH LJ R D OH i LGR E N
ML-/~ R 'SON WAU D
JAMES A V E !_ D E
ROBERT F GRAHAM
L_AUR£NCE A CARTON
GORDON H SMiT1-1
_ ^ G Y C VV SOWERS
ROBE-H^A GARDNER JR
W i i_ _ ' A M .j N E A i_ 0 N
RAY GARRETT ^ p
PETES M M E R L N
_' O S E ^ <-> => CARR
JAMES „ M c C L L, R E JR
-jOH N -j Ci-ERKiN
THCMAS ARTHUR
-ViL^iAM i_ MORRISON
o O i-i \ K N OTZ J R
GORDON _ANG JR
^.CE A SUTHERLAND
DALE PARK ^ R
-CHS ~ 3 E G GA N
-V  - G R ENE^SE^GE0
 ONE FIRST NATIONAL PLAZA

CHICAGO, ILLINOIS 60670

  AREA CODE 312  726-2-452

     CAS L E-GARCAR
         May 21, 1971
HENRY A GARDNER
     1883 1968'
ALFRED T CARTON
ANTHONY L MICHEL
VEPNON R ^OUCKS
     COUNSEL

JOHN A BROSS JR
L EDWARD BRYANT ^ P
2ANE COHN
GEORGE M COV'NGTON
DEWEY 3 CRAWFORD
JOHN T C'JSACK
PAUL H  DYKSTRA
THOMAS A KILLOREN
GEORGE C McKANN
SARRY T ^CNAMARA
JOHN E REINERT
JAMES G REYNOLDS
= OBERT j w,i_C:EK
       Mr.  Richard MacMullen
       United States Environment
         Protection Agency
       Federal Water Quality Office
       Room 410
       333  East Congress Parkway
       Chicago, Illinois 60605

                 Re:  North Shore  Sanitary District
                      Clavey Road  Sewage Treatment Plant

       Dear Mr. MacMullen:

                 Further to our recent telephone conversation I would
       like to submit the following  information on behalf of  the
       Chicago Horticultural Society,  of which I am a Vice President
       and  for which I act as  legal  counsel.

                 (1)  The Chicago  Historical Society is in the process
       of constructing a botanic garden on some 300 acres of  land
       leased from  the Forest  Preserve District of Cook County at  a
       site immediately south  of Lake  Cook Road and east of Kennedy
       Expressway.   The East Skokie  Drainage Ditch bisects this tract
       of land.
                 (2)  Since the  effluent of the Clavey Road Sewage
       Treatment Plant and other sources of pollution render  the  water
       of the East Skokie Drainage  Ditch totally unusable  for  any pur-
       pose,  the Society has been forced to divert the ditch under  and
       around the site of the botanic garden.   This diversion  was
       accomplished at great expense  to the Society (something in excess

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Mr. MacMullen
Page Three
May 21, 1971
in saving the East Skokie Drainage Ditch and restoring it to
a state of cleanliness so that its waters cease to be a
health hazard and become useable again for at least plant
watering purposes.

          We sincerely hope that the progress which is being
made through your efforts in connection with the elimination
and pollution caused by the Clavey Road sewage treatment
plant will not end at this point but that they will continue
diligently with a view towards eliminating all other sources
of pollution.

          If you have any questions please do not hesitate
to contact me at your convenience.

                              Sincerely yours,
                              Peter H. Merlin
mp
cc:  Dr. George W. Beadle, President
     Chicago Horticultural Society

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Mr. Richard MacMullen
Page Two
May 21, 1971
of $300,000) and is still the source of considerable trouble.
Without diverting the waters of the East Skokie Drainage Ditch
the site would be totally unusable for any purpose.  Yet the
City of Highland Park, property owners and golf courses
immediately to the north of Lake Cook Road continuously accuse
the diversion system erected by the Society as the cause of a
variety of flood conditions north of Lake Cook Road.  This is
the case in spite of the fact that the diversion system has
been approved by the State of Illinois (Division of Waterways)
and in spite of changes which were made in this system after
public hearings in August of 1969.

          (3)  The Society has repeatedly emphasized its position
that as the builder and operator of a botanic garden it is in
great need of water usable for plant purposes.  The Society now
purchases such water at considerable expense from the Village
of Northbrook.  If the waters of the East Skokie Drainage Ditch
were not so heavily polluted with organic and nutrient materials,
the Society could use such waters and save the expense of
purchasing water from Northbrook.  Furthermore, if the waters of
the East Skokie Drainage Ditch were clean the present diversion
system would not be needed.

          (4)  The Society therefore welcomes any efforts on the
part of the Federal Government,  and in particular of your office,
to require the Clavey Road Sewage Treatment Plant to adhere to
the highest standards of water quality.  We urge that all pre-
cautions be taken to guarantee that the effluent of the treatment
plant be of purest quality and that under no circumstances (even
in case of emergencies)  untreated sewage or substandard effluent
be permitted to enter the East Skokie Drainage Ditch.

          (5)  However,  I must emphasize that the Clavey Road
sewage treatment plant is by no means the sole source of pollution
of the East Skokie drainage ditch.  Even if the Clavey Road sewage
treatment plant did not exist the East Skokie Drainage Ditch would
still carry substantially polluted water to the site of the
botanic garden and on down into the Skokie lagoons.  The Society
is in no position with its limited resources to undertake what-
ever steps may be necessary to clean up the East Skokie Drainage
Ditch.  We therefore hope that your office will be instrumental

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                                tOI; 3

                                                    May  24,  1971

Mr. Gary W. Schsnzsl
Hoosi 410
33 West Congress Parkway
Chicago, 111. 60035

Bear Mr, Schenzel,

     I aa writing to Inform you that our group,  Studants
Organized for Survival, supports tha draft  of the  -tSnviremaental
Impact Statement dona by fiegian V of the water  Quality  Office
of the U.3,3.P.A. in regards to the  application of the  N.S.S.D.
sewerage project no. WPC-I11.-754.

     Our organisation represents thes«  atudaats at Highland
Park High School canoernsd with protecting  eur  natural  anviron-
nent  ,,;dj basically concern aursslves with what  goes ®n  In
Highland Park because this is the araa  in which we can  exerciaa
the S93C influence. One of the mere  prominent things we have
concsrnad ©ursslvas with this year has  been, you guessed  it, tha
Clavey H*>ad Sewaga Plant.

     In regards te this controversial plant we  have seen
adults act more childishly than we ever did. To our dismay
we have sometimes seen people,,some  very influential, act not
out of environmental concerns, but out  of economic,  political,
and even personal ones. Of the whole N3SD operation in  Highland
Park what we have to say is thus: we applaud the district's  plans
to phasa out the three lakefront plants and to  divert the
sewage to the Clavey Ho&d plant for  treatment.  One of we  kids'
favorite summeS: pastimes is to swim  at  the beaoh.  We feel it is
about time the pellution of the lake is stepped. We also  fael
that the Clavey Ho&d Sewage Plant sh&uld be expanded to handle
the Isad pumped from the lakefront plants because  a senseless
delay in the lakefront plant phase-eut  plan would  ensue if
the Clavay Road plant was abttthe plant designated to handle
this sewage.

     We are also, however, quite vehement in our demand that
the Clavey Haad plant be a safe one. The Committee te Save
Highland Park, the.rgroup of residents living near  the plant,
have caused ecological and economic  delay in the dictrict's
plans, and heartache for a lot af people. It is very easy to

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OPEN

LANDS
PROJECT

53 W .ACKSON BLVD
CHICAGO ILL'NOIS 60604
427J256
    v q SHORT ,R
WILLIAM „ BEECHER, Ph D

RICHARD L ETTl'NGER

WALTER T FISHER

/OLNEY w FOSTER

CORWtTH HAMiLL

CYRUS MARK

CHARLES E OLMSTED ^ 0

GEORGE N  OVERTCN

CHARLES f 3AVELSCN M D

FARWELL SMITH

SYDNEY STE'N, JR

-ARRY M WEESE

GEORGE H WOODRUFF VI 0
May 21,  1971



Mr. William Ruckelshaus
Administrator
Environmental Protection Agency
1626 K Street
Washington, D. C.  20460

       Re:      Draft Environmental Impact Statement

                Sewarage Project Number WPC-fll.-754
                Submitted by North Shore Sanitary District,
                Waukegan,  Illinois

Dear Mr. Ruckelshaus:

       After reviewing the Draft Environmental Impact Statement from

the Water Quality Office, Region 5, Federal Environmental Protection

Agency,  various reports of the State of Illinois Pollution Control Board,

statements of the Lake  Michigan Protectors of the Environment, and the

Illinois League of Women Voters, the Open Lands Project would like to

support the  report and action of the State of Illinois Pollution Control

Board.

       We recognize the complicated problems with the North Shore Sani-

tary District and the Clavey Road Sewage Plant, but after  reading the dis-

trict's statement too, we feel that the recommendations of the State will

accomplish more in the interest of protecting Lake Michigan immediately

and in the long run than other alternatives.



Sincerely,
                       Gunnar A. Peterson
                       Executive Director

                       /ma

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DC*
  FOREST PRESERVE  DISTRICT
                       of Cook County, Illinois
                                                                   The Board of Commissioners
       MATHEV. W. BIESZCZAT
       CHARLES S. SGNK
       CHARLES F. CHAPLIN
       FRANK W. CriESROW
       WILLIAM N. ERICKSON
       FLOYD T. FULLE
       CHARLES J. GRUPP. JR.
WILLIAM H. HARVE^
JEROME HUPPEOl
LILLIAN PIOTSOASt
ROSY P.rAN
JOHN H. STROGER, ,
JOHN P. TO'JHY
JOSEPH i. WOODS
       GEORGL \\. DUNNE, PRESIDENT
                                GENERAL HEADQUARTERS: 536 NORTH HARLEM AVENUE. RIVER FOREST, ILLINOIS 6030
                                                   COLUMBUS 1-8400 I FOREST 9-9420

                                                   Arthur L. Janura, GENERAL SUPERINTENDENT
                                               April 28,
POLLUTIOr! CO.-iTiiOL BOA^D
           Chairman
           Illinois Pollution Control Board
           189 West Madison Street
           Chicago, Illinois 60602

           Dear Sir:
               The recent proposal by the Federal Environmental Protection .Agency
          to discharge effluent  from rhe Skois-ip Ri^er Watershed into the DssPldircc
          River does not have our support.

               We strongly  expressed our opposition to the removal of  any flow from
          the Skokie River  at a public hearing held in Riverside,  Illinois earlier this
          year.

               The Forest Preserve District has some of its finest recreational lands
          along  the Skokie drainage system and the ecology of these lands is dependent
          upon present water tables.  To divert any portion of these flows to another
           likely influence the entire Skokie Lagoon system and all other  forested  areas
           adjacent to the water course.

               The Skokie Lagoons have  great significance with regard to a man-made
           flood control system that offers recreational opportunity to hundreds of
           thousands of visitors each year.  With the nearby Botanical Gardens, the
           importance  of the Skokie Riirer and its water quality grows even more important.
           It would seem that this most recent proposal has given little consideration to
           the ecological consequences or to the possible detrimental effects :o the
           public recreational lands that  have and continue to serve the recreational
           needs of people.

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                                   -2-                 APR ''
                                                 PP ' '  '   I      1 '  •' •> i -N '
                                                 i o.'.^ji.vii v/v.^r.u  .  '  \
    We hold fa=;t to ^ur opposition to the DesPlaines River proposal and
seek the retention of a  greatly improved water quality discharge into the
natural watershed which is the Skokie Paver.

                                    Sincerely yours,
                                    Arthur L.  Janura,
                                    General Superintendent
ALJ:es

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                                           May 0, 1971

Mr. William Fuckelshaus, Director
U.S.E.P.A.
1626 K Street N.W.
Washington, B.C. 20460

Dear Mr. Ruckelshaus:

As participants in the Lake Michigan Interleague Group
and members of the League of Women Voters of Illinois
we are deeply concerned about the recent recommendations
of the U.S. Environmental Protection Agency to the
North Shore Sanitary District, placing limits below
those previously approved by the Illinois Pollution
Control Board for the construction and expansion of the
Clavey Road sewage disposal plant in Highland Park.

Once again controversy brings much delay in a situation,
which at its best sends raw, untreated sewage into Lake
Michigan.  We strongly back the recommendations of the
Illinois Pollution Control Board.  We urge you to inter-
vene and give your strong support to those plans set
forth by the Illinois Pollution Control Board in behalf
of the millions of people who use Lake Michigan.

Last November, the Anti-Pollution Bond Act, for which
we worked so hard, was passed, but Illinois has received
no matching federal grants under the Clean Water Restora-
tion Act which soon expires.  Our concern deepens as the
July 1, 1971 deadline approaches and no new legislation
to extend the federal grant program is forthcoming.  We
ask your immediate help in obtaining the legislation to
make available future funds which are so essential to
clean up Illinois lakes and rivers.

Yours very truly,
(Mrs.) William J. Pietenpol
Environmental Quality Chairman
 (Mrs.) Stephen J. Fraenkel
President

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A
      LEAGUE OF WOMEN VOTERS OF GLENCOE, ILLINOIS
                                         May 5,  1971

      The Honorable Charles H.  Percy
      Senate Office Building
      Washington, D. C.   20510

           Re:  Objection to  tho  reduction  in capacity  of
           the proposed expansion of the sewsre treatment
           plant on Clavey Road,  Highland Park, Illinois.

      Dear Senator Percy:

      In the proposed preliminary environmental r-sse.^.'i/.ent by
      the Office of Water Quality, U.S.  Environments! vrot^ction
      Agency, reg. V, recently  issued to the North iiiore Spriitary
      District of Lake County,  there is  a recora.acnc.ntnoa to
      reduce th<-j capacity of  the  sewage  treatment  plant being
      expanded on Clavey  Ro.^d.  An earlier  1-,'JJD pirn  r.-d called
      for expanding this plant  to 21). mgd (inillion  Dillons n aay).
      At the request of the City  of  Hifhlsnd Pork,  t;,c  plan
      was changed to an 18 ingd  expansion, and  approved  by the
      Illinois Environment el  Protection  Agency  on  Dccp.-jbcr 23,  1970
      The rocent recommendation by the U.3.  EPA is  to limit
      the plpnt capacity to only  12  mgd,  and to reduce  the
      planned storm water retention  bosin to 10 million gallons
      from the original 20 million gallons.

      The League of Women Voters  of  Glencoe,  Illinois,
      strongly objects to such a  reduction  in capacity  of the
      expanded Clavey Ro^d plant.   The purpose  of  tho expansion
      is to  transfer to the expanded plant  the  load of  five
      small  and outdated primary  treatment plrnts on  the
      lakefront,  which presently  di sc hgr£e  in_g_d_c_qur tc 1 y  treated
      and often raw sewego_ (TirecTtly  into" Lake HJJ^hiVnn'."
      The sura of the present loeds of Clavey Hoed end of  the
      plants  to be  closed already   amounts to 11.5 "ig^ in
      dry weather.   Thus a plent expanded to 12 mgd will  make
      no allowance  for growth of the community, &IIG none  for
      •wet weather  flow.   The plpnt of such capacity will  be
      already inadequate on the day when  it  is  completed.

      Less capacity and reduced retention size  will cause
      more frequent discharge  of incompletely treated sewage
      into the Skokie  Ditch.   The  pollution of  the dkokie
      lagoons directly affects our community, nnd others
      along  the North Shore.   A more serious consequence,

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                                   The  Honorable Charles H. Percy
                                   Page Two
afreet ing millions of_ P_eo£l_e_,  is  that  the dispgreenent
between the  assessment°~6lM;he  U.  S.  EPA pnd the order
of the Illinois  Pollution  Control Board (see enclosed
newsletter), adding to  the  controversy end litipntions
by nearby residents and other  groups,  may del-:y for
yeors the termination of p_pljLution qf_  Lake_ I-achIr?.n
by_ the :\'orth Shore Sanitary' District,  '"The controversy
is blocking  the  funds Available to the NSSD, both
from a bond  issue and from  federal money,  and therefore
may jeopardize the timely completion of the District's
entire effluent  diversion progrsia, of  which Clavey  Ho ad
is only n part.  Furthermore,  the  U. 3.  Congress has
foiled to authorize funds to aid  the continuation
of antipollution projects after July 1,  1971.

We therefore respectfully urge you (1) to intervene
in behalf of the plan sanctioned  by  the  Illinois PCS
against pollution of the Lake  (making  the  §11.55
million of federal money available to  the  NSSD),
and (2) to help  making further U.S.  funds  available
in the future.

                                   Yours  very truly,
                                  Mrs. Leonard Liebschutz
                                  President
End/
Newsletter if 19
State of Illinois Pollution Control Board

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ost  Sfcofcie
              DRAINAGE DISTRICT
Sr'i n ",00

1811 Si JOHNS AVJNI-F   •  HK.HI >.sn I'ARK, Ii : INOIS
.m, CHAIUMAN
                                                         Dr.  Hilbert
                                                                 Lang
                                              May 4,  1971
   Mr. John C.  Guillou,  Chief Engineer,
   Division of Waterways,
   Department of Jublic  V.crks and Buildings,
   201 West Monroe,
   Springfield,  111.  62?JO
            Re:  North Shore Sanitary District Proposed
                Outfall  Structures on Right Bank of the
                Skokie River in Highland Park,  Lake
           	County,  Illinois .	
        OBJECTIONS  OF  THE EAST SKOKIE DRAINAGE DISTRICT
  Dear  Mr.  Guillou:

        This  will  acknowledge  receipt  of your notice dated
  April  26,  1971  relative  to  the  above  subject  matter.   We
  have  had  no  notice  of  this  application from the North
  Shore  Sanitary  District.  Please  be advised as  follows:

        1.   North  Shore Sanitary District at  no  time applied
  to  us  as  provided by Statute for  approval  of  their pro-
  posed  72"  effluent  outfall  headwall nor for the 63"x98"
  elliptical storm drain outfall  headwall.   Both  of these
  headwalls  are planned  to be within  the right-of-way of
  the East Skokie Drainage District,  and inasmuch as they
  will  interfere  with our  plans in  regard to the  full use
  of  our easement, we find same objectionable.

       2.  On  April 19th,  on  their  invitation,  they met  with
  the undersigned and our  engineer, Mr.  James C.  Anderson and
  with Highland Park City  Engineer, Mr.  Philip  DIttmar,  at
  the North  Shore Sanitary District offices  at  Waukegan.

       3.  They presented  to  us a proposal whereby  they
  would remove the present 60" effluent  outfall pipe which
  invades the  right-of-way about  35', and would convey  to
  the East Skokie Drainage District a 50' right-of-way  ease-
  ment for drainage purposes on the opposite  bank of the
  East Skckie Drainage ditch.   They asked iii  x-eturn,  that  we

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                                         May 4,  1971


Mr. John C. Gulllou, Chief Engineer,


                           -2-
permit the new 72" effluent outfall headwall and the new
63"x98" elliptical outfall headwall to remain 35' from  the
center of the present ditcn, and were to confirm this pro-
posal in writing, which If accepted, would be followed  by
a. Deed of Dedication or Easement to the 50'.  To date,  we
have not received any written confirmation of this  proposi-
tion nor any Deed of Dedication or Easement.

     Our acceptance of their proposal would be based on
the following representations made to us, and we reserve
our rights in the event that these representations  are  not
borne out by the facts:

        (a)  That there will be no flooding" as a result of
the plant installation proposed or in progress or completed,
no back-up in the East Skokie Drainage Ditch and no inter-
ference with the normal drainage waterflow.

        (b)  That in the event of any apparent need for use
of the increased 50'  right-of-way,  or if at any time, in the
judgment of either the North Shore Sanitary District or the
East Skokie Drainage District,it becomes necessary or advisable,
they will excavate to provide a shelf for the expansion during
high water periods,  onto this fifty foot shelf.

        (c)  That In the event of any flooding or water back-up,
the North Shore Sanitary District will provide such storm drain-
age storage facilities as may be necessary.

        (d)  That they will not pollute the stream.

        (e)  That at the south end of this fifty-foot Dedication
or easement,  they will co-operate in providing for the  expansion,
either on the east bank or west bank or partially on both so that
like facilities will be provided for run-off to County  Line Road.
                                ery/sincerely you^s,
                               
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                                                             4.
                                                 /
              (47>DECJ75
IE H»037 PB NE PDF HIGHLAND  PARK! ILL 18
GARY W SCHEN2EL
  WATER RESOURCES  PLANNER EPA WATER QUALITY OFFICE ROOM 410
33 WEST CONGRESS PARKWAY  CHGO 60605
« COMMEND YOUR DRAFT ON  CLAYEY  PLANT AND COUNT ON YOU TO PROTECT
ITS SCHIENTIFIC FINDINGS. LITERALLY THOUSANDS OF PEOPLE ARE
WITHIN A MILE RADIS OF THE UN3ELIEVEABLE PLANNED ENVIRONMENTAL
DISASTER OF AN EXPANDED SEWAGE  PLANT
  MR AND MRs WARNER S KADDEN  851 TIMBER HILL ROAD HIGHLAND
ARK ILL.
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    GARY V SCHENZEL, WATER RESOURCES  PLANTER, E.P.A. WATER
    QUALITY OFFICE ROOM U10 33 WEST CONGRESS  F^RKWAY CHGO
  BT
  WOULD APPRECIATE OBJECTIVE S^DY  OF  CLAVEY ROAD SANITATION PLANT
  APPEARS AS IF YOUR OBJECTIVE REPORT  WILL  HAVE TOUGH GOING AGAINST
  LOCAL SANITATION DISTRICT BECAUSE CF LOCAL  PORK BARRIL POLITICS
  PLEASE DO YOUR BEST TO SEE  THAT THIS PLANT Is PHASED OUT QUICKLY
     ROBERT $• URNER.
  NNNN(0537P EOT)                                                .
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     GARY W SCHENZEL, WATER RESOURCES PLANTER, E.P.A. WATER
     QUALITY OFFICE ROOM UlC 33 WEST CONGRESS PARKWAY CHGO 6o605
   BT
   WOULD APPRECIATE OBJECTIVE STUDY OF CLAVEY ROAD SANITATION PLANT
   APPEARS AS IF YOUR OBJECTIVE REPORT WILL HAVE TOUGH GOING AGAINST
   LOCAL SANITATION DISTRICT BECAUSE OF LOCAL PORK BARREL POLITICS
   PLEASE DO YOUR BEST TO SEE THAT THIS PLANT IS PHASED OUT QUICKLY
      ROBERT S. LERNER.
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    GARY SCHEN2EL,  WATER RESOURCES  PLANNER
     RM  UlO  33  WEST CONGRESS PARKWAY  CHGO
   BT
   HAVE  WAITED  SO  LONG ^OR TRULY OBJECTIONAL  STUDY  OF  CLAVEY
   ROAD  S.T.P.  EMBRACING GRANOVIEW  OF GREAT LAKES WATER  QUALITY
   CONTROL PROBLEMS. I COMMEND YOUR PRELIMINARY REPORT AND
   URGE  YOU  TO  PROTECT ITS  SCIENTIFIC FINDINGS AGAINST LOCAL
   GREED AND MISINFORMATION  I  URGE  THIS  PLANT  BE PHASED  OUT
   QUICKLY
     RICHARD FLEISHER  6*17 HIGHLAND  PLACE
     HIGHLAND  PARK ILL
   WNN(0706P  EOT)

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   WILLIAM RUCKELSHAUS,    CARE  FRANCIS T  MAYO,  ENVIRONMENTAL  ""'^£'
   PROTECTION AGENCY  DLY 75
     35   EAST CONGRESSPARKWA/ ROOM 410  CHGO ;  • '••••'•-
   QUESTION OF CLAVE/ ROAD SEwAGE TREATMENT PLAMT  IN MIDST OF
   HIGH DENSITY RSIDENTIAL AREA OF URGENT CONCERN  TOCESIDENCE
   OF COMMUNITY  DETERMINATION OF EFFEOTON OF POLLUTION ON MAN
   AS ORGANISM MUST SE GIN FIRST CONSIDERATION.   TECHNOLOGY SECONDARY
   TO WELFARE OF RESIDENCE AND PROTECTION OF ENVIROMENT.  FWQA
   DRAFT ASSESSMENT CALLS FOR STUD/ OF POTENTIAL HEALTH  HAZARDS
   TO RESIDENCE WHAT CONCRETE STEPS IS FEDERAL GOVERNMENT  TAKING
   TO PROTECT OURSELVE AND OUR POSTERITY
    GERALD L SURELL, LAKE MICHIGAN PROTECTORS OF  THE  ENVIRONMENT
   S5>4  MERCMA,'.D:--E MART  CHICAGO ILLINOIS.
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    VALICE AND DON GOLDSMITH 852 TIMBER HILL ROAD HIGHLAND PARK
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     WATER RESOURCES  PLANNER  EPA  ENVIRONMENTAL PROTECTION AGENCY
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   COMMEND YOUR PRELIMINARY  DRAFT ON CLAVEY POLLUTION PLEASE PROTECT
   AGAINST POLITICAL  PRESSURES
     MR AND MET GEORGE  BERLIANT513 TIMBER HILL ROAD HIGHLANDPARK
   ILL.

-------
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   GARY W SCHENZEL                                          /
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   ROOM 10 33 EAST CONGRESS »RK«AY CHGO
   COMMEND YOUR PRELIMINARY DRAFT ON CWftVEY  POLLUTION  PLEASE  PROTECT
   AGAINST POLITICAL PRESSURES
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   GARY W SCHENZEL, WATER RESOURCES PLANNER, EPA ENVIRONMENTAL
   PROTECTION AGENCY
     35 EAST CONGRESS PKWY ROOM U10 CHGO
   PECOMMEND YOUR PRELIMINARY DRAFT ON CLAVEY  POLLUTION PLEASE
   PROTECT AGAINST POLITICAL PRESSURES
     MR AND MRS GERALD FACTOR JS3  HASTINGS  HIGHLAND PARK ILL.

-------
    ~LLD23S  (09)(28)DEA127                          	""  °     ?  37
     DS HPAQ??,
     PB NL PDF HIGHLAND PARK ILL 20
     GARY W  SCHENZEL
       WATER RESOURCES PLANNER EQA ENVIRONMENTAL PROTECTION AGENCY
     ROOM 1*10 33  EAST CON3RESS PARKWAY
     COMMEND YOUR PRELIMINARY DRAFT ON CLAVEY POLLUTION PLEASE
     PROTECT AGAINST POLITICAL PRESSURES
       MR AND MRS JORDAN GLASSMAN 252  ASPEN LANE HIGHLAND PARK
     ILL.

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        33 BSfcT CONGRESS  CH30
     PROTECT  PEOPLE  RIGHTS  CLAVEY PLANT  HAZARDOUS  PLEASE HELP US
               SHAPIRO 2 88HASTINGS RB HIGHLAND PARK  ILL

-------
    TXA509 (42)DEA113
    DE HPA083 QB NL PDF HIGHLAND PARK ILL 20
    GARY w SCHENZEL WATER RESOURCES PLANNER EPA  ENVIRONMENTAL
    PROTECTION AGENCY
     ROOM 410 33 EAST CONGRESS PAJKWAY CHGOCOMMEND  YOUR PRELIMINARY
    DRAFT ON CLAVEY POLLUTION PLEASE PROTECT AGAINST  POLITICAL
    PRESSURES
     MR AND MRS RICHARD LEWIS 3A4 HASLINGS AVE  HIGHLAN
    PARK ILL,
SF-1201 (R5-69)
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   'LLF166 (57)(30)OEC255                          /
   CE HPAQ75 Pfi  NL PDF  HIGHLAND  PARK  ILL 20^   /      ..<.,  :-
   GARY W SCHENZEL                            /
     WATER RESOURCES PLANNER  EPA ENVIRONMENTAL PROTECTION AGENCY
   ROOM ino 55 EAST CONGRESS  PARKWAY  CHGO
   COMMEND YOUR PRELIMINARY DRAFT ON  CLAVEY POLLUTION PLEASE PROTECT
   AGANST  POLITICAL PRESSURES
     MR AND MRS VICTOR  GOULDING  565 ASPEN LANE HIGHLAND PARK ILL*
                                                                     \A\

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    GARH SCHENZEL Us EmaONMENTAL Pf^TECT          19?1 VAV ?0  !•',!
      33 EAST CONGRESS ^PBSSSWAY CH30
    WE COHHEND YOU ON sTHOI^ ST^JQ TAKEN CONCERNING  THE  CLAYEY
    ROAD SW4GE TREATMENT PLANT AND LAKE MICHIGAN
      VE ARE GLAD YOUR OFFICE WAS NOT INFLUENCED BY  ANY  POLITICAL
    COMMITTMENT CONT11ME YCUR UNBIAS WORK
      Oft AND MRS JERALD MILLER 1893 SHERIDAN ROAD HIGHLAND PARK
     ILL.
  8F-1201 (RS-68)
                                                     Telegram
                                                           1971 MAY 21  AM 7
     LLD015  (12)CCB009
     (AT 1 M1CC50^009)PD  IPM/EIA MVN       0731 A E6T05/21/71
     ZCZC 012 PR NL PD TDVE HIGHLAND PARK ILL 20
      GARY W SCHENZEL, DLY 75
       WATER RESOURCES PLANNER EPA WATER QUALITY OFC RM UlO
       33 |Epj) CONGRESS  PARKWAY CHGO ($0605

     HA/E WAITED SO  LONG FOR TRULY OBJECTIVE STUDY OF CLA/EY ROAD STP
     EMBRACING  BROAD V IEW OF GREAT LAKES WATER QUALITY CONTROL
     PROBLEMS  I COMMEND  YOUR PRELIMINARY REPORT AND URGE YOU TO PROTECT
     ITS SCIENTIFIC FINDINGS AGAINST  LOCAL GREEN AND MISINFORMATION.
     I URGE  THIS PLANT BE PHASED OUT QUICKLY
       MR AND  MRS PAUL A BROWN 303 HASTINGS ROAD HIGHLAND PARK ILL
     NNNN(0733A EOT)
.II1

-------
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   GARY V SCHENZEL ERA  WATER QUALITY OFFICE RM 523
    33 * CONGRESS PKWAY CHGO 6oSo5
  BT
 WE COMMEND PRELIMINARY DRAFT ON CLAVEY.  PROTECT  FEDERAL  FINDINGS
 GOOD PLANNING IS KEYNOTE
    MR AND MRS ALLAN EDELsON 263 HASTINGS  RD HIGHLAND  PARK ILL
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   GARY W  CHENZEL WATER RESOURCES PLANNER EPA ENVIRONMENTAL PROTECTION
     ROOM  410  33  EAST CONGRESS PKVY CHGO
   COMMEND YOUR PRELIMINARY DRAFT ON CLAVE Y POLLUTION PLEASE PROTECT
   A3AINST POLITICAL PRESSURES
     MR  AND MRS LES  POLWACK 3^3 HASTINGS AVE HIGHLAND PARK  ILL«
                                                                  } Y

-------
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  FVEASE  FOLLOW THE RECOMXE^OATI ON OF THE  FEOEJAL  EN I VORN,VENTAL
  PROTECTION AGENCY NOR THE CLAVEY ROAD SEX'AG  PLANT  PROTECT THE
  LAKE AFO THE  PEOPLE
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      33 EAST CONGRESS PARKWAY  CHGO
   I  SUPPORT THE F'.vr)A REPORT REGARDING  T^  NSSD AND THE CLAYEY
   ROAD STP
      LOIS  H ZISOOK 77* HIGHLAND  PL  HIGHLAND PARK ILL
   FWQA  NSSD STP
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  GARY  w  SCHE^ZEL, WATER  RESOURCES PLANNER EPA ENVIRONMENTAL,.,.^
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      33  E CONGRE-S  PARKWAY CHGO
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  COMMEND YOUR PRELIMINARY DRAFF  ON  CLAVEY POLLUTION PLt.ASE PROTECT '*&!-.£
  AGAINST POLITCAL PRESSURES
    OR AND ,'!RC WI.LIA," MELTZEP 7^3  TIMBER HI_L HIGHLAND PARK
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  GARY  SCHENZEL WATER RESOURCES PLANNER  WATER DUALITY OFFICE
  ROOM   410 EPA                                             ^ "v/n,, ^
       33  EAST CONGRESS  PARKWAY CHGO
  HAVE  MITIi, '--0  LO:\G FOR  TRULY OBJECTIVE  STUDY  OF CLAVEY ROA-OI'.  *
  S~P  EMBRACING GRANDVIE.V  OF GREAT LAKE0 WATER QUALITY CONTROL
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  PROTECT  If- CIEMTIFIC  FINDINGS  AGAINST LOCAL GREED AND MISINFORMATION
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       MRS  RO'ERT '/<  K'JPCHICK                                         (.i|
  (^22).                                                          /it''' ,

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   COMMEND YOUR PRELIMINARY DRAFT ON CLAVEY  POLLUTION  PLEASE
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    DR AND MRS SEYMOUR SIEGEL 595  HILLSIDE  DR  HIGHLAND  PAR>\
   ILL.
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   PROTECTION AGENCY ROOM 410 55 EAST CONGRESS  ^ARKWA/  CHGO
   COMMEND YOUR PRELIMINARY DRAFT ON CLAVE/  POLLUTION  PLEASE
   PROTECT AGAINST POLITICAL PRSSURES
     MR  AND MRS LAWRENCE PERLSTEIN S?y TIM='E!5  HI_L  ROAD HIGHLAN
   PARK  ILL.

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          (12)LLCA007                                      |,
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   GfcRY SCHEN2EL, WATER RESOURCES PLANNER                   ;-, ,	   ,
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   fKWY CHGO
   PROTECT DRAFT AGAINST LOCAL POLITICAL GREED MISINFORMATION  PLEASE
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     MR AND MRS JOSEPH RUBIN  567 HASTINGS HIGHLAND PARK  ILL.
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WE SUPPORT YOUR POSITION RE: THE  CLAVEY RD.  PLANT AND URGE
IT BE IMPOSED ON THE N.S-S.D
  MR/MRS ED SOLLO 5592 SUMMIT  HIGHLAND  PARK  ILL 50035.
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copy


                                               505  Maple Avenue
                                               ;*ilmette, Illinois
                                                    60091
                                               April  24,1971

Mr. "..illiam D.  Ruckelshs.ua
Admi ni strator ,  U.S.E.P.A.
' v'ash:' ngton, D.C.

Dear Mr.  Ruckelshaus:
     The  stateneitt  of  the  United, states Environmental  Protection Agenc,
in regards to  the North Shore Sanitary District  3 n Illin is was
absolutely the  most unbelievable, disappointing, truly alarming bit
•"f _,nv' ronmental news  v/e could possibl.  have.

     Unbelievable --because I had sat through all of  the Illinois
Pollution Control Board hearings on the Clavey Road  ilant,  plus the
meeting held by Lt.  Governor Paul oirion, ; lus riany other meetings in
regard to this  critical situation.  I felt the Illinois Pollution
Control Board  came  up  with a realistic b^lut.' )n  to get a long overdue
job done.  Getting  the sewage out of the lake from those five treatmerr
plants is of CRITICAL  URGENCY.

     ^ our action would make  construction dela; ,  add  another ^£0 -to ^o.
million in costs, add  nutrients to further speed up  r.utrophication
in Lake Michigan, and  no doubt lead to no use of the Illinois beaches
for a few years, plus  add  more cost to water purification plants.
plan has absolutely everything negative in it that could possible  be.
I strongly feel :>ary ochenzel was poorly informed  if he did not hear
all of the testimony and attened many other meetings relc-ted  to ti.e
north 6hore danitary District.
     I sincerely feel  the  U3EPA has made a bio; mistake  in  t". e-"r
dec-'s'on on the North  bhore  sanitary District.  n.lso, no public  hea.  •;
•"•as held by the agency.   A small gro.'p of citizens have held up
construction for two years,  adding a large f-'nanc'al burden to  resin-  •
of the area, the state,  and  UiibPA.  The lake has sr.ffered  ''hat ma;  "•
irreparable damage  because of this,  five -  u one half  'lilli'-n  people
deptancl on the lake  as  a  source of vatt-r.  'Jlit Il-ini'-'s  pollution Contr<
Board ordered, the NSSD to  proceec, a.t once to construct  additional
facilities t- 1 the Clavey xioad treatment } lant , tr'd this v/oulo end rutt
almost raw sewage into the lake from five rlarits alon^  the  shore.  Th
input of nutrients  to  the  l&ke mUST oTOP, for it 's ft.st beco ing
eu trophic.

     oince I attend all  Pollution C ntrol Fc:-ra mtctines ana all of thi
hear-' ngs on the NSSD case  and many others i-c ti^in^ the situation 1
found I fully agreed vvith  the decision (^ f-'lc i-^ll^ t'. >- Control  Board,
because I had heard the  testimon; presenteu to thf r plus '•lore.    I &•<•••
very much impressed with the integrity of thj s capable  ?oard.  Ricna/
Kissel va.3 a fair,  dedicated hearing officer -.it:  the rior, : d  pave  ~uch
fbonn-io-t- to thi s important c.-,se.  ikir .  cc1"-'-^--" •^•|'f'.]]y ^ ' ^ ;•"•' ;'c r("ier i ^(
Board decision

-------
   It  was absolutely impossible for me to  set how  the federal LP.a
-.'..-I possibly have come up with your  decision..   -You certainly
:  ,iot  have the future of Lake Michigan in  mind  or  the h^lth and v,ater
..";; of  millions of people.  It seems to me Lake Michigan * s more imt or-ts
.••jnaidsr than th« Interests of 200 selfish citizdns who shouldn't have
-. !,'.&%&$. :home^ nest to a sewage treatment plant  if  they \vere  concerned.
  .Jlatr-sy Road plant does have an odor now  because  it is overloaded,
,d proper expansion it will not.  Expert witnesses have fet>t j f i ec.~ to this
:i33ns residing next to similar treatment  plants have not coriplai ned.

   jriis  is a matter of vital concern to all Illinois communities along
    1.v8,  including Chicago.  Indeed it is of concern to all people living
  . '-'3  Michigan, and I feel certain that thousands  of citizens will
 '.l.u  on USEPA if you maintain the present position.  I for one v/ould
  i, a  great deal of time urging citizen action  on  this vital n&tter.
           Mr. Ruskelshaus, reconsider this backyard  decision.  O'he
   v;  nl ant must be expanded to the full IJ^mrd  at  once .  Iht, sr.aller
  -: -,££&. wouScTnot have an adequate safely rHr7~in~ tTr'n^nole t,he
  -;- -,i"pj/a«wage<  It will take much less time to enlarge Clavey than
 . .;42«f a , .new plant at County line.  I vonde:- if :/;'r ichenzel has much
 -• M 3-a*e with Sanitary district treatmerfc  plants.   I  kno\  our ULinoib
 :^i has  A very competent meber who has.

   ii^ also ignored the fact thfat five and  "'ne  half mr'llicn people
..-•»  4  asafe, healthful, productive, and esthetically pleas 'm-. inv j ronpe
r ."..^Ii9 Michigan--not just for 200 Clavey Rot«d  residents.   The interestin
 T^ is t&St these same 200 also depenl on  the  Lake for their v.ater
 ?;33  they use bottled woter — ard they can affard  that.

