PROCEEDINGS
                                         Fifth Session
                                         Detroit, Michigan
                                         Junes, 4,1970
                                         Vol.
In the Matter of Pollution off Lake Erie and its
Tributaries- Indiana-Michigan-New York-Ohio-
  U. S. DEPARTMENT OF THE INTERIOR • FEDERAL WATER QUALITY ADMINISTRATION

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           905R65101
                                            421
FIFTH SESSION OF THE CONFERENCE IN
THE MATTER OF POLLUTION OF LAKE
ERIE AND ITS TRIBUTARIES  (INDIANA-
MICHIGAN-NEW YORK-OHIO-PENNSYL^ANIA)
                           Cobo Hall
                       Detroit, Michigan
                          June 4,  1970

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                                                      422



                                                                  ,'f
                       CONTENTS
                                                                   *
STATEMENT OF;                                         Page

Frank J. Kallin                                       423

Al R. Balden                                          439

Gerald J. Remus                                       444

Hillel S. Liebert                                     505

George H. Eagle                                       515

Walter A. Lyon                                        570

Perry Miller                                          590

Russell C. Mt. Pleasant                               602

Lowell A. Van Den Berg                                646

Albert M. Shannon                                     725

R. W. Purdy                                           728

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                                                      423
                        JUNE 4, 1970
                          9:35 a.m.
                     PROCEEDINGS
          MR. STEIN:  We will reconvene with Mr. Purdy.

          MR. PURDY:  Yes, Mr. Stein.

          I would like to call now upon Mr. Frank Kallin,

Ford Motor Company, for a statement.


                  STATEMENT OF FRANK J. KALLIN

             FACILITY ENVIRONMENTAL CONTROL MANAGER

                       FORD MOTOR COMPANY

                       DETROIT, MICHIGAN


          MR. KALLIN:  Mr. Chairman, conferees and ladies

and gentlemen, my name is Frank J. Kallin and I am manager

of Facility Environmental Control for Ford Motor Company.

          I appreciate this opportunity to report on the

continued progress Ford Motor Company has made in wastewater

control at its Rouge and Monroe plants since the June 1965

session.  Improvements have been brought about variously by

new waste treatment facilities, expansion and modernization

of existing facilities, and by process changes which have

eliminated or minimized waste producing operations.

          At the Rouge manufacturing area, our primary waste

water tasks have been the reduction of suspended solids,

phenol, oil, and the dissolved iron from steel pickling

liquor.  At Monroe, our tasks were concerned with reducing

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                                                        424




                    Frank J.  Kallin






cyanide and holding bacteria, oil, and phosphates to specified




limits.  I will discuss the steps we have taken and are taking




to bring each of these within the limitations stipulated by




the Michigan Water Resources Commission.




          First, suspended solids.  At the time of the 1965




conference, 4 of the 5 major outlets in the Rouge complex




were already under the objective of 50 milligrams of suspended




solids per liter.  Excess solids in the one exception resulted




from the grinding and polishing of glass.  Since then, this




solids loss has been eliminated at the source by a new float




glass-making process which does not require the grinding and




polishing operations.




          However, a minor "trade-off" with improved air




pollution controls at the Rouge powerhouse  and the Dearborn




Specialty Foundry has given us an interim problem with sus-




pended solids.




          New dust collector equipment installed at the power—




house removes more suspended particulates of smaller micron




size from the boiler exhaust gases and a part of these solids




are lost to the sewer system through a water induced vacuum




system.  The temporary condition will be corrected by the




installation of a so-called  "Baghouse" filter system scheduled




for completion by next January 15.




          At the specialty foundry, the solids are suspended

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                                                       425




                        F. J. Kallin






particulates trapped from exhaust air by new wet collectors




on the cupolas.  Along with the wet collectors, we installed




an elaborate diatomaceous earth filtration system for removing




the particulates from the water — in effect, a full-scale




research project since this type of filter had not previously




been used for this application.  We hoped and expected it to




yield filtered water containing less than 5 milligrams of




suspended solids per liter, but unfortunately the system




failed to work despite extensive changes tried out by both




the supplier and Ford.  We are now designing a system using




the more proven principle of clarification which will reduce




the suspended solids content from our cupola wet scrubbers




to less than 25 milligrams per liter.  Preliminary planning




will be completed this month and the system will be in opera-




tion before the end of 1971.  Although not as significant,




we have been able to reduce suspended solids losses by




initiating a program of converting to dry in-plant dust col-




lectors.




          Naturally, we are disappointed at the lack of suc-




cess with the diatomaceous earth approach which appeared to




hold so much promise.  However, we think the data and




experience we acquired will be of value in establishing and




determining equipment limitations for future applications.




          Now, with respect to phenol, in our coke-making

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                        F. J. Kallin






operations at the Rouge, we generate approximately 1,200 to




1,400 pounds of phenol a day.  By pumping the final cooler




water into a deep disposal well, we were able to reduce the




quantity of phenol discharged into the Rouge River to less




than the limit of 600 pounds a day required in the 1952




order from the Michigan Water Resources Commission.




          In 1966, Ford entered into a voluntary stipulation




with the Commission, agreeing to reduce the daily discharge




of phenol generated from the coke oven operation from 600




pounds to less than 70 pounds.  Additional deep wells, a




phenol recovery plant and a biological destruction process




were among the methods we considered for accomplishing this




steep reduction.  The first two alternatives were discarded




only after we had designed, built and operated a pilot plant




which determined that biological destruction was feasible.



This conclusion was further supported by our findings that,



particularly in the summer months, as much as 80 percent of



the phenol which we discharged into the Rouge River had de-




composed by the time it reached the confluence with the




Detroit River.  On the basis of this evidence, we proceeded




to design a full-scale biological plant to be located on Ford




property for the treatment of our phenol-bearing waste.




          After completing the design, however, it appeared




to us that a more logical solution might be to see whether

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                                                       427




                        F. J. Kallin






the Detroit metropolitan water services treatment plant could




and would accept our remaining phenol waste for biological




destruction.  Detroit officials so agreed with the provisions,




among others, that we transfer a part of our 70-pound stipula-




tion to the city and pay an equitable additional rate for




the convenience and additional services rendered.




          Now, with respect to oil, the recovery system




which formerly served the north half of the Rouge complex




has been completely replaced by an advanced collection and




removal system now entering its third year of operation.




          Additionally, since May 3 of this year, an oil




polishing lagoon has been operational in conjunction with




the Gate 11 oil removal facilities which were installed in




1954.  Owing to extensive delays in a planned relocation of




the Rouge River channel by the U.S. Corps of Engineers, due




to restricted Federal funding, the property which we had



originally contemplated as the site of the lagoon has not




yet become available to us.  Fortunately we were able to




purchase other suitably located land across the river for




the purpose.




          We believe that these improvements, supplemented by




a continuing program of careful and energetic housekeeping




within our plants, have given us an effective oil control




system at the Rouge.

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                                                       428




                        F. J.  Kallin






          With with respect to steel pickling liquor/ for




many years our steel operations at the Rouge used sulphuric




acid for the removal of iron scale in its pickling operations,




resulting in waste pickling liquor which was discharged to




our boat slip.  After studies of possible alternatives —




including disposal wells, acid recovery systems and chemical




neutralization — our Steel Division found it most feasible




to switch from sulphuric acid to hydrochloric acid, which is




more capable of being economically recycled and reused.




          Under contract, an outside supplier now hauls




from the Rouge all the spent pickling liquor generated each




day.  Since April 1969 there has been no disposal to the




boat slip except for some incidental leaks — which since




have been completely corrected — and small quantities of dis-




solved iron contained in  the rinse water.  Even though we are




meeting our iron stipulation, we are currently designing




additional facilities to  prevent any loss of iron in the




rinse water to the boat slip which will eliminate occasional




discoloration.  We expect to have this installation operat-




ing by May 1971.




          Now, with regard to cyanide and phosphate at our




Monroe plant, waste treatment facilities at our Monroe plant




were initially installed  in 1950 and were expanded in 1955




to provide for the treatment of cyanide and for the removal

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                                                       429




                        F. J. Kallin






of chromium and nickel used in plating operations.   Addi-




tional facilities operating since January 1969 have utilized




chlorine to destroy cyanide and this has reduced the cyanide




concentrations in wastewater to less than .025 parts per




million in accordance with a voluntary stipulation  entered




into between Ford and the Michigan Water Resources  Commission.




          The above wastewater treatment facilities also




enable us to meet our stipulation on oil, bacteria  and phos-




phate .




          That concludes my report on the current status of




Ford Motor Company*s continuing effort to improve wastewater




control at its Rouge and Monroe plants.  We believe that,




with the exception of the short-term problem with suspended




solids resulting from our air purification efforts  at the




Rouge, our process changes and waste treatment facilities




have placed these two plants in substantial compliance with




existing water quality standards and objectives. In keeping




with Ford Motor Company's commitment to an improved environ-




ment, as spelled out publicly by Mr. Henry Ford II  last




December 1,1 can assure you that our company will  continue




in its efforts to help achieve the goal of cleaner  air and




cleaner water.




          Thank you again for giving me this opportunity to




discuss the progress we have made.

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                                                       430




                        F. J.  Kallin






          Mr. Chairman, I have one additional comment.




Yesterday, I had an opportunity to review the summary state-




ment delivered by Mr. Harlow.   On page 27 of that report, I




believe the word "air" should replace the word "oil".




          Making this change,  the sentence would read:   "The




State of Michigan adopted a final order of determination at




its May meeting to require further control of suspended




solids resulting in part from air pollution control facilities,"




as opposed to oil pollution control.




          MR. STEIN:  Do you accept that, Mr. Harlow?




          MR. HARLOW:  Yes, that's right.




          MR. STEIN:  Thank you for that correction.




          Are there any other comments or questions?  And I




wish we would have a few here because at least on its face,




the statement we had of the status of Ford from Mr. Harlow



and the statement from Mr. Kallin do not seem to completely




jibe.



          Let me make my point and let's see if we can get




this clarified.  Mr. Kallin says they are in substantial




compliance.  As I understand it from the Federal statement,




Ford was behind.  Can we resolve that somehow?




          MR. HARLOW:  I think the statement of Mr. Kallin




was in connection with the suspended solids.  And I believe




it was because this filter didn't work and you went to

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                                                      431




                        F. J. Kallin






another system that caused you to be delayed.




          MR. KALLIN:  That's right.  And I think my state-




ment reflects that we are not in compliance with suspended




solids.




          MR. HARLOW:  It is good to see you again, Mr.




Kallin.




          MR. KALLIN:  Thank you.




          MR. HARLOW:  On page 3 of your report, when you




talk about —




          MR. STEIN:  Pardon.  Let me get this because I




think this is the key point.  If you are not in compliance




with suspended solids, what does that statement at the end




of your report say on process changes and waste treatment




facilities have placed these two plants in substantial com-




pliance with existing water quality standards  and objectives?




          MR. KALLIN:  But I think, Mr. Chairman, that I say



that we believe that with the exception of the short-term



problem of suspended solids.




          MR. PURDY:  Mr. Kallin, you have a number of out-




lets to the Rouge River from your Rouge operations.  Many




of these contained or did at one time contain  suspended




solids in excess of the requirements that have been agreed



upon.




          Now, are you behind time on suspended solids

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                                                      432




                        F.  J.  Kallin






control on all of these outlets or only on one or two?




          MR. KALLIN:  No,  sir.  We are only not in compliance




on actually two outlets.  And I think that is covered some-




what, possibly not enough detail, in the first part of the




presentation where we said initially we had a suspended solids




resulting from the grinding and polishing of glass which has




been eliminated.  And the suspended solids problem we have




today is the result of the air pollution control facilities




which were put in.  So that these two situations, the power




house and the Dearborn specialty foundry, happened to drain




into two separate sewers.




          So, to put it another way, we have 5 sewer systems




and 3 are in compliance and 2 are not, if that is helpful.




          MR. HARLOW:  Is the  powerplant discharging through



the tailrace?




          MR. KALLIN:  Yes, sir.




          MR. STEIN:  Are we in substantial agreement on




the situation now?




          MR. HARLOW:  Yes.




          MR. STEIN:  What do you think is the situation in




the Ford plants?  Do you think they are in substantial com-




pliance except for the air pollution scrubbers, control




scrubbers?




          MR. HARLOW:  Well, I have one or two questions I

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                                                       433




                        F. J. Kallin






would like to ask to explore this a little further.



          MR. STEIN:  Right.




          MR. HARLOW:  Mr. Kallin, on page 3 of your state-




ment in connection with the oil — and I think most of your




reference here is in the oil problem from Gate 11, and you




did construct a lagoon — is this across the Rouge River




now from where the Gate 11 discharge was?




          MR. KALLIN:  Yes, sir.  What we have done is we




picked up the effluent from the clarifiers which we installed




back in 1954 which since that time have been discharging




directly to the Rouge River.  We have picked up that




effluent and now carry it underneath the Rouge River to the




new so-called polishing lagoon.  And that went into opera-




tion May 30th this year.




          MR. HARLOW:  And are the discharges of these lagoons




within 15 milligrams per liter of oil?



          MR. KALLIN:  Yes.  As a matter of fact, Mr. Harlow,



if we are talking about an arithmetical number, my recollec-




tion is that for the most part, the arithmetical 15 milligrams




per liter, we were attaining with the clarifiers as they were.




However, we recognize that there was still oil coming out of




them.  That's why we have gone the extra step.  And we think




this is going to make a significant improvement to the water




quality going into the Rouge.

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                                                      434




                        F.  J.  Kallin






          MR. HARLOW:  Now, what I recall,  I think,  was




Willow Creek outfall where  most of your oil from your rolling




mills came out.




          MR. KALLIN:  No,  most of the oil  from the  rolling




mills came out to this Gate 11 system, that system against




the southwest half of the Rouge plant.




          MR. HARLOW:  Back at the end of the Ford slip




where you had the skimmers, are these skimmers still in




operation?




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  Are  they working satisfactorily?




          MR. KALLIN:  Yes.




          MR. HARLOW:  So you are able to meet your  stipula-




tion for oil which I believe says measuring just the other




side of the skimmer?




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  And that is within the compliance?




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  Now, in connection with the cyanides




at the Monroe plant, the stipulation also calls for  meeting




25 pounds per day.




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  Your estimate refers to just  concen-




tration units, but are you also meeting the 25 pound per

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                                                       435




                        P. J. Kallin






day for cyanide?




          MR. KALLIN:  Yes, we are.  What we are actually




doing is chlorinating down to zero cyanides.  So it is well




less than 25 pounds.




          MR. HARLOW:  I have no further questions.




          MR. STEIN:  Any other questions or comments?




          MR. O'LEARY:  I have one question.




          On page 3, Mr. Kallin, on your phenol operation,




you have stated this part of an agreement with Detroit would




be to transfer part of a 70-pound stipulation to the city.




Has that been accomplished or what?




          MR. KALLIN:  No, it has not.   And I think that is




an arrangement, if you will, between Detroit and Ford.  In




other words, it was since Detroit was going to offer this




service, since we can get down well below 70, it appeared




logical to transfer a portion of this amount to Detroit.



          MR. O'LEARY:  I mean Detroit would be allowed to



discharge more phenol, is this the meaning?




          MR. KALLIN:  I would assume so.  In other words,




if Detroit has an arithmetical limitation as we do,  the end




result on the river would be the same,  but the source would




be from one location as opposed to the two locations.




          MR. PURDY:  Mr. Stein.




          MR. STEIN:  Yes, Mr. Purdy.

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                                                       436




                        F.  J.  Kallin






          MR. PURDY:   There seems  to be  a  slight  point  here,




I believe, that needs some  clarification.   And that  is  that




the Ford Motor Company will be discharging a  part of their




phenol-bearing waste  to the Detroit system.   And  in  recogni-




tion of this, the Ford Motor Company will  transfer a part




of their allocated load to  the river to  the city  of  Detroit




in consideration of this treatment that  Detroit will provide.




          MR. STEIN:   Any other questions?




          MR. HARLOW:  I have one  more question,  Mr.




Chairman.




          Mr. Kallin, in getting back to oil  a little bit,




the stipulation also  calls, in reference to oil wastes  from




Ford, that there not be visible film of  oil on the surface




of the waters.  Do you think that  the 15 milligrams  per liter




is sufficient to prevent any film  of oil on the water surface?



          MR. KALLIN:  I think that we have specifically



with respect to the Rouge because  of the full concentration



of minute quantities  of oil that accumulate,  again referring




to Gate 11, to really get rid of all the oil.  Essentially we




have seen, of course, a decided improvement in the oil  prob-




lems in the river.  And we haven't had a chance yet  since




May 3 to really on either a short-term or  a long-term look




to see what the extent of the benefits we  are going  to  get




from this new facility are.  We have high  hopes for  it.

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                                                       437




                        F.  J.  KALLIN






          MR. STEIN:  Any other comments or questions?




          MR. PURDY:  I have one question, Mr.  Stein.   I




will comment first.




          And that is, of course, with respect  to Gate 11




sewer and the 15 ppm oil concentration, the Water Resources




Commission recognized that to correct the problems of  oil




accumulation in the Rouge River that we would have to  look




at an effluent that would have less than 15 ppm oil in the




Gate 11 outlet.  And this is why the stipulation calls for




no visible film of oil.  We recognize that at 15 ppm,  you




can have a very slight slick.




          Now, with respect to the Gate 11 sewer, I might




ask Mr. Kallin if at the time that the flood control project




is completed on the Rouge River, do you 'have plans to  still




add additional facilities?



          MR. KALLIN:  Mr. Purdy, the effluent from the



lagoon now goes into the portion of the river which will be



vacated by the flood control channel.  We do have provisions




made in the Corps contract to use that portion of the  river




for further treatment.




          MR. PURDY:  So that as soon as the flood control




project has been completed to the point that this part of




the channel can be released to you, you will add a, so to




speak, second polishing lagoon.

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                                                        438




                        F.  J.  Kallin






          MR.  KALLIN:   Yes, sir.




          MR.  STEIN:   Thank you.




          Are  there any other comments  or questions?  Are




we all satisfied with the progress report now or  is  there




any problem?




          (No  response*)




          Thank you,  Mr. Kallin,  for  a  complete statement.




          I think it might be helpful — and I just  throw




this out and maybe we can think about this — if  we  ask our




people, in conjunction with the State people, perhaps,  to




have an inspection of Ford, since you are one of  the principal




ones named.  In this case,  perhaps a  joint statement of the




facts of the situation, including a prognosis, can be pre-




pared and agreed upon among Ford, the State of Michigan and




the Federal Water Quality Administration.  This will be




laid out so that we can all agree upon  a statement of the




conditions.




          I think this will be helpful  to all because if




the situation is substantially cleaned  up — and  we  are just




dealing with minor problems now — I  think we should state




that for all to see and lay it out if that is a fact.




          MR.  PURDY:  We would be pleased to make those




arrangements.




          MR.  STEIN:  Thank you very  much, Mr. Kallin.

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                                                       439




                        A. R. Balden






          Mr. Purdy.




          MR. PURDY:  Mr. Balden, Chrysler.






                  STATEMENT OF AL R. BALDEN




                 WASTE TREATMENT  SPECIALIST




                      ENGINEERING OFFICE




           CHRYSLER CORPORATION, DETROIT, MICHIGAN






          MR. BALDEN:  Mr. Stein, conferees, ladies and




gentlemen, it is a pleasure for me to appear before you to




make a brief statement.




          My name is Al Balden and I am the Waste Treatment




Specialist for Chrysler Corporation which has three manu-




facturing plants on the Detroit River, all in the vicinity




of Trenton, Michigan.  These plants are:




          1.  The Amplex Division's Trenton plant, built in




1953, which sinters small metal parts.




          2.  The Chemical Division's Trenton plant, built




in 1947, which makes industrial adhesives, brake linings,




machining coolants, cleaners and the like.




          3.  The Trenton engine plant, built in 1951,  which




machines engine components and assembles these into engines.




          It has been basic to Chrysler's operating philoso-




phy that protecting the quality of our environment is an




integral part of the cost of making a product.  We have

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                                                       440


                        A.  R.  Balden



designed and built plants to protect our waterways from


degradation, as contrasted with the more limited approach of


meeting the requirements of the law.  We have always tried


to anticipate potential pollution and its ecological effects


and have solved the problems presented to the best of our


ability, based on the best technological knowledge currently


available.  As we have learned more, we have applied this


knowledge.  Each plant built has represented the accumulated


experience applicable to that problem.  Those of us associated


with the designing, building and surveillance of such equip-


ment have become firm believers in the validity of Murphy's


Law.  We have seen things happen which are unanticipated and
                                    r

have constantly worked to eliminate the unexpected.


          Each production plant built by Chrysler in the


Trenton area varies considerably in reference to the manu-


factured product and therefore the manufacturing operations


and the types of wastes produced.  We have worked closely


with the Water Resources Commission staff during the design


of the waste treatment facilities, discussing the plant


operation and the types and volumes of contaminants to be


treated and removed as well as the proposed facilities for


accomplishing the desired pollution prevention.


          At the Amplex plant, the potential pollutant was


free oil and a retention pond with a weired overflow with a

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                                                       441




                        A. R. Balden






drum skimmer upstream of the weir has been effective in




preventing loss of the oil.




          The chemical plant was recognized to have a problem




due to small but anticipated losses of oils, solvents and




the like during the transfer of raw materials from the




delivery truck to holding tank and while pumping the final




product from the mixing tank to the shipping conveyance.  A




lagoon was constructed to catch and hold this drainage.  The




floating material was periodically pumped to a truck and




hauled to an incinerator.  The aqueous portion was pumped




to a drying bed.  Due to operational errors, this procedure




has not been entirely effective in preventing pollution, so




additional equipment is to be installed to provide an effec-




tive remedy.  We have entered into a voluntary stipulation with




the State to have these facilities in operation by April 1,




1971.



          It was recognized that the Trenton engine plant



would have a serious pollution problem because of the many




machining and cleaning operations performed.  For this reason,




waste treatment facilities were included as part of the plant




as built.  These represented the most advanced technology




known and were quite acceptable at that time — 1951.  They




consisted of a large  holding tank followed by air flotation




and included means of recovering oil.

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                                                       442




                        A.  R.  Balden






          As we learned more about the limitations  of our




equipment and as the effluent demands became more exacting/



it was evident that additional facilities were required.   A




completely new tertiary treatment plant was installed in




1967, consisting of primary oil skimming, air flotation and




final settling.  This plant has enough flexibility  to satis-




factorily treat a variety of wastewaters and its operation




has been completely satisfactory as reflected by the reports




sent to the Water Resources Commission.




          The greatly increased public awareness of threats




to the quality of our environment can be beneficial in many




ways.  We hope one positive result will be an increased




awareness in the cause and effect of thoughtless actions  by




people who handle industrial pollutants as well as  their  daily




job.  New and stricter laws can be enacted and they will  be



effective, but only to a point.  They will always fall short




of their full potential until each man and woman in their




roles as employees and citizens of this society become fully




committed to his surrounding environment.  The installation




of adequate facilities must be matched by intelligent




individual commitment to their use.




          MR. STEIN:  Thank you, Mr. Balden.




          Are there any comments or questions?




           (No response.)

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                                                       443




                        A. R. Balden






          Mr. Balden, I would like to take this opportunity




to commend you in particular and Chrysler because it has




been my experience that under your direction, Chrysler Cor-




poration has taken cognizance at least of water pollution




problems in the country.  For an industry faced with major




potential pollutants, it has been always cooperative with




Federal, State and local governments in putting in these




devices.




          And I think if other companies had had the policy,




and perhaps had had the leadership of someone like Mr.




Balden, we wouldn't have this problem today.




          I don't know about one area.  And Mr. Lyon may




want to listen to this.  You don't find this all over the




country.  How are you doing in the Delaware River Basin?




          MR. BALDEN:  Fine.  We have no problems there that




I am aware of.




          MR. STEIN:  O.K.




          MR. BALDEN:  We have been in close touch with the




people in Delaware, and they seem to be happy.




          MR. STEIN:  Oh, I know they are happy, but I don't




know how happy that water is.




          All right, thank you.




          Mr. Purdy.




          MR. PURDY:  Mr. Stein, I would like to call on now

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                                                       444




                        G.  J.  Remus






Mr. Gerald Remus, the General  Manager of the Detroit Water




Board, to describe to the conference the largest single




system of intercepting sewers  and wastewater treatment




plants that has ever been placed under construction in the




State of Michigan.  And I think it is also the largest




single system of intercepting  sewers and waste treatment




that has ever been placed under construction in any part




of the U. S. section of Lake Erie.




          Mr. Remus.






                STATEMENT OF GERALD J. REMUS




                      GENERAL MANAGER




        CITY OP DETROIT METROPOLITAN WATER DEPARTMENT






          MR. REMUS:  Thank you, Mr. Purdy.




          Mr. Chairman, members of the conference, I am




Gerry Remus, General Manager of the Detroit Metropolitan




Water Department.




          We had prepared a report which after sitting




here for a day and a half now, I would like to comment on




rather than read because there are some points that come




up that seem to me need to be clarified.




          MR. STEIN:  Mr. Remus, how about my putting the




whole report in the record as if read?  We may have a few




problems with your map.  If we put it in, it will probably

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                                                       445




                          G. J.  Remus






have to appear in black and white and will  not have  the




insert.  We may have to push it  down.




          And I do not know if we can reproduce these




pictures, Gerry.




          MR. REMUS:  We can probably get you the pictures.




          MR. STEIN:  The pictures,  we have here. But




unless we can get the originals, we  may want to eliminate




the pictures.  If you want them  in,  you will have to have




other things to help us.




          MR. REMUS:  I have no  personal feeling on  the




pictures except to establish that the entire effort  as far




as I am concerned is dedicated to the fact  we are not  going




to be talking about how lousy things are, which we have heard




enough of in the last day, but rather what  construction we




have under way and what progress we  have made and are  hoping




to make provided we can keep cooperative efforts going.




          (The above-referred to report follows in its




entirety.)

-------
               REPORT/TO THE
      CONFEREES ON INTERSTATE LAKE ERIE
FEDERAL-STATE POLLUTION ABATEMENT PROGRAM
                     BY
        G. REMUS, GENERAL MANAGER
    DETROIT METRO WATER DEPARTMENT
                JUNE 3, 1970

-------
                                                                        447
                                               June 3,  1970
Conferees on  Interstate  Lake Erie
Federal-State Pollution Abatement  Program


Gentlemen:


Since I last reported to this Conference on June 27,  1969,  I am happy to report

substantial progress toward meeting our mutual goal of pollution abatement in the

Detroit River and Lake  Erie.

Projects which were nearing the construction stage a year ago are under construction,

and projects under construction a year ago are basically  completed and beginning to

show results.    Work  totaling $74 million,  including engineering costs,  is under

construction now.   Another  $90  million worth of contracts will start this year.

The  progress to be described applies to all or  parts of a regional sewage  disposal

system now serving about three million persons in Detroit and 54 suburban communities.

We have contracted to serve an additional 15  communities and the remaining portions of

another two already in the system.  Contracts to serve 12 more are under consideration.
                                       -  1 -

-------
                                                                          448
The regional Sewage Treatment Plant serving these communities is currently treating




an average daily flow of 750 million gallons,  a  rate which is  steadily increasing  as




development continues in the present  service  area.







Progress will be described in five areas:  (1) Installation of advanced treatment facilities




in our Sewage Treatment Plant;  (2) Extension of the regional interceptor system;




(3) Improvements in storm water overflow control;  (4) Other pollution preventive




measures, and  (5) Contracts which we intend to award by the end of 1970.   The photo-




graphs attached indicate the size and scope of some of the current projects (Exhibit A).










I.   ADVANCED TREATMENT





Last year we reported design criteria for phosphate removal and biological treatment




facilities, based on almost two years of operation of our  pilot treatment plant.   Today




we can report successful full-scale soluble phosphate  removal, substantial reduction in




coliform bacteria, and a major innovative change in design of our biological treatment




process.  The charts attached indicate our projected removal capabilities as we complete




projects (Exhibit B).







    A.   Phosphate  Removal




         On March 30 of this year we began measured injection of waste ferrous chloride




         into the two interceptors which carry sewage into the Sewage Treatment Plant,




         Since then,  the two-month average of orthophosphate in our effluent has been




         less than 21,000 pounds per day maximum contained in our  stipulation with the




         Michigan Water Resources Commission.
                                       - 2 -

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                                                                         449







A.   Phosphate Removal (Continued)




     The Department is currently using the entire output of ferrous chloride from




     Great Lakes Steel's Ecorse Plant.  Indications are that eventually other sources




     will have to be found.  The Department transports the  ferrous chloride to two




     150,000-gallon  storage tanks at the plant:  Currently,  injection  of  10 - 15




     milligrams of iron per liter of sewage influent is adequate to meet the poundage




     stipulation,







B.   Coliform Bacteria





     The bacteria count in our effluent is approaching the stipulated level of 1,000 per




     100 milliliters.  But bacterial pollution from the Rouge River is wiping out the




     value of this reduction to the River, samplings downstream indicate.







C.   Biological Treatment





     Last year we reported our intent to construct a step-feed activated sludge process,




     incorporating enough flexibility to deal with daily and long-term changes in




     quantity and quality of sewage influent.






    While design continued,,  our engineers studied the possibility of  substituting




    pure oxygen for air in the proposed aeration tanks.






    Potential advantages of oxygen aeration appeared to include doubling capacity of




    an aeration tank of a given size with resultant long-term  savings in operating and




    capital expense  (including acquisition of less land), reduction in  odor  and greater




    ease of sludge handling.  Disadvantages appeared to be the possibility that the




    process might not live up to its claims, plus short term higher expenses for




    operation and construction,




                                   •  3 -

-------
                                                                          450






    C,  Biological Treatment (Continued)





        Earlier this year, we decided to test the process on a plant-sized scale.  Plans




        call for one-half of the first aeration module to use the oxygenation system and




        the other half to use a conventional aeration system.   The dual flow train system




        will provide invaluable cost and operational comparisons for the benefit of future




        Department expansion and for the benefit of other agencies involved in water




        pollution control.





        The Department expects to save about $6 million in construction expense by 1975




        if both tanks use oxygen to  treat 600 million gallons of sewage per day in the




        biological process., with a savings in annual operating expense of more than




        $200.000 if the Department builds  its own oxygen plant.






        Contracts for this first module of biological treatment are to be awarded by the




        end of this year.









II.  REGIONAL INTERCEPTOR SYSTEM




The Department for more than a decade has stressed the need for a regional approach to




the regional problem of water pollution.   Our earliest proposals were given impetus by




growing Federal and State emphasis on regional  solutions for a variety of governmental




efforts. This  emphasis has led to Federal  and State recommendations for a single




regional Sewage Treatment Plant to  serve all or  portions of Wayne, Oakland and Macomb




Counties.   The attached map, "Water Pollution Control Program"  shows our proposed




regional interceptor system capable of serving the region's needs past the year 2000.
                                       -  4 -

-------
                                                                          451






Today, a major portion of the initial construction of the Detroit Metro Water Department's




Oakland-Macomb Interceptor system in Macomb County is under way,  When completed,




the initial and future interceptor arms will serve all of Macomb County and much of




northern Oakland County --an ultimate population of 3. 4 million -- and will allow the phase-




out of all existing treatment plants whose effluent is currently tributary to the Clinton River.









III. STORMWATER  OVERFLOW CONTROL





On May 25 of this year, a  short, intense thunderstorm moved southeast across Detroit,




dropping an average  of 0. 47 inches of rain over the area in 45 minutes, and as much as




0. 95 inches on some parts in a  similar time period.  Interceptor gradients had already




been lowered in anticipation of thunder showers predicted by the U.  S.  Weather Bureau,




and the Department's Systems Control Center was poised for action.







First direct warning of rainfall came from a remote-registering rain gauge seven (7) miles




west of the city,  15 minutes before the first sprinkles reached another rain gauge inside




the city,







About one billion gallons fell over Detroit, and about 450 million gallons entered the sewer




system,  Yet so much stormwater was retained that overflows  into the Detroit and Rouge




Rivers were fewer in number and of shorter duration than usual.  The Sewage Treatment




Plant processed about 365  million gallons over average flow during the following 30-32




hours,  with no further rainfall,






Retention of this storm in  our combined sewers was one of the  most dramatic demonstra-




tions of a rainfall and sewer monitoring system whose nucleus  is now  nearing complete




installation.



                                       -  5 -

-------
                                                                      452
The system and the Department's ability to interpret and to make decisions based on the




system's reporting was so finely tuned by May 25, that the Systems Control Center was




able to tell a fanned storm pumping station to contain part of the storm in the system




above it -- rather than to start pumping polluted stormwater into the Detroit River to




protect basements.  Rain gauges and sewer level gauges upstream  from the pumping




station had indicated that the storm had nearly spent itself by that time.  Many other rapid




decisions were made during that storm to reduce overflows.






Financed Avith a $1 million Federal grant, the $2.1 million project  includes 14 telemetering




rain gauges, four of them located in suburbs to the northwest, 80 sewer level gauges in




combined sewers,  40 level gauges in interceptors,  71 overflow indicators at backwater




gates  and remote-control capabilities at  seven sanitary and stormwater  pumping stations.






The system for the la'st year has enabled us to learn mofe about the relationships of rain-




fall, sewage levels and overflows to the  Rouge and Detroit Rivers, and it has enabled us




to reduce the occurrence and volume of overflows as indicated in the narrative above.






The Department  is in the process of working out a similar program for all of Southeast




Michigan.






Ultimately, we realize, more effort and  money must be expended to provide even more




control of overflows.  The Water Resources Commission has called for substantial control




by 1977.   But the experience and knowledge of our dewer  system gained from the new data,




coupled with results of other demonstration projects such  as ours,  makes us confident we




can come up with good  solutions  to stormwater overflow reduction.

-------
                                                                           453
IV. OTHER POLLUTION  PREVENTION




All industries in our sewage disposal system discharge treatable wastes into the system




and must pretreat or dispose of elsewhere wastes incompatible with our system.  The




Department now requires an inspection manhole at the connection of an industrial sewer




lead to they system.  Industries have responded well to our industrial waste control




program.   Chrysler Corporation has installed two waste oil treatment installations at




locations within our service area  and is transporting waste oil from other plants to the




new installations.   Detroit Diesel Engine Division of the General Motors Corporation




also has built a pretreatment facility and plans further work.   Other work is planned or




in progress at plants of Ford Motor Company,  more GM plants, Budd Company,




Marathon Oil and others.







Recent efforts of the industrial waste control team have been directed toward pretreatment




of oiL  Greater emphasis  in the future  will be placed on preventing cyanides,  chromium




and other heavy metal wastes from entering the system.







The Department has urged that other pollutants as well should be kept out of the sewer




system -- street cleaning rather than waiting for rains to wash leaves, dirt and grit into




our sewers would result in a net   savings to the city, for example.







Although some detergent manufacturers have announced sale of low-phosphate or




phosphate-free products in the near future, we feel that action is necessary at the Federal




and State levels to encourage this trend.  Detroit Common Council recently urged the State




to legislate a phosphate limit of 10 to 15 percent in detergent products sold in Michigan,
                                       -  7  -

-------
                                                                            454






Regarding a pollutant of immediate regional concern, sampling of our raw water shows




no native mercury,  and if there were some,  our treatment process would take care of it. ,







Our testing procedures, supported by Michigan Public Health Department and the Federal




Water Quality Administration, are accurate to two  parts per billion.  Our Sewage Plant




effluent likewise shows no mercury.









V.  PROGRAM  COSTS





Transmitted by our letter of June 3 is a copy of "Engineering Division Monthly Report --




Status of Contract Work Ending April 30, 1970. "  That report lists pollution control




program construction contracts totaling nearly $71 million.  Total cost of the work is




$74 million including engineering and contingencies.  Not listed is an additional $3 million




spent for treatment plant site acquisition.






Work programmed for construction starts this year are as follows:




        PC I-15    15-Mile Road Interceptor




        PC-231   Primary Influent Sampling




        PCI-10A  Oakland Arm - - Section III A




        PCI-10B  Oakland Arm --Section IIIB




        PC-239   Connecting Interceptors and Control Facilities





                  SUBTOTAL (including engineering and contingencies)   $  9, 900?000





        PC-222   Four Final Tanks




        PC-233   Aeration Module I




        PC-234   Intermediate Pumping Units

-------
                                                                             455





 Construction Starts  This  Year  --  Continued





         PC-23 5   Blower Units




         PC-23 6   Transformers




         PC-23 7   Switchgear




         PC-243   Avon-Dequindre Control Facility




         PC-244   Oil Storage Relocation




         PC-245   Scum Disposal and Incineration




         PC-246   Sludge  Filtration and Incineration




         PCI-12    Romeo Arm --Section I




                  SUBTOTAL (including engineering and contingencies)   $80,000,000





                  TOTAL cost of contracts to be awarded in 1970 	  $89, 900,000





Work programmed for construction starts in 1971 through 1974 has been estimated to




cost approximately $290 million.









VI.  FINANCING





Inflation is crunching us between our pollution control program commitments and our




ability to finance them.  The cost of our interceptor construction and the first phase of




upgrading our treatment plant was originally estimated at $104 million.  For the past




couple of years we have planned to spend about $159 million for approximately the same




work, but as  of now,  the cost of the work has risen to about $180 - 200 million, and our




financing for  the two  years' worth of work remains locked in at about  $159 million.




Something has to give in  that kind of situation,  and the only source that hasn't  given




much to date is the  Federal Government.






                                       - 9  -

-------
                                                                              456
Again, we must question the sincerity of the Federal Government's war on pollution in
light of legislation providing Federal funds for 55 percent of our projects when it has
actually provided only 5 percent or less.

The Government is getting good at calling attention to water pollution problems.   But
one of the biggest water pollution problems of 1970 appears to include those responsible
for our national priorities and specifically,  those who propose that the Government can
accomplish  $10 billion worth of pollution control with an expenditure of $4 billion.

That kind of seed money doesn't go very far, as Michigan has found out.  Voters of this
state approved a $335 million clean-water bond issue in November,  1968,  after they  were
told that the $335 million could seed four times that much in statewide pollution control
projects --hinging on Federal grants ranging from 30 - 55 percent.  With state and local
funds now required to "prefinance" the absent Federal money,  both state and local funds
are running short.

On May 12,  1970P  we paid an all-time high interest rate of 7. 78 percent on a sewer bond
issue of $24 million.   The total interest cost on the bond issue will be about  $44 million.
If our bonds had been sold in 1968;, the interest rate would have been about 5 percent,,  at
a savings in interest cost of about $15 million.

What  is  ironic is that  $20 million of the $24 million was to  pick up the  financing for
the Federal Government.

Are we on schedule?  We are,  although the program  is not.  Our pollution control construc-
tion program ultimately has been scheduled by the availability of Federal and State funds,
and shortfalls and delays in these funds have produced corresponding delays in our construc-
tion program.
                                       - 10  -

-------
                                                                             457
In summary  then  Detroit this year is building $164 million worth of improvements to

its interceptor and treatment systems,  and the programs going on now are bigger and

bolder than those in any other population center on the Great Lakes,


We have recognized the problem of stormwater  overflows and we're building up the

knowledge and expertise we will need to solve them in the most expeditious  and

economical manner.


But, we're beginning to be concerned now with how to finance the 1971 -1974 construction

phase.  Due to the lack of Federal funds  in the  last two years,  there will be no State

funds  to help us out  and if recent Federal announcements are any guide,  no more than

a dribble of Federal funds will be available.


That  1971 -1974 construction phase is vital  if we're to solidify the  benefits from the

present construction.



                                               Respectfully submitted.
                                               G, Remus
                                               General Manager
                                       -  11  -

-------
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-------
                                                                   466
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-------
                                                        468




                        G. J. Remus






          MR. REMUS:  I would like to get the Federal record




corrected once and for all that this is not Detroit system.




It is Metropolitan Detroit system.  And it creates very much




of a misunderstanding,when each time it is referred to as




Detroit,when actually this is Detroit and 54 communities that




are now on the system with construction going forth for an




additional 15 and negotiations under serious consideration




for an additional 12.  We are providing service now for




better than 40 percent of the State's population, and it is




increasing.  And my discussion here is to hope to point




out the merits of a metropolitan area operation as it per-




tains to the overall.




          I should point out that in trying to satisfy your




honorable conference here, that is only one of 253 autonomous




units of government that we deal with.  Saying that politely,




that is too damn much government.  But we, therefore, have



difficulties in the acceptance of this type of program.




          I raise that question because it seems to me that




our plea here today is to get help from you people rather




than establish that things aren't as good as they should be,




which we heartily agree with.  But there aren't many things




you could do that would help expedite these programs.




          I will briefly go over the report, and then I




will refer to some of the factors that I think need to be

-------
                                                      469




                        G.  J.  Remus






emphasized.




          In 1966, as a matter of part of your record already




existing, the city of Detroit underwrote an area program and




signed a formal contract with the Water Resources Commission




of the State of Michigan whereby they agreed to do the area




job.  The map which went with that is on the wall.  The con-




tract is in here.  The stipulations are part of this report.




It is a part of your record at past meetings, anybody who




wants a report, drop us a note, we will send them a copy.




          In there, we say how the contracts will be pre-




pared, how the rates will be set and how the relationships




will be developed.  Obviously, we are in a kind of a no-man




or no-law area because development in the suburbs does not




take place until you have water supply and potential for




pollution control.  And until that happens, you have no basic




government with much of any financial capability to do the




job themselves.




          Obviously, the area job as the correct answer




has been recognized by 15 different studies made — Federal,




State and local.  And we know of none other than one or two




engineering reports where the consultants said to do it




locally.  Of course, they did the design for the local con-




struction.




          I think that just briefly following the various

-------
                                                      470




                        G.  J.  Remus






paragraphs in the report, we did not get a clearance on




the State grant account to execute this program until the




first part of December 1969.  In that month, we allocated




$74 million worth of construction.  Designs had been pre-




pared over the years past awaiting operation.  We are pre-




pared to put $90 million worth of construction under way




this year.




          The pictures that you find in the exhibits are




the ones that are existent.  And if you people had time,




I would like to have you go out to our sewage treatment




plant and show you the 27 acres, 301 families that we moved,




the heavy construction that is going on there and that for




the first time, we are now doing what has to be done.  We




are doing the construction rather than the conference.




          We have brief statements in here relative to




where we are or what we are about to do with each of the



packers.




          As was mentioned — I don't know which one of



the Federal people mentioned it — relative to the phosphate




removal, we think we have that under control.  We have met




that which we said we would do.




          I would like to point out one correction.  There




was some reference to 650 million gallons of sewage.  Today




we are treating in excess of 750 million.

-------
                                                       471




                        G.  J.  Remus






          On the bacteria coliform situation relative to the




Detroit River, we did agree to 1,000 value as far as our




sewage plant effluent is concerned.  We have attained 1,000




as far as the Detroit River is concerned.   There is no mis-




understanding about that.  But charts clearly show that if




you take a median value of the Detroit River before you




include the Rouge River flow that we do meet the 1,000




median value.  And we will have 1,000 in our sewage plant




effluent count as soon as our activated slip section of the




plant is in operation.




          As you know, we placed in service within a year's




time a pilot station that was of a size equivalent to a




community of 2,700 people.  And some of the things that we




are doing, we have documented pretty well.  And we are quite




sure of the results we will get.



          We are using part of our plant improvement as far



as biological treatment is concerned.  We have decided to



use oxygen for a variety of reasons for a portion of it.  And




hopefully, if it works out as successfully as we think it




will, it will be used for all.




          The reason for that is, of course, it takes less



space, less initial capital investment.  And after we get




our own plant as far as oxygen compression is concerned, we




would be getting less operating cost.

-------
                                                       472




                        G.  J.  Remus






          We have about $60 million committed,  $40 million,




roughly, is under construction, for an interceptor on the




Clinton Valley.  We would like to point out that is the area




up here in Macomb County and Oakland County, the yellow area,




          The red is the area Detroit will prepare and have




under contract.




          This section of blue will be awarded within the .




next month.




          The red up in Oakland County is being prepared




by Oakland County and is under construction.




          While I am on this,  I would like to just briefly




point to one of the comments that was made relative to




Selfridge Field.  When Detroit's facilities are available,




all they have to do is sign a contract, and it might be




available.  But I would like to point out that we have for-




merly contracted with Macomb County to build up to Mount



Clemens.  Selfridge Field is over here 5 or 6 miles away.




I think this illustrates the typical situation we run into.




Let Detroit do it.  We will use them as an alibi.  And that




is what has gone on up here.




          While I am on it, I would like to talk about




Mount Clemens.  Mount Clemens was included in the ban that




existed in lower Macomb County several years ago.  And it




was lifted when we signed a contract with Macomb County.

-------
                                                      473




                        G.  J.  Remus






          Now, in this interceptor construction,  we agreed




to provide service for Mount Clemens.   Mount Clemens has




agreed they would have an engineering  study made  which they




did.  And about 2 weeks ago, their study came in  and said,




"You should join the Detroit system."   Within the week,




they had hired another set of engineers.  And within that




same week, we already knew the conclusion was going to be




the opposite.




          Now, it is those type of things that we think




there has to be pressure put on to either do it or not do




it.  But I don't think that we should  be committing $169




or $159 million worth of construction  and then be badgered




with that type of stuff.




          I would like to point out while we are  in this




same area that we are building through the city of Warren




a 12-foot sewer.  That sewer is big enough to take care of




Warren's requirements as per our contract with Macomb County.




We are going to holler from here to kingdom come  if they




should suddenly get a grant because we are building that




property through there at their request.  And we  did it




when they had a building ban.  And we  corrected it after-




wards.




          I would like to point out, and I will refer to




that later, that Warren has now challenged the State and

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                                                       474




                        G. J. Remus






Federal Government on their grant program.   And if they




should win, I would point out that that is  probably the last




intercept that the central system will build.   Because if




we cannot depend on our revenues, we cannot build for the




future.




          This interceptor situation, of course, is paid




for entirely by the revenues we expected to collect and by




the revenue bonds we issued for our portion of the construc-




tion.




          I would like to refer to a part of this problem




which is not in our stipulations.  But by the very nature




of the fact that we commit our money to where we get the




best results, we have gotten deeply involved with the storm-




flow as it is now.  I will use one example.  On May 25 this




year, we had an average rainfall of .47 of  an inch over the




city of Detroit that lasted for 45 minutes.  And the inten-



sity was as much as .95 of an inch.  All of that was treated.




If it had not been, there would have been a large tonnage



going to BOD and solids going to the Detroit River.




          In doing this, it cost us considerable extra




money in our operations because we pump our system which is




made up of several 16-foot tunnels, two 12  by 17 foot




channels.  And we keep it empty, particularly just prior to




a storm.  And we have just recently put in  operation a

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                                                       475




                        G.  J.  Remus






monitoring and telemetering system data logger which the




Federal Government helped pay  for — roughly 50-50 — wherein




we have 138 sensor units throughout the city that give us




sewer levels, storm intensity, the rapidity with which it




goes across the city.  And we  think for the first time that




we are beginning to make some  real progress with this




stormflow.




          I mention this because I don't see how we can put




in an activated sludge plant with all the construction at




the sewage plant without also  going at this stormflow




system.  We expect to expand that to the area.  And in that




way, we will be able to know when a storm comes in from




Toledo to Lansing and Flint and Ontario and the whole area.




          There is a part of our operations that, again, is



not reflected in the stipulations.  And that is what we call



pollution prevention.  Mr. Kallin of Ford Motor Company only




talks about those things that they are under the gun on.  He



forgot to mention that we are  taking a good slice of his




problem up in Sterling Township and taking care of it for




him as we are for General Motors, as we are for Chrysler.




          Of particular importance is the fact that in the




area that we serve, the Clinton River down to the Rouge




River, there is no industry in the white or yellow area that




discharges into the Detroit River or into the receiving

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                                                       476




                        G. J.  Remus






waters.  All their waste goes  through the public system.




We do the job for them to the  extent that our system can




handle their wastes.  We have  the proper ordinances, and




we have about 6 men working on it all the time, to work




cooperatively with industry to get our system in such a




shape that we can handle our wastes.  And if we can't, they




have to put them in a preparatory position so they can be




handled.




          Some of the principal ones, one that isn't men-




tioned in the report, is Scott Paper Company.  And, of




course, that isn't under the gun right now.  But that plant




was right across from our sewage plant.  On the basis of




the orders given it, it would  have had to shut down if we




hadn't worked out a program with them because they had no




space to build facilities.  They are paying us today on the




basis of the extra wastes we treat for them a little better




than $580 a day.  And it was with the cooperative effort




with them because they felt it was important.




          There are plenty of  examples of what I think has




to have a great deal of pressure.  And that is pollution




prevention, partly to control  what comes into our system,




partly — somebody referred to salt.  Last year, there were




406 million pounds of salt in  the metropolitan area dumped




on the streets.

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                                                       477




                        G.  J.  Remus






          Now, I hear some  conversation it doesn't do any




harm.  Are we going to wait until the mess is here and




then clean it up?  If we are going to do that, people that




are in our type of job will be forever under the lash of




somebody.  Because if we are going to wait until these




messes are created, then you are never going to clean them




up.




          We have the same  comments on other heavy metal




wastes, on detergents.  We  think that a better job could be




done there.  Our common counsel has adopted a ruling to ask




the State to adopt the law asking that not more than 10




percent phosphate be allowed on the market.




          Now, if you are referring to page 8, you will see




what construction would be done by the $90 million that I




have referred to.  I would like, however, to talk a little



bit about the money, the financing.




          On the basic $80 million that we have, we ordered



$74 million of contract.  But on the basis of the $80 million




that was scheduled — and the last part of it will be awarded




this month — the Federal Government should have provided




$44 million.  The State should have provided $20 million.




And we should have provided $20 million.  That is on the




basis of the law that is on the land.




          Since the Federal appropriations were not financed,

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                                                           478

                         G.  J.  Remus


it developed that our system provided $40 million and that

the State provided $40 million and the Federal people pro-

vided $4 million.  The State prefinanced $20 million for

the Federal people, and our operations prefinanced $20

million for the Federal people.  If you were in my place/

you would make as nasty a remark as you could about this.

And I am going to do the best I can.

          It makes you so damn mad that of the $24 million

that we had to issue bonds on this last week, we paid 7.78

percent interest, far more than we ever paid before.  And
                                                      /
$20 million of that was financing what the Federal people

have committed us to.  And if that is going to continue, you

have broken the back of this type of an operation because we

do not have the tax base or the metropolitan area available

to us.  We have only revenue bond financing.

          In fact, the Federal portion of the grants we

have received are like pulling backwards when you are going

forwards because they haven't even kept up with inflationary

factors.

          Further, the State has to continue to prefinance

a portion of the Federal.  It's obvious their program will

break down because $335 million for 25 percent of the job

wasn't enough.  And if it has to now go to 50 percent of the

job, obviously the whole program is in jeopardy.

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                                                       479




                        G.  J.  Remus






          I have briefly commented on the fact that we  have




reduced our B.  coli,  that we have reduced our  oils,  we  have




reduced and have under good control  bacterial  kill.   But we




have in addition to that a considerable effort to exercise




as far as BOD and solid removal is concerned.




          I have also pointed out, and I as a  representative




of our department, and I as representative of  the area, that




part of this program that was late was because of the Detroit




metropolitan efforts.  We could not get clearances on finan-




cing.  And the delays that we are now faced with are




entirely because of that.  And our stipulations, even though




some of the charts in the report do not show it exactly,




will be met in 1972 if you will give us credit for the




extra BOD and solid loadings that we take on because of our




improved method of handling stormflows.




          Now, before I answer questions, I would like to




comment on a few things.  There has been a lot of discus-




sion about the 180-day situation.  Well, if the purpose is




to help us, that will not be applied for this reason that




we already have a lawsuit by the city of Warren.  Add that




to it, and you probably are putting us in a position where




our bond financing people will say,  "Hey, wait until every-




thing is cleared up before you issue bonds."




          If we don't say it, the investors will say it

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                                                       480




                        G. J. Remus






because they will say, "That is a kind of a flimsy opera-




tion out there, and we are not going to loan money to them."




And that is particularly serious in this type of operation.




          I would like to say also that —  Well, to finish




that sentence, the Mayor of Detroit, the City Clerk who




represents the Common Council, the City Comptroller, have




to sign a stipulation saying that there is no lawsuit or




potential lawsuit before we can issue bonds.  And if we




have all kinds of Federal and questionable legal positions




to contend with, we will not get those clearances.




          Now, I would like to bring out another thing.




That is the reason I referred earlier to the business that




this is a metropolitan operation, the city of Detroit being




responsible for the execution thereof.  This program has




now been approved by four mayors since 1957 when it was




adopted.  The Common Council has continually re-endorsed




the program and approved the bonds and so forth.  But most




certainly, if the progress that we are making now gets the




impression that it isn't good enough, you are hurting our




support toward the solution of this program.  If you apply




180 days and divide it up, give us about 10, give a few to




the State and the rest to the Federal Government for the




delay proportionate, we are not going to argue for it.




