-------
                                                                              420
                                     TABLE   5
                            LOW FLOW CHARACTERISTICS
                                       FOR
                            GRAND-CHARITON RIVER BASIN
                                Interstate Streams


GRAND
Grand River near Grant City
Grand River near Stanberry
Grand River near Darlington
Grand River near Pattonsburg
Grand River near Gallatin
Grand River at Chillicothe
Grand River near Sumner
Annual 7 day low flow, in cubic feet
per second, for indicated recurrence
interval in years.
2 5
RIVER
1.7
3.3
8.2
11
20
78
105







6


41
10 20 30

Vl
e
0-1
el-3
el-3
3.6

17

25







2.7


17







2.4


13
EAST FORK OF GRAND RIVER
East Fork Grand River at Albany
1.9

eo-i


THOMPSON RIVER
Thompson River near Mt. Moriah
Thompson River at Trenton
11
16


5.4
d
_J3,2
	 _
2.0
	
1.6
LITTLE RIVER
The U.S. Geological Survey has insufficient flow data for the Little Rive on which
to base a flow analysis.




































d-Insufficient data for estimate
e-Range in discharge estimated on basis of frequency curve slopes  at nearby
  continuous-record stations and extension of regression curves
f-Short-time continuous-record station which was analyzed as a partial-record
  station due to scant data

-------
                                                                              421
                                     TABLE 5_
                            LOW .FLOW CHARACTERISTICS
                                       FOR
                     GRAND-CHARITON RIVER/BASIN (continued)
                               Interstate Streams


WELDON
Weldon River near Mercer
Weldon River at Mill Grove
Weldon River near Trenton
Annual 7 day low flow, in cubic feet
per second, for indicated recurrence
interval in years.
2
c
RIVER
0.3
2.2
6.2

0
0.3


10 20 30

0
0
(d)
0
0


0
0


CHARITON RIVER
^hariton River at Novinger
^hariton River near Prairie Hill
















7.4
21
















2.1
9.5
















1.0

6.5

















0.5
5.0
















0.3
4.6
















b-Discontinued continuous-record station
d-Insufficient data for estimate

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                      E. Lightfoot






               MR.  LIGHTFOOT:   Thank you.




               MR.  STEIN:  Thank you.




               Let  me indicate what we may have on the




program for the rest of the day.




               By the way,  does anyone from Nebraska want




to speak or not?



               If not--




               MR.  SAMSON:   Mr. Chairman,  I have indicatec




that I didn't have  any remarks to make, and I am accom-




panied here by our  Executive Secretary, Mr. Filipi, who




I know loves to make a speech.



               But  I am somewhat confused, which isn't




unusual.  In your Water Quality Standards  Conference,




State of Iowa, you  made a requirement here or a recom-




mendation that all  significant municipal wastes dischargee




into the interstate waters  of Iowa shall receive a mini-




mum of secondary treatment  prior to discharge, and then




you have a timetable there  that compliance shall be sub-




mitted not later than December 31, 1969, and the compli-




ance date of not later than December 31, 1977.




               Now, if my memory serves me correctly,
-------
                                                      435
                         J.  Samson
and you can correct me if I am wrong, I think there is




a provision in the Federal Act that requires some con-




sistency between areas.  Isn't there some provision like




that?




               MR. STEIN:  I don't know about it.




               MR. SAMSON:  I thought that there was some




generally areas that were neighbors, that there should be




some consistency.




               MR. STEIN:  I think we try to be consisten"




Of course we are from the east, and you know Emerson was




from the east too and he is the man who said, "Consistency




is the hobgoblin of mediocre minds."




               (Laughter.)




               MR. SAMSON:  Well, aside from that, our




provisions in Nebraska, the water quality standards which




were approved by the Secretary of the Interior sometime




ago, in connection with the Missouri River provides that;




                The date for compliance v/ith the standards




on all municipal and industrial wastes, except for those




facilities located on the main stem of the Missouri River.




shall be by 1972.  A special timetable for facilities dis-




charging into the Missouri River will be developed- by
-------
                                                      436
                        J. Samson
December 31, 1969.  A continuing program of waste treat-




ment plant construction will go forward with the assistam




of the grants.



               I wonder if there isn't some inconsistency




here on the position of the Federal authorities on what




is required here in Iowa and what we have done in Nebrask^,.




               And the second point I wanted to raise is




on this continuous disinfection shall be implemented as a




control of bacteriological pollution.   I don't recall




as far as Nebraska was concerned that there was ever any




problem raised by you folks on the Federal level involving




the control of the bacteriological pollution and we are




going to run into this question of continuous disinfectioji.




               MR. STEIN:  We will throw all those ques-




tions up to our staff.  I think you have a point on several




of those.



               One, let me indicate that as far as I see




the standards program, and the staff can check me, dealing




with 53 jurisdictions and in dealing with Federal-State




relations,  I don't think you are going to have complete




uniformity  or it  may depend on your definition of con-




sistency.   Every  State program is not going to be the
-------
                         
-------
                                                      438
                         J.  Samson
Missouri River, and I think what we worked out on thermal




pollution was approved by your agency.




               Isn't that right, Mr. Rademacher, on the




thermal pollution, that is at Desoto--and if there is




such a thing--at Desoto and at Falls City?




               MR. RADEMACHER:  Again I think that the




question of thermal standards on the Missouri River is




not an issue.  It is on the interior streams of Iowa that




this question arises.




               MR. BUCKMASTER:  I agree.




               MR. STEIN:  Well, this still raises a




question, you see, if you are going to look for consistent




I am not sure that there was any requirement on--is there




a thermal requirement on the interior streams in Nebraska"?




               MR. SAMSON:  ¥ill you restate that?




               MR. STEIN:  Is there a requirement on the




thermal pollution?  Is it about the same as this that you




are recommending here?




               MR. BURD:  Yes.




               MR. STEIN:  All right.




               MR. BUCKMASTER:  What is it?




               MR. STEIN:  I don't know.
y<
-------
                        J. Samson






               MR. BUCKMASTER:  Let's have somebody tell




us who does know.




               MR. STEIN:  Does anyone remember this?




               MR. BUCKMASTER:  I think it is important




that we know because we have spent almost a total day




In Davenport and here by people who have been pulled in




all over the United States talking about a difference of




three degress, and if it didn't require any for Nebraska




it would be interesting to Iowa to know why, although we




don't claim that would be any defense for us, but it




would be an interesting exercise in how the Federal mind




works.




               (Laughter.)




               MR. STEIN:  Thank you for a double compli-




ment, that we have a mind and it works.




               (Laughter.)




               MR. BUCKMASTER:  Now show us how,  Mr. Steiji




               (Laughter.)




               MR. STEIN:  Well, I think we can produce




that, but let's not hold up the proceedings for that.




               Let's move on.  Can we answer that second




question that Mr. Samson raised on disinfection?   Do we
-------
                         J.  Samson






have a requirement for disinfection in Nebraska?




               MR. SAMSON:  No.




               MR. STEIN:  ¥e don't?




               MR. SAMSON:  None.




               MR. STEIN:  All right.  We don't have a




requirement in the internal streams or in the Missouri?




               All right.




               I suggest we go on and we will give you




an opportunity later when we find the temperature, if




there is a temperature requirement, to get that informa-




tion in the record.  0. K.?




               Let me indicate the people we have left




this afternoon.




               MR. SAMSON:  Mr. Stein, may I inquire,



what is the response from the government on that bacterio




logical disinfection, what is the position of the govern-




ment?




               MR. STEIN:  You heard the recommendation




here.  They said they had none for Nebraska.




               MR. SAMSON:  I mean  inasfar  as Iowa is
concerned.
               MR. STEIN:  I think they agree.  It says
-------
                                                      441
                         J.  Samson
control—unless I am mistaken — control of bacteriological




pollution by continuous disinfection shall be implemented.




A timetable for implementation shall be established by




September 30, 19^9- In no case shall the compliance date




for the installation and operation of continuous disin-




fection facilities extend beyond December 30, 1970.




               MR. SAMSON:  All right.  Thank you.




               MR. STEIN:  And that is the position as




far as I know of the people preparing this report for




Iowa.  As far as I can see, and check my recollection




if this isn't correct, I think the region—this is not the




Kansas City region, but the region in Chicago made the




same recommendation in Davenport last week or essentially




the same recommendation.




               What we do have is a list of three more




participants this afternoon.  One is W.  W. Amundson of




Sioux City,  second is Mrs. Koerber of the League of Women




Voters, and the third is Dr. Morris.  Is there anyone




else?   Because we are going to recess -before we hear




these three.




               Is there anyone else who  would want to be




heard this afternoon?  If you do, would  you come up to me
-------
                       W. Amundson






during recess.  We will stand recessed for 10 minutes




                        (RECESS)




               MR. STEIN:  May we reconvene.




               May we have Mr. Amundson, please, of




Sioux City.
              STATEMENT BY WILLIAM AMUNDSON




                      CITY ENGINEER




                     SIOUX CITY, IOWA








               MR. AMUNDSON:  Mr. Chairman and conferees,




I am Bill Amundson, City Engineer for Sioux City.  I have




no written statement.  I merely want to reiterate the




position of Sioux City in this matter.




               I would like, in speaking for Sioux City,




to take the position of thanking the Iowa Water Pollution




Control Commission for the stand that they have taken in




this matter and to indicate that the city of Sioux City




is in full agreement with it.




               Sioux City, as many of you know, holds the




unfavorable and unpopular and dubious distinction of




having been one of the few cities put under Federal order
-------
                       W. Amundson






to cease and desist polluting the Missouri River prior to




the construction of our primary treatment plant.  We have




constructed this primary treatment plant and we feel that




we have probably as tight a rein on our situation and the




packing industry in our city as anyone on the river.  We




deplore the situation that goes on in other areas on the




Missouri River, particularly on the other side with our




adjacent State Nebraska.




               We feel that we wonder whether the measure




ments that have been taken by the Federal Water Pollution




Control Administration were taken specifically from the




Sioux City--our name has been bandied around here today




as being a serious contributor to this pollution; we




wonder whether these measurements were taken as repre-




senting Sioux City's outfalls rather than the many,  many




other outfalls that contribute to the downstream areas



Just below Sioux City.




               I would repeat again that the city of




Sioux City takes the stand of supporting the position of




the Iowa Water Pollution Control Commission.




               MR.  STEIN:   Thank you,  Mr.  Amundson.




               You know, we were up in Sioux City ma'ny
-------
                                                      444
                   Mrs. G. G. Koerber
years, and I will say after they got the plant in it was




very nice up there because they used to invite me to that




annual steak dinner they had in Washington.




               Let's go off the record for a minute.




               (Off the record.)




               MR. STEIN:  May we have Mrs. Koerber, of




the League of Women Voters.








          STATEMENT BY MRS. GEORGE G. KOERBER




    DIRECTOR AND STATE CHAIRMAN FOR WATER RESOURCES




            LEAGUE OF WOMEN VOTERS OF IOWA








               MRS. KOERBER:  I am Mrs. George G. Koerber,




an elected Director of the League of Women Voters of Iowa




and State Chairman for Water Resources.  The League of




Women Voters is a volunteer, non-partisan group working




to promote informed and active participation of citizens




in government.  I am grateful for this opportunity to




present the views of Iowa League members regarding surface




water quality standards.




               For many years, the League in Iowa and in




the United States has been concerned with water resources
-------
                   Mrs. G. G. Koerber






We have expressed our concern by supporting measures to




encourage coordinated planning and management of water




resources on a river basin or regional basis.  At the




same time, we have worked for enactment and enforcement




of pollution abatement legislation as well as for State




and Federal appropriations and local bond issues to con-




struct treatment facilities.  In 19&5* the League with




other interested groups supported the formation of the




Iowa Water Pollution Control Commission.




               We were particularly pleased that the




statute establishing the Commission declared that the




public policy of Iowa is "to conserve the waters of the




State and to protect,maintain, and improve the quality




thereof for public water supplies, for the propagation of




wildlife, fish and aquatic life, and for domestic, agri-




cultural, industrial, recreational and other legitimate




uses of such waters; to provide that no waste be discharg




into any waters of the State without first being given th




degree of treatment necessary to protect the legitimate




uses of such waters; to provide for the prevention, abate




ment, and control of new, increasing, potential, or exist




ing water pollution."  The statute, in addition, specific illy
-------
                   Mrs. G. G. Koerber






empowers the Commission "to develop comprehensive plans




and programs for the prevention, control and abatement




of new, increasing, potential, or existing pollution of




the waters of the State."




               Acting under this authority, the Iowa




Water Pollution Control Commission has made Iowa a




leader in pollution control.  Iowa has the highest




percentage of its urban population served by sewage




treatment facilities.  The Commission has proposed




regulations to prevent and control water pollution by




cattle feedlots.  Thus Iowa is among the first group of




States to deal constructively with this problem.  For




providing this leadership, the Commission deserves wider




recognition of its achievements than it has received.




               In addition, the Commission should be com-




mended for adopting a preventive policy toward water




quality standards for low flow streams.  This policy is




stated on page 8 of the Water Quality Criteria and Plan




for Implementation and Enforcement as revised  June 1968.




It reads "to protect legitimate uses on low flow streams,




the wastes will be given the highest practicable degree




of treatment without respect to dilution in order to
-------
                   Mrs. G. G. Koerber






 prevent the development of nuisance or health  problems




 below discharge.  Treatment  less than secondary  treatment




 will not be accepted unless  it can be shown that the




 legitimate uses can be protected with a lesser degree of




 treatment."




               Now, if this  means what I think it means,




 I ask these questions:  If it is possible to require




 secondary  treatment on low flow streams without  proof by




 the Commission that water quality has been affected




 adversely,  is it not possible to require the same degree




 of treatment on high flow streams as well?  Is it not




 equally valid to place the burden of proof that  primary




 treatment is not detrimental on those discharging into




 high flow streams as well as those on low flow ones?




 After all,  a high flow has at least one disadvantage--evei




 though it provides greater dilution,  it has the effect of




 decreasing the distance between communities so that the




 stream has  less time between communities to cleanse itsel:




               The League of Women Voters of Iowa believe




 secondary treatment or its equivalent by municipalities




 and industries along the Missouri River is necessary to




prevent and control new,  increasing,  or potential pollution
-------
                                                      448
                   Mrs. G. G. Koerber
if not existing pollution.  We ask the Iowa Water Pollu-




tion Control Commission to continue to look ahead, to



anticipate problems and to adopt measures to prevent the



development of nuisance or health problems.



               With our present population, let's assume




for a moment that primary treatment is adequate, what



happens if we wait to require secondary treatment?  Even



with the best monitoring system possible, water quality



would be lowered unless we can install treatment facilities



on an overnight basis.



               We urge the Iowa Water Pollution Control



Commission to adopt a requirement for secondary treatment




or its equivalent along the Missouri River and to initiat



plans for implementation and enforcement now.  Action now



will prevent pollution from accompanying the predicted



increase in population for the urban areas along this



river, because action now means the necessary treatment



facilities will be in operation when the increase occurs- •




not five or more years later.  Action now will save the



public money.  It costs less to treat the wastes entering




the river than it does to treat the water to make it



potable or usable by industry.  Action now will avoid
-------
	449





                    Mrs.  G.  G.  Koerber






 some  of  the  annual  increase in cost  of  constructing




 facilities.



                On the  remaining matters  under  discussion




 here,  the League as  a  lay group cannot  speak on  the




 technical points involved.   We can,  however, speak to  the




 policy that  will govern  the technical decisions.  The




 League believes the  Commission when  setting quality




 standards should abide by policy which  gives greater




 weight to protecting the public and  to  protecting the




 environment  than to  other factors.




                We know that other areas  of the Nation




 have  greater pollution problems.   This  fact, however,




 does  not remove the  need to prevent  or  control pollution




 in  this  basin.  On  the contrary,  the severe problems




 elsewhere should be  justification for preventive action




 here  because it demonstrates so well the  result  of pro-




 crastination and undue reliance upon dilution as a means




 of  water quality control.   We  must learn  from experience




 and take this opportunity to keep history from being




 repeated.  As taxpayers  and consumers,  League members




 are willing  to  pay  their share of the cost to conserve




 water  quality for succeeding generations.
-------
                        C. Noren






               Thank you.




               MR. STEIN:  Thank you, Mrs. Koerber.




               I will put this in next because it comes




from an official State agency.




               "This telegram is to emphasize the concern




of the Missouri Department of Conservation regarding the




detrimental effects of pollution on the fish, wildlife,




and recreation resources of the Missouri River and its




tributaries.  We believe that a high degree of waste




treatment is necessary to improve the condition of the




Missouri River and that a non-degradation policy is




essential to prevent further damage to the aquatic




resources of waste, heat or other pollutants unforeseen




at this time.



               "Sincerely,




               "Carl R. Noren, Director



               "Missouri Department of Conservation."




               Now, Mr. Bob Russell.




               Mr. Russell.
-------
                                                       451
                      R. C. Russell
             STATEMENT BY ROBERT C. RUSSELL




           EXECUTIVE SECRETARY, IOWA DIVISION




             IZAAK WALTON LEAGUE OP AMERICA




                    IOWA CITY, IOWA
               ME. RUSSELL:  Mr. Chairman, as Chairman




of this conference, we thank you for allowing us to




present the following.  My name is Robert C. Russell,




and I am the Executive Secretary for the Iowa Division




of The Izaak Walton League of America (I.W.L.A.).  As




such, and having received a copy of the March 5* 19^9,




notice by Secretary of the Interior Walter J. Hickel




setting this conference, I brought it to the attention




of the Iowa Division I.W.L.A. State Board of Directors at




their meeting of March 15, 1969. After discussing the




content of the notice and how it related to our interest




in water pollution abatement, I was delegated to prepare




and present a statement that would contain the sentiments




of the Board's discussion and other pertinent commentary.




The following is that statement.




               It has been the policy and indeed the
-------
                                                      452
                      R. C. Russell
history of the Iowa Division of the I.W.L.A. to have a




strong interest in and to support a strong water pollutioi




abatement program.  Our effort and support in the estab-




lishment of the present Iowa Water Pollution Control Law;




our statements presented at the November-December, 1966.5




hearings on water quality criteria for all Iowa waters;




and our statement given at the four April,1968,public




hearings on the subject of cattle feedlot waste disposal




all bear this out.



               Because of these involvements and our




knowledge of the program and actions of the Iowa Water




Pollution Control Commission, we would be remiss at this




time if we did not publicly thank them for the work that




they have done.  It should also be noted that many of




their accomplishments have been made to date in spite of




inadequate financing, lack of departmental personnel, and




perhaps even the very Iowa laws under which they administer




and operate.



               Now to grips with the purpose of this




conference, as we understand it:  Namely, resolving the




differences between the water quality standards of the




State of Iowa and the Federal Water Pollution Control
-------
                                                       453
                      R.  C.  Russell
Administration  regarding  the  interstate waters  of  Iowa,




as noted in  the  conference notice  and  determined in  part




not to  be  consistent with the  protection  of  the public




health  and welfare, the enhancement of the quality of




the water, and  the purposes of the Federal Water Pollutioji




Control Act  with particular reference  to:




                1.  The treatment requirements and




     implementation plan for waste discharges to the




     Mississippi and Missouri Rivers;




               2.  The requirements for disinfection




     of controllable waste discharges which may be




     sources of bacteriological pollution;




               3.  The temperature criteria for the




     interstate waters of the State other than the




     Mississippi and Missouri Rivers.




               First it is important to point out that ou




views  on these points  are from a non-technical standpoint




and to note that we believe the following to be relevant



to this conference:




               1.  From the FEDERAL WATER POLLUTION




     CONTROL ACT, AS AMENDED,  "DECLARATION OF POLICY,




     Section 1.  (a)  The  purpose  of this  Act is  to
-------
                 R. C. Russell






enhance the quality and value of our water




resources and to establish a national policy




for the prevention, control and abatement of




water pollution."




          2.  From the IOWA WATER POLLUTION




CONTROL LAW, CHAPTER 4-55B.1, Statement of




policy, excerpt, "...it is hereby declared




to be the public policy of this State to




conserve the waters of the State and to




protect, maintain and improve the quality




thereof..."




          3.  From the CONSERVATION POLICIES




OF THE IZAAK WALTON LEAGUE OF AMERICA in the




section on WATER POLLUTION, No. 6.  "Since




water courses know no political boundaries,




pollution control is rightfully a Federal as




well as a local, State, and interstate re-




sponsibility.  Although control measures should




be initiated at the lowest effective level,




the Federal Government should have clear




authority to strongly enforce pollution




abatement .and prevention in cases when lower
-------
                                                      455
                      R. G. Russell
     authority proves ineffectual or inadequate."




               If these stated Federal and State policies




of water quality enhancement and improvement are to have




any meaning, for the reasons which this conference was




called, and because this organization historically has




supported an enhancing clean waters program, we urge the




Iowa Water Pollution Control Commission to resolve the




issues upon which this conference was called and thereby




qualify the Iowa Water Quality Standards with a program




acceptable to the Federal Water Pollution Control Adminis




tration.




               Should the Iowa Water Pollution Control




Commission feel the need for changes or additional Iowa




legislation that affects its ability to comply with the




Federal Water Pollution Control Act, it is suggested that




they immediately petition the Iowa Legislature for such




authority.




               In closing we would like to note the




splendid example set by the City of Dubuque, Iowa,  in its




recent move to improve its sewage treatment program.




Perhaps their action will set a pattern for other cities




on Iowa's border streams.   It could hopefully be ind'icati'
-------
                                                       456
                        D.  F.  Beam
 that cities,  industries  and agriculture are seeing the




 "light"  towards  a better environment.   It is also hoped




 that the Federal and State water pollution control agencies




 involved with this conference can show a good example of




 cooperation.




                Thank you.




                MR. STEIN:   Thank you,  Mr. Russell.




                Now,  before we call on  Dr. Morris, is




 there anyone  else from other than the  Iowa official




 agencies who  wishes  to make a statement?




                Yes,  come on up here, please.




                MR. BEAM:  Did you want me to follow Docto




                MR. STEIN:   No.  Come on up here.








                  STATEMENT OF D. F. BEAM




           VICE CHAIRMAN, NEBRASKA COMMITTEE FOR




         PURE  AIR AND WATER, INC., OMAHA, NEBRASKA








                MR. BEAM:  I am Mr. Beam and I am from




I Nebraska, from Omaha.  I am Vice Chairman of the Nebraska




 Committee for Pure Air and Water, Inc.  We, too,  thank




 the Secretary of the Interior and Mr.  Stein as his
-------
                                                      457
                       D. F. Beam
representative for having this regional hearing.  I do




not have a prepared statement except that I jotted down




some notes from attending the meeting this morning.




               It seemed to me that the concern seems to




be on aquatic life in the streams, and my thought and my




question was because we are humans perhaps maybe I missed




the point of the whole study, but I think that part of




it was brought out when food processing was mentioned,




and so forth, when foods are prepared from this water




after it is treated.  But if we are concerned about the




fish life, I think the Federal Government as well as the




Iowa Water Pollution Commission needs to be concerned




about such matters as toxicity as far as the human being




is concerned and I think that the public hearing is




threshing out some of the solutions and controls.  I




think to report back to the public, the taxpayer, that is




you and I, you also, myself included, I think this needs




to be done, because we need to be made aware of how our




money is being spent and if it is being spent wisely.




               And then also I am wondering about the




Commission staffs, if there is enough public represen-




tation on these councils.  Nebraska,  I understand,  has a
-------
                                                      458
                       D.  F.  Beam
council,  Nebraska Water Pollution Council.   I am wondering




if there is enough representatives.  I think there is one




representative to represent the public in Iowa,  but I am




not too sure about Nebraska.  That is one of the question^




that I noted down.



               Now, one of the other things that I didn't




have too much time to delve into was the possibility of




the recent heavy construction of nuclear  powerplants.  I




think the Federal Government has adequate technical staff




to delve into this and I don't know whether the Federal




water pollution council has included this in their




studies.  This would be a radioactive waste byproduct




accident, possibly, and this was just recently brought




to the attention of the public through the Des Moines




Register of this past Sunday which was summarized from




the national history publication about the increase in




numbers of nuclear  powerplants throughout the country.



               I think that your publicity that you have




received  locally is very  good.  As far as a lay person,




I would like to see more publicity ahead of the conferenc




although maybe this conference was really earmarked for




the people  that are concerned, such  as the \vater treatmen
-------
                                                     459
                       D. F. Beam






and sanitation engineers.




               Is that true, Mr. Stein?




               MR. STEIN:  No, no, no.  Let rne




Interrupt since you have paused.  Don't go away; I




don't want to cut you off.




               These are always delicate issues. I




think you have raised some good questions and we




are going to let Nebraska, hopefully, answer you.




However, I will give you my philosophy on this.




               In dealing with publicity before the




conference vie have certain enforcement actions under




the law.  One runs the risk of using whatever the




forum is--newspapers, radio and T.V.--to try a case




or wait until you come before a forum such as this




where all sides can be represented.  With the best




of intentions,  when you put all this material out




in advance you don't have the traditional face-to-




face confrontation that we like in our society, which




seems to be the best way of getting at the truth.




               We follow the law strictly.  First




we prepare our reports.   I hope they got them out




in advance so everyone could see them.  We made a
-------
                                                     46o
                       D. F. Beam
distribution to the appropriate congressional members,,




to the appropriate State agencies, to everyone else we




thought would be interested in a technical report.  We




sent out notices of the conferences, and I like to use




the phrase "deadpan notices."  I know one mailing from




the Kansas City office alone was,  what,  800 names, wasn't




it?  How many names did we get from the  Chicago office




on the other side?  Perhaps a like number.




               In other words, we  sent out over 1,500




notices.  Anyone who received those notices could have




come in and asked for the information.  The information




is all public.




               However, as you see, with issues such as




we have here—and again trying to  have an even-handed




administration of the law--I believe that is about as




far as an agency can reasonably go before a conference




to distribute or disseminate the information and put out




what you might call, in quotes, "publicity."  The reason




for that is apparent.  We are trying to  set up a forum




or a procedure where we have all the points of view and




are able to make a judgment.  In other words, we wouldn't




be calling a conference of this type if  we didn't have
-------
                       D. F. Beam






questions  like that  and we  didn't  recognize there might




be differing points  of view that are to be aired and




adjudicated.




               I know how much you are interes ted—and




I am just  as much—in the widest dissemination of informa




tion.  But under the American system of government, the




jurisprudence, and in the interest of fair play, every




governmental agency--! don't care whether it is State,




Federal or local—when you have a situation of this type,




has to exercise a reasonable amount of restraint in the




kind of, again, "publicity" engaged in before the con-




ference.  This is the avenue by which we get all the




various views, some agreeing, some opposing, so we can




try to arrive at truth,  if we can, and agreements if at




all possible.  But this  does not mean that we by the use




of any term have a closed society or we have any secret




information.  It is just that we make the information




available through normal channels and do not try to push




this  too far before we have the conference.




               By the way,  this is the  essence of the




Federal-State relations.  Where a lot of the  problems come




up—again let me give you my experience--! would say that
-------
                                                     462
                       D. F. Beam
70 percent or 80 percent of the problems that I have




found in Federal and State relations, Federal-State-local




industrial relations, emanate from someone reading a stor




or an alleged quote or a release in a newspaper or in a




magazine and going back.  Again, as you know, they always




come to me.   I have never felt that I have ever had to telll




a magazine or a newspaper to change a story.  They do the




best they can and we are dealing with very technical




matters.  By and large, I would say they have been pretty




accurate and they generally get the main point of the




story across, which is all you can expect.  I certainly




have never had a complaint.




               But this is the kind of thing we all have




to watch.  I believe we have struck a balance and ive come




to this as fast as we can.  I know the conservation group




and a lot of the public groups would like to see some-




thing different, but again I really do not think there is




a substitute for face-to-face confrontation.




               Feel free to comment on that, or we can




ask the Nebraska people to talk first if you want to.




               Mr. Samson.




               MR. SAMSON:  Mr. Beam, I think it is very
-------
                                                      463





                       D. F. Beam






gratifying that you as a citizen take the time to come




over and. attend this conference.




               I just want to call your attention to our




statute in Nebraska provides for a membership of 10, and




of those 10 members on the Nebraska Water Pollution




Control Council 4 of them are ex officio members of the




official bodies in the State House, that is the Director




of Fish and Game, Director of Health, Director of Soil




and Conservation.  And then there are six who were




appointed by the Governor, citizens over the State, and




they are divided two representing municipalities, I mean




citizens such as you and others that the Governor picks




out who are interested in water pollution, one represents




agriculture and three represent industry.  So that is the




way the Nebraska Water Pollution Control Council is




constituted.




               Thank you.




               MR. BEAK:  Yes, that is very good.  That




is what I was waiting to hear.  I had not seen, you know,




a regulation or statute which shows how it is composed.




I appreciate that.




               I think that is all.
-------
 paper.
	464



              Dr.  Morris




      MR. STEIN:   Thank you.


      Is there  anyone  e.ise?


      If not, may  we have  Dr.  Morris.






    STATEMENT BY DR. ROBERT L.  MORRIS


ASSOCIATE DIRECTOR, IOWA STATE HYGIENIC


        LABORATORY, AMES,  IOWA






      DR. MORRIS:  I do not have  a  prepared






      I would like to  make a few  comments  on  som
 of the things that were in the basic initial report from


 the Federal Government.  Some things I do not feel quite


 represent the feeling of technical people and I would


 like to point them out.  I had planned one of them before


 this last gentleman talked, but because of his comment


 I doubly want to discuss it.


                I want to talk for a moment about radio-



i activity.  It says in the basic report in the blue cover
i

• on V-3, section E under "Radioactivity":


                "Water treatment plants remove little



 radioactive pollution from raw water supply."
-------
                                                       465
                       Dr.  Morris
                I hope  this  isn't  true, because at  reactor




sites we use  rather  conventional  water treatment processe




to  remove many  kinds of  radioisotopes.  We  precipitate




and filter them off  to concentrate the waste, they are




passed through  ion exchange materials and the cations,




many of them  are the isotopes of  interest,  are taken out




in ion exchange and  either  eluted or taken  away from




those resins  and concentrated in  other kinds of fluids




so that they  can be  disposed of in a variety of manners.




                And if this  statement is true, we are in




a very difficult position in  handling   radioactive




wastes.  The  division of radiological health of the




Public Health Service has for many years done very




excellent research and given us techniques and procedures




to handle these kinds of wastes.  They are classical



water treatment plant procedures.




               Also,the research done by the State




Hygiene Laboratory in Iowa has indicated at times follow-




ing weapon detonations, at least, and this is where our




experience has been gained because we really have no




industrial radiation industry in Iowa of any size,   we




have found time and time  again in our national  rivers,
-------
	___	466





                       Dr. Morris






 especially  the Mississippi,  the  Iowa and  the  Cedar,




 where we have worked  primarily,  that 50 to 75 percent




 of  the  radioactivity  in  our  streams is in suspended




 material.




               Well,  the  purpose of a water treatment




 plant in the first  step  of surface water  treatment is




 to  remove suspended material,  and many of our plants




 are highly  efficient  at  this,  either in just  simple




 sedimentation or  chemically-produced coagulation and




 then sedimentation, and  it is  a  demonstrated  fact that




 this significantly  reduces the concentration  of radio-




 isotope s .




               If we  go  through  classical lime softening,




 which is quite common in  surface water supplies as well




 as  some  ground water  supplies  in Iowa, these  are the




 materials that are  taken  out.  Strontium, for instance,




 which is a  well-known isotope, reacts to  softening




 processes just like calcium  and  magnesium and iron and




 manganese,  which  are  the  things  we are taking out.  So




 that this again is  effective as  a removal technique.




               I  am not  going  to get complicated and




 talk about  percentage removals and some of the variables
-------
	467





                        Dr.  Morris






 in  it,  but  nevertheless  I  think  that  statement  shoul^




 be  understood.




               In  Iowa  it is  not  uncommon  bo  zeoV be




 soften  municipal  supplies,  some  of  them even  surface




 waters.   And we know for a fact  that  radium  226,  which




 is  a  common natural  isotope in  ground water  supplies




 in  southeastern Iowa,  is removed to some  place  around  the




 97  to 98  percent  removal level by passage  through zeo-




 lite.



               The Public  Health Service  for  about three




 years had what they called the midwest environmental




 study based out of our laboratory in  Iowa  City  where




 hundreds  of samples naturally coming  from  the wells and




 those which had been passed  through zeolite  softeners




 were  shown  to  have reduced this  isotope to a  very sig-



 nificant  extent.




               I  think because of the comment that this




 last  gentleman made about  bhe concern about  reactors,




 nuclear   powerplants,  someone should  at least comment on




 this  statement.




               In addition  to the radioisotope  idea of




 removal,  I  would  like  to state that our standards^ such
-------
                                                      468
                       Dr. Morris
as  existed  the last time we considered it, are in




essential conformance with what the Water Pollution




Control Administration is recommending and I think they




are non-controversial and I think they are very adequate.




Our research in the Iowa environment during the time when




we were getting fallout materials indicated that we never




came anywhere near the limit of 1,000 micro-microcuries




or picocuries.  This is a value that I think we can live




with and it is certainly our intent to do what we can




from a State level to see that the nuclear installations




meet these standards.




                 So,  I don't think there is any reason




for concern in this respect. I think the Federal Govern-




ment   requirements or philosophy on this is sound and




we have no argument with it.



               The second item I would like to discuss




a little bit is bacteria.  Mr. Buckmaster mentioned that




we had a letter from an FWPCA official talking about




bacteriological standards and essentially accepting our




attitude on this.  We feel that in this environment the




highest coliform organism density, which is the parameter




that practically everyone uses, at least in part, in thei
-------
                                                      469
                       Dr. Morris
evaluation of water quality, is at an extremely high




level in the early stages of runoff which reaches or




cleanses the upper surface of our soil.  Thousands of




acres, maybe hundreds of thousandsr-I have never tried




to figure it out--in a broad Statewide rain of a sig-




nificant amount, in our experience a half inch to an




inch normally is sufficient to do this, pollute  our




streams with agricultural land runoff of which the




coliform organism group is a major constituent to a very




extensive degree. And after many conferences with the




Federal people we finally hammered out an agreement,which




we thought was permanent,that we would evaluate the




quality of our waters at what was termed low flow.




               Now, there are many waters in the State




where we can meet the levels which the Federal Government




has established and that we have agreed with,  and I will




only quote one of them for recreation, which seems to be




the guiding impetus of these conferences, 200  fecal colif




organisms per 100 milliliters.  We can meet this in a




geometric mean in many of the recreational waters in




Iowa.  We can't meet these levels at periods of high flow




We exceed them many, many times and I don't quite see how
rm
-------
                       Dr. Morris






  we  can arraign   150,000 farmers from the State of Iowa




to change their agricultural practices.




               By that I do not mean to infer — and I




think the whole Commission agrees with this—that the




Iowa Water Pollution Commission is not going to exert




every possible effort we can to produce better soil




conservation conditions so that the i^ater is held on




the individual farm where it falls.  What we are really




trying to do, and there is some argument against this,




but it is the best way we know how to go about it, is




to force the water into the ground water aquifer rather




than force it into the streams.  We are limited to some




extent "by this because we don't want to have all the




water flowing down our streams coming from ground water



to a river watershed recharge.  We wouldn't have enough




to dilute some of the products that get into the river,




including effluents from secondary or tertiary treatment.




It still needs dilution.




               So we are going to try and do what we  can




to hold the water where it is.  Until we do this to an




adequate extent, we are only going to meet these standard^




or any conceivable bacteriological level, at the low  flow
-------
                                                      471
                       Dr. Morris
periods in our State, and I strongly suspect many of the




States in the midwest are in exactly the same position




whether they know it or not as yet.  If they look, they




will see that it is something logical and we don't know




how to reverse it except by holding water where it falls.




               Actually, the Federal Government survey




that was performed, I think  in October last year, at




least in part brings this out.  If you look on page A-2




you can see that the geometric mean below Sioux City was




62,800 total coliforms and 26,600 fecal coliforms, and




this was by their description of the hydrology of the




period a relatively dry or low flow period.




               Over on the top of the next page, A-3, the




make a statement that a two-day rain-affected period at




19 of the 21 stations showed the total coliforms at




1.44 million, and the fecal coliforms, which is an




important point,were 1.12 million.  This is a vast




increase, but there is one other salient point here.




If you calculate percentages, and I didn't bring my




slide rule along and I make all kinds of mistakes with a




pencil and paper, fewer with a slide rule, it looks to me




like about 77 percent of the total coliforms were fecal
-------
                                                      472
                       Dr. Morris
in nature, meaning that they came from the intestinal




tract of warm-blooded animals.  We are quite inadequate




to determine whether the fecal coliforms are coming from




human beings or from livestock, but we can separate




those   which   are of intestinal origin and,  there-




fore, possible disease transmitters from those which are




of natural soil forms which normally have less important




effect as far as disease transmission.




               So the data which the people fro.m the




Federal Government produced here corresponds with what




we have found in Iowa on the internal streams, what we




have found on the Mississippi, and what we have found




with some of the work we have done on the Missouri.  And




as Mr. Stein so aptly stated, when we get together and




talk with each other, we reach some conclusions while we




are looking each other in the eye that you don't always




bring out in reports that are flown back and forth.  This




is one of the points. I think we must recognize that we




can set any bacteriological standard we want and the




environment in this situation doesn't make it possible




to meet a number.  You have to live with the environmenta




condition.  I think we should understand this about
-------
                                                      473
                       Dr. Morris
bacteriological levels.




               I think there is some question as to whether




we can meet this on the Missouri, and anybody who looks




at the data which was collected by this study in October




has to ask himself this question.  To make the decision




that you can't meet it is one thing.  To decide what you




should do about it is another, and there is more than




just secondary treatment involved.  Disinfection of waste;




can reduce the bacteriological load. This gets, in my




opinion, to be an engineering decision and an economic




one . Which way you want to approach the problem?




               The third thing I would like to discuss




is phenols.  We had a discussion of this in Davenport, and




I am not going to spend the time on it here that I did




there, except to say that the commonly accepted and agreec




to level of phenols pretty much around the country is one



part per billion.  Again I lean on our environment and




the monitoring data which we have and on some theory which




I think supports what we find.  The State of Missouri




made the comment that they can't meet the one part per




billion.  ¥e can't meet it either.  The State of Illinois




has signified that they can't meet the one part per billidn
-------
                                                      474
                       Dr. Morris
maximum permissible concentration of phenols in the




Mississippi River and other of their internal streams,




and the question becomes why.




               It is a quite well documented fact that




phenolic compounds can result from nature herself.  Many




natural materials can degrade into phenolic compounds




by a variety of pathways, and if people will read the




California Water Standards in the section for phenols,




this is so stated in here with bibliographies that can




be looked up to at least show you where these materials




come from.




               The best article on this I have read any




place in a single spot is an article in Air and Water




Pollution Journal, which happens to be a British journal,




but it is an extremely well done article.  It is entitled,




"Recovery and Identification of Organics  in Water" by




Richard D. Hoak.  He was working at the Mellon Institute




in Pittsburgh, Pennsylvania.  This documents, in my




opinion, in a very well done fashion, some of the sources




of these materials naturally.




               We have noticed the same phenomenon




in the phenol, problem that we have just been discussing
-------
                       Dr. Morris






in the bacteriological densities at dry periods and high




runoff periods.  We find in our work on the streams in




Iowa that the phenol concentrations are higher in early




stages of runoff.  This confirms the fact or at least makajs




it logical to assume that these are of natural origin,




because their increase fits with this kind of a cleansing




action on the soil.




               Actually, from my own experience and from




discussions with the engineers in the State Health Depart-




ment, we have very little industrial input of phenols




into our environment.  We are recording quite significant




levels in our streams. On the Mississippi we record an




average of about 10 parts per billion, we have recorded




levels as high as 18.  This is the reason why our standarc




is not one part per billion.  It isn't consistent with




our environment.



               And the other salient point on this, and




reason why the one part per billion was chosen,  is that




there is a lot of work which shows that certain  phenols




at the one part per billion level can produce compounds




when chlorinatedjthat do produce measurable tastes.  And




I am not here to argue with this.  It has been done by
-------
	476





                       Dr. Morris






some very  competent researchers.




               But I think it is reasonable to assume




that the types of phenolic compounds that are in our




natural environment are not producing the same levels




of  taste and  odor when they are chlorinated in our




natural water supplies.   Constitutuents entering a mole-




cule can change these taste levels and I think most




people working in this field realize this.  So that I




think we have to take a look at the natural input of




phenols into  our environment.




               There was  a discussion of this by the




State of Missouri, and I  don't recall having heard, and




I would like  to be informed if it exists, an actual




standard for  phenols in the State of Missouri. I have



heard it stated twice that they concur with our level of




20  parts per  billion, but I am not in possession of what




level they have actually  accepted and, unless I misunder-




stood the  statements, their standards have been approved




by  the Federal Government.  I would like to know whether




they are higher than ours or lower than ours.




               I also, in my ignorance, do not know what




the standards for Nebraska are with respect to phenols.
-------
                                                       477
                        Dr.  Morris
 If  it  is  one  part  per  billion,  we  are  going  to  have  to




 sample  on the  other  side  of  the river,  I-guess,  because




 the  part  that  we sample in Iowa is not  going to  meet




 that one  part  per  billion level.   I  have  no  information




 to  indicate that the other side of the  river is  really




 any  better than ours with respect  to this  type  of  runoff.




               Fourthly,  I am deeply disturbed,  because




 it  is a responsibility which at least in  part would  be




 directed  to me and the State Hygienic Laboratory and the




 Water Pollution Commission and  the State  Department  of




 Health, over a statement  on IV-42 which talks about  a




 matter very dear to my heart, monitoring  of  water  quality




 or surveillance, and it says:




               "The scheduled sampling frequencies of




 existing  and proposed monitoring stations operated by




 the  Iowa Water Pollution  Control Commission  are  on a




 quarterly basis for physical, chemical and bacteriologica:




 parameters."