   Mr, Ruckelshaus, I am afraid my letter  is a bit strong, but 1 am
.11 7  upset by this position the EP^L has taken, and I  beg of ; ou to
         the situation.  Please honor tte  position of the Illin is
        Control Board and let us get on with this  clean-uf of the
        is sq erlWKfKliy needed.
   I  am looking forward to meeting you in May.

                                 Ver; trul^ yours,
                                    ]i:Meen L. Johnston
         Mayo
          Hioh^T«a OgilvXe
         Blaaar
         AdlaJ Stevenson
       r? Cijarlsti Percy
       fhllip crane

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*
II you missed the broadcast of this editorial, we hope you will
read it. Your comments are always most welcome
 WBBM-TV editorials express the opinions of the station's
 lanagement Because we recognize that others may differ
 lith our opinions, it is the policy of WBBM-TV
 consider requests for broadcast time
by responsible spokesmen representing opposing viewpoints
LEON DREW,
V'-vpresident/General Manager, WBBM-TV
                                                                       Editor
                                               WBBM-TV 630 NORTH McCLURG COURT CHICAGO, ILLINOIS 60611  (312J944-60C
                                       NORTH SHORE SEWAGE PLANTS
          CARD:

          William D. Ruckelshaus
          Environmental Protection
                        Agency
          Washington, D.C.  20242
                                        The North Shore Sanitary District was on the way to solving the
                                        major sewage problems of Eastern Lake County when the Federal
                                        Government entered the picture.

                                        The district had planned expansion of the Clavey Road sewage
                                        treatment plant in Highland Park, new construction elsewhere,
                                        and the phasing out of five less than adequate sewage treatment
                                        plants along Lake Michigan.

                                        These plans, though opposed by residents in the vicinity of the
                                        Clavey Road plant and delayed by protests, studies, and hearings,
                                        were finally given a go-ahead March 31st by the Illinois Pollution
                                        Control Board.  Now, however, the United States Government,
                                        less than four weeks later, has released what is called an Environ-
                                        mental Impact Study and muddled up the whole project.

                                        The Federal Government has said the Clavey Road plant should
                                        only be two-thirds as large as planned, that storm water retention
                                        basins must be fully covered, and that an additional sewage
                                        treatment plant must be built five miles to the west on the Des
                                        Plaines River ... recommendations that will be far more costly and
                                        create yet another delay.

                                        The North Shore Sanitary District trustees, defying the Federal
                                        Government, say they  are going ahead with their original plans.
                                        Such action, however,  would jeopardize valuable federal grants,
                                        so the real answer is for the United States Government to
                                        reverse its position. The man to make that decision is William
                                        D. Ruckelshaus, head of the Environmental Protection Agency,
                                        WBBM-TV urges you to encourage him to make it.
                                          PRESENTED ON TUESDAY, APRIL 27, 1971, AT 5:55 P.M.
                                          BY RICHARD WESTERKAMP, EDITORIAL DIRECTOR OF WBBM-TV.

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                                   A»ril 27, 1971
       st. 8.1.
#a0biaftoA, D.C.
i;«ar Ar»
            I |«el  tJaat  it  vaa a ,»r.-a,t aistak*
tru FecUrai go»«ana*ut cr?*rrul«.a tat 111lacia
Control Agency in tae Clavvy 8o*d ««*ag« tr«at««At affair.
             ua« u««u h«ld  uj, for ^ years by 200
          • iliioa otatr* watcti Lake rticii^aa g«t aor«
and nor9 polluted ^«?aau*« of tiiia federal d«eicioa,
ia goiot to continue to  diaeAarge it* ae*«ge into L*K<
 for 2. to j> /ears loader, *a iuexcuaable del*/, "fh*
     ;r* J'ioally, ti« federal (overaoettt aaoulci not
     ta« at«t« ia
  I &ope you will recoiuiiaer your
                            Sincerely,
Mr a.
                                        r'f utaear«ut«r
                                       Av«.
                                      111.
Copy to: fraacxa

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                        CONGREGATION  SOLEL
                                         3301 Ciavey Road • Highland Park, Illinois 60035 •  IDIewood 3-3555

                                                                       Arnold Jacob Wolf, Rabbi

                                                                       Louis I. Heller, Admintstralof
     OFFICERS

      President
    Morton A. Pierce

    Vice Presidents
    Albert L Ffnston
    Jay L. Frankel
    Arthur W Segil
  Mrs S. Richard Wynn

      Secretary
    Karl J Berliant

      Treasurer
    Robert H Lowiti

    Past Presidents
  Herman C Edwards
  Benjamin J Gingiss
    Irving A Haniq
  Howard M Landau
     Allen Levls
    William Swartz
    Bertram J Wolf
    DIRECTORS
  Mrs. Burton G. Balsam
  Dr. Alvin M. Becker
  Edwin E. Bederman
   Albert R. Belrose
    Milton Bram
  Mrs. Paul A. Brown
  Mrs. Arthur I Caplin
    Soiis Dudnick
  Robert M. Eckhouse
  Mrs. Leonard Efh'ot
    Leonard Farb
 Mrs. Russell L Ffshman
  Jotham G. Fnedland
 Mrs Donald A. Goldstein
  Donald D Jacobs
  Sidney C. Xleinman
    Alan Lenhoff
   Irving B Levine
   Jack C Lipsey
  Marc Reinqanum
  Euaene A. Rosenfeld
 Mrs. Edward I Rothschild
 Mrs. Jerome H Rodman
  Robert W. Salpeter
  Wiliiam Samuels
 Donald W. Schaumberger
  Courtney D. Shanken
  Martin L SHverman
   Allen A. Zuraw
                                              May  20,  1971

Mr.  Gary  W.  Schenzel
Water Resources  Planner
Environmental  Protection  Agency
Water Quality  Office
33  West  Congress  Parkway
Chicago,  Illinois  60605

Dear Mr.  Schenzel :

we  are writing you  on  behalf  of  Congregation  Sole!, a
resident  and  concerned institution in the  immediate area
of  the North  Shore  Sanitary  District's  Ciavey  Road  Plant,
Highland  Park, Illinois.   We  have  carefully  reviewed  the
recommendations  of  your  agency with  respect  to  the  en-
largement of  the  Ciavey  Road  Plant and  believe  them to
be  proper and  required in this situation.   We  urge  your
agency to insist  on  the  implementation  of  these rec-
ommendations  by  the  North Shore  Sanitary  District.

                                     Very truly  yours ,

                                                     SOLEL
                                      orton  A.  Pierce, President
cc:  Louis  I.  Heller
cc:  Sidney  C.   Kleinman
 RELIGIOUS SCHOOL

    Cnairman

Mr- Marshail E. Domash
Rabbi Stanley 0 Meisels

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                     MILDRED KIRSCH
                    310 HASTINGS ROAD
                 HIGHLAND PARK. ILLINOIS 6OO35
 i/9 ,,U    ^ ^-
,      ^t/u^
6U_   frMjf A jr/) SLt ,
                                     O V ;
                                     -  i/v^-^-
•p-tuuLtg &ca

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        HOWARD C WECHSLER,  M. D.
                          340 ASPEN LANE, HIGHLAND PARK, ILLINOIS 60035
0/x
*^S1-
^^


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                                62*
                                                      60035
v-^^-
 0

                                                 'vJ

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                              s. (John ^Buii Ctavey
                                 r\    r
                              435 Ulavey J^ane
                         
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Mrinihf CUrcli
                     425 LAUREL AVENUE • HIGHLAND PARK, ILLINOIS 60035



                    18 May, 1971
 Environmental Protection Agency
 Water Duality Office
 Room IilO
 33 West Congress Parkway
 Chicago, Illinois  6060^
 Attention: Mr. Gary W.  Schenzel
                                       Clavey Road. Sewage
                                       Treatment Plant
 Dear Mr.  Schenzel:
 I wish, to add my voice to those who are in support of
 the Federal >

(The Rey). j Douglas R^ Spence
Rector, Trinity Church


DMS: 11

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             HIGHLAND PARK REFORM TEMPLE
                     27»9 OAK STREET
                  HIGHLAND PARK. ILLINOIS
                                              DR. SHOLOM A. SINGER
                                                      RABBI
May 19, 1971
Mr. Gary Schenzel
U.S. Environmental Protection Agency
•later Quality Office
33 £ar,t Cong re.is Pkwy.
Chicago, Illinois  60605

Dear Mr. Schenzel:

As a member of the clergy of Highland  Park I co—sponsored
a resolution requesting a moratorium on  construction of
the proposed expansion of the Clavey Road  Sewage Treatment
Plant.  The moratorium was  sought  so that  the proper
autacrj tlec could make a determination as  to a suitable
alternate site in a non-residential area and an investigation
undertaken as to the potential  health  hazards of a sewage
treatment facility located  in a high density residential area.

I have followed the developments in the  Clavey Road controversy
with great interest and so  it was  with great satisfaction that
I rori-J tne recent draft environmental  impact statement on the
prop-vie-..' expansion of the Clavey Road  plant.  As a clergyman
/;ho~r'  responsibility is to  the  community at large as an entity
an-", '.o the individual residents of the city of Highland Park,
I w-nt to urge that the invironmental  Protection Agency stand
by  i1.-. draft limiting the expansion to only 12 million gallons
-jer <• ay.

  •,"'«r, T endorse the draft  in its recommendation that the
••-, • r --.-jr ' --"ivanced v;aste treatment unit processes be provided."
I -igr^-e t:  it tne  retention  basins  be  completely covered but I
=-,uo;qr":t t'.e ertire rratter of  locating  retention basins in a
re si-'"it;-•'I area  be re-evaluated.   May I further suggest your
agency ta
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frori  -,
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Norman J. Ehrllch, M.D.
Donald B. Frank*!, M.D.
Arnold A. Gutman, M.D.
Angalo E. Falleronl, M.D,
Donald P. Schwartz, M.D.
ASSOCIATED ALLERGISTS, LTD.

   111 NORTH WABASH AVENUE
         SUITE 1518
    CHICAGO, ILLINOIS 60602
          332-4292


         ALLERGY
                                         May  18,  1971
       Envi ronmental  Drotection Aqency
       Water Duality Office
       Pm  410 -  33 West Conqress Dkwy,
       Chicaao,  Illinois 60605

       ATTENTION:  MR,  G.'.l. SCHEflZEL
        Dear  Mr.  Schenzel:

        I would like to add ny name to  the  list of physicians in Hiqhland
        Park  who  oppose enlarqinn the C^ifc/ey noad Treatment plant.

        I am  an allergist with an office  in Hiqhland nark and I have
        many  patients with bronchial asthma and other resniratory disorders
        who  live  in the area near the olant.  Since patients with allernic
        respiratory disorders are usually the first to suffer from  polluted
        or contaminated air, I feel stronqly that this olant should not
        be enlarqed.

        I realize that sewage treatment plants are necessary, but in  this  -
        decade and in Lake County,  Illinois there are certainly alternatives
        in areas  that are sparsely  populated.  I am makinq these comments
        not  only  for my patients, but for all people, sick or well, who
        miqht be  adversely affected by  enlarnement of the Clavey Poad
        facility.
                                          Sincerely yours,
        AAH/ler
                 /( /    '.  /.  ' -

            Arnold A.  Hutman, M.D.
                       i

            ^   '     f'-,'-    ''

            .- .-<   ;  /.   '

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                             ASSOCIATED ALLERGISTS, LTD.

                                111 NORTH WABASH AVENUE
Norman J. Ehrllch, M.D.                        SUITE 1518
Donald B. Frankel, M.D.                   CHICAGO, ILLINOIS 60602
Arnold A. Gutman, M.D.                          	
Angela £. Falleroni, M.D.                        --_ ._„_
Donald P. Schwartz, M.D.

                                      ALLERGY
                                                  21, 1971
       Environmental Drotection  Mency
       '-•'ater nualitv Office
       Peon 410
       33 '-,'est Comress  narkwav
       Chicane, Illinois 60605
               ri: :
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              RABBI  ARNOLD JACOB WOLF
                  STUDY «  13OI CLAVEY ROAD
                HIGHLAND PARK. ILLINOIS 6OO35
                 TELEPHONE IDLHWOOD 3-355S

                                   May 19, 1971


Mr. Gary Schenzel
U.S. Environmental Protection Agency
Water Quality Office
33 East Congress Pkwy.
Chicago, 111.  60605

Dear Mr, Schenzel:

     As a member of the clergy of Highland Park I co-sponsored a
resolution  requesting a moratorium on construction of the
prepared expansion of the Clavey Road Sewage Treatment Plant.
The moratorium was sought so that the proper authorities could
make a determination as to a suitable alternate site in a non-
residential area and an investigation undertaken as to the
potential health hazards of a sewage treatment facility located
in a high density residential area.

     I have followed  the developments in the Clavey Road con-
troversy with great interest and so it was with great satisfac-
tion that I read the recent draft environmental impact state-
ment on the prepared expansion of the Clavey Road  plant.  As
a clergyman whose responsibility is to the community at large and
to individual residents of  the city of Highland Park, I want to
urge that the Environmental Protection Agency stand by its draft
limiting the expansion to only 12 million gallons per day.
     Further, I endorse the draft in its  recommendation that
"necessary  advanced waste treatment unit processes be provided."
I agree that the retention basins be completely covered but I
suggest the entire matter of locating retention basins in a
residential area be re-evaluated.  May I further suggest your
agency take a stand in opposition to the effluent lagoon now
under construction.  What the North Shore Sanitary District has
done to that area in construction the effluent lagoon is uncon-
scienable; it has no place in the midst of a residential area
containing homes, schools, houses of worship, public park land
and hundreds of school age children.
     In conclusion, I support the recommendation that a  study be
initiated to  "ascertain the possibility of airborne  infection from
sewage treatment facilities."  Thank you for your cooperation.

                                  Very 'truly yours,',

                                              / .  i   -i   „.  >
                                   Rabbi Arnold tfatob  Wolf
cc: Mr. William D.  Ruckelshaus       •                    /
    Director  E.P.A.                *""
    Washington, D.C.  20460

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1175  SHERIDAN  ROAD  HIGHLAND  PARK  ILLINOIS 60035
                                                       PHONE 432-8900
                                                   Mnv  in,  ]o~i
       'fr.  Ci.'iry Schenzel
       L.S.  I.nvironnental  Protection A
       /.nt^r Huaiity Office
       5"  !.T=t Congress ParKway
       fhic.no, 111 inoi s  606^5

       •~te~n' "IT. Srhonrcl :
                                                                     Samuel H Dresner
                                                                     Pabo.

                                                                     Pni :o L  Lipis
                                                                     Rabbi Emeritus
                                                                     Reuven
                                                                     Canfor

                                                                     Dr Louis Ka'zoff
                                                                     Director of
                                                                     Relig/ous Education

                                                                     C/nl G  O'aham
                                                                     Executive Direc''"
             nonth? acio members of tiic cl^ruy Li" i i'/hland  Park 'inr' ofhe~r
       iptcre?tcd t ersons  rcc.uosteu a noratorium on rlar-  to exi^and  tSv
       n -IVPV T.v.-'i1 ^o'x-nqe  Tr^-itr.ri t PI not _   '>"o -,.,Trc concerned th^t nr
       nltonvtc ?itc in  'MI  are'i I'liich '-.as  noTi-rc^icc^tinl  wnnlc' br  cl^sen to
       situate a sewage trcatncnt :ilant  in  view nr the hrnlth danger?
       involved .

       1  • i? ^1r\T='~d to note thr statercrt  frmi your of Li I-'?  rhe^efore,
       rcunrdi^", the Clavcv  Road Plan^.  and arr vrit"inri  to you to indicate
       my ^tmng feelings  about the necessity in Hrntine.'  the e.v\-ipsiou of
       th.is  ">lant to t\velve  million gallons ]--er dav. as vour office  indicated.
'H-at :'neces?an' wnste  trratr'rrt unit process- s be "-rovide
thi
                                                                         T  further
              of ij^at  importance, as i.cll  as  th-^ i ten cox-erir-" t'rc retention
              .   'Hie buildine of ar effluent  ]ar,oor: ir a  rr-si-Vrtial  area
       -v  tiie >'orth Sliorr  Snnitnrv Pis^rict  is difficult in the extrenc  to
       conrrehend .   Your surest ion tliat  n  study he  initi'ited to 'ascertain
       the  I'Ossihility of  air-borne infprtinr frnn <;ewa'ic  treatment  facilities''
       should furthermore  be an item of hi(;b"St r.riorit^.
                                                   Sincerely ^ours .

       SI ID/ ire
       cc: x-lr. 'Ailliam Is.  PucVdshaus
           Pdrector, I'n.vi rorr.cntal Protectinn
                                            11
                                                       iti!)   I   0   i
                                                               \
                                                                                     I

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                       NORTH  SHORE  RADIOLOGISTS,  S. C.

                              2500  RIDGE AVE., SUITE 203

                              EVANSTON, ILLINOIS  60201

                                  TELEPHONE 869-4660
RICHARD C. TURBIN, M D

MARTIN BERKOWITZ, M.D
                                                     May 17, 1971
         Environmental  Protection Agency
         Water  Quality  Office
         Room 410
         334 W.  Congress  Parkway
         Chicago,  Illinois   60605

         Mr. Gary  W.  Schenzel
         Water  Resources  Planner
         Planning  Branch

         Dear Mr.  Schenzel:
                                             RE:  Clavey Road S.T.P.
                                                 Federal Water Quality Office
                                                 Environmental Draft
I have before me a copy of your  Clavey  Road draft.
and urge that they be implemented.
                                                            I support these measures
         I  feel  that  a  12 MGD plant is still too large, and that a definite health
         risk  potential exists.  As the draft apparently represents the only effective
         counter measure to  the plans of the North Shore Sanitary District, I give
         it my full support.
                                                     Very truly yours,
         RCT:ds

         cc:  Amos  Turner,  P.E.
                                                     Richard C. Turbin, M.D.

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                                         *! r .  \  Mrs.  R o v  s 1 o v p n k o
                                                  and 1'lacp
                                                  Park,  IP.  ^n
                                         May  17,  1071
Mr. Gary >*. bchenzel
tiater Resources Planner
E.P.A. »ater quality Office
Chicago, 111.

i*ear .ur. bchenzel:

     Too long have we waited  for a  truly  objective study  of
the Clavey Road bewage Treatment Plant  e^'bracins  a total  vi PV  of
the Great Lakes 'rtater Quality  Control Problem.

     \\e commend your preliminary report and  tirse  you to nrotect
its scientific findings against  local creed  and rnj ?i nf or^a 11 on .
«e urge that this plant be phased  out quickly.

                               Very  sincerelv  vours,
                                I x.
                                \~^

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        TORS. CDARSHALL FlNKeLCT)A.N

332 LARKSPUR, HiqHLANb PARK, ILLINOIS 60035
                                        u         d
                    I'

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                      OFFICE OF THE CHAIRMAN

                           of
                     (Soiattg ^uilbing, Jlalu
                                  May 10,1971


Mr. Amos Turner, P.E.
Director
Lake Michigan Protectors  of
the Environment , Inc .
360 Charal Lane
Highland Park, Illinois  60035

Dear Mr. Turner:

I thank you for the  (FWQO) draft that you enclosed in your

letter of May 3rd.

In order that members be  kept  informed, I am making the

draft available to our  Public  Works Committee.

Thanking you, I am

Sincerely
Ronald R.Coles,^haTrman
Board of Supervisors

RRC.d

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   V!LLAGE-C?S€SiLLER PARK
     COOK COUNTY, ILLINOIS
             '•*
          RESOLUTION

     WHEREAS, it  has come to
   the  attention  of  the President
   and Board  of Trustees of the
   Village of Schiller Park  that
   the North Shore  Sanitary Dis-
   trict Clavey Road Plant in High-
   land  Park  is being expanded
   and the effluent  therefrom go-
   ing into the Des Plaines River
   will receive  only   secondary
   rather than tertiary treatment;
   and
     WHEREAS, after July 1,1972,
   all effluent discharged into Lake
   Michigan and me Skokie River
   must receive tertiary treatment
   and there is  no  good and suf-
   ficient reason why effluent dis-
   charged into  the Des  Plaines
   River should not also  receive
   tertiarytreatment, and
     WHEREAS,  the dumping of
   such effluent  and the increase
/ in volume into and through the
   Des Plaines River will consti-
   tute a grave hazard to the pub-
   lic health and welfare of me
   residents of those suburbs, in-
   cluding me Village of Schiller
   Park, through which  the  Des
   Plaines River flows.
     BE  IT  THEREFORE RE   -
   SOLVED by the Village of Schil-
   ler Park that the Village does
   formally protest  the proposed
   plans  of the North Shore Sani-
   tary District to  flush only
   secondarily treated effluent into
   the Des Plaines  River and that
   the  Illinois  Pollution  Control
   Board be and  herewith is mem-
   orialised to  resist the plans
•   of the North Shore Sanitary
   District aforesaid and mat equal
   to the  Skokie River and Lake
   Michigan and thus  prevent the •
   discharging into the Des Plaines
   River of any effluent that has
   not received tertiary treatment.

     APPROVED mis 29th day of
   April, 1971.

        Approved:
        Edward  Bluthardt
           President
   Attest:

   Walter Bykowski
       Clerk

n franklin Park. Illinois.

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                                3700  Ka.vthorn St.
                                Schiller Park, 111.
                                    8,  1971
Mr. F. T. Mayo,
Interim Reg. Dir.,
Yv'ater Duality Office,
U.S. Snvironaiental Protection  Agency,
Dear I,lr. Mayo,

Please include the enclosed  resolution with tne LTui't

of the Assessment of the  Environmental Impact  of the

T5T.S.S.D. Clavey Rd. Plant on the DesPlaiaes River.




Enclosure: Protest Resolution  passed  by the Village  Bd.

of Schiller Park on April 29,  1971  as published in  the

Schiller Park Independent.



                               Sincerely,
678-6864                       Mary i.'1Oddson

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*-•
   From The Desk Of
   BARBARA VOLIN
                11,
         " '  ' *A-t^07VL -


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                              1210 Gregory Street
                              Wilmette, Illinois
                                         60091
                              May 4, 1971
The Honorable Francis Mayo
Water quality Division
U.S. Environmental Protection Agency
33 Bast Congress
Chicago, 111.  60606
Dear Mr. Mayo:

          The month of discussion and final
decision as to the capacity of the Clavey Rd.
plant is Apr. 23 to May 23, 1971.  Many of
us in conservationist groups would like to
have this plant expanded much more for future
needs lest the proposed "compromise" plant
will be very slow in implementation, and not
realized until 1975 or later.

           If you believe with us that this
expansion is the easiest and the most economical,
and there is anything we can do, please contact
us. An encouraging word from you would help.

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\°    Q
                                         A*ril
      Mr. William D. 2ucicel*naus
      Administrator
      U.S. Environmental  Protection  Agency
      1626 K St. N.W.
      Washington, D.C. 20460
      Dear Mr. Ruckelshaus,
                  I Jeel  that it was  a £_reat  mistake  that
      the Federal government overruled tne Illinois Pollution
      Control Agency in tne Clavey Ho*d  sewage  treatment affair,
      Constructiojj nas been neld up for  2 years  oy 200 people
      while 5*5 million others watch  Lake Michigan get more
      and more polluted Because of this  federal  decision,  Highland  ParJt
      ia going to continue to discharge  i»,s sewage into L*Ke Micnigan
       for 2 to 5 years longer, an inexcusable delay. The  cost  will be
      higher. Finally, the federal government should not intervene
      when the state ic ^oing  a responsible  job
        I hope you will reconsider your  Action.
                                 Sincerely,
                                 Mrs. Robert Pfutzenreuter
                                 727 Linden Ave.
                                 Wilastte, 111. 60091
      Copy to: Francis Mayo

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                                      125 Maple Ave.
                                      Highland Park, 111,,6003d

                                      May 9,  1971
    Environmental Protection Agency
    Water Cuality Office
    Room 410
    33 V,  Congress Parkway
    Chicago,  II.,60605

	~7j4ttn:  Mr,  Gary W,  Schenzel

I   Gentlemen:

    PLEASE  do  not listen to the disruptive voices calling themselves
    "Lake Michigan Protectors of the Environment", "Protectors" indeed.'.'.'

    This group seises  any name appropriate.  When S.A.V.E, began(and
    still exists) as a thoughtful legitimate environmentally concerned
    group - this other (the disruptive ones) called themselves,"Save
    Highland Park" - capitalising on another group's good name.

    Now that there is  a resp«n*i51e group called, "The Lake Michigan
    .Federation," this  abonefgroup is writing letters asking us to write
    you and calling itself  Lake Michigan Protestors etc«.»"

    Highilnd Park and fhe North Shore Sanitary Dist. have spent afiono
    t-ime agonizing a formula.  Now the Clavey Rd. olant is goina ahead.

    At last, we, who place above all tther issues, the saving of Lake
    Michigan,  thought the difficulties were ironed out.

    Now, your office comes along, just when peace was beginning (we
    thought) - your office comes along and wants to chance the formula.
    You have let both  sides start the fight all over again.  WK7????

    Please,  let peace  reign.  Let the formula alone.   Let everyone
    precede  as before  and try to save Lake Michigan before its too late.

    There ate  a few voices like the above mentioned group - but
    I'm sure from reading election returns and votes for bond issues
    that the above tfo  not speak for the great majority of North Starve
    people who wish above all else to save our most important natural
    resource,  the Lake.

                                      Sincerely yours
                                      Mr, & Mrs, R.

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                     NORTHWESTERN UNIVERSITY
                           CHICAGO, ILLINOIS 60611
THE MEDICAL SCHOOL
WARD MEMORIAL BUILDJ-NT
  1IH E CHICAGO A\F
                                    May 10, 1971

      Environmental Protection Agency
      Water Quality Office
      Room 410
      33 West Congress Parkway
      Chicago, Illinois 60605

      Attn:   Mr.  Gary W. Schenzel
             Water Resources Planner
             Planning Branch

      Dear Mr. Schenzel:

           I should like to vigorously support the  Draft  Proposal

      of your office regarding the Clavey Road Sewage  Treatment

      Plant.  It  is a far-sighted solution assuring not only the

      maximum in  safety but the maximum in efficiency  of  sewage

      treatment for Southeast Lake County.


                                    Sincerely yours,
                                    Jack Arbit,  Ph.D.
                                    Associate  Professor
                                    Director of  Graduate Education
                                     (Psychology)
                                    Department of Psychiatry
      JA:ko

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                arcliitects
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                                                           (312) 33e-1333

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                              LESTER  SCHWARTZ, M.D.
                             81
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                                             Mrs. Emanuel Winston
v _                                           671 Marion  Avenue
                                             Highland Park, Illinois  600.3^_

                                             May 22, 1971

 Mr. Gary  Schenzel
 U.S. Environmental "Protection Agei cy
 Region V
 33 East Congress Parkway
 Chicago,  Illinois  60605

 Dear Mr.  Schenzel^

 Ordinary  citizens seem  to  stand back  in  awe when the experts  of  the
 federal government take over the investigation  of a problem,  especially
 a technical one.  I wish the politicians would  do the same.   It  seems
 obvious to me  the pressures your preliminary draft received,  had other mot-
 ivation than the desire to see the best  technical, ecologically  sound,
 long-range solution.
 As /me of the  members of the Committee to Save  Highland  Park  who was
 involved  in the technical  aspect of this problem, I studied all  the
 documentation  and triad to educate our city with the facts* A frustrating
 taak,  as  it seemed from the inside the true story was never accurately
 reported  at each juncture.
 We gave our hearts to the  effort to convince the city to fight for
 Highland  Park's welfare.   Too little, too late  they begin to  accede  to
 and make  resolutions opposing, each defect in the District's  plan.   I
 think  by  the time the plant is completed everyone will  agree  it  shouldn't
•have been built here.   It  is as  if they  must maintain the dignity of
 judgments previously made, especilly  that of our former  mayor, now  a
 member of the  Illinois  Pollution Control Board.
 The District fights desperately  to save  its original plans even  as  the exper
 prove  the defects, all  the while wasting our money and  time for  the  Lake.
 The Lake  County political  representatives give  powerful  vocal support to
 the District,  without  seeming to have read your report.  Perhaps I  am
 naive  but I don't understand why, or  who has what to gain.
 The Illinois Pollution  Control Board, an honorable body  but political
 appointees rather than  experts in the technology in ecology,  holds  a
 hearing which  seemed a  mockery to me  and issued a reoort whose legality
 is being  questioned by  both sides.
 Mr. Schenzel,  your report.was beautifully and masterfully done.  I  can't
 understand the statements/by its  vocal opposition, such  as Mrs. Rome  of
 the Illinois League of  Women Voters,  unless they didn't  read  it.  You
 convincingly covered every point and  some hei&ofore uninvestigated,  long-
 range  considerations, like the ultimate  effect  of the diversion  on  the
 watershed and  the possible changes in the biota of the Skokie river  and
 lagoon system.. You have taken into account the needs of all  Lake County
 and have  met the Lake deadline.  I atmlaud your report  and pray the final
 draft  is  as strong if not  stronger.
 For I  take a stronger  stand than you.  Where we live on  Marion Avenue,  the
 plant  you envision' would probably be  safe for us.  However, not  if  the
 North  Shore Sanitary District is running it.  Even under intense public
 scrutiny  for the past four years, they have made no effort to modify the
 proven air pollution or improve  their housekeeping - all the  while
 claiming, "we're overloaded, give us  money to enlarge and we'll  be good
 boys." This past ..summer they were not overloaded and still had  many days
 of  air pollution.  In  their meetings  they make  statements such as "Some
 day we're going back to Highland Park, and, by  God, we're going  to  get
 them," And, inrgpite  of the 18 million  gallon  aggrement with the city
 -i.                                                                      *

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     Mrs. Emanuel Winston         May 22, 1971          Page 2


 prohibiting future land purchase in Highland Park, "if we need more land,
 fe'll buy it."
Your report has acknowledged the possibility of health hazards the extent
of which is unknown.  Monitoring all possible air pollution will not stop
it.  We do not wish to be the guinea pigs used the study the effects of
sewage treatment plant air pollution, on a densely residential area.
Our Committee's original goal was to have the present plant modified to
control air pollutioijfbut not expanded, to serve Highland Park and our
lakefroat plants enly,)a3 soon as possible.  However, when your first cost
feasibilityfetudy envisioned a 30 MOD plant at an industrial site on the
Des Plaines River and eventual phasing out of Clavey, this was the ideal
solution.  But, it would be economically feasible only if Clavey was never
expanded to 12 MGD at a cost of $10-20,000.  Therefore, our proposal to
strongly counter the opposing political pressure is:
              1.  If the NSSD would agree to the 30 MGD plant at Des Plaines.
              2.  If they would build Gurnee with as much speed as they're
                  putting into Clavey, to remove  the industrial sewage
                  from the north, including North Chicago.
              3.  If they would improve, but not expand, Clavey in:
                  a. Capacity - by coagulant chemicals
                  b. Air Pollution abatement - by proper devices and
                     improved housekeeping or "state of the art"
              ; «  C'i D««6nst»ate the desire to serve us and helt> us -
                     instead of "get us".
              ij..  We would accept the present capacity, especially since
                  residential sewage could be more efficiently processed,
                  accept the possibility of overload for the 3-5 years
                  until the Des Plaines 30 MGD plant is completed and
                  Clavey phased out.
              5.  We wonld accept the lakefront diversion as soon as humanly
                  possible thereby meeting or advancing the "save the lake"
                  time schedule.
              6.  We would, of course, drop our lawsuits to save them and
                  ourselves money.
Please,Mr. Schenzel, accept the courage of our convictions.  We were in
awe of our government or apathetic, but we've gotten involved at great
physical and emotional expense.  Please use the full force of the federal
government to oppoa« the local, county, and state political pressure.
Write a strong final report for ecologically long range solution that is
safe for people.
Mrs. Emanuel Winston

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4-   I

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                          Hal M. Brown
                          3333 Greenbriar Road
                          Deerfield, Illinois 60015
                                                  May 17, 1971
Water Quality Office,  Region V
Federal Environmental Protection Agency
33 East Congress Street
Chicago, Illinois
              Re:   Draft Environmental Impact Statement for
                    Sewage Project No.  WPC-I11.  754 Submitted
                    by North Shore Sanitary District, Waukegan,
                                  Illinois
Dear Sirs:
       I have the following comments with respect to certain conclusions
drawn in the above captioned environmental impact study relating to the
recommendation to advise the  North Shore Sanitary District to build a
sewage treatment facility on the Des Plaines River.

       1.  The recommendation that the North Shore Sanitary District
build an additional facility on the Des Plaines River is not supported by
the Environmental Impact  Statement,  but appears  to be designed to quiet
objections voiced by residents  of the area surrounding the present Clavey
Road plant.   The statement states that the Des Plaines  River is already
subject to severe pollution.  The statement  (see page 13) that a more desirable
ecosystem may result from an increased flow into the Des Plaines River is
pure conjecture.  Furthermore, an increased flow of 18 MGD (28CFS) of
effluent into the Skokie River would have less of an adverse effect on that
stream than a similar flow into the  Des Plaines  River.   This conclusion appears
in the report itself on page 16.

       2.  While possibly  alleviating  some of the distress caused to residents
of the Clavey Road plant area,  the plant on the Des Plaines River would cause
similar problems  and dissatisfaction to residents  near  the Des Plaines River
site.  In addition,  it should be  noted that the proposed Des Plaines River site
(in contrast to the proposed site at Roundout) is  not within the present or proposed
boundaries of the North Shore  Sanitary District.  A plant on the Des Plaines

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River would result in lessening of property values and physical discomfort
to persons who in no way would benefit from the construction of such a plant.

       3.  The construction of the  Des Plaines River site will also cause
severe temporary disruption to the residents in the surrounding area during
the construction period. The site discussed for the area near Roundout
(apparently an industrialized area) was not considered because it would cost
approximately $1, 000, 000  to $3, 000, 000 more than the Des Plaines River site
(an area containing many homes).  There  is apparently no problem with respect-
to asking the sanitary district to spend approximately $19, 000, 000 more to
build an  18 MGD  plant at Des Plaines rather than at Clavey Road.

       In conclusion, for the reasons stated above, I believe the draft impact
study should be changed to recommend additional facilities for the North
Shore Sanitary District in an area other than the Des Plaines River site proposed
in the draft study.

                                         Very truly yours,

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   H.  BOWEN STAIR                          -o        tf> „ / 
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May  24,  J97J

Ak.  GOAIJ Schznzzl
tt'oter  Re-icorcexS PlannzA
E.P.A.  Woter QuaJiity.  O^icz Km.  410
33 W.  Ccngre44 PaA.kiva.ij
CkA.ca.QO,  lit.  60605

Pea*. Gory,

Under  iepara-te cover  members OQ'  -the  Lafee rlic'nigan  Pn.Qte.cX.oXA o^  -the
Env-tronmen-t have aJin.za.dij -submittzd -  on. wilt submit -  comment OKI  the
env-cron/rien-ta£ -impact  6-tatemeftt on the MoAth Share  Sa.nitaA.Lf Vi>stAict' •$
pAcposzd expansion plans.   The-ie commen-ti covet the technical, eng-cneer-cng
and  inx.cAcfato£cg-tca£ aipec-ti e^ -tfie pfioj'e.ct and aim ^tl>J. endowed  and
            !/ t/te erc£ti.e membeu/wp oj t/te Lafee ''ickigan Pn.ot  03
In addition tke. Soc-ietu  against U-iotzna to tkz EnvLioiwunt (SA1/E)  and
-the Campaign kga-iMt  PottlitLcn  (CAP)  nave endowed ^e F W 0 A'i  dia^-t
meyutal  i-ta^emeni a-i hai  the b co-id cj  School Piittic-t  70S in Higkiand Pa,ife.
tuAt.ktnjmon.
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Mr. Gary Schenzel
Chicago, 111.  60605


The Lake Michigan  Protectors  o{, the Environment  endorses  the recommendations o$ the
FWQA In their entirety -  tclth one major exception.   In  our judgment the size oft the
plant should be limited to 6  MGP 04 detailed in  Mr.  Turner's engineering and technical
report.