Actually, it would delay or confuse our program a great deal,

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                                                       481




                        G.  J.  Remus






          And I would like  to  just briefly —  and I have a




brief report here on a water supply thing or the contracts




we have awarded — to refer to this because I  believe there




has been very little said on two parts of this program that




are necessary outside of the stipulations that must be




qualified for before you can construct in a sewage effort.




And one is water supply.




          If you examine this  effort here which shows our




sister, the plant at Lake Huron, under operation, you look




in the report and you will  see there is about $80 million




of contracts under way and another $60 or $70 million will




be awarded this calendar year.  If you are going to adopt




an area program which the Federal people have and the States,




if that is going to be expedited, you cannot make it work




unless you first put water into those areas.  This is a very



important part of this issue.



          Take the Clinton Valley, for instance.  There is



only about 160 gallons of flow in that stream per person as




it now looks, to say nothing about the development of the




future.  And under those kind of conditions, unless you




reinforce that, you have either got a basic decision to make




that the Clinton River will be a sewer, or it will be a




stream.  But you have to have water supply go into all the




areas that are served before you can take the water out.

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                                                      482




                        G.  J.  Remus






          A second part that seems to me must be dwelled




on a great deal, the Clinton River is an example of it, but




our department has been designated by the city of Detroit




as the area agency for stormflow control.  And I would like




to refer to the Rouge River.




          To take Ford out of the Rouge River or anyone




else and allow the same thing to develop further up in the




county is an exercise in frustration.  And that is what is




happening.  There are no means available today to relieve




the Ford.  We are working on it.  We have now the basic




organization.  But until you also have a basic program




working whereby the streams will be protected where develop-




ment yet has not taken place,  you are just postponing or




transferring your agony from one place to another.




          And I think those two points need to be worked




out simultaneously before you put an area pollution control



program into action.




          Now, I have covered a lot of points here, some of



them rather rapidly.  I basically summarize it by saying that




we have now $74 million worth of construction under way.  We




invite you to come out and see that operation.  We are proud




of it.  We have $90 million worth of work ready to award or




mostly ready to award and are waiting for the O.K.s on the




grants which, Mr. Purdy, I think we will get in July to

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                                                        483




                         G.  J.  Remus






start awarding those construction projects  that  are  listed




in our report.  But the other  supplemental  work  of water




supply and stormflow rationalization  has  to be put into




action also.  And we are working on that.




          Thank you.




          MR. STEIN:  Thank  you, Mr.  Remus, for  a very




excellent statement.




          Gerry, I think as  I  am getting  older/  I am




mellowing, but I am glad to  see you are still holding out,




          MR. REMUS:  I want to commend you because  I didn't




hear anything about sophisticated wastes  or exotic wastes




or pristine clear in this conference, which seem to  me  is




all I heard about 3 or 4 years ago.  I don't know yet what




pristine clear is.




          MR. STEIN:  There  you are.   You know,  these are




classical references, Gerry.




          I always thought that Jefferson said it better




about the government years ago when he said, "That government




is best that governs least."  But I figured I had to come




here and listen to you improve on that when you  said we  have




"...too damn much government."




          Are there any comments?




          MR. MAYO:  I have  several comments, Mr. Chairman,




          First, I would like  to thank Mr.  Remus for

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                                                       484




                        G. J. Remus






providing us very recently with a very detailed breakdown




on the construction program that has been requested from




the Regional Office,and for appending or making a part of




that breakdown essentially a schedule of compliance/or




apparently a schedule of compliance with the stipulations.




And we have got a few questions that we would like to ask




about the apparent dates at which certain levels of waste-




water treatment improvement could be accommodated.  And I




would like to just go through some of the specific stipula-




tion items.




          As we interpret the information you provided to




us, Mr. Remus, the current stipulation calls for a BOD load




in the discharge of 412,000 pounds per day if not more than




that.




          Or, rather, 250 pounds per day.  Excuse me.




          In reviewing the information that you provided




to us, you would get down to approximately 262,000 pounds




per day by August or September of 1973.  If we interpret




the dates that you have attached —




          MR. REMUS:   I think that was shown in the curves,




yes.




          MR. MAYO:  As we understand the basic date for




the current stipulation — perhaps Mr. Purdy can correct




or confirm this — we are talking about November 1972.  Is

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                                                       485




                        G.  J.  Remus






that correct?




          MR. REMUS:  That's correct.   And I commented on




that a little bit.  And I would like to  reemphasize it.   As




we start working this problem out,  obviously some of the




factors we agreed to in the contract for 1966 have taken  a




little different form.  If  you will take the construction




that we have complete in 1972, which is contracts that will




be awarded this calendar year, with what is already under




construction and give us some credit for the job that we  are




not required to do by law on the loading as far as BOD and




solids are concerned and the stormflow, we will be doing




better in the sum total picture.




          MR. MAYO:  My query wasn't intended to be critical.




I want to make sure that we are interpreting the information.




          MR. REMUS:  That's correct.   I didn't take it that




way.  I think it is very important because of the fact of




the definition of our job which is to get the best value  for




the dollar you can get ahold of.  It required we had to take




a crack at this and get what we call the first flush of the




storm which isn't really a  good definition, but which illus-




trates that we had to capture a lot of the dirt that lies




in our combined sewer system if we weren't going to flood




out our plant any time we had a storm.




          MR. MAYO:  Just to follow through with the identi-

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                                                       486




                        G.  J.  Remus






fication items, the stipulation would provide for not more




than 50 milligrams per liter or what would seem not more




than 452,000 pounds per day of suspended solids.




           MR. REMUS:  Correct.




          MR. MAYO:  And you would reach that level approxi-




mately January 1975?




          MR. REMUS:  That's correct.  Andf again, I have




to take credit for the opposite of this picture.   I think




if we take the total catalog and inventory what we are doing,




we are taking the solids out.   It is unfortunate that we did




not look at it in the total picture when we signed this con-




tract because that is only  one arm of the total problem.




          MR. MAYO:  With respect to phenols, the stipula-




tion provides for not to exceed 115 pounds per day.  The




information that you provided to us was in terms of percent




of effluent.  And I would appreciate it if you would make




some translation for us between the percent of effluent if




you can get that down into  pounds per day at some place.




          MR. REMUS:  Well, originally, I think the contract




I have here said 95 pounds  per day.  Now, on that, I am




having considerable amount of trouble.  And we do not figure




that factor is realistic.  We have talked some to the water




research officials on that.  To put ourselves in a way of




analyzing it is to point out that the 93 pounds applied to

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                                                      487




                        G.  J.  Remus






Detroit with 57 communities we have  under contract with all




their industry, all their commercial establishment and the




Ford Motor plant in itself  has got 70 pounds,  I think there




is some unrealistic figuring here.  We had hoped that this




would in a normal sequence  of events take care of itself




as this construction went forward.




          To keep ourselves on a reasonable basis there,




our agreement with the Ford Motor Company was  if we could




get it down to acceptable standards, we would  accept their




portion of their waste.  If we couldn't, of course, they




would have to provide for it themselves.  And  we are in that




study area now.




          We think we will approach it, but 93 pounds is




a pretty unrealistic figure when you consider  the type of




load we have.




          MR. MAYO:  As I understand the later stipulation,




at least the figure you provided us with was 115 pounds per




day.




          MR. REMUS:  That probably took advantage of the




Ford slice that they have turned over to us.




          MR. HARLOW:  I think, Gerry, there was 22 addi-




tional panels added to the 93 for the north interceptor.




          MR. REMUS:  I don't remember how that was arrived




at.  Raise it to about 300 pounds, and we have got it made.

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                                                       488




                        G. J.  Remus






What do you say?




          (Laughter.)




          MR. MAYO:  Do you want to roll the dice a couple




of times?




          MR. STEIN:  Well, I  tell you, you are up to 7




what in your interest?  What is your percent rate on your




interest?




          MR. REMUS:  7.78.




          MR. STEIN:  You are  going to have a lot of law-




suits to scare me off buying those.  But why don't you




raise that bond figure?  It looks real attractive.




          MR. REMUS:  Those are tax free, too.  That




should interest you.




          MR. MAYO:  Could you provide for us some infor-




mation on what the pounds per  day of phenol in the discharge




are at the present time?




          MR. REMUS:  It is too high.  It is somewhere in




the range of about 1,200 pounds a day.




          What were those figures you gave me this morning?




          DR. SHANNON:  This year, it was 1,700.  The




average this year was 1,700.  Before, it was 1,500.




          MR. REMUS:  It is too high.  It is 1,500 or 1,700.




          MR. MAYO:  As we would interpret the projection




of information that you have given, you would get down to

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                                                       489




                        G.  J.  Remus






the range of the 70 percent reduction over the effluent




until sometime about 1975.




          MR. REMUS:  Well, I  don't think I am prepared to




answer that.  I would think, however, that we would have




the proof to that in the next  couple of months pretty




directly or at least when the  construction we have now under




way is under way.  The way we have resolved or are going to




resolve the problem as far as  we are concerned is that we




can't get this down to acceptable poundage.  When we get




our 1972 construction complete and in operation, then we




will go to the pollution prevention aspects of it, one being




the Ford Motor Company, saying, "We can't handle your phenols."




That will take one portion out of here.




          We will go to the industries and to the people




that we serve so that at the input side, we will start




reducing that.  But I do not see that we can justify millions




of dollars just to put a phenol reduction plant in there.




I think it has to be attacked  at its source.




          MR. MAYO:  Do you feel it would be practical to




take this approach of essentially pretreatment at the point




of discharge from the industrial constrictors of phenol




waste at a much earlier date than that?  A lot of your basic




program places that burden on the discharger rather than the




metropolitan system.

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                                                       490




                        G.  J.  Remus






          MR. REMUS:  We are doing that as I related.  I




think it is 488 industries we have met with to ask them for




what they are putting in.  Our monitoring system is being




designed so we can keep checks on what is coming in.  And I




think that by attacking it at both points, we can get that




down to a couple of hundred pounds where we ought to be, at




least.




          MR. MAYO:  Do you have any time frame that you




would suggest that might be accomplished?




          MR. REMUS:  Well, last month, wasn't the figure,




Mr. Shannon, 1,200 pounds we had in February and March?




          MR. SHANNON:  Yes.




          MR. REMUS:  We have knocked some of it out already




as we have on the oil by going to the source of the problem.




We have not attacked the problem yet from a standpoint of




the suburbs as energetically as we should, but will for the




reason that our contracts   provide control.  But the




ordinance does not define that precisely.  But many of the




suburbs, of course, are sending in, since we are wholesalers




through our master meetings, wastes that we don't think they




should be sending to us.  So by attacking both within




Detroit and the suburbs against discharge, I think we can




meet that standard.




          And I would think that gradually here in the next

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                                                       491




                        G.  J.  Remus






months, we will be bringing that down.




          MR. MAYO:  With respect to oil,  the stipulation




requires that there be not more than 15 milligrams per liter.




Your projection would indicate that you would reach that




level of treatment at about January 1975.




          MR. REMUS:  Unless we can do a better projection




job.  I think Mr. Balden of Chrysler gave you a little run-




down in the development of his facility.  I think that is a




good illustration on the proper way to go at this in that




when they were ready to build their plant addition, their




improvement for treatment, they came to us.  And we ran




quite a few tests to establish which was best.  And we took




wastes from them that we could handle.  It saved them quite




a lot of money, and it improved our revenue picture.




          So the 1975 data, I think if you add it to the




credits that we should have because of other things, we have




done well and really have obtained that goal sooner.




          MR. MAYO:  Is there much of an opportunity that




you could pass the responsibility for oil removal back onto




the original discharger as distinguished from the district




assuming the responsibility?




          MR. REMUS:  There is no doubt that we can hand it




back to the suburbs because we can check whether their waste




comes into our system — at least most of them.  In Detroit

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                                                       492




                        G. J.  Remus






that gets to be quite a hide-and-seek game.




          I don't think I better say any more about that.




          MR. MAYO:  I think that is a problem that is




characteristic of every one of the older metropolitan cities.




          MR. PURDY:  Mr. Chairman, I think an example of




what is taking place in this area is the fact that Detroit




had as a consultant to them the late Hayes Black and have




instituted a sampling program on their sewer system.  And




as Mr. Remus pointed out earlier in his discussion, he has




some 6 people that devote their full time to this particular




activity.  And I think it is not something that will ever




cease.  This will be a continuing activity that will have to




go on from now as long as the Detroit Water Board operates




a metropolitan system.




          MR. REMUS:  I am sure that is 100 percent true.




          I would like to point out also that in the reduc-




tions we made on bacteria, on oils and on phosphates and




even the BOD and solids loading having stayed where they




are, is quite some accomplishment in light of the rapid




expansion that has taken place in the Detroit metropolitan




area.  So this has all been accomplished, not as well as




we would like, but it did not restrict development in any




way.




          MR. MAYO:  With respect to the phosphate loading,




the stipulation provides for 80 percent removal of soluble

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                                                       493




                        G.  J.  Remus






phosphate and not to exceed 26,000 pounds per day.




          We note in extending your schedule here that you




would get down below the 26,000 pounds per day in 1971, but




that the 80 percent removal would not be achieved even by




1975 or 1976.




          MR. REMUS:  Well, the way our system operates, I




don't know how you can use the term 80 percent.  I think we




would have to use the basis of what we discharge to the




river.  We have been as low as 7,000 pounds on ortho and




5,000, some days not any.  And the reason for that is that




we have accepted even sulfide wastes from a steel pickling




industry in small amounts if they neutralize it first.  We




have allowed the steel industry to put their wastes in




within our system.  So that total phosphate that comes into




our system is not really known because part of that reduc-




tion process takes place in the system.  And we would rather




that we use a figure of so many pounds that we would be




allowed to discharge.  And that way we don't have to do the




wonderment about what is happening in our system.




          To further emphasize that, when the steel mills




went on strike and they dumped their vats, we had no phos-




phate at all.  So I think it would be a very hard thing to




use 80 percent factor there.




          We have another factor that we refer to in our

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                                                       494




                        G. J. Remus






contract.  We refer to ortho phosphate.  And, of course,




that is one of the improvements we think should be made in




the contract.  We have informally discussed this with the




Water Resources Commission and found no objections to making




that solid.




          MR. PURDY:  I think you stated to this conference,




Mr. Remus, you are looking at total phosphates.




          MR. REMUS:  That's correct.  We are looking at the




total figure even though the total contract is still in the




original form.




          MR. MAYO:  That was a point I wanted to raise with




Mr. Purdy because what the conference recommends with regard




to phosphate removal is in terms of total phosphate as dis-




tinguished from the terminology soluble phosphate that you




have used in making your projection.




          MR. REMUS:  Well, of course, when we signed this




contract in 1966, we had very little information as to what




really was going to happen anywhere.  I think that to clear




the record and make the record secure, we are talking total




phosphate in our program.




          MR. MAYO:  As far as Michigan is concerned.




          MR. PURDY:  There is no disagreement.  Mr. Remus




has made this commitment to the conferees several times.




And we are in agreement with it.  This is what we are looking

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                                                       495




                        G. J. Remus






at.  There is no disagreement on it.




           MR. STEIN:  Are there any more questions or




comments?




          MR. LYON:  Mr. Remus, do you have any idea how




many treatment plants other than your own exist in that




area on the map there?




          MR. REMUS:  There were quite a few little ones.




In your report there, it shows a small section of this map,




and you will see a bunch of little plants identified on




there that were eliminated or are in the process of being




eliminated.




          MR. LYON:  So there are really very few left now?




          MR. REMUS:  That is correct.  The only two that




are in discussion in this whole Macomb area are the city of




Warren who have challenged a grant program and the city of




Mount Clemens who saved money by running from one engineer-




ing consultant to another.




          I hope somebody from Mount Clemens is here.  I




wouldn't want that to be wasted.




          MR. LYON:  The reason I asked this question, Mr.




Chairman, is because I think Mr. Remus and his organization




and municipalities and industries in this area should really




get a huge amount of credit and congratulations for the




outstanding job that they have done in developing this kind

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                                                       496




                        G. J. Remus






of system in the Detroit area.  It is something that is




going to save the industries and the municipalities and tax-




payers in this area large amounts of money, including Federal




grants and State grants and so forth.




          I wish I could say that we had similar systems in




Pennsylvania.  We recently made a study in the area on Pitts-




burgh and North Pittsburgh in a 50-mile radius of Butler,




Pennsylvania.  We found, believe it or not, 950 sewage treat-




ment plants, industrial waste treatment plants, and drainage




treatment plants.  And as you can imagine, the diseconomies,




the costs, in that kind of fragmentation are almost incredible,




And it really shows a very fine accomplishment that has been




attained here both in saving tax dollars for the citizens




and helping to clean up Lake Erie.




          MR. STEIN:  Well, we have that prefinancing prob-




lem.  And as you know, I have tried in previous conferences




and in public statements for the Federal Government to give




Mr. Remus credit, but he always answers he wants cash.




          (Laughter.)




          MR. REMUS:  I would like to keep before you the




overall program.  And that is, if the Clinton Valley clean-




up, which is a tributary to Lake St. Clair and the Detroit




River, can be held together with the type of construction we




are doing and systematically, the Rouge and the Huron will

-------
                                                       497




                        G.  J.  Remus






come under the same type of improvement.   If we try to do it




all in one big glob, it will break because there won't be




that kind of money available.   But there  is a systematic way




of doing it.




          We did it with water supply when we laid that pro-




gram out.  We presented a program of $172 million.  And




pretty near everybody fainted.  And if everybody had approved




it right away, I would have fainted.  But the fact remains




that it was approved.  We did construct systematically.




          We expected $172 million worth  of construction to




carry us to 1985.  As a matter of fact, it only took us to




1966 from 1959.  And we were able by that process to develop




enough revenue base so that since that time we have spent at




least another $175 million.




          The same thing can happen here  if we do it in an




orderly way for the entire area.




          MR. MAYO:  In Mr. Purdy's summary with respect to




the Detroit system and in your summary of construction




information, you both used the terminology"advanced treat-




ment. "




          MR. REMUS:  I would like to answer that because I




am having fits about this business of what concentrated




activated sludge is — I didn't mean it that way, but that




is how it came out — or secondary treatment or tertiary

-------
                                                       498




                         G.  J.  Remus






treatment.  Our treatment is made up of oxygenation and the




use of chemical treatment to the extent that it is  necessary




in combination to take care  of both the organic and inorganic




waste.  And I call it "advanced treatment."  And I  don't have




to get all hooked up trying  to explain in front of  various




groups what so and so meant  and what so and so meant.




          MR. STEIN:  Let me make a comment on-that because




I think it may save time all around.  I think maybe you




don't like this term that I  used before, possibly — "sophis-




ticated."  But I think as our treatment is getting  more and




more sophisticated and we are dealing with the things  you




are talking about here, the  sooner we stop using the terms




"primary," "secondary," "tertiary," "advanced treatment," and




the more we describe these in the terms which you have attempted




to describe them — the things you tried to get out, the pounds




per day you are trying to remove, or if you can't do it in




pounds per day, possibly percentages, but hopefully pounds  —




I think we are going to be a lot better off.  Because  I have




found that even in terms such as "secondary treatment," it  may




mean something.  As you take such a term as "BOD,"  it  can




vary from 75 to 90 or 95 percent.  And that is quite a




spread.  You are not talking about the same thing.




          I do think, Mr. Remus, the kind of approach  you




have taken on these specifics -- and, by the way, we have

-------
                                                       499




                        G.  J.  Remus






gotten this from the industrial people representing Chrysler




and Ford on meaningful terms today, and that is generalized




terms.




          MR. REMUS:  I agree with that 100 percent because




there is so much confusion existent today about what we are




talking about.  They say,  "98 percent treatment.^  Wei]., you




can spend a week explaining that.




          MR. STEIN:  That's right.




          MR. MAYO:  It is our understanding, Mr. Remus, that




the current stipulation under which you are operating has a




completion date of the fall of 1970.




          MR. REMUS:  Right.




          MR. MAYO:  And that you presently have before the




Commission a request for an extension of that date or a sub-




sequent stipulation.  Is there any range of dates specifi-




cally being discussed?




          MR. REMUS:  If I had to do it over again, I would




never have sent that in because of this factor that all we




can do is as rapidly as we can get money do the construc-




tion.  We lost in awaiting financing and in clearing red




tape better than a year.  We do not think that should be




charged to us.  You add that to the November 1970 date, and




we are not very far out of step.




          These contracts that we have referred to, and we

-------
                                                      500




                        G. J. Remus






are not talking about plans or what we are going to do, this




was sufficient.  That is, this action will be completed in




1972, and I think you will see great improvement.




          MR. PURDY:  I would like to comment on that.   Mr.




Mayo, that request was placed before our Commission, and




the Commission recognized that any extension of time would




have to be a joint Federal decision and also a joint Federal-




Lake Erie conference decision.  The Commission did not act




upon it.  It instructed me to discuss this with the Federal




Water Quality Administration officials.  And at their




request, the Commission has delayed any action upon that




extension of time pending progress by the city of Detroit.




And that is where it lies at the moment.




          MR. REMUS:  I would want to emphasize that since




we have had clearances on the funds, I think the record




shows very clearly that a great many millions of dollars of




construction are underway.  And as soon as we get the next




clearance, another $90 million will be put into construction,




And it will be what it will be and where.  It is not satis-




tory to us, and it probably isn't to you people.  But never-




theless, the basic construction program is under way.




          When did we start?




          You know, I can't remember, and I have been here




41 years.  But in World War II, if you said something when

-------
                                                       501




                        ^G.  J.  Remus






the Federal Government came  in  and stopped automobile produc-




tion and started the airplane production about getting that




out of the sewers, you would have been unpatriotic.   And




that's really where the great amount of this deterioration




from the standpoint of keeping  up with the job occurred.




          MR. MAYO:  I have  one final question, Mr.  Remus.




In your schedule, you indicate  that as of November 1972,




approximately 400 MGD would  be  received in primary only and




the remaining 400 MGD would  be  received as you have identi-




fied as "advanced."




          MR. REMUS:  That has  been stepped up in that we




are referring to twice the capacity for half the amount on




oxygenation because you can  get more out of there.  So about




two-thirds of the total output  would be aerated/ all of it




would be treated with polymers  and chemical precipitation.




And I think we will meet those  standards that are on the




basis of data we have prepared.




          MR. MAYO:  You have indicated that all of the




approximate thousand MGD will receive what you have identi-




fied as advanced treatment by 1976.




          MR. REMUS:  That's correct.  And if you will refer




to the program we referred to,  that additional $280 million




worth of construction, that's what we are talking about.




That is not financed, however.   The $159 million is.  And

-------
                                                       502




                        G. J.  Remus






here I think the Federal people can help us a great deal




because by that time they will owe us $40 million on the




basis of the schedule we have got.  If we get that plus a




few other things, we will do the $280 million, too.




          MR. MAYO:  Thank you very much.




          MR. STEIN:  Any other comments or questions?




          (No response.)




          I admire your financing, and I am not going to




dispute it here about owing you $40 million.  I will try to




get you as much as I can.




          You know, I would like to join Mr. Lyon in saying




that I think that you certainly ought to be commended for




working out as effective a plan with your suburban communi-




ties as any I have known in the country, particularly when




you have had to go the hard way through negotiations.




          MR. REMUS:  Thank you.




          MR. STEIN:  In some of the places they put them




all together by State statute, and there is no way to go




but you have had to do it the hard way.  And I think this




is a problem we have all over.  And I think in my opinion,




there is no question that you have been more successful here




than we have anywhere else in dealing with that kind of




problem.




          Are there any other comments?

-------
                                                       503




                         G.  J.  Remus






          (No response.)




          Let me just tell you  a little bit because  I know




you get confused or everyone gets confused on this financing




and Federal operation.  But because we have had to consider




the city of Warren suing us as  well as you, maybe they  think




we are on the same side.   I don't know.  It is very  peculiar.




          I don't know if a representative of the city  of




Warren is here to hear this.  I don't want it to be  lost.




After they finally sued,  they came into Washington and  asked




for it again.




          And I know at least the way I have been brought up,




and I think you have been, Gerry, when someone sues  you and




they come around and ask for money, I don't know that the




welcome mat is out.  I don't quite understand that.




          I was going to say a little before we stopped this




on financing to give you an idea how this works.  I  was out




with three fellows the other day for  lunch in Washington.  And




after the check came, all these three people grabbed.   I




was sitting there quietly.  But they  all grabbed for the




check.  And each one had their hand over it.  And one fellow




said, "You better let me pick this check up."  He said, "You




know, I am in the 50 percent tax bracket.  It is going to




cost me 50 cents on the dollar."




          The other fellow said, "Heck, I am in the  90

-------
                                                       504




                        G.  J.  Remus






percent bracket.  It is only going to cost me a dime."  The




third fellow said, "You both better quit and give it to me.




I have a contract with the Government, and I am going to




make 6 percent."




          Thank you, Gerry.




          MR. REMUS:  No wonder you didn't reach for that




check.




          MR. STEIN:  I was in good company.




          Thank you, Gerry.




          MR. PURDY:  Well, Mr. Stein, we, of course, are




quite pleased and very proud of the accomplishments that




have been made in pollution control here in southeastern




Michigan through the regional system.  Significant progress




has been made.  There are places where there have been sig-




nificant delays, but you can see a program unfolding.




          Yesterday, in the Government's presentation, if



you remember, he came out strong for the regional systems.




And in his remarks, he did note that in dealing with these




many units of government in a regional system that this



required time and that there might be delays in unfolding




the system, delays that we would not like to see occur, but




in the long run if we gave time for the regional system to




develop that we would come out ahead in the future.  And so




this is the sort of program I think we see developing here

-------
                                                       505




                        H. S.  Liebert







in the southeast Michigan area.




          I have one other request to make a statement.   I




have been informed it is a short statement.  It is Mr.




Liebert, representative of the Downriver Antipollution




League,




          Mr. Liebert.






               STATEMENT OF HILLEL S. LIEBERT




               DOWNRIVER ANTIPOLLUTION LEAGUE




                    ANN ARBOR, MICHIGAN






          MR. LIEBERT:  Thank  you, gentlemen, for letting me




make my statement without any  advance warning.  I walked in




and asked to be able to do this, and lo and behold! I was




the next speaker.




          My name is Hillel Liebert.  I am a social worker




student in community practice  at the University of Michigan.




I have lived in southwest Detroit, and I have been asked by




the Downriver Antipollution League to make a few comments,  a




few statements, which mainly deal with process.  They don't




deal with the technical points,  and they don't deal with much




of the substance I am sure you have been talking about.




          I wasn't here yesterday.  I am not sure exactly




what has gone on.  I know mercury is a big issue here,  and




it is with us.  The Downriver  Antipollution League is made

-------
                                                       506




                       H. S. Liebert






up mostly of working people in the downriver cities.




Southwest Detroit is included, but River Rouge, Ecorse,




Wyandotte, Lincoln Park, and all the way down to Monroe is




where our members live.




          They couldn't be here today because many of them




are working.  We have heavy representation among UAW workers,




steel workers, and oil, chemical and atomic workers in that




area.




          Mainly, the statements deal with citizen partici-




pation.  And I jotted down a few notes.  We will see how




brief I can be.




          First of all, we feel citizen participation is




very important.  Back at school where social workers talk




to social workers, we have heard a great deal about the new




trend.  Citizen participation is in.  It is the thing.  But




when I come to hearings of the various enforcement officials,




bodies, when I see the newspaper headlines, when we speak




with officials and write to them and receive replies, we




find this is not really as in as we would like it to be.




And we find that citizens do not have as much influence as




we thought or that people in the campuses perhaps think they




have right now.




          We feel that citizens can best represent citizens.




And we feel that there is need to make some changes in the

-------
                                                       507




                       H.  S.  Liebert






procedures and processes that people in the pollution field




are setting up and following right now.




          We feel also that citizens can help.  We feel we




can help officials on all levels.   In particular,  the people




in the downriver area say that they have a very special




position.  They work in the plants.  They have a lot of




information.  And they have been offering this information,




but it hasn't been taken up.   Their offers have not been




taken up.  And they want you to know that they are willing




to cooperate and to help in cleaning up the environment in




every possible way.




           I think it is important, especially in these




times of unrest, that citizens are involved on all levels




before crises emerge and they start picketing as well as




after crises like the mercury one emerge.  In these times,




I think it is important that citizens have not only a




feeling that they have some control over the environmental




forces around them and that are affecting their daily lives,




but that they actually have a significant degree of control




over these forces.




          We feel that the commissions, including the Water




Resources Commission of the State of Michigan, need widen-




ing.  And one reason we are interested in this particular




hearing is that we feel Federal intervention may be necessary

-------
                                                       508




                       H. S. Liebert






because we don't seem to be able to get anywhere when we




ask for citizen participation on the top levels; citizen




representation on commissions such as the Water Resources




Commission.  And we find when we read back, John Kenneth




Galbraith wrote about counterbalancing power where the




giant labor unions on the one hand and giant business cor-




porations on the other hand will counterbalance each other




and the public interest will somehow be served.  We find




when we read about this and we talk about this that it is




not true in the water pollution field.  There are no labor




representatives on the Water Resources Commission to repre-




sent the so-called powerful labor interests and to counter-




balance the interests of the big business corporations in




this State.




          This is the main concern of the Downriver Anti-




pollution League right now.  This is what they asked me to




say.




          On two particular issues, we feel we have been




getting a run-around.  One of them is the mercury issue, of




course.  I am not going to say too much about that.  We had




a district engineer from the Water Resources Commission




toward the end of March speaking at a public meeting of ours,




He was extremely defensive about questions dealing with




Wyandotte Chemical Company and mercury pollution.

-------
                                                       509




                       H.  S.  Liebert






          He was even more defensive when we brought up the




question of thermal pollution which might result from the




Detroit Edison nuclear plant  — I think it is called the




Enrico Fermi plant -- in Monroe where many of our members




are very upset by the fact that they don't seem to be instal-




ling cooling towers or concerned too much about possible




damage to the environment, and they are operating.




          We feel people aren't listening to us.  We feel




we have interests to represent, and we have a contribution




to make.  These two issues in particular are up right now




for discussion, and we hope that citizens will be involved.




          It is true there are procedures like this.  I am




allowed to get up here and speak.  But we find that the




general structure, not only of the commissions, but of




hearings and procedures and setting of standards make it




very difficult for citizen groups to be involved and make




their feelings known.  Just the general attitude of officials,




the way the people are spoken to and dealt with, makes it




very difficult for us to say  what is on our minds.




          We also feel that although the enforcement officials




do have problems in the areas of funds, funding and enabling




legislation, that they seem to be overly concerned with busi-




ness interests, interests involved in tourism, and less con-




cerned with the citizens who  live and use recreation

-------
                                                       510




                       H. S. Liebert






facilities in the areas affected or involved.




          We feel we need strong penalties, and we need




strong enforcement of those weak penalties we  now have if we




are going to get anywhere.  And we feel that small people




and people in the middle areas such as the commercial fisher-




ment in Lake St. Clair need compensation for losses caused




by such companies as Dow of Canada — the future losses per-




haps from other companies on this side in the  mercury area.




And we feel we are not going to get any action unless there




is Federal intervention.  At least, at this time, this is how




we feel.




          Federal standards are extremely important.  And




Federal pressure on State officials is what we think will




really count.




          And thank you very much for letting me just say




this.  This is our feeling right now and our attitude.  And



that is about all they wanted me to convey.



          MR. STEIN:  Thank you, Mr. Liebert.




          Mr. Purdy.




          MR. PURDY:  Mr. Liebert, I think that you do know




that there is a 7-member Water Resources Commission.  Three




of those members are citizen members at the present time




appointed by the Governor.  That's not quite 50 percent,




but there is citizen participation in the Commission.

-------
                                                      511




                       H. S. Liebert






          The Commission does not determine who the members




will be.  This is a legislative matter.




          The Commission has not opposed widening of repre-




sentation on the Commission.  To my knowledge,  there has




never been a bill introduced in the legislature to place a




representative of labor unions on the Commission.  I would




imagine that if such a bill were introduced that the Com-




mission would support this sort of widening of  representa-




tion.




          So I believe that your criticism of the Commission




from that standpoint is somewhat unfair.




          MR. LIEBERT:  Thank you, Mr. Purdy, for your




support in our request  or what I think is your support.




There is a bill, or I have been told there is a bill, which




asks additional representation on the Commission from the




Department of Commerce.




          MR. PURDY:  That's correct.




          MR. LIEBERT:  And we would hope that  the legis-




lators we have been speaking with, if this bill hasn't




already been disposed of, and the Water Resources Commission




would ask that this bill be amended to specify  conservation




interests to be represented and labor interests as well.




          MR. PURDY:  Generally, a good way to  kill legis-




lation is for the administrative agency to ask  that something

-------
                                                       512
                       H. S. Liebert

be included in it.  The legislators seem much more responsive
to the citizens rather than the administrative agencies who
are frequently referred to as bureaucrats that are only
trying to widen their scope of power.  So I say to you that
you ought to contact your legislators and get them to intro-
duce that amendment.  And you will be much more successful
in doing that than having the Water Resources Commission
attempt to do that.
          MR. LIEBERT:  Yes, sir, I think our members have
been trying to do this.  And I think you are right.
          One of the problems we had, though, or we felt
that exists, is the fact that when you have all these
department heads on the Commission, it is hard to get action.
There are conflicts of interest, and there are vested interests,
And we would prefer to see  them as consultants rather than
as voting, active members of this Commission.
          But I know this isn't really the business of this
body.
          MR. STEIN:  Yes, I am not sure you are making your
pitch before the proper forum.  I don't know whether we
agree or disagree with you.
          Thank you very much.
          MR. PURDY:  That completes the presentation on the
part of Michigan.  I would like to make one closing comment

-------
                                                       513
on Michigan's behalf.




          Yesterday, you referred to the problems of pollu-




tion in Lake Erie.  We had a presentation by the Bureau of




Commercial Fisheries in which certain recommendations were




made.  And they said that the solution to the problems of




Lake Erie was the removal of nutrients and under question-




ing specifically stated phosphates to be the key.  Other




problems that have been identified in the Detroit River and




Lake Erie are problems caused by bacteria"  of human origin




as it relates to the coliform organism as the identifying




form, although Lake Erie as a whole does not have a bacterial




contamination problem.




          Other problems have been suspended solids of muni-




cipal and industrial waste origin — phenols primarily of




industrial origin, oils of industrial origin, waste acid from




steel mills, and then the organic oxygen-consuming substances




as measured by the biochemical oxygen demand, largely trace-




able to paper mills and municipal waste sources.




          Now, I think really that major progress has been




made in the battle to save Lake Erie, in particular since




the problem in Lake Erie as a whole relates to the nutrient




input and in particular phosphates.  We pointed out that




the Detroit Water Board system that serves some 40 percent




of the population of Michigan represents the largest single

-------
                                                       514
input.




          Also, now, it has provided treatment to take the




phosphate nutrients, tie them up so that they are not




available now to feed the algae loads in Lake Erie.




          Significant progress has been made in controlling




the bacteria of human origin.  The suspended solids  load




from industry has been largely now reduced to the objectives




that the Water Resources Commission has set.  And those




objectives had been agreed to by the conferees.




          The polyelectrolytes will be added to the  Detroit




water for the system in 1971, and there will be significant




reduction of suspended solids of municipal waste origin.




          The phenol problem is yet to be licked entirely.




          The oil problem, though, has been substantially




corrected.  This was largely of industrial origin.




          The waste acid from steel mills now has been com-




pletely eliminated.  As a waste, it has been fed on  a control




basis in the Detroit system to control nutrients.




          So I am not quite as discouraged as some of your




remarks might have indicated yesterday.  I think that major




progress has been made towards saving Lake Erie.  There are




remaining problems of major concern, but these problems now




affect largely localized areas within the Detroit River and




the localized area near the mouth of the Raisin River.

-------
                                                       515




                        G.  H.  Eagle






          There are some dissolved oxygen problems there




right at the mouth of the river, and there are the coliform




problems on the Sterling State Park beaches.  But again,




construction is under way to correct those problems, and we




can see an end.  So I am encouraged by the progress that has




been made.




          MR. STEIN:  Thank you.




          Are there any comments or questions?




          (No response.)




          If not, does Michigan have any more?




          MR. PURDY:  That's all.




          MR. STEIN:  I think we will be able to complete




the presentations of the other States before the noon break.




And this afternoon,, we will devote to mercury.




          At this point, we would like to call on Ohio.






                STATEMENT OF GEORGE H. EAGLE




                      CHIEF ENGINEER




                 OHIO DEPARTMENT OF HEALTH






          MR. EAGLE:  Mr. Chairman, conferees, ladies and




gentlemen, my name is George II. Eagle.  I am Chief Engineer




of the Ohio Department of Health.  The Division of Engineer-




ing serves as the technical staff of the Ohio Water Pollution




Control Board.  On behalf of the Board and the Department,

-------
                                                       516




                        G. H. Eagle






I wish to submit this report in its entirety for the record.




          I am going to skim through this report to some




extent.




          With regard to municipal programs, the conferees




established corrective measures and schedules of construc-




tion for 95 municipalities involving 97 projects, 77 of these




municipalities were to have the required facilities completed




by December 31, 1969.  The progress to date with respect to




these requirements is as follows:




          This is basically the same data Mr. Harlow presented




yesterday, but the summaries are quite different.  And you




will note here that of these 77 municipalities, only 35 had




completed and placed into operation their facilities.




Another 33 of them are in the construction or planning stage




at this time, and there are nine that I will report on separately,




But of these 33, in the next paragraph, explanation is given




of what the status of these are, the progress that they are




making.




          And of the remaining nine, three of these nine




communities have failed to make satisfactory progress in the




planning of the required facilities.  These communities —




namely, Avon, Independence and Oakwood — have been ordered




after public hearings by the Board to submit reports and




general plans by September 1970.  To prevent further water

-------
                                                       517




                        G.  H.  Eagle






pollution from these communities, the Board has prohibited




any new connections to the  sewer systems of these communities




which contribute additional pollution to waters of the State.




In essence this means a freeze on any new building in these




communities.  Three more communities, namely, Grand River,




Northwood, and Waterville,  are required to complete the neces-




sary legislation and to provide the necessary sewers for con-




veying their municipal wastes to the facilities of another




municipality.  Two communities are preparing revised plans




for facilities to accommodate expanded service areas.  The




ninth community finally hired an engineer in February of this




year.




          The schedules adopted by the conferees called for  -




the completion of 15 more municipal projects by December 15,




1970.  Five of these are currently under construction, two




will be completed this year and the other three will be com-




pleted during 1971.  Detail plans have been approved for the




sixth municipality xvith construction to begin this fall.  A




seventh is preparing detail plans.  Of the remaining eight




municipalities, six have failed to make satisfactory progress




in planning the necessary facilities.  As a result three




have been ordered by the Board to prepare the required detail




plans prior to January 1, 1971.  These three are Broadview




Heights, Euclid and Willoughby, all in the Cleveland area.

-------
                                                       518




                        G. H. Eagle






In addition, Painesville and Antherst have been ordered to




complete detail plans and general plans respectively by




September 1970 and Fairport Harbor has been ordered to com-




plete negotiations for connection to the Painesville




systems.  The Board here again has imposed a "freeze" on




any new building in Painesville, Fairport Harbor and Broad-




view Heights.  Of the remaining two, the City of Sandusky




is required by current permit to initiate construction, and




the City of Delphos is required by permit to authorize the




preparation of detail plans by June 1970.




          The facilities under construction by the City of




Akron are one of the two projects mentioned above to be com-




pleted this year.  In fact, these facilities should be com-




pleted by July 1.  Concurrently with the completion of this




project three of the four major rubber companies will com-




plete this fall major pretreatment facilities for the signi-




ficant reduction of latexes discharged to the Akron city




sanitary sewer system.  A fourth company is expected to




complete its latex removal facilities next spring.  Also by




next spring, facilities for the recovery of spent pickle




liquors from a major operation now discharged to the sanitary




sewer system will be placed in operation.




          These have been quite a problem in the City of




Akron as pointed out here.  And these pretreatment facilities

-------
                                                       519



                        G.  H.  Eagle






are being installed in accordance with the City of Akron and




Ohio Department of Health requirements.   And the general




clean-up of the other industrial waste problems in the City




of Akron, and in view of the above, these major improvements




of the  system in Akron should considerably improve the water




quality of the Cuyahoga River downstream from Akron this




summer.  This has been a very, very difficult problem.




          The schedule adopted by the conferees for the com-




pletion of projects beyond 1970 are as follows.  Cleveland-




Westerly December 1971, Lake County-Madison Sewer District




January 1, 1971, Lake County-Willoughby-Mentor Sewer District




January 1, 1971, and Toledo February 1972.




          Toledo is under construction,  and these others are




in the various stages of planning.  And the Board has ordered




the City of Cleveland to submit detailed plans of improvements




to the westerly plant by November 1970.   This order was given




because the City of Cleveland failed to comply with earlier




permit conditions calling for general and detail plans




acceptable to the Division of Engineering.  The orders of




the Board were supplemented by a ban on additional pollution




of waters of the State by the city, here again, by the build-




ing freeze type of order in the City of Cleveland.




          And the details of all of this are given in Table 1,




Appendix A.

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                                                       520




                        G. H. Eagle






          With regard to phosphorus removal, remember, at




the last session, we gave a rather detailed report on the




facilities that were being ordered and planned in Ohio for




phosphorus removal.  And our policy was adopted by the




Department to require all plants to design capacity of one




million gallons per day or more to provide phosphate removal




facilities.




          Major facilities now under construction and in a few




instances nearing completion which will provide phosphorus




removal include those of Ashtabula, Avon Lake, Cleveland-




Easterly, Lorain, Port Clinton, Toledo, Akron, Defiance and




Findlay.  The last three discharge to tributary streams




whereas the first six discharge directly to the lake.  The




combined phosphorus load to these facilities is estimated




to be 16,600 pounds per day or nearly half of the total




estimated Ohio municipal load to Lake Erie.  Phosphorus




removal facilities at the Cleveland-Westerly plant have been




in operation for a number of months with temporary facilities




on an experimental basis.




          Later this year major phosphorus removal facilities




are expected to be placed under construction at Rocky River.




          With regard to the industrial programs, completion




schedules for facilities for the abatement of water pollution




by discharges of industrial wastes to the waters of the State

-------
                                                       521




                        G.  II.  Eagle






were a'dopted by the conferees  for 97 Ohio establishments.




In no instance did these dates extend beyond December 31,




1969, that is, for completion.  Sixty of the required pro-




jects have been completed,  four other industries have ceased




operations.  Fifteen others have facilities under construc-




tion; 13 of these are expected to be completed this year.




Eleven others are expecting to connect to municipal sanitary




sewers in their areas.  Plans  of proposed facilities for




five industries have been prepared and are awaiting approval.




One other industry is planning to cease all operations this




fall.  Studies are underway at one plant which has built




substantial in-plant facilities for the recovery of process




chemicals.




          One of the proposals for the discharge of indus-




trial wastes to municipal sewers is rather unique and may be




of interest to the conferees.   The City of Cleveland is




planning to accept the calcium sulfate wastes from the Harshaw




Chemical Company into its sewer system for conveyance to the




Southerly plant.  This waste is expected to aid substantially




in the city's proposal for removal of phosphorus of this




plant.




          Water quality standards — suffice it to say here




that Ohio has revised water quality standards criteria which




were adopted on April 14, 1970, and were worked out with the

-------
                                                       522




                        G. H. Eagle






Federal people and have been submitted to the Secretary for




approval.  These are appended in Appendix B of this report.




And these criteria include the statement on the protection




of high quality of waters.




          And I might point out that these criteria apply to




Lake Erie or portions thereof where such quality levels are




better than existing water quality.  In the Lake Erie water




quality standard, we stated where they were not better than




the existing quality, the existing quality in the lake




would prevail, would become the standard.




          Now, with regard to advanced municipal waste




treatment or 95 percent removal if you prefer or whatever




you want to call it, we have a number of places in Ohio that




call for more than the conventional secondary treatment.




And these are listed here.  There are about 10 municipalities




that now are presently in one stage or another providing so-




called advanced waste treatment facilities.




           Now, on the next page, we speak about the exces-




sive stormwater problems in combined sewer overflows.  And




these are very serious problems in and around the City of




Cleveland.  And failure of the City of Cleveland was one of




the reasons that they were given an order to prohibit any




further contacts until this program moved forward.




          Another serious problem is the use of storm sewers

-------
                                                       523




                        G.  H.  Eagle






of the City of Euclid which conveyed industrial wastes to




Lake Erie.  Legally,  the use of this sewer — I think Mr.




Harlow mentioned this in his report yesterday — is under




the jurisdiction of the city,  of course.   Action towards




correction of pollution caused by the wastes in this sewer




has been hampered for a number of years due to prolonged




litigation between the city and an industry over damages to




this sewer.  Recently, a member of our staff has carried




out several investigations of this problem in cooperation with




the city.  As a result recommendations as to treatment re-




quirements were made to the city by the Ohio Department of




Health staff.  Furthermore, as a guideline, the staff pro-




vided the city water quality objectives for defining storm-




water, which are in effect criteria for water quality for




all uses.  And a copy of this has been provided the Cleveland




office of FWQA.




          Industrial waste in the Ashtabula area, this is a




problem of long standing.  And while a lot of improvements




have been made, conditions are still far from satisfactory.




And I think we are going to have a workshop in Ashtabula so




this will probably be taken up in detail there.  But to




correct this problem, the Board has requested or more or




less ordered the industries to give serious consideration




to a joint terminal facility for treatment of the combined

-------
                                                       524




                        G. H. Eagle






industrial waste effluent from this field growth.




          Just in conclusion, I would like to mention that




one of the reasons — not an excuse, but certainly it is a




reason — why we are behind on these schedules, particularly




with regard to municipalities, is that we have lost practi-




cally a year and a half in trying to implement the $100




million bond issue that was passed in Ohio in November 1968,




to provide the necessary funds to finance these projects




from the State and the Federal Government.  Of course, in




the meantime, the Federal appropriations have been increased.




          I am very happy to report that now our funding on




the 30 percent basis for all projects is fully underway.  And




we have close to a half a billion dollar program over the




next three or four years — two or three years, hopefully —




underway.  A.nd we will be in process in one form or another




in the construction stage within the next two or three years.




This will certainly accelerate conditions considerably, we




feel.




          That's all.  Thank you.




          MR. STEIN:  Thank you, Mr. Eagle, for a very




extensive reort.  The whole report, without objection, will




appear in the record as if read.




          (The above-mentioned report follows in its




entirety.)

-------
                      OHIO VfA'.f "^  ivJj..v.'Jj'.ro.;  CO::
                                      l-'AY,  1970
                                                                                    525
A
E.  W.  ARli'C'i,i),  L'.D.
DiTa;cT:-;;  (.7 n  'A.OIJ

-------
                                                                       526

                      STATEMENT OF DIVISION OF ENGINEERING
ป

                            OHIO DEPARTMENT OF HEALTH
*

     Mr. Chairman, conferees, ladies and gentlemen, my name is George H. Eagle.
I  am Chief Engineer of the Ohio Department of Health.  The Division of Engineering
serves as the technical staff of the Ohio Water Pollution Control Board.  On
behalf of the Board and the Department. I wish to submit this report in its
entity for the record.

     This report is a progress evaluation of Ohio's program for compliance with the
conclusions and recommendations of the Lake Erie Pollution Enforcement Conference
of August 1965.

Municipal Programs

     The conferees established corrective measures and schedules of construction
for 95 municipalities involving 97 projects, 77 of these municipalities were to
have the required faciJ-ities completed by December 31? 19&9•   -^e progress to date
with respect to these requirements is as follows:

     Number of municipalities requiring facilities by December 31 j 19&9 ~ 77

               Number completed                             35
               Number under construction                    10
               Number - detail plans approved               12
               Number - reports and general plans appro\ ^3.  11
               Number remaining                              9

     Of the 10 projects under construction eight are to be completed this year,
and two are to be completed during 1971-  Of the 12 communities with approved
detail plans, six a,re expected to complete the construction of their facilities
during 1971 and three are expected to complete their facilities during 1972; two
projects are being he3.d up by litigations.  Construction has  been delayed for one
small project to arrange for the necessary finances.  Most of the area of this
community is tributary to other facilities.  Detail plans are currently in
preparation for the 11 communities with approved reports and general plans.
These plans are expected to be completed later this year or early next year.
Upon approval of the detail plans, it is expected that construction will begin
within 90 days and that construction will be completed late in 1971 or early 1972.

     Three of the nine communities remaining have failed to make satisfactory
progress in the planning of the required facilities.  These communities, namely
Avon, Independence and Oakwood have been ordered after public hearings by the
Ohio Water Pollution Control Board to submit reports and general plans by
September 1970.  To prevent further water pollution from these communities,  the
Board has prohibited any new connections to the sewer systems of these communities
which contribute additional pollution to waters of the state.  In essence this
means a freeze on any new building in these communities.  Three more communities,
namely Grand River, Korthwood, and Waterville, are required to complete the

-------
                                                                        527

necessary legislation and to provide the necessary sewers for conveying their
municipal wastes to the facilities of another municipality.   Two communities
are preparing revised plans for facilities to accommodate expanded service areas.
The ninth community finally hired an engineer in February of this year.

     The schedules adopted by the conferees called for the completion of 15 more
municipal projects by December 15, 1970.  Five of these projects are cu.rrent.ly
under construction, tv.'o will be completed this year and the  other three will be
completed during 1971.  Detail plans have been approved for  the sixth municipality
with construction to begin this fall.  A seventh municipality is currently revising
detail plans.  Of the remaining eight municipalities six have failed to make
satisfactory progress in planning the neccncary facilities.   As a result three
have been ordered by the Board to prepare the required detail plans prior to
January 1, 1971.  These three municipalities are Broadview Heights, Euclid and
Willo\ighby.  In addition, Paincsville and Amherst have been  ordered to complete
detail plans and general plans respectively by September 1970 and Fairport Harbor
has been ordered to complete? negotiations for connection to the Painesville
systems.  Furthermore, the Board has imposed a "freeze" on any new building in
Painesville, Fairport Harbor and Broadview Heights.  Of the  remaining two, the
city of Sandusky is required by current permit to initiate construction, and
Delphos is required by permit to authorise the preparation of detail plans by
June 1970.

     The facilities under construction by the city of Akron  are one of the two
projects mentioned above to be completed this year.  In fact, these facilities
should be completed by July 1.  Concurrently with the completion of this project
three of the four major rubber companies will complete this  fall, major pre-treatment
facilities for the significant reduction of latexes dis(Jtiurgc.d to the Akron city
sanitary sewer system.  A fourr.h company is expected to complete its latex removal
facilities nejrfc spring.  Also by next spring, facilities for the recovery of spent
pickle liquors from a major operation now discharged to the  sanitary sewer system
will be placed in operation.  The above waste increments have placed a major burden
on and have interfered with the performance of the facilities of the city of Akron.
These pre-treatment facilities are being installed in accordance with requirements
of the Ohio Department of Health, working in cooperation with officials of the city.
The industrial waste discharge of ^0 other industrial discharges to the sewer
system have been found to be in violation of City Code and orders for corrective
measures have been issued by the city in accordance with the requirements of the
city's permit from the Board,  In view of the above, major improvements of the
water quality of the Cuyahoga River downstream of Akron is expected by next summer.

     The schedule adopted by the conferees for the completion of projects beyond
1970 are as follows.  Cleveland-Westerly December 197-1, Lake County -Kadis on Sewer
District January 1, 1971, Lake County-Willoughby-Mentor Sewer District January 1,
1971, and Toledo February 1972.  The facilities for the city of Toledo were placed
under construction in April 1970.  The Board has required by permits, detail plans
for Madison Sever District by October 1970 and general plans for Uilloughby-Kentor
by June 1970.  The Board has .also ordered the city of Cleveland to submit detail
plans of improvements to the Westerly plant by Ifoveii.bcr 1970.  This order was
given because the city of Cleveland failed to comply with earlier permit conditions
calling for general and detail plans acceptable to the Division of Engineering.
The orders of the Board were supplemented, by a ban on additional pollution of
waters of the state by the city.


                                       -2-

-------
                                                                        528


     Information on the status of compliance of each municipal project with the
recommendations and conclusions of the conferees are given in Table 1, Appendix A.

Hio_qphorous__RCjr\o val

     At the last session of the conference Ohio's program for phosphorous removal
was presented.  Included was a list of those cities which have been required to
install phosphorous removal facJlitics.  Included were 15 facilities which dis-
charge directly to Lake Erie and 20 facilities which discharge to Ohio tributaries
to Lake Erie.  The Ohio Department of Health has adopted a policy of requiring
phosphorous removal at all plants with a design capacity of 1.0 mgd or more.

     Major facilities now under construction and in a few instances nearing
completion which will provide phosphorous removal include those of Ashtabula,
Avon Lake. Cleveland-Easterly, Lorain, Port Clinton, Toledo, Akron, Defiance and
Findlay.  The last three discharge to tributary streams whereas the first six
discharge directly to the Lake.  The combined phosphorous load to these facilities
is estimated to be 16.600 pounds per day or nearly half of the total estimated Ohio
municipal load to Lake Erie.  Phosphorous removal focilities at the Cleveland-
Westerly plant have been in operation for a number of months with temporary
facilities on an experimental basis.