               Now, I have in front of me a  cooperatively




worked out agreement or suggestion, I guess,  proposal,




 by the, I think it is,  Region V group out of Chicago,




 a Mr.  Risley came to Des  Moines and  worked with Mr.
-------
                                                      478
                       Dr. Morris
Schliekelman and myself and Dr. Gakstatter from our




staff, discussing proposed sampling points in Iowa, and




we worked out, after a full day of going over our data




and what the Federal people had, what I believe to be a very




adequate surveillance program for Iowa streams.  A certair




class of surveillance is done quarterly, some things




semi-annually, by the way this includes phenols, pesti-




cides, radioactivity, which happen  to be monthly, and




detergents, which is on a quarterly basis.  We sat down




and tried to work out with reason and judgment, as engi-




neers and chemists and liranologists, what it would take




to evaluate our environment, and we came up with a




detailed but variable type program.



               The statement goes on in the Missouri Rivei




report:



               "The  sampling frequencies for these




parameters should be increased to at least weekly




intervals" on a group of streams.  Some of these are




those on which we have worked out these sampling




frequencies.



               If I  may be permitted a  probably pre.judicec




statement, one. which I mean  to put politely, I don't know
-------
                          	479





                       Dr. Morris






whether any  chemists were involved  in making  that  state-




ment, but there is a whale of a  lot of work and  a  lot  of




money and an enormous amount of  leg work  in the  field  to




collect a broad spectrum of samples like  this  on at  least




a weekly basis.  I can assure you the State Hygienic




Laboratory, plus the Health Department in  Iowa,doesn't  have




this kind of manpower muscle, nor do I see where we will




get it,nor do I see the necessity for it.




               I would like to ask  that that  statement be




looked at again in a little more realistic manner.  Some




of our streams deserve daily analytical control, others




of them weekly, others monthly, some quarterly, and we




have tried to work this out.




               Now, I was very pleased when Mr. Risley




representing the Federal Government, came out  and sat




down in what I considered to be a very fine technical




fashion and worked this program out.  I would  hope that




we would get the same sort of a cooperative attempt from




the Missouri Basin Region



               I want to assure you that we will make




available any of the experience our laboratory has and I




am sure the  Health Department staff will do exactly the
 the way in which he has operated  these  conferences.   I





                                                  Vlll'f".
-------
                       Dr. Morris






same thing, but I don't like to see someone from outside



tell us what our sampling frequency should be on an



internal stream without at least discussing the problem






                                                      482
                        Dr. Morris






                Thank you very much.




                MR. STEIN:  Thank you.




                I have one comment.  You had better




 listen to this, because you may want to strike it




 yourself.  I direct this comment not only to the




 Iowa people but to the Federal people.  Over and




 over again I have heard in both reports whether we




 can tell whether a coliform or some kind of patho-




 gen, fecal eoli, fecal strep, what-have-you, is




 coming from field runoff, from a plant, from a




 packing house, etc.




                Now, if my recollection is correct,




 and I think it is, there are still two people in the




 room who started on this case on the Missouri River--




 Virginia Rankin, whose name used to be Hough then,




 and myself.  We were much younger then.  Paul Houser




 is here too.  At any rate, as I recall  Harold Clark's




 work during the 1950's, he was subjected to the most




 piercing cross examination by top notch attorneys




 who were hired by the packing house plants and municipali



 •Hi' 00  (-HO O -f-4- ^TAV^ r^-crr. ~~ -f-U^ „ 4- „ -P-P  	--£« -I-1- -
-------
                                                      483
                        Dr. Morris
 to too cross examination.  As I understood Mr. Clark's




 testimony in the late 1950's, it was this:




                He could determine whether that bug




 came from a field runoff or from a, waste discharge




 ana could distinguish between them.  I believe I




 recognize another face in the room; I think Mr.




 Samson was involved as a member of the Hearing Board.




 Harold Clark could distinguish whether the bug came




 from a packing house or from human wastes.  He also




 could distinguish by the viability in the length




 of flow, if he picked it up, say, below Omaha arid




 ?,ouncM Bluffs, whether it came from Sioux City or




 from Omaha.




                I am not arguing the facts one way




 or i:he other.  But if we are talking in terms of what




 kind of treatment exists and where the flow is coming




 from, it seems to me, gentlemen--and we will  check this




 until tomorrow, although Mr. Geldreich is in  the room




 who works in the same technique—it seems to  me, sir, if




> we had these techniques in the 1950's and they were  em-




 ployed then to give us the information and we have the




 same questions today, I just wonder why we shouldn't be ajble
-------
                                                      484
                       Dr. Morris
to use that methodology,if it is valid,to give us the




same results now as we had then.  And I just raise that




               May I call Mr. Geldreich for a moment.




Is what I said substantially correct?




               MR. GELDREICH:  That is correct.
this--
               MR. STEIN:  All right.  I would just ask
               Go ahead.
               DR. MORRIS: May I speak to that just a
minute?
               MR. STEIN:  Surely. By the way, it should




be clear, I have drawn no conclusions, you know, but it




just seems to me that we have a method to get the answers




               DR. MORRIS: I see Mr. Geldreich back there



and I Know that Mr. Clark, Dr. Kabler, Mr. Geldreich, and




a lot of people at the Robert A. Taft Sanitary Engineering




Center did an enormous amount of work on this.    on the




surface of things I too have read and talked with Harold




Clark a number of times about this.  The only hooker to




this system as you described it is that they don't use




the standard coliform test in making this differentiation.




They go into more sophisticated bacteriology, into the
-------
                                                      485
                       Dr. Morris
streptococci, and so forth, and these not only can




differentiate whether it came from one kind of animal,




a cow, a sheep, a pig, but the sad part of it is, unless




I read the articles wrong—and I hope Mr. Geldreich will




clarify this because I know he was in on it—also these




same kinds of organisms have origin in the soil and




plants also and this muddies the water, so to speak; so




that even with this ability to differentiate above and




beyond what the coliforms permit you to do, there have




been a lot of scientists--and I think this includes the




articles that Clark and Kabler and Geldreich have pub-




lished--are not absolutely certain in this differentiatior




There are breakouts where these organisms are not absolutely




identified with that single source.




               A lot of bacteriologists have taken rather




vigorous exceptions.  Now,  I don't know about Mr. Geldreidh



He may believe very firmly in the differentiation cap-




ability.  But a lot of people don't quite accept it 100




percent.  I am not one of them.  I am not as developed in




this field, but I have read the articles and there are a




lot of people that don't accept that in total.




               MR. STEIN:   Why don't you--
-------
	486





                       Dr. Morri'3






               I defer to Mr. Geldreich.




               MR. STEIN:  Why don't you come up, Ed.




               Here is what I am trying to get at.  If




this is a crucial issue--and as far as I know, ever since




I have been on the Missouri, certainly, and I think on




the Mississippi too, but certainly on the Missouri, this




is the crucial issue.  Let me just give it in the terms




that everyone can understand.




               Where do the bugs come from?  Do they come




from human wastes, do they come from a packing house or




did they run off from the land?  And you may have




different effects.  And also once you differentiate




that, what city do they come from or what industrial




outfall do they come from so we can pinpoint the source?




               Now, unless we can provide these answers,




we are going to find ourselves wallowing around through




the years, and I don't care what we do here in the dis-




position of this, just the equities of the situation are




going to require you to have these kinds of answers.  I




think we will make a great advance if we can agree on




the methodology.



               Not intending to preempt Ed, I used to
-------
                                                      487
                       Dr. Morris
think that Harold Clark had this down to such a fine




point that I used to ask him what the sex of the animal




was .



               (Laughter.)




               MR. GELDREICH:  Thank you, Mr. Stein.




               We have spent about 15 years working on




this  particular problem, that is finding a better




indicator of fecal pollution, and we believe we have it,




in fact, I will go so far as to say I know we have it,




in the fecal coliform group.




               First of all, we have looked at the




environment in every aspect, we have looked at warm-




blooded animals,  be ;".hey -ian or animals other than man.




We have looked at the soil, we have looked at fish, we




have  looked at water, we have looked at plants, we have




looked at insects, we have looked at everything that




would somehow or other contribute possible pollution to




our water environment that we are concerned with and




we have concluded and have published in probably about




25 papers and 1 book our findings over this period of




time.  We believe that the fecal coliform test is




measuring the fecal coliforms from all of these animals,
-------
                                                      488
                       Dr. Morris






be they men or be they some other animals that is warm-




blooded.  We find these organisms only in the contami-




nated environment when man or these animals are the




contaminators. They are not in soils remote from man's




habitation.  In fish they are not a normal inhabitant




of the intestinal tract, and when fish do have them it




is a reflection of the food they eat, the water they




swim in.




               In plants this is a reflection--and this




has been reported by others also besides ourselves--this




is a reflection of contamination from fertilizers, from




contaminated soil and from insect pollinators. Insect




polliners quite frequently spent part of their li-fe




cycle in manure piles and other areas where they do




pick up the contamination.



               The fecal coliform test is in standard




methods, it is in the current edition. I am on the




methods committee for the next edition, the thirteenth




edition, and we have further refined it to put in a




fecal coliform membrane filter media in addition to the




multiple tubes procedure which is in the current edition.




We have the methodologics,they are standardized, they
-------
                                                      489
                       Dr. Morris
have been recognized in the hearings in Sioux City and




Kansas City in the 1950's that we spoke of before.




               As far as fecal strep are concerned, this




particular indicator does have some room for an improve-




ment in methodology before it is as precise as the fecal




coliform procedure.  By the way, the fecal coliform




procedure will detect 93 percent of all of the fecal




coliforms found in warm-blooded animals feces of one




sort or another.




               The fecal strep in conjunction with the




fecal coliform in the development of a relationship or




a ratio has been used and we do use it in our stream




pollution investigations to pinpoint sources of pollution




We have found repeatedly that in domestic sewage there




are more fecal coliforms than there are fecal strep, in



the order of a ratio 4 to 1 or higher.  In cattle feedlot




wastes, slaughterhouse wastes, we find this ratio is




reversed from this.  There are more fecal streptococci,




a tremendously greater number, than t-here are fecal




coliforms and, therefore,  our ratio instead of being




4 to 1 is very frequently less than 0.6 to 1.  This is




the way we can quickly differentiate the two.
-------
                                                      490
                       Dr. Morris
               Yes, sir.




               MR. BUCKMASTER:  I am a layman, most of




the people here are^ and I don't understand it.  I think




you and Dr. Morris are having fun talking this way.




               MR. GELDREICH:  Talking shop.




               MR. BUCKMASTER:  The question is can you




distinguish between coliform out of warm-blooded animals




and man?




               MR. GELDREICH:  No, sir.




               MR. BUCKMASTER:  Well, we are dancing,




then,  on the head of a pin, because--




               MR. GELDREICH:  No, let me —




               MR. BUCKMASTER:  Let me finish.  It will




take you a couple of minutes.  It won't take me a fractior




of that time.




               MR. GELDREICH:  0. K.



               MR. BUCKMASTER:  Our contention is that




the runoff of animal manure from the large number of




animals we have, warm-blooded animals, cannot be dis-




tinguished from that of a human being.  There is no




quarrel,  I believe, with the question of that that comes




from plants and other forms.  It is this differentiation
-------
                       Dr. Morris






between all warm-blooded animals, man  being  one  of  them.




               MR. GELDREICH:  Right.




               MR. BUCKMASTER: Can you differentiate




between man and cows?




               MR. STEIN:  Just a moment,  please.




               MR. BUCKMASTER:  Yes.




               MR. STEIN:  Save the question, because  if




we go back and forth it gets confused.




               I think the answer is that  as far as I




can understand, although I know he answered  no,  the answe




as I understood they gave me was yes.   In  other words,




if they take the coliform and check,they  will be able  to




tell you if this came from a feedlot or whether this




came from a sewage treatment plant by  checking the  ratio




of the fecal coliform--




               MR. GELDREICH:  Only if we  do it in  con-




junction with a fecal strep test.




               MR. BUCKMASTER:  We are not talking about




a feedlot.  We have thousands of acres with  cattle and




hogs on pasture,  so it doesn't come from one source, it




comes from individual animals.




               MR. STEIN:   Yes.  Let me rephrase the
-------
                                                      492
                       Dr. Morris
question.




               When you ask an expert a question, you




know, he answers with a question.




               You said can you distinguish fecal coli-




form; the answer is no.  What you do is to put the




question this way:




               Can you take the fecal coliform plus the




fecal strep test, do a test on both, put those together




and distinguish?




               MR. GELDREIGH:  Very good, that is correct,




               MR. STEIN:  Then the answer is yes, you




see.  All right.




               MR. GELDREICH:  What we are trying to say--




               MR. BUCKMASTER:  Do you get indication




or do you prove it?



               MR. GELDREICH:  We prove it.



               MR. BUCKMASTER:  All right, I understand.




               MR. STEIN:  I am not trying to argue.




               MR. BUCKMASTER:  I am not either.  I was




just trying to find out what he is saying.




               MR. STEIN:  Yes, sir.




               MR. BUCKMASTER:  We lawyers can finally
-------
                       Dr. Morris






work it out, Mr. Stein.




               MR. STEIN:  Right.




               MR. BUCKMASTER:  It may be difficult, but




we finally get it.




               DR. SPEERS:  I am Dr. Speers from the




State Department of Health.




               Let me ask another question now.  Supposin




you have two sources upstream, one of which is of animal




origin and one of which is of human origin.  Can you take




this ratio then and make any meaning out of it and say




from that result that we have two sources, one of human




and one of animal origin and how much of each?




               MR. GELDREICH:  If they are mixed, I




assume that somewhere., at this point where you are samplin




both the fecal coliforms from the domestic sewage and




the fecal coliforms from the cattle feedlot are mixed




in the stream and now we have this mixture, can we sort




this out?   This becomes somewhat difficult because you




get into a ratio which is meaningless in an area between




the high one and the low one.  It is in these dramatic




areas near the runoff and within 2k hours downstream that




we can use this material successfully in interpreting.
-------
                       Dr. Morris






Beyond that I would not want to venture an answer.




               DR. SPEERS:  The reason I asked this ques-




tion, because it seems to me that many of the points of




controversy on the Missouri River are exactly this  kind




of situation where you have got several sources and they




are going to be mixed and it is going to be hard to sepa-




rate .



               MR. STEIN:  Let me try to get at that.




               Just look at the record.  I am not trying




to draw a conclusion.  But when we went up and down the




Missouri in the late 1950's with Harold Clark,we in a




sense--and I am just talking from a legal evidentiary




sense--were lucky that we didn't have these masses  of




pollution.  We had separate sources.  In other words, you




had a concentration.  You know them as well as I do.  We



had Yankton and Vermillion, then we had Sioux City, then




we had Omaha and Council Bluffs, you moved down to  St.




Joseph, Atchison, Leavenworth, Kansas City, Independence,




Columbia, and so forth.  And in between those it was




relatively clear.



               Now, what Harold Clark did wag use a third




variable, as I recall the testimony, and I think I recall
-------
                               495
Dr. Morris
it because  it made  a  tremendous  impression  on  me  at  that




time.  What he  did  was he  took the  fecal  coliform, the




fecal strep, used them together'  in  a  ratio,  and he also




took the point  of discharge  at which he  could figure  what




coming out  from the point  of discharge  and  traced the




flow down the river;and he got what to  him  was a pretty




accurate picture of where  the bugs  came from at all  these




points down the river.




                The  thing that I  am  saying as we are




standing here 10 years llater is: either we find  defects in




the method that we  can't go along with, or if someone




could do this 10 years ago,why can't they do it now?




Again,! don't know what the results are going  to be  if




they do it,  but this is the issue.




                Yes.



               DR. MORRIS:   I think we  do that, Mr. Stein,




when we ask to  do our bacteriological work,  fecal coli-




forms,  at low flow. We essentially are  evaluting the




input of municipal and industrial wastes,  and I know they




both exist,  in the stream when we have cancelled out a




variable.   Now,  any mathematician knows that one way to




simplify the solution to an equation is to cast a variable
                                   as
-------
                                                     496
                       Dr. Morris
and that is all we have done, cast a variable.




               MR. BUCKMASTER:  That is very reasonable.




               MR. STEIN:  That is right.  Again,, and as




I understood from Mr. Hegg's statement this morning, I




understand substantially that this is what they did.




Again I have no brief with the figures because that




you are going to have to do.  They found that 50 percent




of the loadings,, at least in dry flow, below the big




city centers of Ornaha and Sioux City came from the muni-




cipal waste sources, which included the industries.  Now,




this is as I understood it and as I understood the thesis




               MR. BUCKMASTER:  You are right, you are




right, and we have agreed to disinfection of those areas.




Our only quarrel comes on the recreational areas other




than seasonal.  We have no quarrel with this.




               MR. STEIN:  But what we should do between




State and Federal people is that if we have the




methodology—and as far as 1 can se;:se we do--we




should be able to come up with some reasonable state-




rne">t that all hands can agree on just about how much is




coming from the industrial sources; how much is coming ou|t




from the municipal sources; how much is coming off the
-------
                                                       497
                        Dr.  Morris
 land, and proceed from there.




               The  only point  I  am  making, is--




               MR.  BUCKMASTER:   I don't  think we  have any




 quarrel  on it.




               MR.  STEIN:  All right,  I  think this  will




 put us ahead if we  have that.




               Is  there anything else?




               MR.  GELDREICH:  I would like  to  add  one




 more comment.




               Dr.  Morris, the fecal  strep  procedure  will




 be in the next edition of Standard  Methods,  the one which




 we used.  There are some methods currently used in  the




 book.  The methods, as I say, in all  cases are  available.




               DR.  MORRIS:  We have been  using  them for




 years.




               MR.  GELDREIGH:  Yes, I know.  I  have




 evaluated your laboratory in the past.  I know  you  do it.




               Thank you.




               MR.  STEIN:  Let me again make this point.




We have a lot of experts in the room here and Dr. Morris




 and company are familiar with them.  I have  always  pushed




 for the notion,  and I hope Iowa and the other States  will
-------
                                                      498
                       Dr. Morris
join me in  this—I think they have in the past—that



if a n y of the bright young people wherever they are



located come up with a method and it looks like it is goir
to work that we use it and we not wait until one of these



committees, which gets encrusted like any bureaucracies,




including ours, puts it in one of their books and enshrines



it in a method book.  In other words, if the technique



works, we use it as fast as we can.




               I think this,what Mr. Geldreich has been



talking about is a case in point.  As far as I can see,



this thing on the fecal coliform has been percolating



through their committee for about 10 years now before



it has finally made it.    I think 10 years is a long



time to wait in the pollution business.  If you have a



method, let's use it for those 10 years and not wait



until it gets into Standard Methods.



               Does anyone have anything more to say?



               With that we will be recessed until 9:30



tomorrow.  I think we can finish this tomorrow.



               (Whereupon, an adjournment was taken




until 9:30 o'clock a.m, April 16, 1969.)
g
-------
                                                     499
                                     (9:30 a.m.)






               MR. STEIN:  May we reconvene.




               I have here a letter from Roger Bachmann




of Ames,  Iowa,  which we will put in the record.




               MR. BUCKMASTER:  I didn't hear you,  Mr.




Stein.




               MR. STEIN:  This is a letter from Roger




Bachmann, which we showed to the technical staff,  and




there was no objection from either side that this  be put




into the  record.




               (Which said letter is as follows:)
-------
                                                                          500

                                        April  }k,  1969
Mr. Murray Stein
Assistant Commissioner for Enforcement
Federal  Water Pollution Control  Commission

Dear Mr. Stein,

     I would like to enter the following into the proceedings of the
Iowa water quality hearings held in Dubuque,  Iowa on April  8 and 9»  1969.

     On page 15 of the April  1969 statement of the Iowa Water Pollution
Control  Commission in support of the Iowa water quality standards and
plan for implementation and enforcement reference is made to my communi-
cation of November 22, 1966 with regard to temperature criteria.  This
was presented to the public hearing on proposed water quality criteria
held by the Iowa Water Pollution Control Commission at Fort Dodge,  Iowa
on November 30, 1966.  Since this statement is being used as a justification
for the Iowa temperature criteria, I would like to quote that portion
of the communication that dealt with temperature criteria.

     "I do not believe that the proposed water temperature  criteria  will
adequately protect aquatic life.  While many Iowa fishes may withstand
temperatures as high as 95  F for a few days at a time during the summer,
the normal temperatures for these species are 10 to 20 degrees lower.
Furthermore, many species need periods of cold and seasonal  changes  in order
to complete their life cycles.  For more adequate protection of aquatic
life I would recommend that water temperatures not be more  than 10  F
above the normal or upstream temperatures and in no case exceed 95  F."

     I would like to point out that the proposed criteria to which I
was referring in the above quotation was:  "Temperature;  Not to exceed
95  F at any time."  as listed in the hearing notice of the Iowa
Water Pollution Control Commission of 28 October 1966.  My main concern
at that time was that the proposed criteria allow for a seasonal temperature
cycle as well as specifying a maximum temperature.  The use of a temperature
differential appears to be a practical way to meet this objective and is
commonly used in water quality criteria recommendations.

     With our present state of knowledge about the complex relationships
between stream organisms and water temperature I feel that  the choice
between a 5  F and a 10  F differential is arbitrary and that I cannot
presently provide objective support for either one over the other for
the Iowa standards.
                                        Sincerel y,
                                        Roger W. Bachmann,  PhD.
                                        R. R. #3
                                        Ames , Iowa
RWB:rh
-------
                                                     501
                        Mr. Stein
               MR. STEIN:  I think it behooves us all
to get this record completed as soon as possible.
However, I would like anyone here to think about how
long he would like to keep the record open if he wants
to put in additional material.  I would like a sug'
gestion toward the end of this.  I would not like to
keep this open too long, because the longer we keen
the record open the longer the issue is going to be
pending and we are not going to be able to come to a
conclusion.
               We will now continue with Iowa.   Mr
Buckmaster.
-------
	502






                       R.  Buckmaster









              STATEMENT BY ROBERT BUCKMASTER




          CHAIRMAN,  IOWA WATER POLLUTION CONTROL




               COMMISSION,  DES MOINES,  IOWA









                MR.  BUCKMASTER:   Mr. Stein, Dr.  Morris is






 not  able  to  be with us today, but he called me  this






 morning and  wanted  me  to  put something in the record






 before we  started in response to the colloquy we had at






 the  close  yesterday between  Mr.  Geldreich and Dr.  Morris






 in connection  with  fecal  coliforms.






                I make  reference  now to the report  of the






 Committee  on Water  Quality Criteria,  which was  the officis






 advisory  committee  established by the  Department of the






 Interior  on  water quality and was submitted to  the Sec-






 retary of  the  Interior,  at that  time Mr.  Udall,  by Mr.
-------
                                                      503
                      R. Buckmaster
Moore, which contained the recommendations of the Nationa




Advisory Committee.




               I am going to quote from page 12 of that




report:




               "Fecal streptococci in combination with




total coliforms are being used in sanitary evaluation.




Selection of techniques to be applied and the interpre-




tation of results are in a state of  flux  and




uncertainty.  Problems include the unresolved question of




whether or not all types of fecal streptococci found in




warm-blooded animals are revealed by the tests, the fact




that appreciable numbers of streptococci from other




sources (plants and insects) yield positive test results,




and added time and manpower requirements for monitoring




agencies.  Fecal streptococci should not be used as pri-




mary criteria,but are useful as a -supplement to fecal




coliforms where more precise determination of sources of




contamination is necessary."




               Which, as Dr. Morris understands it,




supports the statements he made yesterday in connection




with that subject.




               MR.  STEIN:   I see Mr.  Geldreich.  I don't
-------
                                                      504
                      R. Buckmaster
want to interrupt.




               Does this substantially support your




position too?




               MR. GELDREIGH:  That is exactly what I am




trying to say.  I want you to use fecal coliform,period.




We went off on a tangent yesterday.




               MR. BUCKMASTER:  At long last we got what




you were trying to say.




               MR. STEIN:  I think we have agreement, at




least in one area.  Thank you.




               Mr. Buckmaster, will you continue.




               MR. BUCKMASTER:  Mr.  Schliekelman will be




the first one to present a matter he would like to bring




before this conference.








             STATEMENT BY R. J. SCHLIEKELMAN



         TECHNICAL SECRETARY, IOWA WATER POLLUTION




           CONTROL COMMISSION, DES MOINES, IOWA








               MR. SCHLIEKELMAN:  My name is R. J.




Schliekelman.  I am the Technical Secretary for the Iowa




Water Pollution Control Commission.
-------
	305





                   R. J. Schliekelman






               The statement which we will enter into



the  record has been given to the recorder, and I will try




to summarize a portion of this for the sake of saving



time and may also add a few additional statements that



do not completely follow the statement itself.




               (Which said statement is as follows:)
-------
                   STATEMENT
IN SUPPORT OF THE IOWA WATER QUALITY STANDARDS
  AND PLAN FOR IMPLEMENTATION AND ENFORCEMENT
             MISSOURI RIVER BASIN
    IOWA WATER POLLUTION CONTROL COMMISSION

                  APRIL 1969
-------
507
-------
                                                                          508

A.  INTRODUCTION

By notice of March 5, 1969, the Secretary of Interior called a conference
to consider water quality standards for the interstate waters of Iowa.
This is a statement of the Iowa Water Pollution Control Commission's
position on the matters to be considered at the April 15, 1969 Council
Bluffs, Iowa session of the conference.  A similar statement, with emphasis
on Iowa waters of the Mississippi River basin, was presented at the Davenport,
Iowa session of the conference which convened on April 8, 1969.  The Iowa
Standards apply to all waters of the state and much of the Mississippi
statement is repeated herein.  However, this statement will discuss matters
more specifically pertaining to waters of the Missouri River basin.

The Iowa Wat^r Pollution Control Law, enacted in 1965, created the Iowa
Water Pollution Control Commission and charged the Commission, through the
administrative and technical staff of the State Health Department, with
the general supervision, administration, and enforcement of all laws relat-
ing to pollution of the waters of the state.  Among the powers and duties
of the Commission are those of prescribing rules and regulations, adopting
reasonable water quality standards, and developing comprehensive plans
and programs for the prevention, control, and abatement of pollution.

The Water Quality Act of 1965, amending the Federal Water Pollution Control
Act, provided for establishment of water quality standards for interstate
waters.  The Act requires the states to adopt such standards which ultimately
become Federal standards, after approval by the Secretary of the Interior.
With that authority, the State of Iowa ahead of the schedule specified by
the Federal Act, filed a letter of intent to adopt standards, held public
hearings on the proposed criteria, and adopted the standards which include
the water quality criteria and a plan for implementation.  The standards
were submitted to the Secretary, and after clofie liason between state and
Federal representatives and after numerous conferences and correspondence
attempting to agree on a mutually acceptable document, the Secretary
determined that certain of the provisions were not approvable as Federal
standards, and called a standards setting conference.

The purpose of this statement is to set out the State of Iowa's position
on tha matters of disagreement.  The Federal position is outlined in a
report prepared by the Missouri Basin Region of the Federal Water Pollution
Control Administration, for the Water Quality Standards Conference convening
April  15, 1969.  The report is comprehensive and contains a wealth of detailed
background information arid technical discuesion, so no attempt will be made
to duplicate  or enlarge on that aspect.  However, as with the Federal Water
Pollution Control Administration report on the Mississippi River basin,
there  is considerable discussion of such aspects as turbidity and bacterial
and nutrient  loa.ling from agricultural  land runoff, and also of conditions
resulting in  large part from waote discharges from Nebraska.  Such aspects,
while  appearing to discredit the water  quality and the state's pollution
control efforts, but being actually outside the scope of Iowa Water Pollution
Control Commission control, are not at  all at issue in the matters being
considered by  the conference.  To the casual reader, such discussion tends
to create false impressions of wide spread pollution and ineffective control.
This statement  therefore,  is an attempt to put the issues in context, to
clarify the Iowa position  on matters actually in controversy, and to present
the positive  aspects of the Iowa program.
                                  -1-
-------
                                                                          509
Part B will outline the Iowa policy and review past  and present  pollution
control in the state.  Parts C and D will comment  on the background  inform-
ation and summary and conclusions and recommendations presented  in the
Federal report.  Finally,  the Iowa Water Pollution Control  Commission has
during past months of negotiation agreed on certain  revisions  of the standards
and implementation plan, and these are summarized  in Section E.
                                   -L-
-------
                                                                          510
B-  .STATEMENT OF POLICY AND THE PAST AND PRESENT IOWA WATER POLLUTION CONTROL
    PROGRAM

The present authority for stream pollution control in the State of Iowa is
embodied in Chapter 455B of the state code, the "Iowa Water Pollution Control
Law".  Enacted in 1965, it created the Iowa Water Pollution Control  Commission.

The conduct of the program, as intended by the legislature and as actually
being implemented by the Commission and the State Health Department, can
best be expressed by the statement of policy as written into the law;

     "4553.1 Statement of Policy. Whereas the pollution of the waters of
     this scate constitutes a menace to public health and welfare, creates
     public nuisances, is harmful to wildlife, fish and aquatic life, and
     impairs domestic, agricultural, industrial, recreational and other
     legitimate beneficial uses of water, and whereas the, problem of water
     pollution in this state is closely related to the problem of water
     pollution in adjoining states, it is hereby declared to be the  public
     policy of this state to conserve the waters of the state and to protect,
     maintain and improve the quality thereof for public water supplies,
     for the propogation of wildlife, fish and aquatic life, and for domestic
     agricultural, industrial, recreational and other legitimate (beneficial)
     uses;  to provide that no waste be discharged into any waters of the
     state without first being given the degree of treatment necessary to
     protect the legitimate (beneficial) uses of such waters; to provide for
     the prevention, abatement and control of new, increasing, potential,
     or existing water pollution; and to co-operate with other agencies of
     the state, agencies of other states and the federal government  in
     carrying out these objectives. (61GA, ch 375, §1)"

This policy, not in the least inconsistent with the present Federal  Act, was
enacted prior to approval of the amendments in the Water Quality Act of 1965.

As present policy, it evolves from and reflects long and continued progress
of stream pollution control in Iowa.  The progress can be seen in a  brief
history of stream pollution control accomplishments.

The first law, passed in 1923, gave the State Department of Health regulatory
and enforcement authority.  Even before that, Iowa was "ahead of the program".
The Department of Health working under legislative authority for supervision
over the installation and operation of sewerage works and control of nuisances,
and towns recognizing the public health and clean streams need for sewage
treatment, had already begun stream pollution control.  At the time  the 1923
law was passed, nearly 200 municipal sewage treatment plants were already
in operation.  These being in the smaller towns, only 350,000 some persons
were being served by the plants, and this represented only 30T4 of the
population being served by municipal sewer systems.  However, this was a
good start.

The program operated under the same authority for many years.  Then  in 1949,
the law was changed, among" other things, adding a sewage disposal permit
feature.  By reviewing treatment plant construction plans and specifications
required to obtain a permit, the State Health Department could insure that
any proposed plant was capable of producing an effluent of sufficiently high

                                   -3-
-------
                                                                           511
quality to protect the receiving stream.  Essentially no sanitary sewer
permits have been granted unless served by a treatment plant, and in
particular, a treatment plant operating satisfactorily.  Although this
philosophy had been in effect as a matter of policy for many years, the
permit feature formalized the policy.

No combined sewers have been approved in Iowa for the last 40 years.

At the time of the 1949 legislation, some 230 municipal treatment plants
were in operation.  Some of the new plants were constructed by the larger
municipalities, so the capacity of the 230 plants was almost three times
that of 1923, and the plants were serving approximately 70% of the sewered
population.

In recognition of the fact that treatment plant construction is effective
only if operation is efficient and competent, an operator training and
voluntary certification program was implemented in 1952.  In 1965, legis-
lation was passed and implemented, and Iowa is now one of only 17 states
with a mandatory operator certification law.  The operator training program
has expanded and thrived.  Under the cooperative effort of the State Health
Department, the Iowa Water Pollution Control Association, and the State
Universities, laboratory courses are conducted at the Universities and
regional basic and advanced operation courses are conducted throughout the
state.

From 1949, plant construction steadily and dramatically progressed, and in
1965 some 400 plants were in operation.  This represented an increase in
population served by treatment to approximately 97.57o of the sewered popula-
tion.

The 1949 law lifted a previous restriction, so that effective in 1951,
Mississippi and Missouri River cities and towns were subject to all provis-
ions of the stream pollution control law.  In recognition of common interests
in water quality, Iowa in 1952 entered into a tri-state agreement with
Illinois and Wisconsin, resolving to require any such corrections of
pollution conditions needed to render Mississippi River waters suitable for
all purposes.

On the Missouri River also, loxja as a member of the Missouri Basin Health
Council, agreed to and participated in adoption of a similar "Guide for
Water Pollution Control Activities."  The several states of the Council in
1952 agreed to a program for elimination of toxic substances and settleable
and floatable solids, and treatment of industrial wastes as necespary to
prevent deterioration of water quality, and to provide treatment over and
above removal of settleable and floatable solids as necessary to protect
downstream water uses.  The Guide also provided for future programs for
legislation, construction of treatment plants, improvement of plant opera-
tion and maintenance and stream surveillance.

1965 was the year of enactment of the present pollution control law and
formation of the Commission.  In addition to retention of the perrait feature,
the new law provided improved enforcement provisions, and authorization for
rules and regulations and water qual:?;y standards.  It should be noted that
this Iowa requirecent for water quality standards, proven to be consistent
with the Federal act, was imposed prior to the water quality amendments of
the Federal act.

                                   -4-
-------
                                                                           512

Since the current law was  passed,  the  Commission has adopted three regulations
to aid in surveillance and enforcement.   The first is a regulation relating
to the General Criteria of the water quality standards, which makes
mandatory the effective removal  of settleable and floatable solids from
municipal waste water discharges.   The water quality criteria which apply
to all surface waters at all  times and places,  require that the surface
waters be free from floatable and  settleable solids x^hich could form
putrescent and objectionable  sludge deposits and be otherwise unsightly
and deleterious.  This general criteria  has  been effective in demonstrat-
ing conditions of pollution and  has been used as the basis for ordering
corrections.  Hox;ever, removal of  settleable and floatable solids in most
cases does not satisfactorily meet the standards, and the public water
supply, aquatic life and recreation criteria have necessitated secondary
treatment on Virtually all interior streams.

Rules arid regulations also require submission of monthly treatment plant
operation reports.  By specifying  format and content, the Department can
require reporting of sufficient  flow and laboratory testing data to evaluate
plant effectiveness, and thereby obtain  an indication of the plant's affect
on receiving stream water  quality. To aid in more efficient and effective
use of the repofcts, a program for  computer scanning of the reports is in
the final stage of development.

The Iowa "Mail Order BOD"  program  has  also proven effective in surveillance
of treatment plants.  This program, which utilizes a technique for fixing
samples in tha field in preparation for  BOD determination in the State
Laboratory, eliminates the need  for refrigeration and enables transportation
to the laboratory by ordinary mail. It  is a unique procedure and was
developed in the State Hygienic  Laboratory.

Although not yet having legislative approval, a third regulation has been
adopted by the Commission  requiring control of feedlot runoff.  Feedlot
pollution is being effectively controlled through the present enforcement
provisions of the Law, utilizing the water quality standards and definition
of stream pollution, but approval  of the regulation x?ill hopefully reduce
staff time required and prove to be a  more efficient and effective means
cf control.

Using the various regulations and  enforcement provisions, the Commission
since its inception in 1965 hflo  isrsued 114 order,:s for correction of pollution
conditions.  The poin*: is  tlmt tl.c. orders, aloug with more informal education
and per3uasi.cn. efforts c• r:>.j and lar^c ".'-.nnunities rL- have
s'•-.•\:;c treatir.jvt.  This; roccrd raci • "Lth the highest in the uc.tiou.
                                   -5-
-------
                                                                          513

Of the industries, the Iowa Meat Packing Plants are the largest potential,
sources o£ pollution.  Every meat packing plant in the state has a treatment
plant in operation or under construction, and this represents some 3.5
million population equivalent being treated.  Some of the plants are realiz-
ing as much as 90 or 997= BCD removal, due in significant part to pioneering
and development of anaerobic/aerobic lagoon treatment in Iowa.  With the
exception of those on border streams, all packing plant wastes receive at
least secondary treatment.

Other wet process industries, though not producing the magnitude of waste
produced in meat packing, are subject to and complying with treatment
requirements (or if more appropriate, some type of inplant control), to
meet Iowa water quality standards.  Iowa has no provision for untreated
waste discharge permits.

It is significant that Iowa docs not have stream classification.  Although
the standards do specify recreation, fishing, and public water supply uses,
and areas of applicability have been defined, minimum defined standards of
high quality apply to all waters of the state.

In summary, Iowa has through the years recognized the need for clean streams
and continued and expanded its programs to meet the need.  The regulatory
agency has exercised it's authority to abate pollution and maintain and
improve water quality, and municipalities and industries have complied with
tha requirements.  The accomplishments shown by the record can be compared
with the best in the nation.  DGspit£ the adverse impressions created by
the Federal reports and the Secretary's decision to except certain provisions
of the Standards, Iowa has in the past and will in the future exercise it's
regulatory authority to the fullest legal extent.
-------
                                                                                                           514
           IOWA  LEADS  NATION  IN,SEWAGE  TREATMENT

           No  Urban  Population  Without  Treatment

       TABLE 3. URBAN POPULATION SERVED BY ADEQUATE AND LESS THAN ADEQUATE
                MUNICIPAL WASTE TREATMENT FACILITIES AND URBAN POPULATION
                NOT SERVED, BY STATE:  FY 1968
                               (In thousands, except percent)
State

u.s I/...
Ala..... 	
Alaska-'. 	
Aril 	
Ark.... 	
Calif2-'. 	
Colo 	

Del 	
D. C. . 	
Fla-. 	 ,
Ga 	
Hawaiii/ 	
Idaho. 	
Ill 	
Ind 	 ,
Iowa U ?_/
Kan? / 	
Ky 	
La 	
Maine 	
Md.... 	 ,
Ma»2-/. 	
Mich 	
Minn 	
Miss 	
Mo2-/ 	
Monti/ 	
Nebr1/2/ 	
Nev 	
N.H 	
N.J 	
N. Mex 	
N. Y. 	
N.C 	
N. Dak1/ 	
Ohio 	
Okla 	
Oreg 	
Pa 	
R.I 	
S.C 	
S. DakL/ 	

Tex 	
Utah 	
Vt 	
Va 	
Wash2/ 	
W. Va 	
Wis 	
Wyo1/2/ 	
Total
Urban Population
....:. 145,602
	 2,140
	 121
	 1,411
	 937
	 17,651
	 1,602
	 2, 342
	 356
	 832
	 4, 860
	 2, 727
	 591
	 349
	 8, 923
	 3, 182
1.5261-'
	 1,475
	 1,539
	 2, 479
	 509
	 2, 785
4,563
	 6, 377
	 2, 370
	 988
	 3,141
379i/
	 846
	 376
	 414
	 6, 444
	 764
	 16, 003
	 2, 138
	 2541/
	 7, 870
	 1, 694
	 1, 320
	 8, 428
	 793
	 1,134
287i/
	 2, 214
	 8, 874
	 825
	 162
. . 2 756
	 2, 139
	 710
	 2, 804
1981-/
Population Served By (Facilities)! * of Pop. with less than
Adequate Less than Adequate None Adequate or None
81, 703
819
19
711
684
12, 766
854
312
9
832
1,741
1,081
162
160
7,410
2,286
1,590
1,267
536
818
37
2,119
1,729
1,340
769
460
2,522
123
833
366
43
1,629
671
8,017
1,447
278
4,591
1,332
552
5 325
395
540
290
750
6,819
500
9
1,092
681
149
2,049
189
31, 865
678

34
156
36
593
1,286
267

864
1,003

134
586
529

192
792
515
60
162
1,173
4,223
1,324
23
183
263
100
6
102
3, 179
5
3,733
125
15
2,071
199
SO4
2,916
190
178
39
319
130
19
121
1, 328
444
348
689
29
32, 293
643
102
666
97
4,849
155
744
80

2,255
643
429
55
927
367
I/
ir
211
1,146
412
504
1,661
814
277
505
436
V
I/
4
269
1,636
88
4,253
566
V
1,208
163
264
187
208
416
J/
1,145
1,925
306
32
336
1,014
213
66
V
44.1
61.7
84.2
49.6
27.0
27.7
46.7
86.7
97.5

64.2
60.4
72.6
54.2
17.0
28.2 Nl

14. i wi
65.2
67.0
92.7
23.9
62.1
79.0
67.6
53.4
19.7
69.4
11.8
2.7
89.6
74.7
12.2
49.9
32.3
5.9
41.7
21.4
58.2
36.8
50.2
52.4
13.6
66.1
23.2
39.4
94.4
60.4
68.2
79.0
26.9
14.6
                                                                                     No population
                                                                                    without treatment
!_/  Population served by treatment facilities exceeds total urban population of these States by 259, 000 persons.

    Thus the detail adds to 259,000 more than the total U. S. urban population.
2J  Water quality standards adopted call for primary waste treatment in some urban areas of this State.
    Standards adopted for other States call for at least secondary waste treatment.

Source:  1962 Inventory, Municipal Waste Facilities in the United States, updated by FWPCA Construction Grants
       Awards; urban population estimates based on U. S. Census of Population, 1960j Bureau of Census

       Population Estimates, Series P-25.

                      From:  THE COST OF  CLEAR MATH - Volume I SuMaary Report,
             0  S Departoent of Interior, Federal Water Pollution Control Aoblniitration
                                   January 10, 1969
-------
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                                                                          517

C.  COMMENTS ON SUMMARY AND CONCLUSIONS.. OF THE, FEDERAL^EjgjRT

The extensive text is summarized in Section II of the Missouri River Basin
Water Quality Standards Conference report.  Several of the items deserve
comment and are discussed below.  The parenthesis indicates material quoted
or paraphrased from the Federal report.