      A. We endorse the covering o< the retention  basins  and the re-evaluation oft the
         proposed  capacity.
      8. We endorse the recommendation /(or a new.' facility o'\ IS MGP on -the Pe4
      C. We endo/tie ^ne ^eque/i-t xt/iai the. NSSV "Ion-it  e.n\>-ifioyme.ntat damage du.fu.nQ
         conA&iucstion and fi^tofie. d^ ofi Mote.fi faom one. ujate.'Uhzd to ancthe.si" .
      F. The. recommendation that a *tu.dy be. initiated ande-l confiolle.d conditions  to
         "aAce.?italn the. possibility o^ aifioofine.  inaction  ^fiom -iecoage t->ie.atme.nt
         fiacllLltleA" , lb totally and strongly endowed by  QUA cltize.ns group.  This
         is a tA.esne.ndous oppo^fttanlty faon the. Federal  Government to perform an out-standing
         seAvlcn not only to the. 'ie.slde.nts In the imme.d^ate. a/tea -iarrouna^ng the Clavay
         ptant  but an oppotutunitij to perform a 4erv< immoftal  and unconscionable, that
         thousands o^ us - especially oufi chlld,ie.n  -- must ..serve ai human guinea pigs.
      G. We urge that the. FW£A Insist on the. removal  OQ  ^ne e^^ueni £agocn $
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           HEHUKRT A.LOKB, HT

             37O HASTINGS AVENUIS

        HIOHLANB PARK, ILLINOIS 6OO35

              AREA 312/132-0002



                            5-26-71
Mr. William Ruckelshaus
Director
Environmental Protection Agency
Washington, D. C.

Dear Mr. Ruckelshaus:

With reference to the Clavey Road Sewage Treatment
Plant (I live about  .6 miles from the plant),  I
urge that:

1)  The existing plant not be enlargad and that
    plans be made for eventual phasing out of
    the plant.

2)  The plant be landscaped properly, to avoid any
    further damage to the environment.

3)  That the effluent lagoon construction be stopped
    at once, since tertiary treatment will supplant
    it.

4)  That any construction which is dons in the
    future be handled in a manner which reduces
    environmental damage.  Enough damage has been
    done already.

5)  That a plant b* constructed, starting at once, on the
    Des Plaincs river, of a size that will enable
    phassout of the Clavey plant.

6)  That the retention basin at Clavey be covered.

We appreciate the interest that the E.P.A. has taken
in this matter, with special appreciation for the
attention given the immediate neighbors of this
plant.  Yours is the first governmental body to have
shown evidence that protection of thes'a people was
an important factor.

Thank you.

                        Yours t,

CC: Mr. Gary Schenzsl    /
    Sen. Charles Percy
    Sen. Adlai Stevenson
    Gov. Richard Ogilvy

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   LSAGU2 OP WOMEN VOTERS OF HIGHLAND PARK

   FOR HfcffiDIATE RSL2ASE

                            STATSME3T TO CITY COUNCIL . May 10, 1971
                            REl  BAN ON NSW SEWER HOOK-UPS TO NSSD_

      %    While we are svare of tho serious rani float ions of our position,

      the League of Women Voters believes that directing any additional sewage

      to the already overburdened Clavey Road Sewage Treatnent Plant, or necessi*

      tatins the dunping 'additional, inadequately treated sewage Into lake

      Michigan, would constitute an environmental and health hazard which cannot

      be tolerated*

           Unless and until the NSSD can provide interim facilities to increase

      its capacity to treat additional sewage — facilities which would be accept-

      able within the constraints of environmental protection -« we oppose the

      Issuance of permits for new sower hookups*

           We respectfully request that the City of Highland Park reconsider its

      action to exclude single family dwellings from the ban imposed by the Illinois

      Pollution Control Board, with the exception of those homes already under

      construction.  We feel that to allow additional connections, and to urge other

      municipalities to do likewise, will create a further "hardship1* on the people

      of Highland Park which balances or exceeds the hardship on those to whoa

      permits will be denied.  The use of Lake Michigan is now denied to us all;

      the Skokie Lagoon has becooe a cesspool;  and the NSSD has claimed that

      over leading of the Clavey Road plant has been responsible for odors and mal-

      function*

           There is an enormous potential for single family development in the

o    £"area served by the NSSD which must be postponed until the facilities are
     _
  o   ^adequate to receive the additional sewage generated!

 —*£  Sic: City Council, Highland Park      Illinois Pollution Control Board
          Trustees, NSSD                   League of Women Voters of Illinois
      —  City of Lake Bluff                  "   "    "     "    "  Lake Bluff
      X  City of Lake Forest                 "   »    »     »    "  Lake Forest
      3E  Illinois Pollution Control Board
          Highland Park News, Highland Park Life, Waukegan-News Sun

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                     '  itiuiii- of
                        , «- 1?, 1971
i.r . Francis T. . ays
Interim Regional Lirector
 jater '''uality Office
I'. S. environmental Protection Agency
33 Tiast Congress Parkway
Chicago, Illinois 6Co05
AS the Village President of the Village of Hodgkins  I  am
writing your office stating the Village of Hodgkins  views  on
t-.e new sewpge disposal nlants.

1 './ish to ro on record th<-t we violently oopose  under  any
conditions the dumping or disnosin;; of Anything  into the
F,'?s Maine s ':iver.

Our village is located adjacent to the Ees Plaines .liver
;!nd are very much concerned about any chance of  a flooding
condition.  This, I feel, will be greatly increased  with
the suggested methods as outlined in the attached newspaper
article .

The Santa ?e Railroad has many acres available for future
industrial expansion in this area, any threat of a flooding
condition would be very detrimental to the economy of  the
railroad and the Village of Hodgkins.

Thanking you, in advance, for presenting .my letter to  the
nroner authorities.
Yours trul
                                 y,
                    '" ''Leon u. Cook
                       Village President
L.iC : bb

cc:  i syor : ichael Coduto, Countryside, Illinois
     j r. i erle Anholt, The Atchison, Topeka -c- Santa Fe

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                           DONALD  N.  MANN
                               ATTORNEY AT LAW
                            til SOUTH DEERE PARK DRIVE
                         HIGHLAND PARK. ILLINOIS 6DD3S
                                IDLCWOOD 3-33Q5


                                May 1°, 1971

Enviromental Protection Agency
Water Quality Office
Room hlO
33 West Congress  Parkway
Chicago, Illinois 60605

ATT: Mr. Gary W.  Schenzel
     Water Resources  ^lanner  - Planning Branch

Dear Mr. Schenzel:

By action of the  Board of  Directors of the  ^eere Park Neighborhood Assoc.,
taken on Wednesday, May 19, 1971 we wish to go on record as favoring the
FEDERAL WATER QUALITY OFFICE  draft as to the  matter on Clavey Road in
Highland ^ark,  Illinois,

We believe such action is  necessary to Dreserve not onlv the
but also the total  ecology of the  area,

          ur support  and help in  anyway possible.

         OARJ) PF  02RECTP9S £%$&  PARK. NEHBRHD. ASCOC.

                 /? f
           M MAMM  PRESIQENT"
                        (^

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        PRESIDENT
           3a bbagh

        VICE PRESIDENT
        L. 3eokar
                                  Riverside Lawn

                            Improvement Association

                            3748 Stanley, Riverside,  111.   60546
                                       Lay 20,  1971
 L!r« Gary Schenzel
 U. S. Environmental Protection Agency
 1819 J. Pershing .load
 Qhicago, Illinois
Dear
          ichenzels
 He *  Sawaga Treatment  Plant Construction on DesPlaines  ^ivar at
      Cook-Lake County  line

               The  peonle  of Riverside Lara are opposed  to  the nroposal
 by your agencv that  affluent  fror tie North "hore  -anitary District be
 dumped into the QeaPlaines .'liver.

               P.iverside Lawn  is an unincorporated  community located in
 Riverside Township and surrounded on three sides >>y  the  DegPlainea River-
 3ecause of this location  *B are vulnerable to flooding  caused by ice
 jama, spring thuvrg or rteriods of heavy rain.   This flooding brings
 with it any sevi/age,  oil,  debris and other forms of filth that have been
 discharged into the  river by  combined sevaers,  industry and sanitary
 districts located  upstream of Hcffman Dam.  Over the years this problem
-has  increased  to the point where w feel it  «fill becone a  serious threat
 to our '*alfare  to  nlace any aiditional effluent into the DesPlaines.

               At this time TO  are considering  application to the federal
 Housing and Urban  Development  for subsidized  flood insurance*  Insurance
 at any cost can never remove the rissries of  fl coded property,  but we
 see  no logic  in the federal government placing  our hoines in jeopardy
 and  then offering  to pay  for dacages.

                                        5incsrely,
                                                    -y
                                        ra.  BarnaroVJ. Regnier
                                        Secretary

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 17639 DUNDEE ROAD

 HOMEWOOD. ILLINOIS 6O43O

 312/798-5674
May 24, 1971


Mr. Gary W. Schenzel
Water Quality Office of United States
Environmental Protection Agency
33 East Congress Street
Chicago, Illinois 60605

Dear Mr. Schenzel:

RE:  HIGHLAND PARK, ILLINOIS
     CLAVEY ROAD WASTE TREATMENT PLANT

The Illinois EAA has with uncommon wisdom recommended the use
of chemical coagulation to improve the efficiency and throughput
of the above conventional activated sludge plant.  We propose
that consideration be given to the use of a thoroughly proved
unique chemical-biological treatment that improves the operation
of the primary, secondary, final and digester.  The fundamental
physical chemistry supporting the approach was developed through
basic studies at IITRI by the undersigned.  Variations of the
process have been utilized in hundreds of industrial applications.
More recently the process was adopted for sanitary use in a 15-
month plant demonstration study.  The demonstration was monitored
by both the federal and state EPA.  The system can be readily
adapted to existing plants.  The day-to-day plant operation has
proved to be relatively simplistic and requires a minimum of
semi-skilled control over broad operating conditions.

The following is a simpliffed technical discussion on the process.
The unique combination of commercially available coagulants
separate suspended matter, colloids, and a large percentage of
complexed soluble substrate from the aqueous phase.  The rationale
for this step is supported by the fact that before microorganisms
can utilize solid phase nutrient, a series of enzymes specific to
a given waste must be generated and utilized by the microorganisms,
The generation of specific enzymes by microorganisms is time
consuming.  Enzyme generation is accountable, to a major degree,
for the low efficiency of conventional plants.  By removing the
difficult to break down suspended and colloidal solids in the pri-
mary, only soluble substrate enters the secondary.  Solubilized
nutrient can be rapidly and efficiently utilized by bacteria.  The
solid phase materials are transferred to the digester where the
slower enzymatic reactions can take place with no opportunity for
escape to the receiving body of water.

It has been plant proved that suspended, colloidal and a large
         uf une compiexea soluble substrate can be removed in the

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Mr. Gary W. Schenzel
May 24, 1971
Page 2


primary by a unique complementary combination of chemicals.  The
use of conventional coagulants, such as iron and aluminum salts, will
improve to a lesser degree the solids removal rate in the primary.
The common metal salts function effectively within narrow parameters
that require skillful testing and close process control — even
then their performance has proved erratic and relatively inefficient
on a cost-effective basis.

A split feed permitting addition of the unique combination of
coagulants to the final settling basin increases the floe size and
density.  This action improves the rise rate capability of the
settling basin in the same manner as in the primary settling basin.
Experience teaches that the rise rate can be conservatively improved
by a factor of two.  Of equal importance is the compaction or con-
centration of sludge (MLSS) by the coagulants.  Experience teaches
that with all other variables constant the reaction rate in the
secondary is a function of the amount of MLSS.  The MLSS are recir-
culated into the secondary from the final.  Under conventional
operating conditions the increase in MLSS is accomplished by increas-
ing the recirculation rate.  A typical rate is 30% of total flow.
Unfortunately when the recirculation rate is increased a proportional
loss in reaction time occurs due to the increased hydraulic load.
The sludge concentrated by the coagulants permits an increased bio-
oxidation rate in the secondary without a large loss in residence
time due to excessive hydraulic loading.

A dual function of one of the coagulant chemicals is to adsorb
waste and to provide a surface for biological families to generate
sequential enzyme systems.  The surface provided permits bacteria
to create localized conditions for optimized pH and redox parameter

The results of the plant demonstration study has shown marked im-
provements in the day-to-day operation and efficiency of the primary
secondary, final and digester.  It is estimated that the chemical-
biological approach could double the rated capacity of a typical
plant at a total cost of 2 to 5/6/1000 gals.  This cost figure in- *
eludes operation, chemicals,depreciation and maintenance of the
chemical system.

The field demonstration was a techno-economic success.  Average
flow rate during the 15 month trial period was 160% of rated capa-
city.  Effluent BOD was reduced from an average of 42 mg/1 to less
than 4 mg/1; suspended solids were reduced from 77 mg/1 to less
than 5 mg/1.  Total phosphate, as PO^ , was reduced to less than
1 mg/1.

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Mr. Gary W. Schenzel
May 24 , 1971
Page 3


The improved throughput and efficiency was obtained at an added
dollar cost.  In addition to the dollar costs there are certain
disadvantages to the system.  Although coagulant cherabals improve
filtration of the sludge, the coagulant residue adds , depending
upon dosage , between 500 Ibs. and 1000 Ibs .  of dry solid waste
per day for a typical four million gpd plant.  Hauling costs can
be estimated at 30^ per ton mile.  Eighty five percent of all
solid waste is disposed of in this manner.  The relatively minor
increase in solids disposal costs are often given as the excuse
for not using advanced coagulation, when designing a new plant or
expanding an existing facility.  Of perhaps greater significance
is the fact that the design engineers fee is calculated on a
percentage of the total plant cost.  The potential loss in income
is more than a subtle driving force when one considers that a
detailed cost study has shown that a plant using advanced coagu-
lation techniques costs approximately fifty percent of that of a
conventional treatment plant producing the same quality effluent.

We would be pleased to review the results of the field demonstration
study with you.
Very truly yours,
R. Kir^connell
Director of Research

RK:p

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o

                                      ENVIRONMENTAL DEFENSE FUND
                                      162 OLD TOWN ROAD
                                      EAST SETAUKET, NY 11733
                                      516 751-5191
                    1910 N STREET, N W
                    WASHINGTON, 0 C 20036
                    202 833-1485
 Mr.  William D. Ruckelshaus,  Director
 Environmental Protection Agency
 1626 K Street N.W.
 Washington, D. C. 20460
                   May 21, 1971

Mr. Gary W. Schenzel
Water Resources Planner
Environmental Protection Agency
Water Quality Office
Room 416
33 West  Congress  Parkway
Chicago, Illinois 60605
         Re;            Draft Environmental Impact Statement
                                       £_

                     Sewerage Project Number WPG - 111. - 754
                     Submitted by North Shore Sanitary District
                                  Waukegan, Illinois
                     Federal Environmental Protection Agency

  Dear Messrs. Ruckelshaus and Schenzel:

         Some of the citizens of the area affected by the above-mentioned project
  have asked us to comment on the National  Environmental Policy Act environ-
  mental impact statement prepared in connection therewith.   Being unfamiliar
  with the geographical area I am unable to comment in detail on most of the
  particulars  covered but the statement does  seem to give an adequate description
  of the environmental effects to be expected from the various alternative actions
  considered.  I would gather that many if not all of the objections raised by the
  local citizens have been answered or minimized by recommending slight changes
  in the original design plan.  To the extent this is true, it demonstrates how  useful
  a tool these statements can be in allaying legitimate questions of concern raised
  by responsible citizens.  It is hoped  that this procedure will be employed widely
  in the future.

         The law seems to require that the Water Quality Office not fund a final
  project design that does not incorporate the "recommendations" of the impact
  statement or such improvements that  might be suggested as a result of this
  review process.  It should, in fact, be made clear that no federal funds  will
  be provided unless the  recommended conditions are substantially complied with.

         A specific comment relates to requesting the inclusion of an operational
  definition of what constitutes "the  necessary waste treatment unit processes to
  protect" the appropriate receiving water body.  It is not clear,  but should be,
  whether a percentage removal of some item is envisioned or whether an  effluent
  concentration of these items is  means.  The numerical values should be included
DENNIS PULESTON, CHAIRMAN
RODERICK A CAMERON, EXECUTIVE DIRECTOR
                    WILLIAM A BUTLER. ATTORNEY

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                                       - 2 -

       Recommendation 5) advises the Water Quality Office of the U. S.
Environmental Protection Agency to

       a) initiate a broad impact study of the environmental consequences
       of diversions  of water from one watershed to another.

       b) initiate a study under controlled conditions to ascertain the
       possibility of airborne infection from sewage treatment facilities.

There should be some assurance that an effective mechanism has been set up
whereby these and similar recommendations arising from field office studies  are
channelled to the Research and Development Office, or other appropriate group, in
either the Water Quality Office  or another branch of EPA for review and evaluation.
It would be disturbing to discover that such recommendations dead-end admini-
stratively in these statements,  particularly since the purpose of NEPA is to
assure that such recommendations are implemented.


                                                Yours truly,


                                                Nils E. Erickson
cc: The Honorable David Dominick
NEE/mlr

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                                 815 16-th Street
                                 Wilmette, Illinois 60091

                                 19 May 1971
Mr. William D. Ruckelshaus, Adm.
USEPA
1626 "K" Street, N.W.
Washington, D.C.  20^61
                Re« Highland Park, Illinois
                    Clavey Road Sewage Treatment Plant
Dear Sirt
     We are writing to urge you to support the State
Pollution Control Board's decision to proceed with the
above mentioned plant.

     In our opinion, the difference between 12 mgd and
18 mgd is not enough to continue delaying the construction.
It is time to stop putting untreated sewage in our
beautiful Lake so we may once again enjoy this natural
asset to its fullest.

     The Illinois State Pollution Control Board is
doing afi excellant job, and should be encouraged in its
efforts.

                                 Sincerely,



                                •> 'Marshall and Joan Moretta

cci Richard J. Kissel

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                    Epstein  ana
EXECUTIVE OFFICE 31 S WEST ADAMS ST., CHICAGO, ILLINOIS, 60606 U.S.A.  • PHDN E (3 1 2) 7B2-7S1 5-1 6


                            CABLE ADDRESS • SHEPS CHICAGO
                                    O&O^
                                        7
          •  DIRECT ALL CORRESPONDENCE TO e*ETM ITIVtr ne-rir-c-

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r   (JUowien   (Joters  or <_/ VortnbrooK
/                       /
    ectcfMe or     owien    oers or  <_  ornrooK     northbrook, nnnois 50052
_ c/ _ / _ /
let the people know  make the people care   help the people act


                                                   May 14,  1971

Mr. Willic.r. D. Huckelsriv.us
Environmental Protection Agency
1626 K Street i;.  V.
Washington D.C. 20460

Dear Mr.  Kuc.ielshc.us:

¥e  &re writing to protest the LPA  dr::ft  er.vi rerun ~- at _1  1-c.p: ct
study of  trie Korth_ jahore Sanitary  District/ s expansion plans
for the  sewarp^lreatrr.ent facilities on Cl; vey Road in  Highland
Park.

The EPA  recommendations include  reducing the pi. -.lined capacity
of  the Clavey Fl^nt frorr, II: to 12  "illior, C2 lions •; d-;y,  r nd
building facilities elsewriere to  cccp^ns: te for the reJuced
capacity.  These recommendations,  if followed, \.culd result
in  creatly increased costs for the  Korth Shore ii:nit-ry  District
and its  taxpayers, and "/ould delay  by ..t le..£t c. yec:r  the
closins  of 5 obsolete plants no;--?  di£ch;.rcin^ in-.decu-.tely
treated  sewage into Like .'.ichic-^ froz L,.he Bluff, L. he  Forest
and Highland Park.  The present  olr.n, ordered b" the Illinois
Pollution Control Eo;-rd, for i>n  lo  Trillion Bailor, cr^.-city
at  Clavey, T.,rould permit diversion of seTi.':-;ie frcr.i the chore
plants,  and from the like, as soon , .£ ne / construction is com-
plete, in 1973.  Reduced capacity   ;ould  del^.y re-rcutin,_ until
197-4, vrhen the up^radin^ of present 1\ cilitles is finished.
Thus sewage receiving only pric-.ry  trcr.t_;ent--_r.d rii,r  sev/a^e
during  storras--v:ill continue  tc  enter Lake -.ichigrr. for
longer  time  under the EPA plan  than under t
Ana  the risks  involved in using,  sewage-cent r::inated a1 ri lining
water will  continue to be borne  by  tens of thousands of people
on the  north shore -jlone for  a  5C,'J  longer tia.e.

The  EPA environmental inspect  study  aces not appc- r tc  consider
the  consequences of its recc .... enactions on Lake ..icai^an and
its  users.   The principal be.ioflei; rius of changed.  ;l:ric :• t
Clavey  would be the homeowners  t.iere,  ar.d the bsnsfit  they
would receive  is tenuous at best.   Claimed daaiage to property
values  froc  the presence of the  sewage plrr.t dees not  jibe
with the fact  th't nost of the  hexes there v/ere built  after
the  plant.   Protests concerning  odor are primarily based on
crobleus connected '.'itn operatin^  the .^lant considerably in
excess  of ca.xcity, s situation ahich -.,rill continue tc ;;:ist
if the  smaller pi: nt is .:p.,.oved,  since its c-^acity will  be
exceeded the day it opens.  Fears  of airborne viruses  do not
appear  to be justified.  The  .•ctcr.tial risk of wrtcrbcrne  vi-
ruses in drir_kin.c water is grc ter,  and  threr-teiis  _.. ?ir ^rc-ater
number  of -. e^ple,  including,  it  should, be  nctc-d,  Glavey P.c: d
residents as ':eil.

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The EPA draft study ic ir. contradiction  to  the  judgement,  deci-
sions, and orders of tiic Illinois Pollution Control Beard,
vhich is overseein^ t^e work of  trie iicrta. Shore i. nitary District.
The IPCB is an agency which hat;  been moving strongly s gainst
polluters in Illinois.  We are concerned thft if 2  federal
agency endorses a less stringent timetable  for  ending sewage
discharge into Lake Michigan than that of IPCB,  other polluters
under IPCB orders to clean up -.-ill start to seek less stringent
timetables from the federal government also, end the fine work
of the IPCB v.rill be undermined and weakened by  hearings and
delays .
Finally, delay in diverting sewage  from  the  shore plants
not by itself destroy Lake hic:ii£an,  cut it  is  one of the
:n:'ny insults, small .-.nd l:r^e, v:hich  :-dded  together v:ill indeed
lead tc the L:.ice's dootructicn.   This  is the environmental
impact with  hich the £?A shoul^  be :i:ost C-.-ncerned, and which
the draft study fails to consider adequately .

                                    Sincerely yours,
                                     Mrs.  Ralph Seeder
                                     President
                                     3913  ixaacliffe
                                    .llorthbrook,  Illinoi
                                    ^ Wjv> Uo (iXua-^-A "T-  Y <57xju2>\ /->>
                                     Mrs.  Willia.T. T. ?o"srs
                                     Envlroruzont:--.! quality Chairman
                                     113C  tfhitfield Hoad
                                     Northbrooa,  Illinois oOC£2

                                     League of Women Voters
                                     Northbroolt,  Illinois

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           HERBERT A.LOEB, lU
             37O HASTINGS AVENOE

         HIGHLAND PARK. ILLINOIS 6OO35
              AREA 312 / "132-0002



                           5-26-71
Mr. William Ruckelshaus
Director
Environmental  Protection Aqency
Washington, D. C.

Dear Mr. Ruckelshaus:

With reference to the Clavey Road Sewage Treatment
Plant (I live about .6 miles from the plant), I
urge that:

1)  The existing plant not be enlarged and that
    plans be made for eventual phasing out of
    the plant.

2)  The nlant be landscaped properly, to avoid any
    further damage to the environment.

3)  That the effluent lagoon construction be stopped
    at once, since tertiary treatment will sunplant
    it.

4)  That any construction which is done in the
    future be handled in a manner which reduces
    environmental damage.  Enough damage has been
    done already.

5)  That a plant be constructed, starting at once, on the
    Des  Plaines river, of a size that will enable
    phaseout of the Clavey plant.

bj  mat tne retention basin at Clavey be covered.

We appreciate the interest that the E.P.A. has taken
in this matter, with" special appreciation for the
attention given the immediate neighbors of this
plant.  Yours is the first governmental body to have
shown evidence that protection of these people was
an important factor.

Thank you.
CC: Mr. Gary Schenz;!
    Sen.  Charles Percy
    Sen.  Adlai Stevenson
    Gov.  Richard Ogllvy

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                         THE REDMANS
                         2O6 ASPEN LANE
                    HIGHLAND PARK, ILL.  SOO3B
          \Xje_
UW   ok)

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 Mrs. Donald Fuhr
          333 Larkspur Drive, Highland Park, Illinois 60035
                                         17, 1971
Mr. William D. Ruckelshause
Directory E. P. A
Washington, D. C.  20U60

Dear Sir:

We have waited so long for truly objective study of
Cleavey Road Sewrage Treatment Plant embracing grand
view of Great Lakes Water Quality Control Problems.
I commend your preliminary report andurge you to
protect its scientific findings against  local greed
and His-inforaatIon.  I urge this plant fee phased out
quickly.
                         Yourst truly,

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             ffHii. Uimotfiu (D. H '/nits.


               2<+14 'Ofia.us.i ^>tis.s.t
                       J


             Evanikcn, QLiinoi* 60201
         J
                                            /JT/17/
                             *..+ 4.1*4


                                     t-*l*«-*ju.

                 <7       .                 0.
ttt,  /frjtJZu*   
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                  MILDRED KIRSCH
                 31O HASTINGS ROAD
               HIGHLAND PARK. ILLINOIS 6OO35
fc/y/        UJA^<$ ia<> ^^^€) /^.
^r ^^^^ •     -         ^ r

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                       Donmoor.^olf
                       makes thing? boys like to wear

May 21,  7971
MA. GOAL/ Schznz&t
WateA ReiouAce*  PlanneA
E.P.A. UJateA  Quality Orf^tce  Rm.
33 W. CongAe44  PoAfewoi/
Chicago, III.   60605
I am 4uAe  r/oa can u.ndeAAtand that  ai  pAivate. octizen^ eacn o^ ai  hat>  to
     QUA own tivzJLJ-hood.  In otktn. wofidb ,  u?e a/ie faa4-i.ne^-5 and p4C"j2xS4
       -en  addition to anoth&i heApon&icumt>tanc£A and tktfit^ofti  I mw^t appeal
to you. to  gsiant 04 an extend-con  6$  time. u.nti£ Maw 26th to te,ipond  at6#i
comrnejtti on ^tne dfia^t e.nviAonme.ntai i,tateme.nt.   MA. TuAneA xLi ^abm^ittin
andeA. t>e.pan.ate. coveA, e.ng-ine-e. comment on -tne mx^cAo fa-co£og-tca£ a4pec£j, unde-1
       04  we££.  Tne ex-ten^^on o^ ^>un£ wJUL peAmx^t JeAAy Facfe-toA and
             OOA 044-tgned position o& oaA Aeiponie ^:o ^tne cka^ t>tat
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                         Donmoon^W
                         makes things boys like to wear
May 11,  1971
Mti. fJJ-liLiam V . Rucke£i> hauA
ViitctoA,  E.P.A.
Washington, V.C.   20460

Veai Mt.  Rucfee&sftou/s,

Ai a -te^tden^ o{,  Highland Pa-ik,ujho-t>e home.  un$oit.unaf.e.tt/ ha.ppe.tu,  to  be  no
ma fit than  $  potiato^ bat 6J.nce.  I have, thize. school, age, cktldA.e.n
you can undeAAtand  my 4e£^-c4/in£4i.  In addition,  I am de.e.p£y concerned
about t'm quatity Og OUA 4jnp£y do not httong, -in high de.ru> -Lty l
a-reai.   T/ie  hta£th and wti^aAt ofi fiu-idtntA  should be. youi pfu.maA.y  conc&in.
T'/vit>  caJLt6 $01 a phazt out o$ the. C&avty  Road ptant.   We AuppoAt youJi
diafit btatemt'/vt but. u/tge a 9 ,V( G V p-iant.   Hotd $a6t tc the. ie.comme.ndation-i>
$01 advanced wcvteA. tAe.atme.nt and comp£t£eJLy coveAtd itttntion ba$-in4 .   We
uige.  that you advocatt the. itmovat o$ tht t^tutnt lagoon.  The. -imp£ejne.n£ation
o$ a  Atudy o$ aiiboint -in$e.c£ion xLi a ma-i^.   Combat potiution and pitvtnt the.
de.gA.adati.on  c$ OUA tnv-Lionmtnt but not  at the. poAA-ible. expense eg human
            you&&,
          .  GEKALV /.  SUKELL
               ey
   Donmoor,Inc. 854 Merchandise Mart. Chicago. 111. 60654 • Telephone (312) 321-0121
                     Hearts,,'

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   AMERICAN
    MOTORS
                   HARRIS  MOTORS
221 Sheridan Road    Telephone 746-1221
WINTHROP  HARBOR, ILLINOIS 60096
Kenosha  Telephone 658-4040
                                                      June 8,  1971
Mr. ',/illiam D. Ruckelshaus,  Administrator
Federal Environmental Protection Agency
Washington, D. C. 20460

Dear Mr. Ruckelshaus:

The section of Eastern Lake  County Illinois,  in  the  North Shore Sanitary
District, has been gravely struck with the  order of  the  Illinois Environmental
Protection Agency that no new sewer hookup  can be made to the NSSD until its
facilities are expanded to take care of  the present  users and the calculated
long range new users.   I certainly agree with this thinking and I am sure most
people, who are not greedy,  also concur  with  the thinking.  However this sort
of action cannot and must not continue for  too long  a period of time.

It is my belief, as well as  my colleagues,  that  Federal  Government in con-
junction with the State and  County Government (NSSD) should quit "playing
footsie" and make the Clavey Road Plant  an  18 million gallon per day facility
plus any other facility needed to get the north  shore waste out of Lake Michigan
and give the area back its sanitary sewer.

The economic condition, standards, and growth of the area are at a very low
ebb as well as the moral of  the people is sickened by the lackadaisical inability
of a rich government to solve this very  important problem.  Another problem that
should be and must  be handled in the near  future is some type of master sanitarv
sewer system for the balance of Lake County Illinois, outside the North Shore
Sanitary System.  The^Chain  of Lakes and other Lake County waterways have absorbed
about all the waste they can take.

It is hoped that you will give your attention and lend your position to getting
an immediate solution to the above described  problems.

Thanks for the good work you have been doing.
                                        Sincerely yours,
                                                           OLA
                                        S.\A. "Jimmie" Harris, Chairman
                                        LaJte County Regional Planning Commission
SAH:MAH

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                  ELAINE R. GROSSMAN

                 418  Briarwood  Place

               Highland  Park, Illinois
                         60035
                                      June 21, 1971
Mr. Francis Mayo
Environmental Protection Agency
33 East Congress Street
Chicago, Illinois 60605
Dear Mr. Mayo:

          I do not know whether anyone has spoken for the
179,800 citizens of the North Shore Sanitary District who
are not represented by the Save Highland Park Committee.
As a citizen of Highland Park who lives about a mile from
the plant, and as the former Water Resources Chairman of
the local League of Women Voters for fourteen years, I
would like to state a few points that the Save Committee
does not mention.

          (1)  The plant is situated at the low point of
the district which it serves.  Much of the sewage reaches
it by gravity.  That fact of nature cannot be utilized at
any other spot in or out of the district.  At a time in
history when the creation and uses of electricity loom
before us as the next problem, we might consider this as
an important point and enlarge the plant to whatever size
necessary to take full advantage of this fact.  It is the
reason the plant was placed there, squarely in the middle
of a swampy area, unsuitable for housing, reeking with the
odor of peat bogs and an often stagnant Skokie Ditch.  That
a sharp developer surrounded it with houses whose inhabi-
tants assume the ditch and peat odors come from the plant
is unfortunate.

          (2)  If one believes that public funds collected
from all should be used to the best advantage for the most
people, one does not put the property values of 200 people
above the needs of 179,800 other people who are taxed to
raise that money.

          (3)  That their property values go down as the
plant capacity goes up cannot be denied.  That 150 doctors

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Mr. Francis Mayo
Page 2
June 21, 1971
signed a statement that a survey should be made to be sure
the plant would not affect their health is a fact.  I am a
medical technician, working for the head of internal medi-
cine at Highland Park Hospital, so I know how the signa-
tures were obtained.  The pressure tactics were exactly
those you can imagine them to have been, of mothers on
their pediatricians, women on their obstetricians, and al-
lergists upon each other (as the biggest allergist in the
district lives a few blocks from the plant) .  Any name on
that list will tell you, if questioned, that the viruses in
sewage are there because they are water-borne, not air-borne
. . . that you need no survey to remind you that mankind has
a  long history of shoveling manure, having an outhouse next
to the kitchen door and working in sewage treatment plants
without air-borne injury.  Man also has a long history of
water-borne infection due to untreated sewage - so we had
best get on with treating ours now.

           (4)  In fairness to the 179,800 citizens who con-
tribute the taxes, we had best not waste their funds on
dalays and bowings to the needs ot 200 unfortunate people
who bought expensive houses on cheap land next to a sewage
plant.
                                    Sincerely yours,
                                    Elaine R. Grossman
                                    (Mrs. Arthur I.)
ERG: eel
CC to:  The Honorable Charles Percy
          U. S. Senate
          Washington, D. C. 20510

        The Honorable Adlai Stevenson
          U. S. Senate
          Washington, D. C. 20510

        The Honorable Robert McClory
          House of Representatives
          Washington, D. C. 20515

        Mr. William Ruckerhaus
          Environmental Protection Agency
          Washington, D. C. 20460

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                                              June 23, 1971


Mr. Willlaa D.  SucJcalshauj,  Director
JSnvirennsental  Pr«t«etion Agency
1626  if Street,  N.¥,
Washington, B.C.  20h60

Dear Mr, Rackalahaus:

     Pleas* be  advised that  the Beard  of  Directors  of North Suburban Synagogue
Beth £1, 1175 Sheridan Head, Highland  Park,  Illinois comprising over 300
familiee, at their regularly constituted  meeting on Monday, June 21,  1971 did
pass the fallowing resolution:

"Resolved, that Vorth Suburban  Synagogue  Beth SI had requested  an independent
study of the M^SD nropesed ^mansion at Clavey  Hoad and  a moratorium sn
constructien."

"Reaolred, that an independent  study was  undertaken by the Water Quality
Office »f the United States  2nrir»nB»ntal Protectian Agency and that a
preliminary report and reeoficsendatiens were  aade public  on April 23, 1971."

"Resolved, that the North Suburban Synagogue 9eth 51 urges and  requests that:

1.     davwy Road Sewage Treatment  Plant be kept to the smallest possible
       si*«, »$-that it could be phased out  at  some  future date.

2,  Another *xLant be built lur.ediately and located  in a  non-residential area.

3.  That the retention basis* be noved to a  non-residential  area and be com-
    pletely cerered,

h»  That the effluent  lagoon be eliainatad.

5*  That the latest *State of the Art* is employed  to elL-ninate any  possible
    health hazards,

and

 6.  That a monitoring study is undertaken te eliminate  any possible airborne
     infections,
                                 very truly yours,

                                Daniel Taxtman,  President
                                By:
C.C. Gary W. Schensel               Mrs.  Bernard  H.  Sekol,  Secretary
C.C. Amos Turner

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                                             1210 Gregory Street
                                             vaimette, Illinois
                                                        60091
                                             May 4, 1971
The Honorable Win. D. Ruckelshaua
Administrator
U.S. Environmental Protection Agency                   /j
1626 K Street N.W.                                    ./
Washington, D.C. 20460                                 f

Dear Mr. Rusckelshaas:                                  J

     \'!e have been told that continuation of the construction
at the Glavey Road Sewage Treatment Plant has been halted for
a thirty day period (for reasonable argument) to decide whether
or not the North Shore Sanitary District's order to proceed
with the expansion plans to make it possible to handle as a
maximum 18 million gallons of water per day, - shall be Imple-
mented  OR  will the expansion plans be such that the plant
can handle only 
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                        C


1626 X Screen
__c.r ..r.  :<.uckeisr.aus :

.-.-.ilosid  you will  fine, 5. o.:I.J-.i:-^I'.jr..._o^y leaner  from

_:rc^C£ic  expansion of ;he ..crcr. £.ic"3  district..

I -;ould 2"sa^iy appraci^j^  •...:-	-^r ir.fon.:at:icn and
i-iiloc—«cs ycur good ori"ic^.i  can ^rcviia  in. connec'cion
..icr. :.:*/ ras^cnse in this i::-:^c3v.
                                           R.  Collier

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QUANT & GRANT
LOUIS Z. GRANT

• UKTON r. GRANT
          Offices
          of
BURTOX F. GRANT
  69 WEST WASHINGTON STREET

  CHICAGO, ILLINOIS 6O6O2


     May  19, 1971
    SUITE 2252
    TELEPHONE

AREA CODE 3IE 64I-36OO
     Mr. William D. Ruckelshaus
     Director
     K.P.A.
     Washington, D.C.   20460
     Gentlemen:

          As  a resident of the southern half of Highland Park,
     I want to commend your preliminary report and urge you
     to protect  its  scientific findings against local greed
     and mis -information.   A truly objective study of the
     Clavey Road Sewage Treatment Plant embracing the grand
     view of  Great Lakes Water Quality Control Problems has
     been long awaited.