     Later this year major phosphorous removal facilities are expected to be
placed under construction at Rocky River.
     Completion schedules for facilities for the abatement of water pollution by
discharges of industrial wastes to the waters of the state were adopted by the
conferees for 97 Ohio establishments.  In no instance did these dates extend
beyond December 31 5  19^9 •  Sixty of the required projects have been completed,
four other industries have ceased operations.  Fifteen others have facilities
under construction j  thirteen of these are expected to be completed this year.
Eleven others are expecting to connect to municipal sanitary sewer systems;  five
of these eleven are  currently negotiating for connection to municipal sewers and
the other six are awaiting the construction of municipal sewers in their areas.
Plans of proposed f acilili es for five industries have been prepared and are
awaiting approval.  One other industry is planning to cease all operations this
fall.  Studies are underway at one plant which has built substantial in-plant
facilities for the recovery of process chemicals.

     One of the proposals for the discharge of industrial wastes to municipal
sewers is rather unique and may be of interest to the conferees.  The city of
Cleveland  is planning to accept the c3,lcixim sulfate wastes from the Harshaw
Chemical Company, into its sewer system for conveyance to the Southerly plant.
This waste is expected to aid substantially in the city's proposal for removal
of phosphorous of this plant.
                                       -3-

-------
                                                                        529


Water Quality Standards

     As reported at the last session, the Ohio Water Pollution Control Board had
adopted Water Quality Standards for all significant Ohio tributaries of Lake Erie.
On AprilT^, 1970, the Board adopted amended criteria of stream water quality for
various water uses.  A copy of the Board's, resolution is included in Appendix B.
The amended criteria up grades waters classified as Aquatic Life A,  Aquatic Life B,
and recreational waters.  The revised criteria for Aquatic Life A up grades the
requirements for dissolved oxygen, water temperatures and pH.   For Aquatic Life B
the revised criteria up grades the requirements for dissolved oxygen and pH.  The
revised criteria for recreational water uses consists of a fecal coliform limit
in place of the total coliform limit.

     The above criteria are to be applied to all respective standards adopted by
the Ohio Water Pollution Control Board for all tributaries of Lake Erie.  Further-
more, these criteria are also to be applied to Lake Erie or portions thereof where
such quality levels are better than existing water quality, otherwise existing
quality levels are to prevail.

     The amended criteria adopted by the Board on April lk, 1970 includes a policy
statement with regards to the protection of high quality waters.  This policy shall
be applied to Lake Erie and all applicable sections of the tributary streams.  To
meet the Water Quality Standards established for Lake Erie and its tributaries
will require, in a number of instances, treatment facilities or corrective measures
in addition to those originally established, by the conferees.   In addition, further
corrective measures are required as the result of expansions,  changes in processes,
annexations, population growth and the obsolescence of existing facilities.  New
or additional requirements to meet these conditions as set forth by  permit conditions,
board orders or the establishment of intrastate water quality standards for municipal
facilities are given in Table 3, Appendix A, likewise the new or additional
requirements for industrial establishments are given in Table k, Appendix A.

Advanced MunicipalJWaste Treatment

     For municipal wastes the standards call for the construction of advanced
waste treatment facilities in a number of critical areas.  The communities and/or
facilities for which this requirement has already been established are as follows:

               Ada                           Cleveland-Westerly
               Akron                         Delphos
               Archbold                      Findlay
               Bryan                         Lima
               Cleveland-Easterly            Van Wert
               Cleveland-Southerly           Wapakoneta

     The facilities for Findlay are currently under construction and detail plans
of such facilities have been approved for Archbold and a report and  general plan
has been approved for Bryan.  The current permits for the other communities call
for the submission of reports and general plans for such facilities  prior to the
expiration date.  In no instance, is a permit calling for improvements granted
for a period of more than one year.


                                       -4-

-------
                                                                        530

      Also in accordance with the  adopted Water Quality Standards most permits
 include a condition calling for the  correction of excessive storm water problems
 and combined sewer overflows.  The latter  is a most serious problem in and
•around Cleveland.   Failure  of the city to  provide an adequate program for the
 correction of this problem  was an important factor in the Board's action of
 imposing a ban on  any additional  pollution of the "waters of the state" by the
 city.

      Another serious problem is the  use of a storm sewer of the city of Euclid
 for the conveyance of industrial  wastes to Lake Erie.  Legally the use of this
 sewer is under the jurisdiction of the city.  Action towards correction of
 pollution caused by the wastes in this sewer has been hampered for a number of
 years due to prolonged litigation between  the city and an industry over damages
 to this sewer.  Recently, a member of our  staff has carried out several investi-
 gations of this problem in  cooperation with the city.  As a result recommendations
 as to treatment requirements were made to  the city by the Ohio Department of Health
 staff.  Furthermore, as a guideline, the staff provided the city water quality
 objectives for defining storm water.  A copy of these guidelines have been
 furnished to the Cleveland  office of Federal Water Quality Administration for
 their comments.

 Industrial Wastes  - Ashtabula Area

      The program of corrective measures adopted by the conferees for the industrial
 waste discharges from the chemical complex in the Ashtabula area were based on
 production and process operations at that  time.

      As originally conceived some of the wastes of one plant became a part of the
 raw materials of another plant.   This is no longer the case with respect to
 hydrochloric acid  which was produced as a  by-product.  Waste treatment facilities
 constructed in accordance with requirements of the conferees were not capable of
 treating the no longer saleable by-product.  To cope with this problem additional
 corrective measures were required.   Furthermore, the interaction of the treated
 wastes from these  industries plus those who have recently constructed new plants
 is such that the waters in  Fields Brook do not meet the criteria for asthetic
 conditions and the discharge of this stream into the Ashtabula River is such that
 it seriously degrades the water quality of the river.  To correct this problem
 the Board has requested the industries to  give serious consideration to a joint
 terminal facilities for treatment of the combined industrial waste effluents.
                                       -5-

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                                     562
APPENDIX B

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                                                                           563
                       WATER POLLUTION CONTROL BOARD
                         OHIO DEPARTMENT OF HEALTH
                               COLUMBUS, OHIO

   RESOLUTION ESTABLISHING AMENDED CRITERIA OP STREAM-WATER QUALITY
       FOR VARIOUS USES ADOPTED BY THE BOARD ON APRIL iH, 1970


WHEREAS,  Section 6lll,03, of the Ohio Revised Code, provides, in part,
          as follows:

               "The water pollution control "board shall have power:

          (A)  To develop programs for the prevention, control and
          abatement of new or existing pollution of the waters of
          the state; .,,," and

WHEREAS,  Primary indicators of stream-water quality are needed as
          guides for appraising the suitability of surface waters in
          Ohio for various uses; and

WHEREAS,  The stream-water quality criteria for various uses and
          minimum conditions applicable to all waters adopted by the
          Board of June 1^, 1966, have been amended by the Ohio River
          Valley Water Sanitation Commission; and

WHEREAS,  The criteria adopted by the Board on October 10, 1967, have
          been further amended by the Ohio River Valley Water Sanitation
          Commission;

THEREFORE BE IT RESOLVED, That the following amended stream-water quality
          criteria for various uses, and minimum conditions applicable to
          all waters, and policies for protection of high quality waters
          and for water quality design flow, are hereby adopted in
          accordance with amendments of the Ohio River Valley Water
          Sanitation Commission, and the recommendations of the Federal
          Water Pollution Control Administration.

AND BE IT FURTHER RESOLVED, That the amended stream-water quality criteria
          for various uses, for minimum conditions, for protection of high
          quality waters, and, for water quality design flow, be made
          applicable to the following waters of the state:

          1.  Maumee, Tiffin, St, Joseph, and St, Marys River Basins;
          2.  Lake Erie & Interstate Waters thereof;
          3.  Great Miami, Whitewater, and Wabash River Basins;
          U,  Ashtabula River, Conneaut and Turkey Creeks;
          5,  Ohio River of Ohio-West Virginia and Ohio-Kentucky;
          6,  North Central Ohio Tributaries of Lake Erie;
          7.  Scioto River Basin;
          8,  Little Miami River Basin;
          9.  Rocky, Cuyahoga, Chagrin  and Grand River Basins;
         10.   iuskingum River Basin;
         11.  Hocking River Basin,

-------
                                                                         564
                   MINIMUM CONDITIONS APPLICABLE TO
               ALL WATERS AT ALL PLACES AND AT ALL TIMES

1.  Free from substances attributable to municipal, industrial or other
    discharges, or agricultural practices that will settle to form pu-
    trescent or otherwise objectionable sludge deposits,

2,  Free from floating debris, oil, scum and other floating materials
    attributable to municipal, industrial or other discharges, or
    agricultural practices in amounts sufficient to be unsightly or
    deleterious.

3.  Free from materials attributable to municipal, industrial or other
    discharges, or agricultural practices producing color, odor or other
    conditions in such degree as to create a nuisance,

^.  Free from substances attributable to municipal, industrial or other
    discharges, or agricultural practices in concentrations or combina-
    tions which are toxic or harmful to human, animal, plant or aquatic
    life.

                   PROTECTION OF HIGH QUALITY WATERS

Waters whose existing quality is better than the established standards as
of the date on which such standards become effective will be maintained at
their existing high quality, pursuant to the Ohio water pollution control
statutes, so as not to interfere with or become injurious to any assigned
uses made of, or presently possible, in such waters.  This will require
that any industrial, public or private project or development which would
constitute a new source of pollution or an increased source of pollution
to high quality waters will be required, as part of the initial project
design, to provide the most effective waste treatment available under
existing technology.  The Ohio Water Pollution Control Board will cooperate
with other agencies of the state,  agencies of other states, interstate
agencies and the Federal Government in the enforcement of this policy.

                       WATER QUALITY DESIGN FLOW

Where applicable for the determination of treatment requirements the water
quality design flow shall be the minimum seven consecutive day average
that is exceeded in 90 percent of  the years,

                        STREAM-QUALITY CRITERIA

FOR PUBLIC WATER SUPPLY

    The following  criteria are for evaluation of  stream quality  at the
point at which water is withdrawn  for treatment and distribution as  a
potable supply:

-------
                                                                        565
!•  Bacteria;  Coliform group not to exceed 5,000 per 100 ml as a
    monthly average value (either MPN or MF count); nor exceed
    this number in more than 20 percent of the samples examined
    during any month; nor exceed 20,000 per 100 ml in more than
    five percent of such samples.

2,  Threshold-odor Number;  Not to exceed 2h (at 60 deg, C.) as
    a daily average.

3.  Dissolved solids;  Not to exceed 500 mg/1 as a monthly average
    value, nor exceed 750 mg/1 at any time,

H,  Radioactivity;  Gross beta activity not to exceed 1,000 picocuries
    per liter (pCi/l), nor shall activity from dissolved strontium-90
    exceed 10 pCi/l, nor shall activity from dissolved alpha emitters
    exceed 3 pCi/l.

5.  Chemical constituents;  Not to exceed the following specified
    concentrations at any time.

                 Constituent                Concentration (mg/1)

                 Arsenic                          0.05
                 Barium                           1,0
                 Cadmium                          0.01
                 Chromium                         0.05
                   (hexavalent)
                 Cyanide                          0.025
                 Fluoride                         1,0
                 Lead                             0.05
                 Selenium                         0,01
                 Silver                           0,05

FOR INDUSTRIAL WATER SUPPLY

    The following criteria are applicable to stream water at the point at
which the water is withdrawn for use (either with or without treatment)
for industrial cooling and processing:

1,  Dissolved oxygen;  Not less than 2.0 mg/1 as a daily-average value,
    nor less than 1.0 mg/1 at any time.

2.  pH;  Not less than 5.0 nor greater than 9.0 at any time.

3-  Temperature;  Not to  exceed 95 deg, F, at any time.

^.  Dissolved solids;  Not to exceed 750 mg/1 as a monthly  average value,
    nor exceed 1,000 mg/1 at any time,
                                   -3-

-------
                                                                        566
FOR AQUATIC LIFE A

    The following criteria are for evaluation of conditions for the maintenance
of a well-balanced, warm-water fish population,  They are applicable at any
point in the stream except for areas necessary for the admixture of waste
effluents with stream water:

1.  Dissolved oxygen;  Not less than an average of 5.0 mg/1 per calendar day
    and not less than ^.0 mg/1 at any time,

2.  p_H:

    A.  No values "below 6,0 nor above 8.5,

    B,  Daily fluctuations which exceed the range of pH 6,0 to pH 8,5
        and are correlated with photosynthetic activity may be tolerated.

3.  Temperature;

    A.  No abnormal temperature changes that may affect aquatic life
        unless caused by natural conditions.

    B,  The normal daily and seasonal temperature fluctuations that
        existed before the addition of heat due to other than natural
        causes shall be maintained,

    C.  Maximum temperature rise at any time or place above natural
        temperatures shall not exceed 5 deg, F.  In addition, the water
        temperature shall not exceed the maximum limits indicated in
        the following table.
Maximum
WATERS
All waters except
Ohio River
Main Stem-Ohio River
Jan,

50
50
Feb.

50
50
Mar.

60
60
Temperature in
Apr.

TO
70
May June

80 90
80 87
Dep;
July

90
89
. F,
Aup;

90
89
During
, Sept,

90
87
Month
Oct.

78
78

Nov.

70
70

Dec.

57
57
    Toxic substances;  Not to exceed one-tenth of the ^8-hour median
    tolerance limit, except that other limiting concentrations may be
    used in specific cases when Justified on the basis of available
    evidence and approved by the appropriate regulatory agency.

-------
                                                                          567
FOR AQUATIC LIFE B

    The following criteria are for evaluation of conditions for the maintenaru
of desirable biological growths and, in limited stretches of a stream, for
permitting the passage of fish through the crater, except for areas necessary
for admixture of effluents with stream water;

1,  Dissolved oxygen:  Not less than 3,0 mg/1 as a daily-average value, nor
    less than 2.0 mg/1 at any time,

2.  pH:  Not less than 6,0 nor greater than 8,5 at any time,

3,  Temperature:  Not to exceed 95 deg, F. at any time,

k.  Toxic substances:  Not to exceed one-tenth of the US-hour median
    tolerance limit, except that other limiting concentrations may be
    used in specific cases when Justified on the basis of available
    evidence and approved by the appropriate regulatory agency,

FOR RECREATION

    The following criterion is for evaluation of conditions at any point in
waters designated to be used for recreational purposes, including such
water-contact activities as swimming and water skiing:

    Bacteria:  The fecal coliform content (either MPN or MF count) not
    to exceed 200 per 100 ML as a monthly geometric mean based on not
    less than five samples per month; nor exceed HOO per 100 ML in more
    than ten percent of sill samples taken during a month.

FOR AGRICULTURAL USE AND STOCK WATERING
    The following criteria are applicable for the evaluation of stream
quality at places where water is withdrawn for agricultural use or stock-
watering purposes:

1.  Free from substances attributable to municipal, industrial or other
    discharges, or agricultural practices that will settle to form
    putrescent or otherwise objectionable sludge deposits.

2.  Free from floating debris, oil, scum and other floating materials
    attributable to municipal, industrial or other discharges, or
    agricultural practices in amounts sufficient to be unsightly or
    deleterious,

3.  Free from materials attributable to municipal, industrial or
    other discharges, or agricultural practices producing color,
    odor or other conditions in such degree as to create a nuisance,

h.  Free from substances attributable to municipal, industrial or other
    discharges or agricultural practices in concentrations or combinations
    which    • toxic or harmful to human, animal, plant or aquatic life.

-------
                                                      568




                        G. H. Eagle






          MR. STEIN:  I think since we are going to have




 these workshops, possibly the conferees or other people could




 defer some  specific comments on the material in the appendix




 to  the time we have these workshops.




            MR. EAGLE:  I would just like to point out, Mr.




 Stein, we welcome these workshops, and we hope this will




 result in some substantial assistance from the Federal Govern-




 ment because we do have some laggards in Ohio — not too many,




 but some -- that we do need some help with.  And any assis-




 tance you can give with regard to these, we would appreciate




 very much.




          MR. STEIN:  I am happy to say that with all the




 Lake Erie States, I think particularly since we have had




 these series of conferences, generally speaking, we have




 problems, maybe some  rough edges of State-Federal relations,




 but I think it is pretty  fair to say we have been working




 practically as one staff  for the past year or two.  And you




 can be assured we will give you all the help possible.




          MR. EAGLE:  Thank you.




          MR. STEIN:  Are there any other comments or ques-




 tions?




          MR. VOGT:   I have a question, Mr. Chairman.




          George,  I note  that in a number of instances, you




initiated,  as you  call it, building  fees, imposed building

-------
                                                       569




                        G. H.  Eagle






fees, on some of your communities.  And this particular




technique, we have used in Michigan and found it to be rather




effective in accelerating control programs,  pollution control




programs.




          I am wondering what has been your experience so far




in Ohio with these types of impositions.




          MR. EAGLE:  Very good results.  In about 90 percent




of the cases, it has solved the problem.  Of course, we still




have a number of them outstanding.  I think we have some 25




or 30 outstanding at this time.  We started this program




about three years ago.  To date more than 75 percent of them




have gotten under way to the extent that the building fees




could be lifted.




          MR. VOGT:  I see.  That is interesting because,




in other words, it assures the initiation and continuation




of a positive program of pollution control.




          MR. EAGLE:  Of course, we do have on the other




side, John, some city officials prevail on us to give them




building fees because they don't want to see their munici-




pality develop.  They want to keep it just like it is.




          MR. STEIN:  Are there any other comments or ques-




tions?




          (No response.)




          Thank you very much, Mr. Eagle, for a very

-------
                                                       570




                         W.  A.  Lyon







interesting contribution.




          May we call on Pennsylvania?







                  STATEMENT  OF  WALTER A.  LYON




            DIRECTOR, BUREAU OF SANITARY  ENGINEERING




               PENNSYLVANIA  DEPARTMENT OF HEALTH






          MR. LYON:  I will  try not to go into any detail




and make this very brief, Mr. Chairman.




          Mr. Bellaman,   our Regional Engineer, is passing




out copies of our report.




          I would like also  permission to make as part of




the record a statement by Mayor Louis J.  Tullio of the city




of Erie.  And Mr. Bellaman     has copies of that statement.




          MR. STEIN:  Both the  statements will appear in




the record as if read in their entirety without objection.




          (The above-referred to statements follow in their




entirety.)

-------
                                                                571
               STATUS REPORT
Water Pollution Control in the Pennsylvania
       Portion of the Lake Erie Basin

                 June, 1970
                                     Sanitary V/ater Board
                        Pennsylvania Department of Health

-------
                                                                         572
                    STATUS REPORT TO LAKE ERIE CONFEREES

                                      by

                        Commonwealth of Pennsylvania
                            Department of Health

                                June 3, 1970
     (1)   Pursuant to adoption of the Lake Erie phosphorus removal  plan
adopted by the Sanitary Water Board on June 18, 1969, orders were issued
to ten industries and municipalities requiring a substantial reduction in
the amount of phosphorus discharged from their waste treatment facilities.
Compliance with the orders will  result in at least 80% reduction of phosphorus
from municipal and industrial sources in the Pennsylvania portion of the
Lake-Lrie basin.  At this time,  six of the ten dischargers are either in
compliance with the orders or are on schedule to achieve compliance by the
July 1, 1972 overall deadline.  Four of the municipalities have requested
hearings.   The municipalities that requested hearings are the Boroughs of
Girard, North East, Lake City and Albion.  The hearings have not yet been
scheduled by our Legal Counsel.   We hope to have these soon.

     (2)   The detection of significant concentrations of mercury in Lake Erie
fish has  had a deleterious effect on Pennsylvania's use of the lake's waters.
The market for commercial fishes has been seriously affected and Governor
Shafer has had to warn sport fishermen that concentrations of mercury exceeding
FDA limits have been found in certain sport species and these should not be
consumed.   Mercury in Lake Erie represents a public health threat and is
having an adverse economic effect on Pennsylvania.

          Mercury analyses performed to date show detectable concentrations
of mercury in all fishes taken from Pennsylvania waters.  Concentrations varied
with species and ranged from 0.0k parts per million to 1.^3 parts per million.
Only edible portions of fish were analyzed.  Generally, the top predators such
as walleye, smallmouth bass, white bass, and fresh water drum showed the
highest concentrations of mercury.  Smelt, perch, rock bass, carp,  suckers and
crappies showed lower concentrations of mercury in the flesh.  Samples of
several coho salmon taken from the lake showed levels of mercury less than
0.5 parts per million but ranged from 0.3^ parts per million to 0.^)6 parts per
million.   The Pennsylvania Fish Commission is periodically sampling fish from
Lake Erie.  These fish are being analyzed by the Food and Drug Administration
Laboratories.

-------
                                    - 2 -

                                                                         573


          Samplings of water and waste discharges for mercury were conducted
during April and May.  Bottom mud and fish samples from the Lake were also
taken by the Pennsylvania Fish Commission for analysis.  Mercury was not
detected in the lake waters and in the bottom muds at the limits of detection
of the tests.   Mercury was detected in one waste water discharge, but re-sampling
indicated that mercury was not present.  Contamination of the sample bottles was
possible since the first series of samples were not collected in properly cleaned
containers.

          As a result of our waste water survey, we are convinced that there
are no significant sources of mercury being discharged to Lake Erie from
Pennsylvania sources.  We did learn that the Hammermill Paper Company used
mercurials up to ten to fifteen years ago for slime control but discontinued
the use at that time.  We have sampled the bottom muds in the vicinity of the
Hammermill outfall to determine if residual mercury is present in this area.
We will continue a surveillance program of discharges to Lake Erie.

          We recommend that action be taken by the conferees to insure that
all discharges of mercury and other toxic materials to Lake Erie and its
tributaries are halted.

     (3)  Attached are listings of the status of sewerage and industrial waste
cases that have been considered by the Lake Erie Enforcement Conference.  In
addition to these cases, permits have been issued for several small sewage
treatment plants to serve installations such as highway rest stops.  These
treatment plants meet the minimum requirements established by the conferees.

-------
                                                                            574
                                      TABLE  I

                                  Sewerage Status
                                    (June, 1970)
              Name                               Present  Status  -  Comments

City of Erie                              1.   Sewage  treatment  plant  expansion  and
                                              improvements  -  Plans approved  for ex-
                                              pansion  and improvements  that  include
                                              secondary  treatment  and phosphorus
                                              removal  such  that  the effluent will
                                              contain  no  more than 1  mg/1  phosphorus
                                              as  P.  Will  treat  Erie  metropolitan
                                              plus  Hammermill  Paper Company  wastes.
                                              If  grant processing  moves  expeditiously
                                              should begin  construction  by October  1,
                                              1970  and complete  construction and
                                              begin operation by February  15,  1972.

                                          2.   Present  treatment  efficiency,  untreated
                                              discharges  through storm  sewers  -
                                              Treatment  plant now  providing  secondary
                                              treatment with  continuous  disinfection
                                              with  exception  of  excessive  solids  loss
                                              from  final  settling  tanks  during  periods
                                              of  peak  flow.   Interim actions  to
                                              reduce  these  losses  have  been  ordered
                                              and include tighter  operation' control.

                                              Recent surveys  indicate that 80%  of
                                              the untreated sewage being by-passed
                                              at  storm sewer  outlets  has been  diverted
                                              to  the  treatment  plant.  Expansion of
                                              the treatment plant, including hydraulic
                                              changes, is expected to achieve 100%
                                              abatement.   At  present, additional sewer
                                              extensions  and  new connections are pro-
                                              hibited. A hearing  on  this  problem
                                              held  on  October 31,  1S&9  was adjudicated
                                              on  May  15,  1970,  and a  compliance
                                              schedule must be  submitted by  August  15,
                                              1970.   Expansion  of  the Bay  Front inter-
                                              ceptor will  ultimately  be needed  to
                                              serve future  growth  and reduce or
                                              eliminate overflows  during storms.  This
                                              project  is  being  held up  by  design of
                                              the Bay  Front highway.  Sewer  and highway
                                              design arid  construction will have to  be
                                              coordinated.

-------
                                         - 2 -
              Name
   Present Status - Comments
                                                                              575
North East Borough
Gi rard Borough
Albion Borough
Lake City Borough
Fa i r.view School
Erie County Home
Greene Township Elementary School
Talarico Truck Stop
Howard Johnson Motor Stop
Penn State Behrend Center
Harborcreek Township School
Oakdale Corporation
Poplar White Thru-way
Terrace Restaurant
Mums Motel
Conneaut Valley Union Joint
   Elementary School
Kahkwa Club
Presently providing secondary treatment.
Ordered August 1, 1969 to provide tertiary
treatment including phosphorus removal.
Have requested hearing before Sanitary
V/ater Board on order.  Hearing has not
been scheduled by the office of Legal
Counsel.

Presently providing secondary treatment.
Ordered August 1, 1969 to provide tertiary
treatment plus phosphorus removal.  Have
requested hearing before the Sanitary
Water Board on the order.  Hearing has
not been scheduled by the Office of Legal
Counsel.

Presently providing secondary treatment.
Ordered August 1, 1969 to provide tertiary
treatment plus phosphorus removal.  Have
requested hearing before the Sanitary
Water Board on the order.  Hearing has
not been scheduled by the Office of Legal
Counsel.

Ordered August 1, 1969 to provide tertiary
treatment including phosphorus removal.
Have requested hearing before the Sanitary
Water Board on order.  Hearing has not
been scheduled by the Office of Legal
Counsel.

Treatment plant is overloaded with the
result that less than secondary treatment
is being provided.  Additional sewer
extensions and connections are being
proh ib i ted.

Secondary treatment provided
    n
    it
    ii
    n
    n
    n
    n
    11
    n

    ii
    n
n
n
n
n
M
M
n

ii
ii
n
n
n
ii
n
M
M
n
n

n
n

-------
                                         -  3  -
              Name
   Present Status - Comments
                                                                                576
Lakeshore Country Club
Presque Isle State Park
Travelers Rest
Fairview Township Industrial
   Development Corporation
Rondal Convalescent Home
Humble Oil and Refining Company
Summit School District
Interpace Corporation
Larry's Truck Stop
Wenner's Esso Station
Wi Ison Motel

Alpine Manor
Georgetown

South Shore Service Company
Secondary treatment provided
    I!         II        II
    II

    II

    II

    II

    II

    II

    II

    II
II

II

II

II

II

II

II

II
II

II

II

II

II

II

II

II
Secondary treatment provided as of
April 1, 1970.

Secondary treatment provided.

Secondary treatment provided.  Ordered
August 1, 1969 to provide phosphorus
removal.  Feasibility study was completed
but plans not submitted on schedule.
Enforcement conference scheduled for
May 29, 1970.  If plans received by
June 1, 1970 there should be no overall
delay toward meeting compliance.

-------
                                      TABLE I I

                                 Industrial Status
                                    (June, 1970)
                                                                               577
            Case Name
Albro Packing Company
Hammermill Paper Company
Interlake Steel  Company
Kaiser Aluminum and Chemical
   Corporation
Penelec Company
Ruberoid Company

Welch Grape Juice Company
       Present Status ^Comments

    Providing adequate treatment including
    phosphorus control.

1.   A portion of total compliance will
    depend on the City of Erie sewage
    treatment expansion.

2.   Delays due to strikes against certain
    supplies of material, together with
    construction worker labor problems
    have caused about two months delay  in
    the pulping conversion process which
    will reduce the raw waste production to
    about 1/3 of the BOD load and 1/6 of
    the color load.

    Objections raised to deep water outfall
    for treated wastes may delay outfall
    construction until October 1, 1971.

    Pulping conversion and resulting waste
    reduction expected February 15, 1971
    instead of December 15,  1970.  Phosphorus
    control adequate.

    Adequate treatment provided
    Adequate treatment provided for organic
    wastes.   Cooling water causing thermal
    pollution in Sixteen Mile Creek.
    Feasibility report due July 1, 1970.

-------
                                        - 2 -
            Case Name
   Present Status - Comments
                                                                               578
J. McCormick Construction Company
Nickel Plate Sand and Gravel
Erie Ceramics
Erie Brewing Company
International Pipe and Ceramics Corporation

Parker White Metal
Gunnison Brothers Tannery
Adequate Treatment Provided
   n         n        ii
General Electric Company
American Sterilizer Company
Ervite Corporation
W. Ridge Gravel
   n
   n
   n
n
n
n
n
ii
ii
Adequate treatment installed as of
December 9, 1969-

Present treatment less than secondary.
Tertiary treatment and adequate
phosphorus control designed after
research and development project.
Inability to obtain necessary rights-
of-way has required redesign and
relocation of the treatment facility.
Now to begin construction by August 1,
1970 and begin operation by October 15,
1970.

Phosphorus control is adequate.  Ordered
to provide treatment of oil bearing
wastes.  Contracts awarded May 1, 1970.
Strikes caused 3i months delay.  Partial
completion and operation now expected
by December 30,  1970 with total com-
pletion and operation by April 30, 1971-

Adequate Treatment Provided
   M         n        ii
Erie Reduction
Connected to City of Erie.

-------
                                                                           579






•WHAT THE  CITY OF ERIE, PENNSYLVANIA HAS DONE AND IS DOING TO ABATE POLLUTION




                        ft * *   INTO LAKE ERIE   * * *




         BY MAYOR LOUIS J.  TULLIO, CITY OF  ERIE,  PENNSYLVANIA




      THE  CITY OF ERIE'S PRESENT PLANT WAS CONSTRUCTED IN 1954 UNDER PERMIT




 FROM THE  PENNSYLVANIA DEPARTMENT OF HEALTH AND AT THAT TIME HAD AN EFFLUENT




 THAT MET  OR EXCEEDED THE DEGREE OF TREATMENT REQUIRED FOR DISCHARGE INTO LAKE




 ERIE.




      THE  PLANT  CLASSIFIED AS INTERMEDIATE TREATMENT IS CAPABLE OF TREATING




 45 MILLION GALLONS PER DAY.  THE AREA SERVED BY THE PLANT IS METROPOLITAN IN




 SCOPE SERVING NOT ONLY THE CITY OF ERIE BUT ALSO THE BOROUGH OF WESLEYVILLE




 AND THE TOWNSHIPS OF LAWRENCE PARK, MILLCREEK AND HARBORCREEK.




      THE  ORIGINAL PERMIT CALLED FOR CHLORINATION OF THE EFFLUENT ONLY DURING




 THE BATHING SEASON.  IN APPROXIMATELY 1963 THIS PERMIT WAS AMENDED TO CALL




 FOR YEAR  AROUND CHLORINATION.  THE CITY HAS COMPLIED WITH THIS ORDER SINCE




 IT WAS ISSUED.




      IN 1965, TO ELIMINATE INDUSTRIAL WASTE DISCHARGE FROM THE STORM SEWER




 SYSTEM AND TO CONTROL THESE DISCHARGES IN THE SANITARY SEWER SYSTEM THAT WERE




 THREATENING THE SEWERAGE PLANT WITH UPSETS, THE CITY THROUGH THE COOPERATION




 OF THE MANUFACTURERS ASSOCIATION HAD MADE AN INDUSTRIAL WASTE SURVEY OF THE




 CITY TO DETERMINE THE QUALITY, QUANTITY AND LOCATION OF INDUSTRIAL DISCHARGES.




 THIS LED  TO PASSAGE OF AN INDUSTRIAL WASTE ORDINANCE IN 1966.  THIS ORDINANCE




 CONTROLS  WHAT CAN BE DISCHARGED INTO THE SYSTEM AND WHAT REQUIRES PRE-TREAT-




 MENT BEFORE IT  IS DISCHARGED.  DURING 1966 AND 1967 INDUSTRY COMPLIED WITH




 THESE REGULATIONS.  PERIODIC CHECKS SHOW THAT COMPLIANCE WITH THIS ORDINANCE




 BY INDUSTRY HAS BEEN GOOD.




      WITH THE CHANGE IN THE STANDARDS FOR DISCHARGE INTO LAKE ERIE, THE CITY,




 THROUGH ITS SEWER AUTHORITY, WAS ORDERED TO UPGRADE ITS DEGREE OF TREATMENT.

-------
                                                                          580
                                      -2-







PRELIMINARY DESIGN WAS UNDERWAY WHEN WE WERE APPROACHED BY THE HAMMERMILL




PAPER COMPANY TO CONSIDER THE POSSIBILITY  OF COMBINED TREATMENT OF  THEIR IN-




DUSTRIAL WASTE AND OUR MUNICIPAL WASTE. THIS WAS AGREED AND PILOT  PLANT AND




BENCH STUDIES WERE CONDUCTED TO DETERMINE  THE DESIGN PARAMETERS AND THE




FEASIBILITY OF COMBINED TREATMENT.   CONCLUSIONS OF THIS STUDY INDICATED THAT




COMBINED TREATMENT WAS FEASIBLE BOTH TECHNICALLY AND ECONOMICALLY.   AS A  ,




RESULT OF THIS AN AGREEMENT WAS NEGOTIATED BETWEEN THE CITY, THE SEWER AUTHOR-




ITY AND THE HAMMERMILL PAPER COMPANY TO SHARE IN THE COST OF CONSTRUCTION,




MAINTENANCE AND OPERATION OF THE NEW EXPANDED PLANT.




     THE EXPANDED PLANT IS NOW UNDER ENGINEERING DESIGN.  PRELIMINARY PLANS




HAVE BEEN SUBMITTED TO THE STATE.  THE CONSULTING ENGINEERS ARE WORKING TOWARDS




A FALL DEADLINE FOR COMPLETED PLANS SO THAT THIS NEW PLANT CAN BE PUT OUT TO




BIDS AND CONSTRUCTION STARTED THIS YEAR.  THE EXPANDED PLANT WILL PROVIDE FOR




COMPLETE TREATMENT PLUS PHOSPHATE REMOVAL IN COMPLIANCE WITH THE STATE'S




ORDER.  PRELIMINARY COST ESTIMATES FOR THIS PLANT ARE APPROXIMATELY $12,000,000




FOR CONSTRUCTION WITH AN ADDITIONAL $600,000 TO BE REQUIRED ANNUALLY FOR CHEM-




ICALS TO TREAT THE PHOSPHATES.




     COMBINED SEWERS:




     THE OLDER PART OF THE CITY IS SERVICED BY COMBINED SEWERS.  THIS WAS




STANDARD PRACTICE UNTIL ABOUT 1930.  ALL CONSTRUCTION AFTER THAT TIME WAS




SEPARATE SYSTEMS.




     THE CITY HAS BEGUN A PROGRAM TO SEPARATE ITS COMBINED SEWER SYSTEM  IN




THE PAST FEW YEARS.  EXTENSIVE CONTRACTS HAVE BEEN LET, ESPECIALLY  IN THE




DOWNTOWN AREA TO ACCOMPLISH  THIS.  DOLLAR VOLUME FOR THIS WORK HAS  EXCEEDED




$2,000,000  IN THE PAST FOUR  YEARS WITH AN ADDITIONAL $400,000  UNDER CONTRACT




AT THIS TIME.

-------
                                                                           581







                                      -3-




     ERIE WILL CONTINUE WITH THIS PROGRAM OF SEPARATION AS FUNDS ARE MADE




AVAILABLE.




     SANITARY SEWERS:




     THE CITY HAS PROVIDED SANITARY SEWERS TO ALL PARTS OF THE CITY.  IT HAS




ALWAYS BEEN THE ADMINISTRATION POLICY TO EXTEND THESE SERVICES AS PROMPTLY




AS POSSIBLE FOLLOWING A REQUEST.  AT PRESENT OVER 95% OF THE AREA OF THE CITY




IS SERVICED BY SEWERS.  THIS PROVIDES SERVICE TO ALMOST 100% OF THE POPULATION.




THE ONLY AREAS REMAINING TO BE SERVICED ARE THOSE NOT YET DEVELOPED AND CER-




TAIN PORTIONS OF THE BAY FRONT.




     THE CITY BECAUSE OF ITS TERRAIN DOES NOT REQUIRE MANY LIFT STATIONS.




THE CITY HAS AT PRESENT FIVE, THREE OF THESE WERE CONSTRUCTED WITHIN THE PAST




FOUR YEARS AT A COST IN EXCESS OF $2,000,000.  THIS YEARS CAPITAL IMPROVEMENTS




BUDGET PROVIDES $250,000 TO CONSTRUCT ANOTHER LIFT STATION TO SERVICE THE




BAY FRONT AREA.




     THE BAY FRONT AREA OF THE CITY IS SITUATED BELOW THE INTERCEPTOR SEWER,




SO ALL OF THIS AREA MUST BE SERVICED WITH LIFT STATIONS.  IN 1966 THE CITY HAD




THEIR CONSULTANTS PREPARE PRELIMINARY PLANS FOR THIS AREA.  PLANS CALL FOR FIVE




LIFT STATIONS IN THIS AREA.  TWO OF THESE WERE BUILT WITHIN THE PAST TWO YEARS




WITH ANOTHER SCHEDULED FOR CONSTRUCTION IN THIS CALENDAR YEAR.  THIS SHOULD




COVER THE DEVELOPED AREAS, THE REMAINDER WILL BE CONSTRUCTED AS DEVELOPMENT




TAKES PLACE.




     THE CITY ALSO HAS PLANS TO CONSTRUCT LIFT STATIONS AT ITS WEST SIDE




WATER PLANT TO PUMP THE WASTE WATER BACK INTO THE SEWER SYSTEM RATHER THAN




INTO THE BAY.




     AS A RESULT OF ENCLOSING THE CREEKS AND RUNS IN THE CITY, MANY SANITARY




SEWERS HAD TO BE SIPHONED UNDER THE STORM SEWERS.  TO INSURE NO FLOODING OF




BASEMENTS, OVERFLOWS WERE REQUIRED TO BE CONSTRUCTED AT THESE SIPHON LOCATIONS.

-------
                                                                         582




                                      -U-




IN THE PAST MANY OF THESE SIPHONS BECAME CLOGGED AND OVERFLOWED INTO THE




STORM SEWERS.   TO REDUCE THIS TO A MINIMUM WE HAVE INSTITUTED A PROGRAM OF




BI-WEEKLY INPSECTIONS OF THESE SIPHONS AND CLEANING WHEN REQUIRED.   THIS HAS




GREATLY REDUCED THE OVERFLOWS FROM THIS SOURCE.




     DURING THE PERIOD OF CONSTRUCTION OF COMBINED SEWERS MANY OVERFLOWS HAD




TO BE CONSTRUCTED TO DIVERT HEAVY COMBINED FLOWS FROM THE TREATMENT PLANT.




SINCE THE PLANT HAS HAD ADDED CAPACITY MANY OF THESE HAVE BEEN ABANDONED OR




PLUGGED.  OTHERS STILL EXIST, WE ARE WORKING ON THIS PROBLEM AND THROUGH THE




COMBINATION OF SEPARATING THE COMBINED SEWERS AND ADDITIONAL CAPACITY AT THE




PLANT SITE, WE HOPE TO SOLVE THIS PROBLEM.




     THE MOST IMPORTANT PROBLEM WE HAVE NOW IS WITH OUR OLDER SEWER SYSTEM.




MANY ILLEGAL CONNECTIONS EXIST AND SOME CROSS CONNECTIONS MUST BE THERE.  WE




HAVE FOUND MANY OF THESE AND CORRECTED THEM, THEREBY REDUCING THE FLOW TO THE




BAY CONSIDERABLY.  WE ARE WORKING DILIGENTLY TO CORRECT THIS BUT IT IS A TIME




CONSUMING JOB, REQUIRING SEARCHING OLD RECORDS, DYE TESTING AND LOCATION




STUDIES.  WE WILL CONTINUE TO PURSUE THIS UNTIL ALL LOCATIONS ARE FOUND AND




CORRECTED.




     WE BELIEVE THAT WE HAVE BEEN PROGRESSIVE IN OUR FIGHT TO ABATE THE




POLLUTION OF LAKE ERIE AND WILL PLACE OUR RECORD OF ACHIEVEMENT AGAINST ANY




ALONG THE LAKE.  WE WILL CONTINUE WITH OUR PLANS AND WILL NOT REST UNTIL ALL




SOURCES OF POLLUTION INTO THE LAKE FROM ERIE ARE ABATED.

-------
                                                        583




                         W. A. Lyon






          MR. LYON:  1 also understand that the county




commissioners of the County of Erie and the County Health




Department in Erie intend to submit written statements at a




later date.




          MR. STEIN:  What later date?  To this conference?




          MR. LYON:  I think to this conference.




          MR. STEIN:  I will keep the record open for a




week.




          MR. LYON:  Fine.  We will advise them accordingly.




          They may already be in the mail.




          Our report covers essentially two areas.  And I




will not read our report.  One is the mercury problem.




          Summarizing briefly, we have monitored our dis-




charges and found no consequential mercury discharges any-




where in Pennsylvania.  We have monitored our waters and




have not found anything serious in the way of mercury.




          We have found that some of the fish that were col-




lected in Pennsylvania did have mercury concentrations in




excess of the limits, and our Governor has advised sportsmen




to not eat certain types of fish.  And this is also covered




in our report.




          And we are naturally very deeply concerned about




this mercury problem, and I hope will be talking about that.




          MR. STEIN:  You don't mean other people can eat

-------
                                                        584




                         W.  A.  Lyon









the fish other than the sportsmen?




          MR. LYON:  No.  We are talking about the  fish  that




the sportsmen collect.




          We are in favor of sportsmen having mercury-free




fish, Mr. Chairman.




          In connection with our municipal and industrial




program, let me briefly summarize that all but two  minor




discharges in Pennsylvania are  providing secondary  treatment.




We have 32 sources of sewage — municipal and private




institutions.




          Four of our smaller municipalities have requested




hearings before our Board in connection with the phosphate




reduction orders.  And we hope  to have these scheduled




soon.




          The city of Erie is approximately 14 months behind




schedule in the completion of its program for phosphate




removal.  And this is associated with the Hammermill dis-




charge because the city of Erie has agreed to a significant




portion of the Hammermill wastes.  They in themselves have




helped reduce the phosphates because they will demand




phosphates.  The delay was caused because it was necessary

-------
                                                        585




                         W. A. Lyon






to change the Hammermill process to allow the city of Erie




to take those wastes.




          In connection with page 3 of my report, the South




Shore Service Company which is a very small sewage source




indicates that the Enforcement Conference is scheduled for




May 29.  That should be changed to June 5.




          And the last sentence, beginning with "if plans"




should be struck from that portion of the report.




          We have 16 industrial waste discharges.  Three of




them are behind schedule, one for two months, one for seven




months, and the other for three and one-half months.  Other-




wise, our industrial program is in good shape.




          I would like to mention that even though the city




of Erie sewage treatment plant will not go into operation




until February 15, 1972, the wastes from the Hammermill




Paper Company will in fact be reduced very significantly




when their change in process goes into effect on or about




February of 1971.  Their BOD loads will be reduced by about




two-thirds and their coli load will be reduced about 80




percent.  So that in itself will be a very major reduction




in industrial waste to Lake Erie and Pennsylvania.




          In connection with Mr. Harlow's report, I think




the additions I indicated are due to the passage of time




perhaps since this information was submitted.  I would like

-------
                                                       586




                         W.  A.  Lyon






to, for example, refer to page  2 of the municipal report.




          Under Erie there should be an indication that an




adjudication has been issued as a result of the Bay Point




sewer problem requiring abatement by 5/15/72.




          And the record should also show,  and I would




request that these changes be made in Mr. Harlow's report




if he agrees, that an order stopping all additional sewer




extensions and connections has  been issued.




          And I might also mention that the city of Erie has




reduced its discharge from this Bay Point sewer from about




10 to 15 million gallons per day to approximately 3 to 5




million.




          Similarly, in connection with Lake City, sewer




connections are being prohibited and the permit is being




suspended for failure to meet a compliance schedule.  And




an order will be issued to expand the sewage plant which




appears to be overloaded.




          In connection with Alpine Manor, the record should




show that secondary treatment was provided as of 4/1/1970.




Mr, Harlow's report says no schedule.




          Switching over to the industrial waste portion




of Mr. Harlow's report, page F-3, General Electric, the




report should show that a permit was issued in March 1970




and construction will be completed and operation begun by

-------
                                                       587




                         W. A. Lyon






4/30/71.




          In connection with Gunnison Brothers, the report




should show that the construction will be completed and




operation will be begun by October 15, 1970.




          And in connection with the Haminermill Paper Com-




pany, Mr. Harlow's report should show that the pumping




conversion and separate discharge of the diffuser system




for the beach plant effluent should be completed by February 15,




1971.  And that will indicate the very significant reduction




in wastes from that company at that time.




          And unless there are questions, that completes my




report.




          MR. STEIN:  Are there any comments or questions?




          (No response.)




          I don't want to necessarily get into detail on




this, but I just want to spotlight this.  In your report,




you have North East Borough, Girard Borough, and Albion




Borough, Lake City Borough.  And presumably your Sanitary




Water Board has taken action, but your Office of Legal




Counsel has not scheduled hearings.  And these are removable




necessarily now, and they are in violation.




          MR. LYON:  Well, they are not now in violation




until the hearings are held and adjudicated.  We are asking




our Office of Legal Counsel to schedule these hearings as

-------
                                                       588



                         W.  A.  Lyon







soon as possible.




          MR. STEIN:   When I talk about violation,  I  mean




of the schedules received at this conference.




          MR. LYON:  That's  correct.




          MR. STEIN:   And then  I think we have one  more that




maybe we don't see the light at the end of the tunnel —




Welch Grape Juice  Company.  The thing we are looking  for is




just the feasibility report. We don't have a commitment yet




that they are going to clean up.




          MR. LYON:  No, my report says that adequate treat-




ment is provided.




          Are you looking on industrial wastes?




          MR. STEIN:   Table II.  It says, "Adequate treat-




ment provided for organic wastes.  Cooling water causing




thermal pollution.  Feasibility report due."




          MR. LYON:  Yes, that  is correct.  I will  ask Mr.




Bellaman  to comment on that.




          MR. STEIN:    Well, we can wait.




          MR. BELLAMAN:   We have received a schedule, but




I don't recall offhand what the schedule calls for.




          MR. STEIN:   I think my primary point is to spot-




light these so when we go to the workshops, we can get in




on these.




          There is one other one, and I hope we are over the

-------
                                                       589


                         W. A. Lyon




hump, because I think that, Walter, long before you went to


Pennsylvania, we were always dealing with the Hanunermill


Paper Company.  Do you think that Hammermill is completely


on its way now or do we still have some loose ends that we


are going to have to tie up before we can write that one


off and say they provide adequate treatment?


          MR. LYON:  I think Hammermill is completely on its


way.  There is one loose end that the company cannot control.


They have requested a permit from the Corps for an outfall

              ฃ
to handle its breach plant wastes, and we have issued a permit


for that discharge.  We think it will be completely adequate.


However, the Corps has so far not issued its permit.  We


hope they will.   If they don't issue that permit soon, there


is going to be a delay.


          MR. STEIN:  Does the Corps have some comments on


that?


          MR. HARLOW:  Yes.  The Corps has asked us for


comments, and we have provided the information to the Corps.


But the Corps has not released the permit  yet.


          MR. STEIN:  Are we in favor of the permit or not?


          MR. HARLOW:  We are in favor of issuing the permit


in connection with meeting the requirements of the Sanitary


Water Board.


          MR. STEIN:  Thank you.

-------
                                                       590



                        Perry Miller







          Are there any other comments or questions?




           (No response.)




          If not, thank you very much, Mr. Lyon.   And I




want to congratulate you on the program,  particularly on




solving this Hammermill Paper Mill case because I almost




dispaired that we would ever clean that up in our careers.




But I guess we are on our way.




          May we call on Indiana?






                  STATEMENT OF PERRY MILLER




            INDIANA STREAM POLLUTION CONTROL BOARD






          MR. MILLER:  Mr. Chairman, conferees, ladies and




gentlemen, my name is Perry Miller.  And I am representing




the Indiana Stream Pollution Control Board.




          In the introduction to this report, we have indi-




cated that we have contacted all of the industries in the




Lake Erie Basin, and there are not any of these that are




using mercury compounds.




          Also, Indiana has initiated a pesticide monitor-




ing program.  We received a grant of approximately $40,000




to institute such a program in the Lake Michigan Basin.  We




have expanded this and are doing pesticide monitoring in the




Lake Erie Basin as well as the Lake Michigan Basin.




          All Indiana municipalities in the Lake Erie Basin

-------
                                                       591




                        Perry Miller






with recognized sewer systems have secondary-type treatment




facilities.  In compliance with Indiana's Mandatory Certifi-




cation Act, all municipal wastewater treatment facilities




in the basin have a certified operator in responsible charge




of the facilities.  This, plus routine surveillance by repre-




sentatives of the Stream Pollution Control Board, has improved




operation and maintenance activities.




          The City of Fort Wayne is continuing the planning




and construction of major improvements to its combined sewer




system to provide separation and/or treatment of combined




sewer overflows.  A holding lagoon is  under construction




across the river from the treatment plant for studies on




effectiveness in reducing the pollution from sewer overflows




and primary effluent bypassing during  runoff from rainfall.




A storm sewer separation project is under construction in




Glenwood Park and an inner city storm  relief plan is proposed




if KUD funds are available.




          The Maumee River plant operated by Diversified




Utilities, a private utility, is still operating under over-




loaded conditions.  An order of this Board requires the




utility to expand its treatment facilities  (as provided by




the Federal Court) and to connect to the Fort Wayne sewer




system by September 1, 1970.  In addition, at least 80 percent




phosphorus removal is to be provided not later than December 31,

-------
                                                       592




                        Perry Miller






1972ป  In the interim,  requests for additional  connections




to the sewer system serving this area are not permitted.




Effluent Chlorination




          The Board's plan of implementation adopted in




1967 required the municipalities of Avilla,  Berne,  Butler,




Fort Wayne, Garrett, and Waterloo to provide effluent chlori-




nation facilities by the end of 1968.  Auburn,  Decatur, Garrett




Monroeville, and Waterloo and Diversified Utilities, Inc.,




are providing effluent chlorination.  Avilla and Fort Wayne




have chlorination facilities under construction and Butler  is




expected to start construction of plant improvements, includ-




ing chlorination, in the next few weeks.   New Haven's project




for plant improvements including chlorination and phosphorus




removal has been delayed by litigation against  the bond sale;




however, the city attorney has advised that he  expects the




project to proceed in the near future.  Berne  and  Garrett  do not have




an effluent chlorination project under way.




Phosphorus Removal




          To comply with the recommendations of the Lake




Erie conference for 80 percent reduction in phosphorus in




wastewater, the Board determined that all communities above




2,000 would be required to install phosphorus removal facili-




ties before the end of 1972 capable of reducing phosphorus




contributions by 80 percent.  The municipalities of Auburn,

-------
                                                       593




                        Perry Miller






Berne; Butler; Decatur; Diversified Utilities, Inc., Fort




Wayne; Garrett; and New Haven were notified of this require-




ment during April 1969.  As mentioned in the preceding




paragraph, Butler and New Haven have projects approved,




which include phosphorus removal, which should go to con-




struction in the near future.  The pilot plant studies on




phosphorus removal by the City of Fort Wayne are expected to




start in June 1970.  Berne and Decatur have grant applica-




tions on file for projects which include phosphorus removal.




          Of the 21 industries in the basin, 17 have adequate




waste control facilities and four need additional treatment




facilities.  Of the four industries, Kitchen Quip, Inc.,




Waterloo, and General Plating and Engineering Company, Fort




Wayne', do not have adequate control programs in progress.




          There is a list of 17 of the adequate industries




in the report.




          And it is also noted that Auburn Tankage Company,




Auburn, was closed in 1969.




          A status report on the five industries listed as




inadequate at the last status report in June 1969 is as




follows:




Franke Plating Works,  Inc., FortM^ayj^e




          Construction on cyanide and chromium wastewater




treatment facilities was started during March 1969.  Completion

-------
                                                       594




                        Perry Miller






was scheduled for the fall of 1969;  however,  because of late




start of construction and equipment delivery, the facilities




were not completed on schedule.   All equipment has been




delivered and final installation is being made and should be




completed by June 15, 1970.




International Harvester Company, Fort Wayne




          The company has completed all pollution control




work with the exception of improved sewage disposal for a




warehouse and packaging building located in the southeast




area of the plant.  The operation utilizes 290 employees and




the waste is treated by a septic tank-absorption system.




Only during extremely high soil moisture periods does any of




the waste reach the receiving stream.




          By September 1970, the level of employees should




drop to 100 which will improve the capability of the system.




Construction is proceeding on a sewer  (by a sewer utility)




which will enable discharge of this waste to the Fort Wayne




sewerage system.  Construction on the sewer by the utility




was started during the spring of 1968.  Construction was




stopped during the summer of 1968 because of court action




filed by a property owner concerning connection charges and




delayed again during late 1968 and early 1969 because of




financial difficulty brought on by the delay.  Construction




was restarted during March 1969.

-------
                                                       595




                        Perry Miller







          MR. STEIN:  When was that to be completed, Mr.




Miller?




          MR. MILLER:  I really do not have a completion




date, but I v/ould expect it sometime later this year.