Agricultural Runoff Effects

Items E, G, and K on pages II-2 and II-3 deal generally with agricultural
runoff effects.  While of interest, this particular aspect is actually
outside the scope of controllable standards, and the manner of the statements
could lead the less than totally informed ceader to unwarranted conclusions.

E.  (It is estimated that at least 3,300,000 cattle and calves and 6,100,000
hogs and pigs were on farms.  These animal wastes have a population equivalent
of 65,000,000 and can cause several conditions of stream degradation.',)
There is no particular problem, from animal waste until such time as rain-
fall, snox? melt or water passes through the feed lot dissolving material
from the manure and carrying it to the stream.  Since the load of dissolved
and suspended material vjater carried to the stream is only a fraction of
that on the feed lot, the 65,000,000 population equivalent of animal waste
on the feed lots should not at all be interpreted as the load on the stream.

(There are approximately 46,000 feeder lots in the state - page IV-23,)
This statement is misleading in that a feeder lot could be defined as an
area from which one or more grain-fed beef was marketed during  the year.
This could not be much of a pollution problem, and certainly not one over
which control could be exercised.  Iowa does however, effectively control
large confinement feed lot runoff pollution.

G.  (Sediment from uncontrolled runoff is a major pollutant of the Missouri
River.).     The reference to  low turbidity of water discharged from Gavins
Point Dam, compared to the turbid condition through Iowa is understandable.
The effect of settling of sediment in the pool above the dam is not avail-
able in the lower reaches.  Again, this aspect is outside the scope of
controllable standards and is  not an issue of the Standards conference.

K.  (High densities of bacteria and high concentrations of nitrogen and
phosphorus are found in Iowa tributaries  to the Missouri River, especially
during periods of stormwater runoff.)    This statement could be expanded to
include the agricultural  land  and streams in all states.  Furthermore,
while some control may be imposed, the bacteria, nitrogen and phosphorus
in storawater runoff can never be fully abated.  Storawater runoff effects
negate at  least in part,  the desirable effect of continuous disinfection
of  treatment plant effluents.

Recreational Uses

Items P, Q, and S deal generally with recreational uses and give emphasis
to  impairment of use by grease.

P.   (Recreational activities on the main  stem include boating, water skiing,
swimming and wading.  These activities are directly affected by presence of
floating material and grease balls, high  bacterial densities, dissolved
organics and turbidity.   Samples of water taken in the survey had as high
as  2000 bacteria per drop.)
                                  -7-
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                                                                          518

Q.  (Esthetic values of the waters in this area are reduced due to turbidity,
floating materials, and other effects which reduce or eliminate the oppor-
tunity for development of spectator oriented activities, e.g., boat or canoe
races, etc.)

S.  (Fouling of fishnets and lines with grease is common below major municipal
and industrial waste outlets.  Similarly, boat hulls of recreational water-
craft are fouled with grease and scum.)

The Iowa Water Pollution Control Commission has not designated the main
stctn of the Missouri as a recreation stream involving whole body contact
sports (swimming and water skiing).  The Iowa Health Department has for
many years recommended that Iowa streams not be used for this purpose
because of the injury and drowning hazards involved.  Section IV of the
Federal report contains the following statements which would appear to bear
out this position.

Second paragraph, page IV-7 (Present recreation use along the Missouri River
in Iowa has not met its potential for the amount of land and water acreage
involved.  While being light, however, it appears that most recreation
activities are participated in with sightseeing, boating, picnicking and
fishing as the most popular.)     Last paragraph, page IV-7(Water skiing,
surprisingly is enjoyed even though the river contains a high silt load.
Swimming is not considered a common activity due in large measure to the
dangerous water conditions and high turbidity.)     Third paragraph, page
IV-ll-(It can be expected that  use on the waters of the Missouri will prin-
cipally be in the form of fishing, and boating, and on the adjoining lands
in the form of sightseeing, picnicking, hiking, driving and walking for
pleasure, and in historical interpretation.)

From this, it would appear that there is general agreement that the value
of the Missouri River for whole body sports is dictated principally by
factors other than controllable water quality criteria, and that maintenance
of the general criteria and the criteria for public water supply and aquatic
life should adequately protect recreational uses.

The grease ball, grease and scum problems mentioned in items P and S have
not been shox>m to be attributable  to the Sioux City or Council Bluffs
municipal sewage plant discharges.  The discharges which would be most
suspected of containing large amounts of grease would be the Iowa Beef
Packers discharge at Dakota City, Nebraska, the municipal sewage treatment
plant  effluent at Sioux City, Iowa, and the City of Omaha discharges.  Grease
is discussed on  paga A-26 of the Federal report and this discussion is
quoted  in its entirety as follows:

(The concentration of grease from  the daily composite from the Konroe" Street
and South Omaha  sewers averaged 299 mg/1 during the October 19C8 survey.
The actual  amount of grease reaching  the Missouri River following a privately
operated  recovery operation at  the Monroe Street sewer was not determined.)

(The grease concentration in the effluent from the Sioux City, Iowa, sewage
treatment plant  during  the October  1968 survey averaged  17 mg/1.  The amount
of grease removed  through the sewage  treatment plant was not determined.)
                                   -8-
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                                                                          519

(Grease results from the January 1969 survey were not available for inclusion
in this report.)

The amount of grease being discharged (in the Monroe Street sewer) to the
private recovery operation, using a total daily flow of 40 million gallons
per day as shown in Table A-l, is fifty (50) tons per day.  In comparison,
the 17 mg/1 of grease found in the Sioux City effluent is not significant.
The Iowa State Department of Health has found that this amount of grease
is not visible in effluents or in the receiving stream.  The 17 mg/1 of
grease amounts to a little over one (1) ton in the Sioux City effluent, as
compared to fifty (50) tons being discharged in the Omaha Monroe Street
sewer.

The Federal report speaks of grease balls as big as oranges, but does not
say x^here these were observed.  Nor does it contain information concerning
the grease content of the Iowa Beef Packers effluent at Dakota City,
Nebraska.   The waste being discharged from Iowa Beef Packers is not treated
in a municipal plant and can be expected to contain appreciable amounts of
grease.  The waste treatment, facility consists of an air flotation grease
removal unit, the type of which past Health Department observations have
shown, present operator  problems and  is subject to operational outages.

The Iowa State Department of Health has information that the State of
Nebraska permitted lova Beef Packers at Dakota City to discharge wastes
which may be over 200,000 population equivalent, compared to 195,000
population equivalent listed in the Federal report for the Sioux City
sewage treatment plant effluent.  Grease removals in the Sioux City plant
would be much more effective than the IBP industrial unit, so that the
grease observation should not be attributed to Sioux City.

Water Quality Effects.

Items L, 0, and R on pages H-3, and II-4, discuss certain other vater quality
effects.

L.  (Survey results from the main stream of the Missouri River in Iowa identi-
fied adverse changes in water quality.  Turbidity increased four-fold in the
length of reach surveyed and cyanide and phenols were found)     It is true
that phenols were found in the Missouri River, however, the Federal report
failed to mention in the summary that the maximum observed phetiol concentra-
tions (Table No. A-5) did not change from station M-52, which is located
above Sioux City, to station M-38, which is located below the Omaha-Council
Bluffs area.  These maximum levels, which shoued no .relation to waste dis-
charges, were 2 parts per billion (ppb), which is twice as high as the
suggested FWPCA standard of 1 PPb.  These data further substantiate Iowa's
position that phenol concentrations resulting from natural degradation pro-
ducts often exceed the FWPCA standard of 1 ppb, and that this standard is
therefore unreasonable.

During the January, 1969 FWPCA survey, turbidity values were shown to decrease
from 19 units above Sioux City to 8 units below Omaha-Council Bluffs.  During
this period storm water runoff was minimal and these data show that sewage
treatment plant discharges had no effect on the turbidity of the Missouri
River.  High turbidity in the Missouri is caused exclusively by land drainage
and that subject is not relevant to the conference.
                                  -9-
-------
                                                                          520

Cyanide concentrations up to 15.2 ppb were measured in the Missouri River.
These concentrations given in Table A-5 bear no apparent relationship to
municipal or industrial discharges.  12.2 ppb of cyanide were found above
Sioux City while less than 1 ppb x
-------
                                                                          521

Failure of the Omaha meat packing plants to remove paunch manure and other
solids in pre-treatnent produced such severe plant operation problems that
the packing plant wastes and the south half of the City of Omaha still
remain untreated.  Four additional conference sessions ending March 1966
produced an agreement between the packers and the City of Omaha for construct-
ion of packing plant waste pre-treatment facilities, scheduled for completion
in 1969.

FWFCA Biological Study

The manner in which the biological data was presented did not deviate from
the rest of the Federal report.  Conclusions were "not objective" and
pertinent facts were buried which tended to create the illusion that Iowa is
a major polluter of the Missouri River.

The FWPCA summary (part M, page II-3) regarding the biological study states
the following.  (Biological investigations revealed predominately clean water
organisms and associated aquatic life above Sioux City.  However a consistent
increase in pollution tolerant organisms and biota were observed in many
stretches of the river between Sioux City and St. Joseph.)     This statement
leads one to believe that all is well above Sioux City, whereas the Missouri
downstream from Sioux City is polluted.  If the data (Table B2-Federal Report)
is examined objectively, it is obvious that this statement is misleading.

The fact is that the study shov;ed little difference in the biological quality
between station 736 and 730 above the Sioux City sewage treatment plant
discharge, whereas every sample taken in the first 74 miles below the Sioux
City discharge definitely demonstrated a biological fauna which was superior
in quality to that observed upstream from Sioux City.  Stoneflies, which are
noted for being extremely pollution intolerant, were found at three stations
downstream from Sioux City, while the data indicate that no stoneflies were
found above Sioux City.  Likewise there was a greater diversity of mayflies
in the first 74 ruiles below the Sioux City discharge than there was above
Sioux City.  Mayflies are also pollution intolerant organisms which require
high water quality.  The FWPCA data (Table B-2) demonstrate that pollution
intolerant forms were present in greater diversity in the first 74 miles
below the Sioux City discharge than above it.  This not a claim that the
treated waste discharge from Sioux City enhances biological quality in the
Missouri River, but merely points out that the biological quality was not
deteriorated at these stations by the Sioux City discharge.

It is stated in the Federal report (page B-l) that severe degradation of
the bottom associated organisms occurred for 54 miles downstream from the
Omaha-Council Bluffs area, and that floating solids (grease and chunks of
animal fat) were observed for 166 miles downstream.

It is interesting to compare the waste contribution of Omaha, Nebraska and
Council Bluffs, Iowa. This can be readily done by a few simple calculations
using the data given on page IV-24 of the Federal report.  Omaha, Nebraska
discharges 1,801,640 P.E. to the river, or 46 times as much as the Council
Bluffs 39,000 P.E. discharge.  Omaha's waste load to the river thus exceeds
the sum total waste load discharged by the 20 Iowa municipalities (including
industries) which are located on the Mississippi River.

                                  -11-
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                                                                          522

Eighty-eight percent of Omaha's raw waste load receives no treatment or,
in other words, is discharged directly to the Missouri River.  All of the
Council Bluffs waste receivescprimary treatment.

It is therefore not all surprising that the Missouri is biologically degraded
for 54 miles below Omaha, nor is it surprising that grease balls are found
as far as 166 miles downstream.  However, these conditions can hardly be
attributed to Council Bluffs, Iowa.

Water Quality Monitoring

(Pages IV-41, IV-42 and IV-43 of the Federal report contain discussion of
the need for water quality monitoring and recommendations that Iowa establish
additional monitoring stations and increase sampling frequency.)

The Iowa Uater Pollution Control Commission agrees that an adequate water
quality monitoring program is necessary and that this program should fit the
needs of all the agencies involved in water pollution control.  This is
further emphasized by sections of this statement recommending additional
study of parameters at issue in the Standards Conference.  However, the
extent of monitoring is directly dictated by staff manpower capability.
This, being an extremely small staff agency, priorities must be established.

Iowa has recently expanded its limnology program, which is a direct increase
in monitoring effort.  Iowa has also moved forward by development of the
mandatory treatment plant operation report program.  This, together with
automatic data processing, mandatory operator certification, and mail order
EOD, is a form of monitoring, but monitoring of sources of waste discharge
rather than stream water quality.  However, priority must be given to
correction of poor effluent discharges rather than stream sampling, and
this effort is a more efficient utilization of staff resources.  Such
sampling as is now possible is being carried out, and every effort will
be made  to expand the monitoring station network and increase sampling
frequency as manpower increases permit.
                                   -12-
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                                                                          523

D.  COMMENTS ON FEDERAL RECOMMENDATIONS

The recommendations of the Department of the Interior are set out,  starting
on page VI-1 of the Water Quality Standards Conference Report-Missouri
River Basin.  The Iowa position on each of the recommendations is outlined
below, in the same order as it appears in the Federal Report.

SeconSsry Treatment

The Department of Interior blanket requirement for secondary treatment of
all municipal and biodegradable wastes cannot be justified on the basis
of Congressional intent, nor can such a requirement be adopted by the
Commission under present Iowa statutory authority.  An effluent standards
provision, such as this secondary treatment requirement, was rejected during
early Congressional hearings, and the standards provision reported out of
Committee contemplated the setting of water quality standards for receiving
waters only.  However, on the basis of Guideline 8, the Department of
Interior has attempted to impose a uniform requirement of secondary treat-
ment or the equivalent, in all State water quality standards.

The Commission, under Icwa law, has no direct statutory authority to establish
or enforce effluent standards.  There is no authority to specify a type
of treatment, except that based on the water quality criteria of the receiving
stream.  Treatment can be regul :ted only to the extent that it will produce
an effluent that will protect the stream and meet the water quality criteria.

On the basis of stream water quality requirements, secondary treatment will
be needed, and therefore has or will be required for all but 4 or 5 of the
490 municipal sewage treatment plants located on interior streams.  However,
the Mississippi and Missouri rivers have very high stream flows furnishing
very high assimilative capacity, and the need for a degree of treatment
higher than primary is difficult and in most places impossible to demonstrate.
Extensive Mississippi River water quality studies during the middle 1950's
and a 1950 pollution investigation on the Missouri River, demonstrated
relatively little effect of even untreated wastes on these border streams.
But as the result of water pollution hearings and voluntary compliance, all
cities and towns, with the exception of the small Mississippi River towns
of Marquette and Lansing, completed primary or secondary treatment during
the 1950 to 1966 period.

The dissolved oxygen values presented in Figure A-2 of the Federal report
indicate no significant decrease in dissolved oxygen during the October 1968
survey period, and an actual increase progressing downstream to the Omaha
area during the January 1969 period.

The principal oxygen demanding sources now existing in the Sioux City area
are the primary treated effluent of the City of Sioux City and the relatively
untreated waste from the Iowa Beef Packers plant at Dakota City, Nebraska,
approximately 4 miles downstream from the Sioux City municipal sewage
treatment outfall.  As determiaed from samples collected by FWPCA and from
composite plant operation" reports submitted to the State Department of
Health, the Sioux City plant effluent has a population equivalent waste
loading in the range of 200,000.  No similar composite samples were collected
by the FWPCA from the effluent of the Iowa Beef Packers plant at Dakota
City, but information available to this Department indicates that the State

                                  -13-
-------
of Nebraska has permitted the Iowa Beef Packers plant to discharge an organ-
ic load of over 200,000 population equivalent to the Missouri river.  It
can be seen that this oxygen demanding waste load figure may be equal to
that contributed by the entire domestic population of Sioux City and its
packing plant waste load combined.

The table of municipal discharges to the Missouri river on page IV-24 of
the Federal report lists a plant discharge population of 39,000 for Council
Bluffs, Iowa and over 1,801,000 for Omaha, Nebraska.  The oxygen demanding
wastes for Omaha are thus 46 times that of Council Bluffs.  Some oxygen
depression was created by the discharge of primarily untreated wastes in
this area but could not be declared to have a serious detrimental effect.

These water quality studies have shown no significant reduction in dissolved
oxygen levels below sources of oxygen demanding wastes, even prior to
primary treatment.  This is a fortunate condition, and fares well compared
to others of the nation's major streams where secondary treatment jl£ needed.
For instance, the 1968 report of the Ohio River Valley Water Sanitation
Commission showed that dissolved oxygen levels of below 4 ppm occurred
33% of the time in the lower reaches of the Ohio River.  Likewise, the lower
reaches of the Delaware River now have very low oxygen levels, and hundreds
of millions of dollars must be expended for secondary treatment, simply to
maintain 3.5 ppm dissolved oxygen.

It also deserves comment that most of the larger border cities proceeded
with primary treatment in the early years of the Federal construction grant
program, and did not enjoy the degree of financial assistance that will be
available to cities in other States that have delayed any plant construction
to this point.

Using cost figures compiled by Smith and published in the JWPCF, it has
been estimated that construction of secondary treatment facilities for
all waste discharges to the Mississippi and 'Missouri Rivers would cost
over $25 million.  Furthermore, according to figures published in a 1969
FWPCA report, the cost of operation and maintenance of these secondary
plants would be approximately $1.7 million per year more than for primary
treatment.

The Iowa Water Pollution Control Commission has no hesitancy to require
secondary treatment of any waste discharge to either the Mississippi or
Missouri Rivers, when the need to satisfy water quality requirements is
shown.  However,  it is the Iowa position that a naed for uniform secondary
treatment of all waste discharges has not been shown, and there is no
scientific reason to believe that secondary treatment of every waste
discharge on the border streams will enhance the water quality.

Some degradation of water quality was evident below the Omaha-Council Bluffs
area due to the lex? percentage of wastes receiving treatment.  It is
suggested additional water quality studies be conducted following completion
of meat packing plant pretreatment facilities to permit evaluation of
Missouri river water quality when receiving full primary treated effluents
from the City of Omaha.
                                  -14-
-------
                                                                          525

Disinfection

At a meeting on February 9, 1968 with Robert S. Burd, Director of the FWPCA
Water Quality Standards Staff, Iowa agreed to adopt definite numerical
bacteriological limits compatible with National Technical Advisory Committee
recommendations for waters used for public water supplies 'and primary contact
recreation (swimming and water skiing).  Interior further agreed that the
standards would recognize these values as applying during dry weather, but
will state that all reasonable efforts will be made to reduce bacteria
concentration increases during periods of storm water runoff.

The Iowa Water Pollution Control Commission at its April 4, 1968 meeting
approved a motion accepting these provisions, and the Iowa water quality
standards have been revised to include the following numerical bacteriologic-
al limits:

          Public xvater supply

          Numerical bacteriological limits of 2000 fecal coliforms
          per 100 ml for public water supply raw water sources will
          be applicable during low floxv periods when such bacteria
          can be demonstrated to be attributed to pollution by
          sewage.

          Recreation

          Numerical bacteriological limits of 200 fecal coliforms
          per 100 ml for primary contact recreational waters will
          be applicable during low flow periods when such bacteria can
          be demonstrated to be attributable to pollution by sewage.

The water quality criteria and plan for implementation and enforcement tor
the surface waters of Icwa, adopted by the Iowa Water Pollution Control
Commission in May 1967, designated the surface waters to be protected for
public water supply uss as well as the recreation use areas on lakes,
impoundments and rivers.  The treatment needs in the plan have specified
colifonn reduction or effluent disinfection by the municipalities to protect
this use during the recreational season.  Information provided by other
state agencies and presentations at the public water quality hearings were
used to designate interior stream recreation areas, and coliform reduction
has been specified for interior municipalities where necessary to protect
recreational uses.

The State of Iowa therefore feels that acceptable bacterial criteria have
been established for interstate streams in Iowa.  These criteria are
compatible with criteria of adjoining states established for public
water supply and for recreation.  Other state bacterial criteria generally
take into consideration the effect of land runoff, and are applied when
necessary to protect specified uses.   Disinfection of treatment plant
effluents is required by states adjoining Iowa, generally where  public
water supplies are involved and where, necessary to protect public health
for recreational waters during the recreational season.  The State of Iowa
had previously gone on record in its  implementation plan as requiring
effluent disinfection where necessary to protect downstream water uses.

                                   -15-
-------
                                                                          526

Land runoff contributes high bacterial densities and bacterial studies in
the State of Iowa and elsewhere have shown that commonly acceptable coli-
forra levels have been greatly exceeded even in the absence of wastes
attributable to human sources.  The following is quoted from a long term
study (1) of total coliforms in the Iowa River at Iowa City.

          "If a stream contains coliform organisms that are of domestic
sewage origin, one might expect the MPN to vary inversely with the dilution
capacity of the stream.  High MPN values would be expected during the dry
seasons.  On the other hand, high turbidities would be expected with high
water conditions due to increased erosion and scour.

          "In the Iowa River, increases in stream flow are accompanied by
increases in both turbidity and coliform organisms.  This pattern has
been apparent over the entire 1950-64 period and is true whether one
examines daily or monthly average data.

          "Apparently, large numbers of coliform organisms are carried
into the river after each rainfall and snow melt.  The increase in turbidity
also indicates the agricultural land adjacent to the river as the source
of many of these coliform organisms.  Storm sewer overflow is not considered
a significant factor because the nearest upstream city is 30 mi. above Iowa
City, and above the impoundment.

          "In view of the apparently high numbers of nonfecal coliform
organisims, and the correlation of high coliform densities with high flow,
one might question the significance of such MPN data as related to the
bacterial safety of the Iowa River Water.  Does a high MPN, expecially a
high monthly average, which may be caused by runoff from a single rainfall,
mean that this water is an undesirable source?  Probably not."

Among his conclusions Professor Powell states:  "There are considerable
seasonal differences in water quality.  The impoundment has tended to reduce
this variation, for example, by distributing the poor water from spring
runoff  over a longer period of time.

          "Stream flow, turbidity, and bacterial density follow the same
seasonal pattern.  Increases in flow are accompanied by increases in the
other two.  During high flows the extremely high coliform densities are
due to  agricultural land drainage.

          "Improved methods of evaluating bacterial quality and recommend-
ing treatment are greatly needed.  In view of present day treatment capabilit-
ies, the worst rivers  in the country can probably be purified with relative
ease."
 (1)  Water Quality Changes Due to Impoundment, Marcus P. Powell &
     P. M. Berthouex, JAWWA July 1967
                                    16-
-------
                                                                          527
Figure 1 illustrates the pattern, on a monthly average basis, of the direct
relationship of increasing stream flows accompanied by increases in both
turbidity and total coliform density.  Figure 2 indicates that the monthly
coliform MPN average is less than 5000 per 100 m/1 about 46% of the months
both before and after impoundment above the supply in 1958.  Figure 3
illustrates coliform variations with flow and turbidity on the Raccoon
River at Des Moines,

Tables 2 and 3 contain total coliform data for the years 1964 & 1965
raw water at the University of Iowa water treatment plant intake at Iowa
City, Iowa.  This data indicates that commonly accepted total coliform
criteria both for public water supply and recreation uses are exceeded
due to land runoff a high percentage of the time.

The following are estimates of the costs for continuous disinfection
(chlorinatiori) of municipal waste treatment plant effluents, including
effluents from industrial wastes which may contain pathogenic agents as
recommended by the Department of Interior.

                      Estimated Chlorination Costs
             Iowa Cities and Towns on Interstate Streams
                                                 Construct.        Annual
                               Raw      Eff.     & Equip.          Chlorine
                               PE       PE        costs              cost

Major Mississippi River cities 1,029,000  700,000 $   642,000     $390,000
Major Missouri River cities      447,000  295,000     307,000      176,000
Interior Interstate Streams                         1,400.OOP      291.000

               Total Chlorination Costs            $2,394,000     $857,000
The expenditure annually of the large sums of money required for year-
round disinfection of municipal and industrial wastes as recommended by
FWPCA, will not improve the bacterial quality of interstate waters during
periods of run-off, and these are the periods when high bacterial levels
have been found.  The lona Water Pollution Control Commission has agreed
to disinfection of waste discharges where these discharges can be expected
to affect recreational or public water supply uses.  Primary body contact
(swimming and water skiing) recreational uses of Iowa streams is limited
by nature to summer months.  It has not been demonstrated to the Iowa Water
Pollution Control Commission that year round Chlorination is required to
protect secondary contact (boating and fishing) recreational uses.

The Missouri River being unsuitable for whole body contact recreational
sports (swimning and water skiing), precludes the need for disinfection
to protect this use.  The one possible need for disinfection would be at
the Sioux City area to protect the downstream water supplies.  However,
that naed, as demonstrated by the FWPCA water quality study, appears to be
rather borderline, and the study was relatively brief.  Therefore before
definitely establishing a compliance requirement and making the large expendi-
ture that will be required, additional study should be undertaken to more
accurately determine the coliform densities and sources.
                                  -17-
-------
    528
w
o
-------
                          529
0001  X  NdW
9|qoqoJd
-------
                                         530
 SJO-MC/M
TUiQOT/NdW
-------
                                                                              531
                                 TABLE 	2_

                                IOWA RIVER
                            WATER PLANT INTAKE
                            UNIVERSITY OF IOWA
                        TOTAL COLIFORM M.P.N. DATA
                                   1964
                        Public Water Supply          Recreation
Month  Number   Ave.      % > MPN   % > MPN     % > KPN         % > MPN
of MPN per
Samples 100 ml
Jan.
Feb.
March
April
May
June
July
Aug.
Sept.
Oct.
Nov.
Dec.
17
19
20
22
19
22
22
21
21
21
20
21
2,780
1,335
5,890
478
10,240
22,980
2,240
1,450
3,700
4,970
206
51
5,000
per
100 ml
11
05
20
0
31
50
18
04
14
14
0
0
20,000
per
100 ml
05
0
10
0
05
22
0
0
04
09
0
0
1,000
per
100 ml
41
31
55
09
78
81
63
14
61
38
0
0
2,000
per
100 ml
41
21
45
09
78
77
45
14
52
38
05
0
2,400
per
100 ml
23
15
45
09
78
77
36
14
52
33
0
0
5,000 Mean
per Flow
100 ml cfs
11
05
20
0
31
50
18
04
14
14
0
0
187
655
467
803
1,391
1 , 040
1,355
452
637
213
294
419
      *When averaging MPN values all values  less  than  30 were  considered 30.
-------
                                                                               532
                                  TABLE _3	

                                 IOWA RIVER
                             UNIVERSITY OF IOWA
                             WATER PLANT INTAKE
                           TOTAL COLIFOkM MPN DATA
                                    1965
                        Public Water Supply           Recreation
Month  Number   Ave.      % > MPN   % > MPN     % > MPN        % > MPN
of MPN per
Samples 100 ml
Jan.
Feb.
March
April
May
June
July
Aug.
Sept.
Oct.
Nov.
Dec.
20
20
23
27
20
22
21
22
21
20
21
20
37
46,000
15,000
32,000
17,000
5,100
6,100
27,000
38,000
2,100
670
12,000
5,000
per
100 ml
0
30
48
52
65
18
29
41
77
5
0
15
20,000
per
100 ml
0
30
13
33
20
9
14
27
53
0
0
10
1,000
per
100 ml
0
35
96
78
85
46
62
77
90
40
14
30
2,000
per
100 ml
0
35
87
74
85
41
57
77
90
30
5
25
2,400
per
100 ml
0
30
70
59
80
32
48
59
86
15
0
20
5,000 Mean
per Flow
100 ml cfs
0
30
48
52
65
18
29
41
77
5
0
15
1,282
2,039
3,388
6,257
4,989
5,633
2,661
513
2,651
3,593
4,025
3,807
      *When averaging MPN values all values less than 30 were consider-ed
       30 and all values greater than 110,000 were considered 110,000
-------
                                                                          533

Te-.r.perature

The temperature criteria for interior streams was excepted from approval by
Secretary of Interior.  During the lengthy negotiations, the temperature
criteria has been the subject of wide variation and inconsistency in the
Department of Interior's position.  In five separate expressions, for
instance, Interior has gequested different maximum temperature requirements,
ranging from 86°F to 93 F.

Agreement uas reached on the 93°F maximum on interior streams but not on
permitting a differential of 10°F above the natural background.  Interior
has insisted that this follox* the pattern of the larger streams, like the
Mississippi and the Missouri, dictating a differential of 5°F above natural
background from May 1 through October 1, and then 10°F October 1 through
May 1.  This issue is unx\rarranted and would seriously add to the expense of
power plane oparations where applicable.

The thermal loading in Iowa is primarily from electrical power generation.
Other industries using river water for heat exchange work are not believed
to be of such magnitude as to exceed the lower limit proposed when operating
plants on respective streams at low flow conditions.  This leaves then,
only those power plants which can properly and economically use this re-
source when able to stay below the maximum stream temperature set forth
by the criteria.

The trend in this area should be noted.  Older power plants are being closed
rather than expend funds for modernization of air and water pollution
control facilities and for other operational reasons.  These services are
being replaced by transmission of electrical currents from other larger and
more modern plants.  With the forthcoming of the atomic power plants in
this region, increases in the thermal loading at these smaller local points
on the interior streams, does not appear to be a problem for the near future.

The several guidelines issued by the National Technical Advisory Committee,
describing considerations for setting temperature limits, frequently refer
to the need for local study and for specific analysis of each habitat at
the zone in question.  Iowa believes this to be a most valid consideration
and submits to the expert opinions of those professional authorities who
have conducted investigations and have knoxjledge of the aquatic life on the
streams where such concern may exist.

The temperature limits in the standards were not finally established until
after the seven hearings conducted throughout the state.  The final criteria
were considered to be a fair representation of values recommended by and
acceptable to various biologists who testified at the hearings.  The views
of the Superintendent of the Biology Section of the State Conservation
Commission and the Principal Limnologist of the State Hygienic Laboratory
are also firm in the contention that the temperature maximums and the 10°F
temperature rise on interior streams are acceptable standards for aquatic
life.
                                   -18-
-------
                                                                          534

The recommendations of the Federal Report on the Missouri Basin water are
quite vague in regard to temperature maximums, but a February 21, 1968
letter from Robert S. Burd, director of the FWPCA Water Quality Standards
Staff, definitely stated that the maximums then proposed in the Iowa Standards
were acceptable, and indicated that the 10°F rise on interior streams was
the only point at issue.

Iowa believes however, that the first hand knowledge of the problems involved
and the subsequent testimonies of the professional authorities who counseled
in preparation of the temperature standards, are logical and valid reasons
for retaining the 10° tolerance above natural temperatures on interior
streams.  The 93° maximum temperature should also be retained.

Further, it should be recorded that all industry sharing this thermal
pollution problem has cooperated with the Iowa Water Pollution Control
Commission and adjusted its agreements to assure compliance within the
parameters desired by the Commission.  Industry is seriously concerned when
reviewing the various thinking, and changes in position expressed in letters
coining from the FWPCA, each adding to and further restricting their right
for using this resource.  Iowa believes the balance it has recommended to
be both reasonable and valid for water quality temperature criteria in Iowa.
                                   -19-
-------
                                                                          535

Protection of High Quality Waters

The October 2, 1960 minutes of the Iowa Water Pollution Control  Commission
state that the language of the non-degradation clause which was  accepted
by the state of Colorado and adjacent states is acceptable to the  Water
Pollution Control Commission.  This action is considered firm, and the
following non-degradation statement is incorporated as a part of the water
quality standards:

          Waters whose existing quality is better than the established
          standards as of the date on which such standards become  effect-
          ive will be maintained at high quality unless it has been
          affirmatively demonstrated to the State that a change  is
          justifiable as a result of necessary economic or social
          development and will not preclude present and anticipated use
          of such waters.  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 to provide the necessary degree of waste treatment
          to maintain high water quality.   In implementing this  policy,
          the Secretary of the Interior will be kept advised and will
          be provided with such information as he will need to discharge
          his responsibilities under the Federal Water Pollution Control
          Act, as amended.
                                  -20
-------
                                                                          536
Phenols

Phenol concentrations in Iowa streams are highly variable ranging from less
than one part per billion to a maximum of 20 ppb.  This variation occurs at
given sampling points at different times of the year being a function of
hydrologic flow, climatic conditions and other factors.

Experience indicates that the highest phenolic compound concentracions occur
at the early stages of high flow conditions rather than at low flows.  This
phenomenon causes us to discount the significance of industrial or municipal
input as this type source would tend to produce the highest phenol levels
during low flow-low dilution conditions.

Aromatic ring compounds abound in nature and bacterial and fungal organisms
are well known producers of hydroxylated ring metabolites.  The probability
is high that phenolic type compounds reactive to 4-aminaontipyrine could
have a potential metabolic pathway resulting from such natural materials as
wood tars, plant proteins, tannins, etc.  Since Iowa waters at times are
loaded with natural soluble organics due to soil surface leaching, the
correlation with early stage run-off and elevated phenol concentrations is
logical.

Iowa data bears this postulation out and sotae typical data illustrating
phenol levels are delineated in tabular form attached.

The summary data (Table A-5) in the Federal report shows maximum phenol
concentrations of 2 ppb did not change from above Sioux City to below
the Omaha Council Bluffs area.  These maximum levels which showed no
relation to waste discharges are twice as high as the suggested FWPCA
standard of 1 ppb and again indicate  phenol concentrations resulting from
natural degredation products often exceed the suggested standard.

          Iowa river cities using surface water showing phenol levels
          in the 10-20 range have not experienced taste and odor episodes
          attributable to phenol concentrations subsequent to normal
          chlorination for disinfection purposes.

          In view of the high and variable levels of phenolic compounds
          found in Iowa surface waters not traceable to industrial or
          municipal sources, it is the recommendation of the Iowa Water
          Pollution Commission that the maximum permissible concentration
          of phenolic type compounds be retained at 0.020 parts per
          million in all waters.

          There is no evidence or logic to suggest the pertinency of an
          individual standard for aquatic use specifically as most of our
          streams are multiple use including public water supply.  While
          aquatic life is far less affected by phenols, it is realistic
          to provide the single standard at 0.020 parts per million
          on the basis of the most critical potential use.
                                   -21-
-------
                                                   537
           TABLE  4

  PHENOL CONCENTRATION  IN
        IOWA  STREAMS
DATE
1-24/25-67
it
M
ii
ii
ii
n
ti
n
n
10/9/68




n
10/24/68
2/12/69
n
2/13/69
M
2/3/69
n
RIVER
Des Moines -Euclid
" Ipalco
11 Ottumwa
Raccoon
Missouri-Co Bluffs
Cedar- Cedar Rapids
lox^a River-Iowa City
Mississippi-Davenport
" Burlington
" Keokuk
Mississippi-Ups tream from
Des Moines River
11 Keokuk
it it
it it
DCS Moines -Keokuk
Mississippi-Lansing
" Davenport
11 tt
" Burlington
M n
" Keokuk
n n
PHENOL ppb
2
18
3
2
< 1
5
5
11
11
11


l(Iowa Side)
2 (Channel)
2 (Illinois Side)
2
1
9(481.3 channel)
8(480.1 channel)
8(404.1 channel)
12(400.3 channel)
10(363.6 channel)
QC^SQ 1 rhnnnpn
Des Moines-Keokuk
-------
                                                                          538

Radioactivity

The original brief criteria on radioactive substances had been acceptable
to the Federal Water Pollution Control Administration during earlier
discussions.  There was no indication of any disagreement on this criteria
until the Federal reports x\rere prepared for the conference, and there is
no particular disagreement now.  The State of Icwa has an adequate radio-
activity sampling program and will accept the more detailed radiological
limits now suggested by the FWPCA.  The following limits on radioactive
substances have now been adopted by the Iowa Water Pollution Control
Commission:

          Gross beta activity (in the known absence of 90 strontium and
          alpha emitters) shall not exceed 1000 picocuries per liter.

          The concentration of 226 radium and 90 strontium shall not
          exceed 3 and 10 picocuries per liter respectively.

          The annual average concentration of specific radionuclides,
          other than 226 radium and 90 strontium, should not exceed
          1/30 of the appropriate maximum permissible concentration for
          the 168 hour week as set forth by the International Commission
          on Radiological Protection and the National Committee on
          Radiation Protection.

          Because any human exposure to unnecessary ionizing radiation is
          undesirable, the concentrations of radioisotopes in natural
          waters should be maintained at the lowest practicable level.
                                  -22-
-------
                                                                          539

E.  SUMMARY OF ACCEPTABLE WATER QUALITY STANDARDS REVISIONS AND ADDITIONS.

The following are the various revisions or additions to the surface water
quality criteria and plan of implementation which have been adopted by the
Iowa Water Pollution Control Commission:

Section 1.2(455B) Surface water quality criteria
     1.2(3)
         a.  Public Water Supply
           (1)  Bacteria:  Numerical bacteriological limits of 2000 fecal coli-
                forms per 100 ml for public water supply raw water sources will
                be applicable during the low flow periods when such bacteria
                can be demonstrated to be attributed to pollution by sewage.

           (2)  Radioactive Substances:

                Gross beta activity (in the known absence of 90 strontium
                and alpha emitters) shall not exceed 1000 picocuries per
                liter.

                The concentration of 226 radium and 90 strontium shall not
                exceed 3 and 10 picocuries per liter respectively.

                The annual average concentration of specific radionuclides,
                other than 226 radium and 90 strontium, should not exceed
                1/30 of the appropriate maximum permissible concentration
                for the 168 hour week as set forth by the International
                Commission on Radiological Protection and the National
                Committee on Radiation Protection.

                Because any human exposure to unnecessary ionizing radiation
                is undesirable, the concentrations of radioisotopes in
                natural waters should be maintained at the lowest practic-
                able level.

         b.  Aquatic life
           (1)  Warm water areas.

                Temperature:
                    Mississippi River-Not to exceed an 89°F maximum
                temperature from the Minnesota border to the Wisconsin
                border and a 90°F maximum temperature from the Wisconsin
                border to the Missouri border nor a 5°F change from back-
                ground or natural temperature in the Mississippi River.

                    Missouri River-Not to exceed a 90°F maximum
                daily temperature nor a 5 F change from background or natural
                temperature during the months of May through October and a
                10 F change during the months of November through April.

                    Interior streams-Not to exceed a 93 F maximum temperature
                nor a maximum 10°F increase over background or natural temper-
                ature.

                    Heat should not be added tc any water in such a manner
                that the rate of change exceeds 2°F per hour.
                                  -23-
-------
           (2)  Cold water areas.

                Temperature:

                Not to exceed a 70°F maximum temperature.  The rate of change
                due to added heat shall not exceed 2°F per hour with a 5°F
                maximum increase from background temperature.

         c<  Recreation
           (1)  Bacteria:

                Numerical bacteriological limits of 200 fecal coliforms per
                100 ml for primary contact recreational waters will be applic-
                able during low flow periods when such bacteria can be
                demonstrated to be attributable to pollution by sewage.

Non-degradation statement

     Waters whose existing quality is better than the established standards
     as of the date on xvhich such standards become effective will be main-
     tained at high quality unless it has been affirmatively demonstrated
     to the State that a change is justifiable as a result of necessary
     economic or social development and will not preclude present and antici-
     pated use of such waters.  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
     to provide the necessary degree of waste treatment to maintain high
     water quality.  In implementing this policy, the Secretary of the
     Interior will be kept advised and will be provided with such information
     as he will need to discharge his responsibilities under the Federal
     Water Pollution Control Act, as amended.
                                  -24-
-------
                   R. J. Schliekelman






               (See also Appendix A and B.)




               MR. SCHLIEKELMAN:  The purpose of the




statement is to set out the State of Iowa's position on




the matters of disagreement with the FWPCA.  The Federal




position is outlined in the report which was presented




yesterday.  We feel, however, that there has been con-




siderable discussion of some aspects, such as turbidity,




bacterial loading, nutrient loading, agricultural land




runoff  and other conditions which may not be entirely




accurate.  Some of these aspects do actually appear to




discredit the water quality and the State's water pol-




lution control efforts.  In addition to that,  some of




these items are outside, really, the scope of the Iowa




Water Pollution Commission control.




               To the casual reader some of the discussion



tends to create false impressions of widespread pollution




and ineffective control.  This statement,  therefore,  is




an attempt to put the issues in context to clarify the




Iowa position on  matters actually in controversy and  to




present the positive side of the Iowa program.




               I  might get a little bit into the history




of the Iowa water pollution control program from actually
-------
                                                      542
                   R. J. Schliekelman
a long ways back.




               The first Iowa water pollution control law



was passed in 1923* and I think even at that time Iowa



was considerably ahead of a lot of the other States as



far as water pollution control program is concerned. At




the time this law was passed we had nearly 200 municipal



sewage treatment plants in operation in the State of Iowa.



               In recognition of the fact that treatment



plant construction is effective only if operation is



efficient and competent, an operator training and volun-



tary certification program was implemented in 1952.  In



1965 the Legislature passed and implemented a mandatory




certification law, and Iowa is now one of 17 States which



has such a mandatory certification law.



               Also in 1949 the law at that time lifted



a previous restriction so that effective in 1951 the



Mississippi and Missouri River cities and towns were sub-



jected to all provisions of the stream pollution control




which was in effect at that time.



               On the Missouri River, Iowa is a member of




the Missouri River Basin Health Council.  They agreed in



1952 to participate in the adoption of a guide for water
-------
                   R. J. Schliekelman






pollution control activities.  The several States of the



Council at that time agreed to a program for elimination



of toxic substances and settleable solids, and treatment



of industrial wastes as necessary to prevent deterioration



of water quality.




               In 1965 we did have the enactment of the



present water pollution control law which did create the



Iowa Water Pollution Control Commission.  Since this law



was passed, the Commission has adopted three regulations



to aid in surveillance and enforcement.  The first is a



regulation relating to the general criteria of water




quality standards, which makes mandatory the effective



removal of settleable and floatable solids from municipal



wastewater discharges.




               The second regulation requires submission



of monthly operation reports from treatment plants.  By



specifying the format and content, the department can



actually evaluate the plant effectiveness and obtain an



indication of the plant's effect on the receiving stream




water quality.



