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 1
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 6
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 1*
III. LAND USE CONSIDERATIONS 19
Facilities Location and Construction 20
The Probable Impact of the Proposed Action on the
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 30
2. North Chicago 30
3. Clavey Road 30
4. Gurnee 39
IV. PUBLIC OBJECTIONS TO PROJECT 40
RECOMMENDATIONS 46
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SgjiMAjI
1, Date of Statement --------- - ----------------------------- June 21, 1971
2. Status of Environmental Statement-— ---------------- - — -Final
3. List of Departments and Agencies From which Comments on the
Draft Environmental Impact Statement Have Been Received : \J
Federal
Department of Agriculture
Department of Commerce
Environmental Protection Agancy
Department of Interior
Department of Health, Education and Welfare
Department of Transportation
Department of Army
Department of Housing and Urban Development
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 Environment
Businessmen for the Public Interest
Northeastern Illinois Planning Commission
Campaign Against Pollution
Society Against Violence tc the Environment
Chicago Horticultural Society
Students Organized for Survial
Open Lands Project
Forest Preserve District of Cook County, Illinois
Lake Michigan Ihterleagae Group Participants
League of Yomen Voters of Glencce, 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
WBBM-TV, Richard Kesterkamp, Editorial Director
Congregation Sol el
Associated Allergists, Ltd.
B'Nai Torah - Highland Park Reform Temple
Trinity Church
North Shore Radiologist, S. C.
ilcr-oh Suburban Synagouge Beth EC
Office of the Chairman-Beard of Supervisors, Waukegan
]/ Comments from all interested partis s 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 Impact 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. When 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. 2/
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 comments received on the original draft
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 operation by
the NSSD consist of seven plants at sites along Lake Michigan and one
treatment plant located on the Skokie River.
3h 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 MGD of sewerage
from the lakeside plants.
2/ Under subsequently adopted SPA 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 Eiiviron-
mental Protection Agency and endorsed by the Illinois Pollution Control
Board, calls for the construction of a new treatment facility at Gurnee
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. %/
The central impact 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 hones 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 U5 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 STATMMT
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 of h mg/L biochemical oxygen
demand (BOD) and 5 mg/L suspended solids (SS). 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.
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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 MQD
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 MOD 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 significant esthetic difference between a 12 MOD
and 18 MOD sewage treatment plant.
Ws believe at this juncture a word is appropriate as to our view
of EPA1s 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. Vfe 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. Vfoile 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
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: l) expansion
of the North Chicago plant, 2) additional facilities at the Wnukegan
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 ii) a pumping station, force
main, 2j and sewer to convey the effluent from the Waukegan plant to the
Des Plaines River, 5) sedimentation and chlorination facilities to treat
V Interceptors are large sewer mains which collect sewage from smaller
mains.
2/ Force mains are pipelines which convey pumped sewage.
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NORTH SHORE SANITARY DISTRICT
LAKE COUNTY, ILLINOIS
REPORT ON SEWAGE DISPOSAL
SUPPLEMENT NO. 3
SEWER DISTRICTS
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GREELEY AND HANSEN
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storm overflows ^/ at Winthrop Harbor, Zion, Waukegan, North Chicago,
and Highwood, 6) a -": cs::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, southermost 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: l) 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 MDD from
the souther sector of the District, V 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 wastes 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. Thsss
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 MOD will be expanded to
U.26 MOD by 1990 and it will provide only pre-treatment before the flows
are pumped to the new Gumee facility. The Waukegan plant's capacity
is 9.5 MGD and it will be expanded to treat 20 MOD. At the Clavoy
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Road plant, the design capacity will be increased from the present
U.5 MaD to 18 M}D. The new Gumee facility will now have a capacity
of 17.25 MOD _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 lb./d of
suspended solids. Specific discharges and relative loadings are identi-
fied below:
1990
Location Receiving Flow Through
Sewage Treatment Plant (STP) Waters STP lb/BOD/d Ib/ss/d
1. Waukegan Des Plaines 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 l,5h&
Total to Skokie Rlvar 593 7u2
These figures reflect the calculated design effluent quality subsecruent
to advanced waste treatment at each location and will be in coraplaince with
permissable stream loadings under applicable water quality standards.
II. IMPLSMJMTATION NESDS
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 Gumee facility.
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Interim chlorination facilities have been provided at the seven lakeside
plants as directed. Other pertinent requirements applicable to this
project are: l) 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 Flaines River where
necessary under interstate water quality standards, li) 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 U, 1970, the Illinois Sanitary Water Board (now the
ILlanois 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 511,550,000 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 $35 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 Jtebruary 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. NESD 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
Assessment. The applicant was requested to prepare this assessment
and on December 1U, 1970, the Environmental Assessment was received in
the Regional Office.
V. 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
7/ At issue in litigation are zoning, the validity of 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
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had not been provided at the Clavey Road plant against odors and
possible airborne infection.
On februaiy 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 this matter, the Clavey Road proposal was modified
to incltide covers for the primary settling tanks 8/, aeration tanks and
filial 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 10/. 3y 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.
2/ These two processes are referred to as the Activated Sludge process
which reduces the organic content of sewage by forced aeration and
gravity sedimentation.
10/ 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 THE ENVIRONMENTAL STATEMENT
INTRODUCTORY CONSIDERATIONS
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 Iiqpact of the Proposed Action on the Environment.
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 cummulative impact of the total diversions, present
and projected, from the Great lakes System into the Mississippi River
Drainage Basin. 11/. 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 Effects 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
j_V 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 Siforcement Conference or other
regulatory requirements. However, the applicant and other municipalities
have chosen to remove the effluents from the Lake 12/.
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 stornrwater 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. THE DSS PLADJ3S RIVSR 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 GFS and that there have been periods with no measurable
flow during the period of record. The average discharge for 2U years
of record a'; this gage is 203 CFS.
This river typically exhibits periods of extremely low flow in late
summer, fall, and perhaps through the 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 CFG 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 apt>roxiuiately 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 jShort-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
111) 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. 3. 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 Glavey Road facility dis-
charges its effluent into the Skokie River at a point approximately 7
miles downstream from the Lake Forest gage and approximately 5 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 MGD (9.3 CFS).
This plant is currently overloaded, resulting in poor performance of
the individual processes.
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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 formation of bottor/i deposits. These lagoons
have been used for boating as wtll as other recreat-ionai activibie'3,
but their continued intensive use is being jeopardized by the degrada-
tion of the quality of water.
A. The Probable Impact Of The Proposed Action On The Environment.
The applicant's proposal would increase the capacity of the Clavey Road
treatment plant to 18 MGD 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 MGD (28 GFS) 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 MGD (9.3 GPS) to 18 MGD
-------
(28 CFS). The discharge of 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 stormwater 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 Plaines 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 Clavee 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_'j5
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 obvious o 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.
-------
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 naw 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 l|f>-foot diameter
sludge storage tanks, two 'elutrjLation 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 29,8UO 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 present0 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.
l6/ 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
hunan life patterns.
3) Clave? 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 U5 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 apparent0
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. I?/ 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.
177 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 plant,, 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 stormwater 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 sever 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. l6/
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.
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unavailability of needed land to expand the existing lakeside
facilities or to acquire a large single lakeshore 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 18 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 minitnum 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 naximura 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 minimize 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 ccce expanded. Wherever 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 presedimentation 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 water-borne diseases indicates differences
of opinion as to the occurencea 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
-------
Medical School, testified that in his opinion no danger presently
exists. Dr. Bertram Carnow, Chief of the Section of Environmental
Health, University of Illinois, indicated in the Waukegan hearings
that adequate studies have not been perfarmed 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
-------
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 treatment
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 maximum
protection at this time.
Complete covering of the entire retention basin offers the best
way to effectively minimize any adverse effects resulting from poten-
29
-------
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 Standards at the Clavey Road plant.
li) Qurnee. The adverse impact 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 encoxmtered 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.
3. Alternatives To The Proposed Action.
1) Waukegan. The alternative is to eliminate any opportunity for
stomwater 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
MGB), is now treating average flows of 6 MGD. The proposed plant will
also receive wastes from the five lakeside plants that will be phased
out by irdd-1972. As a result, the flow to Clavey Road will be increased
30
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to about 11.3 MOD upon completion of the plant. Since no facility
other than the Clavey Road plant will be available to acconodate
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-Cook County Line,
and the industrially zoned area of Rondout immeda ?tely west of Lake
Bluff. In selecting these three possible plant locations for comparison,
consideration was given to other sites, but none were believed
feasible. lj?/
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 Table 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-denitrification for ammonia removal and chlorination of
the effluent; 2) alternatives would be sized for the anticipated 1990
sewage flow of 30 MOD; 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.
-------
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-------
basinj k) 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 $U.O million
even with a phase out of that facility. This interim expansion to
12 MOD capacity at davey Road would be required since a major plant
at a second site could not be on line until possibly 197£. It would
consist of the existing primary treatment 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
$U.O million of each other which shows a cost differential of seven
percent,, Alternatives involving the 12 MGD and 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 $3 1/2 million more than comparable development at the Des
33
-------
Plaines site (option G & H) depending on the size of the facility.
The annual costs for operation and maintenance would be essentially
the same at both the Rondout and Des Plaines sites as shown in
detailed estimates contained in Appendix E. Because of the economic
disadvantage at the Rondout site with no apparent offsetting environ-
mental or social effects, no further consideration will be given in
this report to development at the Rondout site.
The review of capital cost in Table 1 thus reveals a feasible
alternative to the applicant's, namely, alternative number Uj Clavey
Road plant with reduced capacity to 12 MGD, tertiary treatment and
nutrient removal, complete covering and deodorization and a. 10 MG
retention basin. This is utilized in combination with a 18 MGD plant
of similar design and a 20 MG retention basin at the Des Plaines site.
This alternative involves the addition of 7.f? MGD capacity to the
existing primary, secondary, and disinfection facilities at the Clavey
Road plant. The retention basins at both sites would be covered to avoid
the possibility of airborne infection. The costs shown for the two sites
indicate that savings in relation to capacity would occur with the larger
retention basins at the Des Plaines plant.
Annual costs for operation and maintenance have been computed for
three points in time—I960, 198$, 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
B&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. Oetailed evaluations of the anticipated cpei'^i ^JL.
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-
-------
13ie 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.? million will be incurred
if the 12 MOD 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 MOD 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
-------
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.
10 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. PUBLIC OBJECTIONS TO PROJECT AND RESOLUTIONS
A. Applicant's Original Proposal As Contained In 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 Glavey 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 MOD was placed on the Clavey Road installation,
Uo
-------
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.
Ul
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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 N5SD 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 NSSD project was measured.
-------
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 MGD plant, given the unique features and conditions
on the Clavey Road facility as they now stand? :
-------
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 I960, 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
-------
rise and in all probability, the more difficult it will be to sec art;
the necessary land.
The determination of relative impact on the environment yields the
conclusion that there is no significant difference when con3iuerinr a
!;• KGD plant versus an 18 MGD operation, given the highest Jeve.l of
environmental controls and safeguards herein identified for Lhe i.-iv.y
Road plant.
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RECOMMEMPATIONS
Based en the review and discussions contained in the preceding
t,ext, the Wsber Program Office recommends:
1. The Horth Shore Sanitary District prcceed with the total sewer-
age project as originally proposed and outlined on pages 1 and
7 of this document, but with the following additions:
a. To meet environmental considerations, additional stormwater
retention and/or treatment ce provided as necessary at
Waukegan and North Chicago.
b. The Clavey Road treatment plant provide the necessary ad-
vanced waste treatment unit processes for direct discharge
(
to the Skokie River and the retention basin ce covered to
protect the local residents from cbjecoicnable 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.
-------
h» The North Shore Sanitary District is advised to limit environ-
mental damage during construction and to restore disrupted areas
to their former condition.
5». 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 Water 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.
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APPENDIX A
COMMENTS RECEIVED ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
-------
ALLEN J. CLLKNDKH. LA., CHAIRMAN
JOHN L. MCCLFLLAN. ARK.
WAHREN G. MAGNUSON, WAIH.
JOHN C. STENNIS. MISS.
JOHN O. PASTORE, R.I.
ALAN BIBLE. NEV.
MIK€ MANSFIELD MONT.
WILLIAM PROXMIRE. WI3.
JOSEPH M. MONTOYA, N. MEX.
DANIEL K. INOOYE, HAWAII
KRWCST r, HOU.IHOS, B.C.
MILTON H. YOUNG. N. DAK.
KARL E. MUNDT, S. DAK.
MARGARET CHASE SMITH, MAIN!
ROMAN L. HRUSKA. NEB*.
GORDON ALLOTT, COLO.
(<*{ '
^£>ictte&
HIRAM L. FON
-------
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
Adlai E. Stevenson, III
United States Senator
Robert McClory
United States Representative
-------
ROBERT McCLORY """^ °KFICF B""-»"^
(202) ^23-b^Zl
1ZT. DISTRICT , ILUNOIS
DISTRICT OFFICE-
JUDICIARY COMMITTEE posT OFFICE BUIUDING
Congress of flje ®mteu States
ANTITRUST (3)2) 335.4554
IHaa&foston, 53.C. 20515
May 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 recommendations 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;
-------
3) Tf"? 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 ye£,r ago and was determined to be unnecessary.
In any event, a recommendation made to the contrary
at this tine should also include a recommendation
th-ir additional Federal funds be made available for
4) 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 tMarch 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 etherise provided by or pursuant to court order . . •
be displaced by Federal enforcement action." (33 U.S.C.A.
§H60(b)) In this instance, the Regional recommenda-
tions would delay pollution abatement, stymie building
activities, and destroy state initiative.
-------
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 McCiory
Member of Congress
RMcC/jwo.
cc: Senator Charles Percy
Senator Adlai Stevenson
Governor Richard B. Ogilvie
Mr. Viilliam D. Ruckelshaus, Administrator
Environmental Protection Agency
-------
ALLEN J. ELLENDER, LA., CHAIRMAN
JOHN L. MCCLELLAN, ARK.
WARREN G. MAGNUSON, WASH.
JOHN C. STENNIS, MISS.
JOHN O. PASTOHE, R.I.
ALAN BIBLE, NEV.
ROBERT C. BYRD. W.VA.
GALE W. MCGEE, WYO.
MIKE MANSFIELD, MONT.
WILLIAM PROXMIRE, WIS.
JOSEPH M. MONTOYA, N. MEX.
DANIEL K. INOUY6. HAWAII
ERNEST F. HOLLINGS. S.C.
MILTON R. YOUNG. N. OAK.
KARL E. MUNDT. S. DAK.
MARGARET CHASE SMITH, MAINE
ROMAN L. HRUSKA, NEBR.
GORDON ALLOTT. COLO.
NORRIS COTTON. N.H.
CLIFFORD P. CASE. N.J.
HIRAM L. FOMG, HAWAII
J. CALEB BOGGS, OEL.
CHARLES H. PERCY, ILL.
EDWARD W. BROOKE. MASS.
COM M ITTEE ON APPROPRIATIONS
WASHINfTnN DC 2QS1O
WASHINGTON, U.C.. ZOSIO
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 Richard B. Ogilvie
Mr. William D. Ruckelshaus
-------
nOBEST McCUORY
IZTH DISTRICT. ILLINOIS
JUDICIARY COMMITTEE
SUBCOM M1TTEES:
ANTITRUST
SUBMERGED LANDS
MEMBER:
U.S. INTERPARLIAMENTARY
UNION DELEGATION
Congress of tije Untteb A
2)ouse of Eepresentattbes
, Ji.C. 20515
May 21, 1971
ROOM 426
CANNON HOUSE OFFICE BUILDING
(202) 225-5221
DISTRICT OFFICE:
POST OFFICE SUILDING
326 NORTH GENESEE STREET
WAUKESAN, ILLINOIS 60085
(312) 336-45S4
Mr. Francis T. Mayo
Regional Coordinator
Environmental Protection Agency
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 deves-
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 confronting our joint
efforts to combat the spoil^g-: 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 Perc;/
The. Hon. Adlai Stevenson
William Ruckelshaus, Administrator. EPA
Sintzerely youns,
Rob er t IlcClo *v - iT.
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*» DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
"% tulfflt / 360 NORTH MICHIGAN AVENUE, CHICAGO, ILLINOIS 60601
"0>»13fl I****
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. Kisley'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,
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 606O5
WCDPD-ER
Regional Director
U. S. Environmental Protection Agency Region V
Attn: Mr. Gary Schenzel
Water Quality Office
Room UlO, 33 E. Congress Parkway
Chicago, Illinois 60605
Dear Sir:
This is in reply to your letter to Col. J. B. Itfevman, Executive Director
of Civil Works, Office of the Chief of Engineers, Washin.Tton, D. C.
dated 22 April 1971- You request commentc on a Dra.'t Environmental
Impact Statement for a proposed sewerage project by the Kcrth Shor,.
Sanitary District of Waukegan, Illinois.
The draft environmental statement has been reviewed and 13 -jerv id^rt; j
satisfactory. We do feel that this and future diversions will increase
flooding on the Des Plaines River. Seme communities now 7iiff~:-ing fvor.
flooding will certainly "be affected by these di-ercions. Flood ?
studies underway in the Chicago District may help ~c alleviate this
problem.
Sincerely yours,
JAMES W. GILLAI03
Colc-.-ol, Corpc- of Engineorc
r,c-;>
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OFFICE OF THE SECRETARY OF TRANSPORTATION
WASHINGTON, O.C. 20590
ASSISTANT SECRETARY
JW r' "• '-71
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,
Herbert F. DeSimone
I
| v~\ Assistant Secretary for
/ij 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 lir. Risley:
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.
The 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 f ••
is appreciated. --- x •_ -.
Sincerely yours, /
V .1-
r ' —
Roger 0. Egeberg, 3F7D.
Assistant Secretary
for Health and Scientific Affairs
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United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, B.C. 20240
JUN 8 197^
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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OPTIONAL FORM NO. 10
MAY iM
e«A mm (a cm) i«t-n.«
DATE:
20>
UNITED STATES GOVERNMENT
Memorandum
TO : Francis T. Mayo
Interim Regional Coordinator, EPA
FROM : F. Donald Maddox, P.E.
Acting Regional Representative, DWH
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 office. We understand that Mr. Van
Mersbergen has received a copy of this document for review.
Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Washington, D. C. 20250
JMA. . .• 'S71
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,
, dministrator
•Voting
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QrF'GS OF THE ASSISTANT SECRETARY C~ CG
Washington, D.C. 20230
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/ -
tion by all appropriate agencies within the Department r:!
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 comment be transmitted In 15 copies to the_
Depu>y Assistant Secretary for Environmental Affairs for
review and further distribution as appropriate^.
Sincerely,
a
Sidney R. Caller
Deputy Assistant Secretary
£6r ^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.
Sincerely
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 the 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 Clovey 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 NSSD 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.
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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, depen.'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 MnO? formed is insoluble,
and therefore not a water pollutant, as might 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 dispe/ised in significant
quantities from uncontrolled plants. It is probably, therefore,
that no biological 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
per^Ked 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 flSSD may find that a water
scrubber installed before the KMnO, 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 seam 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.
Since the NSSD is to install iron sponge purifiers to remove
H2S in the sludge gas, which I presume they will use as a fuel
in 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 TKUSTEES
f.-esiden^ Robert P. Will, Winthrop Harbor
W.-iliam T. Jones. High/and Park
treasufer, Ross A. Granna, Waukegan
Donalcf L. Wylie, Lake Forest
comptroller, Richard D. New/and, Waukegan
north shore sanitary district
SECRETARY-GENERAL MANAGER, RAYMOND E. ANDERSON / DAHRINGER ROAD, WAUKEGAN. ILLINOIS 60085 / Telephone: 312/623-6060
A TTORNEY
Murray R. Conzelman
SUPERINTENDENT OF MAINTENANCE
Joseph J. Debevic
CH,EF ENGINEER May 13, 1971
H. W. Byers
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. T
,-7
-> -,
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
MAjesti- "-1010
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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 source
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 13 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
i e-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 Statemer
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 construe
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 f"ue judgment made.
-o-
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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,
:he 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 DesPlaines
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 within
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.
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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 \Vaukegan 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 Highland Park were added was 12. 1 million gallons per
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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.
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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.
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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.
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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
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STATE OF ILLINOIS
ITTZO.^ CO^'THOJ- 33-OA14JJ
189 WEST MADISON STREET SUITE 9OO
DAVID P. CURRIE.C-IAIRMAN CHICAGO, ILLINOIS 6O6O2 TELEPHONE
SAMUEL R.ALDRICH 312-793-3620
JACOB D. DUMELLE
RICHARD J. KISSEL
SAMUEL T. LAWTON.JR.
May 20, 1971
Mr. william Ruckelshaus
Adminis trator
Environmental Protection Agency
1626 K Street
Washington, D. C. 20460
Re: Draft Environmental Impact Statement
Sewerage Project Number WPC-I11.-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, 1971
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 put in a real, and uncalled for, quandary.
The mere issuance of the report has done nothing more 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 expensive delay.
Perhaps before the frustration and anxiety of the Board and the
majority cf 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 giver, the "go ahead" to start its expansion
program. The District established a plan at that time and took it
to its constituency in the form of a $35 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 cr administrative proceedings. A detailed outline cf 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.
It is estimated that for each mor.th cf delay, the cost vill be
increased by about 1%. On that basis a delay of even six months
could mean an additional cost to the cecols of the District of. almost
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Mr. William Ruckelshaus
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, when and if completed, will include tertiary
treatment, nutrient removal, and adequate chlorination at all of its
facilities. No wastes will be discharged into Lake Michigan, except
on rare 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 Gurnee) 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
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 cremise on which the report 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 qapacity 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 Distric-
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 IB mgd capacity is $20.44 million. The total cost of an
18 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,
sewage treatment plants have been located in area?; vh^rp> npnplp 1 i \/e -
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 accomplished
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?
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Mr. William Ruckelshaus
May 20, 1971
Page Five
Shouldn't they all be moved 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 means is that the EPA should ooen uo 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—Dees 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 IPCB has rules . . . that an effluent from the
Clavey Road facility must be given tertiary treatment before
discharge into the Des Plaines River" (Emphasis supplied) .
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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 thejrClavey 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 ancl orders of this Board.
V
RJKrbt
Encl.
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FCL\ SZ",r^-
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retention basins must be reduced frorr. their 20 million gallon size
-co a. lesser size (10 million gailcr.s was orally suggested' by the
draft sea-cement' s author) and (2) the Cl'avey Road Plant's reten-
tion basins must be covered and (3) an 18 million gallon plant
should be promptly built on the Des Pli.ir.es River with covered re-
•cer.-c.ion basins. The League objects to these changes for the facts
c.o not support tr.em. _?urtner the League oo3ects to tne Federal.
Lnvironmental Protection Agency halting grant funds to the portions
of the North Shore Sanitary District's plan to which the Federal
Government does not object. The delay caused by the Federal
Government's withholding funds granted to the North Shore Sanitary
District over a year ago is quite serious. In the Illinois Pollu-
tion Control 3oard 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 North 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-
turn in the euthrophication process. So testified Dr. Eugene
Stcerraer 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
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show new and more serious degradation of the Lake have been spoteed
this year off the shore of the area served by the Xorth Shore Sanitary
Discricc.
AHSTETIC CGXSIDZPJITICXS 0? TH2
SIZE 0? THE CLAVZY ROAD PLAXT
The author of che drafe statement states that the proposed
Clavey Road plant expansion should be limited to a 12 million gallon
per day (XGD) capacity instead of an IS XGD capacity. I-Ia scaees
that an 13 2-iGD plane would .oe j'ust coo large for a residential
neighborhood. Yet, he does noc indicate the difference in the
physical size of the two plants. Me probably never attempced
co ascereain this and, therefore, his conclusions are subjeccive
racher than objective. Further, he ignores the fact chac land-
scaping could negace che presence of an 13 XGD plant. There is
a large burner strrp becween en.e plane and che nomes cnac cou_c. oe
planted wich trees and bushes so as to generally hide che plane
from che homes. The plant will be a one story plane jo this should
not be too difficult especially since the homes in che area are
mostly one story ranch style homes. 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. ?ureher, the covering, if made, will not be so high
as cannoc be obscured by trees and bushes. The engineer for che
Xorch Shore Sanitary District stated that proper landscaping would.
diminish che effect of the oianc's presence. Page 12 of che
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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 preempred 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 site selection
from its inception...is an obligation and responsibility of the
local regularory agency in addition to being a very strong res-
ponsibility of the state water pollution control agency and by
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the tine 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 XGD 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 Clavey 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. Th.e 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 Xorth
Shore Sanitary District's plan for an IS XGD plant at Clavey was
•Grocer.
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THE REDUCTION I\ SIZE 0? 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 to _2 MGD and the retention
basins should be reduced from 20 MGD to about 10 MGD (he stated 10
MGD orally). Ke 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 drafz statement presumes 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 scon be overloaded. However, in March
cf 1971, the Clavey Road plant, according to th
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receiving an averags flew of 7.1 MGD 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 ir.ay not stay in use) which averages be-
tween .5 and .7 MGD overloading the 12'MGD 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 Control Board hearings that based on ex-
perience the 13 XGD plant with 20 MGD 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 MGD 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 tlie 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 MGD flows were received
at Clavey Road at various times. Prom observing records of
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Sanitary District for the Clavey Plant, it: is noted that in May
and early June of 1970 there was one flow of 16.21 MGD, one of
16.42 MGD, one of 16.89 MGD, one of 18.04 MGD, one of 19.26 MGD
and one of 26.74 MGD. Some of these flows were back to back. On
June 8, 1969 there was a flow .or just the Clavey area of 23.08
followed, on June 9 , It > 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 287-89 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 13
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
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as che Clavey plant became overloaded the bass and perch perished.
Last winter National Geographic gave national coverage ro a fish
kill of thousands of carp in the Skokie lagoon due to an ice cover
on water whose oxygen was depleted by oxygen consuming organic
wasce frcr:. zhe Clavey sewage plant, uhe main source of such waste.
Francis Mayo, Acting Coordinator of EPA Region V was quoted in
thaz 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 •cher.. During 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 Ciavey plant. A
700 acre recreation center is going to waste and it is passed over
lightly by the author of the draft statement. People who come
in contact with the water can become diseased due to its not being
•created. The Illinois Pollution Control Board considered this
problem and said that the 18 MGD effluent with tertiary treatment
would flush these lagoons and make this 700 acre recreation spot
bloom again. However, if the Clavey plant is restricted to 12
1-lGD it will not handle all washes and shameful pollution of the
Skokie 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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TM FORCED EXPENDITURE C? MILLIONS OF DOLLARS
TO COVER RETENTION BASINS DUE TO SUPPOSED ODORS
AND SUPPOSED VIRUS DANGERS is VJRGNG BECAUSE
SAID DAGGERS WILL NOT EXIST.
Tlia 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 Rearing to be 2-1/2 million dollars.
A covering for a 10 MGD retention basin would cost in excess of
$750,000. If hazards cause the covering at these plants, ail similar
plants should be covered. Facts indicate that the covers will not
be necessary at the expanded Ciavey Road plant. The author of
the draft statement confines himself to odor problems and disease
problems involving the retention basins because he recognizes the
sophisticated system involving catylitic (now thermal) combustion,
oxidizing with alkaline permanganate, negative pressure to prevent
leaks out of the buildings, forced air and many other protective
measures to stop odor and other contamination.
The author of the draft statement wants the retention
basins covered because "a malfunction of mechanical equipment
related to the operation of the retention basin or presedirnenta-
tion basin followed by untimely corrective measures would in theory
/,
produce a very unpleasant situation.