          I urge that this plant be phased out quickly.
                                         BURTON F.  GRANT
     BFG:lsf

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              Epstein  ana
EXECUTIVE OFFICE 313 WEST ADAMS ST.. CHICAGO, ILLINOIS.
                    ,  Unc.
                   CABLE ADDRESS -
            jr. U.S.**,
     SHEPS CHICAGO
                    PHONE (31 2) 7B2-7B1 5-1 &
                             ^
   ^ V      S7
 s<^~~-*-*^^L   c^^,
^i^<^2fe_
  ?£/ ^tz^^^-gr et&l
 v ^/r  xx?  ^ x^2>  „

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                ENVIRONMENTAL PROTECTION AGENCY
                         Office of Water Programs
                         WASHINGTON, D.C. 20242
                                                      JUN 11
Mrs. William J. Pietenpol
Environmental Quality Chairman
League of Women Voters
Winnetka, Illinois  60093

wear Mrs. Pietenpol:

Xr. Ruckelshaus has asked us to reply to your letter concerning the
recommendations of our Chicago Regional Office with respect to the
North Shore Sanitary District sewerage project.

This Agency is vitally concerned with the conditions of the Great Lakes,
and we believe that the recommendations of the Regional Office, if
implemented, will result in the provision of adequate facilities to
abate pollution in the area in accordance with established Federal ana
State deadlines.

The purpose of the modifications of the North Shore project, as included
by the Regional Office in the draft environmental impact statement,
was to make the project more responsive to the total environmental
needs by revision to eliminate storm water overflows to Lake Michigan;
by redesigning and covering the storm water retention basin at
Clavey Road; and by proceeding immediately to plan and construct a
new treatment facility in a presently undeveloped area near the
Des Plaines River.  The second plant will provide necessary capacity
to more than compensate for the recommended reduction in the planned
expansion of capacity at the Clavey Road facility.  Because of
anticipated needs beyond even the highest proposed capacity at the
Clavey Road facility, the plant on. rlie Des Plaines site will be
required in any case by 1980.  Our L«commendation merely moves up
the deadline for its development.

As you may be aware, our legionai Office has been accumulating comments
on the draft statement from the Illinois Pollution Control Board and
other interested organizations and individuals.  The Regional staff
is now in the process of evaluating the comments prior to writing che
final environmental impact statement.  Copies of this correspondence
are being referred to the Region for their information and consideration
If you wish to submit additional comments to that Office, please feel
free to do so.

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We are not certain of the meaning of the reference in your letter  to
the absence of matching funds for Illinois under the Clean Water
Restoration Act.  Since 1956, the State of Illinois has received
yearly allotments under the Federal Water Pollution Control Act, as
amended by the Clean Water Restoration Act, and other legislation.
The Illinois allotment for Fiscal Year 1971 was $43.6 million, of
which over $33.25 million has been allocated—as of this writing—to
projects approved and certified for priority by the State.

We are appreciative of your concern about new legislation to  continue
the construction grant program.  President Nixon has proposed the
continuation of the program and recommended the appropriation of
$6 billion for the next three years, to be allotted at the rate of
$2 billion for each of the years 1972 through 1974.  The legislation
which is presently under consideration by the Congress would  double
last year's appropriation.

Your interest in the protection of Lake Michigan and in the funding
of the construction grant program are very much appreciated.  You  are
assured of our continued efforts under requirements of the Federal
Water Pollution Control Act and the National Environmental Policy  Act
of 1969 to assist the States and localities in constructing facilities
which will contribute to the goals which you advocate.

                      Sincerely yours,


                      Ralph C. Falange_

                      Pvalph C. Palange
                      Acting Director
                      Division of Facilities Construction and Operation


 cc;   Regional Office,  Chicago   (2)

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f
                        OT
                                                              May 6, 1971
               of Winnetko. — Northfield — Kenilworth
                    Winnetka, Illinois 60093


Mr. William Ruckelshaus,  Director
U.S.E.P.A.
1626  K Street  N.W.
Washington,  B.C.  20460

Dear  Mr.  Ruckelshaus:

As participants  in  the Lake Michigan Interleague Group
and members  of the  League  of Women Voters of Illinois
we are deeply  concerned about  the recent recommendations
of the U.S.  Environmental  Protection Agency to  the
North Shore  Sanitary District,  placing  limits below
those previously  approved  by the  Illinois Pollution
Control Board  for the  construction and  expansion of the
Clavey Road  sewage  disposal plant in Highland Park.

Once  again  controversy brings  much delay in a situation,
which at  its best sends raw, untreated  sewage into Lake
Michigan.  We  strongly back the recommendations  of the
Illinois  Pollution  Control Board.  We urge you  to inter-
vene  and  give  your  strong  support to those plans set
forth by  the Illinois  Pollution Control Board in behalf
of the millions of  people  who  use Lake  Michigan.

Last  November, the  Anti-Pollution Bond  Act,  for  which
we worked so hard,  was passed,  but Illinois  has  received
no matching  federal grants under  the Clean Water Restora-
tion Act which soon expires.  Our concern deepens as the
July  1, 1971 deadline  approaches  and no new  legislation
to extend the  federal  grant program is  forthcoming.   We
ask your immediate  help in obtaining the legislation to
make  available future  funds  which are so essential to
clean  up Illinois lakes and rivers .

Yours very truly,
                   (Mrs.) William J. Pietenpol
                  Environmental Quality Chairman
                  (Mrs'.) Stephen J. Fraenkel
                  President

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                            MRS. RALPH G. DUNUOP

                             2240 ORRINQTON AVENUE

                            EVANSTON, ILLINOIS SO2OI
                                          June  13,  1D>


Mr.  ;.tilli.:.m  D. Ruckelsbnu*, Administrator
United .ct -tos ttnvironncnt/: I Protection Ar.eney
JKLJfi K ctreet
,-,c.| jnTt')".   f.C.
I". : nr  "• .    ».   ! " '  n  :

1 .  rr  \.iy       c  ,'c.rrseti i:i out the  restoration anu  .rrcs-
erv  t -. ,!••  .f .'   nu . 1 i i y of  L, ';o J.-i chi:T ru   I  ho-'c  (. :irt  c
i«ri 1 ;  fit. everything  noesii:lc  to nvoicf further  deteriorut iun
of  the Ivke.

Tn  this c°«'  uti  : ,  it . o «s to mo  to be  i  r.er.-itive  th;.t  J
the  Clavcv   •.-' U,  In  • J *i t     rk, I ! lii.-oi s,  HC  ;.;x -d4 — ^-is;-*J. T
yilnn. b«- !•    n^.c d to the re-con' .ended 18m.«d  C:  "'scity now.
I  krif- \\\: t    c^r tr- ry  rc':  ir  -ry  .'<. c • .« i i'•   i _'  ", -i evic or-ce   r'. SL  L^»,  in s>:    -ri  ->r  ! •   •••x-
prjn.^i'jn of t^is   L-nt,  i;<-  t ;c  uls.itio;,  riiicii b-  ; .     .!.••
fro!.;  i! i  y ;.r e:;   nFioi-, I  request  tlu.t you ! cc;/  si,, c-r .. ' ..r
dccisiur .

                                          Sincerely
                                           .ary
      \!r.  /r-ncis Mayo                  ( 'rs.

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                              MRS  ELAINE LE GOFF
                             1663 NORTHLAND AVENUE
                         HIGHLAND  PARK. ILLINOIS  6OO35
          O/T-A  <
         t--- T  C
    CLJLO
                                        '-C
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                                   ' ~t- ~- — *O^



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TO:     Mr. G. W. Schenzl,
        Water Resources Planner, EPA WQO

FROM:   Dr. Martin H. Rogoff

DATE:   May 21, 1971

SUBJECT: Comments on draft environmental impact statement:
         Project WPC-ILL-254; WQO, Reg. V,FEPA

My reading of the assessment prompts the following comments:

First,general:

1.  The report is thorough, well written and most objective.

2.  The report conclusions (pp 37-38) take cognizance of three
    factors that NSSD is either unwilling to consider or chooses
    to disregard.  These are a) whether diversion of clean water.
    assuming future adequate sewage treatment, from the lake is
    the correct long range plan; b) that an epidemiological
    hazard indeed may exist in association with sewage treatment
    facilities, and c) that malfunctions in sewage treatment
    facilities are possible and probable.  Recognition of these
    factors by EPA is most commendable and several specific
    comments listed below are pertinent to these points,

3 .  The report recognizes the existence of human inhabitants in
    the environs of the plant (p 23).  It further recognizes
    that their needs must also be considered.

Specific comments.

1.  Recognition by EPA that the existence of malfunctions in
    sewage treatment processes may occur (p 8) is noted.  This
    is precisely the instance in which epidemiological hazards
    are most likely to exist (also p 12).

2.  The clean water V?iota whir.h will arise as a result of dis-
    charge of high quality water into the Skokie River shouM
    be noted.  It is stated to be more sensitive to changes in
    water quality of the stream.  This is quite important in that
    such a biota can be used as an indicator of effectivenes:; of
    the plant treatment process.  In short, the manner of operation
    of the plant by NSSD can probably be effectively monito- ^3. b"
    suitable microbiological analytical procedures designed to
    characterize the new biota and observe changes in it.

3.  The entire position of NSSD on epidemiological considerations
    rests on testimony of Dr. Deinhardt  (p 25).  This testimony is
    not included in the appendix.  It should be I  The natur^ of
    his testimony is such that it cannot support his conclu,_,; on
    that no danger exists, or will exist.  Several points lie made
    can be negated by the Berg paper  (included) and by more
    recent literature  (M. Rogoff, included)  now in the statement.

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Mr. G.  W.  Schenzl             -2-         May 21,  1971

4.  Chlorine  handling  hazards precautions  have  not  considered
    the public.  NSSD  personnel protective measures are  ex-
    haustively covered.   Since NSSD employees on  NSSD  property
    can be further  from  the  chlorine  than  are certain  areas
    outside the  plant, consideration  and facilities for  the
    safety of individuals in these areas should be  recommended.

5.  The commentary  of  G.  M.  Marks is  most  comprehensive.   His
    position  re  conflicting  testimony on the health aspects
    should be quoted.

6.  Van Mersbergen's comments (p 91)  are pertinent. He  has  picked
    up  an  engineering  soft point whose impact has not  been
    thoroughly explored  in the assessment  re S02  and H2S.

7.  It  is  most interesting that the Bureau of Water Hygiene  has
    no  comment as  to health  effects to other than bathers  and
    water  drinkers  (p  92).  Do they assume Clavey Road dwellers
    are not exposed to the same pathogens?

8.  NSSD's "practical  measure of effect on environmental"  viz.,
    real estate  values assumes realtors and homebuyers are public
    health experts  (NSSD revised 12/14/70, p 18) .  I would
    hesitate, as should  EPA, to certify validity  of lack of
    health aspects  of  plant  expansion on the basis  of  real estate
    values .

9.  NSSD has  maintained  lack of disease symptoms  in sewage plant
    workers is adequate  evidence of lack of hazard. Berg's
    paper  (p  148)  effectively explains why disease  incidence in
    certain individuals  may  not be pertinent.   This refutation
    should have  been quoted  and its significance  explored.

10.   I would like to add  the  following two  references,  if I may,
    to my  statement .

    DUBOVI, Edward J.   1970.  Biological Activity of the Nucleic
    Acids  Extracted from Two Aerosolized Bacterial  Viruses.
    Applied Microbiology 21,4, 761-762.

    BENBOUGH, J. E.  1971.  Some Factors Affecting  the
    Survival  of  Airborne Viruses.  J. gen. Virol. 10,209-220.
 MHR/jb

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                    ..    •.„,
                    '"'•''• "'"
                                               f. WARD JUST, PUDLISWtn

                        't                         	
  1OO WEST  MADISON STREET/ WAUKEGAN.  ILLINOIS GOO63/AC312 OOS.7OOI
'lylr. Donald Rumsfeld
Executive Office of the President of the United States
Washington, D.  C, 20506

Dear Mr. Rumsfeld:

            Attached you will find the Illinois Pollution Control Board orders
issued March 31, 1971, to the North Shore Sanitary District which has
information vital to the future of the district and the 200,000 people it serves.

            We earnestly solicit your immediate attention to the recommendation
and urge that you convey this information to the Environmental Protection Agency
so they may have the-ljenefit of this information prior to their decision on the
forthcoming Environmental Assessment of the North Shore  Sanitary District.

            As a Citizen of the district, I can'-t stress too strongly the
urgency and importance of accomplishing this.

            With kindest personal regards,
               I
                                           Sincerely,
                                             C-<
                                           Richard F. Kennedy
                                           Executive Vice President
RFKild
enc:

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WILLIAM G. WITH                        Vfj^rn                            nusreis
 fretidsnl                            \iVoL2tf I i '*.—^^
*03«T J. NELSON, JR.                   ~^^^^^^=~                   HOWARD GAULT
 C'vt                                  ~"~ "                        GEORGE W. GOLC*£CK
4v- ~v.vuAi.if                   '       INCORPORATED
*.., -V.ST MALIK                                               ,           EIWOOO N. GKAUNKE
 r-."C*ri                               lose
                                                                  £. JAMES HARTWIG
 Tncsurgr                        •    ,      May 21,  1971              GEORGE KUCHARCHUK
WTIE BSEOFIELD (M!3.)                           .                            MICHAEL WARTIMES


       Federal  Environmental
         Protection Agency
       1819 West  Pershing Road
       Chicago, Illinois

       Gentlemen:

                  I am writing this letter on  behalf of the President
       and Village Board of the Village of Lyons.

                  The Village of Lyons is greatly disturbed by the
       actions  of the Federal Environmental Protection Agency's
       recommendation for the construction of a sewage treatment
       plant  at the Cook-Lake County line discharging sewage effluent
       into the Des Plaines River.

                  The Des Plaines River has changed in recent years
       from being a source of recreation and  pleasure to the resi-
       dents  of the Village of Lyons, to a source of pollution,
       disagreeable odors and discomfort to the same residents.
       The residents of the Village of Lyons  were very hopeful  that
       the quality of the Des Plaines River would be upgraded and
       the pollution would be ended.  However,  we feel that your
       proposal for this sewage treatment plant will merely aggravate
       the pollution.

                  We, therefore, wish to go on record that the Village
       of Lyons is in complete opposition to  the further discharge
       of any sewage treatment plant effluent into the Des Plaines
       River  under the present water quality  standards and the
       existing physical conditions regarding the Des Plaines River.
       The Village of Lyons further states its complete opposition
       to the construction of any sewage treatment plant facilities
       for treatment and discharge of sewage  into the Des Plaines
       River, unless the same be equipped and capable of providing
       third  stage, supplementary and tertiary treatment of sewage,

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Federal Environmental
Protection Agency            -2-             May 21, 1971
capable of removing 95% or more of the organic or oxygen-
demanding pollutants from effluent being discharged into
the Des Plaines River.

                              Very truly yours,
                              Karl Klomann
                              Village Attorney
KK:ER
CC;  Mr. William G. Smith
     Mr. Carl Duffek

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                                                         BOX 583 v** 1 L M E
    the Committee on  Lake  Michigan  Pollution  -e
I!r,  ,/illian D. huckelshitua,  ....
U.o. ^nvironrental  Fro-!-,tctior..
'.'ashin, .ton, D.C.
Dear  -"T-.  7iU.ckelsh.ius:
       The Committee on Lahe "i    ^
oT  residents "hi  suburbs lurbh nf C' :"cc
 e  heve been c.:i  c.ct.'ve ,,roup ^c .' ';ht ;.
      Anon_ nany  other ^nv ' ron: .t ntal • ';- t  erj   ft '"rt '.,-. j  e /_;.
and  h&ve • orked  d::li^ently on '  ve bet .  -  ^crc 1'b^v.e  ." -;• tl.e '"ort'.i
Shore San:' tarj District,  -- nc>  K  st.-te cone"  I^sue • -\: c"-  - ^v.l:" «^-
tl^  construct'lvn of te'Vc^e tre^.t" tnt x lo. '•"'". i,  '>i ~ll:v^  " i, .   t •  ,.v=
observers at till the ^ece _t " et.r.'.n s c^nc^r-'.' n • " L "• . • [•"  ^'  -  c
       ,ry District.   CUP   ? -'>-i' c-nc«r;i :' t  '-olluL'.". •  -'   I,/ c, " ' c'- : c
      ',e  rere and.  sti'll ;?re ve:--~ ^ lessee •""t;-  i'be c; i-t."-..." :„  '   '
out  and  '.veil presented op.'n^c'n i' id order  of  the ril.~ ;•'_-"..  !'•-.' 1,i /•
Control  Board, on  t] Is very con.t.'oversj.u.!  ityue.    e ,  re  VL.\,  .'.;
and  disappointed  • i th tr e ro^F^i. -/nvii-o ii en till i ].<='- 1  ^t-te- o-nt
our  opinion it  il?.  delay conjtructi-'n, ceO •    ^t"1'"'"'   ;•."-'.  •]
ser/a^e out of the  Icd.e fror. f:^-e treat tpt  ^ 1- "t.   :]:.-._  t .t h
also  --j 11 ?dd ground "3C ":ill:' -n v-1 co;-. bs^  •' ;-. fc ct, s,:c"   _•• "
del a  t-.dd.-j !/••) to  costa.
       200 very unreal'' otic •-:' i '.z<~r s   \ c "fid  ':  c •••'. tr1;*.- 1:\ n
tv'o years,  and thus  have ^ er  :''J^ed  " no: <-_; . cd  i  /^^ ,, 1- -•,-.-•-_ c" t
                                     "         -   -   -'      —"
Beaches  have be ,n  cl-i; ed ..ii"". "  e^li."    f ce
closed.   ^h  evidence  ._ s "ce n  jre. ^erted .
deleterious  effects  to tlie^e rt.-j.hd.cnts    -
Clivey  "lOi.d  trtr.t .tnt ^1. ' t.   hei-e*ie'     •
to it be in,  \ro^oly overloaded. . t  rt yr- t.
IS rri/'d  there ""ill  not be th.'s  r--^'lt. .
                                                  r.x -c  '.  ci-e
                                                  ^' t v  1 c r^e
                                                 / IL t;  ^ t Cl
                                                  ''  ]_ropei- c.
     3i'i:'l--r treat' cnt plants "_• ve   irh    --
is a  Batter of vital  concern, to c-ill co . u
tol
                          condlt."
                                     of L^.] e "ichi^tn
utnoct  urgency to keep nvJ:r:'ento  --id othu. pollute
t':at  ere  present!^
                                                          or.t
                                                                           c t
'r.'.e jj_sor;. ct   ; ^  uefcn tr; -_•:,_,   ~r -evc:^l -ue:

s__eed  ahead.  " 'e urce :d e 'd-_ih.i to /..'no.:- t.'  c
of our capable Eosi-6..  "dht; " ,.--
                                                    to
                                                            •itfo cent,

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    ttJRS. CDARSHALL FINK€LmAN
332 LARKSPUR, HICHLANb pAKK, ILLINOIS 60035
  LoaJ&A  ,0-0
              CJL
        O
2o+ cCtuJL*
y  /Lo*4sfe,
   W*_^

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                                          709

C H/V -<:

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                         GENERAL ASSEMBLY
                             State of Illinois
                             Bradley M. Glass
                       State Representative — 1st  District
  723 Happ Road                                              COMMITTEES.
Northfisld, Illinois 60093                                           Education
  (312)446-2506                JlOie 12,  1971                 Elementary and Secondary
                                                        Judiciary I

       Mr. William D.  Ruckelshaus
       United  States  Environmental
         Protection Agency
       1626  "K"  Street,  K.W.
       Washington,  D.C.   20^4-60

       Dear  Mr.  Ruckelshaus:

             I  an greatly alarmed by the recommendation of
       the United States Environmental Protection Agency to
       reduce  the capacity of the  sewage treatment plant be-
       ing expanded at Clavey Road in Highland  Park,  Illinois.
       It is my  understanding that the Illinois Environmental
       Protection Agency recommended an expansion of  this
       plant to  18  mgd,  but that your agency reduced  this to
       12 mgd  and also reduced the planned storm water re-
       tention basin  from  20 million gallons to 10 million
       gallons.

             This action is in defiance of the recommendations
       of the  Illinois Environmental Protection Agency -which
       gave  the  matter a thorough and fair hearing.   Furthermore,
       this  plant,  when expanded, would replace $ other in-
       adequate  primary treatment plants.  With a change to
       18 mgd  it will  have allowed for growth in the  community
       and for wet  weather flow.  A plant with  a capacity of
       12 mgd, however,  will allow for neither.   The  threat to
       Lake Michigan  is  obvious - a discharge of inadequately
       treated sewage.

             This is an intolerable result.  It  is my  sincere
       hope, therefore,  that you will review your recommenda-
       tion  and  revise it  in accordance, with that of  the
       Illinois  Environmental ProtectionvAgency.
                                        Very truly yours,
       BUG:bp

       oc: Mrs.  Eileen L.  Johnston
           Mrs.  Leonard Liebschutz

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                 moan
  1175 SHERIDAN  ROAD,  HIGHLAND  PARK,  ILLINOIS 60035
                   PHONE 432-8900
                                              June  23,  1971
Mr. William D.  Ruckelshaus, Director
Envirenraental Protection Agency
1626 K Street,  N.W.
Washington, B.C.  201*60

Dear Mr. Ruckelshaus:
                         Samuel H  Dresnei
                         Rabbi

                         Philip L. Lipis
                         Rabbi Emeritus

                         Dr. Louis Katzoff
                         Director of
                         Religious Eaucatio>

                         Cyril G. Oldham
                         Executive Director

                         Gerard W  Kaye
                         Youth Director
     Please be  advised that the Board of Directors of North Suburban Synagogue
Beth El,  1175 Sheridan Read, Highland park, Illinois comprising over 800
families,  at  their regularly constituted meeting on iMonday, June 21,  1971 did
pass the  following resolution:

"Resolved, that North  Suburban Synagogue Beth El had requested  an  independent
study of  the  NSSD  proposed expansion at Clavey Road and a moratorium* on
construction."

"Resolved, that an independent study was undertaken by the Water Quality
Office of the United States Environmental Protection Agency and that a
preliminary report and recommendations were made public on April 23,  1971."

"Resolved, that the North  Suburban Synagogue Beth El urges and  requests  that;

1.     Clavey Road Sewage  Treatment Plant be kept to the smallest  passible
       size,  99.that it could  be  phased out at some future date.

2.  Another plant  be built immediately and located in a non-residential  area.

3.  That  the  retention basics  be  moved to a non-residential area and be  com-
    pletely covered.

lit  That  the  effluent  lagoon be eliainated.

5.  That  the  latest "State of  the Art" is employed to eliminate  any possible
    health hazards.

and

 6.  That a monitoring study is undertaken to  eliminate  any passible airborne
     infections.
                                Very truly yours,

                                Daniel Tauman, President ^

                                By:
C.C. Gary W. Schenzel
C.C. Am«s Turner
                              * 1
Mrs.
         C  |I I'
      « ^sss|Jf fl
HTSbkol. Secretary
                    sAi
1 (
1
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                                              11(»'a ru
                                                             . i
                                 I

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                          MRS RALPH G DUNLOP

                           2246 ORRiNGTON' AVENUE

                          EVANS7ON. ILLINOIS SO2O1
                                      June 13, 197i
Mr. vYilliam D. Ruckelshnus,  Adir.inistrntor
United States Environmental  Protection A ency
1626 K Street
Washington, D.C.
Dear .Vr. ^uc!:elsh. us:

I ?m very -nucb concerned  about the restoration and pres-
ervation of the  quality  of  Lrke .Vichiji-an.   I ho^e that -/e
will do everything  nossible to ^void further deteri orat i. on
of the 3>ke.

In this connecti' r.,  it seems to me to be i™nerr'tive that
the Clavey P.ord,  Hichl^nd H;rk, Illinois,  se-ar:e dip^osp-l
plant be ex  ncied to the  recommended ISmg'd c.-iacity now.

I know that a contrary nrelirrinsry decision has been m.ace.
In light of the  evidence  oreser-ted in sunnort of the ex-
pansion of this  plant, and  the "Dilution which is resulting
from delay in expansion,  I  request that you reconsider your
decision.

                                      Sincerely,
Copy Mr. Francis Mayo
Mary Helen bun lop
(Mrs. Ral-ib G.)

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LE-V1S D CLARKE

DANIEL J DAIZIEL

MLLIAM A.HOLMQiJiST

JULIAN JOHNSON

•\L?RED W LEWT5

GERALD C JNYDER JR

JOHN F KENNEDY
JA-^E5 ,vt JONES

LEWIS D.CLARKE, JR.

WALTER D JACOBS

JULIUS J ZSCHAU
                     LAW OFFICES OF-

5NYDER, CLARKE, DALZIEL, HOLMQUfST ft IOHNSON
                 3O1 WASHINGTON j~R.EE7
                WAUKEGAN, ILLINOIS SCOS5
                May 18, 1971
GERALD C SNYDER

  OF COUNSEL
                                                         TELEPHONE

                                                          623-OI2O

                                                        AREA CODE 312
                                                                  "HE RESPONSIBILITY OF
Water Quality  Office., Region V
Federal  Environmental Protection Agency
33 East  Congress Parkway
Chicago,  Illinois   60605
                                                           Alfred  VV. Lewis
                                    A cm:   Mr.  Gary Schenzel
   Re:  Draft Environmental Impact Statement dated  April  21,  1971
        For Sewage Project No.  WPC- 111.  7.54  Submitted  by North
        Shore Sanitary District,  Waukegan,  Illinois

Gentlemen:

I have been instructed by the President and Board of Trustees  of the
Village of Riverwoods,  Lake County,  Illinois,  as its attorney,  to comment
on  the above  described  Draft Environmental  Impact  Statement.

The Village of Riverwoods  is an entirely  residential community  bounded on
the west  by the Des Plaines River and the Lake Count}'  Forest Preserve.
It is  bounded  on the south by the Lake Cook  Road.   The Village  residents
will,  therefore,  be directly  affected  by the location of sewage  treatment
facilities  on the  Des Plaines River at the Lake Cook Road as is  mentioned
and proposed  in  your Draft  Environmental Impact Statement.

The Village received  no notice  or  advice  concerning your Draft  Environmental
Impact Statement of May  17,  1971, and it was only by happenstance that at
the regular meeting of  the  Board last  evening, a resident  of the  Village  who
had procured  a copy of the statement from your offices  presented the  same
to the Village Board.   It was immediately  noted from Page  ii of  the Summary
that only  30 days are available for comment  from  interested persons  following
release of the Statement.   If it was intended  by the Water Quality Office,
E.P. A. that the  30 days available  were those  days  immediately  following
April  21,  1971,  it  is obvious that  there  has been insufficient notice and time
to intelligently comment on the Statement.  However, giving consideration to
the nature and chai-acter  of the  environment and development of  the area of
Riverwoods,  including the  Des Plaines River  ana ihe adjacent Lake County

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            5NYDER, CLARKE. DALZIEL, HOLMOJJIST 8 JOHNSON
                                   -  2 -

Forest Preserve,  and upon cursory  review of the  Statement,  certain commen;
are immediately appropriate.

   1.   The  Des- Plaines  River is essentially a recreational  facility through
       all of Lake County and the northern part of Cook  County.

   2.   For  many  years,  the  area surrounding the river in  northern  Cook
       County has  been  preserved as  a forest preserve district.   For at
       least the past five years, the Forest Preserve District of Lake County
       has  expended  large sums  of money in acquiring property abutting
       the  Des  Plaines River to  preserve  its natural  beauty and use  as a
       forest preserve for the  general public.

   3.   The  entire Village of  Riverwoods,  as  the  name  of the village implies,
       is composed of heavily forested land with winding  private  paths pro-
       viding access to  the substantial homes  which are all located on one-
       to five-acre  lots.

   4.   The  location of a sewage  treatment plant on the river within  the
       boundaries of Riverwoods would reverse  entirely the concept  of
       environmental development which has been  planned and executed
       over the past many years.

   5.   The  Clavey Road  facility  was  proposed, planned and approved by  the
       several governmental  agencies only after years  of study and debate.
       If the study, plan and approval were valid  in  the first place,  it is
       particularly difficult to understand  or  accept as valid comment  this
       latest statement  suggesting major  alternative proposals for locations
       of the  treatment  facilities.

   6.   The  Skokie  River Basin,  a proposed alternate,  has been used for mai
       years as an  adjunct to the collection and discharge of the sewage
       systems  serving  the general  area.   Your report indicates that  it
       might be expanded as  an  alternate  method to relieving the North
       Shore Sanitary District from   the complaints of residents living
       near the Clavey  plant.

   7.   It is quite  unthinkable that the heretofore recreational Des  Plaines
       River area  is now proposed to be used as  a means  to serve  the
       sanitary  sewage  requirements of the North Shore area.  As noted
       above, such  proposal  reverses  the use and planned conservation of
       a natural,  recreational environment.

On  behalf of the Village  of Riverwoods ana its residents,  we ask and  trust
that your draft  proposal  to locate a  sewage treatment plant at the Lake  Cook

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           5NYDER. CLARKE. DALZIEL, HOLMQUIST 8 JOHNSON

                                   -  3 -

Road  and the Des Plaines River  will be submitted to  full public  disclosure
and discussion  before  any final decisions  are  made.   We fur the r ask that  you
kindly acknowledge this letter and  furnish us  with your  comments concerning
the procedures and proposals for further  action on the project.

                                  Respectfully submitted,
                                  Alfred W.  Lewis, Attorney for the Village
                                  of Riverwoods,  Lake County,  Illinois
AWL:b
cc's to:  President and Board of Trustees of the Village of Riverwoods
cc:  Chairman of  the Lake County Forest Preserve  District
cc:  Deerfield  Review
cc:  Illinois Environmental Protection Agency
cc:  Administrator of the  United States  Environmental Protection  Agency
cc:  Attorney  for  the North  Shore  Sanitary District
cc:  Honorable Robert McClory
cc:  Honorable Charles H.  Percy
cc:  Honorable Adlai E. Stevenson III

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                  APPENDIX B
PUBLISHED ARTICLES, STATEMENTS, AND TESTIMONY

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        Reprinted from AMERIC VN I.VDL.STRI \I. IIYC.ir.Ni: ASSOCIATION IOUR\\L
                             Volume '11, .\nv.i i.ilii-i-Ocn nil'iT, 19G6
 Bacterial  Air  Pollution  from Activated  Sludge  Units
                   CLIFFORD \\: RANDAL!,* and JOE C. LEDBIiTTERt
      Arlington Stale  College,  Arlington, Texas, and The  University of Texas,  Au-
mission  taught  that  the aiv  v.a-5  the chief
            O
vehicle of  infection.   This  belief  existed as
far back  as 1600 D.c.1 and  was promoted bs
Hippocrates, the "father of medicine,"  with
his \\riting that  men  \\ere attached by fe\ejs
when  they inhaled air containing !;o>tile pol-
lutants.5  Foul odors  associated  \\itli sf.^ers,
waste\i.ater, and rotting orsrnnir mateiial  v\ere
           '          O   O
generally  considered  to be  evidence  of  such
"hostile pollutants." and e%en the early move-
ments  for  sanitai\ impaneinept during the
 18th and  19ih centuries uere based on mias-
mic theory.1
   Following the ad\ent  of  the  genii thcor\
of disea.->e in  nrdninetter.th century, distinc-
 tion was chaun  l:etueen foul-smelling air and
 infective air.3  Many attempts uere made to
Pitt»buridei able di5tanc^-..
but  he  concluded that infection  from srwer
gas  was remote.
   B> 1910 nearly all  the dtcaded  epidemic
diseases, particularly those  infecting  the in-
testines, had been traced  to  vehicles other
than air, as  theit primars modes  of infection
and airborne infection had practical!)  bee '
discounted.  Moreover, as control of  upho,..
 fe%ei became established tluousrh  \\ater tn .t-
                              O
rpent. feces disposal, and food sanititiun, ',>\-
terest  in  aiiborne  sewage  organisms  prac-
tically clisappeattd.
   Follo%vintr  a  re\i\a! of  interest in  airborne

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American Industrial
infection around 1930, Fair and  Wells con-
ducted  the first study  of  bacteria  emitted
to the atmosphere by  sewage disposal pro-
cesses.'  From  their  brief look at  the bac-
terial density of the atmosphere surrounding
sewage treatment works, they concluded that
bacteii?! Contamination of the air Lv sew-
age  vvorks exist*  und th'U Iibi.Tu.ttd
isms of rct:/nce  of travel  of  viable bac-
teria cGireJnted directly  with  the wind ve!o-
city.
  Prior to  Albrecht's  investigation.  Jer'-^n
had looked  into  the  presence  ai.d  survival
of the tubercle bacillus  in the liquid phases
of scwaye treatment processes.5  From these
results I",1 surmised  that there is a real dan-
ger  of  ttibt'iculoiij  infection.  especially  to
opeiating  and supervisory personnel, fiom
droplets injecced  into  the  air  by activated
sludge  units. h\  trickling  filteis,  by  spray
irrigation  with sewngc effluent, and by wind
action  on \\asteuater surfaces.  Several peo-
ple  have  shown   that many  human  patho-
gens are contained  in various stages of the
sewage  treatment  process.9-10  Because path-
ogens are  present in the liquids being tieated,
some cursory attempts have  been made  to
determine whether the incidence of infection
among  sewage plant woikers  is  increased,
but  they have resulted in inconclusi.e find-
ings that  were attributed to incomplete em-
ployee medical iecords.n
  The  mechanism of aerosol production  by
bursting air  bubbles on  the  surface of salt
water was studied by Woodcock.15 He saw
the  small particles  evaporate before  falling
back to the  water surface and  became con-
vinced  that aeration of  sewage would  result
in large numbers  of airborne bacteria. Hig-
gins conducted laboratory research into bac-
terial aerosol production resulting fiom aera-
tion of polluted  water.13 He used suspen-
sions of several species of microorganisms to
:V«i- Association  Journal
                                                             '    Y
                     find  the effect of  acrosol'i/ation and chcm-  '
                     ical additives along with other variables on
                     the generation  of  viable  aerosols.  Higgins
                     reported very low recoveries of coliform or-
                     ganisms compared  with  Scrratia rnaict'scens,
                     Bacillus subtilis, and two Streptococcus spe-
                     cies, with  no \iab!e Eidierichia  coli  or  E.
                     jrcundii found.
                     Tfie Enferic Bacilli

                       To accomplish a significant study of the
                     wide variety of bacteria that may be emitted
                     from  an activated sludge unit, biochemical
                     classification studies during this investigation
                     were restricted to the enteric bacilli.  Generic
                     identifications were further restricted to mem-
                     bers of the familv Enterobacteiiaceae.
                       In  this study  the enteric  bacilli  aie con-
                     sidered to be gram-negative, non-spore-fctm-
                     ing tods whose common habitat L the intes-
                     tinal tract of man. They are defined here to
                     include all members of  the family  Entcro-
                     bacteriaceae  plus  Pn-vdomonas  aeruginoia,
                     Alkali<;cnrs faccalis,  and  all  other  P^euc/o-
                     monas, Alkaligenes, and  related species chat
                     are capable of growth on EMB agnt.

                     Entcrcbactcriaccac

                       The Enterobacteiiaceae are  made  up of a
                     series of interrelated  tjpes that do  not lend
                     themselves to sharp  division  into  tribes  or
                     genera; however, the family is so large and
                     unwieldy  that it  is necessaiv a< a matter of
                     expediency to dKide the fainil) into gioups
                     that form the basis of practical  work.  The
                     following grouping, primariK as piopo.-ed by
                     Ewing and Edwards,1' will be used in report-
                     ing the results of  this study. All isolated mem-
                     bers of the family will be classified  and re-
                     ported according to groups, wheieas the only
                     species and subgroups reported will be those
                     listed in Table I.
                       This grouping  is based on both biochemi-
                     cal  and antigenic  relationships,  and  it docs
                     not recognize the  distinction  of  the "para-
                     colon group'' based on slow lactose fermenta-
                     tion.  The Klebsiclla  o.^tocum of Lautiop1*
                     Is included in  the Klebsiclla group as recom-
                     mended by Ewing and Edwards; however, in
                     this study it is differentiated from A',  pneu-
                     moniae simply by the abilit)  to produce in-

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                         TABLE I
             Classification of Er.terobactenacenc
          Principal
                                     Group s
                                                                      Xoi-crnber-Deccmber, 1966
                                                               ' TABLE II
                                                      Di(fc.e-.:ut.-i of A, . l)^.^,'.f.1 .i.-d Aetotj -Icr*
                                                             Lys:no  Aryir.ine Ornnhine  Motili
         *i .'/none'.'..? — Arizon
             Cttiobac'fft
                              An so-1.i
                              Citrcbac'er
c
              - P:o\id*rce
                              Hro% ideice

                              Let in t.T
dole.  Identifications of the members of the
family were made by the methods of EcKsards
and Ewinrj1* and of KaufTmruin 1T
          o
  Satisfactory  differentiation between  Klcb-
siella  and  Acrobactt'r can  be made  thiough
die use  of niotility  and amino  acid decar-
boxylasc reactions as recommended bs Kanf-
mann.18  The reactions ate shown  in Table II.

