Conference In The Matter Of Pollution Of Lake Erie And Its Tributaries (indiana Michigan New York Ohio) Proceedings Fifth Session Detroit June 34 1970 Volume 2

PROCEEDINGS Fifth Session Detroit, Michigan June 3, 4,197O VolJ\|2 In the Matter of Pollution of Lake Erie and its Tributaries- Indiana-Michigan-New York-Ohio- U. S. DEPARTMENT OF THE INTERIOR • FEDERAL WATER QUALITY ADMINISTRATION ------- 421 FIFTH SESSION OF THE CONFERENCE IN THE MATTER OF POLLUTION OF LAKE ERIE AND ITS TRIBUTARIES (INDIANA- MICHIGAN-NEW YORK-OHIO-PENNSYLVANIA) ENVIRONMENTAL PROTECTION AGENCY Library, Region V 1 Worth Wacker Drive Chicago, Illinois 60G06 Cobo Hall Detroit, Michigan June 4, 1970 ------- 422 CONTENT^ STATEMENT OF: Page Prank J. Kallin 423 Al R. Balden 439 Gerald J. Remus 444 Hillel S. Liebert 505 George H. Eagle 515 Walter A. Lyon 570 Perry Miller 590 Russell C. Mt. Pleasant 602 Lowell A. Van Den Berg 646 Albert M. Shannon 725 R. W. Purdy 728 ------- 423 JUNE 4, 1970 9:35 a.m. PROCEEDINGS MR. STEIN: We will reconvene with Mr. Purdy. MR. PURDY: Yes, Mr. Stein. I would like to call now upon Mr. Frank Kallin, Ford Motor Company, for a statement. STATEMENT OF FRANK J. KALLIN FACILITY ENVIRONMENTAL CONTROL MANAGER FORD MOTOR COMPANY DETROIT, MICHIGAN MR. KALLIN: Mr. Chairman, conferees and ladies and gentlemen, my name is Frank J. Kallin and I am manager of Facility Environmental Control for Ford Motor Company. I appreciate this opportunity to report on the continued progress Ford Motor Company has made in wastewater control at its Rouge and Monroe plants since the June 1965 session. Improvements have been brought about variously by new waste treatment facilities, expansion and modernization of existing facilities, and by process changes which have eliminated or minimized waste producing operations. At the Rouge manufacturing area, our primary waste water tasks have been the reduction of suspended solids, phenol, oil, and the dissolved iron from steel pickling liquor. At Monroe, our tasks were concerned with reducing ------- 424 Frank J. Kallin cyanide and holding bacteria, oil, and phosphates to specified « limits. I will discuss the steps we have taken and are taking to bring each of these within the limitations stipulated by the Michigan Water Resources Commission. First, suspended solids. At the time of the 1965 conference, 4 of the 5 major outlets in the Rouge complex were already under the objective of 50 milligrams of suspended solids per liter. Excess solids in the one exception resulted from the grinding and polishing of glass. Since then, this solids loss has been eliminated at the source by a new float glass-making process which does not require the grinding and polishing operations. However, a minor "trade-off" with improved air pollution controls at the Rouge powerhouse and the Dearborn Specialty Foundry has given us an interim problem with sus- pended solids. New dust collector equipment installed at the power-- house removes more suspended particulates of smaller micron size from the boiler exhaust gases and a part of these solids are lost to the sewer system through a water induced vacuum system. The temporary condition will be corrected by the installation of a so-called "Baghouse" filter system scheduled for completion by next January 15. At the specialty foundry, the solids are suspended ------- 425 F. J. Kallin particulates trapped from exhaust air by new wet collectors on the cupolas. Along with the wet collectors, we installed an elaborate diatomaceous earth filtration system for removing v the particulates from the water — in effect, a full-scale research project since this type of filter had not previously been used for this application. We hoped and expected it to yield filtered water containing less than 5 milligrams of suspended solids per liter, but unfortunately the system failed to work despite extensive changes tried out by both the supplier and Ford. We are now designing a system using the more proven principle of clarification which will reduce the suspended solids content from our cupola wet scrubbers to less than 25 milligrams per liter. Preliminary planning will be completed this month and the system will be in opera- tion before the end of 1971. Although not as significant, we have been able to reduce suspended solids losses by initiating a program of converting to dry in-plant dust col- lectors . Naturally, we are disappointed at the lack of suc- cess with the diatomaceous earth approach which appeared to hold so much promise. However, we think the data and experience we acquired will be of value in establishing and determining equipment limitations for future applications. Now, with respect to phenol, in our coke-making ------- 42b F. J. Kallin operations at the Rouge, we generate approximately 1,200 to 1,400 pounds of phenol a day. By pumping the final cooler water into a deep disposal well, we were able to reduce the quantity of phenol discharged into the Rouge River to less than the limit of 600 pounds a day required in the 1952 order from the Michigan Water Resources Commission. In 1966, Ford entered into a voluntary stipulation with the Commission, agreeing to reduce the daily discharge of phenol generated from the coke oven operation from 600 pounds to less than 70 pounds. Additional deep wells, a phenol recovery plant and a biological destruction process were among the methods we considered for accomplishing this steep reduction. The first two alternatives were discarded only after we had designed, built and operated a pilot plant which determined that biological destruction was feasible. This conclusion was further supported by our findings that, particularly in the summer months, as much as 80 percent of the phenol which we discharged into the Rouge River had de- composed by the time it reached the confluence with the Detroit River. On the basis of this evidence, we proceeded to design a full-scale biological plant to be located on Ford property for the treatment of our phenol-bearing waste. After completing the design, however, it appeared to us that a more logical solution might be to see whether ------- 42? P. J. Kallin , the Detroit metropolitan water services treatment plant could and would accept our remaining phenol waste for biological destruction. Detroit officials so agreed with the provisions, among others, that we transfer a part of our 70-pound stipula- tion to the city and pay an equitable additional rate for the convenience and additional services rendered. Now, with respect to oil, the recovery system which formerly served the north half of the Rouge complex has been completely replaced by an advanced collection and removal system now entering its third year of operation. Additionally, since May 3 of this year, an oil polishing lagoon has been operational in conjunction with the Gate 11 oil removal facilities which were installed in 1954. Owing to extensive delays in a planned relocation of the Rouge River channel by the U.S. Corps of Engineers, due to restricted Federal funding, the property which we had originally contemplated as the site of the lagoon has not yet become available to us. Fortunately we were able to purchase other suitably located land across the river for the purpose. We believe that these improvements, supplemented by a continuing program of careful and energetic housekeeping within our plants, have given us an effective oil control system at the Rouge. ------- 428 F. J. Kallin With with respect to steel pickling liquor, for many years our steel operations at the Rouge used sulphuric acid for the removal of iron scale in its pickling operations, resulting in waste pickling liquor which was discharged to our boat slip. After studies of possible alternatives — including disposal wells, acid recovery systems and chemical neutralization — our Steel Division found it most feasible to switch from sulphuric acid to hydrochloric acid, which is more capable of being economically recycled and reused. Under contract, an outside supplier now hauls from the Rouge all the spent pickling liquor generated each day. Since April 1969 there has been no disposal to the boat slip except for some incidental leaks — which since have been completely corrected — and small quantities of dis- solved iron contained in the rinse water. Even though we are meeting our iron stipulation, we are currently designing additional facilities to prevent any loss of iron in the rinse water to the boat slip which will eliminate occasional discoloration. We expect to have this installation operat- ing by May 1971. Now, with regard to cyanide and phosphate at our Monroe plant, waste treatment facilities at our Monroe plant were initially installed in 1950 and were expanded in 1955 to provide for the treatment of cyanide and for the removal ------- 429 P. J. Kallin of chromium and nickel used in plating operations. Addi- tional facilities operating since January 1969 have utilized chlorine to destroy cyanide and this has reduced the cyanide concentrations in wastewater to less than .025 parts per million in accordance with a voluntary stipulation entered into between Ford and the Michigan Water Resources Commission, The above wastewater treatment facilities also enable us to meet our stipulation on oil, bacteria and phos- phate . That concludes my report on the current status of Ford Motor Company's continuing effort to improve wastewater control at its Rouge and Monroe plants. We believe that, with the exception of the short-term problem with suspended solids resulting from our air purification efforts at the Rouge, our process changes and waste treatment facilities have placed these two plants in substantial compliance with existing water quality standards and objectives. In keeping with Ford Motor Company's commitment to an improved environ- ment, as spelled out publicly by Mr. Henry Ford II last December I/ I can assure you that our company will continue in its efforts to help achieve the goal of cleaner air and cleaner water. Thank you again for giving me this opportunity to discuss the progress we have made. ------- 430 F. J. Kallin Mr. Chairman, I have one additional comment. Yesterday, I had an opportunity to review the summary state- ment delivered by Mr. Harlow. On page 27 of that report, I believe the word "air" should replace the word "oil". Making this change, the sentence would read: "The State of Michigan adopted a final order of determination at its May meeting to require further control of suspended solids resulting in part from air pollution control facilities," as opposed to oil pollution control. MR. STEIN: Do you accept that, Mr. Harlow? MR. HARLOW: Yes, that's right. MR. STEIN: Thank you for that correction. Are there any other comments or questions? And I wish we would have a few here because at least on its face, the statement we had of the status of Pord from Mr. Harlow and the statement from Mr. Kallin do not seem to completely jibe. Let me make my point and let's see if we can get this clarified. Mr. Kallin says they are in substantial compliance. As I understand it from the Federal statement, Ford was behind. Can we resolve that somehow? MR. HARLOW: I think the statement of Mr. Kallin was in connection with the suspended solids. And I believe it was because this filter didn't work and you went to ------- 431 F. J. Kallin another system that caused you to be delayed. MR. KALLIN: That's right. And I think my state- ment reflects that we are not in compliance with suspended solids. MR. HARLOW: It is good to see you again, Mr. Kallin. MR. KALLIN: Thank you. MR. HARLOW: On page 3 of your report, when you talk about — MR. STEIN: Pardon. Let me get this because I think this is the key point. If you are not in compliance with suspended solids, what does that statement at the end of your report say on process changes and waste treatment facilities have placed these two plants in substantial com- pliance with existing water quality standards and objectives? MR. KALLIN: But I think, Mr. Chairman, that I say that we believe that with the exception of the short-term problem of suspended solids. MR. PURDY: Mr. Kallin, you have a number of out- lets to the Rouge River from your Rouge operations. Many of these contained or did at one time contain suspended solids in excess of the requirements that have been agreed upon. Now, are you behind time on suspended solids ------- 432 F. J. Kallin control on all of these outlets or only on one or two? MR. KALLIN: No, sir. We are only not in compliance on actually two outlets. And I think that is covered some- what, possibly not enough detail, in the first part of the presentation where we said initially we had a suspended solids resulting from the grinding and polishing of glass which has been eliminated. And the suspended solids problem we have today is the result of the air pollution control facilities which were put in. So that these two situations, the power house and the Dearborn specialty foundry, happened to drain into two separate sewers. So, to put it another way, we have 5 sewer systems and 3 are in compliance and 2 are not, if that is helpful. MR. BARLOW: Is the powerplant discharging through the tailrace? MR. KALLIN: Yes, sir. MR. STEIN: Are we in substantial agreement on the situation now? MR. HARLOW: Yes. MR. STEIN: What do you think is the situation in the Ford plants? Do you think they are in substantial com- pliance except for the air pollution scrubbers, control scrubbers? MR. HARLOW: Well, I have one or two questions I ------- 433 F. J. Kallin would like to ask to explore this a little further. MR. STEIN: Right. MR. HARLOW: Mr. Kallin, on page 3 of your state- ment in connection with the oil — and I think most of your reference here is in the oil problem from Gate 11, and you did construct a lagoon — is this across the Rouge River now from where the Gate 11 discharge was? MR. KALLIN: Yes, sir. What we have done is we picked up the effluent from the clarifiers which we installed back in 1954 which since that time have been discharging directly to the Rouge River. We have picked up that effluent and now carry it underneath the Rouge River to the new so-called polishing lagoon. And that went into opera- tion May 30th this year. MR. HARLOW: And are the discharges of these lagoons within 15 milligrams per liter of oil? MR. KALLIN: Yes. As a matter of fact, Mr. Harlow, if we are talking about an arithmetical number, my recollec- tion is that for the most part, the arithmetical 15 milligrams per liter, we were attaining with the clarifiers as they were. However, we recognize that there was still oil coming out of them. That's why we have gone the extra step. And we think this is going to make a significant improvement to the water quality going into the Rouge. ------- 434 F. J. Kallin MR. HARLOW: Now, what I recall, I think, was Willow Creek outfall where most of your oil from your rolling mills came out. MR. KALLIN: No, most of the oil from the rolling mills came out to this Gate 11 system, that system against the southwest half of the Rouge plant. MR. HARLOW: Back at the end of the Ford slip where you had the skimmers, are these skimmers still in operation? MR. KALLIN: Yes, sir. MR. HARLOW: Are they working satisfactorily? MR. KALLIN: Yes. MR. HARLOW: So you are able to meet your stipula- tion for oil which I believe says measuring just the other side of the skimmer? MR. KALLIN: Yes, sir. MR. HARLOW: And that is within the compliance? MR. KALLIN: Yes, sir. MR. HARLOW: Now, in connection with the cyanides at the Monroe plant, the stipulation also calls for meeting 25 pounds per day. MR. KALLIN: Yes, sir. MR. HARLOW: Your estimate refers to just concen- tration units, but are you also meeting the 25 pound per ------- 435 F. J. Kallin . day for cyanide? MR. KALLIN: Yes, we are. What we are actually doing is chlorinating down to zero cyanides. So it is well less than 25 pounds. MR. HARLOW: I have no further questions. MR. STEIN: Any other questions or comments? MR. O'LEARY: I have one question. On page 3, Mr. Kallin, on your phenol operation, you have stated this part of an agreement with Detroit would be to transfer part of a 70-pound stipulation to the city. Has that been accomplished or what? MR. KALLIN: No, it has not. And I think that is an arrangement, if you will, between Detroit and Ford. In other words, it was since Detroit was going to offer this service, since we can get down well below 70, it appeared logical to transfer a portion of this amount to Detroit. MR. O'LEARY: I mean Detroit would be allowed to discharge more phenol, is this the meaning? MR. KALLIN: I would assume so. In other words, if Detroit has an arithmetical limitation as we do, the end result on the river would be the same, but the source would be from one location as opposed to the two locations. MR. PURDY: Mr. Stein. MR. STEIN: Yes, Mr. Purdy. ------- 436 F. J. Kallin MR. PURDY: There seems to be a slight point here, I believe, that needs some clarification. And that is that the Ford Motor Company will be discharging a part of their phenol-bearing waste to the Detroit system. And in recogni- tion of this, the Ford Motor Company will transfer a part of their allocated load to the river to the city of Detroit in consideration of this treatment that Detroit will provide. MR. STEIN: Any other questions? MR. HARLOW: I have one more question, Mr. Chairman. Mr. Kallin, in getting back to oil a little bit, the stipulation also calls, in reference to oil wastes from Ford, that there not be visible film of oil on the surface of the waters. Do you think that the 15 milligrams per liter is sufficient to prevent any film of oil on the water surface? MR. KALLIN: I think that we have specifically with respect to the Rouge because of the full concentration of minute quantities of oil that accumulate, again referring to Gate 11, to really get rid of all the oil. Essentially we have seen, of course, a decided improvement in the oil prob- lems in the river. And we haven't had a chance yet since May 3 to really on either a short-term or a long-term look to see what the extent of the benefits we are going to get from this new facility are. We have high hopes for it. ------- 437 F. J. KALLIN MR. STEIN: Any other comments or questions? MR. PURDY: I have one question, Mr. Stein. I will comment first. And that is, of course, with respect to Gate 11 sewer and the 15 ppm oil concentration, the Water Resources Commission recognized that to correct the problems of oil accumulation in the Rouge River that we would have to look at an effluent that would have less than 15 ppm oil in the Gate 11 outlet. And this is why the stipulation calls for no visible film of oil. We recognize that at 15 ppm, you can have a very slight slick. Now, with respect to the Gate 11 sewer, I might ask Mr. Kallin if at the time that the flood control project is completed on the Rouge River, do you 'have plans to still add additional facilities? MR. KALLIN: Mr. Purdy, the effluent from the lagoon now goes into the portion of the river which will be vacated by the flood control channel. We do have provisions made in the Corps contract to use that portion of the river for further treatment. MR. PURDY: So that as soon as the flood control project has been completed to the point that this part of the channel can be released to you, you will add a, so to speak, second polishing lagoon. ------- 438 F. J. Kallin MR. KALLIN: Yes, sir. MR. STEIN: Thank you. Are there any other comments or questions? Are we all satisfied with the progress report now or is there any problem? (No response.) Thank you, Mr. Kallin, for a complete statement. I think it might be helpful — and I just throw this out and maybe we can think about this — if we ask our people, in conjunction with the State people, perhaps, to have an inspection of Ford, since you are one of the principal ones named. In this case, perhaps a joint statement of the facts of the situation, including a prognosis, can be pre- pared and agreed upon among Ford, the State of Michigan and the Federal Water Quality Administration. This will be laid out so that we can all agree upon a statement of the conditions. I think this will be helpful to all because if the situation is substantially cleaned up — and we are just dealing with minor problems now — I think we should state that for all to see and lay it out if that is a fact. MR. PURDY: We would be pleased to make those arrangements. MR. STEIN: Thank you very much, Mr. Kallin. ------- 439 A. R. Balden Mr. Purdy. MR. PURDY: Mr. Balden, Chrysler. STATEMENT OF AL R. BALDEN WASTE TREATMENT SPECIALIST ENGINEERING OFFICE CHRYSLER CORPORATION, DETROIT, MICHIGAN MR. BALDEN: Mr. Stein, conferees, ladies and gentlemen, it is a pleasure for me to appear before you to make a brief statement. My name is Al Balden and I am the Waste Treatment Specialist for Chrysler Corporation which has three manu- facturing plants on the Detroit River, all in the vicinity of Trenton, Michigan. These plants are: 1. The Amplex Division's Trenton plant, built in 1953, which sinters small metal parts. 2. The Chemical Division's Trenton plant, built in 1947, which makes industrial adhesives, brake linings, machining coolants, cleaners and the like. 3. The Trenton engine plant, built in 1951, which machines engine components and assembles these into engines. It has been basic to Chrysler's operating philoso- phy that protecting the quality of our environment is an integral part of the cost of making a product. We have ------- 440 A. R. Balden designed and built plants to protect our waterways from degradation, as contrasted with the more limited approach of meeting the requirements of the law. We have always tried to anticipate potential pollution and its ecological effects and have solved the problems presented to the best of our ability, based on the best technological knowledge currently available. As we have learned more, we have applied this knowledge. Each plant built has represented the accumulated experience applicable to that problem. Those of us associated with the designing, building and surveillance of such equip- ment have become firm believers in the validity of Murphy's Law. We have seen things happen which are unanticipated and 9 have constantly worked to eliminate the unexpected. Each production plant built by Chrysler in the Trenton area varies considerably in reference to the manu- factured product and therefore the manufacturing operations and the types of wastes produced. We have worked closely with the Water Resources Commission staff during the design of the waste treatment facilities, discussing the plant operation and the types and volumes of contaminants to be treated and removed as well as the proposed facilities for accomplishing the desired pollution prevention. At the Amplex plant, the potential pollutant was free oil and a retention pond with a weired overflow with a ------- 441 A. R. Balden « drum skimmer upstream of the weir has been effective in preventing loss of the oil. The chemical plant was recognized to have a problem due to small but anticipated losses of oils, solvents and the like during the transfer of raw materials from the delivery truck to holding tank and while pumping the final product from the mixing tank to the shipping conveyance. A lagoon was constructed to catch and hold this drainage. The floating material was periodically pumped to a truck and hauled to an incinerator. The aqueous portion was pumped to a drying bed. Due to operational errors, this procedure has not been entirely effective in preventing pollution, so additional equipment is to be installed to provide an effec- tive remedy. We have entered into a voluntary stipulation with the State to have these facilities in operation by April 1, 1971. It was recognized that the Trenton engine plant would have a serious pollution problem because of the many machining and cleaning operations performed. For this reason, waste treatment facilities were included as part of the plant as built. These represented the most advanced technology known and were quite acceptable at that time — 1951. They consisted of a large holding tank followed by air flotation and included means of recovering oil. ------- 442 A. R. Balden As we learned more about the limitations of our equipment and as the effluent demands became more exacting, it was evident that additional facilities were required. A completely new tertiary treatment plant was installed in 1967, consisting of primary oil skimming, air flotation and final settling. This plant has enough flexibility to satis- factorily treat a variety of wastewaters and its operation has been completely satisfactory as reflected by the reports sent to the Water Resources Commission. The greatly increased public awareness of threats to the quality of our environment can be beneficial in many ways. We hope one positive result will be an increased awareness in the cause and effect of thoughtless actions by people who handle industrial pollutants as well as their daily job. New and stricter laws can be enacted and they will be effective, but only to a point. They will always fall short of their full potential until each man and woman in their roles as employees and citizens of this society become fully committed to his surrounding environment. The installation of adequate facilities must be matched by intelligent individual commitment to their use. MR. STEIN: Thank you, Mr. Balden. Are there any comments or questions? (No response.) ------- 443 A. R. Balden Mr. Balden, I would like to take this opportunity to commend you in particular and Chrysler because it has been my experience that under your direction, Chrysler Cor- poration has taken cognizance at least of water pollution problems in the country. For an industry faced with major potential pollutants, it has been always cooperative with Federal, State and local governments in putting in these devices. And I think if other companies had had the policy, and perhaps had had the leadership of someone like Mr. Balden, we wouldn't have this problem today. I don't know about one area. And Mr. Lyon may want to listen to this. You don't find this all over the country. How are you doing in the Delaware River Basin? MR. BALDEN: Fine. We have no problems there that I am aware of. MR. STEIN: O.K. MR. BALDEN: We have been in close touch with the people in Delaware, and they seem to be happy. MR. STEIN: Oh, I know they are happy, but I don't know how happy that water is. All right, thank you. Mr. Purdy. MR. PURDY: Mr. Stein, I would like to call on now ------- 444 G. J. Remus Mr. Gerald Remus, the General Manager of the Detroit Water Board, to describe to the conference the largest single system of intercepting sewers and wastewater treatment plants that has ever been placed under construction in the State of Michigan. And I think it is also the largest single system of intercepting sewers and waste treatment that has ever been placed under construction in any part of the U. S. section of Lake Erie. Mr. Remus. STATEMENT OF GERALD J. REMUS GENERAL MANAGER CITY OF DETROIT METROPOLITAN WATER DEPARTMENT MR. REMUS: Thank you, Mr. Purdy. Mr. Chairman, members of the conference, I am Gerry Remus, General Manager of the Detroit Metropolitan Water Department. We had prepared a report which after sitting here for a day and a half now, I would like to comment on rather than read because there are some points that come up that seem to me need to be clarified. MR. STEIN: Mr. Remus, how about my putting the whole report in the record as if read? We may have a few problems with your map. If we put it in, it will probably ------- 445 G. J. Remus * have to appear in black and white and will not have the insert. We may have to push it down. And I do not know if we can reproduce these pictures, Gerry. MR. REMUS: We can probably get you the pictures. MR. STEIN: The pictures, we have here. But unless we can get the originals, we may want to eliminate the pictures. If you want them in, you will have to have other things to help us. MR. REMUS: I have no personal feeling on the pictures except to establish that the entire effort as far as I am concerned is dedicated to the fact we are not going to be talking about how lousy things are, which we have heard enough of in the last day, but rather what construction we have under way and what progress we have made and are hoping to make provided we can keep cooperative efforts going. (The above-referred to report follows in its entirety.) ------- REPORT/TO THE CONFEREES ON INTERSTATE LAKE ERIE FEDERAL-STATE POLLUTION ABATEMENT PROGRAM BY G. REMUS, GENERAL MANAGER DETROIT METRO WATER DEPARTMENT JUNE 3, 1970 ------- 447 June 3, 1970 Conferees on Interstate Lake Erie Federal-State Pollution Abatement Program Gentlemen: Since I last reported to this Conference on June 27, 1969, I am happy to report substantial progress toward meeting our mutual goal of pollution abatement in the Detroit River and Lake Erie. Projects which were nearing the construction stage a year ago are under construction, and projects under construction a year ago are basically completed and beginning to show results. Work totaling $74 million, including engineering costs, is under construction now. Another $90 million worth of contracts will start this year, The progress to be described applies to all or parts of a regional sewage disposal system now serving about three million persons in Detroit and 54 suburban communities. We have contracted to serve an additional 15 communities and the remaining portions of another two already in the system. Contracts to serve 12 more are under consideration. - 1 - ------- 448 The regional Sewage Treatment Plant serving these communities is currently treating L an average daily flow of 750 million gallons, a rate which is steadily increasing as development continues in the present service area. Progress will be described in five areas: (1) Installation of advanced treatment facilities in our Sewage Treatment Plant; (2) Extension of the regional interceptor system; (3) Improvements in storm water overflow control; (4) Other pollution preventive measures, and (5) Contracts which we intend to award by the end of 1970. The photo- graphs attached indicate the size and scope of some of the current projects (Exhibit A). I. ADVANCED TREATMENT Last year we reported design criteria for phosphate removal and biological treatment facilities, based on almost two years of operation of our pilot treatment plant. Today we can report successful full-scale soluble phosphate removal, substantial reduction in coliform bacteria? and a major innovative change in design of our biological treatment process. The charts attached indicate our projected removal capabilities as we complete projects (Exhibit B), A. Phosphate Removal On March 30 of this year we began measured injection of waste ferrous chloride into the two interceptors which carry sewage into the Sewage Treatment Plant. Since then, the two-month average of orthophosphate in our effluent has been less than 21,000 pounds per day maximum contained in our stipulation with the Michigan Water Resources Commission. - 2 - ------- 449 A. Phosphate Removal (Continued) The Department is currently using the entire output of ferrous chloride from Great Lakes Steel's Ecorse Plant. Indications are that eventually other sources will have to be found. The Department transports the ferrous chloride to two 150.000-gallon storage tanks at the plant.- Currently, injection of 10 - 15 milligrams of iron per liter of sewage influent is adequate to meet the poundage stipulation, B. Coliform Bacteria The bacteria count in our effluent is approaching the stipulated level of 1,000 per 100 milliliters. But bacterial pollution from the Rouge River is wiping out the value of this reduction to the River 3 samplings downstream indicate. C. Biological Treatment Last year we reported our intent to construct a step-feed activated sludge process, incorporating enough flexibility to deal with daily and long-term changes in quantity and quality of sewage influent. While design continueds our engineers studied the possibility of substituting pure oxygen for air in the proposed aeration tanks. Potential advantages of oxygen aeration appeared to include doubling capacity of an aeration tank of a given size with resultant long-term savings in operating and capital expense (including acquisition of less land), reduction in odor and greater ease of sludge handling. Disadvantages appeared to be the possibility that the process might not live up to its claims, plus short term higher expenses for operation and construction. . 3 . ------- 450 C, Biological Treatment (Continued) Earlier this year., we decided to test the process on a plant-sized scale. PlaAs call for one-half of the first aeration module to use the oxygenation system and the other half to use a conventional aeration system. The dual flow train system will provide invaluable cost and operational comparisons for the benefit of future Department expansion and for the benefit of other agencies involved in water pollution control. The Department expects to save about $6 million in construction expense by 1975 if both tanks use oxygen to treat 600 million gallons of sewage per day in the biological process, with a savings in annual operating expense of more than $200 f 000 if the Department builds its own oxygen plant. Contracts for this first module of biological treatment are to be awarded by the end of this year. II. REGIONAL INTERCEPTOR SYSTEM The Department for more than a decade has stressed the need for a regional approach to the regional problem of water pollution,. Our earliest proposals were given impetus by growing Federal and State emphasis on regional solutions for a variety of governmental efforts. This emphasis has led to Federal and State recommendations for a single regional Sewage Treatment Plant to serve all or portions of Wayne, Oakland and Macomb Counties, The attached maps "Water Pollution Control Program" shows our proposed regional interceptor system capable of serving the region's needs past the year 2000. - 4 - ------- 451 Today, a major portion of the initial construction of the Detroit Metro Water Department's Qikland-Macomb Interceptor system in Macomb County is under way, When completed, the initial and future interceptor arms will serve all of Macomb County and much of northern Oakland County --an ultimate population of 3. 4 million -- and will allow the phase- out of all existing treatment plants whose effluent is currently tributary to the Clinton River. III. STORMWATER OVERFLOW CONTROL On May 25 of this year, a short, intense thunderstorm moved southeast across Detroit, dropping an average of 0. 47 inches of rain over the area in 45 minutes, and as much as 0. 95 inches on some parts in a similar time period. Interceptor gradients had already been lowered in anticipation of thunder showers predicted by the U. S. Weather Bureau, and the Department's Systems Control Center was poised for action. First direct warning of rainfall came from a remote-registering rain gauge seven (7) miles west of the city, 15 minutes before the first sprinkles reached another rain gauge inside the city, About one billion gallons fell over Detroit, and about 450 million gallons entered the sewer system. Yet so much stormwater was retained that overflows into the Detroit and Rouge Rivers were fewer in number and of shorter duration than usual. The Sewage Treatment Plant processed about 365 million gallons over average flow during the following 30-32 hours, with no further rainfall, Retention of this storm in our combined sewers was one of the most dramatic demonstra- tions of a rainfall and sewer monitoring system whose nucleus is now nearing complete installation. ~ 5 - ------- 452 The system and the Department's ability to interpret and to make decisions based on the . '* system's reporting was so finely tuned by May 25, that the Systems Control Center was able to tell a ijhanned storm pumping station to contain part of the storm in the system above it -- rather than to start pumping polluted stormwater into the Detroit River to protect basejnents. Rain gauges and sewer level gauges upstream from the pumping station had Indicated that the storm had nearly spent itself by that time. Many other rapid decisions were made during that storm to reduce overflows. Financed with a $1 million Federal grant, the $2.1 million project includes 14 telemetering rain gauges, four of them located in suburbs to the northwest, 80 sewer level gauges in combined sewers, 40 level gauges in interceptors, 71 overflow indicators at backwater gates and remote-control capabilities at seven sanitary and stormwater pumping stations. The system for the la'st year has enabled us to learn more about the relationships of rain- fall, sewage levels and overflows to the Rouge and Detroit Rivers, and it has enabled us to reduce the occurrence and volume of overflows as indicated in the narrative above. The Department is hi the process of working out a similar program for all Of Southeast Michigan. Ultimately, we realize, more effort and money must be expended to provide evefl more control of overflows. The Water Resources Commission has called for substantial control by 1977. But the experience and knowledge of our dewer system gained from the new data, coupled with results of other demonstration projects such as ours, makes us confident we can come up with good solutions to stormwater overflow reduction. ------- 453 IV. OTHER POLLUTION PREVENTION Jr All industries in our sewage disposal system discharge treatable wastes into the system and must pretreat or dispose of elsewhere wastes incompatible with our system. The Department now requires an inspection manhole at the connection of an industrial sewer lead to they system. Industries have responded well to our industrial waste control program. Chrysler Corporation has installed two waste oil treatment installations at locations within our service area and is transporting waste oil from other plants to the new installations. Detroit Diesel Engine Division of the General Motors Corporation also has built a pretreatment facility and plans further work. Other work is planned or in progress at plants of Ford Motor Company, more GM plants, Budd Company, Marathon Oil and others. Recent efforts of the industrial waste control team have been directed toward pretreatment of oil. Greater emphasis in the future will be placed on preventing cyanides, chromium and other heavy metal wastes from entering the system. The Department has urged that other pollutants as well should be kept out of the sewer system -- street cleaning rather than waiting for rains to wash leaves, dirt and grit into our sewers would result in a net savings to the city, for example. Although some detergent manufacturers have announced sale of low-phosphate or phosphate-free products in the near future, we feel that action is necessary at the Federal and State levels to encourage this trend. Detroit Common Council recently urged the State to legislate a phosphate limit of 10 to 15 percent in detergent products sold in Michigan, ------- 454 Regarding a pollutant of immediate regional concern, sampling of our raw water shows no native mercury, and if there were some, our treatment process would take care of^it. Our testing procedures, supported by Michigan Public Health Department and the Federal Water Quality Administration, are accurate to two parts per billion. Our Sewage Plant effluent likewise shows no mercury. V. PROGRAM COSTS Transmitted by our letter of June 3 is a copy of "Engineering Division Monthly Report -- Status of Contract Work Ending April 30, 1970. " That report lists pollution control program construction contracts totaling nearly $71 million. Total cost of the work is $74 million including engineering and contingencies. Not listed is an additional $3 million spent for treatment plant site acquisition. Work programmed for construction starts this year are as follows: PCI-15 15-Mile Road Interceptor PC-231 Primary Influent Sampling PCI-10A Oakland Arm --Section III A PCI- 10B Oakland Arm - - Section III B PC-239 Connecting Interceptors and Control Facilities SUBTOTAL (including engineering and contingencies) $ 9,900?000 PC-222 Four Final Tanks PC-233 Aeration Module I PC-234 Intermediate Pumping Units ------- 455 Construction Starts This Year -- Continued PC-23 5 Blower Units -» PC -23 6 Transformers PC-23 7 Switchgear PC-243 Avon-Dequindre Control Facility PC-244 Oil Storage Relocation PC-245 Scum Disposal and Incineration PC-246 Sludge Filtration and Incineration PCI-12 Romeo Arm --Section I SUBTOTAL (including engineering and contingencies) $80,000,000 TOTAL cost of contracts to be awarded in 1970 $89,900,000 Work programmed for construction starts in 1971 through 1974 has been estimated to cost approximately $290 million, VI. FINANCING Inflation is crunching us between our pollution control program commitments and our ability to finance them. The cost of our interceptor construction and the first phase of upgrading our treatment plant was originally estimated at $104 million. For the past couple of years we have planned to spend about $159 million for approximately the same work, but as of now, the cost of the work has risen to about $180 - 200 million, and our financing for the two years' worth of work remains locked in at about $159 million. Something has to give in that kind of situation, and the only source that hasn't given much to date is the Federal Government, _ 9 . ------- 456 Again, we must question the sincerity of the Federal Government's war on pollution in. light of legislation providing Federal funds for 55 percent of our projects when it has 7* actually provided only 5 percent or less. The Government is getting good at calling attention to water pollution problems. But one of the biggest water pollution problems of 1970 appears to include those responsible for our national priorities and specifically, those who propose that the Government can accomplish $10 billion worth of pollution control with an expenditure of $4 billion. That kind of seed money doesn't go very far, as Michigan has found out. Voters of this state approved a $335 million clean-water bond issue in November, 1968, after they were told that the $335 million could seed four times that much in statewide pollution control projects --hinging on Federal grants ranging from 30 - 55 percent. With state and local funds now required to "prefinance" the absent Federal money, both state and local funds are running short. On May 12, 1970, we paid an all-time high interest rate of 7, 78 percent on a sewer bond issue of $24 million. The total interest cost on the bond issue will be about $44 million, If our bonds had been sold in 1968S the interest rate would have been about 5 percent, at a savings in interest cost of about $15 million. What is ironic is that $20 million of the $24 million was to pick up the financing for the Federal Government. Are we on schedule? We are, although the program is not. Our pollution control construc- tion program ultimately has been scheduled by the availability of Federal and State funds, and shortfalls and delays in these funds have produced corresponding delays in our construc- tion program. - 10 - ------- 457 In summary then Detroit this year is building $164 million worth of improvements to it* interceptor and treatment systems and the programs going on now are bigger and bolder than those in any other population center on the Great Lakes, We have recognized the problem of stormwater overflows and we're building up the knowledge and expertise we will need to solve them m the most expeditious and economical manner. But, we're beginning to be concerned now with how to finance the 1971 - 1974 construction phase, Due to the lack of Federal funds in the last two years, there will be no State funds to help us out and if recent Federal announcements are any guide, no more than a dribble of Federal funds will be available. That 1971 -1974 construction phase is vital if we're to solidify the benefits from the present construction. Respectfully submitted. G, Remus General Manager - 11 - ------- 458 to CO c o u to O o o u 03 a I2 'C CD a T- c to c co — J5 " ~ a. c g ^ ^ c c S S oo to O Q> - CO c - •"- O <° >. '•P gj co ^; +-• T3 o •— 111 O +j co _ o> cn "•" O5 O H= C tj O — I Sf Hi ------- 459 o CO l_ 1-J § tn in +-• o CD O C 00 O t/> ^ 0> l- o 3 S c o c fe a JD IE X LU - o 0 S « .2? -' C - Q> o N E u O5 00 ^ OJ ~ +-> tf> 3 « 111 ° -c I '§ o '-5 QJ 3 ^ J o '•-' £ o '6 1 \| Q goo M CO 4^ ™ 5 c _ ^/ -D E CO C ------- 460 CD a ro TO C o o o CNI o = cs ' o c O O 09 S r- CO .b en X w (U -^f "8 8 o a •-• ca E o I . 1° 0 w •i-1 C C 0) 3 E _ -l-l H- (D " tO fl) i g i § ------- 461 •o ° C QJ o g o o (0 —» a > ns • CO OJ -O £ fe 0 .y a. r~ a a. 2 t c 0 o co 4-< =1 l ' CD »- O O «8 § -a CM ° - s £ •:r O co l-« 8lS .a !E x o Q) -C 0 c o l« CD 0) o . +- .> -c a> .c c .^ •2 « H— O5 a> 3 > ° CCE o o . Q. ------- 462 SOLUBLE QUANT/TV 70,000 6,0,000 50,000 X -40,000 ! 20,006 iO, 000 o TO ) - QLESS I— -4 H//?.d - S T. 'PULA 77OA/ £6,00 207" £3S d J ' J, 6.7 '68 't>9 '70 '71 '72 '73 '74 '72 '76, '77 Exhibit B ------- 463 7O,OOO 50,O06 X -4QQOO .30,000 20,000 1O,OOO TV I— -i - STIPULATION £O% 20% '6,7 (/ACLV&//VG A/£A) '70 ' 2 'l? '74 '77 Exhibit B ------- 464 70 o 256,000 69 -70 />l/?A/7~— - 73 ~7-f- POLLUTANT ££MOVfiL Exhibit B ------- 465 CQUTO&MS - QC/ANT/TY DAY 8Q,OOO 70,OOO 60,000 50,000 40,000 \ ^j 3QOOO 20,000 /0,000 o L- sooc T -j .ooc^ooo ORMS/JOO™/. ooo ^ 72 f73 f74 ' '77 Exhibit B ------- 466 leg i 30 * K k/^C STIP^ Q I z^s.; /)l/E£/)G£ '-(, /f/"/A/£A/7 66 67 68 7/ 73 Exhibit B ------- CITY Or DETROIT DETROIT METROPOLITAN WATER SERVICES , WATIR POLLUTION CONTROL PROGRAM DETROIT REGIONAL WATERSHED LAKC HURON OCT. 1969 The sanitary sewage interceptor network depicted on the above map represents only one portion of the total regional pollution control program Equally important is the massive addition of treatment tanks and equipment at the Wastewater Plant at 9300 W Jefferson Avenue m Detroit The site has been expanded by 27 Acres primarily to facilitate an advanced treatment process which is to remove a high proportion of suspended solids, BOD (oxygen depleting wastes), phosphates, oils, phenols and bac- teria Expenditures by 1970-71 for treatment plant and interceptor work are estimated at $159,000,000. Other work which cannot be depicted on the map includes preliminary work toward an improved storm water overflow control system to be in effect by 1977 Within the City of Detroit, extensive renovation and improvement of the local collection system is also planned The construction schedules, rouies and locations of all work depicted on the map are subject to acquisition of right-of-way, subsequent development or discovery of population growth patterns The service areas shown will be devel- oped provided that service contracts are made with the constituent communities The layout shown basically provides the trios' economical solution for water pollution control for the area watershed after 2000 by DMWS by DMWS Future DMWS Wasiewater Treatment Plant Existing DMWS Wastewater Treatment Plant Existing Wastewater Treatment Plant to be ptiased out as interceptors become available ------- 468 G. J. Remus MR. REMUS: I would like to get the Federal record corrected once and for all that this is not Detroit system. It is Metropolitan Detroit system. And it creates very much of a misunderstanding/when each time it is referred to as Detroit, when actually this is Detroit and 54 communities that are now on the system with construction going forth for an additional 15 and negotiations under serious consideration for an additional 12. We are providing service now for better than 40 percent of the State's population/ and it is increasing. And my discussion here is to hope to point out the merits of a metropolitan area operation as it per- tains to the overall. I should point out that in trying to satisfy your honorable conference here, that is only one of 253 autonomous units of government that we deal with. Saying that politely, that is too damn much government. But we, therefore, have difficulties in the acceptance of this type of program. I raise that question because it seems to me that our plea here today is to get help from you people rather than establish that things aren't as good as they should be, which we heartily agree with. But there aren't many things you could do that would help expedite these programs. I will briefly go over the report, and then I will refer to some of the factors that I think need to be ------- 469 G. J. Remus emphasized. In 1966, as a matter of part of your record already existing, the city of Detroit underwrote an area program and signed a formal contract with the Water Resources Commission of the State of Michigan whereby they agreed to do the area job. The map which went with that is on the wall. The con- tract is in here. The stipulations are part of this report. It is a part of your record at past meetings, anybody who wants a report, drop us a note, we will send them a copy. In there, we say how the contracts will be pre- pared, how the rates will be set and how the relationships will be developed. Obviously, we are in a kind of a no-man or no-law area because development in the suburbs does not take place until you have water supply and potential for pollution control. And until that happens, you have no basic government with much of any financial capability to do the job themselves. Obviously, the area job as the correct answer has been recognized by 15 different studies made — Federal, State and local. And we know of none other than one or two engineering reports where the consultants said to do it locally. Of course, they did the design for the local con- struction. I think that just briefly following the various ------- 470 G. J. Remus paragraphs in the report, we did not get a clearance on the State grant account to execute this program until the first part of December 1969. In that month, we allocated $74 million worth of construction. Designs had been pre- pared over the years past awaiting operation. We are pre- pared to put $90 million worth of construction under way this year. The pictures that you find in the exhibits are the ones that are existent. And if you people had time, I would like to have you go out to our sewage treatment plant and show you the 27 acres, 301 families that we moved, the heavy construction that is going on there and that for the first time, we are now doing what has to be done. We are doing the construction rather than the conference. We have brief statements in here relative to where we are or what we are about to do with each of the packers. As was mentioned — I don't know which one of the Federal people mentioned it — relative to the phosphate removal, we think we have that under control. We have met that which we said we would do. I would like to point out one correction. There was some reference to 650 million gallons of sewage. Today we are treating in excess of 750 million. ------- 471 G. J. Remus On the bacteria coliform situation relative to the Detroit River, we did agree to 1,000 value as far as our sewage plant effluent is concerned. We have attained 1,000 as far as the Detroit River is concerned. There is no mis- understanding about that. But charts clearly show that if you take a median value of the Detroit River before you include the Rouge River flow that we do meet the 1,000 median value. And we will have 1,000 in our sewage plant effluent count as soon as our activated slip section of the plant is in operation. As you know, we placed in service within a year's time a pilot station that was of a size equivalent to a community of 2,700 people. And some of the things that we are doing, we have documented pretty well. And we are quite sure of the results we will get. We are using part of our plant improvement as far as biological treatment is concerned. We have decided to use oxygen for a variety of reasons for a portion of it. And hopefully, if it works out as successfully as we think it will, it will be used for all. The reason for that is, of course, it takes less space, less initial capital investment. And after we get our own plant as far as oxygen compression is concerned, we would be getting less operating cost. ------- 472 G. J. Remus We have about $60 million committed, $40 million, roughly, is under construction, for an interceptor on the Clinton Valley. We would like to point out that is the area up here in Macomb County and Oakland County, the yellow area. The red is the area Detroit will prepare and have under contract. This section of blue will be awarded within the next month. The red up in Oakland County is being prepared by Oakland County and is under construction. While I am on this, I would like to just briefly point to one of the comments that was made relative to Selfridge Field. When Detroit's facilities are available, all they have to do is sign a contract, and it might be available. But I would like to point out that we have for- merly contracted with Macomb County to build up to Mount Clemens. Selfridge Field is over here 5 or 6 miles away. I think this illustrates the typical situation we run into. Let Detroit do it. We will use them as an alibi. And that is what has gone on up here. While I am on it, I would like to talk about Mount Clemens. Mount Clemens was included in the ban that existed in lower Macomb County several years ago. And it was lifted when we signed a contract with Macomb County. ------- 473 G. J. Remus Now, in this interceptor construction, we agreed to provide service for Mount Clemens. Mount Clemens has agreed they would have an engineering study made which they did. And about 2 weeks ago, their study came in and said, "You should join the Detroit system." Within the week, they had hired another set of engineers. And within that same week, we already knew the conclusion was going to be the opposite. Now, it is those type of things that we think there has to be pressure put on to either do it or not do it. But I don't think that we should be committing $169 or $159 million worth of construction and then be badgered with that type of stuff. I would like to point out while we are in this same area that we are building through the city of Warren a 12-foot sewer. That sewer is big enough to take care of Warren's requirements as per our contract with Macomb County. We are going to holler from here to kingdom come if they should suddenly get a grant because we are building that property through there at their request. And we did it when they had a building ban. And we corrected it after- wards . I would like to point out, and I will refer to that later, that Warren has now challenged the State and ------- 474 G. J. Remus Federal Government on their grant program. And if they should win, I would point out that that is probably the last intercept that the central system will build. Because if we cannot depend on our revenues, we cannot build for the future. This interceptor situation, of course, is paid for entirely by the revenues we expected to collect and by the revenue bonds we issued for our portion of the construc- tion. I would like to refer to a part of this problem which is not in our stipulations. But by the very nature of the fact that we commit our money to where we get the best results, we have gotten deeply involved with the storm- flow as it is now. I will use one example. On May 25 this year, we had an average rainfall of .47 of an inch over the city of Detroit that lasted for 45 minutes. And the inten- sity was as much as .95 of an inch. All of that was treated. If it had not been, there would have been a large tonnage going to BOD and solids going to the Detroit River. In doing this, it cost us considerable extra money in our operations because we pump our system which is made up of several 16-foot tunnels, two 12 by 17 foot channels. And we keep it empty, particularly just prior to a storm. And we have just recently put in operation a ------- 475 G. J. Remus monitoring and telemetering system data logger which the Federal Government helped pay for — roughly 50-50 — wherein we have 138 sensor units throughout the city that give us sewer levels, storm intensity, the rapidity with which it goes across the city. And we think for the first time that we are beginning to make some real progress with this stormflow. I mention this because I don't see how we can put in an activated sludge plant with all the construction at the sewage plant without also going at this stormflow system. We expect to expand that to the area. And in that way, we will be able to know when a storm comes in from Toledo to Lansing and Flint and Ontario and the whole area. There is a part of our operations that, again, is not reflected in the stipulations. And that is what we call pollution prevention. Mr. Kallin of Ford Motor Company only talks about those things that they are under the gun on. He forgot to mention that we are taking a good slice of his problem up in Sterling Township and taking care of it for him as we are for General Motors, as we are for Chrysler. Of particular importance is the fact that in the area that we serve, the Clinton River down to the Rouge River, there is no industry in the white or yellow area that discharges into the Detroit River or into the receiving ------- 476 G. J. Remus waters. All their waste goes through the public system. We do the job for them to the extent that our system can handle their wastes. We have the proper ordinances, and we have about 6 men working on it all the time, to work cooperatively with industry to get our system in such a shape that we can handle our wastes. And if we can't, they have to put them in a preparatory position so they can be handled. Some of the principal ones, one that isn't men- tioned in the report, is Scott Paper Company. And, of course, that isn't under the gun right now. But that plant was right across from our sewage plant. On the basis of the orders given it, it would have had to shut down if we hadn't worked out a program with them because they had no space to build facilities. They are paying us today on the basis of the extra wastes we treat for them a little better than $580 a day. And it was with the cooperative effort with them because they felt it was important. There are plenty of examples of what I think has to have a great deal of pressure. And that is pollution prevention, partly to control what comes into our system, partly — somebody referred to salt. Last year, there were 406 million pounds of salt in the metropolitan area dumped on the streets. ------- 477 G. J. Remus Now, I hear some conversation it doesn't do any harm. Are we going to wait until the mess is here and then clean it up? If we are going to do that, people that are in our type of job will be forever under the lash of somebody. Because if we are going to wait until these messes are created, then you are never going to clean them up. We have the same comments on other heavy metal wastes, on detergents. We think that a better job could be done there. Our common counsel has adopted a ruling to ask the State to adopt the law asking that not more than 10 percent phosphate be allowed on the market. Now, if you are referring to page 8, you will see what construction would be done by the $90 million that I have referred to. I would like, however, to talk a little bit about the money, the financing. On the basic $80 million that we have, we ordered $74 million of contract. But on the basis of the $80 million that was scheduled — and the last part of it will be awarded this month — the Federal Government should have provided $44 million. The State should have provided $20 million. And we should have provided $20 million. That is on the basis of the law that is on the land. Since the Federal appropriations were not financed, ------- 478 G. J. Remus it developed that our system provided $40 million and that the State provided $40 million and the Federal people pro- vided $4 million. The State prefinanced $20 million for the Federal people, and our operations prefinanced $20 million for the Federal people. If you were in my place, you would make as nasty a remark as you could about this. And I am going to do the best I can. It makes you so damn mad that of the $24 million that we had to issue bonds on this last week, we paid 7.78 percent interest, far more than we ever paid before. And $20 million of that was financing what the Federal people have committed us to. And if that is going to continue, you have broken the back of this type of an operation because we do not have the tax base or the metropolitan area available to us. We have only revenue bond financing. In fact, the Federal portion of the grants we have received are like pulling backwards when you are going forwards because they haven't even kept up with inflationary factors. Further, the State has to continue to prefinance a portion of the Federal. It's obvious their program will break down because $335 million for 25 percent of the job wasn't enough. And if it has to now go to 50 percent of the job, obviously the whole program is in jeopardy. ------- 479 G. J. Remus I have briefly commented on the fact that we have reduced our B. coli, that we have reduced our oils/ we have reduced and have under good control bacterial kill. But we have in addition to that a considerable effort to exercise as far as BOD and solid removal is concerned. I have also pointed out, and I as a representative of our department, and I as representative of the area, that part of this program that was late was because of the Detroit metropolitan efforts. We could not get clearances on finan- cing. And the delays that we are now faced with are entirely because of that. And our stipulations, even though some of the charts in the report do not show it exactly, will be met in 1972 if you will give us credit for the extra BOD and solid loadings that we take on because of our improved method of handling stormflows. Now, before I answer questions, I would like to comment on a few things. There has been a lot of discus- sion about the 180-day situation. Well, if the purpose is to help us, that will not be applied for this reason that we already have a lawsuit by the city of Warren. Add that to it, and you probably are putting us in a position where our bond financing people will say, "Hey, wait until every- thing is cleared up before you issue bonds." If we don't say it, the investors will say it ------- 480 G. J. Remus because they will say, "That is a kind of a flimsy opera- tion out there, and we are not going to loan money to them." And that is particularly serious in this type of operation. I would like to say also that — Well, to finish that sentence, the Mayor of Detroit, the City Clerk who represents the Common Council, the City Comptroller, have to sign a stipulation saying that there is no lawsuit or potential lawsuit before we can issue bonds. And if we have all kinds of Federal and questionable legal positions to contend with, we will not get those clearances. Now, I would like to bring out another thing. That is the reason I referred earlier to the business that this is a metropolitan operation, the city of Detroit being responsible for the execution thereof. This program has now been approved by four mayors since 1957 when it was adopted. The Common Council has continually re-endorsed the program and approved the bonds and so forth. But most certainly, if the progress that we are making now gets the impression that it isn't good enough, you are hurting our support toward the solution of this program. If you apply 180 days and divide it up, give us about 10, give a few to the State and the rest to the Federal Government for the delay proportionate, we are not going to argue for it. Actually, it would delay or confuse our program a great deal, ------- 481 G. J. Remus And I would like to just briefly — and I have a brief report here on a water supply thing or the contracts we have awarded — to refer to this because I believe there has been very little said on two parts of this program that are necessary outside of the stipulations that must be qualified for before you can construct in a sewage effort. And one is water supply. If you examine this effort here which shows our sister, the plant at Lake Huron, under operation, you look in the report and you will see there is about $80 million of contracts under way and another $60 or $70 million will be awarded this calendar year. If you are going to adopt an area program which the Federal people have and the States, if that is going to be expedited, you cannot make it work unless you first put water into those areas. This is a very important part of this issue. Take the Clinton Valley, for instance. There is only about 160 gallons of flow in that stream per person as it now looks, to say nothing about the development of the future. And under those kind of conditions, unless you reinforce that, you have either got a basic decision to make that the Clinton River will be a sewer, or it will be a stream. But you have to have water supply go into all the areas that are served before you can take the water out. ------- 482 G. J. Remus A second part that seems to me must be dwelled on a great deal/ the Clinton River is an example of it, but our department has been designated by the city of Detroit as the area agency for stormflow control. And I would like to refer to the Rouge River. To take Ford out of the Rouge River or anyone else and allow the same thing to develop further up in the county is an exercise in frustration. And that is what is happening. There are no means available today to relieve the Ford. We are working on it. We have now the basic organization. But until you also have a basic program working whereby the streams will be protected where develop- ment yet has not taken place/ you are just postponing or transferring your agony from one place to another. And I think those two points need to be worked out simultaneously before you put an area pollution control program into action. Now/ I have covered a lot of points here, some of them rather rapidly. I basically summarize it by saying that we have now $74 million worth of construction under way. We invite you to come out and see that operation. We are proud of it. We have $90 million worth of work ready to award or mostly ready to award and are waiting for the O.K.s on the grants which, Mr. Purdy, I think we will get in July to ------- 483 G. J. Remus start awarding those construction projects that are listed in our report. But the other supplemental work of water supply and stormflow rationalization has to be put into action also. And we are working on that. Thank you, MR. STEIN: Thank you, Mr. Remus, for a very excellent statement. Gerry, I think as I am getting older, I am mellowing, but I am glad to see you are still holding out, MR. REMUS: I want to commend you because I didn't hear anything about sophisticated wastes or exotic wastes or pristine clear in this conference, which seem to me is all I heard about 3 or 4 years ago. I don't know yet what pristine clear is. MR. STEIN: There you are. You know, these are classical references, Gerry, I always thought that Jefferson said it better about the government years ago when he said, "That government is best that governs least." But I figured I had to come here and listen to you improve on that when you said we have "...too damn much government," Are there any comments? MR. MAYO: I have several comments, Mr, Chairman, First, I would like to thank Mr. Remus for ------- 484 G. J. Remus providing us very recently with a very detailed breakdown on the construction program that has been requested from the Regional Office, and for appending or making a part of that breakdown essentially a schedule of compliance,or apparently a schedule of compliance with the stipulations. And we have got a few questions that we would like to ask about the apparent dates at which certain levels of waste— water treatment improvement could be accommodated. And I would like to just go through some of the specific stipula- tion items. As we interpret the information you provided to us, Mr. Remus, the current stipulation calls for a BOD load in the discharge of 412,000 pounds per day if not more than that. Or, rather, 250 pounds per day. Excuse me. In reviewing the information that you provided to us, you would get down to approximately 262,000 pounds per day by August or September of 1973. If we interpret the dates that you have attached MR. REMUS: I think that was shown in the curves, yes. MR. MAYO: As we understand the basic date for the current stipulation — perhaps Mr. Purdy can correct or confirm this — we are talking about November 1972. Is ------- 485 G. J. Remus that correct? MR. REMUS: That's correct. And I commented on that a little bit. And I would like to reemphasize it. As we start working this problem out, obviously some of the factors we agreed to in the contract for 1966 have taken a little different form. If you will take the construction that we have complete in 1972, which is contracts that will be awarded this calendar year, with what is already under construction and give us some credit for the job that we are not required to do by law on the loading as far as BOD and solids are concerned and the stormflow, we will be doing better in the sum total picture. MR. MAYO: My query wasn't intended to be critical. I want to make sure that we are interpreting the information. MR. REMUS: That's correct. I didn't take it that way. I think it is very important because of the fact of the definition of our job which is to get the best value for the dollar you can get ahold of. It required we had to take a crack at this and get what we call the first flush of the storm which isn't really a good definition, but which illus- trates that we had to capture a lot of the dirt that lies in our combined sewer system if we weren't going to flood out our plant any time we had a storm. MR. MAYO: Just to follow through with the identi- ------- 486 G. J. Remus fication items, the stipulation would provide for not more than 50 milligrams per liter or what would seem not more than 452,000 pounds per day of suspended solids. MR. REMUS: Correct. MR. MAYO: And you would reach that level approxi- mately January 1975? MR. REMUS: That's correct. And, again, I have to take credit for the opposite of this picture. I think if we take the total catalog and inventory what we are doing, we are taking the solids out. It is unfortunate that we did not look at it in the total picture when we signed this con- tract because that is only one arm of the total problem. MR. MAYO: With respect to phenols, the stipula- tion provides for not to exceed 115 pounds per day. The information that you provided to us was in terms of percent of effluent. And I would appreciate it if you would make some translation for us between the percent of effluent if you can get that down into pounds per day at some place. MR. REMUS: Well, originally, I think the contract I have here said 95 pounds per day. Now, on that, I am having considerable amount of trouble. And we do not figure that factor is realistic. We have talked some to the water research officials on that. To put ourselves in a way of analyzing it is to point out that the 93 pounds applied to ------- 487 G. J. Remus Detroit with 57 communities we have under contract with all their industry, all their commercial establishment and the Ford Motor plant in itself has got 70 pounds, I think there is some unrealistic figuring here. We had hoped that this would in a normal sequence of events take care of itself as this construction went forward. To keep ourselves on a reasonable basis there, our agreement with the Ford Motor Company was if we could get it down to acceptable standards, we would accept their portion of their waste. If we couldn't, of course, they would have to provide for it themselves. And we are in that study area now. We think we will approach it, but 93 pounds is a pretty unrealistic figure when you consider the type of load we have. MR. MAYO: As I understand the later stipulation, at least the figure you provided us with was 115 pounds per day. MR. REMUS: That probably took advantage of the Ford slice that they have turned over to us. MR. HARLOW: I think, Gerry, there was 22 addi- tional panels added to the 93 for the north interceptor. MR. REMUS: I don't remember how that was arrived at. Raise it to about 300 pounds, and we have got it made. ------- 488 G. J. Remus * What do you say? (Laughter.) MR. MAYO: Do you want to roll the dice a couple of times? MR. STEIN: Well, I tell you, you are up to 7 what in your interest? What is your percent rate on your interest? MR. REMUS: 7.78. MR. STEIN: You are going to have a lot of law- suits to scare me off buying those. But why don't you raise that bond figure? It looks real attractive. MR. REMUS: Those are tax free, too. That should interest you. MR. MAYO: Could you provide for us some infor- mation on what the pounds per day of phenol in the discharge are at the present time? MR. REMUS: It is too high. It is somewhere in the range of about 1,200 pounds a day. What were those figures you gave me this morning? DR. SHANNON: This year, it was 1,700. The average this year was 1,700. Before, it was 1,500. MR. REMUS: It is too high. It is 1,500 or 1,700. MR. MAYO: As we would interpret the projection of information that you have given, you would get down to ------- 489 G. J. Remus the range of the 70 percent reduction over the effluent until sometime about 1975. MR. REMUS: Well, I don't think I am prepared to answer that. I would think, however, that we would have the proof to that in the next couple of months pretty directly or at least when the construction we have now under way is under way. The way we have resolved or are going to resolve the problem as far as we are concerned is that we can't get this down to acceptable poundage. When we get our 1972 construction complete and in operation, then we will go to the pollution prevention aspects of it, one being the Ford Motor Company, saying, "We can't handle your phenols." That will take one portion out of here. We will go to the industries and to the people that we serve so that at the input side, we will start reducing that. But I do not see that we can justify millions of dollars just to put a phenol reduction plant in there. I think it has to be attacked at its source. MR. MAYO: Do you feel it would be practical to take this approach of essentially pretreatment at the point of discharge from the industrial constrictors of phenol waste at a much earlier date than that? A lot of your basic program places that burden on the discharger rather than the metropolitan system. ------- 490 G. J. Remus MR. REMUS: We are doing that as I related. I think it is 488 industries we have met with to ask them for what they are putting in. Our monitoring system is being designed so we can keep checks on what is coming in. And I think that by attacking it at both points, we can get that down to a couple of hundred pounds where we ought to be, at least. MR. MAYO: Do you have any time frame that you would suggest that might be accomplished? MR. REMUS: Well, last month, wasn't the figure, Mr. Shannon, 1,200 pounds we had in February and March? MR. SHANNON: Yes. MR. REMUS: We have knocked some of it out already as we have on the oil by going to the source of the problem. We have not attacked the problem yet from a standpoint of the suburbs as energetically as we should, but will for the reason that our contracts provide control. But the ordinance does not define that precisely. But many of the suburbs, of course, are sending in, since we are wholesalers through our master meetings, wastes that we don't think they should be sending to us. So by attacking both within Detroit and the suburbs against discharge, I think we can meet that standard. And I would think that gradually here in the next ------- 491 G. J. Remus months, we will be bringing that down. MR. MAYO: With respect to oil, the stipulation requires that there be not more than 15 milligrams per liter. Your projection would indicate that you would reach that level of treatment at about January 1975. MR. REMUS: Unless we can do a better projection job. I think Mr. Balden of Chrysler gave you a little run- down in the development of his facility. I think that is a good illustration on the proper way to go at this in that when they were ready to build their plant addition, their improvement for treatment, they came to us. And we ran quite a few tests to establish which was best. And we took wastes from them that we could handle. It saved them quite a lot of money, and it improved our revenue picture. So the 1975 data, I think if you add it to the credits that we should have because of other things, we have done well and really have obtained that goal sooner. MR. MAYO: Is there much of an opportunity that you could pass the responsibility for oil removal back onto the original discharger as distinguished from the district assuming the responsibility? MR. REMUS: There is no doubt that we can hand it back to the suburbs because we can check whether their waste comes into our system — at least most of them. In Detroit ------- 492 G. J. Remus that gets to be quite a hide-and-seek game. I don't think I better say any more about that. MR. MAYO: I think that is a problem that is characteristic of every one of the older metropolitan cities, MR. PURDY: Mr. Chairman, I think an example of what is taking place in this area is the fact that Detroit had as a consultant to them the late Hayes Black and have instituted a sampling program on their sewer system. And as Mr. Remus pointed out earlier in his discussion, he has some 6 people that devote their full time to this particular activity. And I think it is not something that will ever cease. This will be a continuing activity that will have to go on from now as long as the Detroit Water Board operates a metropolitan system. MR. REMUS: I am sure that is 100 percent true. I would like to point out also that in the reduc- tions we made on bacteria, on oils and on phosphates and even the BOD and solids loading having stayed where they are, is quite some accomplishment in light of the rapid expansion that has taken place in the Detroit metropolitan area. So this has all been accomplished, not as well as we would like, but it did not restrict development in any way. MR. MAYO: With respect to the phosphate loading, the stipulation provides for 80 percent removal of soluble ------- 493 G. J. Remus phosphate and not to exceed 26,000 pounds per day. We note in extending your schedule here that you would get down below the 26,000 pounds per day in 1971, but that the 80 percent removal would not be achieved even by 1975 or 1976. MR. REMUS: Well, the way our system operates, I don't know how you can use the term 80 percent. I think we would have to use the basis of what we discharge to the river. We have been as low as 7,000 pounds on ortho and 5,000, some days not any. And the reason for that is that we have accepted even sulfide wastes from a steel pickling industry in small amounts if they neutralize it first. We have allowed the steel industry to put their wastes in within our system. So that total phosphate that comes into our system is not really known because part of that reduc- tion process takes place in the system. And we would rather that we use a figure of so many pounds that we would be allowed to discharge. And that way we don't have to do the wonderment about what is happening in our system. To further emphasize that, when the steel mills went on strike and they dumped their vats, we had no phos- phate at all. So I think it would be a very hard thing to use 80 percent factor there. We have another factor that we refer to in our ------- 494 G. J. Remus contract. We refer to ortho phosphate. And, of course, that is one of the improvements we think should be made in the contract. We have informally discussed this with the Water Resources Commission and found no objections to making that solid. MR. PURDY: I think you stated to this conference, Mr. Remus, you are looking at total phosphates. MR. REMUS: That's correct. We are looking at the total figure even though the total contract is still in the original form. MR. MAYO: That was a point I wanted to raise with Mr. Purdy because what the conference recommends with regard to phosphate removal is in terms of total phosphate as dis- tinguished from the terminology soluble phosphate that you have used in making your projection. MR. REMUS: Well, of course, when we signed this contract in 1966, we had very little information as to what really was going to happen anywhere. I think that to clear the record and make the record secure, we are talking total phosphate in our program. MR. MAYO: As far as Michigan is concerned. MR. PURDY: There is no disagreement. Mr. Remus has made this commitment to the conferees several times. And we are in agreement with it. This is what we are looking ------- 495 G. J. Remus at. There is no disagreement on it. MR. STEIN: Are there any more questions or comments? MR. LYON: Mr. Remus, do you have any idea how many treatment plants other than your own exist in that area on the map there? MR. REMUS: There were quite a few little ones. In your report there, it shows a small section of this map, and you will see a bunch of little plants identified on there that were eliminated or are in the process of being eliminated. MR. LYON: So there are really very few left now? MR. REMUS: That is correct. The only two that are in discussion in this whole Macomb area are the city of Warren who have challenged a grant program and the city of Mount Clemens who saved money by running from one engineer- ing consultant to another. I hope somebody from Mount Clemens is here. I wouldn't want that to be wasted. MR. LYON: The reason I asked this question, Mr. Chairman, is because I think Mr. Remus and his organization and municipalities and industries in this area should really get a huge amount of credit and congratulations for the outstanding job that they have done in developing this kind ------- 496 G. J. Rernus * of system in the Detroit area. It is something that is going to save the industries and the municipalities and tax- payers in this area large amounts of money/ including Federal grants and State grants and so forth. I wish I could say that we had similar systems in Pennsylvania. We recently made a study in the area on Pitts- burgh and North Pittsburgh in a 50-mile radius of Butler, Pennsylvania. We found, believe it or not, 950 sewage treat- ment plants, industrial waste treatment plants, and drainage treatment plants. And as you can imagine, the diseconomies, the costs, in that kind of fragmentation are almost incredible. And it really shows a very fine accomplishment that has been attained here both in saving tax dollars for the citizens and helping to clean up Lake Erie. MR. STEIN: Well, we have that prefinancing prob- lem. And as you know, I have tried in previous conferences and in public statements for the Federal Government to give Mr. Remus credit, but he always answers he wants cash. (Laughter.) MR. REMUS: I would like to keep before you the overall program. And that is, if the Clinton Valley clean- up, which is a tributary to Lake St. Clair and the Detroit River, can be held together with the type of construction we are doing and systematically, the Rouge and the Huron will ------- 497 G. J. Remus come under the same type of improvement. If we try to do it all in one big glob, it will break because there won't be that kind of money available. But there is a systematic way of doing it. We did it with water supply when we laid that pro- gram out. We presented a program of $172 million. And pretty near everybody fainted. And if everybody had approved it right away, I would have fainted. But the fact remains that it was approved. We did construct systematically. We expected $172 million worth of construction to carry us to 1985. As a matter of fact, it only took us to 1966 from 1959. And we were able by that process to develop enough revenue base so that since that time we have spent at least another $175 million. The same thing can happen here if we do it in an orderly way for the entire area. MR. MAYO: In Mr. Purdy's summary with respect to the Detroit system and in your summary of construction information, you both used the terminology"advanced treat- ment. " MR. REMUS: I would like to answer that because I am having fits about this business of what concentrated activated sludge is — I didn't mean it that way, but that is how it came out — or secondary treatment or tertiary ------- 498 G. J. Remus treatment. Our treatment is made up of oxygenation and the use of chemical treatment to the extent that it is necessary in combination to take care of both the organic and inorganic waste. And I call it "advanced treatment." And I don't have to get all hooked up trying to explain in front of various groups what so and so meant and what so and so meant. MR. STEIN: Let me make a comment on that because I think it may save time all around, I think maybe you don't like this term that I used before, possibly — "sophis- ticated." But I think as our treatment is getting more and more sophisticated and we are dealing with the things you are talking about here, the sooner we stop using the terms "primary," "secondary," "tertiary," "advanced treatment," and the more we describe these in the terms which you have attempted to describe them — the things you tried to get out, the pounds per day you are trying to remove, or if you can't do it in pounds per day, possibly percentages, but hopefully pounds — I think we are going to be a lot better off. Because I have found that even in terms such as "secondary treatment," it may mean something. As you take such a term as "BOD," it can vary from 75 to 90 or 95 percent. And that is quite a spread. You are not talking about the same thing. I do think, Mr. Remus, the kind of approach you have taken on these specifics — and, by the way, we have ------- 499 G. J. Remus gotten this from the industrial people representing Chrysler and Ford on meaningful terms today, and that is generalized terms. MR. REMUS: I agree with that 100 percent because there is so much confusion existent today about what we are talking about. They say, "98 percent treatment.** Wei]., you can spend a week explaining that. MR. STEIN: That's right. MR. MAYO: It is our understanding, Mr. Remus, that the current stipulation under which you are operating has a completion date of the fall of 1970. MR. REMUS: Right. MR. MAYO: And that you presently have before the Commission a request for an extension of that date or a sub- sequent stipulation. Is there any range of dates specifi- cally being discussed? MR. REMUS: If I had to do it over again, I would never have sent that in because of this factor that all we can do is as rapidly as we can get money do the construc- tion. We lost in awaiting financing and in clearing red tape better than a year. We do not think that should be charged to us. You add that to the November 1970 date, and we are not very far out of step. These contracts that we have referred to, and we ------- 500 G. J. Remus * are not talking about plans or what we are going to do, this was sufficient. That is, this action will be completed in 1972, and I think you will see great improvement. MR. PURDY: I would like to comment on that. Mr. Mayo, that request was placed before our Commission, and the Commission recognized that any extension of time would have to be a joint Federal decision and also a joint Federal- Lake Erie conference decision. The Commission did not act upon it. It instructed me to discuss this with the Federal Water Quality Administration officials. And at their request, the Commission has delayed any action upon that extension of time pending progress by the city of Detroit. And that is where it lies at the moment. MR. REMUS: I would want to emphasize that since we have had clearances on the funds, I think the record shows very clearly that a great many millions of dollars of construction are underway. And as soon as we get the next clearance, another $90 million will be put into construction, And it will be what it will be and where. It is not satis- tory to us, and it probably isn't to you people. But never- theless, the basic construction program is under way. When did we start? You know, I can't remember, and I have been here 41 years. But in World War II, if you said something when ------- 501 "G. J. Remus the Federal Government came in and stopped automobile produc- tion and started the airplane production about getting that out of the sewers, you would have been unpatriotic. And that's really where the great amount of this deterioration from the standpoint of keeping up with the job occurred. MR. MAYO: I have one final question, Mr. Remus. In your schedule, you indicate that as of November 1972, approximately 400 MGD would be received in primary only and the remaining 400 MGD would be received as you have identi- fied as "advanced." MR. REMUS: That has been stepped up in that we are referring to twice the capacity for half the amount on oxygenation because you can get more out of there. So about two-thirds of the total output would be aerated; all of it would be treated with polymers and chemical precipitation. And I think we will meet those standards that are on the basis of data we have prepared. MR. MAYO: You have indicated that all of the approximate thousand MGD will receive what you have identi- fied as advanced treatment by 1976. MR. REMUS: That's correct. And if you will refer to the program we referred to, that additional $280 million worth of construction, that's what we are talking about. That is not financed, however. The $159 million is. And ------- 502 G. J. Remus here I think the Federal people can help us a great deal because by that time they will owe us $40 million on the basis of the schedule we have got. If we get that plus a few other things, we will do the $280 million, too. MR. MAYO: Thank you very much. MR. STEIN: Any other comments or questions? (No response.) I admire your financing, and I am not going to dispute it here about owing you $40 million. I will try to get you as much as I can. You know, I would like to join Mr. Lyon in saying that I think that you certainly ought to be commended for working out as effective a plan with your suburban communi- ties as any I have known in the country, particularly when you have had to go the hard way through negotiations. MR. REMUS: Thank you. MR. STEIN: In some of the places they put them all together by State statute, and there is no way to go but you have had to do it the hard way. And I think this is a problem we have all over. And I think in my opinion, there is no question that you have been more successful here than we have anywhere else in dealing with that kind of problem. Are there any other comments? ------- 503 G. J. Remus (No response.) Let me just tell you a little bit because I know you get confused or everyone gets confused on this financing and Federal operation. But because we have had to consider the city of Warren suing us as well as you, maybe they think we are on the same side. I don't know. It is very peculiar. I don't know if a representative of the city of Warren is here to hear this. I don't want it to be lost. After they finally sued, they came into Washington and asked for it again. And I know at least the way I have been brought up, and I think you have been, Gerry, when someone sues you and they come around and ask for money, I don't know that the welcome mat is out. I don't quite understand that. I was going to say a little before we stopped this on financing to give you an idea how this works. I was out with three fellows the other day for lunch in Washington. And after the check came, all these three people grabbed. I was sitting there quietly. But they all grabbed for the check. And each one had their hand over it. And one fellow said, "You better let me pick this check up." He said, "You know, I am in the 50 percent tax bracket. It is going to cost me 50 cents on the dollar." The other fellow said, "Heck, I am in the 90 ------- 504 G. J. Remus percent bracket. It is only going to cost me a dime." The third fellow said, "You both better quit and give it to me. I have a contract with the Government, and I am going to make 6 percent." Thank you, Gerry. MR. REMUS: No wonder you didn't reach for that check. MR. STEIN: I was in good company. Thank you, Gerry. MR. PURDY: Well, Mr. Stein, we, of course, are quite pleased and very proud of the accomplishments that have been made in pollution control here in southeastern Michigan through the regional system. Significant progress has been made. There are places where there have been sig- nificant delays, but you can see a program unfolding. Yesterday, in the Government's presentation, if you remember, he came out strong for the regional systems. And in his remarks, he did note that in dealing with these many units of government in a regional system that this required time and that there might be delays in unfolding the system, delays that we would not like to see occur, but in the long run if we gave time for the regional system to develop that we would come out ahead in the future. And so this is the sort of program I think we see developing here ------- 505 H. S. Liebert in the southeast Michigan area. I have one other request to make a statement. I have been informed it is a short statement. It is Mr. Liebert, representative of the Downriver Antipollution League. Mr. Liebert. STATEMENT OF HILLEL S. LIEBERT DOWNRIVER ANTIPOLLUTION LEAGUE ANN ARBOR, MICHIGAN MR. LIEBERT: Thank you, gentlemen, for letting me make my statement without any advance warning. I walked in and asked to be able to do this, and lo and behold1 I was the next speaker. My name is Hillel Liebert. I am a social worker student in community practice at the University of Michigan. I have lived in southwest Detroit, and I have been asked by the Downriver Antipollution League to make a few comments, a few statements, which mainly deal with process. They don't deal with the technical points, and they don't deal with much of the substance I am sure you have been talking about. I wasn't here yesterday. I am not sure exactly what has gone on. I know mercury is a big issue here, and it is with us. The Downriver Antipollution League is made ------- 506 H. S. Liebert up mostly of working people in the downriver cities. Southwest Detroit is included, but River Rouge, Ecorse, Wyandotte, Lincoln Park, and all the way down to Monroe is where our members live. They couldn't be here today because many of them are working. We have heavy representation among UAW workers, steel workers, and oil, chemical and atomic workers in that area. Mainly, the statements deal with citizen partici- pation. And I jotted down a few notes. We will see how brief I can be. First of all, we feel citizen participation is very important. Back at school where social workers talk to social workers, we have heard a great deal about the new trend. Citizen participation is in. It is the thing. But when I come to hearings of the various enforcement officials, bodies, when I see the newspaper headlines, when we speak with officials and write to them and receive replies, we find this is not really as in as we would like it to be. And we find that citizens do not have as much influence as we thought or that people in the campuses perhaps think they have right now. We feel that citizens can best represent citizens. And we feel that there is need to make some changes in the ------- 507 H. S. Liebert procedures and processes that people in the pollution field are setting up and following right now. We feel also that citizens can help. We feel we can help officials on all levels. In particular, the people in the downriver area say that they have a very special position. They work in the plants. They have a lot of information. And they have been offering this information, but it hasn't been taken up. Their offers have not been taken up. And they want you to know that they are willing to cooperate and to help in cleaning up the environment in every possible way. I think it is important, especially in these times of unrest, that citizens are involved on all levels before crises emerge and they start picketing as well as after crises like the mercury one emerge. In these times, I think it is important that citizens have not only a feeling that they have some control over the environmental forces around them and that are affecting their daily lives, but that they actually have a significant degree of control over these forces. We feel that the commissions, including the Water Resources Commission of the State of Michigan, need widen- ing. And one reason we are interested in this particular hearing is that we feel Federal intervention may be necessary ------- 508 H. S. Liebert because we don't seem to be able to get anywhere when we ask for citizen participation on the top levels; citizen representation on commissions such as the Water Resources Commission. And we find when we read back, John Kenneth Galbraith wrote about counterbalancing power where the giant labor unions on the one hand and giant business cor- porations on the other hand will counterbalance each other and the public interest will somehow be served. We find when we read about this and we talk about this that it is not true in the water pollution field. There are no labor representatives on the Water Resources Commission to repre- sent the so-called powerful labor interests and to counter- balance the interests of the big business corporations in this State. This is the main concern of the Downriver Anti- pollution League right now. This is what they asked me to say. On two particular issues, we feel we have been getting a run-around. One of them is the mercury issue, of course. I am not going to say too much about that. We had a district engineer from the Water Resources Commission toward the end of March speaking at a public meeting of ours, He was extremely defensive about questions dealing with VJyandotte Chemical Company and mercury pollution. ------- 509 H. S. Liebert He was even more defensive when we brought up the question of thermal pollution which might result from the Detroit Edison nuclear plant — I think it is called the Enrico Fermi plant -- in Monroe where many of our members are very upset by the fact that they don't seem to be instal- ling cooling towers or concerned too much about possible damage to the environment, and they are operating. We feel people aren't listening to us. We feel we have interests to represent, and we have a contribution to make. These two issues in particular are up right now for discussion, and we hope that citizens will be involved. It is true there are procedures like this. I am allowed to get up here and speak. But we find that the general structure, not only of the commissions, but of hearings and procedures and setting of standards make it very difficult for citizen groups to be involved and make their feelings known. Just the general attitude of officials, the way the people are spoken to and dealt with, makes it very difficult for us to say what is on our minds. We also feel that although the enforcement officials do have problems in the areas of funds, funding and enabling legislation, that they seem to be overly concerned with busi- ness interests, interests involved in tourism, and less con- cerned with the citizens who live and use recreation ------- 510 H. S. Liebert - facilities in the areas affected or involved. We feel we need strong penalties, and we need strong enforcement of those weak penalties we now have if we are going to get anywhere. And we feel that small people and people in the middle areas such as the commercial fisher- ment in Lake St. Clair need compensation for losses caused by such companies as Dow of Canada -- the future losses per- haps from other companies on this side in the mercury area. And we feel we are not going to get any action unless there is Federal intervention. At least, at this time, this is how we feel. Federal standards are extremely important. And Federal pressure on State officials is what we think will really count. And thank you very much for letting me just say this. This is our feeling right now and our attitude. And that is about all they wanted me to convey. MR. STEIN: Thank you, Mr. Liebert. Mr. Purdy. MR. PURDY: Mr. Liebert, I think that you do know that there is a 7-member Water Resources Commission. Three of those members are citizen members at the present time appointed by the Governor. That's not quite 50 percent, but there is citizen participation in the Commission. ------- 511 H. S. Liebert The Commission does not determine who the members will be. This is a legislative matter. The Commission has not opposed widening of repre- sentation on the Commission. To my knowledge, there has never been a bill introduced in the legislature to place a representative of labor unions on the Commission. I would imagine that if such a bill were introduced that the Com- mission would support this sort of widening of representa- tion. So I believe that your criticism of the Commission from that standpoint is somewhat unfair. MR. LIEBERT: Thank you, Mr. Purdy, for your support in our request or what I think is your support. There is a bill, or I have been told there is a bill, which asks additional representation on the Commission from the Department of Commerce. MR. PURDY: That's correct. MR. LIEBERT: And we would hope that the legis- lators we have been speaking with, if this bill hasn't already been disposed of, and the Water Resources Commission would ask that this bill be amended to specify conservation interests to be represented and labor interests as well. MR. PURDY: Generally, a good way to kill legis- lation is for the administrative agency to ask that something ------- 512 H. S. Liebert be included in it. The legislators seem much more responsive to the citizens rather than the administrative agencies who are frequently referred to as bureaucrats that are only trying to widen their scope of power. So I say to you that you ought to contact your legislators and get them to intro- duce that amendment. And you will be much more successful in doing that than having the Water Resources Commission attempt to do that. MR. LIEBERT: Yes, sir, I think our members have been trying to do this. And I think you are right. One of the problems we had, though, or we felt that exists, is the fact that when you have all these department heads on the Commission, it is hard to get action. There are conflicts of interest, and there are vested interests, And we would prefer to see them as consultants rather than as voting, active members of this Commission. But I know this isn't really the business of this body. MR. STEIN: Yes, I am not sure you are making your pitch before the proper forum. I don't know whether we agree or disagree with you. Thank you very much. MR. PURDY: That completes the presentation on the part of Michigan. I would like to make one closing comment ------- 513 on Michigan's behalf. Yesterday, you referred to the problems of pollu- tion in Lake Erie. We had a presentation by the Bureau of Commercial Fisheries in which certain recommendations were made. And they said that the solution to the problems of Lake Erie was the removal of nutrients and under question- ing specifically stated phosphates to be the key. Other problems that have been identified in the Detroit River and Lake Erie are problems caused by bacteria" of human origin as it relates to the coliform organism as the identifying form, although Lake Erie as a whole does not have a bacterial contamination problem. Other problems have been suspended solids of muni- cipal and industrial waste origin — phenols primarily of industrial origin, oils of industrial origin, waste acid from steel mills, and then the organic oxygen-consuming substances as measured by the biochemical oxygen demand, largely trace- able to paper mills and municipal waste sources. Now, I think really that major progress has been made in the battle to save Lake Erie, in particular since the problem in Lake Erie as a whole relates to the nutrient input and in particular phosphates. We pointed out that the Detroit Water Board system that serves some 40 percent of the population of Michigan represents the largest single ------- 514 input. Also, now, it has provided treatment to take the phosphate nutrients, tie them up so that they are not available now to feed the algae loads in Lake Erie. Significant progress has been made in controlling the bacteria of human origin. The suspended solids load from industry has been largely now reduced to the objectives that the Water Resources Commission has set. And those objectives had been agreed to by the conferees. The polyelectrolytes will be added to the Detroit water for the system in 1971, and there will be significant reduction of suspended solids of municipal waste origin. The phenol problem is yet to be licked entirely. The oil problem, though, has been substantially corrected. This was largely of industrial origin. The waste acid from steel mills now has been com- pletely eliminated. As a waste, it has been fed on a control basis in the Detroit system to control nutrients. So I am not quite as discouraged as some of your remarks might have indicated yesterday. I think that major progress has been made towards saving Lake Erie. There are remaining problems of major concern, but these problems now affect largely localized areas within the Detroit River and the localized area near the mouth of the Raisin River. ------- 515 G. H. Eagle There are some dissolved oxygen problems there right at the mouth of the river, and there are the coliform problems on the Sterling State Park beaches. But again, construction is under way to correct those problems, and we can see an end. So I am encouraged by the progress that has been made. MR. STEIN: Thank you. Are there any comments or questions? (No response.) If not, does Michigan have any more? MR. PURDY: That's all. MR. STEIN: I think we will be able to complete the presentations of the other States before the noon break. And this afternoon, we will devote to mercury. At this point, we would like to call on Ohio. STATEMENT OF GEORGE H. EAGLE CHIEF ENGINEER OHIO DEPARTMENT OF HEALTH MR. EAGLE: Mr. Chairman, conferees, ladies and gentlemen, my name is George H. Eagle. I am Chief Engineer of the Ohio Department of Health. The Division of Engineer- ing serves as the technical staff of the Ohio Water Pollution Control Board. On behalf of the Board and the Department, ------- 516 G. H. Eagle "I wish to submit this report in its entirety for the record. I am going to skim through this report to some extent. With regard to municipal programs, the conferees established corrective measures and schedules of construc- tion for 95 municipalities involving 97 projects, 77 of these municipalities were to have the required facilities completed by December 31, 1969. The progress to date with respect to these requirements is as follows: This is basically the same data Mr. Harlow presented yesterday, but the summaries are quite different. And you will note here that of these 77 municipalities, only 35 had completed and placed into operation their facilities. Another 33 of them are in the construction or planning stage at this time, and there are nine that I will report on separately. But of these 33, in the next paragraph, explanation is given of what the status of these are, the progress that they are making. And of the remaining nine, three of these nine communities have failed to make satisfactory progress in the planning of the required facilities. These communities — namely, Avon, Independence and Oakwood — have been ordered after public hearings by the Board to submit reports and general plans by September 1970. To prevent further water ------- 517 G. H. Eagle pollution from these communities, the Board has prohibited v any new connections to the sewer systems of these communities which contribute additional pollution to waters of the State. In essence this means a freeze on any new building in these communities. Three more communities, namely, Grand River, Northwood, and Waterville, are required to complete the neces- sary legislation and to provide the necessary sewers for con- veying their municipal wastes to the facilities of another municipality. Two communities are preparing revised plans for facilities to accommodate expanded service areas. The ninth community finally hired an engineer in February of this year. The schedules adopted by the conferees called for - the completion of 15 more municipal projects by December 15, 1970. Five of these are currently under construction, two will be completed this year and the other three will be com- pleted during 1971, Detail plans have been approved for the sixth municipality with construction to begin this fall. A seventh is preparing detail plans. Of the remaining eight municipalities, six have failed to make satisfactory progress in planning the necessary facilities. As a result three have been ordered by the Board to prepare the required detail plans prior to January 1, 1971. These three are Broadview Heights, Euclid and Willoughby, all in the Cleveland area. ------- 518 G. H. Eagle In addition, Painesville and Amherst have been ordered to complete detail plans and general plans respectively by September 1970 and Fairport Harbor has been ordered to com- plete negotiations for connection to the Painesville systems. The Board here again has imposed a "freeze" on any new building in Painesville, Fairport Harbor and Broad- view Heights. Of the remaining two, the City of Sandusky is required by current permit to initiate construction, and the City of Delphos is required by permit to authorize the preparation of detail plans by June 1970. The facilities under construction by the City of Akron are one of the two projects mentioned above to be com- pleted this year. In fact, these facilities should be com- pleted by July 1. Concurrently with the completion of this project three of the four major rubber companies will com- plete this fall major pretreatment facilities for the signi- ficant reduction of latexes discharged to the Akron city sanitary sewer system. A fourth company is expected to complete its latex removal facilities next spring. Also by next spring, facilities for the recovery of spent pickle liquors from a major operation now discharged to the sanitary sewer system will be placed in operation. These have been quite a problem in the City of Akron as pointed out here. And these pretreatment facilities ------- 519 G. H. Eagle are being installed in accordance with the City of Akron and Ohio Department of Health requirements. And the general clean-up of the other industrial waste problems in the City of Akron, and in view of the above, these major improvements of the system in Akron should considerably improve the water quality of the Cuyahoga River downstream from Akron this summer. This has been a very, very difficult problem. The schedule adopted by the conferees for the com- pletion of projects beyond 1970 are as follows. Cleveland- Westerly December 1971, Lake County-Madison Sewer District January 1, 1971, Lake County-Willoughby-Mentor Sewer District January 1, 1971, and Toledo February 1972. Toledo is under construction, and these others are in the various stages of planning. And the Board has ordered the City of Cleveland to submit detailed plans of improvements to the westerly plant by November 1970. This order was given because the City of Cleveland failed to comply with earlier permit conditions calling for general and detail plans acceptable to the Division of Engineering. The orders of the Board were supplemented by a ban on additional pollution of waters of the State by the city, here again, by the build- ing freeze type of order in the City of Cleveland. And the details of all of this are given in Table 1, Appendix A. ------- 520 G. H. Eagle With regard to phosphorus removal, remember, at the last session, we gave a rather detailed report on the facilities that were being ordered and planned in Ohio for phosphorus removal. And our policy was adopted by the Department to require all plants to design capacity of one million gallons per day or more to provide phosphate removal facilities. Major facilities now under construction and in a few instances nearing completion which will provide phosphorus removal include those of Ashtabula, Avon Lake, Cleveland- Easterly, Lorain, Port Clinton, Toledo, Akron, Defiance and Findlay. The last three discharge to tributary streams whereas the first six discharge directly to the lake. The combined phosphorus load to these facilities is estimated to be 16,600 pounds per day or nearly half of the total estimated Ol.io municipal load to Lake Erie. Phosphorus removal facilities at the Cleveland-Westerly plant have been in operation for a number of months with temporary facilities on an experimental basis. Later this year major phosphorus removal facilities are expected to be placed under construction at Rocky River. With regard to the industrial programs, completion schedules for facilities for the abatement of water pollution by discharges of industrial wastes to the waters of the State ------- 521 G. 11. Eagle were a'dopted by the conferees for 97 Ohio establishments. In no instance did these dates extend beyond December 31, 1969, that is, for completion. Sixty of the required pro- jects have been completed, four other industries have ceased operations. Fifteen others have facilities under construc- tion; 13 of these are expected to be completed this year. Eleven others are expecting to connect to municipal sanitary sewers in their areas. Plans of proposed facilities for five industries have been prepared and are awaiting approval. One other industry is planning to cease all operations this fall. Studies are underway at one plant which has built substantial in-plant facilities for the recovery of process chemicals. One of the proposals for the discharge of indus- trial wastes to municipal sewers is rather unique and may be of interest to the conferees. The City of Cleveland is planning to accept the calcium sulfate wastes from the Harshaw Chemical Company into its sewer system for conveyance to the Southerly plant. This waste is expected to aid substantially in the city's proposal for removal of phosphorus of this plant. Water quality standards — suffice it to say here that Ohio has revised water quality standards criteria which were adopted on April 14, 1970, and were worked out with the ------- 522 G. H. Eagle Federal people and have been submitted to the Secretary for approval. These are appended in Appendix B of this report. And these criteria include the statement on the protection of high quality of waters. And I might point out that these criteria apply to Lake Erie or portions thereof where such quality levels are better than existing water quality. In the Lake Erie water quality standard, we stated where they were not better than the existing quality, the existing quality in the lake would prevail, would become the standard. Now, with regard to advanced municipal waste treatment or 95 percent removal if you prefer or whatever you want to call it, we have a number of places in Ohio that call for more than the conventional secondary treatment. And these are listed here. There are about 10 municipalities that now are presently in one stage or another providing so- called advanced waste treatment facilities. Now, on the next page, we speak about the exces- sive stormwater problems in combined sewer overflows. And these are very serious problems in and around the City of Cleveland. And failure of the City of Cleveland was one of the reasons that they were given an order to prohibit any further contacts until this program moved forward. Another serious problem is the use of storm sewers ------- 523 G. H. Eagle of the City of Euclid which conveyed industrial wastes to Lake Erie. Legally, the use of this sewer — I think Mr. Harlow mentioned this in his report yesterday — is under the jurisdiction of the city, of course. Action towards correction of pollution caused by the wastes in this sewer has been hampered for a number of years due to prolonged litigation between the city and an industry over damages to this sewer. Recently, a member of our staff has carried out several investigations of this problem in cooperation with the city. As a result recommendations as to treatment re- quirements were made to the city by the Ohio Department of Health staff. Furthermore, as a guideline, the staff pro- vided the city water quality objectives for defining storm- water, which are in effect criteria for water quality for all uses. And a copy of this has been provided the Cleveland office of FWQA. Industrial waste in the Ashtabula area, this is a problem of long standing. And while a lot of improvements have been made, conditions are still far from satisfactory. And I think we are going to have a workshop in Ashtabula so this will probably be taken up in detail there. But to correct this problem, the Board has requested or more or less ordered the industries to give serious consideration to a joint terminal facility for treatment of the combined ------- 524 G. H. Eagle industrial waste effluent from this field growth. JUst in conclusion, I would like to mention that one of the reasons — not an excuse, but certainly it is a reason — why we are behind on these schedules, particularly with regard to municipalities, is that we have lost practi- cally a year and a half in trying to implement the $100 million bond issue that was passed in Ohio in November 1968, to provide the necessary funds to finance these projects from the State and the Federal Government. Of course, in the meantime, the Federal appropriations have been increased. I am very happy to report that now our funding on the 30 percent basis for all projects is fully underway. And we have close to a half a billion dollar program over the next three or four years — two or three years, hopefully — underway, a.nd we will be in process in one form or another in the construction stage within the next two or three years. This will certainly accelerate conditions considerably, we feel. That's all. Thank you. MR. STEIN: Thank you, Mr. Eagle, for a very extensive reort. The whole report, without objection, will appear in the record as if read. (The above-mentioned report follows in its entirety.) ------- 525 (1D.C3'!