To place this situation in its true light we must point
cut certain facts. First, these basins would be used about 13-20
times a vear if the -slant was an 1C XGD olant. Their use orevents
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bypassing willed is against: Federal po"$'i£y. The covered prssedimen-
tation basin would be the basin used 13-20 times a year according
to the testimony by the I\TOrth Shore Sanitary District. That basin
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
chlorine then can work better on bacteria, odor causing agents, and
virus. It was estimated that if the plant was 13 MGD, the initial
filling of the covered presedimentation. basin would cause the reten-
tion basins to be used only 12-14 times a year. There would be two
retention basins, each of 10 XGD 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 S0% of the
solids are removed in that basin before the dilluted 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 recircuia-
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 the 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 st.and.ards, they will be found well below the harmful
level. Other concerns of Dr. Carnow like iron particulate matter
12
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are many pathogenic viruses in sewage. But their presence does
not cause disease. A ir.eth.oa 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, PhD who we learned works principally in the area
of soil rr.icrobiology. 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. Dein-
hardz 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
I-lcspi-cai. Dr. Lorenzo wher, 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
ueen 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
bacteria 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 the 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 rhe
Berg article on page 145 of the appendix merely show that there
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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. Carnow's statements on gas
were discussed above. Dr. Carnow admitted in the proceeding before
the Illinois Pollution Control Board that he did not know if the
Clavey Plant would cause harm. It is terrible that the author of
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 airjl 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
British 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. That is being studied. Studies
indicate that pathogens carried by water particles in the air have
15
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have a short average Life span. Some illness including hoof and
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.ad in the retention basins. •
A windbreak of trees and bushes ccu_d 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 also 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 o
Kanover 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-
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ment. That 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 PLANNING CAUSED THE RECOMMENDED PLANT
ON THE DES PLAINES RIVER 3E 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 attempt 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 Clavey.
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. States Department of Commerce and the United States
Department of Agriculture on pages 85 and 93 of the Appendix, there
are some flooding problems on the Des Plaines River. The author
of the draft statement ignores this and ignores the concepts of basin
and regional planning. The Gurnee and Waukegan Plants will add 30
MGD to the Des Piaines. The O'Hare plant and the Salt Creek Plant
of the Chicago Metropolitan Sanitary District will add 78 MGD to
that stream. Can that river afford the 18 MGD plant that is proposed
- the craft statement? Shouldn't we wait to see how those plants
affect the river? Should the 6 MGD be taken fr<—'. Clavey to the Des
Plaines River when other areas on the Des Plaints River may need
that capacity whereas the North Shore Sanitary District is the only
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District really using the Skokie 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 1980, one looses out on gaining technolo-
gical advances made during the next five to eight years. Possible
better methods of treatment will be sacrificed. Many technology break-
throughs are on the threshold. Uinox would enable a smaller plant
to be built in the future. The Army Corps of Engineers is working
on 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, it then would be filtered through sand, filtering out
viruses and it would recharge the ground water. Denitrofication, 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 14GD including an inflation factor through
construction is $19,046,000. These costs were filed with the Illinois
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
IS
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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 the NOrth Shore area except the
Highland Park LEague 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 Skokie 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 6C602
19
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RICHARD X. KATES
At.torr.3y a- Law
120 West Xadioon Strecrc
Chicago, Illinois 60502
(312) 346-01-15
May 25, IS71
Mr. Francis T. Mayo
United Stazes of America
Environr.er.-cal Protection Agency
Region V
Water Quality Office
33 East Congress Parkway
Chicago, Illinois 60505
Dear Mr. Mayo:
Pursuant to the authority contained in the _.-tached lecter
sent by your acting regional director giving the League through
May 25, 1971 to submit comments to your office on the _:cr~h Shore
Draft Environmental Statement, v;e hereby request and require that:
the enclosed Appendix be attached to cur corrraents which were de-
livered to your office on May 2-.-, 1571. "his letter is being hand
delivered to you on May 25, IS71.
This Appendix is also being attached to the cc~".2nui cf
the League of Women Voters of the State of Illinois which are being
delivered by the request of certain orh^r 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 letrer with rhe original photographs is being
sent directly to Mr. Schenzel. Please excuse "che high degree of for-
mality which I am using in this rr.a-c'cer. Iw is no reflection on any
member of your staff. It is merely an a-ctorney's caution.
Sincerely,
Richard I
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APPENDIX A
DR. DEINHARDT
The purpose of this paragraph is to state some of the quali-
fications of Dr. Deinhardt, who served as the League's witness and
advisor regarding methods of transmission of bacteria and virus. Dr.
Deinhardt holds a Doctor of Medicine Degree (Sumrna Cum Laude); he is
the Chairman of and Professor in the Department of Microbiology of
the University of Illinois Graduate Schools and Medical Schools;
Chairman of the Department of Microbiology ae the massive and nation-
ally known Rush Presbyterian St Luke's Medical Center complex in
Chicago, Illinois; consultant to the Board of Health of the City of
Chicago; member of ehe U.S. Surgeon General's Advisory Committee on
general medicine; special consultant, National Institute of Health;
associate member Commission on Viral Infections, United States Armed
Forces Epidemiological Board. He has published more than 50 articles
in nationally known medical and scientific journals including the
Journal of Iraunology, the Airierican Medical Associate Archives of
Internal Medicine, rhe Journal of Virology, the Journal of Experimen-
tal Medicine and -che American Journal of Hygiene.
he Hanover Plant of zhe
Metrcpolitan Sani-ary District. They were senz by that district: i
answer to a request cf the League of Women Voters of the Srate o~
Illinois for pictures of one of fcheir waste treatment planes wnicn
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v:as located in a residential area. ±- is cur understanding that the
President of -che United S-cates has visited that plant as an example of
a:i updated treatment planz. The covering or. the :\'orth Shore Sanitary
District Plant is more complete than -chat on -c.he Kanover Plant. There
is no indication of any disease in the area of the Hanover Plant which
was caused by -che plant. If you will examine the pictures, you will
noce that there is a school immediately next to plant facilities and
there is a walk through the open facilities of the plant to rhar school.
The close proximity of the children to zhe planz has lead to no notice-
able disease problems. This plant is smaller uhan the proposed North
Shore Plant, buu its proximity to the children is exceedingly closer.
-------
Technical and Engineering Comments
by
l_ake 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 l_akes Region
April 23, 1971
Amos Turner
Registered Professional Engineer
Illinois License No. 19471
May 21, 1971
.1,
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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 R ecommendations 6.
2.1 Additional Stormwater Retention 6.
2.2 Size of the Clavey Road Plant 7.
2.3 New, 18MGD plant on the Oes 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 1 ]
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.
germs, viruses and possibllly of air borne
infections
3.0 Conclusion 12.
1 .
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ABBREVIATIONS
FWQO Federal Water Quality Office
G £* 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 Oeneral
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 on 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 &• 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 recommend
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 attenc
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.
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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-'
lion 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 Clavey, to
establish a "Fait Accompli" and to force the enlarged facility 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.
1PCB 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 IPCB takes
objection to the FWQO recommendations, which would benefit
ail and hurt no one.
b. NSSD was ordered (IPCB order Item No. 7) not to
permit 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 , fj Lake Ccunty Constructors Assr . 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 ciairn that they
were not part of the proceedings and that "work stoppage caused
by item 7 of IPCB order would result in wide spread urem-
ployment of construction industry related labor in the NSSCJ
boundries, cause financial ruin and bankruptcy of a great number
of individuals and corporations engaged 'n the construction ;-dustrv
cause financial ruin and bankruptcy o, a substantial n^mce-- of "^'
dividuals ^ Corp. who have invested in property to be deve'oped *>
-------
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 Rlaines river , thus requiring an
Advanced treatment plant. On August 20, 1970 or 9 months
ago L-MPotEE 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 spent
about $300,000 on the lagoon through April, 1971. NSSD
would not commit Itself to a phaseout of the lagoon,as ^soon 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 "F"WQO 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 &c H that Clavey Plant, if expanded in
accordance with IPCB order to 18 MGD , would be overloaded
by 1980, the IPCB did not allow a discussion on remedial actions
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 Mayor
of HP requesting stopping of the construction of the Effluent
Lagoon.
f. C S' H admitted under cross examinatic-; that trere A-!! b^;
monitoring of H2S,SO~ anc Chlorine Oas, but not of other-
pollutants, as has been ordered by a circuit court. The K-~--<~~;_
did not order the district to monitor other pollutants.
-------
g. The total program, including diversion of the Lake Front
Plants, was estimated by G £* H in June, 1968 at $9,830,000
(see Application to NUPC , project 068^. The Program was
estimated by C-reeley fy Hansen or' April 23, ;r"7l
$95,270,000 or approximately ten (10) rimes as mui'-i . And
at Clavey, the program provides for 1950 needs <=r". -ol for
1990 needs as contemplated all the tirne.
LMPotE ard/or the individual claimants ha-.-e appealed the IPCB order
because of the reasons described in the above paragraphs a-q 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'1 . We commend the FWQO 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 *> H . None of the suggestions f and comments contained herein
should be ^sconstrued by anyone, as opposing or disapproving the
basic intent of the FWQO in providing^ maximum safety and protection
to the people and to the envtrdnment, commensurate with cost
considerations.
In, order that the people living near Lake Michigan are assured of tt- «-
high quality of the water that they drink and swim in, and that the
Sewer Connection ban is lifted, securing employment and preventiny
hardships to thousands of families in eastern Lake County, the expan-
sion and/or the construction of new sewage treatment facilities In the
NSSD district should proceed, but with the following exceptions.
2 . 1 Additional Stormwater Retention (FWQO R ec . it. No. 1 a )
O &• H admitted at !PCE hearing on April 29 and 30, 1971 that
overflows of raw sewage into Lake Michigan will continue. FWGO
recommendation, item la, to provide additional Stormwater retention
at Waukegan , North Chicago, and the lakeside pumping stations, if
properly sized, would eliminate any discharges of raw sewage into
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 he used to provide maximum safety. The basins
could be either underground or covered, with proper ventilating and
air pollution control devices and proper landscaping.
6.
-------
If a retention basin is located at the Cary Avenue pumping station,
the retention basin at Clavey Road could be eliminated or reduced
to a maximum 5 MG size.
2. 2 Size of the Clavey 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 Clavey Road or Highland
Park have objected to a reduction of the Clavey Road Plant because
of misinformation and erroneous assumptions.
The facts are as follows:
The reduction of the Ciavey Road Plant would not ctelay 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 Clavey Road
3. North Chicago Plant additions
4. Waukegan additional treatment facilities
5. Middle Fork Sewer
6. Gurnee - secondary facilities (November 1, 1973)
The projected completion date of engineering for additional treatment
facilities at Clavey 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) facility would not have to take 21 months but could
be shortened almost in proportion to the reduction in size.
The 1PCEP order is being appealed by the NSSD, the Lake County
EPuilders Assn. and the Lake County Constructors Assn. and
LMPotE. 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 ' 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.V.PotEl. When and if this hapocns, a!! litigation byLMPoiE
will be dropped and a spirit of co-operation established, which may in-
fluence the other interested parties to drop their litigation.
-------
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 lm 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
Art 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 new
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 Clavey
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 flow ai Ciavey by 1974.
-------
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.P..
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, 16MGD 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 l_agoon.
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 Effluent Lagoon
The history of the Effluent Lagoon was described above. lA'e « ^O-A- ~cv*
that construction of the Lagoon should have r- '^.
mental , ecological damage to the area of the Vl'aae or the A'oods
could have been avoided and the taxpa\ ens wouid *••?.• «.- .">• *->i $3uu.COG
to $400,000.
-------
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 as 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 affluent.
Effluent lagoons are used in areas where land values are very low.
!n accordance with established 10 State standards, they 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 G £> H Studies in 1967).
An advanced treatment facility will be built at Clavey. !t could be-
come operative not on November 1 , 1974 as shown on NSSD sche-
dule of 4/28/71 but sometime in 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 IPCE3, a much smaller
i-,v5Stment 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 ,
now located across the road from the lagoon.
2 . 7 Chlorine Handling
CHfonine Institute's pamphlet on "Facilities and Operating Procedures
for Chlorine Storage" states in P. 2.1 Oeneral Area, "Where
pnactical , tanks should be located away from densely occupies areas.'
As chlorine gas is poisonous and the chlorine ton cylinders would be
located outdoors about 150 feet away from homes, the use of Sodium
Hvpochlorite in lieu of liquid chlorine is imperative. Dr. Quon , con-
sultant to the 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 sodium hypochlorite solution at all of its plants. NSSD is
using it at the 5 lake front plants. The City of Chicago does not
allow cnlori^e within 1/9 of a. mile of homes. The Building Officials
Conference of America Basic Fire Prevention Code, adopted Dv the
Ci{\ of HP .^ . orcl--ance requires a i rour fireoroof builci-.g for
storage of chlorine.
ing, r'n e .j^e of Sodium Hypochlorite is im-Derati ,-e
of liciuid 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 FWQO recommenda-
tion is commended highly.
2.9 Study of environmental consequences. of diversion of water from one
watershed to another (FWQO Rec. Item No. 5a).
This study will be of tremendous importance to conservationists
concerned with possible upsetting of the laws of nature t^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 FWQO study of the problem
is commended highly.
2.10 Study including monitoring of Air Pollutants, Germs, Viruses and
possibility of air borne infection (FWQO Item No. 5bl
Although monitoring is not specifically mentioned in FWQO recommenda-
tion, LMPotE assumes that monitoring, alarm and recording will be
made of air pollutants, viruses, and germs.
G & H testifying in front of IPCB on April 29 f> 30, 1971 admitted
that the only pollutants that will be monitored will be: Hydrogen
sulphide (H2S) , Sulphur Dioxide (SO2) and chlorine gas.
If monitoring is to be of value, then it should be complete, and both
inside and around th plant.
The pollutants to be monitored should include H2S, mercaptans,
carbon disuifide, SO£ , SO^ , Sulfuric acid, NO2, bacteria and
viruses. Monitoring the mercaptans in addition to hydrogen sulfide is
essential . since they are organic sulfur compounds with odor thresholds
of approximately 100 times 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
on!y Highland Park residents, but all mankind.
-------
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 County, Illinois are built and/or expanded, at an
earliest possible moment.
The conflict can be resolved either by litigation in State and Federal
courts for a number of years, or by a reasonable agreement, sanc-
tioned by Federal and State Environmental agencies and Courts.
L_MPotE 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.
-------
*<*• • •
360 Charal Lane
Highland Park, Illinois 60035
May 24, 1971
Mr. Gary Schenzel
Water Resources Planner
Planning Branch
Environmental Protection Agency
Water Quality Office
Room 410
33 We«t Congress Parkway
Chicago, Illinois 60605
RE: Technical & Engineering Comments
on the Draft Environmental Statement
Sewage Project No. WPC-III.- 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
-------
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,
Anpios Turner, P.E.
Director
Lake Michigan Protectors of the Environment
ATrpk
cc: Hon. Senator C. H. Percy
Hon. Senator A. E. Stevenson, III
Hon. Governor R. B. Ogitvie
Hon. L_t. Gov. P. Simon
Hon. Atty General W. Scott
Hon. Congressman R. McClory
Hon. K. Bernlng
Hon. J. H. Kleine
Hon. G. W. L_Indberg
Hon. D. M. Pierce
Hon. R. R. Coles
Hon. R. J. Geraci
Messrs: W. Ruckelshaus, D. Dominlck, A. J. Barnes, F. T. Mayo,
W. Blaser, R. J. Kissel, M. Schneiderrnan, J. V. Karaganls
Drs: D. P. Currie, F. D. Voder, J. F. Pfeffer
-------
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Victor Souldln?
tipkin
Edward
Harold Kugler
Jerald Surell
Elmer Slegel
Burton Simon
Martin Schneider
Ted Tannenbaiaa
Robert Lustbader
JJenneth Brftude
Sll ftreeman
fester Schwartz
Harris
Sidney Oberaan
Jordon Glaa»«an
Lotsoff
Btffton Keener
David tfanger
Hilton Boblros
H. Goldberg
S&wftrd Bazelon
Ubert Waller
Arthur P«t*
Yale Irak*
Rlchsard Saslow
Howard Wlttepbarg
Balp* Boee.Jr.
Morrts Suson
B^^vwn
•nd Mrs.
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and Kr«.
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and Mrs.
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and Krs.
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and Mr*.
and Mrs.
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368
761
766
778
7B7
791
300
811
812
Aspen lane
363
370
383
384
178
192
201
206
211
216
226
223
260
261
266
279
280
295
296
315
320
270
277
295
30.2
322
350
Charal Lane
Stone Gate Or.
-------
Page
r.
* Vrs. Maurice Gross
Stcnezate Dr.
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Page 5
Mr. and Mrs. Alan Bloomfleld
iv.r. "^r.dKrs. Pr«nk Moyer
i-'.r. ••ir."' .yrs.
ciflrhland Place
.v.r.
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Mr.
'Ti. 3ob»rt Lerne
rtrc:. Ir'-Jir L°vin
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Mrs. and Mrs
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Mr. and Mrs.
Mr. and i-'.rs.
Mr. and Mrs.
Mr. and Mrs.
Mr. Richard
Mr. and Mrs.
Mrs. and Mrs
Mr. and Mrs.
Dr. and Mrs.
Dr. and Mrs.
Mr. land Mrs
Kr. and Mrs.
Mr. an^ Mrs.
Mr. and Krs.
Kr. and Mrs.
Mr. and Mrs.
Mr. an-1 Krs,
Mr. and Krs.
Kr. land Mts
M4r. and Krs
Mr. and Krs.
Mr. and Krs.
Kr. and Mrs.
Alan Klchell
Mr. and Mrs.
Mr. and Mrs.
Krs. and Mrs
Kr. and Mrs.
Mr. and Mrs.
Dr. and Mrs.
Mr. and Krs.
Mr. and Mrs.
Mr. and Mrs.
Kr. and Mrs.
Mr. and Mrs.
Dr. and Krs.
Mr. and Mrs.
Mr. land Krs
S^'^wwin J^nowG
..erbert
Jerry F<
:-illerd Volin
\. \. Carlton
P^vid Superfine
William Hosskarn
. L. Feiler
Edwin Turner
Irvin* Goppel
Jpseph Licata
Arthur M*
Frank
Louis Steinberg
Kahn - POR NOHTPMCOR
LeRoy Carlson
. Martin I. Stoodman
Maurice Unger
Joel Kaplan
Jack Arbit
. Jack Berkson
Manny Windton
Melvin «. Falkof
J. F. Lebow
Wm L«dany
Jeel Pox
Alvin Gaines
David R. lanski
. Lester Acelrod
. S. Buchsbaum
riicb-ard C. Hashraan
Sheldon Karor
Ludwis; Streifinder
A. H. Michaels
Bjorn Sornaen
. Laurence Raich
Wai Barman
Jacob Rosenstein
Eu«rene BlonsVy
Seymour Banksh
Richard ^einatein
Ralph 'A
Sodkln
Pone her
rfelvln
D^vid White
Kramer
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'j-50
511
533
124 Hiawatha Trail
551 Clavey L«n?
570 Clavey Lane
57R Clavey Lane
COUNTRY CLUB
13?3 Hiawatha Ct.
1037 Brlttny
1275 aherwood
1243 Weverly
730 Kimball
431 Sheriaan Rd.
Marion
Lakeside
Kone'-'ood
2323 Linden
1765 Tale Ave
11?3 BobOLlnk
1662 McCarren
866 Marion
^ Marlon
Surton
1130 Hldpre-^
Lincoln
Karion
1915 Cl^ Pri-
flii^ --arbarry
165 M«ple
303 ITeer Perk
17?? Ryr'ers L*ne
471 L" ceside PI.
2121 ^r^nc-ill Ct.
-------
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Mrs. Hlchard J. Ludw:
••'.rs. Ml ton Hock
1-ro. Maurice Flckarl
Lawrence J. Curley
<-.rs.
Mrs.
Mrs.
Mrs. Stlebel
Theodore Lest
Patrick Israel
rt. D. I.r. ^nd /.rs,
»v.r. and N.rs. Bernard
Gordon L. istyler
Kr,. And Mrs. Walter J. dlockton
Mr. and Mrs. Edwin Brown
Renkin
Henete Illes
Fir. and Mrs. Gerald E. Grensdy
Kr. and Mrs. Albert Cohn
Mr. and Mrs. A. T. .Petronen
Kr. and Mrs. William Kaplan
ttrs, and Mrs,
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^Vlei' Lane
Vlnthrop
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597 Sumac
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Su.-nac
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XI rats 11 rood
5Q0 Ranb*er Lane
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"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.
»*. Trees and vegetation be planted to pro-
vide a buffer zone.
-------
WHEREAS the Board or Education of School District 108 is
concerned with the health and safety of students, »nd
WHEREAS this Board is interested in the value of its property
holdings in the area of the Clavey Read sewage treatment plant,
and
WHEREAS the Water Quality Office of the U. S. Environmental
Protection Agency has asked for conments on the draft of its
report,
MOW, THEREFORE, BE IT RESOLVED, that thii Board of Education
of School District 108 support! in principal the recoe»endatioiM
contained on page* 37-38 of the draft of the report of the Water
Quality Office of the U. S. Environmental protection Agency.
-------
DONALD N. MANN
ATTOItNCV AT LAW
111 •OUTM OCIIIC CAHK OHIVl
HIGHLAND PARK, ILLINOIS *OQ3»
lOuiwooo J-3JOS
•is
•
May 1
Highland ^ark, minois.
We believe such action is necessary to preserve not only the comtmity
but also the total ecology of the area.
art and help in anyway possible.
PARK. NEHBRHD. AS53C.
-------
fm
m
jri-iJ
800 west fuilerton awe.
Chicago, Illinois 60614
929 2922
Co-Cho
LEONARD DUB I
©Aft C2UNDUS
V.
411
PlttMT
OffiM
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33
va la
PUa*
21, i§71
(CAF), «a *?$«•*****•*
first •* it*
tto fiMl «!M •* tte
-------
, IKe. Society Ayjuuwk. ViaJjance. Jo Ae, {jiyjutonmervt, Support* Ae.
Quality ^nyJunnatenjtoJL Q*a£t of. AptuJ. 23, Xfll, exvepi Jhtut Ae
of. Ae Qiavey. flood flawL jhovdd 6e M*olved afjLtA. a
Aod taken place*
(/ ,
Suety fyai.ru* ViaJanc*.
-------
NORTH SHORE RADIOLOGISTS, S. C.
250O RlDGf AVE.. SUITE 203
EVAHSTON. ILLINOIS 00201
Tt"LEPHONC 8 6 9 - 4 H f, O
• ••» . T I, » f ' «• , M <
". • i_ M K c A i • / M :.
Nay 17, 1971
Protection Agency
Water Quality Office
tee* 410
334 M. Owwrtii Parbmy
Qileaeo, Illinois 80605
Mr. fiary V. Schanxel 1C: Clavay tead S.T.P.
Water fctso«rc« Planner Federal Water Qeallty Offtee
Branch Envlronnental Draft
Daar Mr.
I tare before m a cocy of vmir Clavey Road draft. I support
and tree thct they be
I fa*l that a 12 M60 plant 1s still too larys and that a definite
risk prttntfal txlsts. As tha draft apparently raorasanta tha only affaetfva
eavntar aeastfra to t)M plans of ttia North Shore Sanitary District. I
1t vy full support.
Vary truly yours*
Mcaard C. Tot-bin. M.D.
KT:ds
cet ASM Turner, P.I.
-------
(->l~2)
Noi: , \STKI!\ I Li -
:'! ',' 'NC COMMJS-/ v
LEE V
WALCEVAR A
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,
Matthew L. Rockwell
Executive Director
MLR:im
Encl.
iC',. A>'.r>rrey :RA j BACH Pr
W c,t La Grange rPED V ?
'.'^go COT:T»;' ^r''1 r r; P/JC^T^
-------
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 the 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 administrative 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
pla nt.
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 elimination 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 riant, 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 affected persons should have a voice in
influencing th. final 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.
-------
GOHIKIN SHhHMAN
President
ALl \ANDER POLIKOFF
Executive Director
MARSHALL PATNF.R
General Counsel
DAVID DlNSMORE COMhY
Director of
Environmental Research
THOXIVS R. MhiThs
Associate Counsel
BUSINESSMEN FOR THE PUBLIC INTEREST
10y NORTH DEARBORN STREU r
SUITE 1001
CHICAGO. ILLINOIS 60602
(312) 641-5570
BY MESSENGER
May 24, 1971
Water Quality Office
Region V Environmental Protection
Agency
33 East Congress Street
Chicago, Illinois 60605
Re
Comments of Businessmen for the Public
Interest on Draft Environmental Impact
Statement, Released on April 23, 1971,
Respecting Sewerage Project No. WPC-
111.-754, Submitted by North Shore
Sanitary District, Waukegan, Illinois.
Gentlemen:
We appreciate the opportunity to submit the
following comments to you on the above Draft Environmental
Impact Statement.
1. Inadequate Size of the Proposed 12 mgd
Clavey Plant
The Draft Environmental Impact Statement (herein-
after the "Draft Statement") recommends a reduction in
the proposed capacity of the Clavey Plant from 18 to 12 mgd
(p. 37.) The Draft Statement asserts that the sraaller
capacity will be sufficient to handle the total sewage
flow, estimated to be approximately 11.3 mgd (p.24),
required to be handled by the Clavey Plant during the
"next several years." (p.23.) This is the time it is
expected to take to provide a "relief plant" on the
Des Plaines river, recommended to be built near the Lake-
Cook County line. (p.37.)
It appears to us that the Draft Statement is in
error both in its estimate of the flow required to be
handled during the next several years and in its estimate
of the time required to provide additional capacity at
a new Des Plaines River location.
-------
Water Quality Office May 24, 1971
Page 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 years,, and perhans 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
optimistic.
-------
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
Page 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 time 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
Alexander Polikbf£A
/
''-'
David Dinsmore Comey
ALPreo
Enc.
-------
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
JGArnck
-------
find fault with the Committee, tfe have in the past ourselves.
However, in our hearts we know we could never fault these
people for their purpose, .fe 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. *te believe
the report, if adhered to, will assure us of a safe plant at
Clavey Hoad.
de realize that there is opposition to the report. The
Illinois Pollution Control Board, a just and honorable board,
approved the NSSD's expansion plans( adding tertiary treatment).
k»fe are afraid, however, that the control board gave the district
too much leeway on what the district is able to daeide to do.
The city of Highland 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, ws appeal to you, stick to your report. 3e
abova 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, rlowever the city just
doesn't have the power or influence to bring this messy and
damaging conflict to a close, £ou do» Secause you sir, have the
ultimate tool for leverage, the almighty dollar. »Ve 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 duzlrg constuction, and a sewage plant as
small and safe as pc-vlble.
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, 18 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 aire.
Chicago, Illinois 60614
929 2922
Co-Chairmen
PAULR. BOOTH
REV. LEONARD DUB I
GAILCRANDUS
Mr. Gary W. Schenzer
Water Resources Planner
Water Quality Office
Room 410
Environmental Protection Agency
33 West Congress Parkway
Chicago, Illinois 60605
May 21, 1971
Dear Mr. Schenzer:
The Campaign Against Pollution (CAP), an organization devoted to
fighting pollution in the greater Chicago metropolitan area
commends the Federal Water Quality Office (FWQO) for an objective
study and analysis of the North Shore Sanitary District proposed
expansion.