               Also a couple of years ago Iowa adopted



what they call an Iowa--or rather we adopted a mail order
-------
                                                      544
                   R. J. Schliekelman
BOD program, which also has proven effective in surveil-




lance of treatment plants.  This program utilizes a




technique for fixing samples in the field in preparation




for a BOD determination in the State laboratory.




               The third regulation, which has not yet




received legislative approval, has been adopted by the




Commission requiring control of feedlot runoff.  Actually,




at the present time feedlot pollution is being effectively




controlled through the present enforcement provisions of




the law.




               Under various provisions in enforcement




procedures, the Commission since its inception in 1965




has actually issued 114 consent orders for correction of




pollution conditions.



               Iowa is one of the large meat packing




States in the Union, and the meat packing plants do con-



stitute one of the largest potential sources of pollution.




Every meat packing plant in the State has a treatment




plant in operation or under construction, and this




represents some three and one-half million population




equivalent.  We feel that some of the plants are getting




really good removal, up to 98 and 99 percent  BOD removal,
-------
                   R. J. Schliekelman






and I think a lot of this has been due in part to the




pioneering of the anaeboric/aerobic lago.on treatment proc




by the State of Iowa.




               We think it is significant that Iowa does




not have stream classification.  We have all streams




classified to the highest extent.  Although the standards




do specify recreation, fishing, and water supply uses,




and the areas of applicability have been defined, minimum




defined standards of high quality apply to all waters of




the State.




               In summary,  Iowa has through the years




recognized the need for clean water and continued its




expansion of the program to meet needs.  The regulatory




agency has exercised its authority to abate pollution and




to maintain and improve water quality, and municipalities




and industries have complied with the requirements.   The




accomplishments shown by the record can be compared  with




the best in the Nation.   Despite the adverse impressions



created by the Federal report,  and the Secretary's decisic




to except certain provisions of the standards,  Iowa  in th<




past and will in the future exercise its  regulatory




authority to the fullest extent.
ss
n
-------
                                                      546
                   R. J. Schliekelman
               I might make a little comparison with



some of the other States as far as the percent of treat-



ment of urban population is concerned.  The State of




California at the present time has about 4.8 million of



its urban population without treatment out of a total




urban population of 17 million.  The State of Florida



has 2.2 million urban population without treatment as



compared with 4.8 million total urban population.  The




State of Maine has 412,000 population without treatment



out of a total population of 509,000.



               Now we will try to get a little bit into




the discussion of the summary and conclusions made in the



Federal report.  We feel that some of these items do



deserve comment and they will be discussed to some extent,



¥e have a section here which we have entitled "Agricul-




tural Runoff Effects."



               Items E, G and K of the Federal report




deal generally with agricultural runoff effects.  While



of interest, this particular aspect is actually outside



the scope of controllable standards, and the manner of



the statements as they have been presented in the report




could lead the less than totally informed reader to
-------
                   R. J. Schliekelman






unwarranted conclusions.




               To take up section E, this is  a quote  from




the report:




               "it is estimated that at least 3,300,000




cattle and calves and 6,100,000 hogs and pigs are on




farms.  These animal wastes have a population equivalent




of 65,000,000 and can cause several conditions of stream




degradation."




               There is no particular problem from animal




waste until such time as rainfall, snow melt or water




passes through the feedlot dissolving material from the




manure and carrying it to the stream.  Since the load of




dissolved and suspended matter carried by the water to




the stream is actually only a fraction of that on the




feedlot, therefore the 65,000,000 population equivalant of animal




waste on the feedlot should not be interpreted as a load



on the stream.




               There is another comment quoted:




               "Sediment from uncontrolled runoff is a




major pollutant of the Missouri River."




               This reference to low turbidity water dis-




charged from Gavins Point compared to the turbidity
-------
                   R. J. Schliekelman






conditions through Iowa is understandable.  The effect




of settling of sediment in the pool above the dam at




Gavins Point is not available in the lower reaches.  Agai:i




this aspect is outside of controllable standards and is




not an issue at the present time.




               Item K from the Federal report.  This is




quoted as follows:




               "High densities of bacteria and high




concentrations of nitrogen and phosphorus are found in




Iowa tributaries to the Missouri River, especially during




periods of stormwater runoff."




               This statement could be expanded to includ




the agricultural land and streams in all States.  Further




more, while some control can be imposed, the bacteria,



nitrogen and phosphorus in stormwater runoff can never be




fully abated.Stormvrater runoff effects negate at least in part




the desirable effect  of continuous disinfection of treat




ment effluents.



               We will have a few comments also on




recreational uses.  This is covered in one section,




Item P of the Federal report.  This is quoted as follows:




               "Recreational uses on the main stream include
-------
                   R. J. Schliekelman






boating, water skiing, swimming and wading.  These




activities are directly affected by the presence of




floating material and grease balls, high bacterial




densities, dissolved organics and turbidity.  Samples




of water taken in the survey had as high as 2,000




bacteria per drop."




               Another quote from the report states:




               "Fouling of fish nets and lines with




grease is common below major municipal and industrial




waste outlets,  Similarly, boat hulls of recreational




watercraft are fouled with grease and scum."




               The position of the Iowa Water Pollution




Control Commission has been that we have not designated




the main stem of the Missouri as a recreation stream




involving whole-body contact, namely swimming and water



skiing.  The Iowa Health Department also has for many




years recommended Iowa streams not be used for this




purpose because of the injury and drowning hazards




involved.  Actually, section IV of the Federal report




contains the following statements which appear to bear out




this position:    The second paragraph on page IV-7  of the




report is quoted as  follows:
-------
                                                      550
                   R. J. Schliekelman
               "Present recreation use along the Missouri




River in Iowa has not met its potential for the amount of




land and water acreage involved.  While being light, how-




ever, it appears that most recreation activities are




participated in with sightseeing, boating, picnicking




and fishing as the most popular."




               We have another quote that says as follows




               "Water skiing, surprisingly, is enjoyed




even though the river contains a high silt load.  Swim-




ming is not considered a common activity due in large




measure to the dangerous water conditions and high




turbidity."




               This is quoted from the Federal report.




               Another quote is as follows:



               "it can be expected that use on the waters




of the Missouri will principally be in the form of fish-




ing and boating, and on the adjoining lands in the form




of sightseeing, picnicking, hiking, driving and walking




for pleasure, and in historical interpretation."




               These are the end of the quotes.




               From this we believe that it would appear




that there is general agreement that the value of the
-------
                                                      551
                   R. J. Schliekelman
Missouri River for whole body sports is dictated prin-




cipally by factors other than controllable water quality




criteria and that maintenance of the general criteria and




the criteria for public water supply use and aquatic life




should adequately protect recreational uses.




               We also wish to comment on some of the




discussion regarding the grease balls, grease and other




problems mentioned in items P and S of the Federal report




The discharges which would be most suspected of containing




large amounts of grease would be the Iowa Beef Packers




discharge at Dakota City, Nebraska, the municipal sewage




treatment plant at Sioux City, Iowa, and the city of




Omaha, Nebraska.  Grease is discussed on page A-26 of the




Federal report, and this discussion is quoted as follows:



               "The concentration of grease from the




daily composite from the Monroe Street and South Omaha




sewers averaged 299 milligrams per liter during the




October 1968 survey.  The actual amount of grease reach-




ing the Missouri River following a privately-operated




recovery operation at the Monroe Street sewer was not
determined.
               Another quote continues as follows:
-------
                                                      552
                   R. J. Schliekelman
               "The grease concentration in the effluent




from the Sioux City, Iowa, sewage treatment plant during




the October 1968 survey averaged 17 milligrams per liter.




The amount of grease removed through the sewage treatment




plant was not determined."




               That is the end of the quote.




               Actually, the amount of grease discharged




to the Monroe Street sewer in Omaha can be computed to




be about 50 tons per day.  In comparison, the 17 milligrams




of grease found in the Sioux City effluent is not sig-




nificant.  The 17 milligrams of grease amounts to a little




over 1 ton in the Sioux City effluent as compared to the




50 tons being discharged to the Omaha Monroe Street sewer.




               Studies conducted by the Public Health




Service, I believe, in 19^5 at the time of reconvened



session of the Omaha conference on the Missouri River




also came up with the conclusion that there were about




100,000 pounds of grease discharged from the Omaha area.




That is, I think, really from the Omaha sewers, not the




Omaha area.



               The Federal report also speaks of grease




balls as big as oranges, but does not say where these
-------
                                                      553
                   R. J. Schliekelman
were observed.  Nor does it contain information concernin




the grease content of the Iowa Beef Packers' effluent at




Dakota City, Nebraska.  This particular effluent is




located about four miles downstream from the effluent




of the Sioux City sewage treatment plant.  We don't want




to appear to be actually putting the Iowa Beef Packers




Company in a bad light.  Our relations actually in the




State of Iowa have been very good, they have had a very




good record on the two plants that they have at Denison,




Iowa, and also Port Dodge, Iowa, so actually they are doiijig




a good job as far as the Iowa side of the stream is con-




cerned.  But we do not have information as to what is




being done at Dakota City.



               The Iowa Department of Health has informa-




tion that the State of Nebraska has permitted Iowa Beef




Packers at Dakota City to discharge wastes which may be




over 200,000 population equivalent compared to 195,000




population equivalent listed in the Federal report for




the city of Sioux City sewage treatment plant effluent.




Grease removals in the Sioux City plant we feel would




be much more effective than the Iowa Beef Packers indus-




trial unit, so that the grease observation should probabl,
-------
                                                      55^
                   R. J. Schliekelman
not be attributed to the city of Sioux City.




               ¥e have a section on water quality effects




which will be discussed further by Dr. Gakstatter of the




State Hygienic Laboratory.




               ¥e also have a section on fish tainting




\tfhich will be discussed by Mr. Harry Harrison of the




Iowa State Conservation Commission.




               We do have a comment regarding treatment




requirements in other States as described in item T of




the Federal report.  This states as follows:




               "Every State which borders the Missouri




River, except for Iowa, has adopted as part of its stan-




dards a minimum requirement for secondary treatment or




its equivalent for wastes discharged into the Missouri




River."



               This department has been informed by the




State of Kansas that Kansas, which borders on the Missour:.




River, has not agreed to a blanket requirement for secon-




dary treatment without such need being demonstrated.




Kansas standards have not been approved by the Secretary




of the Interior.



               We have a section in our statement regarding
-------
                                                      555
                   R. J. Schliekelman
the Federal Water Pollution Control Administration bio-




logical study which will also "be discussed by Dr. Jack




Gakstatter of the State Hygienic Laboratory.




               In our next section we wish to comment on




some of the recommendations that have been made by the




Department of the Interior for the Missouri River Basin.




The Iowa position on each of the recommendations is out-




lined in the same order as they appear in the Federal



report.




               Secondary treatment.




               The Department of Interior blanket require




ment for secondary treatment of all municipal and bio-




degradable wastes cannot be justified on the basis of




Congressional intent,  nor can such a requirement be




adopted by the Iowa Water Pollution Control Commission




under present Iowa statutory authority.




               The Commission,  under Iowa law,  has no




direct statutory authority to establish or enforce




effluent standards.  There is no authority to specify




type of treatment except that based on water quality




criteria of the receiving stream.   Treatment can be




regulated only to the  extent that  it will produce an
-------
                                                      556
                   R. J. Schliekelman






effluent that will protect the stream and meet the water




quality criteria.




               On the basis of stream water quality




requirements, secondary treatment will be needed and,




therefore,  has or will be required for all but four or




five of the 490 municipal sewage treatment plants




located on interior streams.  However, the Mississippi




and Missouri Rivers have very high assimilative capacity,




and, therefore, we did not feel that there should be




treatment applied without a necessity being actually




demonstrated.  Extensive studies made during the 1950's




on the Mississippi River and also a 1950 pollution




investigation on the Missouri River demonstrated a




relatively low effect of even untreated wastes on these



border streams.  However, as a result of water pollution




investigations and voluntary compliance, all cities and




towns, with the exception of the small Mississippi River




towns of Marquette and Lansing, completed primary or




secondary treatment during the 1950 to 1966 period.




               The dissolved oxygen values actually




presented in figure A-2 of the Federal report indicate




no significant decrease in dissolved oxygen during the
-------
                                                       557
                    R.  J.  Schliekelman
 October  1968  survey  period,  and  there  was  an  actual




 increase  progressing downstream  to  the  Omaha  area  during




 the  January 19^9  period.




                The principal  oxygen demanding sources




 now  existing  in the  Sioux  City area are  the primary




 treated  effluent  of  the city  of  Sioux  City and the




 relatively untreated waste from  the Iowa Beef Packers




 plant at  Dakota City, Nebraska.  As  determined from




 samples  collected by FWPCA and from composite  plant




 operation reports submitted to the  State Department of




 Health,  the Sioux City effluent  has  a population




 equivalent waste loading in the  range of 200,000.  No




 similar plant composites were collected  by the FWPCA




 from the effluent of  the Iowa Beef  Packers plant at




 Dakota City, but actually the information available does




 indicate that the Iowa Beef Packers  plant may be dis-




 charging a load of approximately 200,000 to the Missouri



River.




               The oxygen demanding wastes for Omaha as




given on page  IV-24 of the Federal report is  1.8 hundred




thousand, which is ^6 times that of the city  of Council




Bluffs.   Some  oxygen  depreciation was created  by the
-------
                         	558




                   R. J. Schliekelman






discharge of this primarily untreated effluent in the




Omaha area.




               These water quality studies which have




been made show that there has been little significant




reduction of dissolved oxygen levels below sources of




oxygen demanding wastes, even prior to primary treatment.




This is a fortunate condition, and actually fairs well




as compared with some of the other major streams where




secondary treatment is needed.  For instance, the 1968




report of the Ohio River Valley Water Sanitation Commissicjn




showed dissolved oxygen levels of below 4 parts per




million occurred a~bout 33 percent of the time in the lowei




reaches of the Ohio River.  Likewise, the lower reaches




of the Delaware River have had  very low oxygen levels



and hundreds of millions of dollars must be expended




by communities and industries along this stream for




secondary treatment simply to maintain three and a half




parts per million of dissolved oxygen.




               Using cost figures published in the Journa]




of the Water Pollution Control Federation, it has been




estimated that construction of secondary treatment




facilities for all waste discharges to the Missouri and
-------
                                                       559
                   R.  J.  Schliekelman
 Mississippi  Rivers would  cost  over  25  million  dollars.




 Furthermore,  according  to  figures published  in the  19&9




 Federal Water Pollution Control  Report,  the  cost  of




 maintenance  and  operation  of these  secondary plants would




 be  approximately 1.7  million dollars  per year  more  than




 for the existing primary  treatment.




               The Iowa Water  Pollution  Control Commission




 has had no hesitancy  to require  secondary treatment of an;




waste discharge to either the Mississippi  or Missouri River




 when the need to satisfy water quality requirements is




 shown.  However,  it is  the Iowa  position that aneed far uniform




 secondary treatment of  all waste discharges  has not been




 shown and that there  is no scientific  reason to believe




 that secondary treatment  of every waste  discharge on the




 border streams will enhance the  water  quality.




               Some degradation  of water quality  is




 evident below the Omaha-Council  Bluffs area  due to  the




 low percentage of wastes actually receiving  treatment




 during this  particular  period.   It is, therefore, sug-




 gested that  additional  water quality studies be conducted




 following completion  of the meat packing plant pretreatmei




 facilities to permit  evaluation  of Missouri  River wat&e*
-------
	56 o





                    R. J. Schliekelman






 when receiving primary treated effluents from the city



 of Omaha.




                The next section is on disinfection.




                At a meeting on February 9,  1968,  with Robert




 S. Burd,  Director of the Federal Water Pollution  Control




 Administration Water Quality Standards Staff,  Iowa agreed




 to adopt  definite numerical bacteriological .limits compatible




 with the  National Technical Advisory Committee recommen-




 dations for  waters used for public water supplies and




 primary contact recreation, namely swimming and water




 skiing.   The Department of  the Interior further agreed




 that the  standards would recognize these values as




 applying  during dry weather,  but will state that  all




 reasonable efforts will be  made to reduce bacteria con-




 centration increases during periods  of stormwater runoff.




                The Iowa Water Pollution Control Commissio




 at its April ^,  1968,  meeting adopted a motion accepting




 these provisions,  and the Iowa water quality standards




 have been revised to include  the following  numerical




 ["bacteriological limits:




                Public water supply.   Numerical bacterio-




 logical limits  of 2,000 fecal coliforms per 100 ml for
-------
	56i





                   R. J. Schliekelman






 public water  supply  raw water  sources will "be




 applicable during low flow periods when such bacteria




 can be demonstrated  to be attributed to pollution by




 sewage.




               The same terminology applies to recreation




 use, except the bacteriological limit is specified as




 200 fecal coliforms  per 100 ml.




               The water quality criteria and plan for




 implementation and enforcement for the surface waters of




 Iowa was adopted by  the Iowa Water Pollution Control Com-




 mission in May 196?  and this plan did designate the




 surface waters to be protected for public water supply




 use as well as the recreational use areas on lakes,




 impoundments and rivers.  The treatment needs in the




 plan specified coliform reduction or effluent disinfec-




 tion by the municipalities to protect this use during




 the recreational season.  Information obtained from other




 State agencies and information at the public water




 quality hearings were used to designate these recreational




 areas, and the plan  does specify for interior municipalit:




 chlorination where necessary to protect these uses.




               The State of Iowa therefore feels that
es
-------
                                                      562
                   R. J. Schliekelman
acceptable bacteriological criteria have been established




for interstate waters in Iowa.   These criteria are com-




patible with criteria from adjoining States which have




been established for public water supply and recreation.




These other States also generally specify or take into




consideration the effective land runoff and are also




applied when necessary to protect specific water uses.




               Land runoff does contribute high bacterio-




logical densities, and bacterial studies in the State of




Iowa and elsewhere have shown that commonly acceptable




coliform levels have been greatly exceeded even in the




absence of wastes attributable to human sources. The




following is quoted from a long term study of total




coliforms in the Iowa River at Iowa City, Iowa:



              "if a stream contains coliform organisms




that are of domestic sewage origin, one might expect




the MPN to vary inversely with the dilution capacity of




the stream.  High MPN values would be expected during




the dry seasons."



               Quoting further:




               "in the Iowa River, increases in stream




flow are accompanied by increases in both turbidity and
-------
                                                      563
                   R. J. Schliekelman
coliform organisms.  This pattern has been apparent over



the entire 1950-1964 period and is true whether one



examines daily or monthly average data.



               "Apparently, large numbers of coliform



organisms are carried into the river after each rainfull



and snow melt.  The increase in turbidity also indicates



the agricultural land adjacent to the river as the source



of many of these coliform organisms.  Storm sewer overflow



is not considered a significant factor, because the



nearest upstream city is 30 miles above Iowa City and



above the impoundment.




               "in view of the apparently high numbers



of nonfecal coliform organisms and the correlation of



high coliform densities with high flow, one might questior



the significance of such MPN data as related to the



bacterial safety of the Iowa River water.  Does a high



MPN, especially a high monthly average which may be



caused by runoff from a single rainfall, mean that this



water is an undesirable source?  Probably not."




               We have made some estimates on the cost of



continuous disinfection or chlorination of municipal




treatment plant effluents of 77 municipalities  which are
-------
                                                      564
                   R. J. Schliekelman
located on interstate streams in Iowa.  It is estimated




that the construction and equipment costs for these 77




municipalities,which are located on both the Missouri and




Mississippi Rivers as well as interstate streams, would




cost approximately 2.4 million dollars and the annual




chlorine cost would be in the neighborhood of about




$850,000.




               The expenditure annually of these large




sums of money required for year-round disinfection of




municipal and industrial wastes as recommended by FWPCA




will not improve the bacteriological quality of inter-




state waters during periods of runoff, and these are the




periods when high bacterial levels have been found.  The




Iowa Water Pollution Control Commission has agreed to




disinfection of these waste discharges,ones that can be




expected to affect recreational or public water supply




uses .




               The Missouri River is considered as being




unsuitable for whole body contact recreation, and this




precludes the need for disinfection to protect this




particular use.  The one possible need for disinfection




would be in the Sioux City area to protect downstream
-------
                                                      565
                   R. J. Schliekelman
water supplies.  However, that need, as demonstrated by




the Federal Water Pollution Control Administration water




quality report, appears to be rather borderline and the




study covered a relatively brief period of time.  There-




fore, before definitely establishing a compliance require




ment and making the large expenditures that will be




required, additional study should be undertaken to more




accurately determine the coliform densities and sources.



               Temperature requirements will be covered




rather briefly by Mr. Harrison of the State Conservation




Commission.



               We apparently are in agreement on the non-




degradation clause and this will not be covered this




morning.



               Phenols were also discussed yesterday by




Dr. Morris.  I don't know if Dr. Gakstatter will comment




a little bit more fully on this or not this morning.



               Radioactivity was also described yesterday




and I think our position is that we are acceptable to the




Federal requirements on this particular phase of the




recommendations.




               I  believe that is our summary, then, of
-------
                                                      566
                    Dr. J. Gakstatter
the position.




               MR. STEIN:  Do you want to introduce your




next speaker?




               MR. SCHLIEKELMAN:  Dr. Gakstatter, would




you want to present your portion of the statement?








              STATEMENT BY JACK GAKSTATTER




          PRINCIPAL LIMNOLOGIST, STATE HYGIENIC




              LABORATORY, DES MOINES, IOWA








               DR. GAKSTATTER:  Mr. Chairman, ladies and




gentlemen.



               My name is Jack Gakstatter and I am Prin-




cipal Limnologist for the Des Moines Branch of the State




Hygienic Laboratory.  I would like to begin with some




comments of the FWPCA biological study.



               The manner in which the biological data




was presented did not deviate from the rest of the Federa




report.  Conclusions were not objective and pertinent




facts were buried which tended to create the illusion




that Iowa is a major polluter of the Missouri River.




               The FWPCA summary, and this in part M
-------
                                                      567
                    Dr. J. Gakstatter
on page II-3, regarding the biological study states the




following, and I quote:




               "Biological investigations revealed pre-




dominately clean water organisms and associated aquatic




life above Sioux City.  However a consistent increase in




pollution tolerant organisms and biota were observed in




many stretches of the river between Sioux City and St.




Joseph. "




               This statement leads one to believe that




all is well above Sioux City, whereas the Missouri down-




stream from Sioux City is polluted.  If the data, and




this is on Table B-2 of the Federal report, is examined




objectively, it is obvious that this statement is mis-




leading.




               The fact is that the study showed little




difference in the biological quality between station 736




and 730--these are river mileages,  station numbers are




M-52 and M-50--above the Sioux City sewage 'treatment




plant discharge,  whereas every sample taken in the first




74 miles  below the Sioux City discharge definitely




demonstrated a biological fauna which was superior in




quality to that observed upstream from Sioux City.
-------
                                                     568
                    Dr. J. Gakstatter
stoneflies, which are noted for being extremely pollution




Intolerant, were found at three stations downstream from




Sioux City, while data indicate that no stoneflles were




found above Sioux City. Likewise there was a greater diversity




of mayflies in the first 7^ miles below the Sioux City di




charge than there was above Sioux City.  Mayflies are als




pollution intolerant organisms which require high water




quality.  The FWPCA data, also on Table B-2, demonstrate




that pollution intolerant forms were present in greater




diversity in the first 7^ miles below the Sioux City dis-




charge than above it.  This is not a claim that the treated




waste discharge from Sioux City enhances biological quality




in the Missouri River,, but merely points out that the bio




logical quality was not deteriorated at these stations




by the Sioux City discharge.




               It is stated in the Federal report, page




B-l, that severe degradation of the bottom associated




organisms occurred for 5^ miles downstream from the Omaha




Council Bluffs area, and that floating solids, this refer




to grease and chunks of animal fat, were observed for




166 miles downstream.




               It is interesting to compare the waste




contribution of Omaha, Nebraska, and Council Bluffs, Iowa
-------
                                                      569
                    Dr. J. Gakstatter
This can be readily done by a few simple calculations




using the data given on page IV-24 of the Federal report.




Omaha, Nebraska, discharges 1,801,6^0 population equiva-




lents to the river, or 46 times as much as the Council




Bluffs 39,000 population equivalent discharge.  Omaha's




waste load to the river thus exceeds the sum total waste




load discharged by the 20 Iowa municipalities (including




industries) which are located on the Mississippi River.




               Eighty-eight percent of Omaha's raw waste




load receives no treatment or, in other words, is discharged




directly to the Missouri River.  All of the Council Bluff




waste receives primary treatment.




               It is therefore not at all surprising that




the Missouri is biologically degraded for 5^ miles below




Omaha, nor is it surprising that grease balls are found a




far as l66 miles downstream.  However, these conditions




can hardly be attributed to Council Bulffs.




               Now I have some comments regarding parts



L and 0 in the Federal summary, which are found on page




II-3.  Part L states, and I quote:




               "Survey results from the main stream of th>




Missouri River in Iowa identified adverse changes in wate:
-------
                                                      570
                    Dr. J. Gakstatter
quality.  Turbidity increased fourfold in the length of




reach surveyed and cyanide and phenols were found."




               It is true that phenols were found in the




Missouri River.  However, the Federal report failed to




mention in the summary that the maximum observed phenol




concentrations in table number A-5 did not change from




station M-52, which is located above Sioux City, and




station M-38, which is located below the Omaha-Council




Bluffs area.  These maximum levels, which showed no




relation to waste discharges, were two parts per billion,




which is twice as high as the suggested FWPCA standard




one part per billion.  These data further substantiate




Iowa's position that the phenol concentrations resulting fr




natural degradation products often exceeded the FWPCA



standard of one part per billion, and that this standard




is therefore unreasonable.



               During the January 1969 FWPCA survey,




turbidity values were shown to decrease from 19 units




above Sioux City to 8 units below the Omaha-Council




Bluffs area.  During this period stormwater runoff was




minimal and these data show that the sewage treatment




plant discharges had no effect on the turbidity of the
-------
                                                      571
                    Dr. J. Gakstatter
Missouri River.  High turbidity in the Missouri is caused




exclusively by land drainage and that subject is not




relevant to this conference.




               Cyanide concentrations up to 15.2 parts




per billion were measured in the Missouri River.  These




concentrations given in Table A-5 of the Federal report




bear no apparent relationship to municipal or industrial




discharges.  12.2 parts per billion of cyanide were found




above Sioux City while less than one part per billion was




found below the Omaha-Council Bluffs area.  In no case




was the Iowa aquatic life standard of 25 parts per billion




of cyanide violated.




               Part 0 of the report states, and I quote:




               "Public water uses relying on the Missouri




River as a source of supply report problems associated




with turbidity, ammonia, coagulation, taste and odors."




               These are common problems of most surface




water treatment plants, whether or not being affected by




upstream waste discharges.  We have already established




that turbidity problems in the Missouri are not caused




by waste discharges but by land runoff over which we have




no control.
-------
                                                      572
                    Dr. J. Gakstatter
               Sewage treatment plants are designed to




eliminate settleable materials and organic carbon, not




ammonia.  Waste effluents from secondary treatment plants




contain concentrations of ammonia which are many times




greater than concentrations in the average receiving




waters.  Nevertheless, increased ammonia concentrations




in the Missouri and in other Iowa streams are generally




the result of agricultural land drainage and not sewage




treatment plant discharges.  This is substantiated by the




fact that 85 percent of the Missouri River stations had




greater ammonia concentrations during the runoff period




than during the period of normal flow, and this could be




verified in Table A-3 of the FWPCA report.




               Finally, in conclusion, it has been widely




recognized by Iowa that taste and odor problems frequentlj




are encountered during periods of surface runoff, particu-




larly in late winter and spring.  However, again this is




something which isn't related to sewage treatment plant




discharges.



               That is the end of my statement.




               MR. STEIN:  Thank you.




               Who is next from Iowa?
-------
	573





                      H.  M.  Harrison






                MR.  BUCKMASTER:   Mr. Harrison








              STATEMENT BY HARRY M.  HARRISON




            IOWA STATE CONSERVATION  COMMISSION




                     DES  MOINES,  IOWA  .








                MR.  HARRISON:  My name  is  Harry M.  Harri-




 son.   I  work  for the Iowa State  Conservation Commission.




 I  have  been employed by  that  agency for 23  years.   Seven-




 teen  years  of that  time  was spent in the  field as  a field




 biologist.




                I would like to  say  to  begin with,  ladies




 and gentlemen,  that I am very, very happy to be here this




 morning.  My  interest in wildlife and  fisheries goes way




 back  to  my  youth, and in this time  I have spent a  lot of



 time  in  the rivers  of this State, much of it without the




 protection  of  a bathing  suit.  After -listening to  Mr.




 Geldreich's report  yesterday, and considering the  exposur*




 that  I have had to  pathogens, added to the  good will that




 I  heaped on myself  over  at Davenport last week,  I  should




 say that I  am  happy to be any place today.




                (Laughter.)
-------
                     H. M. Harrison






               I heard a talk Monday of this week by a




reputable sanitarian, and he mentioned that the big prob-




lems in this day are really caused by very little things,




and then he went on to mention the ovum, the atom, a




little bit of skin pigment, and to that list I would




like to add one more thing, pathogenic organisms in flow-




ing water.




               Over at Davenport I began my remarks with




words to the effect that I was accusing FWPCA of practic-




ing legerdemain with biological facts and statistics to




create some illusions that were misleading, confusing,




had very little basis in fact, and not germane to the




conference. This about sums up my impression of the




present conference.




               With that, I would like to wade in--excuse




me, discuss with youj  I don't want to wade into anything




any more (laughter)--discuss with you some of the dis-




cussion here that we had with temperature.




               I am not sure that the people that dis-




cussed temperature were familiar with the facts as they




are in this day«  We have no dispute with FWPCA on tem-




peratures in the Missouri River.  This was settled before
-------
                                                      575
                     H. M. Harrison
the time of the conference.  ¥e have no dispute with the



maximum temperature.  This was decided before the con-




ference.  The dispute that we have involves whether or



not we should permit or whether or not a difference or



an increase in 5 degrees or 10 degrees will protect




aquatic life in Iowa.



               It is my considered opinion that 10 degree^



will protect aquatic life.  I would, therefore, point out



again that the other discussions are really not germane,



but there is one thing that I would like to call atten-



tion to. The data was cited that the preferred tempera-




ture of smallmouth bass was 82.^,  for the yellow perch



it was 75.6 and for the green sunfish it was 8l.2.  I



guess I kind of favor the green sunfish.  My preferred



temperature is 8l.3«  How about that?



               (Laughter.)



               MR. STEIN:  Mine is 96.8.



               (Laughter.)



               MR. HARRISON:   Now  there have been some



other illusions that our fisheries populations in Iowa




are suffering from pollution  and probably in jeopardy,




and I would like to clarify some of my remarks or some
-------
                                                      576
                     H. M. Harrison
of the things that I think were misinterpreted over at



Davenport by citing a little history.




               Back in 1886 to 188? a gentleman by the



name of Seth Meek traveled through Iowa and collected



fishes at various places in the State of Iowa.  I have



his publication and have looked at it many, many times.



In 19^-0 Dr. Reeve Bailey, a fishery scientist of great



renown, retraced Mr. Meek's steps and collected in the



same area.  I followed Dr. Bailey with my collections



in 1950, and I have people assigned to me  today that



will do this work again in 1969 and 1970.  So we have



some idea of what the fisheries picture is in the whole




State of Iowa.



               I might point out that my own collections



in the 1950's, 1951 and 1952, amounted to about 1,000



collections in various places in the State of Iowa.



               We know pretty well what the distribution




by species is, and some of the facts that were stated




here yesterday were facts, but they were not complete.



We know, for instance, that in the Missouri side of the



State of Iowa that there are probably in the order of



75 different kinds of fish.  In the whole State there are
-------
                                                      S77
                     H. M. Harrison
140.  It depends upon the taxonomist how they want to




split them up.  It may be l4l or 1^2, but to come to




some of the differences you have to count the number of




scales that go around the body and if it is 13 it is




one fish and if it is 14 it is another.  I could never




figure out myself what difference that made to anything




except another fish of the same kind.




               But I did point out over at Davenport




that this was a channel catfish and carp State.  I assume




that the people In the audience knew that I was referring




to the species of fish that are of importance to the Iowa




angler.  The Iowa angler doesn't care anything about a




brassy minnow or a golden shiner.  These are of interest




only to me and a few other people.




               Dr. Tarzwell yesterday made a statement,




and I don't think that we can really argue with it too




much,  that evolution has set the stage for the present




fish populations.   To a degree this is true.   However,




the fish populations that were in Iowa at the turn of




the century must have received a shock when the white




man started plowing the ground,  straightening the rivers,




and so forth,  and  although evolution may have set the
-------
                                                      578
                     H. M. Harrison
scene, the fish populations that exist in Iowa today are



here because of habitat and habitat alone.




               The habitat in western Iowa has been



destroyed, particularly in the Missouri River, by



channeling, straightening, and so forth.  ¥e do not have



a species, to my knowledge, in our State that is adapted



to life in the Missouri River.  Now, that does not say



that some fish don't get by and that some fish do not




reach fair numbers there.  But the Missouri River in



this day is a millrace.  Now, there may be a fish some



place in the world, a species, that we could import and




put into the Missouri River that would make a good



species for that river.  I don't know what it is.  If



anybody does, why, we would be glad to know about it.



               The streams in southwestern Iowa, starting




with the lower reaches of the Little Sioux, the Maple



River, the Boyer, Nishnabotna, the Nodaway, the Tarkio,




and other streams that were named, have all been straighte




between—well, before 1920.  Fish populations in those




areas are really not too good.



               Now, we do have good fish populations in




some of our artificial impoundsments and some of the othe
ed
-------
                                                       579
                     H. M. Harrison
 streams  in  the  slope  that  drains to  the Missouri River.



 I would  call your  attention to some  of the work that is



 carried  on  by my department on the Little Sioux River.




 This is  considered one of  the better catfish  streams in



 the United  States.  We have done life history studies out




 there on the channel  catfish, population estimates, and



 so forth, and in some of our tagging experiments one of



 our biologists was  able to capture about 5,000 channel



 catfish  one summer, tag those fish and release them to



 study their movements.




               Our  fish hatchery that specializes in the



 production of channel catfish goes to the Missouri River



 or did for three years in a row to get the brood fish for



 the hatchery.  They take about 1,000 brood fish per year



 from the river—they took these out of about  a three-mile



 stretch  of the river--to our hatchery to propagate channe]



 catfish.  I think this indicates  something of the quality



 of the fish there that they could go in and take brood fi



numbering nearly a thousand out of perhaps three miles of



 stream.




               In another study that we conducted over



 there  with  respect to  movement, we  transported channel
-------
                                                      580
                     H. M. Harrison
catfish from one area to another to see what would happen




to them.  In this project we were able to capture below




a little stabilizer, which is another way of saying a




low head dam, I guess, 10,000  channel catfish in less




than a month's time.  We moved those fish upstream in the




Maple River to a little town of Ida Grove and released




them to see what would happen. It might be of interest




to you to know that the returns that we got were right




back to where we picked them up in the first place, and




it points out the fact that habitat is very important in




fish  life.  They just didn't have the habitat up there




where we stocked them, so they turned on their tails and




returned to where they could find habitat.




               There has "been some thought, I think, or



some illusions that secondary treatment might enhance




fishery populations in western Iowa.  I doubt very




seriously that secondary treatment would do anything for




the fish populations out there.  Again you have the prob-




lem of habitat and it just won't get the job done.




               I scribbled these notes down this morning




and I want to make sure that I get everything.




               I would like now to go to the discussion
-------
                                                      581
                     H. M. Harrison
on commercial fisheries.  Some mention was made about the




catches of 1901 as compared with 1969.  .1 don't believe




this can be a valid comparison for a couple of reasons.




We have had lots of changes since 1901 to  19^9«




               I would also point out to you that the




catch statistics reported upon are collected by people




that work for me, and the reason that we collect these




statistics is because the code of Iowa requires us to.




We have absolutely no confidence in the data that we get,




and the reason is that commercial fishermen just do not




report their catches.  They operate out of their hind




pocket, and if they can pick up $10 here and $10 there




and do not have to report it as an income, why, that is




just a little more for them.




               To offer a simple answer to a complex



question,  I discussed this last week and I don't think




there is such a thing as a simple answer to a complex




question.   It has been suggested that pollution is the




reason for the drop in the catch of commercial fish.   I




submit another simple answer now.  I think that the




reduction in commercial fisheries catch in the Missouri




River is inversely proportional to the income  tax  schedule's.
-------
	582





                      H.  M. Harrison






                Taste  and odors.  I  am not  aware that we




have  a  real  significant  problem  with taste  and odors  in




fish  populations  in the  Missouri River, and I do not




wish  to  discount  the  testimony that was offered here




yesterday.   Some  gentleman named two fishermen, I believe




that  had to  throw away fish  because of taste and odor




problems.  I can  understand  and  believe this, and I am




sure  that it does happen from time to time.  However,  if




taste and odors was a very,  very significant problem  in




the fish flesh, I am  sure that I would be aware of this.




This  sort of thing comes directly  to my desk, and in  the




time  that I  have  been in the Des Moines office, five  and




a  half  years,  I don't believe that I have ever had a




complaint, at least a written complaint,  of the problem




of taste and odors in fishes from  the Missouri River.



                Our department is also concerned somewhat




with  water-based  recreation, not my department in particu




lar,  but our Commission, and I would like to call your




attention to one  other thing that  has been  touched on by




Mr. Schliekelman. I  don't believe that if  you had dis-




tilled  water running  down the Missouri River it would be




much  of a place for outdoor  recreation.   The Missouri Riv
-------
                                                      583
                     H. M. Harrison
is a hazardous body of water, and most certainly I




wouldn't put my small children out there with a pair of




water wings and tell them to go swimming.  It just doesn'




lend itself to this type of recreation.  We will hope tha




some things that the Corps of Army Engineers have in




mind will become a reality some day and we will have




some impounded waters beside the Missouri River,, and this




is where we will send our people to water ski and swim,




and so forth.




               In closing, I would like to repeat pretty




much something that I said over at Davenport and point




out to those of you who were not over there last week




that I am not  a member of the Iowa Water Pollution Contro




Commission.  I have had the privilege to keep a watchful




eye on them to see what they are doing, and I have come t|D




some conclusions about them that I think everybody ought




to be aware of.




               This is not a troop of boy scouts nor is




it a fraternity of do-gooders.  These are dedicated men,




they come from a broad spectrum of our society,  they are




competent and  they are aggressive.  I have seen them take




on many, many  problems of pollution in the State of Iowa
-------
	584





                     H. M. Harrison






and work them out and correct the situation.



               I would like to mention something about



the competence and dedication of these men.  You heard



Dr. Morris yesterday.  He is a very, very fine scientist.




The State of Iowa employs him to head up their State



Hygienic Laboratory.



               This is no small responsible job.



               Mr. Buckmaster is a successful businessman




an attorney, and he has taken a lot of his time to serve



on this board.  And for those of you that are concerned



about conservation, I don't think that Mr. Buckmaster



really got into pollution first and foremost because of




pollution but because he was a smallmouth bass fisherman



and he thought maybe something is happening to the waters



of Iowa that he could correct.



               These other gentlemen represent State



agencies. They head up State agencies. They are success-



ful farmers and businessmen. They represent cities and




towns, and so this organization is taking care of pollu-




tion in Iowa.



               Now, if the Great White Father in Washing-




ton isn't resting easy because he thinks the people in lo
a
-------
                                                      585
                     H. M. Harrison
are wallowing in some squalor  out here, you people when




you go back tell them it isn't so, that these people take




care of pollution in Iowa and I am sure we will all get




along fine.




               Thank you.




               MR. STEIN:  Thank you.




               Is there anyone else from Iowa?




               MR. BUCKMASTER:  I might make a few remark




               MR. STEIN:  This is off the record.




               (Off the record.)








             STATEMENT BY ROBERT BUCKMASTER




         CHAIRMAN, IOWA WATER POLLUTION CONTROL




              COMMISSION, DES MOINES, IOWA








               MR. BUCKMASTER:  Mr. Stein, ladies and




gentlemen.




               I will jump around and cover some things




and try to  sum up Iowa's position.  I always talk extem-




poraneously and sometimes worse, and I will probably do




that on this occasion.




               As I indicated in Davenport, Mr.  Stein,  I
-------
                                                      586
                      R. Buckmaster
am deeply appreciative of the many courtesies that you




as hearing examiner have extended to us in Iowa in pre-



senting our views.



               I am, as indicated there,  deeply concerned



about the public's reaction as a result of press stories-



I am not critical of the press for this--of what it has




done to Iowa's position nationally and in the State of



Iowa.  Some of us who worked most of our lives fighting




pollution are now being attacked by former friends who ar



quoting from the New York Times, other periodicals and



Iowa periodicals, saying that Iowa has the worst pollu-



tion situation in the United States.  You know and I know
it isn't true.
               What this conference is about is a differe
of opinion on the matter of attacking the problem,  but it



has resulted in putting us in the position of being the



fellows with the black hats and you are the great white



knights in Washington who are saving Iowa for posterity.




               I think the people of Iowa should know, an



I think some of them do, that we need no experts from any




place to come out and lecture or instruct us on the value



of the Mississippi and the Missouri River to this State.
ce
-------
                                                      58?
                      R. Buckmaster
Nor do we need any instruction on the values of wildlife



or the necessity of maintaining our environment.  Nor do




we need any instruction on the fact that pollution




destroys these values.  We have no difference of opinion



on this.




               I think our record in Iowa, going "back



for a good many years, indicates that lowans are deeply



concerned about this and have expressed their concern in



having adequate treatment of industrial and municipal



wastes, and as your own figures show, Iowa leads all the



States in the United States in the percentage of people




having treatment of municipal wastes.



               As a matter of fact, just so we get the



record straight, your figures, in which you use the term



urban population, show that there are approximately



1,500,000 people in Iowa who live in urban areas with



sewage treatment.  Now, I don't recall presently whether



you use the figure 2,000 or 2,500 in defining an urban



area.   Your figures show that in every one of those we



have treatment.  We are the only State that has 100 per-



cent treatment of urban sewage,




               Let me add to that some other figures.
-------
                                                      588
                      R. Buckmaster
¥e have a number of small towns in the State of Iowa




that are under 2,000 or under 2,500, a large number.