(;.'„;- E. W. ------- 526 STATEMENT OF DIVISION OF ENGINEERING OHIO DEPARTMENT OF HEALTH Mr. Chairman, conferees, ladies and gentlemen, my name is George H. Eagle. I am Chief Engineer of the Ohio Department of Health. The Division of Engineering serves as the technical staff of the Ohio Water Pollution Control Board. On behaJf of the Board and the Department. I wish to submit this report in its entity for the record. This report is a progress evaluation of Ohio's program for compliance with the conclusions and recommendations of the Lake Erie Pollution Enforcement Conference of August 1965. MunicipalPrograms The conferees established corrective measures and schedules of construction for 95 municipalities involving 97 projects, 77 of these municipalities were to have the required facilities completed by December 31> 19&9- -^ie progress to date with respect to these requirements is as follows: Number of municipalities requiring facilities by December 31? 19^9 - 77 Number completed 35 Number under construction 10 Number - detail plans approved 12 Number - reports and general plaus approved 11 Number remaining 9 Of the 10 projects under construction eight are to be completed this year, and two are to be completed during 1971- Of the 12 communities with approved detail plans, six a,re expected to complete the construction of their facilities during 1971 and three are expected to complete their facilities during 1972; two projects are being he3_d up by litigations. Construction has been delayed for one small project to arrange for the necessary finances. Most of the area of this community is tributary to other facilities. Detail plans are currently in preparation for the 11 communities with approved reports and general plans. These plans are expected to be completed later this year or early next year. Upon approval of the detail plans, it is expected that construction will begin within 90 days and that construction will be completed late in 1971 or early 1972. Three of the nine communities remaining have failed to make satisfactory progress in the planning of the required facilities. These communities, namely Avon, Independence and Oakwood have been ordered after public hearings by the Ohio Vator Pollution Control Board to submit reports and general plans by September 1970. To prevent further •water pollution from these communities, the Board has prohibited any new connections to the sewer systems of these communities which contribute additional pollution to waters of the state. In essence this means a freeze on any new building in these communities. Three more communities, namely Grand River, Northwood, and Waterville, are required to complete the ------- 527 necessary legislation and to provide the necessary sewers for conveying their municipal wastes to the facilities of another municipality. Two communities are preparing revised plans for facilities to accommodate expanded service areas. The ninth community finally hired an engineer in February of this year. v The schedules adopted by the conferees called for the completion of 15 more municipal projects by December 15, 3-970. Five of these projects are currently under construction, two will be completed this year and the other three will be completed during 1971. Detail plans have been approved for the sixth municipality with construction to begin this fall. A seventh municipality is currently revising detail plans. Of the remaining eight municipalities six have failed to make satisfactory progress in planning the necessary facilities. As a result three have been ordered by the Board to prepare the required detail plans prior to January 1, 1971. These throe municipals tics are Broadview Heights, Euclid and Willoughby. In addition, Paincsvi.lle and Amlierst have been ordered to complete detail plans and general plans respectively by September 1970 and Fairport Harbor has been ordered to complete negotiations for connection to the Painesville systems. Furthermore, the Board has imposed a "freeze" on any new building in Painesville, Fairport Harbor and Broadview Heights. Of the remaining two, the city of Sandusky is required by current permit to initiate construction, and Delphos is required by permit to authorise the preparation of detail plans by June 1970. The facilities under construction by the city of Akron are one of the two projects mentioned above to bs completed this year. In fact, these facilities should be completed by July 1. Concurrently with the completion of this project three of the four major rubber companies will complete this fall, major pre-treatment facilities for the significant reuuevion of lutc;:etj discliui'god to the Aluron city sanitary sewer system. A fourth company is expected to complete its latex removal facilities next spring. Also by next spring, facilities for the recovery of spent pickle liquors fro-,r. a major operation now discharged to the sanitary sewer system will be placed in operation. The above vaste increments have placed a major burden on and have interfered with the performance of the facilities of the city of Akron. These pre-treatment facilities are being installed in accordance with requirements of the Ohio Department of Health, working in cooperation with officials of the city. The industrial waste discharge of ^0 other industrial discharges to the sewer system have been found to be in violation of City Code and orders for corrective measures have been issued by the city in accordance with the requirements of the city's permit from the Board. In view of the above, major improvements of the water quality of the Cuyahoga River downstream of Akron is expected by next summer. The schedule adopted by the confci^ccc for the completion of projects beyond 1970 are as follows. Cleveland-Westerly December 1971, Lake County-Madison Sewer District January 1, 1971, Lake County-Willoughby-Mcntor Sewer District January 1, 1971, and Toledo February 1972. The facilities for the city of Toledo were placed under construction in April 1970. The Board has required by permits, detail plans for Madison Sever District by October 1970 and genera,! plans for Uilloughby-Mentor by June 1970. The Board has also ordered the city of Cleveland to submit detail plans of improvements to the Westerly plant, by Roveir.bcr 1970, This order was given because the city of Cleveland failed to comply with earlier permit conditions calling for general and detail pi ens acceptable to the Division of Engineering. The orders of the Board were supplemented by a ban on additional pollution of waters of the state by the city. -2- ------- 528 • Information on the status of compliance of each municipal project with the recommendations and conclusions of the conferees are given in Table 1, Appendix A. Phosphorous RCTOval At the last session of the conference Ohio's program for phosphoroiis removal was presented. Included was a list of those cities which have been required to install phosphorous removal facJlitics, Included were 15 facilities which dis- charge directly to T,ake Erie and 20 facilities which discharge to Ohio tributaries to Lake Erie. The Ohio Department of Health has adopted a policy of requiring phosphorous removal at all plants with a design capacity of 1.0 mgd or more. Major facilities now under construction and in a few instances nearing completion which A/ill provide phosphorous removal include those of Ashtabula, Avon Lake. Cleve3.and-Easterly, Lorain, Port Clinton, To3.edo, Akron, Defiance and Findlay. The last three discharge to tributary streams whereas the first six discharge directly to the Lake. The combined phosphorous load to these facilities is estiru/bed to be 16.600 pounds per day or nearly half of the total estimated Ohio municipal load to Lake Erie, Phosphorous remove! facilities at the Cleveland- Westerly plant have been in operation for a number of months with temporary facilities on an experimental basis. Later this year major phosphorous removal facilities are expected to be placed under construction at Rocky River. Industrial P^{2~£M£ Completion schedules for facilities for the abatement of water pollution by discharges of industrial wastes to the waters of the state were adopted by the conferees for 97 Ohio establishments. In no instance did these dates extend beyond December 31? 1969- Sixty of the required projects have been completed, four other industries have ceased operations. Fifteen others have facilities under construction; thirteen of these are expected to be completed this year. Eleven others are expecting to connect to municipal saaitary sewer systems; five of these eleven are currently negotiating for connection to municipal sewers and the other six are awaiting the construction of municipal sewers in their areas. Plans of proposed facilili es for five industries have been prepared and are awaiting approval. One other industry is planning to cease all operations this fall. Studies are underway at one plant which has built substantial in-plant facilities for the recovery of process chemicals. One of the proposals for the discharge of industrial wastes to municipal sewers is rather unique and may be of interest to the conferees. The city of Cleveland is planning to accept the calcium sulfate wastes from the Harshaw Chemical Company, into its sewer system for conveyance to the Southerly plant. This waste is expected to aid substantially in the city's proposal for removal of phosphorous of this plant. ------- 529 As reported at the last session, the Ohio Water Pollution Control Board had adopted Water Quality Standards for all significant Ohio tributaries of Lake Erie:- On AprilT^-, 1970, the Board adopted amended criteria of stream water quality for various water uses. A copy of the Board's resolution is included in Appendix B. The amended criteria up grades waters classified as Aquatic Life A, Aquatic Life B, and recreational waters. The revised criteria for Aqmtic Life A up grades the requirements for dissolved oxygen, water temperatures and pH. For Aquatic Life B the revised criteria up grades the requirements for dissolved oxygen and pH. The revised criteria for recreational water uses consists of a fecal coliform limit in place of the total coliform limit . The above criteria are to be applied to all respective standards adopted by the Ohio Water Pollution Control Board for all tributaries of Lake Erie. Further- more, these criteria are also to be applied to Lake Erie or portions thereof where such quality levels are better than existing water quality, otherwise existing quality levels are to prevail. The amended criteria, adopted by the Board on April 1^4 , 1970 includes a policy statement with regards to the protection of high quality waters. This policy shall be applied to Lake Erie and all applicable sections of the tributary streams. To meet the Water Quality Standards established for Lake Erie and its tributaries will require, in a number of instances, treatment facilities or corrective measures in addition to those originally established by the conferees. In addition, further corrective measures are required as the result of expansions, changes in processes, annexations, population growth and the obsolescence of existing facilities. New or additional requirements to meet these conditions as set forth by permit conditions, board orders or the establishment of intrastate water quality standards for municipal facilities are given in Table 3> Appendix A, likewise the new or additional requirements for industrial establishments are given in Table h, Appendix A. Advanced I'lOnLcipal _Wa.ste Treatment For municipal wastes the standards call for the construction of advanced waste treatment facilities in a number of critical areas . The communities and/or facilities for which this requirement has already been established are as follows : Ada Cleveland-Westerly Akron Delphos Archbold Findlay Bryan Lima Cleveland-Easterly Van Wert Cleveland-Southerly Wapakoneta The facilities for Findlay are currently under construction and detail plans of such facilities have been approved for Archbold and a report and general plan has been approved for Bryan. The current permits for the other communities call for the submission of reports and general plans for such facilities prior to the expiration date. In no instance, is a permit calling for improvements granted for a period of more than one year. ------- 530 -Also in accordance with the adopted Water Quality Standards most permits include a condition calling for the correction of excessive storm water problems and combined sewer overflows. The latter is a most serious problem in and around Cleveland, Failure of the city to provide an adequate program for the correction of this problem was an important factor in the Board's action of imposing a ban on any additional pollution of the "waters of the state" by the city. Another serious problem is the use of a storm sewer of the city of Euclid for the conveyance of industrial wastes to Lake Erie. Legally the use of this sewer is under the jurisdiction of the city. Action towards correction of pollution caused by the wastes in this sewer has been hampered for a number of years due to prolonged litigation between the city and an industry over damages to this sewer. Recently, a member of our staff has carried out several investi- gations of this problem in cooperation with the city. As a result recommendations as to treatment requirements were made to the city by the Ohio Department of Health staff. Furthermore, as a guideline, the staff provided the city water quality objectives for defining storm water. A copy of these guidelines have been furnished to the Cleveland office of Federal Water Quality Administration for their comments. Industrial Wastes__- Ashtabula Area The program of corrective measures adopted by the conferees for the industrial waste discharges from the chemical complex in the AshtaTrula area were based on production and process operations at that time. As originally conceived some of the wastes of one plant became a part of the raw materials of another plant. This is no longer the case with respect to hydrochloric acid which was produced as a by-product. Waste treatment facilities constructed in accordance with requirements of the conferees were not capable of treating the no longer saleable by-product. To cope with this problem additional corrective measures were required. Furthermore, the interaction of the treated wastes from these industries plus those who have recently constructed new plants is such that the waters in Fields Brook do not meet the criteria for asthetic conditions and the discharge of this stream into the Ashtabula River is such that it seriously degrades the water quality of the river. To correct this problem the Board has requested the industries to give serious consideration to a joint terminal facilities for treatment of the combined industrial waste effluents. -5- ------- H j O a: !__ -IT.. — O \O uj vo r' O^ -w 532 ;D f£ >- c- o „- m^\o. — •. vo : •. ------- 533 ISZC3 — co o — ^r or •""S^j . UJ UJ — > UJ CC. CO -^ »CO 10 000 Ott: CD CL. O U_ 2; H- — 2 UJ _J G_ O CJ o UJ UJ — i o. o l_J O UJ U.I _J Q- O (_) O UJ UJ _j G_ O 0 or: O r.' >• a. 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UJ t— CO — O J o — CO C.I u, ti!Z o j -i •: o :: 560 ------- — o t_ — uj t— • ^f 561 -t ID ^-: c.1 O ^J I— CJ — co So ujce — O o — -(. ------- 562 APPENDIX B ------- 563 WATER POLLUTION CONTROL BOARD OHIO DEPARTMENT OF HEALTH COLUMBUS, OHIO RESOLUTION ESTABLISHING AMENDED CRITERIA OP STREAM-WATER QUALITY FOR VARIOUS USES ADOPTED BY THE BOARD ON APRIL lU, 1970 WHEREAS, Section 6111,03, of the Ohio Revised Code, provides, in part, as follows: "The water pollution control board shall have power: (A) To develop programs for the prevention, control and abatement of new or existing pollution of the waters of the state; ,.,," and WHEREAS, Primary indicators of stream-water quality are needed as guides for appraising the suitability of surface waters in Ohio for various uses; and WHEREAS, The stream-water quality criteria for various uses and minimum conditions applicable to all waters adopted by the Board of June lU, 1966, have been amended by the Ohio River Valley Water Sanitation Commission; and WHEREAS, The criteria adopted by the Board on October 10, 1967, have been further amended by the Ohio River Valley Water Sanitation Commission; THEREFORE BE IT RESOLVED, That the following amended stream-water quality criteria for various uses, and minimum conditions applicable to all waters, and policies for protection of high quality waters and for water quality design flow, are hereby adopted in accordance with amendments of the Ohio River Valley Water Sanitation Commission, and the recommendations of the Federal Water Pollution Control Administration. AND BE IT FURTHER RESOLVED, That the amended stream-water quality criteria for various uses, for minimum conditions, for protection of high quality waters, and, for water quality design flow, be made applicable to the following waters of the state: 1. Maumee, Tiffin, St, Joseph, and St, Marys River Basins; 2. Lake Erie & Interstate Waters thereof; 3, Great Miami, Whitewater, and Wabash River Basins; U, Ashtabula River, Conneaut and Turkey Creeks; 5, Ohio River of Ohio-West Virginia and Ohio-Kentucky; 6, North Central Ohio Tributaries of Lake Erie; 7. Scioto River Basin; 8, Little Miami River Basin; 9, Rocky, Cuyahoga, Chagrin and Grand River Basins; 10. luskingum River Basin; 11. Hocking River Basin, ------- 564 MINIMUM CONDITIONS APPLICABLE TO ALL WATERS AT ALL PLACES AND AT ALL TIMES 1. Free from substances attributable to municipal, industrial or other discharges, or agricultural practices that will settle to form pu- trescent or otherwise objectionable sludge deposits, 2. Free from floating debris, oil, scum and other floating materials attributable to municipal, industrial or other discharges, or agricultural practices in amounts sufficient to be unsightly or deleterious. 3, Free from materials attributable to municipal, industrial or other discharges, or agricultural practices producing color, odor or other conditions in such degree as to create a nuisance, k. Free from substances attributable to municipal, industrial or other discharges, or agricultural practices in concentrations or combina- tions which are toxic or harmful to human, animal, plant or aquatic life. PROTECTION OF HIGH QUALITY WATERS Waters whose existing quality is better than the established standards as of the date on which such standards become effective will be maintained at their existing high quality, pursuant to the Ohio water pollution control statutes, so as not to interfere with or become injurious to any assigned uses made of, or presently possible, in such waters. This will require that any industrial, public or private project or development which would constitute a new source of pollution or an increased source of pollution to high quality waters will be required, as part of the initial project design, to provide the most effective waste treatment available under existing technology. The Ohio Water Pollution Control Board will cooperate with other agencies of the state, agencies of other states, interstate agencies and the Federal Government in the enforcement of this policy. WATER QUALITY DESIGN FLOW Where applicable for the determination of treatment requirements the water quality design flow shall be the minimum seven consecutive day average that is exceeded in 90 percent of the years, STREAM-QUALITY CRITERIA FOR PUBLIC WATER SUPPLY The following criteria are for evaluation of stream quality at the point at which water is withdrawn for treatment and distribution as a potable supply: ------- 565 l-ir Bacteria; Colifonn group not to exceed 5,000 per 100 ml as a monthly average value (either MPN or MF count); nor exceed this number in more than 20 percent of the samples examined during any month; nor exceed 20,000 per 100 ml in more than five percent of such samples. 2, Threshold-odor Number; Not to exceed 2k (at 60 deg, C.) as a daily average. 3. Dissolved solids; Not to exceed 500 mg/1 as a monthly average value, nor exceed 750 mg/1 at any time, k. Radioactivity; Gross beta activity not to exceed 1,000 picocuries per liter (pCi/l), nor shall activity from dissolved strontium-90 exceed 10 pCi/l, nor shall activity from dissolved alpha emitters exceed 3 pCi/l. 5. Chemical constituents; Not to exceed the following specified concentrations at any time. Constituent Concentration (mg/1) Arsenic 0.05 Barium 1.0 Cadmium 0.01 Chromium 0.05 (hexavalent) Cyanide 0,025 Fluoride 1.0 Lead 0.05 Selenium 0,01 Silver 0.05 FOR INDUSTRIAL WATER SUPPLY The following criteria are applicable to stream water at the point at which the water is withdrawn for use (either with or without treatment) for industrial cooling and processing: 1, Pissolved oxygen; Not less than 2.0 mg/1 as a daily-average value, nor less than 1.0 mg/1 at any time. 2. pH; Not less than 5.0 nor greater than 9.0 at any time. 3. Temperature; Not to exceed 95 deg. F, at any time. k. Dissolved solids! Not to exceed 750 mg/1 as a monthly average value, nor exceed 1,000 mg/1 at any time, -3- ------- 566 FOR AQUATIC LIFE A The following criteria axe for evaluation of conditions for the maintenance of a well-balanced, warm-water fish population, They are applicable at any point in the stream except for areas necessary for the admixture of waste effluents with stream water: 1. Pissolved oxygen: Not less than an average of 5.0 mg/1 per calendar day and not less than U.O mg/1 at any time. 2. p_H: A. No values below 6,0 nor above 8.5? B, Daily fluctuations which exceed the range of pH 6,0 to pH 8,5 and are correlated with photosynthetic activity may be tolerated, 3. Temperature: A. No abnormal temperature changes that may affect aquatic life unless caused by natural conditions, B, The normal daily and seasonal temperature fluctuations that existed before the addition of heat due to other than natural causes shall be maintained, C. Maximum temperature rise at any time or place above natural temperatures shall not exceed 5 deg, F. In addition, the water temperature shall not exceed the maximum limits indicated in the following table. Maximum WATERS All waters except Ohio River Main Stem-Ohio River Jan, 50 50 Feb. 50 50 Mar. 60 60 Temperature Apr. 70 70 in Deg May June July 80 90 80 87 90 89 . F, Aug. 90 89 During Sept, 90 87 Month Oct. 78 78 Nov. 70 70 Dec. 57 57 Toxic substances; Not to exceed one-tenth of the US-hour median tolerance limit, except that other limiting concentrations may be used in specific cases when Justified on the basis of available evidence and approved by the appropriate regulatory agency. ------- 567 \.FOR AQUATIC LIFE B ** The following criteria are for evaluation of conditions for the maintenam •? of desirable biological growths and, in limited stretches of a stream, for permitting the passage of fish through the abater, except for areas necessary for admixture of effluents with stream waters 1. Pissolved oxygen; Not less than 3,0 mg/1 as a daily-average value, nor less than 2.0 mg/1 at any time, 2. pH; Not less than 6,0 nor greater than 8.5 at any time, 3. Temperature; Not to exceed 95 deg. F, at any time, U. Toxic substances; Not to exceed one-tenth of the US-hour median tolerance limit, except that other limiting concentrations may be used in specific cases when Justified on the basis of available evidence and approved by the appropriate regulatory agency, FOR RECREATION The following criterion is for evaluation of conditions at any point in waters designated to be used for recreational purposes, including such water-contact activities as swimming and water skiing: Bacteria; The fecal coliform content (either MPN or MF count) not to exceed 200 per 100 ML as a monthly geometric mean based on not less than five samples per month; nor exceed kOO per 100 ML in more than ten percent of all samples taken during a month, FOR AGRICULTURAL USE AND STOCK WATERING The following criteria are applicable for the evaluation of stream quality at places where water is withdrawn for agricultural use or stock- watering purposes: 1. Free from substances attributable to municipal, industrial or other discharges, or agricultural practices that will settle to form putrescent or otherwise objectionable sludge deposits, 2. Free from floating debris, oil, scum and other floating materials attributable to municipal, industrial or other discharges, or agricultural practices in amounts sufficient to be unsightly or deleterious. 3. Free from materials attributable to municipal, industrial or other discharges, or agricultural practices producing color, odor or other conditions in such degree as to create a nuisance. it. Free from substances attributable to municipal, industrial or other discharges or agricultural practices in concentrations or combinations which i toxic or harmful to human, animal, plant or aquatic life, ------- 568 G. H. Eagle MR. STEIN: I think since we are going to have these workshops, possibly the conferees or other people could defer some specific comments on the material in the appendix to the time we have these workshops. MR. EAGLE: I would just like to point out, Mr. Stein, we welcome these workshops, and we hope this will result in some substantial assistance from the Federal Govern- ment because we do have some laggards in Ohio — not too many, but some — that we do need some help with. And any assis- tance you can give with regard to these, we would appreciate very much. MR. STEIN: I am happy to say that with all the Lake Erie States, I think particularly since we have had these series of conferences, generally speaking, we have problems, maybe some rough edges of State-Federal relations, but I think it is pretty fair to say we have been working practically as one staff for the past year or two. And you can be assured we will give you all the help possible. MR. EAGLE: Thank you. MR. STEIN: Are there any other comments or ques- tions? MR. VOGT: I have a question, Mr. Chairman. George, I note that in a number of instances, you initiated, as you call it, building fees, imposed building ------- 569 G. H. Eagle fees, on some of your communities. And this particular technique, we have used in Michigan and found it to be rather effective in accelerating control programs, pollution control programs. I am wondering what has been your experience so far in Ohio with these types of impositions. MR. EAGLE: Very good results. In about 90 percent of the cases, it has solved the problem. Of course, we still have a number of them outstanding. I think we have some 25 or 30 outstanding at this time. We started this program about three years ago. To date more than 75 percent of them have gotten under way to the extent that the building fees could be lifted. MR. VOGT: I see. That is interesting because, in other words, it assures the initiation and continuation of a positive program of pollution control. MR. EAGLE: Of course, we do have on the other side, John, some city officials prevail on us to give them building fees because they don't want to see their munici- pality develop. They want to keep it just like it is. MR. STEIN: Are there any other comments or ques- tions? (No response.) Thank you very much, Mr. Eagle, for a very ------- 570 W. A. Lyon interesting contribution. May we call on Pennsylvania? STATEMENT OF WALTER A. LYON DIRECTOR, BUREAU OF SANITARY ENGINEERING PENNSYLVANIA DEPARTMENT OF HEALTH MR. LYON: I will try not to go into any detail and make this very brief, Mr. Chairman. Mr. Bellaman, our Regional Engineer, is passing out copies of our report. I would like also permission to make as part of the record a statement by Mayor Louis J. Tullio of the city of Erie. And Mr. Bellaman has copies of that statement. MR. STEIN: Both the statements will appear in the record as if read in their entirety without objection. (The above-referred to statements follow in their entirety.) ------- '. ------- 572 STATUS REPORT TO LAKE ERIE CONFEREES by Commonwealth of Pennsylvania Department of Health June 3, 1970 (1) Pursuant to adoption of the Lake Erie phosphorus removal plan adopted by the Sanitary Water Board on June 18, 19&9, orders were issued to ten industries and municipalities requiring a substantial reduction in the amount of phosphorus discharged from their waste treatment facilities. Compliance with the orders will result in at least 80£ reduction of phosphorus from municipal and industrial sources in the Pennsylvania portion of the Lake-Lrie basin. At this time, six of the ten dischargers are either in compliance with the orders or are on schedule to achieve compliance by the July 1, 1972 overall deadline. Four of the municipalities have requested hearings. The municipalities that requested hearings are the Boroughs of Girerd, North East, Lake City and Albion. The hearings have not yet been scheduled by our Legal Counsel. We hope to have these soon. (2) The detection of significant concentrations of mercury in Lake Erie fish has had a deleterious effect on Pennsylvania's use of the lake's waters. •The market for commercial fishes has been seriously affected and Governor Shafer has had to warn sport fishermen that concentrations of mercury exceeding FDA limits have been found in certain sport species and these should not be consumed. Mercury in Lake Erie represents a public health threat and is having an adverse economic effect on Pennsylvania. Mercury analyses performed to date show detectable concentrations of mercury in all fishes taken from Pennsylvania waters. Concentrations varied with species and ranged from O.OA parts per million to 1.^3 parts per million. Only edible portions of fish were analyzed. Generally, the top predators such as walleye, smallmouth bass, white bass, and fresh water drum showed the highest concentrations of mercury. Smelt, perch, rock bass, carp, suckers and crappies showed lower concentrations of mercury in the flesh. Samples of several coho salmon taken from the lake showed levels of mercury less than 0.5 parts per million but ranged from 0.3^ parts per million to 0.46 parts per million. The Pennsylvania Fish Commission is periodically sampling fish from Lake Erie. These fish are being analyzed by the Food and Drug Administration Laboratories. ------- - 2 - 573 Samplings of water and waste discharges for mercury were conducted during April and May. Bottom mud and fish samples from the Lake were also taken by the Pennsylvania Fish Commission for analysis. Mercury was not detected in the lake waters and in the bottom muds at the limits of detection of the tests. Mercury was detected in one waste water discharge, but re-sampling indicated that mercury was not present. Contamination of the sample bottles was possible since the first series of samples were not collected in properly cleaned containers. As a result of our waste water survey, we are convinced that there are no significant sources of mercury being discharged to Lake Erie from Pennsylvania sources. We did learn that the Hammermill Paper Company used mercurials up to ten to fifteen years ago for slime control but discontinued the use at that time. We have sampled the bottom muds in the vicinity of the Hammermill outfall to determine if residual mercury is present in this area. We will continue a surveillance program of discharges to Lake Erie. We recommend that action be taken by the conferees to insure that all discharges of mercury and other toxic materials to Lake Erie and its tributaries are halted. (3) Attached are listings of the status of sewerage and industrial waste cases that have been considered by the Lake Erie Enforcement Conference. In addition to these cases, permits have been issued for several small sewage treatment plants to serve installations such as highway rest stops. These treatment plants meet the minimum requirements established by the conferees. ------- 574 TAELE I Sewerage Status (June, 1970) Name Present Status -_ Comments^ City of Erie 1. Sewage treatment plant expansion and improvements - Plans approved for ex- pansion and improvements that include secondary treatment and phosphorus removal such that the effluent will contain no more than 1 mg/1 phosphorus as P. Will treat Erie metropolitan plus Hammermill Paper Company wastes. If grant processing moves expeditious ly should begin construction by October 1, 1970 and complete construction and begin operation by February 15, 1972. 2. Present treatment efficiency, untreated discharges through storm sewers - Treatment plant now providing secondary treatment with continuous disinfection with exception of excessive solids loss from final settling tanks during periods of peak flow. Interim actions to reduce these losses have been ordered and include tighter operation' control. Recent surveys indicate that 80% of the untreated sewage being by-passed at storm sewer outlets has been diverted to the treatment plant. Expansion of the treatment plant, including hydraulic changes, is expected to achieve 100% abatement. At present, additional sewer extensions and new connections are pro- hibited. A hearing on this problem held on October 31, 1S&9 was adjudicated on May 15, 1970, and a compliance schedule must be submitted by August 15, 1970. Expansion of the Bay Front inter- ceptor will ultimately be needed to serve future growth and reduce or eliminate overflows during storms. This project is being held up by design of the Bay Front highway. Sewer and highway design arid construction will have to be coord inated. ------- - 2 - Name Present Status - Comments 575 Nortfi East Borough Presently providing secondary treatment. Ordered August I, 1969 to provide tertiary treatment including phosphorus removal. Have requested hearing before Sanitary Water Board on order. Hearing has not been scheduled by the office of Legal Counsel. Gi rard Borough Albion Borough Lake City Borough Fa ? r.view School Erie County Home Greene Township Elementary School Talarico Truck Stop Howard Johnson Motor Stop Penn State Behrend Center Harborcreek Township School Oakdale Corporation Poplar White Thru-way Terrace Restaurant Mums Motel Conneaut Valley Union Joint Elementary School Kahkwa Club Presently providing secondary treatment. Ordered August 1, 1969 to provide tertiary treatment plus phosphorus removal. Have requested hearing before the Sanitary Water Board on the order. Hearing has not been scheduled by the Office of Legal Counsel. Presently providing secondary treatment. Ordered August 1, 1969 to provide tertiary treatment plus phosphorus removal. Have requested hearing before the Sanitary Water Board on the order. Hearing has not been scheduled by the Office of Legal Counsel. Ordered August 1, 1969 to provide tertiary treatment including phosphorus removal. Have requested hearing before the Sanitary Water Board on order. Hearing has not been scheduled by the Office of Legal Counsel. Treatment plant is overloaded with the result that less than secondary treatment is being provided. Additional sewer extensions and connections are being proh ibi ted. Secondary treatment provided ii ii ii ii ii ii ii ii ii ii ii ii M ii n n n n n n n n n n n n n ii n n M n 11 ii M n ------- - 3 - Name Present Status - Comments 576 Lakeshore Country Club Presque Isle State Park Travelers Rest Fairview Township Industrial Development Corporation Rondal Convalescent Home Humble Oil and Refining Company Summit School District Interpace Corporation Larry's Truck Stop Wenner's Esso Station Wi Ison Motel Alpine Manor Georgetown South Shore Service Company Secondary treatment provided ii n ii n n n n n n n n n n n n n Secondary treatment provided as of April 1, 1970. Secondary treatment provided. Secondary treatment provided. Ordered August 1, 1969 to provide phosphorus removal. Feasibility study was completed but plans not submitted on schedule. Enforcement conference scheduled for May 29, 1970. If plans received by June 1, 1970 there should be no overall delay toward meeting compliance. ------- 577 TABLE II Industrial Status (June, 1970) Case Name Albro Packing Company Hammermill Paper Company Present Status - Comments Providing adequate treatment including phosphorus control. 1. A portion of total compliance will depend on the City of Erie sewage treatment expansion. 2. Delays due to strikes against certain supplies of material, together with construction worker labor problems have caused about two months delay in the pulping conversion process which will reduce the raw waste production to about 1/3 of the BOD load and 1/6 of the color load. Interlake Steel Company Kaiser Aluminum and Chemical Corporation Penelec Company Ruberoid Company Welch Grape Juice Company Objections raised to deep water outfall for treated wastes may delay outfall construction until October 1, 1971. Pulping conversion and resulting waste reduction expected February 15> '971 instead of December 15, 1970. Phosphorus control adequate. Adequate treatment provided n n n n Adequate treatment provided for organic wastes. Cooling water causing thermal pollution in Sixteen Mile Creek. Feasibility report due July 1, 1970. ------- - 2 - Case Name Present Status - Comments 578 J. McCormick Construction Company Nickel Plate Sand and Gravel Erie Ceramics Erie Brewing Company International Pipe and Ceramics Corporation Parker White Metal Gunnison Brothers Tannery Adequate Treatment Provided ii n ii General Electric Company American Sterilizer Company Ervite Corporation W. Ridge Gravel n n n n n n n n Adequate treatment installed as of December 9, 1969. Present treatment less than secondary. Tertiary treatment and adequate phosphorus control designed after research and development project. Inability to obtain necessary rights- of-way has required redesign and relocation of the treatment facility. Now to begin construction by August 1, 1970 and begin operation by October 15» 1970. Phosphorus control is adequate. Ordered to provide treatment of oil bearing wastes. Contracts awarded May 1, 1970. Strikes caused 3i months delay. Partial completion and operation now expected by December 30, 1970 with total com- pletion and operation by April 30, 1971- Adequate Treatment Provided n n n Erie Reduction Connected to City of Erie. ------- 579 WHAT THE CITY OF ERIE, PENNSYLVANIA HAS DONE AND IS DOING TO ABATE POLLUTION ft * * INTO LAKE ERIE * * * BY MAYOR LOUIS J. TULLIO, CITY OF ERIE, PENNSYLVANIA THE CITY OF ERIE'S PRESENT PLANT WAS CONSTRUCTED IN 1954 UNDER PERMIT FROM THE PENNSYLVANIA DEPARTMENT OF HEALTH AND AT THAT TIME HAD AN EFFLUENT THAT MET OR EXCEEDED THE DEGREE OF TREATMENT REQUIRED FOR DISCHARGE INTO LAKE ERIE. THE PLANT CLASSIFIED AS INTERMEDIATE TREATMENT IS CAPABLE OF TREATING 45 MILLION GALLONS PER DAY. THE AREA SERVED BY THE PLANT IS METROPOLITAN IN SCOPE SERVING NOT ONLY THE CITY OF ERIE BUT ALSO THE BOROUGH OF WESLEYVILLE AND THE TOWNSHIPS OF LAWRENCE PARK, MILLCREEK AND HARBORCREEK. THE ORIGINAL PERMIT CALLED FOR CHLORINATION OF THE EFFLUENT ONLY DURING THE BATHING SEASON. IN APPROXIMATELY 1963 THIS PERMIT WAS AMENDED TO CALL FOR YEAR AROUND CHLORINATION. THE CITY HAS COMPLIED WITH THIS ORDER SINCE IT WAS ISSUED. IN 1965, TO ELIMINATE INDUSTRIAL WASTE DISCHARGE FROM THE STORM SEWER SYSTEM AND TO CONTROL THESE DISCHARGES IN THE SANITARY SEWER SYSTEM THAT WERE THREATENING THE SEWERAGE PLANT WITH UPSETS, THE CITY THROUGH THE COOPERATION OF THE MANUFACTURERS ASSOCIATION HAD MADE AN INDUSTRIAL WASTE SURVEY OF THE CITY TO DETERMINE THE QUALITY, QUANTITY AND LOCATION OF INDUSTRIAL DISCHARGES. THIS LED TO PASSAGE OF AN INDUSTRIAL WASTE ORDINANCE IN 1966. THIS ORDINANCE CONTROLS WHAT CAN BE DISCHARGED INTO THE SYSTEM AND WHAT REQUIRES PRE-TREAT- MENT BEFORE IT IS DISCHARGED. DURING 1966 AND 1967 INDUSTRY COMPLIED WITH THESE REGULATIONS. PERIODIC CHECKS SHOW THAT COMPLIANCE WITH THIS ORDINANCE BY INDUSTRY HAS BEEN GOOD. WITH THE CHANGE IN THE STANDARDS FOR DISCHARGE INTO LAKE ERIE, THE CITY, THROUGH ITS SEWER AUTHORITY, WAS ORDERED TO UPGRADE ITS DEGREE OF TREATMENT. ------- 580 -2- PRELIMINARY DESIGN WAS UNDERWAY WHEN WE WERE APPROACHED BY THE HAMMERMILL PAPER COMPANY TO CONSIDER THE POSSIBILITY OF COMBINED TREATMENT OF THEIR IN- DUSTRIAL WASTE AND OUR MUNICIPAL WASTE. THIS WAS AGREED AND PILOT PLANT AND BENCH STUDIES WERE CONDUCTED TO DETERMINE THE DESIGN PARAMETERS AND THE FEASIBILITY OF COMBINED TREATMENT. CONCLUSIONS OF THIS STUDY INDICATED THAT COMBINED TREATMENT WAS FEASIBLE BOTH TECHNICALLY AND ECONOMICALLY. AS A , RESULT OF THIS AN AGREEMENT WAS NEGOTIATED BETWEEN THE CITY, THE SEWER AUTHOR- ITY AND THE HAMMERMILL PAPER COMPANY TO SHARE IN THE COST OF CONSTRUCTION, MAINTENANCE AND OPERATION OF THE NEW EXPANDED PLANT. THE EXPANDED PLANT IS NOW UNDER ENGINEERING DESIGN. PRELIMINARY PLANS HAVE BEEN SUBMITTED TO THE STATE. THE CONSULTING ENGINEERS ARE WORKING TOWARDS A FALL DEADLINE FOR COMPLETED PLANS SO THAT THIS NEW PLANT CAN BE PUT OUT TO BIDS AND CONSTRUCTION STARTED THIS YEAR. THE EXPANDED PLANT WILL PROVIDE FOR COMPLETE TREATMENT PLUS PHOSPHATE REMOVAL IN COMPLIANCE WITH THE STATE'S ORDER. PRELIMINARY COST ESTIMATES FOR THIS PLANT ARE APPROXIMATELY $12,000,000 FOR CONSTRUCTION WITH AN ADDITIONAL $600,000 TO BE REQUIRED ANNUALLY FOR CHEM- ICALS TO TREAT THE PHOSPHATES. COMBINED SEWERS: THE OLDER PART OF THE CITY IS SERVICED BY COMBINED SEWERS. THIS WAS STANDARD PRACTICE UNTIL ABOUT 1930. ALL CONSTRUCTION AFTER THAT TIME WAS SEPARATE SYSTEMS. THE CITY HAS BEGUN A PROGRAM TO SEPARATE ITS COMBINED SEWER SYSTEM IN THE PAST FEW YEARS. EXTENSIVE CONTRACTS HAVE BEEN LET, ESPECIALLY IN THE DOWNTOWN AREA TO ACCOMPLISH THIS. DOLLAR VOLUME FOR THIS WORK HAS EXCEEDED $2,000,000 IN THE PAST FOUR YEARS WITH AN ADDITIONAL $400,000 UNDER CONTRACT AT THIS TIME. ------- 581 -3- ERIE WILL CONTINUE WITH THIS PROGRAM OF SEPARATION AS FUNDS ARE MADE AVAILABLE. SANITARY SEWERS: THE CITY HAS PROVIDED SANITARY SEWERS TO ALL PARTS OF THE CITY. IT HAS ALWAYS BEEN THE ADMINISTRATION POLICY TO EXTEND THESE SERVICES AS PROMPTLY AS POSSIBLE FOLLOWING A REQUEST. AT PRESENT OVER 95% OF THE AREA OF THE CITY IS SERVICED BY SEWERS. THIS PROVIDES SERVICE TO ALMOST 100% OF THE POPULATION. THE ONLY AREAS REMAINING TO BE SERVICED ARE THOSE NOT YET DEVELOPED AND CER- TAIN PORTIONS OF THE BAY FRONT. THE CITY BECAUSE OF ITS TERRAIN DOES NOT REQUIRE MANY LIFT STATIONS. THE CITY HAS AT PRESENT FIVE, THREE OF THESE WERE CONSTRUCTED WITHIN THE PAST FOUR YEARS AT A COST IN EXCESS OF $2,000,000. THIS YEARS CAPITAL IMPROVEMENTS BUDGET PROVIDES $250,000 TO CONSTRUCT ANOTHER LIFT STATION TO SERVICE THE BAY FRONT AREA. THE BAY FRONT AREA OF THE CITY IS SITUATED BELOW THE INTERCEPTOR SEWER, SO ALL OF THIS AREA MUST BE SERVICED WITH LIFT STATIONS. IN 1966 THE CITY HAD THEIR CONSULTANTS PREPARE PRELIMINARY PLANS FOR THIS AREA. PLANS CALL FOR FIVE LIFT STATIONS IN THIS AREA. TWO OF THESE WERE BUILT WITHIN THE PAST TWO YEARS WITH ANOTHER SCHEDULED FOR CONSTRUCTION IN THIS CALENDAR YEAR. THIS SHOULD COVER THE DEVELOPED AREAS, THE REMAINDER WILL BE CONSTRUCTED AS DEVELOPMENT TAKES PLACE. THE CITY ALSO HAS PLANS TO CONSTRUCT LIFT STATIONS AT ITS WEST SIDE WATER PLANT TO PUMP THE WASTE WATER BACK INTO THE SEWER SYSTEM RATHER THAN INTO THE BAY. AS A RESULT OF ENCLOSING THE CREEKS AND RUNS IN THE CITY, MANY SANITARY SEWERS HAD TO BE SIPHONED UNDER THE STORM SEWERS. TO INSURE NO FLOODING OF BASEMENTS, OVERFLOWS WERE REQUIRED TO BE CONSTRUCTED AT THESE SIPHON LOCATIONS. ------- 582 -4- IN THE PAST MANY OF THESE SIPHONS BECAME CLOGGED AND OVERFLOWED INTO THE * STORM SEWERS. TO REDUCE THIS TO A MINIMUM WE HAVE INSTITUTED A PROGRAM OF BI-WEEKLY INPSECTIONS OF THESE SIPHONS AND CLEANING WHEN REQUIRED. THIS HAS GREATLY REDUCED THE OVERFLOWS FROM THIS SOURCE. DURING THE PERIOD OF CONSTRUCTION OF COMBINED SEWERS MANY OVERFLOWS HAD TO BE CONSTRUCTED TO DIVERT HEAVY COMBINED FLOWS FROM THE TREATMENT PLANT. SINCE THE PLANT HAS HAD ADDED CAPACITY MANY OF THESE HAVE BEEN ABANDONED OR PLUGGED. OTHERS STILL EXIST, WE ARE WORKING ON THIS PROBLEM AND THROUGH THE COMBINATION OF SEPARATING THE COMBINED SEWERS AND ADDITIONAL CAPACITY AT THE PLANT SITE, WE HOPE TO SOLVE THIS PROBLEM. THE MOST IMPORTANT PROBLEM WE HAVE NOW IS WITH OUR OLDER SEWER SYSTEM. MANY ILLEGAL CONNECTIONS EXIST AND SOME CROSS CONNECTIONS MUST BE THERE. WE HAVE FOUND MANY OF THESE AND CORRECTED THEM, THEREBY REDUCING THE FLOW TO THE BAY CONSIDERABLY. WE ARE WORKING DILIGENTLY TO CORRECT THIS BUT IT IS A TIME CONSUMING JOB, REQUIRING SEARCHING OLD RECORDS, DYE TESTING AND LOCATION STUDIES. WE WILL CONTINUE TO PURSUE THIS UNTIL ALL LOCATIONS ARE FOUND AND CORRECTED. WE BELIEVE THAT WE HAVE BEEN PROGRESSIVE IN OUR FIGHT TO ABATE THE POLLUTION OF LAKE ERIE AND WILL PLACE OUR RECORD OF ACHIEVEMENT AGAINST ANY ALONG THE LAKE. WE WILL CONTINUE WITH OUR PLANS AND WILL NOT REST UNTIL ALL SOURCES OF POLLUTION INTO THE LAKE FROM ERIE ARE ABATED. ------- 583 W. A. Lyon MR. LYON: I also understand that the county commissioners of the County of Erie and the County Health Department in Erie intend to submit written statements at a later date. MR. STEIN: What later date? To this conference? MR. LYON: I think to this conference. MR. STKIN.* 1 will keep the record open for a week. MR. LYON: Fine, We will advise them accordingly. They may already be in the mail. Our report covers essentially two areas. And I will not read our report. One is the mercury problem. Summarizing briefly, we have monitored our dis- charges and found no consequential mercury discharges any- where in Pennsylvania. We have monitored our waters and have not found anything serious in the way of mercury. We have found that some of the fish that were col- lected in Pennsylvania did have mercury concentrations in excess of the limits, and our Governor has advised sportsmen to not eat certain types of fish. And this is also covered in our report. And we are naturally very deeply concerned about this mercury problem, and I hope will be talking about that. MR. STEIN: You don't mean other people can eat ------- 584 W. A. Lyon the fish other than the sportsmen? MR. LYON: No. We are talking about the fish that the sportsmen collect. We are in favor of sportsmen having mercury-free fish, Mr. Chairman. In connection with our municipal and industrial program, let me briefly summarize that all but two minor discharges in Pennsylvania are providing secondary treatment. We have 32 sources of sewage — municipal and private institutions. Four of our smaller municipalities have requested hearings before our Board in connection with the phosphate reduction orders. And we hope to have these scheduled soon. The city of Erie is approximately 14 months behind schedule in the completion of its program for phosphate removal. And this is associated with the Hammermill dis- charge because the city of Erie has agreed to a significant portion of the Hammermill wastes. They in themselves have helped reduce the phosphates because they will demand phosphates. The delay was caused because it was necessary ------- 585 W. A. Lyon to change the Hammermill process to allow the city of Erie to take those wastes. In connection with page 3 of my report, the South Shore Service Company which is a very small sewage source indicates that the Enforcement Conference is scheduled for May 29. That should be changed to June 5. And the last sentence, beginning with "if plans" should be struck from that portion of the report. We have 16 industrial waste discharges. Three of them are behind schedule, one for two months, one for seven months, and the other for three and one-half months. Other- wise, our industrial program is in good shape. I would like to mention that even though the city of Erie sewage treatment plant will not go into operation until February 15, 1972, the wastes from the Hammermill Paper Company will in fact be reduced very significantly when their change in process goes into effect on or about February of 1971. Their BOD loads will be reduced by about two-thirds and their coli load will be reduced about 80 percent. So that in itself will be a very major reduction in industrial waste to Lake Erie and Pennsylvania. In connection with Mr. Harlow's report, I think the additions I indicated are due to the passage of time perhaps since this information was submitted. I would like ------- 586 W. A. Lyon to, for example, refer to page 2 of the municipal report. Under Erie there should be an indication that an adjudication has been issued as a result of the Bay Point sewer problem requiring abatement by 5/15/72. And the record should also show, and I would request that these changes be made in Mr. Harlow's report if he agrees, that an order stopping all additional sewer extensions and connections has been issued. And I might also mention that the city of Erie has reduced its discharge from this Bay Point sewer from about 10 to 15 million gallons per day to approximately 3 to 5 million. Similarly, in connection with Lake City, sewer connections are being prohibited and the permit is being suspended for failure to meet a compliance schedule. And an order will be issued to expand the sewage plant which appears to be overloaded. In connection with Alpine Manor, the record should show that secondary treatment was provided as of 4/1/1970. Mr. Harlow's report says no schedule. Switching over to the industrial waste portion of Mr. Harlow's report, page F-3, General Electric, the report should show that a permit was issued in March 1970 and construction will be completed and operation begun by ------- 587 W. A. Lyon 4/30/71. In connection with Gunnison Brothers, the report should show that the construction will be completed and operation will be begun by October 15, 1970. And in connection with the Hammermill Paper Com- pany, Mr. Harlow's report should show that the pumping conversion and separate discharge of the diffuser system for the beach plant effluent should be completed by February 15, 1971. And that will indicate the very significant reduction in wastes from that company at that time. And unless there are questions, that completes my report. MR. STEIN: Are there any comments or questions? (Mo response.) I don't want to necessarily get into detail on this, but I just want to spotlight this. In your report, you have North East Borough, Girard Borough, and Albion Borough, Lake City Borough. And presumably your Sanitary Water Board has taken action, but your Office of Legal Counsel has not scheduled hearings. And these are removable necessarily now, and they are in violation. MR. LYON: Well, they are not now in violation until the hearings are held and adjudicated. We are asking our Office of Legal Counsel to schedule these hearings as ------- 588 W. A. Lyon soon as possible. MR. STEIN: When I talk about violation, I mean of the schedules received at this conference. MR. LYON: That's correct. MR. STEIN: And then I think we have one more that maybe we don't see the light at the end of the tunnel — Welch Grape Juice Company. The thing we are looking for is just the feasibility report. We don't have a commitment yet that they are going to clean up. MR. LYON: No, my report says that adequate treat- ment is provided. Are you looking on industrial wastes? MR. STEIN: Table II. It says, "Adequate treat- ment provided for organic wastes. Cooling water causing thermal pollution. Feasibility report due." MR. LYON: Yes, that is correct. I will ask Mr. Bellaman to comment on that. MR. STEIN: Well, we can wait. MR. BELLAMAN: We have received a schedule, but I don't recall offhand what the schedule calls for. MR. STEIN: I think my primary point is to spot- light these so when we go to the workshops, we can get in on these. There is one other one, and I hope we are over the ------- 589 W. A. Lyon ' hump, because I think that/ Walter, long before you went to Pennsylvania, we were always dealing with the Hammermill Paper Company, Do you think that Hammermill is completely on its way now or do we still have some loose ends that we are going to have to tie up before we can write that one off and say they provide adequate treatment? MR. LYON: I think Hammermill is completely on its way. There is one loose end that the company cannot control. They have requested a permit from the Corps for an outfall to handle its beach plant wastes, and we have issued a permit for that discharge. We think it will be completely adequate. However, the Corps has so far not issued its permit. We hope they will. If they don't issue that permit soon, there is going to be a delay. MR. STEIN: Does the Corps have some comments on that? MR. HARLOW: Yes. The Corps has asked us for comments, and we have provided the information to the Corps. But the Corps has not released the permit yet. MR. STEIN: Are we in favor of the permit or not? MR. HARLOW: We are in favor of issuing the permit in connection with meeting the requirements of the Sanitary Water Board. MR. STEIN: Thank you. ------- 590 Perry Miller Are there any other comments or questions? (No response.) If not, thank you very much, Mr. Lyon. And I want to congratulate you on the program, particularly on solving this Hammermill Paper Mill case because I almost dispaired that we would ever clean that up in our careers. But I guess v/e are on our way. May we call on Indiana? STATEMENT OF PERRY MILLER INDIANA STREAM POLLUTION CONTROL BOARD MR. MILLER: Mr. Chairman, conferees, ladies and gentlemen, my name is Perry Miller. And I am representing the Indiana Stream Pollution Control Board. In the introduction to this report, we have indi- cated that we have contacted all of the industries in the Lake Erie Basin, and there are not any of these that are using mercury compounds. Also, Indiana has initiated a pesticide monitor- ing program. We received a grant of approximately $40,000 to institute such a program in the Lake Michigan Basin. We have expanded this and are doing pesticide monitoring in the Lake Erie Basin as well as the Lake Michigan Basin. All Indiana municipalities in the Lake Erie Basin ------- 591 Perry Miller "with recognized sewer systems have secondary-type treatment facilities. In compliance with Indiana's Mandatory Certifi- cation Act, all municipal wastewater treatment facilities in the basin have a certified operator in responsible charge of the facilities. This, plus routine surveillance by repre- sentatives of the Stream Pollution Control Board, has improved operation and maintenance activities. The City of Fort Wayne is continuing the planning and construction of major improvements to its combined sewer system to provide separation and/or treatment of combined sewer overflows. A holding lagoon is under construction across the river from the treatment plant for studies on effectiveness in reducing the pollution from sewer overflows and primary effluent bypassing during runoff from rainfall. A storm sewer separation project is under construction in Glenwood Park and an inner city storm relief plan is proposed if HUD funds are available. The Maumee River plant operated by Diversified Utilities, a private utility, is still operating under over- loaded conditions. An order of this Board requires the utility to expand its treatment facilities {as provided by the Federal Court) and to connect to the Fort Wayne sewer system by September 1, 1970. In addition, at least 80 percent phosphorus removal is to be provided not later than December 31, ------- 592 Perry Miller « 1972. In the interim, requests for additional connections to the sewer system serving this area are not permitted. Effluent Chlorination The Board's plan of implementation adopted in 1967 required the municipalities of Avilla, Berne, Butler, Fort Wayne, Garrett, and Waterloo to provide effluent chlori- nation facilities by the end of 1968. Auburn, Decatur, Garrett Monroeville, and Waterloo and Diversified Utilities, Inc., are providing effluent Chlorination. Avilla and Fort Wayne have Chlorination facilities under construction and Butler is expected to start construction of plant improvements, includ- ing Chlorination, in the next few weeks. New Haven's project for plant improvements including Chlorination and phosphorus removal has been delayed by litigation against the bond sale; however, the city attorney has advised that he expects the project to proceed in the near future. Berne and Garrett do not have an effluent Chlorination project under way. Phosphorus Removal To comply with the recommendations of the Lake Erie conference for 80 percent reduction in phosphorus in wastewater, the Board determined that all communities above 2,000 would be required to install phosphorus removal facili- ties before the end of 1972 capable of reducing phosphorus contributions by 80 percent. The municipalities of Auburn, ------- 593 Perry Miller Berne; Butler; Decatur; Diversified Utilities, Inc., Fort Wayne; Garrett; and New Haven were notified of this require- ment during April 1969. As mentioned in the preceding paragraph, Butler and New Haven have projects approved, which include phosphorus removal, which should go to con- struction in the near future. The pilot plant studies on phosphorus removal by the City of Fort Wayne are expected to start in June 1970. Berne and Decatur have grant applica- tions on file for projects which include phosphorus removal. Of the 21 industries in the basin, 17 have adequate waste control facilities and four need additional treatment facilities. Of the four industries, Kitchen Quip, Inc., Waterloo, and General Plating and Engineering Company, Fort Wayne', do not have adequate control programs in progress. There is a list of 17 of the adequate industries in the report. And it is also noted that Auburn Tankage Company, Auburn, was closed in 1969. A status report on the five industries listed as inadequate at the last status report in June 1969 is as follows: Franke Plating Works, Inc., Fort Wayne Construction on cyanide and chromium wastewater treatment facilities was started during March 1969. Completion ------- 594 Perry Miller was scheduled for the fall of 1969; however, because of late start of construction and equipment delivery, the facilities were not completed on schedule. All equipment has been delivered and final installation is being made and should be completed by June 15, 1970. International Harvester Company, Fort Wayne The company has completed all pollution control work with the exception of improved sewage disposal for a warehouse and packaging building located in the southeast area of the plant. The operation utilizes 290 employees and the waste is treated by a septic tank-absorption system. Only during extremely high soil moisture periods does any of the waste reach the receiving stream. By September 1970, the level of employees should drop to 100 which will improve the capability of the system. Construction is proceeding on a sewer (by a sewer utility) which will enable discharge of this waste to the Fort Wayne sewerage system. Construction on the sewer by the utility was started during the spring of 1968. Construction was stopped during the summer of 1968 because of court action filed by a property owner concerning connection charges and delayed again during late 1968 and early 1969 because of financial difficulty brought on by the delay. Construction was restarted during March 1969. ------- 595 Perry Miller MR. STEIN: When was that to be completed, Mr* Miller? MR. MILLER: I really do not have a completion date, but I would expect it sometime later this year, MR. STEIN: I wonder if as soon as you get that, we could have it to complete the record. 13R. MILLER: Yes, sir, we will supply this, (The above-mentioned information follows,) ------- 595a STATE- ~;S INDIANA ~ f^S^^^^ INDIANAPOLIS 46206 1330 West Michigan Street STREAM POLLUTION CONTROL BOARD O34OO June 29, 1970 Mr. Murray Stein Assistant Commissioner for Enforcement Federal Water Quality Administration Department of the Interior Washington, D. C. 202^2 Dear Mr. Stein: Re: Conference on Lake Erie and its Tributaries At the reconvening of the Conference on Lake Erie and its Tributaries in Detroit on June 3 and U, you requested information about the completion date for the sewer to serve the International Harvester Company in Fort Wayne. American Suburban Utilities advised us on June 12 that this sewer should be completed in the International Harvester area by the Fall of 1970 and certainly before December 31, 1970. In reviewing the report that was presented on behalf of the Stream Pollution Control Board in Detroit, there is a correction that should be made on Page 2 under Effluent Chlorination. The City of Oarrett is providing effluent chlorination and, therefore, should be added in the second sentence as one of the communities chlorinating their plant effluent. The last sentence of this section should be corrected to show that the City of Berne does not have an effluent chlorination project underway. Should you have any questions concerning the above please contact us. Very truly yours, Poole Technical Secretary PEMiller/se ------- 595b Perry Miller ' Parrot Packing; Company, Fort Wayne Construction of a sewer was completed on August 12, 1969, that allowed all the waste to be conveyed to the Fort Wayne sewerage system for treatment. Adequate control is being provided. General Plating and Engineering Company, Fort Wayne The company started construction of cyanide and chromium wastewater treatment facilities during the fall of 1968. Progress on the construction was poor because the owner insisted on doing a large part of the installation. During the summer of 1969, the company abandoned much of the work accomplished and began installation of another method of treatment. Attempts to obtain revised plans were futile and enforcement action was initiated in November 1969. A hearing was held on February 4, 1970, concerning pollution of the receiving stream. The recommended findings of fact have not been issued, but should be available in the near ------- 596 Perry Miller future. The staff plans to recommend to the hearing officer that plans and specifications be submitted by October 1, 1970, and waste treatment facilities be completed by Decem- ber 1, 1971. The company recently employed an equipment company to complete plans for waste treatment facilities. If corrective action is not taken, the matter will be referred to the Attorney General as soon as practicable. Kitchen Quip, Inc., Waterloo Because of above-normal streamflow during 1969 and the spring of 1970, the staff has been unable to obtain suf- ficient evidence for the Board to proceed with new enforce- ment action. The Board's order of June 18, 1968, was over- ruled by the Lagrange County Circuit Court. This plant will be under surveillance during low flow periods to determine if water quality standards are violated. MR. STEIN: Thank you. Are there any comments or questions? (No response.) I just have one comment that I am raising as a question. I notice Kitchen Quip has been hanging around for awhile, and I recognize the problems. I raise the question, and I think we want to work this out mostly with you people in Indiana, whether you want to go x^ith the State action or whether 180-day Federal action would be appropriate or ------- 597 Perry Miller 'whether we should proceed on both fronts with Kitchen Quip. I think we should try to remove that name from the list some- time. MR. MILLER: I would agree with you. It should be removed from the list. And if you want my comment, I would say I would be in favor of every action we can have to get this removed. MR. POOLE: It is the only case we have ever lost in court. MR. STEIN: I know. And I think in that, we might be able to help by using both. But let's think about that one. Any other comments or questions? MR. SEEBALD: May I ask what the court found to overturn your order? MR. POOLE: It was based on some pretty fuzzy technical data. And this is why, Murray, maybe the 180-day will do the trick. We were unable in sampling in 1969 to show any violation of our water quality criteria. We are just looking for 70 in lower stream flows. MR. MILLER: This is a small plating plant above Fort Wayne on the stream. And there are times when he does a fairly good job. There are other times when he doesn't do a good job. And it is difficult, really, to run him down. ------- 598 MR. STEIN: Right. Well, thank you. MR. POOLE: We might have to wait for a drought in Indiana. That's the reason maybe you can help us. MR. STEIN: You know, we can bring on droughts, too. We are going to change the procedure a little. I said we would finish all the States. But in looking at the time -- New York has a relatively short statement of about 15 minutes -- we will recess for lunch. Let's try to get back here at 1:30. We will take up the New York statement and then the mercury problem. And we will try to finish as early as possible this afternoon. MR. EAGLE: Mr. Chairman, sorry to say we will be unable to be here this afternoon, but Mr. Van Den Berg of the FWQA has worked with us on the mercury problem and can speak for Ohio and make a report for Ohio on the mercury problem. MR. STEIN: Again, I really appreciate that state- ment. You don't know how far we have come. Mr. Van Den Berg is our Federal official in Cincinnati who is in charge of the enforcement task force. And when the State of Ohio gives him the proxy to speak, I think we really have come a long way on this. ------- 599 We will recess for lunch. (Whereupon, at 12:10 o'clock p.m., the meeting recessed, to reconvene at 1:30 p.m. the same day.) ------- 600 AFTERNOON SESSION (1:40 p.m.) MR. STEIN: Let's reconvene. MR. MAYO: Mr. Chairman, during the presentation of the information on status of compliance of Federal facilities yesterday, Mr. Poole raised the question about the availability of comparable information to that which Mr. Harlow summarized for municipal and industrial installa- tions. We have distributed for each of the conferees a summary sheet by name of agency giving the comparable status of compliance information. And this should be added to the earlier report as an appendix. (See p. 132A.) MR. STEIN: Without objection, this will be done. MR. PURDY: Mr. Stein, I have a question. Does this column mean that for U. S. Army, the total of 13 installations, the enforcement conference deadline was August 1966 and that now anything to the right of that column means that the schedule has been extended? MR. STEIN: No, the schedule hasn't been extended at all. Anything to the right of that means they are in violation. MR. PURDY: O.K., but they are beyond the original conference deadline. The conference deadline for all 13 U.S. Army installations was August of 1966, is that correct? ------- 601 MR. STEIN: Mr. Garnet. MR. GAMET: That was the recommendation of the conferees that all Federal installations should be in com- pliance by August of 1966. So as you say, everything to the right of that column means they are in violation. MR. PURDY: If that would compare with the earlier charge, those that are behind schedule would be all of those under no established schedule and those in date scheduled for compliance in 1970, 1971 and 1972. MR. GAMET: That is correct. MR. POOLE: If I remember, back in 1966, out of fairness to the Federal installations, we were not consider- ing vessels at that time. MR. GAMET: I realize that, but as I stated yes- terday, I felt with the recent legislation and interest and concern about waste from vessels, it was about time we included a report on these which we considered to be Federal installations. MR. STEIN: Any other comments or questions at this time? (No response.) We will call on Mr. Seebald. MR. SEEBALD: Mr. Chairman, I would like to point out that this will be the last report of the New York State ------- 602 R. C. iMt Pleasant Department of Health as a member of this conference. The environmental health activities associated with water pollu- tion will be taken over as of 1 July by the new Department of Environmental Conservation in the State of New York. And it is assumed that a representative of that department would then sit as a conferee in future reconventions of this con- ference. And towards that purpose, I have passed out a progress report of the Department of Health on their pure water program. And in there there is an insert advising all who use it or have access to it of the creation of this new department. It contains the highlights of the accomplish- ments of the Department of Health in the water pollution field to date as of last December and points out the high- lights of the program. I do not intend this should be a part of the record necessarily. The presentation for New York will be made by Mr. Russell Mt. Pleasant, Director of Basin Development of the State Department of Health. STATEMENT OF RUSSELL C. MT. PLEASANT ASSOCIATE SANITARY ENGINEER DIVISION OF PURE WATERS NEW YORK STATE DEPARTMENT OF HEALTH ------- 603 R. C. Mt. Pleasant • MR. MT. PLEASANT: Mr. Chairman, members of the conference, ladies and gentlemen, I am Russell Mt. Pleasant, Associate Sanitary Engineer, the Division of Pure Waters, New York State Department of Health. We passed out the formal statement to be presented on behalf of New York State. All of the conferees have them. I have given the transcriber a copy. And there are a few extra copies on the front table here. MR. STEIN: You are going to summarize this, aren't you? MR. MT. PLEASANT: Yes. MR. STEIN: Without objection, the full report will appear in the record as if read. (The above-referred to report follows in its entirety.) ------- 604 LAKE ERIE ENFORCEMENT CONFERENCE PROGRESS REPORT REPORT TO THE CONFEREES Detroit, Michigan Submitted by THE NEW YORK STATE DEPARTMENT OF HEALTH HOLLIS S. INGRAHAM, M.D., COMMISSIONER ------- 605 NEW YORK STATE DEPARTMENT OF HEALTH DIVISION OF PURE WATERS Progress Report to the Conferees of the Lake Erie Federal Water Pollution Enforcement Conference June 3, 1970 Detroit, Michigan The following resume will describe the status of New York State's •water pollution control program as it effects Lake Erie water quality. As in the past, only those discharges having a significant effect directly or indirectly through Lake Erie tributaries from the Buffalo River to the New York-Pennsyl- vania state line inclusive, will be discussed. Comments will also be made regarding New York State's current program involving previous conference recommendations. Enforcement Status As of May 1, 1970, 17 of the 42 previously tabulated sources discharging into or effecting Lake Erie are considered abated, inactive or insignificant. The remaining 25 unabated polluters discharge a total of 225 MGD of wastewater. Four industries and one municipality (Section B of the Appendix) have facilities under construction which will intercept and treat 174 MGD. Eleven municipalities and four industries accounting for another 21 MGD of wastewater are in the final or preliminary design. One of these industries may be referred to the Attorney General if progress does not materially improve. Four industries and a village discharging a total of 30 MGD have been referred for legal action including Departmental penalty assessments or action by the Attorney General. Specifics relating to industrial projects are summarized in the attached appendix. Construction Grants New York State's Pure Water Enforcement and Construction Grant programs have generated $51.6 million worth of municipal construction projects for water pollution control in this portion of the Lake Erie Basin. State grants of $21.4 million are committed to these projects including pre-financing of the federal share where necessary. Similar expenditures by industries exceed $16 million for projects already completed or under construction,, This construction program is in compliance with the $400,000+ comprehensive sewage planning effort for Cattaraugus, Chautauqua and Erie Counties. Also incorporated in this construction program are phosphorus removal processes as required in New York State by the policy which was announced a year ago in Cleveland. ------- 606 Operation and Maintenance Grants Although major emphasis is currently on enforcement and construction for the elimination of water pollution, efforts are continuing to concurrently obtain maximum performance from existing facilities. As an incentive, New York State communities may receive 33 1/3% reimbursement of their audited Operation and Maintenance expenses. Eligibility requirements include resolution by the governing body to adhere to a specified time schedule for remedial action, when necessary. In the Lake Erie enforcement area as previously described, there are 37 sewage treatment plants serving a population of 181,000. 73% of these plants serving 97% of the sewered population have received Operation and Maintenance grants totaling about $1 million since 1965. This program has met with unqualified success in improving the level of plant operation and protection of water quality standards. More importantly, it has established strategic inroads with municipal officials in establishing awareness and good habits necessary for effective operation and protection of capital expenditures. Highlights Continued progress has been achieved towards meeting the objectives of the IJG and complying with the recommendations and conclusions established by the conferees of the Lake Erie Enforcement Conference. The Bethlehem Steel Corporation in the City of Lackawanna is setting the pace for pollution control. At this time, all nine (9) permits required for pollution abatement facilities have been issued for construction of works to treat approximately 126 MOD of wastes at an estimated construction cost of $10.8 million, $8 million of which is completed. These waste treatment facilities include treatment for hot and cold bar and strip and slabbing mill wastes; coke oven wastes; blast furnace and BOF including the final thickener, the cold mill and pickle liquor rinse water and deep well disposal of the concentrated waste pickle liquor. Two operation permits have been issued, one for the 45" slab mill wastewater and one for the 10" and 12" bar mills. These facilities treat up to 17. 8 MGD. The other projects are very near completion and will go into operation in 1970. The Moench Tannery, Division of Brown Shoe Corporation, located in the Village of Gowanda has completed and submitted final plans which provide for treatment to adequately reduce waste discharges to Cattaraugus Creek. This was approved April 23, 1970, and a construction permit issued. Construc- tion is now underway to be completed by June 1971. Republic Steel Company has $3. 25 million worth of projects under construction to treat 23 MGD of process wastes from the Bar Mill, Blooming Mill, Blast Furnace and BOF. Completion of construction is expected by July 1971. ------- 607 The Buffalo Dye Plant, Division of Allied Chemical Corporation, has facilities under construction to pretreat 4. 5 MGD of process wastes before discharge to Buffalo Sewer Authority System. Actual tie-in to BSA System is scheduled for January 1971. Final plans for secondary treatment at the City of Dunkirk, revised to include phosphorus removal, are scheduled for completion this month. Construction of the outfall line and interceptor sewer is already under construc- tion with overall completion by November 1971. Problem Areas Problems have besieged the municipal-industrial complexes in the Villages of Fredonia and Westfield. In Fredonia, the consultant was required to conduct pilot plant studies in order to firm up final design. The contributory industry, Red Wing Company, has not taken significant action in construction of pretreatment facilities prior to discharge into the village system. This action is long overdue and consequently the company's case was referred to the Attorney General for legal action. The requirement for pilot plant studies has caused the village to fall behind the construction start date. The joint municipal-industrial project for the Village of Westfield was not sufficiently supported with information on which to base final design. As a result, the consultant was required to conduct pilot plant studies with complete sampling and analysis to substantiate a rational design. Unfortunately, the canning season has passed and this sampling and pilot plant study was postponed until this coming September and October 1970. The village disengaged the original consultant and retained another firm which is also evaluating the industrial wastes from the three major food processing industries within the village. All four entities are committed to the same abatement schedule which is slated for initiation of construction by October 1, 1971. One of these, Welch Grape Juice Corporation, has been referred to the Attorney General's Office for legal action. Status of Conference Recommendations 1. Nutrient Removal The policy in New York State as developed and announced last year has been implemented. The City of Dunkirk is including phosphorus removal processes in final design. The Town of Hamburg Master Sewer District will also include removal units in its design. The City of Lackawanna has retained a consultant to evaluate the City's alternatives of upgrading to secondary treatment with phosphorus removal or connecting to the Hamburg Master plant. The Village of Westfield is faced with a nutrient deficient combined industrial waste. Evaluation of the relevance of phosphorus removal in this instance will be forthcoming in project design. The Villages of ------- 608 Lancaster and Depew will connect to the BSA which is designing for phosphorus removal. The Ripley Sewer District and Village of Brocton are not within^ the scope of the requirements and -will attain whatever levels of phosphorus treatment are inherent to conventional secondary treatment. There have not, as yet, been any industrial wastes identified as needing nutrient removal. 2. Deep Well Disposal This method of waste disposal remains as one of last resort which must be demonstrated to be of least effect on the total environment. To date, two permits have been issued for construction of deep wells for waste disposal; the Hooker Chemical Corporation has recently abandoned this method of waste disposal and the Bethlehem Steel Corporation has not received an operating permit and has not yet used the well. 3. Bathing Beach Surveillance This surveillance program was continued during the summer of 1969. One hundred and forty samples were bacteriologically analyzed for nine different Chautauqua County beaches. In Erie County, 308 samples were tested from seven different beaches. Extensive amounts of decomposing algae rendered two beaches in the City of Dunkirk unsuitable for bathing. Both were later reopened. In Erie County, less than 1% of the 303 samples exceeded 2400 coliforms/lOOml. Sanitary surveys and repeated sampling discounted the significance of these results. 4. Dredging A meeting is scheduled with the Corp of Engineers tentatively June 1, 1970, to discuss disposal of harbor dredgings. 5. Oil and Gas Drilling None of the prohibitive legislation introduced by various sponsors against leasing and drilling for oil and gas in New York's portion of Lake Erie was passed. However, the Commissioner of the Conservation Department has issued a two year moratorium on all activities relating to oil and gas exploration, drilling and production until the summer of 1972. To date, there have been no leasings granted. 6. Combine Storm and Sanitary Sewers No change in status. ------- 5 609 7. Prevention of Spills • A progress report through March 1970 on City of Buffalo's federal demonstration grant, "Program for Preventing and Eliminating Oil Pollution of Buffalo River" is summarized by each of four phases: River Phase - On March 10, 1970, an oil leak into the Buffalo River of about 1300 gallons was discovered and traced to the failure of an 8" underground pipeline which carries "bunker G" fuel oil from the Mobil Oil refinery to Republic Steel. The Gity of Buffalo immediately offered use of equipment derived from this grant, to Republic Steel officials and installed 250 feet of Warne boom and two oil skimmers at the site of the accumulated oil. Straw was spread on the slick that had formed and Republic Steel personnel dredged and removed an unknown mass of oil and straw from the river bottom. Attempts to remove oil remaining on the surface and retained by the boom with two skimmers were hampered when straw clogged them. An air barrier has been installed across the river surface and experiments are being conducted on configuration and nozzle sizing to provide the most efficient air current under various flow conditions. Sewer Phase - Work continued on the development of an UV oil detector and on other sensors of small quantities of oil. The former device is being calibrated and will be evaluated in the Buffalo River as a probe. Development continues of a sensor head suitable for sewer installation. Oil Sampling, Identification and Analysis Phase - Investigation of techniques and their first quantitative results for analyzing bulk water samples are continuing. Analyses of oil in various samples from the Buffalo River supports earlier evidence that the river shore is an efficient oil-sink and will continue to replenish the decreasing river pollution level as cleanup measures are placed in operation. Vapor phase chromatography, UV spectroscopy and various extraction agents are undergoing evaluation. Cost Analysis and Economic Evaluation Phase - The costs of controlling future oil pollution, as well as eliminating existing oil pollution will be determined for the Buffalo River and the associated municipal sewer system. The economic evaluation task has been postponed until the latter part of the 27 month program. 8. Elimination of Lake Front Municipal Refuse Dumps No such sites on New York State's Lake Erie Waterfront. 9. Control of Deleterious Runoff The advisory committee to the Commissioner of Health on agricultural drainage has prepared a final draft of the report entitled, ------- 610 "Guides for Controlling Contaminate Emission Released from Confinement Animal Production Farms". Non-point discharges from cattle or other livestock feeding or confinement areas are considerated as subject to provisions of existing Water Pollution Control Law. In this enforcement area, there have been no sizable such operations identified. The Research and Development Unit of the Department is conducting a detailed pilot demonstration study of small lake basins ineastern New York State. The purpose of the study is to gain a better understanding of the eutrophication process in order that an effective control program can be carried out on a statewide basis. Basic data on the physical, hydrological, chemical and biological characteristics of the lake has been obtained. This provided the basis for formulation of a detailed plan of research from which to evaluate the need for and value of engineering control mechanisms such as advanced waste treatment, improved individual summer home disposal methods, changed agricultural practices, diversion of land run-off or waste, etc.» Completion of this phase is expected in 1970. Once the necessary control measures are defined, the final phase of full scale demonstration of the engineering control measures found necessary will be performed to determine costs and effectiveness. This phase will be conducted during 1971 and 1972. 10. Industrial Effluent Sampling Programs Industries discharging into or affecting water quality in Lake Erie routinely sample wastes, maintain records and report periodically to the New York State Health Department. Industries which are required to monitor these effluents as part of an active operating permit are: Eastern Tanners Glue Co. The Borden Company Bethlehem Steel Nuclear Fuels Services Penn Central Railroad Allegany Ludlum Steel Gowanda (V) Arcade (V) Lackawanna (C) Ashford (T) West Seneca (T) Dunkirk (C) Gattaraugus Go. Wyoming Co. Erie Co. Gattaraugus Go. Erie Go. Ghautauqua Go. Construction permits have been issued to the Penn Central Railroad in the City of Buffalo and the Moench Tannery in Gowanda. These industries will be required to maintain effluent sampling programs when construction is completed. Testing and measuring is also carried on by the following industries included in the waste outlet registration program: Allied Chemical Donner Hanna Socony Mobil Oil Buffalo (C) Buffalo (C) Buffalo (C) Erie Co. Erie Co. Erie Co. ------- 611 Republic Steel Buffalo (G) Erie Go. Niagara Mohawk Dunkirk (C) Erie Go. These data are being reported to Albany on an annual summary- basis for compilation and evaluation with respect to permit renewals and effects of waste on water quality. 11. Water Quality Surveillance Network New York State has established a water quality surveillance network consisting of 116 sampling stations including 12 automatic monitors. Included in the Lake Erie Enforcement Conference area are manual sampling stations on the Buffalo River, 1. 6 miles upstream from the mouth, on Buffalo Greek at the USGS gauging station in Gardenville approximately 10. 4 miles upstream from its mouth, on Gattaraugus Creek at the Aldridge Street Bridge in Gowanda approximately 16.7 miles from Lake Erie, and in Buttermilk Greek at Thomas Corners Road Bridge about 0.2 miles upstream from the junction with Gattaraugus Creek. In addition an automatic monitor station has been placed in operation on Bird Island in Buffalo to continuously sample the Niagara River and Black Rock Canal. 12. Regional Planning Gounty-wide comprehensive sewage study have been completed for Erie, Ghautauqua and Gattaraugus Counties. These studies initially were responsible for some delay in achieving compliance with abatement schedules. However this has been overcome and implementation is moving at a brisk rate. Requirements for compliance with comprehensive plan for construction grants eligibility have been successful in securing cooperation between neighboring communities. Summary In summary, treatment facilities are under construction to effectively treat over 75% of New York State's unabated wastewater discharges. Another 10% by volume are under preliminary or final design and the remaining 15% have been referred for Departmental penalty assessments and legal action by the Attorney General's Office. A supplementary statement regarding the mercury problem in Lake Erie as it effects New York State is attached. THIS CONCLUDES NEW YORK STATE'S PRESENTATION ------- Lake Erie Enforcement Conference 612 Progress Report June 3, 1970 Detroit, Michigan Supplemental Statement on Mercury in Lake Erie Surface water supplies, wastewater outfalls, bottom sediments, and fish in Lake Erie were sampled and analyzed for mercury concentrations. Manufacturers, distributors and users of mercury and mercury compounds were inventoried. This investigation has been coordinated with FWQA. Asa result of this investigation, it was determined that the only industrial plant discharging mercury into the waters of Lake Erie was the Buffalo Dye Works Division of Allied Chemical Company in Buffalo. There is no evidence that this discharge effects mercury levels in Lake Erie water or fish samples due to its proximity to the Niagara River out flow. However, on May 8, 1970, the company was directed to reduce the wastewater discharge of mercury by our Buffalo Regional Office. The company's response was to completely suspend the mercury using process. (Mercury is used in this instance as an intermediate in the production of dyes.) It was estimated that the company was using about 4 pounds/day of mercury before suspending the operation. On May 15, the company was directed to submit a plan by May 25, 1970, for elimination of the mercury discharge. This plan has been received and is being evaluated. In the meanwhile, operation of the mercury using process remains suspended. ------- 613 CO 5 CO II 4-> n) -O 4) •1J n) .0 ni TO D 13 +J m T3 0> % A 0> -tJ Rj •o V w M W w KM 5 i co STATU H ?H W 3 r- rH r-T tt s 4> 00 nt u CO si TD +•> ni ^ n! 4) •-> y 0) D O G 0 Taken Action 1? 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O ^. t-i 0 o to ca CO -M u 'f^ .J CO 'O cu •"-• o MH CU T3 O CO P w & n H ^ O O P o S R O '•-> cd u o A 13 C a v a (0 £ 0) (J CO O CO co O h o in O 3 ffi Q o U ISO g c "tj CO cu CO CO cu o 6 A! Dunkir 1—4 rd u Chemi< 1—4 Genera CO (—4 cd u a cu J3 U 0 i — i id MH >H 3 S. o U i— * hemica U Allied • U Buffalo ,M 1 0 S cd V4 CO M cd rH S5 • U X Dunkir CO TD O O h J2 U •4-J a •o i-H O • > i— l i-H Blasde ^ ~ cu f-t O Silver o U '> CO cu »4 . PH > >! X CU CU (U CU SH FH U U Silver Silver CM id -------An error occurred while trying to OCR this image. ------- B 00 • Preliminary Desi M O ,_, td £H h rs have Initiated V ^J rH 0 FU cu +^ m CO ^ o Add'l Action Required To be included in Town Action Taken on Required +j u H ft o c vi rt Implementation of a Retained Hill & Hi k^ Liminary plans bj V Pn ro O abatement schedule. 0 «» Engineering Inc. t itnplement schedu i i £ c § .2 f— t 4-» 30, 1970; final p 0; start construe :>. r- (0 "^ § 2 , o 0 fc 4-> CO 71; complete com - 12/31/71. "> c A (M £ Proceed with final V f-< a Contracted with P o" r~ t construction 3/ £H ifl w •<• 1— 1 rJ design and construction. 4-> C Waters Authority; authorized consult G plete constructio d rj M ^"" u ^o 616 •o to conduct require pilot plant studies 0) TD O CO CD b. W 3 £ n) ,5 O WOO O * u ? w C. 3 a* c 3 o •»-> u 3 O ns h J2 cq U # o O U rt C c ^, ffiB o .—1 03 C % O 3 Q PQ ner u 'i* CO 3 CD co ti D 0) i—i t—< pf^ p^\ * o >° ""•"* (13 .2 g. C 3 o m T3 -M 4) 3 H ^ ^ O g o U nt v ffi 0) 4-> rt 4-^ CO ------- W W W 3 en P H r— 4 oo ^~- i-4 CO CO R R O rt •- ^g (fl H-1 R co •~* R O 0 ° r- R .^r -6o ~~- CO a 0> to Buffalo Sewer Sysl ro ^ •^^ o R O -»-> y L const n! R Incorporated in Erie .1. --» M O CO ^4 •>> •4- • f-l r— 4 tf-4 y nl M tewate CO n! =#= 4_> County Sewer Distric o r- t—4 co .—4 CO a 1—4 1—4 n! R o t—4 ies Implementation o: ns abatement schedu r—4 ^ • . IT) R O tructi n cons CO ,0 00 f— 4 o f— 4 R o .f-4 y L const nt .5 .r-4 Wastewater and facil ^ rt CO 4-> 1>% 1-4 m T3 R o y CO CO "5 o ni ^-4 (X 1—4 n R f.-4 MS 1— 1 l> 1— 4 r— 4 4-J h 0 D4 (U fH V4 0 R .^4 +•} fO m o ncorp ns men R o .r^ 4-> y pj FH ^ CO R O U R 'So CD ja f— 4 r- 1-4 00 i—4 CO -4-> y .-4 ^4 -4-J CO 60 R •+-* CO 1 i y 3 CO 3/1/72; complete con tion 5/1/73. jH J R m ^ 4^ • f* , Q co" Verno -H* P P O o * co O 0 CM Connect to Hamburg Sewer District burg)(T) ABOVE (Ham W W CO o co o Connect to Hamburg Sewer District P "oio 1 ABOVE (Ham W W CO o N O ring consul- Implement compre- 4> G •n-l 60 fj t. compre- ementation of a i— i o CO R* CIS U 1 CO R co "y SL.2 (U M 'P W # > CO ifl y nl .-1 y .—4 h CO • f-4 P CO co P CO — •s? .ij P s § ^ E * •«-> y CO • f-4 P w ^ R H o —• R W) CO p ^1 S K O nl R R H ° 5u •^ CO y .S ft) >W J W a a o U nl CD K V •<-> nl <-> CO 0) 13 ------- to l-l 8 to M 3 co H CO O M H O U Add'l Action Required ng Implementation of •M Action Taken Disengaged consul -a c nj ±3 fc O -o (^ V ^ .f~( & A) PH C O »-< 4-> U < cu »H t» J-l (4 C 6 •—1 r— < V ^ A C op 0 a S CO 0> o in lined abatement schedule. nd ™ <« engineer. Have re Harnish & Lookup r-4 h * 1 .s <H C! CO .. C £ rfl f~ i-H ^^ Du "^ w ^ P ••a H-i H C3 (1? 1) s a .S -& 'oo C g tl ^ 0) '£ 9 established a tente abatement schedul .„ •^ ^! fH t^ <3> ra o • « t— 1 t— < f- C -^ o m -r; C o > E CO • C 2 S 0 a o R o •^ o 3 Vl 4-^ CO C O U 0) J * d) • r-5 N a t- S^ o ^. u o Implementation of •s abatement schedule. w CO Harnish & Lookup Consulting Engine -o £" c C n) ir> -M -* S- JX C 0) (fl h •-< &< ^ a3 n) S .S 'C 5 « c i— < (0 2 fi S 0 Ci u (U abatement schedu] as Village. £ O •"^ +J U 3 b 4-> CO c 0 U 5 CD • ^! (M ft t>- a^ O -~- o o Implementation of Harnish & Lookup T3 R m •M h 0 ft V h t>, H ft) R 1 p— < 0) FH A •s abatement schedule. M 0) Consulting Engine • 0 ^H t— m i— F-< c rt r— 1 ft 00 .s 'tH 0) 0) c 'oo c i-i n! co -- r— t ^T ^ C. -^ 2 o •-1 ^H xO C CO .2 rt « -2 3 a h •M •-J 05 C C K O HH U 0) abatement schedul as Village. c o •«-* u 3 ^ --> CO C O U u ~ «2 h V 4) «-< T3 •—4 C O • ~4 CO CD 1 a o O CO V •o a ------- KE ERIE Action Lega TD V CT 0) C 0 u Comply with abatemem schedule. 1 Action Taken Referred for depart mental penalty assessment pro- ceedings under Section 1250, PHL. Village informed company they will 0) 03 3 o -4-J TD 0) £ 0 I-H (— 1 rt 0> ,n 4-> O rt village system. W § CO. W 3 CO SAME AS ABOVE CO ? P £ H 4) H(y H (tf 4J CO i H £ "g ^ 0 " w -° -g S g f W rt » H J3 rt < » s « fc 2 ^. i) ^ << +J y 55 S ^ 0) ^ 0) -4-> CO rovide wa fin 0 "o t— i n. H ^ P ^ J 5 Q J co O O (M eatment. ^ 'S c \|i Tj •(-> C « •-« o 0) ^ •S • •t «> ?• 4-> O pretrea General. action; presently o o vO t>^ X! discharge into Village system; CD 00 rt 'O Article 78 procee also to challenge ~ i 03 validity of Gommj sioner's Orders. 619 00 ^ o •u (H O rt (U ffi +J A CO SH 4) -O P * ------- 620 BS W W W 5 co P H <; H CO H fc W S w H o I— I H O O Pi 3 cr< 4) C o '•-> u !> o r-J rH O h ^ V c h o Action Taken Referred to Att 13 C ft) U O 17-1 w 0) J. M '3 cr I) P5 C O '•<-» y < ft cu h t>, h rt C a ••-i ^-i 0) M Pn t-l a -\|-> CO AT 1> ^^ in 1—4 •sO CO C n) i — i ft 'a c M-( 1 0 Harnish and Lo (—1 c~- ^^ .^^ o w—i c o 4-1 o P h -M CO C O O CQ Lneer Consulting Engi C o .i-t 4-> O rj •H 4-J CO PJ 0 y CD .!_> v i-H ft a o u cu a o CO independently. 