Other Enterics
  Besides  the Enterobacte- iaccae, the gram-
ncgativc rods most cornmonk  found in the
intestinal nact are of the AlLali^eri'.s species,
particularly A.  jccaiu.  Othei common in-
habitants  are  the psfiidomonads, piimarik
Pseudornonas  afruginosa,  and the Flarobac-
terium species   The AlkaHyiiics and  Picudo-
tnonas groups are  of  particular  interest  in
this study because the \\otk of McKinnes arid
\Veichlein13 indicates  that  they aic  the pre-
dominant bacteria in the activated sludge at
the Austin biosorption plant, uhcrc  most of
the data repotted here ueie obtained

Sampling and Counting Melhods

  The sampling of viable airborne  bacteria
was done  by tluee different  methods:  (1)
direct plates,  (21  liquid  impingement, and
(3)  the  Andersen  sampler.  The  method se-
lected depended on the requiieruer.^ of the
paiticular  experiment.
       Direct Plate Mah)'!
         Dining  the  car!;, phases of the
                                         air-
         3S.fi\t reaction, - negative reaction.


borne bacteiia were  sampled  by merely  ex-
posing the surfaces of poured agar plates to
the wind  for  thiee minutes  at a  height of 4
feet.  The sampling  was  done  in  duplicate
with the 3/2-inch petri plates facing the wind
but tilted  backward about 30 degrees for  im-
paction of the aerosol on  the  agar surface.
This method  was not attempted during  pe-
riods of c?lrn.

Inijiinvrr  Method
  The impinger  used  was especially designed
for sampling  bacteria!   aerosols  (Millipore
all-glass impinger) with 30  ml  of  a  sterile
collecting   fluid  (may  be  nutrient)  to  im-
pinge the  aeiosols. Aiu r sampling, the liquid
was filtered through a membrane filter which
was then placed  on a  nutrient agar ba^e in a
petri dish  and incubated for  12 to 18 hours at
35°C.  The colonies were counted under obli-
que  lighting  and magnification.  The  short
incubation periods were used  to  prevent  the
colonies from merging.
  The \iolence of the  aeitation  during  im-
pingement should ha\e  broken   any  clumps
and promoted counts  of individual bacteria.
The samples were filtered within 45 minutes
to reduce the possibility of multiplication by
the bacteiia  in the impinger.

Andersen  Sampler Method
  The Andersen  sampler was employed  to
collect  bacterial   aerosols by  impaction  on
nutrient agar surfaces and to separate them
simultaneous!) into six size ranges on six  dif-
ferent  agar plates.30  The first two stages of
the sampler remo\ed particles greater than 5
microns, the  remaining  four stages remo\ed
the respirable particles (less  than  5 microns),
those  that may  be breathed into the lower
respirator) trart.
  The  plates  obtained   with  the  Anderson
sampler were counted in the usual manner
when  the  numbers were sr.ia'l,  and  in  all

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American Industrial Hygiene Association Journal
cases for the first tvo stages; however,  when
large numbers of colonies were collected,  the
probable numbers of bactetia were obtained
from tables that were statistical considerations
of the  number of positive holes  (among  the
400 perforations) for stages 3 to 6 as outlined
by the  designer.30

Background
  In each experiment  on prototype  plants
the intent was to measure  the increase in  the
bacterial population density of  the  air as a
result of its passage o\er the aeration  units.
To accomplish  this objective a  background
count was made upwind of the aeration unit
in each sampling,  the background was sub-
tracted  from the downwind  counts, and  the
data were  recorded as  net counts.  Routine
technique contiols  were run throughout  the
study in order to maintain high standards for
accuracy.
  The wind, temperature, and relative humi-
dity were :ecorded for each test. Wind velo-
cities were obtained from  the U. S.  Weather
Bureau at the municipal airpott 3J/:  miles
NNW  from the sampling aica and weie used
on  the assumption  that  the >atnc regime pre-
vailed  at die two places.

Sampling Location
  The  data  presented  here came primarily
from the Govallc bioboiption se\vagc disposal
plant in Austin, Texas.  Most of the samples
were taken  in  the  vicinity of and downwind
from the activated  sludge tanks, but a cursoiy
examination was  also made of  the bacteria
emitted by the gat and grease nmo\al unit,
which uses diffused aeration. In addition, a
few samples weie  collected at the activated
sludge plant in Round Rock, Texas, to sec if
emissions from that plant, which  does not use
chlorine for  controlling  scpticity in  the sew-
age lines, are about the  same  as for Austin,
which does practice such chloiination.
   The samples that were  intended primaiih
for determining the density of bacterial emis-
sions weie generally taken at 2^-,  50-,  and
 100-foot distances  downwind of  the aeration
unit, while  those  samples for  study  of  the
 types of b.ictctia  and  their relati\e abund-
ance ueie usually m.'.dc immediately adjacent
to and downwind from the aeration tanks at
height* of 2 to •i feet above the liquid surface.

Indentification Techniques
   The identifications were made in a cursory
or gross  manner  by selective sampling, while
differential  biochemical  tests  and antiscrums
were used for laboratory classifications.

Selective Sampling
   Nutrient  agar  (BBL)  and eosin-tnethylenc
blue  (EMB)  agar  (Difco)  plates  were ex-
posed simultaneously  for  all  samples.  The
nutrient agar plates were  incubated  for  24
hours at 35°C before counting, whereas the
EMB plates were incubated for 43 hours be-
cause of the effects of the  inhibitory  agents.
Total counts were obtained from both media,
and coliform  organisms were  determined  by
typical reactions  on the EMB agar. The ac-
curacy of the coliform reaction on EMB agar
for the bacteria being sampled was evaluated
biochemically  by  the  procedures  given  in
Table III.  Of 28  typical  coliform  colonies
picked,  all  were  members of the family En-
terobacteriaccae.  The only  noncoliforms
found were two Serratia.  Of the  other  26
colonies, seven were E. coll, four were Citio-
bacter, six were intermediate Eschcrichia, five
were Klcbsiclla,  and  four  were Acrobactcr.
EMB agar  was used throughout the studs as
the  collection medium for  the survey  of the
enteric organisms.
   Special techniques were used in attempting
to  demonstrate  the  presence  of Salrnnnclla
and Sliigella organisms in the air.  All three
aerosol sampling methods were ttied  for this
purpose, and  samples were  taken at all three
sites.
   Agar plates containing MacConkey  (Mac),
Salmonella-Shigella  (S-S).  brilliant  green
 (BG), and bismuth suIfite'(BS)  agars "(Dif-
co)  were exposed in the Andersen sampler
and  by the diiect method.   Samples were
taken with  the all-glass impingeis using brain-
heart infusion  bioth (Difco). The impinger
•samples  were then  filtered through a mem-
brane filter, and  the.  filtci  was either  (1^
placed  on  nutrient pads containing  selenite
enrichment broth (Difco) and then plated on
S-S,  ES, 01 KG  agar or (2)  plat-.-d  direct',)
on S-S,  BS, or KG a?a;s. Additional samples

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                                                                            November-December, 1966
c
                             TABLE  in
     Selection and Identification Procedure for Enterobaeteriaceae

Collection from A f.io sphere
      Directly exposed a car plates
      Liquid irrpinf ervient
      Andersen  sampler

        \
Growth and Isolation on EMB or Mac Convey Agar


Trlple-Sug^T'Iron Agar Slants
        . _.._._. Discard all negative (=) reactions

Screening Tests  for  Enteroba^teriaceae           Reaction
      O^cidative-fermentatu G (O-F)                 F
      Cytochronie oxtdase                     Negative
      Nitrate reduction,                        Positive
      Cats la se                               Positive

        I _.„«..«., Discard ail other reaction combinations

Standard Differ*ntiation Tests for Entcrobac tt ilaceae
      Urease 	 if poaitne in 4 hours,_JJ...,,,,.,,,,_ pheny lalanaa e
        | ».,.,--_ Discard f'rixcuji

      Deitrose
      Lactose — hold for delayed reaction
      Sucrose —hold for dela> ed reaction
      Indol
      Methyl red — ar.alyz« alter 48 hours
      Simmons citrate
      Lysine   1
      Arginine  >   la^er with \aspar; hold 4 days for delayed reactions
      Omithine  }
      MotiHty — semisohd ag^r; 2 days at 37°C, 3 dnys at 2"2°C

Indole -         Scrtafu          Sa/mone//a         Shttetlj
Lactose ~       ^eroAac/er       Arizona           Alkatoscens — Pispar
Motilitv  *        K/eiaie-I/a          t                4
Motility          ZscAer.cAf'a      Dulcitol          Serology
    Y	      Salicm
Pheny lalanase       y              y
                Inositol         Serolocy
(Detection of    Matonate
 Providence         Y  ------- Discard all bjt KlebsteUj
                Voges-Proskauer
                Capsule production
                Serotog>
Cram *tain if still unknown

jVore; ^as(eure//3 psstts and P. pscurfofuiercu/osis -iill pass scr'.enr,g tests.
       were taken  %\ith the impingcrs  using sclcnitc
       broth  or tctrathionatc  broth  (Difcol  as the
       collecting fluid.  The  broth  %\as left  in the
       impingers after sampling and incubated for
       24 hours at 37°C. Following incubation, loop-
       fuls  of the  broth  \\cre stieakcd for isolation
       on Mac, S-5, BG, and BS agar plates.  The
       remaining broth was filtered  through :i mem-
       brane filter, which was then placed  on  an S-S
       agar plate  for incubation  Following  colony
       development, all  noncolifona colonies  uerc
       Identified by the pioccdure given in Table III.
                                    Laboratory Analysis
                                      The  cultivation and difTerentiation pioce-
                                    dures used in  this  study were composites  of
                                    methods developed by the Texas  State Health
                                    Department  Laboratories and are essentially
                                    those recommended by Edwards  and  Ewing16
                                    and by Kauffmann.17 Unle^ otherwise noted,
                                    the \arious media used \\cre dehydrated Dif-
                                    co products,  "With the exception  of the carbo-
                                    hydrate, alcohol, and  urea solutions, all media
                                    svore stcrili/ed  in the autoclave at 12l°C.
                                      For  identification  purposes airborne  b.ic-

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'American Industrial Hygiene Association  Journal
                                        TADLE  IV
                             Grouping of Nor.-Enterohacteriaceac
Group
Xtffomonas-like
XrcJiromoiacrcr-hke
tilcc
TSIa 0-Fb Oxidase Nitrate Catalase
© *
2 O - -or+ +
* F + + •(•
              *TSt reactions: -, no acid; -, acid;Q, acid and gas.
              "O-F reactions: 0, acid production by oxidation; F, acid production, by
                          fermentation.
teria were collected on agar plates exposed in
the Andersen sampler or by the direct plate
method.  Following incubation  each visible
colony was streaked for isolation on EMB
agar.  For each isolation, one of  each Upe of
colony that developed  was  transferred  to a
triple-sugar-iron  agar  slant  (TSI),  and the
bacteria were differentiated by the procedure
given in Table III.
  All media  were inoculated fiorn grouth on
the  TSI  slants,  incubated  at  37°C,   and
examined or chemically  tested after 24 hours
except where othetuise  noted in Table  III.
  Christenscn's  uiea agar.  prepared in the
laboratory  according to Christenscn'i original
procedure,31 was  employed for the urease  test.
The motility, nitrate reduction, and ovidatne-
fennentative media \\ere also prepnied in the
laboratoiy according to formula? recommend-
ed by the U. S. Public Health Seivice, Com-
municable  Disease Center.
  Purple broth base was used  as the'basal
medium for the fermentation tests.  The  car-
boludrates and alcohols  wete filtci-steiilu'ed
in  IQC'c  solutions and  added aseptically to
obtain final   concentrations  of  \c'c  in  the
media.  Gas  production uas  detected  with
Dm ham tubes.   The media  were incubated
for 24 hours  before inoculation.  Amino acids
were added to decarboxylase medium base in
concentrations of 0.5rc,  and  all tubes  were
layered with vaspar following  inoculation.
  Except  for the incubation time  (48 hoars
instead of  five days'* of  the metlul  red  test,
the indole, Yogcs-Pro-kaucr, 
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                                                                           November-December, 1966
G
                                 O Nutrient Agor
                                 3 EH3 Agar
                                 • Conforms
       i
       5 10
                 2O     40     60     80
                    Distance  Downwind  (feet)

         FIGURE  1.  Effect  of distance  on  numbers  of
       bacteria found.
        1000 -
                      5        IO        IS
                       Wind  Velocity (mph)
                                                  20
               Z    3   4    5   6    7
                Tirse m Atmospters (S«: )

  FIGURE  3.  Geometrical  nature  of  bacterial die-
off  in relation  to time in the atmosphere.
                                                           IOO
                                                          i
                                                          o
                                                            50
                                                                  20"
                                                                                         O
                                                                                           O
                                                                                         O O

                    SO        60
               Relolive Humidity f/J
         FIGURE 2.  Effect of %vind %e!ocity on  numbers      FIGLRE 4  Effect  of relatise humidity on num-
       of bacteria  found                                  bers of bacteria found.
         Figure  1  shous  the effect of distance from
       the unit on numbers of bacteria  found on 35
       different  days  at   the Govalle  plant   The
       cunes are apparent!} powci  functions of tlic
       fonn
                          A7 = asb
\vherc  X =  number of colonies abo\e control
         s —  distance dour,\\ind of unit (feet).
      a, b —  regression constants
       3       O
An alyehuiic fitting of tl;r  c'.a'a \\.i-5  deemed
justifiable because 3J nur.ibei-. \\eie axeiaged
for eacli point nnu th.e rep'ii a;e saiv.ji'.es ucrc

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American Industrial  Hygiene Association Journal
   100
        20 Oowrwlnd
        Wind V«loeilyMOm5h
         SO
                    60        70
              Relative Humidity 83
  FIGURE 5.  Effect of relative humidity on num-
bers of bacteria found  (wind factor suppressed).

in good agreement.  This fitting  showed a
values of "45  for nutrient ajar, 458 for EMB
agar,  and 227 for coliforrns. The correspond-
ing b values  \vere -1.04, -1.18, a-nd  -1.25.
  The numbers of colonies on nutrient agar
at the 20-foot downwind station for samples
taken on 55 different days ore  plotted against
wind  velocity in Figure 2. The effect of lesi-
dence time on the  viabilitv of  the  bacteria is
easily  seen  in both Figuies 1 and 2.  The
inteirelationships of distance,  wind velocity,
and residence time showed an effective half-
life of 0.38 second at the 20-foot station; half-
Jives  at the other  distances differ somewhat
from   this value because  of  the piobable
changes in the predominant species \\ith ti:iv.
the dispersion of the air ma«s,  and the dev in-
tion of the survival from the exponential.
   The geometrical natuie of bacterial c'V-ol
iii the atmosphere can br seen  in Figure 3.
The maximum death rate occur? between  0 7
and 1.0 second after emission.  This period is
followed  fiist by a rapidly declining deray
rate  for two seconds,  then  by  an apparent
stabilisation after three seconds, which lesults
 in relative!} lonar survival  times for the resist-
           /    O
     ant organisms. The power equation presented
     above holds  only for the first tinee seconds;
     then  the decay becomes linear with time.
        Overall  relative  humidity data showed al-
     most  no correlation with survival (see  Figure
     4).  The only way that an  effect could be
     noted for  the relative  humidity was to sup-
     press the dominant factor, the wind. Such has
     been  done in Figure 5, where it is indicated
     (though roughly)  that the bacteria survive
     longer at higher humidities.  These data ate
     necessarily incomplete because of the nairo-.v
     range of relative humidity observed for any
ao   one wind velocity during the study.
        A comparison of the numbers of bacteria
     sampled through direct  plate  impaction  bv
     the  wind,  the  Andersen sampler,  and  tiie
     aerosol impinger is shown in Table V. These
     numbers are averages of data for five sampl-
     ing  occasions.  The  samples  were  collected
     .simultaneously at 2 feet above the liquid sur-
     face of the aeration unit.
        If it is assumed that the difference between
      the  impinger  and the  Andersen  sampler i--,
      caused b)  separation  of lumps of organism-.,
      the  number of bacteria per particle  is 1.35:
      hovvcver, the number  of mixed colonies  ob-
      tained could  be surmised  to result fiom  two
      separate particles that impact near enough to
      the  same spot to form a single homogeneous
      colony.
        Generic   c'e'.eimina-.ion.'  sh' itr meth-
      od  to b;  squall;. efToct'v t for  K-cr.very of
      EmereLat.'.^iace..'   T.':e prcpoi:! iris did  not
      hoicl  ''ir otnn  enuiics,  since direct  plate
      samples  from which 98  Emerobactc-i iaceac
      were  isolated gave  only  53  other enterics,
      while  for the Ander-t.n  sampler  the similar
      numbers were 101 and 238, icspectively.  The
      major difference  in the numbers  collected by
      the  two  methods  occurred in the  Alhaligiiics-
      FlaLobacterium group (inactive on TSI agar}.
                                         TABLE v
                         Quanti'a'.Uc  Ccrr.panscn of S'.-rphr,: ".tc
                  Method
               Nurb-r per juv>ic foot
                                      1170
                                      100
            870
             74 4

-------
c
                                                                   November-December, 1966
                                            TABLE VI
                                Relative Numbers of Airborne


SMtfeJla
EschtrschtJ
£. co/i

Arizona
Cttrobacter
Bethtidj - Bailew?
JC/e6src//j
K. pneutticiijte
K. OTV fi>CU TI
Aetoijjct et
A. aers ter.es
Hafma
Serratta
Profffys
Providence
Enrinu
Unknou n
K...EBU»bact.,,«,«
Total enterics
Number of Isolates
Species Croup
0
54
19
0
0
17
1
77
4 J
28
51
32
3
14
8
11
0
10
*) A fi
,i "O
476
721
Person.
Entero-
0
22

0
0
6.9

31.5


20.8

1.2
5.7
3.3
4.5
0
4.!
1 00


^f Tout
E:r.o-.cs
0
7.3

0
0
2.4

10.7


7.1

0.4
1.9
1.1
1.5
0
1.4
34.0
66.0
100
    Airborne Enterics

     . From samples taken  immediately adjacent
    to  the aeration  tanks,  group  typings  \\cie
    made on more than  700 enterics, and generic
    classifications were done for' 243 members of
    the  family  Enterobacteiiaceae.   All  visible
    colonies were biochemically analyzed for each
    sample  taken;  the  results, representing the
    actual percentage' of  occunence,  are tabu-
    lated in Table VI.  The bacteria cultured on
    EMB agar were found to tcpresent 56^c of
    the total  colony count on nutrient agar, Th'ese
    data indicate that, of the 1170 bacteiia per
    cubic foot that are  emitted,  enterics num-
    bered 655,  including  222  (or lO^c  of the
    total) Enterobacteriaceac.
      The most significant aspect  of the data in
    Table VI is the large numbers of A.",V />.-;'. I'a
    organism-,  found  in  the  atmosphere.  All
    spec-es of this g?nus are kro^.n prrho.i~:i5 of
    the  re-pir?.to.\  tract,21-"  and its  members
    couip:l-'ed near!;, one-tLru of  ail  Kntur.br.c-
    tcriaceae iiol.ii.ed.  Six pci  crnt of all bacteria
    emitted f:om the activated sludge  u.nit belong
    to the Klebr.cllfi group  From c'r.t.i co-le-.ted
    in thi^ it-;c'\'. r. r.;an woi':'ivr -.vit1':!1 ^ '\"M of
               • -
the d
                  ede of
    the v,\\ ;  \cloi_it'.
    a slucLv
a viable KL'bsii:l!!;
1-6 ai.ti^erutu.  howevci, only  t\\o slide  ag

-------
American  Industrial Hygiene Association  journal
                 TABLE  VII
   Relative Nu.T.ters of Non-F.riterob^cicriaccao

£«'
Achro
Pas;<
Altai
ToM
Group
fe£';«.f,V.
.•^o6tic-ff f-li'xs
uro/fj-.-icfrnn S
ifenoj-fljun.
non-Entetobact
Number of Perre r.t
Isolate* of Tot3 I


.K-i«m-lik*
i.-tf rfum-!ike
•jnaceae
36
27
14
55
344
476
7.6
5.7
2.9
U.5
jJLl
too
glutinations  could be  confiimed by positive
qucllung reaction.
  An unexpected result was  found in the re-
lative numbers of the Pro!em and Providence
groups—the  latter dominated, which  is the
reverse of stool specimens. However, the usual
order occurred  in the  raw sewage emissions.
Of  the  eight Proteus  organisms  reported in
Table  VI, three  were H;S-positive  on TSI
agar slants.
  The ab-,cru..j  of Sdni.-'i'.dla, ^'V.7-,  and
Aii?ona  i.-olru!e.n> H not  1-10 si.Tmiim?. de-
spite  nmr.cTou? report? of their  ^'f^or.rc in
seuagc a"ci act!''stt'd ^V.c,c.  Tl'es  ~\r"  -<•> fc\\
in nunihei that tht- ;:u !!.r/ri- i:s.'G  ;.•* iccrver
thft'\ fr01 ' s'.ali er.\ Iionrr.rui'5 'ijp.il!'.'  cr.tail
co:H'.r, ions ^amnii;'.'; i<->- it-iLxls  of tii.ic in
excess of ?
tial S'.icc-1-'' i< obtninf-d.1'1 ll
  Tl'.o iaol.ited non-F.nterobacteriaceae  were
broken  dosvn into groups based  on the clas-
sification system given in Table IV.  The re-
sults are tabulated in Table VII.  As expected
from  reported studies  of the bacterial  popu-
lation of artivated sludge,10'29 the vast major-
ity of the non-Enterobacteriaceae belonged to
the  Alkaligenes-Flai'obacteriuni   (biochemi-
cally  inactive) group.  The number of Psi-u-
donionas-\\}:e bacteria  isolated  was  consider-
ably smaller than expected, but some Pscuiio-
monas species aie inactive on TSI agar and
would be grouped with the Alkaligcnes-Flavo-
bactc-iium.  One  such species,  Pseudomonas
tnallophdia, which has a \'ery distinctive TSI
reaction ( ~ H.Sj, \'.-as found.

Sj/ituiL    ^/\'V'i- -ii-lii-Ai r ,1 net, ,-) aic
Hctte: ^n'trH  to r'i:\i^:i!  tiia:i tlv ., .ipy.iku-..
                                                                                             •D.
\
                                        TABLE  viit
                                 Spread of Airborne F.ntencs
Classification
Ea£°fc,[";*:"f
E. colt
Atk.'IescCT,— Di^paf
C'*:<>bi' '«. •
A'.' Asi '.'d
A. pnr-urron j,ic
/\. o.'ytjcmn
^ **r i ' '<••
^ a-rotJ^.Ti
Hal.-.. a
Serrj.'m
P.-otet/a
Ptcvicence
Unknown
Total
^ffrotror -is-Iike

,4c/)rom.iAacrcr-!iwe
Pa3ff-urr//J- 4 "ifiij '.icr.'i'u* -hi- ?
.4ltj/i^!rr3-f h.oia. •.--:-. -. like
Tots'
Total isolated
DisUnr
20
Species Group
U
4
1
4
IS
11
5
IS
8
0
2
0
4
2
«:
0
' 0
2
4
_62
JH
130
e O^^n^-md frjni Soc'cr >,feot)
50 100
Species Group Spec-Ies
3
1 2
0 0
2
9
4 4
5 5
4
1 3
1
1
1
1
0
-
0
3
2
5
65
To
97


Group
j


0
10


6

1
2
0
1
0
23
• o
a
3
4
70
a;
109

-------
                                 November-December,  1966

Klc

Dtstnnce Do*r. nd (fee.)
EMS agar
Nutrient agar
TABLE IX
iirc.'/j Su:vua!
X/eosic/
0
10. S
6.0


/j as pe
20
13.8
7.8


rceil of To' a!
50
9.3
5 .2


Couil
100
9.3
5 2
          TABLE  X
Size of Viable Airborne Particles
Stage of
Saxpter

Si'e Range
Of Particles (/!)
Particles per Stdgy as Percent
Station-Feet Downwind fro-y
0
1
2
3
4
S
6
>3.2
5.0 -
3.0 -
2.0 -
1.0 -
Up to
10.4
6.0 7 Lun£ penetratir.^
3.5 T
2.0~~T Ai'-e^lar retention
i o T
38
22
21
11
4
2
.4
.0
.4
.a
.0
.4
3
15
32
31
17,
3
0
20
.1
.0
1
.0
,6
S
23
38
17
9,
3
.1
.0
_2
•7
3
of Total
. Unit
50
20
29
17
18
7
.0
7
.0
I
.6
,6
100
24.4
22.3
27.6
12.2
5.5
7.0
C;
group (/T.j<-/u-rjc/na-Citiobacter). Of the sam-
ples taken in  the  immediate vicinity of the
activated sludge units  (sec  Table VI), the
capsule formers compiised  52^c of the Entei-
obacteriaceae.   This pcicentage steadily  in-
creased with distance downuind and reached
709e  of the total at the  100-foot station. The
acapsulate group, by contiast. dropped  fto'ii
      in  the first group of samples  to 13fc  in
the samples taken at the 100-fort -i?\
are consider^.!  tu Ui l<-^ cv.v'i'e  of >n\ivaj_
in tlsi- j.tiao.>ph:ie  tl.nn iv'st  ut!;r '->;.,'-  of
bacteria, the A'-pi\>:V.'.'t;  sn.iins \.e.e found  to
be  neailv  as  iesi-ta;it  to  de-\\ t'on  as the
         ' F           •           •    • •      T~~
average  ct tr.c oa.te::a  rarir.iir.n ::i li.'* stuor.
(sec Table IX). The incieaj'? in the rrlnti\e
percent  of Klt-bticlla at th.e 20-foot  station
probably indicates   that,   because  they  are
encapsulated. Klcbi'.i-lln 'M\O a l"n.'-r r. %i-iod
of equilibration.
  In  an attempt to  e\a!uat<: the possible  at-
tenuation of \irulencc of Kit  bsii IIa organisms
with time in the atmosphere,  a result reported
for other pathogens,™ Klcb^uila recovenxl  at
distances of 20, 50, and 100 feet ueie checked
for capsule production and  compared  \\ith
those sampled  at the source.  The pcicc-ntagrs
of isolates capable  of capsule piod-ict'on  at
distances of 0,  20, 50. and  100  ,'Vrt M^e 97.S,
78.0,  55.5 and  COO  respeuivek. Appai.Mitk,
loss of the caroiile-picd'icinz fur.r'.i* T> oi\urs
                fairly rapidly during  the ecjuililtration period,
                but those that still  retain the capability uhen
                equilibrium is i cached sufTei no fuither lo^s.
                It should be noted  that capsule ptoduction is
                limited b) the methods used in this stuck, and
                the apparently  acapsitlate stuins may be cap-
                able of  pi educing  capsules if cultivated in a
                more -j'fiblc ?r\ !i.'mi:'er t
                  Since the  pa: iiclu  si/e pla^i an impoitant
                role in lung penctiation and retention, certain
                sixe data  were  deduced  fiom  the .\ndcis~n
                samplei data. This i elation is propei'.y diawn
                because the  sampler is  designed to scoaiate
                                i           O          i
                particles b\ size   The data are piescnted in
                Table X.  \\"h!!e the c'.'it'i :M • ac'::::ti'-d!> \ ail-
                able and the ivi.-.., r-, r-Tu  :s  la..'k -,g :•) p> •-
                cisioii, it i< demur stinted t.!iat a courier able
                num^e' of t!i'": i_o!lc-c'.. d v?.; ilrics could  pene-
                trate into and be
                Cc-n'rij! Scr/ip'c  Types
                  Fifty-eight  of  the  control  sample colonies
                (collected upwind of the aeration units; \\eie
                biochemically t\ped — ten  uere of the  famils
                F.nterobacteriaceae. Of these, f\\ e \veie Klcb-
                siella  (all  K. oxyiocurn],  three  ueie  inter-
                mecliate  Acrobact<.r  specie-*, and  two \sere
                members of the I'ro\ idence group.  The aver-
                age  concentration of  the  contiol  samples.
                usir.sj tii,'- Andei^eri sampler, \\as si\ per cubic
                foot en nutrient .T'ir.  That thf controls \\ere

-------
American Ind initial Hvgicnf Association Jouinal
                  .2
                  .a
                                        in   —i
                                               O —f^ O O
                               O T  000 -

                                               o — « - o

                                v, '-<  vi < u :<
                             130-

-------
                                                                  November-December, 1966
 '  influenced by  the  other  units  was  shown
    in the results of  several samples  thai weie
    taken upwind of the entiie treatment plant;
    these  samples shouecl no Enteiobactemceae.

    Cornpaiison Studies
      In  Table XI, the viable airborne bacteria
    emitted  from  the  Austin  activated  sludge
    plant are compared uich the emissions from
    the grit  remover  (raw sewage)  at the same
    plant and  from die activated sludge units at
    Round Rock, Texas. These data reveal con-
    siderable  similarity between  the  emissions
    from  the two  activated sludge  plants.  The
    same  groups of  bacteria  \\crc dominant at
    both  plants,  and the various organisms  ueie
  •  found in comparable percentages.  The  most
    noticeable  difference   was  the  absence  of
    Aerornoiias-like organisms in the  Round Rock
    sample.
      Klebsiella,  Eschcrichia,   and   Acrobaeter
    species occurred  most frequently among the
    Enterobactcriaceae  in the raw sewage emis-
    sions  just  as they  did from the  activated
    sludge units; however, the  fraction  of the
    total  enterics  that  \\ere  Enterobacteriaccae
  _  was considerably greater. The primary cause
f.  of this effect was the significantly larger num-
    bers  of  Klebsiella in  the  raw seua^e emis-
                                       7
    sions.
      Conspicuously  absent  from  the airbome
    raw  sewage  bacteria  were  members  of the
    Providence group.  By contrast,  members of
    the Proteus  group increased  to  7.3^c of the
    Enterobacteriaceae, and all isolates were H^S-
    positive  on TSI agar slants.

    Special Studies {or Pathogens
       As expected,  no Salmonella  or  Shigella
    organisms were collected  during the  noimal
    procedures.  Because of the importance usu-
    ally attached to  these species, rather strong
    efforts were  made to find such organisms by
    special  studies.  Samples from fi\e  minutes to
     14 hours were  tried with selcnite broth in the
    impingcr.  Still no Salmonella or Shigella was
    found,  although  a  Salmonella-like organism
    was collected at  the Round Rock plant. The
    pseudo-Salmonella was an Enterobacteriaceae
    recovered from selenite broth and'isolated on
    S-S agar.  It gave a positive slide-agglutina-
     tion  in  Salmonella poly A-1 aruiscrum  and
had   the  following  biochemical  reactions:
Triple sugar iion ngar, — ; positive on methyl
red,  citrate, lysine, argininc  (delayed),  orni-
thine, motility, and salicin (ten-day delayed) ;
acid and  gas  from glucose;  negative on lac-
tose,  sucrose,  urease,  indole, phenylalanase,
and  dulcitol.  No positive identification could
be made  by  the  methods employed  in this
study, but, according to Edwards and Ewing,
the  organism  was eliminated from  the  Sal-
monella classification by the salicin reaction.
  Sampling for scveial hours uas tried \\ith
the  Andersen sampler  using  various  agar
media recommended  for  the  cultivation of
Salmonella  and Shigella  (MacConkey's, bis-
muth sulfite, brilliant gieen,  and Salmonclla-
Shigellcx).  Several false Salmonella reactions
weie obtained on bismuth  sulfite  agar; all
proved to be Klebsiella oxytocum.

Conclusions
  The  following   conclusions   have  been
reached, based on analysis and  evaluation of
the collected data.
   1.  The bacteria! population  of  tl"*  nir i*-
significantly  in^rc,a,?fd  bv  passage  over  an
activated  sludge  waste, trcntr/ient  uni^  from
aoout eig;ht  per cubic foot on the upwind
side to 1170 per  cubic foot on  the downwind
side
   2.  Despite  a rapid div-off of bacteria dur-
ing  the first three  second!; they aie airborne,
die  increase in bacterial  population  pelsjsts
for  a considerable time  and  distance^—the
distance   'being; s'trongiv'~3epen3e.rLt. on, _thc
wind velocity.,
   3. Bacteria of the family Enterob.ictcriace_asv_.
including species of known rjatho^cnjcity, are
emitted in  large.. nunjbeis^. The'/  make  up
19r/o of the total bacterial emissions.
siflla species, proved pathogens of the
tory  tract,  are  the_ inost_numcrous of the
Enterobactrriaccae: they  represcnT'S^c of aTT
bacicria emitTecT.'"
  4.  The Enterobacteriaceae tii.it are poten-
tial  pathogens of the .rcspir.ato.r..y_-tracj:_/&k:b-
sielki, Aerobactcr, Proteus) are far_more_nu-
meious tiian   the  entciic P2^]2P3£i"'J   T^lcv
iTi.ikc  up  nearly  5Gfc  of  the  familv^ a_nJ
10.55o of all  bacteiia emitted,  hi addition,

-------
American  Industrial Hygiene Association Journal
Klcbsiella ai:d Aerobactcr species, p.trticularly
                   ijiorcTcsistaij tr to  ( i «^ ciTcc 'o _af
      ^iPA t!ian
   5.  About 40^; of the_yijijjfcj,'3n?.ri.:lj'r\ '^
               vicinity  of  the  activated  sludge
   6.  There  exists a  definite, possibility of  air-
borne  infection  from  acti\ ated  sludge units.
   7. Klebsiclla are the best, indirators of bnc-
terial air pollution from sewage source's.
   Note:  The  preliminaiy  data of this work,
which pertained  only to numbers,  were  pre-
viously published.31


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CHaisiT.NitN,  \V. B.: Urea  DecompositJcn  AS a  Means
of DifTerifn Dating  Trot cm jnd Paracolon Cultures from
Each  Otiwr and  from 5/i/mint'i/a and  Shi^c'ta  Typv'j.
/. Bacteriol.   52: 461  (1946).
Standard .\fetftodt for  the Examination  af Wetter  and
Waste  Wttltr^ Ihh  Ed,   American  PuMic Holth As-
sociation,  New York tl960).
HoocrnruDE,  J  C.- Studies on Capsule  Formation,  I
The  Conditions  iindtr   "Wl^ ch  Kitbsiftl.fi  pntit'ttctnae
Forin,- C^psuJe,. /. Rsctetioi.  3€: 3-'i7 (1959}.
Lf.rrsK  M. H :  Opportunist:c Gr2ni-ne^t:\c  Rr<|  P-il-
monnr>- Infections.  Dif&tfs  of the Chest -i~f' 18 il?61(.
O^;^KO\ , lov:  SC''^^tioti3  in the  A'.'t i»'tl'.~
Group.  2.  Occurfc'ici;  of   Kltt»t' ila  in  Sputa   Act*
Pathal MlcrolioL Scar-d.  36-  454  ,1955).
DtFfY  T. J, and I  CHOFN\S  Piunar>  L'tns  \b-CL-^
Amer. J  5o. 45  2(i9  (IP^C).
GR>FNprjc, L  F.,  J.id S.  B. Kvfrs  Klfh*  ''<: piteu-
ntoni.i  \»ith   Piij-urothr'.\,    PtinirnomeJ i-:« i-un  .in^H
Pncumop<*r.toruum.  Put': r  o/ ('M C/fJf VJ  5-t'i -1%JJ
GP* t-Nr.Fki, L. F, and  M.  Fttt: Studies on  thf Kl'b-
iiella'AfTjbccter  Group  of Bacceria.  /,  Ir.ffc, Dis*ii'><*
91: S2  (1952).
Dus,  F.  F.,  and J.  V. BH<.T:  Microbial  FroIorN  0(
Acti^Jted SluJje  I   Dnminant Bjcteria   Ap.'l.  .\lirrn-
bio!.  1?: 4U  (ISW).
Gto\v,  R.   J , and F. A. LEON*KO   V'.ibi'it\  and
Infcct.\it>  of  Nfic.'oorta.-ii'iiii'  in  F^pencier.tal  Ai'bornc
Infection.'  Bzc'-r-.ul  Re:  25. 18.!  M9-J1'
LEDrtrrrn, J  O., and C  W  K\.so\u.-  Hartcrinl  E"IL,-
sioiis  from  Activated  S!utJ»Te  Unit*.   Ind.  Mrii   Surg
31(1):  130  (1%3.
                                 Received May ?7 1%6

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 Colifonn Aerosols Emitted by Sewage Treatment Plants