The Environmental Impact Statement, the first of its kind, could
set a precedent in providing a vehicle to counteract local governmental
red tape and bureaucracy, for the benefit of the people. This
draft and future studies can assure all Americans safe, healthfully
productive and esthetically pleasing surroundings.
CAP commends the FWQO recommends except that the final size of the
Clavey Road Plant should be kept to an absolute minimum to protect
people and the environment in the area of the plant.
Sincerely,
Paul R. Booth
Co-Chairman
Rev. Leonard Dubi
Co-Chairman
cc: William Ruckleshaus
David Dominick
Amos Turner
-------
-3-
vast new reforms for the good of this nation. Will our idealism
for change be converted into constructive efforts to make
our government respond ot will our hopes be sourad by a view of
government as corrupt and unrepresentative. Don't you see sir,
whether of not I cast a vote 03* a brick next year could very
depend on your decision.
-------
GARDNER, CARTON, DOUGLAS, CHILGREN & WAUD
JAMES H DOUGLAS
ARTHUR D CHILGREN
MC R R! SON WAUD
JAME5 A VELDE
ROBERTF GRAHAM
LAURENCE A CARTON
GORDON H SMITH
^L.3YD W BOWERS
ROBERTA GARDNER JR
WILLrAM o NEALON
RAY GARRETT JR
PETER H MERLIN
JOSEPH P CARR
JAMES J MCCLURE JR
j CHN j CLERK1N
THOMAS ARTHUR
WILLIAM L MORRISON
JOHN K NOTZ JR
GORDON LANG JR
JOE A SUTHERLAND
DALE PARK JR
JOHN F BEGGAN
'.V F GRIENENSERGER
ONE FIRST NATIONAL PLAZA
CHICAGO, ILLI N OIS 6O67O
AH£A CODE 312 726-2.453
CABLE-GARCAR
May 21, 1971
HENRY A GARDNER
I883-I9681
ALFRED T CARTON
183^-1968'
ANTHONY L MICHEL
VEPNON R LOUCKS
COUNSEL
JOHN A BROSS JR
L EDWARD BRYANT JR
ZANE COHN
GEORGE M COVINGTON
DEWEY B CRAWFORD
JOHN T C'JSACK
PAUL H OYKSTRA
THOMAS A KILLOREN
GEORGE C McKANN
BARRY T MCNAMARA
JOHN £ REINERT
JAMES G REYNOLDS
SOBERT j WILCZEK
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
-------
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
-------
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
-------
r:: operation in Highland
Park what we have t» say is thuss we applaud the district's plans
to phase out the three lakefront plants and to divert the
sawage to the Glavey Road plant for treatment. One of we kids'
favorite summei? pastimes is to swim at the beaoh. We feel it is
about time the pollution of the lake is stepped. We also feel
that the Clavey Road Sewage Plant sheuld be expanded to handla
the l$ad pumped from the lakefront plants because a senselass
delay in the lakefront plant phase-«ut plan would ensue if
the Clavey Road plant was ahttthe plant designated to handle
this sewage.
We are also, however, quite vehement in our demand that
';he Clavay Haad plant be a safe one. The Committee to Save
Highland Park, the-cgroup of residents living near the plant,
caused ecological and economic delay in the dictrict's
ans, and heartache for a lot af people. It is very aasy to
-------
OPEN
LANDS
PROJECT
53 W JACKSON BLVD
CHICAGO, LLINOIS 60604
427-4256
JEFFREV R SHORT JR
president
executive director
e rectors
WILLIAM j BEECHER. Ph.o
RICHARD L ETTUNGER
WALTER T FiSHER
VOLNEYW FOSTER
CORWITH HAM1LL
CYRUS MARK
CHARLES E OLMSTED, Ph 0
GEORGEW OVERTON
CHARLES F SAMELSON, M D
HARWELL SMITH
SYDNEY STEiN, JR
HARRY M WEESE
GEORGE H WOODRUFF, M 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-H1.-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
-------
:* •• '70
FOREST PBSSEIIVS DISTRICT "
of Cook County, Illinois .'
The Board of Commissioners
MATHEW W. BIESZCZAT
CHARLES S. BONK
CHARLES F. CHAPLIN
FRANK W. CHESROW
WILLIAM N. ERICKSON
FLOYD T. FULLE
CHARLES J. GRUPP, JR.
WILLIAM H. HARVE'
JEROME HUP'=E=T
LILLIAN PIOTRO,VS>
RUBY RYAN
JOHN H. STR03ER, j
JOHN P. TO'JHY
JOSEPH I. WOODS
GEORGL" U. DL.N.NE, PRESIDENT
GENERAL HEADQUARTERS: 536 NORTH HARLEM AVENUE, RIVER FOREST, ILLINOIS 6030
COLUMBUS 1-8400/FOREST 9-9420
Arthur L. Janura, GENERAL SUPERINTENDENT
April 28,
APR
Chairman
Illinois Pollution Control Board
189 West Madison Street
Chicago, Illinois 60602
Dear Sir:
POLLUTION CO-iTROL
J.«'..u-
The recent proposal by the Federal Environmental Protection .Agency
to discharge effluent from rhp Skoln'p P.iv
-------
APR
V/e hold fast 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 River.
Sincerely yours,
Arthur L. Janura,
General Superintendent
ALJ:es
-------
May 0, 1971
Mr. William Fuckelshaus, Director
U.S.E.P.A.
1626 K Street N.W.
Washington, D.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
-------
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 the reduction in capacity of
the proposed expansion of the se\vs£'e treatment
plant on Clavey Road, Highland Park, Illinois.
Dear Senator Percy:
In the proposed preliminary environmental essefivient by
the Office of Water Quality, U.S. Environments! protection
Agency, reg. V, recently issued to the rlorth Snore Spnitary
District of Lake County, there is a recoraacnc:ntioa to
reduce th
-------
The Honorable Charles H. Percy
Page Two
afreet ing millions^ of pepjDle_, is that the disagreement
between the assessment "of the U. S. EPA pnd the order
of the Illinois Pollution Control Board (see enclosed
newsletter), adding to the controversy end litigations
by nearby residents end other f-roups, may del^y for
years the termination of_ gpllution pjr Lake_ Mi c hi ran
by the ivorth Shore Sani tary' 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 program, of which Clnvey Road
is only a part. Furthermore, the U. 3. Congress has
failed 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 PCB
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 # 19
State of Illinois Pollution Control Board
-------
DRAINAGE DISTRICT
Si:rn 100
1 SI I Si. JOHNS A\ i MT •
Trlciiliimi- ini<*'ii>oil 2--WO
IIic.iu\sn I'A:IK, Ii.i INOIS
(
MclHUMIII SlVl.I-.n, CHAIRMAN
DfcJcwexxsfiscso Dr. Hllbert
i.i i i- f.'ouA Lan,
May 4, 1971
Mr. John C. Guillou, Chief Engineer,
Division of Waterways,
Department of Public V.'crks and Buildings,
201 West Monroe,
Springfield, 111. 62700
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 sane 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 in return, that we
-------
May 4, 19?!
Mr. John C. Guillou, 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 ditch, 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.
s,
f6RTIMg!rs"INGEft, Chairman
MS : pm
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ITS SCHIENTIFIC FINDINGS. LITERALLY THOUSANDS OF PEOPLE ARE
WITHIN A MILE RADIs OF THE UN3ELIEVEABLE PUNNED ENVIRONMENTAL
DISASTER OF AN EXPANDED SEWGE PLANT
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PLEASE DO YOUR BEST TO SEE THAT THIS PLANT IS PHASED OUT QUICKLY
ROBERT S. LERNER.
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URGE YOU TO PROTECT ITS SCIENTIFIC FINDINGS AGAINST LOCAL
GREED AND MISINFORMATION I URGE THIS PLANT BE PHASED OUT
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HIGH DENSITY RSIDENTIAL AREA OF URGENT CONCERN TOCESIDENCE
OF COMMUNITY DETERMINATION OF EFFECTON OF POLLUTION ON MAN
AS ORGANISM MUST 3E GIN FIRST CONSIDERATION. TECHNOLOGY SECONDARY
TO WELFARE OF RESIDENCE AND PROTECTION OF ENVIROMENT. FWQA
DRAFT ASSESSMENT CALLS FOR STUDY OF POTENTIAL HEALTH HAZARDS
TO RESIDENCE WAT CONCRETE STEPS IS FEDERAL GOVERNMENT TAKING
TO PROTECT OURSELVE AND OUR POSTERITY
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r.'AY 2^
LLD171
DE HPAOU-l MO NL PDF HIGHLAND PARK ILL 20
GARY SCHENZEL CARE WA2ER QUALITY OFFICE
33 MrT CONGRESS CH30 ^]H
PROTECT PEOPLE RIGHTS CUVEY PLANT HAZARDOUS PLEASE HELP US
SHAPIRO 2 88HASTINGS RS 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
ROOK 410 33 EAST CONGRESS PAJKWAY CHGOCOMMEND YOUR PRELIMINARY
DRAFT ON CLAVEY POLLUTION PLEASE PROTECT AGAINST POLITICAL
PRESSURES
MR AND MRS RICHARD LEWIS 344 HASLINGS AVE HIGHLAN
PARK ILL.
V
A
SF-1201 (R5-69)
uiE5tErrr union
^^^f • jm- '•' • • •• ' • ^ • • • ; *'>»^»
Tefegrarrif
LLF166 (57)(50)OEC253
CE HPAQ73 PB NL POP HIGHLAND PARK ILL
GAPY W SCHENZEL /
WATER RESOURCES PLANNER EPA ENVIRONMENTAL PROTECTION AGENCY
ROOM 1*10 33 EAST CONGRESS PARKWAY CHGO
COMMEND YOUR PRELIMINARY DRAFT ON CLAVEY POLLUTION PLEASE PROTECT
AGANST POLITICAL PRESSURES
MR AND MRS VICTOR GOULDING 3$ ASPEN LANE HIGHLAND PARK ILL.
-------
LLD179 (57X51)02^9^
DE HPA056 PB NL PCF HIGHLAND PARK ILL 20
GARH SCHENZEL US SW/iaCMIENTAL PROTECT 1971 WY 20 P";1
33 EAST CONGRESS £ ^^ -- .:. • -. i/JyiVsfe-"
1971 MAY 21 AM
LLD015 (12)CCB009
(AT 1^1CC50U009)PD IPMYEIA 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 IESI) CONGRESS PARKWAY CHGO <50&5
BT ***r
.1AVE WAITED SO LONG FOR TRULY OBJECTIVE STUDY OF CLAVEY ROAD STP
EMBRACING BROAD V IEW OF GREAT LAKES WATER QUALITY CONTROL
PROBLEMS I COMMEND YCUR PRELIMINARY REPORT AND URGE YOU TO PROTECT
ITS T^IENTIFIC FINDINGS AGAINST LOCAL GREEN AND MISINFORMATION,
I URCE THIS PLANT BE PHASED OUT QUICKLY
MR AND MRS PAUL A BROWN 303 HASTINGS ROAD HIGHLAND PARK ILL
NNNN(0733A EOT) , j,
7 35
I'll
-------
LLA026 (11)0005
(AT 1U1CC629003)PD I PMVEIA MVN 0900* EOT 05/21/71
ZCZC 070 PR PD TDVE HIGHLAND PARK ILL 21
GARY W SCHENZEL EPA WATER QUALITY OFFICE RM 523
33 * CONGRESS PKWAY CHGO 60605
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
NNNN(0902A EOT)
3F-1201 (R5-69)
/ ^ J •"-,, Uy
"LLF010 (5*0(OS)MA029 I / - >'•'"' 2! A1:
M CC16U XCT2206 FY (DE HPA06S PB) NL PDF HIGHLAND PARK ILL 20
GARY W CHENZEL WATER RESOURCES PLANNER EPA ENVIRONMENTAL PROTECTION
12
ROOM 410 55 EAST CONGRESS PKWY CHGO
COMMEND YOUR PRELIMINARY DRAFT ON CLAVEY POLLUTION PLEASE PROTECT
GAINST POLITICAL PRESSURES
MR AND MRS LES POLWACK 5^5 HASTINGS AVE HIGHLAND PARK ILL*
-------
TYAOOo (23)(2l)DE?Oo2
DE HPAU27 MO PDF HIGH WAND PAJK ILLS 21 7V; A CDT _•*
us EN;VORN\ENTAL PROTECTION AGENCY REBION 5 " •" ^.^
33 EAST CONGJESS PARKWAY CHGO ""•"
FWEASE FOLLOW THE RECOMMENDATION OF THE FEDEJAL EMIVORNMENTAL
PROTECTION AGENCY NOR THE CLAVEY ROAD SEtfAG PLANT PROTECT THE
LAKE AFD THE PEOPLE
MR AND MRS ED//ARD: ^AZELON
(9202.
SF-1201 (R5-68)
TYAOO? d'
DE HPA02J >^0 PDF HIGHLAND PARK ILL 2"! 3^CA CDT ir^
GARY SCHENZEL IS EM */ORNMENTAL PROTECTION AGENCY REGION "-.;_;
33 EAST CONGRESS PARKWAY CHGO
I SUPPORT THE FWOA REPORT REGARDING THE NSSD AND THE CLAVEY 'C\<
ROAD STP
LOI? H ZISOOK 775 HIGHLAND PL HIGHLAND PARK ILL
FWQA NSSD STP
•/
-------
meatee
DE HPMG12 MO NL PDF HIGHLAND PARK ILL 20
GARY W SCHEivjZEL, WATER RESOURCES PLANNER EPA ENVIRONMENTAL,^.,,^
PROTECTION AGENCY RM 41'j
55 E CONGRESS PARKWAY CHGO -..- *
'*"'"• • • *f£*
COMMEND YOUR PRELIMINARY DRAFT ON CLAYEY POLLUTION PLEASE PROTECT'**
AGAINST POLITCAL PRESSURES
DR AND MRC WILLIAM MELTZEP 79? TIMBER HI_L HIGHLAND PARK
ILL.;
8P-12C1 (RS-e9)
DE HPA023 MO PDN HIGHLAND PARK ILL 21 ?1^A CDT
GARY SCHENZEL WATER RESOURCES PLANNER WATER QUALITY OFFICE
ROOM U1C EPA "
55 EAST CONGTESS PARKWAY CHGO
HAVE WAITIG -0 LONG FOR TRULY OBJECTIVE STJDY OF CLAVEY-
SIP EMBRACING GRANDVIE.J OF GREAT LAKES WATER QUALITY CONTROL
PROBLEMS. I COMMEND YOUR PRELIMINARY REPORT AND URGE YOU TO
PROTECT ITS CIENTIFIC FINDINGS AGAINST LOCAL GREED AND MISINFORMATION
. I URGE THIS PLANT -^ t^-^cn -M
-U5ED OUT QUICKLY
MRS ROrE
UPCHICK
O22).
-------
*; ;^,e
-.-- ' ? -f- -* .!>'".". _ a j*, <«»•*• .. ;-^T'if^""'*i*** *«?•**•<.'^^iE. «••$.!*&»**&lA-^.'P* n-'
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DE HPAG07 PB i\L PDF HIGHLAND PARK I_L 20
GARY W SCHE.\ZEL VATER REC0'JRCEC. PLAINER EPA E\'VlR3!\XENTAt! "
PROTECTION AGENCY
ROOM UVj 33 EAST CONGRESS PARKWA/ CHGO
COMMEND YOUR PRELIMINARY DRAFT ON CLAVEY POLLUTION PLEASE
PROTECT AGAINST POLITICAL PRESSURES
DR AND MRS SEYMOUR SIEGEL 595 HILLSIDE OR HIGHLAND PARK
ILL.
IX
8P-1201 (RS-N)
(01)SPC023 (53)DEA023 -r.T SiuJiATUtiE
DE HPAOC2 PB NL PDF HIGHLAND PARK ILL 20
GARY W SCHENZEL, WATER RESOURCES PLANNER EPA ENVIRONMENTAL
PROTECTION AGENCY ROOM U10 33 EAST CONGRESS PARKWAY CHGO
COMMEND YOUR PRELIMINARY DRAFT ON CLAVEr POLLUTION PLEASE
PROTECT AGAINST POLITICAL PRSSURES
MR AND MRS LAWRENCE PERLSTEIM 3?> TIMBER Hl»L ROAC »1.1
PARK ILL.
-------
(12)LLCA007 |)
XCT1076 ED (DE HPAOU3) HO ML PDF HIGHLAND PARK ILL 21
GARY SCHEN2EL, WATER RESOURCES PLANNER ;;--< , ?0
EPA ENVIRONMENTAL PROTECTION AGENCY RM U10 33 EAST CONGRESS
PKWY CMGO
PROTECT DRAFT AGAINST LOCAL POLITICAL GREED MISINFORMATION PLEASE
PROTECT OUR HEALTH WELFARE AND HAPPINESS
MR AND MRS JOSEPH RUBIN 367 HASTINGS HIGHLAND PARK ILL.
TYA02U
M OABOJO El PD OA CHICAGO ILL 21 12J1P CD
US ENVIRONMENTAL PROTECTION AGCY, DLY .?5
33 EAST CONGRESS PKWY CHGO
WE SUPPORT YOUR POSITION RES THE CLAVEY RD. PLANT AND URGE
IT BE IMPOSED ON THE N.S.S-D
MR/MRS ED SOLLO 3392 SUMMIT HIGHLAND PARK ILL 60035.
21
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505 Maple Avenue
',.Tilriette, Illinois
60091
April 24,19^1
Mr. ;,illiam D. Ruckelshaus
Administrator, U.S.E.P.A.
'.'ash" ngton, J./.C.
Dear Mr. Ruckelshaus;
The staterieitt of the United states iinvironmental Protection Agenc
in regards to the North Shore Sanitary District in Illin is was
absolutely the most unbelievable, disappointing, truly alarming bit
of environmental news we could possiblt have.
Unbelievable—because I had sat through all of the Illinois
Pollution Control Board hearings on the Clavey Road ;lant, plus the
meeting held by Lt. Governor Paul Simon, ;lus many other meetings in
regard to this critical situation. I felt the Illinois Pollution
Control Board came up v-ith a realistic tjniv.t.' ->n to get a long overcoie
job done. Getting the sewage out of t'-it lake from those five treatmer]
plants is of CRITICAL URGENCY.
Your action would make construction dela; , add another ^£0 -to ^.c
million in costs, add nutrients to further speed up eiitrophi.cation
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. You
plan has absolutely everything negative in it that could possible be.
I strongly feel ^ary Schenzel was poorly informed if he did not hear
all of the testimony and attened many other meetings related to t>. e
North Shore Sanitary District.
I sincerely feel the USEPA has made a big mistake in t: e'r
decision on the North Shore sanitary District. ulso, no public Iiearir
\";as held by the agency. A small gro -p of citizens have held up
construction for two years, adding a large financial burden to resider
of the area, the state, and UShPA. The lake has suffered '*hat ma; be
irreparable damage because of this. Five - u one half 'ill! ^n people
depend on the lake as a source of water. The Il-in:>'s Pollution Contr
Board ordered the NSSD to proceed ett onct to construct additional
facilities et the Clavey Road treatment slant, a~'d this voulci end jutt
almost raw sev/age into the lake from five plants alonj> the short. The
input of nutrients to the lake MUST STOP, for it is fast beco ing
eutrophic.
Since I attend all Pollution C ^ntr.<1 Ecura r.tc.-tines and all of tr
hearings on the NSSD case and many othtrs i-e ' r-:K i n, • tl.t iit'.ation 1
found I fully agreed irvith th-e decisi vi ,.f ^ >..-. r-11- t' - Control r.-ardj
because I had heard the testimony presenteu to tl'itr r].us "lore. I an
very much impressed with the integrity of this capable ?oard. Ric-iarc
Kissel v:as a fair, dedicated hearing officer i :c the 5c^:d pave ruch
1-TnrMirrVit- to thi s important c.-3t. iar. ocv-'^"-" "'"f?'.j2y -1' ^r" :-•- rrier, the
Board decision.
-------
It rvaa absolutely impossible for me to see how the federal iPA
i possibly have come up with your • d&claion.. -You certainly
.tot have the future of Lake Michigan in mind or the he*lth and i»ater
' 7 of jnillions of people. It seems to me Lake Michigan :'s r-ore ±mi ortant
;,aaid3p than ths interests of 200 selfish citizens who shouldn't have
Ajta-A hoaiea> nest to a sewage treatment plant If they were concerned.
jlavsy Hoad plant does have an odor now because it is overloaded,
, proper expansion it will not. Expert witnesses have testif i ec~to this.
i3ns residing next to similar treatment plants have not complained.
.Ilia is a matter of vital concern to all Illinois communities along
"£.2, including Chicago. Indeed it is of concern to all people living
:•> ;>fiIr» Buckelshaua, I am afraid ny letter is a bit strong, but 1 am
17.7 upset by this position the EPA has taken, and I beg of ; ou to
••--, ider the situation. Please honor 'tis position of the Illinois
". : ..ion Control Board and let us get on with this clean-up of the
; ;vat is s
-am looking forward to meeting you in May.
Very truly yours,
iil:--s BrMeen L. Johnston
Mayo
.-?lolmi«ci|;
3tev«naon
ii Percy
-------
If 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
management. Because we recognize that others may differ
with our opinions, it is the policy of WBBM-TV
to consider requests for broadcast time
by responsible spokesmen representing opposing viewpoints
LEON DREW,
V'-vPresident/General Manager, WBBM-TV
Editorial1
WBBM-TV 630 NORTH McCLURG COURT CHICAGO, ILLINOIS 60611 (312) 944-6000
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.
-------
A*ril 27, 1971
tf.4. £ntirt»*B*t»l ;yrot*ctioB Agency
16.26 X St. 3.W.
, D.C.
I f«el toat it »•* a ,*r.-*t «ict«lt» tiut
Control '-.gwacjr la t.a« Clavoj 8o*d ««««g« tr««ta«at affair.
uaa u«*u n«ld u^ for ^ years by 200
»illioa otatra watch L*k« Mlc&i^aa $«t nor«
and /nor* polluted 9e«*ua« of trtia federal deeicion,
la £ola« to coati&a* to discaarge ita ««*a£« xata L*it«
for 2 to ^ y«ara loafer, aa iu«xcaaabl« deiaj. fi»*
r. iiaall/, ta« f«d«ral fovvr&asat aaoula aot
i
fca« «tac« i» 4ola< * r«aj-anaible job
i oop« you wiii r»coa*i««r your Action.
**ra« jiabart Pfuta«ar«ut«r
Linden AY*.
t«, lil.
Copy to: jfraacia iteyo
-------
CONGREGATION SOLEL
1301 Clavey Road
Highland Park, Illinois 60035 • IDIewood 3-3555
Arnold Jacob Wolf, Rabbi
Louis I. Heller, Administrator
May 20, 1971
OFFICERS
President
Morton A. Pierce
Vice Presidents
Albert L. Finston
Jay I. Frank*!
Arthur W. Segil
Mrs. S. Richard Wynn
Secretary
Karl J. Berliant
Treasurer
Robert H. Lowitz
Past Presidents
Herman C. Edwards
Benjamin J Gingiss
Irving A. Hanig
Howard M. Landau
Alien Levii
William Swartz
Bertram J. Wolf
DIRECTORS
Mrs. Burton G. Balsam
Dr. Alvirt M. Becker
Edwin E. Bederman
Albert R. Selrose
Milton Bram
Mrs. Paul A. Brown
Mrs. Arthur I. Caplin
Soils Dudnick
Robert M. Eckhouse
Mrs. Leonard Elliot
Leonard Farb
Mrs. Russell L. Fishman
Jotham €. Friedland
Mrs. Donald A. Goldstein
Donald D. Jacobs
Sidney C. Kleinman
Alan Lenhoff
Irving B. Levine
Jack C. Lipsey
Marc Reinganum
Euaene A. Rosenfeld
Mrs. Edward I. Rothschild
Mrs. Jerome H. Rudman
Robert W. Salpeter
William Samuels
Donald W. Schaumberger
Courtney D. Shanken
Martin L. Silverman
Allen A. Zuraw
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 writin
resident and
of the North
Highland Park
recommendati o
largement of
be proper and
agency to ins
ommendati ons
g you on behalf of Congregation Sole!, a
concerned institution in the immediate area
Shore Sanitary District's Clavey Road Plant,
, Illinois. We have carefully reviewed the
ns of your agency with respect to the en-
the Clavey Road Plant and believe them to
required in this situation. We urge your
1st on the implementation of these rec-
by the North Shore Sanitary District.
Very truly yours ,
QONGREGMIQN SOLEL
Pierce, President
orton
cc: Louis I. Heller
cc: Sidney C. Kleinman
RELIGIOUS SCHOOL
Chairman
Mr-, Marshall E. Domash
Rabbi Stanley D Meise/s
-------
/t.
V^/U^c uu^U
MILDRED KIRSCH
31O HASTINGS ROAD
HIGHLAND PARK, ILLINOIS 6OO3S
^%%'
/ / J^" ^
W4- pJduuQ
<^
-------
HOWARD C. WECHSLER, M.D.
340 ASPEN LANE, HIGHLAND PARK, ILLINOIS 60035
*^y~t
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(*X^
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Hrinity CUrcli
425 LAUREL AVENUE • HIGHLAND PARK, ILLINOIS 60035
16 May, 1971
Environmental Protection Agency
Water Duality Office
Room Ij.10
33 West Congress Parkway
Chicago, Illinois 60605
Attention: Mr. Gary W. Schenzel
Ri-1: Clavey Road. Sewage
Treatment Plant
Dear Mr. Schenzel:
I wish to add my voice to those who are in support of
the Federal Water Duality Office .environmental Draft
regarding the Clavey Road Sewage Treatment Plant in
Highland Park. I believe the provisions of the draft
offer a reasonable solution to the controversy which
has surrounded the proposed expansion of these facilities,
No one, I'm sure, questions the need of the North Shore
Sanitary District to improve their total facilities
in order to help curb further pollution of Lake Michigan.
Nonetheless, this must not be accomplished in a manner
that will be detrimental in other ways to the health
and welfare of our citizens. Again, I feel your draft
provides a most equitable solution to tais situation,
and it is my sincere hope that its implementation can
be secured.
Yours truly,
<
Re^.) D
(The Rev/.) Douglas M-4 Spence
Rector, Trinity Church
DMS:11
-------
HIGHLAND PARK REFORM TEMPLE
27S8 OAK 8TKEKT
HIGHLAND PARK. ILLINOIS
OR. SHOLOM A. SINGER
MABBI
Hay 19, 1971
Mr. Gary Schenzel
U.S. Environmental Protection Agency
Water Quality Office
33 East Congress 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
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 controversy
with great interest and so it was with great satisfaction that
I rsri-i the recent draft environmental impact statement on the
prop'; led expansion of the Clavey Road plant. As a clergyman
who~e reoponnibility is tn the community at large as an entity
and to the individual residents of the city of Highland Park,
I v/.-nt to urge that the Environmental Protection Agency stand
by It- draft limiting the expansion to only 12 million gallons
"••'r'.ner, I endorse the draft in its recommendation that the
"r-r ••' ",~-;r / Advanced waste treatment unit processes be provided."
I -igree t:.;-it the retention basins be completely covered but I
suggest -.-.<-: entire matter of locating retention basins in a
residential ^ree be re-evaluated. May I further suggest your
agencY ta
-------
f ron Gs,
"..1!'/ youiT3,
Jr. . -o-O.M i. )'Lp.gev
or . ,'r* .A.
-------
Norman J. Ehrlich, M.D.
Donald B. Frankal, M.D.
Arnold A. Gutman, M.D.