01 t^ 1—4 O rt u o c a v a rd * V o «J cu cu n o • t-4 CO CO a a o O CO M V cj r-l ~~------- 621~~ ------- 622 R. C. Mt. Pleasant MR. MT. PLEASANT: The purpose of the report is to describe the status of New York State's water pollution control program and also the progress made on the Enforce- ment Conference recommendations. As in the past, the report addresses itself to the wastewater discharges in the Lake Erie portion of New York State from the Buffalo River to the southern New York State-Pennsylvania State line. The enforcement status: 17 of the 42 previously identified wastewater sources have been abated or have become inactive or are now considered insignificant. The remaining 25 unabated wastewater dischargers account for a total of 225 MGD of municipal or industrial wastewaters. Pour industries and one municipality out of this 25 have projects under construction which will intercept and treat about 174 MGD of this wastewater. Four industries and 11 municipalities accounting for another 21 million gallons of wastewaters have projects in final or preliminary design. Four industries and one municipality accounting for another 30 MGD of waste have been referred for legal action including penalty assessments and Attorney General action. The specifics relating to the individual dates of the abatement schedules and action taken and action pending are included in the appendix attached to this report. With respect to construction grants, New York ------- 623 R. C. Mt. Pleasant •State's Pure Water Enforcement and Construction Grants Program has generated a $51.6 million worth of construction projects in this area for water pollution control. State grants to these projects amount to $21.4 million including prefinancing of Federal shares when necessary. This construction is in compliance with the $400,000 comprehensive planning effort which is now completed for Erie, Cattaraugus and Chautauqua Counties. This construction program is also incorporating the phosphorus removal requirements in New York State as described a year ago in Cleveland. With respect to operation and maintenance grants, although major emphasis is currently on enforcement and con- struction, efforts are continuing to concurrently obtain the maximum performance from existing facilities. As an incentive, New York State communities may receive one-third reimbursement of audited operation and maintenance expenses. And in this enforcement conference area, 37i sewage treatment plants currently serve an estimated 181,000 people. Seventy-three percent of these plants serving 97 percent of this population have received about $1 million in O&M grants since 1965. This indicates that these plants do treat with- in the design capability of the existing facilities and have committed themselves to an abatement schedule acceptable ------- 624 R. C. Mt. Pleasant to the department. Unqualified success in improving the level of plant operation and protection of water quality standards has resulted from this program. But more importantly, it has set the stage in establishing awareness and good habits essential for effective operation and protection of the capital expenditures underway. In the area of highlights, I would like to just briefly run over the construction aspects of the waste sources in this enforcement area. At Bethlehem Steel in Lackawanna, all 9 permits required for the construction of essential pollution control facilities have been issued by the Department of Health. Two operational permits have been issued, one for the 45-inch slab mill and one for the 10- and 12-inch bar mills, which will handle 17.8 MGD. These units are in operation. The total construction program for Bethlehem is estimated at $10.8 million of which $8 million worth of projects are completed. Completion of all projects is expected by June 1971. Republic Steel has $3.25 million worth of water pollution control projects under construction which will treat 23 MGD of process waste from the bar mill blast furnace and basic operation general furnace. Completion of ------- 625 R. C. Mt. Pleasant construction at Republic Steel is expected by July 1971. The Moench Tannery, Division of Brown Shoe, at Gowanda, New York, has completed and submitted final plans which provide for treatment to adequately reduce its waste discharges to Cattaraugus Creek prior to discharge into Lake Erie. Construction is now under way to be completed by June 1971. The Buffalo Dye plant on the Buffalo River has facilities under construction to pretreat 4.5 MGD of waste prior to discharge to the Buffalo Sewer Authority System. Actual tie-in to the Buffalo Sewer Authority is scheduled by January 1971. Finally, the City of Dunkirk is revising its final plans to include phosphorus removal which should be com- pleted this month. Construction of the outfall line and the interceptor sewer is already under construction with overall completion by November 1971. We have a couple of problem areas, just to briefly go over, mainly at joint municipal and industrial waste com- plexes. In Fredonia in Chautauqua County, pilot plant studies were required by the department to firm up final design. The major contributory industry in the village has not taken action to construct required pretreatment facili- ties and, consequently, has been referred to the Attorney ------- 626 R. C. Mt. Pleasant General's office for legal action. MR. STEIN: What kind of company is that? MR. MT. PLEASANT: That is the Red Wing Company. MR. STEIN: What do they do? MR. MT. PLEASANT: They make canning products, tomatoes. MR. STEIN: It is a cannery? MR. MT. PLEASANT: Yes. MR. STEIN: Thank you. MR. MT. PLEASANT: Requirement for pilot plant work on the Fredonia project has caused the village to fall behind on construction start date. In the Village of Westfield, a similar problem is encountered where the consultant was also required to con- duct pilot plant studies to verify waste characteristics and treatability. These studies will be performed during the upcoming canning season during September and October of this year. The original consultant was disengaged and another firm which is also evaluating industrial wastes from the three major processing industries within the village was retained. All four entities are committed to the same abate- ment schedule with start of construction by November 1971. One of the major industries, Welch Grape Juice, has ------- 627 R. C. Mt. Pleasant been referred to the Attorney General for legal action because of inconsequential action taken on its requirements. With respect to the conference recommendations, I will just skip through a couple of these. With respect to the nutrient removal policy, the policy that was described last year is being implemented. Municipal officials have been contacted by the health department and the policy described and their responsibilities included. At this time, the City of Dunkirk, the Town of Hamburg master plan and the City of Lackawanna are being required to provide for phosphorus removal facilities. The Villages of Lancaster and Depew in Erie County will be connecting to the Buffalo Sewer Authority which is also designing for phosphorus removal. So far, no industries have been identified as needing phosphorus removal. With respect to deep well disposal, this alterna- tive remains as a method of last resort which has to be demonstrated to have the least effect on the total environ- ment. To date, in New York State, two construction permits have been issued, one to Hooker Chemical Corporation which is not in this particular area. This company has abandoned this method of disposal in favor of reclamation of the hydrochloric acid. Bethlehem Steel Company has received the other ------- 628 R. C. Mt. Pleasant construction permit. That well has been constructed, is not operating, and so far has not received an operating permit. We anticipate that before any operating permit is issued, if it is issued, it will be preceded by a public hearing. With respect to bathing beach surveillance in Erie and Chautauqua Counties, nine Chautauqua County beaches were surveilled and seven Erie County beaches. None of these beaches were closed because of coliform results. There are two beaches in the City of Dunkirk that were closed because of decomposing algae, but were later reopened after clean-up. I think before completing, I would like to include the statement on the mercury problem in Lake Erie as it affects New York State. This is a short one. Surface water supplies, wastewater outfalls, bottom sediments, and fish in Lake Erie were sampled and analyzed for mercury concentrations. Manufacturers, distributors and users of mercury and mercury compounds were inventoried. This investigation has been coordinated with FWQA. As a result of this investigation, it was deter- mined that the only industrial plant discharging mercury into the waters of Lake Erie was the Buffalo Dye Works Division of Allied Chemical Company in Buffalo. There is no evidence that this discharge affects mercury levels in Lake Erie water or fish samples due to its proximity to the ------- 629 R. C. Mt. Pleasant .Niagara River outflow. However, on May 8, 1970, the company was directed to reduce this wastewater discharge of mercury by our Buffalo Regional Office. The company's response was to completely suspend the mercury-using process. In this instance, mercury is used as an intermediate in the production of dyes. It was estimated that the company was using about 4 pounds per day of mercury before suspending the operation. On May 15, the company was directed to submit a plan by May 25, 1970, for elimination of the mercury discharge. This plan has been received and is being evaluated. In the meanwhile, operation of the mercury-using process remains suspended. That concludes this part of the presentation. MR. STEIN: Thank you. Are there any comments? MR. MAYO: I notice the report didn't make any mention of the Mobil Oil refining problem. MR. MT. PLEASANT: I will identify the wastewater sources that have been referred to the Attorney General for penalty proceedings. This is in Section D of the appendix. You are right, it isn't in the narrative. North Collins Village in Erie County and Producers and Canners Cooperative in North Collins Village have been referred to departmental penalty proceedings under the ------- 630 R. C. Mt. Pleasant public health law. Socony Mobil Oil in Buffalo City has been referred to the Attorney General for legal action. Red Wing Company in Chautauqua County and Fredonia has also been referred to the Attorney General for legal action. They are also challenging the validity of the Commissioner's order under an Article 78 proceeding. MR. STEIN: What is the Mobil Oil problem? The reason I am asking the question is just from looking at the gallons per day discharge, they are by far the biggest non- compliance. Are they objecting to the authority? MR. MT. PLEASANT: No. MR. STEIN: What is the problem? MR. MT. PLEASANT: Delay and non-compliance with the schedule just generally. Specifically, perhaps Mr. Seebald could elaborate. MR. SEEBALD: They have high phenol in the oil and run antiquated oil removal apparatus. And they have failed to either renovate their existing equipment or provide us up until last week with a report on their intentions. We received this just late last week, but we will probably not take any direct action in response to this pending some advice from counsel inasmuch as it is in litigation right now. ------- 631 R. C. Mt. Pleasant MR. STEIN: I can understand that. Any other comments or questions? MR. SEEBALD: I would like to add just for the record that three pieces of legislation in New York State significant with respect to water pollution were passed by the legislature at the past session. One gives the depart- ment the authority to control the storage and transportation of hazardous liquids. The second provides for an aid program to assist in the construction of lateral sewers in small communities. A third involves raising the penalties for water pollution events from $500 to $2,500 in the first instance, and for a continuing discharge, a daily penalty raise from $100 to $500 per day. In addition, I would like to emphasize that the problem in the municipal slippage as indicated in our tabu- lation is centered around the fact that implementation of the metropolitan plan provided for in the comprehensive study has been hampered by the lack of an effective umbrella agency for this type of implementation in Erie County and has not been due to any real foot dragging on the part of the communities themselves. They have been willing to amal- gamate, but there has been no incentive at the top level. And actually the effectiveness that has been instant to ------- 632 R. C. Mt. Pleasant date has been through the State requiring a combined approach to sewage and sewage treatment using the eligibility for grant assistance with Federal Government support hinging upon the requirement that they comply with the comprehensive study acceptable to the Commissioner. And it is to be hoped that the Federal Water Quality Administration will continue to support this comprehensive study to allow us to persuade these communities to join together. I noted this morning it was brought up by Mr. Remus. It is one of his fond hopes that the Federal Government will continue to support this comprehensive approach to sewage treatment and not permit a GTA loan policy supplied with Federal or local assistance. MR. STEIN: Are there any comments or questions? MR. POOLE: May I ask one? What about the local sewer program? How much fund- ing was provided for that? MR. SEEBALD: It has been a mystery. It was a $10 million appropriation. The first payments will not be made until next fiscal year, March 31, 1971. By that time, we hope to nail down just the exact amount of funding. This last legislature adjourned in rather hurried fashion and left quite a bit of this legislation pending, including of most significance, of course, the funding of ------- 633 R. C. Mt. Pleasant * the various programs. MR. POOLE: What percentage of the costs can you take? MR. SEEBALD: It is based upon an upset figure of $150 per household connection, the State picking up the remainder up to the cost of the actual connection. This is based on a sliding scale with the base determined by the number of connections and the total cost of the project. As the number of connections increase, the actual per connec- tion support will decrease. MR. POOLE: Thank you. MR. STEIN: Are there any other questions or com- ments? (No response.) If not, thank you very much. I think that concludes the State presentations. Before we go into the consideration of mercury, do any of the States have anything for us to consider? MR. PURDY: Only one suggestion, Mr. Stein. And this is to expand your request to have a joint Federal- State review of the Ford Motor Company project. I would like to expand that to have a joint Federal-State on-site review of all of those projects that are listed in your report as being behind schedule so that there will be a complete under- ------- 634 standing on both sides here. MR. STEIN: Will that be agreeable? If I understand the suggestion — and I might say I think this is good — if we have projects which are listed as behind schedule in our report, we should be able to get together with the State concerned and hopefully the industry and come up with a statement on that project which is agreed to, factual statement which is agreed to. That State, the Federal Government and hopefully the industry ought to give a substantial description of what the situation is. This will be based on inspection where you think it appropriate and not just representation. MR. PURDY: That's right. Where facilities are under construction and so forth, this will be an on-site inspection. MR. STEIN: I visualize this to be somewhat like the reports we got of the 180-day notice reports where we signed off that everyone was in agreement that this was what the situation is. And in all those cases, by the way, I think we all are in agreement that the program is proceeding and no further action is necessary, MR. PURDY: I hope we can reach that conclusion. MR. STEINr, Well, I don't know, but I think the only possible way you can reach that is for everyone to ------- -635 agree on the facts. MR. PURDY: Right. MR. STEIN: And this is what I think Mr. Purdy is proposing. Will we be able to do that with them? MR. MAYO: As far as the regional facilities are concerned, it is going to be a very substantial work load. We would have to sit down and from the Regional Office establish point and make some evaluation of what it would require in the way of manpower and resources to conduct what may be a hundred or more inspections. MR. STEIN: Well, let me make this offer to you: We will supply the people to you from our national resources to do that because I think this is essential. Otherwise, we are just going to come here and in the absence of an inspec- tion and an agreed-upon report, we are going to necessarily get disparities. And we are at the stage of the case where I think we have to get down to the hard facts. By the way, let me tell you when this was done in Ohio, there was complete agreement as far as I know with the city, the industries, the State and the Federal Government, on the facts of the five cases involved. And as far as I can see, there is no factual problem or difference now. We have the same situation involving that Eagle Petrol case. And I think this is just one activity that we ------- 636 are going to have to engage in if we are going to deal with compliance or alleged violations to determine whether further action is necessary or not. And I don't see if you are ever considering modifying or overlooking the compliance how you could ever make the recommendation without having this. I myself can't see how we possibly can move ahead. MR. POOLE: I would like to put in a bid to have that done for the Indiana projects also, Mr. Chairman. MR. STEIN: Is this agreeable? MR. LYON: Do I understand this correctly, Mr. Chairman, you are planning to go over every project that is behind schedule? MR. STEIN: That is alleged to be behind schedule so we have an agreed-upon factual statement with the industry if we can get it, but certainly with the State and Federal Government. MR. LYON: They will be done at these regional conferences? MR. STEIN: No, we will send our men out with you and make arrangements to do it. Because in a lot of cases, you are going to sit down in the office. And as you and I well know, you can talk and talk, but you have to go out and look before you are going to decide what the situation is, MR. LYON: Well, let me just try to clarify this. ------- 637 Are you saying that you are going to physically visit every single sewerage source and every single industrial waste source that is in fact behind the original schedule that was set up originally? MR. STEIN: No. What I am saying is where you could not come to an agreement by sitting in the office or where there is a doubt, then you have to go out and look. Obviously, you are not going to spend time, I would hope, where everyone is in agreement or you feel there is no doubt. MR. LYON: I misunderstood. MR. MAYO: Then, I misunderstood also, Mr. Chairman. Under those circumstances, I think we can work within our existing resource. MR. HARLOW: I think we ought to recognize, Mr. Chairman, though, probably over half the cities and indus- tries involved here are in Ohio. And Ohio is not here to speak for this. MR. STEIN: We will offer this. Now, my guess with Ohio is that Ohio will partici- pate as you could tell with their approach here today. They have participated with us in the past. And as a matter of fact, maybe we should take our hat off; because before, when Mr. Purdy suggested that we come to this stage with these Ohio communities, they made a request that someone from the ------- 638 Federal Government attend their monthly meetings -- each one -"- so as these came upr we and they could proceed on the same set of assumptions on the facts. If there were any differences Ln the facts, we could go out and investigate them and see what the truth of the matter was. I have no doubt that Ohio is going to push this. I think in the absence of this, as they say back at home, it is going to be more work for mother. This is the fastest way of doing it. Unless we can get agreement and complete agreement between the State and the Federal Government on the facts at this stage of the operation, we may embark on procedures which can be very time-consuming and have really drastic legal consequences. So I think we have to keep that in mind and move. And hopefully, the industries and the cities will join us in that. Because I think this is to everyone's benefit. MR. LYON: My confusion arises, and I think we have already spent a lot of time — almost two days here -- in this thing, is this something that is going to happen before these regional meetings or is this joint Federal- State review? Will this happen, for example, in Pennsylvania? When you come to Erie, are we going to look at the facts and — MR. STEIN: No, no. ------- 639 MR. LYON: May I finish this point? Am I correct that we are going to then look at the record, and if we agree, that is fine. And if we don't agree, then we are going to go out in the field and look at it? MR. STEIN: Right. MR. LYON: But the Erie meeting will be the time when we carefully review each case? MR. STEIN: When we see what we have to do. Now, the Erie meeting also, as I understand it, has another aspect. At the Erie meeting, we will want to hear from the industry and the people and other jobs to see what information they have. They may raise some points which may require investigation before we can lay those to rest and settle them. MR. LYON: My only concern is that we try to as efficiently as we can get together on information. We find that we are spending so much of our time giving information to the Federal Government and going to meetings that we don't have much time left to clean up the pollution. So my only suggestion is let's please make this process official so we don't have to write 10 more letters and write five more reports and go to five more meetings. If we can clean this up at the Erie meetings and if there are any differences, fine, we will go out and look at the facts. ------- 640 We feel the Federal Government should have all the facts and should take enforcement action when it is needed. But let's try to somehow streamline this process. We feel very frustrated by the many Federal reports we have to sub- mit. And frankly, we just don't have the man-hours. We think our time should be spent cleaning out pollution. MR. HARLOW: Since it looks like my office may be doing some of this work, I want to make sure I understand what it is you are asking for. Now, if you are talking about putting together, like you said before, some kind of statement regarding what we did on the 180-day notices, I think you are talking about a major undertaking. But if you are talking about just sitting down in the State offices and going over city by city, industry by industry, those that are behind and coming to an agreement on what the status is, my first reaction is that this, we already have. MR. LYON: That's right. We just did that. We just sat down. MR. HARLOW: We have been doing that the last three or four weeks. MR. STEIN: I am not sure you are in complete agree- ment, and I am not sure you have checked these facts out on the basis of an inspection. ------- 641 MR. LYON: Mr. Chairman, they change almost from day to day. So you will undoubtedly find that the facts in some of these cases will have been changed by next week, some for the better, some for the worse. MR. STEIN: No one is arguing about those changes. We are talking about apparent differences in Federal, State and industry reports when they come in at the same time. Now, I thoroughly agree with what this is going to say, but one of the reasons, I think, is not because it is a Federal or State report or a meeting. I think if we are going to sit around on our bureaucratic rear ends, I fear we are going to get enmeshed in operations. And if it takes us this long to get a simple inspection and recording system off, I understand why it takes so long. I don't look for this to be an involved operation. MR. LYON: Yes, but the problem is, Murray, we were just asked by your Charlottesville office for the same information about two months ago. And it is taking us literally thousands of man-hours to put all of this informa- tion together. We separately gave it to Mr. Harlow. We also have to submit it separately as part of the comprehen- sive planning process. And frankly, I am not going to keep any more people in the office to do clerical work. We simply have ------- 642 got to get out into the field and check on polluters. Last year, Pennsylvania lost 6,000 inspections because we were kept in the office doing clerical work, fil- ling out Federal reports. And we simply can't do any more. MR. STEIN: I think maybe I misunderstood Mr. Purdy, but if you think this involves clerical work, I think we missed the point. MR, LYON: If it doesn't, we have got no problem. MR. POOLE: Mr. Chairman, may I get in? As you well know, we did some of this with both Illinois and Indiana industries in the south end of Lake Michigan. And it was a special project, Walt. But it was done in a very short period of time — in this case, I think a matter of about two and one-half weeks. And my judgment is that it had a very healthy effect on a portion, at least, of the people that we looked at in those inspections. Like Pennsylvania, I don't want to get involved in a lot more paper shuffling and report writing and office work. But what I visualized as Purdy and the chairman started discussing this is that I would like for somebody to come down to the office and we will go over our list and then jointly go into the field and sort of put it up to them, whether it be a city or an industry, that we have come here to look things over to make up our mind whether or not ------- 643 the 180-day notice ought to be filed against them. And I think that that kind of a visit will shake some of these places off of dead center whereas if I go back to Indianapolis in the morning and say, "I have been up to Detroit two days, and you are behind schedule, and people are getting awfully impatient about this and you better get on the ball," they will pay a lot more attention to the joint inspection than they will to that communication from me. So I would not like to reserve the Indiana work only to either industries or cities where there is a difference of opinion between my office and Mr. Mayo's office or Harlow's office as to the rate of progress. I think it is workable. I don't think it will take too much time. And if you want to know what I actually think about it from the standpoint of pollution abatement, I think it will do a hell of a lot more good than sitting here at this table talking about it for the last two days. MR. STEIN: I agree with you. May I make just one more comment as an example here? Going to a major United States steel company — and I was there with George — we went there on one of these visits, and we looked at the effluent,coming out of their operation. And they had a pretty extensive operation. The ------- 644 air looked like about the color of this cigar, maybe a little lighter. And they bragged in the office. I said, "Let's see the effluent line." I said, "Do you mean this is what you are putting out?" And they indicated some days it is better, some days it is worse» I said, "Well, you know, this is a great thing. What would you have done today if I came down with the League of Women Voters and they saw this effluent?" Well, we had a little polite conversation. Then the companies were served with 180-day notices. When George Harlow went back there the next week, do you know what the color of that effluent was? The color of this water. And it was the same facility. I agree with Mr. Poole, if we can get that kind of improvement with just a little visit like that, it does a lot more good when you give this individual attention and spotlight the facts than by almost any other method. The reason I say that is I think we are at this stage of the game. In these earlier planning stages dealing with preliminary reports, this wouldn't be effective. But at the stage of compliance and enforcement we are at now, I think this can be the most effective method and ------- 645 L. A. Van Den Berg produce the most rapid results. MR. LYON: No objection at all to that as long as we don't get a letter from George Harlow asking us to once more update all our cases. I would be happy to review every one of them at the yearly meeting and cooperate with you. MR. MAYO: Mr. Chairman, the Regional Office will accept the responsibility for putting together a schedule. And we will be in touch with you. MR. STEIN: All right, is there anything else before we go on to mercury? (No response.) Let's go on, then. Mr. Mayo. MR. MAYO: Yes. The presentation of the mercury report for the Federal Water Quality. Administration will be given by Mr. Lowell Van Den Berg, Assistant to the Director of the National Field Investigating Center of FWQA, Cincinnati, Ohio. I understand that a Mr. Beebe of the Food and Drug Administration may be available here this afternoon. Is he in the audience? ------- 646 L. A. Van Den Berg STATEMENT OF LOWELL A. VAN DEN BERG ASSISTANT TO THE DIRECTOR NATIONAL FIELD INVESTIGATIONS CENTER FEDERAL WATER QUALITY ADMINISTRATION CINCINNATI, OHIO MR. VAN DEN BERG: Mr. Chairman, I have additional information since this report was compiled. I took the liberty last night of incorporating that data in this one revised copy. So I will update the report and send you a copy for inclusion in the record. MR. STEIN: Yes, go ahead. MR. VAN DEN BERG: This report was compiled by personnel from the Great Lakes Regional Office, Lake Huron Basin Office and Lake Erie Basin Office, in cooperation with personnel of the National Field Investigations Center. The introduction starts on page 8. The toxic effects of mercury and its compounds in the water environment are well known and are documented in the literature. However, much remains to be learned on toxicity limits of the various mercurial compounds in the water environment. The upper limit of mercury in food, used by the Food and Drug Administration, is 0.5 ppm wet weight. Limits have also been set for atmospheric concentra- ------- 647 L. A. Van Den Berg tions and numerous cases of poisoning have been reported. Critical pollution from mercury became apparent on March 24, 1970, in the Great Lakes. Mercury concentrations as high as 500 parts per billion (or 5 ppm) were reported in some of the pickerel shipments from Canada and commercial fishing involved was suspended by Canada, then Ohio, Michigan and New York. The presence of mercury in fish and bottom sediments in the St. Clair River-Lake Erie system has con- firmed the existence of an environmental problem of major scope. Mercury is discharged to the water environment from industrial processes and uses of mercurial products. In 1968, mercury produced from mining in the United States was 2,194,000 pounds. The total amount used in 1968, how- ever, was 5,732,000 pounds. Over 163 million pounds of mercury have been consumed in the United States in the pre- sent century, but little information is available on the final disposition of it and amounts accumulated in the environment. Metallic mercury and mercurial compounds in liquid wastes are characterized by their high densities. Free mercury and the mercurous compounds form sludges and settle to the bottom of receiving waters. The mercuric compounds form precipitates with oxides, phosphates, sulfides and ------- 648 L. A. Van Den Berg carbonates. The high density is responsible for the rapid deposition in bottom sediments where they persist, become subject to sediment transport and are available to the aquatic life. Metallic mercury can be oxidized readily to divalent mercury ions under the conditions present at the bottom of lakes and rivers. This has been shown to occur experimentally as well. The divalent inorganic mercury produced has an extremely strong affinity for organic muds and is methylated in the bottom sediments. Divalent organic mercury, when methylated, is readily released from the sediments into the water. Many fish are bottom feeders or feed upon organisms which are bottom dwellers and therefore the hazard of mercury ingestion becomes very great. Pish also absorb mercury from the water through the gills and possibly the scales. Since biological concentration of mercury occurs, the accumulation of mercury in the food chain is a matter of grave concern. A recent report indicates a magnification or concentration of mercury of over a million in the protoplasm of bacterial species. It has been demonstrated that the con- centration from water to pike is in the order of 3,000 or more. Uses of Mercury Sources of mercury in the environment principally ------- 649 L. A. Van Den Berg •come from industrial processes utilizing a form of mercury and the use of mercurial products by man. The industrial uses in 1968 are listed as follows: These values are in thousands of pounds. 1. Electrical apparatus 1,492 2. Electrolytic preparation of chlorine and caustic soda 1,326 3. Paints 803 4. Charging new installations of chlorine and caustic soda cells 630 5. Industrial and control instruments 581 6. Agricultural uses 260 7. Dental preparations 158 8. Catalyst preparations 145 9. Laboratory uses 151 10. Pharmaceuticals 32 11. Pulp and paper uses 31 12. Amalgamation 20 Mercury is used as the cathode in the electrolytic manufacture of chlorine with caustic soda and hydrogen as by-products. Cell recharging to make up the various losses from this process was 26 percent of the total mercury used in 1968 by all industries. To maintain the mercury inven- tory it required purchases of 1.3 million pounds of mercury in 1968. Weak spent brines, acids from the chlorine driers, ------- 650 L. A. Van Den Berg brine sludges and cell cleanings are discharged to the water environment from this process. The mercury may be metallic mercury emulsion, soluble and insoluble mercury salts. In 1968, 630,000 pounds of mercury were used in the start-up of new electrolytic installations. This amount eventually contributes to the cell losses. Information from manufactures of mercurials used for herbicides, fungicides and bactericides is not readily available. These compounds usually are produced in batch processes and require considerable cleanup with possible losses of mercury. In the pulp and paper industry, phenyl mercury acetate is used for slime control and ground wood pulp may contain up to 20 ppm of the fungicide. This mercury is either lost to the product or to the waste load during pro- cessing. In either case it becomes a waste. Large quantities of mercury are used in the manu- facture of electrical apparatus and industrial and control instruments such as mercury cells, arc lights, pumps and switches. This poses a hazard of loss during the manufac- turing process. Catalysts, containing 10 percent mercuric chloride are manufactured for use by the petrochemical industry. This is made by passing a water solution of mercuric chloride over ------- 651 L. A. Van Den Berg carbon and is used for making vinyl chloride from acetylene. Another catalyst containing mercuric sulfate is used in pro- cessing acetylene to acetaldehyde. There are losses to the water environment from these processes. Paints, those used for mildew control as well as those having anti-fouling characteristics, contain mercury, usually in the organic form. Erosion from paint films con- taining these compounds is another source of loss to the environment. Mercury is used in dentistry for the preparation of amalgams. Minor losses may result from this use. Laboratory use of mercury in manometers, thermo- meters, calomel cells, standard cells and as reagents results in an occasional discharge to sewers. In large research centers or universities, the quantities can become appreciable. Minor users of mercury are the pharmaceutical manu- facturers and in amalgamation. In the pharmaceutical manu- facture, diuretics and antiseptics, i.e. calomel, phenyl mercury acetate and merthiolate are made. Accidental spills are the source of loss to the water environment. The recovery of gold and silver by mercury amalgam is a wet process and may result in rather high losses of mercury in the plant effluent. Additional mercury is introduced to the water ------- 652 L. A. Van Den Berg environment through the use of products containing mercurial compounds. The most widespread example of this is in the agricultural application of fungicides and pesticides, which results in losses during periods of runoff from the area to which they are applied. The FWQA-Lake Huron Basin Office (LHBO) initiated a water and sediment sampling and analysis program for mercury in the St. Clair River to Lake Erie system immediately after the Canadian Government announced the fishing ban in Lake St. Clair on March 24, 1970. Sample collections were made by personnel from the Lake Huron Basin Office with assistance from the Michigan Water Resources Commission. Water samples were collected with a surface grab- sampler. Sediment samples are obtained by the use of either a Petersen dredge or a drag line sampler. These devices penetrate the bottom to about one-fourth foot. The State of Michigan reports no measurable mercury in any water supply intakes within this area. Page 15 is one of those which I rewrote. St. Clair River and Lake St. Clair. Fifteen sediment samples and 6 water samples were collected in the St. Clair River. All water samples contain less than the measurable concentration at 37, 33 and 25.5. They contain ------- 653 L. A. Van Den Berg * concentrations of 1.0, 0.2 and 0.3 milligrams per kilogram by weight respectively. The other 12 sediment samples contain less than the measurable limit of 0.5 milligrams per kilogram wet weight, but indicated traces of mercury were present. In Lake St. Clair, one water sample and 26 sediment samples were analyzed. Six sediment samples and a naviga- tion channel close on the U. S. side contain mercury and are in concentrations from 0.3 to 9.2 milligrams per kilogram. Two samples from a disposal area outside the channel contain mercury concentrations of 1.5 to 2.1 milligrams per kilogram dry weight. The other 18 sediment samples indicated the pre- sence of mercury, but were less than the measurable limit. Upper Detroit River (Lake St. Clair to Grassy Island), page 20, sampling of the upper Detroit River and lower Rouge River began on March 26, 1970, and continued to April 24. Sixteen sediment and 6 water samples were obtained. Mercury was detected in sediments along the U. S. Shore line at boat ramps and in other backwater areas. Values ranged from below the measurable level near the headwaters to 2.0 mg/kg downstream from the Rouge River. Levels in sediments around Grassy Island and upper Fighting Island were all below the measurable limit. ------- 654 L. A. Van Den Berg Lower Detroit River (Grassy Island to Mouth). In the portion of the Detroit River from Grassy Island to the mouth of Lake Erie, 78 sediment and 23 water samples were collected between March 26 and April 16. The highest levels of mercury occurred in the bottom muds of the Trenton channel downstream from the Wyandotte Chemicals Corporation South Works, in a narrow strip of from 20 to 100 feet along the western shore. Concentrations along the east shore of the channel near Grosse lie are less than the measurable limit of 0.5 mg/kg. Mercury in the sediments indicates that the Wyandotte Chemicals mercury discharge hugs the western shore of the Trenton channel, depositing mercury in the bottom muds along shore. No mercury deposits were found around Wyandotte Chemicals waste beds, located on the northern tip of Grosse lie. However, one sample collected between Grassy Island and Grosse lie contained 4.4 mg/kg mercury. Mercury concentration in sediments was found along shore as far as Lake Erie. In addition to high values near Wyandotte Chemicals, one sample with 26.0 mg/kg dry weight was present at the northern tip of Horse Island (Gibraltar, Michigan) at mile point 6.7. Of the four samples collected at the southern end of Fighting Island, one contained 1.2 mg/kg mercury, and the ------- 655 L. A. Van Den Berg * "others contained trace amounts, but were less than the measurable limit. Wyandotte Chemicals waste lagoons are located on Fighting Island. The only mercury measurable in four samples in Canadian sediments was near the shore at mile point 3.9. That value was 0.6 mg/kg. The levels of mercury in all water samples but one were below the measurable limit of 0.01 mg/1. One sample collected 300 feet downstream from Wyandotte Chemi- cals outfall W23 (RM 13.3) contained 0.03 mg/1 March 31, 1970. The effluent was diluted by Detroit River water so mercury was not measurable further downstream from the dis- charge point. Western Basin of Lake Erie, including the Raisin and Maumee Rivers. The sampling of Lake Erie began on April 6, 1970, with bottom sediments collected at two stations near the mouth of the Huron River. From April 6 to April 27, 44 bottom sediment stations were sampled. Samples were collected in western Lake Erie west of Pelee Island, with the majority of samples collected near the mouths of Michigan tributaries. Based on the measurable limit of 0.5 mg/kg wet weight, mer- cury was present at 16 of the 44 stations, although traces were found at most of the other stations. ------- 656 L. A. Van Den Berg The Raisin River was sampled on two different dates at three stations. Traces of mercury were found; however, all results were less than the measurable limit. The Maumee River was sampled on April 17 at six stations, and traces of mercury were found at most stations; however, all results were less than the measurable limit. The 1G stations where mercury was found are located in the deepwater areas of the western basin of Lake Erie from the mouth of the Detroit River southward and eastward. Since shore line and minor tributary samples do not show appreciable amounts of mercury, the Detroit River appears to be the principal source, with mercury being deposited in the deeper quiescent parts of the lake. Mercury analyses in the eastern portion of the Lake Erie Basin. As part of its mercury investigations in the Lake Erie Basin, the Federal Water Quality Administration-Lake Erie Basin Office analyzed bottom sediments from the lower portions of south shore tributaries and from the lake bottom. Tables 10 and 11 include results from the sediment and water analyses to 5/12/70 except those made at the Detrex Chemi- cal Corporation plant. Detrex analyses are listed in a special report on the plant (Appendix II). At the Lake Erie Basin Office the lower limit of ------- 657 L. A. Van Den Berg i .measurability of mercury in sediments is 1 mg/kg and in water 0.002 mg/1. The States of Ohio, Pennsylvania, and New York report no measurable mercury in any water supply intakes within this area. In Table 10 on page 39, you will note that mercury concentrations at the hydro discharge to Grand River, Dia- mond Shamrock, Painesville, is 0.01 mg/1. Euclid sewage treatment plant is 0.004. Cleveland Southerly STP 0.004 Cleveland Westerly STP 0.003 Cleveland Eastern STP, less than 0.002 Mile 1.0 West Branch Ashtabula River 200 feet downstream from titanium plant, less than 0.002 General Electric, Nela Park, Cleveland - discharge 3 gallons cover water every two weeks 1.060 This is a very insignificant amount of mercury on a daily basis, but on Table 11 is Black River at mile 0.61, 8. One hundred feet north of the Easterly sewage and treatment outfall, it was 4 mg/kg. Fifty feet north of the East 222nd Street - Babbitt Road sewer outfall in Euclid, it was 2 mg/kg. The Ashtabula River at 0.76 mile, it was 2 mg/kg. ------- 658 L. A. Van Den Berg And No Name Ditch east of Ashtabula at Route 531 bridge, it was 8 mg/kg. The only other measurable mercury level in sedi- ment are on page 42. River mile 0.0, Buffalo River, 4 mg/kg. River mile 4.3, the Buffalo River, 1 mg/kg. Heavy metals in the Lake Erie Basin. As part of the investigations in the Lake Erie Basin, the FWQA, National Field Investigation Center analyzed bottom sediments from various shore areas and tributaries. The results of analyses for 10 heavy metals — magnesium, chromium, polonium, nickel, mercury, manganese, iron, copper, zinc and cadmium. Stations were selected in the mouth of tributaries and immediately off-shore. Heavy metals are toxic to aquatic bottom organisms and fish when present in sufficient concentrations. Combi- nations of some of these metals such as copper and zinc have a total toxicity greater than the sum of the toxicities of each metal taken independently. Metals such as iron oxides precipitate in water and may blanket the bottom and smother bottom organisms. Toxic metals in bottom muds can be made available to the overlying water by physical, chemical or biological means. Metals may re-enter the overlying water by scouring of the stream bed because of velocity increases, by wave action, or other water turbulences. These metals ------- 659 L. A. Van Den Berg •may also be resolubilized by the waterbody dependent upon environmental conditions such as pH, temperature and concen- trations of other metals present. Some of these metals may also be detrimental to aquatic organisms when concentrated in the food web. Summary and conclusions, page 1. 1. Data provided for the Bureau of Commercial Fisheries, Technological Laboratory, Ann Arbor, Michigan, show that mercury was present in fish throughout the St. Clair River- Lake Erie system. Concentrations (parts per million, wet weight) in the edible portions of various fish were: Keep in mind the F.D.A. limit 0.5 ppm. Yellow Perch 0.32 to 1.70 Northern Pike 0.64 Coho Salmon 0.24 to 0.96 Carp 0.08 to 0.28 White Bass 0.53 to 0.80 Steelhead less than 0.15 Walleye Pike 1.4 to 3.57 Channel Catfish 0.32 to 1.8 Gizzard Shad 0.24 Sucker 0.88 Sheepshead 0.24 2. Available information indicates that no measurable ------- 660 L. A. Van Den Berg concentration of mercury was present in water supply intakes in the St. Clair River-Lake Erie system. 3. Mercury in excess of 1 mg/kg dry weight was pre- sent in sediments in the Erie, Pennsylvania, in Euclid and Cleveland, Ohio, areas and the Buffalo, Black and Ashtabula Rivers. Results of analyses indicate the following levels of mercury in the areas specified: The first area has been rewritten as a result of newer data. In the St. Clair River, mercury was present at mile .37, 33 and 25.5 at concentrations from 0.2 to 1.0 mg/kg. All other samples indicated the presence of mercury. Six sediment samples from the navigable channel in Lake St. Clair off-shore from the mouth of the St. Clair River had mercury concentrations from 0.3 to 9.2 mg/kg dry weight. The upper Detroit River headquarters to Grassy Island, mercury was not measurable at the head of the Detroit River, but ranged from 1.4 mg/kg in backwater areas to the U. S. shore upstream from the Rouge River and as high as 2.0 mg/kg in backwater areas downstream from the Rouge. The lower Detroit River, Trenton channel, in a narrow strip of about 20 to 100 feet along the U. S. Shore line, concentrations range from 86.0 to 5.4 mg/kg within a ------- 661 L. A. Van Den Berg * -mile downstream from the Wyandotte Chemicals outfall and then vary from 26.0 mg/kg to trace amounts downstream to Lake Erie depending on the settling characteristics of the specific point. The main channel of the Detroit River/ one sample collected between Grassy Island and Grosse lie contained 4.4 mg/kg. On the east side of Fighting Island, one con- tained 1.2 mg/kg. And one near the Canadian shore near the mouth contained 0.6 mg/kg. Northern Grosse lie, no mercury was present in measurable amounts in samples along the northern part of Grosse lie, the area of Wyandotte Chemicals waste beds, but trace amounts were indicated. Western Lake Erie, Michigan waters, concentrations near the Detroit River varied from 1.0 to 2.1 mg/kg. Along the Michigan shore, mercury was not measurable. Near LaPlaisance Bay, one sample contained 0.8 mg/kg. Ohio waters, four points near West Sister Island have values ranging from 1.6 to 2.1 mg/kg. In other areas nearer to shore, mercury was not measurable. Canadian waters, concentrations of 1.3 to 2.7 mg/kg were present at three points extending eastward about 15 miles from the Detroit light and about 5 miles from the Ontario shore. Points extending to Pelee Island showed no ------- 662 L. A. Van Den Berg measurable mercury. Eastern Lake Erie, Ohio waters, concentrations of 2.0 and 2.4 mg/kg were present off-shore from mouth of the Grand River and Cleveland Harbor, respectively. Off-shore from the Cleveland Easterly sewage treatment plant, a con- centration of 4.0 mg/kg occurred. Pennsylvania waters, a concentration of 1.1 mg/kg was found in Presque Isle Bay. Tributaries, concentrations in excess of 1.0 mg/kg were present in the Black, Ashtabula and Buffalo Rivers. In the Rouge, Huron, Maumee, Sandusky, Portage, Rocky, Cuyahoga, Grand, and Raisin Rivers, the concentrations were less than 1.0 mg/kg. 4 . The waters of the study area revealed no mercury except for one sample collected at mile point 13.3 in the Trenton channel downstream from the Wyandotte Chemical Com- pany; this concentration was 0.03 ng/1. 5. The Detroit River area is the primary source of mercury in the western end of Lake Erie. This is revealed by the distribution pattern established through sediment samples. 6. Because of mercury discharges, the State of Michigan stopped the production of chlorine by Wyandotte Chemicals Corporation until a treatment system was developed and the ------- 663 L. A. Van Den Berg mercury bearing wastes were removed from the receiving waters. In our latest data on the 22nd of May, there appeared no discharge of mercury from that outfall. 7. The State of Ohio issued an order to the Detrex Chemical Industries, Inc., Ashtabula, Ohio, on April 13, 1970, to "..cease and desist the discharge of liquid indus- trial waste containing any mercurial compounds to waters of the State." Some operational changes were made but data collected on May 11, 1970, indicate that Detrex still dis- charged 1.2 pounds of mercury per day. 8. Allied Chemical Company, Buffalo Dye Division, Buffalo, New York, is a source of mercury to the Buffalo River. On May 8, 1970, a sample of the plant effluent revealed 0.12 mg/1 mercury. The company stated that the process utiliz- ing mercury was not in use on that day. Based on this infor- mation, Allied Chemical Company was discharging approximately 4 pounds of mercury per day from sources other than the reported production of disulfo intermediates. 9. The discharge from Diamond Shamrock, Painesville, Ohio, to the Grand River had a concentration of 0.010 mg/1 mercury on April 4, 1970. 10. The first statement has to be changed. Recently received data revealed that concentrations of 0.002 mg/1 occurred at the Ann Arbor, Wayne County, Wyandotte and ------- 664 L. A. Van Den Berg Detroit sewage treatment plants. These were all on 24-hour composites on the 14th of May. No measurable concentration of mercury was present in sewage treatment plant effluents investigated in Michigan (State data). Concentrations of 0.003 and 0.004 mg/1 mercury were present in Euclid and Cleveland Westerly and Southerly sewage treatment plant effluents, respectively. Although no measurable concentration of mercury was present in the Cleve- land Easterly sewage treatment plant effluent, which receives wastes from several users of mercury, 4 mg/kg were present in Lake Erie sediments 100 feet north of the discharge point. 11. On May 7, 1970, a concentration of 0.011 mg/1 mercury was present in the outfall from the National Aeronau- tics and Space Administration, Lewis Research Center, Cleve- land, Ohio. This occurred during a period when there was no discharge from lagoons that supposedly receive all mercury wastes from known sources. 12. Investigations of additional potential dischargers of mercury to Lake Erie are in progress by the State and the Federal Water Quality Administration. Recommendations. 1. Surveillance and sampling programs be initiated by industries, municipalities, States and the Federal Government to locate and identify all sources or potential sources of ------- 665 L. A. Van Den Berg mercury and to determine mercury concentrations in surface waters, land run-off, waste streams, aquatic life, and sediments. 2. All dischargers of mercury to surface or ground waters or to municipal or regional waste treatment plants, including Federal installations, be ordered to cease and desist. 3. Precautionary measures be taken by all users and possessors of mercury or mercurial compounds for any purpose to prevent accidental spills or other losses to the water environment. That concludes my statement. MR. STEIN: Thank you, Mr. Van Den Berg. Are there any comments or questions? Mr. Purdy. MR. PURDY: First, I would like to have you repeat the insert that you put in between 9 and 10 on page 5. I didn't quite catch that. I think you inserted some additional data. MR. VAN DEN BERG: Yes. In the beginning of 10. Recently received data revealed concentrations of 0.002 mg/1 in Ann Arbor, Wayne County, Wyandotte and Detroit sewage treatment plants. This was based on a 24-hour composite collected on May 14, 1970. ------- 666 L. A. Van Den Berg MR.PURDY: On page 1, when you are presenting the data from the Bureau of Commercial Fisheries on concentra- tions of mercury in the edible portion of fish, is that data that has been supplied or collected only by the Bureau of Commercial Fisheries or is this now a summary of all the data that is available on mercury content, including that of Michigan Department of Agriculture, Ohio's data and Ontario's data? MR. VAN DEN BERG: That's just Bureau of Commercial Fisheries data from Ann Arbor. MR. PURDY: So really there is a great deal more. MR. VAN DEN BERG: There is a great deal more infor- mation available if we can get our hands on it. MR. SEEBALD: Is this data on individual fish? MR. VAN DEN BERG: In Appendix IV, the tables from BCF indicate the number of fish that were analyzed in these samples. And this varied depending on the type of fish. Some of them were 8, 9, some of them were much larger numbers. MR. PURDY: In sample preparations, Mr. Seebald, they sometimes take 10 fish and grind them up together and make one simple out of that. MR. SEEBALD: I am puzzled because it gives a range in some cases and specific numbers in other cases which lead me to believe either they were a single batch or in other ------- 667 L. A. Van Den Berg Cases a number of batches. MR. VAN DEN BERG: There is a Footnote #4 on page 91 that explains those ranges. They have an average value there, but they also give a range. The average value is on 6 individual samples in that particular case. MR. POOLE: This is off that point, but on page 8, the second paragraph where you say 500 parts per billion or 5 ppm in pickerel, which is it? MR. VAN DEN BERG: Mr. Mayo, can you clarify that? That information came from your office. MR. POOLE: Well, I think your table on page 1 would show that it is above 500 parts per billion. MR. STEIN: It is just straight arithmetic. One of those figures has to be wrong. MR. POOLE: All I am trying to find out is whether you have as much as 5 ppm in fish. MR. VAN DEN BERG: I can't clarify that. MR. STEIN: Let's go on, and we will try to pick that up. MR. PURDY: I have some other questions, Mr. Stein. MR. STEIN: Go ahead. MR. PURDY: I am wondering if you would venture to make a statement on what you might find in the way of mercury content of the bottom that had not been contaminated from ------- 668 L. A. Van Den Berg some man-made source. MR. VAN DEN BERG: No, I wouldn't make a statement on that. MR. PURDY: Wouldn't you expect to find something? MR. VAN DEN BERG: I would expect to find some in certain areas, yes, sir. What level, I don't know. MR. PURDY: I have another comment on this matter of Detrex down the Ohio, Ashtabula, Ohio, apparently. Yet, in the midpoint of May, it is discharging 1.2 pounds. I was able to read in the newspaper by George Rhodes with respect to what took place in Michigan. Apparently he has not been quite as concerned about mercury that arises in Ohio being discharged in Michigan. MR. POOLE: It is farther south. It is not as damaging. MR. PURDY: You mentioned about the Lewis Research Center, a certain concentration of mercury, and there was no discharge from lagoons that receive all mercury waste from known sources. What would the level be if there is a dis- charge from the lagoons? MR. VAN DEN BERG: I took some water samples or George did from the lagoon, and the water itself in the lagoon didn't show any mercury. MR. HARLOW: Mr. Purdy, in regard to that statement ------- 669 L. A. Van Den Berg on page 6 in connection with NASA, at the time that we took the initial sample on May 7 when we had 11 parts per billion, the lagoon was not discharging. But the ditch that enters Rocky River which receives a number of storm connections from other sources measured 11 parts per billion. And you could guess here where it might have come from. It might have been residual in the muds, or it could have come from another source. So we went back at two different times subsequent to that and sampled the lagoon when it was discharging, sampled the water in the lagoon, and also sampled the final ditch that carries the storm water. And on these other two occasions, we didn't find any mercury at all. MR. LYON: You mean there was no mercury in the lagoon? MR. HARLOW: No. MR. STEIN: Are there any others? MR. PURDY: On page 9, several statements are made with respect to the fate of mercury discharge to the waters and then what happens when they accumulate in bottom muds. And there is the one about they are available to aquatic life and that they are readily released from the sediments in the water and that fish absorb the mercury from the water through the gills and possibly the scales. ------- 670 L. A. Van Den Berg We have been doing a great deal of research of the literature in the past several weeks to attempt to determine the fate of mercury. And I am wondering if at some later point in time you could furnish to us the references from which this information came. MR. VAN DEN BERG: Certainly. MR. PURDY: Then, on page 11, there is the perni- cious reference to a report by N. A. Smart, "Use and Residues of Mercury Compounds in Agriculture," to the effect that it raises the spectre of paper mills being a source of mercury today. And I am wondering if you know what period of time this particular author was talking about in his report. MR. VAN DEN BERG: I refer that question to Mr. Muir from our office in Cincinnati. Can you answer that, Larry? MR. MUIR: Mr. Purdy and Mr. Chairman, this in- formation carried from 1964 up through 1967 and probably into 1968. In 1966, I believe, the Swedish Government banned the use of these materials. And much of this original statement stated that Norway, Sweden, United States and Canada were shipping pulp from their forests internationally, and it contained up to 20 ppm phenyl mercury acetate. MR. PURDY: From U. S. sources also? MR. MUIR: This includes United States as being ------- 671 L. A. Van Den Berg Chipped, as I understand it, from our south coast or from the Texas, Louisiana, Mississippi and Florida areas to Europe. And this material contained the phenyl mercury acetates. MR. PURDY: Why I am curious about this is the presence of mercury now from paper mill discharges is not something that we are experiencing here in Michigan. And in fact, I think about 1959, the Food and Drug Administra- tion banned the use of phenyl mercury acetate as a slimocide in paper mills where the paper came in contact with food products. And as a general rule, the paper mills have dis- continued the use of this. In fact, we have found none being used in Michigan paper mills. And in fact, the industry indicates that this is pretty much the situation throughout the United States — somewhat different, then, from what this reference seems to indicate. MR. MUIR: As I say, this was up through 1968. MR. PURDY: Well, the ban issued by the Food and Drug Administration was in 1959. MR. VAN DEN BERG: Mr. Purdy, do your paper mills in Michigan utilize imported pulp that is transported for long distances? MR. PURDY: There is pulp that has been purchased ------- 672 L. A. Van Den Berg from Canadian sources and other sources transported quite some distance. We have sampled this, and we are not find- ing mercury present in significant quantities. MR. STEIN: I think Mr. Purdy has a good point there because I have been asked that question several times before I came out here and was waiting on the report. I think if we are going to proceed with the mercury investiga- tion, we should do this pretty rapidly, get in touch with the Pulp and Paper Trade Association in New York — and maybe there is a representative here, but I doubt it; I don't see him — and ask how many mills are using this in the United States, what the prevalence is, and whether we are getting any pulp from other places that we are processing. Because the question that comes up — and I think Mr. Purdy asked this in Michigan — how many pulp and paper mills use mercury in their process for slime control. And I think we are going to have to have an answer to that. MR. VAN DEN BERG: I hope, Mr. Stein, that infor- mation is being collected by our Regional Offices for sub- mission for the national report. MR. STEIN: Well, I don't know. You can short- circuit that, you see. When you have a question raised, you could find that the trade association of the pulp and paper industry is very knowledgeable on this. And they always ------- 673 L. A. Van Den Berg • "give out accurate information. So we may try to get that and see how that checks against our regional submissions. MR. MAYO: A point that might be kept in mind, Mr. Chairman, is I understand the FDA regulations apply to the pulps that are used best domestically for packaging materials that come in contact with food. In the waste pulp that was being shipped overseas for later use overseas in the manufacture of paper and packaging materials, the FDA regulations may not apply. MR. STEIN: I recognize that. That's why I am asking for a nose count. Because obviously, they are not banning the phenyl mercury acetate in all paper mills or in all processes. This is not what the Food and Drug ban goes to. The question that we have to ask is, in fact, how many paper mills are using the mercury. Some judgment must be made on that. Because on your previous page, you get the thousands of pounds estimate. MR. VAN DEN BERG: Those thousands of pounds esti- mates come from the Bureau of Mines Mineral Year Book. MR. PURDY: Is that consumption in the U. S. or worldwide? MR. VAN DEN BERG: That's in the U. S. MR. STEIN: Again, Mr. Purdy, if we take this at ------- 674 L. A. Van Den Berg its face value — and I don't want to spin this out too far — but if you look at industrial uses in the U. S. in 1968, the Food and Drug ban was in existence since 1959. We have for pulp and paper uses 31,000 pounds. When I first saw this and read this, Mr. Van Den Berg, I thought pulp and paper wound up pretty low on the list. This may be the reason for it. It may not be exten- sively used or used in wide areas. MR. PURDY: It is used for other purposes in paper mills. MR. STEIN: In some. MR. PURDY: Some on the face of clocks, paper used in clocks. Some of it is used in paper that goes into wrapping of soap bars and so forth. MR. LYON: I understand its use as a slimocide was stopped some considerable time ago. For example, Hammermill Paper used mercurial compounds as slimocides about 10 years ago. MR. PURDY: On page 44, there is this matter of the toxic metals in bottom muds can be made available to the overlying water by physical, chemical or biological means. I have gone through how they say possibly mercury might be made available to the overlying waters. I am wondering if you could describe to me how this might take ------- 675 L. A. Van Den Berg 'place by other means. Is it something that we would reasonably expect to happen or does it take some unusual condition for this to come out of the bottom muds and be in the overlying waters? MR. VAN DEN BERG: I don't think it takes an unusual condition. So much of this depends on the local characteristics of the body of water. MR. PURDY: Certainly it has got to be an unusual condition, doesn't it, if it once is precipitated into the bottom muds? There has got to be some driving force now to put that back into the overlying waters. MR. VAN DEN BERG: Yes, sir. But these deposits that can take place during one period of the year over tem- perature changes, for instance, in some cases are enough to make that difference. MR. PURDY: For what heavy metal, then, would a temperature change cause it to redissolve? MR. VAN DEN BERG: Practically any. MR. PURDY: To the point that it would be toxic? MR. VAN DEN BERG: No, not necessarily to the point that it would be toxic at the concentration in the water, but if the biological life has the capability of concentrating within their bodies the toxic metal from the water, there is a possibility of buildup^ where levels ------- 676 L. A. Van Den Berg could be significant. IVR. PURDY: Then, in the next sentence about they may reenter the water by the scouring process, when they scour, you mean they would be redissolved? MR. VAN DEN BERG: Not necessarily. I think you probably have a good example of that in the Detroit River. At those intakes, there are bottom deposits, I am quite sure, that are picked up and moved to another area. MR. PURDY: And in fact is more like just sediment, MR. VAN DEN BERG: Right. MR. PURDY: Suspended solids. MR. VAN DEN BERG: But in the process of doing this, if you have a sludge bed that contains a metal that has been covered over so it is not available, at that time when it is scoured and transported to a different area and resettled, it again may be in a position to be within the active portion of the sludge or sediment deposit. MR. PURDY: I think the statement is well quali- fied by me. MR. SEEBALD: In the interests of accuracy, I would just like to ask the question about the reference to the measurable limit of 0.5 mg/kg as cited on page 31 and then a measurable limit on page 38 at 0.1 mg/kg. MR. VAN DEN BERG: This data, Mr. Seebald, was ------- 677 L. A. Van Den Berg • -developed in about three or four different laboratories. And some people are using the dithizone method which depends also on the size of the cell they use in the spectrograph. Other laboratories are using flamotoxic absorption. We use a flameless vapor atomic adsorption technique. And each has a different limit. MR. SEEBALD: O.K. So then we don't have a uniform base on which to compare the relative levels of this mercury throughout the systems that we are talking about because of the differential analysis we have got. MR. VAN DEN BERG: Only above certain — MR. STEIN: What is the answer to that question? Is the answer that we don't have? MR. VAN DEN BERG: We do in a certain range, yes. At a certain range, we do, yes. About 1 rag/kg, the data is comparable. But in the lower ranges, one guy can be — MR. STEIN: Are these lower ranges ever significant? MR. VAN DEN BERG: Mr. Stein, I don't think we know. MR. STEIN: If they are significant and the fish concentrate them, you might want to consider one recommenda- tion that we come up with a uniform method of measuring. MR. SEEBALD: That's my point, Mr. Stein. MR. VAN DEN BERG: This was recommended to the Admini stration. ------- 678 L. A. Van Den Berg MR. STEIN: Was it recommended here? MR. VAN DEN BERG: No, I am sorry. MR. STEIN: O.K. Any other comments or questions? MR. SEEBALD: Just one other one. And, again, it is a matter of accuracy. On page 39, the lower sensitivity is 0.01 mg/1. MR. VAN DEN BERG: Yes. I am afraid I am getting mixed two people's data there, Mr. Seebald. MR. SEEBALD: I am not being picayune. I just want to be serious about this. MR. VAN DEN BERG: This will go into the record right. MR. PURDY: Mr. Stein, on the insert of the data of the Ann Arbor wastewater treatment plant, the Wayne County Wyandotte plant and the Detroit wastewater plant, I have been informed that that statement is based upon infor- mation that was collected by the Michigan Water Resources Commission and based upon a report that I was just handed. And it shows of these samples, all but two have been collected on 5/14/70. And there is something wrong there because they had completed our sampling by that time. We do not have our data with us, but we do not remember having mercury present in the Detroit plant. ------- 679 L. A. Van Den Berg We would like to have the opportunity to review this data with our laboratory data back in the office and send in any corrections that may be necessary by one week. MR. STEIN: Yes. Right. For the record — but I do think in light of what you said, Mr. Purdy, this is developing in an area where to come up with an equitable solution, we should get the materials that are going to be presented in the workshops from the other States. Because I don't think we can ask communities in Michigan to do some- thing without taking reference to what they are doing in the others. And maybe when that is concluded, we will be in a position for the conferees to make recommendations and come to conclusions. But we would like to have that within a week. And I think we will go over this again because I think it is fair to say Mr. Van Den Berg is to be commended for putting together a very good report. But as you can tell from his report today and the information that I keep getting, new information on mercury is pouring in now every day. And I think we are facing a moving target here, so to speak. I think we will be in better shape in a couple of weeks. Are there any other comments? MR. LYON: Yes. Mr. Van Den Berg, in an earlier report that I ------- 680 L. A. Van Den Berg received prior to the conference, there is an indication that;the concentrations as high as 170 ppm have been found in the discharge ditch of the Detrex Chemical plant in Ashtabula which discharged to Lake Erie. But your report — this report, at least — does not have any concentrations that high. Is that correct? MR. VAN DEN BERG: I don't remember seeing a document that had that high of a concentration, Mr. Lyon. MR. LYON: This is the report from Mr. Mayo on May 14 which was addressed to the State water pollution control agencies. On page 7 of that report, it quotes concentrations as high as 170 ppm have been found in the discharge ditch of the Detrex Chemical plant in Ashtabula. MR. HARLOW: Mr. Lyon, this is on page 73 of Mr. Van Den Berg's report. MR. VAN DEN BERG: It is a sediment sample. MR. LYON: Yes, it is in the section on sediments. O.K., I didn't see that. MR. VAN DEN BERG: 169 in this report. MR. STEIN: Go ahead, Mr. Lyon. MR. LYON: The next question I have is based on the investigations that you are familiar with. Is it your opinion that there are presently discharges of mercury going into Lake Erie? ------- 681 L. A. Van Den Berg MR. VAN DEN BERG: Yes. MR. LYON: And I assume that this is what your recommendation to issue a cease and desist order is based on. MR. STEIN: If you want to wait — I was waiting until you were finished -- but let me give you a preview, and you can continue. If we agree that the cease and desist should be made, I have a list of names I want to call up here: Wyandotte. Detrex. Allied Chemical, Buffalo Dye Division. Diamond Shamrock. Those Cleveland plants* National Aeronautics and Space Administration. We can go over them one by one later. If there is a cease and desist — in fact have these places stop discharging? Are they putting in mercury now? I think this is a key question. But maybe we should save that until we get all the technical questions out of the way. MR. LYON: Well, I don't know. Do you want to wait? MR. STEIN: No. Do you want to? If you accept an amendment, let's expand these. Let's go down and look at your list. How about Wyandotte Chemical? Are they putting ------- 682 L. A. Van Den Berg any mercury into Lake Erie now? MR. VAN DEN BERG: No. The latest data I have is March 22. I understand there is new data since then. It still indicates no mercury discharge. MR. STEIN: No mercury from Wyandotte now. Detrex Chemical? MR. PURDY: Mr. Stein, I would like to indicate that the cease and desist order has already been issued through the Circuit Court, Ingham County, State of Michigan. So that has already been accomplished. MR. STEIN: Well, the point is I think we have some cases where cease and desist orders have come out and the indication is that there is still a discharge. Detrex Chemical. They also have a cease and desist order issued against them. Any discharge from them? MR. VAN DEN BERG: Yes. On May 12, they still were discharging 1.2 pounds per day. MR. STEIN: Allied Chemical. Any discharge from the Buffalo Dye Division? MR. VAN DEN BERG: From our data, yes. And from New York's report, I suspect they are still discharging some mercury. MR. STEIN: All right, Diamond Shamrock, Paines- ville, Ohio. ------- 683 L. A. Van Den Berg • MR. VAN DEN BERG: Their hydro discharge indicated 0.01 mg/1. MR. STEIN: And you would consider that a signifi- cant discharge? MR. VAN DEN BERG: Yes, sir. MR. STEIN: How about those Cleveland chemical plants where you found material in the river? Do you feel they have enough of a program to prevent mercury coining through their plants and there is no problem with them any more? That is Euclid, Cleveland Westerly and Southerly, particularly the Easterly plant, where you found 4 mg in the sediments. Do you think they have a safeguard there in an industrial waste safeguard so no more mercury is going to come out? MR. VAN DEN BERG: No, I do not. MR. STEIN: What? MR. VAN DEN BERG: No, I do not. MR. STEIN: All right. MR. HARLOW: Mr. Chairman, I can shed some light on that. A large part of the mercury that reaches the Easterly plant comes from GE Lab Division. MR. STEIN: Has GE stopped putting that mercury into the sewer? MR. HARLOW: GE has reported to us they have ------- 684 L. A. Van Den Berg stopped the mercury from the sources. MR. STEIN: On a voluntary basis? MR. HARLOW: We had some meetings with them. MR. STEIN: But there is no order against GE? MR. HARLOW: No. MR. STEIN: And there is no requirement against GE to stop them putting mercury in as far as you know? MR, HARLOW: As far as I know. MR. STEIN: Well, I don't know that we can rely on your pleasing personality all the time, (Laughter.) We may have to get something else. MR. MAYO: Mr. Chairman, I might just make a comment at this point. We have a letter report from GE to Mr. Harlow dated May 27 that outlines the corrective actions that GE is in the process of making. We can submit this for the record. MR. STEIN: All right. (The above-referred to letter follows in its entirety.) ------- ENERAL COMPANY PTHIf v I n B w 4ELA PARK, CLEVELAND, OHIO 44112 . . Aroo Cod. 216 266-3376 685 LAMP DIVISION May 27, 1970 Mr. George Harlow, Director Federal Water Quality Administration Lake Erie Water Basin 21929 Lorain Road Fairview Park, Ohio kkl26 Dear Mr. Harlov: In cooperation with your Messrs. Winklhofer and Kramer we have, reviewed those operations in the Lamp Division of the General Electric Co., wherein elemental mercury is being used. Of the six locations visited, water samples were obtained from the Large Lamp Department Pilot Plant - Fluorescent, at Nela Park, East Cleveland, Ohio; the Bucyrus Lamp Plant, Bucyrus, Ohio; and the Chemical Products Plant, Cleveland, Ohio. Of these, samples of water were obtained at the processes themselves, but not from the plant effluent. This was done only at the Chemical Products Plant, where samples were also obtained at an outfall where the effluent was representative of that discharged into the combined sewers of the City of Cleveland. As I have explained to your representatives, our mercury handling processes have been designed to prevent loss of mercury for both economic and pollution abatement purposes. I believe that this philosophy was amply demonstrated to them during their visit to our plants. To place the data obtained in the proper prespective, and to describe the remedial action we have undertaken, I respectfully submit the following: I. Large Lamp Engineering Piloting Operation: a) The process here involves the dropping of tipped-off exhaust tubes from fluorescent lamps into a tray of water. The purpose of the water overlay is to prevent dissemination of mercury vapor from these tubes into the air of the working environment. Only one such tray is normally involved, and the water is continuously recirculated. Periodically, the exhaust tubes are removed, and the tray of water is discharged to the sanitary system. The frequency of water change is variable depending upon the build-up of phosphor powder, slime, etc. Maintenance men are instructed to slowly decant this water into the plant drain. ------- 686 Mr. George Harlow -2- May 27, 1970 b) Concentrations of mercury in the sample from this tray obtained by your field representatives was 1.06 p.p.m. Our analysis was 1.02, which shows good correlation. Total water discharge from Nela Park into the city sewer is 1.3 million gallons per day. Thus, even if this tray containing about 3 gallons of water were to be discharged into the Wela Park drains over a period of 1/2 hour a day, the average concentration for this period, as the waste- waters enter the city sewer, would be about 0.1 ppb. c) Although we believe our mercury discharge into the water system to be negligible, we have nevertheless already taken steps to completely eliminate even this small quantity by setting up a filtration and recycling system which permits continuous re-use of this tray water, without the need for bleeding into the water drains. This system is already in effect. II. Bucyrus Lamp Plant: a) The use of water for mercury cover here is for the same purpose as in the Pilot Plant. Wine trays are involved, each filled with about 3 gallons of standing water. The tipped-off exhaust tubes are caught in a wire-mesh basket, and over a period of 24 hours each of these baskets are removed from the water-tray, shaken, and placed over an open drum to permit drain-off. Once a day, this drain-off water is carefully decanted into a 2' x 4' stainless steel sink which has a stand-pipe with its opening about 3" from. the bottom sink surface. Any mercury which may accidentally drop into the sink is collected from a special drain opening located at one end. Over-flow water leaves the stand-pipe and enters a large trapped pipe into the plant drain system. b) A cample of water removed from a typlcnl cxhauat tube water tray showed 0.85 p.p.m. by your analysis. Total water discharged from this plant to city sewer is 300,000 gpd. Only the drain-off from these 9 trays eventually reaches the sewer lines, and the decanting procedure takes about one hour. If all the trays were discharged into the sink, over a period of one ho\ir/2k hours, the Hg concentration would be O.l8 ppb as the waste water leaves the plant. c) On May 15, 1970, when Mr. Winklhofer visited this plant, modifications to the stainless steel sink had already been made wherein the stand-pipe was diverted from the drain-pipe to a 30-gallon drum. This will permit continuous re-use of the water to fill the exhaust-tube trays. This system too is now in effect. ------- 687 Mr. George Harlow -3- May 27, 1970 III. Chemical Products Plant: a')j The mercury discharged from this plant is from a mercury cleaning process in which the dirty mercury returned from our other plants is steeped with nitric acid. The supernatant acid is removed to a ceramic crock, as are the first several water rinses. This supernatant is treated with liquid caustic, during which time mercury is precipitated and removed. The treated supernatant and subsequent mercury rinses are discharged through a removable catch basin in a trapped floor drain to confluent with other waste water effluents from the plant. b) Your data indicates the presence of about 153 p.p.m. of mercury in the treated supernatant, and 13.9 p.p.m. in the rinse waters prior to discharge into the plant stream. At the last outfall prior to entry into the City sewer system concentrations, as reported by your invcotigatoro, were between O.OP1 and 0.037 mg./li. These discharges occur only over a 1/2-hour period at a frequency of 2-3 times a week. c) The system of mercury cleaning at this plant is presently being changed. 1. A more dilute nitric acid will be used in the steeping operations to reduce dissolved mercury salt. 2. All final rinse waters will be treated together with the supernatant. 3. Neutralization and precipitation of mercury by liquid caustic followed by occondary precipitation with hydrogen sulfide, and k. filtration of the liquid instead of decantation. Thcnc additional aiopn arc expected to oLH'oet a vory marked reduction in Hg content of the discharge from thio process, and may completely eliminate it. Laboratory tests appear to bear this out. These modifications will go "on-stream" starting the week of June 1, 1970. The samples taken at our two Lamp Plants indicates that our waste-water discharge into the municipal sewerage system would never exceed the suggested maximum of 2 ppb of mercury. The steps already taken at their two plants will assure that no mercury will be diachur^cM], It Id aluo our bivMd' that the remedial action being taken at our Chemical Producta Plant will profoundly reduce the dinnamination of the already minute quant; 11; Inn ol' mercury periodically dlachurgoU into t'hu wuuta wutur oiTluanta, and may uomji'lol.f.'ly olijuiuatu It. Sinc_grely yours, I. Matelsky, Ch/airman Division Council on Water and Air IM;ah Pollution Abatement ------- 688 L. A. Van Den Berg MR. STEIN: The question here is whether the city of Cleveland that GE is hooked up to in their sewer system should have a requirement against GE so they don't put some- thing in that is a violation. Now, how are we doing with the National Aeronau- tics and Space Administration? Are they still putting some stuff out, Mr. Van Den Berg? Lewis Research Center. I guess that is a Federal installation. How about that, Mr. Harlow? MR. HARLOW: Mr. Chairman, there is a representa- tive in the audience — there was a few minutes ago — from NASA, Ed Stevenson. But I don't see him now. I guess he walked out at the wrong time. MR. STEIN: It depends on your point of view. You know how slick that mercury is. MR. HARLOW: It is the NASA quitting time, I think. MR. STEIN: Do you think they should stop putting this in? MR. VAN DEN BERG: Yes, I do. MR. STEIN: Mr. Garnet, do you have a program to do that at the Federal installations? I don't think I heard that in your report. MR. GAMET: I believe they have a program. As a matter of fact, I have a letter addressed to me based on some ------- 689 L. A. Van Den Berg « ^inquiries that Mr. Harlow made of the Lewis Research Center on April 13^ asking questions about any possible mercury dis- charges and techniques used in waste disposal and the effluents from the waste retention basin. In addition to that, I have a copy also of sample analysis from #1 and #2 basins on April 14, 1970, indicating zero ppm of mercury. If you choose, I can introduce this. MR. STEIN: On May 7, Mr. Van Den Berg reports he found a measurable quantity of mercury coming out. Now, again, he has a recommendation here that all discharges, including Federal installations,be ordered to cease and desist. And we heard Ohio has a cease and desist order against Detrex. Michigan has taken a cease and desist order against Wyandotte. And you have gone to court in Michigan. It doesn't seem to me on the sum of what you have read that we really are talking in terms of cease and desist. MR. GAMET: I am not saying they are lily white, believe me. This is the information I have. I think George probably has additional informa- tion beyond what I have. I am not - sure. MR. HARLOW: They earlier stated that subsequent to that May 7, they sampled at two other times, and it was zero. ------- 690 L. A. Van Den Berg » MR. LYON: Mr. Chairman, I think that recommenda- tion regarding cease and desist orders as a whole probably ought to be expanded to the extent of not merely looking at the discharges, but asking the question what the company or installation is in fact doing with their mercury. Now, if they have stopped the process, that is one thing. If they haven't, then we ought to find out where the mercury is going. MR. STEIN: By the way, we did ask this question of Mr. Van Den Berg in the inventory program. That is, if we find anyone using a significant amount of mercury, we want to know what they are doing with it, how they are con- trolling it; and if they are not controlling it, what their program is to control it, with the date. If that isn't satis- factory, get them to come up with a remedial program. Now, I think this is the kind of thing we are going to need with the National Aeronautics and Space Administration. I think Mr. Harlow got that from General Electric and Cleveland — the program for containment. But I don't think we have it for the National Aeronautics and Space Administration — the program of what exactly they are doing with their mercurv and how they are containing it. MR. HARLOW: Well, I don't know exactly what all the sources of mercury at Lewis Research center are, except ------- 691 L. A. Van Den Berg • that the recent samples confirmed what they said, "no mercury discharge." MR. STEIN: I understand. Let's get back to Mr. Lyon's suggestion. And that is exactly, Walter, what we have proposed. The point is if we have an in-and-out situation in April of zero, and you come in early May and get a measurable amount, and in late May zero again, it seems to me this is exactly the kind of situation where we ask them what their sources are, what they are doing with it, and what they are doing to contain it. Now, can we get that from these people? MR. LYON: I think to clarify this point, what we need is a complete mercury balance indicating what is coming in, what is happening to it, and how is it leaving the plant so that we can get a complete balance on the mercury every- place where mercury is being used, MR. STEIN: This is what we are seeking to get from every significant source in that survey that Mr. Van Den Berg is working on now. I would suggest that particularly the way to get at this National Aeronautics and Space problem is to obtain such a mercury balance, because it looks as if we have an intermittent discharge problem. Is it possible, Mr. Garnet, that you could get that? MR. GAMET: Yes, I am sure we can get it. ------- 692 L. A. Van Den Berg Would you care to have me read the letter? MR. STEIN: No, just put it in the record. (The above-referred to letter follows in its entirety.) ------- 693 NATIONAL AERONAUTICS AND SPACE ADMINISTRATION LEWIS RESEARCH CENTER 21OOO BROOKPARK ROAD Cl I VI LAND. OHIO 44135 TcttPHQNi 433 AOOO TWX. CV-S2O IN REPLY REFER TO 1 006 APR 2 4 1970 • Regional Director, Great Lakes Region Department of Interior, FWPCA 33 East Congress Parkway Chicago, 111inois 60605 Attention: Mr. Merrill B. Garnet Federal Activities Coordinator Dear Sir: Subject: Mercury Control Program at NASA-Lewis Research Center On April 13, 1970, Mr. George L. Harlow, Director, Lake Erie Basin Office, •FWPCA, contacted Mr. E. F. Stevenson of the Safety Office in regards to mercury usage at Lewis Research Center. The following information was requested. .1. Does Lewis use mercury in its Cleveland - Plum Brook facilities? Mr. Harlow was advised that mercury is used principally in the liquid metal form in research instruments and in ion engine thrusters for space engine research. 2. What quantities are used annually and what procurement replacements occurred this past year? A semi-annual inventory and report is prepared by the Equipment and Supply Division for the combined facilities at Cleveland and Plum Brook. Copies of the reports for 1969 dated September 9, 19&9 and the January 5, 1970, Recapitulation of Mercury Inventory are attached. The declared losses are the result of plating out of mercury vapors on chamber cold walls and baffles. Unexplained losses include mercury accumulation in vacuum pump oil reservoirs, vaporized mercury vented to atmosphere through exhaust pump dis- charge, and portions of accidental spill material which is not recovered. No new mercury was procured in 19&9. ------- 694 3. What technique is used in waste disposal? Due to the critical value of this material, it has been the policy at Lewis Research Center to reclaim all contaminated or used mercury. No mercury is discharged into any sewer system. Accidental spills are vacuumed with special vacuum cleaners that trap condensed vapors and droplets for reclaim. Wet mop water after vacuum operations is discharged into the sanitary sewer. k. Is the effluent from the industrial waste retention basin sampled for mercury before discharging into Rocky River? Mercury is not deposited in the storm or industrial waste system. Since the Cleveland Metropolitan Park Board Resolu- tion does not require sampling for mercury, sampling has not been done in the past. However, in the interest of a cooper- ative investigation, these basins were sampled April 13, 1970 and April \k, 1970, according to the procedure suggested by the Lake Erie Basin Office. Using the Dimethyzol Stripping Method, the analyses indicated zero ppm of mercury concentra- tion for both tests. A copy of the Analysis Report is attached. If we can be of further assistance in any way to the FWPCA Regional or Basin Offices with additional data or technical advice, please do not hesitate to let us know. Sincerely yours, Bruce T. Lund in Director Enclosures 5 cc: G. L. Harlow, Director Lake £rie Basin Office, FWPCA ------- 695 ANALYTICAL CHHGSTRI ANALYSIS REQUEST AND REPORT This "space to be completed by analytical section: Sample No(s),: <£ Date completed: Date reported* • This space to be completed by person desiring analysis* Name: PAX: -7> 7/ Date subndtted Date report J. 0« Description of material to be analyzed and analysis desired: Analysis report: * V 70 Of C.832 C8/3M) ------- 696 L. A. Van Den Berg MR. SEEBALD: Mr. Stein, I think we should con- sider where this mercury may be going in the wastes. If we remove it from the Lake Erie environment and we are going to put it in a deep well or put it in a sludge bed that might reach out into groundwaters or other surface waters is of material significance. And I think the practicality of a cease and desist order to the environment may be considered completely unfeasible in sort of shutting down the complete industry. MR. LYON: Mr. Chairman, I think there shouldn't be any question about shutting down a process if there is anything going to Lake Erie. MR. SEEBALD: I don't think we should talk about Lake Erie in this case. We should talk about the environ- ment. MR. STEIN: I think you talked about surface and other ground waters. And as a matter of fact, in large measure, as I understand it, that is what Michigan did with the portion of Wyandotte Chemical that was using this pro- cess. They just shut down. And that is what Detrex did in large measure. It was either switch the process or shut down. And I do agree with your point that in the same way as we deal with this, we don't consider a satisfactory ------- 697 L. A. Van Den Berg 'solution to v/ater pollution to be contamination of the air, contamination of the ground or something else. But the recommendation here is that all discharges of mercury into the area over which we have jurisdiction -- that is, the waters — be stopped forthwith. I think several of the States have indicated that they have taken this action. MR. SEEBALD: We have taken this action, but it is just fortunate in our case it is Allied Chemical Dye Works which is a batch process. They have shut down their dye process manufacture, And it is only by shutting down can they achieve it. I am more concerned in generalities with these continuing chlor-alkali plants who have also provided us in New York State with schedules for reduction, but not elimina- tion. And I think this may be a matter for further considera- tion, not for New York State at the present time, but for the other States where they would have continuing process runs. MR. STEIN: You mean we are going to let a little bit of mercury come out of these plants? MR. SEEBALD: I don't intend to let a little bit of mercury come out. MR. STEIN: What does the reduction process mean? ------- 698 L. A. Van Den Berg Are we going to do it over a period of time? MR. SEEBALD: We asked for a process of elimina- tion. MR. STEIN: Over a period of time? MR. SEEBALD: Yes. MR. STEIN: Like you run down phenols and stuff like that? MR. SEEBALD: I think we are faced with this. MR. STEIN: All right, that is a proposal. MR. LYON: Mr. Chairman, I want to make Pennsyl- vania's position very clear on this thing. And it is our very strong feeling that if any plant that has been reported or has been discharging to Lake Erie doesn't stop within the next week, I think we as conferees should recommend that a Federal injunction be issued against those plants. MR. SEEBALD: How many plants do you have, Walter? MR. LYON: How many plants do we have that are discharging mercury? None. But we are being affected by the mercury. MR. STEIN: I have got this list here, Walt. I will be glad to refer these cases to the Department of Justice if you don't think they are stopped within a week. As far as I can see, of the ones that I read on the list here, perhaps Euclid at least, Cleveland and GE ------- 699 L. A. Van Den Berg •have stopped perhaps. And I don't know that the National Aeronautics and Space Agency has stopped. We have got a big question mark there. Wyandotte, we know has stopped. This leaves us with indicated reports of mercury coming out from Detrex Chemical, Allied Chemical, Buffalo Division, Buffalo, Diamond Shamrock and possibly National Aeronautics and Space. And if your proposal is unless they are all stopped within a week the conferees recommend that we take appropriate Federal legal action, I would be happy to take that judgment back. MR. LYON: That's our proposal, Mr. Chairman. I don't know whether the subject of the toxicity t of mercury and its effect on man has been given enough dis- cussion here, but I would like to just for the record read what was in the Federal report concerning methyl and ethyl mercury poisoning. I am aware of the fact that not all of these mercury contaminations take that form, but I suspect that some of it does. And it also depends naturally on the concentrations, but we have found some high concentra- tions. The symptomatology of acute and chronic poisoning from both compounds is similar, including numbness and tingling of the lips and hands and feet, ataxia, disturbances ------- 700 L. A. Van Den Berg of speech, concentric obstruction of the visual fields, impairment of hearing, emotional disturbances, with severe intoxication. The symptoms are irreversible. And I think this is the important point that this material accumulates in the tissues of man and animals. This is the first epidemic. And then it goes into the Japanese epidemic. But the point is we are dealing with a very, \ery toxic substance. And I think it is essential that if these dischargers are not stopped, if the State courts are not enforcing these discharges, then the Federal Government should take appropriate action. MR. STEIN: I don't want to modify your motion specifically, but why don't you make it appropriate legal action? MR. LYON: Appropriate legal action to stop the discharge. MR. STEIN: Well, I don't know. What do you think of that proposal? MR. PURDY: As I have understood in the past, Mr. Stein, this hasn't been the sort of thing where you have a motion and a seconder and a vote and so forth. MR. STEIN: That's right. We are just looking for an expression of views if anyone wants to give any. ------- 701 L. A. Van Den Berg MR. PURDY: Certainly we believe it is only fair to our industries, to our Governor in his State address to the President, that Michigan has taken aggressive action now to cause the mercury discharges from its plants to be stopped. And to be fair to our industry, he feels that the same sort of action should be taken throughout the country, not only in the Lake Erie Basin, but throughout all 50 States. Certainly, past statements by the Governor and by our Commission would support aggressive action to stop immediately those discharges of mercury to the water that cause harmful conditions. MR. STEIN: How about you, Mr. Poole? MR. POOLE: Well, I think I would share that view. I have been keeping pretty quiet because we are in the same position at the moment, at least, as far as Lake Erie is concerned as Pennsylvania is. It is pretty easy if you don't know of any to say everybody else ought to stop immediately. But I think all known sources in view of the things that have come out here today and earlier ought to be stopped immediately. MR. STEIN: O.K. Now, we have got over the two easy ones. Would you care to make a statement for the Federal installations? Could we adopt the same policy to ------- 702 L. A. Van Den Berg try to get rapid action for Federal cleanup? MR. MAYO: Certainly, the substance of the recent Executive Orders is such that there should be no question that we can approach NASA installation at the Lewis Research Center and advise them of the findings, advise them of the sense of feeling of the conferees, and the need for the installation — MR. STEIN: Would you have any objection to this: Within a week, in line with this proposal, you have a report from that NASA facility so that we either have assurances that everyone is satisfied that they have accounted for the balance of the mercury and there will be no further discharges or we will take appropriate action through the Executive establishment, I will recommend that they be directed to stop if you haven't reported that they have a satisfactory program. MR. MAYO: We will contact the installation immediately. MR. STEIN: All right, if you want to do that. Now, we come to the two hard States because the Federal Government may add this, but it isn't our agency, either, we are dealing with. Michigan has got to clean up. There are no known sources or significant sources in Indiana and Pennsylvania. Ohio isn't here to speak. ------- 703 L. A. Van Den Berg • MR. VAN DEN BERG: They said I could speak for them. (Laughter.) MR. STEIN: You know, there were once a couple of political figures like that. One guy made some remark, and the other guy said, "You know, everyone is privileged to be stupid, but this guy abuses the privilege." Let's not abuse that proxy. I don't want to put you on the spot in New York, but do you care to comment or not? MR. SEEBALD: Yes. As far as I am concerned, as it affects Lake Erie, there is no problem in cease and desist order against Allied Chemical Dye Works because they have stopped. And they have entered a commitment they would not commence using mercury in their dye processing until they had a review of their application presently before us that was scheduled to minimize. And we have not rendered an opinion on this. It is our intention to have them indicate why they cannot and have this go through an appropriate evidence for presentation. And it is the inclination of the State right now to cause them to cease. MR. STEIN: But may I say I think, Mr. Seebald, again on this one, I wish if there is any doubt about the ------- 704 L. A. Van Den Berg facts here that you give this one priority. Either they have ceased discharging mercury or they haven't ceased discharging mercury. This is a fact. On May 8, presumably Mr. Van Den Berg has some information which caused him to say that they were still discharging mercury. If/ in fact, they have stopped and this isn't occurring, I wonder if you and Mr. Van Den Berg could get together, have your represen- tatives make a visit there, and come up with the facts. If they have stopped using mercury, they shouldn't have any coming out unless there is a residue that is wash- ing out that you know of. MR. SEEBALD: That's the one reservation I have. I think that may be the case. I don't know. MR. STEIN: If that is the case, let's find out what the facts are so we know where to move. But I think if this is the case, unless you can resolve the factual issue, this seems to be crying for inspection pretty soon. So the Federal and State people should get together and know where we stand on this so we won't be bugging you for a cease and desist order when in fact they may have stopped. MR. SEEBALD: It is my impression that they have. I would like to ask Mr. Mayo, haven't you a man on assignment to the Buffalo Regional Office at the present time? Or has he been reassigned? Is Mr. Wilcox not there ------- 705 L. A. Van Den Berg any longer? MR. MAYO: We don't have anyone at Buffalo any longer. MR. SEEBALD: Wilcox was there on the occasion you made this one inspection, I know. MR. HARLOW: Wayne Wilcox came up at the same time to check on the compliance and status of all your city industries. While he was there, he accompanied Violanti to the Allied Chemical plant. MR. SEEBALD: Is that the sampling on which you predicate this? MR. HARLOW: Yes. MR. SEEBALD: I understood he was there at the present time. I didn't know how long he was going to be there. MR. HARLOW: He came right back to Cleveland. MR. SEEBALD: We would be glad to sample. MR. STEIN: Let me ask another question. And I ask this here really just for getting information. I see no recommendation here made to get up the mercury that is in the sediment. Maybe we should or shouldn't. Maybe the thrust of the questions asked by Mr. Purdy meant it is just going to stay there. But if you are talking about the fairly large ------- 706 L. A. Van Den Berg quantities of mercury which have been discharged and if you have a fairly discrete area which you pretty accurately defined for Wyandotte Chemical, do you think that is all right to leave that there? Or should we do anything about that or direct our attention to that? Again, I have absolutely no preconceived notion of this. But I think we have,at least to my mind,something which raises the question in your report and we may get questioned about. I hate to leave a loose end. MR. VAN DEN BERG: This area, Mr. Stein, is some- thing that takes a considerable amount of thought. If there is high mercury in the sediments, we may very well cause more problems by trying to dredge it out than by leaving it where it is set if it is covered in the sediments and will not be disturbed. The first point I think we have to look at is when the mercury discharges are discontinued, then follow whether or not there is a corresponding decrease in the levels in fish and aquatic life. If this happens after dis- charges are stopped, I would see very little reason to dredge sediments to remove mercury. MR. STEIN: Let me try to rephrase what I think I understood you to say. You say your present thinking is to leave the sediments there and check the concentrations ------- 707 L. A. Van Den Berg "of mercury in the fish in Lake Erie. If these mercury con- centrations go down, leave well enough alone. If the mercury concentrations remain at high level and you find a causal relationship that may be related to the sediments, then we will think about disturbing those sediments. Is that a fair statement? MR. VAN DEN BERG: Yes. MR. LYON: Mr. Chairman, isn't there one other point in this connection that should be considered? And that is we ought to, as Mr. Van Den Berg has suggested, monitor these to see what is happening. But if some of these deposits are in areas where dredging is contemplated, this is where I would feel quite fearful as to what might happen. And, therefore, we really ought to take your sug- gestion one point further and maybe make sure that there wouldn't be any dredging in that area or make some special plans if there is a plan for dredging in that area. Because if those mucks get dredged up and put someplace else, I think we are going to have a problem. MR. VAN DEN BERG: I would refer your comment to Mr. Mayo on that since I think he is involved in a discus- sion right now concerning dredging. MR. MAYO: Among some of the most recent informa- tion that Mr. Van Den Berg included in the revised material ------- 708 L. A. Van Den Berg I believe is some data for Lake St. Clair and the occurrence of mercury in rich sediments in the upper part of the Trenton channel in Lake St. Clair. And vre were advised the latter part of last week that the Corps anticipates a dredging project this year in that portion of the Trenton channel and that the normal procedure has been to dispose of those dredgings over to the side of the channel in the waters of Lake St. Clair. This is the problem that the conferees need to address themselves to. And I think it is correctly related to the observation that Mr. Lyon just made. MR. PURDY: The problem is we have got the geo- graphy twisted to some extent, I think. The Trenton channel is not up in Lake St. Clair. MR. MAYO: The ship channel in Lake St. Clair. MR. PURDY: We are not talking about the Trenton channel. We are talking about the shipping channel in Lake St. Clair. MR. MAYO: The upper end of Lake St. Clair. MR. STEIN: Is the Corps going to go ahead unless we do something? MR. MAYO: The Corps has asked for comments, and we are obliged now to respond. And we have not responded, choosing to have the issue raised here with the conferees. ------- 709 L. A. Van Den Berg MR. STEIN: All right. Do you think we can pre- pare our comment now? I don't know how soon the Corps needs a comment. Do you think you and Michigan, talking about the Federal Government and Michigan, should get together and prepare a statement on that? Can you do that within a week for con- sideration of the conferees? Because I hate to let the Corps get revved up. You know, you are not going to stop them unless you have enough leadtime if you feel that is what you want to do. MR, MAYO: The Corps has indicated to us there can be a modest postponement of the dredging operation in order to give us an opportunity to respond. I am sure we can get together with Mr. Purdy within the next week. MR. STEIN: All right. Maybe some of my friends from the Corps are here. I don't want you to be restricted that way. As far as I am concerned, if you don't think those muds should be disturbed, I am not worried about any modest postponement, we will just stop it. MR. MAYO: Well, that wasn't the context in which I offered the comment. MR. STEIN: Well, I know. But I think you should get the full gamut of this. ------- 710 L. A. Van Den Berg One, whether these muds should be disturbed at all. Two, if they are disturbed, what precautions should be taken as to where the soil is placed. Is that a fair thing? But I would like to have the Federal conferee and the State of Michigan take a look. I think if we are going to make any meaningful push on that, we should have a joint report, if possible, with a recommen- dation on this dredging, signed by Michigan and our Regional Office, in about a week, so we can get some signal on how we are going to move. After I clear the decks in Washington, I would hope we would be able to arrange this to allow the Region to take the initiative with the District Office and the Corps here, and handle it on this level rather than letting it get back to Washington if we can. O.K., is that agreeable? MR. PURDY: I am not prepared to comment on this now, since it was first brought to my attention yesterday. We are in agreement to meet with Mr. Mayo and discuss a joint position, MR. STEIN: Are there any other comments or questions on that mercury problem or any other point? MR. POOLE: I have two questions. ------- 711 L. A. Van Den Berg I got the impression from listening to Mr. Van Den Berg if you get different results with different analytical methods/ I would like to suggest to him that FWQA decide which is the best analytical method and immediately supply that to at least all of the States that are represented here. MR. VAN DEN BERG: I am afraid if we do that, Blucher, somebody would not be able to afford it. MR. POOLE: Afraid what? MR. VAN DEN BERG: Some people may not be able to afford it. MR. POOLE: Can we send the samples to you, then? MR. VAN DEN BERG: A lot of people have been doing that if you have problems. MR. POOLE: Isn't this really a problem yet? MR. VAN DEN BERG: Yes. There are some limita- tions in the analytical procedures, but at the present time we are using the best method and equipment that the individual laboratories have available. Unfortunately, we are not all equally equipped. MR. POOLE: You are dealing in very small quantities here. And I think this can be a pretty important item. Well, you do the best for us, then, supply us with various methods. MR. STEIN: Let's try to get at this if we can ------- 712 L, A. Van Den Berg because, again, I think the best method means the best practical method you can expect the State to use. Are you saying if you get down to 1 ppm? MR. VAN DEN BERG: We get down to 1 ppb. MR. STEIN: By what kind of method? Can everyone use a reasonably accurate method that isn't too costly down to 1 ppm? MR. VAN DEN BERG: No. MR. STEIN: They can't? MR. VAN DEN BERG: The dithizone method which is the one I am aware of — Larry maybe can expand on this — but at least the ones I am aware of, without going to atomic adsorption unit, you cannot get down to 1 ppb. And this has to be with a flameless vapor technique on the atomic adsorp- tion. MR. STEIN: Is that one part per million or billion? MR. VAN DEN BERG: One part per billion in water. MR. POOLE: This has a bearing on my second comment or question, Mr. Chairman. And that is you report 3 and 4 ppb in two of the Cleveland plants. And we have had an explanation here for the Easterly plant that apparently some- body, at least, has found some in three or four of the Michigan sewage treatment plants. If you turn to page 10 and look at that list of ------- 713 L. A. Van Den Berg • mercury users and you get down past item 4, I am assuming that a great many of these users that are tabulated in the lower half of the table are hooked onto municipal sewer systems. I for one—and I will freely admit to being the most ignorant one up here at this table as far as mercury contamination is concerned—wonder if we aren't obligated to start looking at least at some of our major sewage treat- ment plants. And the second wonderment I have is: Are we going to try to shut off every drop of mercury from getting into a stream or a lake? Or can we end up with a tolerable limit? I don't expect you to answer all that today, but I would like to have your opinion. MR. VAN DEN BERG: Every drop of mercury being removed from a waste treatment plant, for instance, is almost an impossibility unless we outlaw the use of mercury in Pharmaceuticals. And they are uncontrollable. But my idea in the recommendation was that the industries themselves, the users of mercury themselves, should be responsible to take the mercury out before it reaches a municipal system. MR. POOLE: That is a beautiful theory, but I have had some experience with laboratories since we operate ------- 714 L. A. Van Den Berg a fairly sizable laboratory and we are on the IU Medical School campus. And they operate a lot of laboratories. And there are just a hell of a lot of things that happen in some of these research laboratories that ought not happen, but they do. This troubles me. MR. VAN DEN BERG: Accidental spills in laboratories is something that is extremely difficult to do anything about. MR. STEIN: I don't know. It may be difficult to do anything about, but it is not impossible because we have had places with accident spills where we have been plagued by that in industrial plants. And they have taken action to do this. They have got warning systems, they have traps, baffles around the drains in the floor that will stop this. The point is this gets to be a big problem. And industry has solved this problem again and again. And I appreciate what Mr. Poole is saying. This has been true for years. You talk about these wonderful tolerances in the research laboratories, and I wonder. I just raise this. I wonder if their housekeeping methods in handling their wastes are as good as we expect from most of the industry. MR. VAN DEN BERG: Probably not as good as the research. There were plants that were reported in this one. There is an instrument plant, for instance, that installs a ------- 715 L. A. Van Den Berg -floor drain in any room where mercury is used. MR. POOLE: I am kind of leading up to this because this has been Indiana's policy for 10 years now on cyanide. And apparently mercury is just as bad or worse than cyanide except the quantities are a little different. And I am wondering if before you get through this we won't need to think about setting up the same kind of procedures with users that you have for spills and decontamination of radioactive materials. This is what is going through my head. MR. VAN DEN BERG: It is possible. MR. POOLE: I don't know. Maybe .003 of a part per billion in Cleveland sewage plant or Fort Wayne sewage plant is of no consequence. I don't know. MR. STEIN: I think we have got two points that I am pretty sure we are going to have to answer. One is if we are looking for the so-called zero tolerance because, you know, what happens there when you say no measurable limit. Three months from now, some bright young guy is going to come up with a method that is going to measure the stuff that you are finding no measurable limit on now. And if this is hot enough three months from then, someone is going to come up with something you can measure in parts per trillion. And we will be off and running. So if you mean ------- 716 L. A. Van Den Berg every trace of this that we are ever going to find, we have one thing. Now, if you are going below parts per billion or down to a part per billion, as you are, and we are dealing with this mercury, we have to come to this conclusion, it seems to me, if we are going ahead with this program. Either we are coming up with a standard method that we can give to the States, municipalities and industries where they can reasonably get reliable results that we all can base our program on, or else we are going to have to set up facilities ourselves. Whether you use atomic absorption, gas chromatography, or whatever, we are going to have to set up facilities ourselves and accept these samples and do the work ourselves, or else contract with some laboratories that have these fancy machines. Again, we must choose between one or the other. Although these are very proper questions, unless we do that, in delivering any technical report, we are going to have this same series of questions on these discrepancies in the number. Exactly what does a little trace of this mean in a sewer pipe or sewer system? I think we just have to come to grips with those problems, work our way through and come up with recommenda- tions. Otherwise, we are going to have a mercury ------- 717 L. A. Van Den Berg problem. And let me make one last remark on this. We, and I think I particularly, have given thought to this mercury problem, but they are talking about all toxic materials. If we can't do this on mercury, which is a relatively easy one, what are we going to do on the others? That's why I say I think we should look at this as kind of a pilot operation in dealing with the whole area of control of toxic materials, and see if we can come up with a reasonable program that we can live with, and the States can live with, and the users of mercury can live with. MR. LYON: Mr. Chairman, I would like to comment on this. This touches on one of the items we talked about yesterday morning regarding the whole question of toxic substances. You remember, Murray, an old colleague of ours, Morris Ettinger, used to point out most sewage treatment plants provide cosmetic treatment. It makes things look better. But we are finding increasingly that sewage treatment plants in many cases are discharging toxic effluents because of industrial wastes and other substances that are discharged to them. And this is probably equally true in the case of certain industrial wastes as we have just found out in the case of mercury. The history of points of view by scientists, ------- 718 L, A. Van Den Berg as I said earlier — Rachel Carsonon this — goes back to ?t& Mark Hollis and later congressional committees and policy advisory committees at the Federal level. Whether you read the report of the Tukey Cornmitteeor White Com- mittee^or Linton Commit tee* or* Daddario Committee** ¥$ey have all said the same thing. They said that we must set up a national system of monitoring for these toxic substances, They have said that we must refine our analytical tools. And they have said that we must develop much better knowledge about the chronic health effects of these substances. I think it is essential that when we are dealing with a lake as critical as Lake Erie, we as conferees recom- mend to the Secretary of the Interior that he sponsor or introduce legislation or request appropriate funds to tool up the capability of the States and the Federal Government to deal with this problem. The capability today simply does not exist, and we do not have the tools to protect the population of the United States against these toxic sub- stances . And I think that it is important that we make this point and make it very, very forcefully. Because these technical people know that there is no protection at this point against these substances. MR. STEIN: Walter, let me address myself to that. * through ****** see 7l8a — ------- 7l8a * Carson, Rachel "Silent Spring," Houghton Misslin, Boston, 1962 Hollis, Mark Chief, Sanitary Engineer Public Health Service, Department of Health, Education, and Welfare Washington, D. C. Tukey Committee Report of the President's Science Committee "Restoring the Quality of our Environment" The White House, November 1965 White Committee A Report of the Committee on Water, "Alternatives in Water Management," -Publication 14.08, National Academy of Sciences, National Research Council, Washington, D. C, 1966 Linton Committee Report of the Task Force on Environmental Health and Related Problems to the Secretary of Health, Education, and Welfare, Superintendent of Documents, June 1967 Daddario Committee Report of the Subcommittee on Science, Research and Development, Serial S, Committee on Science and Astronautics, U.S. House of Representatives, 88th Congress ------- 719 L. A. Van Den Berg I think what you say in a way is very valid, but I have another suggestion because I think the conferees have a better opportunity. It just happened that the mercury situation came to the fore in the Lake Erie Basin where we had a conference working. They have given us the job of coming up with a report on the mercury control program, and I think we are on our way. In addition to that, because everyone is worried about what you are worried about, they have also given us the opportunity to come up with a general toxic control program. Now, I think instead of just asking for money and a program which takes time to percolate through, the conferees here have an opportunity to come up with specific recommenda- tions on how we are going to get that program operating, both in mercury and other toxic materials. If it requires legislation and money, as it very well might, we can come up with a specific program to the conference, or at least that we would propose to the Administration to take to the conference, without just going into a vague hunting expedi- tion. I think we have as good a sampling and as good an experience here as anyone. And I would say I am hoping out of this mercury operation, and out of the general view ------- 720 L. A. Van Den Berg of the toxic material operation, that we may come up with recommendations for a much more specific national program than just to get the money for this program and to point out we have a problem in this area. I think we can move the whole situation a lot faster if we do that. And I have no notion about that. One of the things we might consider is your sug- gestion for a national clearinghouse — how we set this up, how we monitor and how we feed this stuff in. However, I would see that as either a task for the conferees or perhaps a task for a technical committee to be appointed by the conferees. Because I think, in the past, in other areas such as setting up specific numbers and standards, the con- ferees, for example, in Lake Michigan did that. They showed the way for national standards all through the country, and they beat them by years when they got out that little book of what the requirements would be in water quality. I think this is the chance we have. As we work our way through, I hope the conferees will avail themselves of that and try to come up with a specific report. It might be a little too early yet, but when we reconvene, we may want to establish a committee to come up with specific recommendations on how we can move in this area. ------- 721 L. A. Van Den Berg And I am sure it will be much better if we have the book and the music when we go into Washington than if we just have a generalized feeling of a proposal. MR. LYON: Well, I think we are together on this. I think that the important point is that this kind of a pro- gram consists of three elements. One is monitoring. The other one is doing research on the health effects. And the last item is to come up with better ana- lytical methods. Two of these certainly go beyond Lake Erie. And I think it would be quite appropriate for the conferees on Lake Erie to come up with such a program. I just hope that we don't delay this too long; that we try to tackle this job soon. MR. STEIN: Obviously, you have given a lot of thought to it. By not delaying it too long, I would like to talk to you about commitments privately because I have a good idea about who could be the chairman. MR. LYON: I will be glad to help. MR. PURDY: Mr. Stein, Mr. Lyon mentioned delay. I would like to say from the standpoint of Michigan, there is not going to be a delay. In fact, this sort of program is under way. I don't intend to delay it at all because ------- 722 L. A. Van Den Berg the Governor said this is something we shall do. It is being done, and it will be continued. MR. LYON: I think, Ralph, our legislators were very impressed by Governor Milliken's statement. And they have asked for a copy of the 20-point program. This is definitely showing some real leadership in this field. This is the kind of thing we need to do. MR. STEIN: Are there any other comments or ques- tions on any of the aspects of the program? MR. PURDY: I have a request from Dr. Shannon that he would like to make a statement with respect to mercury if Mr. Van Den Berg is through. MR. VAN DEN BERG: I have a statement from Ohio. MR. STEIN: Let us have a 10-minute recess. (Whereupon, a recess was taken.) MR. STEIN: Let's get going again. Mr. Van Den Berg, would you go on? MR. VAN DEN BERG: This is a status report, investi- gation of mercury contamination in the Ohio portion of Lake Erie. Detrex Chemical Company The effluent being discharged to Lake Erie by Detrex Chemical Company was sampled by Detrex on 10 days between March 4 and April 10, 1970. The analyses, made by ------- 723 L. A. Van Den Berg • Detrex, were in the range of from 0.34 to less than 0.01 milligrams of mercury per liter. Since that time, Detrex has taken precautions which are designed to make sure that the mercury content of the effluent will not increase to the detectable limit. The Federal Water Quality Adminis- tration is continuing with a program of sampling and analysis. MR. STEIN: May I ask an information question? What is a detectable limit? MR. VAN DEN BERG: Ours is 1 ppb. MR. STEIN: Do they set their own detectable limits? MR. VAN DEN BERG: I don't know. MR. STEIN: I don't mean for that to be a mean question, but this is always the key point in here. Unless you come up with a number, we are not quite sure what is detectable. Not only do you have to come up with the number, but you have to come up with the method. MR. VAN DEN BERG: Survey of mercury users. An investigation is being conducted of mercury losses by industry in Ohio. For the Lake Erie Basin, this was a joint effort by the Ohio Department of Health and FWQA. The companies surveyed were those reported by the U. s. Bureau of Mines as purchasers of mercury in 1969. ------- 724 L. A. Van Den Berg The results to date have not disclosed any significant dis- charge except that discussed above for Detrex Chemical Company. FWQA is continuing the investigation. To the best of our knowledge, there is no seed pro- cessors in Ohio who use a mercury compound for seed treatment. An agricultural chemical company, who formerly produced mercury fungicides, discontinued the production about a year ago. A survey of the paper industries in Ohio who dis- charge into the Lake Erie Basin indicates that it has been several years since any of these paper mills have used any slimicide containing mercury. Lake Erie Water Samples of raw water were obtained from each of the municipal water supply intakes, 22 in all» These were analyzed by the Ohio Department of Health Laboratory and by Battelle Memorial Institute. Battelle performed the analyses at no charge, as a public service. The results showed that all of the samples contained less than detectable amounts of mercury and specifically less than 5 parts of mercury per billion parts of water. The probability is high that the actual mercury content, if it could be detected, would be between zero and one-half of one part per billion. That concludes the Ohio statement. (The above-discussed report follows in its entirety.) ------- 724A INVESTIGATION OP MERCURY IN THE ST. CLAIR RIVER - LAKE ERIE SYSTEMS Federal Water Quality Administration Great Lakes Regional Office Lake Huron Basin Office Lake Erie Basin Office National Field Investigations Center May 1970 ------- ERRATA SHEET (JULY 10, 3.970) TABLE 1 MERCURY ANALYSES OF DETKEX EFFLUENT AND RECEIVING WATERS Date 3-4-70 3-13-70 3-18-70 3-25-70 4-3-70 . 4-6-70 4-7-70 4-8-70 4-9-70 4-10-70 4-17-70 4-18-70 4-19-70 4-20-70 4-21-70 4-22-70 4-23-70 4-24-70 5-6-70 Sta. Ditch mg/1 < 0.01 .' < 0.01 0.009 0.005 0.012 0.005 0.013 0.005 0.007 0.006 0.002 No. 4 mouth Ibs/day • < 2.0_ < 2.0 1.8 1.0 2.3 1.0 2.5 1.0 1.4 1.1 0.4 Sta. No. 2 Ditch "belov Detrex Kg/1 Ibs/day* 0.02 0.02 O.J4 < 0.02 0.07 0.11 0.04 < 0.01 9-^9 0.132 0.340 o.o4o 0.135 0.058 0.058 0.035 0.045 0.030 0.6 0.6 9.5 <0.6 2.0 3.1 1.1 < 0.3 8.1 3.7 9-5 l.l 3-8 1.6 1.6 1.0 1.3 0.8 Sts. No. 1 Sump effluent rng/1 Ibs/day • 0.072 0.020 0.108 0.092 0.046 0.049 0.066 0.021 0.044 1.5 0.4 2.2 1.9 0.9 1.0 1.4 0.4 0.7 Underlined analyses by Detrex; all others by LEBO Data obtained from Detrex; data reported earlier by Detrex showed < 0.01 rng/1 for 4-8- and 4-10-70. Loadings based upon 23.3 p-g<3- di'.ich flow which includes flow fran Detrex, Linde Welding, and Linde Air, * Loadings based upon 3-34 mgd from Detrex only. **** Loadings based upou 2.4$ mgd from Detrex sump effluent only. 65 ------- This report was developed by personnel of the Great Lakes Regional Office, Lake Huron Basin Office, and Lake Erie Basin Office in cooperation with personnel of the National Field Investigations Center. ------- HEAVY METALS IN THE LAKE ERIE BASIN TABLE OF CONTENTS SUMMARY AND CONCLUSIONS --- ___________ --- _ i RECOMMENDATIONS ------------ ......... - 7 INTRODUCTION ----------------------- 8 USES OF MERCURY -- ........ - ------- -- 10 REFERENCES - ....... - ..... _________ 13 MERCURY ANALYSES IN THE ST. CLAIR RIVER, LAKE ST. CLAIR, DETROIT RIVER AND WESTERN LAKE ERIE ........... lU LOWER ST. CLAIR RIVER AND LAKE ST. CLAIR -------- 15 UPPER DETROIT RIVER (LAKE ST. CLAIR TO GRASSY ISLAND)- - 20 LOWER DETROIT RIVER (GRASSY ISLAND TO MOUTH) ..... - 25 WESTERN BASIN OF LAKE ERIE, INCLUDING THE RAISIN AND MAUMEE RIVERS --- --- _________ 31 MERCURY ANALYSES IN THE EASTERN PORTION OF THE LAKE ERIE BASIN ..... --------------- 38 APPENIDX I ---- --- - ............ ____ 52 REPORT ON WYANDOTTE CHEMICALS CORPORATION, WYANDOTTE, MICHIGAN APPENDIX II ------ ......... --------- 61 REPORT ON DETREX CHEMICAL CORPORATION, ASHTABULA, OHIO ii ------- Page APPENDIX III 77 INVENTORY OF INDUSTRIES USING MERCURY IN THE LAKE ERIE APPENDIX IV 86 FISH ANALYZED FOR MERCURY CONTENT APPENDIX V 92 STANDARDS FOR MERCURY AND HEAVY METALS LAKE ST. CLAIR - LAKE ERIE DRAINAGE AREA APPENDIX VI 9U CHRONOLOGY OF EVENTS iii ------- INVESTIGATION OF MERCURY IN THE ST. CLAIR RIVER - LAKE ERIE SYSTEMS SUMMARY AND CONCLUSIONS l 1. Data provided by the Bureau of Commercial Fisheries, Tech- nological Laboratory, Ann Arbor, Michigan, show that mercury was present in fish throughout the St. Clair River - Lake Erie System. Concentrations (parts per million, wet weight) in the edible portions of various fish were: Yellow Perch 0.32 to 1.70 Northern Pike 0.6k Coho Sa3jjion 0.24- to 0.96 Carp 0.08 to 0.28 White Bass 0.53 to 0.80 Steelhead < 0.15 Walleye Pike l.k to 3.57 Channel Catfish 0.32 to 1.8 Gizzard Shad 0.2^ Sucker 0.88 Sheepshead 0.2k ------- 2. Available information indicates that no measurable concentra- tion of mercury was present in water supply intakes in the St. Clair - Lake Erie System. 3. Mercury in excess of 1 mg/kg dry weight was present in sediments in the Erie, Pennsylvania, and Euclid and Cleveland, Ohio, areas and the Buffalo, Black, and Ashtabula rivers. Results of analyses indicate the following levels of mercury in the areas specified: AREA St. Clair River Lake St. Clair Upper Detroit River (Headwaters to Grassy Island) Lower Detroit River Trenton Channel MERCURY LEVELS IN SEDIMENT (mg/kg dry weight) Mercury was present at mile points 37.0, 33.0, and 25.5 in concentra- tions of 1.0, 0.2, and 0.3 mg/kg, respectively. All other samples indicated the presence of mercury. Six sediment samples in the naviga- tion channel, off-shore from the mouth of the St. Clair River, contained mercury at concentrations ranging from 0.3 to 9.2 rag/1. Samples from a dredging disposal area had concentra- tions of 1.7 and 2.1 mg/kg. All other samples indicated the presence of mercury. Mercury was not measurable at the head of the Detroit River, but ranged from 1.14- mg/kg in backwater areas along the U. S. shore upstream from the Rouge River and as high as 2.0 mg/kg in backwater areas downstream from the Rouge. In a narrow strip of about 20 to 100 feet along the U. S. shoreline concentrations ranged from 86.0 to 5.1- mg/kg within a mile downstream from the Wyandotte Chemicals' outfall and then vary from 26.0 mg/kg to trace amounts downstream to Lake Erie, depend- ing on the settling characteristics at the specific point. ------- Main Channel of Detroit River Northern Grosse lie Western Lake Erie Michigan Waters Ohio Waters Canadian Waters Eastern Lake Erie Ohio Waters One sample collected between Grassy Island and Grosse lie contained k.k mg/kg of mercury; one on the east side of Fighting Island contained 1.2 mg/kg; and one near the Canadian shore near the mouth contained 0.6 mg/kg. Mercury was not present in measurable amounts in samples along the northern part of Grosse lie, the area of Wyandotte Chemi- cals' waste beds, but trace amounts were indicated. Concentrations near the Detroit Light varied from 1.0 to 2.1 mg/kg. Along the Michigan shore, mercury was not measurable. Near LaPlaisance Bay one sample contained 0.8 mg/kg. Four points near West Sister Island had concentrations ranging from 1.6 to 2.1 mg/kg. In other areas nearer the shore, mercury was not measurable. Concentrations of 1.3 to 2.7 mg/kg were present at three points extend- ing eastward about 15 miles from the Detroit Light and about 5 miles from the Ontario shore. Points extending to Pelee Island had no measurable mercury. Concentrations of 2.0 and 2.U mg/kg were present off shore from mouth of the Grand River and Cleveland Harbor, respectively. Off shore from the Cleveland Easterly Sewage Treat- ment Plant, a concentration of ^.0 mg/kg occurred. ------- Pennsylvania Waters A concentration of 1.1 rag/kg was present in a sample from Presque Isle Bay. Tributaries Concentrations in excess of 1.0 mg/kg were present in the Black, Ashtabula, and Buffalo rivers. In the Rouge, Huron, Maumee, Sandusky, Portage, Rocky, Cuyahoga, Grand, and Raisin rivers, the concentrations were less than 1.0 mg/kg. k. The waters of the study area revealed no mercury except for one sample collected at mile point 13.3 in the Trenton Channel down- stream from the Wyandotte Chemical Company; this concentration was 0.03 mg/1. 5. The Detroit River area is the primary source of mercury in the western end of Lake Erie. This is revealed by the distribution pattern established through sediment samples. 6. Because of mercury discharges, the State of Michigan stopped the production of chlorine by Wyandotte Chemicals Corporation until a treatment system was developed and the mercury-bearing wastes were removed from the receiving waters. 7. The State of Ohio issued an order to the Detrex Chemical In- dustries, Inc., Ashtabula, Ohio, on April 13, 1970, to "... cease and desist the discharge of liquid industrial waste containing any mercurial compounds to waters of the state." Some operational changes were made but data collected on ------- May 11, 1970, indicate that Detrex still discharged 1.2 pounds of mercury per day. 8. Allied Chemical Co., Buffalo Dye Division, Buffalo, New York, is a source of mercury to the Buffalo River. On May 8, 1970, a sample of the plant effluent revealed 0.12 mg/1 mercury. The company stated that the process utilizing mercury was not in use on that day. Based on this information, Allied Chemical Co. was discharging approximately h pounds of mercury per day from sources other than the reported production of disulfo intermediates. 9. The discharge from Diamond Shamrock, Painesville, Ohio, to the Grand River had a concentration of 0.010 mg/1 mercury on April 4, 1970. 10. Concentrations of 0.002 mg/1 were present in the effluents from the Ann Arbor and Wayne County-Wyandotte, Michigan, waste water treatment plants. No measurable concentration of mercury was present in six other waste water treatment plant effluents inves- tigated in Michigan (State data). Concentrations of 0.00^, 0.003, and 0.00^ mg/1 mercury were present in Euclid and Cleveland Westerly and Southerly sewage treatment plant effluents, respectively. Although no measurable concentration of mercury was present in the Cleveland Easterly sewage treatment plant effluent, which receives wastes from several users of mercury, U- rag/kg were present in Lake Erie sediments 100 feet north of the discharge point. ------- 11. On May J, 1970 a concentration of 0.011 mg/1 mercury was present in the outfall from the National Aeronautics and Space Administra- tion, Lewis Research Center, Cleveland, Ohio. This occurred during a period when there was no discharge from lagoons that supposedly receive all mercury wastes from known sources. 12. Investigations of additional potential dischargers of mercury to Lake Erie are in progress by the states and the Federal Water Quality Administration. ------- RECOMMENDATIONS 1. Surveillance and sampling programs be initiated by industries, municipalities, States and the Federal Government to locate and identify all sources or potential sources of mercury and to determine mercury concentrations in surface waters, land run-off, waste streams, aquatic life, and sediments. 2. All dischargers of mercury to surface or ground waters or to municipal or regional waste treatment plants, including Federal installations, be ordered to cease and desist. 3- Precautionary measures be taken by all users and possessors of mercury or mercurial compounds for any purpose to prevent accidental spills or other losses to the water environment. ------- INTRODUCTION The toxic effects of mercury and its compounds in the water environment are veil known and are documented in the literature. However, much remains to be learned, on toxicity limits of the various mercurial compounds in the water environment. The upper limit of mercury in food, used by the Food and Drug Adminis- tration, is 0.5 parts per million wet weight. Limits have also been set for atmospheric concentrations and numerous cases of poisoning have been reported. Critical pollution from mercury became apparent on March 2k, 1970, in the Great Lakes. Mercury concentrations as high as 5000 parts per billion (or 5 Ppm) were reported in some of the pickerel shipments from Canada and commercial fishing involved was suspended by Canada, then Ohio, Michigan and New York. The presence of mer- cury in fish and bottom sediments in the St. Clair River-Lake Erie system has confirmed the existence of an environmental problem of major scope. Mercury is discharged, to the water environment from indus- trial processes and uses of mercurial products. In 1968, mercury produced from mining in the United States was 2,19^,000 pounds. The total amount used in 1968 however, was 5,732,000 pounds. Over 163 million pounds of mercury have been consumed in the United States in the present century, but little information is available on the final disposition of it and amounts accumulated in the environment. 8 ------- 9 Metallic mercury and mercurial compounds in liquid wastes are characterized by their high densities. Free mercury and the mercurous compounds form sludges and settle to the bottom of re- ceiving waters. The mercuric compounds form precipitates with oxides, phosphates, sulfides and carbonates. The high density is responsible for the rapid deposition in bottom sediments where they persist, become subject to sediment transport and are available to the aquatic life. Metallic mercury can be oxidized readily to divalent mercury ions under the conditions present at the bottom of lakes and rivers. This has been shown to occur experimentally as well. The divalent inorganic mercury produced has an extremely strong affinity for organic muds and is biologically methylated in the bottom sediments. Divalent organic mercury, when methylated, is readily released from the sediments into the water. Many fish are bottom feeders or feed upon organisms which are bottom dwellers and therefore the hazard of mercury ingestion becomes very great. Fish also absorb mercury from the water through the gills and possibly the scales. Since biological concentration of mercury occurs, the accumula- tion of mercury in the food chain is a matter of grave concern. A recent report—' indicates a magnification or concentration of mercury of over a million in the protoplasm of bacterial species. It has been demonstrated that the concentration from water to pike is in the order of 3,000 or more.£/ ------- 10 Uses of Mercury Sources of mercury in the environment principally come from industrial processes utilizing a form of mercury and the use of mercurial products by man.f The industrial uses in 1968 are listed in the following tabled Thousand of Pounds 1. Electrical apparatus 1,^92 2. Electrolytic preparation of ., „,- chlorine and caustic soda ' 3. Paints 803 k. Charging new installations of ,-„ chlorine and caustic soda cells 5. Industrial and control instruments 581 6. Agricultural uses 260 7. Dental preparations 158 8. Catalyst preparations 1^5 9. Laboratory uses 151 10. Pharmaceuticals 32 11. Paper and pulp uses 31 12. Amalgamation (mercury alloys) 20 Mercury is used as the cathode in the electrolytic manufac- ture of chlorine with caustic soda and hydrogen as by-products. Cell recharging to make up the various losses from this process was 26 percent of the total mercury used in 1968 by all industries. To maintain the mercury inventory it required purchases of 1.3 million pounds of mercury in 1968. Weak spent brines, acids from the chlorine driers, brine sludges and cell cleanings are discharged ------- 11 to the water environment from this process. The mercury may be metallic mercury emulsion, soluble and insoluble mercury salts. In 1968, 630,000 pounds of mercury were used in the start- up of new electrolytic installations. This amount eventually contributes to the cell losses. Information from manufacturersof mercurials used for herbi- cides, fungicides and bactericides is not readily available. These compounds usually are produced in batch processes and require considerable clean up with possible losses of mercury. In the paper and pulp industry, phenyl mercury acetate is used for slime control and ground wood pulp may contain up to 20 k/ ppm of the fungicide." This mercury is either lost to the product or to the waste load during processing. In either case it becomes a waste. Large quantities of mercury are used in the manufacture of electrical apparatus and industrial and control instruments such as mercury cells, arc lights, pumps and switches. This poses a hazard of loss during the manufacturing process. Catalysts, containing 10 percent mercuric chloride are manufactured for use by the petrochemical industry. This is made by passing a water solution of mercuric chloride over carbon and is used for making vinyl chloride from acetylene. Another catalyst containing mercuric sulfate is used in processing acetylene to ------- 12 acetaldehyde. There are losses to the water environment from « these processes. Paints, those used for mildew control as well as those having anti-fouling characteristics, contain mercury, usually in the organic form. Erosion from paint films containing these com- pounds is another source of loss to the environment. Mercury is used in dentistry for the preparation of amal- gams. Minor losses may result from this use. Laboratory use of mercury in manometers, thermometers, calomel cells, standard cells and as reagents results in an occasional discharge to sewers. In large research centers or universities, the quantities can become appreciable. Minor users of mercury are the pharmaceutical manufac- turers and in amalgamation. In the pharmaceutical manufacture, diuretics and antiseptics, i.e. calomel, phenyl mercury acetate and merthiolate are made. Accidental spills are the source of loss to the water environment. The recovery of gold and silver by mercury amalgam is a wet process and may result in rather high losses of mercury in the plant effluent. Additional mercury is introduced to the water environment through the use of products containing mercurial compounds. The most wide-spread example of this is in the agricultural applica- tion of fungicides and pesticides, which results in losses during periods of run-off from the area to which they are applied. ------- 13 References 1. Minerals Yearbook, 1968, Vol. 1-11, Metals, Minerals and Fuels, Bureau of Mines, Chapter on "Mercury" by J. M. West. 2. Woods, J. M. "Environmental Pollution by Mercury," Advances in Environmental Science, Vol. II (in Print). 3. Jernelov, P. "Biological Methylation of Mercury in Aquatic Organism," Nature, Vol. 223, No. 5207, pp. 753-75^, August 16, 1969. h. Smart, N. A. "Use and Residues of Mercury Compounds in Agriculture," Residue Reviews, Vol. 23, pp. 1-36. 1968, 5. Battelle Memorial Institute, Design of an Overview-System for Evaluating the Public-Health Hazard of Chemicals in the Environment, Appendix A, 1967. 6. Johnels, A. G., et al. "Pike (Esox lucius L.) and Some Other Aquatic Organisms in Sweden as Indicators of Mercury Contamina- tion in the Environment," Oikos, 18(2): 323-333, 1967. ------- MERCURY ANALYSES IN THE ST. GLAIR RIVER. LAKE ST. GLAIR, DETROIT RIVER AND WESTERN LAKE ERIE The FWQA-Lake Huron Basin Office (LHBO) initiated a water and sediment sampling and analysis program for mercury in the St. Clair River — Lake Erie system immediately after the Canadian government announced the fishing ban in Lake St. Clair on March 2k, 1970. Sample collections were made by personnel from the Lake Huron Basin Office with assistance from the Michigan Water Resources Commission. Water samples were collected with a surface grab-sampler. Sediment samples were obtained by the use of either a Petersen dredge or a drag line sampler. These devices penetrate the bottom to a depth of about one-fourth foot. Physical properties such as odor, color, and general composition of the bottom materials were recorded. The State of Michigan reports no measurable mercury in any water supply intakes within this area. State data on analyses of 2U-hour composite samples from nine municipal waste water treatment plants revealed concentrations of 0.002 mg/1 at the Ann Arbor, Michigan, and Wayne County-Wyandotte, Michigan, plants on April lk, 1970. ------- 15 ST. CLAIR RIVER AND LAKE ST. CLAIR One water sample and 26 sediment samples were collected and analyzed from Lake St. Clair (Table 1 and Figure l). Six sediment samples in the navigation channel contained mercury in concentrations from 0.3 to 9-2 mg/kg dry weight. Two samples from a dredging dis- posal area contained mercury at concentrations of 1.7 and 2.1 mg/kg dry weight. In the other 18 sediment samples the presence of mercury was indicated, but was less than the measurable limit. The water sample contained less than the measurable limit. Sampling of the St. Clair River began on March 26, 1970. Fifteen samples of sediments and six water samples were collected between river mile (R.M.) 10.k and 37.0. Sediment samples from R.M. 37.0, 33.0, and 25.5 contained concentrations of 1.0, 0.2, and 0.3 mg/kg, respectively (Table 1 and Figure 1). The other 12 sediment samples contained less than the measurable limit of 0.5 mg/kg wet weight, but indicated that traces of mercury were present. The six water samples contained no measurable concentrations of mercury. ------- Table 1 MERCURY SURVEY Sample Analysis Results St. Glair River Sample Collection Date 1970 3/26 ri ii it 4/30 Location Ft. from River Mile U.S. Shore 10.4 10.6 10.6 17.5 17.5 17.5 35.4 33.5 31.5 29.5 27.5 23.5 21.5 19.5 Mercury Content Sediment (mR/kg) Wet Basis Dry Basis 20 1850 4120 20 1500 2700 100 100 100 100 100 100 100 100 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 „< 0.5 Water < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 <- 0.01 16 ------- LAKE HURON IASIN OFFICE MERCURY BOTTOM SEDIMENT SURVEY ST. CLAIR RIVER APRIL 1970 U.t. DEPARTMENT OF THE INTERIOR FEDERAL WATER QUALITY ADMINISTRATION • REAT LAKES RE«ION •ROSSI ILt, MICHIGAN SCALE IN MILES 2 Ortdglng DOW CHEMICAL CO. MICHIGAN FIGURE 1 ONTARIO <0.5 Wet Weight Mg/Kg Mile Points Dry Weight Mg/Kg ------- Table 2 MERCURY SURVEY Sample Analysis Results Lake St. Glair Sample Collection Date 1970 4/15 n n " n n n 4/21 M n • n n 4/22 n *• n n n n n Location Grid 18. 8N 3.8N 13. 5N 16. 5N ' 16. 6N 18. 7N 20. ON 0.4N 1.8N .3.2N ' 5.5N 7.5N 6.8N ' 11. 2N .- 11. 6N 13. 9N 17. 8N 21. 7N 21. 5N Coordinates 10. 6E 4.3E 9.9E 10. OE 7.6E 8.6E 11. 9E 0.4W 1.1E 1.7E 2.5E 2.3E 7. IE 11. 2E 2.9E . 4.8E 6.6E 9.6E 13. 4E Mercury Content Sediment (mg/kg) Water fag/1) Wet Basis Dry Basis < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.005 2L6 ------- FIGURE 2 24N - ZZN - 20N - I 8N - 4S - 68 <0.5 Wet Weight Mg/Kg (Varies from <0.6 to ------- 20 tfPPER DETROIT RIVER (LAKE ST. CLAIR TO GRASSY ISLAND) Sampling of the upper Detroit River and lower Rouge River began on March 26, 1970, and continued to April 2U. Sixteen sedi- ment and six water samples were obtained, as indicated in Tables 3 and 4, and shown on Figures 3 Qnd 4. Mercury was detected in sedi- ments along the U. S. shoreline at boat ramps and in other backwater areas. Values ranged from less than the measurable level near the headwaters to 2.0 rag/kg downstream from the Rouge River. Concentra- tions in sediments around Grassy Island and upper Fighting Island were less than the measurable limit. ------- Table 3 MERCURY SURVEY Sample Analysis Results Upper Detroit River (upstream from the Rouge River) Sample Collection Da Co 1970 Location River Kile Feet from U.S. Shore Mercury Content Sediment (mg/kg) Water Wot Basis Dry Baais 3/26 3/30 n it M 4/14 4/23 " n n " " 11 11 26.8 30.8 30.8 30.7 30.7 29.3 30.8 29.4 27.4 ' - 26.2 ^5.7 23.8 2"2.3 21.1 700 500 1000 500 980 1600 0 0 3300 2300 0 100 0 0 < 0.5 < 0.5 < 0.5 < 0.5 0.6 < 0.5 0.9 0.5 0.6 0.7 0.9 1.2 0.7 1.2 1.4 < 0, < 0. < 0. < 0, 01 01 01 01 < 0.01 21 ------- FIGURE 3 MICHIGAN DETROIT LEGEND + <0.5 Wet Weight Mg/Kg (Varies from <:0.6 to ------- Table 4 MERCURY SURVEY Sample Analysis Results ROUKO River Sample . Mercury Content Collection ' Sediment (m^/kg) Water Date River Mile Wee Basis Dry Basis (mg/1) 1970 3/26 1.1 < 1.0 < 0.01 4/23 .3 Old Channel < 0.5 11 1.5 Old Channel < 0.5 4/24 1.8 < 0.5 " 3.1 < 0.5 .1 < 0.5 23 ------- FIGURE 4 LAKE HURON BASIN OFFICE MERCURY BOTTOM SEDIMENT SURVEY ROUGE RIVER APRIL 1970 U.t. DEPARTMENT OP THC INTERIOR PEDERAL WATER OlMLITr AOMINKTRATION • NEAT LAKIf RE«ION •HOItC ILE, MICNI4AN -f- Le«s than the Detectable Limit MP2.0 Mile Points ONTARIO ------- 25 LOWER DETROIT RIVER (GRASSY ISLAND TO MOUTH) In the portion of the Detroit River from Grassy Island to the mouth at Lake Erie, 78 sediment and 23 water samples were collected between March 26 and April 16, as shown in Tables 5 and 6 and Figure 5- The highest levels of mercury occurred in the bottom muds of the Trenton Channel downstream from the Wyandotte Chemicals Corp. South Works, in a narrow strip of from 20 to 100 feet along the western shore. Concentrations along the east shore of the channel near Grosse lie were less than the measurable limit of 0.5 mg/kg. Mercury in the sediments indicates that the Wyandotte Chemicals' mercury discharge hugs the western shore of the Trenton Channel, depositing mercury in the bottom muds along shore. No mercury was present around Wyandotte Chemicals' waste beds, located on the northern tip of Grosse lie. However, one sample collected between Grassy Island and Grosse lie contained k.k mg/kg mercury. Mercury contamination in sediments was present along shore as far as Lake Erie. In addition to high values near Wyandotte Chemicals, one sample with 26.0 mg/kg dry weight was collected at the northern tip of Horse Island (Gibralter, Michigan) at mile point 6.7. Of the four samples collected at the southern end of Fighting Island, one contained 1.2 mg/kg mercury, and the others ------- 26 contained trace amounts, but all were below the measurable limit. Wyandotte Chemicals waste lagoons are located on Fighting Island. The only mercury measurable in four samples in Canadian sediments was near the shore at mile point 3-9 (0.6 mg/kg). As indicated in the tables, the levels of mercury in all water samples but one were below the measurable limit of 0.01 mg/1. One sample collected 300 feet downstream from Wyandotte Chemicals outfall W23 (RM 13.3) contained 0.03 mg/1. The effluent was diluted by Detroit River water so mercury was not measurable further downstream from the discharge point. ------- Table 5 MERCURY SURVEY Sample analysis Results Lower Detroit River (below the mouth of the Rouge River excluding _the Trenton Channel) Sample Collection Date 1970 3/27 it it n ii 3/30 n 4/6 4/8 n n ti n n 4/14 , n n n n n n n 4/16 n n n n ti ii n Location River Mile 13.5 13.3 8.4 3.9 3.9 3.9 3.. 9 ' 5.9 14.2 13.7' 13.3 12.7 15.3 16.0 14.6 16.0 16.3 16.4 16.5 16.7 18.1 19.0 16.3 14.8 13.5 13.6 15.3 17.1 16.0 15.4 Ft. from U.S. Shore 9400 8850 17,700 15,000 19,000 15,000 19,000 13,500 ' 1400 2100 2400 3200 1500 2300 1300 5500 500 0 2900 1000 0 0 9950 8200 / 7200 7700 4300 2500 3700 1000 Mercury Content Sediment (mg/kg) "Wet Basin Dry Basis < 1.0 < 0.5 < 0.5 < 0.5 0,5 0.6 < 1.0 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 1.1 4.4 < 0.5 0.7 2.0 0.5 1.7 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 0.7 1.2- < 0.5 ,< 0.5 < 0.5 < 0.5 <0.5 < 0.5 Water (mr ------- Table 6 MERCURY SURVEY Sample Analysis Results Detroit River-Trenton Channel Area Sample Collection Date . 1970 3/26 3/27 ti ii ii n ii 3/30 ii 3/31 ii it 4/1 ii n n n ' n ii n n ii M n ii 4/3 n n M n n n n n n Location River Mile 8.7 13.1 13.4 13.2 12.4 3.9 3.9 3.9 3.9 13.2 13.1 13.3 13.4 13.4 13.2 13.2 13.1 13.1 13.1 12.4 12.4 12.4 12.4 13.9 12.0 13.2 13.1 12.4 13.3 12.8 12.0 11.3 10.5 9.8 8,7 Feet from U.S. Shore 80 20 20 20 20 2500 6500 2500 6500 20 20 20 20 100 20 100 20 100 200 20 200 800 1000 0 0 20 20' 20 20 20 20 50 50 50 80 Sed iment Wet Basis <1.0 28.0 13.0 10.0 4.0 4.9 < 0.5 . 2.0 < 2.0 ' 5.0 < 2.0 25.0 6.0 < 2.0 4.0 < 2.0 < 2.0 < 2.0 < 2.0 6.0 Mercury Content (ing/kg) Dry Basis 86.0 21.0 16.0 8JO 11.0 3.0 7.0 82.0 10.0 10.0 14.0 Water4 (ma /I) < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 0.03 <0.01 •<0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 28- ------- Table 6 MERCURY SURVEY Sample Analysis Results Detroit River-Trenton Channel Area (cont.) U\Z Ui. V J- u Sample Collect! Date 1970 4/6 u n u u u n n 4/7 n n n 4/8 n u n it 4/16 4/17 n n n n 4/24 4/26 n u n n u u n Location ' on River Mile 8.7 8.7 10.2 7.9 5.4 4.7 5.8 12.0 7.6 6.7 6.3 6.3 .^ 11.6 12.0 12.5 12.8 13.4 8.6 6.7 6.7 6.7 6.7 6.3 8.3 13.0 13.0 12.9 12.8' 12.7 12.6 ,12.5 13.2 Feet from U.S. Shore 80 1240 0 300 600 . 6200 7200 20 100 150 ' 1200 3400 1150 1850 1850 1500 850 600 100 1000 2000 3000 150 0 20 20 20 20 20 20 20 20 Mercury Content r__.Se_dimant fag/kg) Water Wet Basis Dry Basis fag/1) 1.9 5.0 < 1.0 2.8 4.3 1.7 2.6 2.2 4.6 < 1.0 < 1.0 7.1 15.0 . 1.0 1.3 11.0 26.0 < 1.0 < 1.0 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 0.9 1.2 0.9 3.0 0.6 0.8 < 0.5 < 0.5 1.5 2.3 < 0.5 < 0.5 4.9 16.0 12.0 27.0 9.7 20.0 2.4 5.4 5.6 14.0 4.3 9.5 5.7 8.1 29 ------- M I C H I 6 A N WYANDOTTE FOR THIS AREA SEE LARGER SCALE MAP THIS DWG. <0.5 Wet Weight Mg/Kg (Varies from <0.6 to ------- 31 WESTERN BASIN OF LAKE ERIE, INCLUDING THE RAISIN AND MAUMEE RIVERS The sampling of Lake Erie began on April 6, 1970, with bottom sediments collected at two stations near the mouth of the Huron River (Figure 6). From April 6 to April 27, kk bottom sediment 'stations were sampled. Samples were collected in western Lake Erie, west of Pelee Island, with the majority of samples collected near the mouths of Michigan tributaries. Based on the measurable limit of 0.5 mg/kg wet weight, mercury was present at 16 of the kk stations, although traces were present at most of the other stations (Table 7). The Raisin River was sampled on two different dates at three stations (Figure 6). Traces of mercury were present; how- ever, all results were less than the measurable limit (Table 8). The Maumee River was sampled on April 17 at six stations (Figure 7), and traces of mercury were present at most stations; however, all results were less than the measurable limit (Table 9)- The 16 stations where mercury was present are located in the deepwater areas of the western basin of Lake Erie from the mouth of the Detroit River southward and eastward. Since shoreline and minor tributary samples did not contain appreciable amounts of ------- 32 mercury, the Detroit River appears to be the principal source, with mercury being deposited in the deeper quiescent parts of the lake. ------- Table 7 MERCURY SURVEY Sample Analysis Results Lake Erie Sample Collection Date 1970 4/6 M 4/7 n II 4/10 M II 4/14 4/15 4/25 n 4/27 Mercury Content Location Grid Coordinates 2.2N 2. ON 0.7N O.ON 1.3S 2. OS 2.9S 3.7S 2.8S 4.3S 5. OS 5.4S 9.6S 17. 4S 0.5N 5. IS 8.7S 9.4S 10. 7S 16. 5S 17. 4S 11. 2S 1.3S 4.3S 8.6S 14. 8S 21. 3S 23. 6S 24. 8S 6. OS 10. OS 14. OS 14. OS 20. OS 20. OS 24. OS 2.4N 0.3N 4. OS 4. OS 4. OS 14. OS 20. OS 16. OS 2.6W . 2.4W 1.3W 0.6W 4.2W 3.2W 2.2W 4.8W 5.8W 8.3W 6.4W 9.5W 11. 6W 2.4E 3.2E 2.0W 2.9E 5.7W 6.7E 9.4W 5.8W 10. 3W 2.9W 4.9W 8.1W 13. 1W 7.1W 3.5W 1.2E 0.0 0.0 0.0 8.0E 0.0 8.0E 14. OE 0.4E O.OE 8.0E 14. OE 20. OE 20. OE . 20. OE 14. OE Sediment Wet Basis < 1.0 < 1.0 1.0 1.0 < '0.5 < 0.5 < 1.0 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 0.6 0.5 < 0.5 : 0.5 < 0.5 0.8 < 0.5 < 0.5 < 0.5 < 0.5 0.8 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 0.7 0.6 0.6 < 0.5 0.5 < 0.5 < 0.5 1.0 1.0 0.9 0.5 0.5 < 0.5 < 0.5 < 0.5 (m^/kg) Water Dry Basis (mpc/1) 1.8 1.8 0.8 • 1.6 1.0 1.8 1.0 1.1 1.7 2.1 1.7 1.8 2.1 2.7 1.3 1.5 33' ------- Table 8 MERCURY SURVEY Sample Analysis Results River Raisin Sample Collection Date Location Mercury Content Sediment (mg/kft) Wa t er Grid Coordinates River Mile _Wet Basis Pry Basis (mg/1) 1970 4/10 3/30 3/30 7.6S 9.8W -0.5 < 0.5 Consolidated Paper (S) W154 1.7 < 0.5 Masoiv.Run at Ford Bridge 1.3-0.1 <0.5 W171 < .01 < .01 ------- FIGURE 6 35 ------- Table 9 MERCURY SURVEY Sample Analysis Results Maumce River Sample Mercury Content Collection Location Sediment (mg/kg) Water Date Grid Coordinates River Mile Wet_Basis Dry Basis (rn;;/lj 1970 4/17 0.5 <0.5 " 0.0 < 0.5 " 2.1 < 0.5 5.1 < 0.5 6.9 < 0.5 " 19.6S 14.5W < 0.5 36 ------- FIGURE 7 LAKE MICHIGAN -I- <0.5 Wet Weight Mg/Kg LAKE HURON BASIN OFFICE MERCURY BOTTOM SEDIMENT SURVEY MAUMEE RIVER APRIL 1970 U.S. DEPARTMENT OP TNE INTERIOR FEDERAL WATER QUALITY ADMINISTRATION • RCAT LAKES RCSION SROSSE ILE, MICHIGAN 37 ------- MERCURY ANALYSES IN THE EASTERN PORTION OF THE LAKE ERIE BASIII As part of its mercury investigations in the Lake Erie Basin, the Federal Water Quality Administration-Lake Erie Basin Office analyzed bottom sediments from the downstream portions of south shore tributaries and from the lake bottom. Tables 10 and 11 include results from the sediment and water analyses to 5-12-70 except those made at the Detrex Chemical Corp. plant. Detrex analyses are listed in a special report on that plant (Appendix II). At the Lake Erie Basin Office the lower limit of measurability of mercury in sediments is 1 mg/kg and in water 0.002 rag/1. The states of Ohio, Pennsylvania, and New York report no measurable mercury in any water supply intakes within this area. ------- Table 10 LAKE BRIE BASIN OFFICE MERCURY ANALYSES - WATER Station No. Location Date 1970 Mercury* mg/1 12 Diamond Shamrock, Painesville Influent 4/10 <0.002 Hydro discharge to Grand River 4/10 0.010 North sewer to Lake Erie 4/10 <0.002 Ik 1.59 mi. Ashtabula River (Norfolk and Western RR bridge) 4/17 ------- Table 11 LAKE ERIE BASIN OFFICE MERCURY ANALYSES - SEDIMENT Dry Weight Basis Station No. 1 ? •5 4 5 6 7 8 9 10 11 13 15 16 17 * 1 mg/kg is Location 0.53 mi. Portage Ri^er (Rt. 2 bridge) 0.0 mi. Sandusky River Tributaries emanating from NASA-Plumbrook PB-1 (Plum Brook) PB-2 (No Name Creek) PB-3 (East Branch, Pipe Creek) 0.6l mi. Black River (Rt. 2 bridge) 8.1^ mi. Rocky River 10.0 mi. Rocky River (NASA - Brookpark) 4.27 mi. Cuyahoga River (Norfolk f>- Western RR Bridge) C33-8 (100 ft. North of Cleveland Easterly STP outfall) D24-1 (50 ft. North of E. 222nd St - Babbitt Rd. sewer outfalls- Euclid, 0.) Tributary to Chagrin River (General Biochemical plant) ^1 (200 ft. downstream from plant outfall) #2 (at plant outfall) 2.85 mi. Grand River (St. Claii- St. bridge) 0.76 mi. Ashtabula River (East 5th St. bridge) 1.95 mi. Fields Brook (Columbus RR bridge) No Name Ditch East of Ashtabula (Rt 531 bridge) J41-1 (Presque Isle Bay) - — — — — — the lowest sensitivity of test 40 Date 4/14 4/14 4/10 4/10 4/10 4/13 4/22 4/14 4/10 4/13 4/13 4/10 4/10 4/10 4/15 4/10 V13 4/20 Mercury* mg/kg < 1 < 1 < 1 < 1 < 1 8 < 1 < 1 < 1 4 2 < 1 <- 1 < 1 2 < 1 8 < 1 ------- Table 11 LAKE ERIE BASIN OFFICE (cont'd) MERCURY ANALYSES - SEDIMENT Dry Weight Basis Station No. 18 19 20 21 22 23 2l* 25 26 27 28 29 30 31 32 33 Location G33-12 (20 ft. north of Detrex-Linde lakefront outfall) G33-13 (80 ft. north of Detrex-Linde lakefront outfall) 123-2 (6 mi. north of Ashtabula) H3U-2 (6,600 ft., 38°T from Detrex- Linde outfall) H3U-1 (7,000 ft., 35°T from Detrex- Linde outfall) H33-7 (5,600 ft., 20°T from Detrex- Linde outfall) 5,000 ft. north of Detrex-Linde outfall (H33-8) 3 mi., 56 T from Detrex-Linde outfall (H3U-5) h-3/k mi., 6l°T from Detrex-Linde outfall (H3U-6) 2 miles ENE of Conneaut (H36-20) Mouth of Ashtabula River (A-U) 0.96 miles Ashtabula River (A- 3) 600 ft. north of mouth of Grand River (0-5) 0.50 miles Grand River (G-U) Mouth of Black River (B-U) 1.0 miles Black River (B-3) Date U/20 V23 U/20 V23 U/22 U/22 U/22 U/22 U/23 V23 U/23 U/2U U/28 U/28 U/28 . U/28 U/28 U/28 Mercury* rag/kg < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 < 1 * 1 mg/kg is the lowest sensitivity of test ------- Table 11 LAKE ERIE BASIN OFFICE (concl'd) MERCURY ANALYSES - SEDIMENT Dry Weight Basis Station No. Location Date Mercury* mg/kg 35 37-1/4 mi., 7°T from Cleveland (123-1) Core length 0-1* inches 4-8 inches 4-12 inches 16-20 inches Composite of benthic organisms obtained from Kelleys Island Shoal and Starve Island Reef RM 0.0 Buffalo River RM 4.3 Buffalo River RM 0.0 Mauznee River RM 1.5 Maumee River S-2 Sandusky Bay - 3 miles 310° true from Sandusky Court House S-7 Sandusky Bay - 1.2 miles 10 true from Sandusky Court House RM 0.4 Cuyahoga River C-6 400 feet NW of Cuyahoga River Mouth 8/20/69 8/20/69 8/20/69 8/20/69 4/15 < 1 < 1 < 1 < 1 < 1 5/6/70 5/6/70 4/28/TO 4/28/70 4/29/70 k 1 < l < 1 < 1 4/29/70 < 1 4/29/70 < 1 4/29/70 < 1 * 1 mg/kg is the lowest sensitivity of test ------- ------- HEAVY METAIS IN THE LAKE ERIE BASIN As part of the investigations in the Lake Erie Basin, the FtfQA, National Field Investigations Center analyzed bottom sediments from various shore areas and tributaries. The results of analyses for ten heavy metals are listed in Table 12 and the sample locations are shown on Figures 9, 10, and 11. Stations were selected in the mouth of tribu- taries and immediately off-shore. Heavy metals are toxic to aquatic bottom organisms and fish when present in sufficient concentrations. Combin- ations of some of these metals such as copper and zinc have a total toxicity greater than the sum of the toxicities of each metal taken independently. Metals such as iron oxides precipitate in water and may blanket the bottom and smother bottom organisms. Toxic metals in bottom muds can be made available to the overlying water by physical, chemical or biological means. Metals may re-enter the overlying water by scouring of the stream bed because of velocity increases, by wave action, or other water turbulences. 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Following the discovery of mercury in fishes caught in Canadian waters,' the State of Michigan reviewed the mercury-using industries in the State and found that the Wyandotte Chemicals Corporation of Wyandotte, Michigan was a major user of mercury. The Michigan Water Resources Commission, after consultations with the Wyandotte Chemicals Corp., gave the following information to the Lake Huron Basin Office of the Federal Water Quality Administration. The mercury cell operation at Wyandotte consumes an average of 80 pounds per day of mercury, of which approximately 10 to 20 pounds per day is discharged' to the river. Wyandotte Chemicals bases their estimate of 10 to 20 pounds per day on composite samples collected and composited for three 8-hour periods each day. The pounds per day figures given for FWQA sampling generally indicate higher values. However, FWQA conducted grab sampling operations at the point of discharge to the river which are generally not directly comparable with composite figures when there is variation in concentration of waste throughout the day. It was also discovered from consultations with Wyandotte Chemicals that concentration varies through- out the cross section of the discharge flume. The Lake Huron Basin Office began sampling the effluent from Wyandotte Chemicals on March 27, 1970. The results are given in the following table: ------- Effluent Samples by FWQA from Wyandotte Chemicals Corp. (Outfall Code W23) Mercury Content Approx. Loading Date Day (mg/1 as Hg) (Ibs/day) March 27 30 31 April 3 6 7 8 9 10 F M T F M T W T F AM .10 .66 .33 .24 .14 .11 .12 AM .10 .66 .33 .24 .14 .11 .12 PM .32 .23 .11 .40 .11 .32 <.01 (effluent from mercury cells diverted to temporary treatment pond at 1230) 11 36 74 31 18 30 12 36 April 3 - Wyandotte Chemicals was called into the Michigan Water Resources Commission office and proposed a system of treatment which was -i- tentatively approved by the State agency. Construction began immediately Effluent pipes at the mercury cell were blocked up and a temporary above-ground piping system has been installed from that point to & large concrete-lined containment area which had formerly been used for storage of limestone. An earth dike was used to form a reaction pond area at the south end of the pond, the remainder of the pond being used as a settling area. Weak cell liquor was introduced to the pipeline to keep the pH above normal. An estimated 600 gallons per minute of mercuric chloride waste from the mercury cell was then discharged through the pipeline to a baffled timber mixing box before discharge to the reaction pond. NaHS and spent sulfuric acid were added at the mixing box before discharge to the reaction pond. After about six hours retention in the reaction pond, the effluent discharges through ------- 55 another mixing box to the settling pond, at which point cell liquor is added to bring the pH to neutral. In the settling pond, mercuric sulfide is precipitated which removes approximately 80 to 90 percent of mercury. The discharge from this pond was then discharged to a larger sewer which contained other wastes from the plant and then discharged to the Detroit River. April 10 - The above system was placed in operation. All waste from the mercury cell was diverted into the pond system. There was no detectable discharge to the river, as indicated in the following table: Mg/1 as Hg Date Day AM PM Approx. Ibs/day April 13 M < .005 0 '14 T <.005 <.005 (pond filled, 0 "'' treated effluent dis- charging to sewer at 1930) April 15-16 - Waste discharged to the river through the temporary treatment system contained approximately two pounds of mercury/day. Mg/1 as Hg Date Day AM _PM Approx. Ibs/day April 15 W .006 .026 1.8 16 T .027 <.005 (plant 1.4 shut down by State of Michigan-temporary injunction at 1620) 17 F .023 2.6 18 S <.005 ' 0 19 S <.005 0 20 M <.005 ------- 56 Mg/l as Hg Date Day AM PM Approx. Ibs/day We can probably expect small'losses from accumulations of 30 years of use. Storm runoff from roof and grounds may also contribute.) April 25 S .010 .006 0.9 26 S <.005 .005 Tr (Operation of mercury cell process was resumed. State of Michigan approved a plan of operation in which mercury waste is treated in settling ponds, then discharged to brine caverns on Grosse lie. This is a closed system; brine is pumped from the cavern to Wyandotte Chemicals for use in their processes.) April 27 M .007 . <.005 Tr 28 T .005 < .005 Tr 29 W <.005 ^.005 0 30 T <.005 ^.005 0 May 1 F < .002 < .002 0 4 M <.002 0 5 T <.002 0 6 W .003 .3 7 T <.002 0 ' 8 " F .003 .3 11 M <.002 0 12 T ------- 57 is intercepted before it reaches the river and pumped through temporary above-ground piping systems to the waste pond. . The waste pond is a concrete-lined depression formerly used for limestone storage. Earth dikes divide the pond into two areas; the smaller portion in the south end of the pond is used as a reaction area, and the remainder is used as a settling pond. The pond took longer than anticipated to fill, indicating leakage. Seams in the concrete were then filled with asphalt compound and an area along the west wall was covered with a clay blanket. These measures apparently stopped the leakage problem. The company representative informed us that under drains from the pond connect to the discharge flume at W23 and the leaks were in the settling pond area so that -• even if.leakage occurred, it would be treated effluent and would be measured at the same point as the effluent from the pond. Composite samples collected and analyzed by Wyandotte Chemicals on three shifts at a point approximately 20 feet upstream in the waste flume from the point sampled by FWQA at the point of discharge to the river are as follows. Comparison with FWQA sampling for the same day is shown. Mg/1 as Hg Approx. Ibs/day April 15 Wyandotte Chemicals Composite .027 .014 .012 1.8 AM PM FWQA Grab Samples ( .006 .026 1.8 ------- ECORSE ONTARIO IOOO ECORSE RIVER MICHIGAN WYANOOTTE CHEMICALS CORP. NORTH PLANT SCALE IN FEET IOOO IOOO 1000 WYANDOTTE WYANDOTTE CHEMICA CORP. SOUTH PLANT I I To Deep Well Disposal After April 26, 1970 Discharge to River Prior to April 16, 1970 WYANDOTTC CHEMICALS WASTE BEDS 58 V ------- FIGURE 1A LAKE HURON BASIN OFFICE SKETCH OF WYANDOTTE CHEMICALS TEMPORARY MERCURY TREATMENT APRIL 16, 1970 No Seal "r Mercury Cell Building Wyandotte Chemicals Composite Sampling Pt.— . i — Temporary Dam \ J Cone. Lined Watte Flume ^ \ 3 I • A\Pump ^"-Temporary's, Above Surface' Pipeline , tc ' tc > i • w V \ V V t «• L. I f IB^BHVIH • (Outlet ' Settling Pond t Earth Dike \|-\| 1 7 / 1 1 1 I f 1 1 1 \ III 1 1>^ Reaction Pond O a> c c o V a: c o 0 o (A O JC o - ^-Conc. Lined % Limestone Storage § FWOA Sample Pt. / W23 if Discharge "X I3.5MGD kj $ 1 ^ ^ Q 1 k ^i ^ i ^0 1 1 Uj K. Pit (Abandoned) 59 ------- FIGURE 2 LAKE HURON BASIN OFFICE SKETCH OF WYANDOTTE CHEMICALS TEMPORARY MERCURY TREATMENT APRIL 20, 1970 No Scale t Effutnf Approximate 2 Ib./day Hg 61 6 From Mercury Cell 600 GPM 20lb/doy Hg Weak Cell Liquor Introduced To Control pH Temporory Pipeline —i I Add NaHS H2S04(Spent) Setting Pond I j to 2 days Mercuric Sulfide Precipitates t Reaction Pond 6Hr Add Weak Cell Liquor to bring pH to Nuetral 60 Uj k. ki Q I 5 £ 5 ------- APPENDIX II REPORT ON DETREX CHEMICAL CORPORATION, ASHTABULA, OHIO 61 ------- PRELIMINARY REPORT OK MERCURY INVESTIGATIONS AT DETREX CHEMICAL tORPORATION, ASHTABULA, OHIO April 29, 1970 DETREX PROCESS OPERATIONS Detrex employs the mercury cell in the production of caustic soda (KaOH) and chlorine. In' this process "brine is decomposed in an elec- trolysis cell vhich utilizes mercury as the cathode and graphite as the anode. Chlorine collects at the onode and is led vith slight vacuum to the outlet end (upper portion) of the cell. Sodium immediately forms en amalgam with the mercury, the mercury being placed in a thin -layer at the bottom of the cell. The "basic reactions involved are: 2 KaCl •• 2 ife+ + 2 Cl~ • 2 Cl" •* C12 + 2e (at graphite anode) 2 Ka+ + 2e -• 2 Na (at mercury cathode) Through sn opening at the "bottom of the electrolysis cell, the sod- ium amalgam is directed to a scrubber-like tower (decomposer) vhere de- composition of 'the sodium amalgam takes place. The amalgam is intro- duced from above, through a series of graphite packings. Water is intro- duced from below and rises counter-current to the amalgam. The amalgam decomposition is affected by the formation of " a large number of short circuited cells in vhich the amalgam and graphite are electrodes and the generated caustic solution is the electrolyte. The reaction which takes place is: 2 Na (amalgam) + 2 HgO + 2 NaOH + Hg+ 62 ------- 63 The mercury which IB released from the amalgam collects at the bottom of the decomposer where It is withdrawn "by a mercury pump end returned to the electrolysis cell. Hydrogen gas, along with traces of mercury vapor, Is drawn off through a vent at the top of the decomposer end the caustic solution flows through an exit on the side near the top, as shorn in the diagram. Some trace mercury contaminated hydrogen is sold to Linde Welding. The remainder in vented to the atmosphere through steam. Steam minimizes the possibility of fire and explosion. - :v SCKEMATiC DIAGRAM OF.A MERCURY CELL"' from Blav-Knox Company - 'The Olin Mathieson Mercury Cell Process" 1963 Form No. 2?23 3M ------- • MERCURY LOSSES According to Detrex at the time of the present investigation'(l) there had been no change in recent veeks in the amount of mercury lost in the Chlor-Alkali process, (2) the present loss rate is repre- sentative of mercury losses since 1963,-and (3) mercury analyses of the discharge effluent have, in the past, "been made approximately once per month. Detrex mercury purchases for electrolysis cell make-up, according to the plant manager, amount to 8-10 flasks per month. One flask of mercury is equivalent to 76 Ibs. of mercury (mercury is 13.5 times as heavy as water). Detrex claims that all the j60 l"bs. of monthly make-up mercury doe's not find its vay to receiving waters - they claim some of it is pilfered because of its high market value (Retail $23 per Ib. - Detrex $7 per Ib.). Since Inarch k, 1970 Detrex has been making frequent analyses for —» mercury in its waste discharge, sampling at the mouth of a multiple industry used waste water drainage ditch (station No. U, attached map). Beginning April 17, the Lake Erie Basin Office has sampled daily several sites in the Detrex vicinity including station No. k, a station (No. 2) in the ditch just below Detrex containing only that company's discharges, and a station (No. l) at the Detrex sump effluent. The sump effluent is probably the source of most if not all present mercury discharge. Table 1 lists all the mercury analyses to date of samples from the above three stations. 6k . ------- TABLE 1 MSRCUBY ANALYSES OF ^TTREX EFFLUENT AND RECEr/ING WATERS Date 3-^-70 3-13-70 3-18-70 3-25-70 U-3-70 U-6-70 U-7-70 li-8-70 1- ------- TABLE 1 (Cont'd) MSRCURY ANALYSES OF DETRSX EFFLUEIIT AND RECEIVING WATERS Sta. No. k Sta. No. 2 Sta. No. 1 Date Ditch mouth Ditch beQow Detrex Sump effluent _J mg/1 Ibs/day mg/1 Ibs/day* mg/1 Ibs/day*** 5/11/70 0.006 1.2 - . 0.029 '0.5 Underlined analyses by Detrex; all others by LEBO * Data obtained from Detrex on h-lT-hd; data reported earlier by Detrex did not include fy-9-70 analyses and showed <0.01 mg/1 for U-8-and U-10-70. ** Loadings based upon 23.3 rajd ditch flo.; which includes floT/7 from Detrex, Linie ",'eldin^, and LD'IIC"? Aiv. -x-x- Loauinrs oa.re^ upon 3.3^- ~~'^- ~± "-'-•> :.:e'r-x c-/Jy. Loadings or.s?c upca 1.8? n^d froa Deurex auinp effluent only f, of Drtrex total flow) ; 66 ------- 67 Data collected by the Lake Erie Basin Office on April 10 and later (Table I) Indicate that discharges to the lake have, in fact, been sig- nificantly reduced. Loadings which had previously ranged up to 66 Ibs/ day have been reduced to less than 2 Ibs. per day. However, simultaneous data from the ditch at station No. 2 and a1\the sump effluent (station No. I) Indicate that mercury still continues to be discharged by Detrex. The data from station No. 2, which one would expect to show Intermediate values between those of the sump effluent and the ditch mouth, were in » . most cases the highest. The anomaly Is tentatively explained as being the result of the sampling technique which most likely included some of the "fluffy" sediment from the very shallow ditch waters. The compara- tively tow concentrations and loadings in the ditch mouth waters indicate ihai much of the mercury has been oGtt!!p.a out in the ditch between Detrex and the lake. Sediment analyses at station No. 2 (see Table 2) show that the ditch sediments do contain significant amounts of mercury. All mercury In water discharged frcr;. ^he^ ditch, according to th.3 Ohio Department of Health, is attributable to Detrex since LInde Air and Llnde Welding do not use or store mercury on the premises. Analyses of Llnde Air and LInde Welding effluents, as listed in Table 2, support that assumption. Three plants discharge to the waste drainage ditch. The names of those plants and their average flows, according to the Ohio Department of Health, are as follows: Detrex . 3.34 mgd Linde Air 15.84 " Linde Welding 4.I4 " Total 23.32 " ------- 68 On o yearly average, according to the Detrex plent manager, the piLant uses 2,750 gallons of water per minute or 3.9°" mgd, somewhat higher than the above listed figure. As 8 result of in-process changes to April 21, 1970, also according to the plant manager,- approx- imately hk of the total Detrex flow or 1,200 gpm (l.73 mgd) has been removed from the surnp, since it is mercury free. Beginning April 8, 1970, Detrex 'made a change in discharge practices which it claims is responsible for the low effluent mercury concentra- tions beginning April 8, 1970. Prior to this time, ell Detrex waste waters, including cooling waters, were discharged to the sump preceding the ditch that flows to the lake. The discharge change, claimed by Detrex to have been motivated by economic considerations, involved the removal of some cooling waters from the sump by bypassing the cooling waters through over-sump pipec directly to the ditch. With remove1 of the cooling voters from the cuj-.p, the detention time of the remolding > waste discharged to the"sump is increased. As a result larger quantities of suspended mercury compounds become settleable and should be removed in the sump. STATE AND FEDERAL ACTIONS On April 10, 1970, after the Ohio Health Department had determined that Detrex Chemical Corp. was s probable source of mercury discharge, a visit was made to the plant by Robert Swain, Ohio Department of Health, end Chris Potos, FWQA Lake Erie Basin Office. They met with Robert Baker, (plant manager), Robert Jones, John Kehm, and Dennis Ahistrom of Detrex Corporation. The purposes of this meeting were to learn ------- 69 specifics of the Detrex operation and to determine mercury loss rates, ' recent changes in the loss rates, end amounts discharged to waters of the state. At that time Detrex had already begun changing its opera- tions to divert "clean" vater from its mercury-containing vaste flow. On April 13, 1970 the Ohio Water Pollution Control Board issued a "cease end desist" order to the Detrex Corporation. It contained no time limit for compliance. A copy of this order end the reply to it » - ere attached. The Detrex reply, dated April 17, claimed no mercury discharge to the waters of the state. On April 17, 1970 Chris Potos end A. R. Winklhofer, FWQA Lake Erie Besin Office, met et Detrex vith Messrs. Robert Emmet, Detrex Vice Pres- ident snd Robert Baker, plant jaanagcr, end vith Mr. Robert Swain cf th» » Ohio Department of Health to determine step" taken by Detrex to elimin- ate mercury discharges to waters of the State as demanded in the State's Cease and Desist order of April 13, 197C. According to the plant manager steps taken by Detrex es of April 17 vere es follows: 1. Floor washing stopped end ell mercury picked up with vacuum cleaner since April 16, 1970. 2. Cell cleaning discontinued April 16, 1970 and no cells have been opened or cleaned since that time. Reference to 1. end 2. above— Detrex is installing B collecting tank and pump to collect floor vater, cell spent brine, cell wash water, end return it to the brine system, et which time cell cleaning will be resumed. 3. Mercury treating has been stopped completely and indefinitely. ------- 70 4. The folloving indirect cooling voter streams are bypassing the sump: fl) Hydrogen gas cooler - approximately 65 gpm (2) Wash pump seel water cooler - approximately 100 gpm [3) Brine heat exchanger - .600 gpm 5. Detrex is filtering 50$ caustic soda for the scrubber system (hypochlorite) • Detrex is actively engaged in engineering the folloving changes to: 1. Reroute the brine dechlorination condenser vater to bypass the sump - approximately 500 gpm. >• - 2. Provide a sump or catch basin for hydrogen seal pot vater, nash pump seal vater, etc., which can then be returned to the de- composer feed vater. \ 3. Provide tank, pump piping, etc. to use filtered caustic for neutralizing vaste sulfuric acid and chlorine vater. k. Construct a veir in the effluent ditch to measure quantity of flow; can be used also as » sample point. 5. Install caustic filter backwash tank. Detrex was urgently advised by Mr. Potos on April 171 1. to cease and desist mercury dis^arges to Lake Erie immediately 2. that the ditch and the multiple industry-used-settling pond were not to serve as treatment devices for mercury removal. Detrex discharges were to be made free of mercury prior to leaving Detrex property 3. to hire a consulting engineer to build a vaste treatment system to permanently free Detrex discharge waters of mercury 4. to keep FWQA and, ODH intimately informed thixnigh progress reports On April 21, 1970, Mr. Potos again visited Detrex along vith NFIC (FWQA) representatives, Messrs. John Hyland and Laurence Muir, end the Ohio Health Department's Earl Richards, James Shay, and Robert Svain, to further discuss the mercury problem and additional actions to hasten its abatement. ------- 71 On 8 yearly average, according to the plant manager, Detrex uses 2,750 gallons of water per minute, vith maximum water use occurring in summer. Based, on in-process changes to April 21, 1970, approximately kk percent of Detrex waste water (1,200 gal/min) has been determined "by Detrex to be mercury free, and es a result removed from the sump. It is a Detrex objective as of April 21 to recycle waste streams that contain mercury back to the process in an enclosed system if at all poss- ible. Optimum process operations with least possible mercury discharge are expected by Detrex in two to three weeks. If the mercury-laden streams are impossible to recycle, according to Detrex, the sump effluent will be treated as soon as a practical and economically feasible means becoiTiCC Available. According to Detrex, the best brains in the calor-alkali industry are working on the problem in a crash-program effort. If this effort does not meet with success, Dstrex h&s agreed to our demand to hire consulting chemists and engineers to solve the problem. Presently this route is not favored by chlor-alkali people since they feel they know more about mercury (production, use, treatment) than any practicing consulting chemist or engineer. The State of Ohio is in complete agree- ment with Detrex thinking in this respect. Mr. Potos mentioned to them that ion exchange and reverse osmosis are now on a practical state of the art basis. In an attempt to minimize the effect of expected seasonal increases in precipitation and consequent runoff on ditch sediment resuspension and scouring, Potos suggested that Detrex dredge the ditch from the sump to the settling pond. Detrex exceeded this request by volunteering to excavate a new ditch and complete fill in the old (see map). ------- 72 » Daring the weekend (April 18 end 19) the settling pond was "being gfven its spring dredging by Linde Welding end the Union Carbide Corp. vh'ich owns the entire area and leases segments to various industries. The pond dredging does not seem to have effected mercury concentrations at the ditch mouth approximately one mile distant, at least not through April 20, 1970. Dredgings from the pond are purportedly trucked'to State-approved land fill ereas according to the Ohio Department of Health. * The Lake Erie Basin Office has sampled stations 1, 2, 3, k, 5, 7, 8, \ 9, end 11 daily from April 17 through April 2k. Station 11 is influent to the plant. Sampling will continue less frequently efter April 2k, 1970. Table 2 lists other miscellaneous mercury sampling analyses in the vicinity of Detrex. At sampling station No. 9, east branch of the ditch, mercury presence is likely the result of "beck up vater from Detrex as •there nre no known discharges of any hini 1.0 this branch. The samples, both sediment and water, taken by the Lake Erie Basin Office ere analyzed colorimetrically by that office using Dithizone with chloroform extraction. Along with the attached map is a table of Lake Erie Basin Office analyses to date in the Detrex area, (Table 2). ------- CM W W O 1 1 hO Q W CQ W I CO H f\| CO M a) -p 0} 3= CM -a- CM -1 CM GJ -=r H -4- £ -rt ON 1 a [._ ^ 0 H -3- C 0 •H P CO' •P CQ • 05 • -P O W fe 8 0 o V H O 8 o 0 CM 1 CM 8 v ° p V CM 8 o V Q • \/ 1 a* •H H CO ^ CD "S a « CO CM CO CM CM CM O m O O Q O O O 0 0 • • • * * o o o o o V V V V CM OJ OJ O CM 8O O H O o o o o o o o o o V V CM OJ -3" OJ CM o o o o o o o o o o V ? ° ? V § CM CM O3 CM O O ITN O o o o o 9 S* V* °* 9* 8O OJ O ITN OJ O OJ H o o o o o o o o o o V V -3" CM CM OJ OJ 80 o o o o o o o o o o o o V V V V CM M3 OJ CM QJ 88880 CM Q • 1 1 1 1 \/ 1 1 1 1 1 ^ W ttj CD ft M -P O) (-4 Q i f~t 0) O CO ,fl -P C 0 Co CD -P -P fn T3 »H C O C T3 CU ft O S cd 0 J3 H j> 1 O <>j OJ JH W JS 3 C H •H 0 cd M P, ^ CJ W ("H E •r^ D fO X S 0) -P QJ CQ 'U CQ -P -P fn 6 3 ofl CQ -P -p •HO) Q) ctj fi •H • • • * » n3 ir% t-- co ON H 0) H CQ r~f r™i V V . , , 3 0) b m fn 1 ® a\ ^ 5 ^D H 15 1—1 CD & T3 £ H «j \/ co H 0 lit -P f! JS ai P -P S 3 w O O <1J a s .c o cj ^cj cj 0 0 -H •P P •H -H OO ''O 'Ci --T _c^ • CJ CH CH O -POO •H C bD T3 jG ^! O C P -P -H •H ,JS )H JH P 'O CJ O O cd H C S S3 P o; cd -H > h -P -P ft ,Q 0) CO -H ,C! (U Q) a) CJ O T3 -P CD H O -p cd to CO X! CJ C •H -* CM • O G O •H •P cd -p •H ft •H CJ 0) ft o CM _J- * 73 ------- ------- JA?•£?£> A. RiiODSS. Governor ~<;roc;o; i/:' iical'.r. •150 If.-.st To.v:. Street C«'/.u:.-.'ji;s. Or..o 43216 PUBLIC IiEAL7!i COUNCIL' Ricl.ard V. Brur.r.u:, S.D.ti. Cht.;::..ar. J. IIo\varc Kolrr.of,. ;.:.C. Vice Chair-. Ra!;>h K. Rarr-s.-iyor. M.B. J. F. V.cr.r, P'.i.G. Phillip T. Kr.iOb, '.;.D. Lloyd E. Larrick. :.'..D." J. Bruce V.'er.jcr, D.V.M. April 13, 1970 3strex CiieivL cells Industries, Inc. Chlorine -Allcali ?lan^ P.O. Box 670 Ash^abula, Ohio t^OO^ Attention: R. L. Baker, Plant Mgr. Gentlenen: You are hereby ordered to cease and desist tr.e discharge of liquid industrial waste comiainins any aecurial compounds to waters of the ' state. /.rv concentrations of mercury in th^ raw vaier used in your plant will be Baleen into cons ideraz ion in the compliance with the order. Please advise this office as to your compliance with the above order. Yours very truly, 2. W. Arnold, M.D. Director of Health C2RTIPIZ3 MAIL 75 APR 1 5 1970 .MOUST; ' • is ------- DETREX CHEMICAL INDUSTRIES, INC. » Chlorine - Alkali Plant P. D. DQX 670 ASHTA8ULA. OHIO April 17, 1970 •State of Ohio Department of Health 450 East Town Street P.O. Box 118 Columbus, Ohio 43216 Attention: Dr. E.' W. Arnold, Director of Health Dear Sir: We received, April 15, 1970, your order "to cease and desist the discharge of liquid industrial waste containing any mercurial compounds to waters of the We had -previously taken effluent water samples at our discharge into Lake Erie on April 9th and April 10, 1970. Further samples were taken on April 14th and again on April 16th. In addition, lake bottom samples east, north and west of the discharge ware taken on April 15th. ^ Using analysis methods approved by the State of Ohio, we have obtained negative mercury results on each of the above samples. In accordance with the above analytical results, we state that the Detrex Chemical Industries, Inc. Chlorine-Alkali Plant at Ashtabula, Ohio is not discharging mercurial compounds to waters of the state. Very truly yours, DETREX CHEMICAL INDUSTRIES, INC. Robert L. Baker Plant Manager :\I3/nkv ------- APPENDIX III Inventory of Industries Using Mercury in the Lake Erie 77 ------- 1 CQ £ oj cc MH •P ttJ Si « O 0 J? t> o •p 0) bD rl ,§ u CQ •H P 05" •H CO 43 CO r? £3 J3 £3 P O O 93 ?H d o H 43 65 ^-f O CU § ^ o 4> CO U CO •d C aJ ' ^S fa 0 (D g CQ 0) • bO co a -P ,3 CO 0 -rl ft H CU 0) OH d £ ^J £j ^ > CQ •H P f\ t EH to 4^ •rl O P CO OJ o a o o o -H 08 w 43 a •H a o O iH N 3 g p 43 ° aj fe £ . 4> 0 0 ^s 0) 0 § o 1 CO a 0 •d • C CQ a) fn 0 CO 4> a) o iH T^ ^ o CO 4J CO ti CQ bDH H ft p^ ^^. ^ 1-1 -.8 d < 11^ H O 4i" < -* 2 elS 78 o 45 a 0) CQ •d § b" o f"i a) a 0) . bO co J81S O -H ft C 0) 0) K -d •d § <H CO o o) co •H 0) CQ H bD fa a & O ft bO 4^ 3 4^ 3 CQ 0) C rl Cd CO ft -p -p CO -H CO C d> 0 •H CU ^H O* P Tf (^ 4> •rl -H O O -P -P h j^ o) CO 9) O* O !>> H CO • V£> ft CO Td H p4 CVJ ^ OJ co ^ W31 H " EH 03 4^ O -H M -H CO CO O • O •H CO rl O CT\ rl >rt CO 43 -* 4> O LfN 4) • t— CU S H P W H P . M „ •H •§ & ^ ^> o OJ cu . rl ? 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O O O O fi rH >• 0 0 O 00 . » > 4) 4) •rl /^ i-l r. 4> rl /-» HO H /•» O M O d 4) C O C Q Jd O «M O 8 S • S -IS ; pq pq o col _j _j .43 d •rl ^\| S r-l ft •rl •o .* 0 (4 •P ID d * rjfi C •H W M 01 O 2 o. rH O o. i CQ 0 ft i •s report* N >» rH M Jj O •rl (D rl 0. d M O •P (A 4> O a d rl » O 4> •o 8 o •M ^5 •H M O •P O r-l- o rl •H 43 ------- , oo a. O o o c « 9 i— <. O O o t o f 0) 3 o .2 T3 0) I -o o "8 :> N •.»- 511 »S £ .< vy o. -S 0 O) c - (3 ^^_ "'* O* trt '3 ;--S > > o o -C " «T -• c r-l • ? O . 1 O t» 04 , t O 00 M > •H X h m W 3 O fS ^ rt H O ' "H rt- > ^3 Q) \|H iH CD rH O rt 4-> > CO X 0 co M m in • I • • MS 6 • w C9 CO rH W • M • C4 00 1 rH rH rH 00 C6 Ct CO O O H H H O CO 0 rH • rH O O o t- t- X ' O* 0 CO CO CO ^ s ^4 2* ^JJ ri cn Vi c CD M 3 Ct3 O O •0 - W Vi _ ^S rt X rt O rt co rt cs g rH OH M o i-i S3 W W. - H~ x-N CD fl»' o rt ^j ^ ^rt_ f^ ^j •H . ' -rl 4-> rH -rl bO'rH TJ -D 4J rH -D C rH W W 3 -rl W -rl -rl 03 «H CO VI (A M rt CD « « (D CD -V •H H +> rH rH -H rt rt 45 Ql * * . «M VI o 1 rH •H rt « •o. rt o m •k •a •CD £ •a c rt T3 V I * O PC * • •• 4) rH £> •rl •o 6 .2 •H CD. 10 rt g: fi •H (Q M CD O 0 a M rH v ** CD +* (Q 4J (3 CD (A CD Vi a Vi • o jz; CD •o O 0 CD A G •H Vi CD CD rH •rt £4 •H A 4-> CD A H W O rH a § << C0\| ------- APPENDIX V STANDARDS FOR MERCURY AND HEAVY METALS LAKE ST. CLAIR - LAKE ERIE DRAINAGE AREA ------- FEDERAL-STATE WATER QUALITY STANDARDS AMD USPFS , / DRINKING WATER STANDARDS FOR MERCURY AND HEAVY METALS-7 -LAKE 'ERIE-LAKE ST. CLAIR DRATOAGB AREA The National Technical Advisory 'Committee on Water Quality Criteria 'states: "Surface waters should be free of substances attributable to discharge^or wastes as follows: materials, including radionuclides, in concentrations or combinations which are toxic or which produce undesirable physiological responses in human, fish and other animal life, and plants." Specific nuraberical criteria for toxic sub stances have been included in water quality standards as follovrs: State Metal Indiana Cadmium Chromium (hexavalent) Lead Silver All Toxic Materials Michigan Chromium (hexavalent) New York - No Specific Criteria Ohio Cadmium Chromium (hexavalent) Lead Silver Iron (certp.in rivers on Ohio-Pa, border only) A31 Toxic Materials Criteria Values in mg/1 0.01 0.05 0.05 0.05 2/ 0.1 96-hr TLn£' 0.05 0.01 0.05 0.05 0.05 1.5 0,1 18-hr TLm Use Classification to Which Applied Water Supply Water Supply Water Supply Water Supply Fish & Wildlife Water Supply Water Supply Water Supp.ly - Water Supply Water Supply Water Supply Aquatic Life end Recreation Pennsylvania Manganese Iron (Total ) Iron (Dissolved) 1.0 1.5 0.3 All User, All Uses All Uses !_/ Heavy metals considered: cadmium, chromium, copper, iron, lead, manganese, silver, and zinc. 2/ The TLm is the concentration of a toxJf; mateHsl wM.ch produces death to one -ha If of the test orcnrisur; in a bio?.r,say test within a specified length of time (e.g. U8 hours or $6 hours). 93 ------- APPENDIX VI CHRONOLOGY OF EVENTS ------- CHRONOLOGY OF EVENTS March. 24, 1970 i The Canadian Federal Department of Fish and Forestry banned the sale and export of fish caught commercially within the Canadian bound- aries of Lake St. Clalr because concentrations of mercury In some of the fish made them unfit for consumption. The decision was made as a result of a research report which showed pickerel caught In the lake contained as much as seven parts per million mercury (ppm). Subse- quent laboratory reports Indicated a somewhat lower figure of 1.36 pprn which, however, is still almost three times as great as 0.5 ppm level considered acceptable for fish procured for export by federal food and drug authorities In both Canada and the United States. The Ontario Water Resources Commission Identified one Dow Chemical of Canada Limited chlor-alkalf plant at Sarnia, Ontario as the source of mercury pollution to the St. Clalr River, FWQA Regional Office learned from Mr. Ralph Purdy, Executive Secretary, Michigan Water Resources Commission, that he had written letters to chlor-alkali plants in the state to find out who was using mercury cells. He reported that the Wyandotte Chemical Company on the Detroit River uses mercury cells and that he was conducting discussions with them to learn about the disposition of their mercury bearing wastes. March 26. 1970 Coordination achieved with Michigan agencies, Ontario Water Resources Commission, Bureau of Commereia! Fisheries, and Food and 95 ------- 96 Drug Administration. FV/QA* Lake Huron Basin Office Initiates a water and sediment sampling program for the St. Clalr River, Lake St. Clalr, Detroit River, and Western Shore of Lake Erie. Advised that Field staffs of the Bureau of Commercial Fisheries, Great Lakes Fisheries Laboratory, Ann Arbor, and the Department of Natural Resources, would be conducting a fish sampling program and that arrangements were being made for the Wisconsin Alumni Research Foundation (WARF), Madison, Wisconsin to analyze the fish samples. Learned that the Michigan Health Department and the Michigan Water Resources Commission were getting samples from water Intakes, treatment plants and Industrial outfalls for analyses of mercury at the Lansing laboratory. March 27. 1970 FWQA Lake Huron Basin Office begins collecting water and .-.. .• '••••.•. '".. sediment samples from the Wyandotte Chemical plant. ' ' April 2, 1970 Regional Director, GLR, chaired an. Informal meeting at FWQA Headquarters, Washington, D. C., with Bureau of Commercial Fisheries, Bureau of Sports F.Isheries and Wildlife, Food and Drug Administration, and Ontario and Canadian Federal representatives. The meeting was called to obtain a better understanding of the mercury problem and ' to exchange information. It was the consensus of the representatives present that the mercury problem is serious and of international con- -cern. It was also agreed that an inventory of mercury uses to determine waste concentration was needed and that sampling should continue In order that the problem may be completely defined. ------- • . 97 J\pr11 8, 1970 • v • - .Governor Ml I liken of Michigan advises sportsmen not to eat fish caught from Lake St.- Clalr and the Detroit and St. Clalr Rivers. April 10J 1970 . ' .- . " . t I A meeting of Ontario, Michigan, and Ohio representatives was held In Toronto, Ontario to share Information and explain how deci- sions were reached for Ontario to place a ban on fishing In Lake St. Clalr, St. Clalr River, and Detroit River. Federal people from Canada and'the United States were Invited as observers. Mr. O'Leary of the Lake Huron Basin Office, represented the FWQA Great Lakes Region at the meeting. Rperesentatlves of all agencies agreed that sampling and testing must continue In order that the problem may be completely defined. • ..' • • . Mr. Kerr, Federal Energy and Resources Minister, described . f * the action that has been taken to halt any further mercury discharge from the presently known source of pollution on the Canadian side of the boundary In this area, and Governor Mllflken stated that he had received an assurance today that the presently known source on the Michigan side had today Instituted procedures to eliminate future mercury contamination of the water from Its facility. It was agreed that future action will be taken In a coordinated way so tnat all involved agencies may take similar action. The representatives of the States of Ohio and Michigan agree with those from Ontario that a ban on fishing in Lake Erie Is not ------- 98 . • * . • Indicated at this time. Their respective agencies agreed to ' • 4 ' • 'exchange Information from their sampling and testing programs. * * • Governor MI I liken announced the* following actions and agreements: I. Michigan will Institute proceedings to close Lake St. Clalr and the St. Clalr River to all ftsntng as a precautionary measure pending further study; • . ; 2. Michigan, Ontario, Ohio FDA and the U. S. Federal Water * • i ' * ' Quality Administration agreed to cooperate In developing further Information on the Detroit River and Lake Erie; 3. Participants In the meeting agreed to continue and accelerate efforts to eliminate mercury contamination from all sources; .4. All parties agreed to consult with various other authorities prior to taking actions affecting waters of the Great Lakes; • . ^ 5. AlI parties agreed to participate, with other author- ities. In Investigating additional dangerous substances as to kinds, amounts and effects; 6. AlI parties agreed to recommend the convening of a conference of the Governors and Prime Ministers of the Great Lakes States and Provinces; •7. .Al! parties agreed to urge all respective federal bodies ''to Initiate actions to Investigate sources of mercury contamination In alt states and provinces. ------- 99 .. - Ohio Department of Health determines Detrex Chemical Company • " ' * • * • of Ashtabula, Ohio a proba'ble source of rrsrcury contamination. RVQA Lake Erie Basin Office, Cleveland Initiates a water sampling program In Lake Erie and tributaries and participates in an Inspection of the Detrex Chemical Company plant. Uyandotte Chemical plant ceased mercury waste discharges to the Detroit River at.12:30 p-.m. Mercury enriched waters are now being discharged In holding facilities for chemical treatment. April 13, 1970 Governor Rhodes of Ohio announced a ban on commercial fish- Ing In Lake Erie. Ohio Water Pollution Control Board issued a "cease and desist" order to Detrex Chemicals Company. FV/QA Lake Huron Basin Office personnel met with Michigan State officials. The MWRC agreed to supply one man to aid In the field work collecting sediment samples and to share duplicate samples for verification purposes. MWRC to continue sampling effluents In the area. April 14. 1970 FWQA Great Lakes Region Basin Offices provided with a list of chlor-alkali plants and asked to Investigate as sources of possible mercury pollution. April 16. 1970 # " The Wyandotte Chemical Company was Issued a court order to cease discharges of mercury wastes In any form or amount. The plant ceased operation of the mercury cell room at 6:20 p.m. ------- 100 April 21, 1970 Secretary of the Interior Walter J. HIckel announced his Department Is Initiating a massive campaign to clean up Lake Erie, as a result of reports of lethal .discharges of mercury Into the Lake and Into the Detroit River which empties Into Lake Erie. In a series of steps, Secretary HIckel announced taking the following action: — An enforcement conference on Lake Erie will be reconvened In Detroit, followed by enforcement workshops In Toledo, Cleveland, Loraln, Sandusky, and Ashtabula, Ohio; Erie, Pennsylvania; and » Lackawanna, New York. ' ~ The Secretary's special investigative task force has been assigned to obtain firsthand ijp-to-date data on the entire water pollution problem in the Lake Erie watershed. ••''." — - . . . •' t?*}>fr~-,-._ • - — Increased monitoring and research will be Initiated at the Fish and Wildlife Service's Great Lakes Fishery Laboratory at • Ann Arbor, Michigan, on the toxlcity of mercury and other metal com- pounds and their effect on fish and other aquatic life. — The Fede'ral Water Quality Administration has been directed to Identify and prepare a list of all toxic substances now being discharged in waters throughout the United States. April 23, 1970- Assistant Secretary for Water Quality and Research, Carl Klein, directed the Commissioner, FWQA, to take necessary Immediate action to translate the Secretary of the Interior's announcements of April 21 ------- 101 Info positive action.- Ha also asked that the Task. Force assigned • • • "4 * to obtain firsthand up-to-date data on the entire vzater pollution • / problem In Lake Erie and coordinate with. Michigan, New York, Ohio and Pennsylvania. April 29, 1970 • * Prime Minister John P. Roberts of Ontario called a conference for June to discuss pollution problems In Lake Erie. The Prime Minister Invited the Prims Minister of Quebec and the Governors of Illinois, Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania and Wisconsin. ' ' - April 30, 1970 . -- Governor Rockefeller of New York announced that the Department of Agriculture and Markets began placing all fish caught commercially In LaKe Erie under seizure to'.protect consumers from mercury contamlna- . tlon. The Department of Conservation advised sports fishermen against eating fish taken from Lake Erie. This action was taken after analysis of several New York fish samples showed levels of mercury In excess of 0.5 ppm considered acceptable for sale by the Food and Drug Admin- istration. The Governor announced that the State Health Department also had tested drinking water taken from Lake Erie and that It had been found fully safe for human consumption. Staff members of the FWQA Great Lakes Region met with members of the Secretary of the Interior's Task Force to develop plans for action required to Implement the Secretary's announcement of April 21. Recommendations for appropriate, field investigations and research projects v/ere developed for Headquarters' consideration. ------- 102 May 1, 1970 The State of Ohio rejected 11,300 Ibs. of fish caught in Ohio " waters of Lake Erie because of high levels of mercury (greater than 0.5 ppm.) The rejected fish were from 8 commercial catches of 5 fisheries and were primarily white bass, sheephead and catfish caught in the western basin and the western end of the easterly basin of Lake Erie. The samples analyzed consisted of UOO fish and contained mercury ranging from 0.51 to 0.6k ppm. The State of Ohio made the analysis. May k, 1970 Governor Warren Knowles of Wisconsin issued a 30-day emergency order closing 35 miles of the Wisconsin River for fishing due to mercury contamination. The Wisconsin Department of Natural Resources issued a cease and desist order to Wyandotte Chemical Corporation of Port Edwards to halt the discharge of mercury laden wastes into the Wisconsin River. The Assistant Commissioner for Enforcement FWQA was requested by the Commissioner, Erie County Department of Health to conduct an extensive water and bottom sampling program for toxic materials and substances not only in the western basin but throughout Lake Erie. The Commissioner also requested a re-evaluation of the 19^7 compliance schedule to determine whether any of the municipalities and industries not in compliance are contributing toxic discharges. May 5, 1970 A representative from the Ohio Department of Health visited Reactive Metals Inc., Metal Reduction Plant in Ashtabula , Ohio to ------- 103 obtain information pertaining to mercury discharges. Samples from the plant effluent and receiving tributary were collected for analyses. May 6, 1970 Representatives from the Ohio Department of Health, and FWQA., Lake Erie Basin Office, either visited or contacted by telephone the following industries to obtain information regarding mercury usage: Bailey Metal Co., Wlckllffe, Ohio General Electric Co., Cuyahoga Plant, Cleveland, Ohio General Electric Co., Large Lamp Engineering and Pilot Plant, Cleveland, Ohio Standard Oil Co. of Ohio, Cleveland, Ohio The FWQA, Lake Erie Basin Office collected sediments samples from the Buffalo River for mercury analyses. An effluent sample from the Cleveland Easterly Sewage Treatment Plant was obtained for mercury analysis by Lake Erie Basin Office. May 7, 1970 Representatives from the Ohio Department of Health, and the FWQA. Lake Erie Basin Office visited the following industries to obtain in- formation pertaining to mercury usage: National Aeronautics & Space Administration, Lewis Research Center, Cleveland, Ohio Lincoln Electric Co., Cleveland, Ohio General Electric Co., Powder & Wire Plant, Euclid, Ohio General Electric Chemical Products Plant, Cleveland, Ohio M&y 8, 1970 Regional Director, FWQA. Great Lakes Region presented testimony ------- on mercury contamination in the Great Lakes to the Subcommittee on • Energy, Natural Resources and Environment of the Senate Commerce Committee at Mount Clemens, Michigan. Secretary of the Interior announced that the fifth session of the Lake Erie Enforcement Conference would be held on June 3, 1970 at Cobo Hall in Detroit, Michigan. Representatives from the Ohio Department of Health and the FWQA Lake Erie Basin Office either visited or contacted by telephone the following industries to obtain information pertaining to mercury usage: Union Carbide Corp., Electronic Components Div., Cleveland, Ohio Union Carbide Corp., Carbon Products Plant, Cleveland, Ohio Union Carbide Corp., Edgewater Works, Cleveland, Ohio I. Miller Inc., Cleveland, Ohio Merian Instrument Co., Cleveland, Ohio Schuemann-Jones Co., Cleveland, Ohio B. F. Goodrich, Avon Lake, Ohio E. I. DuPont de Nemours Co., Cleveland, Ohio Representatives from the New York State Health Department and FWQA, Lake Erie Basin Office visited the Allied Chemical Co., Buffalo, New York Dye Division, to obtain information on mercury usage. The New York State Health Department requested the Allied Chemical Co. to minimize the discharge of mercury and to report immediately of their steps for compliance. May 9, 1970 Allied Chemical Corporation of Syracuse, New York diverted their ------- 105 mercury bearing vastes to their settling ponds. Previously wastes were discharged to streams flowing into Onadaga Lake. The settling ponds "being used for mercury wastes may still, however, overflow into streams flowing into Onadaga Lake. May 11, 1970 A representative from the Ohio Department of Health contacted by telephone the following industries to obtain information pertaining to mercury usage: Barshaw Chemical Co., Cleveland, Ohio Bellows Electric Co., Akron, Ohio Effluent samples from Detrex Chemical Co., Euclid Sewage Treatment Plant, and Cleveland Westerly and Southerly Sewage Treatment Plant were obtained for mercury analyses by FWQA Lake Erie Basin Office. The Director, Lake Erie Basin Office notified the Regional Director, Great Lakes Region, that the Allied Chemical Co., Buffalo, New York is a source of mercury in the Lake Erie Basin. He recommended that New York State Health Department issue a desist order. Wayne C. Bellaman, Regional Sanitary Engineer for the Pennsylvania Department of Health, announced the following: 1. Declared that concentrations of mercury in the waters of Lake Erie used for municipal and industrial water supply by the City of Eire are within the limits safe for domestic and industrial use and consumption. No concentrations of mercury in excess of 0.005 mg/1 were found in samples of raw water collected from both of the City water works. ------- 106 2. Selected municipal and industrial waste discharges were sampled, including the effluent from the City of T^rie Sewage Treatment Plant and the Hammermill Paper Co. No concentrations of mercury have been confirmed in these discharges in excess of those from the waters withdrawn by the City of Erie and the Hammermill Paper Co. from Lake Erie. 3. The Erie County Health Department has been assisting in this investigation by checking hospitals and industries connected to the Erie sewer system. No potential major sources of mercury are known to exist within the Erie portion of the Lake Erie Basin. k. Assured that if mercury is found in any of the waste discharges in excess of 0.005 mg/1. enforcement action will be initiated immediately to require immediate and complete abatement. 5. No mercury has been found in the tissue of fish collected from Lake Erie in excess of 0.5 mg/1 limit set by the Federal Pure Food & Drug Administration and the World Health Organization. May 13, 1970 Ontario and Michigan officials met in Toronto to reconsider the fishing ban and arrive at an agreement for possible reopening of fish- ing in Lake St. Clair, Detroit, and St. Clair Rivers. It was agreed that a catch and release restriction be imposed by both governments which will make possession of fish illegal. Effluent samples from the National Aeronautics & Space Admini- stration, Lewis Research Center, were obtained for mercury analysis by FWQA., Lake Erie Basin Office. ------- 107 May lU, 1970 Ontario Officials announced the reopening of sports fishing in Canadian waters of Lake St. Clair and the St. Clair and Detroit Rivers. No catch and release restrictions were imposed; however, warnings on the eating of fish were made. May 1$, 1970 Governor Milliken of Michigan announced that a statement will be issued next week on Michigan's decision to relax the sports fishing ban on U. S. waters of Lake St. Clair and the St. Clair River. Officials of the New York State Conservation Department closed all fishing in Onondago Lake at Syracuse because of mercury contami- nation. The State Conservation Department also recommended that fish caught in Lake Ontario and the Oswego River not be eaten. The Wisconsin Department of Natural Resources held a public hearing concerning Wyandotte Chemical Corporation of Port Edward's discharge of mercury wastes to the Wisconsin River. Regional Director, New York State Health Department, Syracuse, sent a telegram to Allied Chemical Corporation, Solvay, New York asking the Corporation to present the Department of Health a defi- nitive time schedule for complete elimination of mercury from their liquid waste discharge. Allied Chemical was asked to respond by May 25, 1970. Similar instructions were transmitted to Olin Mathie- son Corporation of Niagra Falls, New York. The Olin Mathieson Corporation was asked to meet with State Officials to discuss a suitable time schedule. ------- 108 Representative from the Ohio Department of Health and FWQA, * Lake Erie Basin Office visited the General Electric Company, Cleveland Lamp Plant, to obtain information pertaining to mercury usage. A representative from FWQA, Lake Erie Basin Office visited the General Electric Company, Bucyrus Lamp Plant,to obtain information pertaining to mercury usage. Effluent samples from General Electric Technical Products Plant were obtained for mercury analyses by Lake Erie Basin Office. The Regional Director, Great Lakes Region, advised the Deputy Commissioner, New York Department of Health, of findings pertaining to Allied Chemical, Buffalo Dye Division, and requested to be kept abreast of any enforcement action that may be pending. The New York Depart- ment of Health requested Allied Chemical Company to submit a schedule to eliminate mercury discharges. May 18, 1970 Representatives from the FWQA, Lake Erie Basin Office, Ohio Dept. of Health, and the NFIC, Cincinnati, met in Columbus, Ohio to exchange mercury data. May 19, 19TO Representatives from FWQA, Lake Michigan Basin Office and Illi- nois State Sanitary Water Board visited the Monsanto Company of Sauget, Illinois to inspect plant operations and sample plant effluent and sludge from the brine reaction tank. ------- 725 A. M. Shannon MR. STEIN: All right. Any comments or questions? (No response.) I didn't want to belabor the point, but when they talked about detectable limits, they talked about all below 5 ppb. And you were 500 percent lower than that for your detectable limit on 1 ppb. That is a big spread. All right, thank you. Any comments? (No response.) Mr. Purdy, did you have someone else? MR. PURDY: Dr. Shannon from the Detroit Water Bureau would like to be heard. STATEMENT OF ALBERT M. SHANNON CHIEF, WATER AND WASTEWATER TREATMENT DETROIT METRO WATER DEPARTMENT DR. SHANNON: Mr. Chairman, conferees, ladies and gentlemen, my name is Albert M. Shannon, and I am chief of Water and Wastewater Treatment for the Detroit Metro Water Department. I would like to make a brief statement on the results of our monitoring program for mercury, both at our two raw water intakes and on the incoming raw sewage and the plant effluent at our sewage treatment plant. One of our intakes, the Waterworks Spartan plant, ------- 726 A. M. Shannon r is indicated on the upper end of Belle Island, the upper Detroit River. The southwest intake is located off the northern tip of Fighting Island in Canadian waters. And that is in the lower Detroit River. To date we have determined the mercury in 36 daily 24-hour composite samples, also 12 weekly composite samples, making a total of 48 samples. And to date, we found no measurable quantities of mercury. And the limit of our accuracy sensitivity is 2 parts per billion. Now, since May 11, we have run daily 24-hour composite samples of raw sewage and also the plant effluent. And that is 25 samples of raw sewage and 25 samples of plant effluent. And none of these samples showed the presence of detectable quantities of mercury. And, again, here the limit is 2 parts per billion. That's all. Thank you. MR. STEIN: Two parts what? DR. SHANNON: Two parts per billion. MR. STEIN: O.K. Thanks. Did you ever find mercury in your drinking water here? DR. SHANNON: No, none at all. MR. STEIN: But again, you see what we have had here. We are up with the third figure — 5,2 and 1. And ------- 727 A. M. Shannon I think my suggestion is that we try to get together on this if we haven't gotten together yet. And I ask Mr. Van Den Berg to do this because we are getting out the report. We should make a proposal for what we think is the detectable limit that we are going to go down to, and if you don't find you have a consensus on that, you better get together with the other people who are doing these tests and come up with something that you can agree on. Because unless you have this, we are never going to get the program off the ground. I say this, not only for mercury, but we are going to have to do this for every toxic substance if we are going to deal with it. MR. LYON: I think if we are going to do this, Mr. Chairman, we should not, I suspect, be only concerned with the detectable limit, but also the range of accuracy of the test of the detectable limit. MR. STEIN: I think that is one of the big factors. I think the ability of everyone to do the test and the accuracy of the test are two of the factors which go into what we universally say is the detectable limit. MR. LYON: Because we found with our fish, there was a 3-to-l relationship between two laboratories of the FDA — one in Cincinnati, one in Chicago. So it isn't merely ------- 728 R. W. Purely «r a question of detectable limit, but also a question of the accuracy of the test. MR. STEIN: These are the issues. By the way, don't think this is anything special because we have had this over and over again in every other substance—every other thing we have dealt with in this field. Not only have we had it, Food and Drug has it, and everyone else has got the same problem. But, gentlemen, this just has to be worked out if we are going to move. Are there any other questions or problems? (No response.) If not, thank you very much, sir. MR. PURDY: Mr. Stein, I have passed out a state- ment to all the conferees and to the stenographer, that I would like to have placed in the record as if read. It covers the mercury contamination problem here in Michigan and the action that we have taken on it. There are cer- tain parts,in view of Mr. Atwood's statement yesterday^that I would have liked to have gone over in detail. But because of the lateness of the hour, I think I will pass it up. But I do not agree that State and Federal officials knew about it and didn't take action on it. This was a matter of where the mercury problem was not recognized. As soon as it was recognized, action ------- 729 R. W. Purdy was taken on it. Mr. Atwood didn't say it as a part of this report, but I noted it in the paper. It stated the State agencies failed to take action until the newspapers forced them to do so. Again, I do not agree this is the case. And my statement will show that it was not. MR. STEIN: Without objection, that will be entered into the record as if read. (The above-mentioned statement follows in its entirety.) ------- 730 STATEMENT OF R. W. PURDY, EXECUTIVE SECRETARY MICHIGAN WATER RESOURCES COMMISSION Regarding Mercury Contamination Problem June 3, 1970 I am pleased to have this opportunity to discuss the problems of environmental contami- nation by mercury compounds. We are very concerned over this matter and the State of Michigan has placed high priority on fully investigating and dealing with the problems of mercury contamination. The recent mercury contamination problem in the Lake St. Clair - Detroit River area came as a near total surprise, without warning or anticipation. It seems that nobody recog- nized the problem of mercury contamination in the United States prior to the emergence of certain problems within the last year. In view of the limited, although catastrophic world experience with the problem, the lack of knowledge and apprehension over mercury throughout the United States at both State and Federal levels is a complete paradox. In spite of the history of mercury contamination, the problem was largely unrecognized in this country. The pollution problems of the St. Clair River, Lake St. Clair, the Detroit River and Lake Erie have been thoroughly studied and extensively documented. In April of 1965, the U.S. Public Health Service of the Department of Health, Education and Welfare, now the Federal Water Quality Administration, with the cooperation of the Michigan Water Resources Commission, completed an exhaustive report on the pollution of the Detroit River, Michigan waters of Lake Erie, and their tributaries. There was no mention of mercury problems in that report. The State of Michigan is also actively participating in the Lake Erie Federal-State Enforcement Conference and in the pollution studies of the International Joint Commission. The possibility of widespread mercury contamination has never been considered in these studies until the last two months. We have on many occasions collected and analyzed samples of the wastewater effluent from the Wyandotte Chemical Plant which was until recently discharging mercury compounds in its wastewater. This testing was undertaken in the development of an appropriate water pollution control program for this plant. The mercury levels of this discharge were never considered since the need was unknown. In April, 1968, the report of the National Technical Advisory Committee on Water Quality was published by the Federal Water Pollution Control Administration. This document was considered the most comprehensive document on water quality requirements at that time. It was the work of 5 subcommittees involving some 90 experts in the field of water pol- lution. There was only a very brief mention of mercury and there was no indication of its possible significance. In this discussion, my point is not to justify our own lack of knowledge about mercury contamination of the environment but rather to emphasize a gap, a rather serious gap, in our present environmental protection programs. The current mercury crisis developed almost overnight without warning; however, the contamination has apparently existed for some time. I strongly believe that we must take appropriate steps to ensure that any similar problem is recognized and countered in the early stages before serious damage results. ------- 731 We first became aware of the possibility of mercury contamination in the Great Larkes at a meeting on February 11, 1970 in Toronto, Canada of the International Joint Commission's Advisory Board on Control of Pollution of Boundary Waters. At that meeting, Canadian officials indicated their concern over the possibility of mercury contamination and re- ported that studies were underway. The following day, we began to investigate possible sources of mercury. Of the three chlor-alkali plants in Michigan, we found one which used mercury in its process. This was the Wyandotte Chemical Company plant on the Detroit River. Subsequent investiga- tions revealed that this plant was discharging with its wastewater 10 to 20 pounds of mercury per day. At the time of initial contact with the Wyandotte Chemical Company, the full impact of the mercury problem was not yet known. Company officials were cautior about the possible pollution problem and were asked to ascertain the exact amount of mercury being consumed and lost. The Company was also advised to begin an immediate study of ways to abate the discharge of mercury. Later in March, laboratory analyses of fish from Lake St. Clair area waters conducted by a California laboratory were received by Canadian officials and because of high levels of mercury residues, 12,000 pounds of fish caught in Lake St. Clair were seized by Canadian officials. Two weeks afterwards, Ontario banned all fishing on the St. Clair River, Lake St. Clair, and the Detroit River. A series of steps were instituted to evaluate the level of mercury in the environment and to pin-point possible sources in the Lake St. Clair-Detroit River area and in the rest of the state as well. Fish samples were collected by the Department of Natural Resources from Lake St. Clair for analysis by the Detroit Office of the Food and Drug Administration. Later, fish from throughout the state were collected for testing by the Food and Drug Administration and the Michigan Department of Agriculture. We endeavored to enlist the cooperation of all laboratories in the area as quickly as possible. We found that only the Food and Drug Administration could readily undertake mercury analysis. Arrangements were subse- quently worked out for the analysis of various samples with the Federal Water Quality Administration's Grosse lie (Michigan) laboratory, the Wisconsin Alumni Research Founda- tion's laboratory which was under contract with the Bureau of Commercial Fisheries, the Phoenix and School of Public Health laboratories of the University of Michigan, and the Dow Chemical Company at Midland which offered its assistance. Arrangements were also made to cooperate with the Ontario Water Resources Commission and with the Ohio Department of Agriculture. In succeeding days, the following additional steps were taken to further define the mag- nitude and scope of possible mercury contamination throughout the state: a. The Michigan Department of Public Health undertook to immediately test all public water systems using the St. Clair River, Lake St. Clair, or the Detroit River as a water supply source. A sampling program of domes- tic water supplies in this area continues on a weekly basis and will re- main in effect as long as considered necessary. ------- 732 b.- To identify other uses of mercury or mercury compounds, all 35 pulp and paper mills in Michigan were contacted by telephone. In addition, letters were sent to some 700 industries, commercial establishments and individuals requesting information on the use of mercury and also on the use of arsenic, cadmium, lead or any other heavy metal. Response to this request has been good and information continues to be received. c. Arrangements were made for the analysis of wastewater samples from some three dozen municipal sewage treatment plants throughout the state which treat industrial waste and might therefore contain mercury in their dis- charges. d. Bottom sediment samples were collected at the mouths of major rivers entering the Great Lakes and also below municipal and industrial waste treatment plant outlets. Fish samples were collected at these same locations. e. The Department of Public Health undertook to examine persons in the Lake St. Clair area who were heavy fish consumers to ascertain if there were any adverse effects from the mercury contamination. Only two significant discharges of mercury compounds were located in the State of Michigan. The Wyandotte Chemical Plant on the Detroit River and a General Electric Company plant located at Edmore, Michigan which discharged its waste to a tributary of the Pine River. Wyandotte Chemical proceeded to install a temporary treatment facility which cut its mercury discharge by 80 to 90 percent to less than 2 pounds per day. This reduced discharge was subsequently found unacceptable and a temporary injunction was obtained by the Michigan Attorney General prohibiting any further mercury discharges. Wyandotte Chemical then shut down its mercury cell chlor-alkali operations. Wyandotte Chemical has since formulated a plan which has been accepted by the Water Resources Commission and entered in a circuit court consent order whereby all process wastewater containing mercury will be recycled to a cavity located 1200 feet underground from which the company obtains its salt supply. The Company will treat the wastewater to remove the maximum amount of mercury before recycling and is further required to have permanent above ground control facilities in operation in one year. The above ground recycling system is expected to cost about $1.5 million and when installed will be the most sophisticated mercury control facility known to exist in the world. The Edmore plant of the General Electric Company was notified that all discharges con- taining mercury must be ceased immediately or the Attorney General would be requested to take appropriate legal action. The Company proceeded to promptly halt all mercury discharges. On April 11, Governor Milliken together with appropriate state officials conferred in Toronto, Canada with representatives of the Canadian Federal Government, the Province of Ontario, U.S. Federal agencies, and the State of Ohio. A key objective of the meeting was to review the information collected by the Canadians and obtain their assessment of the situation. A seven point joint program was agreed upon, including the closing by Michigan of Lake St. Clair and the St. Clair River to all fishing. ------- 733 Later, Michigan indefinitely postponed the opening of the commercial fishing walleye season in Lake Erie and initiated a program to screen all commercial fish catches in Lake Erie for actionable levels of mercury. As the situation presently stands, the Lake Erie commercial walleye season remains closed We have been informed that virtually all commercial fishing in the Michigan waters of Lake Erie has stopped. Sportfishing is permitted in Lake Erie however the possession of walleye, white bass or sheepshead is prohibited. The same regulations have also been applied to sportfishing in Southern Lake Huron principally because of the migratory habits of walleye. In Lake St. Clair, the St. Clair River and the Detroit River, sportfishing is permitted on a catch and release basis only. Possession of any fish from these waters is illegal. The Ontario ban on all fishing in the St. Clair River, Lake St. Clair and the Detroit River has been discontinued. We do not know if the mercury content of fish in Lake St. Clair is increasing or de- creasing. In order to attempt to make such a determination, a special sampling program will be initiated to monitor particular species of fish from Lake St. Clair. It is planned to collect a statistically significant sample in July and again in the fall for purposes of comparison. In investigating possible sources of mercury, we learned that mercury and mercury compounds are used in numerous and diverse everyday operations such as: --in diaper laundries; --in marine and acrylic based paints; —in the manufacture of acetylene, polyvinylchlorides, chlorine and caustic soda; --in seed, lawn and pulpwood fungicides; —in hospitals; --in mercury seals in trickling filter sewage treatment plants; --in mercury batteries; --and in paper making plants. Possible sources of mercury, although generally small ones, are present throughout our society. It is clear, therefore, that mercury sampling must become an integral part of regular water quality and environmental monitoring. As a result of the extensive amount of mercury sampling that has been completed, we now have a good estimate of the magnitude of mercury in the water environment. No measur- able mercury was found in any water supply system obtaining its water from the St. Clair River, Lake St. Clair, Detroit River, or Lake Erie. Sampling analysis of (a) certain industrial wastewaters, (b) sewage in communities where industries discharge wastes to municipal sewer systems, and (c) river bottom sediments at the mouths of major rivers entering the Great Lakes and at locations below municipal and industrial discharges indicated no mercury or only trace amounts. This confirms our earlier belief that only Wyandotte Chemical Corporation at Wyandotte and General Electric Company at Edmore were the only sizeable dischargers of mercury or mercury compounds in the state. ------- 734 The Federal Water Quality Administration has completed extensive tests of bottom sediment samples from Lake St. Clair, the Detroit River, and Lake Erie. Their results show no significant amounts of mercury in the sediments of the Michigan portion of Lake St. Clair. Mercury has been found in the sediments of the Detroit River below the Wyandotte Chemical outfall and has been found in Lake Erie sediments in very low levels over a wide area. In regard to these contaminated sediments, we do not know the effective life of the mercury constituents. One source has suggested the effects of the pollution may last for 10 to 100 years unless the mercury is made inactive either by its physical removal or by elimination of its biological availability. We are evaluating the feasibility of removing contaminated sediments through dredging. It has been estimated that to dredge a strip 150 feet wide, 3 feet deep and 1 mile long of the Detroit River would cost approximately one-half million dollars. The cost of dredging Lake Erie, due to the large area involved, would be enormously expensive. Dredging, moreover, could conceivably cause significant environmental damage includ- the Possible additional releases of mercury compounds to the aquatic environment. No conclusion has been reached as yet on the possibility of any dredging. Efforts are also underway to determine whether there is any possible way to chemically neutralize or bind the mercury in bottom sediments within the affected area. Results to date do not indicate any practical method of chemical treatment of the contaminated bottom sediments. As I have stated previously, the contamination of the environment by mercury compounds represents a serious fault in our present environmental protection programs. Looking back at the serious incidents which occurred in Japan and Sweden, our lack of knowledge about the use, disposal, effects and other characteristics of mercury compounds now appears incredible. It is clear however, that we must institute adequate methods of safeguarding the environment from any future catastrophies. I see four areas which are in need of urgent action: 1. A broadened environmental sampling and monitoring program to identify all possible environmental contaminants; 2. Better information on the use and disposal of the thousands of products, raw materials, catalysts, by-products and waste products involved in industrial production; 3. Increased efforts to investigate the environmental effects of the many industrial chemicals and other substances presently in use and a systematic program to evaluate all new products before they are marketed; 4. A national clearing house to coordinate all of the above activities and to help alert pollution control officials regarding emerging and potential problem situations. On our part, Michigan has taken new initiatives to increase our efforts to safeguard the environment. Governor Milliken has introduced legislation to: ------- 735 1. Require the registration of all manufactured products, processes, production materials, by-products and waste products by all indust- ries and businesses within the state which discharge industrial wastewater. 2. Impose a surveillance fee on all commercial and industrial enterprises which use the waters of the state for waste disposal purposes. The revenue raised by this surveillance fee will be used to augment the state's pollution detection, surveillance, and control capability. The additional funds and information that will be made available through these measures will enable us to provide increased protection for the environment and for our citizens. We strongly urge that new national efforts also be undertaken and we offer our coopera- tion and assistance in any way possible. Thank you. ------- 736 MR. STEIN: Are there any other comments or questions? (No response.) If not, I would like to thank you all for coming. I think we had a very, very productive session. As with all the sessions, they do take some time. I think we made a lot of progress in evaluating where we are in the cleanup on Lake Erie and the municipal and industrial sources, I think it is fair to say that while the purpose of these conferences is to emphasize the slippage, the laggards and the places that didn't come through, if you look at the program as a whole, you will find that we are making very substantial progress in moving towards the cleanup of Lake Erie. Municipalities and industries are putting in these remedial facilities. We will be getting local information in the various workshops we conduct the week after next. I would suggest when all that material is in, we will call the conferees back, I hope for a very brief session, where we can come up with conclusions and recommendations. We have all made certain commitments here that I hope will be forthcoming. One, and I think an important one and one that should not be overlooked, is the precedent we have established for the State and the Federal Water ------- 737 Quality Administration to get together on the recommendation on dredging before any deposits containing mercury are even disturbed. I think that may serve to be a pattern for the country where we have this. The second thing, if these dredgings are to be disturbed, we are going to come up with a joint recommenda- tion on where they are to be placed. I think we have a program here of either stopping significant discharges of mercury into Lake Erie or taking appropriate action. I think all the significant sources we know of have been named here. We are going over those and we should be on our way in a week. Either they are going to be stopped, or action is going to be taken by the State or Federal authorities to stop them. I think we have taken quite a leg up on attempting to deal with the problems inherent in controlling a toxic material such as mercury. As far as I know, this is the first little baby step towards a tremendous program in this whole area. I don't think it could have been done with a better group of people than the people we have here in the Lake Erie States. I hope we are going to be able to develop something that is going to show the way for the Nation to get at the mercury problem and the whole question of disposal of toxic substances. ------- 738 For those of you who have stayed with us, you may just barely be able to see the complexity of the problem we have to deal with. But we are going to move forward and meet it, I am sure. Are there any other comments or questions? MR. PURDY: Mr. Stein, on your suggestion of a meeting following the workshops and following this conference here, I have in mind what took place at the so-called execu- tive session of the Lake Michigan Enforcement Conference. I think we need to have citizen participation. And it seems to me that the meeting today and the workshop gives the opportunity for citizen participation. And unless we are just going to talk something to death, we need that oppor- tunity of gathering in an executive session so that the con- ferees can reach recommendations and conclusions and put something on the road here. And I have no objection to the open executive sessions if we can draw up an agenda, limit the discussion to the conferees, and move forward on recommendations and conclusions. If it is impossible to do this in an open executive session, I would request that we make it at least a semi-closed executive session so that we do more than just talk. MR. STEIN: Right. I agree with that suggestion. ------- 739 Let me tell you, we have opened up these proceed- ings, as you know, in the past. We have no secrets. And we have always tried to have our proceedings public, includ- ing our executive sessions. But if people are going to think that part of the social revolution requires them to come in and be heard at every meeting or disrupt the meeting if they are not going to be heard, then we are just going to have to resort to going into a room where we are just going to allow the conferees and their immediate staff and exclude the public. Again, I talked about being stupid and abusing the privilege. If that is what people want to do, they are welcome to do it. I think in the Chicago situation, we were faced with the extraordinary situation where people came in and demanded to be heard. And at least my judgment was that they felt it was their public duty and they were making a contribution to the good of mankind if they could get their heads opened, particularly if there was a TV camera around. We had about 18 TV cameras. In addition to that, we had some officials who I think felt it was their public duty to have an opportunity to open some heads. So all the ducks were on the pond. And I think you have a very difficult situation in those cases. ------- 740 Now, I deplore this, and I think if we are going f to be faced with this, Mr. Purdy, there is going to be no alternative but to get a small room, go in and lock the door and go on with our business. I would like you to come in and see what we do. But unless the public is mature enough to recognize that it has been given a full opportunity to talk, we are going to have a different type of executive session from now on. The people's privilege is there to see us go through this, but when the time comes for an executive session, we have to make a decision. MR. PURDY: I am not criticizing your handling of that meeting. I just think there is not that much time available. MR. STEIN: That's right. That is right. I couldn't agree with you more. Are we all set? MR. POOLE: I commended him privately for his handling of the Chicago meeting. So I can't criticize him. He had no alternative. MR. STEIN: Are there any other questions or comments? (No response.) If not, thank you very much. And we stand adjourned. (Whereupon, at 4:32 o'clock p.m., the hearing adjourned.) ------- CITY OF EUCLID ENGINEERING DEPARTMENT 585 EAST 222nd STREET EUCLID, OHIO 44123 ' (216) 731-6000 HABEY J. KNIJTH )8BBCHSflBa{pa8aa STANLEY L CESEN Mayor City Engineer TONY J. SUSTARSIC Administrative Director June 29 * 1970 Department of Interior Federal Water Quality Administration Washington, D. C. 202^2 Attention: Mr. Murray Stein Chief of Enforcement Dear Sir: At the April 15th meeting of the Ohio Water Pollution Board, the City of Euclid made a presentation outlining the status of its pollution abatement program. A copy of this statement is enclosed. We feel that you should have a copy of this statement so that you will know that Euclid is progressing to the utmost of its ability in the pollution abatement program. Very/-truly yours, Stanley City Engineer LC:mb .cl. cc: Mr. George Harlow, Director Lake Erie Basin Office Mayor Harry J. Knuth Administrative Director T. J. Sustarsic ------- STATEMENT TO THE WATER POLLUTION CONTROL BOARD MEETING, APRIL 15, 1970 Mr. Chairman, Members of the Board, interested citizens: "t f The City of Euclid regrets that it was unable to comply with the original timetable for proposed improvements and additions to its wastewater treatment plant-. Problems associated with the site of the existing treatment plant de- layed the submission of the engineering report and subsequent council action. The Board was apprised as to the nature of these delays when the new target dates were set. At the present time, Euclid is operating under a Water Pollution Control Board Permit which expires October 15» 1970 and complying with the conditions thereof as follows: 1. A pilot plant study is under way to determine the processes which can best be used at the present treatment plant site for secondary treatment and phosphate removal. 2. Upon receipt of the engineer's report of the findings of the pilot plant study and recommendations derived therefrom, and with the concurrence of the State Department of Health, the City will authorize the preparation of detail plans and specifications for the improvements to the treatment facilities. 3. Detail plans and specifications for sludge disposal facilities are in the process of preparation. k. Our present treatment plant facilities are being operated satisfactorily by licensed operators, a fact which was confirmed by a recent inspection by the Health Department. Monthly and annual operating reports are being submitted to the Health Department. 5. The program for reducing the amount of storm water in the sanitary sewers is being carried out vigorously. In several areas, new sewers and connections have been built, are under construction or are being designed which will result in the elimination of storm water from the sanitary sewer system. 6. The City is continuing its monitoring of industries discharging wastewater to the Euclid sanitary sewers and drains. A City permit system is used. Industries which perform pretreatment submit monthly operating reports to the City. These reports are reviewed by the City's wastewater chemist. Frequent visits are made to plants and samples from the sewer system are collected and tested periodically. The City of Euclid expects to have construction of its wastewater treat- ment plant improvements completed by December 1, 1972. Respectfully submitted The City of Suelid ft U. S. GOVERNMENT PRINTING OFFICE : 1970 O - 407-609 (Vol. H) ------- ------- North Wacker 60606 ------- ------- -------