   Abstract, Development of the science of aerobiology lias furnished a tool for/
 the investigation of potential sources of  microbial  aerosols. An investigation of
 aerosols emitted by trickling-ftlter sewage treatment  plants revealed that coliforms
 were indeed emitted and have been sampled  to a distance  of 0.8 mile (12 kilo-
 meters) downwind. Factors affecting survival of Escherichia coli are presented.
   The association of pathogenic micro-
 organisms with water and sewage has
 been  known since  1855  when  John
 Snow in London traced  the source of
 a cholera epidemic  to  a  sewage-con-
 taminated well  (1).  Since that time
 human  fecal waste has  been found to
 contain the  specific etiologic agents of
 some  diseases, many of  which are in-
 testinal  diseases. Although these are
 commonly   transmitted   through  the
 mouth,  experimental  infection of the
^chimpanzee   by  inhalation  of large
 numbers of  aerosolized  typhoid  orga-
 nisms  has  been  demonstrated   (2).
 However, there are other organisms,
 whose respiratory dosage  is compara-
 tively low, which are excreted in the
 fecal  waste  of  infected  persons. Some
 of these are: various respiratory viruses
 and  the  microorganisms  that cause
 brucellosis, encephalitis, hepatitis, poli-
 omyelitis, psittacosis, and  tuberculosis.
   The development  of  the science of
 aerobiology  in  the last few years  pro-
 vided a tool that has encouraged us  to
 investigate  potential sources  of  aero-
 solized  microorganisms.  Schultzs  (3),
 in 1943, studied the fallout  of  small
 droplets resulting from  watering  crops
 with liquid  raw sewage from an over-
 head  sprinkling  irrigation system  in
 Germany. Using a primitive  sampling
 technique, he placed open petri dishes
 at varying  distances downwind  from
 the sprinklers and was able to demon-
 strate the presence of Escherichia coli
 in  the  airborne  droplets. Spcndlovc
 (4),  in  1956,  demonstrated "the acro-
 solization of bacteria from a rendering
 plant and was able to recover airborne
 organisms-downwind from  the  plant
with  the -use of  Andersen  samplers.
  Modern  trickling-filter sewage  treat-
ment plants, because of the  nature  of
their  design,  may  be  an exceptional
source of aerosolized  microorganisms,.
As  we  contemplated the spectrum  of
potential aerosols, jt  became plausible
that the variety of organisms that may
be aerosolized is almost unlimited. The
trickling filter used  in the secondary
treatment of sewage  sprinkles raw sew-
age into the open air onto a rock bal-
last to dosj the filter bed. The process
of sprinkling the raw sewage into the
air  would be expected to aerosolize a
portion  of   the  material  and  create
micron-size   particles  (Fig.  1).   Sew-
age varies considerably in its microbial
count,  but   counts  of  from  10*  to
107  organisms per milliliter  are com-
mon  (5).  A sewage  plant processing
several  million gallons of sewage per
day has the potential, therefore, of pro-
viding a microbial  aerosol source  of
considerable magnitude on  a continu-
ous  basis.
  Two  municipal sewage plants, rang-
ing  in  treatment  capacity from  6  to
25 million gallons (1  gallon = 3.7 liters)
of  sewage   per  day,  were  studied.
The plants  were located  in  the  Intcr-
mountnin West  and  the  studies  were
conducted during May 1970. Andersen
samplers (6, 7), connected to a  port-
able field vacuum source, were used to
collect the aerosols near and downwind
of sewage treatment  plants. The Ander-
sen  sampler aspirates at tho rule of 1
cubic foot  (28.3  liters) per minute and
impinges the collected  orgnnisms  on a
nutrient medium plr.ccd in pctri  piates
positioned   within stages  of the  sam-

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                                                                                                            I1
          Fig. 1. Trickling filter bed from above (A) and looking along the boom (B). Note the droplet formation.
pier. Each stage collects particles of a
different range of sizes, stage 1 collect-
ing the  largest particles and stage  6
the smallest.
  Three different mediums  were used
in the ftudies. Casitone agar was used
for the  collection  and growth of the
general  microbial  population;  Endo's
medium and eosin-mcthylene blue me-
dium, for the selective growth of the
coliform   organisms.   Samples   were
taken  from points in the  immediate
vicinity  of Ibc trickling filters and up
to  distajicrs  of 0.3  mile  "(1.2  km)
downwind. Collections of aerosols were
made  during daytime and nighttime
periods, with sampling periods varying
from 5 minutes to 1 hour. Upwind con-
trols were collected on each test, and the
same types of mediums were used for
these  controls  as  for the downwind
samples. All plates of nutrient mediums
were incubated  for a minimum  of  24
hours  at 37°C.
   Substantial numbers  of coliforms
were  aerosolized from the  trickling
filters.  The  concentration  of aerosol
particles  collected  near  the  source
seemed to  be most affected by the size
of the source and the velocity of the
wind. Plant 1 had only two small trick-
ling filter beds separated by some dis-
tance. Plant 2  had two sets  of four
beds each, with each set of four located
in close proximity to each other. As the
emitted  particles  traveled  downwind,
the relative humidity became more im-
portant If the test  was conducted dur-
ing daylight hours, solar radiation had
a  deleterious  effect.  Overcast  skies
could be expected to reduce somewhat
the effect of solar radiation. Generally
speaking, high wind velocities, high rel-
ative humidity, darkness, and low tem-
peratures~would be expected to give the
           Table 1. Coliform and total bacterial aerosol particle count from trickling filters (I  foot == 0.3 m, 1 yard = 0.9 m).
Distance
Plant from
source
1 50 feet






:'



50 feet
0.25 mile
110 feet
200 yards
130 feet
300 yards
0.5 mfle
130 feet
200 yards
2 • 100 yards
2 600 yards
2 0.8 mile
2 '100 y.irds
2 .100 yards
2 600 yards
2 • 0.8 mile
2 '140 feet
2 .100 ynnli
Test conditions
Wind
speed
(mife/hr)
2-4

1-3
1-3
10-15
10-15
8-10
8-10
8-10
5-10
5-10
5-10
5-10
5-10
5-10
5-10
5-10
5-30
3-7
3-7
Relative
humidity
25

25
25
70
70
65
65
65
25
25
25
25
25
15
15
15
15
55
55
Temp.
(°F)
70
(21. 1'C)
70
70
50
50
46
46
46
65
65
65
65
65
68
68
63
68
59
59
Time
of
day
10:00

10:30
10:30
11:00
11:00
8:30
8:30
,8:30
8:30
8:30
8:30
8:30
8:30
9:00
9:00
9:00
9:00
10:00
• 10.00
a.ai.

p.m.
p.m.
a.m.
ajn.
pjn.
p.m.
p.m.
p.m.
p.m.
p.m.
p.m.
pjn.
p.m.
p.m.
p.m.
p.m.
p.m.
p.m.
Coliform particles
per cubic meter
Downwind
364

300
5
867
30
490
183 >
/09
105
42
193
26
4
.159
' 70
7
3
934
73
Upwind
control




0
0
0
0
0
0
0
1
1
1
1
1
1
1
I
t
Total viable particles
per cubic meter
Downwind
3,911
'•
19,737
i
3,692

2,435
3,396
622
2,493
1,400

i ,
i
914
817
389
856
,

Upwind
control




51

• 574
574
574
1,676
1,676

- , •
" ' . i •
1 607
607
607
607



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                    2          3            4

                              140 feet from source
  .    1            2              3            4.5            6
                                 Upwind control
Fig. 2. Pctri dishes containing Endo's medium, from various stages of the Andersen
sampler.  Note.high concentration of colifonn  colonies on the upper set  which were
located downwind from the trickling filter bed shown in Fig.  1 (1 foot = 0.3 m).
greatest recoveries, both  close  in  and
at greater downwind distances. Relative
humidity is  known  to  have  a pro-
nounced  effect  on the  survival of air-
borne  E. co//;  usually,  the  humidity
during  these studies  was low. Low hu-
midities were shown by Brown (8)  to
have a strongly adverse effect on  sur-
vival of aerosolized E. coll. Positive re-
coveries  of coliform  organisms  were
made at night up  to a distance of 0.8
miic  from  the  source  (which was the
maximum distance sampled). Greater
distances of downwind travel may  be
expected under  more -ideal conditions.
Only a  qualitative investigation, of aero-
sol emission  has been made  to  date,
and Table 1 shows the number of coli-
fonn colonies and total number of bac-
terial   colonies   that   were   recovered
under  the  various conditions  of the
study.
   The  counts presented in Table 1 are
corrected for positive  hole  count  as
reported  by Andersen  (7). It should
be noted that counts reported  are de-
rived from  ncrosol  particles collected
on the various stages  of an  Andersen
sampler.  Each  particle collected  theo-
retically gives rise  to one colony; how-
ever, most  of  the  particles  collected
contained more than one  bacterial  cell.
Andersen (7) estimated  that particles
on stage 5 contained 1  to 4 cells; stage
4, 3 to 10  cells; stage  3,  9 to 25 cells;
st.igc 2, 22 to  200 cells;  and stage  1,
150  or  more cells.  In any  event, the
p;>rticlc count  presented  is  probably
only  a  fraction of the total cell  count.
The heaviest counts were observed on
stages 2, 3, and 4,  with lower counts
on stages 1  nnd 5. Few if any colonies
were observed on stage 6. Policies re-
covered on stages  3  nnd below  arc
        L
known  to  be  in  the  respirable  size
range; hence,  if pathogens were  pres-
ent,   they  would  be  most  infective
in this size range.  Particles larger than
5  /i  in  diameter  (that  is, those  col-
lected on stages  1 and 2)  would be
deposited in the upper respiratory tract
but  also  may  be  swallowed and  enter
the  gastrointestinal tract where many
enteric  pathogens  are effective.
   Since E.  co/; and other coliforms are
the  universal indicator of -fecal pollu-
tion, it is apparent that the discovery
of aerosolized coliform organisms  aris-
ing from scw.ij;c treatment planls  i
portend n  public  I>c;illli  concern.
vcstigations should  be conducted to
tempt to identify other bnctcri.il, fun
and viral aerosols generated by sew
treatment facilities.
  Note added in proof; Aflcr our rcf
was submitted  for  publication, it
called to our attention that C. R.
brecht  had  performed  research  <
somewhat similar nature. Albrccl.i
milled  a thesis to  the   Univcii-ity
Florida in 1958 entitled "Bacteri. ! ,
Pollution Associated  with  the  Sou.
Treatment  Process."  We  hereby
knowledge Albrecht's work.
                       A. PAUL ADA;
                J, CLIFTON SPF.NDI n
Deseret Test Center,
Fort Douglas, UtaJi 84113

                  s  and Notes
1. J. Snow, On the Mode oj Communication
  Cholera {Churchill, ed. 2, London,  1855).
2. D. Crozier and T. E. Woodward, Military A/(
  127, No. 9, 701 (1962).
3. K. Schultzc, Archiv. Hyg.  Bokieriol 130, 2
  (1943).
4. J. C. Spendiove, Public Health Rep. 72, No.
  176 (1957).
5. L. A. AUen, E. Brooks, I. L, WUUanu, /. H>
  47, 303 (1949).
6. Andersen Sampler distributed by CMC Indi
  tries. Salt Lake City, Utah 84107.
7. A. A, Andersen, 1.  BxtirioL. 76, No. 5, 4
  (1958).
8. A. D. Brown, Aust. J.  Blol Scl. 7, 444 (1954
9. Supported  by  DA  Project  1TB61 101A91, Ir
  house  Laboratory Independent Research.
n July 1970

-------
        TECHNICAL AND LEGAL ASPECTS  OF



         WATER RESOURCES MANAGEMENT






                VERNON, B.C.


             April 1-3,  1970
"; 1  , Organized and sponsored by


 ' I    Extension Department

 ;.'j    The University of British Columbia
 -j    Vancouver 8, B.C.

-------
             THE MICROBIOLOGY OF DOMESTIC AMD INDUSTRIAL WASTE
                             P.M. Townsley
                      Department of Food Science
                   Faculty of Agricultural Sciences
                    University of British Columbia
                          Vancouver 8, B.C.
     Many of the waste gases, liquids and solids eventually must
pass through the digestive environments created by the micro-organisms.
Waste enriched with methane, urine, or asphalt will tend to select and
to promote the development or adaptation of soil micro-organisms
capable of using these substrates.  Waste materials which are either
resistant to microbial attack or are produced in quantities exceeding
the degradative capacities of the micro-organisms will accumulate and
place an undesirable burden on the local environment.  The micro-organism
   «a living, competing, reproducing entity which responds to favourable
   satment.  Its appetite is enormous, capable of utilizing 1000 to
10,000 times its own weight of sugar per hour.  Possibly one of the
.Basons for this capability is the large surface/volume ratio.  A
bacterium with a cell diameter of 0.0005 mm will have a surface/volume
ratio of 120 ,000.

     The micro-organism may be considered to be a very efficient
manufacturing or degrading plant where ra.-.; material may be converted
into desirable products.  If an effluent, as an example, contains a
high proportion of hydrocarbons such as benzene, phenol, oil, or linear
alkylated sulfonate detergent, a microbiological flora will develop in
the sewage which will utilize these substrates.  It is not surprizing
that petroleum consuming organisms are found in nature for small
quantities of hydrocarbon occur naturally in many tissues and environ-
ments (1).  We have often seen oily films on stagnant marsh pools and
have heard of the occurrence of n-heptane in the distillate of the
pine tree.  In fact the hydrocarbons occur so frequently in nature that
Approximately one out of four bacteria and fungi can utilize them.

     There are two import-in t points to remember about the organisms
when hydrocarbons form a major constituent of a sewage effluent.  First,
                                    137.

-------
c  -nical combines with a number of compounds found in streams and
sev/age and depending on the polymer size, surrounding acidity and
various interactions it ferns a flooculent.  In addition to being a
flocculating agent lignosulphonates are used in an ever increasing
                               ,*•
amount in a numbor of industrial applications.  They are used as
adhesive, dispersing, binding and stabilizing agents ir. the construction,
cining, chemical and agricultural industries-  In fact, our own
laboratory has used successfully the lignosulfonates to stimulate the
cicrobial utilization of petroleum and petroleum waste (7).  However,
a potential problem may exist as our studies indicate, lignosulphonate
can replace the protein from frozen salmon sperm.  l^ether or not the
lignosulphonates interfere'with the genetic material of the many plants
and animals found in natural waters remains to be determined.

          Approximately 30% of the sulfite spent liquor solids is
carbohydrate material of which possibly SO'l is readily fermentable.
This supply of fermentable carbohydrate rather than being deposited
i  3. sewage system forms a major source of sugar for the production of
alcohol anU a potential source for mushroom culture, vitamin B,,, , and
rr.any other products.

          In biological treatment systems sugar will disappear rapidly
under both anaerobic and aerobic conditions.  Under anaerobic
conditions, one pound of sugar dissolved in ICQ gallons of effluent
will disappear in approximately 30 minutes (3).  Of course, many
nutrient factors will either interfere with or accelerate bacterial
activity.  The inor.ganic nitrate formed in aerobic sewage treatment	
can be removed by anaerobic conversion of nitrate to gaseous nitrogen.
Phosphate can be removed by the addition of multivalent metals such
as iron, aluminum and calcium forming the insoluble phosphate floes.
                                               l
          Optimum conditions for rapid substrate utilisation and
biological flocculation are incompatible.  Bacteria and most biological
•T-ateriais contain a net negative charge and can combine with oppositely
c  -rged materials to form very large particles whi^h separate as a
sluc!ge from solution,  Polyelectrolytes such as pciyacrylamide and

-------
 fire ashes containing  poiyal-iAC  metals  arc  ccrrrnorily added to sewage tc
 increase the flocculation  rate  and  to dehydrate the sludge.  Excess
 carbohydrate, desirable  for  rapid fermentation, interferes with
 flocculation.

           There are, ao  in all  communities, microbial villains which
 are capable  of thriving  on s'ubstrates valued for one reason or anothex
 Not too many years  ago natural  control  over plant and animal disease
 was'supplied by physical isolation  and  the  development of resistance.
 Today, as our human population  grows into  a logarithmic division,
 control of human numbers barring common sense will be exercised by
 disease, lack of food, and pollution as is  found to occur in any
 densely living biological  population.   Just as micro-organisms car,
 adapt to changing sewage composition, they  will occasionally overcome
 human defences.  Thus  it is  important that  the planners of sewage
 systems recognize the  potential  health  hazards of sewage and interrupt
 the transfer of the pathogen in  sewage  disposal.  Well, what do we
 know about the microbiology  of  domestic and animal waste?  First, we
 know that approximately  37 pounds of we't sewage solids are produced
 per person per year (9)  and  secondly, that  only approximately 50' of
 the available bacteria can be isolated  and  characterized from activates
 sludge by using standard microbiological techniques.  The remaining
 40% of the bacteria require  an  extract  of  the sludge to be added to
 the conventional medium  to support  growth  (10).

           We are concerned over the microbial composition of sewage
 from several important points of view,  the  rale at which the sewage
 flora will utilize  the incoming  effluents ,  the ease of sludge
i fiocculation ar.d separation  and  the potential health hazard of se:-.7ag<
           It is the-last point  upon which  I wish to enlarge.  Forty
 percent of the faecal  matter from hurans ar.d domestic animals is
j composed of  bacteria,  mainly represented by the organism EschericM.-r.
j £2ii.-  This  orgar.is." is  a  number cf a group 'of organisms labelled
| th
-------
  Klebsiclla »  a  cause  of  pneumonia and other i-nf lair.-nations of the
  .espiratory  tract,  Shi gel la ,  a cause of dysentery:, and the soil
  orgartisns belonging  to  the' genera Proteus anr! Aerobacter.
                                    \

           The  majority  of  the strains of the bacterium Escherichia
  coli  utilize the  nutrients" of the feces and are not pathogenic to iran.
  There are exceptions ,  however, certain strains of  F. coll can cause
  infantile diarrhoea  resulting in- serious epidemics in nurseries and
  hospitals .

           The  identification  of I',  coli in a food 01 in a water sap-pie
  is  indicative  of  .rascal or scwaee contamination .   It is also an
  indicator of the  riss.  of the  enteric pathogens.

           The  use of antibiotics for the control  of disease in humans
  and in. animals and  for  promoting growth, and more  efficient feed
i  utilization  in domestic animals is  widespread.  A serious consideration
1  in  the use of  antibiotics  is  the appearance of antibiotic-resistant
i  strains especially  ar.ong the  E. coli .  The seriousness of the situation
'  is  not in that an antibiotic-resistant strain of  E_. coli is forced
;  but that this  strain can transfer its resistance  to other genera  of
i  the Enterobacteriaceae , in particular the Salmonella . Klebsiella and
;  gfrigelJa (11) .
I
i           Sewage  sludge is disposed of in three different ways -
j  ty  spreading on land as a fertilizer, as a land fill and by discharging
j  into  waterways.  All three method?  of disposal create a health hazard.
t
;           Just how s'eriou^ is this  situation?  It is known that
i  Ijj-p'-onella when present in faecal material deposited on a stone wall
  "r  in soil will ra'nt^in vi-billr\  for at least 307 days (12).  If  the
  rtdiun supports growth the organism fill grow and ;r.ultiply at terrperature
  ^tvreen 7°C-46°C.   The organism is killed by exposure to 50°C  for  ons
  "our.
            The factors which determine the length of tin-. -3 a pathogen  will
  survive ir. soil or on the surface of a plant are unkr.ov:n but include
  '•'•e competition with, other bacteria.  Vegetable crops such as  the  tomato

-------
To achieve disinfection, however,  the  pll of the  flocced water must be




reduced because I10C1  ionizes  to  hypochloritc ion (OC1~), nostJy as the




pH rises from  7 to 8, and this ion is  a poor virucide.




       Bromine.   Bromine also is a good virucide,  but its usefulness




is still under study.




       U.V. radiatioji.  In  some  applications, physical methods may ce




useful for inactivating viruses.  Even in the presence of some turbidity,




color, organics and other substances  ultra-violet  radiation can be




virucidal (31,32).




       Gaima irradiation.   Gamma irradiation.is  deeply penetrating,




leaves no residual, and is  a  potent virucide. At  the moment, however,




_it is not a practical method  for water or sewage disinfection.






                                 SUMMARY




       A human can be infected by  a single viable  virus excreted by




another hur.ian.  Thus, a single viable  virus in water is a hazardous




pollutant, constituting a danger to health and well-being.  Viruses




have been detected at water intakes along the Missouri River, and



undoubtedly are present at  water intakes along all of our waterways.




Methodology for quantitatively detecting snail amounts of viruses in




large volumes  of  water are  inefficient and urgently demand an accelerated



research effort.




       Investigation  of the problems  of viruses  in water is in its infancy.




The  major problems of what  waterborne  viruses are  important to us, hov




they can be quantitatively  detected and identified in waters of all




     .ities, how effectively  treatment processes remove then, and hov

-------
residual disj-nioctaii-o ±t>- ITl—^.-"ised, and when'ozone  Is used  for  drinking




water, addition of a second disinfectant would be veil directed.



        Most effluents  contain anmonia,  sometimes in excess of 20 mg/1.




 Chlorinating such effluents generally produces only chloramines "because




 eight milligrams  of chlorine react with every milligram of connonia




 nitrogen before the brealrpoint is reached.  Chloramines are slow dis--




 infectants (Figure k [25-2?]) and toxic to fish.  Ozone does not react




 with anmonia, but.it docs react with other interfering substances.




        Iodine.   In water solution, elemental iodine  (12) does not usually




 react with ammonia.  1^ is a slower viracide than hypochlorous acid is,




 but it is a faster virucide than chloramines (lIHCl-^ IJHpCl) are  (Figure  k




•[28,29]).  Moreover, significant amounts of hypoiodous acid  (HOI) occur




 in water at pH levels between 7-5 and. 8.5.  HOI is a much more rapid




 virucide than I2 is (29).  lodate (I0_ ), which form in significant




 quantities from the slow decomposition of HOI as pH levels increase




 beyond 8, are not virucidal.  Iodine ion (l") and triiodide ion  (l, )




 are not virucidal either.  Triiodide ion results fron the reaction of




 elemental iodine and iodide ion.



        Iodine also may be used to disinfect se:/age treated by chemical-




 physical methods.  Ferric sulfate-clarified, carbon-adsorbed sewage may




 retain little turbidity and total organic carbon, but its anmonia content




 is usually high.  In the absence of reducing substances, such waters can




 be disinfected with elemental iodine (Figure k).  Sewage treated with




 alum  and  carbon also is likely to contain large amounts of anmonia, and




 could be  disinfected with iodine.  Extensive studies have indicated that




 iodine  is not toxic to man in the concentrations necessary to disinfect



 water (30).




         Sewage treated with lime has a high pH.  Since high pH makes



       ia-stripping possible, such waters nay be disinfected with 1IOC1.

-------
       In any -'••.   ^  <•--  ••'<• --.a;,;...;.!* procedures remove some viruses and thus




constitute adj0.121,1. ,  ~-.  :> ,•''!„   Furthermore, treatment procedures remove  frc":




water many substar..-..;;  T/,.r;  ;.;:'-21: fare with disinfection and thereby facilitate




eventual total r:-5?r.o-/:J. ;r Jcot'-uction of viruses by terminal disinfection.




Disinfection




       Terminal d_Lsiru :,£;;.-.on is requisite to the production of safe water.




Under the limitations  lupos^d by cost and the uses to which the waters ars to




be put, it is unlikely at this  tine that any one chemical or physical agent




can disinfect waters of all Qualities.  It is necessary today to tailor




disinfecting agents to the  chemical qualities of the waters to be treated.




Thus, the treatment procedure that produces the product water will determine,




in large part, the disinfectant to be used.




       Chlorine.   Chlorine, almost completely accepted as the universal

   •

water disinfectant for many decades, suffers many shortcomings.  However,




when hypochlorous  acid (HOCl) can be maintained in a water, disinfection  is




readily achieved.  Hypochlorous acid is a rapid virucide.  The rapidity with




which it destroys  poliovirus 1 is shown in Figure 2 (23).




       Several years ago, in our laboratory, coxsackievirus A9 vas added  to




an aliquot of an effluent that had undergone primary and secondary treatment,




diatomaceous earth filtration,  carbon adsorption, electrodialysis and chlori-



nation to a level  of less than 2.5 mg HOCl/liter,  The virrs could not be




detected 1 minute  later.  At least 99-99$ of the virus had been destroyed.




This water vas dechlorinated, and later consumed by personnel with no ill effect




       Ozone.  In  those situations where the causticity or toxicity of hypo-
                                     *                                     *



chlorous acid is troublesome, ozone (0.) may be preferable.  Ozone leaves no
                                       *J


residual, decomposing  rapidly into oxygen.  Figure 3 shows that ozone also




is a rapid virucide  (2k}.  Maintaining a drinking water supply with no

-------
Removal of Viruses from Waste and Other Waters by Treatment Processes




       Viruses can be renoved from waters by biological, chemical and




physical treatment procedures.  Most procedures that remove chemical




pollutants also remove viruses, but not always as veil.  Primary settling




removes Uo to 70$ of the viruses in 2^ hours, and almost none in three




hoxirs (Table ^ [18]).  In laboratory studies, activated sludge nay remove




more than 99$ of viruses present (l8), but less effective removal has




been shown in the field (lU).  Coagulation with A^SOi,.)^ may remove 90-




97$ of viruses added to settled effluent (Table 5 [19]), but carbon




adsorption removes little of the virus added to trickling filter effluent




(20).  Ca(OH)2 coagulation, however, may remove 99 to 99-'9$ of poliovirus 1




added to activated sludge effluent (l6).  Alg^O^ and FeCl, (21) remove




more than 90$ of viruses added to river water (Table 6), but effectiveness




in the field has not yet been evaluated.  Cationic polyelectrolytcs may




remove 99 to 99.9$ of viruses added to water (Table 6 [^9,22]).




       Coagulation with lime may produce rapidly virucidal pH levels in




soft waters  (Figure 1  [lo]).








       It is not completely clear to what degree viruses are adsorbed to




carbon and sand, and to what degree they are adsorbed to the microcosnic




deposits on carbon and sand surfaces (1^,20).




       Thus, some treatment procedures remove large quantities of viruses




from waters and some do not.  Usually, laboratory data are more optimistic




than field data are.  The treatment plant coping with various organics,




solids  and  the like is a much  different  situation than  the well-controLLed



laboratory  experiment.

-------
       In order to sample ouch large volumes  of '•;''•-  r  '"	/ - •-- of gallons




had to be trucked to Cincinnati at each  sampling.  Tils "3  a  cumbersome




expensive operation.  Thus, as cur field experic:_• • ..,'. w^sl, we tested




procedures for filtering large volumes of water ir ' >-•  fj';ld and recovering




viruses after transporting filters and adjunct r.a^^le^  t>- the  laboratory.




Comparative studies presented in  Table 3 show that - -emeries  of viruses




were as great from field-filtered samples as fro™ 'Vir.-J.cs trucked to




the laboratory.




       The polyelectrolyte technic is reasonably efficient with poliovirus '1,




but not w'ith any of the other viruses that have been tested.  Poliovirus 1




recoveries often exceed 50$, but  cchovims 7 recoveries are  sometimes




below 30^, and re o virus 1 recoveries are some tines belo-.; 20^ (Table 3 fl^J)-



Dss'pite its low and erratic efficiency,  however, the technic seens to be




the most  sensitive nov available  for studies  of large volur.es  of vater*




Adjunctive procedures developed in our laboratory have  at least doubled




this sensitivity.




       Because many different ion exchange resins can be produced in the




search for raaxinua virus recovery efficiency, these  substances  clearly




warrant the renewed interest they nov: enjoy.




       Osmotic ultrd.filtrat.ion and electro-osmosis.   Osmotic ultrafiltration,




electro-osmosis and other methods are also under study, but  their capability




is not yet clear.  It is not yet  clear either,  whether  we  vail  eventually




attain a  universal recovery systera efficient  with waters of  all qualities,




or whether we will need to tailor the recovery system to the water under



study.

-------
recovery of reovirus 1 nay be achieved In a 3"$ solution of a dehydrated




beef extract (Colab) (l'^,l6).  Efficient recovery of cnteroviruses may




be achieved frora 25 gallon quantities but with larger volumes, recoveries




are now only 50 to 75^ efficient.




       Certain substances, probably organics, apparently coat the adsorptive




oi'ocb oa the luemb runes, and maice tnuu. unavailable to uie virus (1^,1^).




Thus, the membrane filter technic nay be useful for quantitative virus




recovery from tap, renovated, and other clean waters, but even relatively




clean waters may need to be pretreated to renove interfering substances




before quantitative recovery of  viruses can be achieved.  It is  still




to be determined whether waters  of poorer quality can be sufficiently




purified without removing or destroying viruses so that such waters  can




b<; tested with the r.io^brane filter technic.  However, there are  other




filtration methods that offer promise for quantitative  recovery  of




viruses from water.  One such technic is the insoluble  polyelectrolytc,
                                                        *



in essence the ion exchange resin.




       The polyelectrolyte technic.   Viruses in water passed through a




thin layer of  the Monsanto polyelectrolyte  PS  60 nay adsorb to the  poly-




electrolyte and may be eluted with 10$  fetal calf serum in borate  saline




at pH 9-0  (IT).  With  this technic and  other adjuncts developed  during




the  field  experience,  viruses he AT- been  recovered fror.i  50-gallon samples




of river water taken long  distances  from outfalls along the fast-flowing




Missouri River during  the  winter months.  On two occasions we  sampled




 water intakes and recovered  viruses  in  concentrations of 19 and 3  PFU




 per 50 gallons,  respectively,   desc  concentrations are equivalent  to



360,000  and 60,COO  PFU per million gallons of water consumed.

-------
 . ,••  .'£, .T.ocjt  of the  large adcnoviruses and reoviruses Behind.   Peovi ruses

 a_:*  adenoviruses  nay be  recovered from effluents "by precipitation with


 protamine  sulfate but thiu technic leaves most of the umall picomavirj^


 behind  (7).   The  two methods nay be used together to recover r.ost of  the


 viruscsin  all of  ther,e groups.


        Phase separa Lion.  The phase separation oecimic  (8-10), has an


 overnight  time requirement for completion.  In phar.e separation  socliun


 dextran  sulfate and polyethylene glycol are ni;;ed vith  a  sarriple  and allo


 to separate.  The viruccc are then recovered frcn the lower bottom phase


-(dextran)  and inle'rphasc by precipitation with KC1.  Tlie  raethod  riay not


 be efficient with all viruses (ll), but recent studjes  have been more


 encouraginQ (12).

   .    The Al(OH)o-prota:uir.e sulfate and the phase separation methods


 accoranodate only limited volumes, and neither method is completely


 efficient.  From test to test, both may suffer variations in efficiency.


 But, both  technics  are adequate for many purposes, and when only small

 volumes  have to be  tested, these technics may be useful.  V/hcn large


 volumes  must be tested, Mother methods must be sought.

        For large  volumes of vater, the best approach would seem  to be

 a filtration system.


        The membrane filter technic.  The membrane filter  technic (13)

 consists of filtering vater through 0.^5 ji cellulose nitrate membrane


 filters.  Viruses may adsorb to these filters and then be eluted from

                                               f
 then.  Adsorption of viruses requires the presence of salt (LV,15), and


 is greatest at pH 7 (1*0-  Complete recovery of enteroviruses, and 8c$

-------
amounts, and produce in those contacts recognizable illnesses.  Although
such transmission of viruses has an essential water link, the spread  of
infection and disease in this fashion vill appear to be by the personal
contact route.  The disease rates in secondary contacts might well be a
much better indicator of source than the disease rates in water consumers
          y_
themselves .  Such may also be true for bacterial infections and diseases,
because the major concern in this area has also been with disease and not
with infection.
       Since a single PFU of virus is capable of producing infection  in
man, we must be able to detect that amount in relatively large volumes
of water.  We have set as a tentative goal detection of 1 PFU of virus
per 100 gallons of water.  Thus, we must develop this kind of detection
capability.
                                                                        >"
Recovery of Viruses fro:" V/aters of All Qualities
       The recovery of 1 PFU of virus from one-hundred gallons of water
or more will require better concentration procedures than those available
today.  We must develop the capability for complete recovery of viruses
from vaters of qualities ranging from raw sewage to completely renovated.
       Aluminum hydroxide adsorption and protanine sulfate precipitation.
Because relatively large amounts of viruses are usually present in sewage
and in effluents, only small volumes usually need to be tasted.  In these
situations, technics are already available, but they cannot be readily
adapted to large volumes.  The Al(OH)? adsorption procedure (^,5) in
                                     J     t
which the virus is adsorbed   on   an  Al(0!l)o   gel,  may  recover

toost  enteroviruses  in  sewage effluents  (^-6),  but  the  method
 y,
  In controlled studies where controls consume sterile water

-------
such as nilitary training  car.ps,  and institution:;.   Some ccrct^es



produce acute epidemic keratoconjunctivitic,  a  serious  eye  disease,



some can produce cancer in certain laboratory onir.:-ls.


                                   *
            irpses .  The reoviruses , conprisinj -J-.ree serotypos, have
been associated with  respiratory and enteric diseases.  One type has beer.



reported to produce cancer in baby nice when the virus was inocuLut.su in



very sr.£ill concentration:: .



       Infectious  hepatitig virus .   The virus of irfectious hepatitis has



yet to be grown in laboratory cultures, and remains something of an



enigma to this day.



       Most of these  viruses produce asymptoroatic infections nest of the



time.  Only occasionally do they produce disease.  Infection is sc cc~:r.c~,



   ..-evcr, that the  avount of disease produced is significant.




The Hazard of Viruses in _'./ater
              amounts  of viruses entering rivers and streams with vaste-



 vater ai-e  a hazard to those downstream v/ho use these craters.  Even a fe'.,r



 virus particles  in 100 gallons of river water would constitute a hazard,



 for the amount of virus in the total voluxe of water entering the intakes



 of even a  small  city  on any day would be considerable.



        Because snail  amounts of ingested viruses are likely to produce



 infection  but not disease, it is likely that snail amounts of viruses



 could be present in water and go undetected.  Individuals infected with



 snail amounts of viruses nay show no signs, but they nay excrete large

                                                f
                                   »

 anoints of viruses.  Thus, they nay infect their contacts with lar^e
   bo is  an acronym for respiratory,  enteric orphan.

-------
These viruses may also produce aseptic meningitis, and various minor



disorders as well.

                                              *
       Coxsackievlrus A.  The coxsackievlruses  of group A  comprise almost



30 serotypes all of which produce characteristic lesions in newborn nice<



Sortie of these viruses produce herpangina, aseptic meningitis, and rubella-



like rashes in nan.



       Coxsackie virus B.  The coxsackievlruses of group B comprise six



serotypes^ all of which produce  characteristic lesions in newborn nice



that are different from those produced by coxsackievirus A  serotypes.



All of the group B viruses  can cause  aseptic meningitis in  man.   Viruses



of this group also may produce acute  infantile myocarditis, pleurodynia,



and other disorders in man.


                                        •£•£
       EchoviruseG.  The echovirus _group    nov consists of  more  than  30   ^



.serotypes.  Members of this group can produce aseptic meningitis, diarrhea,



rubella-like rashes and other ailments.



       The polioviruses, coxsackieviruses of groups  A and B, and the  echo-



viruses, belong to a major  group of viruses, the picornaviruses"1". Tvo



other major virus groups are significant in water,  the adenoviruses and



the  reoviruses.



       Adenoviruses.  The adenoviruses are  a group  of larger viruses



 consisting of more than  30  serotypes. Members of this group are responsible



 for  many of the respiratory diseases  of childhood.   Other serotypes



 produce  acute  respiratory disease outbreaks in closed populations
  *

    Coxsackie is the name of the community in New York State where these

    viruses were first discovered.

 *-*

    Echo is an acronymibr enteric,  cytopathic,  hunan,  orphan.


    Picorna is an acronym for pico-small,  ma-ribonucleic acid.

-------
              VIRUSES IN WASTE, HS'IOVATSD, Ala) OT^_T. '..'.'.TER3*

                                          Y V
                               'Gerald Berg



       Many viruses are excreted r.."ith the feces of infected  individuals.


These viruses multiply in the alimentary canal of man, or have  access  to


it.  With viruGes of animal, plant, and bacterial origin, they  abound  In


sewage and in receiving rivers and streams.


       The numbers of viruses of human origin in water are small when


compared with the numbers of bacteria excreted by man.  Viruses do  not


multiply outside of living  susceptible cells; thus, viruses  decrease in


numbers in the receiving waters.  The importance of viruses  in  water,


however, does not stein from numbers.  Rather, their importance  is manifest


in their ability to infect  man when present even in small numbers.  The


smallest amount of virus capable of infecting our most sensitive indicators,


cells in culture, is usually capable of producing infection  in  man  (Table 1


[1,2]).


       Because such minimal amounts of viruses can produce infection in


man; the total removal of such viruses from any water that man  might


consume is Justified.  The  viruses of human origin that occur in water


and are of major concern to us are shown in Table 2.


Viruses Important in Water


       All of these viruses can be differentiated from each  other


serologically and, to some  degree, by other means.


       Polioviroses.  The polioviruses consist of three serologically


distinct types each of which can produce paralytic disease in man.
 *
   To  be presented at the Advanced  Waste Treatment and Water  Reuse
   Symposium,  Chicago, Illinois, February 23, 1971.
*-*
   Chief of  Virology, Advanced Waste-Treatment  Research Laboratory,  Water
   Quality Office, Environmental Protection Agency, Cincinnati, Ohio

-------
VIRUSES IN WASTE, RENOVATED, AND OTHER WATERS

                      By

                 Gerald Berg
      Environmental Protection Agency
           Water Quality Office
          Cincinnati, Ohio 45226
              February, 1971

-------
hi.   Sturtevan.r,  A.B., and T.':\ ^eary, Incidence c/ . /1.-'Ctious Drug
     Resistance among Lactose-forcer,tinr Bacteria .  .0^.-;.^ed  from Raw
     and Treated  Sewage, ,\op.  Micrcbiol. _!£, Si?.  '^39.

12.   Keard,  T.K7., Housing and Salmonella Inf^c ti-jn.s, The Vet. R,= c. '85,
     432, 1969.            -  "

13.   Prost,  E.  and H. Riemann, Food Borne Salir.oneT. 1 osis cited in Ann.
     Review  Microbiol. 21_, 504, 1967.

in.   Rankin, J.D., and R.J. Taylor, A Study cf ^rr- Disease Hazards
     which could  be associated with the syst^/Krcf applying"  Cattle
     Slurry  to  Pasture, The Vet. Rec. 35, 573, iii6S~.'