          MR. STEIN:  I wonder if as soon as you get that,




wo could have it to complete the record,




          riR. MILLER:  Yes, sir, we will supply this.




          (The above-mentioned information follows.)

-------
                                                          595a

SxATEr  ~jS INDIANA            ~
                                   sป^^7/MKS^^l^
                                                        INDIANAPOLIS 46206
                                                          1330 West Michigan Street
  STREAM POLLUTION CONTROL BOARD                           esa^tm
                                                          June 29, 1970
     Mr. Murray Stein
     Assistant Commissioner
       for Enforcement
     Federal Water Quality Administration
     Department of the Interior
     Washington, D. C.   202^2
     Dear Mr.  Stein:
                          Re:  Conference on Lake Erie
                               and its Tributaries
          At the  reconvening of the Conference on Lake Erie and its Tributaries
     in Detroit on June 3 and 4, you requested information about the completion
     date for the sewer to serve the International Harvester Company in Fort Wayne.

          American Suburban Utilities advised us on June 12 that this  sewer
     should be completed in the International Harvester area by the Fall of 1970
     and certainly before December 31> 1970.

          In reviewing the report that was presented on behalf of the  Stream
     Pollution Control Board in Detroit,  there is a correction that should be
     made on Page 2  under Effluent Chlorination.  The City of Garrett  is providing
     effluent chlorination and, therefore, should be added in the second sentence
     as one of the communities chlorinating their plant effluent. The last
     sentence of this section should be corrected to show that the City of Berne
     does not have an effluent chlorination project underway.

          Should you have any questions concerning the above please contact us.

                                       Very truly yours,
                                             Poole
                                       Technical Secretary
     PEMiller/se

-------
                                                       595b




                        Perry Miller






Parrot Packing Company,  Fort Wayne




          Construction of a sewer was  completed on August 12,




1969, that allowed all the waste to be conveyed to the  Fort




Wayne sewerage system for treatment.  Adequate control  is




being provided.




General Plating and Engineering Company,  Fort Wayne




          The company started construction of cyanide and




chromium wastewater treatment facilities  during the fall  of




1968.  Progress on the construction was poor because the




owner insisted on doing a large part of the installation.




During the summer of 1969, the company abandoned much of  the




work accomplished and began installation  of another method




of treatment.  Attempts to obtain revised plans were futile




and enforcement action was initiated in November 1969.  A




hearing was held on February 4, 1970,  concerning pollution




of the receiving stream.  The recommended findings of fact




have not been issued, but should be available in the near

-------
                                                       596




                        Perry Miller






future.  The staff plans to recommend to the hearing officer




that plans and specifications be submitted by October 1,




1970, and waste treatment facilities be completed by Decem-




ber 1, 1971.  The company recently employed an equipment




company to complete plans for waste treatment facilities.




If corrective action is not taken, the matter will be referred




to the Attorney General as soon as practicable.




Kitchen Quip, Inc., Waterloo




          Because of above-normal streamflow during 1969 and




the spring of 1970, the staff has been unable to obtain suf-




ficient evidence for the Board to proceed with new enforce-




ment action.  The Board's order of June 18, 1968, was over-




ruled by the Lagrange County Circuit Court.  This plant will




be under surveillance during low flow periods to determine




if water quality standards are violated.




          MR. STEIN:  Thank you.




          Are there any comments or questions?




          (No response.)




          I just have one comment that I am raising as a




question.  I notice Kitchen Quip has been hanging around for




awhile, • and I recognize the problems.  I raise the question,




and I think we want to work this out mostly with you people




in Indiana, whether you want to go with the State action or




whether 180-day Federal action would be appropriate or

-------
                                                       597



                         Perry Miller







whether we should proceed on both fronts with Kitchen Quip.




I think we should try to remove that name from the list some-




time.




          MR. MILLER:  I would agree with you.  It should be




removed from the list.  And if you want my comment, I would




say I would be in favor of every action we can have to get




this removed.




          MR. POOLE:  It is the only case we have ever lost




in court.




          MR. STEIN:  I know.  And I think in that, we might




be able to help by using both.  But let's think about that




one.




          Any other comments or questions?




          MR. SEEBALD:  May I ask what the court found to




overturn your order?




          MR. POOLE:  It was based on some pretty fuzzy




technical data.  And this is why, Murray, maybe the 180-day




will do the trick.  We were unable in sampling in 1969 to




show any violation of our water quality criteria.  We are




just looking for 70 in lower stream flows.




          MR. MILLER:  This is a small plating plant above




Fort Wayne on the stream.  And there are times when he does




a fairly good job.  There are other times when he doesn't




do a good job.  And it is difficult, really, to run him down.

-------
                                                      598
          MR.  STEIN:   Right.




          Well,  thank you.




          MR.  POOLE:   We might have to wait for a drought in




Indiana.   That's the  reason maybe you can help us.




          MR.  STEIN:   You know, we can bring on droughts,




too.




          We are going to change the procedure a little.   I




said we would finish  all the  States.  But in looking at the




time -- New York has  a relatively short statement of about




15 minutes -- we will recess  for lunch.  Let's try to get




back here at 1:30.  We will take up the New York statement




and then the mercury  problem.  And we will try to finish




as early as possible  this afternoon.




          MR. EAGLE:   Mr. Chairman, sorry to say we will be




unable to be here this afternoon, but Mr. Van Den Berg of




the FWQA has worked with us on the mercury problem and can




speak for Ohio and make a report for Ohio on the mercury




problem.




          MR. STEIN:   Again,  I really appreciate that state-




ment.  You don't know how far we have come.  Mr. Van Den Berg




is our Federal official in Cincinnati who is in charge of




the enforcement task  force.  And when the State of Ohio gives




him the proxy to speak, I think we really have come a long




way on this.

-------
                                                       599
          We will recess for lunch.




          (Whereupon,  at 12:10 o'clock p.m.,  the meeting




recessed, to reconvene at 1:30 p.m.  the same  day.)

-------
                                                      600
                     AFTERNOON SESSION




                                            (1:40 p.m.)




          MR. STEIN:  Let's reconvene.




          MR. MAYO:   Mr. Chairman,  during the  presentation




of the information on status of compliance of  Federal




facilities yesterday, Mr. Poole raised the question about




the availability of comparable information to  that which Mr.




Harlow summarized for municipal and industrial installa-




tions.  We have distributed for each of the conferees a




summary sheet by name of agency giving the comparable status




of compliance information.  And this should be added to the




earlier report as an appendix.  (See p. 132A.)




          MR. STEIN:  Without objection, this  will be done.




          MR. PURDY:  Mr. Stein, I  have a question.  Does




this column mean that for U. S. Army, the total of 13




installations, the enforcement conference deadline was




August 1966 and that now anything to the right of that




column means that the schedule has  been extended?




          MR. STEIN:  No, the schedule hasn't  been extended




at all.  Anything to the right of that means they are in




violation.




          MR. PURDY:  O.K., but they are beyond the original




conference deadline.  The conference deadline  for all 13




U.S. Army installations was August of 1966, is that correct?

-------
                                                       601
          MR. STEIN:  Mr. Garnet.




          MR. GAMET:  That was the recommendation of the




conferees that all Federal installations should be in com-




pliance by August of 1966.  So as you say, everything to the




right of that column means they are in violation.




          MR. PURDY:  If that would compare with the earlier




charge, those that are behind schedule would be all of those




under no established schedule and those in date scheduled




for compliance in 1970, 1971 and 1972.




          MR. GAMET:  That is correct.




          MR. POOLE:  If I remember, back in 1966, out of




fairness to the Federal installations, we were not consider-




ing vessels at that time.




          MR. GAMET:  I realize that, but as I stated yes-




terday, I felt with the recent legislation and interest and




concern about waste from vessels, it was about time we




included a report on these which we considered to be Federal




installations.




          MR. STEIN:  Any other comments or questions at




this time?




          (No response.)




          We will call on Mr. Seebald.




          MR. SEEBALD:  Mr. Chairman, I would like to point




out that this will be the last report of the New York State

-------
                                                       602





                     R.  C.  Mt  Pleasant






Department of Health as  a member of this conference.   The




environmental health activities associated with water pollu-




tion will be taken over  as of  1 July by the new Department




of Environmental Conservation  in the State of New York.  And




it is assumed that a representative of  that department would




then sit as a conferee in future reconventions of this con-




ference.




          And towards that purpose, I have passed out a




progress report of the Department of Health on their pure




water program.  And in there there is an insert advising all




who use it or have access to it of the  creation of this new




department.  It contains the highlights of the accomplish-




ments of the Department of Health in the water pollution




field to date as of last December and points out the high-




lights of the program.  I do not intend this should be a




part of the record necessarily.




          The presentation for New York will be made by Mr.




Russell Mt. Pleasant, Director of Basin Development of the




State Department of Health.






            STATEMENT OF RUSSELL C. MT. PLEASANT




                ASSOCIATE SANITARY ENGINEER




                  DIVISION OF PURE WATERS




            NEW YORK STATE DEPARTMENT OF HEALTH

-------
                                                       603




                     R. C. Mt. Pleasant






          MR. MT. PLEASANT:  Mr. Chairman, members of the




conference, ladies and gentlemen, I am Russell Mt. Pleasant,




Associate Sanitary Engineer, the Division of Pure Waters,




New York State Department of Health.




          We passed out the formal statement to be presented




on behalf of New York State.  All of the conferees have




them.  I have given the transcriber a copy.  And there are




a few extra copies on the front table here.




          MR. STEIN:  You are going to summarize this,




aren't you?




          MR. MT. PLEASANT:  Yes.




          MR. STEIN:  Without objection, the full report




will appear in the record as if read.




          (The above-referred to report follows in its




entirety.)

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                                    604
              LAKE ERIE
     ENFORCEMENT CONFERENCE
          PROGRESS REPORT
        REPORT TO THE CONFEREES
             Detroit, Michigan
Submitted by
 THE NEW YORK STATE DEPARTMENT OF HEALTH
       HOLLIS S. INGRAHAM, M.D., COMMISSIONER

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                                                                        605
              NEW YORK STATE DEPARTMENT OF HEALTH

                       DIVISION OF PURE WATERS

                  Progress Report to the Conferees of the
        Lake Erie Federal Water Pollution Enforcement Conference

                                June 3,  1970
                             Detroit,  Michigan
            The following resume will describe the status of New York State's
water pollution control program as it effects Lake Erie water quality.  As in
the past,  only those discharges having a significant effect directly or indirectly
through Lake Erie tributaries from the Buffalo River to the New York-Pennsyl-
vania state line  inclusive,  will be discussed.  Comments will also be made
regarding New York State's current program involving previous conference
recommendations.

Enforcement Status
           As of May 1, 1970, 17 of the 42 previously tabulated sources
discharging into or effecting Lake Erie are considered abated,  inactive or
insignificant.   The remaining 25 unabated polluters discharge  a total of
225 MOD of wastewater.  Four industries and one municipality (Section B of
the Appendix) have facilities under^ construction which will intercept and treat
174 MGD.  Eleven municipalities  and four industries  accounting for another
21 MGD of wastewater are in the final or preliminary design.  One of these
industries may be referred to the Attorney General if progress does not
materially improve.  Four industries and a village discharging a total  of
30 MGD  have been referred for legal action including Departmental penalty
assessments or action by the Attorney General.  Specifics relating to industrial
projects  are  summarized in the attached appendix.

Construction Grants

           New York State's Pure Water Enforcement and Construction Grant
programs have generated $51.6 million worth of municipal construction projects
for water pollution control in this portion of the Lake Erie Basin.  State grants
of $21,4  million are committed to these projects  including pre-financing of the
federal share where necessary.  Similar expenditures by industries exceed
$16 million for projects already completed or under construction.  This
construction  program is in compliance with the $400,000+ comprehensive
sewage planning effort for Cattaraugus, Chautauqua and  Erie Counties.  Also
incorporated in this construction program are phosphorus removal processes
as required in New York State by the policy which was announced a year ago
in Cleveland.

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                                                                         606
Operation and Maintenance Grants

           Although major emphasis is currently on enforcement and
construction  for the elimination of water pollution, efforts are continuing
to concurrently obtain maximum performance from existing facilities.
As an incentive, New York State communities may receive  33 1/3%
reimbursement of their audited Operation and Maintenance  expenses.
Eligibility requirements include resolution by the governing body to adhere
to a specified time schedule for remedial action, when necessary.

           In the  Lake Erie enforcement area as previously described,
there are 37  sewage treatment plants serving a population of 131,000.  73% of
these plants  serving  97% of the  sewered population have received Operation
and Maintenance grants totaling about $1 million since 1965.  This program
has met with unqualified success in improving the level of plant operation and
protection of water quality standards.  More importantly, it has established
strategic  inroads with municipal officials in establishing awareness and good
habits necessary for effective operation and protection of capital  expenditures.

Highlights

           Continued progress has been achieved towards meeting the objectives
of the IJC and complying with the recommendations and conclusions established
by the conferees of the Lake Erie Enforcement Conference.  The Bethlehem
Steel Corporation  in the City of Lackawanna is setting the pace for pollution
control.  At  this time, all nine  (9) permits required for pollution abatement
facilities  have been  issued for construction of works to treat approximately
126 MGD of wastes at an estimated construction cost of $10.8 million,  $8 million
of which is completed.  These waste treatment facilities include treatment for
hot and  cold  bar and  strip  and slabbing mill wastes; coke oven wastes; blast
furnace and BOF including the final thickener,  the cold mill and  pickle liquor
rinse water and deep well  disposal of the concentrated waste pickle liquor.
Two operation permits have been issued,  one for the 45" slab mill wastewater
and one for the 10" and 12" bar mills.  These facilities treat up to 17. 8 MGD.
The other projects are very near completion and will go into operation in 1970.

           The Moench Tannery, Division of Brown Shoe Corporation, located
in the Village of Gowanda  has completed and  submitted final plans which provide
for treatment to adequately reduce  waste discharges to Cattaraugus Creek.
This was  approved April 23, 1970, and a construction permit issued.   Construc-
tion is now underway to be completed by June 1971.

           Republic Steel Company  has $3. 25 million worth of projects under
construction  to treat 23 MGD of process wastes from the Bar Mill,  Blooming
Mill,  Blast Furnace  and BOF.  Completion of construction is expected by
July 1971.

-------
                                                                          607
            The Buffalo Dye Plant, Division of Allied Chemical Corporation,
 has facilities under construction to pretreat 4. 5 MGD of process wastes
'before discharge to Buffalo Sewer Authority System.  Actual tie-in to BSA
 System is scheduled for January 1971.

            Final plans for  secondary treatment at the City of Dunkirk,  revised
 to include phosphorus removal, are scheduled for completion this  month.
 Construction of the outfall line and interceptor sewer is  already under construc-
 tion with overall completion by November 1971.

 Problem Areas
            Problems have besieged the municipal-industrial complexes in the
Villages of Fredonia and Westfield. In Fredonia,  the consultant was required
to conduct pilot plant studies in order to firm up final design.  The contributory
industry, Red Wing Company,  has  not taken significant action in construction of
pretreatment facilities prior to discharge into the village system.  This action
is long overdue and consequently the company's case was referred to the
Attorney General for legal action.  The requirement for pilot plant studies
has  caused the village to fall behind the construction start date.

            The joint municipal-industrial project for the Village of Westfield
was not sufficiently supported with information on which to base  final design.
As a result, the  consultant was required  to conduct pilot plant studies with
complete sampling and analysis to  substantiate a  rational design. Unfortunately,
the canning season has passed  and  this sampling and pilot plant study was
postponed until this coming September and October 1970.  The  village disengaged
the original consultant and retained another firm which is also evaluating the
industrial wastes from the three major food processing industries within the
village. All four entities are committed  to the same abatement schedule which
is slated for initiation of construction  by  October 1,  1971.   One of these,
Welch Grape  Juice Corporation, has been referred to the Attorney General's
Office for legal action.

Status of Conference Recommendations

1. Nutrient Removal

            The policy in New York State as developed and announced last year
has been implemented.  The  City of Dunkirk is including phosphorus  removal
processes  in  final design.  The Town of Hamburg Master Sewer  District will
also  include  removal units in its design.  The City of Lackawanna has
retained a consultant to evaluate the City's alternatives of upgrading  to
secondary treatment with phosphorus removal or  connecting  to the Hamburg
Master plant.  The Village of Westfield is faced with a nutrient deficient
combined industrial waste.  Evaluation of the  relevance  of phosphorus removal
in this instance will be forthcoming in project design.  The Villages of

-------
                                                                        608
Lancaster and Depew will connect to the BSA which is designing for phosphorus
removal.   The Ripley Sewer District and Village of Brocton are not within
the scope of the requirements and will attain whatever levels of phosphorus
treatment are inherent to conventional secondary treatment. There have not,
as yet, been  any industrial wastes  identified as needing nutrient removal.

2.  Deep Well Disposal

           This method of waste disposal remains  as one of last resort
which must be demonstrated to be of least effect on the  total environment.
To date, two permits have been issued for construction of deep wells for
waste disposal; the Hooker Chemical Corporation has recently abandoned this
method of waste disposal and the Bethlehem Steel Corporation  has not received
an operating  permit and  has  not yet used the well.

3.  Bathing Beach Surveillance

           This surveillance program was continued during the summer of
1969.  One hundred and forty samples were bacteriologically analyzed for
nine different Chautauqua County beaches.  In Erie  County,  308 samples were
tested from seven different beaches.  Extensive amounts of decomposing algae
rendered two beaches in the  City of Dunkirk unsuitable for bathing.  Both were
later reopened.

           In Erie County, less than 1% of the 303 samples exceeded  2400
coliforms/lOOml.  Sanitary surveys and repeated sampling discounted the
significance  of these results.

4.  Dredging

           A meeting is scheduled with the  Corp of Engineers  tentatively
June 1, 1970,  to discuss  disposal of harbor dredgings.

5.  Oil and Gas Drilling

           None of the prohibitive legislation introduced by various sponsors
against leasing and drilling for oil  and gas in New York's portion of Lake Erie
was passed.  However, the Commissioner of the  Conservation Department
has issued a  two year moratorium on all activities relating  to oil and gas
exploration,  drilling and production until the summer of 1972.  To date, there
have been no leasings granted.

6.  Combine  Storm and Sanitary Sewers

           No change in status.

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                                                                         609

 7.  Prevention of Spills

            A progress report through March 1970 on City of Buffalo's
 federal demonstration  grant, "Program for Preventing and Eliminating
 Oil Pollution of Buffalo River" is summarized by each of four phases:

            River Phase - On March 10, 1970,  an oil leak into the Buffalo
 River of about 1300 gallons was discovered and traced to the failure of an
 8" underground pipeline which carries "bunker G" fuel oil from the Mobil
 Oil refinery to Republic Steel.  The Gity of Buffalo immediately offered use
 of equipment derived from this grant, to Republic Steel officials and installed
 250 feet of Warne boom and two oil skimmers  at the  site of the accumulated
 oil.  Straw was spread on the slick that  had formed and Republic Steel
 personnel dredged and  removed an unknown mass of  oil and straw from the
 river bottom.  Attempts to remove oil remaining on  the surface and retained
 by the boom with two skimmers were hampered when straw clogged them.
 An air barrier has been installed across the river surface and experiments
 are being conducted on configuration and nozzle sizing to provide the most
 efficient air current under various  flow  conditions.

           Sewer Phase - Work continued on the development of an UV oil
 detector and on other sensors of small quantities of oil.  The former device
 is being calibrated and will be evaluated in the Buffalo River as  a probe.
 Development continues  of a sensor  head  suitable  for  sewer installation.

            Oil Sampling, Identification and Analysis Phase - Investigation of
techniques and their first quantitative results for analyzing bulk water samples
 are continuing.  Analyses of oil in various samples from the Buffalo River
 supports earlier evidence that the river  shore  is an efficient oil-sink and will
 continue to replenish the decreasing river  pollution level as cleanup measures
are placed in operation.  Vapor phase chromatography, UV spectroscopy and
various extraction agents are undergoing evaluation.

            Cost Analysis and Economic Evaluation Phase - The costs of
 controlling future oil pollution,  as well  as  eliminating existing oil pollution
will be determined for  the Buffalo River and the associated municipal sewer
 system.  The economic evaluation task  has been  postponed until the latter
part of the 27 month program.

8. Elimination  of Lake Front Municipal Refuse Dumps

           No such sites on New York State's  Lake Erie Waterfront.

9. Control of Deleterious Runoff

           The advisory committee to the Commissioner of Health on
agricultural drainage has prepared a final  draft of the report  entitled,

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                                                                        610
"Guides for Controlling Contaminate Emission Released from Confinement
Animal Production Farms".  Non-point discharges from cattle or other
livestock feeding or confinement areas are considerated as subject to
provisions of existing Water Pollution Control Law.  In this enforcement area,
there have been no sizable such operations identified.

            The Research and Development Unit of the Department is conducting
a detailed pilot demonstration study of small lake  basins ineastem New York
State.  The purpose of  the study is to gain a better understanding of the
eutrophication process  in order that an effective control program can be
carried out on a statewide basis.   Basic data on the physical, hydrological,
chemical and biological characteristics of the lake has been obtained.  This
provided the basis  for formulation of a detailed plan of research from which
to evaluate the need for and value of engineering control mechanisms such
as advanced waste  treatment, improved individual summer home disposal
methods,  changed agricultural  practices, diversion of land run-off or waste,
etc. 4  Completion of this  phase  is expected in 1970.

            Once the necessary control measures  are defined,   the final
phase of full scale  demonstration of the engineering control measures found
necessary will be performed  to determine costs and effectiveness.  This
phase will  be conducted during  1971 and 1972.

10.  Industrial Effluent Sampling Programs

           Industries discharging into or affecting water quality in  Lake Erie
routinely sample wastes,  maintain records and report periodically to the
New York State Health  Department.  Industries which are  required to monitor
these effluents as part  of an active operating permit are:
Eastern Tanners Glue Co.
The Borden Company
Bethlehem Steel
Nuclear Fuels Services
Penn  Central Railroad
Allegany Ludlum Steel
Gowanda (V)
Arcade (V)
Lackawanna (C)
Ashford (T)
West Seneca (T)
Dunkirk (C)
Gattaraugus  Co.
Wyoming Co.
Erie Co.
Gattaraugus  Go.
Erie Go.
Ghautauqua Co.
            Construction permits have been issued to the Penn Central
Railroad in the City of Buffalo and the Moench Tannery in Gowanda.  These
industries  will be required to maintain effluent sampling programs when
construction is completed.

            Testing and measuring is also carried on by the following
industries  included in the waste outlet registration program;
Allied Chemical
Donner Hanna
Socony Mobil Oil
Buffalo (C)
Buffalo (C)
Buffalo (C)
Erie Go.
Erie Go.
Erie Go.

-------
                                                                         611
Republic Steel                        Buffalo (G)             Erie Go.
Niagara Mohawk                      Dunkirk (C)             Erie Go.

            These data are being reported to Albany on an annual summary
basis for  compilation and evaluation with respect to permit renewals and
effects  of waste on water quality.

11.  Water Quality Surveillance Network

            New York State has established  a water quality surveillance
network consisting of 116 sampling stations including 12 automatic monitors.
Included in tiie Lake Erie Enforcement Conference area are manual sampling
stations on the Buffalo River,  1. 6 miles upstream from the mouth, on Buffalo
Greek at the USGS  gauging station in Gardenville approximately 10. 4 miles
upstream from its  mouth,  on Gattaraugus Creek at the Aldridge Street Bridge
in Gowanda approximately 16. 7 miles from Lake Erie, and in Buttermilk
Greek at Thomas Corners Road Bridge about 0.2 miles upstream from the
junction with Gattaraugus Creek.  In addition an  automatic monitor station
has been placed in  operation on Bird Island  in Buffalo  to continuously sample
the Niagara River and Black Rock Canal.

12.  Regional Planning

            Gounty-wide comprehensive sewage study  have been completed for
Erie, Chautauqua and Gattaraugus Counties. These studies initially were
responsible for some delay in achieving compliance with  abatement schedules.
However this has been overcome and  implementation is moving at  a brisk
rate.  Requirements for compliance with  comprehensive  plan for  construction
grants eligibility have been successful in  securing cooperation between
neighboring communities.

Summary

           In summary, treatment facilities are under construction to effectively
treat  over 75% of New York State's unabated wastewater discharges. Another
10% by volume are under preliminary or final design and  the remaining 15% have
been referred for Departmental penalty assessments and legal action by the
Attorney General's Office.

           A supplementary statement regarding the mercury problem in
Lake  Erie as it effects New York State is  attached.
         THIS CONCLUDES NEW YORK STATE'S PRESENTATION

-------
                    Lake Erie Enforcement Conference                 612

                             Progress Report

                              June 3, 1970

                            Detroit,  Michigan
             Supplemental Statement on Mercury in Lake Erie
           Surface water supplies,  wastewater outfalls, bottom sediments,
and fish in Lake Erie were sampled and analyzed for mercury concentrations.
Manufacturers,  distributors  and users of mercury and mercury compounds
were inventoried.  This investigation has been coordinated with FWQA.

           As a result of this investigation, it was determined that the only
industrial plant discharging mercury into the waters of Lake Erie was the
Buffalo Dye Works Division of Allied Chemical Company in Buffalo.  There is
no evidence that this discharge effects mercury levels in Lake  Erie water or
fish samples due to its proximity to the Niagara River out flow.

           However, on May 8, 1970, the company was directed to reduce
the wastewater discharge of mercury by our Buffalo Regional Office.  The
company's response was to completely suspend the  mercury using process.
(Mercury is used in this instance as an intermediate in the production of
dyes.) It was estimated that the company was using about 4 pounds/day of
mercury before  suspending the operation. On May  15, the  company was
directed to submit a plan by May 25, 1970, for elimination  of the mercury
discharge.  This plan has been received and is being evaluated. In the
meanwhile, operation of the mercury using process remains suspended.

-------
                                                                                                                                     613
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621

-------
                                                       622





                     R.  C.  Mt.  Pleasant






          MR. MT. PLEASANT:  The purpose of the report is




to describe the status of New York State's water pollution




control program and also the progress made on the Enforce-




ment Conference recommendations.  As in the past, the report




addresses itself to the wastewater discharges in the Lake




Erie portion of New York State from the Buffalo River to




the southern New York State-Pennsylvania State line.




          The enforcement status:  17 of the 42 previously




identified wastewater sources have been abated or have become




inactive or are now considered insignificant.  The remaining




25 unabated wastewater dischargers account for a total of




225 MGD of municipal or industrial wastewaters.




          Four industries and one municipality out of this




25 have projects under construction which will intercept



and treat about 174 MGD of this wastewater.  Four industries




and 11 municipalities accounting for another 21 million



gallons of wastewaters have projects in final or preliminary




design.  Four industries and one municipality accounting for




another 30 MGD of waste have been referred for legal action




including penalty assessments and Attorney General action.




          The specifics relating to the individual dates of




the abatement schedules and action taken and action pending




are included in the appendix attached to this report.




          With respect to construction grants, New York

-------
                                                       623




                     R. C. Mt. Pleasant






State's Pure Water Enforcement and Construction Grants




Program has generated a $51.6 million worth of construction




projects in this area for water pollution control.  State




grants to these projects amount to $21.4 million including




prefinancing of Federal shares when necessary.




          This construction is in compliance with the $400,000




comprehensive planning effort which is now completed for




Erie, Cattaraugus and Chautauqua Counties.




          This construction program is also incorporating




the phosphorus removal requirements in New York State as




described a year ago in Cleveland.




          With respect to operation and maintenance grants,




although major emphasis is currently on enforcement and con-




struction, efforts are continuing to concurrently obtain




the maximum performance from existing facilities.  As an




incentive, New York State communities may receive one-third




reimbursement of audited operation and maintenance expenses.




          And in this enforcement conference area, 37i sewage




treatment plants currently serve an estimated 181,000 people.




Seventy-three percent of these plants serving 97 percent of




this population have received about $1 million in O&M grants




since 1965.  This indicates that these plants do treat with-




in the design capability of the existing facilities and




have committed themselves to an abatement schedule acceptable

-------
                                                       624




                     R.  C.  Mt.  Pleasant






to the department.




          Unqualified success in improving the level of




plant operation and protection of water quality standards




has resulted from this program.  But more importantly/  it




has set the stage in establishing awareness and good habits




essential for effective operation and protection of the




capital expenditures underway.




          In the area of highlights, I would like to just




briefly run over the construction aspects of the waste




sources in this enforcement area.




          At Bethlehem Steel in Lackawanna, all 9 permits




required for the construction of essential pollution control




facilities have been issued by the Department of Health.




Two operational permits have been issued, one for the 45-inch




slab mill and one for the 10- and 12-inch bar mills, which




will handle 17.8 MGD.  These units are in operation.



          The total construction program for Bethlehem is



estimated at $10.8 million of which $8 million worth of




projects are completed.  Completion of all projects is




expected by June 1971.




          Republic Steel has $3.25 million worth of water




pollution control projects under construction which will




treat 23 MGD of process waste from the bar mill blast furnace




and basic operation general furnace.  Completion of

-------
                                                       625




                     R. C. Mt. Pleasant






construction at Republic Steel is expected by July 1971.




          The Moench Tannery, Division of Brown Shoe, at




Gowanda, New York, has completed and submitted final plans




which provide for treatment to adequately reduce its waste




discharges to Cattaraugus Creek prior to discharge into Lake




Erie.  Construction is now under way to be completed by




June 1971.




          The Buffalo Dye plant on the Buffalo River has




facilities under construction to pretreat 4.5 MGD of waste




prior to discharge to the Buffalo Sewer Authority System.




Actual tie-in to the Buffalo Sewer Authority is scheduled




by January 1971.




          Finally, the City of Dunkirk is revising its final




plans to include phosphorus removal which should be com-




pleted this month.  Construction of the outfall line and




the interceptor sewer is already under construction with




overall completion by November 1971.



          We have a couple of problem areas, just to briefly




go over, mainly at joint municipal and industrial waste com-




plexes.  In Fredonia in Chautauqua County, pilot plant




studies were required by the department to firm up final




design.  The major contributory industry in the village has




not taken action to construct required pretreatment facili-




ties and, consequently, has been referred to the Attorney

-------
                                                      626




                     R.  C.  Mt.  Pleasant






General's office for legal  action.




           MR. STEIN:  What kind of company  is  that?




          MR. MT. PLEASANT:  That is the Red Wing Company.




          MR. STEIN:  What  do they do?




          MR. MT. PLEASANT:  They make canning  products,




tomatoes.




          MR. STEIN:  It is a cannery?




          MR. MT. PLEASANT:  Yes.




          MR. STEIN:  Thank you.




          MR. MT. PLEASANT:  Requirement for pilot plant  work




on the Fredonia project has caused the village  to fall behind




on construction start date.




          In the Village of Westfield, a similar problem  is




encountered where the consultant was also required to con-




duct pilot plant studies to verify waste characteristics  and




treatability.  These studies will be performed  during the




upcoming canning season during September and October of this




year.




          The original consultant was disengaged and another




firm which is also evaluating industrial wastes from the




three major processing industries within the village was




retained.  All four entities are committed to the same abate-




ment schedule with start of construction by November 1971.




          One of the major  industries, Welch Grape Juice, has

-------
                                                       627




                     R. C. Mt. Pleasant






been referred to the Attorney General for legal action




because of inconsequential action taken on its requirements.




          With respect to the conference recommendations, I




will just skip through a couple of these.  With respect to




the nutrient removal policy, the policy that was described




last year is being implemented.  Municipal officials have




been contacted by the health department and the policy




described and their responsibilities included.




          At this time, the City of Dunkirk, the Town of




Hamburg master plan and the City of Lackawanna are being




required to provide for phosphorus removal facilities.




          The Villages of Lancaster and Depew in Erie County




will be connecting to the Buffalo Sewer Authority which is




also designing for phosphorus removal.  So far, no industries




have been identified as needing phosphorus removal.




          With respect to deep well disposal, this alterna-



tive remains as a method of last resort which has to be




demonstrated to have the least effect on the total environ-




ment.  To date, in New York State, two construction permits




have been issued, one to Hooker Chemical Corporation which




is not in this particular area.  This company has abandoned




this method of disposal in favor of reclamation of the




hydrochloric acid.




          Bethlehem Steel Company has received the other

-------
                                                       628




                     R.  C.  Mt.  Pleasant






construction permit.   That  well has been constructed,  is not




operating, and so far has not received an operating permit.




We anticipate that before any operating permit is issued, if




it is issued, it will be preceded by a public hearing.




          With respect to bathing beach surveillance in Erie




and Chautauqua Counties, nine Chautauqua County beaches were




surveilled and seven Erie County beaches.  None of these




beaches were closed because of coliform results.  There are




two beaches in the City of  Dunkirk that were closed because




of decomposing algae, but were later reopened after clean-up.




          I think before completing, I would like to include




the statement on the mercury problem in Lake Erie as it




affects New York State.   This is a short one.




          Surface water supplies, wastewater outfalls, bottom




sediments, and fish in Lake Erie were sampled and analyzed




for mercury concentrations.  Manufacturers, distributors



and users of mercury and mercury compounds were inventoried.




This investigation has been coordinated with FWQA.




          As a result of this investigation, it was deter-




mined that the only industrial plant discharging mercury




into the waters of Lake Erie was the Buffalo Dye Works




Division of Allied Chemical Company in Buffalo.  There is no




evidence that this discharge affects mercury levels in Lake




Erie water or fish samples due to its proximity to the

-------
                                                      629




                     R. C. Mt. Pleasant






Niagara River outflow.



          However, on May 8, 1970, the company was directed




to reduce this wastewater discharge of mercury by our Buffalo




Regional Office.  The company's response was to completely




suspend the mercury-using process.  In this instance, mercury




is used as an intermediate in the production of dyes.  It




was estimated that the company was using about 4 pounds per




day of mercury before suspending the operation.  On May 15,




the company was directed to submit a plan by May 25, 1970,




for elimination of the mercury discharge.  This plan has




been received and is being evaluated.  In the meanwhile,




operation of the mercury-using process remains suspended.




          That concludes this part of the presentation.




          MR. STEIN:  Thank you.




          Are there any comments?




          MR. MAYO:  I notice the report didn't make any




mention of the Mobil Oil refining problem.



          MR. MT. PLEASANT:  I will identify the wastewater




sources that have been referred to the Attorney General for




penalty proceedings.  This is in Section D of the appendix.




You are right, it isn't in the narrative.




          North Collins Village in Erie County and Producers




and Canners Cooperative in North Collins Village have been




referred to departmental penalty proceedings under the

-------
                                                       630




                     R.  C.  Mt.  Pleasant






public health law.




          Socony Mobil Oil  in Buffalo City has been referred




to the Attorney General for legal action.




          Red Wing Company  in Chautauqua County and Fredonia




has also been referred to the Attorney General for legal




action.  They are also challenging the validity of the




Commissioner's order under  an Article 78 proceeding.




          MR. STEIN:  What  is the Mobil Oil problem?  The




reason I am asking the question is just from looking at the




gallons per day discharge,  they are by far the biggest non-




compliance.  Are they objecting to the authority?




          MR. MT. PLEASANT:  No.




          MR. STEIN:  What is the problem?




          MR. MT. PLEASANT:  Delay and non-compliance with




the schedule just generally.  Specifically, perhaps Mr.




Seebald could elaborate.




          MR. SEEBALD:  They have high phenol in the oil and




run antiquated oil removal  apparatus.  And they have failed




to either renovate their existing equipment or provide us




up until last week with a report on their intentions.  We




received this just late last week, but we will probably not




take any direct action in response to this pending some




advice from counsel inasmuch as it is in litigation right




now.

-------
                                                       631




                     R. C. Mt. Pleasant






          MR. STEIN:  I can understand that.




          Any other comments or questions?




          MR. SEEBALD:  I would like to add just for the




record that three pieces of legislation in New York State




significant with respect to water pollution were passed by




the legislature at the past session.  One gives the depart-




ment the authority to control the storage and transportation




of hazardous liquids.




          The second provides for an aid program to assist




in the construction of lateral sewers in small communities.




          A third involves raising the penalties for water




pollution events from $500 to $2,500 in the first instance,




and for a continuing discharge, a daily penalty raise from




$100 to $500 per day.




          In addition, I would like to emphasize that the




problem in the municipal slippage as indicated in our tabu-



lation is centered around the fact that implementation of




the metropolitan plan provided for in the comprehensive




study has been hampered by the lack of an effective umbrella




agency for this type of implementation in Erie County and




has not been due to any real foot dragging on the part of the




communities   themselves.  They have been willing to amal-




gamate, but there has been no incentive at the top level.




And actually the effectiveness that has been instant to

-------
                                                      632




                     R.  C.  Mt.  Pleasant






date has been through the State requiring a combined approach




to sewage and sewage treatment  using the eligibility for




grant assistance with Federal Government support hinging upon




the requirement that they comply with the comprehensive study




acceptable to the Commissioner.  And it is to be hoped that




the Federal Water Quality Administration will continue to




support this comprehensive study to allow us to persuade




these communities to join together.




          I noted this morning  it was brought up by Mr. Remus.




It is one of his fond hopes that the Federal Government will




continue to support this comprehensive approach to sewage




treatment and not permit a GTA  loan policy supplied with




Federal or local assistance.




          MR. STEIN:  Are there any comments or questions?




           MR. POOLE:  May I ask one?




          What about the local  sewer program?  How much fund-




ing was provided for that?




          MR. SEEBALD:  It has  been a mystery.  It was a




$10 million appropriation.  The first payments will not be




made until next fiscal year, March 31, 1971.  By that time,




we hope to nail down just the exact amount of funding.




          This last legislature adjourned in rather hurried




fashion and left quite a bit of this legislation pending,




including of most significance, of course, the funding of

-------
                                                       633




                     R.  C. Mt.  Pleasant






the various programs.




          MR.  POOLE:  What percentage of the costs can you




take?




          MR.  SEEBALD:  It is based upon an upset figure of




$150 per household connection,  the State picking up the




remainder up to the cost of the actual connection.  This is




based on a sliding scale with the base determined by the




number of connections and the total cost of the project.  As




the number of connections increase, the actual per connec-




tion support will decrease.




          MR.  POOLE:  Thank you.




          MR.  STEIN:  Are there any other questions or com-




ments?




          (No response.)




          If not, thank you very much.




          I think that concludes the State presentations.




Before we go into the consideration of mercury, do any of




the States have anything for us to consider?




          MR.  PURDY:  Only one suggestion, Mr. Stein.  And




this is to expand your request to have a joint Federal-




State review of the Ford Motor Company project.  I would like




to expand that to have a joint Federal-State on-site review




of all of those projects that are listed in your report as




being behind schedule so that there will be a complete under-

-------
                                                       634
standing on both sides here.




          MR. STEIN:  Will that be agreeable?




          If I understand the suggestion — and I might say




I think this is good — if we have projects which are listed




as behind schedule in our report, we should be able to get




together with the State concerned and hopefully the industry




and come up with a statement on that project which is agreed



to, factual statement which is agreed to.  That State, the




Federal Government and hopefully the industry ought to give




a substantial description of what the situation is.  This




will be based on inspection where you think it appropriate




and not just representation.



          MR. PURDY:  That's right.  Where facilities are




under construction and so forth, this will be an on-site




inspection.




          MR. STEIN:  I visualize this to be somewhat like




the reports we got of the 180-day notice reports where we




signed off that everyone was in agreement that this was what




the situation is.  And in all those cases, by the way, I




think we all are in agreement that the program is proceeding




and no further action is necessary.




          MR. PURDY:  I hope we can reach that conclusion.




          MR. STEIN;  Well, I don't know, but I think the




only possible way you can reach that is for everyone to

-------
                                                       635
agree on the facts.




          MR. PURDY:  Right.




          MR. STEIN:  And this is what I think Mr.  Purdy is




proposing.  Will we  be able to do that with them?




          MR. MAYO:   As far as the regional facilities are




concerned, it is going to be a very substantial work load.




We would have to sit down and from the Regional Office




establish point and  make some evaluation of what it would




require in the way of manpower and resources to conduct what




may be a hundred or  more inspections.




          MR. STEIN:  Well, let me make this offer  to you:




We will supply the people to you from our national  resources




to do that because I think this is essential.  Otherwise, we




are just going to come here and in the absence of an inspec-




tion and an agreed-upon report, we are going to necessarily




get disparities.  And we are at the stage of the case where




I think we have to get down to the hard facts.




          By the way, let me tell you when this was done in




Ohio, there was complete agreement as far as I know with the




city, the industries, the State and the Federal Government, on




the facts of the five cases involved.   And as far as I can




see, there is no factual problem or difference now.




          We have the same situation involving that Eagle




Petrol case.  And I  think this is just one activity that we

-------
                                                       636
are going to have to engage in if we are going to deal with




compliance or alleged violations to determine whether further




action is necessary or not.  And I don't see if you are ever




considering modifying or overlooking the compliance how you




could ever make the recommendation without having this.  I




myself can't see how we possibly can move ahead.




          MR. POOLE:  I would like to put in a bid to have




that done for the Indiana projects also, Mr. Chairman.




          MR. STEIN:  Is this agreeable?




          MR. LYON:  Do I understand this correctly, Mr.




Chairman, you are planning to go over every project that is




behind schedule?




          MR. STEIN:  That is alleged to be behind schedule




so we have an agreed-upon factual statement with the industry




if we can get it, but certainly with the State and Federal




Government.




          MR. LYON:  They will be done at these regional




conferences?




          MR. STEIN:  No, we will send our men out with you




and make arrangements to do it.  Because in a lot of cases,




you are going to sit down in the office.  And as you and I




well know, you can talk and talk, but you have to go out




and look before you are going to decide what the situation is.




          MR. LYON:  Well, let me just try to clarify this.

-------
                                                       637
Are you saying that you are going to physically visit every




single sewerage source and every single industrial waste




source that is in fact behind the original schedule that was




set up originally?




          MR. STEIN:  No.  What I am saying is where you




could not come to an agreement by sitting in the office or




where there is a doubt, then you have to go out and look.




Obviously, you are not going to spend time, I would hope,




where everyone is in agreement or you feel there is no doubt.




          MR. LYON:  I misunderstood.




          MR.  MAYO:  Then, I misunderstood also, Mr. Chairman,




Under those circumstances, I think we can work within our




existing resource.




          MR. HARLOW:  I think we ought to recognize, Mr.




Chairman, though, probably over half the cities and indus-




tries involved here are in Ohio.  And Ohio is not here to




speak for this.




          MR. STEIN:  We will offer this.




          Now, my guess with Ohio is that Ohio will partici-




pate as you could tell with their approach here today.  They




have participated with us in the past.  And as a matter of




fact, maybe we should take our hat off;  because before, when




Mr. Purdy suggested that we come to this stage with these




Ohio communities, they made a request that someone from the

-------
                                                        638
Federal Government attend their monthly meetings  —  each  one  —




so as these came up, we and they could proceed on the  same set




of assumptions on the facts.  If there were any differences in




the facts, we could go out and investigate them and  see what




the truth of the matter v/as.  I have no doubt that Ohio is




going to push this,




          I think in the absence of this,  as they say  back




at home, it is going to be more work for mother.   This is




the fastest way of doing it.




          Unless we can get agreement and  complete agreement




between the State and the Federal Government on the  facts at




this stage of the operation, we may embark on procedures




which can be very time-consuming and have  really  drastic




legal consequences.  So I think we have to keep that in mind




and move.  And hopefully, the industries and the  cities will




join us in that.  Because I think this is  to everyone's




benefit,




          MR. LYON:  My confusion arises,  and I think  we




have already spent a lot of time — almost two days  here  —




in this thing, is this something that is going to happen




before these regional meetings or is this  joint Federal-




State review?  Will this happen, for example, in Pennsylvania?




When you come to Erie, are we going to look at the facts  and  -•




          MR. STEIN:  No, no.

-------
                                                       639
          MR. LYON:  May I finish this point?  Am I correct




that we are going to then look at the record, and if we




agree, that is fine.  And if we don't agree, then we are




going to go out in the field and look at it?




          MR. STEIN:  Right.




          MR. LYON:  But the Erie meeting will be the time




when we carefully review each case?




          MR. STEIN:  When we see what we have to do.




          Now, the Erie meeting also, as I understand it,




has another aspect.  At the Erie meeting, we will want to




hear from the industry and the people and other jobs to see




what information they have.  They may raise some points




which may require investigation before we can lay those to




rest and settle them.




          MR. LYON:  My only concern is that we try to as




efficiently as we can get together on information.  We find




that we are spending so much of our time giving information




to the Federal Government and going to meetings that we




don't have much time left to clean up the pollution.  So my




only suggestion is let's please make this process official




so we don't have to write 10 more letters and write five more




reports and go to five more meetings.  If we can clean this




up at the Erie meetings and if there are any differences,




fine, we will go out and look at the facts.

-------
                                                       640
          We feel the Federal Government should have all the




facts and should take enforcement action when it is needed.




But let's try to somehow streamline this process.  We feel




very frustrated by the many Federal reports we have to sub-




mit.  And frankly, we just don't have the man-hours.  We




think our time should be spent cleaning out pollution.




          MR. HARLOW:  Since it looks like my office may be




doing some of this work, I want to make sure I understand




what it is you are asking for.




          Now, if you are talking about putting together,




like you said before, some kind of statement regarding what




we did on the 180-day notices, I think you are talking about




a major undertaking.  But if you are talking about just




sitting down in the State offices and going over city by city,




industry by industry, those that are behind and coming to an




agreement on what the status is, my first reaction is that




this, we already have.




          MR. LYON:  That's right.  We just did that.  We




just sat down.




          MR. HARLOW:  We have been doing that the last three




or  four weeks.




          MR. STEIN:  I am not sure you are in complete agree-




ment, and I am not sure you have checked these facts out on




the basis of an inspection.

-------
                                                       641
          MR. LYON:  Mr. Chairman, they change almost from




day to day.  So you will undoubtedly find that the facts




in some of these cases will have been changed by next week,




some for the better, some for the worse.




          MR. STEIN:  No one is arguing about those changes.




We are talking about apparent differences in Federal, State




and industry reports when they come in at the same time.




          Now, I thoroughly agree with what this is going to




say, but one of the reasons, I think, is not because it is




a Federal or State report or a meeting,  I think if we are




going to sit around on our bureaucratic rear ends, I fear we




are going to get enmeshed in operations.  And if it takes us




this long to get a simple inspection and recording system




off, I understand why it takes so long.  I don't look for




this to be an involved operation.




          MR. LYON:  Yes, but the problem is, Murray, we



were just asked by your Charlottesville office for the same



information about two months ago.  And it is taking us




literally thousands of man-hours to put all of this informa-




tion together.  We separately gave it to Mr. Harlow.  We




also have to submit it separately as part of the comprehen-




sive planning process.




          And frankly, I am not going to keep any more




people in the office to do clerical work.  We simply have

-------
                                                       642
got to get out into the field and check on polluters.




          Last year, Pennsylvania lost 6,000 inspections




because we were kept in the office doing clerical work,  fil-




ling out Federal reports.   And we simply can't do any  more.




          MR. STEIN:  I think maybe I misunderstood Mr.




Purdy, but if you think this involves clerical work, I think




we missed the point.




          MR. LYON:  If it doesn't, we have got no problem.




          MR. POOLE:  Mr.  Chairman, may I get in?  As  you




well know, we did some of this with both Illinois and




Indiana industries in the south end of Lake Michigan.   And




it was a special project,  Walt.  But it was done in a very




short period of time — in this case, I think a matter of




about two and one-half weeks.  And my judgment is that it




had a very healthy effect on a portion, at least, of the




people that we looked at in those inspections.




          Like Pennsylvania, I don't want to get involved




in a lot more paper shuffling and report writing and office




work.  But what I visualized as Purdy and the chairman




started discussing this is that I would like for somebody




to come down to the office and we will go over our list and




then jointly go into the field and sort of put it up to




them, whether it be a city or an industry, that we have come




here to look things over to make up our mind whether or not

-------
                                                      643
the 180-day notice ought to be filed against them.




          And I think that that kind of a visit will shake




some of these places off of dead center whereas if I go back




to Indianapolis in the morning and say, "I have been up to




Detroit two days, and you are behind schedule, and people




are getting awfully impatient about this and you better get




on the ball," they will pay a lot more attention to the




joint inspection than they will to that communication from




me.




          So I would not like to reserve the Indiana work




only to either industries or cities where there is a difference




of opinion between my office and Mr. Mayo's office or Harlow's




office as to the rate of progress.  I think it is workable.




I don't think it will take too much time.




          And if you want to know what I actually think




about it from the standpoint of pollution abatement, I think




it will do a hell of a lot more good than sitting here at




this table talking about it for the last two days.




          MR. STEIN:  I agree with you.




          May I make just one more comment as an example




here?  Going to a major United States steel company — and




I was there with George — we went there on one of these




visits, and we looked at the effluent,coming out of their




operation.  And they had a pretty extensive operation.  The

-------
                                                       644
air looked like about the color of  this  cigart maybe  a  little




lighter.  And they bragged in the office.




          I said,  "Let's see the effluent  line."   I said,




"Do you mean this  is what you are putting  out?"




          And they indicated some days it  is better,  some




days it is worseป




          I said,  "Well, you know,  this  is a great thing.




What would you have done today if I came down with the




League of Women Voters and they saw this effluent?"




          Well, we had a little polite conversation*  Then




the companies were served with 180-day notices.




          When George Harlow went back there  the  next week,




do you know what the color of that  effluent was?   The color




of this water.  And it was the same facility.




          I agree with Mr. Poole, if we  can get that  kind




of improvement with just a little visit  like  that, it does




a lot more good when you give this  individual attention and




spotlight the facts than by almost  any other method.




          The reason I say that is  I think we are at  this




stage of the game.  In these earlier planning stages  dealing




with preliminary reports, this wouldn't  be effective.




But at the stage of compliance and  enforcement we are at




now, I think this can be the most effective method and

-------
                                                       645




                     L. A. Van Den Berg






produce the most rapid results.




          MR. LYON:  No objection at all to that as long as




we don't get a letter from George Harlow asking us to once




more update all our cases.  I would be happy to review




every one of them at the yearly meeting and cooperate with




you.




          MR. MAYO:  Mr. Chairman, the Regional Office will




accept the responsibility for putting together a schedule.




And we will be in touch with you.




          MR. STEIN:  All right, is there anything else




before we go on to mercury?




          (No response.)




          Let's go on, then.  Mr. Mayo.




          MR. MAYO:  Yes.  The presentation of the mercury




report for the Federal  Water Quality. Administration will




be given by Mr. Lowell Van Den Berg, Assistant to the




Director of the National Field Investigating Center of FWQA,




Cincinnati, Ohio.




          I understand that a Mr. Beebe of the Food and




Drug Administration may be available here this afternoon.




Is he in the audience?

-------
                                                       646




                     L.  A.  Van Den Berg






             STATEMENT OF LOWELL A. VAN DEN BERG




                  ASSISTANT TO THE DIRECTOR




             NATIONAL FIELD INVESTIGATIONS CENTER




             FEDERAL WATER QUALITY ADMINISTRATION




                       CINCINNATI, OHIO







          MR. VAN DEN BERG:  Mr. Chairman, I have additional




information since this report was compiled.  I took the




liberty last night of incorporating that data in this one




revised copy.  So I will update the report and send you a




copy for inclusion in the record.




          MR. STEIN:  Yes,  go ahead.




          MR. VAN DEN BERG:  This report was compiled by




personnel from the Great Lakes Regional Office, Lake Huron




Basin Office and Lake Erie Basin Office, in cooperation




with personnel of the National Field Investigations Center.




          The introduction starts on page 8.




          The toxic effects of mercury and its compounds in




the water environment are well known and are documented in




the literature.  However, much remains to be learned on




toxicity limits of the various mercurial compounds in the




water environment.  The upper limit of mercury in food,




used by the Food and Drug Administration, is 0.5 ppm wet




weight.  Limits have also been set for atmospheric concentra-

-------
                                                      647




                     L. A. Van Den Berg






tions and numerous cases of poisoning have been reported.




          Critical pollution from mercury became apparent on




March 24, 1970, in the Great Lakes.  Mercury concentrations




as high as 500 parts per billion (or 5 ppm) were reported in




some of the pickerel shipments from Canada and commercial




fishing involved was suspended by Canada, then Ohio, Michigan




and New York.  The presence of mercury in fish and bottom




sediments in the St. Clair River-Lake Erie system has con-




firmed the existence of an environmental problem of major




scope.




          Mercury is discharged to the water environment




from industrial processes and uses of mercurial products.




In 1968, mercury produced from mining in the United States




was 2,194,000 pounds.  The total amount used in 1968, how-




ever, was 5,732,000 pounds.  Over 163 million pounds of




mercury have been consumed in the United States in the pre-




sent century, but little information is available on the




final disposition of it and amounts accumulated in the




environment.