PROCEEDINGS
                                         Fifth Session
                                         Detroit, Michigan
                                         June 3, 4,197O
                                         VolJ|2
In the Matter of Pollution of Lake Erie and its
Tributaries- Indiana-Michigan-New York-Ohio-
  U. S. DEPARTMENT OF THE INTERIOR • FEDERAL WATER QUALITY ADMINISTRATION

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                                                421
FIFTH SESSION OF THE CONFERENCE  IN
THE MATTER OF POLLUTION OF LAKE
ERIE AND  ITS TRIBUTARIES  (INDIANA-
MICHIGAN-NEW YORK-OHIO-PENNSYLVANIA)
              ENVIRONMENTAL PROTECTION AGENCY
              Library,  Region V
              1 Worth Wacker Drive
              Chicago,  Illinois  60G06

                            Cobo Hall
                        Detroit, Michigan
                            June  4,  1970

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                                                      422
                       CONTENT^




STATEMENT OF:                                         Page
Prank J. Kallin                                       423




Al R. Balden                                          439




Gerald J. Remus                                       444




Hillel S. Liebert                                     505




George H. Eagle                                       515




Walter A. Lyon                                        570




Perry Miller                                          590




Russell C. Mt. Pleasant                               602




Lowell A. Van Den Berg                                646




Albert M. Shannon                                     725




R. W. Purdy                                           728

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

          MR. PURDY:  Yes, Mr. Stein.

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

Ford Motor Company, for a statement.


                  STATEMENT OF FRANK J. KALLIN

             FACILITY ENVIRONMENTAL CONTROL MANAGER

                       FORD MOTOR COMPANY

                       DETROIT, MICHIGAN


          MR. KALLIN:  Mr. Chairman, conferees and ladies

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

of Facility Environmental Control for Ford Motor Company.

          I appreciate this opportunity to report on the

continued progress Ford Motor Company has made in wastewater

control at its Rouge and Monroe plants since the June 1965

session.  Improvements have been brought about variously by

new waste treatment facilities, expansion and modernization

of existing facilities, and by process changes which have

eliminated or minimized waste producing operations.

          At the Rouge manufacturing area, our primary waste

water tasks have been the reduction of suspended solids,

phenol, oil, and the dissolved iron from steel pickling

liquor.  At Monroe, our tasks were concerned with reducing

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                                                        424




                    Frank J.  Kallin






cyanide and holding bacteria, oil,  and phosphates to specified  «




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




to bring each of these within the limitations stipulated by




the Michigan Water Resources Commission.




          First, suspended solids.   At the time of the 1965




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




were already under the objective of 50 milligrams of suspended




solids per liter.  Excess solids in the one exception resulted




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




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




glass-making process which does not require the grinding and




polishing operations.




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




pollution controls at the Rouge powerhouse  and the Dearborn




Specialty Foundry has given us an interim problem with sus-




pended solids.




          New dust collector equipment installed at the power--




house removes more suspended particulates of smaller micron




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




are lost to the sewer system through a water induced vacuum




system.  The temporary condition will be corrected by the




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




for completion by next January 15.




          At the specialty foundry, the solids are suspended

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                                                       425

                        F. J. Kallin



particulates trapped from exhaust air by new wet collectors

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

an elaborate diatomaceous earth filtration system for removing
                      v
the particulates from the water — in effect, a full-scale

research project since this type of filter had not previously

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

yield filtered water containing less than 5 milligrams of

suspended solids per liter, but unfortunately the system

failed to work despite extensive changes tried out by both

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

the more proven principle of clarification which will reduce

the suspended solids content from our cupola wet scrubbers

to less than 25 milligrams per liter.  Preliminary planning

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

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

we have been able to reduce suspended solids losses by

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

lectors .

          Naturally, we are disappointed at the lack of suc-

cess with the diatomaceous earth approach which appeared to

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

experience we acquired will be of value in establishing and

determining equipment limitations for future applications.

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

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                                                        42b




                        F.  J.  Kallin






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




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




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




quantity of phenol discharged into the Rouge River to less




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




order from the Michigan Water Resources Commission.




          In 1966, Ford entered into a voluntary stipulation




with the Commission, agreeing to reduce the daily discharge




of phenol generated from the coke oven operation from 600




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




phenol recovery plant and a biological destruction process




were among the methods we considered for accomplishing this




steep reduction.  The first two alternatives were discarded




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




which determined that biological destruction was feasible.




This conclusion was further supported by our findings that,




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




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




composed by the time it reached the confluence with the




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




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




property for the treatment of our phenol-bearing waste.




          After completing the design, however, it appeared




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

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                                                         42?




                          P. J. Kallin






,  the Detroit metropolitan water services treatment plant could




  and would accept our remaining phenol waste for biological




  destruction.  Detroit officials so agreed with the provisions,




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




  tion to the city and pay an equitable additional rate for




  the convenience and additional services rendered.




            Now, with respect to oil, the recovery system




  which formerly served the north half of the Rouge complex




  has been completely replaced by an advanced collection and




  removal system now entering its third year of operation.




            Additionally, since May 3 of this year, an oil




  polishing lagoon has been operational in conjunction with




  the Gate 11 oil removal facilities which were installed in




  1954.  Owing to extensive delays in a planned relocation of




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




  to restricted Federal funding, the property which we had




  originally contemplated as the site of the lagoon has not




  yet become available to us.  Fortunately we were able to




  purchase other suitably located land across the river for




  the purpose.




            We believe that these improvements, supplemented by




  a continuing program of careful and energetic housekeeping




  within our plants, have given us an effective oil control




  system at the Rouge.

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                                                       428




                        F. J. Kallin






          With with respect to steel pickling liquor,  for




many years our steel operations at the Rouge used sulphuric




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




resulting in waste pickling liquor which was discharged to




our boat slip.  After studies of possible alternatives —




including disposal wells, acid recovery systems and chemical




neutralization — our Steel Division found it most feasible




to switch from sulphuric acid to hydrochloric acid, which is




more capable of being economically recycled and reused.




          Under contract, an outside supplier now hauls




from the Rouge all the spent pickling liquor generated each




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




boat slip except for some incidental leaks — which since




have been completely corrected — and small quantities of dis-




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




meeting our iron stipulation, we are currently designing




additional facilities to  prevent any loss of iron in the




rinse water to the boat slip which will eliminate occasional




discoloration.  We expect to have this installation operat-




ing by May 1971.




          Now, with regard to cyanide and phosphate at our




Monroe plant, waste treatment facilities at our Monroe plant




were initially installed  in  1950 and were expanded in 1955




to provide for the treatment of cyanide and for the removal

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                                                       429




                        P. J.  Kallin






of chromium and nickel used in plating operations.   Addi-




tional facilities operating since January 1969 have utilized




chlorine to destroy cyanide and this has reduced the cyanide




concentrations in wastewater to less than .025 parts per




million in accordance with a voluntary stipulation  entered




into between Ford and the Michigan Water Resources  Commission,




          The above wastewater treatment facilities also




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




phate .




          That concludes my report on the current status of




Ford Motor Company's continuing effort to improve wastewater




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




with the exception of the short-term problem with suspended




solids resulting from our air purification efforts  at the




Rouge, our process changes and waste treatment facilities




have placed these two plants in substantial compliance with




existing water quality standards and objectives.  In keeping




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




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




December I/ I can assure you that our company will  continue




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




cleaner water.




          Thank you again for giving me this opportunity to




discuss the progress we have made.

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                                                       430




                        F.  J.  Kallin






          Mr. Chairman, I have one additional comment.




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




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




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




          Making this change,  the sentence would read:   "The




State of Michigan adopted a final order of determination at




its May meeting to require further control of suspended




solids resulting in part from air pollution control facilities,"




as opposed to oil pollution control.




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




          MR. HARLOW:  Yes, that's right.




          MR. STEIN:  Thank you for that correction.




          Are there any other comments or questions?  And I




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




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




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




jibe.




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




this clarified.  Mr. Kallin says they are in substantial




compliance.  As I understand it from the Federal statement,




Ford was behind.  Can we resolve that somehow?




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




was in connection with the suspended solids.  And I believe




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

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                                                      431




                        F. J. Kallin






another system that caused you to be delayed.




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




ment reflects that we are not in compliance with suspended




solids.




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




Kallin.




          MR. KALLIN:  Thank you.




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




talk about —




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




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




with suspended solids, what does that statement at the end




of your report say on process changes and waste treatment




facilities have placed these two plants in substantial com-




pliance with existing water quality standards and objectives?




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




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




problem of suspended solids.




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




lets to the Rouge River from your Rouge operations.  Many




of these contained or did at one time contain suspended




solids in excess of the requirements that have been agreed




upon.




          Now, are you behind time on suspended solids

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                                                      432




                        F.  J.  Kallin






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




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




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




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




presentation where we said initially we had a suspended solids




resulting from the grinding and polishing of glass which has




been eliminated.  And the suspended solids problem we have




today is the result of the air pollution control facilities




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




house and the Dearborn specialty foundry, happened to drain




into two separate sewers.




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




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




          MR. BARLOW:  Is the  powerplant discharging through



the tailrace?




          MR. KALLIN:  Yes, sir.




          MR. STEIN:  Are we in substantial agreement on




the situation now?




          MR. HARLOW:  Yes.




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




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




pliance except for the air pollution scrubbers, control




scrubbers?




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

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                                                       433




                        F. J. Kallin






would like to ask to explore this a little further.




          MR. STEIN:  Right.




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




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




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




did construct a lagoon — is this across the Rouge River




now from where the Gate 11 discharge was?




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




picked up the effluent from the clarifiers which we installed




back in 1954 which since that time have been discharging




directly to the Rouge River.  We have picked up that




effluent and now carry it underneath the Rouge River to the




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




tion May 30th this year.




          MR. HARLOW:  And are the discharges of these lagoons




within 15 milligrams per liter of oil?




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




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




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




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




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




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




this is going to make a significant improvement to the water




quality going into the Rouge.

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                                                      434




                        F.  J.  Kallin






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




Willow Creek outfall where  most of your oil from your rolling




mills came out.




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




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




the southwest half of the Rouge plant.




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




where you had the skimmers, are these skimmers still in




operation?




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  Are  they working satisfactorily?




          MR. KALLIN:  Yes.




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




tion for oil which I believe says measuring just the other




side of the skimmer?




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  And that is within the compliance?




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  Now, in connection with the cyanides




at the Monroe plant, the stipulation also calls for  meeting




25 pounds per day.




          MR. KALLIN:  Yes, sir.




          MR. HARLOW:  Your estimate refers to just  concen-




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

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                                                         435




                          F. J. Kallin






.  day for cyanide?




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




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



  less than 25 pounds.




            MR. HARLOW:  I have no further questions.




            MR. STEIN:  Any other questions or comments?




            MR. O'LEARY:  I have one question.



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




  you have stated this part of an agreement with Detroit would




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




  Has that been accomplished or what?




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




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




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




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




  logical to transfer a portion of this amount to Detroit.



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



  discharge more phenol, is this the meaning?



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




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




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




  be from one location as opposed to the two locations.




            MR. PURDY:  Mr. Stein.




            MR. STEIN:  Yes, Mr. Purdy.

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                                                       436




                        F.  J.  Kallin






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




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




the Ford Motor Company will be discharging a  part of their




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




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




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




in consideration of this treatment that  Detroit will provide.




          MR.  STEIN:   Any other questions?




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




Chairman.




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




the stipulation also  calls, in reference to oil wastes  from




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




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




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




          MR.  KALLIN:  I think that we have specifically




with respect to the Rouge because  of the full concentration




of minute quantities  of oil that accumulate,  again referring




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




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




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




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




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




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

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                                                       437




                        F. J. KALLIN






          MR. STEIN:  Any other comments or questions?




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




will comment first.




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




sewer and the 15 ppm oil concentration, the Water Resources




Commission recognized that to correct the problems of  oil




accumulation in the Rouge River that we would have to  look




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




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




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




can have a very slight slick.




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




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




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




add additional facilities?




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




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




vacated by the flood control channel.  We do have provisions




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




for further treatment.




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




project has been completed to the point that this part of




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




speak, second polishing lagoon.

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                                                        438




                        F.  J.  Kallin






          MR.  KALLIN:   Yes, sir.




          MR.  STEIN:   Thank you.




          Are  there any other comments or questions?  Are




we all satisfied with the progress report now or  is there




any problem?




          (No  response.)




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




          I think it might be helpful — and I just throw




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




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




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




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




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




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




the Federal Water Quality Administration.  This will  be




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




conditions.




          I think this will be helpful to all because if




the situation is substantially cleaned up — and we are just




dealing with minor problems now — I think we should  state




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




          MR.  PURDY:  We would be pleased to make those




arrangements.




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

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                                                       439




                        A. R. Balden






          Mr. Purdy.




          MR. PURDY:  Mr. Balden, Chrysler.






                  STATEMENT OF AL R. BALDEN




                 WASTE TREATMENT  SPECIALIST




                      ENGINEERING OFFICE




           CHRYSLER CORPORATION, DETROIT, MICHIGAN






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




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




make a brief statement.




          My name is Al Balden and I am the Waste Treatment




Specialist for Chrysler Corporation which has three manu-




facturing plants on the Detroit River, all in the vicinity




of Trenton, Michigan.  These plants are:




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




1953, which sinters small metal parts.




          2.  The Chemical Division's Trenton plant, built




in 1947, which makes industrial adhesives, brake linings,




machining coolants, cleaners and the like.




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




machines engine components and assembles these into engines.




          It has been basic to Chrysler's operating philoso-




phy that protecting the quality of our environment is an




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

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                                                       440


                        A.  R.  Balden



designed and built plants to protect our waterways  from


degradation, as contrasted with the more limited approach of


meeting the requirements of the law.  We have always tried


to anticipate potential pollution and its ecological effects


and have solved the problems presented to the best of our


ability, based on the best technological knowledge currently


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


knowledge.  Each plant built has represented the accumulated


experience applicable to that problem.  Those of us associated


with the designing, building and surveillance of such equip-


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


Law.  We have seen things happen which are unanticipated and
                                    9

have constantly worked to eliminate the unexpected.


          Each production plant built by Chrysler in the


Trenton area varies considerably in reference to the manu-


factured product and therefore the manufacturing operations


and the types of wastes produced.  We have worked closely


with the Water Resources Commission staff during the design


of the waste treatment facilities, discussing the plant


operation and the types and volumes of contaminants to be


treated and removed as well as the proposed facilities for


accomplishing the desired pollution prevention.


          At the Amplex plant, the potential pollutant was


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

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                                                          441




                           A.  R.  Balden






«   drum skimmer upstream of the weir has  been effective in




   preventing loss of the oil.




             The chemical plant was recognized to have a problem




   due to small but anticipated losses of oils, solvents and




   the like during the transfer of raw materials from the




   delivery truck to holding tank and while pumping the final




   product from the mixing tank to the shipping conveyance.  A




   lagoon was constructed to catch and hold this drainage.   The




   floating material was periodically pumped to a truck and




   hauled to an incinerator.  The aqueous portion was pumped




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




   has not been entirely effective in preventing pollution,  so




   additional equipment is to be  installed to provide an effec-




   tive remedy.  We have entered  into a voluntary stipulation  with




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




   1971.




             It was recognized that the Trenton engine plant




   would have a serious pollution problem because of the many




   machining and cleaning operations performed.  For this reason,




   waste treatment facilities were included as part of the plant




   as built.  These represented the most  advanced technology




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




   consisted of a large  holding  tank followed by air flotation




   and included means of recovering oil.

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                                                       442




                        A.  R.  Balden






          As we learned more about the limitations  of our




equipment and as the effluent demands became more exacting,



it was evident that additional facilities were required.  A




completely new tertiary treatment plant was installed in




1967, consisting of primary oil skimming, air flotation and




final settling.  This plant has enough flexibility  to satis-




factorily treat a variety of wastewaters and its operation



has been completely satisfactory as reflected by the reports




sent to the Water Resources Commission.




          The greatly increased public awareness of threats




to the quality of our environment can be beneficial in many




ways.  We hope one positive result will be an increased




awareness in the cause and effect of thoughtless actions  by




people who handle industrial pollutants as well as  their  daily




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



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




of their full potential until each man and woman in their



roles as employees and citizens of this society become fully




committed to his surrounding environment.  The installation




of adequate facilities must be matched by intelligent




individual commitment to their use.




          MR. STEIN:  Thank you, Mr. Balden.




          Are there any comments or questions?




           (No response.)

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                                                       443




                        A. R. Balden






          Mr. Balden, I would like to take this opportunity




to commend you in particular and Chrysler because it has




been my experience that under your direction, Chrysler Cor-




poration has taken cognizance at least of water pollution




problems in the country.  For an industry faced with major




potential pollutants, it has been always cooperative with




Federal, State and local governments in putting in these




devices.




          And I think if other companies had had the policy,




and perhaps had had the leadership of someone like Mr.




Balden, we wouldn't have this problem today.




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




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




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




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




I am aware of.




          MR. STEIN:  O.K.




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




people in Delaware, and they seem to be happy.




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




know how happy that water is.




          All right, thank you.




          Mr. Purdy.




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

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                                                       444




                        G.  J.  Remus






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




Board, to describe to the conference the largest single




system of intercepting sewers  and wastewater treatment




plants that has ever been placed under construction in the




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




single system of intercepting  sewers and waste treatment




that has ever been placed under construction in any part




of the U. S. section of Lake Erie.




          Mr. Remus.






                STATEMENT OF GERALD J. REMUS




                      GENERAL MANAGER




        CITY OF DETROIT METROPOLITAN WATER DEPARTMENT






          MR. REMUS:  Thank you, Mr. Purdy.




          Mr. Chairman, members of the conference, I am




Gerry Remus, General Manager of the Detroit Metropolitan




Water Department.




          We had prepared a report which after sitting




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




rather than read because there are some points that come




up that seem to me need to be clarified.




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




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




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

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                                                         445

                            G. J. Remus
*

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

  insert.  We may have to push it down.

            And I do not know if we can reproduce these

  pictures, Gerry.

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

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

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

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

  other things to help us.

            MR. REMUS:  I have no personal feeling on the

  pictures except to establish that the entire effort as far

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

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

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

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

  to make provided we can keep cooperative efforts going.

             (The above-referred to report follows in its

  entirety.)

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

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


Gentlemen:


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

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

Detroit River and Lake  Erie.

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

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

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

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

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

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

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

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

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

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

development continues in the present service area.

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

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

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

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

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

I. ADVANCED TREATMENT

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

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

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

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

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

projects (Exhibit B),

A. Phosphate Removal

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

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

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

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

Michigan Water Resources Commission.
- 2 -

-------
                                                                         449






A.   Phosphate Removal (Continued)




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




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




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




     150.000-gallon storage tanks at the plant.-  Currently,  injection of  10 - 15




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




     stipulation,







B.   Coliform Bacteria





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




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




     value of this reduction to the River 3 samplings downstream indicate.







C.   Biological Treatment





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




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




     quantity and quality of sewage influent.






     While design continueds  our  engineers studied the possibility of substituting




    pure oxygen for air in the proposed aeration tanks.






     Potential advantages of oxygen aeration appeared to include doubling capacity of




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




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




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




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




    operation and construction.



                                    . 3  .

-------
                                                                          450






    C,  Biological Treatment (Continued)





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




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




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




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




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




        pollution control.






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




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




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




        $200 f 000 if the Department builds  its own oxygen plant.






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




        end of this year.









II.  REGIONAL INTERCEPTOR  SYSTEM





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




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




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




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




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




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




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

-------
451

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

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

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

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

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

III. STORMWATER OVERFLOW CONTROL

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

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

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

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

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

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

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

the city,

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

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

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

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

hours, with no further rainfall,

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

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

installation.

~ 5 -

-------
452
The system and the Department's ability to interpret and to make decisions based on the
. '*
system's reporting was so finely tuned by May 25, that the Systems Control Center was

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

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

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

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

decisions were made during that storm to reduce overflows.

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

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

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

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

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

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

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

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

Michigan.

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

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

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

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

can come up with good solutions to stormwater overflow reduction.

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

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

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

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

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

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

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

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

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

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

Marathon Oil and others.

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

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

and other heavy metal wastes from entering the system.

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

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

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

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

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

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

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

-------
                                                                           454






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




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







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




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




effluent likewise shows no mercury.









V.  PROGRAM  COSTS





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




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




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




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




spent for treatment plant site acquisition.






Work programmed for construction starts this year are as follows:




        PCI-15   15-Mile Road Interceptor




        PC-231   Primary Influent Sampling




        PCI-10A  Oakland Arm --Section III A




        PCI- 10B  Oakland Arm - - Section III B




        PC-239   Connecting Interceptors and  Control Facilities





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





        PC-222   Four Final Tanks




        PC-233   Aeration Module I




        PC-234   Intermediate Pumping Units

-------
                                                                             455





 Construction Starts  This Year  --  Continued





         PC-23 5   Blower Units
  -»



         PC -23 6   Transformers




         PC-23 7   Switchgear




         PC-243   Avon-Dequindre Control Facility




         PC-244   Oil Storage Relocation




         PC-245   Scum Disposal and Incineration




         PC-246   Sludge Filtration and Incineration




         PCI-12    Romeo Arm --Section I




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





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





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




cost approximately $290 million,









VI.  FINANCING





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




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




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




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




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




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




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




much to date is the  Federal Government,





                                       _  9  .

-------
456
Again, we must question the sincerity of the Federal Government's war on pollution in.

light of legislation providing Federal funds for 55 percent of our projects when it has
7*

actually provided only 5 percent or less.

The Government is getting good at calling attention to water pollution problems. But

one of the biggest water pollution problems of 1970 appears to include those responsible

for our national priorities and specifically, those who propose that the Government can

accomplish $10 billion worth of pollution control with an expenditure of $4 billion.

That kind of seed money doesn't go very far, as Michigan has found out. Voters of this

state approved a $335 million clean-water bond issue in November, 1968, after they were

told that the $335 million could seed four times that much in statewide pollution control

projects --hinging on Federal grants ranging from 30 - 55 percent. With state and local

funds now required to "prefinance" the absent Federal money, both state and local funds

are running short.

On May 12, 1970, we paid an all-time high interest rate of 7, 78 percent on a sewer bond

issue of $24 million. The total interest cost on the bond issue will be about $44 million,

If our bonds had been sold in 1968S the interest rate would have been about 5 percent, at

a savings in interest cost of about $15 million.

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

the Federal Government.

Are we on schedule? We are, although the program is not. Our pollution control construc-

tion program ultimately has been scheduled by the availability of Federal and State funds,

and shortfalls and delays in these funds have produced corresponding delays in our construc-

tion program.

- 10 -

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

it* interceptor and treatment systems  and the programs going on now are bigger and

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


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

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

economical manner.


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

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

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

a dribble of Federal funds will be available.


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

present construction.



                                               Respectfully submitted.
                                               G, Remus
                                               General Manager
                                       -  11  -

-------
458
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-------
462
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Exhibit B
-------
463
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-------
464
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-------
465
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-------
466
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-------
CITY Or DETROIT
DETROIT METROPOLITAN WATER SERVICES ,
WATIR POLLUTION CONTROL
PROGRAM

DETROIT REGIONAL WATERSHED
LAKC
HURON
OCT. 1969
The sanitary sewage interceptor network
depicted on the above map represents only
one portion of the total regional pollution
control program Equally important is the
massive addition of treatment tanks and
equipment at the Wastewater Plant at 9300
W Jefferson Avenue m Detroit The site has
been expanded by 27 Acres primarily to
facilitate an advanced treatment process
which is to remove a high proportion of
suspended solids, BOD (oxygen depleting
wastes), phosphates, oils, phenols and bac-
teria

Expenditures by 1970-71 for treatment
plant and interceptor work are estimated
at $159,000,000.

Other work which cannot be depicted on
the map includes preliminary work toward
an improved storm water overflow control
system to be in effect by 1977 Within the
City of Detroit, extensive renovation and
improvement of the local collection system
is also planned

The construction schedules, rouies and
locations of all work depicted on the map
are subject to acquisition of right-of-way,
subsequent development or discovery of

population growth patterns

The service areas shown will be devel-
oped provided that service contracts are
made with the constituent communities The
layout shown basically provides the trios'
economical solution for water pollution
control for the area watershed
after 2000
by DMWS
by DMWS
Future DMWS Wasiewater Treatment Plant

Existing DMWS Wastewater Treatment Plant

Existing Wastewater Treatment Plant to be
ptiased out as interceptors become available
-------
468

G. J. Remus

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

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

It is Metropolitan Detroit system. And it creates very much

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

Detroit, when actually this is Detroit and 54 communities that

are now on the system with construction going forth for an

additional 15 and negotiations under serious consideration

for an additional 12. We are providing service now for

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

increasing. And my discussion here is to hope to point

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

tains to the overall.

I should point out that in trying to satisfy your

honorable conference here, that is only one of 253 autonomous

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

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

difficulties in the acceptance of this type of program.

I raise that question because it seems to me that

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

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

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

you could do that would help expedite these programs.

I will briefly go over the report, and then I

will refer to some of the factors that I think need to be
-------
469

G. J. Remus

emphasized.

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

existing, the city of Detroit underwrote an area program and

signed a formal contract with the Water Resources Commission

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

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

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

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

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

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

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

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

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

take place until you have water supply and potential for

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

government with much of any financial capability to do the

job themselves.

Obviously, the area job as the correct answer

has been recognized by 15 different studies made — Federal,

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

engineering reports where the consultants said to do it

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

struction.

I think that just briefly following the various
-------
470

G. J. Remus

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

the State grant account to execute this program until the

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

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

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

pared to put $90 million worth of construction under way

this year.

The pictures that you find in the exhibits are

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

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

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

the heavy construction that is going on there and that for

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

are doing the construction rather than the conference.

We have brief statements in here relative to

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

packers.

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

the Federal people mentioned it — relative to the phosphate

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

that which we said we would do.

I would like to point out one correction. There

was some reference to 650 million gallons of sewage. Today

we are treating in excess of 750 million.
-------
471

G. J. Remus

On the bacteria coliform situation relative to the

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

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

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

understanding about that. But charts clearly show that if

you take a median value of the Detroit River before you

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

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

effluent count as soon as our activated slip section of the

plant is in operation.

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

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

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

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

sure of the results we will get.

We are using part of our plant improvement as far

as biological treatment is concerned. We have decided to

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

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

will, it will be used for all.

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

space, less initial capital investment. And after we get

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

would be getting less operating cost.
-------
472

G. J. Remus

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

roughly, is under construction, for an interceptor on the

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

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

The red is the area Detroit will prepare and have

under contract.

This section of blue will be awarded within the

next month.

The red up in Oakland County is being prepared

by Oakland County and is under construction.

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

point to one of the comments that was made relative to

Selfridge Field. When Detroit's facilities are available,

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

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

merly contracted with Macomb County to build up to Mount

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

I think this illustrates the typical situation we run into.

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

is what has gone on up here.

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

Mount Clemens. Mount Clemens was included in the ban that

existed in lower Macomb County several years ago. And it

was lifted when we signed a contract with Macomb County.
-------
473

G. J. Remus

Now, in this interceptor construction, we agreed

to provide service for Mount Clemens. Mount Clemens has

agreed they would have an engineering study made which they

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

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

they had hired another set of engineers. And within that

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

the opposite.

Now, it is those type of things that we think

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

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

or $159 million worth of construction and then be badgered

with that type of stuff.

I would like to point out while we are in this

same area that we are building through the city of Warren

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

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

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

should suddenly get a grant because we are building that

property through there at their request. And we did it

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

wards .

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

that later, that Warren has now challenged the State and
-------
474

G. J. Remus

Federal Government on their grant program. And if they

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

intercept that the central system will build. Because if

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

future.

This interceptor situation, of course, is paid

for entirely by the revenues we expected to collect and by

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

tion.

I would like to refer to a part of this problem

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

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

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

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

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

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

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

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

going to BOD and solids going to the Detroit River.

In doing this, it cost us considerable extra

money in our operations because we pump our system which is

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

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

a storm. And we have just recently put in operation a
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G. J. Remus

monitoring and telemetering system data logger which the

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

we have 138 sensor units throughout the city that give us

sewer levels, storm intensity, the rapidity with which it

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

we are beginning to make some real progress with this

stormflow.

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

in an activated sludge plant with all the construction at

the sewage plant without also going at this stormflow

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

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

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

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

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

pollution prevention. Mr. Kallin of Ford Motor Company only

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

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

problem up in Sterling Township and taking care of it for

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

Of particular importance is the fact that in the

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

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

discharges into the Detroit River or into the receiving
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G. J. Remus

waters. All their waste goes through the public system.

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

handle their wastes. We have the proper ordinances, and

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

cooperatively with industry to get our system in such a

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

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

handled.

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

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

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

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

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

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

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

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

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

with them because they felt it was important.

There are plenty of examples of what I think has

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

prevention, partly to control what comes into our system,

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

406 million pounds of salt in the metropolitan area dumped

on the streets.
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G. J. Remus

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

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

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

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

somebody. Because if we are going to wait until these

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

up.

We have the same comments on other heavy metal

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

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

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

percent phosphate be allowed on the market.

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

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

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

bit about the money, the financing.

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

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

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

this month — the Federal Government should have provided

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

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

basis of the law that is on the land.

Since the Federal appropriations were not financed,
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G. J. Remus

it developed that our system provided $40 million and that

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

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

the Federal people, and our operations prefinanced $20

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

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

And I am going to do the best I can.

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

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

percent interest, far more than we ever paid before. And

$20 million of that was financing what the Federal people

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

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

do not have the tax base or the metropolitan area available

to us. We have only revenue bond financing.

In fact, the Federal portion of the grants we

have received are like pulling backwards when you are going

forwards because they haven't even kept up with inflationary

factors.

Further, the State has to continue to prefinance

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

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

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

job, obviously the whole program is in jeopardy.
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G. J. Remus

I have briefly commented on the fact that we have

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

reduced and have under good control bacterial kill. But we

have in addition to that a considerable effort to exercise

as far as BOD and solid removal is concerned.

I have also pointed out, and I as a representative

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

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

metropolitan efforts. We could not get clearances on finan-

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

entirely because of that. And our stipulations, even though

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

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

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

improved method of handling stormflows.

Now, before I answer questions, I would like to

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

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

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

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

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

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

thing is cleared up before you issue bonds."

If we don't say it, the investors will say it
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G. J. Remus

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

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

And that is particularly serious in this type of operation.

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

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

represents the Common Council, the City Comptroller, have

to sign a stipulation saying that there is no lawsuit or

potential lawsuit before we can issue bonds. And if we

have all kinds of Federal and questionable legal positions

to contend with, we will not get those clearances.

Now, I would like to bring out another thing.

That is the reason I referred earlier to the business that

this is a metropolitan operation, the city of Detroit being

responsible for the execution thereof. This program has

now been approved by four mayors since 1957 when it was

adopted. The Common Council has continually re-endorsed

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

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

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

support toward the solution of this program. If you apply

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

the State and the rest to the Federal Government for the

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

Actually, it would delay or confuse our program a great deal,
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G. J. Remus

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

brief report here on a water supply thing or the contracts

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

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

are necessary outside of the stipulations that must be

qualified for before you can construct in a sewage effort.

And one is water supply.

If you examine this effort here which shows our

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

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

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

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

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

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

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

important part of this issue.

Take the Clinton Valley, for instance. There is

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

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

future. And under those kind of conditions, unless you

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

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

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

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

A second part that seems to me must be dwelled

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

our department has been designated by the city of Detroit

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

to refer to the Rouge River.

To take Ford out of the Rouge River or anyone

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

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

happening. There are no means available today to relieve

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

organization. But until you also have a basic program

working whereby the streams will be protected where develop-

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

transferring your agony from one place to another.

And I think those two points need to be worked

out simultaneously before you put an area pollution control

program into action.

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

them rather rapidly. I basically summarize it by saying that

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

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

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

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

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

start awarding those construction projects that are listed

in our report. But the other supplemental work of water

supply and stormflow rationalization has to be put into

action also. And we are working on that.

Thank you,

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

excellent statement.

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

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

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

hear anything about sophisticated wastes or exotic wastes

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

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

pristine clear is.

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

classical references, Gerry,

I always thought that Jefferson said it better

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

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

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

"...too damn much government,"

Are there any comments?

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

First, I would like to thank Mr. Remus for
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G. J. Remus

providing us very recently with a very detailed breakdown

on the construction program that has been requested from

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

that breakdown essentially a schedule of compliance,or

apparently a schedule of compliance with the stipulations.

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

about the apparent dates at which certain levels of waste—

water treatment improvement could be accommodated. And I

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

tion items.

As we interpret the information you provided to

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

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

that.

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

In reviewing the information that you provided

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

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

the dates that you have attached

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

yes.

MR. MAYO: As we understand the basic date for

the current stipulation — perhaps Mr. Purdy can correct

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

that correct?

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

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

we start working this problem out, obviously some of the

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

little different form. If you will take the construction

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

be awarded this calendar year, with what is already under

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

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

solids are concerned and the stormflow, we will be doing

better in the sum total picture.

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

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

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

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

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

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

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

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

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

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

out our plant any time we had a storm.

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

fication items, the stipulation would provide for not more

than 50 milligrams per liter or what would seem not more

than 452,000 pounds per day of suspended solids.

MR. REMUS: Correct.

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

mately January 1975?

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

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

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

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

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

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

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

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

information that you provided to us was in terms of percent

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

some translation for us between the percent of effluent if

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

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

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

having considerable amount of trouble. And we do not figure

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

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

analyzing it is to point out that the 93 pounds applied to
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G. J. Remus

Detroit with 57 communities we have under contract with all

their industry, all their commercial establishment and the

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

is some unrealistic figuring here. We had hoped that this

would in a normal sequence of events take care of itself

as this construction went forward.

To keep ourselves on a reasonable basis there,

our agreement with the Ford Motor Company was if we could

get it down to acceptable standards, we would accept their

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

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

study area now.

We think we will approach it, but 93 pounds is

a pretty unrealistic figure when you consider the type of

load we have.

MR. MAYO: As I understand the later stipulation,

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

day.

MR. REMUS: That probably took advantage of the

Ford slice that they have turned over to us.

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

tional panels added to the 93 for the north interceptor.

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

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

* What do you say?

(Laughter.)

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

of times?

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

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

interest?

MR. REMUS: 7.78.

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

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

raise that bond figure? It looks real attractive.

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

should interest you.

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

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

are at the present time?

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

the range of about 1,200 pounds a day.

What were those figures you gave me this morning?

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

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

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

MR. MAYO: As we would interpret the projection

of information that you have given, you would get down to
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G. J. Remus

the range of the 70 percent reduction over the effluent

until sometime about 1975.

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

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

the proof to that in the next couple of months pretty

directly or at least when the construction we have now under

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

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

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

our 1972 construction complete and in operation, then we

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

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

That will take one portion out of here.

We will go to the industries and to the people

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

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

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

I think it has to be attacked at its source.

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

take this approach of essentially pretreatment at the point

of discharge from the industrial constrictors of phenol

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

program places that burden on the discharger rather than the

metropolitan system.
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G. J. Remus

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

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

what they are putting in. Our monitoring system is being

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

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

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

least.

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

would suggest that might be accomplished?

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

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

MR. SHANNON: Yes.

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

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

We have not attacked the problem yet from a standpoint of

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

reason that our contracts provide control. But the

ordinance does not define that precisely. But many of the

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

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

should be sending to us. So by attacking both within

Detroit and the suburbs against discharge, I think we can

meet that standard.

And I would think that gradually here in the next
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G. J. Remus

months, we will be bringing that down.

MR. MAYO: With respect to oil, the stipulation

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

Your projection would indicate that you would reach that

level of treatment at about January 1975.

MR. REMUS: Unless we can do a better projection

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

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

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

when they were ready to build their plant addition, their

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

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

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

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

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

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

done well and really have obtained that goal sooner.

MR. MAYO: Is there much of an opportunity that

you could pass the responsibility for oil removal back onto

the original discharger as distinguished from the district

assuming the responsibility?

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

back to the suburbs because we can check whether their waste

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

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

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

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

characteristic of every one of the older metropolitan cities,

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

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

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

instituted a sampling program on their sewer system. And

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

some 6 people that devote their full time to this particular

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

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

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

a metropolitan system.

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

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

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

even the BOD and solids loading having stayed where they

are, is quite some accomplishment in light of the rapid

expansion that has taken place in the Detroit metropolitan

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

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

way.

MR. MAYO: With respect to the phosphate loading,

the stipulation provides for 80 percent removal of soluble
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G. J. Remus

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

We note in extending your schedule here that you

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

that the 80 percent removal would not be achieved even by

1975 or 1976.

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

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

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

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

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

we have accepted even sulfide wastes from a steel pickling

industry in small amounts if they neutralize it first. We

have allowed the steel industry to put their wastes in

within our system. So that total phosphate that comes into

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

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

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

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

wonderment about what is happening in our system.

To further emphasize that, when the steel mills

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

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

use 80 percent factor there.

We have another factor that we refer to in our
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G. J. Remus

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

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

the contract. We have informally discussed this with the

Water Resources Commission and found no objections to making

that solid.

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

Mr. Remus, you are looking at total phosphates.

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

total figure even though the total contract is still in the

original form.

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

Mr. Purdy because what the conference recommends with regard

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

tinguished from the terminology soluble phosphate that you

have used in making your projection.

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

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

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

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

phosphate in our program.

MR. MAYO: As far as Michigan is concerned.

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

has made this commitment to the conferees several times.

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

at. There is no disagreement on it.

MR. STEIN: Are there any more questions or

comments?

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

many treatment plants other than your own exist in that

area on the map there?

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

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

and you will see a bunch of little plants identified on

there that were eliminated or are in the process of being

eliminated.

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

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

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

Warren who have challenged a grant program and the city of

Mount Clemens who saved money by running from one engineer-

ing consultant to another.

I hope somebody from Mount Clemens is here. I

wouldn't want that to be wasted.

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

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

and municipalities and industries in this area should really

get a huge amount of credit and congratulations for the

outstanding job that they have done in developing this kind
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G. J. Rernus

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

going to save the industries and the municipalities and tax-

payers in this area large amounts of money/ including Federal

grants and State grants and so forth.

I wish I could say that we had similar systems in

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

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

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

ment plants, industrial waste treatment plants, and drainage

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

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

And it really shows a very fine accomplishment that has been

attained here both in saving tax dollars for the citizens

and helping to clean up Lake Erie.

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

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

and in public statements for the Federal Government to give

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

(Laughter.)

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

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

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

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

are doing and systematically, the Rouge and the Huron will
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G. J. Remus

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

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

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

of doing it.

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

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

pretty near everybody fainted. And if everybody had approved

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

that it was approved. We did construct systematically.

We expected $172 million worth of construction to

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

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

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

least another $175 million.

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

orderly way for the entire area.

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

the Detroit system and in your summary of construction

information, you both used the terminology"advanced treat-

ment. "

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

am having fits about this business of what concentrated

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

is how it came out — or secondary treatment or tertiary
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G. J. Remus

treatment. Our treatment is made up of oxygenation and the

use of chemical treatment to the extent that it is necessary

in combination to take care of both the organic and inorganic

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

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

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

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

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

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

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

more sophisticated and we are dealing with the things you

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

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

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

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

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

pounds per day, possibly percentages, but hopefully pounds —

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

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

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

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

spread. You are not talking about the same thing.

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

have taken on these specifics — and, by the way, we have
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G. J. Remus

gotten this from the industrial people representing Chrysler

and Ford on meaningful terms today, and that is generalized

terms.

MR. REMUS: I agree with that 100 percent because

there is so much confusion existent today about what we are

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

can spend a week explaining that.

MR. STEIN: That's right.

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

the current stipulation under which you are operating has a

completion date of the fall of 1970.

MR. REMUS: Right.

MR. MAYO: And that you presently have before the

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

sequent stipulation. Is there any range of dates specifi-

cally being discussed?

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

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

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

tion. We lost in awaiting financing and in clearing red

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

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

we are not very far out of step.

These contracts that we have referred to, and we
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G. J. Remus

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

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

1972, and I think you will see great improvement.

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

Mayo, that request was placed before our Commission, and

the Commission recognized that any extension of time would

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

Lake Erie conference decision. The Commission did not act

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

Water Quality Administration officials. And at their

request, the Commission has delayed any action upon that

extension of time pending progress by the city of Detroit.

And that is where it lies at the moment.

MR. REMUS: I would want to emphasize that since

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

shows very clearly that a great many millions of dollars of

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

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

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

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

theless, the basic construction program is under way.

When did we start?

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

41 years. But in World War II, if you said something when
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"G. J. Remus

the Federal Government came in and stopped automobile produc-

tion and started the airplane production about getting that

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

that's really where the great amount of this deterioration

from the standpoint of keeping up with the job occurred.

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

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

approximately 400 MGD would be received in primary only and

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

fied as "advanced."

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

are referring to twice the capacity for half the amount on

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

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

would be treated with polymers and chemical precipitation.

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

basis of data we have prepared.

MR. MAYO: You have indicated that all of the

approximate thousand MGD will receive what you have identi-

fied as advanced treatment by 1976.

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

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

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

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

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

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

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

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

MR. MAYO: Thank you very much.

MR. STEIN: Any other comments or questions?

(No response.)

I admire your financing, and I am not going to

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

get you as much as I can.

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

that I think that you certainly ought to be commended for

working out as effective a plan with your suburban communi-

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

you have had to go the hard way through negotiations.

MR. REMUS: Thank you.

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

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

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

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

there is no question that you have been more successful here

than we have anywhere else in dealing with that kind of

problem.

Are there any other comments?
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503

G. J. Remus

(No response.)

Let me just tell you a little bit because I know

you get confused or everyone gets confused on this financing

and Federal operation. But because we have had to consider

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

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

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

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

After they finally sued, they came into Washington and asked

for it again.

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

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

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

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

I was going to say a little before we stopped this

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

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

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

was sitting there quietly. But they all grabbed for the

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

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

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

cost me 50 cents on the dollar."

The other fellow said, "Heck, I am in the 90
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G. J. Remus

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

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

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

make 6 percent."

Thank you, Gerry.

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

check.

MR. STEIN: I was in good company.

Thank you, Gerry.

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

quite pleased and very proud of the accomplishments that

have been made in pollution control here in southeastern

Michigan through the regional system. Significant progress

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

nificant delays, but you can see a program unfolding.

Yesterday, in the Government's presentation, if

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

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

many units of government in a regional system that this

required time and that there might be delays in unfolding

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

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

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

this is the sort of program I think we see developing here
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505

H. S. Liebert

in the southeast Michigan area.

I have one other request to make a statement. I

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

Liebert, representative of the Downriver Antipollution

League.

Mr. Liebert.

STATEMENT OF HILLEL S. LIEBERT

DOWNRIVER ANTIPOLLUTION LEAGUE

ANN ARBOR, MICHIGAN

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

make my statement without any advance warning. I walked in

and asked to be able to do this, and lo and behold1 I was

the next speaker.

My name is Hillel Liebert. I am a social worker

student in community practice at the University of Michigan.

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

the Downriver Antipollution League to make a few comments, a

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

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

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

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

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

it is with us. The Downriver Antipollution League is made
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H. S. Liebert

up mostly of working people in the downriver cities.

Southwest Detroit is included, but River Rouge, Ecorse,

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

where our members live.

They couldn't be here today because many of them

are working. We have heavy representation among UAW workers,

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

area.

Mainly, the statements deal with citizen partici-

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

brief I can be.

First of all, we feel citizen participation is

very important. Back at school where social workers talk

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

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

when I come to hearings of the various enforcement officials,

bodies, when I see the newspaper headlines, when we speak

with officials and write to them and receive replies, we

find this is not really as in as we would like it to be.

And we find that citizens do not have as much influence as

we thought or that people in the campuses perhaps think they

have right now.