Angalo E. Falleronl, M.D.
Donald P. Schwartz, M.O.
ASSOCIATED ALLERGISTS, LTD.
111 NORTH WABASH AVENUE
SUITE 1518
CHICAGO, ILLINOIS 60602
332-4292
ALLERGY
flay 18, 1971
Environmental Protection Aqency
Water nual1ty Office
Pm 410 - 33 West Conqress Dkwy.
Chicaqo, Illinois 60605
ATTENTION; MR, G.W. SCHEMZEL
Dear Mr. Schenzel;
I would like to add ny name to the list of physicians in Hiqhland
Park who oppose enlarqinn the C$&/ey Poad Treatment plant.
I am an allergist with an office in Hiqhland park and I have
many patients with bronchial asthma and other respiratory disorders
who live in the area near the olant. Since patients with allerqic
respiratory disorders are usually the first to suffer from polluted
or contaminated air, I feel stronnly that this olant should not
be enlarqed.
I realize that sewage treatment plants arc 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 enlaroement of the Clavey Poad
faci lity.
Sincerely yours,
AAG/ler
Arnold A. Gutman, M.D.
-------
ASSOCIATED ALLERGISTS, LTD.
111 NORTH WABASH AVENUE
Norman J. Ehrllch, M.D. SUITE 1518
Donald B. Franks!, M.D. CHICAGO, ILLINOIS 60602
Arnold A. Gutman, M.D.
Ang«lo E. Falleroni, M.D. _3_ .___
Donald P. Schwartz, M.D.
ALLERGY
ay 21, 1971
Environmental Protection Aqency
'-'ater nualitv Office
Pcom 410
33 '-,'est Conqress Parkway
Chicaqo, Illinois 60605
ATTENTION: MR. fi. if. SCHENZEL
Dear Mr. Schenzel:
T v/ould like to add my nane to the list o^ nhvsici?ns in the
Miqhland Park area who omose enlarqinn the Clavev npad Treatment nlant.
I am an allerqist with an office at 635 noner Villiams Avenue,
in Hiqhland nark and I have patients v/ith bronchial asthma ?nd
many other respiratory ailments who live in or near the area.
Since these natients, especially those suffering from these
resoiratory disorders are frenuently the first to suffer from
polluted air, I feel stronnly that this nlant absolutely/ should
not be enlarqed.
Sewaqe treatment plants are necessary, but there are certainly
alternative sites less apt to directly affect those with these
respiratory illnesses in areas around Lake County that are less
populated. I am stronqly onposed to this enlaraenent not only
for the benefit of my patients, but for all those neople in the
area, whether they are or are not sick, who miqht also be adversely
affected by anv enlarqement of the Clavey Poad facility.
Verv trulv vours^- ' • - - , .
' ' 7 • / ( <- A
N.IE/ler "oman ,1. EhrTich, M.D.
Chairman ft Tt-tendinq Physician
Ceri9rtnent of .Mlerny
Michael ceese Hosnital
Medical Tenter
Chicaqo, Illinois
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RABBI ARNOLD JACOB WOLF
STUDY • 1301 CLAVEY ROAD
HIGHLAND PARK. ILLINOIS 6OO3S
TELEPHONE IDUEWOOD 3-35SS
May 19, 1971
Mr. Gary Schenzel
U.S. Environmental Protection Agency
Water Quality Office
33 East Congress Pkwy.
Chicago, 111. 60605
Dear Mr0 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',
f' -
' ; j ' 1 - <"
Rabbi Arnold tfaeob Wolf
cc: Mr. William D. Ruckelshaus
Director E.P.A. """"
Washington, B.C. 20460
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1175 SHERIDAN ROAD. HIGHLAND PARK ILLINOIS 60035
PHONE 432-8900
'toy 1°, If"!
'!r. Ci.-iry Schenzel
U.S. Environmental Protection
i'.ater Quality Office
?? I.n^t Congress Parkway
Chicaio, Illinois 6P6°5
Samuel H Dresner
Rabb:
Phi ip L Lipis
Rabbi Emeritus
Reuven Frankel
Cantor
Dr Louis Katzoff
Director of
Religious Education
Cyril G Oldham
Executive Director
Hulei Khers
Mr. Sohenzel :
Some months a so members of tho c]er<_iy in l.ichlarid Park an*-' of he1*
interested t ersons requested a moratorium on 'plan? to expand the
n IVPV K'o-'i1 ^p-'-ncTe Trr~-i tr;pi t m TTt-_ '\'o v/erc concerned that an
alternate site in 'm nre'i which was non-residential would be chosen to
situate a sewage trcatnrnt plant in view or the health dancer?
involved.
I •• ,-ts ^lea^'-d to note the statement from vour of fire ^he^eforc,
rctiardin". the Clavev Road Plan^. and nm vritine to you to indicate
my ?tronu feelings about the necessity in limiting the expansion of
this n.iant to twelve million gallons Per dav, as vour office indicated.
That :'neces?an- wi?te trearmcrt unit processes be '^ovided ,M T further
think of -^at importance, as well as the item, coverin"1 the retention
basins. Tlie buildiTiiz of an effluent Ircioon in a residential area
hv the .vorth Shore Sanitan' Pis^rict i? difficult in the extreme to
comprehend. Vour su<™cstion that a study he initiated to 'ascertain
the possibility of air-borne infnction from ^nwan,e treatment facilities"
sliould furthermore be an item of hi "best priority.
Sincere^v yours.
Samuel I".
Pihhi
SI in/j re
cc: Mr. William ]i. !5ucVel?liau5
Director, r.n.vironnental Protection '\<:cncv
V, ash i ne ton. l\(\ :^\ fi('
i!i
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— -TSfc V
—f- 1 -. I -OHTHIf £
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NORTH SHORE RADIOLOGISTS, S. C.
2500 RIDGE AVE., SUITE 203
EVANSTON, IULINOIS 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,
- ^- • ^., y v \
RCTrds
cc: Amos Turner, P.E.
Richard C. Turbin, M.D.
-------
^ Mrs. Hov slovenko
"isMand I11-TCP
Highland Park, 111. ^O
May 17, 1071
Mr. Gary »» . sschenzel
nater Resources Planner
E.P.A. iiater Duality Office
Chicago, 111.
bear Mr. bchenzel:
Too long have we waited for a truly objective study of
the Clavey Road Sewage Treatment Plant embracing a total vi PV of
the Great Lakes Hater Quality Control Problem.
\»e commend your preliminary report and urge you to nrotect
its scientific findings against local creed and misinformation.
rte urge that this plant be phased out quickly.
Very sincerely yours,
-------
CDKS. ODARSHA.LU
332 LARKSPUR, HIQHLA.N& PARK, ILLINOIS 60035
-------
OFFICE OF THE CHAIRMAN
of j&jperfetsors
(Earottg IButlbmg,
600S5
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
Ronald R. Coles,Chairman
Board of Supervisors
RRC.d
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VILLAGE-C^SGHlLLER PARK
COOK COUNTY, ILLINOIS
v
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
ratter than tertiary treatment;
and
WHEREAS, after July 1,1972,
all effluent discharged into Lake
Michigan and the SkokieRiver.
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 the
residents of those suburbs, in-
cluding the 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 mat
the Illinois Pollution Control
Board be and herewith is mem-
orialized to resist the plans
'. of the North Shore Sanitary
District aforesaid and that 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 this 29th day of
April, 1971.
Approved:
Edward Bluthardt
President
Attest:
Walter Bykowski
Clerk
n franklin Park. Illinois.
-------
3700 La.vthorn St.
Schiller Park, 111.
Lay 8, 1971
Mr. F. T. Mayo,
Interim Reg. Dir.,
'.Vater Duality Office,
U.S. ^Environmental Frotectioxi Agency,
Dear L£r. Mayo,
Please include the enclosed resolution with the
of the Assessment of the Environmental lapact or the
T5T.S.S.D. Glavey Rd. Plant on the DesPlaines i'dver.
Enclosure: Protest Resolution passed by the Village Bd.
of Schiller Park on April 29, 1971 as published in the
Schiller Park Independent.
Sincerely,
678-C864 Mary :.-;Oddson
-------
*• •3D
From The Desk
BARBARA VOLIN
-------
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 "compromise11 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.
Sincerely,
(Mrs. L. T.)
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O-_?.A^/• .- •
r
' " v'J * 0
Mr. Williaa D. Huckelshaus
Administrator
U.S. Environmental Protection Agency
1626 K St. N.'.V.
Washington, D.C. 20^60
Dear Mr. Ruckelshaus,
I Jeel that it was a £,r«at mistake that
the Federal govennment overruled the Illinois Pollution
Control Agency in the Clavey Hoad sewage treatment affair.
Construction has been held up for 2 years by 200 people
while 5«5 million others watch Lake Michigan get more
and more polluted Beaause of this federal decision, Highland Park
is going to continue to discharge it,s sewage into L*ke Michigan
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.
Wila&tte, 111. 60091
Copy to: Francis Mayo
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1S5 Maple Ave.
Highland Park, III., 60035
May 9, 1971
Environmental Protection Agency
Water Cuality Office
Room 410
33 W. Congress Parkway
Chicago, II. ,60605
____ -7Attn: Mr. Gary W0 Schenzel
/ G-entlemen:
PLEASE do not listen to the disruptive voices calling themselves
"Lake Michigan Protectors of the Environment". "Protectors" indee
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 responsible group called, "The Lake Michigan
Federation," this abovefgroup is writing letters asking us to write
you and colling itself Lake Michigan Protestors etc,.."
Hightlnd Park and the North Show* Sanitary Dist. have spent afiono
t-ime agonizing a formula. Now the Clavey Rd. plant is going ahead.
At last, wef who place above all *ther 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 change the formula.
You have let both sides start the fight all over again. WH7????
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 141tc the above mentioned group - but
I'm sure from reading election returns and uotes for bond issues
that the above tfo not speak for the great majority of North Bhirve
people who wish above all else to save our most important natural
resource, the Lake.
Sincerely yours
Mr. & Mrs. R. L. Erttli
inoer
-------
NORTHWESTERN UNIVERSITY
CHICAGO, ILLINOIS 60611
THE MEDICAL SCHOOL
\VAPD MEMORIAL BUILDING
3(B 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
-------
"bernlxeim
arcliiteots
(312) S36-1333
ONE NORTH WACKIER DRIVH! CHICAGO. ILLINOIS
fred 1. bernheim, a r a
lawrence i. kahn, a i a
adrian lozano, a ia,s to
elmer nielsen
e-ireedman^onsultant, graphic communications^
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LESTER SCHWARTZ, M.D.
ar
LESTER SCHWARTZ. H. D.
22 ( A
-------
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LESTER SCHWARTZ, M.D.
91 Uiter Schwortz, M. D. iNUE
226 Aspen Lane 7
Highland fork. III. 60035
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-------
LESTER SCHWARTZ. M.D.
91
L«rer Schwartz, M. 0.
226 Aip«n Lan*
Highland Park, III. 60035
CNUE
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-------
rotection Agency
Mrs. Bmanuel Winston
v _ 871 Marion Avenue
'~ ".. Highland Park, Illinois 60035
May 22, 1971
Mr* Gary Schenzel
U»S. Environmental
Region V
33 East Congress Parkway
Chicago, Illinois S0605
Dear Mr. Schenzel *
Ordinary citizens sesm 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 jbne 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
task, 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 ret>ort 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 atrolaud 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 - ill the while
claiming, "we're overloaded, give us money to enlarge and we'll be good
boys." This past^sxnnmer they were not overloaded and still had many days
of air pollution. In their meetings they make statements such as "Some
day we1 re going back to Highland Park, and, by God, we're going to get
them." And, in -spite of the 18 million gallon aggrement with the city
i_ '
-------
Mrs. Emanuel Winston May 22, 1971 Page 2
prohibiting future land purchase in Highland Park, "If we need more land,
we'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 Cowmittee's original goal was to have the present plant modified to
control air pollutionfcut not expanded, to serve Highland Park and our
lakefront plants enly^as soon as possible. However, when your first cost
feasibilityfctudy envisioned a 30 MGD 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* OeMdnst»ate the desire to serve us and help us -
instead of "get us".
i).. 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 would 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 oppose 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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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
-------
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,
1 /
lal M. Brown
-------
H. BOWIN STAIR -ae- , I f 7 I
899 KIMBALL ROAD, HIGHLAND PARK, ILLINOIS 60035
-------
May 24, 1971
iUt. Gary Schenzel
Water Resources Planner
E.P.A. fttote* Quality Ofifcce. Rm. 470
33 W. Cong^iexi^ PaAkwaiJ
Chicago, It£. 60605
Pea/i Ga/ur,
Under .5e.poAa£e coue^ membeii Of) £he Lake 'lichigan Px.ote.ctou o^ the.
Environment have, atne.ad.ij submitted - on Mill submit - comments on £he dra^t
environmental impact. statement on the. North Shore Sanitary District's
proposed expansion plans. These comment cover the. technical, engineering
and microbiological aspects oft the project and one. foully endorsed and
•buppoited bij the. entile, member kip c< the Lake '\ich.igan P>iote.c.tou o& the.
Envi.twnme.nt.
In addition the. Soc-ietu against Violence to the Env-ilcnme.nt (SAl/E) and
the Campaign Agaxn-i-t Pollution (CAP) have. e.ndouzd the. F W 0 A'.i dtia^t e.nvix.on-
me.ntat *tatwe.nt cu> /ia.i the. boaAd cf. School Vi^t^ict 10& in Highland PaAk.
FuAtkeAmoAz, vaAiou^, memfae-ti o^ the. Highland Paik cle.ith Shcfie Sanitaw Vistiict have Aigidtu ie;(aied to listen tc fie.asonable.
compromise, and tc modi^u their thinking and ptani> in accordance, ii'-it'i -supe.Aior
technology. Their in{itcy.ibititu and stubborn advocacy c< cut-mode.d plans and
techniques has caused the ;irese.nt quagmire.-
A. The. Citij c£ Highland Park has -lequeited removal o{\ the. e.^{,lue.nt
lagoon -- denied bit the. North Shore Sanitary Vis-trict.
8. Reduction and covering oft retention basins - de.nie.d bu the. North
Shore San-itarii V^trict.
C. The State of] Illinois insists on advanced water treatment processes -
denied bu the North Shore San-itaru Vistrict.
V. The F W 0 A dra
-------
(2)
MA. Gary Schenze£
Chicago, 111. 60605
The Lake Michigan Protectors o{, the. Env4A.onme.nt endorses the. recommendations ofi the.
FitlQA in their entirety - with one. major exception. In QUA. ju.dgme.nt the. size o£ the.
plant should be. limited to 6 MGt? as detailed -in MA. Turner's engineering and technical
report.
A. We endoAse the. covering o^ the. retention basins and the. fie- evaluation oft the.
proposed capacity.
8. We. endorse the. recommendation ^or a new facility o{, IS MGt? on the. VeJ>
C. We endcAie ^e ne.qu.&>t that the. WSSP "tan^t e.nv&iu.c£ion and ti&Atone. dij>siu.pte.d aAe.at> to theAA ^oAmeA condition".
P. We endoAie >t/ie sie.c.omme.ndation that the. WSSP "landscape, the. £acxXc£te4 -en
m-cnxLm^.ze. ^ha e.nv" .
E. We endoAie the Aecommendo^con o^ a bfioad Atudy o^ the. "e.nvion o^ the. EPA must w&igh both the. e.nviAon-
me.ntal and the. ecological degradation spawned bt/ the WoAth ShoAe 5anXtaAt/ P^st^cct's
obstinate and obdurate, rejection oft all reasonable solutions. We must Aem^nd the
Federal authorities that their basic responsibility -c-i to the health and
o& the human beings involved. Simple justice demands nothing less,
Cortly,
GERALD L. Sill
LAKE MICHIGAN PROJECTORS OF
THE E.WIROA
11 & Aspen Lane
Higitland Pa,ik, 111. 60035
as/ jhm
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HKHIJKRT A.LOKB, III
37O HASTINOS AVENUU
HIGHLAND PARK, ILLINOIS 6OO35
AREA 312/432-0003
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 enlarged and that
plans be made for eventual phasing out of
the plant.
2) The plant be landscaped properly, to avoid any
. further damags 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 done 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 Plaines river, of a size that will enable
phaseoiit 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* people was
an important factor.
4
Thank you.
Yours t.
CC: Mr. G*ry Schsnzsl
Sen. Charles Percy
Sen. Adlai Stevenson
Gov. Richard Ogilvy
-------
LEAGUE OF WOMEN VOTERS OF HIGHLAND PARK
FOR IMMEDIATE RELEASE
STATEMEST TO CITY COUNCIL « May 10, 1971
RS: BAN ON NEW SEWER HOOK-UPS TO HSSD
^ While we are aware of the serious ramifications of our position,
the League of Women Voters believes that directing any additional sewage
to the already overburdened Clavey Road Sewage Treatment Plant, or necessi-
tating the dunpingAdditional, 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 "hardship" on the people
of Highland Park which balances or exceeds the hardship on those to whom
permits will be denied* The use of Lake Michigan is now denied to us all;
the Skokie Lagoon has become a cesspool; and the NSSD has claimed that
overloading of the Clavey Road plant has been responsible for odors and mal-
function*
There is an enoraous potential for single family development in the
o £area served by the NSSD which must be postponed until the facilities are
ae^o Adequate to receive the additional sewage generated!
g2c S|c: City Council, Highland Park Illinois Pollution Control Board
£<->° Trustees, NSSD League of Women Voters of Illinois
~~ — City of Lake Bluff " » " » '» Lake Bluff
City of Lake Forest n n a n n me Forest
Illinois Pollution Control Board
i»ri p«** r H, - i -• - - »i *--•--
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I ' I if (i ijt- of
' I
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DONALD N. MANN
ATTORNEY AT LAW
111 SOUTH DEERE PARK OBIV6
HIGHLAND PARK. ILLINOIS 6D03S
IDttwooo 3-33O5
May 1°, 1971
Enviromental Protection Agency
Water Quality Office
Room IilO
33 West Congress Parkway
Chicago, Illinois 60605
ATT: Mr. Gary W. Schenzel
Water ftesources ^lanner - Planning Branch
Dear Mr. Schenzel:
By action of the Board of Directors of the Deere 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 park, Illinois.
We believe such action is necessary to preserve not only the community
but also the total ecology of the area.
mort and help in anyway possible.
PARK. NEHBRHD. ASSOC.
Ni MANN RRESH7ENT
L
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Riverside Lawn
Improvement Association
3748 Stanley, diverside, 111. 60546
Kay 20, 1971
PRESIDENT
Sabbagh
VICE PRESIDEHT
L. Becker
SECRETA8
J« Repr
TREASURI
3.
LIr. Gary Schanzel
U. S« Environmental Protection Agency
1819 J, Pershing Road
Qhicago, Illinois
Dear lfr» Schenzels
Re* Sewage Treatment Plant Construction on DesPlaines River at
Cook-Lake County line
The people of Riverside LIOTI are opnosed to the rroposal
by your agencv that effluent L'rorr tne North "hore >ar.itury District be
dumped into the DesPlaines .'liver.
i*
P.iverside Lawn is an unincorporated community located in
Riverside Tovvnship and surrounded on three sides by the DeaPlaines River.
Because of this location *a are vulnerable to flooding caused by ice
jama, spring thuws or periods of heavy rain. This flooding brings
with it any seviage, oil, debris and other forms of filth that have be«n
discharged into the river by combined se'sers, industry and sanitary
districts located upstream of Hoffman Dam. Over the years this problem
•has increased to the point wnere WB feel it *ill become a serious threat
to our wslfare to nlace any additional effluent into the DesPlaines.
.-it this time we are considering application to the 7ederal
Housing and Urban Development for subsidized flood insurance. Insurance
at any cost can never remove the r.iseries of flooded property, but ise
see no logic in the federal government placing our hones in jeopardy
and then offering to pay for darages.
Sincerely,
c/trs.
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
frdulion uf une compj.exea soiuoie substrate can be removed in the
-------
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 parameters.
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 5jd/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.
-------
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 chemfcals 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 30jd 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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ENVIRONMENTAL DEFENSE FUND
162 OLD TOWN ROAD
EAST SETAUKET. NY 11733
516 751-5191
1910 N STREET, N.W
WASHINGTON. D C 20036
202833-1485
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
for
Sewerage Project Number WPC - 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
EDWARD LPP ROGPf^ GFNERAi rnuN=;FI
WILLIAM A BUTLER. ATTORNEY
-------
-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
-------
815 16th Street
Wilmette, Illinois 60091
19 May 1971
Mr. William D. Ruckelshaus, Adm.
USEPA
1626 "K" Street, N.W.
Washington, D.C. 20461
Rei Highland Park, Illinois
Clavey Road Sewage Treatment Plant
Dear Sir«
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,
&U*Ld.
.•gZ.-;^ -•••"
/<~* *"' ' " ' / _ * _ • v - • „ .--
.•- 'Marshall and Joan Moretta
cc« Richard J. Kissel
-------
an
d
EXECUTIVE OFFICE 318 WEST ADAMS ST., CHICAGO. ILLINOIS. 6D6D6 U.S.A. • PHONE (312) 7S2-7B15-16
CABLE ADDRESS - SHEPB CHICAGO
*x^£-t
^7^_4
-------
r (A/omen Uoters or ex Vortnbrook
I I
northbrook, Illinois 60062
(J I '
let the people know make the people care help the people act
May 14, 1971
Mr. William D. I\uck el shaus
Environmental Protection Agency
1626 X Street ::. tf.
Washington D.C. 20460
Dear 2-Ir. 3uckelshaus J
We are writing to protest the LPA draft environmental impact
study of the Nortj3._ jahore Sanitary District's expansion plans
for the sewage" TFea'trcent facilities en Cl: vey Koad in Highland
Park. ~"
The EPA recommendations include reducing the pi rone d capacity
of the Clavey Plant from lr, to 12 million Allans •: dry, -nd
building facilities elsevnere to cempens-;te for the reduced
capacity. These recommendations, if followed, would result
in greatly increased costs for the Korth Shore iscnit-ry District
and its taxpayers, and would delay by at least a year the
closing of 5 obsolete plants now discharging inadequately
treated sewage into Lake I-.ich.igan from Lake Bluff, Lake Forest
and Highland Park. The present plan, ordered by the Illinois
Pollution Control Eoard, for an 1L million Ballon capacity
at Clavey, would permit diversion cf sewage from the chore
plants, and from the lake, as soon as new construction is com-
plete, in 1973. Deduced capacity would delay re-rcutin,_ until
1974, when the upLrading of present facilities is finished.
Thus sewage receiving only primary treatment—:;r.d r^w sewage^
during storms—will continue to enter Lake :-:ichi£:n for a 3C;»
longer time under the EPA plan than under the present timetable.
And the risks involved in using sewage-cor-tc-minated c! rim: ing
water will continue to be borne by tens of thousands of people
on the north shore clone for a 5C;'j longer time.
The EPA environmental imp:.ct study does not appear to consider
the consequences of its recc.avendations on Lake .:ica\igE.n and
its users. The principal bea.efici-; ries of changed .:l:r.c :-t
Clavey would be the homeowners t-.er-e, and the ben-fit they
would receive is tenuous at best. Claimed damage to property
values from the presence of the sewage plrnt dees not jibe
with the fact th:t most cf the hc:r.cs there were built after
the plant, rrotests concerning odor are primarily based on
problems connected wit.x operatln<_ t^e ^lant considerably in
excess of capacity, a situation which ',,'111 continue to exist
if the smaller plrnt is :p..iOved, iince its c'^rcity v:ill be
exceeded the day it opens. Fears of airborne viruses do not
appear to be justified. The potential risk of wrterborne vi-
ruses in drinking -rater is gre ter, -:nd threatens a f: r greater
number of -. sopls, includir.g, it should be acted, Clavey r.oad
residents c.s. T;ell.
-------
The EPA draft study IE in contradiction to the judgement, deci-
sions, and orders of tile Illinois: pollution Control Board,
vliich is overseeing tue work of the ilcrth Shore £ unitary District,
The IPCB is an agency which has been moving strongly against
polluters in Illinois. We are concerned that if a 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 will start to seek less stringent
timetables from the federal government also, and the fine work
of the IPCB will be undermined and weakened by hearings and
delays .
Finally, delay in diverting sewage froia the shore plants w
not by itself destroy Lake Michigan, but It is one of the
:n:'ny insults, cms. 11 --.no. lirge, v.'hich added together will indeed
lead to the Lake's destruction. This Is the environmental
impact with 'hich the SPA shoulj be rcost concerned, and which
the draft study fails to consider adequately.
Sincerely yours,
Mrs. Ralph Boel:er
President
3913 Badcliffe
nNortLbrook,
Mrs. William T. ro"ers
Environmental quality Chairman
Il3c bitfield Hoad
Korthbrook, Illinois 60C62
League of Women Voters
Northbrook, Illinois
-------
HERBERT A. Loss, HI
370 HASTINGS AVENUE
HIGHLAND PARK. ILLINOIS 6OO35
AREA 312 432-OO02
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 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.
b; 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.
Yours t
^7^
CC: Mr. Gary Schenzel /
Sen. Charles Percy
Sen. Adlai Stevenson
Gov. Richard Ogilvy
-------
THE REDMANS
2O6 ASPEN LANE
HIGHLAND PARK, ILL. 6OO3B
(M4t9/mQ
be. (
ci&^'Rtfd
o^g^
fVobWs.
?Gp-O^~
\i i ^
-------
Mrs. Donald Fuhr
333 Larkspur Drive. Highland Park. Illinois 60035
May 17, 1971
Mr. William D. Ruckelshause
Directory E, P. A
Washington, D. C. 2QU60
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 mis-information. I urge this plant be phased out
quickly.
Yourst truly,
-------
s-Hti. Dimotfy €>. W&t
2414 ¥&a.ys.z ^>tis.e.t
Evanitcn, dllinoii 60201 / , ^ >* •» .
/>* AT/??/
J
ar.
6 ^^ ^ ^^^
£
U*3L 4J~J**A. A^N-u-T Jf^**f
. WL A*ZC £&*^ &L&L
/KtL*^ £tL
-------
Uta
/
-------
MILDRED KIRSCH
31O HASTINGS ROAD
HIGHLAND PARK. ILLINOIS 6OO35
-------
£
Donmoon^ff
makes things boys like to wear
21, 7977
M/t. Gany Sc/ienze£
WateA ReaouAce* PlanneA
E.P.A. WoteA QuaLity 0^ce Rm.
33 W. CongAe44 PaAkway
Chicago, ILL: 60605
you can undeAAtand that 04 p-t^vate cctizen4 each o^ ui nai -to
OUA ow;n LiveJLihood. In otke.*. wondb , we at.e butxineAA and pA
peop£e -tn addition to anotheA A^poM-ib-itity at> paA.e.ntA , husband* and
T/UxS handicap* a& to a g/iaat ex^ten-t 4-cnce we can not dzvote. a gizat d&al
tmn ^on. any AuAtainzd nfifio&t ov&i a period oft time, in doing what m^t be
done -eta t&uru> o& the. Ciave.y Road c.on&ioveAAy.
I bztizve. the^e. ann e.Kte.nuating cx>icum4-tance4 and theA.e.^oAe. 1 mutt appeal
to you to giant UA an exteni-con d& time, until May 26th to tieApond w-itk OUA.
corme.ntt> on the. dAa^t env-ct0nmen£a£ 4^:a^emen^:. Wi. TuAneA. iA -submitting
undeA. Ae.paA.ate. coveA, eng-tnee^cng and technical comment •• VA. Rogo^ -ci
comments on t/ie m-icAo biolog-ical aipecti, ande-t 4epatate
uc-££ pe^'unx^t JeAiy PacktoA and mui>
OUA OA4-igne.d position o£ OUA A&AponAe, to the. dAafit 4tate.me.nt.