15.   Shuval, H.I  , Inactivation of Ent-eroviru .e^ in Sewage  by
     Chlorination  Adv. Water Pollut. Res. Proc. Int. Conf. 3rd, 2_,
     37, 1966.

15.   Duff, K.F.  Isolation of Ether-resistant Enteroviruses from Sewage,
     Methodology, /pp. Microbiol., 1_9, 120, 1970.

17.   Wallis, C.,  Concentration of Viruses from sewage and Excreta on
     Insoluble  Polyelectrolytes. App. Microbiol., IB, IC07, 1959.

     Lund, E.,  and C.E. fledstrom, A Study on Sampling and Isolation
     Methods for  the Detection of Virus in S-ewage, Water Res., _3_3 .
     823, 1969.

13.   Shuval, K.I., B. Fattal,  S. Cymbalista and N. Goldblum, The
     Phase-separation Method for the Concentration arid  Detection of
     Viruses in Water, Water Res., _3, 225, 1S69.

     Randall, C.W., and J.O, Ledbetter, Bacterial Air Pollution fro.:.
     Activated  Sludge Units, Am. Ind. Kyg. Ass. 27, SOS, 1S66.

     Coler,  H.A.j and H.B. Gunner, fficrobial Populations as Determinants
\     in Protozoa  Succession, Water Res., 3, 1^3, 1S69.

I
p.   Curds,  C.F.  and G.J. Fey, The Effect of Ciliated Protozoa on the
I     Fate of E. coli, in Activated Sludge Process, Water Res. , 3,
|     853, 1969.       •

p.   Grabow, '/'.O.K., N.A. Grabow, and J.S. Burger, The  Bactericidal
     Effect  of  Lime Flocculation/Flotation an a, Primary Unit Process
     in a Multiple System for the Advanced Purification of  Sewage
     Works Effluent, Water 3es., 3, 943, 1969.

-------
           If  sludge  is maintained at pH 11.5 for 1 hour the Entero-

 tacteriaceae  is  reduced by more than 99°.   On the other hand the

   jn positive bacteria are not destroyed at this high p:I (23).

 Chlorine  will red_ce the sr>Iiform noun-, tc le-:s t-'i:-.r. 100 p = r 1P0 .TL!  in

 >  hours cor.~2.ct  TLre with f mg chl-ri'ire pir liter '15).  However the

 coliforr:  court .7:ay r.ot give ar- accjrate ylctu-e o; tht death of th-

 other pathogens.


           In  conclusion, I would like to stress that micro-organises

 are  very   aggressive and hardworking individuals.  Under proper

 direction and control great benefits ray b..; derived from .these silent

 s-orkers .


                               References


 1.  Jones, J.G.  and A. Williams,  Hydrocarbon Biogenesis, p. 11, cited
     in Microbiology, The Institute of Petroleum, London, Ed, P. Hepple ,
     1967.

 2.  Johnson,  M.J., Utilization of Hydrocarbon by Micro-organisms,
     Chem. and Ind.,  p. 1532, 1964.

 3.  McAuliffe, C.   Solubility in Water of Normal Co and C10 Alkane  Hydro-
     carbons,  Science 163, 478, 1969.

 4-  Halvorsor., H., and \*. Ishaque, ricrobiclogy of Domestic Waste,
     III.  Metabolism of LAS-type Detergents by Bacteria from a
     Sewage Lagoon, Can. Jour. Microbiol., 15, 571, 1969.

 '- 'Humphrey, A.E.,  A Critical Review of Hydrocarbon Fermentations  ar> <
     their Industrial Utilization, Biotech. Eioeng. , 9_, 3, 1967.

 *   Halvorson, H., H. Ishaque and H, Lees, Microbiology of Domestic
     V'astes, II.  A Comparative Study of the Seasonal Physiological
     Activity  of Bacteria Indigenous to a Sewage Lagoon, Can. Jour.
     Kicrobiol.,  !_§_, 563, 13G?.

  •'•  Liu,  D.L. and P.M. Townsley, Pulp 'till Lignosulfonates in  Potrolei'  .
     Jour. Water Pollution Control Federation 1S7G.

  *•  Jeris, J.S.  and P.P. Cardenas, Gluccso Disappearance in Biological
v     Treatment Systems, App. Hicrobiol. 1H, 857, 1366.

\  Y<  Wiley, B.B.,  and S.C. Westerberg, Survival of Human Pathogens  in
;     Composted Sewage, App. Hicrobiol., 18, 99^, 1^69.                  A
!-                                 /     ~~                              w
i     Prakasam, T.3.S., and N.C. Dpndero, Aerobic Keterotrophic  Bacter-j  .
     Populations of  Sewage and Activated Sludge, II. Method of  Character-
     ization of Activated Sludge [Bacteria, Applied Kicrobiol. IS,  1122,  '! 9
                                 '

-------
      of  sewage  treatment systems.  The measurement of the coliform
   anisms  in  chlorinated sewage may not give an indication of the
inactivation  cf the  more resistant virus (15).  The virus particle may
occur  in free form or be combined to organic sewage debris.  The
concentration of  virus in raw sewage can be as high as two infectious
particles  per milliliter (1&).  '"

    To  assay the virus content of sewage the virus can be
isolated   and concentrated by a number of techniques (17, 18, 19).
following  isolation  the virus concentrate is inoculated onto animal
V.idney cultures and  incubated for 10 days.  The number of plaques which
appear are a  count of the infectious virus particles.

    The health hazard of wind-borne bacteria from activated sludge
•j.r.its  is also of  interest.  The bacterial population of air is increased
•~y passage over an activated sludge «aste treatment unit.  For example,
The bacterial count  has been found in one particular sludge unit ~o be
about  8 per cubic foot on the upwind side and 1170 per cubic foot on
    downwind  side (20).  In  this latter case the family Enterobacteriacea=
represented 19% of the total bacteria in the aerosol of which Klebsig_ll-'i
a known respiratory  tract pathogen represented 6':.  In fact, the Kleb.tj.-ill ^
is the best indicator cf bacterial air pollution from seva^a sources.
'"Undall states "that a man working 5 feet off the downward edge of an
Deration tank when the wind velocity is 10 mph, perhaps taking a sludge
sample, could be  expected to inhale a. viable Klebsiella every two breaths.
~'r-2 bacterial death  rate in the aerosol will depend on the resistance
-• the organism tc desiccation  re.ngir.jj frcm a maximum dea ;h rate at -.7
-1- 1.0 seconds after emission tc a Icr.g undetermined survival time

    Since many sewage or waste treatment designers have not been
^so concerned with the health hazards of sewage the reports dealing
-'ith control  measures are not too numerous.  In the activated-sludge
 :--t we know  that the ciliated  prctor.oa .ire principally responsible
•°r destroying £. coljL and possibly other bacteria (21) , as well as
   -roving  the clarity of the effluent (71).  If the sludge is composted
   -r  aeration -_r.d tr.e temperature of the compost ranges between 60°-
'- C,  the  poliovirus is inactivated within the first hour, Salmonella
 'V3 of Ascaris and Candada albicans are inactivated within 43 hours (3).

-------
      have been artificially or naturally contaminated contain  viable
         a for one. week following application (13).
          Cattle slurry which consists of a mixture of faeces  and
urine with a minimum of bedding material all suspended in a  large
quantity of water is a source of disease transmission.  One  hundred
cows produce approximately 20,000 gallons of this slurry per week.
Salmonella dub 1 in ,  Salmonella typnimurium , E. coli , Staphlococcus  aureus
and Bruce 11 a abortus survived for at least eleven weeks in the  slurry.
Two additional pathogens found in faeces , Mycobacteriurn tuberculosis
2nd Mycobacterium j ohne i ,  survive in the slurry and the pasture for
t:any months (1H),  Mono of the above bacteria however, were  found  to
r.ultiply in the slurry.  The spore formers-, Clostridium tetani  commonly
found in cattle faeces and Racillis anthracis may build up.  The anthrax
bacilli are excreted from the animal a short time prior to death and
thus can gain access to the cattle slurry before the disease is
diagnosed.  If this infected slurry is now spread in the field, the  soil
 'ill become perr.;an-3ntly contaminated.  Two other diseases dangerous  to
..<3n may be found in cattle slurry ; 0 fever and leptospirosis .   Q fever
•'hich causes a fever often accompanied by pneumonitis in man can be
3pread by wind in a dry aerosol form from a rain gun and leptospirosis
can infect humans via several difficult  routes and causes infectious
"jaundice.  This latter organism in sewage has been known to  enter
';ater courses and swimming areas..

          In addition to the above diseases, the Helminth parasitic  wcrrcs
"«y also be spread to man and animals through sewage .  The ova of
linear is lumbricoides is commonly found in sewage.
                     *

          The virus of the highly infectious foot and mouth  animal
 -isease is excreted in the faccas of tha animal before the animal  is
                                             4
 clinically ill.  This virus should 'survive for a short period  at
      in  cattle  slurry.
          Rec?r,tlv th^r^ har  Lc^n  \ growing  interest  in  t.h?. . determination
 •* vivus '^cirziclab In 3 2'.--\;;.;e .  These  tests c.c::  time: consuming and
  "Serious bui" certainly necessary  to  determine  the potential health

-------
      b.   Physical health effects.
      The  physical health effects  relate  primarily  to  the  lung  but  also  ru?y  have
 an  effect on  the  heart  and  other  organs.  The  lung  is  the  body's  filter  and  as  the
 two types of  materials  which  are  of great concern  in  ror^rd  to the health question.
 The first relates to  the problem  of gases produce-'.,1.   P<"« produced from a  sewage
 plant include the nitrogen  compounds,  particularly nitrocjc;.  dioxide,  hydrogen
 sulfids and sulfur  dioxide, carbon monoxide,  carhv, dioxide, i.urcaplc.-is and others.
 Studies carried out by  our  group  at the  University of Illinois School of Medicine
 in  the section of Environmental Health in the Department  of  Preventive-  f';dicir.£
 have reveaUd thtt  in the presence of air pollutants  as measured by sulfur  dioxide,
            tdth  chr$*ri£ bronchitis have twice as  many days  of illness  when the
                  are  greater  than 0.2  ppm than they do when  the  pollution levels are
                levels of SO*  expected  from this plant will reach a  maximum  of
 OK23 flfflk  1$ e^si^Hng the levels of  gaseous pollutants to  which  individuals
                      ^^
 wt))  fe§ S«r^t€t^»  ©fl<£  must consider not  only what  conies  from  the plant but also
 ttt^t  t$ tft tfte e$«»«ftity.   K'hile  very  few measurements have  been made,  the  levels
 ef SO^  in the  ambient air from other sources  already  is close  to or exceeding those
 standards  which have  been set by  the State.  Addition of  the gaseous material from
 the plant  will at times cause levels far  exceeding  those  considered safe by the
 federal government as set down by  the Air  Quality Criteria for Sulfur Dioxide
 (Air Quality Criteria for Sulfur Oxides,  Dept. of Health, Education and l.'elfare
AP-50),
     In addition to  the gases, participate will emanate from the pl?nt as a  result
 of burning.  Many of these  ga.ses will become adsorbed by the  participate which also
 can travel longer distances  eventually releasing the gases after they are inhaled
 into the lungs of individuals.  The effects of these gases are  as lung irritants.   They
 cause interference with  and  ultimately destruction of the protective mechanisms
of the  lungs,  including  the  mucociliary apparatus  which is a  system for  clearing
 irritant and infected  particles out of the lungs.   In  addition, they cause inflammation
and swelling and therefore narrowing of the air passages  of the lung and in
 individuals who are  sensitive, spasm of these  air  passages with further  narrowing
which is the body's  way  of resisting the  intrusion  of  irritant  substances.   In
addition, recurrent  irritation from these gases results in the  development of
very thick mucous  in the air passages  which cause plugging or blocking of smaller
air passages,  also reducing  the ability to move air into  and  out  of the  lungs.

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                  or'1 TJ^LTI-TOIS
                                                 January 18, 1971

Mr. Martin Warner
Dear Sir:
     At your request I am responding to the question set forth by Mr.  Gary Schenze'i
of the Water Resources Planning Branch of the U.S.  Department of the Interior.
Question I is, "What is the probable impact of the  project on the environment?"
It is contemplated that the present 4 million gallons per day treatment plant be
enlarged to an 18 million gallons per day treatment plant.
     a.  Odors
     Even at the present level  of treatment a significant area in the surrounding
community is subjected to unpleasant odors from the hydrogen sulfide mercaptans    I
and other gases produced by the sewage plant,  This is particularly true during
the summer months when many individuals are outdoors, sit in their yards, work in
their gardens, prepare food outside, etc.  If one defines health, not merely as
the absence of disease but as a state of physical and mental well being where
individuals can function and enjoy the fruits of their labors, (the definition of
health of the World Health Organization) one can see that there is already an
impact on the health of the community.  In addition to their being vifthJeasar.it
odcrs, many Cctui=e Increased irritability of  individuals.  Some individuals who
are odor sensitive can suffer significant effects on health in that they tend to
have reduced appetites and gastrointestinal  distress.  In addition, intrinsic
asthmatics who are environmental hyperreactors and do react to odors and have
an accentuated negative response to them in  regard to health.  The increase to
an 18 million gallons per day plant cannot help but increase proportionately  the
odors emanating from the plant.  This will not only intensify odors for those
                                                    I
already  being exposed, but will  increase the area of exposure to include more
citizens.   It should be further  noted that a significant  number of schools are wi Li
a half to one mile of the plant  and in  the direction from which the wind blows.    |
a majority of the time (that is  they are east of the plant).  This cannot help but
interfer with student concentration and ability  to learn.

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The argument thai epj ciouiioloy j ca 1 re 3 a t ionr,]'i Jps  have  not  been
proven is not valid.  The work has sJmpJy  not  yet  been  done.
Let us conn ( our.sulves .fortunate  that  our  U.S. Public Health
Service did not wait for definitive proof  before taking
measures to protect our population.  They  brought  sanitation,
quarantine and preventive measures Lo  boar, in some instances',
before germs were related to disease at  all.

Hopefully the Knvironuentril Protection  Agency  rill take the
same "reasonable doubt" attitude  and agree that  potentially,
sewage trontj.ioni in the immediate vjcinity of  human habita-
tion is a tenuous .situation.  When recognixed  as such,
expediency will not be allowed to overcome the public welfare.
                                     Martin  ft.  Rogo'f^/Ph . D.
                                     1563 Robin Hood Place
                                     Highland Park,  Illinois  60035

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4 .   Transforrablo drug resist;   :e in on t ori c b:-.ct cria :

Another factor which should 1   mentioned is that the enteric
bacteria possess the quality f   being able to exchange drug       .
resistance properties between members of a viable population-1—---^/
The genetic factors responsib]c for resistance to certain drugs
in these bacteria are extrachr ;mosomal in  nature and are termed
episomcs.  The phenomenon is termed episomal transfer of drug
resistance.  The chances for transfer of drug resistance
characteristics to non-drug resistant  members of the enteric
microflora in a high population density of enteric bacteria
such as is encountered during sewage treatment would be
excellent.  Replacement of non-antibiotic resistant micro-
flora by antibiotic resistant strains in humans exposed to
this transformed population would be a secondary hazard of
potentially high danger.  This danger is particularly insidious
since it would not be observed until antibiotic therapy was
required.
            \
             v—
IV.   THE QUANTITATIVE EFFECT,  A SUMMARY STATEMENT

The preceding statement is not intended to be interpreted
as a dire prediction of total deterioration of our local
environment in terms of health and habitability should
an improved sewage treatment facility continue to operate at Clavey
Road.   It is intended to point out that such a facility does pre-
sent certain  hazards to health. They are biological and chemical in
nature. They are inherent to the sev/age treatment process and
the nature of the material being processed.  There is an ever-
present danger that due to malfunction of any nature, an
episode of disaster proportions can occur.

The level of possible deleterious effects is quantitatively
related to the amount of sewage treated.   This should be
self evident.  Any increase in the capacity of the Clavey
Road plant will proportionally increase the hazard potential.

It would seem then that the utmost consideration should be
given to halting further expansion of the facility.  If it
is agreed that the possibility of a health hazard exists,
that total lack of health hazard is not currently demonstrable
and that sewage treatment by its very nature cannot benefit a
residential area, but potentially can threaten it, then the
only conclusion to be reached is to remove the facility, or
at least not expand it in the environs of a high concentration
of humans.
7T7	
-^Anderson  (1968) Ann. Rev, Microbiology 22,131.
JJL/
   Smith & Linggood  (1970) J. Gen. Microbiol., 62,287.

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 traii.slorian 1 i on it ml pK./.'x'y Lojis .   Most import ani are stu>:i,'/s
 which have dcmonst ra {.ed  thai  cellular and humora] in.iau.1! .'. ( }'
 can be independent .1 3' affected.  Thus a virus (LDV) vhich
 depressed cellular i-'-^v^j ly ai;L;;non tod humoral i:n;,:u;i.; i }• .
 Another (VL'i") did not  affect  cellular iiMiumity but auj.men (. cd
 humoral.  Another, Gross  leukemia virus,  dcpj osr-:ed both,
 This has important implications pertinent to continuous  (or
'discontinuous) exposure  to  lov; levels of  virus.  Do pros. si on
 of huir.ora 1 irmnun .1 1 y  c o v ild Lia]:.^_ the? host i.-iore susccp t j hlo  to
 other Infect j ous apyon^ ? .  i^Ti^riJ?J^ii_^L:'_ co jj u] a_r_ i j^.'.uin J_t y
 would iov.'cr c»paj lity 1 o r e j e c t  ina I i fj:na j) 1  c o .1 1 s aj ) d
            _   _                                    __     __.
 potent iate tumour ini Li a ^ipt1-  raid  gj.\ov/^h .   Cellular immunity
 depression could also nake  the  host less  able to reject  virus
 infected cells opening a  path toward establishment of chronic
 virus infections.

 The  desirability of creating  an environment designed to  expose
 us  to low levels of viruses seems  at the  very least questionable

 %•   E f f e c L of v/a s I c - do r i y e d c hem ic a 1 po 1 j u t , a nt '.?. _ on hos t  sus-
     cep t i b i 11 1 y :   it should be  noted that  cheinj cal ~poJ lu rants
 associated v/ith the treatment of  sev/ag'e such as N02 ,  S02 , and
 as  had originally bean proposed for use in the Clavcy Road
 facility, ozone,  have the effect  of increasing human suscepti-
 bility to infection by the agents  of numerous diseases.  The
 effects of these pollutants on  infect ivity of pathogens  are
 again well documented in  the  National  Academy of Sciences'
 report "Infectious Disease in Banner Space Flight". •&

 3.   IsTi trous acid as a __rmt;a gen :  it should  also be noted  that
 N02  vhich in aqueous solution forms nitrous acjd, is a known
 mutagen.  Mutagenicity of nitrous  acid is  documented in  the
 references below,5_iif..'_Lliif/  and  in matter of fact, nitrous
 acid is used routinely as a mutagenic  agent in procedures for
 mutation of microorganisms.   This  represents an additional
 hazard since .mutation of  an avirulent  microorganism to a
 virulent form is highly probable,  particularly in view of the
 largo numbers of microorganisms of a potential]}' pathogenic
 nature present in sev.vtge.
 jS/See rcf's page 131 !\?o's 113-143  in  Bibliography of Appendix A,
   page 102 in Infoctjous Disease in Mannojr Space F-l_ij;lrt, National
   Academy of Sciences, V/ashington, D.  C.  1970.
 ^/Tessman, Pod da r & Kumav (1964) J. Mol.  Biol.  _9,352J
 JLOKaudev/itz (1063) Biochem. Bi ophys.  Res.  Comm.  11,  41G.
       wetter & Schuster  (I960) Z.  Naturf.  156,304,

           (1960) C, R. Acad. Sc. Paris 250,1134.

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    hit activated slucigi; process is an acrobjc; proci .v.y and
requires the entraininen i  of air into 1 he sewage being treated.
Recycling, pumping, water turbulence are necessary components
of an activated sludge process.  Such processing then results
in aerosol formation.  One need only observe a large plant in
operation, such as that in Stickncy or Milwaukee, in which
the acrosolization effects are visible to the naked eye.  Note
that there is no case presented demonstrating microbial pathogen
loads or lack thereof Jn air surrounding sewage treatment plants
Such monitoring is n_p_t_ routine.

    As f.or entry of pathogens into ground waters, this is en-
tirely possible in any situation where retention basins or
effluent lagoons arc not structural elements but are excavated
from bare earth.  Loss of water from tiie effluent lagoon comes
about as a function of evaporation and seepage of water through
the underlying soil.  In the case of the Clavey Road plant, in
an area whore the water table is quite close to the surface,
chances for contamination of ground water from bare earth
lagooning should be extremely high.

C,  Se c o nd a ry f a c tors bearing an epidemiology of waste-
    associated disease

1.  The immune response to virus infection:  it was suggested
by Dr. Dinehart, a witness for the League of Women Voters at
hearings of the Illinois Pollution Control Board, that perhaps
exposure of the local population to viruses might be beneficial.
They would develop immunity to a vario-ty of viruses.  The
opinion was echoed by Dr. Slade, Microbiology Consultant to
the City of Highland Park.  I sincerely hope their testimony
was not offered in all seriousness.

Let me respond quickly to the foregoing, first as to the
quantitative nature of the infectious process.  Reactions in-
volving the immune response are diseases and the numbers game
is being played as to which takes command, the infecting agent
or the host's immunologic mechanisms.  It is chancy enough,
viz. influenza or rabies vaccines, to attempt immunization
under con ("rolled dosages.  The idea of j. cui'luin exposure to
unknown quantities of virus is unthinkable as a desirable
feature of a sewage treatment stream in your own back yard.

Further, the individual who forwarded this idea is apparently
not aware of recent literature pertinent to the effects of
virus infection/on immune response.  1 suggest reading of
Notkins, el al-2-  , who indicate the differential immune response
effects of viral infoetions..  These authors point out. first
that viruses can influence many parameters of immune function
including antibody production, immunoglobin levels, induction
of immunological tolerance, delayed skin reaction, lymphocyte
 — Notkins,  Mergcnhagcn  and  Howard  (1970)  Ann.  Rev.  Microb.24,525

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3,  Ph.y_sj._ca.1	y,cc_t_o_rK:  Hank also provides additional  reference
to physical vectors, e.g. airborne solids, direct  contact  and
contamination of food and water supplies.  The associations
treated in this 1J tornturo survey leave little doubt  as  to
the existence of epicle;niological hazards related to sewage
handling.

Let us consider airborne solids further.  The literature  relating
to the survival of bacteria and viruses in aerosols is vast.
Much of the literature on the subject has been compiled  by the
federal scientists at the U.S. Army Chemical Corps Center  at
Ft. Detriok, Frederick, Aid.  This literature, much of which
is restricted, is particularly important since the microorganisms
studied were almost universally those associated with human
disease.  The survival of bacteria and viruses in  aerosols is a
subject of continuing concern and s.tudy.  Documentation  can   /
most simply be initiated by backtracking from Ehrlich, et  al.4"
This reference^is quoted not for the survival data of the
F1 a voba c t e r i inn , a coi.unon soil and water organism, which  it
contains, but simply to demonstrate that the aerosol  survival
problem is well recognized and is the subject of continued
and on-going research.  A rather complete bibliography on  the
subject of airborne pathogens was developed in association
with study of the airborrc infection hazard associated with
manned space flight.  These references appear in the  biblio-
graphy of the National .Academy of Sciences' publication
"Infectious Disease in Manned. Space Flight "/and is available
from the Washington office of that agency.    It is also
possible to document that fecal organisms represent a potential
hazard in their ability  to survive in an abnormal  environment,
e.g. that of respiratory tract.  The transfer of fecal organisms
to the I'espiratory tract of humans as a result of  malfunction
of a sewage disposal system, in this case in a- submarine,  can
be documented by the work of V/atkins, et al,   who reported
their studies to the American Medical Association  in  1964.

    Lastly, it should be pointed out that aerosolization  and
air-transmission are not the sole means of transmission  of
pathogens.' The aforementioned vectors play a role as docs
seepage of sewage through soil to ground uater, hence drinking-
water supplies.  Entry of effluent to water supplies  also  pre-
sents a possible hazard.  Are these modes of transmission
inherent to the operation of a sewage treatment plant?   The
answer must be, YES'.
 -  Ehrlich.. Miller and  Walker  (1970)  Applied  Microbiol.,  20,8S4 .

 -' See Rcf's page 131 No's  90-112  in  Bibliography  of  appendix  A,
   p  102  in Inf cc ti ous_ DijLcr^pc  in  Manned  Space  FHgjit_,  National
   Academy of Sciences, Washington, D. C.,  1970.

   Watkins, et al, Abstracts A MA ^National Meeting,  June 22,1964.

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 of anaerobes due to thoir extror :- 1 <,  [ as i i d j ou.s  ualr.ro .in re-
 gard Lo free oxygen ,   Thus, tlio > a.jor in i crub t al  elements of
 fecal wjcroflcra are not be-in;/, c^ns i uorril in  del ei'tni nn1 j onr;
 of the m.icrob.i o'l ogi cal quality of  sev. ago  .in j luen Is and
 effluents,  or for thai matter in es t imu I ion of  water  supply
 potabili ty.

     It should further be noted that  microbiul  load in a
 treatment plant influent, includ
 not a constant.  It will vary wi
 seasonal variations, general hoa
-of admixture v/jth industrial was
 port.  In other wordy, the dynom
ng pathogenic forms,  it-:
h climatic1 conditions,
th of the commim i ty,  effects
e and holding time  in  trans-
c quality of the  influent
 referred to iu section II holds  or  the  pathogenic load.
 Even without precise data; the seasonal  appearance ol v/ater-
 born.e epidemics of "intestinal virus  disorders" and similar
 diseases attest to the dynamic aspects of  effluents.   The
 persistence of the causative agents  can  be related lo the
 potential health hazard in a quanti 1 a t j v-c  way.   A plant
 operating at 90% efficiency will release infective agents in
 the effluent in direct proportion  to  their presence in the
 influent, all other factors being  equal .  The actunl  pathogen
 load then would be a function of original  numbers, plant
 efficiency and amount of waste treat cc'i.   This is a moi.--, I im-
 portant point in tli3 context o.f this  particular problem.      ,

 B .   Relation of di so a s_o_s t o wji_s t e  d i sjx>_s_a_l_

 1.   Related diseasc-'S:    the relationships  betveen disease
 and solid waste has been well documented in a bibliography
 prepared for the U.S.  Department of  Health,  Education and
 Welfare in 1967 by Haaks.    The listings  are reasonably
 complete and among human diseases  associated with human fecal
 waste he mentions cholera, sh.i gt llosis,  tuberculosis, typhoid
 and paratyphoid f overs, ai.io-o-bic ciy?;on I cry  and othov pro t oxc.'1 :i
 infections, coccidiosiy, i nfec t. ou;-  lic.patitis,  pel j or:\ ol i tls
 arid holmauthic infestations.  Rc-iorences arc also Riven to
 diseases deriving from animal focal  v.astes,  e.g. anthrax  and
 miscellaneous fungal diseases.  Enteric  viruses should cer-
 tainly be added to this list.

 2.   Biological _voctors :  the role-  of  ^vectors in transmission
 of waste-associated pathogen to human  hosts is also document'
 with particular emphasis on flies, mosquitoes and rodents as
 vectors.
   Haaks  (1967) Sol .id Was t e/Di sea so  R'_> 1 a t ioashps
   Cincinnati

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 7.   Increases in HOD nig hi indira-le diH'rt.-.'isc.s  in primary,
     secondary,1ertiary .-saprophyte activity, increased
     predator activity, deeronso in f > occula (. ion by  the
     sludgf.' oi\?,ani.-.i'i.s or a popu7a tior shift  io  organ .i smc;
     having poor settling charact er i .-? . ics .  Thu number ob-
     tained ar. effluor.t £OD cr.nnot tell us which.  In short,
     BOD has no prcd.ictive or insight value into the biolog-
     ical aspects of the sewage treai::cnt process.

 Thus, the BOD criterion cannot be usred as de. z/

     Among the members of the infectious microbial population
 of  sewage with  which we are most concerned would be the enteric
 bacteria, both  aerobic and anaerobic, the enteric viruses and
 other viruses such as the causative agent of hepatitis.  I
 would like to point out in regard to these forms that current
 methods used in  microbiological evaluation of sewage treatment
 cling to identification of colifonn bacteria as indicators of
 fecal flora persistence.   Future concern may not lie with
 this group of organisms.   The recent work of W. C.  Moore at
 Virginia Polytechnic Institute has demonstrated conclusively
 that colifonn bacteria are a minor component of the human
 intestinal microflora.   The bulk of the bacteria present in
 the gut are obligate anaerobes including various pathogenic
 and "opportunistically pathogenic" species.   The presence of
 these anaerobes  is not disclosed by colifonn counts, and may
 not even be revealed by some common techniques  for  culture
 -Rollins (19C6)  Advances  in  Applied Microbiology £,145.
 •'Pipes  O9GG)  Ibid.,  77.

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sewage treatment, system i.v- r> li-uo "in stream" process,
dynamic as opposed to static in nature, responsive to changes
in the nature of the inlluont, and in practice a complete
malleable ecosystem.

      Operators of sewage treatment plants view the process
as "on stream" and attempt to reduce the biological processes
to measurements of chemical parameters, e.g. dissolved solids,
suspended solids, Bl ochemica 1 Oxygen Demand (BOD).  The latter,
BOD, is considered to be a parameter used to measure the .amount
of oxidizable substrate available to the oxidizing rnicroflora
and the pollutional potential of the effluent.  During the
course of presentation of technical information there has been
a tendency to treat BOD as a substance; this it is not.  It
can be reduced but not removed and the terms "nonremovable"
or "ncn-oxidizable" BOD indicate a lack of understanding of
the nature of BOD.  BOD measurements on effluent streams in a
treatment plant cannot be related to epidemiological hazards,
because the measurement itself gives no clue as to what an
increase or decrease in effluent BOD actually indicates bio-
logically.  It is often assumed to measure biologically
degradable substances in the influent which passed through
treatment unaffected.  Actually it measures oxygen consumption
due to other phenomena.  In this regard note the following:

1.  Efficiency of the process depends as much on settling
    characteristics of the sludge as upon removal of the
    noxious components by biological, oxidation.  Therefore,
    low effluent BOD can reflect high levels of noxious
    components unaffected during treatment other than by
    flocculation which remain in the sludge (effluent) lagoons.

2.  Metabolic activity (oxygen consumption) of a pathogen
    cannot be distinguished from that of a normal sewage
    saprophyte.

3.  Spores may not contribute to BOD.

4.  Viruses may not contribute; to BOD.

5.  Only metabolic activity, not numbers of viable micro-
    organisms are measured.

6.  Predator activity probably does not distinguish between
    pathogenic and non-pathogenic prey organisms.  There is
    not necessarily a preferential destruction of pathogens.
    Viruses do not enter "metabolic competition".

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3 .    ST/iTOSNT 0:v POSlVi'O:-,'

      From a microbiological  viowpoir.t  neither  the  roOa I i vc
efficiency of a sewage treatment plant  in  lowering  Biochemical
Oxygen Demand (130])) of influent waste,  nor the  precise method-
ology of treatnicnt is at issue.  Microbiol Q£i cal.ly,  municipal
waste, by its very nature, contains a high population of
potentially pathogenic mi croorgan.isms .   The physical nature
of the proposed treatment facility, indeed, the nature of  the
sewage treatment process itself is such that  a  definitive
possibility exists for transfer to human hosts  of pathogenic
microorganisms derived from  the sewage  under  treatment.
Residents in the immediate environs o.f  sewage treatment-
facilities would, of course,  receive maximum  exposure.

      The microbiological position that must  be taken is
based on two considerations;  these are:  1) no  definitive-
evidence has been forwarded  to demonstrate the  absolute safety
of operation of a sewage treatment plant jn close proximity
to a high population density, and 2) factors  indicative of
potential health hazards can  be documented.   The possibility
of health hazard is concluded to exist.  This should, preclude
actions contributory to the  health hazard  including  continued
operation of the current facility under conditions  of demon-
strated environmental pollution or expansion  of the  plant's
capacity with an attendant quantitative increase in  possible
deleterious effects.

      The intimation on the  part of the NSSD  of the  absolute
certainty of the safety of operation of both  the current
facility and an expanded plant is unrealistic and a  tenuous
position to maintain in the  light of current  knowledge.  To
date no experimental evidence to demonstrate  lack of hazard
has been presented or obtained by KSSD.  Sufficient  evidence
for hazard exists to warrant  the burden of proof of  safety
to be placed on the currently  demonstrated  and potential!}'
massive polluter, ATSSD.  The  following  presentation  will
attempt documentation of certain aspects of the potential
hazards  to health and environment associated  with operation
of a sewage treatment plant  closely contiguous  to a  large
human population.

II.   THE NATURE OF SEV/AGZ TREATMENT AS RELATED TO BIOLOGICAL
      QUALITY OF TJIE THKATMENT STREAM

      In order to support a  position which will not  accept
operational data from sewage  treatment  plants as dogma, somo
understanding of the nature  of the treatment  process is required
First of all, sev/age treatment is a dynamic process.  Influent
waste is of a constantly changing composition and the microbi&l
population dissimulating the  waste responds to  the changing
nature of  the substrates.  The entire system  is then in a
constant state of flux.  Indeed, it mu.st be so  or the efficiency
of treatment would be too low to be of  value.   In short, a

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     The Possibility of iiuiuun iK:allh Hazards  A.''.-.:oci a tod

     with Expansion of the Clayey Itoud Sev/a^e Treatment

     Facili ly ;   A Mi^roluo] p;;-i-9.a.l_Y ie v/po i n L .
               Martin H. Rogoff, Ph.D.

                    January 13,  1971
                         INDEX

I.     Statement of position

II.   The nature of sev.age treatment  as  related  to
      biological quality of  the  treatment  stream

III.  The nature of the potential  health ha/,ard

       A.    Presence and persistence of infectious
             agents
       B.    Relation of diseases  to  waste disposal
                1.  Related  diseases
                2.  Biological vectors
                3.  Physical  veclors
       C.    Secondary iactors bearing on  epidemiology
             of waste-associated disease
                1.  The immune response  to virus infection
                2.  Effect of waste-derived chemical pollu-
                    tants on host  susceptibility
                3.  Nitrous  acid as a inuta^en
                4.  Transferable  drug resistance in
                    enteric  bacteria
                                        f
IV.   The quantitative effect, a suinmnry statement

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                        MONOCHLORAMiNE (4.5mg/I)
                        DICHLORAMINE (lO.Smg/l)
                    \
                      \
                        \
                 J2(!.82mg/l)
                 HOI(0,78mg/I)
.01
  0  10  20  30 40  50  60  70 80  90  100 110  J20 130 140

                       M I W 11 T F S

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Figure U.  Inactivation of poliovirus 1 by a mixture of nonochloraniine
           and dichloranine, and by a nixture of 1.2 and HOI (27)-  All
           concentrations are expressed in terns of titrable haiogan
           present.

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  10,000
     1000
 G?
 o.

 o
 in
Q
M
JOO
        10
01
               4
                                      10      13      16       19
                            MINUTES
  Figure 3.  Inactivation of poliovirus 1 by 0-^ added intermittently to

            seeded river water (2^+).  0-j concentrations (ng/1) axe shown

            at sampling points.

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     2
     .8


     .6


*•••

\   .4


1.3
O
o
X
     .2
     .1


    .08


    .OS

    .05
                                TT
       .5  .6    .8    I
2        34

MINUTES
8    10
             Figure 2.  Relationship betvccrv tine and HOCJL concentration for
                       inactivation of poliovirus 1 at 0 C (23).

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	  pH  10.3
                     60          80
                       MINUTES
'C i.
   Inaccivacion of poliovirus 1 by high pH xa ^.LTe-ri
   rapid sana-nioered effluent ac 25 C.  The Ca(OH)2
   concencrition WHS  5CO z^S/'l.  HC1 vas used to adjust  pH
   levels aownwarU (lo).

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18.  Clarke, N. A., Stevenson, R. E., Chanc, S. L. and Kabler,  P. W.
       (1961).  Am J. Pub. Health, 51:1118.

19.  Chaudhuri, M. and En^lebrecht, R. S.  Renoval of Viruses fron '.later
       by Chemical Coagulation and Flocculation.  Presented at  the Annual
       Conference, Washincton, D. C., June 23, 1970.

20.  Cookson, J. T., Jr. (1969).  J. An. Water '.-for la Assoc., 6l:52.

21.  Chang, S. L. et al.  (1938).  An J. Pub. Health, H8.-159.

22.  Thorup, R. T., Nixon, F. P., Wentvorth, D. F. and Sproul,  0. J.
       (1970).  J. Am. Water Works Assoc., 62:97.

23.  Weidenkopf, S. J.  (1958).  Virology, 5:5^-

2k.  Coin, L., Ilannoun, C. and Gome Ha, C.   (196^).  La  Presse  Me die ale
       72:2153-

25.  Shuval, H. I. et al.  (1966).  Third International  Conferencs on
       Water Pollution Research  ( Proceedings ) ,, Section II, p. 1.

26.  Lothrop, T. L. and Sproul,  0. J.   (1969).  J. Water Poll.  Control
       Feder., 1*
2?.  Berg, G. and Herman, D.  Unpublished data.

28.  Berg, G., Chang, S. L. and Harris, E. K.   (196^).   Virolosy,  22
                                                         *
29.  Berg, G. and Chang, S. L.  Unpublished data.