We feel that citizens can best represent citizens.

And we feel that there is need to make some changes in the
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507

H. S. Liebert

procedures and processes that people in the pollution field

are setting up and following right now.

We feel also that citizens can help. We feel we

can help officials on all levels. In particular, the people

in the downriver area say that they have a very special

position. They work in the plants. They have a lot of

information. And they have been offering this information,

but it hasn't been taken up. Their offers have not been

taken up. And they want you to know that they are willing

to cooperate and to help in cleaning up the environment in

every possible way.

I think it is important, especially in these

times of unrest, that citizens are involved on all levels

before crises emerge and they start picketing as well as

after crises like the mercury one emerge. In these times,

I think it is important that citizens have not only a

feeling that they have some control over the environmental

forces around them and that are affecting their daily lives,

but that they actually have a significant degree of control

over these forces.

We feel that the commissions, including the Water

Resources Commission of the State of Michigan, need widen-

ing. And one reason we are interested in this particular

hearing is that we feel Federal intervention may be necessary
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508

H. S. Liebert

because we don't seem to be able to get anywhere when we

ask for citizen participation on the top levels; citizen

representation on commissions such as the Water Resources

Commission. And we find when we read back, John Kenneth

Galbraith wrote about counterbalancing power where the

giant labor unions on the one hand and giant business cor-

porations on the other hand will counterbalance each other

and the public interest will somehow be served. We find

when we read about this and we talk about this that it is

not true in the water pollution field. There are no labor

representatives on the Water Resources Commission to repre-

sent the so-called powerful labor interests and to counter-

balance the interests of the big business corporations in

this State.

This is the main concern of the Downriver Anti-

pollution League right now. This is what they asked me to

say.

On two particular issues, we feel we have been

getting a run-around. One of them is the mercury issue, of

course. I am not going to say too much about that. We had

a district engineer from the Water Resources Commission

toward the end of March speaking at a public meeting of ours,

He was extremely defensive about questions dealing with

VJyandotte Chemical Company and mercury pollution.
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509

H. S. Liebert

He was even more defensive when we brought up the

question of thermal pollution which might result from the

Detroit Edison nuclear plant — I think it is called the

Enrico Fermi plant -- in Monroe where many of our members

are very upset by the fact that they don't seem to be instal-

ling cooling towers or concerned too much about possible

damage to the environment, and they are operating.

We feel people aren't listening to us. We feel

we have interests to represent, and we have a contribution

to make. These two issues in particular are up right now

for discussion, and we hope that citizens will be involved.

It is true there are procedures like this. I am

allowed to get up here and speak. But we find that the

general structure, not only of the commissions, but of

hearings and procedures and setting of standards make it

very difficult for citizen groups to be involved and make

their feelings known. Just the general attitude of officials,

the way the people are spoken to and dealt with, makes it

very difficult for us to say what is on our minds.

We also feel that although the enforcement officials

do have problems in the areas of funds, funding and enabling

legislation, that they seem to be overly concerned with busi-

ness interests, interests involved in tourism, and less con-

cerned with the citizens who live and use recreation
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510

H. S. Liebert

- facilities in the areas affected or involved.

We feel we need strong penalties, and we need

strong enforcement of those weak penalties we now have if we

are going to get anywhere. And we feel that small people

and people in the middle areas such as the commercial fisher-

ment in Lake St. Clair need compensation for losses caused

by such companies as Dow of Canada -- the future losses per-

haps from other companies on this side in the mercury area.

And we feel we are not going to get any action unless there

is Federal intervention. At least, at this time, this is how

we feel.

Federal standards are extremely important. And

Federal pressure on State officials is what we think will

really count.

And thank you very much for letting me just say

this. This is our feeling right now and our attitude. And

that is about all they wanted me to convey.

MR. STEIN: Thank you, Mr. Liebert.

Mr. Purdy.

MR. PURDY: Mr. Liebert, I think that you do know

that there is a 7-member Water Resources Commission. Three

of those members are citizen members at the present time

appointed by the Governor. That's not quite 50 percent,

but there is citizen participation in the Commission.
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511

H. S. Liebert

The Commission does not determine who the members

will be. This is a legislative matter.

The Commission has not opposed widening of repre-

sentation on the Commission. To my knowledge, there has

never been a bill introduced in the legislature to place a

representative of labor unions on the Commission. I would

imagine that if such a bill were introduced that the Com-

mission would support this sort of widening of representa-

tion.

So I believe that your criticism of the Commission

from that standpoint is somewhat unfair.

MR. LIEBERT: Thank you, Mr. Purdy, for your

support in our request or what I think is your support.

There is a bill, or I have been told there is a bill, which

asks additional representation on the Commission from the

Department of Commerce.

MR. PURDY: That's correct.

MR. LIEBERT: And we would hope that the legis-

lators we have been speaking with, if this bill hasn't

already been disposed of, and the Water Resources Commission

would ask that this bill be amended to specify conservation

interests to be represented and labor interests as well.

MR. PURDY: Generally, a good way to kill legis-

lation is for the administrative agency to ask that something
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512
H. S. Liebert

be included in it. The legislators seem much more responsive
to the citizens rather than the administrative agencies who
are frequently referred to as bureaucrats that are only
trying to widen their scope of power. So I say to you that
you ought to contact your legislators and get them to intro-
duce that amendment. And you will be much more successful
in doing that than having the Water Resources Commission
attempt to do that.
MR. LIEBERT: Yes, sir, I think our members have
been trying to do this. And I think you are right.
One of the problems we had, though, or we felt
that exists, is the fact that when you have all these
department heads on the Commission, it is hard to get action.
There are conflicts of interest, and there are vested interests,
And we would prefer to see them as consultants rather than
as voting, active members of this Commission.
But I know this isn't really the business of this
body.
MR. STEIN: Yes, I am not sure you are making your
pitch before the proper forum. I don't know whether we
agree or disagree with you.
Thank you very much.
MR. PURDY: That completes the presentation on the
part of Michigan. I would like to make one closing comment
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513
on Michigan's behalf.

Yesterday, you referred to the problems of pollu-

tion in Lake Erie. We had a presentation by the Bureau of

Commercial Fisheries in which certain recommendations were

made. And they said that the solution to the problems of

Lake Erie was the removal of nutrients and under question-

ing specifically stated phosphates to be the key. Other

problems that have been identified in the Detroit River and

Lake Erie are problems caused by bacteria" of human origin

as it relates to the coliform organism as the identifying

form, although Lake Erie as a whole does not have a bacterial

contamination problem.

Other problems have been suspended solids of muni-

cipal and industrial waste origin — phenols primarily of

industrial origin, oils of industrial origin, waste acid from

steel mills, and then the organic oxygen-consuming substances

as measured by the biochemical oxygen demand, largely trace-

able to paper mills and municipal waste sources.

Now, I think really that major progress has been

made in the battle to save Lake Erie, in particular since

the problem in Lake Erie as a whole relates to the nutrient

input and in particular phosphates. We pointed out that

the Detroit Water Board system that serves some 40 percent

of the population of Michigan represents the largest single
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514
input.

Also, now, it has provided treatment to take the

phosphate nutrients, tie them up so that they are not

available now to feed the algae loads in Lake Erie.

Significant progress has been made in controlling

the bacteria of human origin. The suspended solids load

from industry has been largely now reduced to the objectives

that the Water Resources Commission has set. And those

objectives had been agreed to by the conferees.

The polyelectrolytes will be added to the Detroit

water for the system in 1971, and there will be significant

reduction of suspended solids of municipal waste origin.

The phenol problem is yet to be licked entirely.

The oil problem, though, has been substantially

corrected. This was largely of industrial origin.

The waste acid from steel mills now has been com-

pletely eliminated. As a waste, it has been fed on a control

basis in the Detroit system to control nutrients.

So I am not quite as discouraged as some of your

remarks might have indicated yesterday. I think that major

progress has been made towards saving Lake Erie. There are

remaining problems of major concern, but these problems now

affect largely localized areas within the Detroit River and

the localized area near the mouth of the Raisin River.
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515

G. H. Eagle

There are some dissolved oxygen problems there

right at the mouth of the river, and there are the coliform

problems on the Sterling State Park beaches. But again,

construction is under way to correct those problems, and we

can see an end. So I am encouraged by the progress that has

been made.

MR. STEIN: Thank you.

Are there any comments or questions?

(No response.)

If not, does Michigan have any more?

MR. PURDY: That's all.

MR. STEIN: I think we will be able to complete

the presentations of the other States before the noon break.

And this afternoon, we will devote to mercury.

At this point, we would like to call on Ohio.

STATEMENT OF GEORGE H. EAGLE

CHIEF ENGINEER

OHIO DEPARTMENT OF HEALTH

MR. EAGLE: Mr. Chairman, conferees, ladies and

gentlemen, my name is George H. Eagle. I am Chief Engineer

of the Ohio Department of Health. The Division of Engineer-

ing serves as the technical staff of the Ohio Water Pollution

Control Board. On behalf of the Board and the Department,
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G. H. Eagle

"I wish to submit this report in its entirety for the record.

I am going to skim through this report to some

extent.

With regard to municipal programs, the conferees

established corrective measures and schedules of construc-

tion for 95 municipalities involving 97 projects, 77 of these

municipalities were to have the required facilities completed

by December 31, 1969. The progress to date with respect to

these requirements is as follows:

This is basically the same data Mr. Harlow presented

yesterday, but the summaries are quite different. And you

will note here that of these 77 municipalities, only 35 had

completed and placed into operation their facilities.

Another 33 of them are in the construction or planning stage

at this time, and there are nine that I will report on separately.

But of these 33, in the next paragraph, explanation is given

of what the status of these are, the progress that they are

making.

And of the remaining nine, three of these nine

communities have failed to make satisfactory progress in the

planning of the required facilities. These communities —

namely, Avon, Independence and Oakwood — have been ordered

after public hearings by the Board to submit reports and

general plans by September 1970. To prevent further water
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517

G. H. Eagle

pollution from these communities, the Board has prohibited v

any new connections to the sewer systems of these communities

which contribute additional pollution to waters of the State.

In essence this means a freeze on any new building in these

communities. Three more communities, namely, Grand River,

Northwood, and Waterville, are required to complete the neces-

sary legislation and to provide the necessary sewers for con-

veying their municipal wastes to the facilities of another

municipality. Two communities are preparing revised plans

for facilities to accommodate expanded service areas. The

ninth community finally hired an engineer in February of this

year.

The schedules adopted by the conferees called for -

the completion of 15 more municipal projects by December 15,

1970. Five of these are currently under construction, two

will be completed this year and the other three will be com-

pleted during 1971, Detail plans have been approved for the

sixth municipality with construction to begin this fall. A

seventh is preparing detail plans. Of the remaining eight

municipalities, six have failed to make satisfactory progress

in planning the necessary facilities. As a result three

have been ordered by the Board to prepare the required detail

plans prior to January 1, 1971. These three are Broadview

Heights, Euclid and Willoughby, all in the Cleveland area.
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518

G. H. Eagle

In addition, Painesville and Amherst have been ordered to

complete detail plans and general plans respectively by

September 1970 and Fairport Harbor has been ordered to com-

plete negotiations for connection to the Painesville

systems. The Board here again has imposed a "freeze" on

any new building in Painesville, Fairport Harbor and Broad-

view Heights. Of the remaining two, the City of Sandusky

is required by current permit to initiate construction, and

the City of Delphos is required by permit to authorize the

preparation of detail plans by June 1970.

The facilities under construction by the City of

Akron are one of the two projects mentioned above to be com-

pleted this year. In fact, these facilities should be com-

pleted by July 1. Concurrently with the completion of this

project three of the four major rubber companies will com-

plete this fall major pretreatment facilities for the signi-

ficant reduction of latexes discharged to the Akron city

sanitary sewer system. A fourth company is expected to

complete its latex removal facilities next spring. Also by

next spring, facilities for the recovery of spent pickle

liquors from a major operation now discharged to the sanitary

sewer system will be placed in operation.

These have been quite a problem in the City of

Akron as pointed out here. And these pretreatment facilities
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519

G. H. Eagle

are being installed in accordance with the City of Akron and

Ohio Department of Health requirements. And the general

clean-up of the other industrial waste problems in the City

of Akron, and in view of the above, these major improvements

of the system in Akron should considerably improve the water

quality of the Cuyahoga River downstream from Akron this

summer. This has been a very, very difficult problem.

The schedule adopted by the conferees for the com-

pletion of projects beyond 1970 are as follows. Cleveland-

Westerly December 1971, Lake County-Madison Sewer District

January 1, 1971, Lake County-Willoughby-Mentor Sewer District

January 1, 1971, and Toledo February 1972.

Toledo is under construction, and these others are

in the various stages of planning. And the Board has ordered

the City of Cleveland to submit detailed plans of improvements

to the westerly plant by November 1970. This order was given

because the City of Cleveland failed to comply with earlier

permit conditions calling for general and detail plans

acceptable to the Division of Engineering. The orders of

the Board were supplemented by a ban on additional pollution

of waters of the State by the city, here again, by the build-

ing freeze type of order in the City of Cleveland.

And the details of all of this are given in Table 1,

Appendix A.
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520

G. H. Eagle

With regard to phosphorus removal, remember, at

the last session, we gave a rather detailed report on the

facilities that were being ordered and planned in Ohio for

phosphorus removal. And our policy was adopted by the

Department to require all plants to design capacity of one

million gallons per day or more to provide phosphate removal

facilities.

Major facilities now under construction and in a few

instances nearing completion which will provide phosphorus

removal include those of Ashtabula, Avon Lake, Cleveland-

Easterly, Lorain, Port Clinton, Toledo, Akron, Defiance and

Findlay. The last three discharge to tributary streams

whereas the first six discharge directly to the lake. The

combined phosphorus load to these facilities is estimated

to be 16,600 pounds per day or nearly half of the total

estimated Ol.io municipal load to Lake Erie. Phosphorus

removal facilities at the Cleveland-Westerly plant have been

in operation for a number of months with temporary facilities

on an experimental basis.

Later this year major phosphorus removal facilities

are expected to be placed under construction at Rocky River.

With regard to the industrial programs, completion

schedules for facilities for the abatement of water pollution

by discharges of industrial wastes to the waters of the State
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521

G. 11. Eagle

were a'dopted by the conferees for 97 Ohio establishments.

In no instance did these dates extend beyond December 31,

1969, that is, for completion. Sixty of the required pro-

jects have been completed, four other industries have ceased

operations. Fifteen others have facilities under construc-

tion; 13 of these are expected to be completed this year.

Eleven others are expecting to connect to municipal sanitary

sewers in their areas. Plans of proposed facilities for

five industries have been prepared and are awaiting approval.

One other industry is planning to cease all operations this

fall. Studies are underway at one plant which has built

substantial in-plant facilities for the recovery of process

chemicals.

One of the proposals for the discharge of indus-

trial wastes to municipal sewers is rather unique and may be

of interest to the conferees. The City of Cleveland is

planning to accept the calcium sulfate wastes from the Harshaw

Chemical Company into its sewer system for conveyance to the

Southerly plant. This waste is expected to aid substantially

in the city's proposal for removal of phosphorus of this

plant.

Water quality standards — suffice it to say here

that Ohio has revised water quality standards criteria which

were adopted on April 14, 1970, and were worked out with the
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522

G. H. Eagle

Federal people and have been submitted to the Secretary for

approval. These are appended in Appendix B of this report.

And these criteria include the statement on the protection

of high quality of waters.

And I might point out that these criteria apply to

Lake Erie or portions thereof where such quality levels are

better than existing water quality. In the Lake Erie water

quality standard, we stated where they were not better than

the existing quality, the existing quality in the lake

would prevail, would become the standard.

Now, with regard to advanced municipal waste

treatment or 95 percent removal if you prefer or whatever

you want to call it, we have a number of places in Ohio that

call for more than the conventional secondary treatment.

And these are listed here. There are about 10 municipalities

that now are presently in one stage or another providing so-

called advanced waste treatment facilities.

Now, on the next page, we speak about the exces-

sive stormwater problems in combined sewer overflows. And

these are very serious problems in and around the City of

Cleveland. And failure of the City of Cleveland was one of

the reasons that they were given an order to prohibit any

further contacts until this program moved forward.

Another serious problem is the use of storm sewers
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G. H. Eagle

of the City of Euclid which conveyed industrial wastes to

Lake Erie. Legally, the use of this sewer — I think Mr.

Harlow mentioned this in his report yesterday — is under

the jurisdiction of the city, of course. Action towards

correction of pollution caused by the wastes in this sewer

has been hampered for a number of years due to prolonged

litigation between the city and an industry over damages to

this sewer. Recently, a member of our staff has carried

out several investigations of this problem in cooperation with

the city. As a result recommendations as to treatment re-

quirements were made to the city by the Ohio Department of

Health staff. Furthermore, as a guideline, the staff pro-

vided the city water quality objectives for defining storm-

water, which are in effect criteria for water quality for

all uses. And a copy of this has been provided the Cleveland

office of FWQA.

Industrial waste in the Ashtabula area, this is a

problem of long standing. And while a lot of improvements

have been made, conditions are still far from satisfactory.

And I think we are going to have a workshop in Ashtabula so

this will probably be taken up in detail there. But to

correct this problem, the Board has requested or more or

less ordered the industries to give serious consideration

to a joint terminal facility for treatment of the combined
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524

G. H. Eagle

industrial waste effluent from this field growth.

JUst in conclusion, I would like to mention that

one of the reasons — not an excuse, but certainly it is a

reason — why we are behind on these schedules, particularly

with regard to municipalities, is that we have lost practi-

cally a year and a half in trying to implement the $100

million bond issue that was passed in Ohio in November 1968,

to provide the necessary funds to finance these projects

from the State and the Federal Government. Of course, in

the meantime, the Federal appropriations have been increased.

I am very happy to report that now our funding on

the 30 percent basis for all projects is fully underway. And

we have close to a half a billion dollar program over the

next three or four years — two or three years, hopefully —

underway, a.nd we will be in process in one form or another

in the construction stage within the next two or three years.

This will certainly accelerate conditions considerably, we

feel.

That's all. Thank you.

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

extensive reort. The whole report, without objection, will

appear in the record as if read.

(The above-mentioned report follows in its

entirety.)
-------
525
(1D.C3'!(;.'„;-
E. W.
-------
526

STATEMENT OF DIVISION OF ENGINEERING

OHIO DEPARTMENT OF HEALTH
Mr. Chairman, conferees, ladies and gentlemen, my name is George H. Eagle.
I am Chief Engineer of the Ohio Department of Health. The Division of Engineering
serves as the technical staff of the Ohio Water Pollution Control Board. On
behaJf of the Board and the Department. I wish to submit this report in its
entity for the record.

This report is a progress evaluation of Ohio's program for compliance with the
conclusions and recommendations of the Lake Erie Pollution Enforcement Conference
of August 1965.

MunicipalPrograms

The conferees established corrective measures and schedules of construction
for 95 municipalities involving 97 projects, 77 of these municipalities were to
have the required facilities completed by December 31> 19&9- -^ie progress to date
with respect to these requirements is as follows:

Number of municipalities requiring facilities by December 31? 19^9 - 77

Number completed 35
Number under construction 10
Number - detail plans approved 12
Number - reports and general plaus approved 11
Number remaining 9

Of the 10 projects under construction eight are to be completed this year,
and two are to be completed during 1971- Of the 12 communities with approved
detail plans, six a,re expected to complete the construction of their facilities
during 1971 and three are expected to complete their facilities during 1972; two
projects are being he3_d up by litigations. Construction has been delayed for one
small project to arrange for the necessary finances. Most of the area of this
community is tributary to other facilities. Detail plans are currently in
preparation for the 11 communities with approved reports and general plans.
These plans are expected to be completed later this year or early next year.
Upon approval of the detail plans, it is expected that construction will begin
within 90 days and that construction will be completed late in 1971 or early 1972.

Three of the nine communities remaining have failed to make satisfactory
progress in the planning of the required facilities. These communities, namely
Avon, Independence and Oakwood have been ordered after public hearings by the
Ohio Vator Pollution Control Board to submit reports and general plans by
September 1970. To prevent further •water pollution from these communities, the
Board has prohibited any new connections to the sewer systems of these communities
which contribute additional pollution to waters of the state. In essence this
means a freeze on any new building in these communities. Three more communities,
namely Grand River, Northwood, and Waterville, are required to complete the
-------
527

necessary legislation and to provide the necessary sewers for conveying their
municipal wastes to the facilities of another municipality. Two communities
are preparing revised plans for facilities to accommodate expanded service areas.
The ninth community finally hired an engineer in February of this year.
v
The schedules adopted by the conferees called for the completion of 15 more
municipal projects by December 15, 3-970. Five of these projects are currently
under construction, two will be completed this year and the other three will be
completed during 1971. Detail plans have been approved for the sixth municipality
with construction to begin this fall. A seventh municipality is currently revising
detail plans. Of the remaining eight municipalities six have failed to make
satisfactory progress in planning the necessary facilities. As a result three
have been ordered by the Board to prepare the required detail plans prior to
January 1, 1971. These throe municipals tics are Broadview Heights, Euclid and
Willoughby. In addition, Paincsvi.lle and Amlierst have been ordered to complete
detail plans and general plans respectively by September 1970 and Fairport Harbor
has been ordered to complete negotiations for connection to the Painesville
systems. Furthermore, the Board has imposed a "freeze" on any new building in
Painesville, Fairport Harbor and Broadview Heights. Of the remaining two, the
city of Sandusky is required by current permit to initiate construction, and
Delphos is required by permit to authorise the preparation of detail plans by
June 1970.

The facilities under construction by the city of Akron are one of the two
projects mentioned above to bs completed this year. In fact, these facilities
should be completed by July 1. Concurrently with the completion of this project
three of the four major rubber companies will complete this fall, major pre-treatment
facilities for the significant reuuevion of lutc;:etj discliui'god to the Aluron city
sanitary sewer system. A fourth company is expected to complete its latex removal
facilities next spring. Also by next spring, facilities for the recovery of spent
pickle liquors fro-,r. a major operation now discharged to the sanitary sewer system
will be placed in operation. The above vaste increments have placed a major burden
on and have interfered with the performance of the facilities of the city of Akron.
These pre-treatment facilities are being installed in accordance with requirements
of the Ohio Department of Health, working in cooperation with officials of the city.
The industrial waste discharge of ^0 other industrial discharges to the sewer
system have been found to be in violation of City Code and orders for corrective
measures have been issued by the city in accordance with the requirements of the
city's permit from the Board. In view of the above, major improvements of the
water quality of the Cuyahoga River downstream of Akron is expected by next summer.

The schedule adopted by the confci^ccc for the completion of projects beyond
1970 are as follows. Cleveland-Westerly December 1971, Lake County-Madison Sewer
District January 1, 1971, Lake County-Willoughby-Mcntor Sewer District January 1,
1971, and Toledo February 1972. The facilities for the city of Toledo were placed
under construction in April 1970. The Board has required by permits, detail plans
for Madison Sever District by October 1970 and genera,! plans for Uilloughby-Mentor
by June 1970. The Board has also ordered the city of Cleveland to submit detail
plans of improvements to the Westerly plant, by Roveir.bcr 1970, This order was
given because the city of Cleveland failed to comply with earlier permit conditions
calling for general and detail pi ens acceptable to the Division of Engineering.
The orders of the Board were supplemented by a ban on additional pollution of
waters of the state by the city.

-2-
-------
528

• Information on the status of compliance of each municipal project with the
recommendations and conclusions of the conferees are given in Table 1, Appendix A.

Phosphorous RCTOval

At the last session of the conference Ohio's program for phosphoroiis removal
was presented. Included was a list of those cities which have been required to
install phosphorous removal facJlitics, Included were 15 facilities which dis-
charge directly to T,ake Erie and 20 facilities which discharge to Ohio tributaries
to Lake Erie. The Ohio Department of Health has adopted a policy of requiring
phosphorous removal at all plants with a design capacity of 1.0 mgd or more.

Major facilities now under construction and in a few instances nearing
completion which A/ill provide phosphorous removal include those of Ashtabula,
Avon Lake. Cleve3.and-Easterly, Lorain, Port Clinton, To3.edo, Akron, Defiance and
Findlay. The last three discharge to tributary streams whereas the first six
discharge directly to the Lake. The combined phosphorous load to these facilities
is estiru/bed to be 16.600 pounds per day or nearly half of the total estimated Ohio
municipal load to Lake Erie, Phosphorous remove! facilities at the Cleveland-
Westerly plant have been in operation for a number of months with temporary
facilities on an experimental basis.

Later this year major phosphorous removal facilities are expected to be
placed under construction at Rocky River.

Industrial P^{2~£M£

Completion schedules for facilities for the abatement of water pollution by
discharges of industrial wastes to the waters of the state were adopted by the
conferees for 97 Ohio establishments. In no instance did these dates extend
beyond December 31? 1969- Sixty of the required projects have been completed,
four other industries have ceased operations. Fifteen others have facilities
under construction; thirteen of these are expected to be completed this year.
Eleven others are expecting to connect to municipal saaitary sewer systems; five
of these eleven are currently negotiating for connection to municipal sewers and
the other six are awaiting the construction of municipal sewers in their areas.
Plans of proposed facilili es for five industries have been prepared and are
awaiting approval. One other industry is planning to cease all operations this
fall. Studies are underway at one plant which has built substantial in-plant
facilities for the recovery of process chemicals.

One of the proposals for the discharge of industrial wastes to municipal
sewers is rather unique and may be of interest to the conferees. The city of
Cleveland is planning to accept the calcium sulfate wastes from the Harshaw
Chemical Company, into its sewer system for conveyance to the Southerly plant.
This waste is expected to aid substantially in the city's proposal for removal
of phosphorous of this plant.
-------
529
As reported at the last session, the Ohio Water Pollution Control Board had
adopted Water Quality Standards for all significant Ohio tributaries of Lake Erie:-
On AprilT^-, 1970, the Board adopted amended criteria of stream water quality for
various water uses. A copy of the Board's resolution is included in Appendix B.
The amended criteria up grades waters classified as Aquatic Life A, Aquatic Life B,
and recreational waters. The revised criteria for Aqmtic Life A up grades the
requirements for dissolved oxygen, water temperatures and pH. For Aquatic Life B
the revised criteria up grades the requirements for dissolved oxygen and pH. The
revised criteria for recreational water uses consists of a fecal coliform limit
in place of the total coliform limit .

The above criteria are to be applied to all respective standards adopted by
the Ohio Water Pollution Control Board for all tributaries of Lake Erie. Further-
more, these criteria are also to be applied to Lake Erie or portions thereof where
such quality levels are better than existing water quality, otherwise existing
quality levels are to prevail.

The amended criteria, adopted by the Board on April 1^4 , 1970 includes a policy
statement with regards to the protection of high quality waters. This policy shall
be applied to Lake Erie and all applicable sections of the tributary streams. To
meet the Water Quality Standards established for Lake Erie and its tributaries
will require, in a number of instances, treatment facilities or corrective measures
in addition to those originally established by the conferees. In addition, further
corrective measures are required as the result of expansions, changes in processes,
annexations, population growth and the obsolescence of existing facilities. New
or additional requirements to meet these conditions as set forth by permit conditions,
board orders or the establishment of intrastate water quality standards for municipal
facilities are given in Table 3> Appendix A, likewise the new or additional
requirements for industrial establishments are given in Table h, Appendix A.

Advanced I'lOnLcipal _Wa.ste Treatment

For municipal wastes the standards call for the construction of advanced
waste treatment facilities in a number of critical areas . The communities and/or
facilities for which this requirement has already been established are as follows :

Ada Cleveland-Westerly
Akron Delphos
Archbold Findlay
Bryan Lima
Cleveland-Easterly Van Wert
Cleveland-Southerly Wapakoneta

The facilities for Findlay are currently under construction and detail plans
of such facilities have been approved for Archbold and a report and general plan
has been approved for Bryan. The current permits for the other communities call
for the submission of reports and general plans for such facilities prior to the
expiration date. In no instance, is a permit calling for improvements granted
for a period of more than one year.
-------
530

-Also in accordance with the adopted Water Quality Standards most permits
include a condition calling for the correction of excessive storm water problems
and combined sewer overflows. The latter is a most serious problem in and
around Cleveland, Failure of the city to provide an adequate program for the
correction of this problem was an important factor in the Board's action of
imposing a ban on any additional pollution of the "waters of the state" by the
city.

Another serious problem is the use of a storm sewer of the city of Euclid
for the conveyance of industrial wastes to Lake Erie. Legally the use of this
sewer is under the jurisdiction of the city. Action towards correction of
pollution caused by the wastes in this sewer has been hampered for a number of
years due to prolonged litigation between the city and an industry over damages
to this sewer. Recently, a member of our staff has carried out several investi-
gations of this problem in cooperation with the city. As a result recommendations
as to treatment requirements were made to the city by the Ohio Department of Health
staff. Furthermore, as a guideline, the staff provided the city water quality
objectives for defining storm water. A copy of these guidelines have been
furnished to the Cleveland office of Federal Water Quality Administration for
their comments.

Industrial Wastes__- Ashtabula Area

The program of corrective measures adopted by the conferees for the industrial
waste discharges from the chemical complex in the AshtaTrula area were based on
production and process operations at that time.

As originally conceived some of the wastes of one plant became a part of the
raw materials of another plant. This is no longer the case with respect to
hydrochloric acid which was produced as a by-product. Waste treatment facilities
constructed in accordance with requirements of the conferees were not capable of
treating the no longer saleable by-product. To cope with this problem additional
corrective measures were required. Furthermore, the interaction of the treated
wastes from these industries plus those who have recently constructed new plants
is such that the waters in Fields Brook do not meet the criteria for asthetic
conditions and the discharge of this stream into the Ashtabula River is such that
it seriously degrades the water quality of the river. To correct this problem
the Board has requested the industries to give serious consideration to a joint
terminal facilities for treatment of the combined industrial waste effluents.
-5-
-------
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APPENDIX B
-------
563
WATER POLLUTION CONTROL BOARD
OHIO DEPARTMENT OF HEALTH
* COLUMBUS, OHIO

RESOLUTION ESTABLISHING AMENDED CRITERIA OP STREAM-WATER QUALITY
FOR VARIOUS USES ADOPTED BY THE BOARD ON APRIL lU, 1970

WHEREAS, Section 6111,03, of the Ohio Revised Code, provides, in part,
as follows:

"The water pollution control board shall have power:

(A) To develop programs for the prevention, control and
abatement of new or existing pollution of the waters of
the state; ,.,," and

WHEREAS, Primary indicators of stream-water quality are needed as
guides for appraising the suitability of surface waters in
Ohio for various uses; and

WHEREAS, The stream-water quality criteria for various uses and
minimum conditions applicable to all waters adopted by the
Board of June lU, 1966, have been amended by the Ohio River
Valley Water Sanitation Commission; and

WHEREAS, The criteria adopted by the Board on October 10, 1967, have
been further amended by the Ohio River Valley Water Sanitation
Commission;

THEREFORE BE IT RESOLVED, That the following amended stream-water quality
criteria for various uses, and minimum conditions applicable to
all waters, and policies for protection of high quality waters
and for water quality design flow, are hereby adopted in
accordance with amendments of the Ohio River Valley Water
Sanitation Commission, and the recommendations of the Federal
Water Pollution Control Administration.

AND BE IT FURTHER RESOLVED, That the amended stream-water quality criteria
for various uses, for minimum conditions, for protection of high
quality waters, and, for water quality design flow, be made
applicable to the following waters of the state:

1. Maumee, Tiffin, St, Joseph, and St, Marys River Basins;
2. Lake Erie & Interstate Waters thereof;
3, Great Miami, Whitewater, and Wabash River Basins;
U, Ashtabula River, Conneaut and Turkey Creeks;
5, Ohio River of Ohio-West Virginia and Ohio-Kentucky;
6, North Central Ohio Tributaries of Lake Erie;
7. Scioto River Basin;
8, Little Miami River Basin;
9, Rocky, Cuyahoga, Chagrin and Grand River Basins;
10. luskingum River Basin;
11. Hocking River Basin,
-------
564
MINIMUM CONDITIONS APPLICABLE TO
ALL WATERS AT ALL PLACES AND AT ALL TIMES

1. Free from substances attributable to municipal, industrial or other
discharges, or agricultural practices that will settle to form pu-
trescent or otherwise objectionable sludge deposits,

2. Free from floating debris, oil, scum and other floating materials
attributable to municipal, industrial or other discharges, or
agricultural practices in amounts sufficient to be unsightly or
deleterious.

3, Free from materials attributable to municipal, industrial or other
discharges, or agricultural practices producing color, odor or other
conditions in such degree as to create a nuisance,

k. Free from substances attributable to municipal, industrial or other
discharges, or agricultural practices in concentrations or combina-
tions which are toxic or harmful to human, animal, plant or aquatic
life.

PROTECTION OF HIGH QUALITY WATERS

Waters whose existing quality is better than the established standards as
of the date on which such standards become effective will be maintained at
their existing high quality, pursuant to the Ohio water pollution control
statutes, so as not to interfere with or become injurious to any assigned
uses made of, or presently possible, in such waters. This will require
that any industrial, public or private project or development which would
constitute a new source of pollution or an increased source of pollution
to high quality waters will be required, as part of the initial project
design, to provide the most effective waste treatment available under
existing technology. The Ohio Water Pollution Control Board will cooperate
with other agencies of the state, agencies of other states, interstate
agencies and the Federal Government in the enforcement of this policy.

WATER QUALITY DESIGN FLOW

Where applicable for the determination of treatment requirements the water
quality design flow shall be the minimum seven consecutive day average
that is exceeded in 90 percent of the years,

STREAM-QUALITY CRITERIA

FOR PUBLIC WATER SUPPLY

The following criteria are for evaluation of stream quality at the
point at which water is withdrawn for treatment and distribution as a
potable supply:
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565
l-ir Bacteria; Colifonn group not to exceed 5,000 per 100 ml as a
monthly average value (either MPN or MF count); nor exceed
this number in more than 20 percent of the samples examined
during any month; nor exceed 20,000 per 100 ml in more than
five percent of such samples.

2, Threshold-odor Number; Not to exceed 2k (at 60 deg, C.) as
a daily average.

3. Dissolved solids; Not to exceed 500 mg/1 as a monthly average
value, nor exceed 750 mg/1 at any time,

k. Radioactivity; Gross beta activity not to exceed 1,000 picocuries
per liter (pCi/l), nor shall activity from dissolved strontium-90
exceed 10 pCi/l, nor shall activity from dissolved alpha emitters
exceed 3 pCi/l.

5. Chemical constituents; Not to exceed the following specified
concentrations at any time.

Constituent Concentration (mg/1)

Arsenic 0.05
Barium 1.0
Cadmium 0.01
Chromium 0.05
(hexavalent)
Cyanide 0,025
Fluoride 1.0
Lead 0.05
Selenium 0,01
Silver 0.05

FOR INDUSTRIAL WATER SUPPLY

The following criteria are applicable to stream water at the point at
which the water is withdrawn for use (either with or without treatment)
for industrial cooling and processing:

1, Pissolved oxygen; Not less than 2.0 mg/1 as a daily-average value,
nor less than 1.0 mg/1 at any time.

2. pH; Not less than 5.0 nor greater than 9.0 at any time.

3. Temperature; Not to exceed 95 deg. F, at any time.

k. Dissolved solids! Not to exceed 750 mg/1 as a monthly average value,
nor exceed 1,000 mg/1 at any time,
-3-
-------
566
FOR AQUATIC LIFE A

The following criteria axe for evaluation of conditions for the maintenance
of a well-balanced, warm-water fish population, They are applicable at any
point in the stream except for areas necessary for the admixture of waste
effluents with stream water:

1. Pissolved oxygen: Not less than an average of 5.0 mg/1 per calendar day
and not less than U.O mg/1 at any time.

2. p_H:

A. No values below 6,0 nor above 8.5?

B, Daily fluctuations which exceed the range of pH 6,0 to pH 8,5
and are correlated with photosynthetic activity may be tolerated,

3. Temperature:

A. No abnormal temperature changes that may affect aquatic life
unless caused by natural conditions,

B, The normal daily and seasonal temperature fluctuations that
existed before the addition of heat due to other than natural
causes shall be maintained,

C. Maximum temperature rise at any time or place above natural
temperatures shall not exceed 5 deg, F. In addition, the water
temperature shall not exceed the maximum limits indicated in
the following table.
Maximum
WATERS
All waters except
Ohio River
Main Stem-Ohio River
Jan,
50
50
Feb.
50
50
Mar.
60
60
Temperature
Apr.
70
70
in Deg
May June July
80 90
80 87
90
89
. F,
Aug.
90
89
During
Sept,
90
87
Month
Oct.
78
78

Nov.
70
70

Dec.
57
57
Toxic substances; Not to exceed one-tenth of the US-hour median
tolerance limit, except that other limiting concentrations may be
used in specific cases when Justified on the basis of available
evidence and approved by the appropriate regulatory agency.
-------
567
\.FOR AQUATIC LIFE B

** The following criteria are for evaluation of conditions for the maintenam •?
of desirable biological growths and, in limited stretches of a stream, for
permitting the passage of fish through the abater, except for areas necessary
for admixture of effluents with stream waters

1. Pissolved oxygen; Not less than 3,0 mg/1 as a daily-average value, nor
less than 2.0 mg/1 at any time,

2. pH; Not less than 6,0 nor greater than 8.5 at any time,

3. Temperature; Not to exceed 95 deg. F, at any time,

U. Toxic substances; Not to exceed one-tenth of the US-hour median
tolerance limit, except that other limiting concentrations may be
used in specific cases when Justified on the basis of available
evidence and approved by the appropriate regulatory agency,

FOR RECREATION

The following criterion is for evaluation of conditions at any point in
waters designated to be used for recreational purposes, including such
water-contact activities as swimming and water skiing:

Bacteria; The fecal coliform content (either MPN or MF count) not
to exceed 200 per 100 ML as a monthly geometric mean based on not
less than five samples per month; nor exceed kOO per 100 ML in more
than ten percent of all samples taken during a month,

FOR AGRICULTURAL USE AND STOCK WATERING
The following criteria are applicable for the evaluation of stream
quality at places where water is withdrawn for agricultural use or stock-
watering purposes:

1. Free from substances attributable to municipal, industrial or other
discharges, or agricultural practices that will settle to form
putrescent or otherwise objectionable sludge deposits,

3. Free from materials attributable to municipal, industrial or
other discharges, or agricultural practices producing color,
odor or other conditions in such degree as to create a nuisance.

it. Free from substances attributable to municipal, industrial or other
discharges or agricultural practices in concentrations or combinations
which i toxic or harmful to human, animal, plant or aquatic life,
-------
568

G. H. Eagle

MR. STEIN: I think since we are going to have

these workshops, possibly the conferees or other people could

defer some specific comments on the material in the appendix

to the time we have these workshops.

MR. EAGLE: I would just like to point out, Mr.

Stein, we welcome these workshops, and we hope this will

result in some substantial assistance from the Federal Govern-

ment because we do have some laggards in Ohio — not too many,

but some — that we do need some help with. And any assis-

tance you can give with regard to these, we would appreciate

very much.

MR. STEIN: I am happy to say that with all the

Lake Erie States, I think particularly since we have had

these series of conferences, generally speaking, we have

problems, maybe some rough edges of State-Federal relations,

but I think it is pretty fair to say we have been working

practically as one staff for the past year or two. And you

can be assured we will give you all the help possible.

MR. EAGLE: Thank you.

MR. STEIN: Are there any other comments or ques-

tions?

MR. VOGT: I have a question, Mr. Chairman.

George, I note that in a number of instances, you

initiated, as you call it, building fees, imposed building
-------
569

G. H. Eagle

fees, on some of your communities. And this particular

technique, we have used in Michigan and found it to be rather

effective in accelerating control programs, pollution control

programs.

I am wondering what has been your experience so far

in Ohio with these types of impositions.

MR. EAGLE: Very good results. In about 90 percent

of the cases, it has solved the problem. Of course, we still

have a number of them outstanding. I think we have some 25

or 30 outstanding at this time. We started this program

about three years ago. To date more than 75 percent of them

have gotten under way to the extent that the building fees

could be lifted.

MR. VOGT: I see. That is interesting because,

in other words, it assures the initiation and continuation

of a positive program of pollution control.

MR. EAGLE: Of course, we do have on the other

side, John, some city officials prevail on us to give them

building fees because they don't want to see their munici-

pality develop. They want to keep it just like it is.

MR. STEIN: Are there any other comments or ques-

tions?

(No response.)

Thank you very much, Mr. Eagle, for a very
-------
570

W. A. Lyon

interesting contribution.

May we call on Pennsylvania?

STATEMENT OF WALTER A. LYON

DIRECTOR, BUREAU OF SANITARY ENGINEERING

PENNSYLVANIA DEPARTMENT OF HEALTH

MR. LYON: I will try not to go into any detail

and make this very brief, Mr. Chairman.

Mr. Bellaman, our Regional Engineer, is passing

out copies of our report.

I would like also permission to make as part of

the record a statement by Mayor Louis J. Tullio of the city

of Erie. And Mr. Bellaman has copies of that statement.

MR. STEIN: Both the statements will appear in

the record as if read in their entirety without objection.

(The above-referred to statements follow in their

entirety.)
-------
'.
-------
572
STATUS REPORT TO LAKE ERIE CONFEREES

Commonwealth of Pennsylvania
Department of Health

June 3, 1970
(1) Pursuant to adoption of the Lake Erie phosphorus removal plan
adopted by the Sanitary Water Board on June 18, 19&9, orders were issued
to ten industries and municipalities requiring a substantial reduction in
the amount of phosphorus discharged from their waste treatment facilities.
Compliance with the orders will result in at least 80£ reduction of phosphorus
from municipal and industrial sources in the Pennsylvania portion of the
Lake-Lrie basin. At this time, six of the ten dischargers are either in
compliance with the orders or are on schedule to achieve compliance by the
July 1, 1972 overall deadline. Four of the municipalities have requested
hearings. The municipalities that requested hearings are the Boroughs of
Girerd, North East, Lake City and Albion. The hearings have not yet been
scheduled by our Legal Counsel. We hope to have these soon.

(2) The detection of significant concentrations of mercury in Lake Erie
fish has had a deleterious effect on Pennsylvania's use of the lake's waters.
•The market for commercial fishes has been seriously affected and Governor
Shafer has had to warn sport fishermen that concentrations of mercury exceeding
FDA limits have been found in certain sport species and these should not be
consumed. Mercury in Lake Erie represents a public health threat and is
having an adverse economic effect on Pennsylvania.

Mercury analyses performed to date show detectable concentrations
of mercury in all fishes taken from Pennsylvania waters. Concentrations varied
with species and ranged from O.OA parts per million to 1.^3 parts per million.
Only edible portions of fish were analyzed. Generally, the top predators such
as walleye, smallmouth bass, white bass, and fresh water drum showed the
highest concentrations of mercury. Smelt, perch, rock bass, carp, suckers and
crappies showed lower concentrations of mercury in the flesh. Samples of
several coho salmon taken from the lake showed levels of mercury less than
0.5 parts per million but ranged from 0.3^ parts per million to 0.46 parts per
million. The Pennsylvania Fish Commission is periodically sampling fish from
Lake Erie. These fish are being analyzed by the Food and Drug Administration
Laboratories.
-------
- 2 -

573

Samplings of water and waste discharges for mercury were conducted
during April and May. Bottom mud and fish samples from the Lake were also
taken by the Pennsylvania Fish Commission for analysis. Mercury was not
detected in the lake waters and in the bottom muds at the limits of detection
of the tests. Mercury was detected in one waste water discharge, but re-sampling
indicated that mercury was not present. Contamination of the sample bottles was
possible since the first series of samples were not collected in properly cleaned
containers.

As a result of our waste water survey, we are convinced that there
are no significant sources of mercury being discharged to Lake Erie from
Pennsylvania sources. We did learn that the Hammermill Paper Company used
mercurials up to ten to fifteen years ago for slime control but discontinued
the use at that time. We have sampled the bottom muds in the vicinity of the
Hammermill outfall to determine if residual mercury is present in this area.
We will continue a surveillance program of discharges to Lake Erie.

We recommend that action be taken by the conferees to insure that
all discharges of mercury and other toxic materials to Lake Erie and its
tributaries are halted.

(3) Attached are listings of the status of sewerage and industrial waste
cases that have been considered by the Lake Erie Enforcement Conference. In
addition to these cases, permits have been issued for several small sewage
treatment plants to serve installations such as highway rest stops. These
treatment plants meet the minimum requirements established by the conferees.
-------
574
TAELE I

Sewerage Status
(June, 1970)
Name Present Status -_ Comments^

City of Erie 1. Sewage treatment plant expansion and
improvements - Plans approved for ex-
pansion and improvements that include
secondary treatment and phosphorus
removal such that the effluent will
contain no more than 1 mg/1 phosphorus
as P. Will treat Erie metropolitan
plus Hammermill Paper Company wastes.
If grant processing moves expeditious ly
should begin construction by October 1,
1970 and complete construction and
begin operation by February 15, 1972.

2. Present treatment efficiency, untreated
discharges through storm sewers -
Treatment plant now providing secondary
treatment with continuous disinfection
with exception of excessive solids loss
from final settling tanks during periods
of peak flow. Interim actions to
reduce these losses have been ordered
and include tighter operation' control.

Recent surveys indicate that 80% of
the untreated sewage being by-passed
at storm sewer outlets has been diverted
to the treatment plant. Expansion of
the treatment plant, including hydraulic
changes, is expected to achieve 100%
abatement. At present, additional sewer
extensions and new connections are pro-
hibited. A hearing on this problem
held on October 31, 1S&9 was adjudicated
on May 15, 1970, and a compliance
schedule must be submitted by August 15,
1970. Expansion of the Bay Front inter-
ceptor will ultimately be needed to
serve future growth and reduce or
eliminate overflows during storms. This
project is being held up by design of
the Bay Front highway. Sewer and highway
design arid construction will have to be
coord inated.
-------
- 2 -
Name
Present Status - Comments
575
Nortfi East Borough
Presently providing secondary treatment.
Ordered August I, 1969 to provide tertiary
treatment including phosphorus removal.
Have requested hearing before Sanitary
Water Board on order. Hearing has not
been scheduled by the office of Legal
Counsel.
Gi rard Borough
Albion Borough
Lake City Borough
Fa ? r.view School
Erie County Home
Greene Township Elementary School
Talarico Truck Stop
Howard Johnson Motor Stop
Penn State Behrend Center
Harborcreek Township School
Oakdale Corporation
Poplar White Thru-way
Terrace Restaurant
Mums Motel
Conneaut Valley Union Joint
Elementary School
Kahkwa Club
Presently providing secondary treatment.
Ordered August 1, 1969 to provide tertiary
treatment plus phosphorus removal. Have
requested hearing before the Sanitary
Water Board on the order. Hearing has
not been scheduled by the Office of Legal
Counsel.

Presently providing secondary treatment.
Ordered August 1, 1969 to provide tertiary
treatment plus phosphorus removal. Have
requested hearing before the Sanitary
Water Board on the order. Hearing has
not been scheduled by the Office of Legal
Counsel.

Ordered August 1, 1969 to provide tertiary
treatment including phosphorus removal.
Have requested hearing before the Sanitary
Water Board on order. Hearing has not
been scheduled by the Office of Legal
Counsel.

Treatment plant is overloaded with the
result that less than secondary treatment
is being provided. Additional sewer
extensions and connections are being
proh ibi ted.

Secondary treatment provided
ii ii ii
ii
ii
ii
ii
ii
ii
ii
ii
ii

M
ii
n
n
n
n
n
n
n
n
n

n
n
n
n
ii
n
n
M
n
11
ii

M
n
-------
- 3 -
Name
Present Status - Comments
576
Lakeshore Country Club
Presque Isle State Park
Travelers Rest
Fairview Township Industrial
Development Corporation
Rondal Convalescent Home
Humble Oil and Refining Company
Summit School District
Interpace Corporation
Larry's Truck Stop
Wenner's Esso Station
Wi Ison Motel

Alpine Manor
Georgetown

South Shore Service Company
Secondary treatment provided
ii n ii
n
n
n
n
n
n
n
n
n
n
n
n
n
Secondary treatment provided as of
April 1, 1970.

Secondary treatment provided.

Secondary treatment provided. Ordered
August 1, 1969 to provide phosphorus
removal. Feasibility study was completed
but plans not submitted on schedule.
Enforcement conference scheduled for
May 29, 1970. If plans received by
June 1, 1970 there should be no overall
delay toward meeting compliance.
-------
577
TABLE II

Industrial Status
(June, 1970)
Case Name
Albro Packing Company
Hammermill Paper Company
Present Status - Comments

Providing adequate treatment including
phosphorus control.

1. A portion of total compliance will
depend on the City of Erie sewage
treatment expansion.

2. Delays due to strikes against certain
supplies of material, together with
construction worker labor problems
have caused about two months delay in
the pulping conversion process which
will reduce the raw waste production to
about 1/3 of the BOD load and 1/6 of
the color load.
Interlake Steel Company
Kaiser Aluminum and Chemical
Corporation
Penelec Company
Ruberoid Company

Welch Grape Juice Company
Objections raised to deep water outfall
for treated wastes may delay outfall
construction until October 1, 1971.

Pulping conversion and resulting waste
reduction expected February 15> '971
instead of December 15, 1970. Phosphorus
control adequate.

Adequate treatment provided
n
n
n
n
Adequate treatment provided for organic
wastes. Cooling water causing thermal
pollution in Sixteen Mile Creek.
Feasibility report due July 1, 1970.
-------
- 2 -
Case Name
Present Status - Comments
578
J. McCormick Construction Company
Nickel Plate Sand and Gravel
Erie Ceramics
Erie Brewing Company
International Pipe and Ceramics Corporation

Parker White Metal
Gunnison Brothers Tannery
Adequate Treatment Provided
ii n ii
General Electric Company
American Sterilizer Company
Ervite Corporation
W. Ridge Gravel
n
n
n
n
n
n
n
n
Adequate treatment installed as of
December 9, 1969.

Present treatment less than secondary.
Tertiary treatment and adequate
phosphorus control designed after
research and development project.
Inability to obtain necessary rights-
of-way has required redesign and
relocation of the treatment facility.
Now to begin construction by August 1,
1970 and begin operation by October 15»
1970.

Phosphorus control is adequate. Ordered
to provide treatment of oil bearing
wastes. Contracts awarded May 1, 1970.
Strikes caused 3i months delay. Partial
completion and operation now expected
by December 30, 1970 with total com-
pletion and operation by April 30, 1971-

Adequate Treatment Provided
n n n
Erie Reduction
Connected to City of Erie.
-------
579

WHAT THE CITY OF ERIE, PENNSYLVANIA HAS DONE AND IS DOING TO ABATE POLLUTION

ft * * INTO LAKE ERIE * * *

BY MAYOR LOUIS J. TULLIO, CITY OF ERIE, PENNSYLVANIA

THE CITY OF ERIE'S PRESENT PLANT WAS CONSTRUCTED IN 1954 UNDER PERMIT

FROM THE PENNSYLVANIA DEPARTMENT OF HEALTH AND AT THAT TIME HAD AN EFFLUENT

THAT MET OR EXCEEDED THE DEGREE OF TREATMENT REQUIRED FOR DISCHARGE INTO LAKE

ERIE.

THE PLANT CLASSIFIED AS INTERMEDIATE TREATMENT IS CAPABLE OF TREATING

45 MILLION GALLONS PER DAY. THE AREA SERVED BY THE PLANT IS METROPOLITAN IN

SCOPE SERVING NOT ONLY THE CITY OF ERIE BUT ALSO THE BOROUGH OF WESLEYVILLE

AND THE TOWNSHIPS OF LAWRENCE PARK, MILLCREEK AND HARBORCREEK.

THE ORIGINAL PERMIT CALLED FOR CHLORINATION OF THE EFFLUENT ONLY DURING

THE BATHING SEASON. IN APPROXIMATELY 1963 THIS PERMIT WAS AMENDED TO CALL

FOR YEAR AROUND CHLORINATION. THE CITY HAS COMPLIED WITH THIS ORDER SINCE

IT WAS ISSUED.

IN 1965, TO ELIMINATE INDUSTRIAL WASTE DISCHARGE FROM THE STORM SEWER

SYSTEM AND TO CONTROL THESE DISCHARGES IN THE SANITARY SEWER SYSTEM THAT WERE

THREATENING THE SEWERAGE PLANT WITH UPSETS, THE CITY THROUGH THE COOPERATION

OF THE MANUFACTURERS ASSOCIATION HAD MADE AN INDUSTRIAL WASTE SURVEY OF THE

CITY TO DETERMINE THE QUALITY, QUANTITY AND LOCATION OF INDUSTRIAL DISCHARGES.

THIS LED TO PASSAGE OF AN INDUSTRIAL WASTE ORDINANCE IN 1966. THIS ORDINANCE

CONTROLS WHAT CAN BE DISCHARGED INTO THE SYSTEM AND WHAT REQUIRES PRE-TREAT-

MENT BEFORE IT IS DISCHARGED. DURING 1966 AND 1967 INDUSTRY COMPLIED WITH

THESE REGULATIONS. PERIODIC CHECKS SHOW THAT COMPLIANCE WITH THIS ORDINANCE

BY INDUSTRY HAS BEEN GOOD.

WITH THE CHANGE IN THE STANDARDS FOR DISCHARGE INTO LAKE ERIE, THE CITY,

THROUGH ITS SEWER AUTHORITY, WAS ORDERED TO UPGRADE ITS DEGREE OF TREATMENT.
-------
580
-2-

PRELIMINARY DESIGN WAS UNDERWAY WHEN WE WERE APPROACHED BY THE HAMMERMILL

PAPER COMPANY TO CONSIDER THE POSSIBILITY OF COMBINED TREATMENT OF THEIR IN-

DUSTRIAL WASTE AND OUR MUNICIPAL WASTE. THIS WAS AGREED AND PILOT PLANT AND

BENCH STUDIES WERE CONDUCTED TO DETERMINE THE DESIGN PARAMETERS AND THE

FEASIBILITY OF COMBINED TREATMENT. CONCLUSIONS OF THIS STUDY INDICATED THAT

COMBINED TREATMENT WAS FEASIBLE BOTH TECHNICALLY AND ECONOMICALLY. AS A ,

RESULT OF THIS AN AGREEMENT WAS NEGOTIATED BETWEEN THE CITY, THE SEWER AUTHOR-

ITY AND THE HAMMERMILL PAPER COMPANY TO SHARE IN THE COST OF CONSTRUCTION,

MAINTENANCE AND OPERATION OF THE NEW EXPANDED PLANT.

THE EXPANDED PLANT IS NOW UNDER ENGINEERING DESIGN. PRELIMINARY PLANS

HAVE BEEN SUBMITTED TO THE STATE. THE CONSULTING ENGINEERS ARE WORKING TOWARDS

A FALL DEADLINE FOR COMPLETED PLANS SO THAT THIS NEW PLANT CAN BE PUT OUT TO

BIDS AND CONSTRUCTION STARTED THIS YEAR. THE EXPANDED PLANT WILL PROVIDE FOR

COMPLETE TREATMENT PLUS PHOSPHATE REMOVAL IN COMPLIANCE WITH THE STATE'S

ORDER. PRELIMINARY COST ESTIMATES FOR THIS PLANT ARE APPROXIMATELY $12,000,000

FOR CONSTRUCTION WITH AN ADDITIONAL $600,000 TO BE REQUIRED ANNUALLY FOR CHEM-

ICALS TO TREAT THE PHOSPHATES.

COMBINED SEWERS:

THE OLDER PART OF THE CITY IS SERVICED BY COMBINED SEWERS. THIS WAS

STANDARD PRACTICE UNTIL ABOUT 1930. ALL CONSTRUCTION AFTER THAT TIME WAS

SEPARATE SYSTEMS.

THE CITY HAS BEGUN A PROGRAM TO SEPARATE ITS COMBINED SEWER SYSTEM IN

THE PAST FEW YEARS. EXTENSIVE CONTRACTS HAVE BEEN LET, ESPECIALLY IN THE

DOWNTOWN AREA TO ACCOMPLISH THIS. DOLLAR VOLUME FOR THIS WORK HAS EXCEEDED

$2,000,000 IN THE PAST FOUR YEARS WITH AN ADDITIONAL $400,000 UNDER CONTRACT

AT THIS TIME.
-------
581

-3-

ERIE WILL CONTINUE WITH THIS PROGRAM OF SEPARATION AS FUNDS ARE MADE

AVAILABLE.

SANITARY SEWERS:

THE CITY HAS PROVIDED SANITARY SEWERS TO ALL PARTS OF THE CITY. IT HAS

ALWAYS BEEN THE ADMINISTRATION POLICY TO EXTEND THESE SERVICES AS PROMPTLY

AS POSSIBLE FOLLOWING A REQUEST. AT PRESENT OVER 95% OF THE AREA OF THE CITY

IS SERVICED BY SEWERS. THIS PROVIDES SERVICE TO ALMOST 100% OF THE POPULATION.

THE ONLY AREAS REMAINING TO BE SERVICED ARE THOSE NOT YET DEVELOPED AND CER-

TAIN PORTIONS OF THE BAY FRONT.

THE CITY BECAUSE OF ITS TERRAIN DOES NOT REQUIRE MANY LIFT STATIONS.

THE CITY HAS AT PRESENT FIVE, THREE OF THESE WERE CONSTRUCTED WITHIN THE PAST

FOUR YEARS AT A COST IN EXCESS OF $2,000,000. THIS YEARS CAPITAL IMPROVEMENTS

BUDGET PROVIDES $250,000 TO CONSTRUCT ANOTHER LIFT STATION TO SERVICE THE

BAY FRONT AREA.

THE BAY FRONT AREA OF THE CITY IS SITUATED BELOW THE INTERCEPTOR SEWER,

SO ALL OF THIS AREA MUST BE SERVICED WITH LIFT STATIONS. IN 1966 THE CITY HAD

THEIR CONSULTANTS PREPARE PRELIMINARY PLANS FOR THIS AREA. PLANS CALL FOR FIVE

LIFT STATIONS IN THIS AREA. TWO OF THESE WERE BUILT WITHIN THE PAST TWO YEARS

WITH ANOTHER SCHEDULED FOR CONSTRUCTION IN THIS CALENDAR YEAR. THIS SHOULD

COVER THE DEVELOPED AREAS, THE REMAINDER WILL BE CONSTRUCTED AS DEVELOPMENT

TAKES PLACE.

THE CITY ALSO HAS PLANS TO CONSTRUCT LIFT STATIONS AT ITS WEST SIDE

WATER PLANT TO PUMP THE WASTE WATER BACK INTO THE SEWER SYSTEM RATHER THAN

INTO THE BAY.

AS A RESULT OF ENCLOSING THE CREEKS AND RUNS IN THE CITY, MANY SANITARY

SEWERS HAD TO BE SIPHONED UNDER THE STORM SEWERS. TO INSURE NO FLOODING OF

BASEMENTS, OVERFLOWS WERE REQUIRED TO BE CONSTRUCTED AT THESE SIPHON LOCATIONS.
-------
582

-4-

IN THE PAST MANY OF THESE SIPHONS BECAME CLOGGED AND OVERFLOWED INTO THE
*

STORM SEWERS. TO REDUCE THIS TO A MINIMUM WE HAVE INSTITUTED A PROGRAM OF

BI-WEEKLY INPSECTIONS OF THESE SIPHONS AND CLEANING WHEN REQUIRED. THIS HAS

GREATLY REDUCED THE OVERFLOWS FROM THIS SOURCE.

DURING THE PERIOD OF CONSTRUCTION OF COMBINED SEWERS MANY OVERFLOWS HAD

TO BE CONSTRUCTED TO DIVERT HEAVY COMBINED FLOWS FROM THE TREATMENT PLANT.

SINCE THE PLANT HAS HAD ADDED CAPACITY MANY OF THESE HAVE BEEN ABANDONED OR

PLUGGED. OTHERS STILL EXIST, WE ARE WORKING ON THIS PROBLEM AND THROUGH THE

COMBINATION OF SEPARATING THE COMBINED SEWERS AND ADDITIONAL CAPACITY AT THE

PLANT SITE, WE HOPE TO SOLVE THIS PROBLEM.

THE MOST IMPORTANT PROBLEM WE HAVE NOW IS WITH OUR OLDER SEWER SYSTEM.

MANY ILLEGAL CONNECTIONS EXIST AND SOME CROSS CONNECTIONS MUST BE THERE. WE

HAVE FOUND MANY OF THESE AND CORRECTED THEM, THEREBY REDUCING THE FLOW TO THE

BAY CONSIDERABLY. WE ARE WORKING DILIGENTLY TO CORRECT THIS BUT IT IS A TIME

CONSUMING JOB, REQUIRING SEARCHING OLD RECORDS, DYE TESTING AND LOCATION

STUDIES. WE WILL CONTINUE TO PURSUE THIS UNTIL ALL LOCATIONS ARE FOUND AND

CORRECTED.

WE BELIEVE THAT WE HAVE BEEN PROGRESSIVE IN OUR FIGHT TO ABATE THE

POLLUTION OF LAKE ERIE AND WILL PLACE OUR RECORD OF ACHIEVEMENT AGAINST ANY

ALONG THE LAKE. WE WILL CONTINUE WITH OUR PLANS AND WILL NOT REST UNTIL ALL

SOURCES OF POLLUTION INTO THE LAKE FROM ERIE ARE ABATED.
-------
583

W. A. Lyon

MR. LYON: I also understand that the county

commissioners of the County of Erie and the County Health

Department in Erie intend to submit written statements at a

later date.

MR. STEIN: What later date? To this conference?

MR. LYON: I think to this conference.

MR. STKIN.* 1 will keep the record open for a

week.

MR. LYON: Fine, We will advise them accordingly.

They may already be in the mail.

Our report covers essentially two areas. And I

will not read our report. One is the mercury problem.

Summarizing briefly, we have monitored our dis-

charges and found no consequential mercury discharges any-

where in Pennsylvania. We have monitored our waters and

have not found anything serious in the way of mercury.

We have found that some of the fish that were col-

lected in Pennsylvania did have mercury concentrations in

excess of the limits, and our Governor has advised sportsmen

to not eat certain types of fish. And this is also covered

in our report.

And we are naturally very deeply concerned about

this mercury problem, and I hope will be talking about that.

MR. STEIN: You don't mean other people can eat
-------
584

W. A. Lyon

the fish other than the sportsmen?

MR. LYON: No. We are talking about the fish that

the sportsmen collect.

We are in favor of sportsmen having mercury-free

fish, Mr. Chairman.

In connection with our municipal and industrial

program, let me briefly summarize that all but two minor

discharges in Pennsylvania are providing secondary treatment.

We have 32 sources of sewage — municipal and private

institutions.

Four of our smaller municipalities have requested

hearings before our Board in connection with the phosphate

reduction orders. And we hope to have these scheduled

soon.

The city of Erie is approximately 14 months behind

schedule in the completion of its program for phosphate

removal. And this is associated with the Hammermill dis-

charge because the city of Erie has agreed to a significant

portion of the Hammermill wastes. They in themselves have

helped reduce the phosphates because they will demand

phosphates. The delay was caused because it was necessary
-------
585

W. A. Lyon

to change the Hammermill process to allow the city of Erie

to take those wastes.

In connection with page 3 of my report, the South

Shore Service Company which is a very small sewage source

indicates that the Enforcement Conference is scheduled for

May 29. That should be changed to June 5.

And the last sentence, beginning with "if plans"

should be struck from that portion of the report.

We have 16 industrial waste discharges. Three of

them are behind schedule, one for two months, one for seven

months, and the other for three and one-half months. Other-

wise, our industrial program is in good shape.

I would like to mention that even though the city

of Erie sewage treatment plant will not go into operation

until February 15, 1972, the wastes from the Hammermill

Paper Company will in fact be reduced very significantly

when their change in process goes into effect on or about

February of 1971. Their BOD loads will be reduced by about

two-thirds and their coli load will be reduced about 80

percent. So that in itself will be a very major reduction

in industrial waste to Lake Erie and Pennsylvania.

In connection with Mr. Harlow's report, I think

the additions I indicated are due to the passage of time

perhaps since this information was submitted. I would like
-------
586

W. A. Lyon

to, for example, refer to page 2 of the municipal report.

Under Erie there should be an indication that an

adjudication has been issued as a result of the Bay Point

sewer problem requiring abatement by 5/15/72.

And the record should also show, and I would

request that these changes be made in Mr. Harlow's report

if he agrees, that an order stopping all additional sewer

extensions and connections has been issued.

And I might also mention that the city of Erie has

reduced its discharge from this Bay Point sewer from about

10 to 15 million gallons per day to approximately 3 to 5

million.

Similarly, in connection with Lake City, sewer

connections are being prohibited and the permit is being

suspended for failure to meet a compliance schedule. And

an order will be issued to expand the sewage plant which

appears to be overloaded.

In connection with Alpine Manor, the record should

show that secondary treatment was provided as of 4/1/1970.

Mr. Harlow's report says no schedule.

Switching over to the industrial waste portion

of Mr. Harlow's report, page F-3, General Electric, the

report should show that a permit was issued in March 1970

and construction will be completed and operation begun by
-------
587

W. A. Lyon

4/30/71.

In connection with Gunnison Brothers, the report

should show that the construction will be completed and

operation will be begun by October 15, 1970.

And in connection with the Hammermill Paper Com-

pany, Mr. Harlow's report should show that the pumping

conversion and separate discharge of the diffuser system

for the beach plant effluent should be completed by February 15,

1971. And that will indicate the very significant reduction

in wastes from that company at that time.

And unless there are questions, that completes my

report.

MR. STEIN: Are there any comments or questions?

(Mo response.)

I don't want to necessarily get into detail on

this, but I just want to spotlight this. In your report,

you have North East Borough, Girard Borough, and Albion

Borough, Lake City Borough. And presumably your Sanitary

Water Board has taken action, but your Office of Legal

Counsel has not scheduled hearings. And these are removable

necessarily now, and they are in violation.

MR. LYON: Well, they are not now in violation

until the hearings are held and adjudicated. We are asking

our Office of Legal Counsel to schedule these hearings as
-------
588

W. A. Lyon

soon as possible.

MR. STEIN: When I talk about violation, I mean

of the schedules received at this conference.

MR. LYON: That's correct.

MR. STEIN: And then I think we have one more that

maybe we don't see the light at the end of the tunnel —

Welch Grape Juice Company. The thing we are looking for is

just the feasibility report. We don't have a commitment yet

that they are going to clean up.

MR. LYON: No, my report says that adequate treat-

ment is provided.

Are you looking on industrial wastes?

MR. STEIN: Table II. It says, "Adequate treat-

ment provided for organic wastes. Cooling water causing

thermal pollution. Feasibility report due."

MR. LYON: Yes, that is correct. I will ask Mr.

Bellaman to comment on that.

MR. STEIN: Well, we can wait.

MR. BELLAMAN: We have received a schedule, but

I don't recall offhand what the schedule calls for.

MR. STEIN: I think my primary point is to spot-

light these so when we go to the workshops, we can get in

on these.

There is one other one, and I hope we are over the
-------
589

W. A. Lyon

' hump, because I think that/ Walter, long before you went to

Pennsylvania, we were always dealing with the Hammermill

Paper Company, Do you think that Hammermill is completely

on its way now or do we still have some loose ends that we

are going to have to tie up before we can write that one

off and say they provide adequate treatment?

MR. LYON: I think Hammermill is completely on its

way. There is one loose end that the company cannot control.

They have requested a permit from the Corps for an outfall

to handle its beach plant wastes, and we have issued a permit

for that discharge. We think it will be completely adequate.

However, the Corps has so far not issued its permit. We

hope they will. If they don't issue that permit soon, there

is going to be a delay.

MR. STEIN: Does the Corps have some comments on

that?

MR. HARLOW: Yes. The Corps has asked us for

comments, and we have provided the information to the Corps.

But the Corps has not released the permit yet.

MR. STEIN: Are we in favor of the permit or not?

MR. HARLOW: We are in favor of issuing the permit

in connection with meeting the requirements of the Sanitary

Water Board.

MR. STEIN: Thank you.
-------
590

Perry Miller

Are there any other comments or questions?

(No response.)

If not, thank you very much, Mr. Lyon. And I

want to congratulate you on the program, particularly on

solving this Hammermill Paper Mill case because I almost

dispaired that we would ever clean that up in our careers.

But I guess v/e are on our way.

May we call on Indiana?

STATEMENT OF PERRY MILLER

INDIANA STREAM POLLUTION CONTROL BOARD

MR. MILLER: Mr. Chairman, conferees, ladies and

gentlemen, my name is Perry Miller. And I am representing

the Indiana Stream Pollution Control Board.

In the introduction to this report, we have indi-

cated that we have contacted all of the industries in the

Lake Erie Basin, and there are not any of these that are

using mercury compounds.

Also, Indiana has initiated a pesticide monitor-

ing program. We received a grant of approximately $40,000

to institute such a program in the Lake Michigan Basin. We

have expanded this and are doing pesticide monitoring in the

Lake Erie Basin as well as the Lake Michigan Basin.

All Indiana municipalities in the Lake Erie Basin
-------
591

Perry Miller

"with recognized sewer systems have secondary-type treatment

facilities. In compliance with Indiana's Mandatory Certifi-

cation Act, all municipal wastewater treatment facilities

in the basin have a certified operator in responsible charge

of the facilities. This, plus routine surveillance by repre-

sentatives of the Stream Pollution Control Board, has improved

operation and maintenance activities.

The City of Fort Wayne is continuing the planning

and construction of major improvements to its combined sewer

system to provide separation and/or treatment of combined

sewer overflows. A holding lagoon is under construction

across the river from the treatment plant for studies on

effectiveness in reducing the pollution from sewer overflows

and primary effluent bypassing during runoff from rainfall.

A storm sewer separation project is under construction in

Glenwood Park and an inner city storm relief plan is proposed

if HUD funds are available.

The Maumee River plant operated by Diversified

Utilities, a private utility, is still operating under over-

loaded conditions. An order of this Board requires the

utility to expand its treatment facilities {as provided by

the Federal Court) and to connect to the Fort Wayne sewer

system by September 1, 1970. In addition, at least 80 percent

phosphorus removal is to be provided not later than December 31,
-------
592

Perry Miller

«
1972. In the interim, requests for additional connections

to the sewer system serving this area are not permitted.

Effluent Chlorination

The Board's plan of implementation adopted in

1967 required the municipalities of Avilla, Berne, Butler,

Fort Wayne, Garrett, and Waterloo to provide effluent chlori-

nation facilities by the end of 1968. Auburn, Decatur, Garrett

Monroeville, and Waterloo and Diversified Utilities, Inc.,

are providing effluent Chlorination. Avilla and Fort Wayne

have Chlorination facilities under construction and Butler is

expected to start construction of plant improvements, includ-

ing Chlorination, in the next few weeks. New Haven's project

for plant improvements including Chlorination and phosphorus

removal has been delayed by litigation against the bond sale;

however, the city attorney has advised that he expects the

project to proceed in the near future. Berne and Garrett do not have

an effluent Chlorination project under way.

Phosphorus Removal

To comply with the recommendations of the Lake

Erie conference for 80 percent reduction in phosphorus in

wastewater, the Board determined that all communities above

2,000 would be required to install phosphorus removal facili-

ties before the end of 1972 capable of reducing phosphorus

contributions by 80 percent. The municipalities of Auburn,
-------
593

Perry Miller

Berne; Butler; Decatur; Diversified Utilities, Inc., Fort

Wayne; Garrett; and New Haven were notified of this require-

ment during April 1969. As mentioned in the preceding

paragraph, Butler and New Haven have projects approved,

which include phosphorus removal, which should go to con-

struction in the near future. The pilot plant studies on

phosphorus removal by the City of Fort Wayne are expected to

start in June 1970. Berne and Decatur have grant applica-

tions on file for projects which include phosphorus removal.

Of the 21 industries in the basin, 17 have adequate

waste control facilities and four need additional treatment

facilities. Of the four industries, Kitchen Quip, Inc.,

Waterloo, and General Plating and Engineering Company, Fort

Wayne', do not have adequate control programs in progress.

There is a list of 17 of the adequate industries

in the report.

And it is also noted that Auburn Tankage Company,

Auburn, was closed in 1969.

A status report on the five industries listed as

inadequate at the last status report in June 1969 is as

follows:

Franke Plating Works, Inc., Fort Wayne

Construction on cyanide and chromium wastewater

treatment facilities was started during March 1969. Completion
-------
594

Perry Miller

was scheduled for the fall of 1969; however, because of late

start of construction and equipment delivery, the facilities

were not completed on schedule. All equipment has been

delivered and final installation is being made and should be

completed by June 15, 1970.

International Harvester Company, Fort Wayne

The company has completed all pollution control

work with the exception of improved sewage disposal for a

warehouse and packaging building located in the southeast

area of the plant. The operation utilizes 290 employees and

the waste is treated by a septic tank-absorption system.

Only during extremely high soil moisture periods does any of

the waste reach the receiving stream.

By September 1970, the level of employees should

drop to 100 which will improve the capability of the system.

Construction is proceeding on a sewer (by a sewer utility)

which will enable discharge of this waste to the Fort Wayne

sewerage system. Construction on the sewer by the utility

was started during the spring of 1968. Construction was

stopped during the summer of 1968 because of court action

filed by a property owner concerning connection charges and

delayed again during late 1968 and early 1969 because of

financial difficulty brought on by the delay. Construction

was restarted during March 1969.
-------
595

Perry Miller

MR. STEIN: When was that to be completed, Mr*

Miller?

MR. MILLER: I really do not have a completion

date, but I would expect it sometime later this year,

MR. STEIN: I wonder if as soon as you get that,

we could have it to complete the record.

13R. MILLER: Yes, sir, we will supply this,

(The above-mentioned information follows,)
-------
595a

STATE- ~;S INDIANA ~
f^S^^^^
INDIANAPOLIS 46206
1330 West Michigan Street
STREAM POLLUTION CONTROL BOARD O34OO
June 29, 1970
Mr. Murray Stein
Assistant Commissioner
for Enforcement
Federal Water Quality Administration
Department of the Interior
Washington, D. C. 202^*2
Dear Mr. Stein:
Re: Conference on Lake Erie
and its Tributaries
At the reconvening of the Conference on Lake Erie and its Tributaries
in Detroit on June 3 and U, you requested information about the completion
date for the sewer to serve the International Harvester Company in Fort Wayne.

American Suburban Utilities advised us on June 12 that this sewer
should be completed in the International Harvester area by the Fall of 1970
and certainly before December 31, 1970.

In reviewing the report that was presented on behalf of the Stream
Pollution Control Board in Detroit, there is a correction that should be
made on Page 2 under Effluent Chlorination. The City of Oarrett is providing
effluent chlorination and, therefore, should be added in the second sentence
as one of the communities chlorinating their plant effluent. The last
sentence of this section should be corrected to show that the City of Berne
does not have an effluent chlorination project underway.

Should you have any questions concerning the above please contact us.

Very truly yours,
Poole
Technical Secretary
PEMiller/se
-------
595b

Perry Miller

' Parrot Packing; Company, Fort Wayne

Construction of a sewer was completed on August 12,

1969, that allowed all the waste to be conveyed to the Fort

Wayne sewerage system for treatment. Adequate control is

being provided.

General Plating and Engineering Company, Fort Wayne

The company started construction of cyanide and

chromium wastewater treatment facilities during the fall of

1968. Progress on the construction was poor because the

owner insisted on doing a large part of the installation.

During the summer of 1969, the company abandoned much of the

work accomplished and began installation of another method

of treatment. Attempts to obtain revised plans were futile

and enforcement action was initiated in November 1969. A

hearing was held on February 4, 1970, concerning pollution

of the receiving stream. The recommended findings of fact

have not been issued, but should be available in the near
-------
596

Perry Miller

future. The staff plans to recommend to the hearing officer

that plans and specifications be submitted by October 1,

1970, and waste treatment facilities be completed by Decem-

ber 1, 1971. The company recently employed an equipment

company to complete plans for waste treatment facilities.

If corrective action is not taken, the matter will be referred

to the Attorney General as soon as practicable.

Kitchen Quip, Inc., Waterloo

Because of above-normal streamflow during 1969 and

the spring of 1970, the staff has been unable to obtain suf-

ficient evidence for the Board to proceed with new enforce-

ment action. The Board's order of June 18, 1968, was over-

ruled by the Lagrange County Circuit Court. This plant will

be under surveillance during low flow periods to determine

if water quality standards are violated.

MR. STEIN: Thank you.

Are there any comments or questions?

(No response.)

I just have one comment that I am raising as a

question. I notice Kitchen Quip has been hanging around for

awhile, and I recognize the problems. I raise the question,

and I think we want to work this out mostly with you people

in Indiana, whether you want to go x^ith the State action or

whether 180-day Federal action would be appropriate or
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597

Perry Miller

'whether we should proceed on both fronts with Kitchen Quip.

I think we should try to remove that name from the list some-

time.

MR. MILLER: I would agree with you. It should be

removed from the list. And if you want my comment, I would

say I would be in favor of every action we can have to get

this removed.

MR. POOLE: It is the only case we have ever lost

in court.

MR. STEIN: I know. And I think in that, we might

be able to help by using both. But let's think about that

one.

Any other comments or questions?

MR. SEEBALD: May I ask what the court found to

overturn your order?

MR. POOLE: It was based on some pretty fuzzy

technical data. And this is why, Murray, maybe the 180-day

will do the trick. We were unable in sampling in 1969 to

show any violation of our water quality criteria. We are

just looking for 70 in lower stream flows.

MR. MILLER: This is a small plating plant above

Fort Wayne on the stream. And there are times when he does

a fairly good job. There are other times when he doesn't

do a good job. And it is difficult, really, to run him down.
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598
MR. STEIN: Right.

Well, thank you.

MR. POOLE: We might have to wait for a drought in

Indiana. That's the reason maybe you can help us.

MR. STEIN: You know, we can bring on droughts,

too.

We are going to change the procedure a little. I

said we would finish all the States. But in looking at the

time -- New York has a relatively short statement of about

15 minutes -- we will recess for lunch. Let's try to get

back here at 1:30. We will take up the New York statement

and then the mercury problem. And we will try to finish

as early as possible this afternoon.

MR. EAGLE: Mr. Chairman, sorry to say we will be

unable to be here this afternoon, but Mr. Van Den Berg of

the FWQA has worked with us on the mercury problem and can

speak for Ohio and make a report for Ohio on the mercury

problem.

MR. STEIN: Again, I really appreciate that state-

ment. You don't know how far we have come. Mr. Van Den Berg

is our Federal official in Cincinnati who is in charge of

the enforcement task force. And when the State of Ohio gives

him the proxy to speak, I think we really have come a long

way on this.
-------
599
We will recess for lunch.

(Whereupon, at 12:10 o'clock p.m., the meeting

recessed, to reconvene at 1:30 p.m. the same day.)
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600
AFTERNOON SESSION

(1:40 p.m.)

MR. STEIN: Let's reconvene.

MR. MAYO: Mr. Chairman, during the presentation

of the information on status of compliance of Federal

facilities yesterday, Mr. Poole raised the question about

the availability of comparable information to that which Mr.

Harlow summarized for municipal and industrial installa-

tions. We have distributed for each of the conferees a

summary sheet by name of agency giving the comparable status

of compliance information. And this should be added to the

earlier report as an appendix. (See p. 132A.)

MR. STEIN: Without objection, this will be done.

MR. PURDY: Mr. Stein, I have a question. Does

this column mean that for U. S. Army, the total of 13

installations, the enforcement conference deadline was

August 1966 and that now anything to the right of that

column means that the schedule has been extended?

MR. STEIN: No, the schedule hasn't been extended

at all. Anything to the right of that means they are in

violation.

MR. PURDY: O.K., but they are beyond the original

conference deadline. The conference deadline for all 13

U.S. Army installations was August of 1966, is that correct?
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601
MR. STEIN: Mr. Garnet.

MR. GAMET: That was the recommendation of the

conferees that all Federal installations should be in com-

pliance by August of 1966. So as you say, everything to the

right of that column means they are in violation.

MR. PURDY: If that would compare with the earlier

charge, those that are behind schedule would be all of those

under no established schedule and those in date scheduled

for compliance in 1970, 1971 and 1972.

MR. GAMET: That is correct.

MR. POOLE: If I remember, back in 1966, out of

fairness to the Federal installations, we were not consider-

ing vessels at that time.

MR. GAMET: I realize that, but as I stated yes-

terday, I felt with the recent legislation and interest and

concern about waste from vessels, it was about time we

included a report on these which we considered to be Federal

installations.

MR. STEIN: Any other comments or questions at

this time?

(No response.)

We will call on Mr. Seebald.

MR. SEEBALD: Mr. Chairman, I would like to point

out that this will be the last report of the New York State
-------
602

R. C. iMt Pleasant

Department of Health as a member of this conference. The

environmental health activities associated with water pollu-

tion will be taken over as of 1 July by the new Department

of Environmental Conservation in the State of New York. And

it is assumed that a representative of that department would

then sit as a conferee in future reconventions of this con-

ference.

And towards that purpose, I have passed out a

progress report of the Department of Health on their pure

water program. And in there there is an insert advising all

who use it or have access to it of the creation of this new

department. It contains the highlights of the accomplish-

ments of the Department of Health in the water pollution

field to date as of last December and points out the high-

lights of the program. I do not intend this should be a

part of the record necessarily.

The presentation for New York will be made by Mr.

Russell Mt. Pleasant, Director of Basin Development of the

State Department of Health.

STATEMENT OF RUSSELL C. MT. PLEASANT

ASSOCIATE SANITARY ENGINEER

DIVISION OF PURE WATERS

NEW YORK STATE DEPARTMENT OF HEALTH
-------
603

R. C. Mt. Pleasant
•

MR. MT. PLEASANT: Mr. Chairman, members of the

conference, ladies and gentlemen, I am Russell Mt. Pleasant,

Associate Sanitary Engineer, the Division of Pure Waters,

New York State Department of Health.

We passed out the formal statement to be presented

on behalf of New York State. All of the conferees have

them. I have given the transcriber a copy. And there are

a few extra copies on the front table here.

MR. STEIN: You are going to summarize this,

aren't you?

MR. MT. PLEASANT: Yes.

MR. STEIN: Without objection, the full report

will appear in the record as if read.

(The above-referred to report follows in its

entirety.)
-------
604
LAKE ERIE
ENFORCEMENT CONFERENCE
PROGRESS REPORT
REPORT TO THE CONFEREES
Detroit, Michigan
Submitted by
THE NEW YORK STATE DEPARTMENT OF HEALTH
HOLLIS S. INGRAHAM, M.D., COMMISSIONER
-------
605
NEW YORK STATE DEPARTMENT OF HEALTH

DIVISION OF PURE WATERS

Progress Report to the Conferees of the
Lake Erie Federal Water Pollution Enforcement Conference

June 3, 1970
Detroit, Michigan
The following resume will describe the status of New York State's
•water pollution control program as it effects Lake Erie water quality. As in
the past, only those discharges having a significant effect directly or indirectly
through Lake Erie tributaries from the Buffalo River to the New York-Pennsyl-
vania state line inclusive, will be discussed. Comments will also be made
regarding New York State's current program involving previous conference
recommendations.

Enforcement Status
As of May 1, 1970, 17 of the 42 previously tabulated sources
discharging into or effecting Lake Erie are considered abated, inactive or
insignificant. The remaining 25 unabated polluters discharge a total of
225 MGD of wastewater. Four industries and one municipality (Section B of
the Appendix) have facilities under construction which will intercept and treat
174 MGD. Eleven municipalities and four industries accounting for another
21 MGD of wastewater are in the final or preliminary design. One of these
industries may be referred to the Attorney General if progress does not
materially improve. Four industries and a village discharging a total of
30 MGD have been referred for legal action including Departmental penalty
assessments or action by the Attorney General. Specifics relating to industrial
projects are summarized in the attached appendix.

Construction Grants

New York State's Pure Water Enforcement and Construction Grant
programs have generated $51.6 million worth of municipal construction projects
for water pollution control in this portion of the Lake Erie Basin. State grants
of $21.4 million are committed to these projects including pre-financing of the
federal share where necessary. Similar expenditures by industries exceed
$16 million for projects already completed or under construction,, This
construction program is in compliance with the $400,000+ comprehensive
sewage planning effort for Cattaraugus, Chautauqua and Erie Counties. Also
incorporated in this construction program are phosphorus removal processes
as required in New York State by the policy which was announced a year ago
in Cleveland.
-------
606
Operation and Maintenance Grants

Although major emphasis is currently on enforcement and
construction for the elimination of water pollution, efforts are continuing
to concurrently obtain maximum performance from existing facilities.
As an incentive, New York State communities may receive 33 1/3%
reimbursement of their audited Operation and Maintenance expenses.
Eligibility requirements include resolution by the governing body to adhere
to a specified time schedule for remedial action, when necessary.

In the Lake Erie enforcement area as previously described,
there are 37 sewage treatment plants serving a population of 181,000. 73% of
these plants serving 97% of the sewered population have received Operation
and Maintenance grants totaling about $1 million since 1965. This program
has met with unqualified success in improving the level of plant operation and
protection of water quality standards. More importantly, it has established
strategic inroads with municipal officials in establishing awareness and good
habits necessary for effective operation and protection of capital expenditures.

Highlights

Continued progress has been achieved towards meeting the objectives
of the IJG and complying with the recommendations and conclusions established
by the conferees of the Lake Erie Enforcement Conference. The Bethlehem
Steel Corporation in the City of Lackawanna is setting the pace for pollution
control. At this time, all nine (9) permits required for pollution abatement
facilities have been issued for construction of works to treat approximately
126 MOD of wastes at an estimated construction cost of $10.8 million, $8 million
of which is completed. These waste treatment facilities include treatment for
hot and cold bar and strip and slabbing mill wastes; coke oven wastes; blast
furnace and BOF including the final thickener, the cold mill and pickle liquor
rinse water and deep well disposal of the concentrated waste pickle liquor.
Two operation permits have been issued, one for the 45" slab mill wastewater
and one for the 10" and 12" bar mills. These facilities treat up to 17. 8 MGD.
The other projects are very near completion and will go into operation in 1970.

The Moench Tannery, Division of Brown Shoe Corporation, located
in the Village of Gowanda has completed and submitted final plans which provide
for treatment to adequately reduce waste discharges to Cattaraugus Creek.
This was approved April 23, 1970, and a construction permit issued. Construc-
tion is now underway to be completed by June 1971.

Republic Steel Company has $3. 25 million worth of projects under
construction to treat 23 MGD of process wastes from the Bar Mill, Blooming
Mill, Blast Furnace and BOF. Completion of construction is expected by
July 1971.
-------
607
The Buffalo Dye Plant, Division of Allied Chemical Corporation,
has facilities under construction to pretreat 4. 5 MGD of process wastes
before discharge to Buffalo Sewer Authority System. Actual tie-in to BSA
System is scheduled for January 1971.

Final plans for secondary treatment at the City of Dunkirk, revised
to include phosphorus removal, are scheduled for completion this month.
Construction of the outfall line and interceptor sewer is already under construc-
tion with overall completion by November 1971.

Problem Areas
Problems have besieged the municipal-industrial complexes in the
Villages of Fredonia and Westfield. In Fredonia, the consultant was required
to conduct pilot plant studies in order to firm up final design. The contributory
industry, Red Wing Company, has not taken significant action in construction of
pretreatment facilities prior to discharge into the village system. This action
is long overdue and consequently the company's case was referred to the
Attorney General for legal action. The requirement for pilot plant studies
has caused the village to fall behind the construction start date.