Ijhm
Donmoor, Inc. 854 Merchandise Mart. Chicago. 111. 60654 Telephone (312) 3-M-<;iJ
Headquarters; 34 West 33rd Street, New York, N.Y. 10001
-------
Donmoor.
makes things boys like to wear
May 21, 1977
M/i. William I
ViAe.ctoA, E.P.A.
Washington, V.C.
20460
Wi. RuckeJLshaus,
Ai a A&Aide.nt ofi Highland PaAk,who-se. home, un^oitunateJly ha.ppe.nt> to be. no
mo fie. than $ifity yaAdb away &AOW the. Clave.y Road sewage plant, I ^ee£
compelled to WAite. you. about the. Ae.ce.nt dAafit i'yivuwnme.ntal £tatejme.nt
conceAning the. Uofitk Shale, Sanitary du>tsu.ctt>' pfiopo^e.d e.x.pan&ion piant.
It may be. ttae. I am 4 e£fj-c4 fo£t/ motivate.d due. to the. u.n{,oitu.nate.
0^ my home, to tkiA pottutoi but -since. 1 have, thjize. t>c.hoot age. chitdAe.n
you. can undeAAtand my &eJt^ii,hnU&. In addition, I am de.e.ptu conceA.ne.d
about the. quaiity o{± QUA. e.nvistonme.nt and about the. state, o^ OUA zcotogy.
AfiteA aUL, it is my chi£dAe.n -- and youAS , too — who aAe, going to have, to
Live, in this pottute.d, de.gAadate.d
Sewage. tAe.atme.nt ^aciJLitieA bimptg do not beJLong in high de.n&itij
oAe.as. The. htaith and MeJi^aAe. o& A&.side.nts should be. youA pAimaiy conce/in.
This caLts ^on a phase, out o& the. Ctave.y Road plant. We. -suppoAt youA
dAafit t,tatme.nt but uAge. a 9 M G V plant. Hold &at>t to the. fte.comme.ndations
&OA advanced ivateA tAe.atme.nt and complet&ly coveAe.d fte.te.ntion basins. We.
uAge. that you advocate, the. timoval o& the. e.^lue.nt Lagoon. The. implme.ntation
oft a -study oft ai/iboAne. inaction is a must. Combat pollution and psie.ve.nt the.
diQAadation o& OUA e,nvinonme,nt but not at the. po&bible. expense 03 human tiv&s.
^tA&^^
x \ ^
Donmoor, Inc. 854 Merchandi<;f Mart-
3rr^ Til f.C\fi- \
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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. 'Jilliara 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 sanitary
sewer system for the balance of Lake County Illinois, outside the North Shore
Sanitary System. ThekrChain 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,
S.\A. "Jimraie" 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 o£ 200 unfortunate people
who bought expensive houses on cheap land next to a sewage
plant.
Sincerely yours,
Elaine R. Grossman
(Mrs. Arthur I.)
ERG reel
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. William D. Ruckelshaus, Director
Smrirenaental Protection Agency
1626 K Street, N.W.
Washington, B.C. 20U60
Dear Mr, Ruckalahaust
Please be advised that the Beard of Directors of North Subiirban Synagogue
Beth £1, 1175 Sheridan Bead, Highland Park, Illinois comprising over 300
families, at their regularly constituted meeting on Honday, June 21, 1971 did
pass the fallowing resolution:
"Bssolred, that >iorth Suburban Synagogue Beth 31 had requested an independent
study ef the HFSD nropeaed expansion at Clavey Road and a moratorium on
cans tructien.*
"Resolved, that an independent study was undertaken by the Water Quality
Office «f the United States Environmental Protectian Agency and that a
preliminary report and recomaendatiens were made public
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1210 Gregory Street
Wilmette, Illinois
60091
May 4, 1971
The Honorable Wm. D. Ruckelshaua
Administrator
U.S. Environmental Protection Agency
1626 K Street N.W.
Washington, D.C. 20460
Dear Mr. Rusckelshaaa: 7
We 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 IS million gallons of water per day, - shall be imple-
mented OR will the expansion pl&ns be such that the plant
can handle only >up " to 12 million gallons per day,
Mr. Gary Schenzel, water resource planner for the
Federal V/a$er Quality Administration is making it clear to the
conservationist groups on the North Shore that while he under-
stands that Lake Michigan is at the center of their thinking
and of those of the federal and state boards who have ordered
the replacement of five obsolete treatment plants on the
lakefront, - he feels that 200 home owners in the area should
receive consideration even though no tests have been made for
bacterial contamination. He further added that
FEDERAL FUNDS FOR TEE PROJECT WILL DEPEND ON THE
ACCEPTANCE OF FEDERAL GUIDELINES.
Perhaps the DesPlaines River project west of Deerfield
and between the Chevy Chase and the Thorngate Country Clubs
(a project Mr. Schenzel »s new plan suggests for federal funding;
will be approved by the citizens of Riverwoods and others. But
also it may be that building in that area will boom before
Mr. Schenzel gets h.is "compromise" plant in operation.
It is unfortunately true that people in this area have
grown accustomed to and believe in the disinterested and proven
judgment of the members of the Illinois Pollution Control Board,
Messrs. Currie, Dumelle, Kissel, Lav/ton and Aldritch. This
Board had previously given permission to the North Shore Sani-
tary District to issue up to §55 million more in bonds without
a public referendum. But now, financial problems mount, a re-
duction in the processing of sewage from IS million gallons to
4.5 to 12 million gallons per day is called a "compromise" and
five obsolete outfalls continue to polute Lake Michigan. Con-
servationists wonder '*~3re to turn.
Respectfully and with considerable frustration
(Mrs. L. T. Wyly) . ,-,
'
ul,
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1-lay 15, 1971
1626 1C Screen
' ."caning'con3 D. C. 2C4cC
_ i ar 1-Ir. Rue ke I s hau s :
..^closed you will find a c.rl-r-ai-^lcnu-ory letruer
ccn£_n.cuanu 1-ir. Tiior-ias j. _i_;—_c.cy zn regard to tne
:rc^osed expansion of cha l.crch £'ncre district. .
1 r:culd greatly appraciac-- " ...:.--s;-^ ir..f orrr.aticn and
c:-joioCi.nce your good o-Uic;i can provide in connection
..iirn ^v response in this lu-ittar.
cinceraiy.
Lc.rola R. Collier \
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O«ANT* GRANT
LOUIS Z. GRANT
• UNTON F. GRANT
1 Offices
of
BURTON F. GRANT
C9 WEST WASHINGTON STREET
CHICAGO, ILLINOIS 6O6O2
SUITE 2252
TELEPHONE
AREA CODE 312 C4I-36OO
Mr. William D. Ruckelshaus
Director
E.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 th*t this plant be phased out quickly.
Verjtruly you]
BURTON F."GRANT
BFGrlsf
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£fxtein and
, 3nc.
EXECUTIVE OFFICE 31S WEST ADAMS'ST.. CHICAGO. ILLINOIS, SCJfi ±F, U.S.A. »
CABLE ADDRESS - SHEPS CHICA3O
PHONE (312) 7B2-7S15-13
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ENVIRONMENTAL PROTECTION AGENCY
Office of Water Programs
WASHINGTON, D.C. 20242
JUN ii
Mrs. William J. Pieterxpol
Environmental Quality Chairman
League of Women Voters
Winnetka, Illinois 60093
iJear 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, x
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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. Palang8_
Ralph C. Palange
Acting Director
Division of Facilities Construction and Operation
cc: Regional Office, Chicago (2)
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OT \»w«««»i«i . w.w'i'j
of Wirmetka — Northf ield — Kenilworth
Winnetka, Illinois 60093
May 6, 1971
Mr. William Ruckelshaus, Director
U.S.E.P.A.
1626 K Street N.W.
Washington, D.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. Pretenpol
Environmental Quality Chairman
(•Mrs'.) Stephen J. Fraenkel
President
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MRS. RALPH G. DUNLOP
2246 ORRINOTON AVENUE
EVAN8TON. ILLINOIS 6O2OI
June 13,
V.r* William D, RuckelshMis, Administrator
United St-tos Environment". I Protection Ar.ency
Jfii>6 K ^treet
. -i?- 1.1 n^t •>"••., »(.C«
rear ' ' • . • k.. • ' " r : u :
I . r \.iy c.jc-. rrseo i:i,out the restoration anti .?rcs-
erv ti .<•• -r .' nu li*y of 1., !;c >.'ichii..'rin« I ho->c t'.ij t c
•«;i P do everything no«?sil;lc to avoid further deterioration
of the L.;ke»
In this c'^n1 ct: : , it . c r.s to me to bo i ]icr:itive th..t I
the Clavcv ;t d, In <•! n< .rk, Illii.-'ois, sc r.;% -eH — =-&«-JL i
plr.ri IH I.-- ri'-td to tlic re-con' .ended l«Sm.i'cl c;: %-scLly row.
I kno- 1 h. t • cot tr- ry rcl: i? >ry ,'<. c: • s i : '.'c.
In 1 i. !r- < _' ;- •<: evit erce • r(. st tc». in sc --ri oT ; • ^x-
pansi'jn of i...is s .-lit, in- t'!!C "oi * .ftiou ruii:.vi b- ,- .- -.i,"
Iroj.i i'i 1 y :.r c:: npioi?, I renucst tiu;t you tt-cu si.c-r ./--.
decision .
Cory Vr. j'r-ncis Mayo
ry c I cr ur.... ;;
( r?. I .1.
I-"! P
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MRS ELAINE LEGOFF
1663 NORTHLAND AVENUE
HIGHLAND PARK, ILLINOIS 6OO35
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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 wacer,
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 v/ater biota whir.h will arise as a result of dis-
charge of high quality water into the Skokie River should
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 effectiveness of
the plant treatment process. In short, the manner of operation
of the plant by NSSD can probably be effectively monitored by
suitable microbiological analytical procedures designed to
characterize the new biota and observe changes in it.
3. The entire position of NSSD on epidemiological consideracions
rests on testimony of Dr. Deinhardt (p 25). This testimony is
not included in the appendix. It should be1. The natur-i of
his testimony is such that it cannot support his conclno I jn
that no danger exists, or will exist. Several points he made
can be negated by the Berg paper (included) and by mors
recent literature (M. Rogoff, included) now in the stateriient .
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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.
MHB/Jb
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Rcc Clxuu%>c.i;i!
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VILLIAM G. SMITH
President
OBHT J. NELSON. JR. ~=^^^^^^^' HOWAR° °AULT
c''efl: ~~ " GEORGE W. GOLOTECK
INCORPORATED - ELWOOO K. GRAUNKE
E. JAMES HARTWIG
•ArsL£r'j. ESZDcK O1 , Q _»
Treosurer • . May
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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/
KK:ER
CC; Mr. William G. Smith
Mr. Carl Duffek
Karl Klomann
Village Attorney
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BOX 583 W! I M £T"-E
the Committee on Lake Michigan Pollution -e
I!r. Willian Do huckelshaus, _.d :"n.:;.-;r
TJ.o. Environmental Protection -^-"c^
".'ashin, .ton, D.C.
Bear ''Ir. riuckelshsus:
The Committee on Lahe h'icl". 1^,-J.p Pollutf 'ii ;' .j t, • :Vr.:: zins rou_
of residents in suburbs n: ve •'<-. d a A;
and have T orked d:hli0ently on h. ye bet-1 .- "^orc l's_v.e .'' r the 1'orth
dhore San:" tary District, and a stc. te EOIU Issue -•"..'(;"* - oul;" *?•. ..-
th? construction of se'Vc.^e trebly ent ^ It.-its "--i ~11:'"'V•-":.•. e • ,.vt
observers at all the rece.it "•es.rln, s C'jnci-jr-.<;-\ :' L *"> .-h ._,"• • o
-ianitfry District. Cur • ^ jor concern is ''Olluri •• ~f I.-/ o " c'~:, , r
'.e vere and still .-.-re very ^ lea tied v-f tr v':e c.-i-t "•..?. 1"^ J^ • / t
out and v/ell presented. op:"niuii i:-" s i'." 1 lih " rn
Control Board on tl is very controversial issue. e , re v-.;•;, >.'.:',: a;-oc.
and disappointed "ith t]" e fjj^PA -^nviro ij .ental i:'j..;';t ot-te-- unt. Tr.
our opinion it ill delay coiutructi-ai, eel- , ^t"'-'".^ i~-<. • ] -t _-,; -
sev^a^e out of the lahe fror: f?iTe treat t-pt ^1-i't,. cl---_ I'.t h, -. '."!-.
also ••'ill pad y round '30 -;ill:'';ri in coses, •" n fc ct, s,;c' ." ' of
dela; t-.rhlo 1^ to costs.
200 very unreal" otic -j;' thzers • \ c, t Id vi_ c ..•-'...tI".K-t:h-n foi-
tvo ye-_.rs, und tlius have ^ e)- T' ' a~ed " no:-o;. .cd i .J'i-^.-1-" :-.-L cf the Iske.
Beaches have be-_n clo: ed -..n'~. " ealh .> f.'cei'.. s_^ •'. .it, —:"11 --. M hi " t
closed. "'h evidence :_:_.s be . n presentei'^ "i i t _ r..v > s ':....ci-e vill ; e
deleterious effects to these rts." dents f.. ^ t--. tie v- lc r^e eri. o£ l\ e
Cli.vey Hoi.d treat .ent pi, rt. ..hfare*2^ -•• pi-,/It s , t Cl vt.^ >h>e
to it bein. \rosoly overloaded ; t ]_ re '---• t. "..':"Jl. proper c._c ^ ":•;•: l~o
16 iT:pd there -:ill not be this p-^-lc, .
Si-i:hl:-r treat-.ent planes h1 ve jiol . r~ c";-":. ei c-. " c in > ^..
is a latter of vital concern to t.ll co . ui.:t:"t.j i/J.c':\ the Ic he. i:.; t rl
vritnesses such as hr. Jtoener of the T'nivers: t^ of h:'cn :' p;aa h v^
told us of the ver; sad condit:1 ^r of Ih.he "ichip^n. It •' s ->f tl e
utviost urgency to heep nubrrents v.-.c oth-u.- pollute nf^ O'-.t "f1 v.'.e 1.1.e
t':at &re presently ^ein:_, put tl ere by the ~rorth .hore Jt .-i* i-..-• h •'.:,\* ct
'ihe District " ? ^ betn tr; i;ij ^~ r .jevc:.-;. 1 ^e:.;-^ to --t '0T :".
mhe II lined s FoW.'uti'rl' do-n^rv!. ~L> .-d • :-dtre<' t '-'i "' " • c^f". "• ".
s_.eed ahead. "'e ur^e V .e V^l_P.i to h'-nor t! e o_ i--* D .r -' Q_^- .1 ~f
of our capable Board.. "hey ~<,--'~e ,:1;i;; ied t" :'o c .e :"].:'. -. h.l^.
i
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TORS. fDA.RSHA.LL FINKeLCDA.N
332 LAKKSpUK, HIQHLA.Nb PA.KK, ILLINOIS 60035
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723 Happ Road
Northfield, Illinois 60093
(312) 446-2506
GENERAL ASSEMBLY
State of Illinois
Bradley M. Glass
State Representative - 1st District
June 12, 1971
COMMITTEES:
Education
Elementary and Secondary
Judiciary I
Mr. William D. Huckelshaus
United States Environmental
Protection Agency
1626 "K" Street, N.W.
Washington, D.C. 20460
Dear Mr. Ruckelshaus:
I am 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 13 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 acoordanpe, with that of the
Illinois Environmental Protectiorr'Agency.
Very truly you^s,
BMG : b
Llrs. Eileen L. Johnston
Mrs. Leonard Liebschutz
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1175 SHERIDAN ROAD, HIGHLAND PARK, ILLINOIS 60035
PHONE 432-8900
Samuel H. Dresner
Rabbi
June 23, 1971
Mr. William D. RuckeLshaus, Director
Environmental protection Agency
1626 K Street, N.W.
Washington, B.C. 20U60
Dear Mr. Ruckelshaus:
Philip L. Lipis
Rabbi Emeritus
Dr. Louis Katzcff
Director of
Religious Education
Cyril G. Oldham
Executive Director
Gerard W. Kay<;
Youth Director
Please be advised that the Beard of Directors of North Suburban Synagogue
Beth El, 1175 Sheridan Read, Highland Park, Illinois comprising over 800
families, at their regularly constituted meeting on Monday,June 21, 1971 did
pass the following resolution:
"Resolved, that North Suburban Synagogue Beth El had requested an independent
study «f 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 possible
size, s«,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 basins be moved to a non-residential area and be com-
pletely wvered.
U. 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 possible airborne
infections. f
Very truly yours, I'^'J
Daniel Tauman,, President
C. C. Gary W. Schenzel
C.C. Amos Turner
nard H. Sokol. Secretary
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MRS. RALPH G. DUNLOP
2246 ORRINGTON- AVENUE
EVANS7ON, ILLINOIS GO2O1
June 13, 1971
Mr. William D. Ruckelshaus, Administrator
United States Environmental Protection A, ency
1626 K Street
Washington, D.C.
Dear l,'.r. :iuc!;elsh: us:
I am very 'p.uch concerned about the restoration and pres-
ervation of the quality of L; ke .Vichijran. I ho^e that "/e
will do everything nossible to avoid further deterioration
of the L-ke.
In this connecti: r., it seems to me to be i™,nerr-tive thrt
the Clavey ?.o;:d, Uichl^nd ?'nrk, IJlinois, se var:e diF--ospl
plant be ex nded to the recommended ISmg'd c,--riacity now.
I know that a contrary ^relirrinary decision has been mace.
In light of the evidence oresented in sunnort of the ex-
pansion of this plant, and the pollution which is resulting
from delay in expansion, I request that you reconsider your
decision.
Sincerely,
Mary Helen uunlop
Copy Mr. Francis Mayo (Mrs. Kaloh G,)
-------
LAW OFFICES OF
5NYDER, CLARKE, DALZIEL,HOLMQUI5T
TOHNSON
LE-*I5 D.CLARKE
DANIEL J.DALZIEL
•WILLIAM A.HOLMOJJIST
JULIAN JOHNSON
ALFRED W. LEWIS
GERALD C SNYDER.JR.
JOHN F. KENNEDY
JAMES M JONES
LEWIS D.CLARKE,JR.
WALTER D JACOBS
JULIUS J ZSCHAU
3O1 WASHINGTON S^XE
WAUKEGAN, ILLINOIS eco
May 18, 1971
ERALD C SNYDER
OF COUNSEL
TELEPHONE
623-012O
AREA CODE 312
Water Quality Office. Region V
Federal Environmental Protection Agency
33 East Congress Parkway
Chicago, Illinois 60605
THIS FILE iS THE RESPONSIBILITY OF
Alfred W. Lewis
Attn: Mr. Gary Schenzel
Re: Draft Environmental Impact Statement dated April 21, 1971
For Sewage Project No. WPC-111. 754 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 County 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 character of the environment and development of the area of
Riverwoods, including the Des Plaines River and ihe adjacent Lake County
-------
SNYDER, CLARKE, DALZIEL,HOLMQJJIST 8 JOHNSON
- 2 -
Forest Preserve, and upon cursory review of the Statement, certain comments
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 many
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
-------
SNYDER. CLARKE. DALZIEL, HOLMaUIST 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 furtte 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
-------
APPENDIX B
PUBLISHED ARTICLES. STATMSNTS, AMD TESTIMONY
-------
Reprinted fr.mi AMERICAN INDUS TR1 \[. IIYC.IF.Ni; ASSOCIATION' .JOURNAL
Volume 27, Nose i,il)ci-Drrc:i!l..t-r, 1966
Bacterial Air Pollution from Activated Sludge Units
CLIFFORD \V. RANDALL* and JOE O. LEDBILTTLKt
Arlington State College, Arlington, Texas, and The University of Texct, Austin, Texa>
@ Large numbers of potentially pathogenic bacteria were collected from the air
surround!!;™ activated sludge units, and ninny persisted for a con^dcrablo time
and distance. Significantly, the airborne enteric pathogens were greatly outnum-
bered by bactrria cf proved pathogcnicity in t!,c respiratory tract. Klrbtiella
prtfumorJaf was the pathogen isolated most frequently, and sc\cra! studies con-
cerning the spread, longevity, and factors of pathogcnicity of this organism were
conducted. The potential Iieahh hazard of the emitted respiratory pathogens was
considerably incrca-ed b\ tlie fact that a large percentage of the aerosol particles
transporting viable bacteria 'Aere of a size permitting lung penetration.
HpHE RESEARCH reported here was done
•*- to obtain data on the numbers and types
of bacteria emitted to the atmosphere from
activated sludge unit?, data that would be
useful in evaluating the possible hrr/ard of
Infection to sewage plant operators and
others in the immediate vicinity.
/
Literature Survey
Nearly all eaily theories of disease trans-
mission taught that the air ua.i the chief
vehicle of infection. This belief existed as
far back as 1600 B.C.' and was promoted by
Hippocrates, the "father of medicine," with
his writing that men were attacked by fevers
when the\ inhaled air containing hostile pol-
lutants.5 Foul odors associated uith sewers,
wastewater, and rotting organic material were
generally considered to be evidence of such
"hostile pollutants." and even the early mc.ve-
ments for sanitary improvement during the
18th and 19th centuries were based on mias-
mic theory.1
Following the advent of the genii theory
of disease in nrdninetecnth centiity, distinc-
tion wasdtaun between foul-smelling air and
infective air.3 Many attempts were made to
^_____^_ ' «
PrtjcrtcJ it th- Ann-near. In'.'xtri-it H^u-rie Con!" encr
Pittiburxli, Prntvxi'i.iiA, M.iv !6-2<\ l'> li
*Assi .:.*r,£ Profej>'>r, Ari'.nqton Stite C>"»T'?ce
tAi^ociaff Prof*5sor, Thr University ot Tc\aa.
link intestinal disease to airborne organisms,
but few efforts were made to actually meas-
ure bacterial emissions from wnstewater. To-
ward the end of the ccntmy Miguel counted
800 to 900 bacteria per cubic meter of air
in Paris scweis; however, he found like num-
bers in the air of the city street'. Similar
bacterial counts were obtained by Carnelly
and Haldanc in London sewers.- Horrocks
also studied a'uboine bacteiia in London
sewers, but he was primarily inteiesied in
mechanisms of emission.'' 'Winslou v. as con-
cerned about the possible transmission cf
enteric fever through the inhalation of sc\\er
gas.5 He proved that the splashing of *ew-
age liberated organisms into the air where
they could be borne convidc-table distances.
but he concluded that infection froir sewer
gas was remote.
By 1910 nearly all the dicaded epidemic
diseases, particularly those infecting the in-
testines, had been traced to vehicles other
than air, as their primarv modes of infection
and airborne infection had practically been
discounted. Moreover, as control of tvphoid
fever became established through v.ater treat-
ruent, feces disposal, and food sanitation, in-
terest in aiiborne sewage organisms prac-
tically disappenied.
Following a revival of interest m airborne
-------
American Industrial Hygiene Associntiun Journal
infection around 1930, Fair and Wells con-
ducted the first study of bacteria emitted
to the atmosphere by sewage disposal pro-
cesses.8 From their brief look at the bac-
terial density of the atmosphere surrounding
sewage treatment works, they concluded that
bacteria! contamination of the air Lv jew-
age works exists :md that liberated organ-
isms of respiratory and skin diseases could,
remain airborne and viable for long periods
of time.
Apparently the next actual study of bac-
terial air pollution from waste treatmuni fa-
cilities was conducted b\ AllieHuT in 1958.
He determined the numbers of bacterja
downwind of a trickling filter and found
that the distance of travel of viable bac-
teria correlated directly with the wind velo-
city.
Prior to Albrecht's investigation. Jensen
had looked into the presence aiid survival
of the tubercle bacillus in the liquid phases
of sewage tieatmem processes.3 From these
results lit1 surmised that there is a real dan-
ger of tubeiciilosii infection, especially to
opeiaiing and supervisory personnel, from
droplets injecced into tiie air by activated
sludge units, h\ trickling filteis, by spray
irrigation with sewage effluent, and by wind
action on wastewater 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 treated,
some cursory attempts have been made to
determine whether the incidence of infection
among sewage plant workers is increased,
but they have resulted in inconclusive find-
ings that were attributed to incomplete em-
ployee medical records.11
The mechanism of aerosol production by
bursting air bubbles on the surface of salt
water was studied by Woodcock.12 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 from aera-
tion of polluted water.13 He used suspen-
sions of several species of microorganisms to
*)
find the effect of acrosol'i/ation and chem- '
ical additives along with other variables on
the generation of viable aerosols. Higgins
reported very low recoveries of coliform or-
ganisms compared with Scrratia maicescens,
Bacillus subtilis, and two Streptococcus spe-
cies, with no %iab!e Escherichia coli or E.
jrcundii found.
The Enteric 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 family Enterobacteriaceae.
In this study the enteric bacilli are con-
sidered to be gram-negative, non-sporc-fonn-
ing rods whose common habitat is the intes-
tinal tract of man. They are defined here to
include all members of the family Entero-
bacteriaceae plus Psi'udomonas aeriigino*a,
Alkaliticncs faccalis, and all other Pseudo-
nionas, Alkaligeiies, and related species that
are capable of growth on EMB agar.
Enter cbactcriaccac
The Enterobacteriaceae are mane up of a
series of interrelated types that do not lend
themselves to sharp division into tribes or
genera; however, the family is bO large and
unwieldy that it is necessaiy as a matter of
expediency to divide the family into gtoups
that form the basis of practical work. The
following grouping, primarily as proposed by
Ewing and Edwards,14 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 fet menta-
tion. The Klcbsiclla oxyiocitm of Lautrop*'
is* included in the Klebsidla group as recom-
mended by Ewing and Edwards; however, in
this study it is differentiated from K. pneu-
moniae simply by the ability to produce in-
-------
November-December, 1956
TA B i, E I
Classification of E"'.erotuc*.t.TiJCeac
Principal
Groups
• TABLE II
Difft. entut.^n cf k '^ *)»;»•/.'.) .ind A eroi t :fera
Lysinc Ar^inine Ornilhine M^tiiity
Shtjelli ~ E«.r
Snlmont-llj — Arizona
Cmobacter
Serra.'ia
Protfus - P:o\ idsrce
Erwinij
£. C3/' Tjpts [ u-J II
AUale icens - Dispai
AtlZO-K,
Citrcbac'.er
Bethesdj - BMlerjp
K. pnt'UiTonu
K. 011 focum
XeroiMclc-r
rUfnia
Prod-as
Prtn irie-ice
£rw in [.i
dole. Identifications of the members of the
family were made by the methods of Edwards
and Ewing1'-1 and of Kauffmann.17
Satisfactory differentiation between Kleb-
siella and Acrobaclcr can be made through
the use of motility and amino acid decar-
boxylasc reactions as recommended by Kauf-
mann.18 Tlie reactions aie sho\\n in Table II.
Other Enterics
Besides the Entcrobacteiiaceae, the gram-
negative rods most commonly found in the
intestinal tract are of the Alkali^en-.s species.
particularly A. fccalis. Othci common in-
habitants are the pseudomonacls, primarily
Pseudornonas aeruginosa, and the Flarobac-
terium species. Tlie AlkaHgencs and Pscudo-
monas groups are of particular interest in
this study because tile uoik of McKinney and
Weichlcin19 indicates that tlicy aie the pre-
dominant bacteiia in tlie activated sludge at
the Austin biosorption plant, where most of
the data reported here were obtained.