          Metallic mercury and mercurial compounds in liquid




wastes are characterized by their high densities.  Free




mercury and the mercurous compounds form sludges and settle




to the bottom of receiving waters.   The mercuric compounds




form precipitates with oxides, phosphates, sulfides and

-------
                                                      648




                     L.  A.  Van Den Berg






carbonates.  The high density is responsible for the rapid




deposition in bottom sediments where they persist,  become




subject to sediment transport and are available to  the




aquatic life.




          Metallic mercury  can be oxidized readily  to divalent




mercury ions under the conditions present at the bottom of




lakes and rivers.  This has been shown to occur experimentally




as well.  The divalent inorganic mercury produced has an




extremely strong affinity for organic muds and is methylated




in the bottom sediments.  Divalent organic mercury, when




methylated, is readily released from the sediments  into the




water.




          Many fish are bottom feeders or feed upon organisms




which are bottom dwellers and therefore the hazard of mercury




ingestion becomes very great.  Pish also absorb mercury from




the water through the gills and possibly the scales.




          Since biological  concentration of mercury occurs,




the accumulation of mercury in the food chain is a matter of




grave concern.  A recent report indicates a magnification or




concentration of mercury of over a million in the protoplasm




of bacterial species.  It has been demonstrated that the con-




centration from water to pike is in the order of 3,000 or more.




Uses of Mercury




          Sources of mercury in the environment principally

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                                                       649

                     L. A. Van Den Berg


come from industrial processes utilizing a form of mercury

and the use of mercurial products by man.

          The industrial uses in 1968 are listed as follows:

These values are in thousands of pounds.

     1.  Electrical apparatus                      1,492

     2.  Electrolytic preparation of
         chlorine and caustic soda                 1,326

     3.  Paints                                      803

     4.  Charging new installations of
         chlorine and caustic soda cells             630

     5.  Industrial and control instruments          581

     6.  Agricultural uses                           260

     7.  Dental preparations                         158

     8.  Catalyst preparations                       145

     9.  Laboratory uses                             151

    10.  Pharmaceuticals                              32

    11.  Pulp and paper uses                          31

    12.  Amalgamation                                 20

          Mercury is used as the cathode in the electrolytic

manufacture of chlorine with caustic soda and hydrogen as

by-products.  Cell recharging to make up the various losses

from this process was 26 percent of the total mercury used

in 1968 by all industries.  To maintain the mercury inven-

tory it required purchases of 1.3 million pounds of mercury

in 1968.  Weak spent brines, acids from the chlorine driers,

-------
                                                       650




                     L. A.  Van Den Berg






brine sludges and cell cleanings are discharged to the water




environment from this process.  The mercury may be metallic




mercury emulsion, soluble and insoluble mercury salts.




          In 1968, 630,000  pounds of mercury were used in the




start-up of new electrolytic installations.  This amount




eventually contributes to the cell losses.




          Information from manufactures of  mercurials used




for herbicides, fungicides  and bactericides is not readily




available.  These compounds usually are produced in batch




processes and require considerable cleanup   with possible




losses of mercury.




          In the pulp and paper industry, phenyl mercury




acetate is used for slime control and ground wood pulp may




contain up to 20 ppm of the fungicide.  This mercury is




either lost to the product or to the waste  load during pro-




cessing.  In either case it becomes a waste.




          Large quantities  of mercury are used in the manu-




facture of electrical apparatus and industrial and control




instruments such as mercury cells, arc lights, pumps and




switches.  This poses a hazard of loss during the manufac-




turing process.




          Catalysts, containing 10 percent  mercuric chloride




are manufactured for use by the petrochemical industry.  This




is made by passing a water solution of mercuric chloride over

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                                                      651




                     L. A. Van Den Berg






carbon and is used for making vinyl chloride from acetylene.




Another catalyst containing mercuric sulfate is used in pro-




cessing acetylene to acetaldehyde.  There are losses to the




water environment from these processes.




          Paints, those used for mildew control as well as




those having anti-fouling characteristics, contain mercury,




usually in the organic form.  Erosion from paint films con-




taining these compounds is another source of loss to the




environment.




          Mercury is used in dentistry for the preparation




of amalgams.  Minor losses may result from this use.




          Laboratory use of mercury in manometers, thermo-




meters, calomel cells, standard cells and as reagents results




in an occasional discharge to sewers.  In large research




centers or universities, the quantities can become appreciable.




          Minor users of mercury are the pharmaceutical manu-




facturers and in amalgamation.  In the pharmaceutical manu-




facture, diuretics and antiseptics, i.e. calomel, phenyl




mercury acetate and merthiolate are made.  Accidental spills




are the source of loss to the water environment.




          The recovery of gold and silver by mercury amalgam




is a wet process and may result in rather high losses of




mercury in the plant effluent.




          Additional mercury is introduced to the water

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                                                       652




                     L. A.  Van Den Berg






environment through the use of products containing mercurial




compounds.  The most widespread example of this is in the




agricultural application of fungicides and pesticides, which




results in losses during periods of runoff from the area to




which they are applied.




          The FWQA-Lake Huron Basin Office (LHBO) initiated




a water and sediment sampling and analysis program for mercury




in the St. Clair River to Lake Erie system immediately after




the Canadian Government announced the fishing ban in Lake




St. Clair on March 24, 1970.




          Sample collections were made by personnel from the




Lake Huron Basin Office with assistance from the Michigan




Water Resources Commission.




          Water samples were collected with a surface grab-




sampler.  Sediment samples are obtained by the use of either




a Petersen dredge or a drag line sampler.  These devices




penetrate the bottom to about one-fourth foot.




          The State of Michigan reports no measurable mercury




in any water supply intakes within this area.




          Page 15 is one of those which I rewrote.




          St. Clair River and Lake St. Clair.  Fifteen




sediment  samples and 6 water samples were collected in the




St. Clair River.  All water samples contain less than the




measurable concentration at 37, 33 and 25.5.  They contain

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                                                       653




                     L. A. Van Den Berg






concentrations of 1.0, 0.2 and 0.3 milligrams per kilogram




by weight respectively.




          The other 12 sediment samples contain less than




the measurable limit of 0.5 milligrams per kilogram wet




weight, but indicated traces of mercury were present.




          In Lake St. Clair, one water sample and 26 sediment




samples were analyzed.  Six sediment samples and a naviga-




tion channel close on the U. S. side contain mercury and are




in concentrations from 0.3 to 9.2 milligrams per kilogram.




          Two samples from a disposal area outside the channel




contain mercury concentrations of 1.5 to 2.1 milligrams per




kilogram dry weight.




          The other 18 sediment samples indicated the pre-




sence of mercury, but were less than the measurable limit.




          Upper Detroit River  (Lake St. Clair to Grassy




Island), page 20, sampling of the upper Detroit River and




lower Rouge River began on March 26, 1970, and continued to




April 24.  Sixteen sediment and 6 water samples were obtained.




Mercury was detected in sediments along the U. S. Shore line




at boat ramps and in other backwater areas.  Values ranged




from below the measurable level near the headwaters to 2.0




mg/kg downstream from the Rouge River.  Levels in sediments




around Grassy Island and upper Fighting Island were all




below the measurable limit.

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                                                      654




                     L. A. Van Den Berg






          Lower Detroit River (Grassy Island to Mouth).




          In the portion of the Detroit River from Grassy




Island to the mouth of Lake Erie, 78 sediment and 23 water




samples were collected between March 26 and April 16.  The




highest levels of mercury occurred in the bottom muds of




the Trenton channel downstream from the Wyandotte Chemicals




Corporation South Works, in a narrow strip of from 20 to




100 feet along the western shore.  Concentrations along the




east shore of the channel near Grosse lie are less than the




measurable limit of 0.5 mg/kg.  Mercury in the sediments




indicates that the Wyandotte Chemicals mercury discharge




hugs the western shore of the Trenton channel, depositing




mercury in the bottom muds along shore.  No mercury deposits




were found around Wyandotte Chemicals waste beds, located




on the northern tip of Grosse lie.  However, one sample




collected between Grassy Island and Grosse lie contained 4.4




mg/kg mercury.




          Mercury concentration in sediments was found




along shore as far as Lake Erie.  In addition to high values




near Wyandotte Chemicals, one sample with 26.0 mg/kg dry




weight was present at the northern tip of Horse Island




(Gibraltar, Michigan) at mile point 6.7.




          Of the four samples collected at the southern end




of Fighting Island, one contained 1.2 mg/kg mercury, and the

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                                                       655




                     L. A. Van Den Berg






others contained trace amounts, but were less than the




measurable limit.  Wyandotte Chemicals waste lagoons are




located on Fighting Island.




          The only mercury measurable in four samples in




Canadian sediments was near the shore at mile point 3.9.




That value was 0.6 mg/kg.




          The levels of mercury in all water samples but




one were below the measurable limit of 0.01 mg/1.  One




sample collected 300 feet downstream from Wyandotte Chemi-




cals outfall W23 (RM 13.3) contained 0.03 mg/1 March 31,




1970.  The effluent was diluted by Detroit River water so




mercury was not measurable further downstream from the dis-




charge point.




          Western Basin of Lake Erie, including the Raisin




and Maumee Rivers.




          The sampling of Lake Erie began on April 6, 1970,




with bottom sediments collected at two stations near the




mouth of the Huron River.  From April 6 to April 27, 44




bottom sediment stations were sampled.  Samples were collected




in western Lake Erie west of Pelee Island, with the majority




of samples collected near the mouths of Michigan tributaries.




Based on the measurable limit of 0.5 mg/kg wet weight, mer-




cury was present at 16 of the 44 stations, although traces




were found at most of the other stations.

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                                                       656




                     L.  A.  Van Den Berg






          The Raisin River was sampled on two different




dates at three stations.  Traces of mercury were found;




however, all results were less than the measurable limit.




          The Maumce River was sampled on April 17 at six




stations, and traces of mercury were found at most stations;




however, all results were less than the measurable limit.




          The 16 stations where mercury was found are




located in the deepwater areas of the western basin of




Lake Erie from the mouth of the Detroit River southward and




eastward.  Since shore line and minor tributary samples do




not show appreciable amounts of mercury, the Detroit River




appears to be the principal source, with mercury being




deposited in the deeper quiescent parts of the lake.




          Mercury analyses in the eastern portion of the




Lake Erie Basin.




          As part of its mercury investigations in the Lake




Erie Basin, the Federal Water Quality Administration-Lake




Erie Basin Office analyzed bottom sediments from the lower




portions of south shore tributaries and from the lake bottom.




Tables 10 and 11 include results from the sediment and water




analyses to 5/12/70 except those made at the Detrex Chemi-




cal Corporation plant.  Detrex analyses are listed in a




special report on the plant (Appendix II).




          At the Lake Erie Basin Office the lower limit of

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                                                       657




                     L. A. Van Den Berg






measurability of mercury in sediments is 1 mg/kg and in




water 0.002 mg/1.




          The States of Ohio, Pennsylvania, and New York




report no measurable mercury in any water supply intakes




within this area.




          In Table 10 on page 39,  you will note that mercury




concentrations at the hydro discharge to Grand River, Dia-




mond Shamrock, Painesville, is 0.01 mg/1.




          Euclid sewage treatment plant is 0.004.




          Cleveland Southerly STP          0.004




          Cleveland Westerly STP           0.003




          Cleveland Eastern STP, less than 0.002




          Mile 1.0 West Branch Ashtabula River 200 feet




downstream from titanium plant, less than  0.002




          General Electric, Nela Park, Cleveland - discharge




3 gallons cover water every two weeks      1.060




          This is a very insignificant amount of mercury




on a daily basis, but on Table 11 is Black River at mile




0.61, 8.




          One hundred feet north of the Easterly sewage




and treatment outfall, it was 4 mg/kg.




          Fifty feet north of the East 222nd Street - Babbitt




Road sewer outfall in Euclid, it was 2 mg/kg.




          The Ashtabula River at 0.76 mile, it was 2 mg/kg.

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                                                       658




                     L. A. Van Den Berg






          And No Name Ditch east of Ashtabula at Route 531




bridge, it was 8 rag/kg.




          The only other measurable mercury level in sedi-




ment are on page 42.  River mile 0.0, Buffalo River, 4 mg/kg.




          River mile 4.3, the Buffalo River, 1 mg/kg.




          Heavy metals in the Lake Erie Basin.




          As part of the investigations in the Lake Erie




Basin, the FWQA, National Field Investigatiors Center analyzed




bottom sediments from various shore areas and tributaries.




The results of analyses for 10 heavy metals — magnesium,




chromium, polonium, nickel, mercury, manganese, iron, copper,




zinc and cadmium.  Stations were selected in the mouth of




tributaries and immediately off-shore.




          Heavy metals are toxic to aquatic bottom organisms




and fish when present in sufficient concentrations.  Combi-




nations of some of these metals such as copper and zinc have




a total toxicity greater than the sum of the toxicities of




each metal taken independently.  Metals such as iron oxides




precipitate in water and may blanket the bottom and smother




bottom organisms.  Toxic metals in bottom muds can be made




available to the overlying water by physical, chemical or




biological means.  Metals may re-enter the overlying water




by scouring of the stream bed  because of velocity increases,




by wave action, or other water turbulences.  These metals

-------
                                                       659




                     L. A. Van Den Berg






may also be resolubilized by the waterbody dependent upon




environmental conditions such as pH, temperature and concen-




trations of other metals present.  Some of these metals may




also be detrimental to aquatic organisms when concentrated




in the food web.




          Summary and conclusions, page 1.




     1.   Data provided for the Bureau of Commercial Fisheries,




Technological Laboratory, Ann Arbor, Michigan, show that




mercury was present in fish throughout the St. Clair River-




Lake Erie system.  Concentrations (parts per million, wet




weight) in the edible portions of various fish were:  Keep




in mind the F.D.A. limit 0.5 ppm.




          Yellow Perch               0.32 to 1.70




          Northern Pike              0.64




          Coho Salmon                0.24 to 0.96




          Carp                       0.08 to 0.28




          White Bass                 0.53 to 0.80




          Steelhead       less than  0.15




          Walleye Pike               1.4 to 3.57




          Channel Catfish            0.32 to 1.8




          Gizzard Shad               0.24




          Sucker                     0.88




          Sheepshead                 0.24




     2.   Available information indicates that no measurable

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                                                       660




                     L.  A.  Van Den Berg






concentration of mercury was present in water supply intakes




in the St.  Clair River-Lake Erie system.




     3.   Mercury in excess of 1 mg/kg dry weight was pre-




sent in sediments in the Erie, Pennsylvania,  in Euclid and




Cleveland,  Ohio, areas and the Buffalo, Black and Ashtabula




Rivers.  Results of analyses indicate the following levels




of mercury in the areas specified:




          The first area has been rewritten as a result of




newer data.




          In the St. Clair River, mercury was present at




mile .37, 33 and 25.5 at concentrations from 0.2 to 1.0 mg/kg.




All other samples indicated the presence of mercury.




          Six sediment samples from the navigable channel in




Lake St. Clair off-shore from the mouth of the St. Clair




River had mercury concentrations from 0.3 to 9.2 mg/kg dry




weight.




          The upper Detroit River headquarters to Grassy




Island, mercury was not measurable at the head of the




Detroit River, but ranged from 1.4 mg/kg in backwater areas




to the U. S. shore upstream from the Rouge River and as high




as 2.0 mg/kg in backwater areas downstream from the Rouge.




          The lower Detroit River, Trenton channel, in a




narrow strip of about 20 to 100 feet along the U. S. Shore




line, concentrations range from 86.0 to 5.4 mg/kg within a

-------
                                                       661




                     L. A. Van Den Berg






mile downstream from the Wyandotte Chemicals outfall and then




vary from 26.0 mg/kg to trace amounts downstream to Lake Erie




depending on the settling characteristics of the specific




point.




          The main channel of the Detroit River, one sample




collected between Grassy Island and Grosse He contained




4.4 mg/kg.  On the east side of Fighting Island, one con-




tained 1.2 mg/kg.  And one near the Canadian shore near the




mouth contained 0.6 mg/kg.




          Northern Grosse lie, no mercury was present in




measurable amounts in samples along the northern part of




Grosse lie, the area of Wyandotte Chemicals waste beds, but




trace amounts were indicated.




          Western Lake Erie, Michigan waters, concentrations




near the Detroit River varied from 1.0 to 2.1 mg/kg.  Along




the Michigan shore, mercury was not measurable.  Near




LaPlaisance Bay, one sample contained 0.8 mg/kg.




          Ohio waters, four points near West Sister Island




have values ranging from 1.6 to 2.1 mg/kg.  In other areas




nearer to shore, mercury was not measurable.




          Canadian waters, concentrations of 1.3 to 2.7 mg/kg




were present at three points extending eastward about 15




miles from the Detroit light and about 5 miles from the




Ontario shore.  Points extending to Pelee Island showed no

-------
                                                      662




                     L. A.  Van Den Berg






measurable mercury.




          Eastern Lake Erie, Ohio waters,  concentrations of




2.0 and 2.4 mg/kg were present off-shore from mouth of the




Grand River and Cleveland Harbor, respectively.   Off-shore




from the Cleveland Easterly sewage treatment plant, a con-




centration of 4.0 mg/kg occurred.




          Pennsylvania waters, a concentration of 1.1 mg/kg




was found in Presque Isle Bay.




          Tributaries, concentrations in excess of 1.0 mg/kg




were present in the Black,  Ashtabula and Buffalo Rivers.




In the Rouge, Huron, Maumee, Sandusky, Portage,  Rocky,




Cuyahoga, Grand, and Raisin Rivers, the concentrations xvere




less than 1.0 mg/kg.




     4 .   The waters of the study area revealed no mercury




except for one sample collected at mile point 13.3 in the




Trenton channel downstream from the Wyandotte Chemical Com-




pany; this concentration was 0.03 mg/1.




     5.   The Detroit River area is the primary source of




mercury in the western end of Lake Erie.  This is revealed




by the distribution pattern established through sediment




samples.




     6.   Because of mercury discharges, the State of Michigan




stopped the production of chlorine by Wyandotte Chemicals




Corporation until a treatment system was developed and the

-------
                                                       663




                     L. A. Van Den Berg






mercury bearing wastes were removed from the receiving waters.




          In our latest data on the 22nd of May, there appeared




no discharge of mercury from that outfall.




     7.   The State of Ohio issued an order to the Detrex




Chemical Industries, Inc., Ashtabula, Ohio, on April 13,




1970, to V..cease and desist the discharge of liquid indus-




trial waste containing any mercurial compounds to waters of




the State."  Some operational changes were made but data




collected on May 11, 1970, indicate that Detrex still dis-




charged 1.2 pounds of mercury per day.




     8.   Allied Chemical Company, Buffalo Dye Division,




Buffalo, New York, is a source of mercury to the Buffalo




River.  On May 8, 1970, a sample of the plant effluent revealed




0.12 mg/1 mercury.  The company stated that the process utiliz-




ing mercury was not in use on that day.  Based on this infor-




mation, Allied Chemical Company was discharging approximately




4 pounds of mercury per day from sources other than the




reported production of disulfo intermediates.




     9.   The discharge from Diamond Shamrock, Painesville,




Ohio, to the Grand River had a concentration of 0.010 mg/1




mercury on April 4, 1970.




    10.   The first statement has to be changed.  Recently




received data revealed that concentrations of 0.002 mg/1




occurred at the Ann Arbor, Wayne County, Wyandotte and

-------
                                                       664




                     L.  A.  Van Den Berg






Detroit sewage treatment plants.   These were all on 24-hour




composites on the 14th of May.




          No measurable concentration of mercury was present




in sewage treatment plant effluents investigated in Michigan




(State data).  Concentrations of 0.003 and 0.004 mg/1 mercury




were present in Euclid and Cleveland Westerly and Southerly




sewage treatment plant effluents, respectively.   Although no




measurable concentration of mercury was present in the Cleve-




land Easterly sewage treatment plant effluent, which receives




wastes from several users of mercury, 4 mg/kg were present in




Lake Erie sediments 100 feet north of the discharge point.




    11.   On May 7, 1970, a concentration of 0.011 mg/1




mercury was present in the outfall from the National Aeronau-




tics and Space Administration, Lewis Research Center, Cleve-




land, Ohio.  This occurred during a period when there was no




discharge from lagoons that supposedly receive all mercury




wastes from known sources.




    12.   Investigations of additional potential dischargers




of mercury to Lake Erie are in progress by the State and the




Federal Water Quality Administration.




          Recommendations.




     1.   Svirveillance and sampling programs be initiated by




industries, municipalities, States and the Federal Government




to locate and identify all sources or potential sources of

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                                                       665




                      L. A. Van Den Berg






mercury and to determine mercury concentrations in surface




waters, land run-off, waste streams, aquatic life, and




sediments.




     2.   All dischargers of mercury to surface or ground




waters or to municipal or regional waste treatment plants,




including Federal installations, be ordered to cease and




desist.




     3.   Precautionary measures be taken by all users and




possessors of mercury or mercurial compounds for any purpose




to prevent accidental spills or other losses to the water




environment.




          That concludes my statement.




          MR. STEIN:  Thank you, Mr. Van Den Berg.




          Are there any comments or questions?




          Mr. Purdy.




          MR. PURDY:  First, I would like to have you repeat




the insert that you put in between 9 and 10 on page 5.  I




didn't quite catch that.  I think you inserted some additional




data.




          MR. VAN DEN BERG:  Yes.  In the beginning of 10.




          Recently received data revealed concentrations of




0.002 mg/1 in Ann Arbor, Wayne County, Wyandotte and Detroit




sewage treatment plants.  This was based on a 24-hour composite




collected on May 14, 1970.

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                                                       666




                     L.  A.  Van Den Berg






          MR.PURDY:  On page 1, when you are presenting the




data from the Bureau of Commercial Fisheries on concentra-




tions of mercury in the edible portion of fish, is that data




that has been supplied or collected only by the Bureau of




Commercial Fisheries or is this now a summary of all the data




that is available on mercury content, including that of




Michigan Department of Agriculture, Ohio's data and Ontario's




data?




          MR. VAN DEN BERG:  That's just Bureau of Commercial




Fisheries data from Ann Arbor.




          MR. PURDY:  So really there is a great deal more.




          MR. VAN DEN BERG:  There is a great deal more infor-




mation available if we can get our hands on it.




          MR. SEEBALD:  Is this data on individual fish?




          MR. VAN DEN BERG:  In Appendix IV, the tables from




BCF indicate the number of fish that were analyzed in these




samples.  And this varied depending on the type of fish.  Some




of them were 8, 9, some of them were much larger numbers.




          MR. PURDY:  In sample preparations, Mr. Seebald,




they sometimes take 10 fish and grind them up together and




make one  sample out of that.




          MR. SEEBALD:  I am puzzled because it gives a range




in some cases and specific numbers in other cases which lead




me to believe either they were a single batch or in other

-------
                                                       667




                     L. A. Van Den Berg






cases a number of batches.




          MR. VAN DEN BERG:  There is a Footnote #4 on page




91 that explains those ranges.  They have an average value




there, but they also give a range.  The average value is on




6 individual samples in that particular case.




          MR. POOLE:  This is off that point,  but on page 8,




the second paragraph where you say 500 parts per billion or




5 ppm in pickerel, which is it?




           MR. VAN DEN BERG:  Mr. Mayo, can you clarify that?




That information came from your office.




          MR. POOLE:  Well, I think your table on page 1




would show that it is above 500 parts per billion.




          MR. STEIN:  It is just straight arithmetic.  One




of those figures has to be wrong.




          MR. POOLE:  All I am trying to find out is whether




you have as much as 5 ppm in fish.




          MR. VAN DEN BERG:  I can't clarify that.




           MR. STEIN:  Let's go on, and we will try to pick




that up.




          MR. PURDY:  I have some other questions, Mr. Stein.




          MR. STEIN:  Go ahead.




          MR. PURDY:  I am wondering if you would venture to




make a statement on what you might find in the way of mercury




content of the bottom that had not been contaminated from

-------
                                                       668




                     L.  A.  Van Den Berg






some man-made source.




          MR. VAN DEN BERG:  No,  I wouldn't make a statement




on that.




          MR. PURDY:  Wouldn't you expect to find something?




          MR. VAN DEN BERG:  I would expect to find some in




certain areas, yes, sir.  What level, I don't know.




          MR. PURDY:  I  have another comment on this matter




of Detrex down the Ohio, Ashtabula, Ohio, apparently.  Yet,




in the midpoint of May,  it is discharging 1.2 pounds.




          I was able to  read in the newspaper by George




Rhodes with respect to what took place in Michigan.  Apparently




he has not been quite as concerned about mercury that arises




in Ohio being discharged in Michigan.,




          MR. POOLE:  It is farther south.  It is not as




damaging.




          MR. PURDY:  You mentioned about the Lewis Research




Center, a certain concentration of mercury, and there was no




discharge from lagoons that receive all mercury waste from




known sources.  What would the level be if there is a dis-




charge from the lagoons?




          MR. VAN DEN BERG:  I took some water samples or




George did from the lagoon, and the water itself in the




lagoon didn't show any mercury.




          MR. HARLOW:  Mr. Purdy, in regard to that statement

-------
                                                       669




                     L. A. Van Den Berg






on page 6 in connection with NASA, at the time that we took




the initial sample on May 7 when we had 11 parts per billion,




the lagoon was not discharging.  But the ditch that enters




Rocky River which receives a number of storm connections




from other sources measured 11 parts per billion.  And you




could guess here where it might have come from.  It might




have been residual in the muds, or it could have come from




another source.




          So we went back at two different times subsequent




to that and sampled the lagoon when it was discharging,




sampled the water in the lagoon, and also sampled the final




ditch that carries the storm water.  And on these other two




occasions, we didn't find any mercury at all.




          MR. LYON:  You mean there was no mercury in the




lagoon?




          MR. HARLOW:  No.




          MR. STEIN:  Are there any others?




          MR. PURDY:  On page 9, several statements are




made with respect to the fate of mercury discharge to the




waters and then what happens when they accumulate in bottom




muds.  And there is the one about they are available to




aquatic life and that they are readily released from the




sediments in the water and that fish absorb the mercury from




the water through the gills and possibly the scales.

-------
                                                       670




                      L.  A.  Van Den Berg






          We have been doing a great deal of research of




the literature in the past several weeks to attempt to




determine the fate of mercury.  And I am wondering if at




some later point in time  you could furnish to us  the references




from which this information came.




          MR. VAN DEN BERG:   Certainly.




          MR. PURDY:  Then,  on page 11,  there is  the perni-




cious reference to a report by N.  A. Smart, "Use  and Residues




of Mercury Compounds in Agriculture," to the effect that it




raises the spectre of paper mills  being a source  of mercury




today.  And I am wondering if you  know what period of time




this particular author was talking about in his report.




          MR. VAN DEN BERG:   I refer that question to Mr.




Muir from our office in Cincinnati.




          Can you answer  that, Larry?




          MR. MUIR:  Mr.  Purdy and Mr. Chairman,  this in-




formation carried from 1964  up through 1967 and probably




into 1968.  In 1966, I believe, the Swedish Government




banned the use of these materials.  And much of this original




statement stated that Norway, Sweden, United States and




Canada were shipping pulp from their forests internationally,




and it contained up to 20 ppm phenyl mercury acetate.




          MR. PURDY:  From U. S. sources also?




          MR. MUIR:  This includes United States  as being

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                                                       671




                     L. A. Van Den Berg






shipped, as I understand it, from our south coast or from




the Texas, Louisiana, Mississippi and Florida areas to




Europe.  And this material contained the phenyl mercury




acetates.




          MR. PURDY:  Why I am curious about this is the




presence of mercury now from paper mill discharges is not




something that we are experiencing here in Michigan.  And




in fact, I think about 1959, the Food and Drug Administra-




tion banned the use of phenyl mercury acetate as a slimocide




in paper mills where the paper came in contact with food




products.  And as a general rule, the paper mills have dis-




continued the use of this.




          In fact, we have found none being used in Michigan




paper mills.  And in fact, the industry indicates that this




is pretty much the situation throughout the United States —




somewhat different, then, from what this reference seems to




indicate.




          MR. MUIR:  As I say, this was up through 1968.




          MR. PURDY:  Well, the ban issued by the Food and




Drug Administration was in 1959.




          MR. VAN DEN BERG:  Mr. Purdy, do your paper mills




in Michigan utilize imported pulp that is transported for




long distances?




          MR. PURDY:  There is pulp that has been purchased

-------
                                                       672




                     L. A.  Van Den Berg






from Canadian sources and other sources transported quite




some distance.  We have sampled this,  and we are not find-




ing mercury present in significant quantities.




          MR. STEIN:  I think Mr.  Purdy has a good point




there because I have been asked that question several times




before I came out here and was waiting on the report.  I




think if we are going to proceed with the mercury investiga-




tion, we should do this pretty rapidly, get in touch with




the Pulp and Paper Trade Association in New York — and




maybe there is a representative here,  but I doubt it; I




don't see him — and ask how many mills are using this in




the United States, what the prevalence is, and whether we




are getting any pulp from other places that we are processing.




          Because the question that comes up — and I think




Mr. Purdy asked this in Michigan — how many pulp and paper




mills use mercury in their process for slime control.  And




I think we are going to have to have an answer to that.




          MR. VAN DEN BERG:  I hope, Mr. Stein, that infor-




mation is being collected by our Regional Offices for sub-




mission for the national report.




          MR. STEIN:  Well, I don't know.  You can short-




circuit that, you see.  When you have a question raised, you




could find that the trade association of the pulp and paper




industry is very knowledgeable on this.  And they always

-------
                                                      673




                     L. A. Van Den Berg






give out accurate information.  So we may try to get that




and see how that checks against our regional submissions.




          MR. MAYO:  A point that might be kept in mind,




Mr. Chairman, is I understand the FDA regulations apply to




the pulps that are used best domestically for packaging




materials that come in contact with food.  In the waste




pulp that was being shipped overseas for later use overseas




in the manufacture of paper and packaging materials, the FDA




regulations may not apply.




          MR. STEIN:  I recognize that.  That's why I am




asking for a nose count.  Because obviously, they are not




banning the phenyl mercury acetate in all paper mills or in




all processes.  This is not what the Food and Drug ban goes




to.




          The question that we have to ask is, in fact, how




many paper mills are using the mercury.  Some judgment must




be made on that.  Because on your previous page, you get the




thousands of pounds estimate.




          MR. VAN DEN BERG:  Those thousands of pounds esti-




mates come from the Bureau of Mines Mineral Year Book.




          MR. PURDY:  Is that consumption in the U. S. or




worldwide?




          MR. VAN DEN BERG:  That's in the U. S.




          MR. STEIN:  Again, Mr. Purdy, if we take this at

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                                                       674




                     L.  A.  Van Den Berg






its face value — and I  don't want to spin this out too far




— but if you look at industrial uses in the U. S.  in 1968,




the Food and Drug ban was in existence since 1959.   We have




for pulp and paper uses  31,000 pounds.




          When I first saw this and read this,  Mr.  Van Den




Berg, I thought pulp and paper wound up pretty  low on the




list.  This may be the reason for it.  It may not be exten-




sively used or used in wide areas.




          MR. PURDY:  It is used for other purposes in




paper mills.




          MR. STEIN:  In some.




          MR. PURDY:  Some on the face of clocks, paper




used in clocks.  Some of it is used in paper that goes into




wrapping of soap bars and so forth.




          MR. LYON:  I understand its use as a  slimocide




was stopped some considerable time ago.  For example,




Hammermill Paper used mercurial compounds as slimocides




about 10 years ago.




          MR. PURDY:  On page 44, there is this matter of




the toxic metals in bottom muds can be made available to




the overlying water by physical, chemical or biological




means.  I have gone through how they say possibly mercury




might be made available  to the overlying waters.  I am




wondering if you could describe to me how this  might take

-------
                                                       675




                     L. A. Van Den Berg






place by other means.  Is it something that we would




reasonably expect to happen or does it take some unusual




condition for this to come out of the bottom muds and be




in the overlying waters?




          MR. VAN DEN BERG:  I don't think it takes an




unusual condition.  So much of this depends on the local




characteristics of the body of water.




          MR. PURDY:  Certainly it has got to be an unusual




condition, doesn't it, if it once is precipitated into the




bottom muds?  There has got to be some driving force now




to put that back into the overlying waters.




          MR. VAN DEN BERG:  Yes, sir.  But these deposits




that can take place during one period of the year over tem-




perature changes, for instance, in some cases are enough




to make that difference.




          MR. PURDY:  For what heavy metal, then, would a




temperature change cause it to redissolve?




          MR. VAN DEN BERG:  Practically any.




          MR. PURDY:  To the point that it would be toxic?




          MR. VAN DEN BERG:  No, not necessarily to the




point that it would be toxic at the concentration in the




water, but if the biological life has the capability of




concentrating within their bodies the toxic metal from the




water, there is a possibility of buildup? where levels

-------
                                                       676




                     L.  A.  Van Den Berg






could be significant.




          iVR. PURDY:  Then, in the next sentence about they




may  reenter  the water by the scouring process,  when they




scour, you mean they would be redissolved?




          MR. VAN DEN BERG:  Not necessarily.   I think you




probably have a good example of that in the Detroit River.




At those intakes, there are bottom deposits, I am quite




sure, that are picked up and moved to another area.




          MR. PURDY:  And in fact is more like just sediment.




          MR. VAN DEN BERG:  Right.




          MR. PURDY:  Suspended solids.




          MR. VAN DEN BERG:  But in the process of doing




this, if you have a sludge bed that contains a metal that




has been covered over so it is not available, at that time




when it is scoured and transported to a different area and




resettled, it again may be in a position to be within the




active portion of the sludge or sediment deposit.




          MR. PURDY:  I think the statement is well quali-




fied by me.




          MR. SEEBALD:  In the interests of accuracy, I




would just like to ask the question about the reference to




the measurable limit of 0.5 mg/kg as cited on page 31 and




then a measurable limit on page 38 at 0.1 mg/kg.




          MR. VAN DEN BERG:  This data, Mr. Seebald, was

-------
                                                       677




                     L. A. Van Den Berg






developed in about three or four different laboratories.




And some people are using the  dithizone  method which depends




also on the size of the cell they use in the spectrograph.




Other laboratories are using flamotoxic absorption.  We use




a flameless vapor atomic adsorption technique.   And each  has a




different limit.




          MR. SEEBALD:  O.K.  So then we don't have a uniform




base on which to compare the relative levels of this mercury




throughout the systems that we are talking about because  of




the differential analysis we have got.




          MR. VAN DEN BERG:  Only above certain —




          MR. STEIN:  What is the answer to that question?




Is the answer that we don't have?




          MR. VAN DEN BERG:  We do in a certain range, yes.




At a certain range, we do, yes.  About 1 mg/kg, the data  is




comparable.  But in the lower ranges, one guy can be —




          MR. STEIN:  Are these lower ranges ever significant?




          MR. VAN DEN BERG:  Mr. Stein, I don't think we  know.




          MR. STEIN:  If they are significant and the fish




concentrate them, you might want to consider one recommenda-




tion that we come up with a uniform method of measuring.




          MR. SEEBALD:  That's my point,  Mr. Stein.




           MR. VAN DEN BERG:  This was recommended to the




Administration.

-------
                                                      678




                      L.  A. Van  Den  Berg






          MR.  STEIN:   Was it  recommended here?




          MR.  VAN DEN BERG:   No, I am  sorry.




          MR.  STEIN:   O.K.




          Any  other comments  or  questions?




          MR.  SEEBALD:  Just  one other one.  And,  again,  it




is a matter of accuracy.   On  page 39,  the lower  sensitivity




is 0.01 mg/1.




          MR.  VAN DEN BERG:   Yes. I am afraid I am  getting




mixed two people's data there, Mr. Seebald.




          MR.  SEEBALD:  I am  not being picayune.  I  just




want to be serious about this,




          MR.  VAN DEN BERG:   This will go into the record




right.




          MR.  PURDY:   Mr. Stein, on  the insert of  the  data




of the Ann Arbor wastewater  treatment  plant,  the Wayne




County Wyandotte plant and the Detroit wastewater  plant,  I




have been informed that that  statement is based  upon infor-




mation that was collected by  the Michigan Water  Resources




Commission and based upon a  report that I was just handed.




And it shows of these samples, all but two  have  been collected




on 5/14/70,  And there is something  wrong there  because




they had completed our sampling  by that time.  We  do not




have our data with us, but we do not remember having mercury




present in the Detroit plant.

-------
                                                       679




                      L. A. Van Den Berg







          We would like to have the opportunity to review




this data with our laboratory data back in the office and




send in any corrections that may be necessary by one week.




          MR. STEIN:  Yes.  Right.  For the record — but I




do think in light of what you said, Mr. Purdy, this is




developing in an area where to come up with an equitable




solution, we should get the materials that are going to be




presented in the workshops from the other States.  Because




I don't think we can ask communities in Michigan to do some-




thing without taking reference to what they are doing in the




others.  And maybe when that is concluded, we will be in a




position for the conferees to make recommendations and come




to conclusions.




          But we would like to have that within a week.   And




I think we will go over this again because I think it is




fair to say Mr. Van Den Berg is to be commended for putting




together a very good report.  But as you can tell from his




report today and the information that I keep getting, new




information on mercury is pouring in now every day.  And I




think we are facing a moving target here, so to speak.  I




think we will be in better shape in a couple of weeks.




          Are there any other comments?




          MR. LYOH:  Yes.




          Mr. Van Den Berg, in an earlier report that I

-------
                                                      680




                      L. A. Van Den Berg






received prior to the conference,  there is  an indication




that,the concentrations as high as 170 ppm  have been found




in the discharge ditch of the Detrex Chemical plant in




Ashtabula which discharged to Lake Erie. But your report




-- this report, at least — does not have any concentrations




that high.  Is that correct?




          MR. VAN DEN BERG:  I don't remember seeing a




document that had that high of a concentration, Mr. Lyon.




          MR. LYON:  This is the report from Mr. Mayo on




May 14 which was addressed to the State water pollution




control agencies.  On page 7 of that report, it quotes




concentrations as high as 170 ppm have been found in the




discharge ditch of the Detrex Chemical plant in Ashtabula.




          MR. HARLOW:  Mr. Lyon, this is on page 73 of Mr.




Van Den Berg's report.




          MR. VAN DEN BERG:  It is a sediment sample.




          MR. LYON:  Yes, it is in the section on sediments.




          O.K., I didn't see that.




          MR. VAN DEN BERG:  169 in this report.




          MR. STEIN:  Go ahead, Mr. Lyon.




          MR. LYON:  The next question I have is based on




the investigations that you are familiar with.  Is it your




opinion that there are presently discharges of mercury




going into Lake Erie?

-------
                                                        681




                     L.  A, Van Den Berg






          MR.  VAN DEN BERG:  Yes.




          MR.  LYON:   And I assume  that this is what your




recommendation to issue  a cease and desist order is based on.




          MR.  STEIN:  If you want  to wait — I was waiting




until you were finished  -- but let me give you a preview, and




you can continue.  If we agree that the cease and desist




should be made, I have a list of names I want to call up here:




          Wyandotteป




          Detrex.




          Allied Chemical, Buffalo Dye Division.




          Diamond Shamrock.




          Those Cleveland plants.




          National Aeronautics and Space Administration.




          We can go over them one  by one later.




          If there is a  cease and  desist — in fact have these




places stop discharging?  Are they putting in mercury now?  I




think this is a key question.  But maybe we should save that




until we get all the technical questions out of the way.




          MR.  LYON:   Well, I don't know.  Do you want to




wait?




          MR.  STEIN:  No.  Do you  want to?  If you accept




an amendment,  let's expand these.   Let's go down and look




at your list.




          How about Wyandotte Chemical?  Are they putting

-------
                                                      682




                     L.  A.  Van Den Berg






any mercury into Lake Erie  now?




          MR. VAN DEN BERG:  No.   The latest data I have is




March 22.  I understand there is  new data since then.   It




still indicates no mercury  discharge.




          MR. STEIN:  No mercury  from Wyandotte now.




          Detrex Chemical?




          MR. PURDY:  Mr. Stein,  I would like to indicate




that the cease and desist order has already been issued




through the Circuit Court,  Ingham County, State of Michigan,




So that has already been accomplished.




           MR. STEIN:  Well, the  point is I think we have




some cases where cease and desist orders have come out and




the indication is that there is still a discharge.




          Detrex Chemical.   They  also have a cease and




desist order issued against them.  Any discharge from them?




          MR. VAN DEN BERG:  Yes.  On May 12, they still




were discharging 1.2 pounds per day.




          MR. STEIN:  Allied Chemical.  Any discharge from




the Buffalo Dye Division?




          MR. VAN DEN BERG:  From our data, yes.  And from




New York's report, I suspect they are still discharging




some mercury.




          MR. STEIN:  All right,  Diamond Shamrock, Paines-




ville, Ohio.

-------
                                                       683




                     L. A. Van Den Berg






          MR. VAN DEN BERG:  Their hydro discharge indicated




0.01 mg/1.




          MR. STEIN:  And you would consider that a signifi-




cant discharge?




          MR. VAN DEN BERG:  Yes, sir.




          MR. STEIN:  How about those Cleveland chemical




plants where you found material in the river?  Do you feel




they have enough of a program to prevent mercury coming




through their plants and there is no problem with them any




more?  That is Euclid, Cleveland Westerly and Southerly,




particularly the Easterly plant, where you found 4 mg in the




sediments.  Do you think they have a safeguard there in an




industrial waste safeguard so no more mercury is going to




come out?




          MR. VAN DEN BERG:  No, I do not.




          MR. STEIN:  What?




          MR. VAN DEN BERG:  No, I do not.




          MR. STEIN:  All right.




          MR. HARLOW:  Mr. Chairman, I can shed some light




on that.  A large part of the mercury that reaches the




Easterly plant comes from GE Lab Division.




          MR. STEIN:  Has GE stopped putting that mercury




into the sewer?




          MR. HARLOW:  GE has reported to us they have

-------
                                                       684




                     L. A.  Van Den Berg







stopped the mercury from the sources.




          MR. STEIN:  On a voluntary basis?




           MR. HARLOW:  We had some meetings with them.




          MR. STEIN:  But there is no order against GE?




          MR. HARLOW:  No.




          MR. STEIN:  And there is no requirement against




GE to stop them putting mercury in as far as you know?




          MR. HARLOW:  As far as I know.




          MR. STEIN:  Well, I don't know that we can rely




on your pleasing personality all the time.




           (Laughter.)




          We may have to get something else.




          MR. MAYO:  Mr. Chairman, I might just make a




comment at this point.  We have a letter report from GE to




Mr. Harlow dated May 27 that outlines the corrective actions




that GE is in the process of making.  We can submit this for




the record.




          MR. STEIN:  All right.




           (The above-referred to letter follows in its




entirety.)

-------
        GENERAL
                     COMPANY
4ELA  PARK, CLEVELAND, OHIO 44112 . . Area Cod* 216
                                              266-3376
          685



  LAMP

  DIVISION


May 27, 1970
  Mr. George Harlow,  Director
  Federal Water Quality Administration
  Lake Erie Water Basin
  21929 Lorain Road
  Fairview Park, Ohio  Mt-126

  Dear Mr. Harlow:

       In cooperation with your Messrs. Winklhofer and Kramer we have,
  reviewed those operations in the Lamp Division of the General Electric  Co.,
  wherein elemental mercury is being used.  Of the six locations visited,
  water samples were  obtained from the Large Lamp Department Pilot Plant  -
  Fluorescent, at Wela Park,  East Cleveland, Ohio; the Bucyrus Lamp Plant,
  Bucyrus, Ohio; and  the Chemical Products Plant, Cleveland, Ohio.  Of
  these, samples of water were obtained at the processes themselves, but
  not from the plant  effluent.  This was done only at the Chemical Products
  Plant, where samples were also obtained at an outfall where the effluent
  was representative  of that  discharged into the combined sewers of the
  City of Cleveland.

       As I have explained to your representatives, our mercury handling
  processes have been designed to prevent loss of mercury for both economic
  and pollution abatement purposes.  I believe that this philosophy was
  amply demonstrated  to them  during their visit to our plants.

       To place the data obtained in the proper prespective, and to describe
  the remedial action we have undertaken, I respectfully submit the following:

       I.  Large Lamp Engineering Piloting Operation:

           a) The process here involves the dropping of tipped-off exhaust
              tubes from fluorescent lamps into a tray of water.  The purpose
              of the  water overlay is to prevent dissemination of mercury
              vapor from these tubes into the air of the working environment.
              Only one such tray is normally involved, and the water is
              continuously recirculated.  Periodically, the exhaust tubes are
              removed, and the tray of water is discharged to the sanitary
              system.   The frequency of water change is variable depending
              upon the build-up of phosphor powder, slime, etc.  Maintenance
              men are instructed to slowly decant this water into the plant
              drain.

-------
                                                                      686
Mr. George Harlow                   -2-                  May 27, 1970


         b) Concentrations of mercury  in the  sample from this tray  obtained
            by your field representatives was  1.06 p.p.m.  Our analysis was
            1.02, which shows good correlation.  Total water discharge from
            Nela Park into the city sewer is  1.3 million gallons per day.
            Thus, even if this tray containing about 3 gallons of water were
            to be discharged into the  Wela Park drains over a period of 1/2 hour
            a day, the average concentration  for this period, as the waste-
            waters enter the city sewer, would be about 0.1 ppb.

         c) Although we believe our mercury discharge into the water
            system to be negligible, we  have  nevertheless already taken
            steps to completely eliminate even this small quantity  by
            setting up a filtration and  recycling system which permits
            continuous re-use of this  tray water, without the need  for
            bleeding into the water drains.  This system is already in
            effect.

    II.  Bucyrus Lamp Plant:

         a) The use of water for mercury cover here is for the same purpose
            as in the Pilot Plant.  Wine trays are involved, each filled with
            about 3 gallons of standing  water. The tipped-off exhaust tubes
            are caught in a wire-mesh  basket,  and over a period of  2k hours
            each of these baskets are  removed from the water-tray,  shaken,
            and placed over an open drum to permit drain-off.  Once a day,
            this drain-off water is carefully decanted into a 2' x  U' stainless
            steel sink which has a stand-pipe with its opening about 3" from
            the bottom sink surface.  Any mercury which may accidentally
            drop into the sink is collected from a special drain opening
            located at one end.  Over-flow water leaves the stand-pipe and
            enters a large trapped pipe  into  the plant drain system.

         b) A sample of water removed  from a  typical exhaust tube water tray
            showed 0.85 p.p.m. by your analysis.  Total water discharged from
            this plant to city sewer is  300,000 gpd.  Only the drain-off from
            these 9 trays eventually reaches  the sewer lines, and the decanting
            procedure takes about one  hour.  If all the trays were  discharged
            into the sink, over a period of one hour/2k hours, the  Hg
            concentration would be O.l8  ppb as the waste water leaves the
            plant.

         c) On May 15, 1970, when Mr.  Winklhofer visited this plant,
            modifications to the stainless steel sink had already been
            made wherein the "stand-pipe  was diverted from the drain-pipe
            to a 30-gallon drum.  This will permit continuous re-use
            of the water to fill the exhaust-tube trays.  This system
            too is now in effect.

-------
                                                                       687
Mr. George Harlow                  -3-                  May 27, 1970


   III.  Chemical Products Plant:

         a)| The mercury discharged from this plant is from a mercury cleaning
            process in which the dirty mercury returned from our other plants
            is steeped with nitric acid.  The supernatant acid is removed to
            a ceramic crock, as are the first several water rinses.  This
            supernatant is treated with liquid caustic, during which time mercury
            is precipitated and removed.  The treated supernatant and subsequent
            mercury rinses are discharged through a removable catch basin in a
            trapped floor drain to confluent with other waste water effluents
            from the plant.

         b) Your data indicates the presence of about 153 p.p.m. of mercury
            in the treated supernatant, and 13.9 p.p.m. in the rinse waters
            prior to discharge into the plant stream.  At the last outfall
            prior to entry into the City sewer system concentrations, as
            reported by your investigators, were between 0.021 and 0.037 mg./li.
            These discharges occur only over a 1/2-hour period at a frequency
            of 2-3 times a week.

         c) The system of mercury cleaning at this plant is presently being
            changed.
            1.  A more dilute nitric acid will be used in the steeping operations
                to reduce dissolved mercury salt.
            2.  All final rinse waters will be treated together with the
                supernatant.
            3.  Neutralization and precipitation of mercury by liquid caustic
                followed by secondary precipitation with hydrogen sulfide, and
            h.  filtration of the liquid instead of decantation.

            Thcne additional atepn are expected Lo uLTect a vory marked reduction
            in Hg content of the discharge fron thla process, and may completely
            eliminate it.  Laboratory tests appear to bear this out.  These
            modifications will go "on-stream" starting the week of June 1, 1970.

     The samples taken at our two Lamp Plants indicates that our waste-water
discharge into the municipal sewerage system would never exceed the suggested
maximum of 2 ppb of mercury4  The steps already taken at their two plants
will assure that no mercury will be dlachurtfod.  T.I In M.IIIO our Ixvllcl' that
the remedial action being taken at our Chemical Producta riant will profoundly
reduce the dlnoemination of the a]ready minute qnnnllhloo ol' mercury periodically
dlochurgod into tho wuota wubur cu'i'luontu, and tuny uoiup'l H.o.'iy oliwluato It.
                                           Sinaerely yours,
                                           I. Matelsky, Chairman
                                           Division Council on Water and Air
IM:eh                                             Pollution Abatement

-------
                                                      688




                     L.  A.  Van Den Berg






          MR.  STEIN:   The question here is  whether the city




of Cleveland that GE  is  hooked up to in their sewer system




should have a requirement against GE so they don't put some-




thing in that is a violation.




          Now, how are we doing with the National Aeronau-




tics and Space Administration?  Are they still putting some




stuff out, Mr. Van Den Berg?




          Lewis Research Center.  I guess that is a Federal




installation.   How about that, Mr. Harlow?




          MR.  HARLOW: Mr.  Chairman, there  is a representa-




tive in the audience  —  there  was a few minutes ago — from




NASA, Ed Stevenson.  But I don't see him now.  I guess he




walked out at the wrong  time.




          MR.  STEIN:   It depends on your point of view.




          You know how slick that mercury is.




          MR.  HARLOW:  It is the NASA quitting time, I think.




          MR.  STEIN:   Do you think they should stop putting




this in?




          MR. VAN DEN BERG:  Yes, I do.




          MR. STEIN:   Mr. Garnet, do you have a program to  do




that at the Federal installations?  I don't think I heard




that in your report.




          MR. GAMET:   I believe they have a program.  As a




matter of fact, I have a letter addressed to me based on some

-------
                                                       689




                     L. A. Van Den Berg






inquiries that Mr. Harlow made of the Lewis Research Center




on April 13^ asking questions about any possible mercury dis-




charges and techniques used in waste disposal and the effluents




from the waste retention basin.




          In addition to that, I have a copy also of sample




analysis from #1 and #2 basins on April 14, 1970, indicating




zero ppm of mercury.  If you choose, I can introduce this.




          MR. STEIN:  On May 7, Mr. Van Den Berg reports he




found a measurable quantity of mercury coming out.




          Now, again, he has a recommendation here that all




discharges, including Federal installations,be ordered to




cease and desist.  And we heard Ohio has a cease and desist




order against Detrex.  Michigan has taken a cease and desist




order against Wyandotte.




          And you have gone to court in Michigan.




          It doesn't seem to me on the sum of what you have




read that we really are talking in terms of cease and desist.




          MR. GAMET:  I am not saying they are lily white,




believe me.   This is the information I have.




          I  think George probably has additional informa-




tion beyond  what I have.  I am not ~sure.




          MR. HARLOW:  They earlier stated that subsequent




to that May  7, they sampled at two other times, and it was




zero.

-------
                                                       690




                     L.  A.  Van Den Berg






          MR. LYON:   Mr. Chairman, I  think  that  recommenda-




tion regarding cease and desist orders as a whole  probably




ought to be expanded to the extent of not merely looking  at




the discharges, but  asking the question  what the company  or




installation is in fact doing with their mercury.




          Now, if they have stopped the  process, that is  one




thing.  If they haven't, then we ought  to  find out where  the




mercury is going.




          MR. STEIN:  By the way, we did ask this  question




of Mr. Van Den Berg  in the inventory program. That is,  if




we find anyone using a significant amount  of mercury, we




want to know what they are doing with it,  how they are con-




trolling it; and if  they are not controlling it, what their




program is to control it, with the date.  If that  isn't satis-




factory, get them to come up with a remedial program.




          Now, I think this is the kind of  thing we are going




to need with the National Aeronautics and  Space  Administration.




I think Mr. Harlow got that from General Electric  and Cleveland




— the program for containment.  But I  don't think we have  it




for the National Aeronautics and Space  Administration — the




program of what exactly they are doing with their  mercury and




how they are containing it.




          MR. HARLOW:  Well, I don't know exactly  what all




the sources of mercury at Lewis Research center  are, except

-------
                                                        691




                     L. A. Van Den Berg






that the recent samples confirmed what they said,  "no mercury




discharge."




          MR. STEIN:  I understand.




          Let's get back to Mr. Lyon's suggestion.   And that




is exactly, Walter, what we have proposed.  The point is if




we have an in-and-out situation in April of zero,  and you




come in early May and get a measurable amount,  and in late




May zero again, it seems to me this is exactly  the kind of




situation where we ask them what their sources  are, what they




are doing with it, and what they are doing to contain it.