The joint municipal-industrial project for the Village of Westfield
was not sufficiently supported with information on which to base final design.
As a result, the consultant was required to conduct pilot plant studies with
complete sampling and analysis to substantiate a rational design. Unfortunately,
the canning season has passed and this sampling and pilot plant study was
postponed until this coming September and October 1970. The village disengaged
the original consultant and retained another firm which is also evaluating the
industrial wastes from the three major food processing industries within the
village. All four entities are committed to the same abatement schedule which
is slated for initiation of construction by October 1, 1971. One of these,
Welch Grape Juice Corporation, has been referred to the Attorney General's
Office for legal action.

Status of Conference Recommendations

1. Nutrient Removal

The policy in New York State as developed and announced last year
has been implemented. The City of Dunkirk is including phosphorus removal
processes in final design. The Town of Hamburg Master Sewer District will
also include removal units in its design. The City of Lackawanna has
retained a consultant to evaluate the City's alternatives of upgrading to
secondary treatment with phosphorus removal or connecting to the Hamburg
Master plant. The Village of Westfield is faced with a nutrient deficient
combined industrial waste. Evaluation of the relevance of phosphorus removal
in this instance will be forthcoming in project design. The Villages of
-------
608
Lancaster and Depew will connect to the BSA which is designing for phosphorus
removal. The Ripley Sewer District and Village of Brocton are not within^
the scope of the requirements and -will attain whatever levels of phosphorus
treatment are inherent to conventional secondary treatment. There have not,
as yet, been any industrial wastes identified as needing nutrient removal.

2. Deep Well Disposal

This method of waste disposal remains as one of last resort
which must be demonstrated to be of least effect on the total environment.
To date, two permits have been issued for construction of deep wells for
waste disposal; the Hooker Chemical Corporation has recently abandoned this
method of waste disposal and the Bethlehem Steel Corporation has not received
an operating permit and has not yet used the well.

3. Bathing Beach Surveillance

This surveillance program was continued during the summer of
1969. One hundred and forty samples were bacteriologically analyzed for
nine different Chautauqua County beaches. In Erie County, 308 samples were
tested from seven different beaches. Extensive amounts of decomposing algae
rendered two beaches in the City of Dunkirk unsuitable for bathing. Both were
later reopened.

In Erie County, less than 1% of the 303 samples exceeded 2400
coliforms/lOOml. Sanitary surveys and repeated sampling discounted the
significance of these results.

4. Dredging

A meeting is scheduled with the Corp of Engineers tentatively
June 1, 1970, to discuss disposal of harbor dredgings.

5. Oil and Gas Drilling

None of the prohibitive legislation introduced by various sponsors
against leasing and drilling for oil and gas in New York's portion of Lake Erie
was passed. However, the Commissioner of the Conservation Department
has issued a two year moratorium on all activities relating to oil and gas
exploration, drilling and production until the summer of 1972. To date, there
have been no leasings granted.

6. Combine Storm and Sanitary Sewers

No change in status.
-------
5 609

7. Prevention of Spills
•
A progress report through March 1970 on City of Buffalo's
federal demonstration grant, "Program for Preventing and Eliminating
Oil Pollution of Buffalo River" is summarized by each of four phases:

River Phase - On March 10, 1970, an oil leak into the Buffalo
River of about 1300 gallons was discovered and traced to the failure of an
8" underground pipeline which carries "bunker G" fuel oil from the Mobil
Oil refinery to Republic Steel. The Gity of Buffalo immediately offered use
of equipment derived from this grant, to Republic Steel officials and installed
250 feet of Warne boom and two oil skimmers at the site of the accumulated
oil. Straw was spread on the slick that had formed and Republic Steel
personnel dredged and removed an unknown mass of oil and straw from the
river bottom. Attempts to remove oil remaining on the surface and retained
by the boom with two skimmers were hampered when straw clogged them.
An air barrier has been installed across the river surface and experiments
are being conducted on configuration and nozzle sizing to provide the most
efficient air current under various flow conditions.

Sewer Phase - Work continued on the development of an UV oil
detector and on other sensors of small quantities of oil. The former device
is being calibrated and will be evaluated in the Buffalo River as a probe.
Development continues of a sensor head suitable for sewer installation.

Oil Sampling, Identification and Analysis Phase - Investigation of
techniques and their first quantitative results for analyzing bulk water samples
are continuing. Analyses of oil in various samples from the Buffalo River
supports earlier evidence that the river shore is an efficient oil-sink and will
continue to replenish the decreasing river pollution level as cleanup measures
are placed in operation. Vapor phase chromatography, UV spectroscopy and
various extraction agents are undergoing evaluation.

Cost Analysis and Economic Evaluation Phase - The costs of
controlling future oil pollution, as well as eliminating existing oil pollution
will be determined for the Buffalo River and the associated municipal sewer
system. The economic evaluation task has been postponed until the latter
part of the 27 month program.

8. Elimination of Lake Front Municipal Refuse Dumps

No such sites on New York State's Lake Erie Waterfront.

9. Control of Deleterious Runoff

The advisory committee to the Commissioner of Health on
agricultural drainage has prepared a final draft of the report entitled,
-------
610
"Guides for Controlling Contaminate Emission Released from Confinement
Animal Production Farms". Non-point discharges from cattle or other
livestock feeding or confinement areas are considerated as subject to
provisions of existing Water Pollution Control Law. In this enforcement area,
there have been no sizable such operations identified.

The Research and Development Unit of the Department is conducting
a detailed pilot demonstration study of small lake basins ineastern New York
State. The purpose of the study is to gain a better understanding of the
eutrophication process in order that an effective control program can be
carried out on a statewide basis. Basic data on the physical, hydrological,
chemical and biological characteristics of the lake has been obtained. This
provided the basis for formulation of a detailed plan of research from which
to evaluate the need for and value of engineering control mechanisms such
as advanced waste treatment, improved individual summer home disposal
methods, changed agricultural practices, diversion of land run-off or waste,
etc.» Completion of this phase is expected in 1970.

Once the necessary control measures are defined, the final
phase of full scale demonstration of the engineering control measures found
necessary will be performed to determine costs and effectiveness. This
phase will be conducted during 1971 and 1972.

10. Industrial Effluent Sampling Programs

Industries discharging into or affecting water quality in Lake Erie
routinely sample wastes, maintain records and report periodically to the
New York State Health Department. Industries which are required to monitor
these effluents as part of an active operating permit are:
Eastern Tanners Glue Co.
The Borden Company
Bethlehem Steel
Nuclear Fuels Services
Penn Central Railroad
Allegany Ludlum Steel
Gowanda (V)
Arcade (V)
Lackawanna (C)
Ashford (T)
West Seneca (T)
Dunkirk (C)
Gattaraugus Go.
Wyoming Co.
Erie Co.
Gattaraugus Go.
Erie Go.
Ghautauqua Go.
Construction permits have been issued to the Penn Central
Railroad in the City of Buffalo and the Moench Tannery in Gowanda. These
industries will be required to maintain effluent sampling programs when
construction is completed.

Testing and measuring is also carried on by the following
industries included in the waste outlet registration program:
Allied Chemical
Donner Hanna
Socony Mobil Oil
Buffalo (C)
Buffalo (C)
Buffalo (C)
Erie Co.
Erie Co.
Erie Co.
-------
611
Republic Steel Buffalo (G) Erie Go.
Niagara Mohawk Dunkirk (C) Erie Go.

These data are being reported to Albany on an annual summary-
basis for compilation and evaluation with respect to permit renewals and
effects of waste on water quality.

11. Water Quality Surveillance Network

New York State has established a water quality surveillance
network consisting of 116 sampling stations including 12 automatic monitors.
Included in the Lake Erie Enforcement Conference area are manual sampling
stations on the Buffalo River, 1. 6 miles upstream from the mouth, on Buffalo
Greek at the USGS gauging station in Gardenville approximately 10. 4 miles
upstream from its mouth, on Gattaraugus Creek at the Aldridge Street Bridge
in Gowanda approximately 16.7 miles from Lake Erie, and in Buttermilk
Greek at Thomas Corners Road Bridge about 0.2 miles upstream from the
junction with Gattaraugus Creek. In addition an automatic monitor station
has been placed in operation on Bird Island in Buffalo to continuously sample
the Niagara River and Black Rock Canal.

12. Regional Planning

Gounty-wide comprehensive sewage study have been completed for
Erie, Ghautauqua and Gattaraugus Counties. These studies initially were
responsible for some delay in achieving compliance with abatement schedules.
However this has been overcome and implementation is moving at a brisk
rate. Requirements for compliance with comprehensive plan for construction
grants eligibility have been successful in securing cooperation between
neighboring communities.

Summary

In summary, treatment facilities are under construction to effectively
treat over 75% of New York State's unabated wastewater discharges. Another
10% by volume are under preliminary or final design and the remaining 15% have
been referred for Departmental penalty assessments and legal action by the
Attorney General's Office.

A supplementary statement regarding the mercury problem in
Lake Erie as it effects New York State is attached.
THIS CONCLUDES NEW YORK STATE'S PRESENTATION
-------
Lake Erie Enforcement Conference 612

Progress Report

June 3, 1970

Detroit, Michigan
Supplemental Statement on Mercury in Lake Erie
Surface water supplies, wastewater outfalls, bottom sediments,
and fish in Lake Erie were sampled and analyzed for mercury concentrations.
Manufacturers, distributors and users of mercury and mercury compounds
were inventoried. This investigation has been coordinated with FWQA.

Asa result of this investigation, it was determined that the only
industrial plant discharging mercury into the waters of Lake Erie was the
Buffalo Dye Works Division of Allied Chemical Company in Buffalo. There is
no evidence that this discharge effects mercury levels in Lake Erie water or
fish samples due to its proximity to the Niagara River out flow.

However, on May 8, 1970, the company was directed to reduce
the wastewater discharge of mercury by our Buffalo Regional Office. The
company's response was to completely suspend the mercury using process.
(Mercury is used in this instance as an intermediate in the production of
dyes.) It was estimated that the company was using about 4 pounds/day of
mercury before suspending the operation. On May 15, the company was
directed to submit a plan by May 25, 1970, for elimination of the mercury
discharge. This plan has been received and is being evaluated. In the
meanwhile, operation of the mercury using process remains suspended.
-------
613
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622

R. C. Mt. Pleasant

MR. MT. PLEASANT: The purpose of the report is

to describe the status of New York State's water pollution

control program and also the progress made on the Enforce-

ment Conference recommendations. As in the past, the report

addresses itself to the wastewater discharges in the Lake

Erie portion of New York State from the Buffalo River to

the southern New York State-Pennsylvania State line.

The enforcement status: 17 of the 42 previously

identified wastewater sources have been abated or have become

inactive or are now considered insignificant. The remaining

25 unabated wastewater dischargers account for a total of

225 MGD of municipal or industrial wastewaters.

Pour industries and one municipality out of this

25 have projects under construction which will intercept

and treat about 174 MGD of this wastewater. Four industries

and 11 municipalities accounting for another 21 million

gallons of wastewaters have projects in final or preliminary

design. Four industries and one municipality accounting for

another 30 MGD of waste have been referred for legal action

including penalty assessments and Attorney General action.

The specifics relating to the individual dates of

the abatement schedules and action taken and action pending

are included in the appendix attached to this report.

With respect to construction grants, New York
-------
623

R. C. Mt. Pleasant

•State's Pure Water Enforcement and Construction Grants

Program has generated a $51.6 million worth of construction

projects in this area for water pollution control. State

grants to these projects amount to $21.4 million including

prefinancing of Federal shares when necessary.

This construction is in compliance with the $400,000

comprehensive planning effort which is now completed for

Erie, Cattaraugus and Chautauqua Counties.

This construction program is also incorporating

the phosphorus removal requirements in New York State as

described a year ago in Cleveland.

With respect to operation and maintenance grants,

although major emphasis is currently on enforcement and con-

struction, efforts are continuing to concurrently obtain

the maximum performance from existing facilities. As an

incentive, New York State communities may receive one-third

reimbursement of audited operation and maintenance expenses.

And in this enforcement conference area, 37i sewage

treatment plants currently serve an estimated 181,000 people.

Seventy-three percent of these plants serving 97 percent of

this population have received about $1 million in O&M grants

since 1965. This indicates that these plants do treat with-

in the design capability of the existing facilities and

have committed themselves to an abatement schedule acceptable
-------
624

R. C. Mt. Pleasant

to the department.

Unqualified success in improving the level of

plant operation and protection of water quality standards

has resulted from this program. But more importantly, it

has set the stage in establishing awareness and good habits

essential for effective operation and protection of the

capital expenditures underway.

In the area of highlights, I would like to just

briefly run over the construction aspects of the waste

sources in this enforcement area.

At Bethlehem Steel in Lackawanna, all 9 permits

required for the construction of essential pollution control

facilities have been issued by the Department of Health.

Two operational permits have been issued, one for the 45-inch

slab mill and one for the 10- and 12-inch bar mills, which

will handle 17.8 MGD. These units are in operation.

The total construction program for Bethlehem is

estimated at $10.8 million of which $8 million worth of

projects are completed. Completion of all projects is

expected by June 1971.

Republic Steel has $3.25 million worth of water

pollution control projects under construction which will

treat 23 MGD of process waste from the bar mill blast furnace

and basic operation general furnace. Completion of
-------
625

R. C. Mt. Pleasant

construction at Republic Steel is expected by July 1971.

The Moench Tannery, Division of Brown Shoe, at

Gowanda, New York, has completed and submitted final plans

which provide for treatment to adequately reduce its waste

discharges to Cattaraugus Creek prior to discharge into Lake

Erie. Construction is now under way to be completed by

June 1971.

The Buffalo Dye plant on the Buffalo River has

facilities under construction to pretreat 4.5 MGD of waste

prior to discharge to the Buffalo Sewer Authority System.

Actual tie-in to the Buffalo Sewer Authority is scheduled

by January 1971.

Finally, the City of Dunkirk is revising its final

plans to include phosphorus removal which should be com-

pleted this month. Construction of the outfall line and

the interceptor sewer is already under construction with

overall completion by November 1971.

We have a couple of problem areas, just to briefly

go over, mainly at joint municipal and industrial waste com-

plexes. In Fredonia in Chautauqua County, pilot plant

studies were required by the department to firm up final

design. The major contributory industry in the village has

not taken action to construct required pretreatment facili-

ties and, consequently, has been referred to the Attorney
-------
626

R. C. Mt. Pleasant

General's office for legal action.

MR. STEIN: What kind of company is that?

MR. MT. PLEASANT: That is the Red Wing Company.

MR. STEIN: What do they do?

MR. MT. PLEASANT: They make canning products,

tomatoes.

MR. STEIN: It is a cannery?

MR. MT. PLEASANT: Yes.

MR. STEIN: Thank you.

MR. MT. PLEASANT: Requirement for pilot plant work

on the Fredonia project has caused the village to fall behind

on construction start date.

In the Village of Westfield, a similar problem is

encountered where the consultant was also required to con-

duct pilot plant studies to verify waste characteristics and

treatability. These studies will be performed during the

upcoming canning season during September and October of this

year.

The original consultant was disengaged and another

firm which is also evaluating industrial wastes from the

three major processing industries within the village was

retained. All four entities are committed to the same abate-

ment schedule with start of construction by November 1971.

One of the major industries, Welch Grape Juice, has
-------
627

R. C. Mt. Pleasant

been referred to the Attorney General for legal action

because of inconsequential action taken on its requirements.

With respect to the conference recommendations, I

will just skip through a couple of these. With respect to

the nutrient removal policy, the policy that was described

last year is being implemented. Municipal officials have

been contacted by the health department and the policy

described and their responsibilities included.

At this time, the City of Dunkirk, the Town of

Hamburg master plan and the City of Lackawanna are being

required to provide for phosphorus removal facilities.

The Villages of Lancaster and Depew in Erie County

will be connecting to the Buffalo Sewer Authority which is

also designing for phosphorus removal. So far, no industries

have been identified as needing phosphorus removal.

With respect to deep well disposal, this alterna-

tive remains as a method of last resort which has to be

demonstrated to have the least effect on the total environ-

ment. To date, in New York State, two construction permits

have been issued, one to Hooker Chemical Corporation which

is not in this particular area. This company has abandoned

this method of disposal in favor of reclamation of the

hydrochloric acid.

Bethlehem Steel Company has received the other
-------
628

R. C. Mt. Pleasant

construction permit. That well has been constructed, is not

operating, and so far has not received an operating permit.

We anticipate that before any operating permit is issued, if

it is issued, it will be preceded by a public hearing.

With respect to bathing beach surveillance in Erie

and Chautauqua Counties, nine Chautauqua County beaches were

surveilled and seven Erie County beaches. None of these

beaches were closed because of coliform results. There are

two beaches in the City of Dunkirk that were closed because

of decomposing algae, but were later reopened after clean-up.

I think before completing, I would like to include

the statement on the mercury problem in Lake Erie as it

affects New York State. This is a short one.

Surface water supplies, wastewater outfalls, bottom

sediments, and fish in Lake Erie were sampled and analyzed

for mercury concentrations. Manufacturers, distributors

and users of mercury and mercury compounds were inventoried.

This investigation has been coordinated with FWQA.

As a result of this investigation, it was deter-

mined that the only industrial plant discharging mercury

into the waters of Lake Erie was the Buffalo Dye Works

Division of Allied Chemical Company in Buffalo. There is no

evidence that this discharge affects mercury levels in Lake

Erie water or fish samples due to its proximity to the
-------
629

R. C. Mt. Pleasant

.Niagara River outflow.

However, on May 8, 1970, the company was directed

to reduce this wastewater discharge of mercury by our Buffalo

Regional Office. The company's response was to completely

suspend the mercury-using process. In this instance, mercury

is used as an intermediate in the production of dyes. It

was estimated that the company was using about 4 pounds per

day of mercury before suspending the operation. On May 15,

the company was directed to submit a plan by May 25, 1970,

for elimination of the mercury discharge. This plan has

been received and is being evaluated. In the meanwhile,

operation of the mercury-using process remains suspended.

That concludes this part of the presentation.

MR. STEIN: Thank you.

Are there any comments?

MR. MAYO: I notice the report didn't make any

mention of the Mobil Oil refining problem.

MR. MT. PLEASANT: I will identify the wastewater

sources that have been referred to the Attorney General for

penalty proceedings. This is in Section D of the appendix.

You are right, it isn't in the narrative.

North Collins Village in Erie County and Producers

and Canners Cooperative in North Collins Village have been

referred to departmental penalty proceedings under the
-------
630

R. C. Mt. Pleasant

public health law.

Socony Mobil Oil in Buffalo City has been referred

to the Attorney General for legal action.

Red Wing Company in Chautauqua County and Fredonia

has also been referred to the Attorney General for legal

action. They are also challenging the validity of the

Commissioner's order under an Article 78 proceeding.

MR. STEIN: What is the Mobil Oil problem? The

reason I am asking the question is just from looking at the

gallons per day discharge, they are by far the biggest non-

compliance. Are they objecting to the authority?

MR. MT. PLEASANT: No.

MR. STEIN: What is the problem?

MR. MT. PLEASANT: Delay and non-compliance with

the schedule just generally. Specifically, perhaps Mr.

Seebald could elaborate.

MR. SEEBALD: They have high phenol in the oil and

run antiquated oil removal apparatus. And they have failed

to either renovate their existing equipment or provide us

up until last week with a report on their intentions. We

received this just late last week, but we will probably not

take any direct action in response to this pending some

advice from counsel inasmuch as it is in litigation right

now.
-------
631

R. C. Mt. Pleasant

MR. STEIN: I can understand that.

Any other comments or questions?

MR. SEEBALD: I would like to add just for the

record that three pieces of legislation in New York State

significant with respect to water pollution were passed by

the legislature at the past session. One gives the depart-

ment the authority to control the storage and transportation

of hazardous liquids.

The second provides for an aid program to assist

in the construction of lateral sewers in small communities.

A third involves raising the penalties for water

pollution events from $500 to $2,500 in the first instance,

and for a continuing discharge, a daily penalty raise from

$100 to $500 per day.

In addition, I would like to emphasize that the

problem in the municipal slippage as indicated in our tabu-

lation is centered around the fact that implementation of

the metropolitan plan provided for in the comprehensive

study has been hampered by the lack of an effective umbrella

agency for this type of implementation in Erie County and

has not been due to any real foot dragging on the part of the

communities themselves. They have been willing to amal-

gamate, but there has been no incentive at the top level.

And actually the effectiveness that has been instant to
-------
632

R. C. Mt. Pleasant

date has been through the State requiring a combined approach

to sewage and sewage treatment using the eligibility for

grant assistance with Federal Government support hinging upon

the requirement that they comply with the comprehensive study

acceptable to the Commissioner. And it is to be hoped that

the Federal Water Quality Administration will continue to

support this comprehensive study to allow us to persuade

these communities to join together.

I noted this morning it was brought up by Mr. Remus.

It is one of his fond hopes that the Federal Government will

continue to support this comprehensive approach to sewage

treatment and not permit a GTA loan policy supplied with

Federal or local assistance.

MR. STEIN: Are there any comments or questions?

MR. POOLE: May I ask one?

What about the local sewer program? How much fund-

ing was provided for that?

MR. SEEBALD: It has been a mystery. It was a

$10 million appropriation. The first payments will not be

made until next fiscal year, March 31, 1971. By that time,

we hope to nail down just the exact amount of funding.

This last legislature adjourned in rather hurried

fashion and left quite a bit of this legislation pending,

including of most significance, of course, the funding of
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633

R. C. Mt. Pleasant
*

the various programs.

MR. POOLE: What percentage of the costs can you

take?

MR. SEEBALD: It is based upon an upset figure of

$150 per household connection, the State picking up the

remainder up to the cost of the actual connection. This is

based on a sliding scale with the base determined by the

number of connections and the total cost of the project. As

the number of connections increase, the actual per connec-

tion support will decrease.

MR. POOLE: Thank you.

MR. STEIN: Are there any other questions or com-

ments?

(No response.)

If not, thank you very much.

I think that concludes the State presentations.

Before we go into the consideration of mercury, do any of

the States have anything for us to consider?

MR. PURDY: Only one suggestion, Mr. Stein. And

this is to expand your request to have a joint Federal-

State review of the Ford Motor Company project. I would like

to expand that to have a joint Federal-State on-site review

of all of those projects that are listed in your report as

being behind schedule so that there will be a complete under-
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634
standing on both sides here.

MR. STEIN: Will that be agreeable?

If I understand the suggestion — and I might say

I think this is good — if we have projects which are listed

as behind schedule in our report, we should be able to get

together with the State concerned and hopefully the industry

and come up with a statement on that project which is agreed

to, factual statement which is agreed to. That State, the

Federal Government and hopefully the industry ought to give

a substantial description of what the situation is. This

will be based on inspection where you think it appropriate

and not just representation.

MR. PURDY: That's right. Where facilities are

under construction and so forth, this will be an on-site

inspection.

MR. STEIN: I visualize this to be somewhat like

the reports we got of the 180-day notice reports where we

signed off that everyone was in agreement that this was what

the situation is. And in all those cases, by the way, I

think we all are in agreement that the program is proceeding

and no further action is necessary,

MR. PURDY: I hope we can reach that conclusion.

MR. STEINr, Well, I don't know, but I think the

only possible way you can reach that is for everyone to
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-635
agree on the facts.

MR. PURDY: Right.

MR. STEIN: And this is what I think Mr. Purdy is

proposing. Will we be able to do that with them?

MR. MAYO: As far as the regional facilities are

concerned, it is going to be a very substantial work load.

We would have to sit down and from the Regional Office

establish point and make some evaluation of what it would

require in the way of manpower and resources to conduct what

may be a hundred or more inspections.

MR. STEIN: Well, let me make this offer to you:

We will supply the people to you from our national resources

to do that because I think this is essential. Otherwise, we

are just going to come here and in the absence of an inspec-

tion and an agreed-upon report, we are going to necessarily

get disparities. And we are at the stage of the case where

I think we have to get down to the hard facts.

By the way, let me tell you when this was done in

Ohio, there was complete agreement as far as I know with the

city, the industries, the State and the Federal Government, on

the facts of the five cases involved. And as far as I can

see, there is no factual problem or difference now.

We have the same situation involving that Eagle

Petrol case. And I think this is just one activity that we
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636
are going to have to engage in if we are going to deal with

compliance or alleged violations to determine whether further

action is necessary or not. And I don't see if you are ever

considering modifying or overlooking the compliance how you

could ever make the recommendation without having this. I

myself can't see how we possibly can move ahead.

MR. POOLE: I would like to put in a bid to have

that done for the Indiana projects also, Mr. Chairman.

MR. STEIN: Is this agreeable?

MR. LYON: Do I understand this correctly, Mr.

Chairman, you are planning to go over every project that is

behind schedule?

MR. STEIN: That is alleged to be behind schedule

so we have an agreed-upon factual statement with the industry

if we can get it, but certainly with the State and Federal

Government.

MR. LYON: They will be done at these regional

conferences?

MR. STEIN: No, we will send our men out with you

and make arrangements to do it. Because in a lot of cases,

you are going to sit down in the office. And as you and I

well know, you can talk and talk, but you have to go out

and look before you are going to decide what the situation is,

MR. LYON: Well, let me just try to clarify this.
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637
Are you saying that you are going to physically visit every

single sewerage source and every single industrial waste

source that is in fact behind the original schedule that was

set up originally?

MR. STEIN: No. What I am saying is where you

could not come to an agreement by sitting in the office or

where there is a doubt, then you have to go out and look.

Obviously, you are not going to spend time, I would hope,

where everyone is in agreement or you feel there is no doubt.

MR. LYON: I misunderstood.

MR. MAYO: Then, I misunderstood also, Mr. Chairman.

Under those circumstances, I think we can work within our

existing resource.

MR. HARLOW: I think we ought to recognize, Mr.

Chairman, though, probably over half the cities and indus-

tries involved here are in Ohio. And Ohio is not here to

speak for this.

MR. STEIN: We will offer this.

Now, my guess with Ohio is that Ohio will partici-

pate as you could tell with their approach here today. They

have participated with us in the past. And as a matter of

fact, maybe we should take our hat off; because before, when

Mr. Purdy suggested that we come to this stage with these

Ohio communities, they made a request that someone from the
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638
Federal Government attend their monthly meetings -- each one -"-

so as these came upr we and they could proceed on the same set

of assumptions on the facts. If there were any differences Ln

the facts, we could go out and investigate them and see what

the truth of the matter was. I have no doubt that Ohio is

going to push this.

I think in the absence of this, as they say back

at home, it is going to be more work for mother. This is

the fastest way of doing it.

Unless we can get agreement and complete agreement

between the State and the Federal Government on the facts at

this stage of the operation, we may embark on procedures

which can be very time-consuming and have really drastic

legal consequences. So I think we have to keep that in mind

and move. And hopefully, the industries and the cities will

join us in that. Because I think this is to everyone's

benefit.

MR. LYON: My confusion arises, and I think we

have already spent a lot of time — almost two days here --

in this thing, is this something that is going to happen

before these regional meetings or is this joint Federal-

State review? Will this happen, for example, in Pennsylvania?

When you come to Erie, are we going to look at the facts and —

MR. STEIN: No, no.
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639
MR. LYON: May I finish this point? Am I correct

that we are going to then look at the record, and if we

agree, that is fine. And if we don't agree, then we are

going to go out in the field and look at it?

MR. STEIN: Right.

MR. LYON: But the Erie meeting will be the time

when we carefully review each case?

MR. STEIN: When we see what we have to do.

Now, the Erie meeting also, as I understand it,

has another aspect. At the Erie meeting, we will want to

hear from the industry and the people and other jobs to see

what information they have. They may raise some points

which may require investigation before we can lay those to

rest and settle them.

MR. LYON: My only concern is that we try to as

efficiently as we can get together on information. We find

that we are spending so much of our time giving information

to the Federal Government and going to meetings that we

don't have much time left to clean up the pollution. So my

only suggestion is let's please make this process official

so we don't have to write 10 more letters and write five more

reports and go to five more meetings. If we can clean this

up at the Erie meetings and if there are any differences,

fine, we will go out and look at the facts.
-------
640
We feel the Federal Government should have all the

facts and should take enforcement action when it is needed.

But let's try to somehow streamline this process. We feel

very frustrated by the many Federal reports we have to sub-

mit. And frankly, we just don't have the man-hours. We

think our time should be spent cleaning out pollution.

MR. HARLOW: Since it looks like my office may be

doing some of this work, I want to make sure I understand

what it is you are asking for.

Now, if you are talking about putting together,

like you said before, some kind of statement regarding what

we did on the 180-day notices, I think you are talking about

a major undertaking. But if you are talking about just

sitting down in the State offices and going over city by city,

industry by industry, those that are behind and coming to an

agreement on what the status is, my first reaction is that

this, we already have.

MR. LYON: That's right. We just did that. We

just sat down.

MR. HARLOW: We have been doing that the last three

or four weeks.

MR. STEIN: I am not sure you are in complete agree-

ment, and I am not sure you have checked these facts out on

the basis of an inspection.
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641
MR. LYON: Mr. Chairman, they change almost from

day to day. So you will undoubtedly find that the facts

in some of these cases will have been changed by next week,

some for the better, some for the worse.

MR. STEIN: No one is arguing about those changes.

We are talking about apparent differences in Federal, State

and industry reports when they come in at the same time.

Now, I thoroughly agree with what this is going to

say, but one of the reasons, I think, is not because it is

a Federal or State report or a meeting. I think if we are

going to sit around on our bureaucratic rear ends, I fear we

are going to get enmeshed in operations. And if it takes us

this long to get a simple inspection and recording system

off, I understand why it takes so long. I don't look for

this to be an involved operation.

MR. LYON: Yes, but the problem is, Murray, we

were just asked by your Charlottesville office for the same

information about two months ago. And it is taking us

literally thousands of man-hours to put all of this informa-

tion together. We separately gave it to Mr. Harlow. We

also have to submit it separately as part of the comprehen-

sive planning process.

And frankly, I am not going to keep any more

people in the office to do clerical work. We simply have
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642
got to get out into the field and check on polluters.

Last year, Pennsylvania lost 6,000 inspections

because we were kept in the office doing clerical work, fil-

ling out Federal reports. And we simply can't do any more.

MR. STEIN: I think maybe I misunderstood Mr.

Purdy, but if you think this involves clerical work, I think

we missed the point.

MR, LYON: If it doesn't, we have got no problem.

MR. POOLE: Mr. Chairman, may I get in? As you

well know, we did some of this with both Illinois and

Indiana industries in the south end of Lake Michigan. And

it was a special project, Walt. But it was done in a very

short period of time — in this case, I think a matter of

about two and one-half weeks. And my judgment is that it

had a very healthy effect on a portion, at least, of the

people that we looked at in those inspections.

Like Pennsylvania, I don't want to get involved

in a lot more paper shuffling and report writing and office

work. But what I visualized as Purdy and the chairman

started discussing this is that I would like for somebody

to come down to the office and we will go over our list and

then jointly go into the field and sort of put it up to

them, whether it be a city or an industry, that we have come

here to look things over to make up our mind whether or not
-------
643
the 180-day notice ought to be filed against them.

And I think that that kind of a visit will shake

some of these places off of dead center whereas if I go back

to Indianapolis in the morning and say, "I have been up to

Detroit two days, and you are behind schedule, and people

are getting awfully impatient about this and you better get

on the ball," they will pay a lot more attention to the

joint inspection than they will to that communication from

me.

So I would not like to reserve the Indiana work

only to either industries or cities where there is a difference

of opinion between my office and Mr. Mayo's office or Harlow's

office as to the rate of progress. I think it is workable.

I don't think it will take too much time.

And if you want to know what I actually think

about it from the standpoint of pollution abatement, I think

it will do a hell of a lot more good than sitting here at

this table talking about it for the last two days.

MR. STEIN: I agree with you.

May I make just one more comment as an example

here? Going to a major United States steel company — and

I was there with George — we went there on one of these

visits, and we looked at the effluent,coming out of their

operation. And they had a pretty extensive operation. The
-------
644
air looked like about the color of this cigar, maybe a little

lighter. And they bragged in the office.

I said, "Let's see the effluent line." I said,

"Do you mean this is what you are putting out?"

And they indicated some days it is better, some

days it is worse»

I said, "Well, you know, this is a great thing.

What would you have done today if I came down with the

League of Women Voters and they saw this effluent?"

Well, we had a little polite conversation. Then

the companies were served with 180-day notices.

When George Harlow went back there the next week,

do you know what the color of that effluent was? The color

of this water. And it was the same facility.

I agree with Mr. Poole, if we can get that kind

of improvement with just a little visit like that, it does

a lot more good when you give this individual attention and

spotlight the facts than by almost any other method.

The reason I say that is I think we are at this

stage of the game. In these earlier planning stages dealing

with preliminary reports, this wouldn't be effective.

But at the stage of compliance and enforcement we are at

now, I think this can be the most effective method and
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645

L. A. Van Den Berg

produce the most rapid results.

MR. LYON: No objection at all to that as long as

we don't get a letter from George Harlow asking us to once

more update all our cases. I would be happy to review

every one of them at the yearly meeting and cooperate with

you.

MR. MAYO: Mr. Chairman, the Regional Office will

accept the responsibility for putting together a schedule.

And we will be in touch with you.

MR. STEIN: All right, is there anything else

before we go on to mercury?

(No response.)

Let's go on, then. Mr. Mayo.

MR. MAYO: Yes. The presentation of the mercury

report for the Federal Water Quality. Administration will

be given by Mr. Lowell Van Den Berg, Assistant to the

Director of the National Field Investigating Center of FWQA,

Cincinnati, Ohio.

I understand that a Mr. Beebe of the Food and

Drug Administration may be available here this afternoon.

Is he in the audience?
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646

L. A. Van Den Berg

STATEMENT OF LOWELL A. VAN DEN BERG

ASSISTANT TO THE DIRECTOR

NATIONAL FIELD INVESTIGATIONS CENTER

FEDERAL WATER QUALITY ADMINISTRATION

CINCINNATI, OHIO

MR. VAN DEN BERG: Mr. Chairman, I have additional

information since this report was compiled. I took the

liberty last night of incorporating that data in this one

revised copy. So I will update the report and send you a

copy for inclusion in the record.

MR. STEIN: Yes, go ahead.

MR. VAN DEN BERG: This report was compiled by

personnel from the Great Lakes Regional Office, Lake Huron

Basin Office and Lake Erie Basin Office, in cooperation

with personnel of the National Field Investigations Center.

The introduction starts on page 8.

The toxic effects of mercury and its compounds in

the water environment are well known and are documented in

the literature. However, much remains to be learned on

toxicity limits of the various mercurial compounds in the

water environment. The upper limit of mercury in food,

used by the Food and Drug Administration, is 0.5 ppm wet

weight. Limits have also been set for atmospheric concentra-
-------
647

L. A. Van Den Berg

tions and numerous cases of poisoning have been reported.

Critical pollution from mercury became apparent on

March 24, 1970, in the Great Lakes. Mercury concentrations

as high as 500 parts per billion (or 5 ppm) were reported in

some of the pickerel shipments from Canada and commercial

fishing involved was suspended by Canada, then Ohio, Michigan

and New York. The presence of mercury in fish and bottom

sediments in the St. Clair River-Lake Erie system has con-

firmed the existence of an environmental problem of major

scope.

Mercury is discharged to the water environment

from industrial processes and uses of mercurial products.

In 1968, mercury produced from mining in the United States

was 2,194,000 pounds. The total amount used in 1968, how-

ever, was 5,732,000 pounds. Over 163 million pounds of

mercury have been consumed in the United States in the pre-

sent century, but little information is available on the

final disposition of it and amounts accumulated in the

environment.

Metallic mercury and mercurial compounds in liquid

wastes are characterized by their high densities. Free

mercury and the mercurous compounds form sludges and settle

to the bottom of receiving waters. The mercuric compounds

form precipitates with oxides, phosphates, sulfides and
-------
648

L. A. Van Den Berg

carbonates. The high density is responsible for the rapid

deposition in bottom sediments where they persist, become

subject to sediment transport and are available to the

aquatic life.

Metallic mercury can be oxidized readily to divalent

mercury ions under the conditions present at the bottom of

lakes and rivers. This has been shown to occur experimentally

as well. The divalent inorganic mercury produced has an

extremely strong affinity for organic muds and is methylated

in the bottom sediments. Divalent organic mercury, when

methylated, is readily released from the sediments into the

water.

Many fish are bottom feeders or feed upon organisms

which are bottom dwellers and therefore the hazard of mercury

ingestion becomes very great. Pish also absorb mercury from

the water through the gills and possibly the scales.

Since biological concentration of mercury occurs,

the accumulation of mercury in the food chain is a matter of

grave concern. A recent report indicates a magnification or

concentration of mercury of over a million in the protoplasm

of bacterial species. It has been demonstrated that the con-

centration from water to pike is in the order of 3,000 or more.

Uses of Mercury

Sources of mercury in the environment principally
-------
649

L. A. Van Den Berg

•come from industrial processes utilizing a form of mercury

and the use of mercurial products by man.

The industrial uses in 1968 are listed as follows:

These values are in thousands of pounds.

1. Electrical apparatus 1,492

2. Electrolytic preparation of
chlorine and caustic soda 1,326

3. Paints 803

4. Charging new installations of
chlorine and caustic soda cells 630

5. Industrial and control instruments 581

6. Agricultural uses 260

7. Dental preparations 158

8. Catalyst preparations 145

9. Laboratory uses 151

10. Pharmaceuticals 32

11. Pulp and paper uses 31

12. Amalgamation 20

Mercury is used as the cathode in the electrolytic

manufacture of chlorine with caustic soda and hydrogen as

by-products. Cell recharging to make up the various losses

from this process was 26 percent of the total mercury used

in 1968 by all industries. To maintain the mercury inven-

tory it required purchases of 1.3 million pounds of mercury

in 1968. Weak spent brines, acids from the chlorine driers,
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650

L. A. Van Den Berg

brine sludges and cell cleanings are discharged to the water

environment from this process. The mercury may be metallic

mercury emulsion, soluble and insoluble mercury salts.

In 1968, 630,000 pounds of mercury were used in the

start-up of new electrolytic installations. This amount

eventually contributes to the cell losses.

Information from manufactures of mercurials used

for herbicides, fungicides and bactericides is not readily

available. These compounds usually are produced in batch

processes and require considerable cleanup with possible

losses of mercury.

In the pulp and paper industry, phenyl mercury

acetate is used for slime control and ground wood pulp may

contain up to 20 ppm of the fungicide. This mercury is

either lost to the product or to the waste load during pro-

cessing. In either case it becomes a waste.

Large quantities of mercury are used in the manu-

facture of electrical apparatus and industrial and control

instruments such as mercury cells, arc lights, pumps and

switches. This poses a hazard of loss during the manufac-

turing process.

Catalysts, containing 10 percent mercuric chloride

are manufactured for use by the petrochemical industry. This

is made by passing a water solution of mercuric chloride over
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651

L. A. Van Den Berg

carbon and is used for making vinyl chloride from acetylene.

Another catalyst containing mercuric sulfate is used in pro-

cessing acetylene to acetaldehyde. There are losses to the

water environment from these processes.

Paints, those used for mildew control as well as

those having anti-fouling characteristics, contain mercury,

usually in the organic form. Erosion from paint films con-

taining these compounds is another source of loss to the

environment.

Mercury is used in dentistry for the preparation

of amalgams. Minor losses may result from this use.

Laboratory use of mercury in manometers, thermo-

meters, calomel cells, standard cells and as reagents results

in an occasional discharge to sewers. In large research

centers or universities, the quantities can become appreciable.

Minor users of mercury are the pharmaceutical manu-

facturers and in amalgamation. In the pharmaceutical manu-

facture, diuretics and antiseptics, i.e. calomel, phenyl

mercury acetate and merthiolate are made. Accidental spills

are the source of loss to the water environment.

The recovery of gold and silver by mercury amalgam

is a wet process and may result in rather high losses of

mercury in the plant effluent.

Additional mercury is introduced to the water
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652

L. A. Van Den Berg

environment through the use of products containing mercurial

compounds. The most widespread example of this is in the

agricultural application of fungicides and pesticides, which

results in losses during periods of runoff from the area to

which they are applied.

The FWQA-Lake Huron Basin Office (LHBO) initiated

a water and sediment sampling and analysis program for mercury

in the St. Clair River to Lake Erie system immediately after

the Canadian Government announced the fishing ban in Lake

St. Clair on March 24, 1970.

Sample collections were made by personnel from the

Lake Huron Basin Office with assistance from the Michigan

Water Resources Commission.

Water samples were collected with a surface grab-

sampler. Sediment samples are obtained by the use of either

a Petersen dredge or a drag line sampler. These devices

penetrate the bottom to about one-fourth foot.

The State of Michigan reports no measurable mercury

in any water supply intakes within this area.

Page 15 is one of those which I rewrote.

St. Clair River and Lake St. Clair. Fifteen

sediment samples and 6 water samples were collected in the

St. Clair River. All water samples contain less than the

measurable concentration at 37, 33 and 25.5. They contain
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653
L. A. Van Den Berg
*
concentrations of 1.0, 0.2 and 0.3 milligrams per kilogram
by weight respectively.
The other 12 sediment samples contain less than
the measurable limit of 0.5 milligrams per kilogram wet
weight, but indicated traces of mercury were present.
In Lake St. Clair, one water sample and 26 sediment
samples were analyzed. Six sediment samples and a naviga-
tion channel close on the U. S. side contain mercury and are
in concentrations from 0.3 to 9.2 milligrams per kilogram.
Two samples from a disposal area outside the channel
contain mercury concentrations of 1.5 to 2.1 milligrams per
kilogram dry weight.
The other 18 sediment samples indicated the pre-
sence of mercury, but were less than the measurable limit.
Upper Detroit River (Lake St. Clair to Grassy
Island), page 20, sampling of the upper Detroit River and
lower Rouge River began on March 26, 1970, and continued to
April 24. Sixteen sediment and 6 water samples were obtained.
Mercury was detected in sediments along the U. S. Shore line
at boat ramps and in other backwater areas. Values ranged
from below the measurable level near the headwaters to 2.0
mg/kg downstream from the Rouge River. Levels in sediments
around Grassy Island and upper Fighting Island were all
below the measurable limit.
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L. A. Van Den Berg

Lower Detroit River (Grassy Island to Mouth).

In the portion of the Detroit River from Grassy

Island to the mouth of Lake Erie, 78 sediment and 23 water

samples were collected between March 26 and April 16. The

highest levels of mercury occurred in the bottom muds of

the Trenton channel downstream from the Wyandotte Chemicals

Corporation South Works, in a narrow strip of from 20 to

100 feet along the western shore. Concentrations along the

east shore of the channel near Grosse lie are less than the

measurable limit of 0.5 mg/kg. Mercury in the sediments

indicates that the Wyandotte Chemicals mercury discharge

hugs the western shore of the Trenton channel, depositing

mercury in the bottom muds along shore. No mercury deposits

were found around Wyandotte Chemicals waste beds, located

on the northern tip of Grosse lie. However, one sample

collected between Grassy Island and Grosse lie contained 4.4

mg/kg mercury.

Mercury concentration in sediments was found

along shore as far as Lake Erie. In addition to high values

near Wyandotte Chemicals, one sample with 26.0 mg/kg dry

weight was present at the northern tip of Horse Island

(Gibraltar, Michigan) at mile point 6.7.

Of the four samples collected at the southern end

of Fighting Island, one contained 1.2 mg/kg mercury, and the
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655

L. A. Van Den Berg
*

"others contained trace amounts, but were less than the

measurable limit. Wyandotte Chemicals waste lagoons are

located on Fighting Island.

The only mercury measurable in four samples in

Canadian sediments was near the shore at mile point 3.9.

That value was 0.6 mg/kg.

The levels of mercury in all water samples but

one were below the measurable limit of 0.01 mg/1. One

sample collected 300 feet downstream from Wyandotte Chemi-

cals outfall W23 (RM 13.3) contained 0.03 mg/1 March 31,

1970. The effluent was diluted by Detroit River water so

mercury was not measurable further downstream from the dis-

charge point.

Western Basin of Lake Erie, including the Raisin

and Maumee Rivers.

The sampling of Lake Erie began on April 6, 1970,

with bottom sediments collected at two stations near the

mouth of the Huron River. From April 6 to April 27, 44

bottom sediment stations were sampled. Samples were collected

in western Lake Erie west of Pelee Island, with the majority

of samples collected near the mouths of Michigan tributaries.

Based on the measurable limit of 0.5 mg/kg wet weight, mer-

cury was present at 16 of the 44 stations, although traces

were found at most of the other stations.
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656

L. A. Van Den Berg

The Raisin River was sampled on two different

dates at three stations. Traces of mercury were found;

however, all results were less than the measurable limit.

The Maumee River was sampled on April 17 at six

stations, and traces of mercury were found at most stations;

however, all results were less than the measurable limit.

The 1G stations where mercury was found are

located in the deepwater areas of the western basin of

Lake Erie from the mouth of the Detroit River southward and

eastward. Since shore line and minor tributary samples do

not show appreciable amounts of mercury, the Detroit River

appears to be the principal source, with mercury being

deposited in the deeper quiescent parts of the lake.

Mercury analyses in the eastern portion of the

Lake Erie Basin.

As part of its mercury investigations in the Lake

Erie Basin, the Federal Water Quality Administration-Lake

Erie Basin Office analyzed bottom sediments from the lower

portions of south shore tributaries and from the lake bottom.

Tables 10 and 11 include results from the sediment and water

analyses to 5/12/70 except those made at the Detrex Chemi-

cal Corporation plant. Detrex analyses are listed in a

special report on the plant (Appendix II).

At the Lake Erie Basin Office the lower limit of
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657

L. A. Van Den Berg
i

.measurability of mercury in sediments is 1 mg/kg and in

water 0.002 mg/1.

The States of Ohio, Pennsylvania, and New York

report no measurable mercury in any water supply intakes

within this area.

In Table 10 on page 39, you will note that mercury

concentrations at the hydro discharge to Grand River, Dia-

mond Shamrock, Painesville, is 0.01 mg/1.

Euclid sewage treatment plant is 0.004.

Cleveland Southerly STP 0.004

Cleveland Westerly STP 0.003

Cleveland Eastern STP, less than 0.002

Mile 1.0 West Branch Ashtabula River 200 feet

downstream from titanium plant, less than 0.002

General Electric, Nela Park, Cleveland - discharge

3 gallons cover water every two weeks 1.060

This is a very insignificant amount of mercury

on a daily basis, but on Table 11 is Black River at mile

0.61, 8.

One hundred feet north of the Easterly sewage

and treatment outfall, it was 4 mg/kg.

Fifty feet north of the East 222nd Street - Babbitt

Road sewer outfall in Euclid, it was 2 mg/kg.

The Ashtabula River at 0.76 mile, it was 2 mg/kg.
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658

L. A. Van Den Berg

And No Name Ditch east of Ashtabula at Route 531

bridge, it was 8 mg/kg.

The only other measurable mercury level in sedi-

ment are on page 42. River mile 0.0, Buffalo River, 4 mg/kg.

River mile 4.3, the Buffalo River, 1 mg/kg.

Heavy metals in the Lake Erie Basin.

As part of the investigations in the Lake Erie

Basin, the FWQA, National Field Investigation Center analyzed

bottom sediments from various shore areas and tributaries.

The results of analyses for 10 heavy metals — magnesium,

chromium, polonium, nickel, mercury, manganese, iron, copper,

zinc and cadmium. Stations were selected in the mouth of

tributaries and immediately off-shore.

Heavy metals are toxic to aquatic bottom organisms

and fish when present in sufficient concentrations. Combi-

nations of some of these metals such as copper and zinc have

a total toxicity greater than the sum of the toxicities of

each metal taken independently. Metals such as iron oxides

precipitate in water and may blanket the bottom and smother

bottom organisms. Toxic metals in bottom muds can be made

available to the overlying water by physical, chemical or

biological means. Metals may re-enter the overlying water

by scouring of the stream bed because of velocity increases,

by wave action, or other water turbulences. These metals
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659

L. A. Van Den Berg

•may also be resolubilized by the waterbody dependent upon

environmental conditions such as pH, temperature and concen-

trations of other metals present. Some of these metals may

also be detrimental to aquatic organisms when concentrated

in the food web.

Summary and conclusions, page 1.

1. Data provided for the Bureau of Commercial Fisheries,

Technological Laboratory, Ann Arbor, Michigan, show that

mercury was present in fish throughout the St. Clair River-

Lake Erie system. Concentrations (parts per million, wet

weight) in the edible portions of various fish were: Keep

in mind the F.D.A. limit 0.5 ppm.

Yellow Perch 0.32 to 1.70

Northern Pike 0.64

Coho Salmon 0.24 to 0.96

Carp 0.08 to 0.28

White Bass 0.53 to 0.80

Steelhead less than 0.15

Walleye Pike 1.4 to 3.57

Channel Catfish 0.32 to 1.8

Gizzard Shad 0.24

Sucker 0.88

Sheepshead 0.24

2. Available information indicates that no measurable
-------
660

L. A. Van Den Berg

concentration of mercury was present in water supply intakes

in the St. Clair River-Lake Erie system.

3. Mercury in excess of 1 mg/kg dry weight was pre-

sent in sediments in the Erie, Pennsylvania, in Euclid and

Cleveland, Ohio, areas and the Buffalo, Black and Ashtabula

Rivers. Results of analyses indicate the following levels

of mercury in the areas specified:

The first area has been rewritten as a result of

newer data.

In the St. Clair River, mercury was present at

mile .37, 33 and 25.5 at concentrations from 0.2 to 1.0 mg/kg.

All other samples indicated the presence of mercury.

Six sediment samples from the navigable channel in

Lake St. Clair off-shore from the mouth of the St. Clair

River had mercury concentrations from 0.3 to 9.2 mg/kg dry

weight.

The upper Detroit River headquarters to Grassy

Island, mercury was not measurable at the head of the

Detroit River, but ranged from 1.4 mg/kg in backwater areas

to the U. S. shore upstream from the Rouge River and as high

as 2.0 mg/kg in backwater areas downstream from the Rouge.

The lower Detroit River, Trenton channel, in a

narrow strip of about 20 to 100 feet along the U. S. Shore

line, concentrations range from 86.0 to 5.4 mg/kg within a
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661

L. A. Van Den Berg
*

-mile downstream from the Wyandotte Chemicals outfall and then

vary from 26.0 mg/kg to trace amounts downstream to Lake Erie

depending on the settling characteristics of the specific

point.

The main channel of the Detroit River/ one sample

collected between Grassy Island and Grosse lie contained

4.4 mg/kg. On the east side of Fighting Island, one con-

tained 1.2 mg/kg. And one near the Canadian shore near the

mouth contained 0.6 mg/kg.

Northern Grosse lie, no mercury was present in

measurable amounts in samples along the northern part of

Grosse lie, the area of Wyandotte Chemicals waste beds, but

trace amounts were indicated.

Western Lake Erie, Michigan waters, concentrations

near the Detroit River varied from 1.0 to 2.1 mg/kg. Along

the Michigan shore, mercury was not measurable. Near

LaPlaisance Bay, one sample contained 0.8 mg/kg.

Ohio waters, four points near West Sister Island

have values ranging from 1.6 to 2.1 mg/kg. In other areas

nearer to shore, mercury was not measurable.

Canadian waters, concentrations of 1.3 to 2.7 mg/kg

were present at three points extending eastward about 15

miles from the Detroit light and about 5 miles from the

Ontario shore. Points extending to Pelee Island showed no
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662

L. A. Van Den Berg

measurable mercury.

Eastern Lake Erie, Ohio waters, concentrations of

2.0 and 2.4 mg/kg were present off-shore from mouth of the

Grand River and Cleveland Harbor, respectively. Off-shore

from the Cleveland Easterly sewage treatment plant, a con-

centration of 4.0 mg/kg occurred.

Pennsylvania waters, a concentration of 1.1 mg/kg

was found in Presque Isle Bay.

Tributaries, concentrations in excess of 1.0 mg/kg

were present in the Black, Ashtabula and Buffalo Rivers.

In the Rouge, Huron, Maumee, Sandusky, Portage, Rocky,

Cuyahoga, Grand, and Raisin Rivers, the concentrations were

less than 1.0 mg/kg.

4 . The waters of the study area revealed no mercury

except for one sample collected at mile point 13.3 in the

Trenton channel downstream from the Wyandotte Chemical Com-

pany; this concentration was 0.03 ng/1.

5. The Detroit River area is the primary source of

mercury in the western end of Lake Erie. This is revealed

by the distribution pattern established through sediment

samples.

6. Because of mercury discharges, the State of Michigan

stopped the production of chlorine by Wyandotte Chemicals

Corporation until a treatment system was developed and the
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663

L. A. Van Den Berg

mercury bearing wastes were removed from the receiving waters.

In our latest data on the 22nd of May, there appeared

no discharge of mercury from that outfall.

7. The State of Ohio issued an order to the Detrex

Chemical Industries, Inc., Ashtabula, Ohio, on April 13,

1970, to "..cease and desist the discharge of liquid indus-

trial waste containing any mercurial compounds to waters of

the State." Some operational changes were made but data

collected on May 11, 1970, indicate that Detrex still dis-

charged 1.2 pounds of mercury per day.

8. Allied Chemical Company, Buffalo Dye Division,

Buffalo, New York, is a source of mercury to the Buffalo

River. On May 8, 1970, a sample of the plant effluent revealed

0.12 mg/1 mercury. The company stated that the process utiliz-

ing mercury was not in use on that day. Based on this infor-

mation, Allied Chemical Company was discharging approximately

4 pounds of mercury per day from sources other than the

reported production of disulfo intermediates.

9. The discharge from Diamond Shamrock, Painesville,

Ohio, to the Grand River had a concentration of 0.010 mg/1

mercury on April 4, 1970.

10. The first statement has to be changed. Recently

received data revealed that concentrations of 0.002 mg/1

occurred at the Ann Arbor, Wayne County, Wyandotte and
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664

L. A. Van Den Berg

Detroit sewage treatment plants. These were all on 24-hour

composites on the 14th of May.

No measurable concentration of mercury was present

in sewage treatment plant effluents investigated in Michigan

(State data). Concentrations of 0.003 and 0.004 mg/1 mercury

were present in Euclid and Cleveland Westerly and Southerly

sewage treatment plant effluents, respectively. Although no

measurable concentration of mercury was present in the Cleve-

land Easterly sewage treatment plant effluent, which receives

wastes from several users of mercury, 4 mg/kg were present in

Lake Erie sediments 100 feet north of the discharge point.

11. On May 7, 1970, a concentration of 0.011 mg/1

mercury was present in the outfall from the National Aeronau-

tics and Space Administration, Lewis Research Center, Cleve-

land, Ohio. This occurred during a period when there was no

discharge from lagoons that supposedly receive all mercury

wastes from known sources.

12. Investigations of additional potential dischargers

of mercury to Lake Erie are in progress by the State and the

Federal Water Quality Administration.

Recommendations.

1. Surveillance and sampling programs be initiated by

industries, municipalities, States and the Federal Government

to locate and identify all sources or potential sources of
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665

L. A. Van Den Berg

mercury and to determine mercury concentrations in surface

waters, land run-off, waste streams, aquatic life, and

sediments.

2. All dischargers of mercury to surface or ground

waters or to municipal or regional waste treatment plants,

including Federal installations, be ordered to cease and

desist.

3. Precautionary measures be taken by all users and

possessors of mercury or mercurial compounds for any purpose

to prevent accidental spills or other losses to the water

environment.

That concludes my statement.

MR. STEIN: Thank you, Mr. Van Den Berg.

Are there any comments or questions?

Mr. Purdy.

MR. PURDY: First, I would like to have you repeat

the insert that you put in between 9 and 10 on page 5. I

didn't quite catch that. I think you inserted some additional

data.

MR. VAN DEN BERG: Yes. In the beginning of 10.

Recently received data revealed concentrations of

0.002 mg/1 in Ann Arbor, Wayne County, Wyandotte and Detroit

sewage treatment plants. This was based on a 24-hour composite

collected on May 14, 1970.
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666

L. A. Van Den Berg

MR.PURDY: On page 1, when you are presenting the

data from the Bureau of Commercial Fisheries on concentra-

tions of mercury in the edible portion of fish, is that data

that has been supplied or collected only by the Bureau of

Commercial Fisheries or is this now a summary of all the data

that is available on mercury content, including that of

Michigan Department of Agriculture, Ohio's data and Ontario's

data?

MR. VAN DEN BERG: That's just Bureau of Commercial

Fisheries data from Ann Arbor.

MR. PURDY: So really there is a great deal more.

MR. VAN DEN BERG: There is a great deal more infor-

mation available if we can get our hands on it.

MR. SEEBALD: Is this data on individual fish?

MR. VAN DEN BERG: In Appendix IV, the tables from

BCF indicate the number of fish that were analyzed in these

samples. And this varied depending on the type of fish. Some

of them were 8, 9, some of them were much larger numbers.

MR. PURDY: In sample preparations, Mr. Seebald,

they sometimes take 10 fish and grind them up together and

make one simple out of that.

MR. SEEBALD: I am puzzled because it gives a range

in some cases and specific numbers in other cases which lead

me to believe either they were a single batch or in other
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667

L. A. Van Den Berg

Cases a number of batches.

MR. VAN DEN BERG: There is a Footnote #4 on page

91 that explains those ranges. They have an average value

there, but they also give a range. The average value is on

6 individual samples in that particular case.

MR. POOLE: This is off that point, but on page 8,

the second paragraph where you say 500 parts per billion or

5 ppm in pickerel, which is it?

MR. VAN DEN BERG: Mr. Mayo, can you clarify that?

That information came from your office.

MR. POOLE: Well, I think your table on page 1

would show that it is above 500 parts per billion.

MR. STEIN: It is just straight arithmetic. One

of those figures has to be wrong.

MR. POOLE: All I am trying to find out is whether

you have as much as 5 ppm in fish.

MR. VAN DEN BERG: I can't clarify that.

MR. STEIN: Let's go on, and we will try to pick

that up.

MR. PURDY: I have some other questions, Mr. Stein.

MR. STEIN: Go ahead.

MR. PURDY: I am wondering if you would venture to

make a statement on what you might find in the way of mercury

content of the bottom that had not been contaminated from
-------
668

L. A. Van Den Berg

some man-made source.

MR. VAN DEN BERG: No, I wouldn't make a statement

on that.

MR. PURDY: Wouldn't you expect to find something?

MR. VAN DEN BERG: I would expect to find some in

certain areas, yes, sir. What level, I don't know.

MR. PURDY: I have another comment on this matter

of Detrex down the Ohio, Ashtabula, Ohio, apparently. Yet,

in the midpoint of May, it is discharging 1.2 pounds.

I was able to read in the newspaper by George

Rhodes with respect to what took place in Michigan. Apparently

he has not been quite as concerned about mercury that arises

in Ohio being discharged in Michigan.

MR. POOLE: It is farther south. It is not as

damaging.

MR. PURDY: You mentioned about the Lewis Research

Center, a certain concentration of mercury, and there was no

discharge from lagoons that receive all mercury waste from

known sources. What would the level be if there is a dis-

charge from the lagoons?

MR. VAN DEN BERG: I took some water samples or

George did from the lagoon, and the water itself in the

lagoon didn't show any mercury.

MR. HARLOW: Mr. Purdy, in regard to that statement
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L. A. Van Den Berg

on page 6 in connection with NASA, at the time that we took

the initial sample on May 7 when we had 11 parts per billion,

the lagoon was not discharging. But the ditch that enters

Rocky River which receives a number of storm connections

from other sources measured 11 parts per billion. And you

could guess here where it might have come from. It might

have been residual in the muds, or it could have come from

another source.

So we went back at two different times subsequent

to that and sampled the lagoon when it was discharging,

sampled the water in the lagoon, and also sampled the final

ditch that carries the storm water. And on these other two

occasions, we didn't find any mercury at all.

MR. LYON: You mean there was no mercury in the

lagoon?

MR. HARLOW: No.

MR. STEIN: Are there any others?

MR. PURDY: On page 9, several statements are

made with respect to the fate of mercury discharge to the

waters and then what happens when they accumulate in bottom

muds. And there is the one about they are available to

aquatic life and that they are readily released from the

sediments in the water and that fish absorb the mercury from

the water through the gills and possibly the scales.
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670

L. A. Van Den Berg

We have been doing a great deal of research of

the literature in the past several weeks to attempt to

determine the fate of mercury. And I am wondering if at

some later point in time you could furnish to us the references

from which this information came.

MR. VAN DEN BERG: Certainly.

MR. PURDY: Then, on page 11, there is the perni-

cious reference to a report by N. A. Smart, "Use and Residues

of Mercury Compounds in Agriculture," to the effect that it

raises the spectre of paper mills being a source of mercury

today. And I am wondering if you know what period of time

this particular author was talking about in his report.

MR. VAN DEN BERG: I refer that question to Mr.

Muir from our office in Cincinnati.

Can you answer that, Larry?

MR. MUIR: Mr. Purdy and Mr. Chairman, this in-

formation carried from 1964 up through 1967 and probably

into 1968. In 1966, I believe, the Swedish Government

banned the use of these materials. And much of this original

statement stated that Norway, Sweden, United States and

Canada were shipping pulp from their forests internationally,

and it contained up to 20 ppm phenyl mercury acetate.

MR. PURDY: From U. S. sources also?

MR. MUIR: This includes United States as being
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671

L. A. Van Den Berg

Chipped, as I understand it, from our south coast or from

the Texas, Louisiana, Mississippi and Florida areas to

Europe. And this material contained the phenyl mercury

acetates.

MR. PURDY: Why I am curious about this is the

presence of mercury now from paper mill discharges is not

something that we are experiencing here in Michigan. And

in fact, I think about 1959, the Food and Drug Administra-

tion banned the use of phenyl mercury acetate as a slimocide

in paper mills where the paper came in contact with food

products. And as a general rule, the paper mills have dis-

continued the use of this.

In fact, we have found none being used in Michigan

paper mills. And in fact, the industry indicates that this

is pretty much the situation throughout the United States —

somewhat different, then, from what this reference seems to

indicate.

MR. MUIR: As I say, this was up through 1968.

MR. PURDY: Well, the ban issued by the Food and

Drug Administration was in 1959.

MR. VAN DEN BERG: Mr. Purdy, do your paper mills

in Michigan utilize imported pulp that is transported for

long distances?

MR. PURDY: There is pulp that has been purchased
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672

L. A. Van Den Berg

from Canadian sources and other sources transported quite

some distance. We have sampled this, and we are not find-

ing mercury present in significant quantities.

MR. STEIN: I think Mr. Purdy has a good point

there because I have been asked that question several times

before I came out here and was waiting on the report. I

think if we are going to proceed with the mercury investiga-

tion, we should do this pretty rapidly, get in touch with

the Pulp and Paper Trade Association in New York — and

maybe there is a representative here, but I doubt it; I

don't see him — and ask how many mills are using this in

the United States, what the prevalence is, and whether we

are getting any pulp from other places that we are processing.

Because the question that comes up — and I think

Mr. Purdy asked this in Michigan — how many pulp and paper

mills use mercury in their process for slime control. And

I think we are going to have to have an answer to that.

MR. VAN DEN BERG: I hope, Mr. Stein, that infor-

mation is being collected by our Regional Offices for sub-

mission for the national report.

MR. STEIN: Well, I don't know. You can short-

circuit that, you see. When you have a question raised, you

could find that the trade association of the pulp and paper

industry is very knowledgeable on this. And they always
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673

L. A. Van Den Berg
•

"give out accurate information. So we may try to get that

and see how that checks against our regional submissions.

MR. MAYO: A point that might be kept in mind,

Mr. Chairman, is I understand the FDA regulations apply to

the pulps that are used best domestically for packaging

materials that come in contact with food. In the waste

pulp that was being shipped overseas for later use overseas

in the manufacture of paper and packaging materials, the FDA

regulations may not apply.

MR. STEIN: I recognize that. That's why I am

asking for a nose count. Because obviously, they are not

banning the phenyl mercury acetate in all paper mills or in

all processes. This is not what the Food and Drug ban goes

to.

The question that we have to ask is, in fact, how

many paper mills are using the mercury. Some judgment must

be made on that. Because on your previous page, you get the

thousands of pounds estimate.

MR. VAN DEN BERG: Those thousands of pounds esti-

mates come from the Bureau of Mines Mineral Year Book.

MR. PURDY: Is that consumption in the U. S. or

worldwide?

MR. VAN DEN BERG: That's in the U. S.

MR. STEIN: Again, Mr. Purdy, if we take this at
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674

L. A. Van Den Berg

its face value — and I don't want to spin this out too far

— but if you look at industrial uses in the U. S. in 1968,

the Food and Drug ban was in existence since 1959. We have

for pulp and paper uses 31,000 pounds.

When I first saw this and read this, Mr. Van Den

Berg, I thought pulp and paper wound up pretty low on the

list. This may be the reason for it. It may not be exten-

sively used or used in wide areas.

MR. PURDY: It is used for other purposes in

paper mills.

MR. STEIN: In some.

MR. PURDY: Some on the face of clocks, paper

used in clocks. Some of it is used in paper that goes into

wrapping of soap bars and so forth.

MR. LYON: I understand its use as a slimocide

was stopped some considerable time ago. For example,

Hammermill Paper used mercurial compounds as slimocides

about 10 years ago.

MR. PURDY: On page 44, there is this matter of

the toxic metals in bottom muds can be made available to

the overlying water by physical, chemical or biological

means. I have gone through how they say possibly mercury

might be made available to the overlying waters. I am

wondering if you could describe to me how this might take
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L. A. Van Den Berg

'place by other means. Is it something that we would

reasonably expect to happen or does it take some unusual

condition for this to come out of the bottom muds and be

in the overlying waters?

MR. VAN DEN BERG: I don't think it takes an

unusual condition. So much of this depends on the local

characteristics of the body of water.

MR. PURDY: Certainly it has got to be an unusual

condition, doesn't it, if it once is precipitated into the

bottom muds? There has got to be some driving force now

to put that back into the overlying waters.

MR. VAN DEN BERG: Yes, sir. But these deposits

that can take place during one period of the year over tem-

perature changes, for instance, in some cases are enough

to make that difference.

MR. PURDY: For what heavy metal, then, would a

temperature change cause it to redissolve?

MR. VAN DEN BERG: Practically any.

MR. PURDY: To the point that it would be toxic?

MR. VAN DEN BERG: No, not necessarily to the

point that it would be toxic at the concentration in the

water, but if the biological life has the capability of

concentrating within their bodies the toxic metal from the

water, there is a possibility of buildup^ where levels
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L. A. Van Den Berg

could be significant.

IVR. PURDY: Then, in the next sentence about they

may reenter the water by the scouring process, when they

scour, you mean they would be redissolved?

MR. VAN DEN BERG: Not necessarily. I think you

probably have a good example of that in the Detroit River.

At those intakes, there are bottom deposits, I am quite

sure, that are picked up and moved to another area.

MR. PURDY: And in fact is more like just sediment,

MR. VAN DEN BERG: Right.

MR. PURDY: Suspended solids.

MR. VAN DEN BERG: But in the process of doing

this, if you have a sludge bed that contains a metal that

has been covered over so it is not available, at that time

when it is scoured and transported to a different area and

resettled, it again may be in a position to be within the

active portion of the sludge or sediment deposit.

MR. PURDY: I think the statement is well quali-

fied by me.

MR. SEEBALD: In the interests of accuracy, I

would just like to ask the question about the reference to

the measurable limit of 0.5 mg/kg as cited on page 31 and

then a measurable limit on page 38 at 0.1 mg/kg.

MR. VAN DEN BERG: This data, Mr. Seebald, was
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677

L. A. Van Den Berg
•

-developed in about three or four different laboratories.

And some people are using the dithizone method which depends

also on the size of the cell they use in the spectrograph.

Other laboratories are using flamotoxic absorption. We use

a flameless vapor atomic adsorption technique. And each has a

different limit.

MR. SEEBALD: O.K. So then we don't have a uniform

base on which to compare the relative levels of this mercury

throughout the systems that we are talking about because of

the differential analysis we have got.

MR. VAN DEN BERG: Only above certain —

MR. STEIN: What is the answer to that question?

Is the answer that we don't have?

MR. VAN DEN BERG: We do in a certain range, yes.

At a certain range, we do, yes. About 1 rag/kg, the data is

comparable. But in the lower ranges, one guy can be —

MR. STEIN: Are these lower ranges ever significant?

MR. VAN DEN BERG: Mr. Stein, I don't think we know.

MR. STEIN: If they are significant and the fish

concentrate them, you might want to consider one recommenda-

tion that we come up with a uniform method of measuring.

MR. SEEBALD: That's my point, Mr. Stein.

MR. VAN DEN BERG: This was recommended to the

Admini stration.
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L. A. Van Den Berg

MR. STEIN: Was it recommended here?

MR. VAN DEN BERG: No, I am sorry.

MR. STEIN: O.K.

Any other comments or questions?

MR. SEEBALD: Just one other one. And, again, it

is a matter of accuracy. On page 39, the lower sensitivity

is 0.01 mg/1.

MR. VAN DEN BERG: Yes. I am afraid I am getting

mixed two people's data there, Mr. Seebald.

MR. SEEBALD: I am not being picayune. I just

want to be serious about this.

MR. VAN DEN BERG: This will go into the record

right.

MR. PURDY: Mr. Stein, on the insert of the data

of the Ann Arbor wastewater treatment plant, the Wayne

County Wyandotte plant and the Detroit wastewater plant, I

have been informed that that statement is based upon infor-

mation that was collected by the Michigan Water Resources

Commission and based upon a report that I was just handed.

And it shows of these samples, all but two have been collected

on 5/14/70. And there is something wrong there because

they had completed our sampling by that time. We do not

have our data with us, but we do not remember having mercury

present in the Detroit plant.
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L. A. Van Den Berg

We would like to have the opportunity to review

this data with our laboratory data back in the office and

send in any corrections that may be necessary by one week.

MR. STEIN: Yes. Right. For the record — but I

do think in light of what you said, Mr. Purdy, this is

developing in an area where to come up with an equitable

solution, we should get the materials that are going to be

presented in the workshops from the other States. Because

I don't think we can ask communities in Michigan to do some-

thing without taking reference to what they are doing in the

others. And maybe when that is concluded, we will be in a

position for the conferees to make recommendations and come

to conclusions.

But we would like to have that within a week. And

I think we will go over this again because I think it is

fair to say Mr. Van Den Berg is to be commended for putting

together a very good report. But as you can tell from his

report today and the information that I keep getting, new

information on mercury is pouring in now every day. And I

think we are facing a moving target here, so to speak. I

think we will be in better shape in a couple of weeks.

Are there any other comments?

MR. LYON: Yes.

Mr. Van Den Berg, in an earlier report that I
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L. A. Van Den Berg

received prior to the conference, there is an indication

that;the concentrations as high as 170 ppm have been found

in the discharge ditch of the Detrex Chemical plant in

Ashtabula which discharged to Lake Erie. But your report

— this report, at least — does not have any concentrations

that high. Is that correct?

MR. VAN DEN BERG: I don't remember seeing a

document that had that high of a concentration, Mr. Lyon.

MR. LYON: This is the report from Mr. Mayo on

May 14 which was addressed to the State water pollution

control agencies. On page 7 of that report, it quotes

concentrations as high as 170 ppm have been found in the

discharge ditch of the Detrex Chemical plant in Ashtabula.

MR. HARLOW: Mr. Lyon, this is on page 73 of Mr.

Van Den Berg's report.

MR. VAN DEN BERG: It is a sediment sample.

MR. LYON: Yes, it is in the section on sediments.

O.K., I didn't see that.

MR. VAN DEN BERG: 169 in this report.

MR. STEIN: Go ahead, Mr. Lyon.

MR. LYON: The next question I have is based on

the investigations that you are familiar with. Is it your

opinion that there are presently discharges of mercury

going into Lake Erie?
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L. A. Van Den Berg

MR. VAN DEN BERG: Yes.

MR. LYON: And I assume that this is what your

recommendation to issue a cease and desist order is based on.

MR. STEIN: If you want to wait — I was waiting

until you were finished -- but let me give you a preview, and

you can continue. If we agree that the cease and desist

should be made, I have a list of names I want to call up here:

Wyandotte.

Detrex.

Allied Chemical, Buffalo Dye Division.

Diamond Shamrock.

Those Cleveland plants*

National Aeronautics and Space Administration.

We can go over them one by one later.

If there is a cease and desist — in fact have these

places stop discharging? Are they putting in mercury now? I

think this is a key question. But maybe we should save that

until we get all the technical questions out of the way.

MR. LYON: Well, I don't know. Do you want to

wait?

MR. STEIN: No. Do you want to? If you accept

an amendment, let's expand these. Let's go down and look

at your list.

How about Wyandotte Chemical? Are they putting
-------
682

L. A. Van Den Berg

any mercury into Lake Erie now?

MR. VAN DEN BERG: No. The latest data I have is

March 22. I understand there is new data since then. It

still indicates no mercury discharge.

MR. STEIN: No mercury from Wyandotte now.

Detrex Chemical?

MR. PURDY: Mr. Stein, I would like to indicate

that the cease and desist order has already been issued

through the Circuit Court, Ingham County, State of Michigan.

So that has already been accomplished.

MR. STEIN: Well, the point is I think we have

some cases where cease and desist orders have come out and

the indication is that there is still a discharge.

Detrex Chemical. They also have a cease and

desist order issued against them. Any discharge from them?

MR. VAN DEN BERG: Yes. On May 12, they still

were discharging 1.2 pounds per day.

MR. STEIN: Allied Chemical. Any discharge from

the Buffalo Dye Division?

MR. VAN DEN BERG: From our data, yes. And from

New York's report, I suspect they are still discharging

some mercury.

MR. STEIN: All right, Diamond Shamrock, Paines-

ville, Ohio.
-------
683

L. A. Van Den Berg
•
MR. VAN DEN BERG: Their hydro discharge indicated

0.01 mg/1.

MR. STEIN: And you would consider that a signifi-

cant discharge?

MR. VAN DEN BERG: Yes, sir.

MR. STEIN: How about those Cleveland chemical

plants where you found material in the river? Do you feel

they have enough of a program to prevent mercury coining

through their plants and there is no problem with them any

more? That is Euclid, Cleveland Westerly and Southerly,

particularly the Easterly plant, where you found 4 mg in the

sediments. Do you think they have a safeguard there in an

industrial waste safeguard so no more mercury is going to

come out?

MR. VAN DEN BERG: No, I do not.

MR. STEIN: What?

MR. VAN DEN BERG: No, I do not.

MR. STEIN: All right.

MR. HARLOW: Mr. Chairman, I can shed some light

on that. A large part of the mercury that reaches the

Easterly plant comes from GE Lab Division.

MR. STEIN: Has GE stopped putting that mercury

into the sewer?

MR. HARLOW: GE has reported to us they have
-------
684

L. A. Van Den Berg

stopped the mercury from the sources.

MR. STEIN: On a voluntary basis?

MR. HARLOW: We had some meetings with them.

MR. STEIN: But there is no order against GE?

MR. HARLOW: No.

MR. STEIN: And there is no requirement against

GE to stop them putting mercury in as far as you know?

MR, HARLOW: As far as I know.

MR. STEIN: Well, I don't know that we can rely

on your pleasing personality all the time,

(Laughter.)

We may have to get something else.

MR. MAYO: Mr. Chairman, I might just make a

comment at this point. We have a letter report from GE to

Mr. Harlow dated May 27 that outlines the corrective actions

that GE is in the process of making. We can submit this for

the record.

MR. STEIN: All right.

(The above-referred to letter follows in its

entirety.)
-------
ENERAL
COMPANY
PTHIf
v I n B w
4ELA PARK, CLEVELAND, OHIO 44112 . . Aroo Cod. 216
266-3376
685

LAMP

DIVISION

May 27, 1970
Mr. George Harlow, Director
Federal Water Quality Administration
Lake Erie Water Basin
21929 Lorain Road
Fairview Park, Ohio kkl26

Dear Mr. Harlov:

In cooperation with your Messrs. Winklhofer and Kramer we have,
reviewed those operations in the Lamp Division of the General Electric Co.,
wherein elemental mercury is being used. Of the six locations visited,
water samples were obtained from the Large Lamp Department Pilot Plant -
Fluorescent, at Nela Park, East Cleveland, Ohio; the Bucyrus Lamp Plant,
Bucyrus, Ohio; and the Chemical Products Plant, Cleveland, Ohio. Of
these, samples of water were obtained at the processes themselves, but
not from the plant effluent. This was done only at the Chemical Products
Plant, where samples were also obtained at an outfall where the effluent
was representative of that discharged into the combined sewers of the
City of Cleveland.

As I have explained to your representatives, our mercury handling
processes have been designed to prevent loss of mercury for both economic
and pollution abatement purposes. I believe that this philosophy was
amply demonstrated to them during their visit to our plants.

To place the data obtained in the proper prespective, and to describe
the remedial action we have undertaken, I respectfully submit the following:

I. Large Lamp Engineering Piloting Operation:

a) The process here involves the dropping of tipped-off exhaust
tubes from fluorescent lamps into a tray of water. The purpose
of the water overlay is to prevent dissemination of mercury
vapor from these tubes into the air of the working environment.
Only one such tray is normally involved, and the water is
continuously recirculated. Periodically, the exhaust tubes are
removed, and the tray of water is discharged to the sanitary
system. The frequency of water change is variable depending
upon the build-up of phosphor powder, slime, etc. Maintenance
men are instructed to slowly decant this water into the plant
drain.
-------
686
Mr. George Harlow -2- May 27, 1970

b) Concentrations of mercury in the sample from this tray obtained
by your field representatives was 1.06 p.p.m. Our analysis was
1.02, which shows good correlation. Total water discharge from
Nela Park into the city sewer is 1.3 million gallons per day.
Thus, even if this tray containing about 3 gallons of water were
to be discharged into the Wela Park drains over a period of 1/2 hour
a day, the average concentration for this period, as the waste-
waters enter the city sewer, would be about 0.1 ppb.

c) Although we believe our mercury discharge into the water
system to be negligible, we have nevertheless already taken
steps to completely eliminate even this small quantity by
setting up a filtration and recycling system which permits
continuous re-use of this tray water, without the need for
bleeding into the water drains. This system is already in
effect.

II. Bucyrus Lamp Plant:

a) The use of water for mercury cover here is for the same purpose
as in the Pilot Plant. Wine trays are involved, each filled with
about 3 gallons of standing water. The tipped-off exhaust tubes
are caught in a wire-mesh basket, and over a period of 24 hours
each of these baskets are removed from the water-tray, shaken,
and placed over an open drum to permit drain-off. Once a day,
this drain-off water is carefully decanted into a 2' x 4' stainless
steel sink which has a stand-pipe with its opening about 3" from.
the bottom sink surface. Any mercury which may accidentally
drop into the sink is collected from a special drain opening
located at one end. Over-flow water leaves the stand-pipe and
enters a large trapped pipe into the plant drain system.

b) A cample of water removed from a typlcnl cxhauat tube water tray
showed 0.85 p.p.m. by your analysis. Total water discharged from
this plant to city sewer is 300,000 gpd. Only the drain-off from
these 9 trays eventually reaches the sewer lines, and the decanting
procedure takes about one hour. If all the trays were discharged
into the sink, over a period of one ho\ir/2k hours, the Hg
concentration would be O.l8 ppb as the waste water leaves the
plant.

c) On May 15, 1970, when Mr. Winklhofer visited this plant,
modifications to the stainless steel sink had already been
made wherein the stand-pipe was diverted from the drain-pipe
to a 30-gallon drum. This will permit continuous re-use
of the water to fill the exhaust-tube trays. This system
too is now in effect.
-------
687
Mr. George Harlow -3- May 27, 1970

III. Chemical Products Plant:

a')j The mercury discharged from this plant is from a mercury cleaning
process in which the dirty mercury returned from our other plants
is steeped with nitric acid. The supernatant acid is removed to
a ceramic crock, as are the first several water rinses. This
supernatant is treated with liquid caustic, during which time mercury
is precipitated and removed. The treated supernatant and subsequent
mercury rinses are discharged through a removable catch basin in a
trapped floor drain to confluent with other waste water effluents
from the plant.

b) Your data indicates the presence of about 153 p.p.m. of mercury
in the treated supernatant, and 13.9 p.p.m. in the rinse waters
prior to discharge into the plant stream. At the last outfall
prior to entry into the City sewer system concentrations, as
reported by your invcotigatoro, were between O.OP1 and 0.037 mg./li.
These discharges occur only over a 1/2-hour period at a frequency
of 2-3 times a week.

c) The system of mercury cleaning at this plant is presently being
changed.
1. A more dilute nitric acid will be used in the steeping operations
to reduce dissolved mercury salt.
2. All final rinse waters will be treated together with the
supernatant.
3. Neutralization and precipitation of mercury by liquid caustic
followed by occondary precipitation with hydrogen sulfide, and
k. filtration of the liquid instead of decantation.

Thcnc additional aiopn arc expected to oLH'oet a vory marked reduction
in Hg content of the discharge from thio process, and may completely
eliminate it. Laboratory tests appear to bear this out. These
modifications will go "on-stream" starting the week of June 1, 1970.

The samples taken at our two Lamp Plants indicates that our waste-water
discharge into the municipal sewerage system would never exceed the suggested
maximum of 2 ppb of mercury. The steps already taken at their two plants
will assure that no mercury will be diachur^cM], It Id aluo our bivMd' that
the remedial action being taken at our Chemical Producta Plant will profoundly
reduce the dinnamination of the already minute quant; 11; Inn ol' mercury periodically
dlachurgoU into t'hu wuuta wutur oiTluanta, and may uomji'lol.f.'ly olijuiuatu It.
Sinc_grely yours,
I. Matelsky, Ch/airman
Division Council on Water and Air
IM;ah Pollution Abatement
-------
688

L. A. Van Den Berg

MR. STEIN: The question here is whether the city

of Cleveland that GE is hooked up to in their sewer system

should have a requirement against GE so they don't put some-

thing in that is a violation.

Now, how are we doing with the National Aeronau-

tics and Space Administration? Are they still putting some

stuff out, Mr. Van Den Berg?

Lewis Research Center. I guess that is a Federal

installation. How about that, Mr. Harlow?

MR. HARLOW: Mr. Chairman, there is a representa-

tive in the audience — there was a few minutes ago — from

NASA, Ed Stevenson. But I don't see him now. I guess he

walked out at the wrong time.

MR. STEIN: It depends on your point of view.

You know how slick that mercury is.

MR. HARLOW: It is the NASA quitting time, I think.

MR. STEIN: Do you think they should stop putting

this in?

MR. VAN DEN BERG: Yes, I do.

MR. STEIN: Mr. Garnet, do you have a program to do

that at the Federal installations? I don't think I heard

that in your report.

MR. GAMET: I believe they have a program. As a

matter of fact, I have a letter addressed to me based on some
-------
689

L. A. Van Den Berg
«

^inquiries that Mr. Harlow made of the Lewis Research Center

on April 13^ asking questions about any possible mercury dis-

charges and techniques used in waste disposal and the effluents

from the waste retention basin.

In addition to that, I have a copy also of sample

analysis from #1 and #2 basins on April 14, 1970, indicating

zero ppm of mercury. If you choose, I can introduce this.

MR. STEIN: On May 7, Mr. Van Den Berg reports he

found a measurable quantity of mercury coming out.

Now, again, he has a recommendation here that all

discharges, including Federal installations,be ordered to

cease and desist. And we heard Ohio has a cease and desist

order against Detrex. Michigan has taken a cease and desist

order against Wyandotte.

And you have gone to court in Michigan.

It doesn't seem to me on the sum of what you have

read that we really are talking in terms of cease and desist.

MR. GAMET: I am not saying they are lily white,

believe me. This is the information I have.

I think George probably has additional informa-

tion beyond what I have. I am not - sure.

MR. HARLOW: They earlier stated that subsequent

to that May 7, they sampled at two other times, and it was

zero.
-------
690

L. A. Van Den Berg
»

MR. LYON: Mr. Chairman, I think that recommenda-

tion regarding cease and desist orders as a whole probably

ought to be expanded to the extent of not merely looking at

the discharges, but asking the question what the company or

installation is in fact doing with their mercury.

Now, if they have stopped the process, that is one

thing. If they haven't, then we ought to find out where the

mercury is going.

MR. STEIN: By the way, we did ask this question

of Mr. Van Den Berg in the inventory program. That is, if

we find anyone using a significant amount of mercury, we

want to know what they are doing with it, how they are con-

trolling it; and if they are not controlling it, what their

program is to control it, with the date. If that isn't satis-

factory, get them to come up with a remedial program.

Now, I think this is the kind of thing we are going

to need with the National Aeronautics and Space Administration.

I think Mr. Harlow got that from General Electric and Cleveland

— the program for containment. But I don't think we have it

for the National Aeronautics and Space Administration — the

program of what exactly they are doing with their mercurv and

how they are containing it.

MR. HARLOW: Well, I don't know exactly what all

the sources of mercury at Lewis Research center are, except
-------
691

L. A. Van Den Berg
•

that the recent samples confirmed what they said, "no mercury

discharge."

MR. STEIN: I understand.

Let's get back to Mr. Lyon's suggestion. And that

is exactly, Walter, what we have proposed. The point is if

we have an in-and-out situation in April of zero, and you

come in early May and get a measurable amount, and in late

May zero again, it seems to me this is exactly the kind of

situation where we ask them what their sources are, what they

are doing with it, and what they are doing to contain it.

Now, can we get that from these people?

MR. LYON: I think to clarify this point, what we

need is a complete mercury balance indicating what is coming

in, what is happening to it, and how is it leaving the plant

so that we can get a complete balance on the mercury every-

place where mercury is being used,

MR. STEIN: This is what we are seeking to get from

every significant source in that survey that Mr. Van Den Berg

is working on now. I would suggest that particularly the way

to get at this National Aeronautics and Space problem is to

obtain such a mercury balance, because it looks as if we have

an intermittent discharge problem.

Is it possible, Mr. Garnet, that you could get that?

MR. GAMET: Yes, I am sure we can get it.
-------
692

L. A. Van Den Berg

Would you care to have me read the letter?

MR. STEIN: No, just put it in the record.

(The above-referred to letter follows in its

entirety.)
-------
693

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
LEWIS RESEARCH CENTER
21OOO BROOKPARK ROAD
Cl I VI LAND. OHIO 44135
TcttPHQNi 433 AOOO TWX. CV-S2O

IN REPLY REFER TO 1 006

APR 2 4 1970 •

Regional Director, Great Lakes Region
Department of Interior, FWPCA
33 East Congress Parkway
Chicago, 111inois 60605

Attention: Mr. Merrill B. Garnet
Federal Activities Coordinator

Dear Sir:

Subject: Mercury Control Program at NASA-Lewis Research Center

On April 13, 1970, Mr. George L. Harlow, Director, Lake Erie Basin Office,
•FWPCA, contacted Mr. E. F. Stevenson of the Safety Office in regards to
mercury usage at Lewis Research Center. The following information was
requested.

.1. Does Lewis use mercury in its Cleveland - Plum Brook facilities?

Mr. Harlow was advised that mercury is used principally in the
liquid metal form in research instruments and in ion engine
thrusters for space engine research.

2. What quantities are used annually and what procurement replacements
occurred this past year?

A semi-annual inventory and report is prepared by the Equipment
and Supply Division for the combined facilities at Cleveland and
Plum Brook. Copies of the reports for 1969 dated September 9, 19&9
and the January 5, 1970, Recapitulation of Mercury Inventory are
attached. The declared losses are the result of plating out of
mercury vapors on chamber cold walls and baffles. Unexplained
losses include mercury accumulation in vacuum pump oil reservoirs,
vaporized mercury vented to atmosphere through exhaust pump dis-
charge, and portions of accidental spill material which is not
recovered. No new mercury was procured in 19&9.
-------
694
3. What technique is used in waste disposal?