Sampling and Counting Methods
The sampling of viable airborne bacteria
was done by tluee different methods: (1)
direct plates, (2'! liquid impingement, and
(3) the Andersen sampler. TTie method se-
lected depended on the re-quitcmer.ts of the
paiticular experiment.
Direct Plate Method
During the early phases of the study, air-
positive reacticn. - negative reaction.
borne bacteria \vere sampled by merely ex-
posing the surfaces of poured agar plates to
the wind for three minutes at a height of 4
feet. The sampling was done in duplicate
with the 3j/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 cairn.
gt'r .Metliod
The impinger used \sas especially designed
for sampling bacterial aerosols (Millipore
all-glass impinger) with 30 ml of a sterile
collecting fluid (may be nutrient^ to im-
pinge the aerosols. After sampling, the liquid
was filtered through a membrane filter which
was then placed on a nutrient a^ar base in a
petri dish and incubated for 12 to 18 houis at
35°C. The colonies were counted under obli-
que lighting and magnification. The short
incubation peiiods wcie used to prevent the
colonies from merging.
The \iolenre of the agitation during im-
pingement should ha\e broken any clumps
and promoted counts of individual bacteria.
The samples were filleted within 45 minutes
to reduc: the possibility of multiplication by
the bacteria in the impinger.
Andersen Sampler Method
The Andersen sampler v\as employed to
collect bacterial aerosols by impaction on
nutrient agar surfaces and to sepatate them
simultaneously into six size ranges on six dif-
ferent agar plates.20 The first two stages of
the sampler removed particles gi eater than 5
microns, the remaining four stages removed
the rr«pir^ble particles (less than 5 microns,',
tho.se that may be breathed into the lower
respirator) tract.
The plates obtained with the Andersen
sampler were counted in the usual manner
\\hen the numbers uere small, and in all
-------
American Industrial Hygiene Association Journal
cases for the first two stages; however, when
large numbers of colonies were collected, the
probable numbers of bacteria were obtained
from tables that weie statistical considerations
of the number of positive holes (among the
400 perforations) for stages 3 to 6 as outlined
by the designer.50
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 over 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 controls were run throughout the
study in order to maintain high standards for
accuracy.
The wind, temperature, and relative humi-
dity were recorded for each test. Wind velo-
cities were obtained from the U. S. Weather
Bureau at the municipal airpoit 3J/2 miles
NXW from the sampling aica and were used
on the assumption that the same regime pre-
vailed at the two places.
Sampling Location
The data presented here came primarily
from the Govalle biosorption sewage 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 grit and grease removal unit,
which uses diffused aeration. In addition, a
few samples were collected at the actuated
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 chlorination.
The samples that were intended primarily
for determining the density of bacterial emis-
sions wcie generally taken at 20-, 50-, and
100-foot distances do\\n\\ind of the aeration
unit, while those samples for study of the
types of bacteria and their relative abund-
ance weie usually made itnmcdiatelv adjacent
to and downwind from the aeration tanks at
heights of 2 to -4 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-methylenc
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 48 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 Scrratla. Of the other 26
colonies, seven were E. coll, four were Citro-
bacter, six were intermediate Eschcrichia, five
were Klcbsiclia, and four were Acrobactcr.
EMB a^ar was used throughout the sttidv as
C> O /
the collection medium for the survey of the
enteric organisms.
Special techniques were used in attempting
to demonstrate the presence of Salmonella
and Shigella organisms in the air. All three
aerosol sampling methods were tiied for this
purpose, and samples were taken at all three
sites.
Agar plates containing MacConkey (Mac),
Sahnondla-Shigclla (S-S). brilliant green
(BG), and bismuth sulfite (BS) agars (Dif-
co) were exposed in the Andersen sampler
and by the direct method. Samples were
taken with the all-glass impingcrs using brain-
heart infusion broth (Difco). The impinger
•samples were then filtered through a mem-
brane filter, and the filtci was either (1)
placed on nutrient pads containing selenite
enricluiK'nt broth (Difco) and then plated on
S-S, BS. or BG agar or (2) plat-.-d diixctK
on S-S, BS, or BG agars. Additional sample-;
-------
November-December, 1966
c
TABLE III
Selection and Identification Procedure1 for Enterobacterlaceoe
Collection from Atmosphere
Directly exposed agar plates
Liquid impingement
Andersen sampler
Growth and Isolation on EMU or MacConkey Aear
Trlple-Sugar-Iron Agar Slants
• . Discard all negative (=) reactions
\
I
Screening Tests for EnterobaiMeriaceae
Oxidatwe-fermentative (O-F)
Cytochrorne oxidaso
Nitrate reduction
Catalyse
Reaction
F
Negative
Positive
Positive
I ....... Discard all o*her reaction combinations
Standard Differentiation Tests for Entcrobactc riareae
UreaAg ^ if positi% e in 4 hours phenylalanase
\
• Discard prj:eus
Dextrose
Lactose —hold for delayed reaction
Sucrose —hold for delayed reaction
Indol
Methyl red — analyze after 48 hours
Simmons citrate
Lysine 1
Arginine > layer with \aspar; hold 4 days for delayed reactions
Ornithine )
Motility - semisolid agar; 2 days at 37°C, 3 days at 22QC
Indole *
Lactose -
Motility *
Pheny lalanase
(Detection of
Providence
Gram utain if stil
Hole: Pastfurflla
Xeroiacter Arizona Alkalescens — Dispar
K/eis/eifa » 4
Zsc/iericA/a Dutcitol Serology
t "t'1"
Inositol Serology
Malonate
Voges-proskauer
Capsule production
Serolog>
LI unknown
peatis and P. pseu(fofu6ercu/os/s -iill pass sciceaing tests.
were taken with the impingcrs using sclcnitc
broth or tctrathionatc broth (Difco) as the
collecting fluid. The broth was left in the
impingers after sampling and incubated for
24 hours at 37°C. Following incubation, loop-
fuls of the broth \\cre streaked for isolation
on Mac, S-S, BG, and BS agar plates. The
remaining broth was filtered through a mem-
brane filter, which was then placed on an S-S
agar plate for incubation. Follouir.g colony
development, all noncoliform colonies uerc
identified by tho procedure gi\en in Table III.
Laboratory Analysis
The cultivation and differentiation proce-
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 En-ing16
and by KaufTmann.17 Unless otherwise noted.
the \arious media used were dehydrated Dif-
co products. With the exception of the carbo-
hydrate, alcohol, and urea solutions, ail media
were sterili/ed in the autoclave at 121°C.
For identification purposes airborne bac-
-------
'American Industrial Hygiene Association Journal
TABLE IV
Grouping of Non-Enterobaeteriaccae
Group
Xeromonas-ltke
P«eurfomonj»-liVe
XrcAromoijcfcr-like
Pa«t€uteUa — .4ct/no6act7/wi-
lik*
TSIa
©
*
+
O-Fb Oxidase
F +
O +
O
F +
Nitrate Catalose
-
+ -r
-or+ +
* +
JJTSI reactions: -, no acid; *, »cid;0, acid and gas.
bO-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 type 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 from growth on
the TSI slants, incubated at 37°C, and
examined or chemically tested after 24 hours
except where otherwise noted in Table III.
Christenscn's urea agar. prepared in the
laboratory according to Christensen's original
procedure,71 was employed for the urease test.
The motility, nitrate reduction, and oxidative-
fcnnentativc media uere also prepared in the
laboratory according to fotmulas tccornmend-
ed by the U. S. Public Health Service, Com-
municable Disease Center.
Purple broth base was used as the'basal
medium for the fermentation tests. The car-
bohydrates and alcohols were filter-sterilized
in 10% solutions and added aseptically to
obtain final concentrations of \^c in the
media. Gas production was detected with
Dm ham tubes. The media were incubated
for 24 hours before inoculation. Amino acids
were added to dccarboxyhse medium base in
concentrations of 0.5^c, and all tubes were
layered with vaspar following inoculation.
Except for the incubation time (48 hours
instead of five clays) of the metlul red test,
the indole, Yoges-Proskauer, «and inetlul red
tests were performed according to Stcndaid
Afcthods.-- Difco instructions were followed
for the phcnylalan.is^ test.
After biochemical analysis, apparent Sal-
monella and Sliivt'lla cr^anNms were sciologi-
cally tested in polyvalent antiserums by the
slide agglutination technique. Salmonella O,
poly A-I, and Yi antiserums were employed.
Alkalescens-Dispar antiserum was used in con-
junction with gioups A, B, C, and D Shigella
antiserums.
Organisms biochemically determined to be
Klchsiclla were seiologically tested in poly-
valent 1-6 antiscium for the qucllung (Xeu-
field) reaction. Prior to testing, capsule pro-
duction was enhanced by growth in the medi-
um of Hoogerhcide33 for four to six hours.
Difco dehydrated antiserums weie chosen
for the scrological tests, which were per-
formed according to the methods of Edwards
and Ewing.16
Isolated bacteria that did not belong to the
family Enterobacteriaceae (as determined by
the screening tests) were grouped according
to their reactions. Organisms that were inac-
tive on TSI agar slants wcie arbitrarily clas-
sified and reported as the Alkaligcnrs-Flaro-
bactcrium group. Those active on TSI agar
were classified on the basis of their screening
test reactions according to Table IY. This
broad grouping simply shows the type of
organisms deemed most likely from the infor-
mation obtained.
Results
The results are grouped into two major
divisions, just as the study was: the early
stages concerned with numbers, and the later,
, piincipal pottion on identification and com-
parison.
Numbers of Viable Bac'ttia Fmiticd
The results repoited here are for samples
colkctfc! do\\iu\ind of the au.uion units by
wind impingement on ag.u plates.
-------
November-December, 1966
G
40 60 SO
Distance Downwind (feel)
IOO
FIGURE 1. Effect of distance on numbers of
bacteria found.
1000 -
20' Downwind
100 r
g
o
10
Holt-lif« • 0 M •»•»
-------
American Industrial Hygiene Association Journal
100
eo
1
60
I
20
20' Downwind
Wind Velocity 10 mph
50
60
Relative Humidity
70
50
FIGURE 5. Effect of relative humidity on num-
bers of bacteria found (\\ind factor suppressed).
in good agreement. This fitting showed a
values of 745 for nutrient agar, 458 for EMB
agar, and 227 for coliforms. The correspond-
ing b values were -1.04, -1.18, n-nd -1.25.
The numbers of colonies on nutrient agar
at the 20-foot downwind station for samples
taken on 55 different days art plotted against
wind velocity in Figure 2. The effect of lesi-
dence time on the viability of the bacteria is
easily seen in both Figures 1 and 2. The
interrelationships of distance, wind velocity,
and residence time showed an effective half-
life of 0.38 second at the 20-foot station; half-
lives at the other distances differ somewhat
from this value became of the probable
changes in the predominant species with time.
the dispersion of the air ma«s3 and the devia-
tion of the survival from the exponential.
The geometrical nature of bacterial c''e-off
in the atmosphere can be seen in Figure 3.
The maximum death raf occurs between 0.7
and 1.0 second after emission. This period is
followed first by a rapidly declining decay
rate fcv two seconds, then by an apparent
stabilization after three seconds, which results
in relatively long survival times for the resist-
ant organisms. The power equation presented
above holds only for the first thiee 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 are
necessarily incomplete because of the narrow
range of relative humidity observed for any
one wind velocity during the study.
A comparison of the numbers of bacteria
sampled through direct plate impaction by
the wind, the Andersen sampler, and the
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 is
caused b) separation of lumps of organism-.,
the number of bacteria per particle is 1.35:
however, the number of mixed colonies ob-
tained could be surmised to renilt from t\\o
separate particles that impact near enough to
the same spot to form a single homogeneous
colon.
G
:nenc C'e'.err.iina'.ions s»;ow»
Ander. ^
thn di: ?
tli the
moth-
od to b; equal!; cfToct'vi. for leccvery of
Er.ierob^.L'.L". tace^-.' . I'i-.e prc,pm:l.n'. , did 1101
hoicl »nr othei enteiics, since direct plate
samples from which 98 Enterobacteiiaceac
were isolated gave only 53 other enterics,
while for the Andersen sampler the similar
numbers were 101 and 238, lespectuely. The
major difference in the numbers collected by
the two methods occuired in the Alkaligtncs-
Flauobacterittni group (inactive on TSI agar).
TABLE V
Quantitative Comparison of S'irrpiir.'; *.!eihc-!r,
Ve:hod
Nurrb-?r per cuMc foot
Rel.-'M.r p-r^er-.t
-------
c
November-December, 1966
TABI.C VI
Relathc Numbers of Airborne
Shi£-l'a
organisms found in the atmosphere. All
spec:es of this g.?nus are known pa;.ho?,-_-:i; of
the re-pir?.to.y tract,24-" anc' its »ur:n!;rrs
coinp:i--ed nearly one-thKi of .ill Kni.;ir.br.c-
teriaceae isolated. Six pe; crnt of all bacteria
emitted ftom the activated sludcje unit belo""
- O
to the Klebs':e!!,i group. From cr.ta co;!c>.tod
in this st'ic';,-. r. man wo;'.'i!^ w'u'iir. ^ .•"•„•'-". of
the dn
th>? \vi
\nv.r.c edge of :i:i r.erat'/
coul
a viabls KL-bsi^Ha evciy f.vo biea;h% based
on a tidal volume of 1 liter.
Both Asrobactrr aiid Pioteu1; organisms
have been repeatedly implicated in u-spiratoiv
infections.;CiCT These two. combined with
Klcbsu'lla, constitute 55.65"c of the Entero-
bactciiaccae, 18.9^c of the enterics, and
lO.o^c of the total bacteria emitted fiom the
activated sludge units.
The most significant airborne enteiic path-
ogens recovered were members of the Pio-
videncc group. Members of the Alkalcscens-
Dispar and Rc-thcsda-I'allerup groups are also
potential enteric pathogens, but they were
present in smaller numbcis.
The large number of indolc-positKe KL'b-
siella was a surprising result, since such or-
eanisms, although frequently reported/'''-9
have never been isolated in large numbers
from any source. The K. otytucum reported
here followed the classic definition of K.
pntiimoniac except for the production of
indo'.e. On the basis of Lautrop's \\ork," they
are equal to K. pneumor.iac in respiratory
pathog'>nicity.
Of the 77 Klebs\dla isolated, 75 showed
encapsulation after incubation for four hours
in the medium of Hoogorheide, and 19 g?\e
pos'.li^e slide aa^Iutinations in Kl-'b^-.-'lla polv
1-6 autiserum; however, only tv\o slide ag-
-------
American Industrial Hygiene Association Journal
TABLE VII
Relative Nutters of Non-KnUrobacteriaceae
Group
/eromnnas-hke
Attalijen,-s-M;>i=>&...:Ierium-!ike
Tot^l non-Ecitetobacteriaceae
Number of
Isolate!
36
27
35
344
476
Pe.-crr.t
of Total
7.6
5.7
2 9
11.5
72.3
100
glutinations could be confirmed by positive
qucllung reaction.
An unexpected result was found in the re-
lative numbers of the Proteus and Providence
groups—the hitter 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 abM:m.e of S-lrncr.dla, SY'^lls, and
Arizona isolation* is not too si.y.-irisir.". de-
spite nuir.crous reports of their pu^ence in
se\sagc a"d acuvsu-d «Hv ,o. TIic\ irr .•-<•> few
in numhei that the r.u'.Lori- t-.srd ;r» loccver
thorn fr^t.1. ?udi er.vu'orin\.-ms 'isi'.M!1.' or.tail
cor.tiri'ious -runnliav; for neiiods of time in
excess of ?1 hruts, ari^ even thfi
tial svicC'1". :* obtained.1'1'11
The ijol.itcd non-F.ntcrobacieriaccae were
broken down 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 activated sludge,19'59 the vast major-
ity of the non-Enterobacteriaceac belonged to
the Alkaligenes-Flavobacterium (biochemi-
cally inactive) group. The number of Psru-
domonas-\\\x bacteria isolated was consider-
ably smaller than expected, but some Pscudo-
monas species aie inactive on TSI agar and
would be grouped with the Alkatigcnt's-Flavo-
bactciium. One such species, Pseudomonas
mallophilia, which has a very distinctive TSI
reaction (~ H.Si. was found.
Information conctrnir.g the survival of the
various groups of the Rnterobacteriaci-ae in
the atmosphere was obtained by analyzing
samples taken at the dounwinc! station-;. The
results of this-study are tabulated in Table
YUI. As expecle.j. t'.-.c :e;ti'ts sl-.ow th.it the
capsiik-' forniers fl\^b-'<.rUi-Air;lr.ct<,-) aic \
better sir ted to r-i: \i»-:i! than tlv. :. •.•>|j.-.'.[l:it-j •
TABLE VIII
Spread of Airborne F.ntoncs
Classification
E'i"'h^T,""r
£. col.
Alk.. lescen*. — Dispar
C 'trob v 't'
K'- ks/ ''.ft
A[. pn«'ur^»ftiac
i\. o~y(jrt;/n
A*rc$ '.'f
A. »'!9it!t'i
Kafnia
SecTtitta
Prottas
Ptov iccncc
Unk-w«,n
Toul
^on-ffirfroiacfefsjcrjc
AeromonjS'like
Pieu30'iiu.T3J-i'ke .
Mc/tromoftjc.'er-lue
Toul i>o!atti
Distance
20
Species Group
14
4
1
4
IS
11
5
13
8
0
2
0
4
2
6?
0
' 0
2
4
62
68
no
Downwind fr?r.l Sou;
50
Species Croup
_,
1
0
2
9
4
5
4
1
1
1
1
1
0
"> 1
0
3
2
5
To
97
rcc (fee;)
100
??ec:e» Group
3
2
0
0
10
4
5
6
3
1
2
0
1
0
23
• 0
g
3
4
70
85
103
-------
c
November-December, 1966
TABLE IX
.
EMB aear
Nutrient agar
Kltesialla
0
10. S
6.0
as Pe1
20
13.8
7.8
•ceru of To' al
50
9.3
5.2
Count
100
9.3
5 2
Size of Viable Airborne Particles
Stage of
Sampler
Si?e Range
of Particles (/()
Particles per Stage as Percent
Station-Feet Downwind froT
0
1
2
3
4
5
6
>8.2 38.4
5.0 -
3.0 -
2.0 -
1.0 -
Up to
10.4
6.0 T Lung penetrating
3.5 T
2.0 T Alveolar retention
1.0 T
22
21
11
4
2
.0
.4
.3
.0
.4
3
15.1
32.0
31.7
17.1
3.5
0.6
20
8
23.
38
17.
9.
3
.1
.0
.2
.2
•:,
of Total
i Unit
50
20
29
17.
18
7
.0
7
.0
.1
.6
.6
100
24
22
27
12
6
.4
.3
.6
.2
.5
.0
r acaf
*•- 299?
group (for/if j-iVna-Citrobacter) . Of the sam-
ples taken in the immediate vicinity of the
activated sludge units (see Table VI), the
capsule formers comprised 52^c of the Entei-
obacteriareac. This percentage steadily in-
creased with distance downwind and reached
70% of the total at the 100-foot station. The
acapsulate group, by contiast. dropped fro-i.
n
in the first group of samples to 13
the samples taken at the 100-foot Ration.
Although the Fnietobni tr-i :c<..ie in gir>
are consider..! to bo i;-^ c.vv.Me of ynvi
in the atmo:.phcie than ivr-st uth;r t);.-'5
bacteiia, the A L'b sic'.'. a srr.iins v,e:e found
be neaiK as ies:>ia;it to dc-:ic.-.t:ini as the
average of the b.v:U:: ';i ramlcd :.:i ll.it stud.
of
to
fairly rapidl) during the equilibration period,
but those that still retain the capability when
equilibrium is reached suffer no fuither lo^s.
It should be noted that capsule, production is
limited b> the method:, used in this studs, and
the apparently acapsulate suains may be cap-
able of producing capsules if cultivated in a
more cj!tih!c ervironujent
Since the p:auc'.e si/e pia)s an impoitant
role in lung penetration and retention, cert.iin
size data were deduced fiom the Andei>"n
sampler data. This lelaiion is propeily diawn
because the sampler is designed to scpatate
particles by si^e. The data are piescnted in
(sec Table IX). The incicij'? in the rrintivc
percent of Ktfbsiclta at the 20-foot station
probably indicates that, because they are
encapsulated. Klcbr.rUa t.ivc a ioir.-r r,-^io'-l
of equilibration.
In an attempt to evaluate the possible at-
tenuation of viiulence of Kli biiclla organisms
with time in the atmosphere, a result reported
for other pathogen':,3'' Khb^lla recovered at
distances of 20, 50, and 100 feet weie ch.cckcd
for capsule production and compared v. ith
those sampled at the source. The peiceiuaers
of isolates capable of capsule pioduct'.on at
distances of 0, 20,, 50, arid 100 fivt \xero 97.5,
78.0, 55.5 and GOO, respectively. Appai .MuK,
loss of the capsule-producing funrti'>r. occurs
- Table X. While thr drift ?n: admitfdl; vari-
able and the <.v!r._, r;:t!'rci :s lar'\'':g i;i ;;'••-
cision, it i< demurs:! a ted that a considerable
niiniHer of the co'.iec'.ji paalcics could pene-
trate intc' and be leiair.rd bv the Jviman lunff.
Fifty-eight of the control sample colonies
(collected upwind of the aeration units) were
biochemically t\ped--ten uerc of the family
Enterobacteriaceae. Of these, five were Klcb-
siella (all K. oxytoc urn] , three were inter-
mediate AcrubaciiT specie-^, and two \\ere
members of the Providence group. The aver-
age concentration of the contiol samples.
using tli-? Andei^en sampler, uas six per cubic
foot en nutrient .T'ar. That th^ controls \\ere
-------
American Industtial Hygiene Association Journal
w .2
<*o
o
ie
w
u". ,-. ?+ «N o t-1 eo I "i
~< M«S
oco oonri
oo fn |
o o « oo
o ^* C\ c^ vn
*n eo o» eo ri
> t^ cs O* O -It^ o C
O Ul
"^ c
o o« «c r* o[ *r| -r
o-r. ooo—
00 00 t^ X
o o o -^ o*
Or- OO
o ac a- ^ t^ o
o» >n
o o « —
CD r* t* en in
O ^ tXr4 -TO
*" C
'IS =
S "? "2 ? ;
130.
-------
,
C
influenced by the other units was shown
in the results of several samples thai weie
taken upwind of the cntiic treatment plant;
these samples showed no Enterobacteiiuceac.
Comparison Studies
In Table XI, the viable airborne bacteria
emitted from the Austin activated sludge
plant are compared \vich 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 were dominant at
both plants, and the various organisms weie
• found in comparable percentages. The most
noticeable difference was the absence of
Aeromonas-likc organisms in the Round Rock
sample.
Klebsiella, Eschcrichia, and Acrobacter
species occurred most frequently among the
Enterobacteriaceac in the raw sewage emis-
sions just as they did from the activated
sludge units; however, the fraction of the
total enterics that were Enterobacteriaccae
_ was considerably greater. The primary cause
of this effect was the significantly larger num-
bers of Klebsiella in the raw sewage emis-
sions.
Conspicuously absent from the airboine
raw sewage bacteria were members of the
Providence group. By contrast, members of
the Proteus group increased to 7.3fc of the
Enterobacteriaceae, and all isolates were HjS-
positive on TSI agar slants.
Special Studies for Pathogens
As expected, no Salmonella or S/iigflla
organisms were collected during the normal
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 selenite broth in the
impingcr. Still no Salmonella or Shigella was
found, although a Salmomlla-Yikz 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-I antiserum and
Novcmbcr-Dccitnbcr, 1966
had the following biochemical reactions:
Triple sugar iron agar, — ; positive on methyl
red, citrate, lysinc, arginine (delayed), orni-
thinc, motility, and salicin (ten-day delayed) ;
acid and gas from glucose; negative on lac-
tose, sucrose, urease, indole, phenylalanase,
and dulcitol. Xo 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 several hours was tried with
the Andersen sampler using various agar
media recommended for the cultivation of
Salmonella and Shigella (MacConkey's, bis-
muth sulfitc, brilliant green, and Salmonclla-
Shigella). Several false Salmonella reactions
were 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 bacterial popula^ign. pf ili.p---'ir j*.
significantly increased, by passage over an
activated sludge waste, treatment ..... unit, Ironi
about eiftht per cubic foot on the upwind
side to 1170 per cubic foot on the downwind
side.
2. Despite a inpid die-ofT of bacteria dur-
ing the first thrce_seco:ids .they aie airborne,
the increase jn bacterial^population peisjsts
for a considerable time and distance — the
distance being s"tro'nglv"r3S3enHenL._on the
•.•••', . . n n. i i.i*»t ....... •.. ,,-,.. -..-,-
wind. velocity..
3. Bacteria of the family Enterobacteriaceae^
including species of knoxvn patho^eniciUj are
emitted in large numbers.. They make up
T.yf/o or the total bacterial emissions. Klcb-
siflla species, proved pathogens of the respira-
tory tract, are the most numerous of the
Enterobacteriaccae; they represent jS^c^of aTf
bacici'ia
4. The Enterobacteriaceae that are poten-
tial pathogens of _t
siclki, Aerobccter, Proc<:u_f/J__arejfar_more_nu-
meious than the enteric pathogens Thev
make up nearly 5C^c of the family^ and"
10.5% of all bacteria emitted. In addition,
-------
American Industrial Hygiene Association Journal
Klcbsiclla ar.d Aerobactcr species, particularly
^j: morcVc-sistant to thcTc^'i.'Ct
PIXON, F. R., and L. J. McC*3E: Health .AjpecU of
Waste^nier Trejtmen;. ]. Wolir Pollution Control
t'idtrat'ion 36: S
dessication than_J,he,pt!^qrnl
5. About 40% of the
.
immediate vicinity of the activated sludge
units are associated with an _acTOjol_ size that.
permits lung penetration^ jj^u^o^grj^ss).
This percentage increases to nearly 70Cc at a
down win j} Hj^nnrp ftf_9Q f"''t'
6. There exists a definite possibility of air-
borne infection from activated sludge units.
7. Klebsiclla arc the best indicators of bac-
terial air pollution from sewage sources.
Note:. The preliminary data of this work,
which pertained only to numbers, were pre-
viously published.31
References
1. WELLS, W.^ F.: Airborne Ccnttfion and Air H)iifr.e,
Harvard University Press, Cambridge, Massachusetts.
1955.
2. GRKOSY, P. H.: The Microbiology ol the Atmosphere,
Interscience Publishers, New York, 1961.
3. TYND^LL, JOHN: Fluatir.; Metier ol the Air. 2nd Ed.,
Lonrmans, Green and Co., London, 1S83.
ne the Con-
ALPJIECIIT, C. R : Bacterial Air Pollution Associated
v-itli the Si-Ma;* Tre.itnu-nt Pr'>c-«. Master's Thesis,
University of FluriJ.i (Ai:_^u3t, 195GK
Jf-VSE,v, K. E : Presence arid Destruction of Tubercle
Bacilli in Srwagc. Bull. World Ifenllh Organization
10: 171 (iy^t).
ftnteroviiiis
II.
12. WoownoK, A. H.: Bursting Babbles and Air Pollu-
tion. Seaage hid. Wajtei 27: llfi'J (1955).