As a matter of fact, another 400,000 people in Iowa live




in towns that are not called urban in your figures.  Of




those 400,000 people that live in cities and towns with




sewers, and these go down to even a couple of hundred




people, all but 13,000 have at the present time sewage




treatment, and that other 13,000 that live  in small town;




are now under orders from our Commission to have treat-




ment and are either in the planning process or the con-




struction process.



               So you can say that every town, every city




whatever population, in the State of Iowa, with the




exception of the total of 13,000, now has treatment and




they are now under  construction, which gives us 100 per-




cent.  There is no  other State that I know of that can




boast this kind of  a record.



               Let  me give you something else about that.




Iowa has no State aid to cities, towns and municipalities




for the construction of treatment plants.  The only aid




that they have received is the 30 percent from the Federa




Government, and I know of small towns in Iowa who have
-------
                                                      589
                      R. Buckmaster
voted bonded indebtedness in the area of $2,000 per home




in order to have treatment, and many of them run in the




area of $900 to $1,200 per home.




               Yes, I am a little emotional that we are




selected, Iowa, as the culprits and when we have been




given national and local publicity so the people think




we are not doing the job in Iowa.




               I don't want to give the impression that




we don't have problems.  Some plants are not properly




operated, some need additions, some need new plants.




But we understand this.  It will be taken care of.  And




I don't mean to imply that we don't have problems on




both the Mississippi and on the Missouri River, although




I think the Missouri is minor compared to our others.   Bu




if we are talking about the main thrust, I feel very




proud of the job that Iowa has done and is doing.



               Let me jump around to a couple of other




things.  One thing I want to mention.   Mrs. Koerber




yesterday from the League of Women Voters, I am sorry




she is not here today, asked a very penetrating question,




and she is entitled to an answer.  As  a matter of fact,




I thought she asked a more penetrating question and made
-------
                                                     590
                      R. Buckmaster
a more penetrating point than all the staffs of Chicago




and Kansas City and Washington with the engineers, the




sanitation people, the scientists and the lawyers.  In




fact she, I think, deserves an answer.




               Her point was, in looking at our total pro




gram for water quality criteria and its implementation,wh




is the provision under General Criteria.  Now,  we said:




               "in general, those small intermittent




streams experiencing low or zero flows or which cannot




under natural conditions support a permanent fish popu-




lation, will have their quality governed by the General




Criteria.  It is the intent of the General Criteria to




protect the water quality in these areas for the legiti-




mate uses to which they are presently being used."




               I don't believe in her statement she gave




the first sentence that starts out what streams we are




talking about.




               "Legitimate uses in this category are




those such as: irrigation, livestock watering,  wildlife




propagation, etc.  To protect these uses on low flow




streams, the wastes will be given the highest prac-




ticable degree of treatment without respect to  dilution
-------
                                                      591
                      R. Buckmaster
in order to prevent the development of nuisance or




health problems below the discharge.  The requirements




are such that the effluent will be suitable for limited




downstream use.  Treatment less than secondary will not




be accepted unless it can be shown that the legitimate




uses can be protected with a lesser degree of treatment."




               Her point was if you can require in that




case secondary treatment, and the proof has to be on the




other people (it isn't required), why can't you do the same




thing generally.  And on the face of it this is a legiti-




mate thrust.




               But what we were covering there and which




is clear, I think, to anybody that has gone into this,




we were talking about streams,  and there are about--!




think out of 510 treatment plants in the State of Iowa




there are about 160 treatment plants on areas that can




support warm-water aquatic life.  These are the larger




streams.




               Now, the balance of these are on inter-




mittent streams, and at low flow there may not be any




water in them at all.  In fact, the only flow may be the




sewage effluent.  And, therefore,  it was our judgment
-------
                                                      592
                      R. Buckmaster
that on the basis of nuisance conditions, as a matter of




public health, on that type of stream we could require




secondary treatment to meet the criteria of nuisance and




health requirements, not to support  -because they couldn'-




meet the water quality standards no matter what they did.




It doesn't change our basic jurisdictional requirement




that treatment has to be such as to protect the water




quality criteria.



               Again, just to summarize, as I understand




the Secretary of the Interior's order of January which




approved our standards, which was 99-99/100'th of what we




did and accepted certain areas, I just want to go back




again and get it focused what we are talking about here a




I understand it. I won't get into radioactive, phenols,




and so on.  We all understand that.




               There are two areas in addition to the




secondary treatment matter.  One is the area of disin-




fection.  We stated our position in Davenport, state it




again. On those interior streams that we are talking




about in this hearing, and regardless of interstate or




intrastate, we will require disinfection by chlorine the




year round where it is used for public water supply.
-------
                       	393





                      R. Buckmaster






In those areas defined as recreational area we will do




it seasonal.




               Again because there are some people here




locally that didn't hear the presentation at Davenport,




it is the judgment of the Iowa Water Pollution Control




Commission that in the months other than May through




October there is no water contact sport in Iowa. Again




as I stated in Davenport, if you will check with the




Federal meteorologist you will find that in those months




in Iowa we do very little swimming, water skiing or




anything else that has to do with body contact in water.




               This is not Florida, and as you indicated,




consistency is the hobgoblin of mediocre minds.  The way




I heard it was it is the hobgoblin of little minds, but




I guess we are talking about the same thing.  Consistency




in this, it seems to me, is a hobgoblin and the condition




are different.  We do not propose to protect for recrea-




tional uses while the streams are frozen.



               Now, on the Missouri River on disinfection




we have a different position.  We are not convinced that




disinfection is required on the Missouri River.  We don't




think that your studies show it, because they are
-------
                                                      594
                      R. Buckmaster
non-selective.  I don't want to get into this whole thick




other than I think that if there are means, as your exper



indicate, to differentiate and determine the source of



these, then why in the hell don't we do it.  Base the



judgment on what that study shows, and on that you will




have no problem with us.  We will meet the water quality



standards if the area in which we control is what is



causing them.  ¥e do not believe from an examination of



the preliminary data collected by your people this




establishes that.  This in general is our position on



disinfection.




               Let's go back to temperature.  ¥e have




no quarrel--! believe it has been adopted in Missouri,



I think we have the same question involved here as we



did in Davenport--of the interior streams.  Our standard



provides for 90 degrees and a 10 degree range.  As



indicated by Missouri, and we have got the same area,




the same type of streams, their experience shows that



these extreme temperatures are pretty much the ambient




air temperature.



               Again a cursory check with any meteorolo-



gist will indicate that we have temperatures consistently
t,



s
-------
                                                      595
                      R. Buckmaster
above 95 degrees up to 100 degrees over this area all




during the summer months.  Therefore,, it seems to us that




90 degrees as a maximum is unrealistic, and for these




reasons, our own studies show the same thing in the




water temperature, that perhaps 93 is even too low, but




we go along.




               All right, so much now, as far as I am




concerned that covers our position on the areas having




to do strictly with water quality criteria.  Now we talk




about secondary treatment, and this is our difference




of opinion and I think it is our really only major area




of disagreement.




               I saw some statement from somebody, from




the Federal pollution people back along before these




hearings, about he gave the impression that the States




surrounding us adopted something different and were




pretty irritated with Iowa because we were fouling up




the whole mess.   But I have noticed,  and I am sure you




have, that the people who have given  formal statements




from other States haven't taken that  position in regard




to secondary treatment.     I recall  for your con-sidera-




tion the statement from the State of  Illinois,  with whom
-------
                                                      596
                      R. Buckmaster
we share a good many miles of stream, the Mississippi




River.  And they indicated, just as we have indicated,




that they didn't have any interest in what the type of




treatment was.  They were interested, as we were, in




maintaining the water quality standards.




               I think it is interesting to note the




statement given by the gentleman from Missouri yesterday




on those streams which are interstate in that they




originate in Iowa and are shown on the map and go into




Missouri, that again Missouri did not care about what




theoretical requirement was made on treatment, but they




were interested that the quality of the water be main-




tained.  So the States that have testified in both of




these hearings that are our neighbors we find have taken




the same position that we have.



               Because there are some people at this




hearing that weren't at the other. That is the reason




I am covering some of these things even though they are




in the record, and I guess your people have done the




same thing--we have plowed some of the same ground in




both hearings, Our position on secondary treatment is




this :
-------
                                                     597
                      R. Buckmaster
               No. 1. It is our judgment that the




Federal Water Pollution Control Act does not give the




Federal Government power to require secondary treatment.




In other words., our position there is that their juris-




dictional basis is in fact no different than ours, both




by the language and by the intent of Congress and by, in




my judgment, the historical common law basis for it.




Let's touch on that for just a minute because I didn't




talk about it at the other hearing.




               Any lawyer who has made any research




into the history of water pollution control knows that




the common lav; base of riparian rights to water was based




on--and 1 am putting it generally--the right to reasonabl




use of water so long as he did not adversely affect other




riparian owners.  And I think this was adopted in most




States and in our State as the basic Jurisdiction for




control of pollution.  The reasonable use doctrine could




be maintained in private action in a case at common




lav;.   In the case where you have adopted pollution contro




that the State could enforce,  where the action is not a




private controversy between two individuals,  the statutes




hold that any user of a stream had a right to reason-




able  use of that stream so long as he did not adversely
-------
                                                     398
                      R.  Buckmaster
affect other users.




               Now, this is what the whole basis  of water




quality standards is based on.   You scientifically




establish what pollution is.  As far as  I am concerned,




when you have established the standards  you have  said on




the basis of valid research that these values do  not




adversely affect any of the other uses — recreation,




aquatic life, public water supply, industrial,  agricul-




tural.  I think that about covers the gamut of  it.  And




you are required to do whatever is necessary so that




what you introduce into a stream does not exceed  these




water quality standards which have been  determined to




protect these uses.




               Now, it has never been the philosophy of




the law so far as I Know in this country — it hasn't been




in Iowa as far as I know—where we take  the other standar




or at least one other test philosophically and  say, we




are going to require everyone to give any waste the




highest possible degree of treatment regardless of




whether we can show it is required to protect other users




and regardless of the economic cost. It seems to me that




the water pollution control people have  somewhat adopted
-------
                                                      599
                      R. Buckmaster
this philosophy, that regardless of whether or not we




can show an adverse effect on users and irregardless of




the economic balance of interests, this is going to be




our test. And I think this is where we are in conflict




on these two basic philosophies.




               There is no question about the Iowa law,




in ray judgment, as I stated before, I drew the Iowa law.




I was on the Governor's committee that studied what Iowa




needed in the way of pollution laws and it came out of




our study.  Our Commission has submitted this matter to




the Attorney General of Iowa.    He has stated to us in




writing that in his judgment our jurisdictional base is o|n




preventing pollution, which means maintaining water




quality standards and that we have no power to require




any specific type of treatment other than our ability to




show that that is required to maintain those standards.




This is the legal base for our Judgment.




               Now, the basis for our judgment on the




merits is that neither our studies, which admittedly are




sketchy, nor your studies, which on the Mississippi




River are no better--in some cases not as good because




we have some d&ta in 1950  better on the Missouri Riverr-
-------
                                                      6oo
                      R. Buckmaster
but neither established a case for secondary treatment




on its merits  that that would enhance the water quality,




or that it is required to mean the Iowa water quality




standards which you accept.




               You have put people on the stand here who




have stated, and I will summarize them — this is what I




think they stated—secondary treatment is better than




primary.  Well, there wasn't any reason to come all the




way from Washington to say that. I think we would have




accepted that.  It takes out more things than primary




treatment does.  Tertiary takes out more than secondary.




And if you don't have any effluent at all, it takes it




all out.  I think you can start with that as a premise




and we won't quarrel with that.




               You have also brought people in to say




that certain things can cause taste and odors in drinking




water and fish.  Well, this didn't come as any great news




to us either.  We are familiar with that.




                  What we have talked about is general




things as  "could" or "might" or "possibly1 or "have"  but very




little has been said about 'wili' or "do."




               As I indicated at Davenport and I indicate
-------
	601





                      R. Buckmaster






today, we will join with you in studies, we will do it




any way it can be done.  We don't have the people; you




have got a lot of them.  They tell me you have got 75 in




the Kansas City office and I don't know how many in




Chicago, and I have been falling all over them at both




of these hearings.  Actually,if we had spent just about




a third as much t:!me surveying the Missouri and Mississipp




Rivers as we have running around having conferences and




writing letters and doing all the folderol that has kept




us really from the pollution jobs for the last two years,




we might have some facts on which we could--




               Would you pardon me while I take this phone




call?



               MR. STEIN:  Do you want to recess now?




               MR. BUCKMASTER:  Yes, five minutes and ther




I will go another ten minutes.




               MR. STEIN:  Yes.  We will have to recess




anyway, because we have to have rebuttal and then we will




run through it without a recess after that.




               MR. BUCKMASTER:  All right.




               MR. STEIN:  May we recess now for ten




minutes.  When we come back, Mr. Buckmaster will complete
-------
                                                      602
                      R. Buckmaster
his statement, then we will have rebuttal and comments.,




and we will try to go right through with it.




                        (RECESS)




               MR. STEIN:   May we reconvene.




               MR. BUCKMASTER:  Mr. Stein, I omitted one




thing in connection with disinfection on the interior str




¥e are  at a loss to  understand--! indicated this at




Davenport and I indicate it here—that the standard which




we adopted for year-round treatment of public water




supplies and seasonal treatment of recreational areas




was accepted, we thought,  by the Federal Government,




because 1 had a letter, I referred to today, from L'r.




Burd in September of 1968 where he said that this criteri




was acceptable.  Yet we have spent, both here and at




Davenport, a good many manhours talking about something




which we thought was all over with.



               It seems to me that the Federal people




here have overlooked one requirement entirely of the




Federal Act.   I refer to the portion on what happens




after the standards improve and we get to enforcement,




The,  act  itself provides what the Secretary has to




show in order to enforce either water quality or the
ams
-------
                                                      603
                      R. Buckmaster
implementation of the program.  And again I want to




quote from the Act itself.



               "in any suit brought under the provisions




of this subsection  the court shall receive in evidence




a transscript of the proceedings of the conference and




hearing provided for in this subsection, together with




the recommendations of the conference and Hearing Board




and the recommendations and standards promulgated by the




Secretary,and such additional evidence, including that




relating to the alleged violation of the standards, as




it deems necessary to a complete review of the standards




and to a determination of allotherissues relating to the




alleged violation.  The court, giving due consideration




to the practicability and to the physical and economic




feasibility of complying with such standards,shall have




jurisdiction to enter such judgment  and orders enforcing




such judgment  as the public interest and the equities




of the case may require."



               So ultimately when the Federal Government




gets all through, both in meetings and confrontations,




and the gold stars are put behind the States that said,




"Yes, I will sometime in the future," not one bit of wate
-------
	oOJI





                       R.  Buckmaster






 has  been  improved  at  that point.   Now  comes  the  question




 of  improving  it, and  when we  come  to improve it,  the




 Act  sets  out  what  the standard  has to  be.




                It  would  seem  to me, it doesn't make any




 difference  what standards you adopt or what  plan of




 implementation,  you are  ultimately going  to  face the




 fact that it  has got  to  be proven  in court,  with the




 Act  g.1ving  what the criteria  are for the  court to take




 into consideration.   Where in this hearing,  either at




 Davenport or  Council  Bluffs,  has the Federal Government




 introduced  one  lota of evidence about  the  economic feas-




 ibility or  the  practicability of  what it proposes?   It




 seems  to  me that is a part of your burden  of proof.  I




 knew very well  it  is  going to be when  you  attempt to




 enforce it.  It seems to  me it  is  a part  of  your burden




 and  you haven't introduced any  evidence on it.




                It  is  a great  thing to  sit  in an  ivory




 tower  and dream up water  quality standards without any




 consideration to other matters  that have  to  be taken




 into consideration by a  responsible public official




 charged with  the responsibility of making  orders that




 people have to  reach  down in  their pockets and pay for.
-------
	605





                       R.  Buckraaster






                And  if  we  forget  .just  a  minute  and concede




 which  I  don't,  that we legally could  require  secondary




 treatment,  and,  number two,  that we should,  right across




 the  board,  as  a responsible  public official  let  me tell




 you  what I  would be facing as a.  matter  of  judgment.   Cur




 projections show that  on  the interior streams  of the




 State  of Iowa  in the next four years  expenditures will




 be required in  a magnitude that  will  require  a Federal suf)




 sidization, based  on  the 30 percent,  of about $13




 million.  In other  words, the program on the  interior




 streams,  which  we consider in many areas will  present us




 with a problem  in the  next four  years  and  a  real problem,




 and  I  am talking about a  problem of meeting  our  water




 quality  standards,  the Federal contribution  of 30 percent




 will be  all eaten up for  the next four  years  because  we




 get $3.4  million  a year.



                If you  take the figures, which  are $25




 million--and my experience with  these  type of  figures




 in an  inflationary  era is before you.have  got  the figures




 put  down they  have  increased--and if  we say $25 miHi°n




 today, which is  the educated guess is  the  cost of going




 to secondary treatment on the Missouri  and Mississippi
-------
                                                      6o6
                      R. Buckmaster
Rivers, we are probably talking something more in the




area of $30 million, this would take all of the Federal




contribution for the next 4 years and we would do nothing




on the interior streams.




               As a public official in the State of Iowa




charged with the responsibility of doing the most with




the dollars available to us to protect water quality




standards, I couldn't justify spending one dime on the




basis of the record that you have shown or what we know




to be on either the Missouri or the Mississippi River if




it meant depleting or cutting out the work that we think




is necessary to protect water quality on the interior




streams.



               Let me point out again that Iowa does not




have any State participation in the construction of these




facilities.  The 70 percent comes from the city or town




itself .




               I would consider it to be irresponsible




action on the part of our Commission to give a priority




to secondary treatment on the Mississippi or Missouri ove




the demonstrated need on the interior streams, and this




is entirely independent of the question of either our
-------
                                                      607
                      R.  Buckmaster
legal right to do it or the merits of whether or not it




should be done.



               So I say in conclusion that in our judgmen




the testimony and evidence that you have adduced here




does not, or even approach  showing a requirement of




general across-the-board secondary treatment.  I am also




going to concede that very well if such proper evidence




were adduced that we may have some areas on both streams




that might require it.



               So there isn't any question again about




our position. I now state that the Iowa Water Pollution




Control Commission is ready and willing to engage with




your Cepartment on definitive studies of both streams.




We are willing to jointly agree on setting up the




parameters and agree to be bound and require whatever




treatment is required to protect the water quality in




both these streams, but we do not intend to require




secondary treatment without such scientific basis, and




I think I have to say in all fairness that we intend to




pursue that position just as far as it is required.




               Thank you.




               MR. STEIN:  Thank you.
-------
                                                      608
                      R. Buckmaster
               Does that conclude the Iowa presentation?




               MR. BUCKMASTER:  I believe it does.  You




and I will now get into nits and lice, and scientists




will come up and say this and that, and so forth, and




we will go through that, but as far as I know, except




for answering some of that, we are through.




               MR. STEIN:  All right.  ThanK you very




much, Mr. Buckmaster.




               As you know, the regulations require that




we have an opportunity for comment and rebuttal, and we




intend to follow the conference requirements and regu-




lations, of course, to the letter.




               Is there anyone here now that wishes to




make a comment, have rebuttal or make a recommendation as




to standards in water quality? I just ask you to do one




thing.  I think we aired this quite a bit in Davenport




and in here.  I would hope that this would really be a




rebuttal statement and we do not bring in new material




at this stage unless you really feel compelled to do so.




               Yes.  Mr. Blomgren.
-------
                                                      609
                     C. V. Blomgren
                  REBUTTAL STATEMENT OF




                    CARL V. BLOMGREN








               MR. BLOMGREN:  Mr. Chairman, we have




listened with interest to the comments presented by the




State representatives.  ¥e respect their dedication,




professional integrity and technical competency.  ¥e




feel there are several statements in their report that




need clarification.




               We have presented documentation which




shows a greatly expanded scope of water uses when com-




pared to the two shown in Iowa's standards for the




Missouri River.  These uses must be recognized and




protected.   Nonrecognition does not reduce the hazard




to the user nor can the assumption be made that it makes




it an illegal activity.




               Recreational use of the Missouri River




is a reality.  The State of Nebraska recognizes this




use.  The Corps of Engineers projects more intensified




recreational use of the river and is planning consider-




able expenditures in the development of recreational
-------
                                                      6io
                     C. V. Blomgren
access sites.  This fact was highlighted by the statement



of Gen. Cannon of the Corps of Engineers.  The Lewis and



Clark Trail development will intensify the recreational




use by focusing national attention on the Missouri River,



emphasizing the historical significance of the river




system.  And we cannot overlook that today the States




of Iowa and Nebraska have 66 developed access sites for



recreation.



               Iowa recognizes water supply use only at



the water intake for Council Bluffs.  Yet Omaha, Nebraska



on the opposite bank from Council Bluffs uses the river



as a water supply source, and St. Joseph, Missouri, 160




miles downstream also depends on the river for water



supply.  Full consideration must be given to these other



water users through full protection of the river quality.



               Over 85 percent of the coliform bacteria



in the river during dry weather flow studies were con-



tributed by municipal waste discharges.




               The material presented by Mr. Geldreich




establishes the high degree of control of the bacterial




densities that can be obtained from properly operated




secondary treatment with disinfection. Dr. Walton
-------
                      C. V.  Blomgren






 emphasized  the  importance  of  this  control  in his




 description of  the multiple barrier  concept for the




 protection  of the water users.  The  waste  treatment




 plant  is  the first line of  defense between the wastes




 of a community  or industry  and the downstream water




 users.  This concept  is further supported  by the  state-




 ments  submitted by the Missouri River Public Water




 Supplies  Association.  The  protection of the health and




 well being of their consumers is dependent on the pro-




 duction of high quality drinking water.  With only men




 and machines standing between the river and the consumer,




 the river must be of the highest possible quality.




               Disinfection is required on a year-round




 basis.  During the warmer seasons, disinfection is




 necessary to reduce the hazard of contact with disease-




 producing agents by recreational and other users and to




 provide a more acceptable source for domestic supplies.




 During the cold weather periods,  disinfection is equally




 important.  Mr.  Geldreich discussed the bacterial  per-




 sistence at lower temperatures  fully supporting the need




 to provide all possible protection for the downstreajn
user.
               Wet weather flows do not negate the
-------
                                                      612
                     C. V. Blomgren
effect of disinfection of waste effluents.  Elimination




of potential sources of pathogenic organisms before they




reach the river is common sense.  The control of bypassin




because of storm flows or mechanical failure is an




objective of all water pollution control agencies.




               The State of Nebraska has adopted criteria




for coliform organisms.  These criteria were set to pro-




tect the river for domestic water supply and for partial




body contact, fishery propagation,  agricultural,  indus-




trial uses and others.  Basically, the coliform group




shall not exceed a geometric mean of 10,000 total  or




2,000 fecal coliform bacteria per 100 ml, based on at




least 5 samples per 30-day period.  These stream criteria




can be achieved only through disinfection of waste




I believe this question arose yesterday, Mr. Chairman.




You will recall that specific treatment requirements




calling for disinfection on the Missouri River were not




spelled out in the Nebraska standards for the Missouri.




However, the stream quality criteria dictate that  dis-




infection is essential.




               Agriculture runoff effects on the quality




of the Missouri River are now outside the scope of
effluents
-------
                                                      613
                     0. V. Blomgren
controllable standards.  The farm animal population with




an estimated 65 million population equivalent of waste




products presents a real threat, at least in part if not




in total, to the water quality of the basin.  Mr. Geld-




reich's statement concerning the pathogenic organisms




present in the excreta of animals emphasizes the disease




potential.  There are about 46,000 feedlots within the




State of Iowa, but only the larger control facilities are




State regulated.  If the larger ones can be controlled,




the smaller ones can too.




               Yesterday at the close of the FWPCA




summary statement, a question arose about the Department




of Interior'^ interpretation of the requirements for




secondary treatment on the interior interstate streams




of Iowa, and at this time I would like to again bring



Bob Burd forward for a clarification of that point,  Mr.




Chairman.
-------
	6l 4





                         R.  Burd








                  REBUTTAL STATEMENT OF




                       ROBERT  BURD








                MR.  BURD:  Mr.  Chairman.




                I would like  to make a brief  statement




 to  clarify  a  point  raised yesterday concerning the Federal




 approval  of water quality standards for  Iowa's interior




 interstate  streams.




                It was the Secretary of the Interior's




 understanding that  the standards he approved as Federal




 standards,  standards applicable to the interior streams




 of  Iowa,  included a general  requirement  of secondary




 treatment for municipal and  industrial wastes discharged




 to  these  streams.   Why did he  reach this  conclusion?




 The Iowa  standards  include the following  statements:




                "All municipalities on interior streams




 will  generally need secondary  treatment  and  some already




 have  two  stage filtration or other tertiary  treatment




 furnishing  up to 96 percent  BOD removal.




                "All industries will be required to




 provide the same degree of treatment or  control that
-------
                                                      615
                         R. Burd
is required of municipalities on the same reach of




stream.  This degree of treatment will generally be the




equivalent of secondary treatment" as a quote from the




Iowa standards.




               Furthermore, the Iowa implementation




plan, what we consider to be the action part of the




standards, supports these two statements.  It shows




that secondary waste treatment has been installed or




will be installed by all but a very few dischargers.  I




would like to quote Iowa's statement prepared for this




conference:




               "Secondary treatment will be needed, and




therefore has or will be required for all but four or




five of the  490 municipal sewage treatment plants located




on interior  streams."




               We were impressed with this record;  99.2




percent of the municipal facilities discharging to




interior streams to provide a minimum of secondary




treatment.




               On the basis of this admirable record and




the general  policy statements on secondary waste treat-




ment, the Secretary approved the standards of the
-------
                                                      6i6
                         R. Burd
interior streams, with exceptions for temperature and




the approach to disinfection.




               MR. STEIN:  Thank you.




               MR. BUCKMASTER:  Gould I answer one state-




ment he made before we get on this other subject?




               MR. STEIN:  Yes, go right ahead, sir.




               MR. BUCKMASTER:  I don't think I need to




come up there.  I think you can hear me.




               I am disturbed by the statement about agri'




cultural and animal wastes that you mentioned.  Now, we




all recognize that a great deal of the coliform bacteria




come from animal wastes.  But it seems to me you indi-




cate a real lack of knowledge about the agricultural




industry in the State.



               You keep talking about feedlots and you




give the assumption to somebody that doesn't know about




it that a great part or all of animals in the State are




in feedlots.  Well, this is absolutely not true. The




vast majority of the swine and cattle in the State of




Iowa are on open pasture and in fields, are not confined,




and the coliform come not from feedlot sources but from




animals all over our terrain.
-------
                                                      617
                         R. Burd
               And you make the statement if we could




control large feedlots we can control small ones.




Explain to me how over the whole State of Iowa, which




is all agriculture and which has cattle and swine on




pretty nearly every acre of it, the Iowa Water Pollution




Control Commission is going to control runoff from those




fields .




               MR. STEIN:  Do you want to address your-




self to that or does someone else want to answer that or




do you want to continue?




               MR. BLOMGREN:  I want to continue.




               ME. STEIN:  All right.




               MR. BLOMGREN:  Now, Dr. Morris, although




we have requested that the phenol question on criteria




will not be discussed because we felt we had some agree-




ment, there was a question from Dr. Morris and I would




like to call on our technical consultant,  Dr. Aaron




Rosen, at this time to speak to some of the points that




Dr. Morris brought up.
-------
                                                      6l8
                      Dr. A.  Rosen
                  REBUTTAL STATEMENT OF




                     DR. AARON ROSEN








               DR. ROSEN:  I understand that yesterday




it was stated that the question of a standard on phenols




is not an issue and, therefore, I am not going to say




anything as to what modification of the original pro-




posed standard has been arrived at, but rather I am




under the understanding that it includes a terminology




relating to phenols of municipal and industrial origin




as opposed to the natural ones that Dr. Morris spoke




about.  Let me point out that Dr. Morris and I are on




a number of committees in this field of organic material




in water, including especially those relating to taste




and odors, and we have no conflict at all on a scientific




basis.



               ¥e can distinguish between those materials




of natural origin of the type that he mentioned, and I




agree that what he said was a proper statement of the




source of many such materials and their occurrence in




streams.  We can distinguish between these which, as he
-------
                                                      619
                      Dr. A. Rosen






said, have, at least so far, not been reported to be




causes of taste and odor from those which he agrees are




causes of taste and odor, that is those materials of




;vaste origin.  Analytical means are available and they




are sensitive enough for the purpose of determining and




identifying quantities as low as one microgram per liter,




or in the engineers' terms, which are the ones most of




us use, one part per billion.




               There are several approaches to these, to




doing this.  I don't want to enumerate all the different




analytical methods.  I just want to mention that there




was a recent publication specifically directed to this




and specifically stating that sensitivities for the




identification and determination of phenols, by this we




mean the kind of phenols that do chlorinate and do produc




a problem, that these sensitivities range as low as one-




tenth part per billion.  So that from the viewpoint of




the chemist,a viewpoint which says we apply these criteri




to the kind of phenols that produce the specific adverse




effect, that such a criteria can be implemented in terms




of the analytical capability.




               MR. BLOMGREN:  Mr.  Chairman, in response
-------
	                             620





                      C. V.  Blomgren






 to  Dr.  Morris's  question  about  monitoring,  I will  ask




 that  this  be  placed  in  the  record  in  response  to Dr.




 Morris  and offers  cooperation in setting up a  joint




 monitoring system  and program.




               MR. STEIN:   That will  be done.




               (Which said  document is as follows:)








                        MONITORING




               Although monitoring is not an issue at




 this  hearing, we believe  the record should  show FWPCA's




 position on this matter.  We feel  that it is unfortunate




 that  Section  IV-D  of  the  FWPCA  report, dealing with




 monitoring, was  interpreted by  Dr. Morris as a criticism




 of  Iowa's  monitoring  program.




               The monitoring section of the report was




 intended to support  current and future monitoring  efforts




 of  the  Iowa Water  Pollution Control Commission.  The
                                                        cal
recommended increases in sampling frequencies for chemi




physical and bacteriological parameters at stations locat




on the ten streams cited in the report represent our




current thinking on optimum surveillance needs on streams




receiving significant ampunts of wastes.
                                                          ed
-------
                                                      621
                     C. V. Blomgren
               The FWPCA Missouri Basin Region is




actively engaged in coordinating the development of a




cooperative Federal-State-local monitoring plan.  One of




the principal benefits of such a cooperative approach




would be the elimination of duplication of monitoring




efforts and would permit greater numbers of sampling




stations to be operated as well as increased sampling




frequency.  ¥e have discussed monitoring with all of the




Missouri Basin States except Iowa.  Hopefully, we can




meet with the technical staff of the Iowa Water Pollution




Control Commission in the near future to discuss monitor-




ing needs and determine the technical and financial




resources required to carry out an effective monitoring




program.                 _ _ _




               MR. BLOMGREN:  Relative to Kansas water




quality standards, which was brought up yesterday and oar




o f this  morning by reference, we do have a commitment




from the State of Kansas, and I will quote from their



treatment requirements, a commitment for secondary treat-




ment.   I can't inform you of the status of the approval




or disapproval of those standards, but based on a letter




from the Governor of January 16, 19o93  we have a commitment
-------
                                                      622
                     C. V. Bloragren
for secondary treatment from the State of Kansas.




               Under treatment requirements in their




standards, the objective of treatment or control will




be to reduce the organic levels, oil, grease, solids,




alkali, acids, toxic materials, color and turbidity,




taste and odor products, and other deleterious materials




to the lowest practicable level.




               Mr. Schliekelman's reference to the cost




of clean waters, a sheet taken from our publication, was,




we believe, adequately covered by Mr. Prank Hall's state-




ment which went into the Davenport record.




               There were some questions that arose




yesterday with reference to bacteriological pollution,




differentiation, and Mr. Buckmaster brought them up again




this morning.  Ed Geldreich, our last technical consultan




would like to make just a few brief remarks on that and




that will be our closing.








                  REBUTTAL STATEMENT OP




                      E. GELDREICH








               MR. GELDREICH:  Mr. Chairman, as I did in
-------
                                                      623
                      E. Geldreich
Davenport, I would like for the record to comment on the




Iowa statement, on page 15 under Public water supply and




recreation,the suggested numerical bacteriological limits




They state that their "bacteriological limits are com-




patible with the National Technical Advisory Committee's




recommendation, and the values, as I said at that time,




now are compatible, but there was one phrase in there




that I would like to comment on:  "when such bacteria




can be demonstrated to be attributable to pollution by
sewage.
               There is nowhere in the recommendations of
the water quality criteria book that was put out by the




committee that so specifies or selectively narrows in on




the fecal coliform population that we are concerned with.




Just as an illustration, I would like to quote that




particular recommendation as it is on page 12 of the




water quality- criteria book:




               "Fecal conforms should be used as the




indicator organism for evaluating the microbiological




suitability of recreational waters."




               There is no mention here in any of the




phraseology that it is to be specific for pollution,
-------
	624





                       E.  Geldreich






 fecal  pollution,  from  sewage  only,  and  I would  like  to




 make that  comment.




               And  as  we  have  said  yesterday morning




 and this morning  again it was  reiterated, we are  con-




 cerned with  all fecal  pollution.  There is no need to




 go into the  differentiation of the  types of fecal




 pollution, because  we  are concerned with a hazard from




 all.   The  fecal coliform  test  is  all we need to do.




 You don't  need all  the supplemental tools that  we have




 available  for this  particular  problem.




               Thank you.




               MR.  STEIN:  Thank  you.




               Are  there  any  other  comments?




               MR.  BLOMGREN:   Yes,  I would like to speak



 to Mr.  Buckmaster's question  concerning feedlots  and




 particularly his  expression of some doubt about the  size




 of the number of  feedlots we  had  in our statement.




               This is certainly  a  problem and  I  won't




 pretend to set up a criteria  for  the control of all




 feedlots regardless of size at this time, but it  will




 take a lot of cooperative effort, undoubtedly some re-




 search and demonstration  grants could be used to  achieve
-------
                                                      625
                   R. J. Schliekelraan






this purpose.  Certainly we stand ready to assist the




State of Iowa in this.
or statements?
               MR. STEIN:  Are there any other comments
               Mr. Schliekelman.
                  REBUTTAL STATEMENT OF
                   R. J. SGHLIEKELMAN
               MR. SCHLIEKELMAN:  I might add, sir, Mr.




Geldreich's comment on this public water supply and




recreational use limits that was set up here, this




actually should follow the portion of the criteria




which we have dealing with bacteria, which is as follows




               "Water shall be considered to be of




unsatisfactory bacteriological quality as a source when:




               "A sanitary survey indicates the presence




or probability of the presence of sewage or other




objectional bacteria-bearing wastes or




               "A bacteriological survey using coliform




or other appropriate indices indicates bacteriological




concentrations significantly higher than those normally
-------
                                                      626
                   R. J. Schliekelman
found or suspected in these waters when free from pol-




lution by sewage."




               Actually this phrase that we have at the




end of this addition does not particularly apply or is




not intended to actually demonstrate in our testing




sewage bacteria. We are talking about sources where




these bacteria might be coming from. I think you have




got to read everything together.




               MR. STEIN:  Thank you.




               Are there any other comments?




               Mr. Buckmaster.




               MR. BUGKMASTER:  Since there has been




some controversy about what Kansas has done and since




a representative of Kansas is here, I would like to




have him state what their position is at this time.




               MR. STEIN:  We will be delighted.




               MR. GRAY:  Would you like to hear from me




with a few comments?




               MR. STEIN:  Yes, sure.
-------
                                                      627
                       M. W. Gray
              STATEMENT BY MELVILLE W. GRAY




           ASSISTANT DIRECTOR OF ENVIRONMENTAL




         HEALTH SERVICES, KANSAS STATE DEPARTMENT




                OF HEALTH, TOPEKA, KANSAS








               MR. GRAY:  I am Melville W. Gray,




Assistant Director of Environmental Health Services,




Kansas State Department of Health.




               As a result of passage of the Water




Quality Act of 1965, Kansas submitted proposed water




quality standards to the Department of the Interior.




At that time Kansas had 3^- primary treatment plants




throughout the entire State.  The remainder were secondarfy




treatment plants.  Since that time, through routine




programming, these have been reduced to 28 primary




treatment plants.




               The Department of the Interior requested




the State of Kansas to require secondary treatment from




all facilities and later amended this to include sig-




nificant sources and listed 16 municipalities which should




be providing the secondary treatment.  The Governor of
-------
                                                      628
                       M. W. Gray
Kansas submitted a letter to the Secretary of the



Interior indicating that with considerable reluctance




and against the advice of his technical staff he would



agree to a date of 1985 as a goal for the provision of



secondary treatment from these 16 plants.




               The Kansas State Board of Health, which



is by law the official water quality regulatory agency,



accepted the Governor's letter and attached it as an



appendage to the plan of implementation with no further




action.
               MR. STEIN: Are there any further comments
or questions?
               Mr. Rademacher.








                  REBUTTAL STATEMENT OF




                   JOHN M. RADEMACHER








               MR. RADEMACHER: I am John M. Rademacher,




Regional Director for the Missouri Basin Region, FWPCA.




               I believe that there is one significant




point that has to be made in response to Mr. Gray's




comment that the date of 1985 was a goal.  I believe as
-------
                                                      629
                    J. M. Rademacher
submitted by the Governor and also accepted by the




Department of Health or the Board of Health in Kansas




on February 7th, and I quote the submission—now, I




don't know what the status of approval or disapproval is,




but our understanding as we read this is a commitment




to secondary treatment:




               "This policy shall be applicable to all




interstate waters in the State with the provision that




an abatement timetable will be submitted to the Depart-




ment of the Interior by or before December 31* 19^9*




for the significant municipal and industrial waste




sources and further that all facilities shall be in




operation prior to completion of equivalent Missouri




River downstream facilities but in no case later than




1985."



               And, of course, the comment that Mr.




Blomgren made earlier about "The objective of treatment




or control will be to reduce the organic levels,  oil,




grease, solids, alkali, acids, toxic materials, color




and turbidity,  taste and odor products, and other




deleterious materials to the lowest practicable level."




               In our view,  this is a commitment to
-------
                                                      630
                    J. M. Rademacher
secondary treatment and a time schedule to it.




               MR. STEIN:  Are there any further comments




or questions?




               Maybe we had better cover this.  There is




one advantage to this comment period. What we eventually




do is get Gray and Rademacher up to the stand and I am




glad to see you both.




               Are there any others?  Mr. Carlson, did




you have something?








              STATEMENT BY PRANK L. CARLSON




            ENGINEER, GENESEE COUNTY, MICHIGAN




            DRAIN COMMISSION POLLUTION CONTROL




                     FLINT,  MICHIGAN








               MR. CARLSON:   I am Carlson and I am from




Genesee County in Michigan.




               I am one of the Indians that has to do




the work of producing these pollution control sewage




disposal plants, etc* like that.  We are the Genesee




County Drainage Commission.   We put in the sewer pipes,




we build the disposal plants, and we think we could make
-------
                                                      631
                      F. L. Carlson
some recommendations to you chiefs on how maybe this




could be done a little bit better and we could suggest




that you integrate a little bit with your air pollution




and land pollution and water pollution.  If this was




integrated in one big program, perhaps it would work




for the betterment of the whole solution, the whole




problem.




               I would like to make a couple of drawings




on your board here for just a suggestion on how to contro]




pollution, water, air, and so forth.




               MR. STEIN:  You know, what we are intereste




in, really, is the record.  Now,  I have no objection to




you drawing it on the board, but we have no way of intro-




ducing that in the record.  0. K.?




               MR. CARLSON:  I don't want to take too




much of your time.  I know this is probably not relative




to your particular problem here,  but I was just passing




through and I felt obliged to make a comment on it. Add




anything that you might--




               MR. STEIN:  Did you want this material




in the record?




               MR. CARLSON:  No,  I have nothing to put
d
-------
                                                      632
                      F.  L.  Carlson
in the record.




               MR. STEIN:  0. K.  Thank you.




               Are there any other comments or statements




any at all?



               (No response.)




               I think we are about to the point where




we are going to close.




               Let me make one observation from sitting




up here for a couple of days.  You know, when you look




at things carefully you see things that possibly you




don't expect in a situation.




               For example, when I got into this hotel




I thought that I was in a traditional hotel public room




that is repeated over and over again through the United




States.  For example, if you look at the decorations




on the wall, they all seem to be derived architecturally




from the late Roman period.  I think the one there over




the door, they seem to have replaced the medallion in




the middle with the seal of Iowa.  But if you look very,




very carefully at this and look at that place where they




have the seal of Iowa, you see those two figures, and




what do we have?  The legs on the two figures and the
-------
                                                      633
                        M.  Stein
feet extend outside the frame and outside the panel, and




this is something that obviously you would never get jn




the pure Roman form.




               So I think if you look hard enough, you




may find things that ordinarily are not apparent and




maybe we can do that here too.




               I would like to thank "both the represen-




tatives from the Federal Water Pollution Control Adminis-




tration in Iowa and all the other people who have




participated in Davenport and in Council Bluffs in these




conferences.




               I think the conferences have been




characterized by a clear statement of the problem.  Some




of you who have sat through both may not think it is so




clear, but I think everybody has to use Mis  own mode




of expression in getting  his  point  of view across.




Obviously, a representative of a women's organization or




citizens'  group is going to put its view forward in one




way, a State or Federal administrative official is going




to say it in another way,  the biologists and the chemists




and the microbiologists all have their way of putting




what they think their views are on the record.  What this
-------
                                                     634
                        M. Stein
has done is provide a forum where we have been able to




get these views.