30.  Freund, G. e_t al.   (1966).  J. Clin. Sndocrinol._ and Metabolism,  26:(

31.  Huff, C. B., Smith, H. F., Boring, W. D. and  Clarke, N. A.   (1965)
       Pub. Health Rap., 80:695.

32.  Kin, W. F., Jr., Kssblet, F. S. and Bcntcr.,  '.-?. H.   (1969).   Appl
       Microbiol., 17:1.

-------
                                 :- -'oronccs


 1.   Plothin,  S. /'.  ..-'.-J "-•--   '-'   (?-967).  In Trrmcnlcoion of Vir-jseg  by
        the Wato: '-••:, '.2  '.-   .   •"•. EC re, Jchn  ,/iley -.ind tjons, I.'ov.'  Yor::,
        New Yo"r'*.""

 2.   Katz, M,  •.-. •   " .     -  .,   -   (19-7).  J. /jn.  Pub. Health Accoc.
        57:133'*

 3.   Berg, G. ~(19o6;    ^j^Jt^Jili',  3:86.

 it.   Wallis, C. and ;',^n\c}-.  ."  r.,  (1967).  In  Ti'ancr.lsslcn of 71rJ33s
        by the '.,'aU'r . „. . -;   ..  .  , ^j '^. Berc, John ,/iley cmd 5cr.s_, 1,'ev
        York, l.'ew York,, p.  12Q.

 5.   Wallis, C. and lle-uc/.  :. :.,  (I9o7).  A-.cr. J. Zpider.iol., 85:^59-

 6.   Moore, 1-i. L,, L\;aov-i -:',  7, :-, and Jeter, W. S.  (1970).  J._]^ter Poll._
        Control Fcder, , •' -  .,;

 T.   England, 3.   r--cbasins  Jv^J',;-'a Precipitation of Kocvirus and Adenovirus
        for their .-^ss-iy in Sc--.'-ce a^d ^rfiuentc.   Presented at the 70th /jinur.l
        Meeting uf  the' /^.c^i -,»:"Society for .Microbiology, 26 April -  1  J^y i:-70.

' 8.   L-ond, 3. and  fiedstror^,  i."   •::>   '1967).   In Transr.ission of Viruses by
        the Water Routa, ecUx^i' 1.;, G. Bars, John  ./ilcy and Sons, I.'sv  Ycrl;,
        Ifew York, p. 371.

 9.   Shuval, H. I., Cjinbaliita, :,, Fatal, B. and Goldblin, II.  (1967).
        In Transnission__qf Viruses by the J.rater _I?outp, edited by G. Bars,
        John Wiley  and  Sons,  I rev York, l.'sv  York,  p. ^5 •

 10.   Shuval, H. I. Personal communication.

 11.   Grindrod, J.  and Cliver,  D. 0.  (1969).  Archiv. gesrjite Virusforsch.,
        28:337.

 12.   Grindrod,  J.  and Cliver,  D. 0.  Archiv. gesar.te Virusforsch.  In  press.

 13.   Cliver, D. 0.  (1967).   In Transr.lGsion of  Viruses by the V.'ater RouLo,
        edited  by G.  Berc, John V/iley and Sons, I   Wallis, C., Grinstcin,  S., MeLnick, J.  L. and Fields, J. 2,  (1969).
        Applied t-iicrobiol., 13:1007.

-------
they can be destroyed in waters of al.1, qualities are still unanswered.



The resolution of all of these problems will mark the direction of



research in this area for the next decade.

-------
Behind these plugs infections frequently develop.  It is logical tlu-s to assume
that thcsi.  i/vlerials will  not only cause' infecMon kit reduce the nbilily ci the
body to fie is i  off infection.   This was clearly shown in the Chicago Air Pollution
Study carried  out and published in tiie Archives of Environmental Health.
(The Chicago Air Pollution Study:  SO- Levels and Acute Illness in Patients with
Chronic Bronchopulmonary Disease -B.  W. Carnow, M. H. Lepper, R. B. Shekelle and J.
Stamler:  Vol. 18, 768  1969) .Other studies suggesting potential serious effects
on sensitive individuals have also been published by us including Air Pollution
and Physician  Responsibility by B. W. Carnow published in the Archives of
Internal Medicine, Vol. 127, Jan.  1971, pg 91 -95.  These reveal that asthmatics
particularly can have unusually severe effects from elevated levels of pollutants
similar to those produced at the sewage plant.
     Another serious problem has not been well documented in relation to sewage plants
relates to bacterial and viral contamination.  This will be increased with the
increase in the size of the plant.  Not only as noted above are the conditions present
for decreasing the ability of the  human body to fight off disease, but there will
be a marked increase in the amount of bacteria and viruses present in the air of
such a community corning from the plant.  The processing  of sewage includes
continuous bubbling.  This presents two potentially serious problems. First.
(Science Vol.  170, Nov. 6, 1970, page 626 in an article by Blanchard and Sydek)
it is pointed  out that " air bubbles breaking at the air-water interface can remove
bacteria that  concentrate in the surface micro!aycr and eject the bacteria into
the atmosphere."  The bacterial concentrations in the drops ejected from the bubbles
may, depending on drop size, be from 10 to 10,000 times that of the v/ater in which
the bubbles burst."  It should also be noted that many bacteria and viruses concentrat
at the surface of the v/ater because of the surface tension. The concentration of
bacteria at the surface has been reported by Higgins, F.B., Thesis, Georgia Institute
of Technology, 1964 and by Parker  and Barsom in Bioscience, Vol. 20, page 87, 1970,
That this is not academic has been shown by Morrow in Nature, Vol. 222, 1969, page
489 and Smith and Hugh Jones, Vol. 223, Nature, page 12, 1969, v/here a report of
such aerosols carrying hoof and mouth disease long distances are noted.  Spendlove in
Science, Nov.  16, 1970, found that E. coli which is a good measure of sewage bacterial
contamination and which is always  accompanied by other bacteria when it is found, may
be found  at relatively high concentrations, up to 0.8 of a mile from the plant.

-------
 Studies  have  shov/n  that  bocl.n'ul corc^oU Cc.n affect  individuals in the surrounding I
 areas as in  a case  of a  small  opic!~u;ic of omithosis in Portland in 1956.  Spend! ove,
 Clifton  J,,  Public  Health  Reports,  Vol.  72,  #2,  Feb. 1975.   It should again  be
 remembered that  the direction  of  the  prevailing  winds  from the sewage plant  is
 toward the lake  and an area  where a large public school is located within a  half-mile
 of the plant. Other schools are  also present at somewhat greater distances.
     ^r^c^^Tu§To?TTMn^in  regard  to the projected increase  in the size of  the
 sewage plant  and its impact  on the  coinrrium'ty, tKer'g'ivrr g^g^ggBW*^ n ' '•inw>$w&3l
                                                                          cause
 considerable irritation  to  .the  respiratory  tract of many people  in the surrounding
 .community.   Those more sensitive  individuals  such  as asthmatics  can be expected
 to show an  increase  in the  number of  attacks  suffered.  ^I^G^^a^^ltSJi^^Ql^Sg^
tfliaJSj^                                              when added  to the lowered
 resistance  because of irritants can only  have a greater deleterous effect, as
 noted the general HSallriir^^

      2.   In regard to probably adverse  environmental effects which cannot  be
 avoided, it is my understanding from reading  various testimonies and reports  that
 some of these can be avoided such as some  of  the  gases,  concentrations of  gases, etc.
 I do not know what cai be done in regard to the concentration of viruses and
 bacteria which I expect will become airborne  as a result of the sewo-ge treatment
 process.
      It Is my considered opinion that before  such an increase in size of this plant
 is considered a study consisting of an  analysis of airborne aerosols and particles,
 the extent of spread of disease producing  aeorsol particles, the levels of
 pollution and ambient air quality and the  additional impact of the air pollutants
 coming from the sewage plant on these levels  ?11  be carried out in a comprehensive
                      *
 study.  This study should also include  an  epidcioiologic  study of the impact on
 the community, particularly in relation to respiratory disease.  It is only at that
 time that question 2 can be answered.  Obviously  only  when the problems are assessed
 can Jie possible ways of solving these  problems  and the  available  technology  for
                                                   (
 solving these problems be ascertained.'   Until that time  I don't think  that one can
 deal with the question of whether  or not  adverse environmental effects can or
 cannot  be avoided, specifically because we do not know what the effects are at this
 time. They have not been adequately studied hei e  or in any other place  in  the country
 that  I  know of.

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       I  trust this will  be helpful  to you in evaluating and considering this

  important matter.

                          .-- 7
  Sincerely,
/Bertram W.  Carnow, M.D.
  Associate Professor                          /
  Department of Preventive Medicine and Community Health
  Chief, Section of Environmental  Health
  University of Illinois

-------
STATE OF ILLINOIS   )
                    ) SS:
COUNTY OF L A K E   )

      IN THE CIRCUIT COURT FOR THE NINETEENTH
      JUDICIAL CIRCUIT, LAKE COUNTY,  ILLINOIS

JOSEPH LICATA, et al.,         )

             Plaintiffs,       )

       Vs.                     )'No.  70  MR  31

NORTH SHORE SANITARY DISTRICT, )
et al.,                        )

             Defendants.       )


        EXCERPTS OF REPORT OF PROCEEDINGS had at

the hearing of the above entitled cause, before the

Honorable Clarence E. Partee, Judge of said  Court,

on the 28th day of September, A.D., 1970.   f

     APPEARANCES :

         MR. JACK SIEGEL,
             appeared for the plaintiff;

         MR. MURRAY R. CONZELMAN,
             appeared for the Defendant,
             North Shore Sanitary District;

         MR. THOMAS H. COMPERE,
             appeared for the defendant, City
             of Highland Park^ a municipal
             corporation of Illinois.

-------
                BERTRAM W .  CARNOW,



called as a witness herein, having been first



duly sworn, was examined and testified as follows:




                DIRECT EXAMINATION




BY MR. SIEGEL:



    Q   Would you state your name, address and



occupation, please.



    A   My name is Bertram Carnow.  I live at




860 Oak Drive in Glencoe, a physician.




  •  Q   Dr. Carnow, would you tell us what your




educational background has  been?



    A   Well, I have a Bachelors Degree and a



Bachelor of Medicine and a  Doctor of Medicine,



Chicago Medical School.  I interned at Cook County



Hospital In Chicago.  I had a residency, specialty



training in Internal medicine at Michael Reese



Hospital, and special training in cardiology and



pulmonary at Michael Reese  Hospital.



    Q   Are you presently associated with any



institutions?                 <




    A   Yes, I am.  I am chief of the section of



environmental health in-  the College of Medicine.




Associate Professor of Preventatlve Medicine,



Medical Director of the Tuberculosis Institute

-------
in Cook County.  I'm a chest consultant and



attending physician at Michael Reese Hospital.




A chest consultant at the University of Illinois




Hospital.  A chest consultant to the Union Health




Service of Chicago.




    Q   Are you a member of any organizations




concerned with air pollution?




    A   Yes, I pointed out I'm medical director of




the Tuberculosis Institute of Chicago and Cook




County.  I'm a Fellow in the American College  of




Chest Physicians.  A member of the Royal Society




of Health, National Thoracic Society, American




Health Association.  All of these are concerned




with this problem.



    Q   Do you hold any memberships on any city,



state or national committees concerned with air




pollution?
                       *



    A   Yes, I sit on the Committee of Chicago's



Technical Advisory Board on air pollution.  I
                              /


sit on the Air Quality Standard Commission on  the




Board of Health of the City of Chicago.  Consul-




tant to the Attorney General, State of Illinois.




I'm the head of a task force for the Lieutenant

-------
Governor, and on the Technical Advisory Committee


of the State of Illinois Air Pollution Board.


    Q   Dr. Carnow, have you published any


articles or other studies on the problems of air


pollution as related to health?


    A   Yes, I have.  I have been conducting


research on air pollution and its health effects


for the last six or seven years, and have published


fairly extensively on this.


    MR. SIEGEL:  Will the Reporter please mark


this Exhibit as Plaintiffs'  Exhibit No.  29,' for


Identification.


                (WHEREUPON,  Plaintiffs'  Exhibit No.


                 29, for Identification,  was so


                 marked. )


    MR. SIEGEL: Q  Now, Dr.  Carnow, I show you a


document which have been marked as Plaintiffs'


Exhibit No. 29, for Identification, and  ask you if


you are familiar with that document?
                              i

    A   Yes, I am.


    Q   What is that, sir?


    A   It's my curriculum vitae.


    Q   What is that?

-------
    A   It details my career, ray appointments



and some of the publications which I mentioned.



I did not mention that I also sit as a member of



the National Academy of Science Panel on Air-Borne



Cancer Producing Substances, and have acted as



consultant to the National Air Pollution Control



Administration on Sulphur Dioxide and Carbon



Monoxide.




    MR. SIEGEL:  Your Honor, I ask that  Plaintiffs'



Exhibit No.  29, for Identification,  be admitted as



Plaintiffs'  Exhibit No.  29.




    MR. CONZELMAN:   No objection.




    THE COURT:   Plaintiffs'  Exhibit  No.  29 is



admitted in  evidence.




                 (WHEREUPON, Plaintiffs'  Exhibit



                 No. 29,  for Identification,  was



                 received in evidence as  Plaintiffs'



                 Exhibit No. 29,  in  evidence,  and is



                 in words and  figures as  follows,



                 to-wit: )

-------
    MR. SIEGEL: Q  Dr. Carnow, during the course

of your professional activities, have you studied

the effects of noxious gases upon health?

    A   Yes, we have.  We have been conducting a

number of studies of the effect, particularly of

sulphur dioxide on health.  We have been following

a group of 560 people with chronic lung diseases.

Other studies and the effects on infants, on the

elderly,  and have been carrying out studies of the

possible  association of death with air pollutants

in the City of Chicago.

    Q   Are you familiar with the Clavey Road

treatment plant in Highland Park, Doctor?

    A   Yes, I am.

    Q   Do you know what type of sewage treatment

process is involved in that plant?

    A  Well, I know it's an activated sludge plant,

yes.  I'm not an engineer.

    Q  Are you familiar with gases which are pro-
                              i
duced and emitted into the atmosphere as a  result

of activated sludge plants, such as the Clavey Road

treatment plant?

    A  Yes .

-------
    Q   Would you tell the Court what some of those



gases are that are produced,  and other substances




other than gas?



    A   Well the -- we're concerned about the two



problems in this regard:  One,  gases which are



produced from the sewage and  from th~e burning of




digestive gases, so that there  is production of



nitrogen compound, including  NO, a nitrogen



compound and sulphur dioxide.



         Also there are emissions of hydrogen



sulphl, which is a poisonous  gas.  In addit.lon, a



number of materials are used  which are toxic when



emitted into the air.  As for example, ozone, which



is highly toxic.  And chlorine,  which is  used in



the sewage process.



         We are further concerned about air-borne



materials, particulate, a matter used in  the



burning, and viruses and bacteria which are thrown



into the air and carried on these particulates .



    Q   Dr. Carnow, I show you  Plaintiffs' Exhibit



C, and direct your attention particularly to Pages




2 and 3, and ask you to examine  that document with



respect to scientific aaza which is contained thereon

-------
        Now, Doctor, assuming a sulphur dioxide

concentration in excess of .2 parts per million.

What is your opinion with respect to the effect

of the emission of such sulphur dioxide upon health

in those residents of the area of the sewage treat-

ment plant?

    A   Well, at those concentrations,  they are

negative health effects on a significant part of

the population.  In the criteria, documents which

the Federal Government released,  and which is a

compendium of what is considered  by them to be

reliable research evidence,  they have arrived at

a level of 0.11 parts per million,  which is con-

siderably lower than the one you  are talking about,
                                   i
at which health effects begin to  appear.

        In our study of chronic bronchitis in

Chicago, we found that in males,  55 and over, had

twice^ as many days of acute  chest illness  when the

levels were .2 parts per million, as when  they were

.04 parts per million.  We alao found,  in  following

a group of individuals, that  at these levels there

was a significantly higher incidence of acute

respiratory symptoms, including cough,  shortness

of breath and  the development of  Infection.  This,

-------
I assume, Is what It says,  maximum ground  level


concentrations from the plant.   Since,  of  course,


there will be other sources producing this material


in the air, such as coal burning and  wood  burning


and others, one can expect  that this  number will be


even higher.


        At these levels we  have found,  particularly


in areas where people are not used to high levels


of pollution, that there are excess deaths.  At least


in the City of Chicago, at  these levels,  from heart


disease and from lung disease in males,  55 years of
                                             i
age and over.  Now this deals -- you've  asked) only
                                             i

about a single gas, but there are others which are
                                             I

emitted, and these gases particularly are  additive,


or what we call sinalglstlc, in that  they  have a


similar effect and, therefore,  they compound 'and


Intensify each other's effects.


    Q   What are the other  gases that would be


emitted from the sewage treatment plant  that would

                             i
have the effect you 'Just described?


    A   Well, nitrogen oxide, which is  a  -- in


fairly highly concentrations, a deadly gas.  There


is 8 disease, as a matter of fact, called  "silo phyllas"

disease, where farmers go into a silo for  ten days

-------
after they put corn in, who are exposed to this


gas, and a high rate of severe bronchitis and


considerable number of deaths.


        In addition, hydrogen sulphide is a very


noxious gas.  There was an episode in Costa Rico


where some of this gas escaped from some of these


tanks --


    MR. CONZELMAN:  I object to this unless he was


in Costa Rico.


    THE WITNESS:  No,  I was not there.


    MR SIEGEL:  Your Honor, if he has knowledge


of this .


    THE COURT:  I think that what the doctor is


testifying to is the in^uriousness of gas.  I think


the general statement is that if it's injuriousness


to health, is sufficient.


    MR. SIEGEL: Q  Are you familiar with the pro-


posed expansion of the Clavey Road plant?


    THE WITNESS: A  I'm familiar with what is
                             I

proposed.


    Q   Will this expansion increase the amount of


noxious substances which are emitted into the


atmosphere?

-------
    A   I would expect that,  yes,  that they would,


since the amount -- certainly the  amount  of


digestion is certainly going  to increase.   Thereby,


a factor related to the increase in sewage, as


well as the use of ozone.


    Q   Now, Doctor, if ozone is used  to  kill odors


in the sewage treatment plant,  what are the effects


of the use of ozone upon the  health of citizens


who may be in the area?


    A   Well, there are two effects that we are


concerned about.  Ozone is  probably the most noxious


of the gases that we're talking about. It's an


extremely irritating gas.   It,  in  addition to


causing acute inflammatory changes  in the air


passages, it lowers resistance  to  acute illness.


We have studied a number of workers in an  operation


called "Migwielding" who are  exposed to high levels


of ozone, and these men have  extreme difficulty


with sinus trouble and acute  bronchitis and so on.
                              t

Ozone is also a radial remittic substance, which


means that it will, even at relatively low levels,


of course, sphering of red  blood cells and chromosone


breakage, means at these concentrations, has the  same

-------
effects as X-rays.  And further, the effect of the
     i
ozone is to produce a very active compound, which

in themselves are extremely irritating, and which

may themselves cause difficulty with.the lungs.

As a matter of fact, we have good reason to suspect

that some of these may be cancer-producing substances,

although we have not proved this in man.

    Q   Now, directing your attention again to

Plaintiffs' Exhibit No. C, which is a letter from

Mr. Quon, consultant to the City of Highland Park,

I ask you whether the chemical substances which

he reports as being produced,  will have dilatorious
                                              i
effect upon public health?

    A   Yes.  Again, I think that he's talking about

maximum figures.  But, again,  what we are talking

about is not one gas, but multiple gases.  We are

talking also about these being added to a community

where these gases are being produced from other

sources.  So that this is the  amount that is going
                              /

to be added.  If this amount,  at the quantity which

is described, is hazardous to. health, and there is

excellent documenta LIon in our stuay and others, that


it is, that if you have these  added to others in the

-------
community, under conditions of inversion and

stagnation, you create a situation where there is

a serious health hazard. .

          If in addition you have bacterial and viral

particles being blown by the wind, by droplets, which

it does, there are significant studies which show

that this is Indeed the case, then you have a --

and as levels of E. coli, for example, have been fairly

high, even up to .8 miles from the plant when the

wind is blowing at a fair rate.  So you have the

conditions in this situation, with the amount of

sewage treatment that you're talking about, a
                                               i
situation where you have irritant gases which

diminish the resistance of the air passages of the

lungs, and diminish the lung's ability to protect

itself against bacteria, and a situation also in

which bacteria are also created, so that you have a

combination of substances which, in my opini-on, may

be very dilatorlous to health.

     Q    What would be the effect of the So2 and the

ozone on the increase in the amount of bacteria in

viruses ?


     A    I'm sorry.  I didn't understand.

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     Q    What would be the effect of the So2 and


the ozone and the increase in the amount of


bacteria and viruses upon the health of the citizens


in the immediate area?


     A    Well, again, in terms of mechanism, the


ozone and the sulphur dioxide, both act to destroy


the ability of the lungs to resist infection.  There


is -- the defense mechanism of the lung is what we


call the pneumocilia apparatus.  Tiny hairs that


operate in the air passages and remove impurities


and bacteria.  In addition, sitting on this -- these


hairs, is a very thin layer of mucus, which is then
                                               ')
escalated out.  Kind of a little blanket which


entraps impurities. Well, these cases will, of


course, paralyze -- will cause paralysis of the


cilia, so they don't act as an escalator, and


ultimately will destroy them.  And in addition, the


mucus, because of irritation of these gases,, is


produced in much greater quantity so that as this
                               /

process goes on, there is a closing or blocking of


air passages of the lung.  There is a flooding of


the air passages with mucus,  so that even though


these tiny hairs beat,  they don't move anything.

-------
And if you superimpose on this destroyed protective


mechanism, and introduce pathogenic bacteria and


viruses, you certainly can look to a much higher


rate of acute illness.  This is what occurred,  we


believe, in our 560 bronchitlcs, and the others


that we have studied.


     Q    Does the amount of humidity in the air


affect the consequences and  the release of these


substances ?


     A    Yes, it certainly  does with increased


humidity the effect of So2 tends to be greater,


because under humid conditions, particularly when


there is particulate in the  air containing manganese


or iron, and in these areas  there is such, and  in


almost all industrial cities there are, and their


environs, you get the rapid  formation of sulphur


trioxide arid sulphuric acid, which is an extremely


irritating acid.


     Q    What is the effect, Doctor, of small  amounts
                               *
of carbon in the  air such as indicated will be  re-


leased here?


     A    Well, carbon acts  as a carrier.  The  sulphur


dioxide, in addition to the  -- its action in the

-------
manner in which you just described, also can be




absorbed.  They are attached to these tiny particles




And if these particles are very small and they tend



to be very small, they get into the lung and these




gases are slowly released.



          In addition, we think these particles have



an effect by themselves on some of the clearing



mechanism of the lung.  Particularly on a scavenger



cell, which removes impurities called micromyces.



These materials tend to inactivate them.




     Q    Now,  Doctor, are the levels which will be



emitted of pollutants, as indicated in Plaintiffs' _




Exhibit C, in your opinion,  represent health hazard



to the surrounding area?




     A    Yes,  I believe that  at  these levels,  under



certain conditions of  stagnation  or inversion,  they



represent levels at which a  significant number  of



individuals in  the population  become ill.  These are



levels considerably above the  .11 at which health



effects were noted in  our studies,  in the Rotterdam



studies,  the London studies  and  others.




     Q    If there is  any breakdown in the operation



of the sewage treatment plant,  either mechanical or

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human failure, would this  result  in a  greater


concentration of these pollutants  being emitted


into the atmosphere?


    A   Well, I presume it would  result in a


greater concentration on greater  bacterial and


environmental pollutants.   Certainly in a  greater

concentration of the other digestive gases.  Now


how much of those get out  into the air, I  don't


know.  It would depend on the engineering  capability


of the plant.

    Q   Based upon your knowledge  and  experience,


Doctor, do you have an opinion as  to whether  or not

the expansion of the Clavey Road  treatment plant,

as proposed, represents a  threat  to the health of

the community and the surrounding  area?


    A   I certainly do.  I think  an 18-million

gallon a day plant in an area such as  that repre-


sents a serious threat to the health and the  welfare


of the individuals in that community.
                              i
    Q   How far awaycould the public  health  be


threatened by the operation of this sewage treat-

ment plant?


    A   Well, it depends on the kind of inversion and

-------
so on.  It would add most to Its immediate sur-


roundings, and depending on how much wind there was,


would add to other areas.  In terms of the bacteria


and virus problem, this would relate to the direction


in which the wind is blowing.  And, as I say,


studies have shown that up to almost a mile away,


fairly, high concentration of E. coli and viruses.


In relation to --


     MR. CONZELMAN:   Objection.  We don't have the


studies.  I don't know what area he is talking


about, your Honor.


     MR. SIEGEL: Q  Would you be a  little more


specific, sir, with  respect to studies in the  area?


     MR. CONZELMAN:   I object to this.  I want to  see


the studies.


     MR. SIEGEL: Q  Do you have the studies, Doctor?


     THE COURT:  I don't think there is  anything


about the study in evidence,  is there?


     MR. SIEGEL: Q  Do you want to  find  me the study

                               i
you are referring to,-Doctor?


     THE WITNESS: A   Yes.


     Q    Doctor, la your opinion based  upon your  own


research and your own activities?

-------
    A   Yes, it Is.


    Q   Are you familiar with the research of other


students of this field of medicine?


    A   Yes.


    Q   I direct your attention to an article which


appears in Science for September 18,  1970, and ask


you whether you are familiar with the study which


commences on Page 1218 of that particular issue?


    A   Yes, I am,


    Q   Will you describe what that study is?


    A   Well, it's a study of the Coliform Aerosols


Emitted by Sewage Treatment Plants, and they revealed


the special filters at various points from the plant,


with measured inflow of air into the  filter, and


they found that conforms were emitted and were sampled


to a distance of 1.2 kilometers down wind.


    Q   Would that conf,irm your own opinion and


observation In this field?


    A   Yes, it would.  We know, and  many, many
                     *

studies, Including some that we have  done with


aerosols, we know that viruses are easily carried


and transmitted by particles and vapors.  Studies


which have been carried out by Lorenzo at the Cook

-------
County Hospital, in which I have participated,

show that this is the case.

    Q   Now, Doctor, are all the pollutants which

you described as being dangerous to health, odor

producing?

    A   Some of them are.  It depends on the

concentrations.  So2, unfortunately, is not odor

producing until it becomes a very serious hazard.

Some of the others are more odor producing, such

as mercaptans and hydrogen sulphide, and so on.

    Q   Just to recapitulate, will you tell us

specifically the substances which are produced by

the operation of an activated sludge sewage treat-

ment plant of the type proposed  here which, in your

opinion,  are dangerous to the public health?

    A   Well, the odors are a nuisance, and I have

not studied what their effects, on health are.

They certainly affect well-being, and if one accepts

the definition of health that the world organization
                              f
gives,  a  state of well-being wherein individuals

can function and enjoy health and property, then the

odors certainly would affect health by this

definition.

-------
        In addition,  the  materials  which  are  given



off, which are hazardous  to health  in adequate


quantities, it depends  on the  individual  breathing



it.  There is a different effect  on a 25-year-old



than a new born or an old person  with heart and


lung disease.  Those  are  the people who suffer  the



most, and have the greatest difficulty with these


materials.  But the pollutants consist of the odors



I mentioned, hydrogen sulphide, So2,  nitrogen com-


pounds, ozone, sulphur dioxide, particulate matter


and the bacteria and  viruses which  I already  dis-



cussed .
                        s «

    Q   And what portions of the  sewage treatment


plant produce these substances?


    A   Well, some of them are produced by the  Intro-


duction of these chemicals in  the treatment process.


I also didn't mention the free radical, those very
                       i

active substances which are produced when ozone  Is


Introduced in relation to hydrocones.  But so that
                               i

some  are produced In the  treatment.  Some are pro-


duced  from the digesting process.  Some are produced


because they arc- introduced into  the treatment,  like



ozone  and chlorine.  Others are a result  of the

-------
"burning of the digest of gases.

    Q   Does the storage of sewage, mixed with

storm water, in retention basins for an effluent,

and the effluent lagoon, constitutes sources of

pollutants?

    A   Well, I again,! have not measured the levels

in these areas, and I don't know what they are.

But digestion of these materials do produce noxious

gases .

    MR. CONZELMAN:  Objection.  The witness already

said he hasn't measured and doesn't know.

    THE WITNESS:  I said I didn't know the quantitites,

sir.

    THE COURT:  Well, the answer will stand.

    MR. SIEGEL:  I have nothing further of this

witness.

                    .CROSS EXAMINATION

BY MR. CONZELMAN:

    Q   Dr. Carnow, would you tell us when you
                              i
were retained in this case?

    A   When I was retained?  You mean when I was

asked to appear?


  Well, I don't recall.  A  number of weeks ago,  I

-------
guess .

    Q   Now, you're on some committee or com-

mission for the Attorney General.   Are you aware

of the fact that the Attorney General of Illinois

has filed suit against the district right in this

court, to get them to go even faster onthis very

project ?

    A   I'm not --

    MR. SIEGEL:  Objection to that.  "That isn't

what the Attorney General filed  suit for.  He filed

suit to prevent the North Shore  Sanitary District

to~ continue pollution."

    THE COURT:  Objection sustained.

    THE WITNESS:  I said I'consulted for, and

consulted with.  I do not work for the Attorney

General.  I have nothing otherwise to do with the

Attorney General.

    MR. CONZELMAN: Q  Now all of these gases and

what not you described, aren't they present with
                              /
any sewage treatment' plant ?

    A   Yes.

    Q   They are present right with the plants we

have there now, aren't they?

-------
    A   Yes.

    Q   Are you familiar with the north side plant

operated by the Metropolitan Sanitary District?

    A   Somewhat familiar with the plant.

    Q   That is a huge plant, much bigger even

than that expanded plant?

    A   Yes, it is.

    Q   And one would expect those gases'to be

present likewise?

    A   Oh, yes.  It's a terrible polluter.

    Q,   In more quantity?

    A   Yes, the more quantity of sewage, the more

quantity of gases..

    Q   They don't have .any covers on the north

side plant, do they?

    A   No, I don't think so.

    Q   Now, E. coli, you spoke of that.  Is that a

disease producing organism?

    A   It's a pathogen.  Yes,- of course.  But
                              i
more Important than that, it's a marker.  The

reason that E. cold was measured is because it's

easy to measure.  But if E. coll is in the air,, it

mea.ns there are others.  It's one way, for example,

of measuring contamination of water.  And the reason   ./

-------
E. coll is used to measure contamination of water

is because we know if E. coli is in the water, that

other bacteria are accompanying it, so we ca'n

extractulate from that,  and know that the water is

polluted,

    Q   It's merely an indicator, however.  It's

not a disease producer itself.  Isn't that correct?

    A   Well, E. coli is.  You inject it'under the

skin, it certainly would give you trouble.

    Q   But if you use it in this area, you used      ^

it as an indicator, is that correct?

 ~   A   In- this study, yes,'because it's easy to

measure.  But it is a pathogenic organism.

    Q   The reference of two parts per million of

sulphur dioxide in-Exhiblt C, which 'is Dr. Quon's

letter, that is a maximum, is it not?

    A   Yes.

    Q   Now, as I understand it, the standards

that we refer to are not maximums, but they are
                              i
24-hour averages.  Isn't that correct?

    A   It depends on the standard you are talking

about.  We have hourly averages, 24-hour maximums,     *


one percent a year, annual averages and so on.

-------
    Q   Well,  let's  go  on.   In his  letter,  the

..sulphur dioxide  standard  is  one  hour  per  year.


 Isn't  that  right?    ...

    A   No.  According  to him, one  percent  of the


 days per year, which is three and a half  days per


 year,  is  .1  parts  per million, which  is less than


 half of what you are talking about.


    Q   Then read  the, next  line, sulphur'dioxide,


 one hour, per day.  Isn't  that right?

     *
    A   That is  the  maximum permissible level, yes.


 One hour per year.-        ...


    Q   Dr. Carnow,.is  there.actually anything


 definitive.in this field?    ,             -


    MR. SIEGEL:  I object to thft, your Honor.  I

 don't  know what  that question means.

    THE COURT:   Restate your question.      ;:

    MR. CONZELMAN: Q  Isn't this the  field that we
                       i
 actually don't know  a lot about?


    THE WITNESS: A   That's very true.


    MR. CONZELMAN:   That's all the questions I have.

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                  REDIRECT EXAMINATION

BY MR. SIEGEL:   •  '

    Q   Dr. Carnow,  would you recommend  a  sewage

treatment plant serving 18-mlllion gallons a  day,

be located in a residential area?

    A   No.  I think it's -- as  I stated,  I think

it's a hazard to health.   I think the  fact that

there are other plants  which are worse,  only  in-

creases my concern.

    Q   Now, Dr. Carnow,  I take  it that  you do know,

even though there is  a  great deal of information we      ™

don't, have, that the kind of emissions which  you

have testified to,  are  a'threat  to public  health?

    A.  , There is no question about it.   I  think that

we are, you know, we are  at an early stage of our

knowledge.  IJm sure as our knowledge  increases  we

will begin to find that smaller  and smaller amounts
                       •       ,      <
are dangerous to health.   But I  think we certainly

know enough to know that  the levels which  are dis-

cussed here --

    Q   You say "here."  You are talking about this?

    A   Yes, in this  document, are by themselves a         f

hazard.  If the maximum is .231  parts  per  million of

-------
sulphur dioxide and the standards are for 24

hours for three and a half days a year, you are

talking about a level which is two and a half times

what is recommended, and levels which we have found

not only cause disease, or increase in disease,

particularly in those that already have it, but

cause an increase in deaths in .the population.

        Now, if you add to that the pollutants

which already exist in this community, you are

talking about a potential level which on three or

four days a year, according to this,  would be

hazardous.  We have found acute effects^: "increased

deaths when compared with the day of  pollution.

Acute respiratory Illness,  a  doublin-g of respiratory

illness on the same day as  the pollution.  So we are

talking about an effect that  is not long term at

these levels, but an effect which occurs within -

hours,' eight hours, sixteen hours of  exposure, and

it doesn't require many days  of exposure, and not
                               (
for a large portion of the  population..

    Q   Is the fact that there is present a sewage

treatment plant there, in your, opinion,  indicate that

the plant should be expanded?

-------
    A   No, I think  that,  again,  the  biological


systems In nature can handle  a  certain amount.


Now I don't know what the effects  of this  plant


are on the health of the people,  but you have a


plant which produces a certain  amount  of material.


Again, the air and the winds  and  so on can,  up to


a point, begin to clear.  When  you talk about pro-


cessing an 18-million gallon  a  day plant and pro-


ducing levels of So2 that you're  talking about,


you're talking about a clear  and  present danger  for


that community.           '            • .


    MR. SIEGEL:  Nothing further.


    MR. CONZELMAN:  No more questions.


    THE COURT:' The Court has a question,  doctor.


    THE WITNESS: A  Yes, sir.


    THE COURT:  Maybe two.  Did I understand you


to testify that downwind from one  of these plants,


that this gas can be dangerous  for an  area "up to


seven or eight miles?
                             i

    THE WITNESS: A  No, sir.


    THE COURT:  What did you  say?


    THE WITNESS: A  I was talking  about -- see,  the


gas, the danger of the gas  depends on  the  meteorological

-------
conditions.  On the high humidity there is,a much

higher production of sulphuric acid.  Where you

have stagnation, what we call an inversion layer,

and don't have vertical exversion, or winds of 6

miles an hour or less, then you get high concen-

tration in the area .  And this acts like an umbrella

over a fairly large area.  What I was talking about

was up to .8 miles, they found fairly high- concen-

trations of bacteria.  Now, they did not study
     i
viruses.  Viruses are much smaller particles which

tend to travel much further.

    MR. CONZELMAN:  May I ask a question in that

regard?  I gather then the viruses could be beyond
                    ,T       + ,    »
the .8 miles?

    THE WITNESS: A  Yes,  sir.

    MR. CONZELMAN:  Q,  Does that have, to do with

the size of the treatment plant?
                      ' t
    THE WITNESS: A  Yes,  I believe that it does.

    MR. CONZELMAN: Q  Well, in connection with the
                              i
north side plant in Chicago, it would be miles and

miles,  wouldn't it?

    THE WITNESS: A  Very possibly.  I haven't  studied

that.   But very possibly,  yes.

-------
MR. 'CONZELMAN:  That's all.  Thank you



               (Witness Excused.)
                                                      4

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 co provide-1 L:\ "chc i:;j:iediatc  area.  ~A  1-0 acre t"olock of donr:e grassy and
h^r"L';.jcou^ eov'c-r in the general area would be  excellent and it, should be
no r.ore Vi^n one-half i::ile  fro-.; the ponds.   Anything trailer than 4-0 acres
wouli still oe wortlr./hile but of  less  value to wildlife.  Cuch cover blocks
will do ir.uch to enhance the area  for upland nesting ducks such as mallards,
teal, pintails and other upland wildlife species.

March edge and matted cattail and bulrush already  in Lake St. Clair provide
nesting cover for divers such as  canvasback and redheads.

Water level fluctuation during nesting can be  a detriment to diving duck
nesting success.

Waterfowl Management techniques not in conflict with the primary purpose of
treating sewage would be of public benefit and  would make the total operation
a raulti purpose project.

Historically i;ood ducks nested near the  existing pond but have ceased since
the nesting trees were removed.   The city of Detroit Lakes is now considering
erecting wood duck houses.  We encourage this.


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