13. Hinotss, F. B.: Bacterial Aerosols from Bursting Bub-
bles. Doctoral Dissertation, Georgia Tccli University,
1964.
14. EWI.VJ, W. H., and P. R. Eovruus: The Principal
Divisions and Groups of Enterobacteriaceae and Their
Differentiation. Intern. Bull. Bacterial. Nomenclature
Taxon. 10: 1 (1960).
15. LAinuor, H.: Gelatin-Liqucfving Ktebsiel'.a Strains
(Bafterium orytocum (Fliisge)). Acta Pathol. Microbiol.
Stand. 39: 375 (1956).
16. EDWAH>S, P. R., and W. H. EWI.NO: Identification of
Enterobacteriaceae, Burgess Publishing Company, Min-
neapolis (1957).
17. KAI.KFN, F.: Enterobuctciioceac, Ejnar Munksgaard
Puhh>her, Copenhagen (1954).
18. KM-itMvsv, F.: A Simpl.ficd Bioclitmica' Table of
Enterobacteriaceae. Acta rathul. Microbtcl. Stand. 39:
103 (19561.
19. McKtNM.y, R. E.. and R. G. V/EICHIXIN: Isolation
of Flue-Producing Bacteria from ActisMed Sludge. Appl.
Microbiol. /: 25U (1953).
20. ANDUSE.V, A. A.: New Simpler for the Collection,
Siring and Enumeration of Viable Airborne Particles.
;. Racttriol. 76: 471 (1958).
21. CHaiSTC.NSix, \V. B.: Urea Decomposition as a Means
of DifTerentJatini Proteus and Piracolon Cultures from
Each Other anil from Salmonella and Shigi'.la Types.
/. Bacterial. 52: 461 (1945).
22. Standard Methods for the Examination of Water end
Waste Water, 11th Ed.. American Public Health As-
sociation, New York (1960).
23. Hooor.mupE, J. C.: Studies on Capj.ilr Formation. 1.
The Conditions under Wh.'ch KUbsifllz pr.e.t'tii'niae
Fotifi.- Cipsules. ], Bacterial. 35: 347 (19J9).
24. LF.n-iR. M. H : Opportunistic Gram-ncj:f'\c Rod Pu|.
monary Infections. Dii{iL>es of the Chest -M: IS >1563).
25. OXSKO%, IDV,: Seroloijical Tnvestijatioiu in tlic K!tb>!el'.-
Group. 2. Occurrence of Klibn-Ua in Sputa. Acti
Pathol. Microbiol. ScarJ. 36: 454 .'1955).
Dl'FFY, T. ]., and I. CHOPS \s- Piuiiar) Lung .\b~cvs.
Amer. ]. Sci. 45: 269 (19'i:).
Gn-TNnr-FC, L. F , a.id S. B. K(ff, Klrb'-^'s pi.eu-
moni;i with Pa:'irrothr t.\, Frir-uraomeJ i-:lii.un .Tnd
Pncnmopcritontuin. PIJIT. c of lli? Ch^i: -13: M'i i!96jj.
28. GB! vsr.fK.-., L. F., and M. Fin.: Studies "n the Klib-
liella-Aerjbactcr Group of Bacteria. /. Ir.ffc. Dijeuits
91: 92 (1952).
29. Dus, F. F., and J. V. BHVT: Microbial Fro!osr> of
Actuated SluJ^c. I. Dominant Bacteria. Afjl. Miern-
biol. /?: 412 (1S04).
30. GOODI&W, R. J., and F. A. Ltos\Ka V!.ibi!!t> and
In£cctNity o[ Niicroorcanivin* in Expepniental Ai-bornc
Infection.' Buc'.-rwl. Rei. 25: 182 (19'Jl1..
31. LEDCtrrrn, J. p., and C W. KV.DMJ.: liartcrtij EMIL<-
sious from Activated Sludge Units. Ind. Mrd. S*rg
34(2): 130 (1%5.
Received May 27 19fi6
-------
Colifonn Aerosols Emitted by Sewage Treatment Plants
Abstract Development of the science of aerobiology has furnished a tool for/
the investigation of potential sources of microbial aerosols. An investigation of
aerosols emitted by trickling-filter 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 aQecting 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 (/). 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
cumbers 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 hi the last few years pro-
vided a tool that has encouraged us to
investigate potential sources of aero-
solized microorganisms. Schultze (J),
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), »'n 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 dose the filter bed. The process
of sprinkling the raw sewage into the -
luf 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 108 to
10T 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 mfllion gallons (1 gallon = 3.7 liters)
of sewage per day, were studied.
The plants were located in the Inter-
mountain 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 the rule of 1
cubic foot (28.3 liters) per minute and
impinges the collected organisms on a
nutrient mcdi'jrr. r!r.ccd in pctri plates
posilioncd within stages of the sam-
-------
i
,•
i'1
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-methylene blue me-
dium, for the selective growth of the
coliform organisms. Samples were
taken from points in the immediate
vicinity of the trickling filters and up
io di.stdncrs of 0.8 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
we're 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 hnd 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~wou!d be expected to give the
Table 1. Coliform and total bacterial aerosol panicle count from trickling filters (I foot = 0.3 m, 1 yard — 0.9 m).
Distance
ant from
source
50 feet
50 feet
0.25 mile
110 feet
200 yards
' 130 feet
300 yards
0.5 mfle
130 feet
200 yards
', • 100 yards
600 yards
0.8 mile
100 yards
.100 yards
600 yards
0.8 mile
'140 feet
.100 ynnli
Wind
speed
(mile/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
5-10
3-7
3-7
Test
Relative
humidity
25
25
25
70
70
65
65
65
25
25
25
25
25
15
15
15
15
55
J5
conditions
Temp.
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 ajn.
10:30 p.m.
10:30 p.m.
11:00 a.m.
11:00 ajn.
8:30 pjn.
8:30 p.m.
^8:30 p.m.
8:30 p.m.
8:30 p.m.
8:30 p.m.
8:30 p.m.
8:30 pjn.
9:00 p.m.
9:00 p.m.
9;00 p.m.
9:00, p.m.
10:00 p.m.
• 10:00 p.m.
Coliform
per cubic
Downwind
364
300
5
867
30
490
183 v
i09
105
42
193
26
4
.159
' 70
7
3
934
73
particles
meter
Upwind
control
'
0
0
0
0
0
0
0
1
1
1
1
1
1
1
1
t
Total viable
per cubic
Downwind
3,911
•'
19,737
i
3,692
2,435
3,396
622
2,493
1.400
i .
,
914
817
389
856
) articles
neter
Upwind
control
51
• 574
574
574
1,676
1,676
' 607
607
607
607 .
-------
3 4
140 feet from source
. J 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 coliform 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:
miditics were shown by Brown (5) 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
mile 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-
form 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 aerosol 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; stngc 3, 9 to 25 cells;
st.-tgc 2, 22 to 200 cells; and stage 1,
150 or more cells. In any event, the
p;irticlc 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 slar;c 6. Purticles re-
covered on stages 3 nnd below arc
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 p 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. coli and other coliforms arc
the universal indicator of fecal pollu-
tion, it is apparent that the discovery
of aerosolized coliform organisms aris-
X .••'- •:o:'-::-.j •'• • -.••
ing from scwap.c treatment plants i,
portend a public health concern.
vcstipntions should be conducted io
tempt to identify other bacterial, fun;
and vira! aerosols generated by sew,
treatment facilities.
Note added in proof: Af Icr our rep
was submitted for publication, it v
called to our attention that C. R. t
brecht had performed research of
somewhat similar nature. AJbrccht si
milled a thesis to the University
Florida in 1958 entitled "Bacterial >
Pollution Associated with the Sewn
Treatment Process." We hereby z
knowledge Albrecht's work.
A. PAUL ADA?.
J. CLIFTON SPENDLO\
Deseret Test Center,
Fort Douglas, Utaii 84113
References and Notes
1. J. Snow, On the Mode of Communication <
Cholera (Churchill, cd. 2, London, 1855).
2. D. Crozier and T, E. Woodward, Military Me
127, No. 9, 701 (1962).
3. K. SchulUc, Arehiv. Hyg. Bakteriol 130, 24
(1943).
4. J. C. Spcndlove, Public Health Rep. 72, No. :
176 (1957).
5. L. A. Allen, E. Brooks, I. L, WUUanu, /. Hyi
41, 303 (1949).
6, Andersen Sampler distributed by CMC Indu;
tries. Salt Lake City. Utah 84107.
7. A. A. Andersen, ), BafierioL 76, No, 5, 47
(1958).
8. A. D. Brown, Aust. J. Blot. Set. 7, 444 (19541
9. Supported by DA Project 1T061101A91, In
house Laboratory Independent Research.
27 Julr 1970 . ., .8
-------
TECHNICAL AMD LEGAL ASPECTS OF
WATER RESOURCES MANAGEMENT
VERN7ON, B.C.
April 1-3, 1970
'^ 1 , Organized and sponsored by
''] Extension Department
•-!.j The University of British Columbia
-J Vancouver 8, B.C.
-------
THE MICROBIOLOGY OF DOMESTIC AND 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
is a living, competing, reproducing entity which responds to favourable
treatment. Its appetite is enormous, capable of utilizing 1000 to
10,000 times its own weight of sugar per hour. Possibly one of the
.--asons for this capability is the large surface/volume ratio. A
bacterium with a cell diameter of O.OOQ5 mm will have a surface/volume
ratio of 120,000.
The micro-organism may be considered to be a very efficient
nanufacturing or degrading plant where ra\/ material may be converted
Into desirable products. If an effluent, as an example, contains a
ligh proportion of hydrocarbons such as benzene, phenol, oil, or linear
ilkylated sulfonate detergent, a microbiological flora will develop in
:he sewage which v/ill utilize these substrates. It is not surprizing
:hat petroleum consuming organisms are found in nature for small
l.uantities of hydrocarbon occur naturally in many tissues and environ-
.• tfa CD. We have often seen oily films on stagnant marsh pools and
lave heard of the occurrence of n-heptane in the distillate of the
>ine 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 important points to remember about the organisms
'hen 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 forr.is a flocculcnt. In addition to being a
flocculating agent lignosulphonates are used in an ever increasing
.^
amount in a number of industrial applications. They are used as
adhesive, dispersing, binding and stabilizing agents in the construction,
sin ing,' chemical and agricultural industries- In fact, our own
laboratory has used successfully the lignosulfonates to stimulate the
ndcrobial 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. VTisther 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 50'!; is readily fermentable.
This supply of fermentable carbohydrate rather than being deposited
i 2. sewage system forms a major source of sugar for the production of
alcohol and a potential source for mushroom culture, vitamin B,?, and
rnany 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 ICO gallons of effluent
will disappear in approximately 30 minutes (3). Of course, many
nutrient factors will either interfere with or accelerate bacterial
activity. The inorganic 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.
t
\
Optimum conditions for rapid substrate utilisation and
^iolo^icdl flocculation are incompatible. Bacteria and most biological
•materials contain a net negative charge and can combine with oppositely
c rged materials to form very large particles which separate as a
sludge from solution. Polyelectrolytes such as polyacrylamide and
-------
fire ashes containing polyalent metals are commonly added to sewagi t-
increase the flocculation rate and to dehydrate the sludge. Excess
carbohydrate, desirable for rapid fermentation, interferes with
flocculation.
There are, as in all communities, microbial villains which
are capable of thriving on substrates valued for one reason or another.
Mot too many years ago natural control over plant and animal disease
was'supplied by physical isolation and the development of resistance.
Today, as our hunan 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 can
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 60C: of
the available bacteria can be isolated and characterized from activated
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 r-ciLe ut which the sewage
flora will utilize the incoming effluents, the ease of sludge
fiocculation and separation and the potential health hazard of sewage.
It is the-last point upon which I wish to enlarge. Forty
Percent of the faecal matter from hunans and domestic animals is
j composed of bacteria, mainly represented by the organism Escherlchia
£Q 1 i. This organise Is a member of a group 'of organisms labelled
| tn? Lnterobact'=r iace 2.2 because their n.enbers are common inhabitant.-:-
| of i-he intestinal Tract.
i
Other members of this group include rhe pathogens ^a.l.-ncr.e 1 la,
j an intestinal pathogen causing enteric fev^r" and food poiso:;ir.j ;
-------
Klebsiolla, a cause of pneumonia and other i-nflair.nettions of the
respiratory tract, Shi gel la, a cause- of dysentery.; and the soil
organises belonging to the' genera Proteus and Aerpbacter.
\
The majority of the strains of the bacterium Escherichia
coli utilize the nutrients" of the feces and are not pathogenic to
There are exceptions, however, certain strains of E. coli can cause
infantile diarrhoea resulting in- serious epidemics in nurseries and
hospitals. . •
The identification of I', coli in a food ot in -i water sample
is indicative of rascal or scv;eee contamination. It is also an
indicator of the risk 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
utilization in domestic animals is widespread. A serious consideration
in the use of antibiotics is the appearance of antibiotic-resistant
strains especially anong the E. coli. The seriousness of the situation
is not in that an antibiotic-resistant strain of E_. coli is forjr.ed
but that this strain can transfer its resistance to other genera of
the Enterobacteriaceae, in particular the .Salmonella. Klebsiella and
Shigella (11).
i
I Sewage sludge is disposed of in three different ways -
j fcy spreading on land as a fertilizer, as a land fill and by discharging
i into waterways. All three methods of disposal create a health hazard.
; Just how serious is this situation? It is known that
| Salmonella when present in faecal material deposited on a stone wall
j "r in soil will ra-.nzain vidtiUTy for at least 30" days (12). If the
i
; "r-diun supports growth the organrsm will grow and ir.ultiply at terrperature
7°C-46°C. The organism is killed by exposure to 50°C for ana
The factors which determine the length of tiir.e a pathogen will
c'J^vive in soil or on the surface of a plant are unknov:n but include
*•'•£ coiupetition with other bacteria. Vegetable crops such as the tomato
-------
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
cow? produce approximately 20,000 gallons of this slurry per week.
Salmonella dublin , Salmonella typhimurium , E. coli , Staphlococcus aureus
and- Bruce 11 a abortus survived for at least eleven weeks in the slurry.
!v;o additional pathogens found in faeces , Mycobacterium tuberculosis
and Mycobacterium j ohne i , survive in the slurry and the pasture for
r:any months (14). Mono of the above bacteria however, were found to
r.ultiply in the slurry. The spore f oi'-mers -, 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 permanently contaminated. Two other diseases dangerous to
..ian may be found in cattle slurry ; Q fever and leptospirosis . Q fever
'"hich causes a fever often accompanied by pneumonitis in man- can be
.spread 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 wcrr.s
"•=y also be spread to man and animals through sewage. The ova of
lumbricpides is commonly found in sewage.
The virus of the highly infectious foot and mouth animal
Disease is excreted in the faeces of tha animal before the animal is
I
c"i-nically ill. This virus should 'survive for a short period at
-cast in cattle slurry.
Reerr.tiy vherrj har been =. growing interest in th? . determination
-- vivus \;cir-~iclc-;ij ir; 3 =;.v\iy;e • These test.s c.c<± ti^e consuming and
^-rious bu^ ccrzainly necessary to determine the potential health
-------
hazard of sewage treatment systems. The measurement of the coliforn
anisms in chlorinated sewage may not give an indication of the
inactivation of 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
articles per milliliter
To assay the virus content of sewage the virus can be
isolated and concentrated by a number of techniques (17, 10, 19).
Following isolation the virus concentrate is inoculated onto animal
xidney cultures and incubated for 10 days. The number of plaques which
appear are a count of the infectious virus particles.
X
The health hazard of wind-borne bacteria from activated sludge
-.'.nits is also of interest. The bacterial population of air is increased
£y passage over an activated sludge v/asta treatment unit. For example,
the bacterial count has been found in one particular sludge unit to 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 Enteroba.cteriaceae
represented 19 % of the total bacteria in the aerosol of which Klebsie_ll-;t
a known respiratory tract pathogen represented 6':. In fact, the Klebgi-^?.
is the beat indicator of bacterial air pollution from sewage sources.
Randall states 'That a man working 5 feet off the downward! edge of an
^ration tank when the wind velocity is 10 mph, perhaps taking a sludge
sample, could be expected to inhale a viable Xlebsiella every two breaths.
"'« bacterial death rate in the aerosol will depend on the resistance
-f the organism to desiccation ranging frcm a maximum dea jh rate at C.7
-•- 1.0 seccnds afr-u' emission to a long undetermined survival time.
Since many sewage or waste treatment designers have net been
*3o concerned with the health hazards of sewage the reports dealing
t
•i-th control measures are net too numerous. In the activated-sludge
:r~t we knov; that the ciliated protozoa are principally responsible
•°r destroying !_. coli and possibly crcher bacteria (21), as well as
•^"•proving the clarity of the effluent (?1). If the sludge is composted
sr aeration ^nc tr.e temperature of the compost ranges between 50°-
'- C, the poliovirus is inactivated within the first hour, Salmonella
>va of As car is and Candada albicans are inactiva-ed within U3 hours (3).
-------
If sludge is maintained at pH 11.5 fcr I hour the Entero-
tacteriaceae is reduced by more than 2C-t. On the other hand the
jn positive bacteria are not destroyed at this high pH (22),
Chlorine will reduce the soliforr1 COUP*, tc le-;^ fV-.r: 100 par I1"13 .nl in
i hours contact ri-re with ? rrig ch].7r:-no p^r liter '15). However the
coliforrr: court may r.ot givo ar> accurate yict'--e o.: tht death of th^
other pathogens.
In conclusion, I would, like to stress that micro-organisms
are very aggressive and hardworking individuals. Under proper
direction and control great benefits pay tx; derived from these silent
workers.
References
1. Jones, J.G. and A. V-'illiams, Hydrocarbon Biogenesis, p. 11, cited
in Microbiology, The Institute of Petroleum, London, Ed. P. Plepple,
1967.
2. Johnson, M.J., Utilization of Hydrocarbon by Micro-organisms,
Chem. and Ind., p. 1532, 19S»t.
3. HcAuliffe, C. Solubility in Water of Normal Co and CJ_Q Alkane'Hydro-
carbons , Science 163, 478, 1969.
4« Halvorsor., H. , and M. Ishaque, ricrobiology 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 and
their Industrial Utilization, Biotech. Eioeng., 9_, 3, 1967.
? Halvorson, H., K. Ishaque and H. Lees, Microbiology of Domestic
Wastes, II. A Comparative Study of the Seasonal Physiological
Activity of Bacteria Indigenous to a Sewage Lagoon, Can. Jour.
Microbiol., 15_, 563, ISG?.
Liu, D.L. and P.M. Tounsley, Pulp Hill Lignosulfonates in Petroleum,
Jour. Water Pollution Control Federation IS70.
. '• Jeris, J.S. and P.P. Cardenas, Glucose Disappearance in Biological
i Trearment Systems, App. Microbiol. lj+, 857, 196S.
1 •• Wiley.^B.B., and S.C. Westerberg, Survival of Human Pathogens in
; Composted Sewage, App. Microbiol., 13 , 991!, 1959.
I rrakasam, T.3.S., and N.C. Dp'ndero, Aerobic Heterotrophic Bacterial
Populations of Sewage and Activated Sludge, II. Method of Character-
ization of Activated Sludgfe 'Bacteria, Applied Microbiol. 15 , 1122, 19
'
-------
Sturtevant, A.B., and T.V7. >~eary, Incidence c^ /^I^ctious Drug
Resistance among Lactose-f ermen trinr Bacteria - .o^-^^ed from Raw
and Treated Sewage, App. Micrcbiol. 18. 91?. ]33D.
Heard, T.W., Housing and Salmonella Infections, The Vet. Rec. '85,
482, 1969.
Prost, E. and H. Rieniann, Food Borne Salmons!Issis cited in Ann.
Review Microbiol. £!_, 504, 1967.
Rankin, J.D., and f\.J. Taylor, A Study of sr^e Disease Hazards
which could be associated with the syst^/fiCof applying Cattle
Slurry to Pasture, The Vet. Rec. 35, 578, iS63"/
Shuval, H.I., Inactivation of Ent-roviru-'.es in Sewage by
Chlorination 3 Adv. V.'ater Pollut. Res. Proc, Int. Conf. 3rd, 2_,
37, 1966.
Duff, Ki.F. Isolation of Ether-resistant Lnteroviruses from Sewage,
Methodology, App. Microbiol., 1_9, 120, 1070.
Wallis, C,, Concentration of Viruses from sewage and Excreta on
Insoluble Polyelectrolytesv App. Microbiol. , 10, 1007, 1969.
Lund, E.., and C.E. Bledstrorr:, A Study on Sampling and Isolation
Methods for the Detection of Virus in S-ewage, Water Res., 3_, .
823, 1969.
Shuval, H.I., B. Fattal, S. Cymbalista and N. Goldblu-n, The
Phase-separation Tiethod for the Concentration and Detection of
Viruses in Water, V.'ater Res., 3_, 225, 1969.
Randall 3 C.W., and J.0< Ledbetter, Bacterial Air Pollution fro;-;
Activated Sludge Units, Am. Ind. Hyg. Ass. 27, SOS, 1966.
Coler, R.A., and H.B. Gunner, Microbial Populations as Deterrr.inants
in Protozoa Succession, Water Res., c[, lu3, 1969.
Curds, C.R. and G.J. Fey, The Effect of Ciliated Protozoa on the
Fate of E. coli., in Activated Sludge Process, Water Res., 3_,
853, 1969.
Grabow, V.0.K. , M.A. Grabow , and J.S. Burger , The Bactericidal
Effect of Lime Flccculatior./Tlotaticn as •= Primary Unit Process
in a Multiple System for the Advanced Purification of Sewage
Works Effluent, V-ater I\es. , 3, 943, 1969.
-------
VIRUSES IN WASTE, RENOVATED, AND OTHER WATERS
By
Gerald Berg
Environmental Protection Agency
Water Quality Office
Cincinnati, Ohio 45226
February, 1971
-------
VIRUSES IK WASTE, RENOVATED, A1ID OTliSR WATERT
•Gerald Berg
>5any viruses are excreted irith the feces of infected individuals.
These viruses multiply in the alimentary canal of man, or have access to
it. With viruses 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 stem 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 nan (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.
Polioviruses. The polioviruses consist of three serologically
distinct types each of which can produce paralytic disease in man.
#
TTo 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
-------
These viruses may also produce aseptic meningitis, and various minor
disorders as well.
j$.
Coxsackievirus A. The coxsackieviruses of group A comprise alnost
30 serotypes all of which produce characteristic lesions in newborn nice.
Some of these viruses produce herpangina, aseptic meningitis, and rubella-
like rashes in man.
Coxsackievirus B. The coxsackieviruses 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.
•&•&
Echoviruses. The echovirus group now 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 picornaviruses4". 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 res-oonsible
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.
He-
Echo is an acronym ibr enteric, cytopathic, hunan, orphan.
Picorna is an acronym for pico-small, rna-ribonucleic acid.
-------
such as military training camps, and institution::. Some cere-types
produce acute epidemic heratoconjunctivitis, a serious eye disease, and
scne con produce cancer in certain laboratory ani.~:.ls.
#
Re ovi ruses. The rcoviruses , comprising Vr.ree serotypes, have
been associated with respiratory and enteric diseases. One type has beer.
reported to produce cancer in "baby nice when the virus was inoculated in
very sr-all concentration::.
Infectious hepatitis virus. The virus of infectious hepatitis has
yet to be grown in laboratory cultures, and remains something of an
enigma to this day.
Most of these viruses produce asymptomatic infections most cf the
time. Only occasionally do they produce disease. Infection is sc cordon,
hov.'3ver; that the ai^ount of disease produced is significant.
. The Hazard of Viruses in Water
Snail amounts of viruses entering rivers and streams with vsste-
vatsr ai-e a hazard to those downstream who use these waters. Even a few
virus particles in 100 gallons of river water would constitute a hazard,
for the amount of virus in the total volume of -.rater entering the intakes
of even a small city on any day would be considerable.
Because small amounts of ingested viruses are likely to produce
infection but not disease, it is likely that snail amounts of virvxes
could be present in water and go undetected. Individuals infected with
o~all amounts of viruses nay show no signs, but they nay excrete large
i
«
amounts of viruses. Thus, they nay infect their contacts with lar^e
* -
Eco is an acronym for respiratory, enteric orphan.
-------
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 will 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
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, ve nust 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 from Waters of All Qualities
The recovery of 1 PFU of virus from one-hundred gallons of water
or more vlll require better concentration procedures than those available
today. We must develop the capability for complete recovery of viruses
from waters of qualities ranging from raw sewage to completely renovated.
Aluminum hydroxide adsorption a.nd protanine sulfate precipitation.
Because relatively large amounts of viruses are usxially present in sewage
and in effluents, only small volumes usually need to be tested. In these
situations, technics are already available, but they cannot be readily
adapted to large volumes. The Al(OH)? adsorption procedure (^,5) in
•^ i
«
which the virus is adsorbed on an Al(0!l)o gel, may recover
most enteroviruses in sewage effluents (^-6), but the method
je.
In controlled studies where controls consume sterile water
-------
. .-• >r, .noat of the large adcnoviruses and rroviruscs behind. Reoviruses
3,.:^ adenoviruses nay be recovered from effluents by precipitation with
protomine sulfute but this technic leaves r.io:;t of the umall picomaviruscs
behind (T). The two methods nay be used tocether to recover r.ost of the
viruses in all of these groups.
Riase separation. The phase separation technic (8-10), has an
overnight time requirement for completion. In phar.e separation sodium
dextran sulfate and polyethylene glycol are nixed with a sample and allovc'l
to separate. The viruses are then recovered frcn the lover bottom phase
-(de:;tran) and inLerpha.sc by precipitation with KC1. The method raay not
be efficient with all viruses (ll), but recent studies have been more
encouraging (12).
. The Al(OH)-3-protc^ainc sulfate and the phase separation methods
accommodate only limited volumes, and neither method is completely
efficient. From test to test, both nay 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. VJhen large
volumes must be tested,mother methods must be sought.
For large volumes of irater, the best approach would seem to be
a filtration system.
The membrane filter technic. The membrane filter technic (13)
consists of filtering water through 0.^5 ji cellulose nitrate membrane
filters. Viruses may adsorb to these filters and then be eluted from
(
them. Adsorption of viruses requires the presence of salt (l'V,15), and
is greatest at pH 7 (l^)- Complete recovery of enteroviruses, and 8o>o
-------
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 fron 25 gallon quantities but with larger volumes, recoveries
are now only 50 to 75^ efficient.
Certain substances, probably organics, apparently coat the adsorptive
si'oujj Oil the uciubruncs, and KaJce tucu unavailable to uic virus (l.j,l;j).
Thus, the membrane filter technic nay be .useful for quantitative virus
recovery from tap, renovated, and other clean watere, but even relatively
clean waters may need to be pretreated to remove 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
bi tested with the luo^branc 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 P2 60 nay adsorb to the poly-
electrolyte and may be eluted with lO1^ fetal calf serum in borate saline
at pH 9.0 (IT). With this technic and other adjuncts developed during
the field experience, viruses have been recovered from 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. Ihesc concentrations are equivalent, to
360,000 and 60,000 PFJ per million gallons of water consur.ed.
-------
In order to sample ouch large volumes of ";•''. r "•-••:".*;-• _J of c
had to be trucked to Cincinnati at each sampling. Ihis "3 a cumbersome
expensive operation. Thus, as our field experien-- _-'-.v. ^c^si, we tested
procedures for filtering large volumeG of water in -IV.- f j-;ld and recovering
viruses after transporting filters and adjunct sarnie-; tr the laboratory.