               At least I have a clear understanding




of where we are going, not necessarily where we are




going but what everyone wants to say.  There may be




certain points on which the technical people in a




particular specialty may not have resolved every last




little issue.  However^ I am not overstating this when




I say Iowa and we probably can arrive at a .judgment




without resolving all these minutia.  We have enough




of the views from all the parties concerned and they




are really set forward on the record.



               I know both we and Iowa have a formidable




task ahead.  I would like to give a personal opinion on




one.  It is abundantly clear that the officials in Iowa




and the officials in the Federal Government both want




to get an  equitable and an expeditious program going




forward to assure that we will control and prevent water




pollution  and have  clean' waters in the Missouri and




Mississippi Basin.  I don't  think there is any question




about that.



                  There  is  another  point  that  we
-------
                                                      635
                        M. Stein
should recognize before this gets out of perspective.




Setting the standards, like any other one of the aspects




of the program we have, is just a tool toward achieving




these objectives.  One thing about the setting of stan-




dards, and I think this is clear, no matter how much you




refine them or how much you set the standards, by Iowa,




by the Federal Government, by any other instrumentality




of government or jurisdiction, I don't think just the




setting of standards is going to clean up water one bit.




               This is a method whereby we get to the




real problem of cleaning up water.  If we are going to




clean up water, what is necessary, and I say where it




is appropriate, is for the wastewater sources to be




gathered together in a place where they can be treated




or diverted and the water be kept clean.  What I would




hope is that the governmental agencies do not spend all




their time in this preliminary area when we have the hard




job of going out and controlling pollution.  ¥e don't




want to get the methodology to exceed the aims of the




program.  And I think it behooves us all not to get




caught up in a proceeding, however entertaining you




might think this is, without keeping the idea that the
-------
                                                     636
                        M.  Stein
real objective that we have is the preservation of the

water quality in the Mississippi and Missouri Basin in
this area.  This is the job on which we have to move

forward.
               I would hope that wo would be able to not

only come to a full agreement with Iowa, but with all the
States in the basin so that the Federal Government and

the various States can move on in concert to get the job
done.  In addition to that, as we well realize, unless we

have the  real cooperation of the municipalities, counties
and the cities, the job is going to be that much harder.
Let us not get on a sidetrack or a siding, let's not, I
hope, get into a cul-de-sac where we can't find our way
out, but let's get on with the job of providing the
cleanest possible water for the maximum number of water
uses in an equitable way so that the municipalities, the
industries, the States, and the Federal Government can

all live with that.
               With that, we will stand adjourned and

I would hope that a resolution of this problem which is

satisfactory to all parties can be forthcoming.
               'Thank you all for your participation.
                       (ADJOURNMENT)
-------
                                                                  637
                         UNITED STATES
                  DEPARTMENT OF THE INTERIOR
            FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
                        MISSOURI BASIN REGION
                        911 Walnut Street, Room 702
                        Kansas City, Missouri 64106
 IN REPLY REFER TO:
                        April  28,  1969
TO:
            Commissioner, Federal Water Pollution Control Administration
            Attn:   Assistant Commissioner,  Office of Enforcement
FROM:       Regional Director, FWPCA

SUBJECT:    Water Quality Standards Conference, State of Iowa

Attached  are  additional statements which we desire to have
included  in the official record of the Water Quality Standards
Conference, State of Iowa,  Council Bluffs session.

Copies are  being provided to the conference recorder and the
Iowa State  Water Pollution Control Commission.
Attachment
Iowa Beef Packers' Report
Bureau of Outdoor Recreation^  Statement
Nebraska Water Quality Criteria
-------
                                                                  638
                          UNITED STATES
                  DEPARTMENT OF THE INTERIOR
            FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
                        MISSOURI BASIN REGION
                       91 1 Walnut Street, Room 702
                        Kansas City, Missouri 64106
 IN REPLY REFER TO:
                        April  28,  1969
TO :        Record
FROM:      Regional Director, FWPCA

SUBJECT:   Nebraska Water Quality  Criteria

The following is a verbatim extract  from  the  "Water  Quality Standards
Applicable to Nebraska Waters," adopted by Water  Pollution Control
Council, State Department of Health, Lincoln,  Nebraska,  and dated
January 1969.

Waste water shall not degrade the  receiving waters below the follow-
ing criteria.  These criteria ....
5.  Temperature

For Class "A" Use -
And Class "B" Use -
                     (Domestic Water  Supply)
                     (Full Body Contact  Sports)
The temperature of the receiving water  shall  not  be  increased  by
a total of more than 5° F  from May  through  October and  not more
than a total of 10° F from November through April.   Maximum rate
of change limited to 2° F  per hour.
For Class
          "C" Use - (Agricultural uses  including  irrigation and
                     Partial body contact sports.
livestock watering.  Partial body  contact  sports.  Growth  and
propagation of fish, waterfowl,  fur bearers  and  other  aquatic  and
semi-aquatic life and wildlife.  Industrial.)

Trout Streams

Allowable change 5° F - Maximum  limit  65   F.

Warm Water Streams

Allowable change 5° F May through  October; 10° F November  through
April.  Maximum limit 90  F - maximum  rate of change - limited to
2° per hour.  For Missouri River from  Gavins Point Dam to  Sioux
City, Iowa - maximum temperature 85° F, allowable change 4°  F.

The classification of waters of  the State  is covered in detail
in Appendix XI of the Nebraska Standards.
                                  rf j
                                r
                                       JOHN M.  RADEMACHER
-------
TO
        OPTIONAL FORM NO. Iff
        MAY Wl EDITION
        OSA FPMR <4t CFR) toi-it.i
                                                                               639
        UNITED STATES GOVERNMENT
        Memorandum
C. V. Blomgren
Director, Technical  Support
                                                          DATE:  April 24,  1969
FROM
           Sanitary Engineer
SUBJECT:    Report on Iowa Beef Packers -  Sampling and Plant Inspection Trip,
           March 26-28, 1969

           During the three day trip,  the following persons were contacted at the
           Iowa Beef Packers'  Dakota City, Nebraska, installation:

           Henry Blumm, Nebraska Department of Health
           James Chittenden, Technical Director, Iowa Beef Packers
           David Osborn, Chemist, Iowa Beef Packers

           Pertinent details of plant  facilities and operations are listed below:

           1.  Kill period - 16 hours  - 2-8 hour shifts
           2.  Cleanup - 8 hours
           3.  Kill - 2000 to  2500 head
           4.  Total employees - 1100
           5.  Average water usage - 1650 gpm from a well system through pressure
               sand filters
           6.  Waste treatment

           Domestic Treatment  - Pacific Industrial Engineering

           This plant at the time of inspection has suspended solids of 10 mg/1
           in the contact tank.   There  was no recirculation,  no skimming on the
           final tanks and no  indication that the plant was receiving any maintenance
           at all.

           Process  Wastes

           All process wastes  go through an air flotation tank for grease and
           grit removal.   At the time of the visit,  no air was being supplied
           and no suction on the grease removal trough.   A four-inch layer of
           grease covered the  flotation tank.

           Stockyard Wastes

           Wastes from the stockyard area are  washed into two settling  basins
           designed  to remove  settleable solids with a 30 minute minimum detention.
           At the time of the  visit,  both tanks were full of  wastes and short-
           circuiting  directly to the outlet.
                 Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan
-------
                                                                          640

                                 -  2  -

 Mr.  Blomgren-—-4/24/69


 There are no BOD data available  for  the  combined wastes  from this
 plant.  A year ago,  the Nebraska Department of Health ran one set
 of samples and lost  all BOD's  because of insufficient dilution.
 At that time,  the effluent's suspended solids ranged from 800 mg/1
 during cleanup to 1500 mg/1 during kill  periods and grease concen-
 trations  were  approximately 550  mg/1.

 At the Dakota  City plant, all  wastes are combined into one main
 sewer.  Analytical values for  comparable wastes at the company's
 West Point Nebraska  plant are:

 Operation Period         Kill        Cleanup $1           Cleanup #2

 Grease ppm               364         370                 161
 Susp.  Solids ppm         404         506
 Total  Solids 7.           0.261       0.298
 Volume of Water (gal)     476,200     132,000              95,000
 BOD5                     1175        1375                 900

   Total kill for the West Point  plant is  1050 to 1100 head.

 At the Dakota  City plant, 11 samples were collected at two-hour
 intervals during the operational period  on March 27, 1969, and pictures
 were taken of  the  outfall and plant waste treatment devices.

 Plant Operation

 During the survey  period, the plant was  operating on a 13 hour kill.
 On March  27 and 28,  a perfect kill (no stoppages during kill period)
 was  obtained and with a chain speed of 163 animals per hour, this
 amounts to 2,119 head per day.  Water use during the two days varied
 from 2.5  to 2.75 million gallons per day based on pumping records on
 the  company-owned water supply.  Operations during the sampling period
were as follows:

 Start Kill                            05:25
 15 Minute  Break & Cleanup             08:30 to 08:45
 30 Minute Lunch & Cleanup             10:30 to 11:00
 15 Minute Shift Change & Cleanup      14:15 to 14:30
 15 Minute Break & Cleanup             17:30 to 17:45
 30 Minute Shift Change & Cleanup      19:30 to 20:00
Peak Cleanup Flow, Approximately      22:30

 Sampling  Operations

 During the period  from 5:00 a.m., March 27 to 1:00 a.m.,  March 28,
samples were collected from the combined waste line from the Iowa
Beef Packers plant.  These samples were air lifted to the interim
laboratory of FWPCA  in Kansas City and analysed for BOD and solids
-------
                                                                                641
                                          - 3 -
            Mr. Blomgren—-4/24/69
            according to the standard methods.  Data for the samples listed as
            3:00 a.m., March 28, were estimated to provide a complete 24-hour
            sequence.
Date
3/27
3/27
3/27
3/27
3/27
3/27
3/27
3/27
3/27
3/27
3/28
3/28
Total
Avg.
Time
0500
0700
0900
1100
1300
1500
1700
1900
2100
2300
0100
0300


Estimated .
Flow (me)-'
0.154
0.228
0.247
0.247
0.228
0.214
0.247
0.228
0.214
0.228
0.294
0.214
2.75 mgd

Temp.
25
26.5
25.5
26.0
26.5
27.0
26.0
26.5
25.5
26.0
25.5


26.0
BOD5
mg/1
386
812
1500
1285
1489
1895
1676
1616
2481
1399
1636
950

1427
Calculated
Ibs.of BODt
495
1544
3089
2647
2831
3382
3452
3072
4428
2660
4071
1693
33363

TSS
mg/1
165
530
1180
1400
1300
1760
1160
860
1080
740
1240


1038
SS
mjt/1
2.5
3.0
8.0
7.0
4.0
7.5
5.0
7.0
6.0
8.5
3.5



Grease
ppm
188

297


305








I/  Flows were estimated for each two-hour period from invert  elevations  on
    discharge line at the sampling location.   Total  flow of 2.75 mgd  agrees with
    the figure furnished by IBP officials. The 0300 sample is extrapolated data.

            Settleable solids were also run in the field using an Imhoff  Cone.
            Results of these tests are:

            0800     3/27/69    Combined Wastes               14 ml
            1000     3/27/69    Domestic Waste Effluent       10 ml
            1200     3/27/69    Combined Wastes                9 ml

            At several times during the day's  sampling,  excessive floating
            solids (meat scraps and grease) were  observed in the samples
            collected at the combined waste sampling point.

            Remarks

            We can assume that a representative raw  domestic sewage would
            contain approximately 0.167 pounds  5-day BOD/P.E./day.  On this
            basis, the IBP effluent represents  an organic load as listed
            below:

            1.   Equivalent to 200,000 population  community raw discharge.

            2.  Assuming 35 percent BOD removal equivalent  to  300,000 population
                primary discharge.
-------
                                                             642

                           - 4 -
Mr. Blomgren	2/24/69
3.  Assuming 85 percent BOD removal  equivalent  to  1,250,000
    population secondary discharge.
                                  WILLIAM J. KEFFER
-------
                                                                           643
IN REPLY REFER TO«
                                 UNITED STATES

                         DEPARTMENT OF THE INTERIOR

                         BUREAU OF OUTDOOR RECREATION
                                 MID-CONTINENT REGION
                            BUILDING 41. DENVER FEDERAL CENTER
                                DENVER. COLORADO 8O225
       D 6431
                                                                  APR 11 1969
       Memorandum
       To:        Regional Director, Federal Water Pollution
                    Control Administration, Kansas City, Missouri

       From:      Regional Director, Mid-Continent Region

       Subject:   Bureau of Outdoor Recreation Statement - Water Quality Setting
                  Conference - Iowa Interstate Waters of Missouri River Basin
                  Council Bluffs, Iowa - April 15, 1969
       Enclosed are five copies of the subject statement.  Since we do not
       propose to have a representative at the Council Bluffs Conference it
       is requested that the Bureau of Outdoor Recreation statement be read
       and entered into the record of the hearing.  We would appreciate
       receiving a copy of the hearing minutes or summary when complete.
                                     Maurice D. Arnold
       Enclosures
-------
                                                                          644
                Water Quality Standards Conference
        Iowa Interstate Waters of the Missouri River Basin
                       Council Bluffs, Iowa
                          April 15, 1969

                            Statement

                  U.S. Department of the Interior
                    Bureau of Outdoor Recreation
                       Mid-Continent Region
                         Denver, Colorado


During the last decade, the people of this country have become increasingly

conscious of the current and potential values of outdoor recreation, and much

of this interest has been centered around the use and enjoyment of our water

resources.  All indications point toward a future need to provide not only

more but a wider variety of outdoor recreation opportunities.


Recent trends indicate a rapidly increasing interest and participation in

water-based recreation activities, especially in swimming, boating, water-

skiing, and skin diving.  There is also a growing interest in nature photog-

raphy and study, often involving the aquatic environment.


We estimate that the number of occasions in which people will engage in water-

oriented recreation activities will increase about 160 percent during the

next 40 years.  In the Missouri River Basin, a portion of which is  the sub-

ject of this conference, our studies indicate that there is a large demand

for outdoor recreation opportunities which remains unsatisfied.  Obviously,

any factor which tends to endanger or reduce the amount or number of clean

water areas, and aesthetically attractive streams, lakes, or shore areas

suitable for recreation purposes should be of great concern to everyone

involved in managing our natural resources for public benefit.


Water serves three basic needs of recreationists:  consumptive, i.e. drinking

and cooking supplies; surface and volume for water contact activities, fishing,
-------
                                                                           645
and boating; and for aesthetic enjoyment.  Water areas also are vital to




the preservation of fish and wildlife, unique biotic communities and, in




combination with adjacent lands, the highly valued scenic natural character




of certain areas.






The Bureau of Outdoor Recreation is interested in seeing quality recreational




opportunities provided.  Polluted water is not compatible with this goal.




It is not only undesirable for boating, water-skiing, and swimming, but is




unattractive for camping, picnicking and may be a health hazard in connection




with these and other water contact uses.  The polluting of recreational




waters results in decreased use and can render areas totally unsuitable for




such use.  Although progress in the abatement of pollution is considerable,




large amounts of pollutants still are being discharged into our water courses.






We are vitally concerned about the maintenance of good water quality in all




streams in the State of Iowa, and we have specific concerns about the water




quality of the Missouri River Basin and especially in the Floyd, Nishnabotna,




Big Sioux and Little Sioux River.






Surveys have revealed that the Missouri River Basin, including a portion of




Iowa, is endowed with a wide variety of recreation, scenic, historic, and




natural values.  Many of these values depend upon the quality of water avail-




able.  Interest has been shown for development of state parks and recreation




areas including a 1,000 surface acre lake near Sioux City, Iowa.  Corps of




Engineers' projects involving approximately 18 reservoirs in the Boyer,  Big




Sioux, Nishnabotna and Little Sioux River Basins are presently under study.
-------
                                                                           646
Also being considered is the development of Oxbow Lake projects which will




provide approximately 2,400 acres of water valuable for recreation and fish




and wildlife uses.






It is clear then that national goals as well as local and State interests




in outdoor recreation and environmental quality are effected by the




availability of clean water.







In regard to the water quality standards in the State of Iowa, the Bureau




of Outdoor Recreation recommends that all interstate waters be designated




for outdoor recreation use and be maintained at a quality which will support




primary or secondary contact recreation use.  Specific water quality for




these uses are set forth in the April 1, 1968 Water Quality Criteria, Report




of the National Technical Advisory Committee to the Secretary of the Interior.
-------
                                                                        647
                                UNITED STATES
                        DEPARTMENT OF THE INTERIOR
                  FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
                              MISSOURI BASIN REGION
                             911 Walnut Street, Room 702
                              Kansas City, Missouri 64106
      IN REPLY REFER TO:
                               April 30, 1969
TO:
Commissioner, Federal Water Pollution Control Administration
Attn:  Assistant Commissioner,  Office of Enforcement
FROM:      Regional  Director,  FWPCA

SUBJECT:   Water Quality Standards Conference, State of Iowa

Attached is an additional statement which we desire to have included
in the official record  of the  Water Quality Standards Conference,
State of Iowa, Council  Bluffs  session.

Copies are being provided to the conference recorder and the Iowa
State Water Pollution Control  Commission.
Attachment
                         ,/£j
                                                       r'^*
                                         JOHN M. yRADEMACHER
-------
                                                                      648
            CONTINUATION OF MISSOURI BASIN REGION, FWPCA,

                         REBUTTAL STATEMENT
     In deference  to  the statement  (Iowa Water Pollution Control


Coranission's  statement, 1969, page  11, paragraph 3, line 4), that the


first 74 miles downstream  from Sioux City discharges reflect water


quality conditions "superior" to those upstream from Sioux City is


not entirely  correct.  The basis for this statement results from the


comparison of types of bottom assoicated organisms and their relative


numbers.  It  must be  remembered that the majority of collections were


of a qualitative nature and can, therefore, be misleading in terms of


relative numbers and  the presence or absence of a particular species


of benthos.   In many  instances, a qualitative collection may miss


certain individuals because of habitat restrictions, etc.  When this


happens, the  total evaluation of an area may be biased in terms of


the numbers of different kinds found.  Benthic sampling of large


streams or rivers is  difficult due, in part, to the variety of natural


substrates encountered.  It is impossible to obtain representative


fauna, even within a  limited area, beceuse of shifting substrates,


variable or high streanflows and a host of other physical factors.


     A number of artificial substrate samplers have been built by


investigators to facilitate or improve benthic sampling,  Scott—;

                2/
Hester and Dandy—.  During the Missouri River Survey (October 1968),


the biology unit utilized artificial substrate samplers described by

              3/
Mason, et. al.— , to monitor water quality in the Sioux City area.


The samplers were installed on the Iowa side of the river and remained


submerged for a period of 40 days (10/11-11/19/68).
-------
                                                                      649
                                 -  2  -


 Results and Discussion
      Station 737,  approximately  3  miles upstream from the Big Sioux
 River confluence,  reflected  a diverse and clean water assemblage of
 benthos.  The total  number of organisms numbered 396.  Of this number,
 97 percent  was pollution  sensitive,  3 percent intermediate forms,
 and  no pollution tolerant forms  recorded.
      Station 730,  approximately  1  mile downstream from the Floyd
 River confluence exhibited a considerable reduction in total numbers
 and  pollution sensitive forms, while there was an increase in inter-
 mediate and pollution  tolerant forms.  Of the 131 organisms collected,
 only 59 percent of the benthos was pollution sensitive, while 40
 percent was intermediate  forms and 1 percent was pollution tolerant.
      Station 723,  approximately  6 miles downstream from the Sioux
 City STP reflected severe degradation of water quality.  From
 the  133 organisms  collected, 45 percent was pollution tolerant,
 29 percent  intermediate forms and  26 percent was of the pollution
 sensitive type.
     The artificial substrate sampling in the Sioux City area clearly
defines an  abrupt  change in water quality affecting the benthic
community.  It is  interesting to note that the stonefly which Iowa
based much of their rebuttal on was absent from all  of  the  samples,
and the diversity of mayflies in this case was restricted  to  one
genera.  However,   the number of mayflies  encountered  at  each  station
is significant.   Iowa states  that "mayflies  are  also  pollution
intolerant organisms  which require  high water quality."  The  number
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                                                                      650
                                - 3 -


of mayflies was reduced from 65 (Station 737) to only 1 individual
(Station 723).  Caddisflies not mentioned by Iowa, but which are in
the pollution sensitive group, were reduced in numbers from 320
(Station 737) to 33 individuals (Station 723).
     Also of considerable importance is the occurrence of tubificidae
in large numbers (60) at Station 723.  The tubificidae commonly
termed "sludgewonns" prefer and thrive in a highly organic environment.
The sampler at Station 723 was suspended off the bottom but nevertheless
collected large amounts of drift organic material creating a favorable
environment for the sludgewonns.
     The results from the artificial substrate program reflect water
quality degradation of a high degree downstream from the Sioux City
area.  This is contradictory to Iowa's statement (page 11,  paragraph 4,
line 15) that the biological quality was not "deteriorated" by the
Sioux City discharge.
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                                                                     651
                             REFERENCES






1.  Scott, D.C., 1958.   Biological Balance  In Streams.  Sewage and




    Industrial Wastes,  30(9):1169-1173.



2.  Hester, F.E. and J.S.  Dendy,  1962.  A Multiple-Plate Sampler




    for Aquatic Macroinvertebratea, Trans.  Amer. Fish. Soc.,




    91(4):420-421.




3.  Mason, Wm.T., Jr.,  J.B.  Anderson, and George E. Morrison, 1967.



    A Limestone-Filled  Artificial Substrate Sampler for the Collection




    of Macroinvertebrates  from Large Streams.  Prog. Fish Cult.
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                                                                         652
STATION 737

POLLUTION SENSITIVE
Hydropsyche
Cheumatopsyche    75
Neureclipis       96
Stenonema         65
                 385
INTERMEDIATE

Hyella         2
Asellus        5
Erioptera      1
Polypedilum    1
Conchapelopia _2
              11
         POLLUTION TOLERANT
STATION 730

POLLUTION SENSITIVE

Hydropsyche      5
Cheumatopsyche   4
Neureclipis     67
Stenonema       __2
                78
INTERMEDIATE

Hyella       46
Orthocladiua  4
Cricotopus    1
Polypedilua  _J.
             52
         POLLUTION TOLERANT
         Tubificidae   1
STATION 723

POLLUTION SENSITIVE

Hydropsyche      6
Cheumatopsyche  17
Neureclipio     10
Stenonema       _1
                34
INTERMEDIATE

Cricotopus
Polypedilum
Orthocladius
Glyptotendipes
Conchapelopia
Asellus
 2
 1
 1
 1
 1
11
39
         POLLUTION TOLERAOT
Tubificidae   60
                                                                       60
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                                                                          653
                                    Sotoa
                      &tate Department of
                             LUCAS STATE OFFICE BUILDING
                               DES MOINES. IOWA 5O319
JAMES F. SPEERS, M.D., M.p.H.                            Environmental Engineering Service

                                            P. J. Houser, M.S., P.E., Chief

                              15 May 1969

           David D.  Dominick
           Commissioner,  Federal Water Pollution
           Control Administration
           Washington,  D.C.  20242

           Attention:   Murray Stein, Assistant Commissioner,
                       Office of Enforcement

           RE:   WATER  QUALITY STANDARDS CONFERENCE, COUNCIL BLUFFS, IOWA
                SESSION
           Enclosed is  an answer to the Federal Water Pollution Control
           Administration rebuttal of the Iowa Water Pollution Control
           Commission Statement,  page 11 (Missouri Basin) which we wish
           to  have  included in the official record of the Water Quality
           Standards Conference,  State of Iowa, Council Bluffs Session.

           The FWPCA biological data referred to had been collected in
           October  and  November 1968 but was not included in the Standards
           Conference Report.

           Copies have  been provided to the Regional Director, FWPCA,
           Missouri Basin Region.
                 Schliekelman,  Director
                 Pollution Division
          RJS/ab
          Enclosure
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                                                               654
     ANSWER TO CONTINUATION OF FWPCA REBUTTAL OF IOWA WATER
     POLLUTION CONTROL COMMISSION'S STATEMENT, 1969, page 11.
                      (Missouri Basin)
Iowa's initial statement regarding the biological quality of the

Missouri River was based exclusively on the biological data which

was presented in Appendix B of the FWPCA's Missouri River Basin

Report.


Since the data presented in the FWPCA rebuttal statement of

April 30 was not included in the original report, it is obvious

that the remarks in the initial Iowa statement were not directed

toward the newly presented data and should not be interpreted as

such.


It is recognized that quantitative biological sampling in a large

river is difficult because of the habitat variety and that the

shifting substrate which is typical of a large portion of the

Missouri River,  is unproductive biologically.  The value of an

artificial substrate sampler is also recognized as providing a

quantitative estimate of numbers and kinds of biota.


Assuming that the numbers of organisms found at each of the three

stations in the Sioux City area were obtained from equal numbers

of substrate samplers, we would be in agreement that there is some

evidence of biological degradation below the Sioux City discharge.
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                                                               655
                            -2-
Whether this degradation at Station 723 is "severe" as stated by

the FWPCA is debatable because species diversity in addition to

total numbers of organisms is important as an indicator of biologi-

cal quality.  Although the number of pollution sensitive organisms

was considerably decreased at station 723, the diversity or kinds

of pollution sensitive organisms had not changed.
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APPENDIX A
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                                               APPENDIX A
        WATER  QUALITY CRITERIA

                   AND

PLAN FOR  IMPLEMENTATION AND ENFORCEMENT

                FOR  THE

        SURFACE WATERS OF IOWA
              ADOPTED BY
                  THE
IOWA WATER POLLUTION CONTROL  COMMISSION
      STATE DEPARTMENT OF HEALTH
              DES MOINES
               MAY 1967
        (Revised June 1,  1968)
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                  FOREWORD
The Water Quality Criteria and Plan for Implemen-
tation and Enforcement for the Surface Waters of
Iowa was originally prepared for and submitted to
the Department of the Interior in May, 1967.

Since that time, the numerous requests received
from consulting engineers, educators and the
general public have necessitated the publication
of this revised edition.

The Criteria and Plan have been left unchanged.
However, Table 11 has been updated to June 1, 1968.
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The Federal Water Quality Act of 1965, signed into
law on October 2, 1965, required all states to de-
velop water quality standards for the interstate
streams within their state boundaries.

Revisions to the Iowa Water Pollution Control Law
effective July 1965 established the Iowa Water
Pollution Control Commission and the authority for
adoption of water quality standards.  The law pro-
vided the Commission with the authority to adopt,
"such reasonable quality standards for any waters
of the state	," and to "develop comprehensive
plans and programs for the prevention, control and
abatement of new, increasing, potential or existing
pollution of the waters of the state."

After conducting seven public hearings throughout
the state, the Iowa Water Pollution Control Commission
adopted the Iowa Surface Water Quality Criteria Rules
and Regulations on February 28, 1967.  The Rules and
Regulations were approved by the Attorney General
of the State of Iowa on March 6, 1967 and by the
Legislative Departmental Rules Review Committee on
March 17, 1967.  They were filed with the Secretary
of State on March 20, 1967, and as provided by law,
became effective 30 days thereafter.

The Implementation and Enforcement Plan for the
Surface Water Quality Criteria was adopted by the
Commission on May 26, 1967.  The Surface Water
Quality Criteria and the Implementation and
Enforcement Plan have been combined and are called
the Iowa Surface Water Quality Standards.  The
Standards as presented are the result of a joint
effort of the Iowa Water Pollution Control Commission
and the Iowa State Department of Health to abate
pollution of the waters of the State of Iowa
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                TABLE OF CONTENTS

Introduction

Section I-General 	   1
   A. Topography	   1
   B. Hydrology   	   1
   C. Flow Regulation & Augmentation  	   2
   D. Present & Future Uses - Iowa Waters	   4
   E. Population	   5
Section II - Surface Water Criteria 	   7
   A. Discussion of Criteria  	   7
       1.  General Policy Considerations  	   7
       2.  General Criteria 	   8
       3.  Specific Criteria  	   9
           a.  Public Water Supply  	   9
           b.  Aquatic Life	11
           c.  Recreation	  11
   B. Surface Water Quality Criteria  	  13
   C. CSmpatability with adjoining states 	  17
Section III Implementation & Enforcement Plans  ....  19
   A. Statutory Autority  	  19
       1.  Statutes	19
       2.  Rules & Regulations	21
   B. Enforcement Procedures  	  22
   C. Surveillance Program  	  23
       1.  Operation reports  	  23
       2.  Plant & operation surviellance 	  25
       3.  Stream Surviellance  	  27
           a.  Existing program   	  27
           b.  Proposed program   	  28
       4.  Existing water quality 	  29
   D. Pollution Control Programs  	  30
       1.  Municipal & Industrial Waste Treatment ...  30
           a.  Significant pollution sources  	  30
           b.  Compliance with water quality  	  30
           c.  Construction schedules 	  32
       2.  Combined Sewer Overflow  	  33
       3.  Agricultural waste waters  	  33
       4.  Waste from boats and marinas	36
Section IV Public Hearings  	  37
Tables
   1.  Low-Flow-10 year Recurrence  	  39
   2.  Public Water Supplies  	  41
   3.  Streams-Aquatic Life..Warm Water Areas 	  43
   4.  Natural Lakes-Aquatic Life Warm Water Area ...  45
   5.  Artifical Lakes-Aquatic Life Warm Water Area .   .  47
   6.  Aquatic Life - Cold Water Areas	49
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                      TABLE OF CONTENTS
                        (continued)
Tables...continued..
     7.  Recreation Areas-Streams Impoundments & Lakes ..51
     8.  Surface Water Sampling Stations-ABS-Pesticides-
         Radioactivity	53
     9.  Surface Water Sampling Stations-Public Water
         Supplies-Major Cities	55
    10.  Chemical Quality - Iowa Streams	57
    11.  Status Waste Treatment Facilities	59
         Mississippi River Basin
         Missouri River Basin
    12.  Municipal Sewerage Systems	83

Figures
     1.  Monthly Coliform Average - Iowa River	85
     2.  MPN Frequency Distribution - Iowa River	87
     3.  Raccoon River Coliform Study	89
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                     SECTION I
                      GENERAL
A.  TOPOGRAPHY OF IOWA

Iowa is situated in the Upper Mississippi River drainage
basin, bounded on the east by the Mississippi River and on
the west by the Missouri and Big Sioux Rivers.  In general
the surface shows but slight relief with the highest point
in the northwest corner (1,675 feet) and the lowest point
in the southeast corner (480 feet).

The entire state is drained by either the Mississippi
River or its tributary, the Missouri River.  The drainage
areas are 38,860 and 17,379 square miles respectively.

Iowa streams entering the Mississippi River flow in a
general course from northwest to southeast.  The major
drainage basins are long and narrow and have fairly regular
outlines with the lateral boundaries tending to be parallel.

The stream drainage basins which drain into the Missouri
River are also relatively long and narrow and extend from
the northeast to the southwest.  They lie nearly perpendicular
to those streams tributary to the Mississippi River.

B.  HYDROLOGY
A seven-day, ten-year low flow has been selected to
recognize the variability of Iowa stream flows in the
aoplication of water quality criteria and in the economic
analysis and evaluation of treatment requirements.  There
also exists a tremendous variability in Iowa streams with
reasonably well sustained low flows, from ground water,
in northeast Iowa and decreasing progressively to the
south and west portions of Iowa.  A review of Table 1,
taken from Low Flow Characteristics of Iowa Streams,
Bulletin No. 9, Iowa Natural Resources Council 1958, shows
this variation quite clearly.
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                        — 2 —

HYDROLOGY	continued

With the exception of upland portions and minor  trib-
utaries the northeast Iowa basins including the  Iowa-
Cedar basins have seven-day, ten-year low flow values
in the range of 0.04 to 0.08 cubic  feet per second  (cfs)
per square mile.  The remainder of  the streams in the
state, south and west of the Iowa-Cedar basins,  have
very poor low flow characteristics.  No stream in this
area of the state has a flow above  0.01 cfs per  square
mile, for the seven-day, ten-year low flow magnitude.
Many streams have less than one-half this value.

For a specific example, the seven-day, ten-year  low
flow for the Cedar River at Cedar Rapids is compared
in the following table, to the Des  Moines River  at
Boone which has a comparable drainage area.
Drainage
Area
Sq. Miles
Yield
cf s/sq.
mile
10 year-
7-day
Flow-cfs
Cedar River at Cedar Rapids       6510    0.047       306
Des Moines River at Boone         5511    0.0065       36

For an equivalent drainage of 6510 square miles, the
Des Moines River basin would yield 42 cfs as compared
to 306 cfs for the Cedar River or only one-seventh of
the comparable flow of the Cedar River.  A similar
comparison indicates that the Upper Iowa River has a
seven-day ten-year low flow approximately 200 times
that of the Skunk River at Ames, with somewhat compar-
able drainage areas.

C.   FLOW REGULATION AND AUGMENTATION

The Surface Water Quality Criteria for the waters of
the State of Iowa are related to and affected by the
existing flows in the streams.  It is, therefore,
important that governmental controls be exercised
where applicable to maintain adequate flows in these
streams.

The Iowa  Natural Resources Council,  the state agency
responsible for administering the water use permit
system,  has adopted a policy that water use permits
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                          -3-

FLOW REGULATION AND AUGMENTATION...continued

will not be granted for the withdrawal of water for
consumptive use which will reduce the flow in the stream
below a given amount.  The cut-off point below which no
consumptive withdrawals can be made is generally much
higher than the seven-day, ten-year low flow used as a
basis for the Water Quality Criteria application.

The principal consumptive uses from streams that are
being regulated are withdrawals for supplemental irri-
gation and for filling of off-stream reservoirs.

When deemed necessary to protect downstream uses, storage
permits require the release of that portion of the natural
flow into the reservoir that is required to prevent material
damage to downstream uses.  In special circumstances,
installation of facilities for the release of certain
minimum flow is included in the storage permit.

Soil conservation and soil management programs controlling
farmland runoff tend to increase ground water reserves,
thereby augmenting low flow when the main source of flow
is ground water.  With increasing soil management programs
this effect might be further realized in the future.

The Iowa Water Pollution Control Commission endorses the
flow regulation policies of the Natural Resources Council
and all other programs designed to prevent soil erosion
and retain farmland runoff and therefore maintain a greater
flow in the state streams.  Maintenance of higher flows
in streams will provide for additional beneficial uses
to be supplied by these streams.

A number of multiple purpose reservoirs have been construct-
ed or authorized in Iowa.  These will generally provide
benefits for flood control, water quality control, water
supply, recreation, and fish and wild life.  Reservoirs
presently constructed or planned with storage for water
quality control will benefit only four major cities.
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                         -4-
D.  PRESENT AND FUTURE USES OF IOWA WATERS

The surface waters of the state are currently being used
in the following ways:  municipal water supply, indust-
rial water supply, livestock watering, fish propogation,
recreation, wildlife habitat and..irrigation.

These uses are relatively uniform throughout the state.
The use of these stream resources -for their full poten-
tial is hampered mainly because of the great variability
of flow and high turbidities occuring in these streams
during certain times of the year.

Currently there are 39 municipalities using surface
water sources for public water supply use.  It is not
anticipated that new surface water supplies will be
developed in the near future although it is expected
that eventually seme municipalities may need to change
from underground soirecee to more adequate surface
supplies.

The demand for increasing the fishery resources through-
out the state will be constantly enlarged due to the
emphasis put on outdoor recreation and also the increas-
ing amount of leisure time available.  Fisheries in Iowa
have been considerably restricted due to heavy siltation
and variable flows in the majority of Iowa streams.
Enhancement of the fishery resources by stream and land
management will, in itself, increase the demand for this
resource.

Activities enhanced by water are camping, hiking and
picnicking.  The principal water based recreational
activities are fishing and boating.  Water skiing and
swimming is generally limited to natural lakes and
impoundments created by dams, including tha Mississippi
River and swimming is generally limited to the artificial
lakes.  The demand for recreational use of surface
water is increasing and it is anticipated that the
demand will be met by construction of artificial impound-
ments.

All surface waters of the state are used at least to a
limited extent for livestock watering and wildlife pro-
pogation.  Presently agricultural use is basically live-
stock watering with limited supplemental irrigation
practiced.
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                          -5-
E.  POPULATION

Iowa's population has been increasing at a substantially
slower tate than the national population since 1900.
Because of farm consolidation and mechanization, many
rural trade centers have lost population and trade
volume, and the larger urban centers have experienced
growth in population and in service and manufacturing
employment.  Population and employment projections
indicate eastern Iowa will experience the greatest
growth in these areas.
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                          -7-
                       SECTiON  II

           IOWA SURFACE WATER QUALITY CRITERIA

A.  DISCUSSION OF CRITERIA

The Iowa Water Pollution  Control Commission, pursuant
to authority granted  in Section 455B.9  and 455B.13, Code
of Iowa 1966, has adopted Rules and Regulations govern-
ing Surface Water Quality Criteria for  the State of Iowa.
These criteria of water quality are intended as guides
for determining the suitability of surface waters  in
the State  of Iowa for  various  uses, and to aid decision
making in  the establishment of waste control measures.

Following  is a discussion of the Water  Quality Criteria
which is presented in  paragraph B of this Section.  The
discussion is divided  into sections corresponding  to
those of the Rules and Regulations.

1-Sec. 2^.1 General Policy Considerations

The surface waters of  Iowa have been classified as to
designated legitimate  uses by  the Water Pollution  Control
Commission.  The classifications of Iowa Waters are found
in tables  2,  3, 4, 5,  6 and 7  listing the public surface
water supplies, streams and lakes, designated as fishing
areas, and lakes and impoundments designated as recreation
areas.  Table 11 in Section III enumerates the water use
criteria at the municipal and  industrial waste discharge
points.

The water quality for  the designated uses will comply with
the criteria at:

      1.  The raw water intake for Public Water Supply Use.
      2.  All points in the stream from the mouth up to
          the designated  cutoff point as well as all
          artificial and  natural lakes  for Aquatic Life Use.
      3.  All points in the recreation pool for Recreation
          Use.

Sampling to determine  conformance to these criteria shall
be done at sufficient  distances downstream from waste dis-
charge points to permit adequate mixing of waste effluents
with the surface waters.  In the performance of tests or
analytical determinations to determine  compliance with  the
established surface water criteria, samples will be collected
at such locations, times,  frequencies,   and in such a manner
as approved by the Commission.
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                          -8-

l-Sec.2,1 General Policy Considerations..continued

The collection, preservation, and testing of samples
will be made in conformance with the methods given in
the latest edition of "Standard Methods of the Examin-
ation of Water and Sewage."  Where more than one method
is prescribed, that method designated by the Commission
shall be used.  Any methods deviating from those pre-
scribed must be approved by the Commission.

2._, Sec. 2.^2 General Criteria

The General Criteria shall apply to all water courses
and lakes at all times.  For designated water use areas,
the General Criteria will be supportive to the specific
criteria applicable to these areas.  Where a surface
water has not been designated for a specific water use,
these criteria will govern.  The General Criteria shall
be interpreted to mean that no raw or treated wastes,
attributable to municipal, industrial or other sources,
shall be discharged into any waters of the state which
will produce putrescent or otherwise objectionable sludge
deposits, floating debris, oil slicks, scum, odors, color,
chemical  concentrations or combinations to such a degree
as to be detrimental or harmful to legitimate downstream
water uses.

In general, those small intermittent streams experienc-
ing low or zero flows or which cannot under natural
conditions support a permanent fish population, will
have their quality governed by the General Criteria.
It is the intent of the General Criteria to protect the
water quality in these areas for the letitimate uses
to which they are presently being used.  Legitimate uses
in this category are those such as« irrigation, live-
stock watering, wildlife propogation, etc.  To protect
these uses on low flow streams, the wastes will be
given the highest practicable degree of treatment with-
out respect to dilution in order to prevent the develop-
ment of nuisance or health problems below the discharge.
The requirements are such that the effluent will be
suitable for limited downstream use.  Treatment less
than secondary will not be accepted unless  it can be
shown that the legitimate uses can be protected with
a lesser degree of treatment.
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                          — 9—

3. Sec. 2.3 Specific Criteria for Designated Water Uses

The criteria in this subsection apply to the water use
areas designated by the Water Pollution Control Commission.
The designation has been made by the Commission with the
advice and assistance of the Iowa Natural Resources Council,
State Conservation Commission, State Department of Health,
public hearing testimony, the faculties of the three state
universities and other interested parties.  The designation
does not limit beneficial uses or prohibit beneficial uses
other than those listed.

The minimum weekly flow which occurs once in ten years
shall be used as the design parameter to determine the
degree of treatment necessary to protect the specific
water use.  Flow will be based on a statistical analysis
of existing flow data, if such data are available.  This
specific surface water criteria shall be met at all times
when the flow exceeds the ten year low flow.  When the
flow is less, the municipality or industry shall not be
held responsible for lower stream quality when their
waste effluent is receiving the necessary degree of treat-
ment or control to comply with criteria at the ten-year
low flow.

The extreme variability of low flow at the seven-day
ten-year magnitudes in Iowa streams has been given
consideration in the application of the criteria to
designated water areas.  The natural water quality may
be degraded naturally by the aquatic environment at these
low flows.  It must be recognized that at the selected
low flow probability, many municipalities in central,
southern and western Iowa will be discharging treated
municipal waste water into essentially dry streams.

a.  Public Water Supply

This criteria has been developed to protect the quality of
the influent raw water for the 39 existing surface water
supplies and will be applied to any future supplies.  The
designated surface waters where the Public Water Supply
Criteria apply are listed in Table 2.
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                         -10-
a. Public Water Supply...continued....

Numerical bacterial limits have not been specified
because of the following reasons:

1.  The Standard Coliform organisms found in streams
are not specific for human sources but members of this
group are found in enteric discharges of warm-blooded
animals, and in the guts of cold-blooded animals, in
soils and in many plants.

2.  Bacterial studies have shown that commonly accept-
able coliform levels have been greatly exceeded in
the absence of wastes attributable to human sources.