          Now, can we get that from these people?




          MR, LYON:  I think to clarify this point, what we




need is a complete mercury balance indicating what is coming




in, what is happening to it, and how is it leaving the plant




so that we can get a complete balance on the mercury every-




place where mercury is being used,




          MR. STEIN:  This is what we are seeking  to get from




every significant source in that survey that Mr. Van Den Berg




is working on now.  I would suggest that particularly the way




to get at this National Aeronautics and Space problem is to




obtain such a mercury balance, because it looks as if we have




an intermittent discharge problem.




          Is it possible, Mr. Garnet, that you could get that?




          MR. GAMET:  Yes, I am sure we can get it.

-------
                                                       692




                     L.  A.  Van Den Berg






          Would you care to have me read the letter?




          MR.  STEIN:   No, just put it in the record.




          (The above-referred to letter follows in its




entirety.)

-------
                                                                        693

                         NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
                                       LEWIS RITSEARCH CENTER
                                          21OOO BROOKPARK ROAD
                                          Ci i vi LAND. OHIO 44135
                                      TCHPMONI 433 4OOO      TWX: CV-SZO

 IN REPLY REFER TO 1 006

                                                         APR 2 4 1970   •

 Regional  Director, Great Lakes Region
 Department of Interior,  FWPCA
 33  East Congress Parkway
 Chicago,  Illinois 60605

 Attention:  Mr.  Merrill  B.  Garnet
             Federal  Activities Coordinator

 Dear Sir:

 Subject:   Mercury Control  Program at NASA-Lewis Research  Center

 On  April  13,  1970, Mr. George L. Harlow,  Director,  Lake Erie Basin Office,
•FWPCA,  contacted Mr.  E.  F.  Stevenson of the  Safety  Office in regards to
 mercury usage at Lewis Research Center.   The following information was
 requested.

   .1.  Does Lewis use mercury in its Cleveland  - Plum Brook facilities?

         Mr.  Harlow was advised that mercury is used principally  in the
         liquid metal  form in research instruments  and  in  ion engine
         thrusters for space engine research.

   2.  What quantities are used annually and  what procurement replacements
      occurred this past year?

         A semi-annual inventory and report is  prepared by the Equipment
         and  Supply Division for the combined facilities at Cleveland and
         Plum Brook.   Copies of the reports for 1969 dated September 9, 19&9
         and  the January  5ป  1970, Recapitulation of  Mercury Inventory are
         attached.  The declared losses are the result  of  plating out of
         mercury vapors on chamber cold walls and baffles.   Unexplained
         losses include mercury accumulation  in vacuum  pump oil  reservoirs,
         vaporized mercury vented to atmosphere through exhaust pump dis-
         charge,  and portions of accidental  spill material  which  is not
         recovered.  No new mercury was procured in  1969.

-------
                                                                     694
3.  What technique is used in waste disposal?

      Due to the critical  value of this material,  it has been the
      policy at Lewis Research Center to reclaim all contaminated or
      used mercury.   No mercury is discharged  into any sewer system.
      Accidental spills are vacuumed with special  vacuum cleaners
      that trap condensed  vapors and droplets  for  reclaim.   Wet  mop
      water after vacuum operations is discharged  into the  sanitary
      sewer.

4.  Is the effluent from the industrial waste  retention basin sampled
    for mercury before discharging into Rocky  River?

      Mercury is not deposited in the storm or industrial waste
      system.  Since the Cleveland Metropolitan Park Board  Resolu-
      tion does not require sampling for mercury,  sampling  has not
      been done in the past.  However, in the  interest of a cooper-
      ative investigation, these basins were sampled April  13, 1970
      and April 14,  1970,  according to the procedure suggested by
      the Lake Erie Basin  Office.   Using the Dimethyzol Stripping
      Method, the analyses indicated zero ppm  of mercury concentra-
      tion for both tests.  A copy of the Analysis Report is attached.

If we can be of further assistance in any way  to the FWPCA  Regional or
Basin Offices with additional data or technical advice, please do not
hesitate to let us know.

                                        Sincerely  yours,


                                               ~   2
                                        Bruce T.  Lund in
                                        Director
Enclosures 5

cc:
G. L. Harlow, Director
Lake -Erie Basin Office, FWPCA

-------
                                                                              695
                                 ANALYTICAL CHEMISTRY

                              ANALYSIS REQUEST AND REPORT
This space to be completed by
  analytical section:

Sample No( a) . i ^
Date completed:
Date reported:
                                              This space to be completed by
                                                person desiring analysis t

                                              Name : ฃf> .
                                              PAX: •?> 7?
                                              Date submitted:
                                              Date report desir
                                              J. 0,
 Description of material to be analyzed and analysis desired*
 Analysis report:
                                                                        t   op*/*
C. 832 C8/3M)

-------
                                                       696




                     L.  A. Van Den Berg






          MR. SEEBALD:  Mr. Stein, I think we should con-




sider where this mercury may be going in the wastes.  If we




remove it from the Lake Erie environment and we are going to




put it in a deep well or put it in a sludge bed that might




reach out into groundwaters or other surface waters is of




material significance.  And I think the practicality of a




cease and desist order to the environment may be considered




completely unfeasible in sort of shutting down the complete




industry.




          MR. LYON:  Mr. Chairman, I think there shouldn't




be any question about shutting down a process if there is




anything going to Lake Erie.




          MR. SEEBALD:  I don't think we should talk about




Lake Erie in this case.   We should talk about the environ-




ment.




          MR. STEIN:  I think you talked about surface and




other ground waters.  And as a matter of fact, in large




measure, as I understand it, that is what Michigan did with




the portion of Wyandotte Chemical that was using this pro-




cess.  They just shut down.  And that is what Detrex did in




large measure.  It was either switch the process or shut




down.




          And I do agree with your point that in the same




way as we deal with this, we don't consider a satisfactory

-------
                                                       697




                     L. A. Van Den Berg






solution to water pollution to be contamination of the air,




contamination of the ground or something else.  But the




recommendation here is that all discharges of mercury into




the area over which we have jurisdiction -- that is, the




waters — be stopped forthwith.




          I think several of the States have indicated that




they have taken this action.




          MR. SEEBALD:  We have taken this action, but it




is just fortunate in our case it is Allied Chemical Dye




Works which is a batch process.  They have shut down their




dye process manufacture.  And it is only by shutting down




can they achieve it.




          I am more concerned in generalities with these




continuing chlor-alkali plants who have also provided us in




New York State with schedules for reduction, but not elimina-




tion.  And I think this may be a matter for further considera-




tion, not for New York State at the present time, but for




the other States where they would have continuing process




runs.




          MR. STEIN:  You mean we are going to let a little




bit of mercury come out of these plants?




          MR. SEEBALD:  I don't intend to let a little bit




of mercury come out.




          MR. STEIN:  What does the reduction process mean?

-------
                                                      698



                    L. A.  Van Den Berg






Are we going to do it over a period of time?




          MR. SEEBALD:  We asked for a process of elimina-




tion.




          MR. STEIN:  Over a period of time?



          MR. SEEBALD:  Yes.




          MR. STEIN:  Like you run down phenols and stuff




like that?




          MR. SEEBALD:  I think we are faced with this.




          MR. STEIN:  All right, that is a proposal.




          MR. LYON:  Mr. Chairman, I want to make Pennsyl-




vania's position very clear on this thing.  And it is our




very strong feeling that if any plant that has been reported




or has been discharging to Lake Erie doesn't stop within




the next week, I think we as conferees should recommend




that a Federal injunction be issued against those plants.



          MR. SEEBALD:  How many plants do you have, Walter?



          MR. LYON:  How many plants do we have that are




discharging mercury?  None.  But we are being affected by




the mercury.




          MR. STEIN:  I have got this list here, Walt.  I




will be glad to refer these cases to the Department of




Justice if you don't think they are stopped within a week.




          As far as I can see, of the ones that I read on




the list here, perhaps Euclid at least, Cleveland and GE

-------
                                                      699

                    L. A. Van Den Berg


have stopped perhaps.  And I don't know that the National

Aeronautics and Space Agency has stopped.  We have got a

big question mark there.  Wyandotte, we know has stopped.

This leaves us with indicated reports of mercury coming out

from Detrex Chemical, Allied Chemical, Buffalo Division,

Buffalo, Diamond Shamrock and possibly National Aeronautics

and Space.

          And if your proposal is unless they are all

stopped within a week the conferees recommend that we take

appropriate Federal legal action, I would be happy to take

that judgment back.

          MR. LYON:  That's our proposal, Mr. Chairman.

          I don't know whether the subject of the toxicity
                                                     t
of mercury and its effect on man has been given enough dis-

cussion here, but I would like to just for the record read

what was in the Federal report concerning methyl and ethyl

mercury poisoning.  I am aware of the fact that not all of

these mercury contaminations take that form, but I suspect

that some of it does.  And it also depends  naturally  on

the concentrations, but we have found some high concentra-

tions.

          The symptomatology of acute and chronic poisoning

from both compounds is similar, including numbness and

tingling of the lips and hands and feet, ataxia, disturbances

-------
                                                      700



                    L. A. Van Den Berg






of speech, concentric obstruction of the visual fields,




impairment of hearing, emotional disturbances, with severe




intoxication.  The symptoms are irreversible.




          And I think this is the important point that




this material accumulates in the tissues of man and animals.




          This is the first epidemic.  And then it goes




into the Japanese epidemic.




          But the point is we are dealing with a very, \ery




toxic substance.  And I think it is essential that if these




dischargers are not stopped, if the State courts are not




enforcing these discharges, then the Federal Government




should take appropriate action.




          MR. STEIN:  I don't want to modify your motion




specifically, but why don't you make it appropriate legal



action?




          MR. LYON:  Appropriate legal action to stop the




discharge.



          MR. STEIN:  Well, I don't know.  What do you think




of that proposal?




          MR. PURDY:  As I have understood in the past, Mr.




Stein, this hasn't been the sort of thing where you have a




motion and a seconder and a vote and so forth.




          MR. STEIN:  That's right.  We are just looking




for an expression of views if anyone wants to give any.

-------
                                                      701




                    L. A. Van Den Berg






          MR. PURDY:  Certainly we believe it is only fair




to our industries, to our Governor in his State address to




the President, that Michigan has taken aggressive action




now to cause the mercury discharges from its plants to be




stopped.  And to be fair to our industry, he feels that the




same sort of action should be taken throughout the country,




not only in the Lake Erie Basin, but throughout all 50




States,




          Certainly, past statements by the Governor and by




our Commission would support aggressive action to stop




immediately those discharges of mercury to the water that




cause harmful conditions.




          MR. STEIN:  How about you, Mr. Poole?




          MR. POOLE:  Well, I think I would share that view.




I have been keeping pretty quiet because we are in the same




position at the moment, at least, as far as Lake Erie is



concerned as Pennsylvania is.  It is pretty easy if you



don't know of any to say everybody else ought to stop




immediately.  But I think all known sources in view of the




things that have come out here today and earlier ought to




be stopped immediately.




          MR. STEIN:  O.K.  Now, we have got over the two




easy ones.  Would you care to make a statement for the




Federal installations?  Could we adopt the same policy to

-------
                                                       702




                     L.  A.  Van Den Berg






try to get rapid action  for Federal cleanup?




          MR.  MAYO:  Certainly, the substance of the recent




Executive Orders is such that there should be no question




that we can approach NASA installation at the Lewis Research




Center and advise them of the findings, advise them of the




sense of feeling of the  conferees, and the need for the




installation —




          MR.  STEIN:  Would you have any objection to this:




Within a week, in line with this proposal, you have a report




from that NASA facility  so that we either have assurances




that everyone is satisfied that they have accounted for




the balance of the mercury and there will be no further




discharges or we will take appropriate action through the




Executive establishment.  I will recommend that they be




directed to stop if you  haven't reported that they have a




satisfactory program.




          MR.  MAYO:  We  will contact the installation




immediately.




          MR.  STEIN:  All right, if you want to do that.




          Now, we come to the two hard States because the




Federal Government may add this, but it isn't our agency,




either, we are dealing with.  Michigan has got to clean up.




There are no known sources or significant sources in




Indiana and Pennsylvania.  Ohio isn't here to speak.

-------
                                                      703



                    L. A. Van Den Berg






          MR. VAN DEN BERG:  They said I could speak for



them.




          (Laughter.)




          MR. STEIN:  You know, there were once a couple of




political figures like that.  One guy made some remark, and




the other guy said, "You know, everyone is privileged to be




stupid, but this guy abuses the privilege."  Let's not




abuse that proxy.




          I don't want to put you on the spot in New York,




but do you care to comment or not?



          MR. SEEBALD:  Yes.  As far as I am concerned, as




it affects Lake Erie, there is no problem in cease and




desist order against Allied Chemical Dye Works because they




have stopped.  And they have entered a commitment they would




not commence using mercury in their dye processing until




they had a review of their application presently before us



that was scheduled to minimize.  And we have not rendered an



opinion on this.




          It is our intention to have them indicate why they




cannot and have this go through an appropriate evidence for




presentation.  And it is the inclination of the State right




now to cause them to cease.




          MR. STEIN:  But may I say I think, Mr. Seebald,




again on this one, I wish if there is any doubt about the

-------
                                                      704



                    L. A. Van Den Berg






facts here that you give this one priority.  Either they




have ceased discharging mercury or they haven't ceased




discharging mercury.  This is a fact.  On May 8, presumably




Mr. Van Den Berg has some information which caused him to




say that they were still discharging mercury.  If, in fact,




they have stopped and this isn't occurring, I wonder if you




and Mr. Van Den Berg could get together, have your represen-




tatives make a visit there, and come up with the facts.




          If they have stopped using mercury, they shouldn't




have any coming out unless there is a residue that is wash-




ing out that you know of.




          MR. SEEBALD:  That's the one reservation I have.




I think that may be the case.  I don't know.




          MR. STEIN:  If that is the case, let's find out



what the facts are so we know where to move.  But I think



if this is the case, unless you can resolve the factual




issue, this seems to be crying for inspection pretty soon.



So the Federal and State people should get together and know




where we stand on this so we won't be bugging you for a




cease and desist order when in fact they may have stopped.




          MR. SEEBALD:  It is my impression that they have.




          I would like to ask Mr. Mayo, haven't you a man




on assignment to the Buffalo Regional Office at the present




time?  Or has he been reassigned?  Is Mr. Wilcox not there

-------
                                                      705



                    L. A. Van Den Berg






any longer?




          MR. MAYO:  We don't have anyone at Buffalo any




longer.




          MR. SEEBALD:  Wilcox was there on the occasion




you made this one inspection/ I know.




          MR. HARLOW:  Wayne Wilcox came up at the same time




to check on the compliance and status of all your city




industries.  While he was there, he accompanied Violanti to




the Allied Chemical plant.




          MR. SEEBALD:  Is that the sampling on which you




predicate this?




          MR. HARLOW:  Yes.




          MR. SEEBALD:  I understood he was there at the




present time.  I didn't know how long he was going to be




there.



          MR. HARLOW:  He came right back to Cleveland.



          MR. SEEBALD:  We would be glad to sample.




          MR. STEIN:  Let me ask another question.  And I




ask this here really just for getting information.  I see




no recommendation here made to get up the mercury that is




in the sediment.  Maybe we should or shouldn't.  Maybe the




thrust of the questions asked by Mr. Purdy meant it is




just going to stay there.




          But if you are talking about the fairly large

-------
                                                      706



                    L. A. Van Den Berg






quantities of mercury which have been discharged and if you




have a fairly discrete area which you pretty accurately




defined for Wyandotte Chemical, do you think that is all




right to leave that there?  Or should we do anything about




that or direct our attention to that?




          Again, I have absolutely no preconceived notion




of this.  But I think we have,at least to my mind,something




which raises the question in your report and we may get




questioned about.  I hate to leave a loose end.




          MR. VAN DEN BERG:  This area, Mr. Stein, is some-




thing that takes a considerable amount of thought.  If there




is high mercury in the sediments, we may very well cause




more problems by trying to dredge it out than by leaving it




where it is set if it is covered in the sediments and will



not be disturbed.



          The first point I think we have to look at is




when the mercury discharges are discontinued, then follow




whether or not there is a corresponding decrease in the




levels in fish and aquatic life.  If this happens after dis-




charges are stopped, I would see very little reason to dredge




sediments to remove mercury.




          MR. STEIN:  Let me try to rephrase what I think




I understood you to say.  You say your present thinking is




to leave the sediments there and check the concentrations

-------
                                                      707




                    L. A. Van Den Berg






of mercury in the fish in Lake Erie.  If these mercury con-




centrations go down, leave well enough alone.  If the




mercury concentrations remain at high level and you find a




causal relationship that may be related to the sediments,




then we will think about disturbing those sediments.  Is




that a fair statement?




          MR. VAN DEN BERG:  Yes.




          MR. LYON:  Mr. Chairman, isn't there one other




point in this connection that should be considered?  And




that is we ought to, as Mr. Van Den Berg has suggested,




monitor these to see what is happening.  But if some of



these deposits are in areas where dredging is contemplated,




this is where I would feel quite fearful as to what might




happen.  And, therefore, we really ought to take your sug-




gestion one point further and maybe make sure that there




wouldn't be any dredging in that area or make some special



plans if there is a plan for dredging in that area.  Because



if those mucks get dredged up and put someplace else, I




think we are going to have a problem.




          MR. VAN DEN BERG:  I would refer your comment to




Mr. Mayo on that since I think he is involved in a discus-




sion right now concerning dredging.




          MR. MAYO:  Among some of the most recent informa-




tion that Mr. Van Den Berg included in the revised material

-------
                                                      708



                    L. A. Van Den Berg






I believe is some data for Lake St. Clair and the occurrence




of mercury in rich sediments in the upper part of the Trenton




channel in Lake St. Clair.  And we were advised the latter




part of last week that the Corps anticipates a dredging




project this year in that portion of the Trenton channel




and that the normal procedure has been to dispose of those




dredgings over to the side of the channel in the waters of




Lake St. Clair.




          This is the problem that the conferees need to




address themselves to.  And I think it is correctly related




to the observation that Mr. Lyon just made.




          MR. PURDY:  The problem is we have got the geo-




graphy twisted to some extent, I think.  The Trenton channel




is not up in Lake St. Clair.



          MR. MAYO:  The ship channel in Lake St. Clair.



          MR. PURDY:  We are not talking about the Trenton



channel.  We are talking about the shipping channel in Lake




St. Clair.




          MR. MAYO:  The upper end of Lake St. Clair.




          MR. STEIN:  Is the Corps going to go ahead unless




we do something?




          MR. MAYO:  The Corps has asked for comments, and




we are obliged now to respond.  And we have not responded,




choosing to have the issue raised here with the conferees.

-------
                                                      709




                    L. A. Van Den Berg






          MR. STEIN:  All right.  Do you think we can pre-



pare our comment now?




          I don't know how soon the Corps needs a comment.




Do you think you and Michigan, talking about the Federal




Government and Michigan, should get together and prepare a




statement on that?  Can you do that within a week for con-




sideration of the conferees?  Because I hate to let the




Corps get revved up.  You know, you are not going to stop




them unless you have enough  leadtime  if you feel that is




what you want to do.




          MR. MAYO:  The Corps has indicated to us there




can be a modest postponement of the dredging operation in




order to give us an opportunity to respond.




          I am sure we can get together with Mr. Purdy within




the next week.




          MR. STEIN:  All right.  Maybe some of my friends



from the Corps are here.  I don't want you to be restricted



that way.  As far as I am concerned, if you don't think those




muds should be disturbed, I am not worried about any modest




postponement, we will just stop it.




          MR. MAYO:  Well, that wasn't the context in which




I offered the comment.




          MR. STEIN:  Well, I know.  But I think you should




get the full gamut of this.

-------
                                                       710




                     L.  A.  Van Den Berg






          One, whether these muds should be disturbed at




all.




          Two, if they are  disturbed,  what precautions




should be taken as to where the soil is placed.




          Is that a fair thing?  But I would like to have




the Federal conferee and the State of  Michigan take a look.




I think if we are going to  make any meaningful push on that,




we should have a joint report, if possible, with a recommen-




dation on this dredging, signed by Michigan and our Regional




Office, in about a week, so we can get some signal on how we




are going to move.




          After I clear the decks in Washington, I would hope




we would be able to arrange this to allow the Region to take




the initiative with the District Office and the Corps here,




and handle it on this level rather than letting it get back




to Washington if we can.




          O.K., is that agreeable?




          MR. PURDY:  I am not prepared to comment on this




now, since it was first brought to my attention yesterday.




We are in agreement to meet with Mr. Mayo and discuss a




joint position.




          MR. STEIN:  Are there any other comments or




questions on that mercury problem or any other point?




          MR. POOLE:  I have two questions.

-------
                                                      711




                    L. A. Van Den Berg






          I got the impression from listening to Mr. Van Den




Berg if you get different results with different analytical




methods, I would like to suggest to him that FWQA decide




which is the best analytical method and immediately supply




that to at least all of the States that are represented here.




          MR. VAN DEN BERG:  I am afraid if we do that,




Blucher, somebody would not be able to afford it.



          MR. POOLE:  Afraid what?




          MR. VAN DEN BERG:  Some people may not be able to




afford it.




          MR. POOLE:  Can we send the samples to you, then?




          MR. VAN DEN BERG:  A lot of people have been doing




that if you have problems.




          MR. POOLE:  Isn't this really a problem yet?




          MR. VAN DEN BERG:  Yes.  There are some limita-




tions in the analytical procedures, but at the present time



we are using the best method and equipment that the individual




laboratories have available.  Unfortunately, we are not all



equally equipped.




          MR. POOLE:  You are dealing in very small quantities




here.  And I think this can be a pretty important item.




          Well, you do the best for us, then, supply us with




various methods.




          MR. STEIN:  Let's try to get at this if we can

-------
                                                      712



                    L. A. Van Den Berg






because, again, I think the best method means the best




practical method you can expect the State to use.  Are you




saying if you get down to 1 ppm?




          MR. VAN DEN BERG:  We get down to 1 ppb.




          MR. STEIN:  By what kind of method?  Can everyone




use a reasonably accurate method that isn't too costly down




to 1 ppm?




          MR. VAN DEN BERG:  No.




          MR. STEIN:  They can't?




          MR. VAN DEN BERG:   The dithizone method which is



the one I am aware of — Larry maybe can expand on this —




but at least the ones I am aware of, without going to atomic




adsorption unit, you cannot get down to 1 ppb.   And this has




to be with a flameless vapor technique on the atomic  adsorp-




tion.



          MR. STEIN:  Is that one part per million or billion?




          MR. VAN DEN BERG:  One part per billion in water.



          MR. POOLE:  This has a bearing on my second comment




or question, Mr. Chairman.  And that is you report 3 and 4




ppb in two of the Cleveland plants.  And we have had an




explanation here for the Easterly plant that apparently some-




body, at least, has found some in three or four of the




Michigan sewage treatment plants.




          If you turn to page 10 and look at that list of

-------
                                                      713



                    L. A. Van Den Berg






mercury users and you get down past item 4, I am assuming




that a great many of these users that are tabulated in the




lower half of the table are hooked onto municipal sewer




systems.




          I for one—and I will freely admit to being the




most ignorant one up here at this table as far as mercury




contamination is concerned—wonder if we aren't obligated




to start looking at least at some of our major sewage treat-




ment plants.



          And the second wonderment I have is:  Are we going




to try to shut off every drop of mercury from getting into




a stream or a lake?  Or can we end up with a tolerable limit?




          I don't expect you to answer all that today, but




I would like to have your opinion.




          MR. VAN DEN BERG:  Every drop of mercury being




removed from a waste treatment plant, for instance, is almost



an impossibility unless we outlaw the use of mercury in




Pharmaceuticals.  And they are uncontrollable.




          But my idea in the recommendation was that the



industries themselves, the users of mercury themselves,




should be responsible to take the mercury out before it




reaches a municipal system.




          MR. POOLE:  That is a beautiful theory, but I




have had some experience with laboratories since we operate

-------
                                                      714




                    L. A. Van Den Berg






a fairly sizable laboratory and we are on the IU Medical



School campus.  And they operate a lot of laboratories.




And there are just a hell of a lot of things that happen




in some of these research laboratories that ought not happen,




but they do.  This troubles me.




          MR. VAN DEN BERG:  Accidental spills in laboratories




is something that is extremely difficult to do anything about.




          MR. STEIN:  I don't know.  It may be difficult to




do anything about, but it is not impossible because we have




had places with accident spills where we have been plagued




by that in industrial plants.  And they have taken action




to do this.  They have got warning systems, they have traps,




baffles  around the drains in the floor that will stop this.




          The point is this gets to be a big problem.  And




industry has solved this problem again and again.




          And I appreciate what Mr. Poole is saying.  This



has been true for years.  You talk about these wonderful



tolerances in the research laboratories, and I wonder.  I




just raise this.  I wonder if their housekeeping methods




in handling their wastes are as good as we expect from most




of the industry.




          MR. VAN DEN BERG:  Probably not as good as the




research.  There were plants that were reported in this one.




There is an instrument plant, for instance, that installs a

-------
                                                      715




                    L. A. Van Den Berg






floor drain in any room where mercury is used.




          MR. PQOLE:  I am kind of leading up to this




because this has been Indiana's policy for 10 years now on




cyanide.  And apparently mercury is just as bad or worse




than cyanide except the quantities are a little different.




And I am wondering if before you get through this we won't




need to think about setting up the same kind of procedures




with users that you have for spills and decontamination of




radioactive materials.  This is what is going through my




head.




          MR. VAN DEN BERG:  It is possible.




          MR. POOLE:  I don't know.  Maybe .003 of a part




per billion in Cleveland sewage plant or Fort Wayne sewage




plant is of no consequence.  I don't know.




          MR, STEIN:  I think  we have got two points that




I am pretty sure we are going to have to answer.  One is if



we are looking for the so-called zero tolerance because,



you know, what happens there when you say no measurable




limit.  Three months from now, some bright young guy is going



to come up with a method that is going to measure the stuff




that you are finding no measurable limit on now.  And if




this is hot enough three months from then, someone is going




to come up with something you can measure in parts per




trillion.  And we will be off and running.  So if you mean

-------
                                                       716




                     L.  A. Van Den Berg






every trace of this that we are ever going to find,  we have




one thing.




          Now, if you are going below parts per billion or




down to a part per billion, as you are, and we are dealing




with this mercury, we have to come to this conclusion, it




seems to me, if we are going ahead with this program.




Either we are coming up with a standard method that we can




give to the States, municipalities and industries where they




can reasonably get reliable results that xve all can base




our program on, or else we are going to have to set up




facilities ourselves.  Whether you use atomic absorption,




gas chromatography, or whatever, we are going to have to




set up facilities ourselves and accept these samples and




do the work ourselves, or else contract with some laboratories




that have these fancy machines.




          Again, we must choose between one or the other.




Although these are very proper questions, unless we do that,




in delivering any technical report, we are going to have this




same series of questions on these discrepancies in the number.




Exactly what does a little trace of this mean in a sewer pipe




or sewer system?




          I think we  just have to come to grips with those




problems, work our way through and come up with recommenda-




tions.  Otherwise, we are going to have a mercury

-------
                                                       717




                     L. A. Van Den Berg






problem.




          And let me make one last remark on this.   We,  and




I think I particularly, have given thought to this  mercury




problem, but they are talking about all toxic materials.




If we can't do this on mercury, which is a relatively easy




one, what are we going to do on the others?  That's why  I




say I think we should look at this as kind of a pilot




operation in dealing with the whole area of control of toxic




materials, and see if we can come up with a reasonable




program that we can live with, and the States can live with,




and the users of mercury can live with.




          MR. LYON:  Mr. Chairman, I would like to  comment




on this.  This touches on one of the items we talked about




yesterday morning regarding the whole question of toxic




substances.  You remember, Murray, an old colleague of ours,




Morris  Ettinger, used to point out most sewage treatment




plants provide cosmetic treatment.  It makes things look




better.  But we are finding increasingly that sewage treatment




plants in many cases are discharging toxic effluents because




of industrial wastes and other substances that are  discharged




to them.  And this is probably equally true in the  case  of




certain industrial wastes as we have just found out in the




case of mercury.




          The history of points of view by scientists,

-------
                                                      718



                    L. A. Van Den Berg






as I said earlier — Rachel Carson*on this — goes back to


           ##
Mark Hollis and later congressional committees  and



policy advisory committees at the Federal level.  Whether



you read the report of the Tukey  Committee*or White Com-



mitte
-------
                                                                  7l8a
   Carson, Rachel
   "Silent Spring," Houghton Misslin, Boston, 1962
   Hollis, Mark
   Chief, Sanitary Engineer
   Public Health Service, Department of Health, Education, and Welfare
   Washington, D. C.
   Tukey Committee
   Report of the President's Science Committee
   "Restoring the Quality of our Environment"
   The White House, November 1965
   White Committee
   A Report of the Committee on Water, "Alternatives in Water Management,"
   -Publication 14.08, National Academy of Sciences, National Research
   Council, Washington, D. C, 1966
   Linton Committee
   Report of the Task Force on Environmental Health and Related Problems
   to the Secretary of Health, Education, and Welfare,
   Superintendent of Documents,
   June 1967

******
   Daddario Committee
   Report of the Subcommittee on Science, Research and Development,
   Serial S, Committee on Science and Astronautics,
   U.S. House of Representatives, 88th Congress

-------
                                                      719




                    L. A. Van Den Berg






I think what you say in a way is very valid, but I have




another suggestion because I think the conferees have a




better opportunity.  It just happened that the mercury




situation came to the fore in the Lake Erie Basin where we




had a conference working.  They have given us the job of




coming up with a report on the mercury control program, and




I think we are on our way.




          In addition to that, because everyone is worried




about what you are worried about, they have also given us




the opportunity to come up with a general toxic control




program.




          Now, I think instead of just asking for money and a




program which takes time to percolate through, the conferees




here have an opportunity to come up with specific recommenda-




tions on how we are going to get that program operating,




both in mercury and other toxic materials.  If it requires



legislation and money, as it very well might, we can come




up with a specific program to the conference, or at least




that we would propose to the Administration to take to the



conference, without just going into a vague hunting expedi-




tion.




          I think we have as good a sampling and as good




an experience here as anyone.  And I would say I am hoping




out of this mercury operation, and out of the general view

-------
                                                       720




                     L. A.  Van Den Berg






of the toxic material operation,  that we may come up with




recommendations for a much  more specific national program




than just to get the money  for this program and to point out




we have a problem in this area.  I think we can move the




whole situation a lot faster if we do that.  And I have no




notion about that.




          One of the things we might consider is your sug-




gestion for a national clearinghouse — how we set this up,




how we monitor and how we feed this stuff in.  However, I




would see that as either a  task for the conferees or perhaps




a task for a technical committee to be appointed by the




conferees.  Because I think, in the past, in other areas




such as setting up specific numbers and standards, the con-




ferees, for example, in Lake Michigan did that.  They showed




the way for national standards all through the country, and




they beat them by years when they got out that little book




of what the requirements would be in water quality.




          I think this is the chance we have.  As we work




our way through, I hope the conferees will avail themselves




of that and try to come up with a specific report.  It might




be a little too early yet,  but when we reconvene, we may




want to establish a committee to come up with specific




recommendations on how we can move in this area.

-------
                                                      721
                    L. A. Van Den Berg


          And I am sure it will be much better if we have
the book and the music when we go into Washington than if we
just have a generalized feeling of a proposal.
          MR. LYON:  Well, I think we are together on this.
I think that the important point is that this kind of a pro-
gram consists of three elements.  One is monitoring.
          The other one is doing research on the health
effects.
          And the last item is to come up with better ana-
lytical methods.
          Two of these certainly go beyond Lake Erie.  And
I think it would be quite appropriate for the conferees on
Lake Erie to come up with such a program.  I just hope that
we don't delay this too long; that we try to tackle this
job soon.
          MR. STEIN:  Obviously, you have given a lot of
thought to it.  By not delaying it too long, I would like
to talk to you about commitments privately because I have
a good idea about who could be the chairman.
          MR. LYON:  I will be glad to help.
          MR. PURDY:  Mr. Stein/ Mr. Lyon mentioned delay.
I would like to say from the standpoint of Michigan, there
is not going to be a delay.  In fact, this sort of program
is under way.  I don't intend to delay it at all because

-------
                                                      722




                    L. A. Van Den Berg






the Governor said this is something we shall do.  It is being




done, and it will be continued.




          MR. LYON:  I think, Ralph, our legislators were



very impressed by Governor Milliken's statement.  And they




have asked for a copy of the 20-point program.  This is




definitely showing some real leadership in this field.  This




is the kind of thing we need to do.




          MR. STEIN:  Are there any other comments or ques-




tions on any of the aspects of the program?




          MR. PURDY:  I have a request from Or. Shannon that




he would like to make a statement with respect to mercury if




Mr. Van Den Berg is through.




          MR. VAN DEN BERG:  I have a statement from Ohio.




          MR. STEIN:  Let us have a 10-minute recess.




          (Whereupon, a recess was taken.)



          MR. STEIN:  Let's get going again.




          Mr. Van Den Berg, would you go on?



          MR. VAN DEN BERG:  This is a status report, investi-




gation of mercury contamination in the Ohio portion of Lake




Erie.




Detrex Chemical Company




          The effluent being discharged to Lake Erie by




Detrex Chemical Company was sampled by Detrex on 10 days




between March 4 and April 10, 1970.  The analyses, made by

-------
                                                      723



                    L. A. Van Den Berg






Detrex, were in the range of from 0.34 to less than 0.01




milligrams of mercury per liter.  Since that time, Detrex




has taken precautions which are designed to make sure that




the mercury content of the effluent will not increase to




the detectable limit.  The Federal Water Quality Adminis-




tration is continuing with a program of sampling and




analysis.




          MR. STEIN:  May I ask an information question?




What is a detectable limit?




          MR. VAN DEN BERG:  Ours is 1 ppb.




          MR. STEIN:  Do they set their own detectable




limits?




          MR. VAN DEN BERG:  I don't know.




          MR. STEIN:  I don't mean for that to be a mean




question, but this is always the key point in here.  Unless




you come up with a number, we are not quite sure what is



detectable.  Not only do you have to come up with the number,




but you have to come up with the method.




          MR. VAN DEN BERG:  Survey of mercury users.




          An investigation is being conducted of mercury




losses by industry in Ohio.  For the Lake Erie Basin, this




was a joint effort by the Ohio Department of Health and




FWQA.  The companies surveyed were those reported by the




U. S. Bureau of Mines as purchasers of mercury in 1969.

-------
                                                       724




                     L.  A.  Van Den Berg






The results to date have not disclosed any significant dis-




charge except that discussed above for Detrex Chemical Company.




FWQA is continuing the investigation*




          To the best of our knowledge, there is no seed pro-




cessors in Ohio who use a mercury compound for seed treatment.




An agricultural chemical company, who  formerly produced mercury




fungicides, discontinued the production about a year ago.




          A survey of the paper industries in Ohio who dis-




charge into the Lake Erie Basin indicates that it has been




several years since any of  these paper mills have used any




slimicide containing mercury.




Lake Erie Water




          Samples of raw water were obtained from each of the




municipal water supply intakes, 22 in  all.  These were analyzed




by the Ohio Department of Health Laboratory and by Battelle




Memorial Institute.  Battelle performed the analyses at no




charge, as a public service.  The results showed that all of




the samples contained less  than detectable amounts of mercury




and specifically less than  5 parts of  mercury per billion parts




of water.  The probability  is high that the actual mercury




content, if it could be detected, would be between zero and




one-half of one part per billion.




          That concludes the Ohio statement.




           (The above-discussed report  follows in its entirety.)

-------
                                                      724A
      INVESTIGATION OF MERCURY
               IN THE
 ST. CLAIR RIVER - LAKE ERIE SYSTEMS
Federal Water Quality Administration
     Great Lakes Regional Office
       Lake Huron Basin Office
       Lake Erie Basin Office
National Field Investigations Center
              May 1970

-------
                    ERRATA SHEET (JULY 10, 3.970)

                               TABLE 1

      MERCURY ANALYSES OF DETREX EFFLUENT AND RECEIVING WATERS
Date
3-4-70
3-13-70
3-18-70
3-25-70
4-3-70 .
4-6-70
4-7-70
4-8-70
4-9-70
4-10-70
4-17-70
4-18-70
4-19-70
4-20-70
4-21-70
4-22-70
4-23-70
4-24-70
5-6-70
Sta.
Ditch
ffig/1


< 0.01



.'
< 0.01
0.009
0.005
0.012
0.005
0.013
0.005
0.007
0.006
0.002
No. 4
mouth
Ibs/day**


< 2.0




< ง.ฃ
1.8
1.0
2.3
1.0
2.5
1.0
1.4
1.1
0.4
Sta, No. 2
Ditch belov Detrex
mg/1 Ibs/day***
0.02
0.02
0^34

***  Loadings based upon 3-34 mgd from Detrex. only.
**** Loadings based upon 2,45 ragd from Detrex surcp effluent only.

                                  65

-------
This report was developed by personnel
of the Great Lakes Regional Office, Lake
Huron Basin Office, and Lake Erie Basin
Office in cooperation with personnel of
the National Field Investigations Center.

-------
HEAVY METALS IN THE LAKE ERIE BASIN
                        TABLE OF CONTENTS
SUMMARY AND CONCLUSIONS --- ___________ --- _     i

RECOMMENDATIONS ---------- ....... _____     7

INTRODUCTION  --- _______.___-__.-__-_     8

   USES OF MERCURY  -------- ........... -    10

   REFERENCES - .......... ___ .........    13

MERCURY ANALYSES IN THE ST. CLAIR RIVER, LAKE ST. GLAIR,
   DETROIT RIVER AND WESTERN LAKE ERIE- --- ____ ---    ii+
   LOWER ST. CLAIR RIVER AND LAKE ST.  CLAIR --- -----    15

   UPPER DETROIT RIVER (LAKE ST. CLAIR TO GRASSY ISLAND)- -    20

   LOWER DETROIT RIVER (GRASSY ISLAND TO MOUTH) ------    25

   WESTERN BASIN OF LAKE ERIE, INCLUDING THE
     RAISIN AND MAUMEE RIVERS --- ..... _______    31

MERCURY ANALYSES IN THE EASTERN PORTION OF THE
   LAKE ERIE BASIN  ....... - ..... -------    38
APPENIDX I  ------- ............ _____    52
   REPORT ON WYANDOTTE CHEMICALS CORPORATION,
   WYANDOTTE, MICHIGAN

APPENDIX II ...... ------- ...........    61
   REPORT ON DETREX CHEMICAL CORPORATION,
   ASHTABULA, OHIO
                               ii

-------
APPENDIX III	-    77
   INVENTORY OF INDUSTRIES USING
   MERCURY IN THE LAKE ERIE

APPENDIX IV	    86
   FISH ANALYZED FOR MERCURY CONTENT

APPENDIX V  -	    92
   STANDARDS FOR MERCURY AND HEAVY METALS
   LAKE ST. CLAIR - LAKE ERIE DRAINAGE AREA

APPENDIX VI			    9*4-
   CHRONOLOGY OF EVENTS
                               iii

-------
                    INVESTIGATION OF MERCURY
                             IN THE
               ST.  GLAIR RIVER - LAKE ERIE SYSTEMS
                     SUMMARY AND CONCLUSIONS


         I
1.   Data provided by  the Bureau of Commercial Fisheries, Tech-

    nological Laboratory, Ann Arbor, Michigan, show that mercury

    was present in fish throughout the St. Glair River - Lake

    Erie System.  Concentrations (parts per million, wet weight)

    in the edible portions of various fish were:

       Yellow Perch                0.32 to 1.70

       Northern Pike               0.6k

       Coho Salbnon                 0.2*4- to 0.96

       Carp                        0.08 to 0.28

       White Bass                  0.53 to 0.80

       Steelhead                 < 0.15

       Walleye Pike                1.1*  to 3.57

       Channel Catfish             0.32 to 1.8

       Gizzard Shad                0.2k

       Sucker                      0.88

       Sheepshead                  0.2*4-

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2.  Available information indicates that no measurable concentra-
    tion of mercury was present in water supply intakes in the

    St. Clair - Lake Erie System.

3.  Mercury in excess of 1 mg/kg dry weight was present in sediments

    In the Erie, Pennsylvania, and Euclid and Cleveland, Ohio, areas

    and the Buffalo, Black, and Ashtabula rivers.  Results of analyses

    indicate the following levels of mercury in the areas specified:
          AREA

St. Clair River
Lake St. Clair
Upper Detroit River
(Headwaters to Grassy Island)
Lower Detroit River
Trenton Channel
MERCURY LEVELS IN SEDIMENT
    (mg/kg dry weight)	

Mercury was present at mile points
37.0, 33.0, and 25.5 in concentra-
tions of 1.0, 0.2, and 0.3 mg/kg,
respectively.  All other samples
indicated the presence of mercury.

Six sediment samples in the naviga-
tion channel, off-shore from the
mouth of the St. Clair River, contained
mercury at concentrations ranging from
0.3 to 9-2 mg/1.  Samples from a
dredging disposal area had concentra-
tions of 1.7 and 2.1 mg/kg.  All
other samples indicated the presence
of mercury.

Mercury was not measurable at the
head of the Detroit River, but ranged
from 1.4 mg/kg in backwater areas along
the U. S.  shore upstream from the
Rouge River and as high as 2.0 mg/kg in
backwater areas downstream from the
Rouge.

In a narrow strip of about 20 to
100 feet along the U. S.  shoreline
concentrations ranged from 86.0 to
5.^4- mg/kg within a mile downstream
from the Wyandotte Chemicals' outfall
and then vary from 26.0 mg/kg to trace
amounts downstream to Lake Erie, depend-
ing on the settling characteristics at
the specific point.

-------
Main Channel of
Detroit River
Northern Grosse lie
Western Lake Erie
    Michigan Waters
    Ohio Waters
    Canadian Waters
Eastern Lake Erie
    Ohio Waters
One sample collected between
Grassy Island and Grosse lie
contained 4.4 mg/kg of mercury;
one on the east side of Fighting
Island contained 1.2 mg/kg; and one
near the Canadian shore near the
mouth contained 0.6 mg/kg.

Mercury was not present in
measurable amounts in samples
along the northern part of Grosse
lie, the area of Wyandotte Chemi-
cals' waste beds, but trace amounts
were indicated.
Concentrations near the Detroit
Light varied from 1.0 to 2.1 mg/kg.
Along the Michigan shore, mercury
was not measurable.  Near LaPlaisance
Bay one sample contained 0.8 mg/kg.

Four points near West Sister Island
had concentrations ranging from
1.6 to 2.1 mg/kg.  In other areas
nearer the shore, mercury was not
measurable.

Concentrations of 1.3 to 2.7 mg/kg
were present at three points extend-
ing eastward about 15 miles from the
Detroit Light and about 5 miles from
the Ontario shore.  Points extending
to Pelee Island had no measurable
mercury.
Concentrations of 2.0 and 2.4 mg/kg
were present off shore from mouth
of the Grand River and Cleveland
Harbor, respectively.  Off shore from
the Cleveland Easterly Sewage Treat-
ment Plant, a concentration of 4.0
mg/kg occurred.

-------
        Pennsylvania Waters        A concentration of 1.1 mg/kg
                                   was present in a sample from Presque
                                   Isle Bay.

    Tributaries                    Concentrations in excess of 1.0
                                   mg/kg were present in the Black,
                                   Ashtabula, and Buffalo rivers.
                                   In the Rouge, Huron, Maumee,
                                   Sandusky, Portage, Rocky, Cuyahoga,
                                   Grand, and Raisin rivers, the
                                   concentrations were less than
                                   1.0 mg/kg.

k.  The waters of the study area revealed no mercury except for one

    sample collected at mile point 13.3 in the Trenton Channel down-

    stream from the Wyandotte Chemical Company; this concentration

    was 0.03 mg/1.

5.  The Detroit River area is the primary source of mercury in the

    western end of Lake Erie.  This is revealed by the distribution

    pattern established through sediment samples.

6.  Because of mercury discharges, the State of Michigan stopped the

    production of chlorine by Wyandotte Chemicals Corporation until

    a treatment system was developed and the mercury-bearing wastes

    were removed from the receiving waters.

7.  The State of Ohio issued an order to the Detrex Chemical In-

    dustries, Inc., Ashtabula, Ohio, on April 13, 1970, to "...

    cease and desist the discharge of liquid industrial waste

    containing any mercurial compounds to waters of the state."

    Some operational changes were made but data collected on

-------
     May 11,  1970,  indicate that Detrex still discharged 1.2 pounds




     of mercury per day.




 8.   Allied Chemical Co.,  Buffalo Dye Division,  Buffalo, New York,




     is a source of mercury to the Buffalo River.   On May 8, 1970,




     a sample of the plant effluent revealed 0.12 mg/1 mercury.




     The company stated that the process utilizing mercury was not




     in use on that day.   Based on this information,  Allied Chemical




     Co. was discharging approximately k pounds  of mercury per day




     from sources other than the reported production of disulfo




     intermediates.




 9.   The discharge from Diamond Shamrock, Painesville, Ohio, to




     the Grand River had a concentration of 0.010 mg/1 mercury on




     April 4, 1970.




10.   Concentrations of 0.002 mg/1 were present in the effluents from




     the Ann Arbor and Wayne County-Wyandotte, Michigan, waste water




     treatment plants.  No measurable concentration of mercury was




     present in six other waste water treatment  plant effluents inves-




     tigated in Michigan (State data).  Concentrations of 0.004, 0.003,




     and 0.004 mg/1 mercury were present in Euclid and Cleveland Westerly




     and Southerly sewage treatment plant effluents, respectively.




     Although no measurable concentration of mercury was present in




     the Cleveland Easterly sewage treatment plant effluent, which




     receives wastes from several users of mercury, 4 mg/kg were present




     in Lake Erie sediments 100 feet north of the discharge point.

-------
11.  On May 1, 1970 a concentration of 0.011 mg/1 mercury was present




     in the outfall from the National Aeronautics and Space Administra-




     tion, Lewis Research Center, Cleveland, Ohio.   This occurred




     during a period when there was no discharge from lagoons that




     supposedly receive all mercury wastes from known sources.




12.  Investigations of additional potential dischargers of mercury




     to Lake Erie are in progress by the states and the Federal Water




     Quality Administration.

-------
                          RECOMMENDATIONS








1.   Surveillance and sampling programs be initiated by industries,



    municipalities,  States and the Federal Government to locate



    and identify all sources or potential sources of mercury and



    to determine mercury concentrations in surface waters,  land



    run-off, waste streams, aquatic life, and sediments.




2.   All dischargers of mercury to surface or ground waters  or to



    municipal or regional waste treatment plants, including Federal



    installations, be ordered to cease and desist.



3.   Precautionary measures be taken by all users and possessors



    of mercury or mercurial compounds for any purpose to prevent




    accidental spills or other losses to the water environment.

-------
                          INTRODUCTION





       The toxic effects of mercury and its compounds in the water




environment are well known and are documented in the literature.




However, much remains to be learned, on toxicity limits of the




various mercurial compounds in the water environment.  The




upper limit  of mercury in food, used by the Food and Drug Adminis-




tration, is 0.5 parts per million wet weight.  Limits have also been set for




atmospheric concentrations and numerous cases of poisoning have




been reported.




       Critical pollution from mercury became apparent on March 2U,




1970, in the Great Lakes.  Mercury concentrations as high as 5000




parts per billion (or 5 ppm) were reported in some of the pickerel




shipments from Canada and. commercial fishing involved was suspended




by Canada, then Ohio, Michigan and New York.  The presence of mer-




cury in fish and bottom sediments in the St. Clair River-Lake Erie




system has confirmed the existence of an environmental problem of




major scope.




       Mercury is discharged to the water environment from indus-




trial processes and uses of mercurial products.  In 1968, mercury




produced from mining in the United States was 2,19^,000 pounds.




The total amount used in 1968 however, was 5,732,000 pounds.  Over




163 million pounds of mercury have been consumed in the United




States in the present century, but little information is available




on the final disposition of it and amounts accumulated in the




environment.



                                   8

-------
       Metallic mercury and mercurial compounds in liquid wastes




are characterized by their high densities.   Free mercury and the



mercurous compounds form sludges and settle to the bottom of re-



ceiving waters.  The mercuric compounds form precipitates with




oxides, phosphates, sulfides and carbonates.  The high density is



responsible for the rapid deposition in bottom sediments where they



persist, become subject to sediment transport and are available to the



aquatic life.



       Metallic mercury can be oxidized readily to divalent mercury



ions under the conditions present at the bottom of lakes and rivers.



This has been shown to occur experimentally as well.   The divalent




inorganic mercury produced has an extremely strong affinity for



organic muds and is biologically methylated in the bottom sediments.



Divalent organic mercury, when methylated, is readily released from the



sediments into the water.



       Many fish are bottom feeders or feed upon organisms which



are bottom dwellers and therefore the hazard of mercury ingestion



becomes very great.  Fish also absorb mercury from the water through



the gills and possibly the scales.



       Since biological concentration of mercury occurs, the accumula-



tion of mercury in the food chain is a matter of grave concern.  A



recent report—' indicates a magnification or concentration of mercury




of over a million in the protoplasm of bacterial species.  It has been



demonstrated that the concentration from water to pike is in the order



of 3,000 or more.ง/

-------
                                 10

Uses of Mercury
       Sources of mercury in the environment principally come from
industrial processes utilizing a form of mercury and the use of
mercurial products by man.t
       The industrial uses in 1968 are listed in the following
tabled
                                             Thousand of Pounds
       1. Electrical apparatus
       2. Electrolytic preparation of               ,
          chlorine and caustic soda                  '
       3. Paints                                      803
       k. Charging new installations of               ,-__
          chlorine and caustic soda cells
       5. Industrial and control instruments          581
       6. Agricultural uses                           260
       7. Dental preparations                         158
       8. Catalyst preparations                       1^5
       9. Laboratory uses                             151
      10. Pharmaceuticals                              32
      11. Paper and pulp uses                          31
      12. Amalgamation (mercury alloys)                20

       Mercury is used as the cathode in the electrolytic manufac-
ture of chlorine with caustic soda and hydrogen as by-products.
Cell recharging to make up the various losses from this process
was 26 percent of the total mercury used in 1968 by all industries.
To maintain the mercury inventory it required purchases of 1.3
million pounds of mercury in 1968.  Weak spent brines, acids from
the chlorine driers,  brine sludges and cell cleanings are discharged

-------
                                 11






to the water environment from this process.  The mercury may be



metallic mercury emulsion, soluble and insoluble mercury salts.



       In 1968, 630,000 pounds of mercury were used in the start-



up of new electrolytic installations.  This amount eventually



contributes to the cell losses.



       Information from manufacturersof mercurials used for herbi-



cides, fungicides and bactericides is not readily available.



These compounds usually are produced in batch processes and require



considerable clean up with possible losses of mercury.



       In the paper and pulp industry, phenyl mercury acetate is



used for slime control and ground wood pulp may contain up to 20


                     k/
ppm of the fungicide.—   This mercury is either lost to the product



or to the waste load during processing.  In either case it becomes



a waste.



       Large quantities of mercury are used in the manufacture of



electrical apparatus and. industrial and control instruments such



as mercury cells, arc lights, pumps and switches.  This poses a



hazard of loss during the manufacturing process.



       Catalysts, containing 10 percent mercuric chloride are



manufactured for use by the petrochemical industry.  This is made



by passing a water solution of mercuric chloride over carbon and



is used for making vinyl chloride from acetylene.  Another catalyst



containing mercuric sulfate is used in processing acetylene to

-------
                                12





acetaldehyde.  There are losses to the water environment from




these processes.




       Paints, those used for mildew control as well as those




having anti-fouling characteristics, contain mercury, usually in




the organic form.  Erosion from paint films containing these com-




pounds is another source of loss to the environment.




       Mercury is used in dentistry for the preparation of amal-




gams.  Minor losses may result from this use.




       Laboratory use of mercury in manometers, thermometers,




calomel cells, standard cells and as reagents results in an




occasional discharge to sewers.  In large research centers or




universities, the quantities can become appreciable.




       Minor users of mercury are the pharmaceutical manufac-




turers and in amalgamation.  In the pharmaceutical manufacture,




diuretics and antiseptics, i.e. calomel, phenyl mercury acetate




and merthiolate are made.  Accidental spills are the source of




loss to the water environment.




       The recovery of gold and silver by mercury amalgam is a




wet process and may result in rather high losses of mercury in




tbs plant effluent.




       Additional mercury is introduced to the water environment




through the use of products containing mercurial compounds.  The




most wide-spread example of this is in the agricultural applica-




tion of fungicides and pesticides, which results in losses during




periods of run-off from the area to which they are applied.