Comparative studies presented in Table 3 show that •••-.cov-ricc of viruses
v;erc as great from field-filtered samples as fror. ninnies truc];ed to
the laboratory.
The polyelectrolyte technic is reasonably efficient with poliovirus'1,
but not vith any of the other viruses that have been tested. Poliovirus 1
recoveries often exceed 50>>, but echo virus 7 recoveries are sometimes
below 30/j, and reovirus 1 recoveries are sometimes below 20$ (Table 3 [14]).
Des'pite its low and erratic efficiency, however, the technic seens to be
the most sensitive now available for studies of large volumes of water*
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 maximum virus recovery efficiency, these substances clearly
warrant the renewed interest they now enjoy.
Osmotic ultrafiltration 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 will eventually
attain a universal recovery system efficient with waters of all, qualities,
•*
or whether we will need to tailor the recovery system to the water under
study.
-------
Removal of Viruses from Wasto and Other Waters by Treatment Processes
Viruses can be removed from waters by biological, chemical and
physical treatment procedures. Most procedures that remove chemical
pollutants also remove viruses, but not always as well. Primary settling
removes Uo to 70$ of the viruses in 2k hours, and almost none in three
hoxirs (Table k Il8]). In laboratory studies, activated sludge may remove
more than 99$ of viruses present (18), but less effective removal has
been shown in the field (14). Coagulation with A^CSO^)^ may remove 93-
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 [\$ ,22}}.
Coagulation with lime may produce rapidly virucidal pH levels in
soft waters (Figure 1 [l6]).
It is not completely clear to what degree viruses are adsorbed to
carbon and sand, and to what degree .they are adsorbed to the nicrocosnic
deposits on carbon and sand surfaces (l4,20).
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 any -'• - - -i-— --L -.'A-.;^.ii procedures remove Bone viruses and thus
constitute ad.ji^v--••-.•-- i-xr r.-?.L. Furthermore, treatment procedures renove fr.;~
water many subsT'r;-.-.;; -..".,rG ln';2rfere with disinfection and thereby facilitate
eventual total r,ir.o-::i or Jc;t^uction of viruses by tcrninal disinfection.
Disinfection
Terminal disinfection is requisite to the production of safe water.
Under the limitations imposed by cost and the uses to which the waters are to
be put, it is unlikely at this tine that any one chemical or physical agent
can disinfect waters of all realities. 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, alxiost completely accepted as the universal
«
water disinfectant for many decades, suffers many shortcomings. However,
when hypochlorous acid (HOC1) 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 was 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 ng HOCl/liter. The virus could not be
detected 1 minute later. At least 99*99$ of the virus had been destroyed.
This water was dechlorinated, and later consumed by personnel with no ill effect.
Ozone. In those situations where the causticity or toxicity of hypo-
4
chlorous acid is troublesome, ozone (0_) may be preferable. Ozone leaves no
residual, decomposing rapidly into oxygen. Figure 3 shows that ozone also
is a rapid virucide (2k], Maintaining a drinking water supply with no
-------
residual disj-niectant, j.s-i.Tl-nd-irlsedi, and when" ozone is used for drinking
water, addition of a second disinfectant would be veil directed.
Most effluents contain ammonia, sometJones in excess of 20 ra.g/1.
Chlorinating such effluents generally produces only chloramines because
eight milligrams of chlorine react with every milligram of c-rmonia
nitrogen before the brealrpoint is reached. Chlorumincs are slow dis--
infectants (Figure k [25-2?]) and toxic to fish. Ozone does not react
with ammonia, but.it docs react with other interfering substances.
Iodine. In water solution, elemental iodine (12) does not usually
react with ammonia. I2 is a slower virucide than hypochlorous acid is,
but it is a faster virucide than chloramines (IIHC1-,, IIHpCl) are (Figure h
-[28,29]). Moreover, significant amounts of hypoiodous acid (JIOl) occur
in water at pH levels between 7-5 a-nd 8.5. HOI is a much more rapid
virucide than 1% is (29). lodate (10, ), 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 (!,")
are not virucidal either. Triiodide ion results from the reaction of
elemental iodine and iodide ion.
Iodine also may be used to disinfect sewage treated by chemical-
physical methods. Ferric sulfate-clarified, carbon-adsorbed sewage nay
retain little turbidity and total organic carbon, but its ammonia 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 ammonia, and
could be disinfected with iodine. Extensive studies have indicated that
f
iodine is not toxic to man in the concentrations necessary to disinfect
water (30).
Sewage treated with line has a high pH. Since high pH makes
ammonia-stripping possible, such waters may be disinfected with 1IOC1.
-------
To achieve disinfection, however, the pll of the flocced water must be
reduced because IIOC1 ionizes to hypochlorite ion (OC1~), nostJy as the
P'H 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. radiation. In some applications, physical methods nay 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).
Gamma irradiation. Garcia irradiation.is deeply penetrating,
leaves no residual, and is a potent virucide. At the moment, howevsr,
it is not a practical nethod for water or sewage disinfection.
SUMMARY
A human can be infected by a single viable virus excreted by
another human. 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 small anounts 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
f
The major problems of what waterborne viruses are important to us, hov
they can be quantitatively detected and identified in waters of a-lT
qualities, how effectively treatment processes remove them, and how
-------
they can be destroyed in waters of B.1,1. qualities are still unanswered.
The resolution of all of these probleris will mark the direction of
research in this area for the next decade.
-------
r-c '.ercnces
1. PlotKin, S. i.- .:-i :it:: M (1967). In Transmission of Viruses by
the Water ~v:".:.-, -:2.!.;: ,y 0. Be re, John ./iley and Sons, Ii'ev York,
Nev/ York, •
2. Katz, M. u^c. -•',-...;. . (1967). J. An. Pub. Health Ac roc.
57:1837.
3- Berg, G. (1566) '• '.- -1"'''_^.V Scj-> 3:86.
4. Wallis, C. and l-^intci-. J". ~,, (1967). In Transmission oC Viruses
by the Water ;.~^-, ._ ,.... ^y C. Berg, John ;7ile3r and Sens, Kev
York, l.'ew York, p. 12Q.
5. V.'allis, C. and HeJL:icK, .' . :,, (1967). Ar.or. J. Eplderrdol., 85:^59.
6. Moore, M. L., L'jdc-.-'.o: , ?. ?. and Jeter, *,7. S. (1970). J. V.7ater Poll.
Control Fodsr. , -r - ^ ^_,
7. England, B. ~-- otasina Jvj_;',.-'-e Precipitation of Pbovirus and Adeno'/irus
for their ^ss^y in 3c.--,:.ac3 and Ef fluents . Presented at the 70th /jinur.l
Meeting of the /^.arlc^r. Society for !-'icrobiolo^r, 26 April - 1 I'.^j 2.^70.
8. Lund, E. and Hedstrora- C . -j\ '.19o7). In Transmission of Vir-^ses by
the Water Route, edited ";y G. Bsrg, John ./ilcy and Sons, l.'ew Ycrl;,
Ksw York, p. 371.
9. Shuval, H. I., Cymbolista, £.- , , Fatal, B. and Goldblun, II. (1967).
In Transmission of Viruses by the '.,Tater RoutJ, edited by G. Ber£,
John Wiley and Sons, Hew York, Hew York, p. ^5 .
10. Shuval, H. I. ' Personal coranunication.
11. Grindrod, J. and Oliver, D. 0. (1969). Archiv. gesarite Virusforsch. ,
28:337-
12. Grindrod, J. and Oliver, D. 0, Archiv. gesante Virusforsch. In press.
13. Oliver, D. 0. (1967). In Transmission of Viruses by thc_ '-.'ater Routo,
edited by G. Ber^, John Wiley and Sons, Uev York, liev; York, p. 139.
lU. Berg, G. and Cohlinc, D. R. Unpublished data.
15. Wallis, C. and Kelnick, J. L. <196?). B^ll. W.n.O., 36:219.
16. Berc, G., Dean, R. 3. and Dahlins, D. R. (1968). J. /\n. '..'ater .vork.s
Assoc., 60:193-
17. Wallis, C., Grinstcin, S., Melnick, J. L. and Fields, J. 2. (1969).
Applied Micrcbiol., 13:1007.
-------
18. Clarke, N. A., Stevenson, R. E., Chans, S. L. and Kabler, P. W.
(1961). Am J. Pub. Health, 51:1118.
19. Chaudhuri, M. and Englebrecht, R. 3. Removal of Viruses from '.fetter
by Chemical Coagulation and Flocculation. Presented at the /Annual
Conference, Washincton, D. C., June 23, 1970.
20. Cookson, J. T., Jr. (l9°9)« J. Am.Water Works Assoc., 6l:52.
21. Chang, S. L. et al. (1938). An J. Pub. Health, U8:159.
22. Thorup, R. T., Hixon, F. P., Wentvorth, D. F. and Sproul, 0. J.
(1970). J. Am. Water Works Assoc.,' 62:97.
23. Wcidcnkopf, S. J. (1958). Virology, 5=5^.
2U. Coin, L.; Ilannoun, C. and Gomella, C. (196^). La Presse Medicale
72:2153-
25. Shuval, H. I. e_t al. (1966). Third International Conference on
Water Pollution Rasearch (Proceedings), Section II, p. 1.
26. Lothrop, T. L. and Sproul, 0. J. (1969). J. Water Poll. Control
Feder., ^1:567.
27. Barg, G. and Berman, D. Unpublished data.
28. Berg, G., Chang, S. L. and Harris, E. K. (1964). Virology, 22:W>9.
*
29. Berg, G. and Chang, S. L. Unpublished data.
30. Freund, G. e_t al. (1966). J. Clin. Endocrinol. and Metabolism, 26:6
31. Huff, C. B., Smith, H. F., Boring, W. D. and Clarke, N. A. (1965).
Pub. Health Rap., 80:695.
32. Hill, W. F., Jr., Ilasiblet, F. E. and Bent en, '.-.'. H. (1969). Appl.
Microbiol., 17:1. . "
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-------
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Figure 3« Inactivation of poliovirus 1 by 03 added intermittently to
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at sampling points.
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Figiuc k. Inactivation of poliovirus 1 by a mixture of nonochloraaine
and dichloraziine, and by a nixture of 1% and HOI (2T)« All
concentrations are expressed in terns of titrable halogen
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-------
.01
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M I N 11 T P f?
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The Possibility oi lUin.an Hv:al(h Hn/.ards Associated
with Expansion of the Clr.vcy IlO'.td Sev/a{;e Treatment
Facility; A IilicrobJ.o3 o;; i c a_l_ V i ev/ppi n L .
Martin H. Rogoff, Ph.D.
January 13, 1971
INDEX
I. Statement of position
II. The nature of sewage treatment as related to
biological quality of the treatment stream
III. The nature of the potential health hazard
A. Presence and persistence of infectious
agents
B. Relation of diseases to waste disposal
1. Related diseases
2. Biological vectors
3. Physical vectors
C. Secondary factors 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 mutagen
4. Transferrable drug resistance in
enteric bacteria
I
IV. The quantitative effect, a summary statement
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3. STATEMENT Or1 POSITION
From a microbiological viewpoint nci ('lieu- the rotative
off ic:i cncj' of a sewage treatment plant in lowering Biochemical
Oxygon Demand (BOD) o£ influent \vaslc, nor the precise method-
ology of treatment is at issue. Microbiologicnlly, municipal
waste, by its very natiu-e, contains a high population of
potentially pathogenic microorganisms. 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 of sev/age treatment
facilities would, of course, receive maximum exposure.
The microbiological position that must be taken is
based on t\vo considerations; these are: 1) no definitive
evidence has been forwarded to demonstrate the absolute safety
of operation of a sev/age treatment plant in 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 attendent 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 NSSD. Sufficient evidence
for hazard exists to warrant the burden of proof of safety
to be placed on the currently demonstrated and potentially
massive polluter, NSSD. 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 SEWAGE TREATMENT AS BELATED TO BIOLOGICAL
QUALITY OF THE TREATMENT STREAM
In order to support a position which will not accept
operational data from sev/age treatment plants as dogma, some
understanding of the nature of the treatment process is required
First of all, sev/age treatment is a dynamic process. Influent
wasto 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 must be so or the efficiency
of treatment would be too low to bo of value. In short, a
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sc%vage treatment system iy a true "Jn stream" process,
dynamic as opposed to static in nalurc, responsive to changes
in the. nature of the inilucnt, 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, Biochemical Oxygen Demand (BOD). The latter,
BOD, is considered to be a parameter used to measure the amount
of oxidizable substrate available to the oxidizing microflora
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 "non-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 v/hat 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 "metaboljc competition".
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7. Increases in DOD Jujf.lU indicate o;c>c;-i;:iscs Jn primary,
secondary ,-lc-rUary saprophyte acLivaly, increased
predator activity, dr-cro;j.so in f1occulalion by the
sHidf'r.- ori'.ani.-'.iufj or a papula tier shift io organisms
having; poor settling characteristics. The njjmb^r ob-
tained an effluonl: £OD cannot toil us which. In short,
COD has ao predictive or insight value into the biolog-
ical aspects of the sewage treatment process.
Thus, the BOD criterion cannot be used as descriptive of the
biological quality of an influent, in-process, or effluent
stream particularly when epidemiclogical considerations are in
question.
III. THE NATURE OF THE POTENTIAL HEALTH HAZARD
A« Presence and.persistence of infectious agents
Infectious agents including bacteria, fungi, viruses,
protozoa and certain higher forms, e.g. eggs of Ascaris may
bo universally found in municipal v/astes. Certain"industrial
wastes such as fermentation liquors, food processing wastes,
oily wastes may also present a high jnicrobial burden to an
influent. Microbial agents of disease can and do persist
through biological waste treatment processes. In fact, there
are reported cases of viruses absent from influent municipal
waste streams which have been detected in the effluents
following treatment. Two general reviews on the subject are
suggested here. *• _>2/
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 coliform 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 coliform 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 coliform counts, and may
not even be revealed by some common techniques for culture
J/Kollins (19G6) Advances in Applied Microbiology _8,145.
(3960) Ibid., 77.
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of anaerobes clue lo LhoJi1 cxlre;..: 1 _\ [as I id \ ous nature .in 10--
gartl Lo free oxygvn. Thus, the ' a.jor m i crob i a 1 eleven is ol
fecal in j erof lorn are not being cons i tiered in dotormi nat i ons
of the microbiological quality of sewage inJluents and
effluents, or for that matter in es t i;ua Lion of \vatcr supply
potabili ty .
It should further be noted that microbial load in a
treatment plant influent, including pathogenic forms, in
not a constant. It will vary with climatic conditions,
seasonal variations, general health of the community, effects
-of admixture \vjth industrial waste and holding time in trans-
port. In other words, the dynamic quality of the influent
referred to in section II holds ior the pathogenic load.
Even without precise data; the seasonal appearance of water-
borne 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 quantiIatjve 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 actual pathogen
load then would be a function of original numbers, plant
efficiency and amount of waste treated. This is a most im-
portant point in the context of this particular problem.
B• Relation of disoases to waste dispo_sa_l
1. Related diseases : the relationships between 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 fevers, as,iambic ayson Levy and other pro toxcn n
infections, coccidiosis, .infectious hepatitis, poliomyelitis
and helminthic infestation.1-,. Rc-ierences arc also U'iven to
diseases deriving from animal feral wastes, e.g. anthrax and
miscellaneous fungal diseases. Enteric viruses should cer-
tainly be added to this list.
2. Biological vectors: the role of ^vectors in transmission
of waste-associated pathogen to human hosts is also documented
with particular emphasis on flies, mosquitoes and rodents as
vectors.
Haaks (1967) Solid Waste/Disease Ru I a t ionshps USDIIEV/,
Cincinnati
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3. P]iy_sj:£ill x'^ocl^oi>j: Ifaak also providers additional reference
to physical vectors, e.g. airborne solids, dirccL contact and
contamination of food and water supplies. The associations
treated in this literature survey leave little doubt as to
the existence of epideiniological 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. Detrick, Frederick, Md. This literature, much of which
is restricted, js 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 study. Documentation can /
most simply be initiated by backtracking from Ehrlich, ot al.^~
This reference is quoted not for the survival data of the
F1avobacter iurn, a coumon 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'yand is available
from the Y/ashington 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 respiratory 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 1954.
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 does
seepage of sewage through soil to ground water, 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'.
4- Ehrlich.. Miller and Walker (1970) Applied Microbiol., 20,884 .
•S- See Ref's page 131 N7o's 90-112 in Bibliography of Appendix A,
p 102 in Inf cc tioiis DJ^C^PC in Manned Spp.co FH.g_ht_, National
Academy of Sciences, V.'ashingt on, D. C., 1970.
^ Watki.ns, et al, Abstiv ts AMA National Meeting, June 22,1964.
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i\ii activated .sludgi.,- process is an nerobje process ami
requires the eniraininont. of air into 1 ho sev/rxge being treated.
Recycling, pur-iping, v/ater turbulence arc.- necessary components
of an activated sludge process. Such processing tlien 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 in air surrounding sewage treatment plants.
Such monitoring is not routine.
As f.or entry of pathogens into ground waters, this is en-
tirely possible in any situation where retention basins or
effluent lagoons are not structural elements but are excavated
from bare earth. Loss of v/ater from the 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 v/ater table is quite close to the surface,
chances for contamination of ground water from bare earth
lagooning should be extremely high.
C• Secondaj^y factors bearing an epidemiology of waste-
assoc i a t ed d i s e as e
•"• • The immune response to virus infection: it was suggested
by DrT 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 night be beneficial.
They would develop immunity to- a variety 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 iminunologic mechanisms. It is chancy enough,
viz. influenza or rabies vaccines, to attempt immunization
under controlled dosages. The idea of rw.uuoiu 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. I suggest reading of
Notkins, el al5- , who indicate the dif fercnl ial immune response
effects of viral infections.. 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, lyir.phocyte
-Notkins, Mergcnhagcn and Howard (1970) Ann. Rev. Microb.24,525
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transf orjuu 1 ion aiK: pJ'r. i;oc'ylo^;is . ?>k>.c; I, ii»pori ant ;irc studios
v/hich have demons t ra tc*.! thai cellular and humoral iiMuuni I y
can be independently affected. Thus a virus (LDV) vhieh
depressed cellular iipvivmi ty augmented humoral i;n;,:u;i.i ty .
Another (VIIK) did not affect ccllulat1 immunity but augmented
humoral. Another, Gross leukemia virus, depressed both,
This has important implications pertinent to continuous (or
discontinuous) exposure to lov: levels ol virus. Depress sion
ojf huir.Gral immunity could raako the host more susceptible t_o_
other in fee t d ous a go n t s . Pop re s s i o n_ of_ cujjll.ul.ar i mmiin it y
•would lov/er capability to reject mal ignant __c:_cl 1 s _a_rm couj_d
pg^tentiate tumour initiation and grov/th. Cellular irci.auni ty
depression could also riake the host less ablo to reject virus
infected cells opening a path tov/ard establishment of chronic
virus i nfoctions.
The desirability of creating an environment designed to expose
us to low levels of viruses seems at the very least questionable
^ • E f f o c t of was I c -derived cherni c a 1 po 11. u t a nts on host sus-
)t ib ijli t y : it should be noted that chemical pollutants
associated with the treatment of sev/age such as N02, S02, and
as had originally been proposed for use in the Clavey 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 infectivity of pathogens are
again v/ell documented in the National Academy of Sciences'
report "Infectious Disease in Manner Space Flight".•&
3. Nitrous acid as a r'iutagcn: it should also be noted that
N02 which in aqueous solution" forms nitrous acid, is a known
mutagen. Mutagenicity of nitrous acid is documented in the
references belo\v,-^J^Jii-L?/ 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
large numbers of microorganisms of a potentially pathogenic
nature present in sev/age.
£/See ref's page 131 No's 113-143 in Bibliography of Appendix A,
page 102 in Infoctious^^Diseaso in Manner Space Flight, National
Academy of Sciences, Washington, D. Ct, 1970.
cj/Tessman, Poddar & Kuwav (1-964) J. Mol. Biol. 9^,352,
JLQjfaudev/itz (1963) Biochem. Bi ophys. Res. Cormn. 11, 416.
v"ie]mettcr & Schuster (1960) Z. Naturf. 156,304.
(1960) C. R. Acad. Sc. Paris 250,1134.
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4 . Transfcrrable drug resist; ;e in on loric bacteria :
Another factor which shoxild 1 mentioned is that the enteric
bacteria possess the quality < '. being able to exchange drug .
resistance properties betv/een members of a viable population-1— -J.il.
The genetic factors responsible for resistance to certain drugs
in these bacteria are extrachrjmosomal 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 v/ould not be observed until antibiotic therapy was
required.
\
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 sewage 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 cDnnot 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.
Anderson (1968) Ann. Rev. Microbiology 22,131.
Smith & Linggood (1970) J. Gen. Microbiol., 62,287.
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The argument that epicieniologjcal relationships have not boon
proven is not valid. The work has simpJy not yet been done.
Let us count ourselves fortunate that our U.S. Public Health
Service did not wait for definitive pro.')]' before taking
measures Lo protect, our population. They brought sanitation,
quarantine and preventive measures to boar, in some instances',
before germs were related to disease at ail.
Hopefully the Knvironriental Protection Agency will take the
same "reasonable doubt" attitude and agree that potentially,
sewage troatuont in the immediate vicinity of human habita-
tion is a tenuous situation. When recognised as such,
expediency \vill not be allowed to overcome the public welfare.
Martin H". Rog
1563 Robin Hood
Highland Park,
D.
Place
Illinois
60035
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U .MTV 131-153 [TV OJ'1 TJ_,I_,I1-TOIS ^T T1-J}L% iMi/JDIO^Lj OJSJW'.Txnra, CKIOVCiO
January 18, 1971
Mr. Martin Warner
Dear Sir:
At your request I am responding to the question set forth by Mr. Gary Schenzel
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
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 beingvJnihjeasar.it
odors, iiiaiiy Cdube 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
»
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 within
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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b. Physical health effects. •
The physical health effects relate primarily to the lung but also niey 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 rerprd to the health question.
The first relates to the problem of gases produce-,:. Gr.r.fcs produced from a sewage
plant include the nitrogen compounds, particularly nitrogen dicxid.*, hydrogen
sulfids end sulfur dioxide* carbon monoxide, carbon dioxide, i.wrcaptc.ns and others.
Studies carried out by our group at the University of Illinois School of Medicine
in the section of Environmental Health in ths Department of Preventive- Midi cine
hay© revealtd that in the presence of air pollutants as measured by sulfur dioxide,
With chronic bronchitis have twice as many days of illness when the
are, gutter than 0.2 ppm than they do when the pollution levels ars
v$)s Of SOg expected from this plant will reach a maximum of
& 23 ?PK 1ft MASidfering the levels of gaseous pollutants to which individuals
wii}) fe§ *«ts|eettd% $m must consider not only what comes from the plant but also
What t$ 1ft thft ewawnity. While very few measurements have been made, the levels
$f SOg in th® 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 Welfare
AP-50),
In addition to the gases, participate will emanate from the plant as a result
of burning. Many of these gases 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.
-------
Behind these plugs infections frequently develop. It is logical tin's to ar.suine
that thesi. Luterials will not only c?i;?f infection but reduce tha ability ci the
body to fio'cti off infection. This was clearly sho\:n in the Chicago Air Pollution
Study carried out and published in the Archives of Environmental Health.
(The Chicago Air Pollution Study: S02 Levels and Acute Illness in Patients with
Chronic Bronchopulmonary Disease -B. W. Carnow, M. H. Lepper, R. B. Shekelle and J.
Statnler: 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 Madicine, 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 wall documented in relation to sev/age 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 microlaycr 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 water in which
the bubbles burst." It should also be noted that many bacteria and viruses concentrate
at the surface of the water 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 shown thai bocL:.; val ?avoso1^ c.c,n affect individuals in the surrounding
areas as in a case of a small epidemic of ornithosis 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.
tlO52fI31I§Offl^i n ^gard to the projected increase in the size of the
sewage plant and its impact on the community, fherd"lV1>j^fgj;]if^M»Hg'tihl tf^fl.wgff
^ 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. ^krnsi^j^SHSTCgr^rneTg
when added to the lowered
resistance because of irritants can only have a greater deleterous effect, as
noted the general HSuHIaO^^
^
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 ca^ 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 all be carried out in a comprehensive
%
study. This study should also include an epidemic! ogic 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 uhe possible ways of solving these problems and the available technology for
t
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 here or in any other place in the country
that I know of.
-------
I trust this v.'ill be helpful to you in evaluating and considering this
important matter.
Sincerely,
/Bertram W. Carnow, M.D.
Associate Professor . t
Department of Preventive Medicine and Community Health
Chief, Section of Environmental Health
University of Illinois
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STATE OF ILLINOIS )
) SS:
COUNTY OF L A K E )
i
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.
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 Preventative Medicine,
-Ti-t v«^« H- nft ^.f +. V, „ rpnX^ -nn n 1 r\o -1 o T-n a •*- 14 -h i •>+- ~
-------
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?
1
\
A Yes, I am.
Q What is that, sir?
A It's my curriculum vitae.
Q What is that?
-------
A It details my career, my 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-
t
duced and emitted into the atmosphere as a result
of activated sludge plants, such as the Clavey Road
treatment plant?
A Yes .
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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 the burning of
digestive gases, so that there is production of
nitrogen compound, including NO2, a nitrogen
compound and sulphur dioxide.
Also there are emissions of hydrogen
sulphi, which is a poisonous gas. In addition, 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 data which is contained thereon
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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 also 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 th,e 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
emitted, and these gases particularly are additive,
i
or what we call sinalglstic, in that they have a
i
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
<
have the effect you 'just described?
i
A Well, nitrogen oxide, which is a -- in
fairly highly concentrations, a deadly gas. There
is a 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 dnjwriousness of gas. I think
the general statement is that if it's injuricusness
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
(
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.
i
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 chromcsone
breakage, means at these concentrations, has the same
-------
effects as X-rays. And further, the effect of the
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
>
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
i
to be added. If this amount, at the quantity which
is described, is hazardous to health, and there is
excellent documentation 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
\
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 opinion, may
be very dilatorious 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.
-------
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
j
mucus, because of irritation of these gases,, is
produced in much greater quantity so that as this
i
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 bronchitics, 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 ?
i
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
tri.oxide arid sulphuric acid, which is an extremely
irritating acid.
Q What is the effect, Doctor, of small amounts
t
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
-------
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-milllon
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
you are referring to,-Doctor?
THE WITNESS: A Yes.
Q Doctor, ia 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 tel! 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
1
gives, a state of well-being wherein individuals
can function and enjoy health and property, then the
odors certainlv would affect health by this
definition.
-------
In addj.cion, 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 .
x «
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
•
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 aro 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,I 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?
We-ll, 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
t
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
i
disease producing organism?
A It's a pathogen. Yes, of course. But
(
more important than that, it's a market?. The
reason that E. colj was measured is because it's
easy to measure. But if E. coli is in the air, it
means 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 can
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. coll 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 Exhibit 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?
i
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 that, 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
•
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-million 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. I'm sure as our knowledge increases we
will begin to find that smaller and smaller amounts
i
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
hazard. If the maximum is .231 parts per million of
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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 doubling 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
i
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
t
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
the .8 miles?
THE WITNESS: A Yes, sir.
MR. CONZELMAN: Q Does that have to do with
the size of the treatment plant?
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.
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MR. CONZELMAN: That's all. Thank you
(Witness Excused.)
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