If a stream contains coliforms that are of a domestic
sewage origin one might expect the most probable number
(MPN) to vary inversely with the dilution capacity of
the stream and that high MPN values would be expected
during the dry seasons.  A long term coliform study on
the Iowa River at Iowa City, beginning in 1950, indi-
cates high bacterial densities are associated with
high stream flows and turbidity.  Due to intense farm-
ing in the drainage basin, each snow melt or rainfall
carries into the river large quantities of silt and
apparently large number of coliform organisms from the
agricultural land.  Sanitary sewage is not considered
a significant factor since the nearest town is approx-
imately 30 miles upstream.

Figure 1 illustrates the pattern, on a monthly average
basis, of the direct relationship of increasing stream
flows accompanied by increases in both turbidity and
coliform density.  Figure 2 indicates that the monthly
coliform MPN average is less than 5000 per 100 m/1 about
46% of the months samples, both before and after impound-
ment above the supply in 1958.

Much data are available from other studies and sources
to substantiate the influence of land runoff on coliform
densities.  Figure 3 includes additional data.

For the above reasons, the Commission has specified that
a sanitary survey be conducted with the results being"
evaluated according to the particular situation investi-
gated.
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                         -11-

a. Public Water Supply...continued

When  a  source of coliform bearing waste which can be
feasibly controlled is  affecting the suitability of a
water supply the Commission may use the following values
as a guide: Coliform organisms are not to exceed a MPN
or MF of 5000/100 ml as  a monthly average value, nor to
exceed  this value in more than 20% of the samples examined
during  any one month nor to exceed 20,000/100 ml in more
than 5% of the samples examined in any one month.  This
value may be used as a guide until suitable indices can
be developed.

b.  Aquatic Life

In the  classification of surface waters, all lakes and
perennial streams capable of supporting a permanent fish
population have Seen designated for Aquatic Life Use.

These areas have been designated by the Water Pollution
Control Commission with the advice and assistance of the
Iowa State Conservation Commission and others.  The warm
water areas are those streams and stream reaches delineated
in Table 3 and the natural and artificial lakes listed
in Tables 4 and 5.

The cold water areas are those waters designated by the
Commission as trout streams and are those which are annual-
ly stocked with trout on a "put and take" basis, by the
State Conservation Commission.  These areas are listed in
Table 6 which is a summary of the current "Guide to Iowa
Trout Waters" published by the State Conservation Commission.

The criteria list only those factors which appear to be of
utmost importance to the preservation of a well-balanced
fish population.  However,  all other waste constituents
that are determined harmful to the stream aquatic life
will also be subject to control by the Commission.

c.  Recreation

The recreational use criteria are designed to reasonably
protect surface waters where the whole body contact sports
of swimming and water skiing are concentrated during the
recreational season.
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                         -12-

c.  Recreation...continued

Use of lakes and streams constitute a much greater
drowning hazard to the swimmer than the supervised
swimming pool due to the lack of water clarity,
presence of hidden obstructions or strong currents,
but it is the intent to provide a reasonable bacterial
water quality for the natural bathing areas.

Information provided from other state agencies, present-
ations at the public hearings, etc., was used by the
Commission to designate the Recreation Use areas on
lakes and Federal impoundments.  These areas are listed
in Table 7.  The Recreational Use areas have also been
classified for Aquatic Life Use since these two uses
are closely related to each other and require a high
quality of water.

No numerical values have been specified for bacterial
limits since studies have shown high bacterial concentra-
tions associated with land runoff, and public health
studies to date have shown little direct correlation
between coliform concentrations and water-borne diseases.
Supportive data collected from Iowa streams showing high
background coliform counts are shown in Figures 1 and 2.

Where a controllable waste discharge is the proven source
of increased bacterial concentrations, the Commission may
use the following as a guide:  The arithmetical mean
coliform density is not to exceed 1,000 per 100 ml as
a monthly average nor exceed this value in more than 20%
of the samples in any one month nor exceed 2,400/100 ml
in any one sample.  This value will be used as a guide
until suitable indices can be developed.

Where a significant coliforn or other bacterial increase
in a designated Recreation Use Area can be identified
with a controllable waste discharge, chlorination or
other control procedures to reduce the bacterial concen-
tration below the guide limits may be required.
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                          '13-
B. SURFACE WATER QUALITY CRITERIA

The following rule and regulation was adopted by the Iowa
Water Pollution Control Commission on February 28, 1967.

       IOWA WATER POLLUTION CONTROL COMMISSION
                RULES AND REGULATIONS
               WATER QUALITY STANDARDS

Pursuant to the authority of sections 455B.9 and 455B.13,
Code of Iowa, 1966, the water quality standards found in
the July, 1966, Supplement, Iowa Departmental Rules, page
70, are hereby amended by adding the following to Chapter 1.

   Section 1.2.  (455B) Surface water quality criteria.

     1.2(1) General policy considerations.  Surface waters
are to be evaluated according to their ability to support
the legitimate (beneficial) uses to which they can feasibly
be adapted, and this specific designation of quality areas
shall be done by the Iowa Water Pollution Control Commission.

       Sampling to determine conformance to these criteria
shall be done at sufficient distances downstream from waste
discharge points to permit adequate mixing of waste effluents
with the surface waters.

     1.2(2)  General criteria. The following criteria are
applicable to all surface waters at all places and at all
times:

     a.  Free from substances attributable to municipal,
industrial or other discharges that will settle to form
putrescent or otherwise objectionable sludge deposits;

     b.  Free from floating debris,  oil, scum and other
floating materials attributable to municipal, industrial
or other discharges in amounts sufficient to be unsightly
or deleterious;

     c.  Free from materials attributable to municipal,
industrial or other discharges producing color, odor or
other conditions in such degree as to be detrimental to
legitimate uses of water;

     d.  Free from substances attributable to municipal,
industrial or other discharges in concentrations or
combinations which are detrimental to human, animal.
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                          -14-

B. Surface Water Quality Criteria....continued

industrial, agricultural, recreational, aquatic or other
legitimate uses of the water.

    1.2(3)  Specific Criteria for designated water uses.
The following criteria are applicable at flows greater
than the lowest flow for seven consecutive days which
can be expected to occur at a frequency of once every
ten years.

      a.  Public water supply.  The following criteria
for surface water quality apply to the point at which
water is withdrawn for treatment and distribution as
a potable supply:

         (1)  Bacteria:  Waters shall be considered to
be of unsatisfactory bacteriological quality as a source
when:

      A sanitary survey indicates the presence or
probability of the presence of sewage or other object-
ionable bacteria-bearing wastes or

      A bacteriological survey using coliform or other
appropriate indices indicates bacteriological concentra-
tions significantly higher than those normally found or
expected in these waters when free from pollution
by. sewage,

         (2)  Radioactive substances:  Gross beta activity
(in the known absence of strontium - 90 and alpha emitters)
not to exceed 1000 micro-micro-curies per liter.

         (3)  Chemical constituents:  Not to exceed the
following concentrations:

              Specific Constituents (mg/1)

Arsenic                0.05        Cyanide       0.025
Barium                 1.0         Fluoride      1.5
Cadmium                0.01        Lead          0.05
Chromium(hexavalent)   0.05        Phenols       0.02

      All substances toxic or detrimental to humans or
detrimental to treatment processes shall be limited to
nontoxic or nondetritnental concentrations in the surface
water.
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                         -15-

      b.  Aquatic life.  The following criteria are
designed for the maintenance and propagation of a well-
balanced fish population.  They are applicable to any
place in surface waters but cognizance will be given to
opportunities for admixture of waste effluents with
such waters.

         (1)  Warm water areas.  Dissolved oxygen:  Not
less than 5.0 tng/1 during at least 16 hours of any 24-
hour period and not less than 4.0 mg/1 at any time during
the 24-hour period.

         pH:  Not less than 6.8 nor above 9.0.

         Temperature:  Not to exceed 93°F during the months
of May through November, and not to exceed 73°F during the
months of December through April.

         Chemical constituents: Not to exceed the follow-
ing concentrations:

             Specific constituents (mg/1)

    Ammonia Nitrogen (N)     2.0   *Copper       0.02
    *Arsenic                 1.0    Cyanide      0.025
    *Barium                  5.0   *Lead         0.10
    *Cadium                  0.05   Phenols      0.20
    *Chromium(hexavalent)    0.05  *Zinc         1.0
    *Chromium(trivalent)     1.00

    *A maximum of 5.0 mg/1 for the entire heavy metal
group shall not be exceeded.

    All substances toxic or detrimental to aquatic life
shall be limited to nontoxic or non-detrimental concen-
trations in the surface water.

         (2)  Cold water areas.  All criteria stated for
warm water areas apply to cold water areas except as
follows:

         Dissolved oxygen:  Not less than 7.0 mg/1 during
at least 16 hours of any 24-hour period nor less than 5.0
mg/1 at any time during the 24-hour period.

         Temperature:  No greater than 70°P.
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                         -16-

      c.  Recreation.  The following criteria are appli-
cable to any waters used for recreational activities
involving whole body contact such as swimming and water
skiing:

         (1)  Bacteria:  Waters shall be considered to be
of unsatisfactory bacteriological quality for the above
recreational use when:

         A sanitary survey indicates the presence or
probability of the presence of sewage or other objection-
able bacteria-bearing wastes or

      A bacteriological survey using coliform or other
appropriate indices indicates bacteriological concentra-
tions significantly higher than those normally found or
expected in these waters when free from pollution by
sewage.

These rules are intended to implement sections 455B.9 and
455B.13, Code of Iowa, 1966.

These rules shall become effective as provided in Chapter
17A of the Code after filing in the office of the Secretary
of State after review by the Departmental Rules Review
Committee.

EXAMINED AND APPROVED
DATE
/s/ '
         March 6, 1967
     JFred Henderickson
ATTORNEY GENERAL
DATE ADOPTED  February.23, 1967
/s/  Robert Buckmaster	
DEPARTMENT HEAD
REVIEWED AND APPROVED
DATE
         March 17.1967
/s/  Adolph W,_Elver.3_
CHAIRMAN, DEPARTMENTAL RULES
REVIEW COMMITTEE
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C.  COMPATABILITV WITH ADJOINING STATES

Notices of public hearings and proposed water quality
data for Iowa streams were submitted to the adjoining
states of Nebraska, South Dakota, Minnesota, Wisconsin,
Illinois arid Missouri.  Representatives from Minnesota
attended one hearing, Illinois - two hearings, and
Missouri - two hearings.  Oral and written statements
were presented at the hearings.

The content and general requirements of the standards
were discussed at specific meetings with the states
of Illinois and Missouri as early as December 1965.
Correspondence and discussion have been carried on with
all adjoining states.

Iowa representatives attended one hearing in Wisconsin,
two in Illinois and two in Missouri and oral and written
statements regarding general consistency and compatability
of the criteria were submitted.  The water quality criteria
and uses for the common waters between Illinois and Iowa
are identical.  The entire Iowa Water Pollution Control
Commission attended one hearing in Illinois.

Reasonable agreement has also been reached with all
states as to the water uses to be made of common inter-
state waters.

Following study of the testimony submitted at the public
hearing the Commission ammended a number of the water
quality criteria parameters.  The phenol concentration
was increased to a more attainable and realistic figure
and the cyanide concentration for the public water
supply used was reduced to correspond to the aquatic
life concentration.  The temperature limit for the
warm water areas was reduced slightly to 93° as a more
generally accepted figure and provision was made to
prevent extreme temperature changes.
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                          -19-

                       SECTION III

          IMPLEMENTATION AND ENFORCEMENT PLAN
Ob.iectj.ye

The purpose of the plan  is  to provide  a  means by which
the water quality criteria  can  be  enforced and the quality
of surface waters protected and enhanced for  beneficial
uses.  The plan has been developed to  protect all surface
waters and not only interstate  waters  as required by the
Federal Water Quality Act of 1965.

A.  STATUTORY AUTHORITY

The Water Pollution Control Cornnsission and the State
Department of Health make use of the following authority
to control or abate pollution of the surface  waters of
the state.

1.  STATUTES

.Iowa.. Wa ter
Specific statutory authority for the Iowa Water Pollution
Control Commission for adoption and enforcement of water
quality criteria is found in Chapter 455B/ Code of Iowa,
1966.  Exerpts of the law pertaining to the authority
follow:

4jL5j3._3.  There is hereby created and established the Iowa
Water Pollution Control Commission.  The Commission is
established as an agency of the state government to
prevent, abate, or control the pollution of the waters
of the state.

45 5B j&  The Commission is hereby given and charged with
the following powers and duties:

     1.  The Commission through the State Department of
Health shall have general supervision over administration
and enforcement of all laws relating to the pollution of
any water of the state, except as provided in Section 135.11
of the Code.
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                         -20-

1.  Statutes...continued

     2.  To develop a comprehensive plan and program
for the prevention, control and abatement of new,
increasing, potential or existing pollution of the
waters of the state.

     3.  The Commission may cause the State Department
of Health to conduct investigations....

     4.  To adopt, modify, or repeal such reasonable
quality standards for any waters of the state in re-
lation to the public uee to which they are or may be
put as it shall deem necessary for the purposes of
this Act.

     6.  To direct the State Department of Health to
issue, revoke or modify permits	.for the discharge
of sewage, .... or for the installation or operation
of disposal systems....

     8.  To prescribe rules and regulations....

     9.  The Commission shall cooperate with other
state or interstate water pollution control agencies
in establishing standards, objectives, or criteria
for quality of interstate waters. . . .

45SB.10.  The State Department of Health shall conduct
such investigations as may be necessary to carry out
the provisions of the Act.

455B.11  The State Department of Health in accordance
with the direction and policies of the Commission may
issue, modify, or revoke such orders as may be required
for the prevention or discontinuance of the discharge
of sewage,industrial waste or other waste in any waters
of the state resulting in pollution in excess of the
applicable quality standard....

Iowa State Department of Health

Section 135.11, paragraph 7, Code of Iowa, requires that
the State Department of Health shall "make inspections
of ...., sewer systems, sewage treatment plants,....
and direct the method of installation and operation
of the same."
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                           -21-

Mandatorv Certification

Chapter 136A, Code of Iowa, 1966, is an act to certify all
public Water Supply Systems and Waste Water Treatment
Systems and require the examination of operators and cert-
ification of their competency to supervise the operation
of these facilities.

Miscellaneous Statutory Provisions

Section 732.3 declares that it is unlawful to throw any
dead animal, night soil, or garbage into any river, well,
spring, cistern, reservoir, stream or pond or in or upon
any land adjoining which is subject to overflow.

Section 657.2(4) declares it is a nuisance to corrupt or
render unwholesome or impure the water of any stream,
river or pond.

2.  RULES AND REGULATIONS

Rules and Regulations have been approved as authorized by
the statutes and have the full effect of law.

Municipal.Effluent Standard

This rule requires that no municipality shall discharge
any sewage to the waters of the state without effective
removal of floatable and settleable solids as the minimum
degree of treatment.

Surface Water Quality Criteria

This rule and regulation is discussed and given in
Section II,  Paragraphs A and B.

Records of Operation of Waste Disposal Systems

This joint rule of the Water Pollution Control Commission
and State Department of Health requires all owners of
waste disposal systems to submit monthly operation reports
to the State Department of Health.

Certification of Water Supply System and Waste Water
Treatment Plant Operators

This rule of the State Department of Health classifies waste
water treatment plants and establishes operator education and
experience qualifications.
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                          -22-

B.  ENFORCEMENT PROCEDURES

To accomplish pollution abatement four different methods
of action can be instigated by the Iowa Water Pollution
Control Commission to abate pollutional conditions:

1.  The Commission may direct the State Department of
Health to conduct an investigation of alleged pollution.
If the Commission finds that pollution exists, a
negotiation meeting is arranged between the Commission
and the alleged polluter.  If agreeable to both parties,
a time schedule of pollution abatement is arranged and
a consent order is drawn by the Commission and signed
by both parties.

If a satisfactory agreement as to a construction time
schedule cannot be reached between the Commission and
the alleged pollutor, a hearing is ordered by the
Commission as provided by law.  If the evidence presented
indicates that pollution does exist,  the Commission
issues an order to abate the pollution within a reason-
able period of time.

2.  If a municipality is discharging raw or inadequately
treated wastes to a state water, the Commission notifies
the municipality that they are in violation of the state
effluent standard requiring a minimum removal of settle-
able and floatable solids.  A negotiation proceeding or
hearing follows as in the first method except that an
investigation is not required.

3.  If a municipality or industry is operating a waste
treatment plant which is in violation of a permit issued
by the Health Department for its installation, the State
Department of Health initiates legal action through the
Attorney General's Office.  The Attorney General notifies
the municipality or industry to take appropriate action
to comply with the stipulations of the permit.

4.  The permit provision of the law provides that permits
for extensions to existing sewer systems can also be
denied where a condition of pollution already exists
below the outlet, unless active planning is underway
for the installation of treatment facilities.
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                         -21-

C.  SURVEILLANCE PROGRAMS

Routine monitoring of waste discharges will be accomp-
lished in three ways:  (1) operation reports,  (2) plant
and operation surveillance, (3) stream surveillance.

1.  Operation Reports;  Rules and Regulations have been
adopted which require monthly submittal of operation
reports by all owners of waste disposal systems which
discharge sewage or wastes into any waters of the state.
where practicable the Commission will require the larger
treatment facilities to initiate a downstream sampling
program.

Five different operation report forms are now being used.
These are differentiated according to the type of waste
disposal system:

               WWTR I     Waste Stabilization Lagoon
               WWTR II    Imhoff and Trickling Filter
               WWTR III   Trickling Filter..Separate
                          Sludge Digestion
               WWTR IV    Extended Aeration
               WWTR V     Industrial Lagoon

Checking the data and actual monitoring of the waste
disposal plant will be done by data processing equip-
ment.  The equipment to be used is the state's IBM 360-40
computer,  which is to be replaced by a 360-65 in the
future.  On order,  but not yet received,  is an IBM 360-20
computer which will be used more directly by the Health
Department.

A description of the computer monitoring process follows:

Each incorporated city or town has been given a code
number according to alphabetical listing.  All waste
producers in the locale of a municipality have been
given the town number.  The waste producers are further
classified as to type:

     1.  Municipality       5.  Recreational
     2.  Industry           6.  Commercial
     3.  Mobile Home        7.  Sanitary District
     4.  School
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                          -24-

 1.  Operation Reports...continued

 The discharge of the waste is further classified as to:

   1.  Treated to City Sewer       5.  Raw to Another
   2.  Untreated to City  Sewer         Municipality
   3.  Treated to State Waters     6.  Raw to a Sanitary
   4.  Untreated to State Waters       District
                                   7.  No recognized
                                       Sewer System

 Explanation of Card Information:

   Card 1.  Plant location information and design data.
   Card 2.  Operator in direct responsibility number,
            type of treatment and construction and
            improvement data.
   Card 3.  Status of the plant according to Commission
            actions with  orders and time schedule for
            pollution abatement.
   Card 4.  Permits for sewer extensions with sizes and
            lengths.
   Card 5.  Operational data required and limits set
            on parameters.

The computer will check on each plant according to:

     1.  Receipt of operation report.
     2.  Compliance of submitting required data.
     3.  Data complying with loading or effluent limits
         established.

Eeery treatment plant requiring operation reports will
receive a monthly statement acknowledging receipt of
 the report and compliance or ommission of required data.
 It is felt that monthly communication with the operator
 is of prime importance to insure adequate report sub-
mittal.  The statement will also indicate if any of the
parameters have exceeded  the limits established.

Periodically, the computer will check on the plants to
determine if the design parameters are being exceeded.
Action will be initiated  to update the waste treatment
plant with overloaded facilities.  The computer system
will, therefore,  be able  to determine current pollution
 conditions and future pollution due to overloading of
 the plant facilities.  The waste treatment plant owners
will be notified that plant improvements are needed and
encouraged to take appropriate corrective action.
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                         -25-

The base files in the storage system will be continually
updated to provide more adequate information on which
to judge operation and facility adequacy.

2.  Plant and Operation Surveillance;

The plant and operator surveillance programs of the
state are aimed to check the operation, maintenance and
efficiency of the treatment plants and to increase the
competency of the operators in charge of these plants.
To achieve these goals the State Department of Health
has in effect the following programs:

a.  Treatment Plant Inspection

The State Health Department field engineers located in
seven regional offices situated throughout the state
periodically inspect all the waste treatment plants in
the state.  Reports stating the condition of the receiving
stream, plant operation, performance and recommendations
for improvements are transmitted to the responsible muni-
cipal or industry officials.  Pertinent data from this
report will also be used to update the computer records
on each treatment plant.  The regional engineers also
offer advice and assistance to the treatment plant operators
on plant operation procedures, report completion, laboratory
procedures or other problems concerning their plant.

b.  BOP Mai1ing Program

In May of 1967 the State Hygienic Laboratory, in conjunction
with the State Department of Health, began the BOD Mailing
Program.  This program enables BOD samples to be collected
in the field and mailed to the State Hygienic Laboratory
without refrigeration.  To facilitate this procedure
samples are acid fixed directly upon collection and then
neutralized and seeded following return shipment to the
laboratory.  Laboratory studies showed that results were
reproducible  with sufficient accuracy to use the field
BOD samples as a check on the plant effluent strength.

Initally,  the BOD samples will be collected by the treat-
ment plant operators upon receipt of request from the
State Hygienic Laboratory.  Each plant effluent will be
sampled at least four times yearly.  As the program
develops,  the regional engineers will also be equipped to
collect additional samples during their plant surveys to
gain additional data concerning the treatment facilities
and final plant effluent.  A future possibility of the
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                          -26-
BOD Mailing Program if additional personnel and equip-
ment are available, might be to permit treatment plants
to submit BOD samples for analysis on a fee basis.

The laboratory BOD results will be tabulated on a computer
coded card and then stored in the data storage record for
each plant.  The results will be analyzed by the computer
and results compared to previous samples and any limits
placed on the effluent.  The BOD results will be included
in the tnonthly operation report analysis sent to the
plant operator.  The BOD Mailing program will thus facil-
tate the continual monitoring of the waste treatment
plant effluents and check the operational report data
submitted.

c.  Operator Competence

Hand a to r y Ce r t i f i c a t i on - To support the plant operation
surveillance the General Assembly enacted a Mandatory
Certification Law, effective in July 1965.  Operators
in direct responsibility of public waste water treat-
ment plants must be certified.  Education and operation-
al experience and a comprehensive examination are graded
according to the classifiication of the certificate.
Certificates are classified as to complexity, type and
size of plant.  All municipalities have complied.

Operator Basic JTraininct Courses - Basic training courses
have been conducted since 1952 when a Voluntary Certifi-
cation Program was initiated.  With the enactment of
the Mandatory Certification Law six courses for approxi-
mately 30 persons each,  (3 hours per week for 9 weeks)
have been held annually with instruction furnished prim-
arily by the two Universities.  Plans are being developed
for an advanced course for the larger and more complex
plants.

Laboratory Course - Currently a laboratory course for
treatment plant operators is being conducted yearly at
Iowa State University in Ames.  This program will need
expansion and plans are being made to arrange funds
and facilities to meet this need.  Advanced laboratory
control courses and seminar are being planned at the
University of Iowa and the State Hygienic Laboratory.
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                         -27-
Laboratory Course..continued

It is felt that through the mandatory certification
program and the operator training couses, the overall
competence of the operators throughout the state will
be greatly increased.  Increased operational efficiency,
accomplished by operator training will greatly benefit
the State surface waters.

3.  STREAM SURVEILLANCE

a.  Existina program

The State of Iowa is currently carrying on the following
surface water surveillance programs:

Municipal Water Supplies - Currently 29 surface water
sources of municipal water supplies are being surveyed
of which 15 are located on interstate streams.  Samples
are being collected send-annually by local officials
and the following analyses are made by the State Hygienic
Laboratory.

     COD                  NA                 Cl
     Hitrogen cycle       K                  SO^
     Solids               CA                 HCO--CO
     pH                   Mg                 Silica
     Hardness             Pe                 Specific conduct-
     PC^ (Soluble)          Mn                 ance
     PO (Total)           F

     Six stream locations are under surveillance for ABS.

Pesticides  Pesticide surveillance began in 1965 and is
presently being expanded to include smaller streams in
the state.  Currently chlorinated hydrocarbons are being
analyzed at six stream locations.

Radioactivity  Alpha and beta-gamma activity are being
determined on the total, dissolved and suspended solids
of the surface waters at 15 stream locations, 2 lake
locations and 3 impoundments.  These samples are collected
on a monthly schedule.
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                        -28-
W.JP.C. Surveillance Network  River stations are being
sampled generally on a monthly basis for the Water
Quality Surveillance System at Dubuque, Burlington
and Omaha.  Sample Analyses include:  plankton, radio-
activity, delayed incubation membrane coliform tests,
and extensive elemental and compound determinations.

Taste and Odor  The Missouri River Public Water Supply
Association has furnished data on extensive taste and
odor studies relative to the Missouri River.  Studies
were conducted on the Boyer, Soldier, Maple and Missouri
Rivers.

Cedar River research studies on biological precursors of
oderiferous compounds have been in progress since 1961.
The Des Moinss River is also receiving similar surveill-
ance because of "fish taints".  The State Hygienic
Laboratory is conducting the research in conjunction with
the State Conservation Commission, the Iowa State Depart-
ment of Health and the Water Pollution Control Commission.

b.  Proposed program

In addition to the current surveillance programs, the
Iowa Water Pollution Control Commission plans the addition
of 66 new surface water sampling stations.  The initiation
of these new stations and the frequency of sampling de-
pends upon financing and facilities being made available.
  These proposed stations will survey additional reaches
of streams and the downstream conditions below waste water
treatment plant outlets.  Initially it is proposed that
samples be collected semi-annually with the following
analyses being made:

   BOD       Turbidity    Heavy metals*     *Analysis at
   COD       Temp         F*                 less frequent
   NH^cycle  PH           Phenols*           intervals
   D. O.     PO (Total)    Cyanide*
Solids       PO*(Soluble)

The designated recreational and water supply areas which
are downstream from a significant bacterial waste discharge
will be sampled with the Belp of local participation.
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                        -29-

b.  Proposed program.... continued
Coordination of the Stream Surveillance Program will be
accomplished with other agencies also concerned with
stream quality.  Those agencies are:

            1.  U. S. Geological Survey
            2.  Corps of Engineers
            3.  State Conservation Commission
            4.  State Universities
            5.  Bordering states
            6.  Public water supplies

By law the State Hygienic Laboratory provides laboratory
services for the Commission and the Health Department.
The Laboratory has the facilities and qualified personnel
to perform the necessary analyses required by the state
in its current surface water surveillance program.  How-
ever, expansion of the Laboratory staff and facilities
will most likely be necessary when the proposed surveill-
ance program is initiated.

The locations of the existing and proposed sampling
stations for the various parameters involved in the
surveillance of waters of the state are tabulated in
Tables 8 and 9.

4.  Existing Water Quality

The existing quality of a major portionof Iowa surface
waters is considered satisfactory for the present and
future water uses.  It is the opinion of the Water
Pollution Control Commission that as a minimum effect
the Surface Water Quality Criteria will maintain the
quality of those waters currently in satisfactory condi-
tion and upgrade those waters of lower quality to support
the designated legitimate beneficial uses.

Table 10 is a tabulation of the data from one of the exist-
ing water quality surveillance programs collected over
the past five (5)  years.
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                        -30-

4.   Existing Water Quality....continued

In  addition to  the regular  sampling  stations,  there  has
been extensive  miscellaneous  sampling  in routine pollution
investigations  below municipalities  and also entire
stream  reaches.   These  samplings  have  generally included
pH,  DO, BOD and Coliform MPN.   These data  are  not pre-
sented  since they are not easily  retrievable and because  the
pollutional conditions  have since been or  are  in the process
of  being corrected.

D.   WATER POLLUTION CONTROL PROGRAMS

The following is  a summary of the Water Pollution Control
Commission policies and programs  to  control and abate
pollution:

1.   Municipal and Industrial Waste Treatment

a.   Significant Pollution Sources

A listing of the  significant pollution sources to surface
waters  is shown in Table 11.  This table divided into
the  Mississippi  and Missouri River Basins  lists the
municipalities  and major industries, the type  of treatment
provided, the treatment needs and a  time schedule for
construction of needed  facilities.   These  listings will
change  as new facilities are provided  and  existing facili-
ties depreciate or become overloaded.

This table also lists the downstream water uses which have
been categorized  in the water quality  criteria.  Any
reach of stream not designated  for a specific water  use
will have its water quality governed by the general
criteria.  The  numerical listings represent the follow-
ing  specific water use  criteria:

            1.  Public  water supply  (point of withdrawal)
            2.  Aquatic life - Warm  water  area
            2a. Aquatic life - Cold  water  area
            3.  Recreation
            4.  General Criteria

b.  Compliance with Water Quality Criteria

Table 11 also presents  the best estimate of treatment needs.
All municipalities on interior streams will generally need
secondary treatment and some already have  two stage  filt-
ration or other tertiary treatment furnishing up to
96% BOD removal.
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                        -31-

b.  Compliance with Water Quality Criteria...continued...

At the present time the Missouri River is  in compliance
with the criteria since the water quality  is not degraded
by the discharge of wastes receiving primary treatment
due to dilution presently afforded.  A greater variety
of beneficial water uses on the Mississippi river neces-
sitates coliform reduction in addition to primary treatment.
Generally a lesser degree of treatment than secondary on
these two large streams will not effect the water quality
criteria due to the great dilution available.

The characteristics of a receiving stream, including its
seven-day ten-year probable low flow, will continue to
be used in determining the type of treatment needed.
Treatment less than secondary will not be  accepted on
low flow streams unless it can be shown that legitimate
uses can be protected with a lesser degree of treatment.

All industries will be required to provide the same
degree of treatment or control that is required of
municipalities on the same reach of the stream.  This
degree of treatment will generally be the equivalent
of secondary treatment.  A more complete inventory of
industrial plants and their pollution producing potential
is underway.

Table 12,  showing the Municipal Sewerage Systems in Iowa
as of December 31, 1966 presents some of the treatment
needs.  97.6% of the sewered population is provided with
treatment facilities and the majority of the remaining
39 communities with a combined population of 42,427 are
under orders to provide treatment.  It will be noted 466
communities out of the total of 944 do not have community
sewer systems.  The majority of these communities are
under 500 population (average 280 pop.)  and do not
present serious pollution problems.  Federal financing
programs have stimulated great interest in sewer systems
and treatment facilities among these small communities.

Knowledge regarding the extent of pollution caused by
nutrients from sewage treatment plants is limited and
may be relatively insignificant compared with nutrients
from land wash.  Further research in both areas is
necessary before considering a time schedule for nutrient
removal.
-------
                         -32-

b.  Compliance with Water Quality Criteria..continued..

Thermal pollution has not constituted a problem but may
grow important with growing power production and a trend
to very large plants.

Supplemental irrigation is very limited and return flows
create no solids buildup problem.

c.  Construction Schedules

Table 11 indicates the time schedule for the municipality
or industry that has been established by the Water Pollu-
tion Control Commission to bring about compliance with
.the standards.  Contract award dates have been given for
projects where the Commission has given an order to pro-
ceed with pollution abatement.  Project completion dates
have not been set by the Commission due to the great
variability and uncertainty of construction projects.
Projects listed with the July 1, 1972 date will be ex-
pected to have construction underway by that date.  More
specific and earlier time schedules will be established
by the Commission in most instances. If it appears that
there will not be compliance with the construction time
schedules, the Commission will hold a hearing and issue
orders setting up the construction schedule.

As time progresses, additional schedules will be set
according to the available data on stream quality surveys
and monitoring which will be expanded to cover all the
streams of the state where pollution can occur.

A project completion schedule typical of those which have
been negotiated or ordered by the Water Pollution Control
Commission is as follows:

               Orders for pollution abatement
               Preliminary report due in 6 months
               Final design due in 6 months
               Contract award due in 4 months
               Construction completed in 6-24 months

Since nearly all present and future municipal treatment
plant construction will be partially financed by Federal
grant funds, certain time allowances have been incorpor-
ated to allow 'for Federal processing of grant applications
and a review of design plans and specifications.
-------
                        -33-

 c.   Construction  Schedules..continued...

 Ample  Federal Water  Pollution  Control Administration
 construction grant funds will  be  available  for  all
 projects  on a "first come-first served" basis if
 Congressional appropriations are  made at  authorized
 levels.

 2.   COMBINED SEWER OVERFLOWS

 It has been the policy  of  the  State Department  of Health
 since  1930 not to approve  combined sewer  systems and
 has  recommended a program  of complete separation of
 sanitary  and storm sewers.  Under the Iowa  Water Pollution
 Law, the  overflow from  the combined sewers  is pollution
 and  the Water Pollution Control Commission  has  taken
 the  position of recommending the  separation of  the systems.
 It is  recognized  that separation  is a long  and  costly
 project since the combined systems are located  in the older
 and  larger cities where development has increased their
 replacement costs.   A majority of the cities have accepted
 recommendations to initiate a  sewer separation  program on
 a schedule spaced over  a period of time.

 3.   AGRICULTURAL  WASTEWATERS

 Agricultural pollution  in the  State of Iowa occurs basically
 in three  forms:

            1.  Turbidity from soil erosion
            2.  Toxicity from  agricultural  chemicals
            3.  Wastes  from feedlots

 The  Commission has appointed an Agricultural Advisory
 Committee comprised  of  faculty members from two of the
 State  Universities to assist the  Commission in matters
 relating  to agricultural wastes.  This committee is
 subject to call by the  Commission to study  specific
 agricultural problems and to make recommendations for
 corrective action.   The lack of practicable methods for
 corrective action precludes the setting of a timetable
without further research and technology.

 Soil Erosion

 Currently there is no legislation requiring farmland
 owners and operators to practice soil and water conser-
vation measures which control  farmland runoff.   Soil
-------
                       -34-

Soil Erosion...continued...

erosion and consequent turbidity in the receiving streams
is an increasing problem  throughout the State of Iowa.
Several factors contribute to the problem of erosion.
Agriculturalists expect at least 18 million acres of
corn and soybeans will be grown in Iowa by 1970, an
increase of 4 million acres over 1964.  To get this
increased acreage, farmers on rolling farm land are
farming their steeper land much more instensively to row
crops than in the past and erosion is accelerated great-
ly.  Less pasture and hay land is needed as dairying
decreases in Iowa, therefore, much of the land formerly
in rotation meadow and pasture is now in row crops.
This reduces the use of strip cropping tremendously.  As
farms get larger, farmers are reluctant to use any con-
servation practices that  slow down planting and caring
for row crops.  Thus the use of contouring, older style
terracing and waterways have been difficult to maintain
and expand.

The State Soil Conservation Committee is carrying on an
active program through its Soil Conservation Districts
to assist landowners and operators in developing soil
conservation plans.  Currently over 60,000 farmers have
developed soil conservation plans for over 12,500,000
farmland acres using the advice and aid of the Soil
Conservation District offices.

The Soil Conservation Service of the U.S. Department
of Agriculture is active  in planning and financing water-
shed programs under Public Law 566 to reduce soil erosion.
Currently 635,000 acres of watershed have been developed
or are under construction and an additional 800,000 acres
are in the planning stages.

Marked results in soil loss reduction have been effected
on lands under soil management programs; however, these
programs cover less than half the farmland acreage.  In
addition, changing farming practices and the trend to-
ward larger farms and machinery as described previously
tend to increase the erosion problem.

The Water Pollution Control Commission endorses the action
of the State Soil Conservation Committee, the Soil Conser-
vation Service and others, and plans to continue to work
with them to further reduce agricultural wastes resulting
from erosion.
-------
                         -35-

Aqricultural Chemicals

With the increasing demand for higher yields, farmers
are increasing the amount of herbicides, pesticides and
fertilizer applications to their lands.  Invariably,
considerable amounts of these chemicals find their way
to the waters of the state.  In sufficient concentration
many of these chemicals can exert a toxic effect upon
the aquatic life present in the receiving water.
Fertilizers of nitrate and phosphate base supply nutrients
which can support undesirable algal populations capable
of producing taste and odors or possible toxic wastes.
The control of these wastes must be in the application
methods and the prevention of farmland runoff.

The state has been monitoring the surface waters since
1965 for chlorinated hydrocarbon pesticide levels.  Plans
are being made for the expansion of the monitoring
program.

Feedlot Wastes

An increasing potential source of stream pollution is the
waste from sizeable farm feedlots.  Currently there are
100 farms feeding over 1,000 head of cattle, 10 farms
feeding over 2,500 hogs and 2 farms raising over 50,000
chickens.  Although there are few records available re-
garding feedlot waste problems in the state, a few
individual cases indicate that some problems of pollution
do exist.  The increasing concentration of livestock on
fewer farms and the resulting larger operations will
present additional waste disposal problems.

A study committee comprised of three Commission members,
two agricultural engineers and a veterinarian from Iowa
State University was formed in November of 1966 to study
the feedlot waste problem and recommend corrective measures
toward waste control.  The committee advised the Commission
that:

    1.  Feedlots can be a source of considerable stream
        pollution when improperly designed.
    2.  A permit system for large operations may be a
        control measure.
    3.  Education of the feedlot owners may produce
        effective results to control feedlot runoff.
    4.  The control of feedlot wastes could be insti-
        gated through Rules and Regulations of the
        Commission.
-------
                         -36-

Feedlot Wastes...continuedi.*.

As additional information and experience becomes
available providing an effective means of control-
ling feedlot wastes, the Commission will consider and
adopt those measures which  are best suited to control
the pollution problem.

4.  WASTE FROM BOATS AND MARINAS

Wastes from marinas and boats in the opinion of the
Water Pollution Control Commission and the State Con-
servation Commission do not  currently present a serious
pollutional problem to the  state waters.  Representatives
of the State Conservation Commission and State Depart-
ment of Health attended a joint meeting with western
bordering states, concerning marina and boat wastes, to
discuss methods for the prevention of pollution from
these sources.

It is the plan of the Water  Pollution Control Commission
and the State Conservation Commission to initiate legis-
lation in the next General Assembly that would control
marina and boat wastes.  It  is anticipated that the
legislation will require holding tanks which store wastes
from marine toilets for subsequent shore disposal.  Suf-
ficient time will be incorporated in the legislation to
allow existing facilities to comply with the requirements.
-------
                        -37-

                      SECTION IV
                    PUBLIC HEARINGS

 The Iowa Surface Water Quality Criteria are designed
 to protect the waters of the state for those present
 and future uses which are most beneficial to the people.
 To accomplish this goal,  the Iowa Water Pollution Control
 Commission developed tentative standards and presented
 these to the  public at seven public hearings throughout
 the state.

 The procedures which the Commission followed to conduct
 the public hearings are outlined and discussed below:

    1.  Hearing Notice

        The Commission distributed 6500 hearing notices
 to all parties interested and affected by the criteria.
Those maim groups which received hearing notices were:
 Agriculture,  Conservation,  Government,  Industry,  and
 Municipalities.    The distribution list is shown in
 Appendix A-l.   The hearing notice contained the follow-
 ing information:

    a.  Hearing locations,  times,  etc.
    b.  Explanation of hearing
    c.  Streams and water  sheds pertaining to each
        hearing location(map)
    d.  Tentative criteria

 A  copy of the  hearing notice  is presented in Appendix  A-2.

    2.   Hearing Advertisement

    The Commission advertised  the  hearing  times  and
 locations in  the  newspapers  of the seven  municipalities
 where the hearings were scheduled in three publications
 at weekly intervals.   The  newspapers and  publication
 dates and copies  of the advertisement  of  the hearings
 are shown in Appendix A-3  and 4 respectively.

    3.   Hearing Proceedings

    At the opening of each  hearing a  Commission  member
 acting as chairman read the opening  statement which  is
 presented in Appendix A-5.  The statement presented  the
 history of  the proposed criteria,  application of  the
 criteria, purpose of the public hearing and  the means  by
 which the criteria  will be enforced.
-------
                       -38-
3.  Hearing Proceedings ... continued...

     All seven public hearings were well attended by a
broad representation of the public interested and affect-
ed by the proposed criteria.  A listing of all those
attending and those who presented oral or written state-
ments is shown in Appendix A-6.  Attendance averaged
over 100 persons per hearing.

     4.  Statements

     Oral and written statements presented at each hearing
expressed the interests of all major groups,  organizations
and individuals.  Tape recordings were made at all hear-
ing locations and a summary of statements presented was
compiled and is presented in Appendix A-7.

Upon completion of the seven hearings the Commission re-
viewed the opinions expressed towards all aspects of the
proposed criteria.  It was felt that much was gained
towards knowledge of public opinion concerning the criteria
and changes that were proposed.

A majority of statements presented were in total agree-
ment with the proposed criteria.  The remaining state-
ments were again in agreement with the criteria with some
exceptions regarding parameters, water uses or classi-
fications .