-------
                               13
References
1.  Minerals Yearbook, 1968, Vol. 1-11, Metals, Minerals and
    Fuels, Bureau of Mines, Chapter on "Mercury" by J. M. West.
2.  Woods, J. M.  "Environmental Pollution by Mercury," Advances
    in Environmental Science, Vol. II (in Print).
3.  Jernelov, P.  "Biological Methylation of Mercury in Aquatic
    Organism," Nature, Vol. 223, No. 5207, PP. 753-75^, August l6,
    1969.
4.  Smart, N. A.  "Use and Residues of Mercury Compounds in
    Agriculture,"  Residue Reviews, Vol. 23, pp. 1-36.  1968.
5-  Battelle Memorial Institute, Design of an Overview-System
    for Evaluating the Public-Health Hazard of Chemicals in the
    Environment, Appendix A, 1967.
6.  Johnels, A.  G.,  et al.   "Pike (Esox lucius L.)  and Some Other
    Aquatic Organisms in Sweden as Indicators of Mercury Contamina-
    tion in the Environment,"  Oikos, 18(2):   323-333, 1967.

-------
                         MERCURY ANALYSES IN
            THE ST.  GLAIR RIVER,  LAKE ST.  GLAIR,  DETROIT
                     RIVER AND WESTERN LAKE ERIE
       The  FWQA-Lake Huron Basin Office (LHBO)  initiated a  water

 and sediment sampling  and analysis  program for  mercury in the  St.

 Clair River —  Lake  Erie  system immediately after  the  Canadian

 government  announced the  fishing ban in Lake  St. Clair on March 2k,

 1970.

       Sample collections were  made by personnel from  the Lake Huron

 Basin Office with assistance  from the Michigan  Water Resources

 Commission.

       Water samples were collected with a surface grab-sampler.

 Sediment  samples were obtained by the use of either a Petersen  dredge

 or  a drag line  sampler.   These  devices penetrate the bottom to a

 depth of  about  one-fourth foot.   Physical properties such as odor,

 color, and  general composition  of the bottom  materials were recorded.

       The  State  of  Michigan  reports no measurable mercury  in  any

 water supply intakes within this area.

       State data on analyses of 2U-hour composite samples from nine

municipal waste water treatment plants revealed concentrations  of

0.002 mg/1 at the Ann Arbor, Michigan, and Wayne County-Wyandotte,

Michigan,  plants on April Ik,  1970.

-------
                                 15
ST. CLAIR RIVER AND LAKE ST. CLAIR




       One water sample and 26 sediment samples were collected and



analyzed from Lake St. Clair (Table 1 and Figure l).   Six sediment



samples in the navigation channel contained mercury in concentrations




from 0.3 to 9.2 mg/kg dry weight.  Two samples from a dredging dis-



posal area contained mercury at concentrations of 1.7 and 2.1 mg/kg



dry weight.  In the other 18 sediment samples the presence of mercury




was indicated^ but was less than the measurable limit.  The water



sample contained less than the measurable limit.



       Sampling of the St. Clair River began on March 2.6, 1970.



Fifteen samples of sediments and six water samples were collected



between river mile (R.M.) 10.k and 37.0.  Sediment samples




from R.M. 37.0, 33.0, and 25.5 contained concentrations of 1.0, 0.2,



and 0.3 mg/kg, respectively (Table 1 and Figure 1).  The other 12



sediment samples contained less than the measurable limit of 0.5 mg/kg



wet weight, but indicated that traces of mercury were present.  The



six water samples contained no measurable concentrations of mercury.

-------
St. Glair River

   Sample
Collection
  Date
                                 Table 1
                              MERCURY SURVEY
                         Sample Analysis Results
       Location
             Ft. from
River Mile   U.S. Shore
        Mercury  Content
  Sediment  (ing/kg)        Water
Wet Basis   Dry  Basis     .(re;;/I).
  1970
  3/26
   II
   It
   II
  4/30
  10.4
  10.6
  10.6
  17.5
  17.5
  17.5
  35.4
  33.5
  31.5
  29.5
                   27,
                   23,
                   21,
                   19.5
20
1850
4120
20
1500
2700
100
100
100
100
100
100
100
100
< 0.5

< 0.5
< 0.5

< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
,-< 0.5
                         < 0.01
                         < 0.01
                         < 0.01
                         < 0.01
                         < 0.01
                         < 0.01
                                      16

-------
        LAKE HURON IASIN OFFICE
MERCURY  BOTTOM SEDIMENT  SURVEY
         ST. CLAIR  RIVER
             APRIL 1970
      U.S. DEPARTMENT OF  THE INTERIOR
   FEDERAL  WATER  QUALITY ADMINISTRATION
   •REAT LAKES RESIGN  SROSSE ILE, MICHIGAN
             SCALE IN MILES
                      -T4	8
  MICHIGAN
     1970
   Dredging
DOW CHEMICAL  CO
                                                                         FIGURE 1
                                                                ONTARIO
                                                                
-------
                                Table 2
                            MERCURY SURVEY
                      Sample Analysis Results
Lake St.  Clair
Sample
Collection
Date
1970
4/15
"
"
n
n
n
n
4/21
11
n
' n
n
4/22
n ซ•
* ^
11
"
it


Location
Grid Coordinates

18. 8N
3.8N
13. 5N
16. 5N
' 16. 6N
18. 7N
20. ON
0.4N
1.8N
.3.2N
' 5.5N
7.5N
6.8N
11. 2N
11. 6N
13. 9N
17. 8N
21. 7N

10. 6E
4.3E
9.9E
10. OE
7.6E
8.6E
11. 9E
0.4W
LIE
1.7E
2.5E
2.3E
7. IE
11. 2E
2.9E .
4.8E
6.6E
9.6E
                                                     Mercury Content
                                             Sediment fag/kg)	     Water
                                                                     fag/I)
Wet Basis   Dry Basis
                                            < 0.5
                                              0,
                                              0,
                                              0,
                                              0.
                                              0.
                                              0.
                                              0.
                                              0.
                                              0,
                                              0.
                                              0.
                                              0.
                                              0.
                                              0.
                                              0.
                                              0.
                                                                    < 0.005
                           13.4E
   0.5
                                   5L6

-------
                          FIGURE  2
Clinton fttvtr
                                              LAKE HURON BASIN OFFICE
MERCURY BOTTOM SEDIMENT  SURVEY
          LAKE ST. CLAIR
             APRIL 1970
     <0.5  Wซt Weight Mg/Kg
     (Voriet from  <0.6 to  
-------
                                 20
UPPER DETROIT RIVER (LAKE ST. CLAIR TO GRASSY ISLAND)




       Sampling of the upper Detroit River and lower Rouge River




began on March 26, 1970, and continued to April 21*.  Sixteen sedi-




ment and six water samples were obtained, as indicated in Tables 3




and 4, and shown on Figures 3 and k.  Mercury was detected in sedi-




ments along the U. S.  shoreline at boat ramps and in other backwater




areas.  Values ranged from less than the measurable level near the




headwaters to 2.0 mg/kg downstream from the Rouge River.   Concentra-




tions in sediments around Grassy Island and upper Fighting Island were




less than the measurable limit.

-------
                                  Table 3
                             MERCURY SURVEY
                          Sample Analytic Results
Upper Detroit River
(upstream from the Rouge River1
  Sample
Collection
Location
  1970

   3/26
   3/30
   4/14
   4/23
    it
    it
    it
    it
    ti
    it
    it
              River Kile
     Feet from
     U.S. Shora
                Mercury  Content
  Sediment  (mg/kg)          Water
Wot Basis   Dry Basis
26.8
30.8
30.8
30.7
30.7
29.3
30.8
29.4
27.4 '
26.2
^5.7
23.8
2'2.3
21.1
700
500
1000
500
980
1600
0
0
3300
2300
0
100
0
0
< 0.5




< 0.5
< 0.5
< 0.5
0.6
< 0.5
0.9
0.5
0.6
0.7
                                   0.9
                                   1.2
                                   0.7
                                   1.2
                                   1.4
                                                 0.01
                                                 0.01
                                                 0.01
                                                 0.01
                                                 0.01
                                       21

-------
                    FIGURE 3
MICHIGAN
 DETROIT
                          LEGEND
                            +     <0.5  Wet Weight Mg/Kg
                                   (Varies from  -eO.6 to  
-------
                                Table 4


                          MERCURY SURVEY

                      Sample Analysis Results
      River
   Sample           .                                Mercury Content
Collection                       '        Sediment .fag/kg)        Water
   Date              River Mile        Wat Basis  Dry Basis      (tnpfl/l)

   1970
    3/26               1.1              < 1.0                  < 0.01
    4/23                .3 Old Channel  < 0.5
     11                 1.5 Old Channel  < 0.5
    4/24               1.8              < 0.5
                       3.1              < 0.5
                        .1              < 0.5
                                   23

-------
                                              FIGURE k
       LAKE HURON  BASIN OFFICE

MERCURY  BOTTOM  SEDIMENT SURVEY

            ROUGE   RIVER
             APRIL  1970
      U.t. DEPARTMENT  OF THE INTERIOR
   FEDERAL WATER QUALITY ADMINISTRATION
   • MEAT LAKES REdON  (ROME ILE, MICHIGAN
                                                 +    Lass than  the Detectable  Limit

                                               .MP2.0   Mile Points
    ONTARIO

-------
                               25
LOWER DETROIT RIVER (GRASSY ISLAND TO MOUTH)




       In the portion of the Detroit River from Grassy Island




to the mouth at Lake Erie, 78 sediment and 23 water samples




were collected between March 26 and April 16, as shown in




Tables 5 and 6 and Figure 5-  The highest levels of mercury




occurred in the bottom muds of the Trenton Channel downstream from




the Wyandotte Chemicals Corp. South Works, in a narrow strip of




from 20 to 100 feet along the western shore.  Concentrations along




the east shore of the channel near Grosse lie were less than




the measurable limit of 0.5 mg/kg.  Mercury in the sediments




indicates that the Wyandotte Chemicals' mercury discharge hugs




the western shore of the Trenton Channel, depositing mercury




in the bottom muds along shore.  No mercury was present around




Wyandotte Chemicals' waste beds, located on the northern tip of




Grosse lie.  However, one sample collected between Grassy Island




and Grosse lie contained k.k mg/kg mercury.




       Mercury contamination in sediments was present along shore




as far as Lake Erie.  In addition to high values near Wyandotte




Chemicals, one sample with 26.0 mg/kg dry weight was collected at




the northern tip of Horse Island  (Gibralter, Michigan) at mile




point 6.7.




       Of the four samples collected at the southern end of




Fighting Island, one contained 1.2 mg/kg mercury, and the others

-------
                              26
contained trace amounts, but all were below the measurable limit.




Wyandotte Chemicals waste lagoons are located on Fighting Island.




       The only mercury measurable in four samples in Canadian




sediments was near the shore at mile point 3-9 (0.6 rag/kg).




       As indicated in the tables, the levels of mercury in all




water samples but one were below the measurable limit of 0.01




mg/1.  One sample collected 300 feet downstream from Wyandotte




Chemicals outfall W23 (RM 13.3) contained 0.03 mg/1.  The effluent




was diluted by Detroit River water so mercury was not measurable




further downstream from the discharge point.

-------
                               Table 5
                             MERCURY SURVEY
                         Sample analysis Results
Lower Detroit River
(below the mouth of the Rouge River
 excluding the Trenton Channel)
Sample
Collection
Date
1970
3/27
it
it
n
ti
3/30
n
4/6
4/8
n
M
n
n
n
4/14 .
n
n
n
n
n
n
n
4/16
n
n
n
n
n
n
n
Location

River Mile

13.5
13.3
8.4
3.9
3.9
3.9
3.9 '
5.9
14.2
13.7s
13.3
12.7
15.3
16.0
14.6
16.0
16.3
16.4
16.5
16.7
18.1
19.0
16.3
14.8
13.5
13.6
15.3
17.1
16.0
15.4
Ft. from
U.S. Shore

9400
8850
17,700
15,000
19,000
15,000
19,000
13,500 '
1400
2100
2400
3200
1500
2300
1300
5500
500
0
2900
1000
0
0
9950
8200
/ 7200
7700
4300
2500
3700
1000
Mercury Content
Sediment (tng/kc)
"Wet Basin Dry Basis

< 1.0
< 0.5
< 0.5
< 0.5
0.5 0.6


< 1.0
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
1.1 4.4
< 0.5
0.7 2.0
0.5 1.7
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
0.7 1.2-
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
Water
(m?/l)

< 0.01


< 0.01
< 0.01
< 0.01
< 0.01























                                       27

-------
                                 Table 6







                             MERCURY SURVEY




                         Sample Analysis Results




Detroit River-Trenton Channel Area
Sample
Collection
Date
. 1970
3/26
3/27
it
it
ii
ii
ii
3/30
it
3/31
ii
M
4/1
n
it
n
n
1 n
n
n
n
n
M
n
ii
4/3
it
n
M
ii
n
n
n
it
n
Location

River Mile

8.7
13.1
13.4
13.2
12.4
3.9
3.9
3.9
3.9
13.2
13.1
13.3
13.4
13.4
13.2
13.2
13.1
13.1
13.1
12.4
12.4
12.4
12.4
13.9
12.0
13.2
13.1
12.4
13.3
12.8
12.0
11.3
10.5
9.8
8.7
Feet from
U.S. Shore

80
20
20
20
20
2500
6500
2500
6500
20
20 .
20
20
100
20
100
20
100
200
20
200
800
1000
0
0
20
20'
20
20
20
20
50
50
50
80
Sediment
Wet Basis

<1.0
28.0
13.0
10.0
4.0
4.9
< 0.5





. 2.0
< 2.0
5.0
< 2.0
25.0
6.0
< 2.0
4.0
< 2.0
< 2.0
< 2.0
< 2.0
6.0










Mercury Content
(ing /kg)
Dry Basis


86.0
21.0
16.0
8JO
11.0






3.0

7.0

82.0
10.0

10.0




14.0










Water(
(iWl)

< 0.01




< 0.01
< 0.01
< 0.01
< 0.01
< 0.01
< 0.01
0.03













<0.01
•<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
                                        28-

-------
                                 Table 6


                            MERCURY SURVEY

                        Sample Analysis Results

Detroit River-Trenton Channel Area  (cont.)
Sample Location '
Collection
Date
L970
4/6
n
n
n
n
n
M
n
4/7
n
n
n
4/8
M
n
n
M
4/16
4/17
n
n
n
M
4/24
4/26
n
n
n
M
n
n
n
River Mile

8.7
8.7
10.2
7.9
5.4
4.7
5.8
12.0
7.6
6.7
6.3
"• 6.3 .
.. 11.6
12.0
12.5
12.8
13.4
8.6
6.7
6.7
6.7
6.7
6.3
8.3
13.0
13.0
12.9
12.8'
12.7
12.6
,12.5
13.2
Feet from
U.S. Shore

80
1240
0
300
600
6200
7200
20
100
150
1200
3400
1150
1850
1850
1500
850
600
100
1000
2000
3000
150
0
20
20
20
20
20
20
20
20
                                                  Mercury  Content
                                         Sediment  fag/kg)           Water
                                      Wet  Basis   Dry  Basis       fag/I)
                                         1.9           5.0
                                       < 1.0
                                         2.8           4.3
                                         1.7           2.6
                                         2.2           4.6
                                       < 1.0
                                       < 1.0
                                         7.1          15.0
                                        . 1.0           1.3
                                        11.0          26.0
                                       < 1,0
                                       < 1.0
                                       < 0.5
                                       < 0.5
                                       < 0.5
                                       < 0.5
                                       < 0.5
                                         0.9           1.2
                                         0.9           3.0
                                         0.6           0.8
                                       < 0.5
                                       < 0.5
                                         1.5           2.3
                                       < 0.5
                                       < 0.5
                                         4.9          16.0
                                        12.0          27.0
                                         9.7          20,0
                                         2.4           5.4
                                         5.6          14.0
                                         4.3           9.5
                                         5.7           8.1
                                      29

-------
M I  C H I 6 A  N
     WYANOOTTE
    FOR THIS AREA SEE
    LARGER SCALE MAP
         THIS DWG.
                                       ERIE
                                                             <0.5 Wet Weight Mg/Kg
                                                             (Vories from  <0.6 to 
-------
                               31
WESTERN BASIN OF LAKE ERIE, INCLUDING
THE RAISIN AND MAUMEE RIVERS

       The sampling of Lake Erie began on April 6, 1970, vith

bottom sediments collected at two stations near the mouth of

the Huron River (Figure 6).  From April 6 to April 27, ^ bottom

sediment'stations were sampled.  Samples were collected in

western Lake Erie, west of Pelee Island, with the majority of

samples collected near the mouths of Michigan tributaries.

Based on the measurable limit of 0.5 mg/kg wet weight, mercury

was present at 16 of the 1*4 stations, although traces were present

at most of the other stations (Table 7) •

       The Raisin River was sampled on two different dates at

three stations (Figure 6).  Traces of mercury were present; how-

ever, all results were less than the measurable limit (Table 8).

       The Maumee River was sampled on April 17 at six stations

(Figure 7)> and traces of mercury were present at most stations;

however, all results were less than the measurable limit (Table 9) •

       The 16 stations where mercury was present are located in

the deepwater areas of the western basin of Lake Erie from the

mouth of the Detroit River southward and eastward.  Since shoreline

and minor tributary samples did not contain appreciable amounts of

-------
                               32
mercury, the Detroit River appears to be the principal source,




with mercury being deposited in the deeper quiescent parts of




the lake.

-------
                                Table 7
Lake Erie


  Sample

Collection

  Date

  1970


  4/6
   ||

  4/7
  4/10
  4/14
  4/15
   n
  4/25
   n
  4/27
                           MERCURY SURVEY

                       Sample Analysis Results
Mercury Content
Location

Grid Coordinates
2.2N
2. ON
0.7N
O.ON
1.3S
2. OS
2.9S
3.7S
2.8S
4.3S
5. OS
5.4S
9.6S
17. 4S
0.5N
5. IS
8.7S
9.4S
10. 7S
16. 5S
17. 4S
11. 2S
1.3S
4.3S
8.6S
14. 8S
21. 3S
23. 6S
24. 8S
6. OS
10. OS
14. OS
14. OS
20. OS
20. OS
24. OS
2.4N
0.3N
4. OS
4. OS
4. OS
14. OS
20. OS
16. OS
2.6W
2.4W
1.3W
0.6W
4.2W
3.2W
2.2W
4.8W
5.8W
8.3W
6.4W
9.5W
11. 6W
2.4E
3.2E
2.0W
2.9E
5.7W
6.7E
9.4W
5.8W
10. 3W
2.9W
4.9W
8.1W
13. 1W
7.1W
3.5W
1.2E
0.0
0.0
0.0
8.0E
0.0
8.0E
14. OE
0.4E
O.OE
8.0E
14. OE
20. OE
20. OE
20. OE
14. OE
Sediment
Wet Basis
< 1.0
< 1.0
1.0
1.0
<'0.5
< 0.5
< 1.0
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
0.6
0.5
< 0.5
: 0.5
< 0.5
0.8
< 0.5
< 0.5
< 0.5
< 0.5
0.8
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
0.7
0.6
0.6
< 0.5
0.5
< 0.5
< 0.5
1.0
1.0
0.9
0.5
0.5
< 0.5
< 0.5
< 0.5
(mg/kfi) Water
Dry Basis (m^/l)


1.8
1.8








0.8
• 1.6

1.0

1.8




1.0






1.1
1.7
2.1

1.7


1.8
2.1
2.7
1.3
1.5



                                    33'

-------
                  Table 8
             MERCURY SURVEY

         Sample Analysis Results
River Raisin

  Sample
Collection
  Date
               Location
                                       Mercury  Content
                                 Sediment
Grid Coordinates  River Mile   Wet Basis  Dry  Basis    (jr\v/l}_
  1970

  4/10
  3/30
  3/30
        7.6S      9.8W       -0.5     < 0.5
Consolidated Paper(S) W154    1.7     < 0.5
Mascru-Run at Ford Bridge  1.3-0.1     < 0.5
           W171
                                                       < .01
                                                       < .01

-------
FIGURE 6
                      35

-------
                           Table  9


                      MERCURY SURVEY
                   Sample Analysis Results

Mhumce River
  Sample                                            Mercury Content
Collection    	Location	     Sediment  (ing/kg)   Water
  _Date        Grid Coordinates  River Mile   Wet Basis   Dry Basis (y\?./Vt
  1970
   4/17                            0.5         < 0.5
                                   0.0         < 0.5
                                   2.1         < 0.5
                                   5.1         < 0.5
    "                              6.9         < 0.5
    11         19.6S      14.5W                 < 0.5
                              36

-------
                    FIGURE  7
                                                            LAKE
Ml C HIOAN
 "OHIO
                                                -h     <0.5  Wet Weight Mg/Kg
                                                  SCALE IN MILES
                                            LAKE  HURON BASIN OFFICE

                                    MERCURY BOTTOM SEDIMENT SURVEY

                                               MAUMEE  RIVER
                                                  APRIL 1970
                                           U.S. DEPARTMENT OP  THE INTERIOR
                                        PEDERAL WATER  QUALITY ADMINISTRATION
                                        • KEAT LAKES RESION  ซRO*tt ILE, MICHI9AN
                        37

-------
                      MERCURY ANALYSES




                IN THE EASTERII PORTION OF TEE




                       LAI3S ERI'iS BASH i






      As part of its mercury investigations in the Lake Erie




Basin, the Federal Water Quality Administration-Lake Erie Basin




Office analyzed bottom sediments from the downstream portions of




south shore tributaries and from the lake bottom.  Tables




10 and 11 include results from the sediment and water analyses




to 5-12-JO except those made at the Detrex Chemical Corp.




plant.  Detrex analyses are listed in a special report on




that plant (Appendix II).




      At the Lake Erie Basin Office the lower limit of




measurability of mercury in sediments is 1 mg/kg and in




water 0.002 rag/1.




      The states of Ohio, Pennsylvania, and New York report




no measurable mercury in any water supply intakes within this




area.

-------
                         Table 10

                   LAKE ERIE BASIN OFFICE

                  MERCURY ANALYSES - WATER
Station No.
Location
Date
1970
Mercury*
mg/1
    12          Diamond Shamrock, Painesville

                   Influent                          U/10    <0.002
                   Hydro discharge to Grand River    4/10     0.010
                   North sewer to Lake Erie          4/10    <0.002

    14          1.59 mi. Ashtabula River (Norfolk
                   and Western RR bridge)            4/1?    <0.002
    15          1.95 mi. Fields Brook (Columbus
                   Rd. bridge)                       4/17    <0,002

                Euclid, Ohio STP                     5/11     0.004

                Cleveland Southerly STP              5/12     0.004

                Cleveland Westerly STP               5/12     0.003

                Cleveland Easterly STP               5/6    < 0.002
                Mile 1.0 West Branch Ashtabula       5/5    < 0.002
                   River 200' downstream from
                   titanium plant


                General Electric, Nela Park,                  1.060
                Cleveland - Discharge 3 gals every
                two weeks
*0.01 ag/1 is the lowest sensitivity of test

                               39

-------
                                 Table 11
                           LAKE ERIE BASIN OFFICE
                         MERCURY ANALYSES - SEDIMENT
                              Dry Weight Basis
Station No.
1
?
3

4
5
6
7
8
9
10

11
13
15
16
17
Location
0.53 mi. Portage Ri^rer (Rt. 2 bridge)
0.0 mi. Sandusky River
Tributaries emanating from NASA-Plumbrook
PB-1 (Plum Brook)
PB-2 (No Name Creek)
PB-3 (East Branch, Pipe Creek)
0.6l mi. Black River (Rt. 2 bridge)
8.1^ mi. Rocky River
10.0 mi. Rocky River (NASA - Brookpark)
4.27 mi. Cuyahoga River (Norfolk P-. Western
RR Bridge)
C33-8 (100 ft. North of Cleveland Easterly
STP outfall)
D24-1 (50 ft. North of E. 22?nd St -
Babbitt Rd. sewer outfalls. Euclid, 0. )
Tributary to Chagrin River (General
Biochemical plant)
^1 (200 ft. downstream from plant
outfall)
#2. (at plant outfall)
2.85 mi. Grand River (St. Clair St.
bridge)
0.76 mi. Ashtabula River (East 5th
St. bridge)
1.95 mi. Fields Brook (Columbus RR
bridge)
No Name Ditch East of Ashtabula (Rt
531 bridge)
J41-1 (Presque Isle Bay)
	 ___^— — — — — —
Date
4/14
k/lk

4/10
4/10
4/10
4/13
4/22
4/14
4/10
4/13
4/13

4/10
4/10
4/10
4/15
4/10
4/13
4/20

Mercury*
mg/kg
< 1
< 1

< 1
< 1
< 1
8
< l
< 1
< 1
4
2

< 1
< 1
< 1
2
< 1
8
< 1

51g/kg is the lowest  sensitivity o:

-------
                                     Table  11
                            IAKE ERIE BASIN  OFFICE  (cont'd)
                              MERCURY ANALYSES  -  SEDIMENT
                                   Dry Weight Basis
Station No.
18
19
20
21
22
23
2U
25
26
27
28
29
30
31
32
33
Location
G33-12 (20 ft. north of Detrex-Linde
lake front outfall)
G33-13 (80 ft. north of Detrex-Linde
lakefront outfall)
123-2 (6 mi. north of Ashtabula)
H3U-2 (6,600 ft., 38ฐT from Detrex-
Linde outfall)
H3U-1 (7,000 ft., 35ฐT from Detrex-
Linde outfall)
H33-7 (5,600 ft., 20ฐT from Detrex-
Linde outfall)
5,000 ft. north of Detrex-Linde outfall
(H33-8)
3 mi., 56 T from Detrex-Linde outfall
(H3U-5)
U-3/U mi., 6lฐT from Detrex-Linde
outfall (H3U-6)
2 miles ENE of Conneaut (H36-20)
Mouth of Ashtabula River (A-U)
0.96 miles Ashtabula River (A- 3)
600 ft. north of mouth of Grand River
(G-5)
0.50 miles Grand River (G-U)
Mouth of Black River (B-U)
1.0 miles Black River (B-3)
Date
U/20
U/23
U/20
U/23
U/22
U/22
U/22
U/22
U/23
U/23
U/23
U/2U
U/28
U/28
U/28
. U/28
U/28
Vป
Mercury*
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
<• 1
*  1  mg/kg is the lowest sensitivity of test

-------
                                   Table 11

                            LAKE ERIE BASIN OFFICE (concl'd)

                              MERCURY ANALYSES - SEDIMENT

                                  Dry Weight Basis
  Station No.
                 Location
 Date
Mercury*
 rag/kg
      35
37-l.A mi., 7ฐT from Cleveland (123-1)
   Core length

      0-k inches
      4-8 inches
      4-12 inches
     16-20 inches

Composite of benthic organisms obtained
from Kelleys Island Shoal and Starve
Island Reef

RM 0.0 Buffalo River

RM 4.3 Buffalo River

RM 0.0 Maumee River

RM 1.5 Maumee River

S-2 Sandusky Bay - 3 miles 310ฐ true
from Sandusky Court House

S-7 Sandusky Bay - 1.2 miles 10ฐ true
from Sandusky Court House

RM 0.4 Cuyahoga River

C-6 400 feet NW of Cuyahoga River Mouth
8/20/69
8/20/69
8/20/69
8/20/69

 4/15
< 1
< 1
< 1
< 1

< 1
                                                               5/6/70      4

                                                               5/6/70      1

                                                               4/28/70   < 1

                                                               4/28/70   < 1

                                                               4/29/70   < 1


                                                               4/29/70   < 1


                                                               4/29/70   < 1

                                                               4/29/70   < 1
* 1  rag/kg is the lowest sensitivity of test
                                           42

-------

-------
HEAVY METALS IN THE LAKE ERIE BASIN



      As part of the investigations in the Lake Erie Basin,



the FWQA, National Field Investigations Center analyzed



bottom sediments from various shore areas and tributaries.



The results of analyses for ten heavy metals are listed in



Table 12 and the sample locations are shown on Figures 9,



10, and 11.  Stations were selected in the mouth of tribu-



taries and immediately off-shore.




      Heavy metals are toxic to aquatic bottom organisms



and fish when present in sufficient concentrations.  Combin-



ations of some of these metals such as copper and zinc have



a total toxicity greater than the sum of the toxicities of



each metal taken independently.  Metals such as iron oxides



precipitate in water and may blanket the bottom and smother



bottom organisms.  Toxic metals in bottom muds can be made



available to the overlying water by physical, chemical or



biological means.  Metals may re-enter the overlying water



by scouring of the stream bed because of velocity increases,



by wave action, or other water turbulences.  These metals may



also be resolubilized by the waterbody dependent upon environ-



mental conditions such as pll, temperature and concentrations



of other metals present.  Some of these metals may also be detri-



mental to aquatic organisms when concentrated in the food web.

-------
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-------
                                                    Figure  9
MICHIGAN
                                                                    19759
                          LEGEND
                             •f     <0.5  Wet V'oighf Mg/K<;,
                                   (Varies from  <0.6 lo j=^-----=^--
                                    6        I
                                LAKK  HURON BASIN OFFICE

                              '.'fiY SOVi'OM SEDIMENT S'JRVEV
                                upr ro  o"7r,o!T RIVEF:
                                             1970
                                            OF r*t IN'. ฃK:O\
                                            osossc

-------

-------
51

-------
      APPENDIX I
 REPORT ON WYANDOTTE
CHEMICALS CORPORATION,
 WYANDOTTE, MICHIGAN
           52

-------
                                    53






Investigation of Wyandotte Chemicals Corp.




     Following the discovery of mercury in fishes caught in Canadian waters,




the State of Michigan reviewed the mercury-using industries in the State




and found that the Wyandotte Chemicals Corporation of Wyandotte, Michigan




was a major user of mercury.  The Michigan Water Resources Commission,




after consultations with the Wyandotte Chemicals Corp., gave the following




information to the Lake Huron Basin Office of the Federal Water Quality




Administration.




     The mercury cell operation at Wyandotte consumes an average of 80




pounds p.er day of mercury, of which approximately 10 to 20 pounds per day




is discharged' to the river.  Wyandotte Chemicals bases their estimate of




10 to 20 pounds per day on composite samples collected and composited for




three 8-hour periods each day.  The pounds per day figures given for FWQA




sampling generally indicate higher values.   However, FWQA conducted grab




sampling operations at the point of discharge to the river which are generally




not directly comparable with composite figures when there is variation in




concentration of waste throughout the day.   It was also discovered from




consultations with Wyandotte Chemicals that concentration varies through-




out the cross section of the discharge flume.  The Lake Huron Basin Office




began sampling the effluent from Wyandotte Chemicals on March 27, 1970.  The




results are given in the following table:

-------

March 27
30
31
April 3
6
7
8
9
10

F
M
T
F
M
T
W
T
F
AM
.10

.66
.33
.24
.14
.11

.12
        Effluent Samples by FWQA from Wyandotte Chemicals Corp.
                          (Outfall Code W23)

                            Mercury Content         Approx. Loading
     Date        Day         (mg/1 as Hg)               (Ibs/day)
                                         PM
                                                           11
                                         .32               36
                                                           74
                                         .23               31
                                         .11               18
                                         .40               30
                                         .11               12
                                         .32               36
                                       <.01 (effluent
                                  from mercury cells
                                  diverted to temporary
                                  treatment pond at 1230)


April 3 - Wyandotte Chemicals was called into the Michigan Water Resources

     Commission office and proposed a system of treatment which was
            -i-
     tentatively approved by the State agency.   Construction began immediately

     Effluent pipes at the mercury cell were blocked up and a temporary

     above-ground piping system has been installed from that point to a

     large concrete-lined containment area which had formerly been used for

     storage of limestone.  An earth dike was used to form a reaction pond

     area at the south end of the pond, the remainder of the pond being used

     as a settling area.  Weak cell liquor was introduced to the pipeline

     to keep the pH above normal.  An estimated 600 gallons per minute of

     mercuric chloride waste from the mercury cell was then discharged through

     the pipeline to a baffled timber mixing box before discharge to the

     reaction pond.  NaHS and spent sulfuric acid were added at the mixing

     box before discharge to the reaction pond.  After about six hours

     retention in the reaction pond,  the effluent discharges through

-------
                                     55


     another mixing box to the settling pond,  at which point cell liquor

     is added to bring the pH to neutral.   In  the settling pond, mercuric

     sulfide is precipitated which removes approximately 80 to 90 percent

     of mercury.  The discharge from this  pond was then discharged to a

     larger sewer which contained other wastes from the plant and then

     discharged to the Detroit River.

April 10 - The above system was placed in operation.  All waste from the

     mercury cell was diverted into the pond system.  There was no detectable

     discharge to the river, as indicated in the following table:

                              Mg/1 as Hg
     Date        Day        AM           PM         Approx. Ibs/day

     April 13     M                   <.005               0
           14     T      <.005       <.005  (pond filled, 0
            "'                     treated  effluent dis-
                                  charging to  sewer at 1930)

April 15-16 - Waste discharged to the river through the temporary treatment

     system contained approximately two pounds of mercury/day.

                              Mg/1 as Hg
     Date        Day        AM           PM         Approx. Ibs/day

     April 15     W        .006         .026              1.8
           16     T        .027        <.005  (plant       1.4
                                shut down by State of
                                Michigan-temporary
                                injunction at  1620)
                                        .023              2.6
                                                           0
                                                           0

                                        .005                .7
                                                           0
                                      < .005               0
                                        .018              1.8
          (Losses from W-23 on 4/24 and other minor losses since are
          verified by Wyandotte Chemicals thru MWRC.  No explanation
          can be found.  Wyandotte Chemicals is conducting an inten-
          sive cleanup of all piping, valving building areas, etc.,
          around the mercury cell operation to prevent further  losses.)
17
18
19
20
21
22
23
24
F
S
S
M
T
W
T
F

<.005
<.005
<.005
.008
<.005
< .005
.015

-------
                                    56

                              Mg/l as Hg
     Date        Day        AM           PM         Approx. Ibs/day

         We can probably expect small'losses from accumulations
         of 30 years of use.  Storm runoff from roof and grounds
         may also contribute.)
     April 25     S         .010         .006              0.9
           26     S      <.005         .005               Tr
         (Operation of mercury cell process was resumed.  State
         of Michigan approved a plan of operation in which mercury
         waste is treated in settling ponds, then discharged to
         brine caverns on Grosse lie.  This is a closed system;
         brine is pumped from the cavern to Wyandotte Chemicals
         for use in their processes.)
     April 27     M         .007      . <.005               Tr
           28     T         .005       ^.005               Tr
           29     W      <.005       ^ .005               0
           30     T      <.005       ^ .005               0
     May 1        F      <  .002       < .002               0
         A        M      <.002                            0
         5        T      <.002                            0
         6        W         .003                            .3
         7        T      <.002                            0
        ' 8 '       F         .003                            .3
        11        M      <.002                            0
        12   ^    T      
-------
                               57
       4
is intercepted before it reaches the river and pumped through temporary

above-ground piping systems to the waste pond.

   .  The waste pond is a concrete-lined depression formerly used for

limestone storage.  Earth dikes divide the pond into two areas; the

smaller portion in the south end of the pond is used as a reaction area,

and the remainder is used as a settling pond.

   The pond took longer than anticipated to fill, indicating leakage.

Seams in the concrete were then filled with asphalt compound and an

area along the west wall was covered with a clay blanket.  These measures

apparently stopped the leakage problem.  The company representative

informed us that under drains from the pond connect to the discharge

flume at W23 and the leaks were in the settling pond area so that
       -<•
even if.leakage occurred, it would be treated effluent and would be

measured at the same point as the effluent from the pond.

     Composite samples collected and analyzed by Wyandotte Chemicals

on three shifts at a point approximately 20 feet upstream in the

waste flume from the point sampled by FWQA at the point of discharge

to the river are as follows.  Comparison with FWQA sampling for the

same day is shown.

                         Mg/1 as Hg
                                                             Approx.
                                                             Ibs/day
April 15  Wyandotte Chemicals Composite  .027  .014  .012      1.8

                                            ...AM     PM
          FWQA Grab Samples      (           .006   .026        1.8

-------
         ECORSE
                                                      ONTARIO
 IOOO
Discharge to
River Prior to
April 16, 1970
                                      3RAS3Y

                                       ISLAND
    MICHIGAN
           WVANOOTTE CHEMICALS
           CORP. NORTH PLANT
      SCALE IN FEET
            IOOO  1000  IOOO
  WYANDOTTE
 WYANDOTTE CHEMICAL
 CORP. SOUTH PLANT
To Deep Well Disposal
After April 2(5, 1970
                                                   WYANDOTTE  CHEMICALS

                                                         WASTE  BEOS
                     ILE

-------
FIGURE  1A
                           LAKE HURON BASIN OFFICE

                                SKETCH OF
                         WYANDOTTE  CHEMICALS
                    TEMPORARY MERCURY TREATMENT
                              APRIL  16, 1970
                                 No  Scale
Wyondotte Chemicals
Composite Sampling Pt.-^
/ — Temporary Dam \
/ Cone. Lined Waste Flume 	 ^ \
fi=\ ft 	 ป. | |
f\Pump
TVi
Mercury ^""Temporory^Xl
Above Surface'
Cell Pipeline .
Building '.







tr '

c
c
5
w
•e
c
o
jc
u
o
o
M
O
0
i
_g
o
^-Conc. Lined ^
Limestone Storage g
Pit (Abandoned) *ซ
FWOA
Sample Pt.
/ W23
F Discharge
"X I3.5MGD


ki
k.
O
Uj
Q
i
ki *
^ ^
^
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15








            59

-------
                    FIGURE  2
                                                    LAKE  HURON  BASIN OFFICE

                                                         SKETCH OF
                                                  WYANDOTTE   CHEMICALS
                                             TEMPORARY  MERCURY TREATMENT

                                                       APRIL 20, 1970
                                                           No Scale
                       t
                      Effutnt Approximate
                      2 Ib./day  Hg
   6(
6'
From Mercury Cell
600 6PM
20lb/day Hg
               11
   Weak Cell
   Liquor Introduced 4?
   To Control pH
         Temporary
         Pipeline —i
                    \
      Add  NoHS
      H2 S04(Spซnt)-
                                  Setting Pond
                                   lฃ to 2 days

                               Mercuric  Sulfide
                                   Precipitates
                                                    \
                                    \\\\\\\ \\\
                                      Reaction  Pond
                                          6Hr
                                                         -Add Weak Cell  a
                                                          Liquor to bring v>
                                                          pH to Nuetrol
                                          60
U:
Uj
*x.
ft:

k
                                                                                IS
                                                                                i

-------
     APPENDIX II
   REPORT ON DETREX
CHEMICAL CORPORATION,
   ASHTABULA, OHIO
           61

-------
         PREKCMIMRY REPORT ON MERCURY INVESTIGATIONS AT

          DETREX CHEMICAL CORPORATION, ASHTABULA, OHIO



                         April 29, 1970
                       DETKEX PROCESS OPERATIONS



     Detrex employs the mercury cell in the production of caustic sodo
                                 ซ


(NaOIl) and chlorine.  In'this process "brine is decomposed in an elec-



trolysis cell vhich utilizes mercury as the cathode end graphite as the



enode.  Chlorine collects at the onode and is led with slight vacuum to



the outlet end (upper portion) of the cell.  Sodium immediately forms



en amalgam, with the mercury, the mercury "being placed in a thin -layer



at the "bottom of the cell.



     The "basic reactions involved are:



          2 NaCl -> 2 Ns+ + 2 Cl"

        -  2 Cl"  •+ C12   + 2e   (at graphite anode)



          2 Ka+ + 2e •* 2 Na (at mercury cathode)



     Through ฃ>n opening et the "bottom of the electrolysis cell, the sod-



ium amalgam is directed to a scrubber-like tower (decomposer) where de-



composition of the sodium amalgam takes place.  The amalgam is intro-



duced from above, through a series of graphite packings.  Water is intro-



duced from below and rises counter-current to the amalgam.  The amalgam



decomposition is affected "by the formation of" B large number of short



circuited cells in vhich the amalgam and graphite are electrodes and the



generated caustic solution is the electrolyte.  The reaction which takes



piece is:



                   2 Na (amalgam) + 2 HgO •ป• 2 NaOH + Eg




                                 62

-------
                                         63
        The mercury which is released from the amalgam collects at the "bottom of

        the decomposer vhere it is "withdrawn "by 8 mercury pump and returned to

        the electrolysis cell.   Hydrogen gas, along with traces of mercury vapor,
                                                                 •
        is drawn off through a  vent at the top of the decomposer end the caustic

        solution flows through  an exit on the Bide near the top, as shovm in the

        diagram.  Some trace mercury contaminated hydrogen is sold to Idnde

        Welding.  The remainder is vented to the atmosphere through steam.  Steam

        minimizes the possibility of fire and explosion,
                                                             '             -    \
*ECD ORiNE
                                                DECOMPOSEB
                                       fo PUMP .. .-.
                             CHLORINE
                                                       IHVOROGEM
EU
                                  PCNT
                                                            ^^J~^,,~

                                   •—=ฃ> tn==^=~=~~L~HS^S   |CAU8TI
                                   NE ^       ~~\{~ฃZ2S~. i5S=  JL .   '
                                   ;]CAU3YIC
                                                                 '••'.
            iil-L':..':.'* v"_SjCHEMATJC DIAGRAM Or^A MERCURY CELL"'
        from Blaw-Knox Company -
                   Olin tothieson Mercury Cell Process"
                   1963     Form No. 2723 3M

-------
                          •  MERCURY LOSSES




     According to Detrex at the time of the present investigation'(l)




there had been no change in recent weeks in the amount of mercury




lost in the Chlor-Alkali process, (2) the present loss rate is repre-




sentative of mercury losses since 1963,-and (3) mercury analyses of




the discharge effluent have, in the past, "been made approximately




once per month.




     Detrex mercury purchases for electrolysis cell make-up, according




to the plant manager, amount to 8-10 flasks per month.  One flask of



mercury is equivalent to 76 Ibs. of mercury (mercury is 13.5 times as




heavy es water).  Detrex claims that all the 7^0 l"bs.  of monthly make-up




mercury does not find its way to receiving waters - they claJm some of




it is pilfered "because of its high market value (Retail $23 per Ib.  -




Detrex $7 per Ib.).



     Since I>u3rch k, 1970 Detrex has been making frequent analyses for



mercury in its waste discharge, sampling at the mouth of a multiple




industry used waste water drainage ditch (station No.  U, attached map).



Beginning April 17, the Lake Erie Basin Office has sampled daily several




sites in the Detrex vicinity including station No. h,  a station (No.  2)



in the ditch just below Detrex containing only that company's discharges,



end a station (No. l) at the Detrex sump  effluent.  The sump effluent



is probably the source of most if not ell present mercury discharge.



Table 1 lists all the mercury analyses to date of samples from the



above three stations.

-------
                                  TABLE 1

         MERCURY ANALYSES OF ^TTREX EFFLUENT AND RECEIVING WATERS
Date
3-^-70
3-13-70
3-18-70
3-25-70
U-3-70
U-6-70
U-7-70
1^-8-70
)i O—fTl
tf-y*. (j
U-10-70
U-17-70
U-18-70
U-19-70
k-20-70
U-21-70
1+-22-70
U-23-70
U-2U-70
5-6-70
Sta. No. **
Ditch mouth
mg/1 Ibs/day**
0.0?
O.Qg
0.3'ป
.,•— ^
0^ f~W*-
.•r.y^
0.01*
0.00^'
<0.005
0.012
0.00?
0.013
0.005
0.007
0.006
0.002
3-9
A O
0' X
f-r, i
\j^^ * '

-------
                                   TABLE 1 (Cont'd)

         MSRCUKY ANALYSES OF DETRKX EFFLUEJIT AND RECEIVING WATERS
                "Sta.  No.  h               St'a. No". 2             Sta. No. 1
 Date          Ditch  mouth           Ditch below Detrex       Sump effluent
 	mg/1     Ibs/day*-*	mg/1    Ibs/day***      mg/1   Ibs/day***

 5/11/70     0.006       1.2     -                        .    0.029    '0.5
Underlined analyses by Detrex; all others by LEBO
*    Data obtained from Detrex on ll-17-^O; data reported  earlier
     by Detrex  did not "include ^-9-70 analyses and showed <0.01 mg/1
     for k-8-and  U-10-70.
**   Loadings based upon 23.3 ni?d ditch flo.f which includes  flow from
     Detrex, Linie ",'eldinjj, and lJr>c"? /iv.
*-x-x-  LoaCinrs bare..: upon 3.3^ r.^; i"-c:t :.:e'r--x c./Jy.
*-"-ซ-x- Loadings b,?.s?c upca 1.87 n^d. fros Debr^x  3U!np effluent only
       5f; of Drfcrex total flow)
                                  66

-------
                                    67


     Data collected by the Lake Erie Basin Office on April 10 and later

(Table I) Indicate that discharges to the lake have, in fact, been sig-

nificantly reduced.  Loadings which had previously ranged up to 66 Ibs/

day have been reduced to less than 2 Ibs. per day.  However, simultaneous

data from the ditch at station No. 2 and ai\the sump effluent (station

No. I) indicate that mercury still continues to be discharged by Detrex.

The data from station No. 2, which one would expect to show intermediate

values between those of the sump effluent and the ditch mouth, were in
                                                  ป •
most cases the highest.  The anomaly Is tentatively explained as being

the result of the sampling technique which most likely included some of

the "fluffy" sediment from the very shallow ditch waters.  The compara-

tively low concentrations and loadings in the ditch mouth waters Indicate

ihai much of the mercury has been oottlln^ out In the ditch between

Detrex and the lake.  Sediment analyses at station No. 2 (see Table 2)

show that the ditch sediments do contain significant amounts of mercury.

     All  mercury in water discharged frcr;. the^ ditch, according to th.3

Ohio Department of Health, Is attributable to Detrex since Linde Air

and Linde Welding do not use or store mercury on the premises.  Analyses

of Linde Air and Linde Welding effluents, as listed In Table 2, support

that assumption.

     Three plants discharge to the waste drainage ditch.  The names of

those plants and their average flows, according to the Ohio Department

of Health, are as follows:

                   Detrex          .   3.34 mgd

                   Linde Air         15.84  "

                   Linde Welding      4.14  "

                           Total     23.32  "

-------
                                 68
     On o yearly average, according to the Detrex plent manager, the

plant uses 2,750 gallons of water per minute or 3'9& mgd, somewhat

higher than the above listed figure.  As a result of in-process

changes to April 21, 1970, also according to the plant manager,-approx-
                                           *
imately kk% of the total Detrex flow or 1,200 gpm (l.73 mgd) has been

removed from the sump, since it is mercury free.

     Beginning April 8, 1970, Detrex'made a change in discharge practices

which it claims is responsible for the low effluent mercury concentra-

tions beginning April 8, 1970.  Prior to this time, ell Detrex waste

waters, including cooling waters, were discharged to the sump preceding

the ditch that flows to the lake.  The discharge change, claimed by

Detrex to have been motivated by economic considerations, involved the

removal of some cooling waters froni the sump by bypassing the cooling

waters through over-sump pipec directly to the ditch.   With remove1 of

the ceding voters from the zvur.p, tl'.o detention time of the remci/.ing
                                                  ป
waste discharged to the 'sump is increased.  As a result larger quantities,

of suspended mercury compounds become settleable and should be removed

in the sump.

                       STATE AND FEDERAL ACTIONS

     On April 10, 1970, after the Ohio Health Department had determined

that Detrex Chemical Corp. was a probable source of mercury discharge,

a visit was made to the plant by Robert Swain, Ohio Department of Health,

end Chris Potos, FWQA Lake Erie Basin Office.  They met with Robert

Baker, (plant manager), Robert Jones, John Kehm, and Dennis Ahistrom

of Detrex Corporation.  The purposes of this meeting were to learn

-------
                                  69
specifics of the Detrex operation end to determine  mercury loss  rates,

recent changes in the loss rates, end amounts  discharged to waters  of

the state.  At that time Detrex had already "begun changing its opera-

tions to divert "clean" vster from its mercury-containing vaste  flow.

     On April 13, 1970 the Ohio Water Pollution Control Board issued

a "cease and desist" order to the Detrex Corporation.   It contained no

time limit for compliance.  A copy of this order end the reply to it
                                                  ป •
ere attached.  The Detrex reply, dated April 17,  claimed no mercury

discharge to the waters of the state.

     On April 17, 1970 Chris Potos and A.  R. Winklhofer,  FWQA Lake  Erie

Basin Office, met at Detrex with Messrs. Robert Emmet,  Detrex Vice  Pres-

ident end Revert Baker, plant manager, end vith Mr.  Robert Swain of tl^

Ohio Department of Health to determine steps taken  by  Detrex to  elimin-

ate mercury discharges to waters of the State  es demanded in the State's

Cease and Desist order of April 13, 197C.

     According to the plant manager steps taken by  Detrex es of  April 17

vere as follows:

     1.  Floor washing stopped end ell mercury picked  up with vacuum
         cleener since April 16, 1970.

     2.  Cell cleaning discontinued April l6,  1970  end no cells  have
         been opened or cleaned since that time.

         Reference to 1. and 2. ebove—

              Detrex is installing e collecting tank and pump to collect
         floor water, cell spent brine, cell wash water, end return it
         to the brine system, at which time cell cleaning will be resumed.

     3.  Mercury treating has been stopped completely and indefinitely.

-------
                                70
     4.  The following indirect cooling water streams  are bypassing the
         sump:

              (l)  Hydrogen gas cooler - approximately 65 gpm
              (2)  Nash pump seal water cooler -  approximately 100 gpm
              (3)  Brine heat exchanger - .600 gpm

     5.  Detrex is filtering 50$ caustic coda for the  scrubber system
         (hypochlorite)
                          •

     Detrex is actively engaged in engineering the following  changes to:

     1.  Reroute the brine dechlorination condenser vater to  bypass the
         sump - approximately 500 gpm.
                                                  .ป •
     2.  Provide a sump or catch basin for hydrogen seal pot  water, nash
         pump seal water,  etc.,  which can then be returned to the de-
         composer feed water.                                          \

     3.  Provide tank, pump piping,  etc. to use filtered caustic for
         neutralizing waste sulfuric acid end chlorine  water.
              \
     k.  Construct a weir in the effluent ditch to measure quantity of
         flow; can be used also es *ป sample point.

     5.  Install caustic filter backwash tank.

     Detrex was urgently advised by Mr.  Potos on  April  IT:

     1.  to cease and desist mercury discharges to Lake Erie  immediately

     2.  that the ditch and the multiple industry-used-settling pond
         were not to serve as treatment devices for mercury removal.
         Detrex discharges were to be made  free of mercury prior to
         leaving Detrex property

     3.  to hire a consulting engineer to build a waste treatment system
         to permanently free Detrex discharge waters of mercury

     4.-  to keep FWQA and, ODH intimately informed through progress reports

     On April 21, 1970, Mr. Potos again visited Detrex along  with NFIC (FWOA)

representatives, Messrs. John Hyland and Laurence Muir, and the Ohio

Health Department's Earl Richards, James Shay,  and Robert Swain, to further

discuss the mercury problem and additional actions to  hasten  its abatement.

-------
                                  71
     On a yearly average,  according to the  plant manager,  Detrex uses




2,750 gallons of vater per minute,  vith maximum water use  occurring  in




summer.  Based, on in-process changes to April 21,  1970, approximately




kk percent of Detrex waste water (1,200 gel/min) has "been  determined




"by Detrex to be mercury free,  and as a result removed from the  sump.




It is a Detrex objective as of April 21 to  recycle waste streams that




contain mercury back, to the process in an enclosed system  if at all  poss-




ible.  Optimum process operations with least  possible mercury discharge




are expected by Detrex in two to three weeks.  If  the mercury-laden




streams are impossible to recycle,  according  to Detrex, the sump effluent




will be treated as soon as a practical and  economically feasible means



becomcc evailable.  According to Detrex,  the  best  brains in the chlor-elkali




industry are working on the problem in a crash-program effort.  If this




effort does not meet with success,  Detrex h&s agreed to our demand to




hire consulting chemists and engineers to solve the problem.  Presently



this route is not favored by chlor-alkali people since they feel they




know more about mercury (production, use, treatment) than  any practicing



consulting chemist or engineer.  The State  of Ohio is in complete agree-



ment with Detrex thinking in this respect.  Mr. Potos mentioned to them



that ion exchange and reverse osmosis are now on a practical state of




the art basis.



     In an attempt to minimize the effect of  expected seasonal  increases




in precipitation and consequent runoff on ditch sediment resuspension




and scouring, Potos suggested that Detrex dredge the ditch from the  sump




to the settling pond.  Detrex exceeded this request by volunteering  to




excavate a new ditch and complete fill in the old  (see map).

-------
                                 72
                                   •


     Daring the veekend (April 18 end 19) the settling pond was "being


given its spring dredging by Linde Welding end the Union Carbide Corp.


vhich owns the entire area and leases segments to various industries.


The pond dredging does not seem to have effected mercury concentrations

                                            *
at the ditch mouth approximately one mile distant, at least not through


April 20, 1970.  Dredgings from the pond are purportedly trucked-to


State-approved land fill areas according to the Ohio Department of


Health.                                           *


     The Lake Erie Basin Office has sampled stations 1,  2,  3,  k, 5, 7,  8,
                                                                        \

9, and 11 daily from April 17 through April 2b.  Station 11 is influent


to the plant.  Sampling will continue less frequently after April 2bf  1970.