Upon review of the hearing record and data available
the Commission revised the proposed criteria and adopted
them as the Iowa Surface Water Criteria on February 28,
1967.
*Appendices A-l through A-7 referred to in Section IV
 have been omitted from this copy.
-------
  TABLES
FIGURES
-------
-39-






















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                                    -41-
                                 TABLE  2
                      Public Surface Water  Supplies
 Lake or Stream Supply

 Municipality

 Adel
 Arnolds Park
 Bedford
 Burlington
 Cedar Rapids
 Clarinda
 Clear Lake
 Council Bluffs
 Davenport
 Des Moines
 Fort Madison
 Glenwood
 Iowa City
 Keokuk
 Lake Park
 Milford
 Okoboji
 Ottumwa
 Panora
 Spirit  Lake
  Source

  Raccoon River
  W. Okoboji  Lake
*102  River
*Mississippi River
*Cedar River
*Nodaway River
  Clear Lake
*Missouri River
*Mississippi River
  Raccoon River
*Mississippi River
 Keg Creek
  Iowa River
*Mississippi  River
  Silver Lake
 W. Okoboji Lake
 W. Okoboji Lake
*Des Moines River
 Raccoon River
 Spirit Lake
Consumption
   MOD

   0.2 mgd
   0.2
   0.15
   5.0
  Standby
   0.5
   0.5
   6.0
  14.0
  30.0
   1.2
   0.1
   4.0
   3.0
   0.1
   0.15
   0.1
   5.0
   0.1
   0.5
 Treatment
 Provided


 F  S  D
     n
 (i    it
 ft  n  n
 «  n  n

 «»    ii
 11    11
 ii  ti  it

 it    ii
 ii  ii  ii
 ii    n

 ii  ii  ii
 it  ii  ii
 ii  it  n
 ii  it  ii
     ii
     it
ii ii ii
ft n !•

II II  II
* Denotes  Interstate  Stream
F - Filtration           S - Softening
                            D - Disinfection
Impoundments
Afton
Albia
Allerton
Blcornfield
Centerville
Chariton
Corning
Corydon
Creston
Fairfield
Greenfield
       Humeston
       Lamoni
       Lenox
       Montezuma
       Mount Ayr
       Osceola
       Seymour
       Tabor
-------
                               TABLE 3
                   AQUATIC LIFE - WARM WATER AREAS
                                 -43-
      Streams

Missouri River Basin

* Chariton River

* Thompson River

* Nodaway River

     E. Nodaway River
     W. Nodaway River
     Mid. Nodaway River

* Nishnabotna River

     E. Nishnabotna River
     W. Nishnabotna River

* Missouri River

Boyer River

* Little Sioux River

     *0cheyedan River
     W. Fk. Little Sioux
     Maple River

* Big Sioux River

     *Rock River

Mississippi River Basin

* Des Moines River

     *E. Fk. Des Moines River
     *W. Fk. Des Moines River
     Middle River
     Raccoon River

          S. Raccoon River
          N. Raccoon River

           M. Raccoon River
     Boone River

Skunk River

     N. Skunk River
     S. Skunk River
            Reach of Stream
Missouri State Line to Bridge on Highway
#65
Missouri State Line to Union County Line

Missouri State Line to confluence of East
and West Nodaway
Nodaway to Highway #148
Nodaway to Morton Hills
Nodaway to Adair County Line

Missouri State Line to confluence of East
and West Nishnabotna
Nishnabotna to Atlantic
Nishnabotna to Avoca

Western Iowa border from Missouri State
Line to Sioux City
Missouri River to Denison

Missouri River to Milford

Little Sioux River to Highway #9
Little Sioux River to Climbing Hill
Little Sioux River to Ida Grove

Missouri River to Minnesota State Line

Big Sioux River to Minnesota State Line
Mississippi River to confluence of East
and West Forks of Des Moines River
Des Moines River to Burt
Des Moines River to Minnesota State Line
Des Moines River to Town of Middle River
Des Moines River to confluence of North
and South Raccoon
Raccoon River to Guthrie Center
Raccoon River to Buena Vista County
Line
Raccoon River to Coon Rapids
Des Moines River to Goldfield

Mississippi River to confluence of North
and South Skunk
Skunk River to Highway #92
Skunk River to Colfax
-------
                                   -44-
TABLE 3 CONTINUED
*Mississippi River


Iowa River

     *Cedar River
          W. Fk. Cedar River
          *Shell Rock River
                *Winnebago River
          *Little Cedar
     English River

*Wapsinicon River

     Buffalo Creek
     Little Wapsipinicon River

Maquoketa River

     N. Fk. Maquoketa River

Turkey River
     Little Turkey River
          Crane Creek
     Volga River

Yellow River

*Upper Iowa River
Eastern Iowa border from Missouri
State Line to Minnesota State Line

Mississippi River to Belmond

Iowa River to Minnesota State Line
Cedar River to Cerro Gordo County Line
Cedar River to Minnesota State Line
Shell Rock River to Minnesota State Line
Cedar River to Minnesota State Line
Iowa River to Kinross

Mississippi River to Minnesota State Line

Wapsipinicon River to Stanley
Wapsipinicon River to Sumner

Mississippi River to Backbone State Park

Maquoketa River to Dyersville

Mississippi River to Vernon Springs
Turkey River to Highway #24
Little Turkey River to Saratoga
Turkey River to Maynard

Mississippi River to Highway #51

Mississippi River to Chester
* Denotes Interstate Stream
-------
      -45-
   TABLE 4

NATURAL LAKES
County
Allamakee

Buena Vista
Calhoun
Cerro Gordo
Clay

Delaware
Dickinson








Emmet



Hamilton
Hancock

Harrison
Johnson
Kossuth
Lee
Louisa
Monona
Muscatine
Os ceo la
Palo Alto


Pocahontas
Pottavattamie
Sac
Winnebago
Woodbury
Worth
Wright
Lakes
Kains Lake
Lansing Big
Storm Lake
North Twin
Clear
Dan Greene Slough
Elk
Silver
Center
Diamond
East Okoboji
Lower Gar
Upper Gar
Minnewashta
Hottes
Jenmerson Slough
Little Spirit
Cheevers
Four Mile
High
Iowa
Little Wall
Crystal
Eagle
Nobles (Pott. Co,)
Babcocks
Goose
Green Bay
Wapello (Klum)
Blue
Keokuk
Rush
Five Island (Medium)
Lost Island
Rush
Clear
Manawa
Black Hawk (Wall)
Duck (Harmon)
Browns
Brights
Cornelia
Acres
200
679
3,060
569
3,643
285
261
45
264
166
1,875
_.-
«•«»••
<•••••
312
100
214
341
219
467
308
273
283
906
160
58
103
272
212
918
511
359
945
1,260
460
187
660
957
72
840
122
385
Lakes
Mud
New Albin Big
Pickeral (Clay Co.)
South Twin

Round
Trumbull

Marble
Pleasant
Prairie
Silver
Spirit
Swan
Welch
West Okoboji

Ingham
Tut tie
Twelve Mile
West Swan

East Twin
West Twin

Swan
Swag



Muscatine Slough
Iowa
Silver
Virgin

Lizzard


Rice (Worth Co.)

Silver
Elm
Acres
164
200
176
600

450
1,190

175
82
136
1,068
5,684
371
75
3,939

421
981
290
1,038

193
109

44
46



237
116
638
200

268


612

318
463
-------
                                   -47-
                                 TABLE 5
                            Artificial Lakes
        County

 Ad air
 Carroll
 Cass
 Davis
 Decatur

 Des Moines and Henry
 Franklin
 Greene
 Guthrie
 Hancock

 Hardin
 Hardin
 Jasper
 Johnson
 Lucas

 Mahaska
 Monroe
 Montgomery
 0'Brien
 Shelby

 Tama
*Taylor
 Union
 Van Buren
 Warren

 Washington
 Wayne
       Lake

Meadow Lake
Swan Lake
Cold Springs
Lake Wapello
Nine Eagles

Geode
Beeds Lake
Spring Lake
Springbrook
Pilot Knob

Pine Lake
Upper Pine Lake
Rock Creek Lake
Lake MacBride
Red Haw Hill

Lake Keomah
Miami
Viking Lake
Mill Creek
Prairie Rose

Union Grove
Lake of Three Fires
Green Valley Lake
Lacey-Keosauqua
Lake Ahquabi

Lake Darling
Allerton
Acres

  42
 130
  16
 287
  56

 205
 130
  49
  27
  15

  63
 101
 640
 950
  72

  82
 143
 150
  25
 218

 110
 125
 390
  30
 130

 302
 115
    On lakes of over 100 acres no motor in excess of 6 H.P.  allowed.
-------
                      -49-

                   TABLE 6
     AQUATIC LIFE  USE - COLD WATER AREAS
  COUNTY
ALLAMAKEE
STREAM            MILES
CLAYTON
DELAWARE
DUBUQUE
FAYETTE
HOWARD
           Bear  Creek                     1
           Clear Creek                    1
           French  Creek                   4
           Hickory Creek                  4
           Little  Paint Creek             2.5
           Livingood Springs and
           Yellow  River Confluence area   1
           Paint Creek                    7
           Teeple  Creek                   2.5
           Village Creek                  6
           Waterloo Creek                 6.5
           Wexford Creek                  1.5
          Bloody Run Creek              9
          Buck Creek                    6
          Ensign Hollow                 2
          Joy Springs & Maquoketa Riv.  2
          Klienlein Creek               3
          North Cedar Creek             2
          Plum Creek                    1.5
          South Cedar Creek             3
          Turkey River Adjacent to Big
          Springs Hatchery               .75
          Elk Creek                     1
          Maquoketa River               2
          Richmond Springs              1
          Spring Branch                 2
          Turkey Creek                  1
          Plum Creek                     .5
          Swiss Valley Creek            1.5
          Glovers Creek                 1
          Grannis Creek                 1
          Mink Creek                    2
          Otter Creek                   4
          Bigalk Creek
-------
Table 6 cont.
                                   -50-
               COUNTY
              JACKSON
              MITCHELL
STREAM
                        Big Mill greek
                        Brush Creek
                        Dalton Lake
                        Little Mill Creek
                        Spring Creek
                        Turtle Creek
                        Wapsie River
MILES
              WINNESHIEK
                        Bohemian Creek
                        Coldwater Creek
                        North Bear Creek
                        South Bear Creek
                        Trout River
                        Trout Run
                        Twin  Springs
                        West  Canoe Creek
                    1.5 acres
                    5
                    2
                    2
                    2.5
                    3
                    2.5
                    5
                    5
                    2.5
                    2
                    0.5
-------
                                   -51-

                                 TABLE 7
               DESIGNATED RECREATION AREAS ON IOWA STREAMS
River or Stream Areas

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
NEAREST TOWN
Minnesota-Missouri
A Id en
Anamosa
Bonaparte
Cedar Falls
Cedar Rapids
Central City
Charles City
Clarksville
Coralville Reservoir
Decorah
Delhi
Des Moines
Elkader
Fort Dodge
Greene
Hopkinton
Humboldt
Independence
Iowa City
Iowa Falls
Lime Springs
Manchester
Maquoketa
Mitchell
Monticello
Nashua
Oakland Mills
Ottumwa
Palisade State Park
Quasqueton
Red Rock Reservoir
Saylorville Reservoir
Steamboat Rock
Waterloo
Waver ly
                                         STREAM

                                   Mississippi River
                                   Iowa River
                                   Wapsipinicon River
                                   Des Moines River
                                   Cedar  River

                                   Cedar River
                                   Wapsipinicon River
                                   Cedar River
                                   Shell Rock River
                                   Iowa River

                                   Upper Iowa River
                                   Maquoketa River
                                   Des Moines River
                                   Turkey River
                                   Des Moines River

                                   Shell Rock River
                                   Maquoketa River
                                   Des Moines River
                                   Wapsipinicon River
                                   Iowa River

                                   Iowa River
                                   Upper Iowa River
                                   Maquoketa River
                                   Maquoketa River
                                   Cedar River

                                   Maquoketa River
                                   Cedar River
                                   Skunk River
                                   Des Moines River
                                   Cedar River

                                   Wapsipinicon River
                                   Des Moines River

                                   Des Moines River

                                   Iowa River
                                   Cedar River
                                   Cedar River
RECREATION ZONE

Iowa Border
Above Dam
Above Dam
Above Dam
Above Dam

Above Dam
Above Dam
Above Dam
Above Dam
Recreation Pool

Above Dam
Above Dam
Above Dam
Above Dam
Above Dam

Above Dam
Above Dam
Above Dam
Above Dam
Above Dam

Above Dam
Above Dam
Above Dam
Above Dam
Above Dam

Above Dam
Above Dam
Above Dam
Above Dam
Above Dam

Above Dam
Recreation Pool
(Under construction)
Recreation Pool
(Under construction)
Above Dam
Above Dam
Above Dam
-------
                                -52-
Table 7 cont.

NATURAL AND ARTIFICIAL LAKES

All natural and artificial lakes listed in TABLES 4 and 5 Aquatic Life
Warm Water Areas shall be also classified for Recreational Use.
FUTURE POTENTIAL RESERVOIRS FOR RECREATIONAL USE;

When the following reservoirs are built their impounded waters will be
classified for Recreational Use.
         NAME

Ames Reservoir
Central City Reservoir
Davids Creek Reservoir
Jefferson Reservoir
Rathbun Reservoir
Rochester Reservoir
Squaw Creek Reservoir
   STREAM

Skunk River
Wapsipinicon
Davids Creek
Raccoon River
Chariton River
Cedar River
Squaw Creek
   STATUS

Authorized
Authorized
Needs Authorization
Study Conducted
Authorized
Authorized
Planning Stage
-------
                                  -53-
                                TABLE 8

                    SURFACE WATER SAMPLING STATIONS
                   ABS, PESTICIDES AND RADIOACTIVITY
ABS
PESTICIDES
RADIOACTIVITY
 STREAMS

 Cedar  River
 Des Moines River
 Des Moines River
 Iowa River
 Raccoon River

 Cedar River
 Iowa River
 Mississippi River
 Mississippi River
 Missouri River
 Raccoon River

 Big Sioux River
 Cedar River

Des Moines River
                       Iowa River
                       Mississippi River
                       Missouri  River

                       Raccoon River
                       Skunk  River

                          Lakes

                       Clear  Lake
                       Okoboji

                          Impoundments

                       Corning
                       Fairfield
                       Greenfield
 LOCATION

 Cedar Rapids
 Des Moines upstream
 Des Moines downstream
 Iowa City
 Des Moines (IPALCO)

 Cedar Rapids
 Iowa City
 Dubuque
 Davenport
 Council  Bluffs
 Des Moines

 Hawarden
 Osage
 Cedar Rapids
 Des Moines upstream
 Des Moines downstream
 Estherville
 Ottumwa
 Iowa City
 Lansing
 Dubuque
 Davenport
 Ft,  Madison
 Sioux City
 Council  Bluffs
 Des Moines
Ames
-------
                                   -55-
                                 TABLE  9

                     SURFACE WATER SAMPLING STATIONS
                  PUBLIC WATER SUPPLIES AND MAJOR CITIES
 Stream

 Big Sioux River


 Cedar  River
Charitem River
Des Moines River
East Fork Des Moines River


Fox River

Little Sioux



Mido Fork Medicine Creek

Mississippi River
Missouri River


Nishnabotna River

Nodaway River

102 River

Rock River
 Location

 Hawarden
 Sioux City

 St. Ansgar
 Charles  City
 Waterloo
 Cedar Rapids
 Columbus Jet,

 Chariton
 Centerville

 Fort  Dodge
 Des Moines
 Ottumwa
 Keokuk

 Do1liver
 Dakota City

 Bloomfield

 Spencer
 Cherokee
 Jet. with Mo,

Allerton

Dubuque
Clinton
Davenport
Burlington
Fort Madison
Keokuk

Sioux City
Council Bluffs

Hamburg

Clarinda

Bedford

Rock Rapids
Jet. with Big Sioux
 A,  B
 A*

 A
 A,  B
 A,  B
 A*,  B
 A,  B

 B
 A,  B

 A*,  B
 A*,  B
 A*,  B
A

 A
 A

 A,  B

 A,  B
 A,  B
 A

 B

 A*,  B
A*,  B
 A*,  B
A*,  B
A*,  B
A*,  B

A*,  B
A*,  B

A, B

A*,  B

A*,  B

A, B
A
-------
TABLE 9 CONTINUED
                                   -56-
Streata

Shell Roclc River

Upper Iowa River


VJapsipinicon River



West Fork Des Moines River



Winnebago River
Location

Northwood                  A

Decorah                    A, B
New Albin                  B

Independence               A, B
Anamosa                    A, B
Jet. with Mississippi      A

Estherville                A, B
Emmetsburg                 A, B
Humboldt                   A

Lake Mills                 A
Mason City                 A, B
     A - Location above water supply inlet or waste outlet
     B - Location below waste outlet after adequate mixing
     * - Locations presently sampled
-------
-57-



















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-------
APPENDIX B
-------
                                APPENDIX B
         Iowa
 Water Pollution
   Control Law
      CODE OF IOWA
          1966
          IOWA

 WATER POLLUTION CONTROL

       COMMISSION
STATE DEPARTMENT OF HEALTH
   ROBERT LUCAS BUILDING
    DES MOINES, IOWA 50319
-------
                                                    APPENDIX B
        Address Communications To:
Iowa Water Pollution Control Commission
    Iowa State Department of Health
           Robert Lucas Building
          Des Moines, Iowa 50319
            Telephone 281-5345
-------
                                                         APPENDIX B
             CHAPTER 455B
      WATER POLLUTION CONTROL
               Referred to in J455.22
          Pesticides, §206.3, subsection 2(d)


 455B.1  Statement of policy.
 455B.2  Definitions.
 455B.3  Commission created.
 455B.4  Membership.
 455B.5  Terms.
 455B.6  Vacancies—removal of member.
 455B.7  Compensation.
 455B.8  Organization.
 455B.9  Powers and duties.
 455B.10 Investigations.
 455B.11 Orders.
 455B.12 Scope of investigation.
 455B.13 Quality standards.
 455B.14 Permission to enter lands or waters.
 455B.15 Hearings.
 455B.16 Subpoena.
 455B.17 Notice of hearing—orders—records.
 455B.18 Appeal.
 455B.19 Transcript on appeal.
 455B.20 Stay order.
 455B.21 Conclusiveness of action.
 455B.22 Trial term.
 455B.23 Injunction.
 455B.24 Contempt—penalty.
 455B.25 Unlawful acts.
 455B.26 Plans of every disposal  system to be
          filed.
455B.27 Assistance  by governmental agencies.
455B.28 Discharge of waste into lakes.
  455B.1  Statement of  policy. Whereas  the
pollution of the waters of this state constitutes
a menace to public health and welfare, creates
public nuisances,  is harmful to wildlife,  fish
and  aquatic life, and  impairs domestic, agri-
cultural,  industrial,  recreational  and  other
legitimate   beneficial  uses   of   water,   and
whereas the problem of water pollution in  this
state is closely related to the problem of water
pollution in adjoining states, it is hereby de-
clared to be the public policy  of this state to
conserve the waters of the state and to protect,
maintain and  improve the quality thereof for
public water supplies, for the propagation of
wildlife, fish and aquatic life, and for domestic,
agricultural, industrial, recreational and other
legitimate  (beneficial) uses; to provide  that
no waste be discharged into any waters of the
state without  first being given the degree of
treatment necessary to protect the legitimate
(beneficial) uses of such  waters; to provide for

                     -3-
-------
                                                         APPENDIX B
the prevention, abatement and control of new,
increasing, potential,  or  existing water pollu-
tion; and to co-operate with other agencies of
the state, agencies of  other states and the fed-
eral government in  carrying  out  these  ob-
jectives.  [61GA, ch 375,§1]
  455B.2  Definitions.  When used in this chap-
ter:
  1. "Sewage" means  the water-carried waste
products from residences, public buildings, in-
stitutions,  or other buildings, including  the
bodily discharges from human beings or ani-
mals  together  with such ground water infil-
tration and surface water as may be present.
  2. "Industrial waste" means  any  liquid,
gaseous  or  solid  waste  substance  resulting
from  any process of industry, manufacturing,
trade or business or from the development of
any natural resource.
  3. "Other waste"  means  garbage,  municipal
refuse, lime, sand, ashes, offal, oil, tar, chem-
icals  and  all other substances which are  not
sewage or  industrial waste which may pollute
the waters of the state.
  4. "Pollution" means the  contamination of
any waters of the state  so as to create a nui-
sance or render such waters unclean, noxious
or  impure so as to be actually harmful, detri-
mental or injurious  to  public health, safety
or welfare, to domestic, commercial, industrial,
agricultural or recreational use or to livestock,
wild  animals, birds, fish or other aquatic  life.
  5. "Sewer  system"  means pipe lines or con-
duits, pumping stations, force mains and  all
other constructions,  devices and  appliances
appurtenant thereto used for conducting sew-
age or industrial waste or other wastes to a
point of ultimate disposal.
  6. "Treatment works" means any plant, dis-
posal field, lagoon, holding or flow regulating
basin, pumping  station, or other  works  in-
stalled for the purpose of treating, stabilizing
or  disposing of  sewage, industrial  waste or
other wastes.
  7. "Disposal system"  means  a  system for
disposing  of  sewage,  industrial  waste  and
other wastes  and  includes sewer  systems,
treatment works,  and dispersal  systems.
  8. "Waters of the state" means all  streams,
lakes, ponds,  marshes,  watercourses, water-
ways, wells, springs, reservoirs,  aquifers,  irri-
gation systems, drainage systems, and all other
bodies or  accumulations of  water,  surface or
underground,  natural or artificial, public or
private, which are  contained  within,  flow
through or border  upon the state or  any  por-
tion thereof.

                     -4-
-------
                                                         APPENDIX B
  9.  "Person"  means the state or  any agency
or institution  thereof,  any municipality, gov-
ernmental  subdivision,  public or private cor-
poration,  individual, partnership,  or other
entity and includes any  officer or governing or
managing body  of any municipality,  govern-
mental subdivision or public  or private corpo-
ration.
  10. "Commission"  means  the  Iowa water
pollution  control  commission.   [61GA,  ch
375,§2]
  Referred to in {4S6B.2S

  455B.3  Commission created. There  is  here-
by  created  and established  the  Iowa water
pollution control  commission. The  commis-
sion is established as an agency  of the  state
government to prevent, abate, or control the
pollution of the waters of the state.  [61GA,
ch 375,§3]
  455B.4  Membership.  The commission  shall
consist of nine members as follows:
  1. The  commissioner of public health.
  2. The  director  of the state conservation
commission.
  3. The director of the Iowa natural resources
council.
  4. A member  from the staff of one of the
universities or colleges of the state who has
technical background, training and knowledge
in the field of water pollution.
  5. The secretary of agriculture.
  6. Four electors of the state who shall be
selected from the state at large  solely  with
regard to their qualifications and fitness to
discharge the  duties of office without regard
to their political affiliation. Of these four, one
shall represent industry,  one shall  represent
municipal government, one shall be an owner-
operator  farmer, and one shall represent the
public at large.  [61GA, ch 375,§4]

  455B.5  Terms.  The members  of  the  com-
mission not holding public office shall be ap-
pointed by  the governor for overlapping terms
of six years.  The members  of the  first  com-
mission not holding public office shall be ap-
pointed for the following terms:  two  electors
for a term  to  expire July 1, 1967; two  electors
for a term to  expire July 1, 1969; and  a mem-
ber of one  of the state universities for a term
to expire July 1, 1971.  Said terms shall begin
immediately upon  the appointment. Thereafter
the term of each  member of the  commission
shall be six years. [61GA, ch 375,§5]
  455B.6  Vacancies—removal of member. Any
vacancy or vacancies on the commission which
                     -5-
-------
                                                       APPENDIX  B
may occur shall be filled by appointment by
the governor for the unexpired portion of the
regular term.
  The  governor may remove any member  of
the commission  for  malfeasance in office  or
for any cause that renders him ineligible for
membership or incapable or unfit to discharge
the duties of his office  and his removal when
so made shall be final.  [61GA, ch 375,§6]
  455B.7  Compensation.  Each member of the
commission, not otherwise in  the full-time em-
ployment of any public body,  shall receive the
sum of twenty-five dollars for each day actually
and necessarily employed in  the discharge  of
official duties  and  each member of the  com-
mission shall be entitled to receive the amount
of his traveling and other necessary expenses
actually incurred while  engaged in the per-
formance of any official duties when  so author-
ized by the commission.  No member  of the
commission shall have  any direct financial in-
terest in any of the operations of the commis-
sion, nor may any member participate in mak-
ing any decision in which he  may have a per-
sonal interest. [61GA, ch 375,§71
  455B.8  Organization.  The commission shall
organize by the election  of  a  chairman and
other officers deemed necessary and the state
department of health shall provide the services
of a technical secretary to the commission and
shall  hold quarterly regular meetings  each
calendar year on the last Monday of each quar-
ter and at such  other  times  and places  as it
may deem necessary. The chairman and other
officers shall be elected  annually.  Meetings
may be called by the chairman at any time and
shall be called as soon as possible by the chair-
man on the written request of four members
of the  commission.  The majority of the  com-
mission shall  constitute  a quorum and the
concurrence of a majority of the commission
in any matter within  its duties shall be re-
quired for its determination. [61GA, ch 375,§8]
  455R.9  Powers and duties.  The commission
is hereby  given and. charged  with the follow-
ing powers and duties:
  1. The commission through the state depart-
ment of health shall have general supervision
over administration  and  enforcement of all
laws relating to the pollution of any water of
the state, except as provided in section 135.11.
  2. To develop comprehensive plans and pro-
grams  for  the prevention, control and abate-
ment of new, increasing, potential, or existing
pollution of the waters of the state.
  3. The commission may cause the state de-
partment  of health to conduct investigations

                    -6-
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                                                         APPENDIX  B
 upon the written petition of:
  a. The governing body of any city or town.
  b. The local board of health.
  c. The supervisors of  any county.
  d. Twenty-five residents of the state.
  e. Any state agency or agencies.
  4. To adopt, modify, or repeal such reason-
 able quality standards  for  any waters of the
 state in relation to the public use to which
 they are or may be put as it shall deem neces-
 sary for the purposes of this chapter.
  Provided that where the quality of water is
 inter-related to the quantity of water the con-
 currence of the Iowa natural resources council
 shall be secured for the  adoption, modification
 or repeal of such standards, prior to the effec-
 tive date thereof.
  5. To  require plans  and  specifications for
 disposal systems or any part thereof to be sub-
 mitted to them for approval or disapproval by
 the state department of health.
  6. To direct the state  department of health
 to  issue, revoke,  modify,  or deny  permits,
 under such conditions  as it may prescribe for
 the prevention or abatement  of pollution, for
 the discharge of sewage, industrial waste or
 other wastes or for the  installation or opera-
 tion of disposal  systems  or parts thereof.
  7. Existing permits shall be recognized by
 the commission for the  continuance of every
 disposal system  now  operating under  legal
 authority.   However,  the  commission   may
 modify  or revoke  such permit in the  same
 manner as other permits.
  8. To prescribe rules and regulations for the
 conduct  of the  commission  and other matters
 within the scope of the powers granted to and
 imposed upon it.
  9. The  commission  'shall  co-operate  with
 other state or interstate water  pollution con-
 trol agencies  in  establishing standards,  ob-
 jectives  or criteria for  quality of interstate
 waters  originating or  flowing through  this
 state.
  10. To hold such hearings  as it  may  deem
 advisable and necessary for the discharge of
 its duties and to authorize any member, em-
 ployee or agent to hold such hearings. [61GA,
ch 375,§9]
  See SS456A.25. subsection 3, 469.6 to 469.8 inc.
  455B.10  Investigations.  The state  depart-
ment of health  shall conduct such investiga-
tions as may be necessary to carry out  the
 provisions of this  chapter.  [61GA, ch 375,§10]
  455B.11  Orders.  The  state department of
health  in accordance with  the  direction and
policies of the commission may issue, modify,

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                                                         APPENDIX  B
or revoke such orders as may be required for
the prevention or discontinuance of the dis-
charge of sewage,  industrial waste or  other
wastes in any waters of the state resulting in
pollution  in excess of  the applicable  quality
standard  established   by  the  commission.
[61GA, ch 375,111]

  455B.12 Scope of investigation.  Whenever
an investigation is made, it  shall be full and
complete  and may include such engineering
studies, bacteriological, biological, and chemi-
cal analyses of the water and location and
character of the source or  sources of contami-
nation as may be  necessary.  If pollution is
found to  exist, taking  into consideration  the
criteria set forth in section 455B.13, the com-
mission shall  first notify the alleged offender
and by informal negotiation attempt to resolve
the problem and failing to do so within four-
teen days, up to and during which time nei-
ther the commission, nor any member of  the
commission, nor its staff or employees shall
make any public statement regarding the firm
or individual as an  alleged offender, shall then
make an order fixing the time and place of
hearing which shall be not later than twenty
days thereafter. Such hearing shall be public
and shall be conducted so far as possible in
the same manner as a court hearing and  every
alleged  offender  shall  have  the right  to  ap-
pear, be  represented by counsel, present testi-
mony and examine witnesses.  [GIGA, ch 375,
§12]
  Examinations made by bacteriological laboratory, J263.8
  455B.13 Quality  standards.   In  adopting,
modifying, or repealing quality standards  for
any waters of the state, the  commission shall
give consideration to:
  1. The protection of the public health;
  2. The  size,  depth,   surface area  covered,
volume,  direction  and  rate of flow, stream
gradient,  and  temperature of the water;
  3. The character and uses of the  land area
bordering said waters;
  4. The  uses which   have  been  made,  are
being made, or may  be made of said waters
for public,  private, or domestic water sup-
plies, irrigation; livestock  watering;  propaga-
tion of wildlife,  fish,  and other aquatic life;
bathing,  swimming, boating, or other recrea-
tional activity; transportation; and disposal of
sewage and wastes;
  5. The  extent  of contamination  resulting
from natural causes including the mineral  and
chemical  characteristics;
  6. The extent to which floatable or settleable
solids may be permitted;

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                                                        APPENDIX  B
  7. The extent to which suspended solids.
colloids, or a combination of solids with other
suspended substances may be permitted;
  8. The extent to which bacteria  and other
biological organisms may be permitted;
  9. The amount of dissolved oxygen that is to
be present and the extent of the  oxygen de-
manding substances which may be  permitted;
  10. The extent to which toxic  substances,
chemicals or  deleterious conditions  may  be
permitted;
  11. The need for standards for effluents from
disposal systems.  [C1GA, ch 375,§13]
  Referred to in J455E.12
  455B.14 Permission to  enter iands or waters.
The commission, its agents, and employees of
the state department of health may enter upon
any lands or waters in the state and bordering
on the state, for the purpose of making any in-
ves'.igaaon,  examination, survey, or study con-
cerning the  quality or pollution of surh waters.
[61GA, ch  375,§14]
  -I55B.13 Hearings.   When  the commission
or  state department  of  health conduct? any
hearing or  investigation,  any member of the
commission  or  any employee or  agent au-
thorized in  writing by the commission or em-
ployee of the state department of health may
administer oaths, examine witnesses and issue,
in the  name of the commission, subpoenas  re-
quiring the  attendance and testimony of wit-
nesses and the production of evidence  relevant
to any matter invch ed in such hearing or  in-
vestigation.  Witnesses shall receive the  siine
fees and mileage  as in civil actions.  [61GA,
ch 375,§15]
  455B.1C Subpoena.   If  any person refuses
to obey a subpoena issued under this  chapter,
the district court of the county where the pro-
ceeding  is  pending shall have jurisdiction,
upon application of the commission or its au-
thorized member, employee, or agent,  to  issue
to such person an order  requiring him to ap-
pear and testify or produce evidence  and any
failure to obey such order of the court may be
punished by said court as a contempt thereof.
[61GA, ch 375,§16]
  455B.17 Notice of hearing—orders—records.
  1. Notice  of the time and place  of  hearing
shall be served upon each alleged  offender at
least ten days before said  her ring.  Such notice
shall be in tne manner  required for the service
of notice of  the commencement of an ordinary
action in a court of record.
  2. Notwithstanding the provisions of subsec-
tion 1 the commission  or state department of
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                                                       APPENDIX  B
health, when it has first been determined that
an  emergency  exists respecting any  matter
affecting or likely to affect the public  health,
may make a temporary order without notice
and without hearing.  A copy of such  tempo-
rary order shall be served as provided  in sub-
section 1.  Any such temporary order entered
by the commission or the state department of
health, shall be binding and effective immedi-
ately until such order is reviewed by a hear-
ing or is modified or reversed by the court.
  3. After such hearing the commission may,
if it finds the alleged offender is guilty of the
charges,  enter an order directing such  person
to desist in the practice found to be the cause
of such pollution, taking into account the use
to which the water is being or may be put or
the commission upon the recommendation of
the state department of  health  may order a
change in the method of discharging sewage,
industrial wastes  and  other wastes into  the
water so that the same will not result in pollu-
tion and  the method shall  be in compliance
with  the  effluent or water  quality standards
adopted by the commission.
  4.  If any such change is ordered, unless such
practice is rendering such water dangerous to
the public health, a  reasonable time shall be
granted to the offender in which to put in use
the method ordered.
  5. The commission shall  keep a  complete
record of such proceedings, including  all the
evidence taken, and such record  shall be open
to public inspection.  However, it shall be un-
lawful for any person in connection with his
duties or employment by the commission, to
make public or give any information relating
to secret processes or methods of manufacture
or production at any public hearing or other-
wise, and all such information shall be kept
strictly confidential.  [61GA, ch 375,§17]

  455B.18  Appeal.  An appeal may be taken
by  any aggrieved party from any order en-
tered in such proceedings to the district court
of the county in which the alleged offense was
committed or such final  order  was entered.
Such appeal  shall be perfected  by serving a
written notice on the chairman of the commis-
sion within thirty days of the entry of such
order. The hearing on appeal  shall be tried as
a suit in equity  and  shall be de  novo.  The
court may receive additional testimony  and
may affirm, modify or reverse the order of the
commission.  The setting aside of such order
by the court shall not preclude the commission
from again instituting proceedings against the
same person if the commission feels that the

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                                                         APPENDIX  B
public health is endangered.
§18]
[61GA, ch 375,
  455B.19  Transcript on appeal. Within thirty
days after an application for an appeal is filed
with the commission, it shall make, certify and
file in the office of the clerk of  the court  to
which an appeal is taken a full and complete
transcript of all documents  and  papers  relat-
ing to the case including a  copy  of the order,
rule, regulation or decision appealed from and
a copy of any findings of fact, rulings or con-
clusions  of  law made by the commission  in
the matter.  [61GA, ch 375,§19]

  455B.20  Stay order. Action of the commis-
sion shall not be stayed by  an appeal except
by order of the court for good cause  shown by
the appellant. The granting of a stay may be
conditioned upon the furnishing by the appel-
lant of such reasonable security  as  the  court
may direct.  A stay may be vacated on appli-
cation of the commission or any other  party
after hearing by the court.   [61GA, ch 375,§20]

  455B.21  Conclusiveness of action.  If no ap-
peal is taken from an order, rule, regulation,
or other decision  of the  commission  as pro-
vided by  this chapter, or if  the action of the
commission is affirmed on  appeal, the  action
of the commission in the matter involved shall
be deemed conclusive and the validity and rea-
sonableness thereof shall not be raised in any
other action or proceeding,  but this shall not
preclude the commission from modifying  or
rescinding its action.  [61GA, ch  375,§21]

  455B.22  Trial term.  The  first term after
appeal is taken shall be the  trial term. [61GA,
ch 375,§22]

  45515.23  Injunction. Any  person,  firm, cor-
poration, municipality, or any officer or  agent
thereof causing pollution as  defined  in section
455B.2 of any waters of the  state  or placing or
causing to be placed  any  sewage,  industrial
waste, or other wastes in a location where they
will probably cause pollution of any waters of
the state may  be enjoined from continuing
such action.
  It shall be the duty of the attorney general,
only upon the request of the commission,  to
bring an action for an injunction against any
person,  firm, corporation,   municipality,  or
agent thereof violating the  provisions of this
section.  In any  such  action, any previous
findings of the commission after due notice and
hearing shall be  prima-facie evidence of the
fact or facts found therein.  [GIGA, ch 375,§23]

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                                                        APPENDIX B
  455B.24  Contempt—penalty. Failure to obey
any order issued under the provisions of this
chapter made by the commission with refer-
ence to matters  pertaining to the pollution of
waters of the state shall constitute prima-facie
evidence of contempt.  In such event the com-
mission may certify to the district court of the
county  in  which such alleged  disobedience
occurred the  fact of such failure. The district
court after notice, as  prescribed by  the court,
to the parties in interest shall then proceed to
hear the matter and if it finds that the order
was  lawful and reasonable it shall  order  the
party to comply with the order.  If the person
fails to comply with the court order, he shall
be punished for contempt.
  Any person, firm, corporation, or  any officer
or agent  thereof found  guilty of  contempt
under this section shall be fined in a sum  not
to exceed one hundred dollars for each offense.
The penalties provided in this section shall be
considered as additional to any penalty which
may  be imposed under  the  law relative  to
nuisances or  any other statute relating to  the
pollution of waters of the state and a convic-
tion  under this  section shall  not be a bar to
prosecution  under  any other penal  statute.
[61GA, ch 375J24]

  455B.25  Unlawful acts.
  1. It shall be unlawful to carry on any of the
following  activities without first securing a
written permit from  the  state department of
health as may be required by the commission
for the disposal of all  sewage, industrial waste,
or other wastes which are  or may  be  dis-
charged into  the waters of the state.
  a. The construction, installation or mod.ifica-
tion of any disposal system or part thereof or
any extension or addition thereto.
  b.  The construction or use of any new outlet
for the discharge of any sewage or  wastes di-
rectly into the waters of the state.  However,
no permit shall be required for any new  dis-
posal system or extension or addition to any
existing disposal system  that receives only
domestic or sanitary  sewage from a building,
housing or occupied by fifteen persons or less.
  2. Plans  and  specifications for any waste
disposal system covered by subsection 1 of this
section shall  be submitted to the commission
before a written permit may be issued and the
construction  of  any such waste  disposal sys-
tem  shall be in accordance  with  plans and
specifications as approved by the state depart-
ment of public  health.  If it is necessary or
desirable to  make  material  changes in such
plans or specifications, revised plans or specifi-

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                                                        APPENDIX  B
cations together with reasons for the proposed
changes must be submitted to the  commission
for a supplemental written permit.
  Any person convicted of violating this sec-
tion shall be fined in a sum not to exceed one
thousand dollars.  [61GA, ch 375,§25]

  455B.26   Plans of every  disposal system to
be  filed.  The commission  may  require the
owner of a waste disposal system,  discharging
sewage or wastes into any of the waters of the
state to file with it complete plans of the whole
or any part of such system and any other in-
formation and records concerning  the installa-
tion and operation of such system. [61GA, ch
375,§26]

  455B.27   Assistance by  governmental  agen-
cies.  The  commission  and the state  depart-
ment of health may request and receive from
any  department, division, board, bureau, com-
mission, public body, or agency of the  state,
or of any political  subdivision thereof, or from
any  organization,  incorporated  or unincor-
porated, which' has for its object the control or
use of any of the water  resources of the  state,
such  assistance  and  data as will  enable the
commission or department to  properly  carry
out  its activities and effectuate its purposes
under  the provisions of this chapter. The com-
mission or department  shall reimburse such
agencies  for special  expense  resulting  from
expenditures not normally a part of the oper-
ating expenses of  any  such agency.  [61GA,
ch 375,§27]
  455B.28   Discharge of waste  into lakes. No
sewage,  industrial  waste  or  other  wastes
whether  treated or  untreated  shall be dis-
charged directly into any state-owned natural
or artificial lake but this section shall not be
construed  to  prohibit the discharge of  ade-
quately treated  sewage  or  industrial  wastes
into a stream tributary to a  lake upon the
written permission of the commission.  [GIGA,
ch 375,§28]
  Appropriation, 61GA, ch 375,§35
      MISCELLANEOUS PROVISIONS

  135.11  Powers  and  duties.  The  commis-
 sioner of public health shall be the head of the
 "State Department of Health", which shall:

  7. Make inspections of the public water sup-
 plies, sewer systems, sewage treatment plants,
 and  garbage  and  refuse  disposal   plants
 throughout the state, and direct the method of
 installation and operation of the same.

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                                                          APPENDIX  B
  455A.25  When  permit  required.  For the
purpose of administering sections 455A.19 to
455A.32, inclusive, a permit as herein provided
shall be required for the following:

  3.  Any  person who  diverts water or  any
material from the surface directly  into  any
underground watercourse  or  basin.  Provided,
however, that any diversion of water or mate-
rial from the  surface directly into any under-
ground watercourse or basin existing upon
May 16, 1957 shall not require a permit if said
diversion does not create waste or pollution.
No permit shall be issued under this subsec-
tion until the  approval of the Iowa water pol-
lution control commission has been  obtained.
  469.6  Certificate of  approval.  No  permit
shall be granted for the construction or oper-
ation of a dam where the water is to be used
for manufacturing purposes, except to develop
power,  until a  certificate of the Iowa water
pollution  control commission has been filed
with the council showing its approval of the
use  of the water for the  purposes specified in
the  application.  [C24, 27, 31, 35, 39,§7772; C46,
50, 54, 58, 62,§469.6; 61GA, ch 375,§30]
  Iowa water pollution control commission, ch 455B
  469.7  Application  for  certificate.  When it
is proposed to use the water for manufactur-
ing purposes, except to develop power, or for
condensation  purposes,  application must be
made to the Iowa water pollution control com-
mission, accompanied by a description of the
proposed use of the water and what, if  any,
substances are to be deposited in such water
and chemical changes  made in the same, and
such other information as the department of
health may require to enable it to determine
the advisability of the  issuance of such certifi-
cate.  [C24, 27, 31, 35, 39, §7773;  C46, 50, 54, 58,
62,§469.7; 61GA, ch 375,§31]
  40ExGA, SF 186J4, editorially  divided
  Iowa water pollution control commission, ch 466B
   469.8  Granting  or refusing.  If the  Iowa
 water pollution control commission is satisfied
 that the use of the water in any such project
 will not cause pollution of the same or render
 it  materially   unwholesome or  impure,  or
 deleterious to fish life, it may issue  a  certifi-
 cate, and if it is not so satisfied, it shall refuse
 to issue same. [C24, 27, 31, 35, 39,§7774; C46, 50,
 54, 58, 62,§469.8; 61GA, ch 375,§32]
   Iowa water pollution control commission, ch 465B

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                                                        APPENDIX  B
         ADDRESS COMMUNICATIONS TO:

  Iowa Water Pollution Control Commission
      Iowa State Department of Health
            Robert Lucas Building
           Des Moines, Iowa 50319
             Telephone 281-5345
CP50043 11/67
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                                   ft U. S. GOVERNMENT PKINTING OFFICE : 1969 O - 362-980
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