     Table 2 lists other miscellaneous mercury sampling analyses in the


vicinity of Detrex.  At sampling station No. 9> east branch of the ditch,


nercury presence is likely the result of "beck up water from Detrex as


there ฑre no known discharges of ar." kini to this branch.


     The samples, both sediment end water, taken by the Lake Erie Basin


Office are analyzed colorimetrically by that office using Dithizone with


chloroform extraction.


     Along with the attached map is a table of Lake Erie Basin Office


analyses to date in the Detrex area, (Table 2).

-------
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-------
jA;.'..3s A. RHODES, Governor
     ~<.roe;o: u:' llcaltr.


   •;50 ^".r.s; 7o.v:. Street

   C.'/.u:.-.j>:s. Or..o 432lo
    PUBLIC UICALTi; COUNCIL"
     Ric.'.arci V. Brur.r.cr. 2.D.6.
                 Chc.i:::-.ar.
     J. Howard Holrr.o.s. :.;.B.
                 Vicu Chait-,
     Ralph K. Rarr,.src.vcr. M.D.
     j. F. r/.cr.r, P:-,.G.
     PhiJIip T. Kr.io;., M.D.
     Lloyd E. Larrick, M.D.
     J. Bruce Venter. D.V.M,
                                                                  April 13,  1970
           D at rex  CIner.icils  Industries,  Inc.
           Chiorine-Aliiali Plant
           P.O. Box 670
           AshwSbula, Ohio   UtoQlf

           Attention:  R. L. Baker, Plant Mgr.

           Gentlemen:

           You are hereby ordered to  cease and  desist tr.e  discharge of licuid
           industrial waste  con-gaining any aecurial compounds to vaters of the
           st-te.

           A:^' concentrations of mercury in the ^aw va'cer  used in your plant
           will be taken into consideration in  the compliance with the order.

           Please  advise this office  as to your compliance with the above
           order.

           Yours very truly,
           S. W.  Arnold, M.D.
           Director of Health
           C2R2IFI2D MAIL
                                                  75
Rr~
b.
                                                                            •<-
                                                                         APR 1 0 1970
                                                                      t riV 0^1 ^~
                                                                            PLAN

-------
           DETRSX CHEMICAL  INDUSTRIES, INC.
                                    ป
                          Chlorine - Alkali Plant
                               P. O. DDX 670
                           ASHTABULA. OHIO

                            April 17,  1970
•State or Ohio
 Department of Health
 450  East Town Street
 P.O. Box 118
 Columbus, Ohio    43216

 Attention:  Dr. E. W.  Arnold, Director of Health

 Dear Sir:

     We received, April 15,  1970, your order "to cease and desist the discharge
 of liquid industrial waste  containing any mercurial  compounds to waters of
 the  staff?,"

     We had -previously taken effluent water samples  at our discharge into
 Lake Erie on April 9th and  April  10, 1970.  Further  samples were taken on
 April 14th and again on April 16th.  In addition, lake bottom samples
 east, north and west of the discharge were taken on  April 15th.

     Using analysis methods approved by the State of Ohio, we have obtained
 negative mercury results on each  of the above samples.

     In accordance with the above analytical results, we state that the
 Detrex Chemical Industries, Inc.  Chlorine-Alkali Plant at Ashtabula, Ohio is
 not  discharging mercurial compounds to waters of the state.

                                      Very truly yours,

                                      DETREX CHEMICAL INDUSTRIES, INC.
                                      Robert L. Baker
                                      Plant Manager
 IxL3/nkv                             76

-------
        APPENDIX III

Inventory of Industries Using
  Mercury in the Lake Erie
               77

-------
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                               79
1.  Paper mills in Michigan were checked for the use of mercury.




    Two mills use mercury in surfacing compounds and lose about




    two pounds per year.







2.  Spot checks of other waste discharges from Chrysler Corp.,




    Monsanto, Penwalt Chemicals, Wyandotte Chemicals (other than




    outfall W23 at FM 13.3), and Consolidated Paper revealed no




    detectable mercury.

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           APPENDIX IV
FISH ANALYSED FOR MERCURY CONTENT
  BUREAU OF COMMERCIAL FISHERIES
     TECHNOLOGICAL LABORATORY
       ANN ARBOR, MICHIGAN
                86

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-------
               APPENDIX V
 STANDARDS FOR MERCURY AND HEAVY METALS




LAKE ST. CLAIR - LAKE ERIE DRAINAGE AREA
                   92

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              FEDERAL-STATE WATER QUALITY STANDARDS AND USPHS  ., /
          DRINKING WATER SPANIARDS FOR MERCURY AND JJFAVY MBTALS-'
                 •LAKE ERIE-LAKE ST. CLAIR DRAINAGE AREA

   The National Technical Advisory "Committee on Water Quality Criteria 'states;
   "Surface waters should be free of substances attributable to discharge or
   wastes as follows;   materials, including radionuclides, in concentrations
   or combinations which are toxic or which produce undesirable physiological
   responses in human,  fish and other animal life, and plants."

   Specific nurnberical criteria for toxic subst&nces have been included in
   water quality standards as follows:
   State          Metal

Indiana       Cadmium
              Chromium (hexavalent)
              Lead
              Silver
              All Toxic Materials

Michigan      Chromium
               (hexavalent)

New York    -  No Specific Criteria

Ohio          Cadmium
              Chromium
               (hexavalent)
              Lead
              Silver
              Iron (certain rivers
               on Ohio-Pa, border
               only)
              A31 Toxic Materials
Pennsylvania  Manganese
              Iron (Total )
              Iron (Dissolved)
   Criteria
Values in mg/1

    0.01
    0.05
    0.05
    0.05         2/
    0.1 96-hr TLnฃ'

    0.05
    0.01
    0.05

    0.05
    0.05
    1.5
    0.1 U8-hr TLm
    1.0
    1.5
    0.3
Use Classification
to Which Applied

  Water Supply
  Water Supply
  Water Supply
  Water Supply
  Fish & Wildlife

  Water Supply
  Water Supply
  Water Supply

  Water Supply
  Water Supply
  Water Supply
  Aquatic Life end
  Recreation

  All User,
  All Uses
  All Uses
I/   Heavy metals considered:  cadmium, chromium, copper, iron, lead,
     manganese, silver, and zinc.

2/   The TLm is the concentration of a tor.jr: matc^i^T vMch produces
     death to one-half of the test orcriri^.t:; in a Mo?.r;say test within
     a specified length of time  (e.g. ^8 hours or 96 houoc).
                                      93

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     APPENDIX VI




CHRONOLOGY OF EVENTS

-------
                       CHRONOLOGY OF EVENTS






March 24, 1970



      The Canadian Federal Department of Fish and Forestry banned the



sale and export of fish caught commercially within the Canadian bound-



aries of Lake St. Clair because concentrations of mercury in some of



the fish made them unfit for consumption.  The decision was made as a



result of a research report which showed pickerel caught In the lake



contained as much as seven parts per million mercury (ppm).  Subse-



quent laboratory reports indicated a somewhat lower figure of 1.36 ppm



which, however,  is still almost three times as great as 0.5 ppm level



considered acceptable for fish procured for export by federal food and



drug authorities in both Canada and the United States.  The Ontario



Water Resources Commission Identified one Dow Chemical of Canada



Limited chlor-alkall plant  at Sarnia, Ontario as the source of mercury



pollution to the St. Clair River.



      FWQA Regional Office leerned from Mr. Ralph Purdy, Executive



Secretary, Michigan Water Resources Commission, that he had written



letters to chlor-alkali plants in the state to find out who was using



mercury cells.   He reported that the Wyandofte Chemical Company on the



Detroit River  uses mercury cells and that he was conducting discussions



with them to  learn about the disposition of their mercury bearing wastes.



March 26. 1970



      Coordination achieved with Michigan agencies, Ontario Water



Resources Commission, Bureau of Comrrercin! Fisheries, and Food and




                               95

-------
                                 96



 Drug Administration.   FWQA' Lake Huron  Basin Office  Initiates  a water


 and sediment sampling program for the  St.  Clalr River,  Lake St. Clalr,


 Detroit River, and Western Shore of  Lake Erie.   Advised that  Field


 staffs of the Bureau  of Commercial Fisheries, Great Lakes Fisheries


 Laboratory, Ann Arbor, and the Department  of Natural  Resources, would


 be conducting a fish  sampling program  and  that  arrangements were  being


 made for the Wisconsin Alumni Research Foundation  (WARF), Madison,


 Wisconsin to analyze  the fish samples.  Learned that the Michigan


 Health Department and the Michigan Water Resources  Commission were


 getting samples from  water Intakes,  treatment plants and Industrial


 outfalls for analyses of mercury at the Lansing laboratory.


 March 27, 1970


        FWQA Lake Huron Basin Office begins collecting water and

     .  "'   :   ••            -. - ..         '•••••          '.-.-.
 sediment samples from the Wyandotte Chemical plant. '     '


 April  2, 1970


        Regional Director, GLR, chaired an. Informal  meeting at FWQA


 Headquarters, Washington, D. C., with  Bureau of Commercial Fisheries,


 Bureau of Sports F.Isheries and Wildlife, Food and  Drug Administration,


 and Ontario and Canadian Federal representatives.   The meeting was


 called to obtain a better understanding of the  mercury problem and


'to exchange information.  It was the consensus  of  the representatives


 present that the mercury problem is serious and of  international  con-


 -cern.  It was also agreed that an inventory of  mercury uses to


 determine waste concentration was needed and that  sampling should

 continue In order that the problem may be  completely defined.

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                     •      \     97

 J\pr11 8, 1970
  •' '*' ""' ' ' '  -L.T.i.—r--w-if-m. T           ,^4                   ,            ^

         .Governor Ml I liken of Michigan advises sportsmen not to eat


  fish caught from Lake St.. Clatr and the Detroit and St. Clalr Rivers.


I April 10 j 1970                    . '                  /
/                          •                      .       '       .
I         A meeting of Ontario, Michigan, and Ohio representatives was

  held In Toronto, Ontario to share Information and explain how deci-

  sions were reached for Ontario to place a ban on fishing In Lake

  St. Clalr, St. Clalr River, and Detroit River.  Federal people from


  Canada and'the United States were Invited as observers.  Mr. O'Leary

  of the Lake Huron Basin Office, represented the FWQA Great Lakes

  Region at the meeting.

         Rperesentatlves of all agencies agreed that sampling and

  testing must continue In order that the problem may be completely


  defined.                           ••' '             "          .   •

         Mr. Kerr, Federal Energy and Resources Minister, described  .
            ""       •              .      •
  the action that has been taken to halt any further mercury discharge

  from the presently known source of pollution on the Canadian side of

  the boundary In this area, and Governor MtIf I ken stated that he had

  received an assurance today that  the  presently known source on the

  Michigan side had today  Instituted procedures to eliminate future

  mercury contamination of the water from Its  facility.

          It was agreed that  future  action will be taken  In a coordinated

   way so tnar all  involved agencies may take similar action.

         The representatives of  the States  of  Ohio and Michigan agree

   with those from Ontario  that a ban on fishing  In Lake  Erie  Is not

-------
                                  98  .

                                   •

      .                •

 Indicated at this time.  Their respective agencies agreed to
                                        '          •   •      •
                        * * *                  *

 exchange Information from their sampling and  testing programs.
              *                                       •             (

        Governor MI III ken announced the following actions and



 agreements:



        I.  Michigan will  Institute proceedings to close Lake St.  Clalr



 and the St. Clalr River to all fls&Ing as a precautionary measure
                                  *                     *               • '


 pending further study;       •                                     .'



        2.  Michigan, Ontario, Ohio FDA and the U. S. Federal  Water
              *      •               i   ' *                  '


 Quality Administration  agreed to cooperate In developing further



 Information on  the Detroit River and Lake Erie;



        3*  Participants In the meeting agreed to continue and



 accelerate efforts to eliminate mercury contamination  from all



 sources;



      ..4.  All  parties  agreed to consult with various  other



 authorities prior to taking actions  affecting waters of  the  Great



 Lakes;               •                                      ^



        5.  All  parties  agreed to participate, with  other author-



 ities,  In Investigating additional dangerous  substances  as to kinds,



 amounts and effects;


        6.  All  parties- agreed to recommend the convening of  a



 conference of the Governors and Prime Ministers of  the Great Lakes



 States  and Provinces;
                                                              j


        •7. .All  parties  agreed to urge all  respective federal  bodies



''to Initiate actions to  Investigate sources of mercury  contamination



 In alt  states and provinces.

-------
                                99 ..   -


        Ohio Department of Health determines Detrex Chemical  Company
                                        •      •    •
                        •ป                  • *

.of Ashtabula, Ohio a probable source of irsrcury contamination.


        FUQA Lake Erie Basin Office,  Cleveland Initiates a water


 sampling program In Lake  Erie and tributaries and participates


 in an Inspection of the Detrex Chemical Company plant.


        Uyandotte Chemical plant ceased mercury waste discharges to


 the Detroit River at .12:30 p-.m.  Mercury enriched waters are now


 being discharged In holding facilities for chemical  treatment.


 April 13, 1970


        Governor Rhodes of Ohio announced a ban on commercial fish-


 ing In Lake Erie.


        Ohio Water Pollution Control  Board Issued a "cease and


 desist" order to Detrex Chemicals Company.


        FWQA Lake Huron Basin Office  personnel met with Michigan


 State officials.  The MWRC agreed to supply one man to aid In the


 field work collecting sediment samples and to share duplicate


 samples for verification purposes.  MWRC to continue sampling


 effluents In the area.


 April 14, 1970


        FWQA Great Lakes  Region Basin Offices provided with a list


 of chlor-alkall plants and asked to  Investigate as sources of


 possible mercury pollution.


 April 16, 1970


        The Wyandotte Chemical Company  was  Issued a court order to


 cease discharges of mercury wastes  In  any  form or amount.  The plant


 ceased operation of the  mercury  cell room at 6:20 p.m.

-------
                              100

April 2L 1970

       Secretary of the Interior Walter J. HIckel  announced his

Department Is Initiating a massive campaign to clean up Lake Erie,

as a result of reports of lethal discharges of mercury Into the Lake

and Into the Detroit River which empties into Lake Erie.
                                           •            • ~^—
       In a series of steps, Secretary HIckel announced taking the

following action:                             •

       — An enforcement conference on Lake Erie will  be reconvened

In Detroit, followed by enforcement workshops In Toledo, Cleveland,

Loraln, Sandusky, and Ashtabula, Ohio; Erie, Pennsylvania;  and
                                          *
Lackawanna, New York.

       -7- The Secretary's special investigative task force has been

assigned to obtain firsthand "Up-to-date data on the entire water

pollution problem in the Lake Erie watershed.
              . '     — •                .                  '• ^•*ปVjปซ~—^-._ • -

       — Increased monitoring and research will be Initiated at the

Fish and Wildlife Service's Great Lakes Fishery Laboratory at
   *
Ann Arbor, Michigan, on the toxlcity of mercury and other metal com-

pounds and their effect on fish and other aquatic life.

       —The Federal Water Quality Administration has been directed

to Identify and prepare a list of all toxic substances now being

discharged in waters throughout the United States.

April 23, 1970-

       Assistant Secretary for Water Quality and Research, Carl Klein,

directed the Commissioner, FWQA, to take necessary Immediate action

to translate the Secretary of the Interior's announcements of April 21

-------
                            101
Info positive action.-  Ha also asked that  the Task. Force  assigned
    •.                   • *                  .        .      -


to obtain firsthand up-to-date data on the entire  water pollution
                                '  •     -           .  •
                 /


problem In Lake Erie and  coordinate with. Michigan, New  York., OMo



and Pennsylvania.                '                  -




April  29, 1970                         •    *



       Prime Minister John P. Roberts of Ontario called a conference



for June to discuss pollution problems In  Lake Erie.  The Prime Minister




Invited the Prims Minister of Quebec and the  Governors  of Illinois,



Indiana, Michigan, Minnesota, New  York, Ohio, Pennsylvania and



Wisconsin.                                '   -




April  30, 1970                .  ,



    -•  Governor Rockefeller of New York announced  that  the Department



of Agriculture and Markets began placing all  fish  caught  commercially



In Lake Erie under seizure to .protect consumers from mercury cont.amlna- .



tlon.   The Department of  Conservation advised sports fishermen against



eating fish taken from Lake Erie.   This action was taken  after analysis



of several New York fish  samples showed levels of  mercury In excess



of 0.5 ppm considered acceptable for sale  by  the Food and Drug Admin-



istration.  The Governor announced that the State  Health  Department



also had tested drinking water taken from  Lake Erie and that  It had



been found fully safe for human consumption.



       Staff members of the FWQA Great Lakes Region met with members



of the Secretary of the  Interior's Task Force to develop  plans for



action required to  implement the Secretary's announcement of April 21.



Recommendations for appropriate, field  Investigations and  research



projects were  developed  for Headquarters'  consideration.

-------
                                  102




 May  1,  1970




        The State  of  Ohio  rejected 11,300  Ibs.  of  fish  caught  in  Ohio




 waters  of Lake  Erie  because  of high levels of  mercury  (greater than




 0.5  PpmO  The  rejected fish were from  8  commercial catches of 5




 fisheries and were primarily white bass,  sheephead and catfish caught




 in the  western  basin and  the western end  of the easterly basin of




 Lake Erie.  The samples analyzed  consisted of  UOO fish and contained




 mercury ranging from 0.51 to 0.6U ppm.  The State of Ohio made the




 analysis.




 May  k,  1970




        Governor Warren  Knowles of Wisconsin issued a 30-day emergency




 order closing 35 miles  of the Wisconsin River for fishing due to mercury




 contamination.  The  Wisconsin Department  of Natural Resources issued




 a cease and desist order  to  Wyandotte Chemical Corporation of Port




 Edwards to halt the  discharge of  mercury  laden wastes  into the Wisconsin




 River .




        The Assistant Commissioner for Enforcement FWQA was requested




 by the  Commissioner, Erie County  Department of Health to conduct an




 extensive water and bottom sampling program for toxic materials




 and  substances  not only in the western basin but throughout Lake




 Erie.   The Commissioner also requested a re-evaluation of the
compliance schedule to determine whether any of the municipalities




and industries not in compliance are contributing toxic discharges.




May 5, 1970



       A representative from the Ohio Department of Health visited




Reactive Metals Inc., Metal Reduction Plant in Ashtabula , Ohio to

-------
                                 103


obtain Information pertaining to mercury discharges.  Samples from the

plant effluent and receiving tributary were collected for analyses.

May 6, 1970

       Representatives from the Ohio Department of Health, and FWQA,

Lake Erie Basin Office, either visited or contacted by telephone

the following industries to obtain information regarding mercury usage:

       Bailey Metal Co., Wlckliffe, Ohio

       General Electric Co., Cuyahoga Plant, Cleveland, Ohio

       General Electric Co., Large Lamp Engineering and Pilot Plant,
                                                    Cleveland, Ohio

       Standard Oil Co. of Ohio, Cleveland, Ohio

       The FWQA, Lake Erie Basin Office collected sediments samples

from the Buffalo River for mercury analyses.

       An effluent sample from the Cleveland Easterly Sewage Treatment

Plant was obtained for mercury analysis by Lake Erie Basin Office.

May 1, 1970

       Representatives from the Ohio Department of Health, and the FWQA.

Lake Erie Basin Office visited the following industries to obtain in-

formation pertaining to mercury usage:

       National Aeronautics & Space Administration, Lewis Research Center,
                                                     Cleveland, Ohio

       Lincoln Electric Co., Cleveland, Ohio

       General Electric Co., Powder & Wire Plant, Euclid, Ohio

       General Electric Chemical Products Plant, Cleveland, Ohio

May 8, 1970

       Regional Director, FWQA Great Lakes Region presented testimony

-------
on mercury contamination in the Great Lakes to the Subcommittee on



Energy, Natural Resources and Environment of the Senate Commerce




Committee at Mount Clemens, Michigan.



       Secretary of the Interior announced that the fifth  session of



the Lake Erie Enforcement Conference would be held on June 3, 1970 at



Cobo Hall in Detroit, Michigan.




       Representatives from the Ohio Department of Health and the FWQA



Lake Erie Basin Office either visited or contacted by telephone the



following industries to obtain information pertaining to mercury usage:




       Union Carbide Corp., Electronic Components Div., Cleveland, Ohio



       Union Carbide Corp., Carbon Products Plant, Cleveland, Ohio



       Union Carbide Corp., Edgewater Works, Cleveland, Ohio



       I. Miller Inc., Cleveland, Ohio



       Merian Instrument Co., Cleveland, Ohio




       Schuemann-Jones Co., Cleveland, Ohio



       B. F. Goodrich, Avon Lake, Ohio



       E. I. DuPont de Nemours Co., Cleveland, Ohio






       Representatives from the New York State Health Department and



FWQA, Lake Erie Basin Office visited the Allied Chemical Co., Buffalo,



New York Dye Division, to obtain information on mercury usage.  The



New York State Health Department requested the Allied Chemical Co. to



minimize the discharge of mercury and to report immediately of their




steps for compliance.




May 9, 19TO




       Allied Chemical Corporation of Syracuse, New York diverted their

-------
                                  105





mercury bearing wastes to their settling ponds.  Previously wastes were




discharged to  streams flowing into Onadaga Lake.  The settling ponds




being used for mercury wastes may still, however, overflow into  streams



flowing into Onadaga Lake.




May 11, 1970



       A representative from the  Ohio Department of  Health contacted by



telephone the  following industries to obtain information pertaining to



mercury usage:



       Harshaw Chemical Co., Cleveland, Ohio



       Bellows Electric Co., Akron, Ohio



       Effluent samples from Detrex Chemical Co., Euclid Sewage Treatment



Plant, and Cleveland Westerly and Southerly Sewage Treatment Plant were



obtained for mercury analyses by FWQA. Lake Erie Basin Office.




       The Director, Lake Erie Basin Office notified the Regional



Director, Great Lakes Region, that the Allied Chemical Co.,  Buffalo,



New York is a  source of mercury in the Lake Erie Basin.  He recommended



that New York  State Health Department issue a desist order.



       Wayne C. Bellaman, Regional Sanitary Engineer for the Pennsylvania



Department of Health, announced the following:



              1.  Declared that concentrations of mercury in the waters



of Lake Erie used for municipal and industrial water supply by the



City of Eire are within the limits safe for domestic and industrial



use and consumption.  No concentrations of mercury in excess of 0.005



mg/1 were found in samples of raw water collected from both of the




City water works.

-------
                                 106





               2.  Selected municipal and industrial waste discharges



were  sampled,  including the effluent from the City of Erie Sewage




Treatment Plant and the Hammermill Paper Co.  No concentrations  of




mercury have been confirmed in these discharges in excess of those




from  the waters withdrawn by the City of Erie and the Hammermill Paper



Co. from Lake  Erie.




               3.  The Erie County Health Department has been assisting



in this investigation by checking hospitals and industries connected




to the Erie sewer system.  No potential major sources of mercury are




known to exist within the Erie portion of the Lake Erie Basin.



              k.  Assured that if mercury is found in any of the waste



discharges in excess of 0.005 mg/1, enforcement action will be initiated



immediately to require immediate and complete abatement.



              5.  No mercury has been found in the tissue of fish




collected from Lake Erie in excess of 0.5 mg/1 limit set by the



Federal Pure Food & Drug Administration and the World Health Organization.




May 13, 19TO



       Ontario and Michigan officials met in Toronto to reconsider the



fishing ban and arrive at an agreement for possible reopening of fish-



ing in Lake St. Clair, Detroit, and St. Clair Rivers.  It was agreed that



a catch and release restriction be imposed by both governments which will




make  possession of fish illegal.



       Effluent samples from the National Aeronautics & Space Admini-



stration,  Lewis Research Center, were obtained for mercury analysis




by FWQA., Lake Erie Basin Office.

-------
                            107





May lkt 1970




       Ontario Officials announced the reopening of sports fishing




in Canadian waters of Lake St. Glair and the St. Clair and Detroit




Rivers,  No catch and release restrictions were imposed; however,




warnings on the eating of fish were made.




May 15, 1970




       Governor Milliken of Michigan announced that a statement will




be issued next week on Michigan's decision to relax the sports fishing




ban on U. S. waters of Lake St. Clair and the St. Clair River.




       Officials of the New York State Conservation Department closed




all fishing in Onondago Lake at Syracuse because of mercury contami-




nation.  The State Conservation Department also recommended that




fish caught in Lake Ontario and the Oswego River not be eaten.




       The Wisconsin Department of Natural Resources held a public




hearing concerning Wyandotte Chemical Corporation of Port Edward's




discharge of mercury wastes to the Wisconsin River.




       Regional Director, New York State Health Department, Syracuse,




sent a telegram to Allied Chemical Corporation, Solvay, New York




asking the Corporation to present the Department of Health a defi-




nitive time schedule for complete elimination of mercury from their




liquid waste discharge.  Allied Chemical was asked to respond by




May 25, 1970.  Similar instructions were transmitted to Olin Mathie-




son Corporation of Niagra Palls, New York.  The Olin Matnieson




Corporation was asked to meet with State Officials to discuss a




suitable time schedule.

-------
                                108






       Representative from the Ohio Department of Health and FWQA,



Lake Erie Basin Office visited the General Electric Company, Cleveland



Lamp Plant, to obtain information pertaining to mercury usage.





       A representative from FWQA., Lake Erie Basin Office visited the



General Electric Company, Bucyrus Lamp Plant,to obtain information



pertaining to mercury usage.



       Effluent samples from General Electric Technical Products Plant




were obtained for mercury analyses by Lake Erie Basin Office.  The



Regional Director, Great Lakes Region, advised the Deputy Commissioner,



New York Department of Health, of findings pertaining to Allied



Chemical, Buffalo Dye Division, and requested to be kept abreast of



any enforcement action that may be pending.  The New York Depart-



ment of Health requested Allied Chemical Company to submit a  schedule



to aliminate mercury discharges.




May 18, 19TO



       Representatives from the FWQA, Lake Erie Basin Office, Ohio Dept.



of Health, and the NFIC, Cincinnati, met in Columbus, Ohio to exchange




mercury data.




May 19, 1970



       Representatives from FWQA, Lake Michigan Basin Office and Illi-



nois State Sanitary Water Board visited the Mansanto Company of



Sauget, Illinois to inspect plant operations and sample plant effluent



and sludge from the brine reaction tank.

-------
                                                      725



                        A. M. Shannon






          MR. STEIN:  All right.  Any comments or questions?




          (No response.)




          I didn't want to belabor the point,  but when they




talked about detectable limits, they talked about all below




5 ppb.  And you were 500 percent lower than that for your




detectable limit on 1 ppb.  That is a big spread.




          All right, thank you.




          Any comments?




          (No response.)




          Mr. Purdy, did you have someone else?




          MR. PURDY:  Dr. Shannon from the Detroit Water




Bureau would like to be heard.






               STATEMENT OF ALBERT M. SHANNON




           CHIEF, WATER AND WASTEWATER TREATMENT



               DETROIT METRO WATER DEPARTMENT






          DR. SHANNON:  Mr. Chairman, conferees, ladies




and gentlemen, my name is Albert M. Shannon, and I am chief




of Water and Wastewater Treatment for the Detroit Metro




Water Department.  I would like to make a brief statement




on the results of our monitoring program for mercury, both




at our two raw water intakes and on the incoming raw sewage




and the plant effluent at our sewage treatment plant.




          One of our intakes, the Waterworks Spartan plant,

-------
                                                      726



                        A. M. Shannon






is indicated on the upper end of Belle Island, the upper




Detroit River.  The southwest intake is located off the




northern tip of Fighting Island in Canadian waters.  And




that is in the lower Detroit River.




          To date we have determined the mercury in 36 daily




24-hour composite samples, also 12 weekly composite samples,




making a total of 48 samples.  And to date, we found no




measurable quantities of mercury.  And the limit of our




accuracy sensitivity is 2 parts per billion.




          Now, since May 11, we have run daily 24-hour




composite samples of raw sewage and also the plant effluent.




And that is 25 samples of raw sewage and 25 samples of plant




effluent.  And none of these samples showed the presence of




detectable quantities of mercury.  And, again, here the




limit is 2 parts per billion.




          That's all.  Thank you.



          MR. STEIN:  Two parts what?



          DR. SHANNON:  Two parts per billion.




          MR. STEIN:  O.K. Thanks.




          Did you ever find mercury in your drinking water




here?




          DR. SHANNON:  No, none at all.




          MR. STEIN:  But again, you see what we have had




here.  We are up with the third figure — 5, 2 and 1.  And

-------
                                                        727




                        A.  M.  Shannon






I think my suggestion is that  we try to get together on this




if we haven't gotten together  yet.   And I ask Mr.  Van Den




Berg to do this because we  are getting out the report.




          We should make a  proposal for what we think is




the detectable limit that we are going to go down  to, and




if you don't find you have  a consensus on that, you better




get together with the other people  who are doing these




tests and come up with something that you can agree on.




Because unless you have this,  we are never going to get the




program off the ground.




          1 say this, not only for  mercury, but we are going




to have to do this for every toxic  substance if we are going




to deal with it.




          MR. LYON:  I think if we  are going to do this, Mr.




Chairman, we should not, I  suspect, be only concerned with




the detectable limit, but also the  range of accuracy of the




test of the detectable limit.




          MR. STEIN:  I think that  is one of the big factors.




I think the ability of everyone to  do the test and the




accuracy of the test are two of the factors which  go into




what we universally say is  the detectable limit.




          MR. LYON:  Because we found with our fish, there




was a 3-to-l relationship between two laboratories of the




FDA — one in Cincinnati, one in Chicago.  So it isn't merely

-------
                                                      728




                         R. W. Purdy





a question of detectable limit, but also a question of the



accuracy of the test.




          MR. STEIN:  These are the issues.



          By the way, don't think this is anything special



because we have had this over and over again in every other



substance—every other thing we have dealt with in this



field.  Not only have we had it, Pood and Drug has it, and



everyone else has got the same problem.  But, gentlemen,




this just has to be worked out if we are going to move.



          Are there any other questions or problems?



          (No response.)



          If not, thank you very much, sir.



          MR. PURDY:  Mr. Stein, I have passed out a state-



ment to all the conferees and to the stenographer, that I



would like to have placed in the record as if read.  It



covers the mercury contamination problem here in Michigan



and the action that we have taken on it.  There are cer-



tain parts,in view of Mr. Atwood's statement yesterday^that



I would have liked to have gone over in detail.  But because



of the lateness of the hour, I think I will pass it up.  But



I do not agree that State and Federal officials knew about



it and didn't take action on it.



          This was a matter of where the mercury problem



was not recognized.  As soon as it was recognized, action

-------
                                                        729




                         R.  W.  Purdy






was taken on it.  Mr. Atwood didn't say it as a part of




this report, but I noted it in the paper.   It stated the




State agencies failed to take action until the newspapers




forced them to do so.




          Again, I do not agree this is the case.  And my




statement will show that it was not,




          MR. STEIN:  Without objection, that will be




entered into the record as if read.




          (The above-mentioned statement follows in its




entirety.)

-------
                                                                           730
                    STATEMENT OF R. W. PURDY, EXECUTIVE SECRETARY
                         MICHIGAN WATER RESOURCES COMMISSION

                       Regarding Mercury Contamination Problem

                                   June 3, 1970


 I am pleased to have this opportunity to discuss the problems of environmental contami-
 nation by mercury compounds.  We are very concerned over this matter and the State of
 Michigan has placed high priority on fully investigating and dealing with the problems
 of mercury contamination.

 The recent mercury contamination problem in the Lake St. Clair - Detroit River area came
 as a near total surprise, without warning or anticipation.  It seems that nobody recog-
 nized the problem of mercury contamination in the United States prior to the emergence
 of certain problems within the last year.  In view of the limited, although catastrophic
 world experience with the problem, the lack of knowledge and apprehension over mercury
 throughout the United States at both State and Federal levels is a complete paradox.

 In spite of the history of mercury contamination, the problem was largely unrecognized
 in this country.  The pollution problems of the St. Clair River, Lake St. Clair, the
 Detroit River and Lake Erie have been thoroughly studied and extensively documented.
 In April of 1965, the U.S. Public Health Service of the Department of Health, Education
 and Welfare, now the Federal Water Quality Administration, with the cooperation of the
 Michigan Water Resources Commission, completed an exhaustive report on the pollution of
 the Detroit River, Michigan waters of Lake Erie, and their tributaries.  There was no
 mention of mercury problems in that report.

 The State of Michigan is also actively participating in the Lake Erie Federal-State
 Enforcement Conference and in the pollution studies of the International Joint Commission.
 The possibility of widespread mercury contamination has never been considered in these
 studies until the last two months.

 We have on many occasions collected and analyzed samples of the wastewater effluent from
 the Wyandotte Chemical  Plant which was until  recently discharging mercury compounds in
 its wastewater.  This testing was undertaken in the development of an appropriate water
 pollution control program for this plant.  The mercury levels of this discharge were
 never considered since the need was unknown.

 In April, 1968, the report of the National  Technical Advisory Committee on Water Quality
was published by the Federal Water Pollution Control Administration.  This document was
considered the most comprehensive document on water quality requirements at that time.
 It was the work of 5 subcommittees involving some 90 experts in the field of water pol-
 lution.  There was only a very brief mention of mercury and there was no indication of
 its possible significance.

 In this discussion, my point is not to justify our own lack of knowledge about mercury
contamination of the environment but rather to emphasize a gap, a rather serious gap,
 in our present environmental protection programs.  The current mercury crisis developed
almost overnight without warning; however,  the contamination has apparently existed for
 some time.  I strongly believe that we must take appropriate steps to ensure that any
similar problem is recognized and countered in the early stages before serious damage
 results.

-------
                                                                             731
We first became aware of the possibility of mercury contamination  in  the  Great Lakes  at .
a meeting on February 11, 1970 in Toronto,  Canada  of the  International  Joint Commission's
Advisory Board on Control of Pollution of Boundary Waters.   At that meeting, Canadian
officials indicated their concern over the  possibility of mercury  contamination and  re-
ported that studies were underway.

The following day, we began to investigate  possible sources  of mercury.   Of  the three
chlor-alkali plants in Michigan, we found one which used  mercury in its process.   This
was the Wyandotte Chemical Company plant on the Detroit River.  Subsequent investiga-
tions revealed that this plant was discharging with its wastewater 10 to  20  pounds of
mercury per day.  At the time of initial contact with the Wyandotte Chemical Company,
the full impact of the mercury problem was  not yet known.  Company officials were cautior
about the possible pollution problem and were asked to ascertain the  exact amount of
mercury being consumed and lost.  The Company was  also advised to  begin an immediate
study of ways to abate the discharge of mercury.

Later in March, laboratory analyses of fish from Lake St. Clair area  waters  conducted by
a California laboratory were received by Canadian  officials  and because of high levels
of mercury residues, 12,000 pounds of fish  caught  in Lake St.  Clair were  seized by
Canadian officials.  Two weeks afterwards,  Ontario banned all  fishing on  the St.
Clair River, Lake St. Clair, and the Detroit River.

A series of steps were instituted to evaluate the  level of  mercury in the environment
and to pin-point possible sources in the Lake St.  Clair-Detroit River area and in the
rest of the state as well.

Fish samples were collected by the Department of Natural  Resources from Lake St.  Clair
for analysis by the Detroit Office of the Food and Drug Administration.   Later, fish
from throughout the state were collected for testing by the Food and  Drug Administration
and the Michigan Department of Agriculture.  We endeavored  to  enlist  the  cooperation of
all laboratories in the area as quickly as  possible.  We  found that only  the Food and
Drug Administration could readily undertake mercury analysis.   Arrangements  were subse-
quently worked out for the analysis of various samples with  the Federal Water Quality
Administration's Grosse He (Michigan) laboratory, the Wisconsin Alumni Research Founda-
tion's laboratory which was under contract with the Bureau  of  Commercial  Fisheries,
the Phoenix and School of Public Health laboratories of the University of Michigan,  and
the Dow Chemical Company at Midland which offered  its assistance.

Arrangements were also made to cooperate with the  Ontario Water Resources Commission and
with the Ohio Department of Agriculture.

In succeeding days, the following additional steps were taken  to further  define the  mag-
nitude and scope of possible mercury contamination throughout  the  state:

     a.  The Michigan Department of Public Health  undertook to immediately test
         all public water systems using the St. Clair River, Lake  St. Clair, or
         the Detroit River as a water supply source.  A sampling program  of domes-
         tic water supplies in this area continues on a weekly basis  and  will re-
         main in effect as long as considered necessary.

-------
                                                                              732
     b.  To identify other uses of mercury or mercury compounds, all 35 pulp and
         paper mills in Michigan were contacted by telephone.  In addition, letters
         were sent to some 700 industries, commercial establishments and individuals
         requesting information on the use of mercury and also on the use of arsenic,
         cadmium, lead or any other heavy metal.  Response to this request has been
         good and information continues to be received.

     c.  Arrangements were made for the analysis of wastewater samples from some
         three dozen municipal sewage treatment plants throughout the state which
         treat industrial waste and might therefore contain mercury in their dis-
         charges.

     d.  Bottom sediment samples were collected at the mouths of major rivers
         entering the Great Lakes and also below municipal and industrial waste
         treatment plant outlets.  Fish samples were collected at these same
         locations.

     e.  The Department of Public Health undertook to examine persons in the Lake
         St. Clair area who were heavy fish consumers to ascertain if there were
         any adverse effects from the mercury contamination.

Only two significant discharges of mercury compounds were located in the State of
Michigan.  The Wyandotte Chemical Plant on the Detroit River and a General Electric
Company plant located at Edmore, Michigan which discharged its waste to a tributary
of the Pine River.  Wyandotte Chemical proceeded to install a temporary treatment
facility which cut its mercury discharge by 80 to 90 percent to less than 2 pounds
per day.  This reduced discharge was subsequently found unacceptable and a temporary
injunction was obtained by the Michigan Attorney General prohibiting any further
mercury discharges.  Wyandotte Chemical then shut down its mercury cell chlor-alkali
operations.

Wyandotte Chemical has since formulated a plan which has been accepted by the Water
Resources Commission and entered in a circuit court consent order whereby all process
wastewater containing mercury will be recycled to a cavity located 1200 feet underground
from which the company obtains its salt supply.  The Company will treat the wastewater
to remove the maximum amount of mercury before recycling and is further required to
have permanent above ground control facilities in operation in one year.  The above
ground recycling system is expected to cost about $1.5 million and when installed will
be the most sophisticated mercury control facility known to exist in the world.

The Edmore plant of the General Electric Company was notified that all discharges con-
taining mercury must be ceased immediately or the Attorney General would be requested
to take appropriate legal action.  The Company proceeded to promptly halt all mercury
discharges.

On April 11, Governor Milliken together with appropriate state officials conferred in
Toronto, Canada with representatives of the Canadian Federal Government, the Province
of Ontario, U.S. Federal agencies, and the State of Ohio.  A key objective of the
meeting was to review the information collected by the Canadians and obtain their
assessment of the situation.  A seven point joint program was agreed upon, including
the closing by Michigan of Lake St. Clair and the St. Clair River to all fishing.

-------
                                                                            733
Later, Michigan indefinitely postponed the opening  of  the  commercial fishing walleye
season in Lake Erie and initiated a program to screen  all  commercial fish  catches  in
Lake Erie for actionable levels of mercury.

As the situation presently stands, the Lake Erie commercial walleye season remains closed
We have been informed that virtually all  commercial  fishing in  the Michigan waters of
Lake Erie has stopped.  Sportfishing is permitted in Lake  Erie  however  the possession
of walleye, white bass or sheepshead is prohibited.  The same regulations  have also been
applied to sportfishing in Southern Lake Huron principally because of the  migratory
habits of walleye.

In Lake St. Clair, the St. Clair River and the Detroit River, sportfishing is permitted
on a catch and release basis only.  Possession of any  fish from these waters is  illegal.
The Ontario ban on all fishing in the St.  Clair River, Lake St.  Clair and  the Detroit
River has been discontinued.

We do not know if the mercury content of fish in Lake  St.  Clair is increasing or de-
creasing.  In order to attempt to make such a determination, a  special  sampling  program
will be initiated to monitor particular species of fish from Lake St. Clair.  It is
planned to collect a statistically significant sample  in July and again in the fall for
purposes of comparison.

In investigating possible sources of mercury, we learned that mercury and  mercury
compounds are used in numerous and diverse everyday operations  such as:

     --in diaper laundries;
     —in marine and acrylic based paints;
     —in the manufacture of acetylene, polyvinylchlorides, chlorine and caustic soda;
     --in seed, lawn and pulpwood fungicides;
     --in hospitals;
     --in mercury seals in trickling filter sewage  treatment plants;
     --in mercury batteries;
     --and in paper making plants.

Possible sources of mercury, although generally small  ones, are present throughout our
society.  It is clear, therefore, that mercury sampling must become an  integral  part of
regular water quality and environmental monitoring.

As a result of the extensive amount of mercury sampling that has been completed, we now
have a good estimate of the magnitude of mercury in the water environment. No measur-
able mercury was found in any water supply system obtaining its  water from the St. Clair
River, Lake St. Clair, Detroit River, or Lake Erie.  Sampling analysis  of  (a) certain
industrial wastewaters, (b) sewage in communities where industries discharge wastes to
municipal sewer systems, and (c) river bottom sediments at the  mouths of major rivers
entering the Great Lakes and at locations  below municipal  and industrial discharges
indicated no mercury or only trace amounts.   This confirms our  earlier  belief that only
Wyandotte Chemical Corporation at Wyandotte and General Electric Company at Edmore were
the only sizeable dischargers of mercury or mercury compounds in the state.

-------
                                                                            734
 The Federal  Water Quality Administration  has  completed extensive tests of
"bottom sediment samples  from Lake  St.  Clair,  the  Detroit  River, and  Lake Erie.  Their
 results show no significant amounts  of mercury  in the sediments of the Michigan portion
 of Lake St.  Clair.  Mercury has  been found  in the sediments  of the Detroit River below
 the Wyandotte Chemical outfall and has been found in Lake Erie sediments in very low
 levels over  a wide area.

 In regard to these contaminated  sediments,  we do  not know the effective life of the
 mercury constituents.  One  source  has  suggested the effects  of the pollution may last
 for 10 to 100 years unless  the mercury is made  inactive either by its physical removal
 or by elimination of its biological  availability.

 We are evaluating the  feasibility  of removing contaminated sediments through dredging.
 It has been  estimated  that  to dredge a strip  150  feet wide,  3 feet deep and 1 mile long
 of the Detroit River would  cost  approximately one-half million dollars.  The cost of
 dredging Lake Erie, due  to  the large area involved, would be enormously expensive.
 Dredging, moreover, could conceivably  cause significant environmental damage includ-
 the Possible additional  releases of  mercury compounds to  the aquatic environment.
 No conclusion has been reached as  yet  on  the  possibility  of  any dredging.  Efforts
 are also underway to determine whether there  is any possible way to  chemically
 neutralize or bind the mercury in  bottom  sediments within the affected area.  Results
 to date do not indicate  any practical  method  of chemical  treatment of the contaminated
 bottom sediments.

 As I  have stated previously, the contamination  of the environment by mercury compounds
 represents a serious fault  in our  present environmental protection programs.  Looking
 back  at the  serious incidents which  occurred  in Japan and Sweden, our lack of knowledge
 about the use, disposal, effects and other  characteristics of mercury compounds now
 appears incredible.  It  is  clear however, that  we must institute adequate methods of
 safeguarding the environment from  any  future  catastrophies.  I see four areas which are
 in need of urgent action:

      1.  A broadened environmental sampling and monitoring program to
          identify all  possible environmental  contaminants;

      2.  Better information on the use and  disposal of the thousands of
          products, raw materials,  catalysts,  by-products  and waste products
          involved in industrial  production;

      3.  Increased efforts  to investigate the environmental  effects  of the
          many industrial chemicals and other  substances presently in use
          and a systematic program  to evaluate all  new products before they
          are marketed;

      4.  A national clearing house to  coordinate  all of the  above activities
          and to help alert  pollution control  officials regarding emerging and
          potential  problem  situations.

 On our part, Michigan  has taken  new  initiatives to increase  our efforts to safeguard the
 environment.  Governor Mi 11iken  has  introduced  legislation to:

-------
                                                                            735
     1.  Require the registration of all  manufactured products,  processes,
         production materials, by-products and waste products  by all  indust-
         ries and businesses within the state which discharge  industrial
         wastewater.

     2.  Impose a surveillance fee on all commercial and industrial  enterprises
         which use the waters of the state for waste disposal  purposes.   The
         revenue raised by this surveillance fee will be used  to augment  the
         state's pollution detection, surveillance, and control  capability.

The additional funds and information that will be made available through  these measures
will enable us to provide increased protection for the environment and for  our citizens.
We strongly urge that new national efforts also be undertaken  and we offer  our coopera-
tion and assistance in any way possible.

Thank you.

-------
                                                       736
          MR. STEIN:  Are there any other comments or




questions?




          (No response.)




          If not, I would like to thank you all for coming.




I think we had a very, very productive session.  As with all




the sessions, they do take some time.  I think we made a




lot of progress in evaluating where we are in the cleanup




on Lake Erie and the municipal and industrial sources,  I




think it is fair to say that while the purpose of these




conferences is to emphasize the slippage, the laggards and




the places that didn't come through, if you look at the




program as a whole, you will find that we are making very




substantial progress in moving towards the cleanup of Lake




Erie.  Municipalities and industries are putting in these




remedial facilities.




          We will be getting local information in the various




workshops we conduct the week after next.  I would suggest




when all that material is in, we will call the conferees




back, I hope for a very brief session, where we can come up




with conclusions and recommendations.




          We have all made certain commitments here that I




hope will be forthcoming.  One, and I think an important




one and one that should not be overlooked, is the precedent




we have established for the State and the Federal Water

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                                                        737
Quality Administration to get together on the recommendation




on dredging before any deposits containing mercury are even




disturbed.  I think that may serve to be a pattern for the




country where we have this.




          The second thing, if these dredgings are to be




disturbed, we are going to come up with a joint recommenda-




tion on where they are to be placed.




          I think we have a program here of either stopping




significant discharges of mercury into Lake Erie or taking




appropriate action.  I think all the significant sources




we know of have been named here.  We are going over those




and we should be on our way in a week.  Either they are




going to be stopped, or action is going to be taken by the




State or Federal authorities to stop them.  I think we have




taken quite a leg up on attempting to deal with the problems




inherent in controlling a toxic material such as mercury.




As far as I know, this is the first little baby step towards




a tremendous program in this whole area.




          I don't think it could have been done with a




better group of people than the people we have here in the




Lake Erie States.  I hope we are going to be able to develop




something that is going to show the way for the Nation to




get at the mercury problem and the whole question of disposal




of toxic substances.

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                                                       738
          For those of you who have stayed with us,  you may




just barely be able to see the complexity of the problem we




have to deal with.  But we are going to move forward and




meet it, I am sure.




          Are there any other comments or questions?




           MR. PURDY:  Mr. Stein, on your suggestion of a




meeting following the workshops and following this conference




here, I have in mind what took place at the so-called execu-




tive session of the Lake Michigan Enforcement Conference.  I




think we need to have citizen participation.  And it seems




to me that the meeting today and the workshop gives the




opportunity for citizen participation.  And unless we are




just going to talk something to death, we need that oppor-




tunity of gathering in an executive session so that the con-




ferees can reach recommendations and conclusions and put




something on the road here.




          And I have no objection to the open executive




sessions if we can draw up an agenda, limit the discussion




to the conferees, and move forward on recommendations and




conclusions.  If it is impossible to do this in an open




executive session, I would request that we make it at least




a semi-closed executive session so that we do more than




just talk.




          MR. STEIN:  Right.  I agree with that suggestion.

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                                                      739
          Let me tell you, we have opened up these proceed-



ings, as you know, in the past.  We have no secrets.  And



we have always tried to have our proceedings public, includ-



ing our executive sessions.  But if people are going to



think that part of the social revolution requires them to



come in and be heard at every meeting or disrupt the meeting



if they are not going to be heard, then we are just going to



have to resort to going into a room where we are just going



to allow the conferees and their immediate staff and




exclude the public.



          Again, I talked about being stupid and abusing



the privilege.  If that is what people want to do, they are



welcome to do it.



          I think in the Chicago situation, we were faced



with the extraordinary situation where people came in and



demanded to be heard.  And at least my judgment was that



they felt it was their public duty and they were making a



contribution to the good of mankind if they could get their



heads opened, particularly if there was a TV camera around.



We had about 18 TV cameras.



          In addition to that, we had some officials who I



think felt it was their public duty to have an opportunity



to open some heads.  So all the ducks were on the pond.  And




I think you have a very difficult situation in those cases.

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                                                       740
          Now, I deplore this, and I think if we are going




to be faced with this, Mr. Purdy,  there is going to be no




alternative but to get a small room, go in and lock the door




and go on with our business.   I would like you to come in and




see what we do.  But unless the public is mature enough to




recognize that it has been given a full opportunity to talk,




we are going to have a different type of executive session




from now on.  The people's privilege is there to see us go




through this, but when the time comes for an executive session,




we have to make a decision.




          MR. PURDY:  I am not criticizing your handling




of that meeting,  I just think there is not that much time




available.




          MR. STEIN:  That's right.  That is right.  I




couldn't agree with you more.




          Are we all set?




          MR. POOLE:  I commended him privately for his




handling of the Chicago meeting.  So I can't criticize him.




He had no alternative.




          MR. STEIN:  Are there any other questions or comments?




          (No response.)




          If not, thank you very much.  And we stand adjourned.




          (Whereupon, at 4:32 o'clock p.m., the hearing




adjourned.)

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                       CITY  OF   EUCLID
                       ENGINEERING DEPARTMENT
                           585 EAST 222nd STREET
                            EUCLID, OHIO 44123
                                (216) 731-6000
 HABRY J. KNUTH
                                                            STANLEY L CESEN
     Mayor                                                      City Engineer


TONY J. SUSTARSIC
Administrative Director                June 29 ,  1970
          Department of Interior
          Federal Water Quality Administration
          Washington, D. C.  202^2

          Attention:  Mr. Murray Stein
                      Chief  of Enforcement

          Dear Sir:

                At the April 15th meeting of the Ohio Water Pollution
          Board, the City of Euclid made a presentation outlining
          the status of its  pollution abatement program.  A copy of
          this statement is  enclosed.

                We feel that you should have a copy of this statement
          so that you will know that Euclid is progressing to  the
          utmost of its ability in the pollution abatement program.
                                           Very^-truly yours,
                                           Stanley
                                           City Engineer
           LC:mb
is:
          cc:   Mr. George Harlow, Director
                Lake Erie Basin Office
                Mayor Harry J.  Knuth
                Administrative  Director T.  J.  Sustarsic

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STATEMENT TO THE WATER POLLUTION CONTROL BOARD MEETING, APRIL 15, 1970

Mr. Chairman, Members of the Board, interested citizens:

      The City of Euclid regrets that it was unable to comply with the original
timetable for proposed improvements and additions to its wastewater treatment
plant. Problems associated with the site of the existing treatment plant de-
layed the submission of the engineering report and subsequent council action.
The Board was apprised as to the nature of these delays when the new target
dates were set.

      At the present time, Euclid is operating under a Water Pollution Control
Board Permit which expires October 15, 19?0 and complying with the conditions
thereof as follows:

  1.  A pilot plant study is under way to determine the processes which can
      best be used at the present treatment plant site for secondary treatment
      and phosphate removal.

  2.  Upon receipt of the engineer's report of the findings of the pilot plant
      study and recommendations derived therefrom, and with the concurrence
      of the State Department of Health, the City will authorize the preparation
      of detail plans and specifications for the improvements to the treatment
      facilities.

  3.  Detail plans and specifications for sludge disposal facilities are in
      the process of preparation.

  ^.  Our present treatment plant facilities are being operated satisfactorily
      by licensed operators, a fact which was confirmed by a recent inspection
      by the Health Department. Monthly and annual operating reports are being
      submitted to the Health Department.

  5.  The program for reducing the amount of storm water in the sanitary sewers
      is being carried out vigorously. In several areas, new sewers and
      connections have been built, are under construction or are being designed
      which will result in the elimination of storm water from the sanitary
      sewer system.

  6.  The City is continuing its monitoring of industries discharging wastewater
      to the Euclid sanitary sewers and drains. A City permit system is used.
      Industries which perform pretreatment submit monthly operating reports
      to the City.  These reports are reviewed by the City's wastewater chemist.
      Frequent visits are made to plants and samples from the sewer system are
      collected and tested periodically.

      The City of Euclid expects to have construction of its wastewater treat-
ment plant improvements completed by December 1, 1972.

                                      Respectfully submitted
                                      The City of Euclid
      * U. S. GOVERNMENT PRINTING OFFICE : 1970 O - 407-609 (Vol. II)

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