Due to the critical value of this material, it has been the
policy at Lewis Research Center to reclaim all contaminated or
used mercury. No mercury is discharged into any sewer system.
Accidental spills are vacuumed with special vacuum cleaners
that trap condensed vapors and droplets for reclaim. Wet mop
water after vacuum operations is discharged into the sanitary
sewer.

k. Is the effluent from the industrial waste retention basin sampled
for mercury before discharging into Rocky River?

Mercury is not deposited in the storm or industrial waste
system. Since the Cleveland Metropolitan Park Board Resolu-
tion does not require sampling for mercury, sampling has not
been done in the past. However, in the interest of a cooper-
ative investigation, these basins were sampled April 13, 1970
and April \k, 1970, according to the procedure suggested by
the Lake Erie Basin Office. Using the Dimethyzol Stripping
Method, the analyses indicated zero ppm of mercury concentra-
tion for both tests. A copy of the Analysis Report is attached.

If we can be of further assistance in any way to the FWPCA Regional or
Basin Offices with additional data or technical advice, please do not
hesitate to let us know.

Sincerely yours,
Bruce T. Lund in
Director
Enclosures 5

cc:
G. L. Harlow, Director
Lake £rie Basin Office, FWPCA
-------
695
ANALYTICAL CHHGSTRI

ANALYSIS REQUEST AND REPORT
This "space to be completed by
analytical section:

Sample No(s),: <£
Date completed:
Date reported* •
This space to be completed by
person desiring analysis*
Name:
PAX: -7> 7/
Date subndtted
Date report
J. 0«
Description of material to be analyzed and analysis desired:
Analysis report:
* V
7*0 Of
C.832 C8/3M)
-------
696

L. A. Van Den Berg

MR. SEEBALD: Mr. Stein, I think we should con-

sider where this mercury may be going in the wastes. If we

remove it from the Lake Erie environment and we are going to

put it in a deep well or put it in a sludge bed that might

reach out into groundwaters or other surface waters is of

material significance. And I think the practicality of a

cease and desist order to the environment may be considered

completely unfeasible in sort of shutting down the complete

industry.

MR. LYON: Mr. Chairman, I think there shouldn't

be any question about shutting down a process if there is

anything going to Lake Erie.

MR. SEEBALD: I don't think we should talk about

Lake Erie in this case. We should talk about the environ-

ment.

MR. STEIN: I think you talked about surface and

other ground waters. And as a matter of fact, in large

measure, as I understand it, that is what Michigan did with

the portion of Wyandotte Chemical that was using this pro-

cess. They just shut down. And that is what Detrex did in

large measure. It was either switch the process or shut

down.

And I do agree with your point that in the same

way as we deal with this, we don't consider a satisfactory
-------
697

L. A. Van Den Berg

'solution to v/ater pollution to be contamination of the air,

contamination of the ground or something else. But the

recommendation here is that all discharges of mercury into

the area over which we have jurisdiction -- that is, the

waters — be stopped forthwith.

I think several of the States have indicated that

they have taken this action.

MR. SEEBALD: We have taken this action, but it

is just fortunate in our case it is Allied Chemical Dye

Works which is a batch process. They have shut down their

dye process manufacture, And it is only by shutting down

can they achieve it.

I am more concerned in generalities with these

continuing chlor-alkali plants who have also provided us in

New York State with schedules for reduction, but not elimina-

tion. And I think this may be a matter for further considera-

tion, not for New York State at the present time, but for

the other States where they would have continuing process

runs.

MR. STEIN: You mean we are going to let a little

bit of mercury come out of these plants?

MR. SEEBALD: I don't intend to let a little bit

of mercury come out.

MR. STEIN: What does the reduction process mean?
-------
698

L. A. Van Den Berg

Are we going to do it over a period of time?

MR. SEEBALD: We asked for a process of elimina-

tion.

MR. STEIN: Over a period of time?

MR. SEEBALD: Yes.

MR. STEIN: Like you run down phenols and stuff

like that?

MR. SEEBALD: I think we are faced with this.

MR. STEIN: All right, that is a proposal.

MR. LYON: Mr. Chairman, I want to make Pennsyl-

vania's position very clear on this thing. And it is our

very strong feeling that if any plant that has been reported

or has been discharging to Lake Erie doesn't stop within

the next week, I think we as conferees should recommend

that a Federal injunction be issued against those plants.

MR. SEEBALD: How many plants do you have, Walter?

MR. LYON: How many plants do we have that are

discharging mercury? None. But we are being affected by

the mercury.

MR. STEIN: I have got this list here, Walt. I

will be glad to refer these cases to the Department of

Justice if you don't think they are stopped within a week.

As far as I can see, of the ones that I read on

the list here, perhaps Euclid at least, Cleveland and GE
-------
699

L. A. Van Den Berg

•have stopped perhaps. And I don't know that the National

Aeronautics and Space Agency has stopped. We have got a

big question mark there. Wyandotte, we know has stopped.

This leaves us with indicated reports of mercury coming out

from Detrex Chemical, Allied Chemical, Buffalo Division,

Buffalo, Diamond Shamrock and possibly National Aeronautics

and Space.

And if your proposal is unless they are all

stopped within a week the conferees recommend that we take

appropriate Federal legal action, I would be happy to take

that judgment back.

MR. LYON: That's our proposal, Mr. Chairman.

I don't know whether the subject of the toxicity
t
of mercury and its effect on man has been given enough dis-

cussion here, but I would like to just for the record read

what was in the Federal report concerning methyl and ethyl

mercury poisoning. I am aware of the fact that not all of

these mercury contaminations take that form, but I suspect

that some of it does. And it also depends naturally on

the concentrations, but we have found some high concentra-

tions.

The symptomatology of acute and chronic poisoning

from both compounds is similar, including numbness and

tingling of the lips and hands and feet, ataxia, disturbances
-------
700

L. A. Van Den Berg

of speech, concentric obstruction of the visual fields,

impairment of hearing, emotional disturbances, with severe

intoxication. The symptoms are irreversible.

And I think this is the important point that

this material accumulates in the tissues of man and animals.

This is the first epidemic. And then it goes

into the Japanese epidemic.

But the point is we are dealing with a very, \ery

toxic substance. And I think it is essential that if these

dischargers are not stopped, if the State courts are not

enforcing these discharges, then the Federal Government

should take appropriate action.

MR. STEIN: I don't want to modify your motion

specifically, but why don't you make it appropriate legal

action?

MR. LYON: Appropriate legal action to stop the

discharge.

MR. STEIN: Well, I don't know. What do you think

of that proposal?

MR. PURDY: As I have understood in the past, Mr.

Stein, this hasn't been the sort of thing where you have a

motion and a seconder and a vote and so forth.

MR. STEIN: That's right. We are just looking

for an expression of views if anyone wants to give any.
-------
701

L. A. Van Den Berg

MR. PURDY: Certainly we believe it is only fair

to our industries, to our Governor in his State address to

the President, that Michigan has taken aggressive action

now to cause the mercury discharges from its plants to be

stopped. And to be fair to our industry, he feels that the

same sort of action should be taken throughout the country,

not only in the Lake Erie Basin, but throughout all 50

States.

Certainly, past statements by the Governor and by

our Commission would support aggressive action to stop

immediately those discharges of mercury to the water that

cause harmful conditions.

MR. STEIN: How about you, Mr. Poole?

MR. POOLE: Well, I think I would share that view.

I have been keeping pretty quiet because we are in the same

position at the moment, at least, as far as Lake Erie is

concerned as Pennsylvania is. It is pretty easy if you

don't know of any to say everybody else ought to stop

immediately. But I think all known sources in view of the

things that have come out here today and earlier ought to

be stopped immediately.

MR. STEIN: O.K. Now, we have got over the two

easy ones. Would you care to make a statement for the

Federal installations? Could we adopt the same policy to
-------
702

L. A. Van Den Berg

try to get rapid action for Federal cleanup?

MR. MAYO: Certainly, the substance of the recent

Executive Orders is such that there should be no question

that we can approach NASA installation at the Lewis Research

Center and advise them of the findings, advise them of the

sense of feeling of the conferees, and the need for the

installation —

MR. STEIN: Would you have any objection to this:

Within a week, in line with this proposal, you have a report

from that NASA facility so that we either have assurances

that everyone is satisfied that they have accounted for

the balance of the mercury and there will be no further

discharges or we will take appropriate action through the

Executive establishment, I will recommend that they be

directed to stop if you haven't reported that they have a

satisfactory program.

MR. MAYO: We will contact the installation

immediately.

MR. STEIN: All right, if you want to do that.

Now, we come to the two hard States because the

Federal Government may add this, but it isn't our agency,

either, we are dealing with. Michigan has got to clean up.

There are no known sources or significant sources in

Indiana and Pennsylvania. Ohio isn't here to speak.
-------
703
L. A. Van Den Berg
•
MR. VAN DEN BERG: They said I could speak for
them.

(Laughter.)

MR. STEIN: You know, there were once a couple of

political figures like that. One guy made some remark, and
the other guy said, "You know, everyone is privileged to be

stupid, but this guy abuses the privilege." Let's not

abuse that proxy.

I don't want to put you on the spot in New York,

but do you care to comment or not?
MR. SEEBALD: Yes. As far as I am concerned, as

it affects Lake Erie, there is no problem in cease and

desist order against Allied Chemical Dye Works because they
have stopped. And they have entered a commitment they would
not commence using mercury in their dye processing until

they had a review of their application presently before us
that was scheduled to minimize. And we have not rendered an

opinion on this.

It is our intention to have them indicate why they
cannot and have this go through an appropriate evidence for

presentation. And it is the inclination of the State right

now to cause them to cease.

MR. STEIN: But may I say I think, Mr. Seebald,

again on this one, I wish if there is any doubt about the
-------
704

L. A. Van Den Berg

facts here that you give this one priority. Either they

have ceased discharging mercury or they haven't ceased

discharging mercury. This is a fact. On May 8, presumably

Mr. Van Den Berg has some information which caused him to

say that they were still discharging mercury. If/ in fact,

they have stopped and this isn't occurring, I wonder if you

and Mr. Van Den Berg could get together, have your represen-

tatives make a visit there, and come up with the facts.

If they have stopped using mercury, they shouldn't

have any coming out unless there is a residue that is wash-

ing out that you know of.

MR. SEEBALD: That's the one reservation I have.

I think that may be the case. I don't know.

MR. STEIN: If that is the case, let's find out

what the facts are so we know where to move. But I think

if this is the case, unless you can resolve the factual

issue, this seems to be crying for inspection pretty soon.

So the Federal and State people should get together and know

where we stand on this so we won't be bugging you for a

cease and desist order when in fact they may have stopped.

MR. SEEBALD: It is my impression that they have.

I would like to ask Mr. Mayo, haven't you a man

on assignment to the Buffalo Regional Office at the present

time? Or has he been reassigned? Is Mr. Wilcox not there
-------
705

L. A. Van Den Berg
*

any longer?

MR. MAYO: We don't have anyone at Buffalo any

longer.

MR. SEEBALD: Wilcox was there on the occasion

you made this one inspection, I know.

MR. HARLOW: Wayne Wilcox came up at the same time

to check on the compliance and status of all your city

industries. While he was there, he accompanied Violanti to

the Allied Chemical plant.

MR. SEEBALD: Is that the sampling on which you

predicate this?

MR. HARLOW: Yes.

MR. SEEBALD: I understood he was there at the

present time. I didn't know how long he was going to be

there.

MR. HARLOW: He came right back to Cleveland.

MR. SEEBALD: We would be glad to sample.

MR. STEIN: Let me ask another question. And I

ask this here really just for getting information. I see

no recommendation here made to get up the mercury that is

in the sediment. Maybe we should or shouldn't. Maybe the

thrust of the questions asked by Mr. Purdy meant it is

just going to stay there.

But if you are talking about the fairly large
-------
706

L. A. Van Den Berg

quantities of mercury which have been discharged and if you

have a fairly discrete area which you pretty accurately

defined for Wyandotte Chemical, do you think that is all

right to leave that there? Or should we do anything about

that or direct our attention to that?

Again, I have absolutely no preconceived notion

of this. But I think we have,at least to my mind,something

which raises the question in your report and we may get

questioned about. I hate to leave a loose end.

MR. VAN DEN BERG: This area, Mr. Stein, is some-

thing that takes a considerable amount of thought. If there

is high mercury in the sediments, we may very well cause

more problems by trying to dredge it out than by leaving it

where it is set if it is covered in the sediments and will

not be disturbed.

The first point I think we have to look at is

when the mercury discharges are discontinued, then follow

whether or not there is a corresponding decrease in the

levels in fish and aquatic life. If this happens after dis-

charges are stopped, I would see very little reason to dredge

sediments to remove mercury.

MR. STEIN: Let me try to rephrase what I think

I understood you to say. You say your present thinking is

to leave the sediments there and check the concentrations
-------
707

L. A. Van Den Berg

"of mercury in the fish in Lake Erie. If these mercury con-

centrations go down, leave well enough alone. If the

mercury concentrations remain at high level and you find a

causal relationship that may be related to the sediments,

then we will think about disturbing those sediments. Is

that a fair statement?

MR. VAN DEN BERG: Yes.

MR. LYON: Mr. Chairman, isn't there one other

point in this connection that should be considered? And

that is we ought to, as Mr. Van Den Berg has suggested,

monitor these to see what is happening. But if some of

these deposits are in areas where dredging is contemplated,

this is where I would feel quite fearful as to what might

happen. And, therefore, we really ought to take your sug-

gestion one point further and maybe make sure that there

wouldn't be any dredging in that area or make some special

plans if there is a plan for dredging in that area. Because

if those mucks get dredged up and put someplace else, I

think we are going to have a problem.

MR. VAN DEN BERG: I would refer your comment to

Mr. Mayo on that since I think he is involved in a discus-

sion right now concerning dredging.

MR. MAYO: Among some of the most recent informa-

tion that Mr. Van Den Berg included in the revised material
-------
708

L. A. Van Den Berg

I believe is some data for Lake St. Clair and the occurrence

of mercury in rich sediments in the upper part of the Trenton

channel in Lake St. Clair. And vre were advised the latter

part of last week that the Corps anticipates a dredging

project this year in that portion of the Trenton channel

and that the normal procedure has been to dispose of those

dredgings over to the side of the channel in the waters of

Lake St. Clair.

This is the problem that the conferees need to

address themselves to. And I think it is correctly related

to the observation that Mr. Lyon just made.

MR. PURDY: The problem is we have got the geo-

graphy twisted to some extent, I think. The Trenton channel

is not up in Lake St. Clair.

MR. MAYO: The ship channel in Lake St. Clair.

MR. PURDY: We are not talking about the Trenton

channel. We are talking about the shipping channel in Lake

St. Clair.

MR. MAYO: The upper end of Lake St. Clair.

MR. STEIN: Is the Corps going to go ahead unless

we do something?

MR. MAYO: The Corps has asked for comments, and

we are obliged now to respond. And we have not responded,

choosing to have the issue raised here with the conferees.
-------
709

L. A. Van Den Berg

MR. STEIN: All right. Do you think we can pre-

pare our comment now?

I don't know how soon the Corps needs a comment.

Do you think you and Michigan, talking about the Federal

Government and Michigan, should get together and prepare a

statement on that? Can you do that within a week for con-

sideration of the conferees? Because I hate to let the

Corps get revved up. You know, you are not going to stop

them unless you have enough leadtime if you feel that is

what you want to do.

MR, MAYO: The Corps has indicated to us there

can be a modest postponement of the dredging operation in

order to give us an opportunity to respond.

I am sure we can get together with Mr. Purdy within

the next week.

MR. STEIN: All right. Maybe some of my friends

from the Corps are here. I don't want you to be restricted

that way. As far as I am concerned, if you don't think those

muds should be disturbed, I am not worried about any modest

postponement, we will just stop it.

MR. MAYO: Well, that wasn't the context in which

I offered the comment.

MR. STEIN: Well, I know. But I think you should

get the full gamut of this.
-------
710

L. A. Van Den Berg

One, whether these muds should be disturbed at

all.

Two, if they are disturbed, what precautions

should be taken as to where the soil is placed.

Is that a fair thing? But I would like to have

the Federal conferee and the State of Michigan take a look.

I think if we are going to make any meaningful push on that,

we should have a joint report, if possible, with a recommen-

dation on this dredging, signed by Michigan and our Regional

Office, in about a week, so we can get some signal on how we

are going to move.

After I clear the decks in Washington, I would hope

we would be able to arrange this to allow the Region to take

the initiative with the District Office and the Corps here,

and handle it on this level rather than letting it get back

to Washington if we can.

O.K., is that agreeable?

MR. PURDY: I am not prepared to comment on this

now, since it was first brought to my attention yesterday.

We are in agreement to meet with Mr. Mayo and discuss a

joint position,

MR. STEIN: Are there any other comments or

questions on that mercury problem or any other point?

MR. POOLE: I have two questions.
-------
711

L. A. Van Den Berg

I got the impression from listening to Mr. Van Den

Berg if you get different results with different analytical

methods/ I would like to suggest to him that FWQA decide

which is the best analytical method and immediately supply

that to at least all of the States that are represented here.

MR. VAN DEN BERG: I am afraid if we do that,

Blucher, somebody would not be able to afford it.

MR. POOLE: Afraid what?

MR. VAN DEN BERG: Some people may not be able to

afford it.

MR. POOLE: Can we send the samples to you, then?

MR. VAN DEN BERG: A lot of people have been doing

that if you have problems.

MR. POOLE: Isn't this really a problem yet?

MR. VAN DEN BERG: Yes. There are some limita-

tions in the analytical procedures, but at the present time

we are using the best method and equipment that the individual

laboratories have available. Unfortunately, we are not all

equally equipped.

MR. POOLE: You are dealing in very small quantities

here. And I think this can be a pretty important item.

Well, you do the best for us, then, supply us with

various methods.

MR. STEIN: Let's try to get at this if we can
-------
712

L, A. Van Den Berg

because, again, I think the best method means the best

practical method you can expect the State to use. Are you

saying if you get down to 1 ppm?

MR. VAN DEN BERG: We get down to 1 ppb.

MR. STEIN: By what kind of method? Can everyone

use a reasonably accurate method that isn't too costly down

to 1 ppm?

MR. VAN DEN BERG: No.

MR. STEIN: They can't?

MR. VAN DEN BERG: The dithizone method which is

the one I am aware of — Larry maybe can expand on this —

but at least the ones I am aware of, without going to atomic

adsorption unit, you cannot get down to 1 ppb. And this has

to be with a flameless vapor technique on the atomic adsorp-

tion.

MR. STEIN: Is that one part per million or billion?

MR. VAN DEN BERG: One part per billion in water.

MR. POOLE: This has a bearing on my second comment

or question, Mr. Chairman. And that is you report 3 and 4

ppb in two of the Cleveland plants. And we have had an

explanation here for the Easterly plant that apparently some-

body, at least, has found some in three or four of the

Michigan sewage treatment plants.

If you turn to page 10 and look at that list of
-------
713

L. A. Van Den Berg
•

mercury users and you get down past item 4, I am assuming

that a great many of these users that are tabulated in the

lower half of the table are hooked onto municipal sewer

systems.

I for one—and I will freely admit to being the

most ignorant one up here at this table as far as mercury

contamination is concerned—wonder if we aren't obligated

to start looking at least at some of our major sewage treat-

ment plants.

And the second wonderment I have is: Are we going

to try to shut off every drop of mercury from getting into

a stream or a lake? Or can we end up with a tolerable limit?

I don't expect you to answer all that today, but

I would like to have your opinion.

MR. VAN DEN BERG: Every drop of mercury being

removed from a waste treatment plant, for instance, is almost

an impossibility unless we outlaw the use of mercury in

Pharmaceuticals. And they are uncontrollable.

But my idea in the recommendation was that the

industries themselves, the users of mercury themselves,

should be responsible to take the mercury out before it

reaches a municipal system.

MR. POOLE: That is a beautiful theory, but I

have had some experience with laboratories since we operate
-------
714

L. A. Van Den Berg

a fairly sizable laboratory and we are on the IU Medical

School campus. And they operate a lot of laboratories.

And there are just a hell of a lot of things that happen

in some of these research laboratories that ought not happen,

but they do. This troubles me.

MR. VAN DEN BERG: Accidental spills in laboratories

is something that is extremely difficult to do anything about.

MR. STEIN: I don't know. It may be difficult to

do anything about, but it is not impossible because we have

had places with accident spills where we have been plagued

by that in industrial plants. And they have taken action

to do this. They have got warning systems, they have traps,

baffles around the drains in the floor that will stop this.

The point is this gets to be a big problem. And

industry has solved this problem again and again.

And I appreciate what Mr. Poole is saying. This

has been true for years. You talk about these wonderful

tolerances in the research laboratories, and I wonder. I

just raise this. I wonder if their housekeeping methods

in handling their wastes are as good as we expect from most

of the industry.

MR. VAN DEN BERG: Probably not as good as the

research. There were plants that were reported in this one.

There is an instrument plant, for instance, that installs a
-------
715

L. A. Van Den Berg

-floor drain in any room where mercury is used.

MR. POOLE: I am kind of leading up to this

because this has been Indiana's policy for 10 years now on

cyanide. And apparently mercury is just as bad or worse

than cyanide except the quantities are a little different.

And I am wondering if before you get through this we won't

need to think about setting up the same kind of procedures

with users that you have for spills and decontamination of

radioactive materials. This is what is going through my

head.

MR. VAN DEN BERG: It is possible.

MR. POOLE: I don't know. Maybe .003 of a part

per billion in Cleveland sewage plant or Fort Wayne sewage

plant is of no consequence. I don't know.

MR. STEIN: I think we have got two points that

I am pretty sure we are going to have to answer. One is if

we are looking for the so-called zero tolerance because,

you know, what happens there when you say no measurable

limit. Three months from now, some bright young guy is going

to come up with a method that is going to measure the stuff

that you are finding no measurable limit on now. And if

this is hot enough three months from then, someone is going

to come up with something you can measure in parts per

trillion. And we will be off and running. So if you mean
-------
716

L. A. Van Den Berg

every trace of this that we are ever going to find, we have

one thing.

Now, if you are going below parts per billion or

down to a part per billion, as you are, and we are dealing

with this mercury, we have to come to this conclusion, it

seems to me, if we are going ahead with this program.

Either we are coming up with a standard method that we can

give to the States, municipalities and industries where they

can reasonably get reliable results that we all can base

our program on, or else we are going to have to set up

facilities ourselves. Whether you use atomic absorption,

gas chromatography, or whatever, we are going to have to

set up facilities ourselves and accept these samples and

do the work ourselves, or else contract with some laboratories

that have these fancy machines.

Again, we must choose between one or the other.

Although these are very proper questions, unless we do that,

in delivering any technical report, we are going to have this

same series of questions on these discrepancies in the number.

Exactly what does a little trace of this mean in a sewer pipe

or sewer system?

I think we just have to come to grips with those

problems, work our way through and come up with recommenda-

tions. Otherwise, we are going to have a mercury
-------
717

L. A. Van Den Berg

problem.

And let me make one last remark on this. We, and

I think I particularly, have given thought to this mercury

problem, but they are talking about all toxic materials.

If we can't do this on mercury, which is a relatively easy

one, what are we going to do on the others? That's why I

say I think we should look at this as kind of a pilot

operation in dealing with the whole area of control of toxic

materials, and see if we can come up with a reasonable

program that we can live with, and the States can live with,

and the users of mercury can live with.

MR. LYON: Mr. Chairman, I would like to comment

on this. This touches on one of the items we talked about

yesterday morning regarding the whole question of toxic

substances. You remember, Murray, an old colleague of ours,

Morris Ettinger, used to point out most sewage treatment

plants provide cosmetic treatment. It makes things look

better. But we are finding increasingly that sewage treatment

plants in many cases are discharging toxic effluents because

of industrial wastes and other substances that are discharged

to them. And this is probably equally true in the case of

certain industrial wastes as we have just found out in the

case of mercury.

The history of points of view by scientists,
-------
718

L, A. Van Den Berg

as I said earlier — Rachel Carson*on this — goes back to

?t&
Mark Hollis and later congressional committees and

policy advisory committees at the Federal level. Whether

you read the report of the Tukey Cornmittee*or White Com-

mittee^or Linton Commit tee* or* Daddario Committee** ¥$ey

have all said the same thing. They said that we must set

up a national system of monitoring for these toxic substances,

They have said that we must refine our analytical tools.

And they have said that we must develop much better knowledge

about the chronic health effects of these substances.

I think it is essential that when we are dealing

with a lake as critical as Lake Erie, we as conferees recom-

mend to the Secretary of the Interior that he sponsor or

introduce legislation or request appropriate funds to tool

up the capability of the States and the Federal Government

to deal with this problem. The capability today simply

does not exist, and we do not have the tools to protect the

population of the United States against these toxic sub-

stances .

And I think that it is important that we make this

point and make it very, very forcefully. Because these

technical people know that there is no protection at this

point against these substances.

MR. STEIN: Walter, let me address myself to that.

* through ****** see 7l8a —
-------
7l8a
* Carson, Rachel
"Silent Spring," Houghton Misslin, Boston, 1962
Hollis, Mark
Chief, Sanitary Engineer
Public Health Service, Department of Health, Education, and Welfare
Washington, D. C.
Tukey Committee
Report of the President's Science Committee
"Restoring the Quality of our Environment"
The White House, November 1965
White Committee
A Report of the Committee on Water, "Alternatives in Water Management,"
-Publication 14.08, National Academy of Sciences, National Research
Council, Washington, D. C, 1966
Linton Committee
Report of the Task Force on Environmental Health and Related Problems
to the Secretary of Health, Education, and Welfare,
Superintendent of Documents,
June 1967
Daddario Committee
Report of the Subcommittee on Science, Research and Development,
Serial S, Committee on Science and Astronautics,
U.S. House of Representatives, 88th Congress
-------
719

L. A. Van Den Berg

I think what you say in a way is very valid, but I have

another suggestion because I think the conferees have a

better opportunity. It just happened that the mercury

situation came to the fore in the Lake Erie Basin where we

had a conference working. They have given us the job of

coming up with a report on the mercury control program, and

I think we are on our way.

In addition to that, because everyone is worried

about what you are worried about, they have also given us

the opportunity to come up with a general toxic control

program.

Now, I think instead of just asking for money and a

program which takes time to percolate through, the conferees

here have an opportunity to come up with specific recommenda-

tions on how we are going to get that program operating,

both in mercury and other toxic materials. If it requires

legislation and money, as it very well might, we can come

up with a specific program to the conference, or at least

that we would propose to the Administration to take to the

conference, without just going into a vague hunting expedi-

tion.

I think we have as good a sampling and as good

an experience here as anyone. And I would say I am hoping

out of this mercury operation, and out of the general view
-------
720

L. A. Van Den Berg

of the toxic material operation, that we may come up with

recommendations for a much more specific national program

than just to get the money for this program and to point out

we have a problem in this area. I think we can move the

whole situation a lot faster if we do that. And I have no

notion about that.

One of the things we might consider is your sug-

gestion for a national clearinghouse — how we set this up,

how we monitor and how we feed this stuff in. However, I

would see that as either a task for the conferees or perhaps

a task for a technical committee to be appointed by the

conferees. Because I think, in the past, in other areas

such as setting up specific numbers and standards, the con-

ferees, for example, in Lake Michigan did that. They showed

the way for national standards all through the country, and

they beat them by years when they got out that little book

of what the requirements would be in water quality.

I think this is the chance we have. As we work

our way through, I hope the conferees will avail themselves

of that and try to come up with a specific report. It might

be a little too early yet, but when we reconvene, we may

want to establish a committee to come up with specific

recommendations on how we can move in this area.
-------
721
L. A. Van Den Berg

And I am sure it will be much better if we have
the book and the music when we go into Washington than if we
just have a generalized feeling of a proposal.
MR. LYON: Well, I think we are together on this.
I think that the important point is that this kind of a pro-
gram consists of three elements. One is monitoring.
The other one is doing research on the health
effects.
And the last item is to come up with better ana-
lytical methods.
Two of these certainly go beyond Lake Erie. And
I think it would be quite appropriate for the conferees on
Lake Erie to come up with such a program. I just hope that
we don't delay this too long; that we try to tackle this
job soon.
MR. STEIN: Obviously, you have given a lot of
thought to it. By not delaying it too long, I would like
to talk to you about commitments privately because I have
a good idea about who could be the chairman.
MR. LYON: I will be glad to help.
MR. PURDY: Mr. Stein, Mr. Lyon mentioned delay.
I would like to say from the standpoint of Michigan, there
is not going to be a delay. In fact, this sort of program
is under way. I don't intend to delay it at all because
-------
722

L. A. Van Den Berg

the Governor said this is something we shall do. It is being

done, and it will be continued.

MR. LYON: I think, Ralph, our legislators were

very impressed by Governor Milliken's statement. And they

have asked for a copy of the 20-point program. This is

definitely showing some real leadership in this field. This

is the kind of thing we need to do.

MR. STEIN: Are there any other comments or ques-

tions on any of the aspects of the program?

MR. PURDY: I have a request from Dr. Shannon that

he would like to make a statement with respect to mercury if

Mr. Van Den Berg is through.

MR. VAN DEN BERG: I have a statement from Ohio.

MR. STEIN: Let us have a 10-minute recess.

(Whereupon, a recess was taken.)

MR. STEIN: Let's get going again.

Mr. Van Den Berg, would you go on?

MR. VAN DEN BERG: This is a status report, investi-

gation of mercury contamination in the Ohio portion of Lake

Erie.

Detrex Chemical Company

The effluent being discharged to Lake Erie by

Detrex Chemical Company was sampled by Detrex on 10 days

between March 4 and April 10, 1970. The analyses, made by
-------
723

L. A. Van Den Berg
•

Detrex, were in the range of from 0.34 to less than 0.01

milligrams of mercury per liter. Since that time, Detrex

has taken precautions which are designed to make sure that

the mercury content of the effluent will not increase to

the detectable limit. The Federal Water Quality Adminis-

tration is continuing with a program of sampling and

analysis.

MR. STEIN: May I ask an information question?

What is a detectable limit?

MR. VAN DEN BERG: Ours is 1 ppb.

MR. STEIN: Do they set their own detectable

limits?

MR. VAN DEN BERG: I don't know.

MR. STEIN: I don't mean for that to be a mean

question, but this is always the key point in here. Unless

you come up with a number, we are not quite sure what is

detectable. Not only do you have to come up with the number,

but you have to come up with the method.

MR. VAN DEN BERG: Survey of mercury users.

An investigation is being conducted of mercury

losses by industry in Ohio. For the Lake Erie Basin, this

was a joint effort by the Ohio Department of Health and

FWQA. The companies surveyed were those reported by the

U. s. Bureau of Mines as purchasers of mercury in 1969.
-------
724

L. A. Van Den Berg

The results to date have not disclosed any significant dis-

charge except that discussed above for Detrex Chemical Company.

FWQA is continuing the investigation.

To the best of our knowledge, there is no seed pro-

cessors in Ohio who use a mercury compound for seed treatment.

An agricultural chemical company, who formerly produced mercury

fungicides, discontinued the production about a year ago.

A survey of the paper industries in Ohio who dis-

charge into the Lake Erie Basin indicates that it has been

several years since any of these paper mills have used any

slimicide containing mercury.

Lake Erie Water

Samples of raw water were obtained from each of the

municipal water supply intakes, 22 in all» These were analyzed

by the Ohio Department of Health Laboratory and by Battelle

Memorial Institute. Battelle performed the analyses at no

charge, as a public service. The results showed that all of

the samples contained less than detectable amounts of mercury

and specifically less than 5 parts of mercury per billion parts

of water. The probability is high that the actual mercury

content, if it could be detected, would be between zero and

one-half of one part per billion.

That concludes the Ohio statement.

(The above-discussed report follows in its entirety.)
-------
724A
INVESTIGATION OP MERCURY
IN THE
ST. CLAIR RIVER - LAKE ERIE SYSTEMS
Federal Water Quality Administration
Great Lakes Regional Office
Lake Huron Basin Office
Lake Erie Basin Office
National Field Investigations Center
May 1970
-------
ERRATA SHEET (JULY 10, 3.970)

TABLE 1

MERCURY ANALYSES OF DETKEX EFFLUENT AND RECEIVING WATERS
Date
3-4-70
3-13-70
3-18-70
3-25-70
4-3-70 .
4-6-70
4-7-70
4-8-70
4-9-70
4-10-70
4-17-70
4-18-70
4-19-70
4-20-70
4-21-70
4-22-70
4-23-70
4-24-70
5-6-70
Sta.
Ditch
mg/1

< 0.01

.'
< 0.01
0.009
0.005
0.012
0.005
0.013
0.005
0.007
0.006
0.002
No. 4
mouth
Ibs/day**
•
< 2.0_

< 2.0
1.8
1.0
2.3
1.0
2.5
1.0
1.4
1.1
0.4
Sta. No. 2
Ditch "belov Detrex
Kg/1 Ibs/day***
0.02
0.02
O.J4
< 0.02
0.07
0.11
0.04
< 0.01
9-^9
0.132
0.340
o.o4o
0.135
0.058
0.058
0.035
0.045
0.030

0.6
0.6
9.5
<0.6
2.0
3.1
1.1
< 0.3
8.1
3.7
9-5
l.l
3-8
1.6
1.6
1.0
1.3
0.8

Sts. No. 1
Sump effluent
rng/1 Ibs/day *•

0.072
0.020
0.108
0.092
0.046
0.049
0.066
0.021
0.044

1.5
0.4
2.2
1.9
0.9
1.0
1.4
0.4
0.7
Underlined analyses by Detrex; all others by LEBO
* Data obtained from Detrex; data reported earlier by Detrex showed < 0.01
rng/1 for 4-8- and 4-10-70.
** Loadings based upon 23.3 p-g<3- di'.ich flow which includes flow fran Detrex,
Linde Welding, and Linde Air,
*** Loadings based upon 3-34 mgd from Detrex only.
**** Loadings based upou 2.4$ mgd from Detrex sump effluent only.

65
-------
This report was developed by personnel
of the Great Lakes Regional Office, Lake
Huron Basin Office, and Lake Erie Basin
Office in cooperation with personnel of
the National Field Investigations Center.
-------
HEAVY METALS IN THE LAKE ERIE BASIN
TABLE OF CONTENTS
SUMMARY AND CONCLUSIONS --- ___________ --- _ i

RECOMMENDATIONS ------------ ......... - 7

INTRODUCTION ----------------------- 8

USES OF MERCURY -- ........ - ------- -- 10

REFERENCES - ....... - ..... _________ 13

MERCURY ANALYSES IN THE ST. CLAIR RIVER, LAKE ST. CLAIR,
DETROIT RIVER AND WESTERN LAKE ERIE ........... lU

LOWER ST. CLAIR RIVER AND LAKE ST. CLAIR -------- 15

UPPER DETROIT RIVER (LAKE ST. CLAIR TO GRASSY ISLAND)- - 20

LOWER DETROIT RIVER (GRASSY ISLAND TO MOUTH) ..... - 25

WESTERN BASIN OF LAKE ERIE, INCLUDING THE
RAISIN AND MAUMEE RIVERS --- --- _________ 31

MERCURY ANALYSES IN THE EASTERN PORTION OF THE
LAKE ERIE BASIN ..... --------------- 38
APPENIDX I ---- --- - ............ ____ 52
REPORT ON WYANDOTTE CHEMICALS CORPORATION,
WYANDOTTE, MICHIGAN

APPENDIX II ------ ......... --------- 61
REPORT ON DETREX CHEMICAL CORPORATION,
ASHTABULA, OHIO
ii
-------
Page

APPENDIX III 77
INVENTORY OF INDUSTRIES USING
MERCURY IN THE LAKE ERIE

APPENDIX IV 86
FISH ANALYZED FOR MERCURY CONTENT

APPENDIX V 92
STANDARDS FOR MERCURY AND HEAVY METALS
LAKE ST. CLAIR - LAKE ERIE DRAINAGE AREA

APPENDIX VI 9U
CHRONOLOGY OF EVENTS
iii
-------
INVESTIGATION OF MERCURY
IN THE
ST. CLAIR RIVER - LAKE ERIE SYSTEMS
SUMMARY AND CONCLUSIONS

l
1. Data provided by the Bureau of Commercial Fisheries, Tech-

nological Laboratory, Ann Arbor, Michigan, show that mercury

was present in fish throughout the St. Clair River - Lake

Erie System. Concentrations (parts per million, wet weight)

in the edible portions of various fish were:

Yellow Perch 0.32 to 1.70

Northern Pike 0.6k

Coho Sa3jjion 0.2*4- to 0.96

Carp 0.08 to 0.28

White Bass 0.53 to 0.80

Steelhead < 0.15

Walleye Pike l.k to 3.57

Channel Catfish 0.32 to 1.8

Gizzard Shad 0.2^

Sucker 0.88

Sheepshead 0.2k
-------
2. Available information indicates that no measurable concentra-
tion of mercury was present in water supply intakes in the

St. Clair - Lake Erie System.

3. Mercury in excess of 1 mg/kg dry weight was present in sediments

in the Erie, Pennsylvania, and Euclid and Cleveland, Ohio, areas

and the Buffalo, Black, and Ashtabula rivers. Results of analyses

indicate the following levels of mercury in the areas specified:
AREA

St. Clair River
Lake St. Clair
Upper Detroit River
(Headwaters to Grassy Island)
Lower Detroit River
Trenton Channel
MERCURY LEVELS IN SEDIMENT
(mg/kg dry weight)

Mercury was present at mile points
37.0, 33.0, and 25.5 in concentra-
tions of 1.0, 0.2, and 0.3 mg/kg,
respectively. All other samples
indicated the presence of mercury.

Six sediment samples in the naviga-
tion channel, off-shore from the
mouth of the St. Clair River, contained
mercury at concentrations ranging from
0.3 to 9.2 rag/1. Samples from a
dredging disposal area had concentra-
tions of 1.7 and 2.1 mg/kg. All
other samples indicated the presence
of mercury.

Mercury was not measurable at the
head of the Detroit River, but ranged
from 1.14- mg/kg in backwater areas along
the U. S. shore upstream from the
Rouge River and as high as 2.0 mg/kg in
backwater areas downstream from the
Rouge.

In a narrow strip of about 20 to
100 feet along the U. S. shoreline
concentrations ranged from 86.0 to
5.1*- mg/kg within a mile downstream
from the Wyandotte Chemicals' outfall
and then vary from 26.0 mg/kg to trace
amounts downstream to Lake Erie, depend-
ing on the settling characteristics at
the specific point.
-------
Main Channel of
Detroit River
Northern Grosse lie
Western Lake Erie
Michigan Waters
Ohio Waters
Canadian Waters
Eastern Lake Erie
Ohio Waters
One sample collected between
Grassy Island and Grosse lie
contained k.k mg/kg of mercury;
one on the east side of Fighting
Island contained 1.2 mg/kg; and one
near the Canadian shore near the
mouth contained 0.6 mg/kg.

Mercury was not present in
measurable amounts in samples
along the northern part of Grosse
lie, the area of Wyandotte Chemi-
cals' waste beds, but trace amounts
were indicated.
Concentrations near the Detroit
Light varied from 1.0 to 2.1 mg/kg.
Along the Michigan shore, mercury
was not measurable. Near LaPlaisance
Bay one sample contained 0.8 mg/kg.

Four points near West Sister Island
had concentrations ranging from
1.6 to 2.1 mg/kg. In other areas
nearer the shore, mercury was not
measurable.

Concentrations of 1.3 to 2.7 mg/kg
were present at three points extend-
ing eastward about 15 miles from the
Detroit Light and about 5 miles from
the Ontario shore. Points extending
to Pelee Island had no measurable
mercury.
Concentrations of 2.0 and 2.U mg/kg
were present off shore from mouth
of the Grand River and Cleveland
Harbor, respectively. Off shore from
the Cleveland Easterly Sewage Treat-
ment Plant, a concentration of ^.0
mg/kg occurred.
-------
Pennsylvania Waters A concentration of 1.1 rag/kg
was present in a sample from Presque
Isle Bay.

Tributaries Concentrations in excess of 1.0
mg/kg were present in the Black,
Ashtabula, and Buffalo rivers.
In the Rouge, Huron, Maumee,
Sandusky, Portage, Rocky, Cuyahoga,
Grand, and Raisin rivers, the
concentrations were less than
1.0 mg/kg.

k. The waters of the study area revealed no mercury except for one

sample collected at mile point 13.3 in the Trenton Channel down-

stream from the Wyandotte Chemical Company; this concentration

was 0.03 mg/1.

5. The Detroit River area is the primary source of mercury in the

western end of Lake Erie. This is revealed by the distribution

pattern established through sediment samples.

6. Because of mercury discharges, the State of Michigan stopped the

production of chlorine by Wyandotte Chemicals Corporation until

a treatment system was developed and the mercury-bearing wastes

were removed from the receiving waters.

7. The State of Ohio issued an order to the Detrex Chemical In-

dustries, Inc., Ashtabula, Ohio, on April 13, 1970, to "...

cease and desist the discharge of liquid industrial waste

containing any mercurial compounds to waters of the state."

Some operational changes were made but data collected on
-------
May 11, 1970, indicate that Detrex still discharged 1.2 pounds

of mercury per day.

8. Allied Chemical Co., Buffalo Dye Division, Buffalo, New York,

is a source of mercury to the Buffalo River. On May 8, 1970,

a sample of the plant effluent revealed 0.12 mg/1 mercury.

The company stated that the process utilizing mercury was not

in use on that day. Based on this information, Allied Chemical

Co. was discharging approximately h pounds of mercury per day

from sources other than the reported production of disulfo

intermediates.

9. The discharge from Diamond Shamrock, Painesville, Ohio, to

the Grand River had a concentration of 0.010 mg/1 mercury on

April 4, 1970.

10. Concentrations of 0.002 mg/1 were present in the effluents from

the Ann Arbor and Wayne County-Wyandotte, Michigan, waste water

treatment plants. No measurable concentration of mercury was

present in six other waste water treatment plant effluents inves-

tigated in Michigan (State data). Concentrations of 0.00^, 0.003,

and 0.00^ mg/1 mercury were present in Euclid and Cleveland Westerly

and Southerly sewage treatment plant effluents, respectively.

Although no measurable concentration of mercury was present in

the Cleveland Easterly sewage treatment plant effluent, which

receives wastes from several users of mercury, U- rag/kg were present

in Lake Erie sediments 100 feet north of the discharge point.
-------
11. On May J, 1970 a concentration of 0.011 mg/1 mercury was present

in the outfall from the National Aeronautics and Space Administra-

tion, Lewis Research Center, Cleveland, Ohio. This occurred

during a period when there was no discharge from lagoons that

supposedly receive all mercury wastes from known sources.

12. Investigations of additional potential dischargers of mercury

to Lake Erie are in progress by the states and the Federal Water

Quality Administration.
-------
RECOMMENDATIONS

1. Surveillance and sampling programs be initiated by industries,

municipalities, States and the Federal Government to locate

and identify all sources or potential sources of mercury and

to determine mercury concentrations in surface waters, land

run-off, waste streams, aquatic life, and sediments.

2. All dischargers of mercury to surface or ground waters or to

municipal or regional waste treatment plants, including Federal

installations, be ordered to cease and desist.

3- Precautionary measures be taken by all users and possessors

of mercury or mercurial compounds for any purpose to prevent

accidental spills or other losses to the water environment.
-------
INTRODUCTION

The toxic effects of mercury and its compounds in the water

environment are veil known and are documented in the literature.

However, much remains to be learned, on toxicity limits of the

various mercurial compounds in the water environment. The

upper limit of mercury in food, used by the Food and Drug Adminis-

tration, is 0.5 parts per million wet weight. Limits have also been set for

atmospheric concentrations and numerous cases of poisoning have

been reported.

Critical pollution from mercury became apparent on March 2k,

1970, in the Great Lakes. Mercury concentrations as high as 5000

parts per billion (or 5 Ppm) were reported in some of the pickerel

shipments from Canada and commercial fishing involved was suspended

by Canada, then Ohio, Michigan and New York. The presence of mer-

cury in fish and bottom sediments in the St. Clair River-Lake Erie

system has confirmed the existence of an environmental problem of

major scope.

Mercury is discharged, to the water environment from indus-

trial processes and uses of mercurial products. In 1968, mercury

produced from mining in the United States was 2,19^,000 pounds.

The total amount used in 1968 however, was 5,732,000 pounds. Over

163 million pounds of mercury have been consumed in the United

States in the present century, but little information is available

on the final disposition of it and amounts accumulated in the

environment.

8
-------
9
Metallic mercury and mercurial compounds in liquid wastes

are characterized by their high densities. Free mercury and the

mercurous compounds form sludges and settle to the bottom of re-

ceiving waters. The mercuric compounds form precipitates with

oxides, phosphates, sulfides and carbonates. The high density is

responsible for the rapid deposition in bottom sediments where they

persist, become subject to sediment transport and are available to the

aquatic life.

Metallic mercury can be oxidized readily to divalent mercury

ions under the conditions present at the bottom of lakes and rivers.

This has been shown to occur experimentally as well. The divalent

inorganic mercury produced has an extremely strong affinity for

organic muds and is biologically methylated in the bottom sediments.

Divalent organic mercury, when methylated, is readily released from the

sediments into the water.

Many fish are bottom feeders or feed upon organisms which

are bottom dwellers and therefore the hazard of mercury ingestion

becomes very great. Fish also absorb mercury from the water through

the gills and possibly the scales.

Since biological concentration of mercury occurs, the accumula-

tion of mercury in the food chain is a matter of grave concern. A

recent report—' indicates a magnification or concentration of mercury

of over a million in the protoplasm of bacterial species. It has been

demonstrated that the concentration from water to pike is in the order

of 3,000 or more.£/
-------
10

Uses of Mercury
Sources of mercury in the environment principally come from
industrial processes utilizing a form of mercury and the use of
mercurial products by man.f
The industrial uses in 1968 are listed in the following
tabled
Thousand of Pounds
1. Electrical apparatus 1,^92
2. Electrolytic preparation of ., „,-
chlorine and caustic soda '
3. Paints 803
k. Charging new installations of ,-„
chlorine and caustic soda cells
5. Industrial and control instruments 581
6. Agricultural uses 260
7. Dental preparations 158
8. Catalyst preparations 1^5
9. Laboratory uses 151
10. Pharmaceuticals 32
11. Paper and pulp uses 31
12. Amalgamation (mercury alloys) 20

Mercury is used as the cathode in the electrolytic manufac-
ture of chlorine with caustic soda and hydrogen as by-products.
Cell recharging to make up the various losses from this process
was 26 percent of the total mercury used in 1968 by all industries.
To maintain the mercury inventory it required purchases of 1.3
million pounds of mercury in 1968. Weak spent brines, acids from
the chlorine driers, brine sludges and cell cleanings are discharged
-------
11

to the water environment from this process. The mercury may be

metallic mercury emulsion, soluble and insoluble mercury salts.

In 1968, 630,000 pounds of mercury were used in the start-

up of new electrolytic installations. This amount eventually

contributes to the cell losses.

Information from manufacturersof mercurials used for herbi-

cides, fungicides and bactericides is not readily available.

These compounds usually are produced in batch processes and require

considerable clean up with possible losses of mercury.

In the paper and pulp industry, phenyl mercury acetate is

used for slime control and ground wood pulp may contain up to 20

k/
ppm of the fungicide." This mercury is either lost to the product

or to the waste load during processing. In either case it becomes

a waste.

Large quantities of mercury are used in the manufacture of

electrical apparatus and industrial and control instruments such

as mercury cells, arc lights, pumps and switches. This poses a

hazard of loss during the manufacturing process.

Catalysts, containing 10 percent mercuric chloride are

manufactured for use by the petrochemical industry. This is made

by passing a water solution of mercuric chloride over carbon and

is used for making vinyl chloride from acetylene. Another catalyst

containing mercuric sulfate is used in processing acetylene to
-------
12

acetaldehyde. There are losses to the water environment from
«

these processes.

Paints, those used for mildew control as well as those

having anti-fouling characteristics, contain mercury, usually in

the organic form. Erosion from paint films containing these com-

pounds is another source of loss to the environment.

Mercury is used in dentistry for the preparation of amal-

gams. Minor losses may result from this use.

Laboratory use of mercury in manometers, thermometers,

calomel cells, standard cells and as reagents results in an

occasional discharge to sewers. In large research centers or

universities, the quantities can become appreciable.

Minor users of mercury are the pharmaceutical manufac-

turers and in amalgamation. In the pharmaceutical manufacture,

diuretics and antiseptics, i.e. calomel, phenyl mercury acetate

and merthiolate are made. Accidental spills are the source of

loss to the water environment.

The recovery of gold and silver by mercury amalgam is a

wet process and may result in rather high losses of mercury in

the plant effluent.

Additional mercury is introduced to the water environment

through the use of products containing mercurial compounds. The

most wide-spread example of this is in the agricultural applica-

tion of fungicides and pesticides, which results in losses during

periods of run-off from the area to which they are applied.
-------
13
References
1. Minerals Yearbook, 1968, Vol. 1-11, Metals, Minerals and
Fuels, Bureau of Mines, Chapter on "Mercury" by J. M. West.
2. Woods, J. M. "Environmental Pollution by Mercury," Advances
in Environmental Science, Vol. II (in Print).
3. Jernelov, P. "Biological Methylation of Mercury in Aquatic
Organism," Nature, Vol. 223, No. 5207, pp. 753-75^, August 16,
1969.
h. Smart, N. A. "Use and Residues of Mercury Compounds in
Agriculture," Residue Reviews, Vol. 23, pp. 1-36. 1968,
5. Battelle Memorial Institute, Design of an Overview-System
for Evaluating the Public-Health Hazard of Chemicals in the
Environment, Appendix A, 1967.
6. Johnels, A. G., et al. "Pike (Esox lucius L.) and Some Other
Aquatic Organisms in Sweden as Indicators of Mercury Contamina-
tion in the Environment," Oikos, 18(2): 323-333, 1967.
-------
MERCURY ANALYSES IN
THE ST. GLAIR RIVER. LAKE ST. GLAIR, DETROIT
RIVER AND WESTERN LAKE ERIE
The FWQA-Lake Huron Basin Office (LHBO) initiated a water

and sediment sampling and analysis program for mercury in the St.

Clair River — Lake Erie system immediately after the Canadian

government announced the fishing ban in Lake St. Clair on March 2k,

1970.

Sample collections were made by personnel from the Lake Huron

Basin Office with assistance from the Michigan Water Resources

Commission.

Water samples were collected with a surface grab-sampler.

Sediment samples were obtained by the use of either a Petersen dredge

or a drag line sampler. These devices penetrate the bottom to a

depth of about one-fourth foot. Physical properties such as odor,

color, and general composition of the bottom materials were recorded.

The State of Michigan reports no measurable mercury in any

water supply intakes within this area.

State data on analyses of 2U-hour composite samples from nine

municipal waste water treatment plants revealed concentrations of

0.002 mg/1 at the Ann Arbor, Michigan, and Wayne County-Wyandotte,

Michigan, plants on April lk, 1970.
-------
15
ST. CLAIR RIVER AND LAKE ST. CLAIR

One water sample and 26 sediment samples were collected and

analyzed from Lake St. Clair (Table 1 and Figure l). Six sediment

samples in the navigation channel contained mercury in concentrations

from 0.3 to 9-2 mg/kg dry weight. Two samples from a dredging dis-

posal area contained mercury at concentrations of 1.7 and 2.1 mg/kg

dry weight. In the other 18 sediment samples the presence of mercury

was indicated, but was less than the measurable limit. The water

sample contained less than the measurable limit.

Sampling of the St. Clair River began on March 26, 1970.

Fifteen samples of sediments and six water samples were collected

between river mile (R.M.) 10.k and 37.0. Sediment samples

from R.M. 37.0, 33.0, and 25.5 contained concentrations of 1.0, 0.2,

and 0.3 mg/kg, respectively (Table 1 and Figure 1). The other 12

sediment samples contained less than the measurable limit of 0.5 mg/kg

wet weight, but indicated that traces of mercury were present. The

six water samples contained no measurable concentrations of mercury.
-------
Table 1
MERCURY SURVEY
Sample Analysis Results
St. Glair River

Sample
Collection
Date
1970
3/26
ri
ii
it
4/30
Location
Ft. from
River Mile U.S. Shore
10.4
10.6
10.6
17.5
17.5
17.5
35.4
33.5
31.5
29.5
27.5
23.5
21.5
19.5
Mercury Content
Sediment (mR/kg)
Wet Basis Dry Basis
20
1850
4120
20
1500
2700
100
100
100
100
100
100
100
100
< 0.5

< 0.5
< 0.5

< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
„< 0.5
Water
< 0.01
< 0.01
< 0.01
< 0.01
< 0.01
<- 0.01
16
-------
LAKE HURON IASIN OFFICE

MERCURY BOTTOM SEDIMENT SURVEY

ST. CLAIR RIVER
APRIL 1970
U.t. DEPARTMENT OF THE INTERIOR
FEDERAL WATER QUALITY ADMINISTRATION
• REAT LAKES RE«ION •ROSSI ILt, MICHIGAN
SCALE IN MILES

2
Ortdglng

DOW CHEMICAL CO.
MICHIGAN
FIGURE 1
ONTARIO
<0.5 Wet Weight Mg/Kg

Mile Points

Dry Weight Mg/Kg
-------
Table 2
MERCURY SURVEY
Sample Analysis Results
Lake St. Glair
Sample
Collection
Date
1970
4/15
n
n
"
n
n
n
4/21
M
n
• n
n
4/22
n **•
n
n
n
n
n

Location
Grid

18. 8N
3.8N
13. 5N
16. 5N
' 16. 6N
18. 7N
20. ON
0.4N
1.8N
.3.2N
' 5.5N
7.5N
6.8N
' 11. 2N
.- 11. 6N
13. 9N
17. 8N
21. 7N
21. 5N
Coordinates

10. 6E
4.3E
9.9E
10. OE
7.6E
8.6E
11. 9E
0.4W
1.1E
1.7E
2.5E
2.3E
7. IE
11. 2E
2.9E .
4.8E
6.6E
9.6E
13. 4E
Mercury Content
Sediment (mg/kg) Water
fag/1)
Wet Basis Dry Basis

< 0.5

< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.005
2L6
-------
FIGURE 2
24N
- ZZN
- 20N
- I 8N
- 4S
- 68
<0.5 Wet Weight Mg/Kg
(Varies from <0.6 to
-------
20
tfPPER DETROIT RIVER (LAKE ST. CLAIR TO GRASSY ISLAND)

Sampling of the upper Detroit River and lower Rouge River

began on March 26, 1970, and continued to April 2U. Sixteen sedi-

ment and six water samples were obtained, as indicated in Tables 3

and 4, and shown on Figures 3 Qnd 4. Mercury was detected in sedi-

ments along the U. S. shoreline at boat ramps and in other backwater

areas. Values ranged from less than the measurable level near the

headwaters to 2.0 rag/kg downstream from the Rouge River. Concentra-

tions in sediments around Grassy Island and upper Fighting Island were

less than the measurable limit.
-------
Table 3
MERCURY SURVEY
Sample Analysis Results
Upper Detroit River
(upstream from the Rouge River)
Sample
Collection
Da Co

1970
Location
River Kile
Feet from
U.S. Shore
Mercury Content
Sediment (mg/kg) Water
Wot Basis Dry Baais
3/26
3/30
n
it
M
4/14
4/23
"
n
n
"
"
11
11
26.8
30.8
30.8
30.7
30.7
29.3
30.8
29.4
27.4 '
- 26.2
^5.7
23.8
2"2.3
21.1
700
500
1000
500
980
1600
0
0
3300
2300
0
100
0
0
< 0.5

< 0.5
< 0.5
< 0.5
0.6
< 0.5
0.9
0.5
0.6
0.7
0.9

1.2
0.7
1.2
1.4
< 0,
< 0.
< 0.
< 0,
01
01
01
01
< 0.01
21
-------
FIGURE 3
MICHIGAN
DETROIT
LEGEND
+ <0.5 Wet Weight Mg/Kg
(Varies from <:0.6 to
-------
Table 4

MERCURY SURVEY

Sample Analysis Results
ROUKO River
Sample . Mercury Content
Collection ' Sediment (m^/kg) Water
Date River Mile Wee Basis Dry Basis (mg/1)
1970
3/26 1.1 < 1.0 < 0.01
4/23 .3 Old Channel < 0.5
11 1.5 Old Channel < 0.5
4/24 1.8 < 0.5
" 3.1 < 0.5
.1 < 0.5
23
-------
FIGURE 4
LAKE HURON BASIN OFFICE

MERCURY BOTTOM SEDIMENT SURVEY
ROUGE RIVER
APRIL 1970
U.t. DEPARTMENT OP THC INTERIOR
PEDERAL WATER OlMLITr AOMINKTRATION
• NEAT LAKIf RE«ION •HOItC ILE, MICNI4AN
-f- Le«s than the Detectable Limit
MP2.0 Mile Points
ONTARIO
-------
25
LOWER DETROIT RIVER (GRASSY ISLAND TO MOUTH)

In the portion of the Detroit River from Grassy Island

to the mouth at Lake Erie, 78 sediment and 23 water samples

were collected between March 26 and April 16, as shown in

Tables 5 and 6 and Figure 5- The highest levels of mercury

occurred in the bottom muds of the Trenton Channel downstream from

the Wyandotte Chemicals Corp. South Works, in a narrow strip of

from 20 to 100 feet along the western shore. Concentrations along

the east shore of the channel near Grosse lie were less than

the measurable limit of 0.5 mg/kg. Mercury in the sediments

indicates that the Wyandotte Chemicals' mercury discharge hugs

the western shore of the Trenton Channel, depositing mercury

in the bottom muds along shore. No mercury was present around

Wyandotte Chemicals' waste beds, located on the northern tip of

Grosse lie. However, one sample collected between Grassy Island

and Grosse lie contained k.k mg/kg mercury.

Mercury contamination in sediments was present along shore

as far as Lake Erie. In addition to high values near Wyandotte

Chemicals, one sample with 26.0 mg/kg dry weight was collected at

the northern tip of Horse Island (Gibralter, Michigan) at mile

point 6.7.

Of the four samples collected at the southern end of

Fighting Island, one contained 1.2 mg/kg mercury, and the others
-------
26
contained trace amounts, but all were below the measurable limit.

Wyandotte Chemicals waste lagoons are located on Fighting Island.

The only mercury measurable in four samples in Canadian

sediments was near the shore at mile point 3-9 (0.6 mg/kg).

As indicated in the tables, the levels of mercury in all

water samples but one were below the measurable limit of 0.01

mg/1. One sample collected 300 feet downstream from Wyandotte

Chemicals outfall W23 (RM 13.3) contained 0.03 mg/1. The effluent

was diluted by Detroit River water so mercury was not measurable

further downstream from the discharge point.
-------
Table 5
MERCURY SURVEY
Sample analysis Results
Lower Detroit River
(below the mouth of the Rouge River
excluding _the Trenton Channel)
Sample
Collection
Date
1970
3/27
it
it
n
ii
3/30
n
4/6
4/8
n
n
ti
n
n
4/14 ,
n
n
n
n
n
n
n
4/16
n
n
n
n
ti
ii
n
Location

River Mile

13.5
13.3
8.4
3.9
3.9
3.9
3.. 9 '
5.9
14.2
13.7'
13.3
12.7
15.3
16.0
14.6
16.0
16.3
16.4
16.5
16.7
18.1
19.0
16.3
14.8
13.5
13.6
15.3
17.1
16.0
15.4
Ft. from
U.S. Shore

9400
8850
17,700
15,000
19,000
15,000
19,000
13,500 '
1400
2100
2400
3200
1500
2300
1300
5500
500
0
2900
1000
0
0
9950
8200
/ 7200
7700
4300
2500
3700
1000
Mercury Content
Sediment (mg/kg)
"Wet Basin Dry Basis

< 1.0
< 0.5
< 0.5
< 0.5
0,5 0.6

< 1.0
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
1.1 4.4
< 0.5
0.7 2.0
0.5 1.7
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
0.7 1.2-
< 0.5
,< 0.5
< 0.5
< 0.5
<0.5
< 0.5
Water
(mr
-------
Table 6
MERCURY SURVEY

Sample Analysis Results

Detroit River-Trenton Channel Area
Sample
Collection
Date
. 1970
3/26
3/27
ti
ii
ii
n
ii
3/30
ii
3/31
ii
it
4/1
ii
n
n
n
' n
ii
n
n
ii
M
n
ii
4/3
n
n
M
n
n
n
n
n
n
Location

River Mile

8.7
13.1
13.4
13.2
12.4
3.9
3.9
3.9
3.9
13.2
13.1
13.3
13.4
13.4
13.2
13.2
13.1
13.1
13.1
12.4
12.4
12.4
12.4
13.9
12.0
13.2
13.1
12.4
13.3
12.8
12.0
11.3
10.5
9.8
8,7
Feet from
U.S. Shore

80
20
20
20
20
2500
6500
2500
6500
20
20
20
20
100
20
100
20
100
200
20
200
800
1000
0
0
20
20'
20
20
20
20
50
50
50
80
Sed iment
Wet Basis

<1.0
28.0
13.0
10.0
4.0
4.9
< 0.5

. 2.0
< 2.0
' 5.0
< 2.0
25.0
6.0
< 2.0
4.0
< 2.0
< 2.0
< 2.0
< 2.0
6.0

Mercury Content
(ing/kg)
Dry Basis

86.0
21.0
16.0
8JO
11.0

3.0

7.0

82.0
10.0

10.0

14.0

Water4
(ma /I)

< 0.01

< 0.01
< 0.01
< 0.01
< 0.01
< 0.01
< 0.01
0.03

<0.01
•<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
28-
-------
Table 6

MERCURY SURVEY

Sample Analysis Results

Detroit River-Trenton Channel Area (cont.)
U\Z Ui. V J- u
Sample
Collect!
Date
1970
4/6
u
n
u
u
u
n
n
4/7
n
n
n
4/8
n
u
n
it
4/16
4/17
n
n
n
n
4/24
4/26
n
u
n
n
u
u
n
Location '
on
River Mile

8.7
8.7
10.2
7.9
5.4
4.7
5.8
12.0
7.6
6.7
6.3
* 6.3
.^ 11.6
12.0
12.5
12.8
13.4
8.6
6.7
6.7
6.7
6.7
6.3
8.3
13.0
13.0
12.9
12.8'
12.7
12.6
,12.5
13.2
Feet from
U.S. Shore

80
1240
0
300
600
. 6200
7200
20
100
150 '
1200
3400
1150
1850
1850
1500
850
600
100
1000
2000
3000
150
0
20
20
20
20
20
20
20
20
Mercury Content
r__.Se_dimant fag/kg) Water
Wet Basis Dry Basis fag/1)
1.9 5.0
< 1.0
2.8 4.3
1.7 2.6
2.2 4.6
< 1.0
< 1.0
7.1 15.0
. 1.0 1.3
11.0 26.0
< 1.0
< 1.0
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
0.9 1.2
0.9 3.0
0.6 0.8
< 0.5
< 0.5
1.5 2.3
< 0.5
< 0.5
4.9 16.0
12.0 27.0
9.7 20.0
2.4 5.4
5.6 14.0
4.3 9.5
5.7 8.1
29
-------
M I C H I 6 A N

WYANDOTTE
FOR THIS AREA SEE
LARGER SCALE MAP
THIS DWG.
<0.5 Wet Weight Mg/Kg
(Varies from <0.6 to
-------
31
WESTERN BASIN OF LAKE ERIE, INCLUDING
THE RAISIN AND MAUMEE RIVERS

The sampling of Lake Erie began on April 6, 1970, with

bottom sediments collected at two stations near the mouth of

the Huron River (Figure 6). From April 6 to April 27, kk bottom

sediment 'stations were sampled. Samples were collected in

western Lake Erie, west of Pelee Island, with the majority of

samples collected near the mouths of Michigan tributaries.

Based on the measurable limit of 0.5 mg/kg wet weight, mercury

was present at 16 of the kk stations, although traces were present

at most of the other stations (Table 7).

The Raisin River was sampled on two different dates at

three stations (Figure 6). Traces of mercury were present; how-

ever, all results were less than the measurable limit (Table 8).

The Maumee River was sampled on April 17 at six stations

(Figure 7), and traces of mercury were present at most stations;

however, all results were less than the measurable limit (Table 9)-

The 16 stations where mercury was present are located in

the deepwater areas of the western basin of Lake Erie from the

mouth of the Detroit River southward and eastward. Since shoreline

and minor tributary samples did not contain appreciable amounts of
-------
32
mercury, the Detroit River appears to be the principal source,

with mercury being deposited in the deeper quiescent parts of

the lake.
-------
Table 7
MERCURY SURVEY

Sample Analysis Results
Lake Erie

Sample

Collection

Date

1970

4/6
M

4/7
n
II

4/10
M

4/14
4/15
4/25
n
4/27
Mercury Content
Location
Grid Coordinates
2.2N
2. ON
0.7N
O.ON
1.3S
2. OS
2.9S
3.7S
2.8S
4.3S
5. OS
5.4S
9.6S
17. 4S
0.5N
5. IS
8.7S
9.4S
10. 7S
16. 5S
17. 4S
11. 2S
1.3S
4.3S
8.6S
14. 8S
21. 3S
23. 6S
24. 8S
6. OS
10. OS
14. OS
14. OS
20. OS
20. OS
24. OS
2.4N
0.3N
4. OS
4. OS
4. OS
14. OS
20. OS
16. OS
2.6W
. 2.4W
1.3W
0.6W
4.2W
3.2W
2.2W
4.8W
5.8W
8.3W
6.4W
9.5W
11. 6W
2.4E
3.2E
2.0W
2.9E
5.7W
6.7E
9.4W
5.8W
10. 3W
2.9W
4.9W
8.1W
13. 1W
7.1W
3.5W
1.2E
0.0
0.0
0.0
8.0E
0.0
8.0E
14. OE
0.4E
O.OE
8.0E
14. OE
20. OE
20. OE .
20. OE
14. OE
Sediment
Wet Basis
< 1.0
< 1.0
1.0
1.0
< '0.5
< 0.5
< 1.0
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
0.6
0.5
< 0.5
: 0.5
< 0.5
0.8
< 0.5
< 0.5
< 0.5
< 0.5
0.8
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
0.7
0.6
0.6
< 0.5
0.5
< 0.5
< 0.5
1.0
1.0
0.9
0.5
0.5
< 0.5
< 0.5
< 0.5
(m^/kg) Water
Dry Basis (mpc/1)

1.8
1.8

0.8
• 1.6

1.0

1.8

1.0

1.1
1.7
2.1

1.7

1.8
2.1
2.7
1.3
1.5

33'
-------
Table 8
MERCURY SURVEY

Sample Analysis Results
River Raisin

Sample
Collection
Date
Location
Mercury Content
Sediment (mg/kft) Wa t er
Grid Coordinates River Mile _Wet Basis Pry Basis (mg/1)
1970

4/10
3/30
3/30
7.6S 9.8W -0.5 < 0.5
Consolidated Paper (S) W154 1.7 < 0.5
Masoiv.Run at Ford Bridge 1.3-0.1 <0.5
W171
< .01
< .01
-------
FIGURE 6
35
-------
Table 9

MERCURY SURVEY

Sample Analysis Results

Maumce River
Sample Mercury Content
Collection Location Sediment (mg/kg) Water
Date Grid Coordinates River Mile Wet_Basis Dry Basis (rn;;/lj
1970

4/17 0.5 <0.5
" 0.0 < 0.5
" 2.1 < 0.5
5.1 < 0.5
6.9 < 0.5
" 19.6S 14.5W < 0.5
36
-------
FIGURE 7
LAKE
MICHIGAN
-I- <0.5 Wet Weight Mg/Kg
LAKE HURON BASIN OFFICE

MERCURY BOTTOM SEDIMENT SURVEY
MAUMEE RIVER
APRIL 1970
U.S. DEPARTMENT OP TNE INTERIOR
FEDERAL WATER QUALITY ADMINISTRATION
• RCAT LAKES RCSION SROSSE ILE, MICHIGAN
37
-------
MERCURY ANALYSES

IN THE EASTERN PORTION OF THE

LAKE ERIE BASIII

As part of its mercury investigations in the Lake Erie

Basin, the Federal Water Quality Administration-Lake Erie Basin

Office analyzed bottom sediments from the downstream portions of

south shore tributaries and from the lake bottom. Tables

10 and 11 include results from the sediment and water analyses

to 5-12-70 except those made at the Detrex Chemical Corp.

plant. Detrex analyses are listed in a special report on

that plant (Appendix II).

At the Lake Erie Basin Office the lower limit of

measurability of mercury in sediments is 1 mg/kg and in

water 0.002 rag/1.

The states of Ohio, Pennsylvania, and New York report

no measurable mercury in any water supply intakes within this

area.
-------
Table 10

LAKE BRIE BASIN OFFICE

MERCURY ANALYSES - WATER
Station No.
Location
Date
1970
Mercury*
mg/1
12 Diamond Shamrock, Painesville

Influent 4/10 <0.002
Hydro discharge to Grand River 4/10 0.010
North sewer to Lake Erie 4/10 <0.002

Ik 1.59 mi. Ashtabula River (Norfolk
and Western RR bridge) 4/17
-------
Table 11
LAKE ERIE BASIN OFFICE
MERCURY ANALYSES - SEDIMENT
Dry Weight Basis
Station No.
1
?
•5

4
5
6
7
8
9
10

11
13
15
16
17
* 1 mg/kg is
Location
0.53 mi. Portage Ri^er (Rt. 2 bridge)
0.0 mi. Sandusky River
Tributaries emanating from NASA-Plumbrook
PB-1 (Plum Brook)
PB-2 (No Name Creek)
PB-3 (East Branch, Pipe Creek)
0.6l mi. Black River (Rt. 2 bridge)
8.1^ mi. Rocky River
10.0 mi. Rocky River (NASA - Brookpark)
4.27 mi. Cuyahoga River (Norfolk f>- Western
RR Bridge)
C33-8 (100 ft. North of Cleveland Easterly
STP outfall)
D24-1 (50 ft. North of E. 222nd St -
Babbitt Rd. sewer outfalls- Euclid, 0.)
Tributary to Chagrin River (General
Biochemical plant)
^1 (200 ft. downstream from plant
outfall)
#2 (at plant outfall)
2.85 mi. Grand River (St. Claii- St.
bridge)
0.76 mi. Ashtabula River (East 5th
St. bridge)
1.95 mi. Fields Brook (Columbus RR
bridge)
No Name Ditch East of Ashtabula (Rt
531 bridge)
J41-1 (Presque Isle Bay)
- — — — — —
the lowest sensitivity of test
40
Date
4/14
4/14

4/10
4/10
4/10
4/13
4/22
4/14
4/10
4/13
4/13

4/10
4/10
4/10
4/15
4/10
V13
4/20

Mercury*
mg/kg
< 1
< 1

< 1
< 1
< 1
8
< 1
< 1
< 1
4
2

< 1
<- 1
< 1
2
< 1
8
< 1

-------
Table 11
LAKE ERIE BASIN OFFICE (cont'd)
MERCURY ANALYSES - SEDIMENT
Dry Weight Basis
Station No.
18
19
20
21
22
23
2l*
25
26
27
28
29
30
31
32
33
Location
G33-12 (20 ft. north of Detrex-Linde
lakefront outfall)
G33-13 (80 ft. north of Detrex-Linde
lakefront outfall)
123-2 (6 mi. north of Ashtabula)
H3U-2 (6,600 ft., 38°T from Detrex-
Linde outfall)
H3U-1 (7,000 ft., 35°T from Detrex-
Linde outfall)
H33-7 (5,600 ft., 20°T from Detrex-
Linde outfall)
5,000 ft. north of Detrex-Linde outfall
(H33-8)
3 mi., 56 T from Detrex-Linde outfall
(H3U-5)
h-3/k mi., 6l°T from Detrex-Linde
outfall (H3U-6)
2 miles ENE of Conneaut (H36-20)
Mouth of Ashtabula River (A-U)
0.96 miles Ashtabula River (A- 3)
600 ft. north of mouth of Grand River
(0-5)
0.50 miles Grand River (G-U)
Mouth of Black River (B-U)
1.0 miles Black River (B-3)
Date
U/20
V23
U/20
V23
U/22
U/22
U/22
U/22
U/23
V23
U/23
U/2U
U/28
U/28
U/28
. U/28
U/28
U/28
Mercury*
rag/kg
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
< 1
* 1 mg/kg is the lowest sensitivity of test
-------
Table 11

LAKE ERIE BASIN OFFICE (concl'd)

MERCURY ANALYSES - SEDIMENT
Dry Weight Basis
Station No.
Location
Date
Mercury*
mg/kg
35
37-1/4 mi., 7°T from Cleveland (123-1)
Core length

0-1* inches
4-8 inches
4-12 inches
16-20 inches

Composite of benthic organisms obtained
from Kelleys Island Shoal and Starve
Island Reef

RM 0.0 Buffalo River

RM 4.3 Buffalo River

RM 0.0 Mauznee River

RM 1.5 Maumee River

S-2 Sandusky Bay - 3 miles 310° true
from Sandusky Court House

S-7 Sandusky Bay - 1.2 miles 10 true
from Sandusky Court House

RM 0.4 Cuyahoga River

C-6 400 feet NW of Cuyahoga River Mouth
8/20/69
8/20/69
8/20/69
8/20/69

4/15
< 1
< 1
< 1
< 1

< 1
5/6/70
5/6/70
4/28/TO
4/28/70
4/29/70
k
1
< l
< 1
< 1
4/29/70 < 1

4/29/70 < 1
4/29/70 < 1
* 1 mg/kg is the lowest sensitivity of test
-------
-------
HEAVY METAIS IN THE LAKE ERIE BASIN

As part of the investigations in the Lake Erie Basin,

the FtfQA, National Field Investigations Center analyzed

bottom sediments from various shore areas and tributaries.

The results of analyses for ten heavy metals are listed in

Table 12 and the sample locations are shown on Figures 9,

10, and 11. Stations were selected in the mouth of tribu-

taries and immediately off-shore.

Heavy metals are toxic to aquatic bottom organisms

and fish when present in sufficient concentrations. Combin-

ations of some of these metals such as copper and zinc have

a total toxicity greater than the sum of the toxicities of

each metal taken independently. Metals such as iron oxides

precipitate in water and may blanket the bottom and smother

bottom organisms. Toxic metals in bottom muds can be made

available to the overlying water by physical, chemical or

biological means. Metals may re-enter the overlying water

by scouring of the stream bed because of velocity increases,

by wave action, or other water turbulences. These metals may

also be resolubilized by the waterbody dependent upon environ-

mental conditions such as pll, temperature and concentrations

of other metals present. Some of these metals may also be detri-

mental to aquatic organisms when concentrated in the food web.
-------
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-------
                                                      Figure 9
MICHIGAN
                                                                       19759
                           LEGEND
                              •fr      <0.5 Wet VM<3h! Mg/»'<;,
                                    (Varies  frorr,  <0.6 io ^rr:^---=r-^^^T-
                                             II
                                 LAKK Hl'RON B AS lf> OFFICE

                          MFRC>,';;Y  F.Oi"i"OM SEDIMENT  S'JRVEV
                                 upr-rn  o^Tr.oir f:ivEf:
                                        APKIL I<570
                                U.S. 5:^STMCNT OF Tri£ IN". EKlOi

-------

-------

-------
      APPENDIX I
 REPORT ON WYANDOTTE
CHEMICALS CORPORATION,
 WYANDOTTE, MICHIGAN
           52

-------
                                    53






Investigation of Wyandotte Chemicals Corp.




     Following the discovery of mercury in fishes caught in Canadian waters,'




the State of Michigan reviewed the mercury-using industries in the State




and found that the Wyandotte Chemicals Corporation of Wyandotte, Michigan




was a major user of mercury.  The Michigan Water Resources Commission,




after consultations with the Wyandotte Chemicals Corp., gave the following




information to the Lake Huron Basin Office of the Federal Water Quality




Administration.




     The mercury cell operation at Wyandotte consumes an average of 80




pounds per day of mercury, of which approximately 10 to 20 pounds per day




is discharged' to the river.  Wyandotte Chemicals bases their estimate of




10 to 20 pounds per day on composite samples collected and composited for




three 8-hour periods each day.  The pounds per day figures given for FWQA




sampling generally indicate higher values.   However, FWQA conducted grab




sampling operations at the point of discharge to the river which are generally




not directly comparable with composite figures when there is variation in




concentration of waste throughout the day.   It was also discovered from




consultations with Wyandotte Chemicals that concentration varies through-




out the cross section of the discharge flume.  The Lake Huron Basin Office




began sampling the effluent from Wyandotte Chemicals on March 27, 1970.  The




results are given in the following table:

-------
        Effluent Samples by FWQA from Wyandotte Chemicals Corp.
                          (Outfall Code W23)

                            Mercury Content         Approx. Loading
     Date        Day         (mg/1 as Hg)               (Ibs/day)

March 27
30
31
April 3
6
7
8
9
10

F
M
T
F
M
T
W
T
F
AM
.10

.66
.33
.24
.14
.11

.12
AM
.10

.66
.33
.24
.14
.11

.12



PM

.32

.23
.11
.40
.11
.32
<.01 (effluent
from mercury cells
diverted to temporary
treatment pond at 1230)

11
36
74
31
18
30
12
36




April 3 - Wyandotte Chemicals was called into the Michigan Water Resources

     Commission office and proposed a system of treatment which was
            -i-
     tentatively approved by the State agency.   Construction began immediately

     Effluent pipes at the mercury cell were blocked up and a temporary

     above-ground piping system has been installed from that point to &

     large concrete-lined containment area which had formerly been used for

     storage of limestone.  An earth dike was used to form a reaction pond

     area at the south end of the pond, the remainder of the pond being used

     as a settling area.  Weak cell liquor was introduced to the pipeline

     to keep the pH above normal.  An estimated 600 gallons per minute of

     mercuric chloride waste from the mercury cell was then discharged through

     the pipeline to a baffled timber mixing box before discharge to the

     reaction pond.  NaHS and spent sulfuric acid were added at the mixing

     box before discharge to the reaction pond.  After about six hours

     retention in the reaction pond,  the effluent discharges through

-------
                                     55


     another mixing box to the settling pond,  at which point cell liquor

     is added to bring the pH to neutral.   In  the settling pond, mercuric

     sulfide is precipitated which removes approximately 80 to 90 percent

     of mercury.  The discharge from this  pond was then discharged to a

     larger sewer which contained other wastes from the plant and then

     discharged to the Detroit River.

April 10 - The above system was placed in  operation.   All waste from the

     mercury cell was diverted into the pond system.   There was no detectable

     discharge to the river, as indicated  in the following table:

                              Mg/1 as Hg
     Date        Day        AM           PM         Approx. Ibs/day

     April 13     M                   < .005               0
           '14     T      <.005        <.005  (pond filled, 0
            "''                     treated   effluent dis-
                                  charging to sewer at 1930)

April 15-16 - Waste discharged to the river through the temporary treatment

     system contained approximately two pounds of mercury/day.

                              Mg/1 as Hg
     Date        Day        AM          _PM         Approx. Ibs/day

     April 15     W        .006         .026              1.8
           16     T        .027        <.005  (plant       1.4
                                shut down by State of
                                Michigan-temporary
                                injunction at 1620)
           17     F                     .023              2.6
           18     S       <.005       '                     0
           19     S       <.005                            0
           20     M       <.005        
-------
                                    56

                              Mg/l as Hg
     Date        Day        AM           PM         Approx.  Ibs/day

         We can probably expect small'losses from accumulations
         of 30 years of use.  Storm runoff from roof and grounds
         may also contribute.)
     April 25     S         .010         .006              0.9
           26     S      <.005         .005               Tr
         (Operation of mercury cell process was resumed.  State
         of Michigan approved a plan of operation in which mercury
         waste is treated in settling ponds, then discharged to
         brine caverns on Grosse lie.  This is a closed system;
         brine is pumped from the cavern to Wyandotte Chemicals
         for use in their processes.)
     April 27     M         .007      . <.005               Tr
           28     T         .005       < .005               Tr
           29     W      <.005       ^.005               0
           30     T      <.005       ^.005               0
     May 1        F      <  .002       < .002               0
         4        M      <.002                            0
         5        T      <.002                            0
         6        W         .003                            .3
         7        T      <.002                            0
        ' 8 "       F         .003                            .3
        11        M      <.002                            0
        12        T      
-------
                               57

is intercepted before it reaches the river and pumped through temporary

above-ground piping systems to the waste pond.

   .  The waste pond is a concrete-lined depression formerly used for

limestone storage.  Earth dikes divide the pond into two areas; the

smaller portion in the south end of the pond is used as a reaction area,

and the remainder is used as a settling pond.

   The pond took longer than anticipated to fill, indicating leakage.

Seams in the concrete were then filled with asphalt compound and an

area along the west wall was covered with a clay blanket.  These measures

apparently stopped the leakage problem.  The company representative

informed us that under drains from the pond connect to the discharge

flume at W23 and the leaks were in the settling pond area so that
       -*•
even if.leakage occurred, it would be treated effluent and would be

measured at the same point as the effluent from the pond.

     Composite samples collected and analyzed by Wyandotte Chemicals

on three shifts at a point approximately 20 feet upstream in the

waste flume from the point sampled by FWQA at the point of discharge

to the river are as follows.  Comparison with FWQA sampling for the

same day is shown.

                         Mg/1 as Hg
                                                             Approx.
                                                             Ibs/day
April 15  Wyandotte Chemicals Composite  .027  .014  .012      1.8

                                             AM     PM
          FWQA Grab Samples      (           .006   .026        1.8
-------
        ECORSE
                                                                                     ONTARIO
IOOO
       ECORSE RIVER
    MICHIGAN
          WYANOOTTE CHEMICALS
          CORP. NORTH PLANT
      SCALE  IN FEET
           IOOO   IOOO  1000
 WYANDOTTE
WYANDOTTE CHEMICA
CORP. SOUTH PLANT
                                       I    I
                              To Deep Well Disposal
                              After April 26, 1970
Discharge to
River Prior to
April 16, 1970
                                                  WYANDOTTC  CHEMICALS
                                                        WASTE BEDS
                                            58
                                                                                   V
-------
FIGURE 1A
                          LAKE HURON  BASIN OFFICE

                               SKETCH OF
                        WYANDOTTE  CHEMICALS
                   TEMPORARY MERCURY TREATMENT
                             APRIL 16, 1970
                                No Seal*
"r
Mercury
Cell
Building
















Wyandotte Chemicals
Composite Sampling Pt.— .
i — Temporary Dam \
J Cone. Lined Watte Flume 	 ^ \
3 I 	 *•
A\Pump
^"-Temporary's,
Above Surface'
Pipeline ,






tc '
tc









>
i
*•
w


















V











\










V









V



t


«•
L.

I
f





IB^BHVIH


•

(Outlet
'

Settling Pond



t
Earth Dike |-|
1 7 / 1 1 1 I f 1 1 1 \ III

	 1 	 1>^

Reaction Pond


O
a>
c
c
o
V
a:
c
o
0
o
(A
O
JC
o
*-
^-Conc. Lined %
Limestone Storage §
FWOA
Sample Pt.
/ W23
if Discharge
"X I3.5MGD


kj
$
1
^
^ Q
1 k
^i
^ i
^0 1
1
Uj
K.





                  Pit (Abandoned)
            59
-------
                    FIGURE 2
                                                     LAKE HURON BASIN OFFICE

                                                           SKETCH  OF
                                                    WYANDOTTE  CHEMICALS
                                              TEMPORARY MERCURY TREATMENT

                                                         APRIL  20,  1970
                                                            No  Scale
                        t
                      Effutnf Approximate
                      2 Ib./day Hg
   61
6
From Mercury Cell
600 GPM
20lb/doy Hg
   Weak Cell
   Liquor Introduced
   To Control pH

         Temporory
         Pipeline —i
                     I
   Add NaHS
   H2S04(Spent)
                                  Setting Pond
                                    I j to 2 days

                                Mercuric  Sulfide
                                    Precipitates
                                                      t
                                      Reaction  Pond

                                           6Hr
                                                              Add Weak Cell
                                                              Liquor to  bring
                                                              pH to Nuetral
                                           60
                                                                                Uj
                                                                                  k.
                                                                                  ki
                                                                                  Q
                                                                                   I
                                                                                5
                                                                                £
                                                                                5
-------
     APPENDIX II
   REPORT ON DETREX
CHEMICAL CORPORATION,
   ASHTABULA, OHIO
            61
-------
         PRELIMINARY REPORT OK MERCURY INVESTIGATIONS AT
          DETREX CHEMICAL tORPORATION, ASHTABULA,  OHIO

                         April 29,  1970
                       DETREX PROCESS OPERATIONS

     Detrex employs the mercury cell in the production of caustic soda

(KaOH) and chlorine.  In' this process "brine is decomposed in an elec-

trolysis cell vhich utilizes mercury as the cathode and graphite as the

anode.  Chlorine collects at the onode and is led vith slight vacuum to

the outlet end (upper portion) of the cell.  Sodium immediately forms

en amalgam with the mercury, the mercury being placed in a thin -layer

at the bottom of the cell.

     The "basic reactions involved are:
          2 KaCl •*• 2 ife+ + 2 Cl~
        •  2 Cl"  •* C12   + 2e   (at graphite anode)

          2 Ka+ + 2e -*• 2 Na (at mercury cathode)

     Through sn opening at the "bottom of the electrolysis  cell,  the  sod-

ium amalgam is directed to a scrubber-like tower (decomposer)  vhere  de-

composition of 'the sodium amalgam takes place.   The  amalgam is intro-

duced from above, through a series of graphite  packings.   Water is intro-

duced from below and rises counter-current to the amalgam.   The amalgam

decomposition is affected by the formation of " a large number of short

circuited cells in vhich the amalgam and graphite are electrodes and the

generated caustic solution is the electrolyte.   The  reaction which takes

place is:

                   2 Na (amalgam) + 2 HgO + 2 NaOH + Hg+


                                 62
-------
                                 63


The mercury which IB  released from the amalgam collects at the bottom of

the decomposer where  It is withdrawn "by a mercury pump end returned to

the electrolysis cell.   Hydrogen gas, along with traces of mercury vapor,

Is drawn off through  a  vent  at the top of the decomposer end the  caustic

solution flows through  an exit on the side near the top, as shorn in the

diagram.  Some trace  mercury contaminated hydrogen is sold to Linde

Welding.  The remainder in vented to the atmosphere through steam.  Steam

minimizes the possibility of fire and explosion.
         - :v SCKEMATiC DIAGRAM OF.A MERCURY CELL"'
from Blav-Knox Company -
      'The Olin Mathieson Mercury Cell Process"
           1963     Form No. 2?23 3M
-------
                          •  MERCURY LOSSES

     According to Detrex at the time of the present investigation'(l)

there had been no change in recent veeks in the amount of mercury

lost in the Chlor-Alkali process, (2) the present loss rate is repre-

sentative of mercury losses since 1963,-and (3) mercury analyses of

the discharge effluent have, in the past, "been made approximately

once per month.

     Detrex mercury purchases for electrolysis cell make-up, according

to the plant manager, amount to 8-10 flasks per month.  One flask of

mercury is equivalent to 76 Ibs. of mercury (mercury is 13.5 times as

heavy as water).  Detrex claims that all the j60 l"bs.  of monthly make-up

mercury doe's not find its vay to receiving waters - they claim some of

it is pilfered because of its high market value (Retail $23 per Ib.  -

Detrex $7 per Ib.).

     Since Inarch k, 1970 Detrex has been making frequent analyses for
                                                           —»
mercury in its waste discharge, sampling at the mouth of a multiple

industry used waste water drainage ditch (station No.  U, attached map).

Beginning April 17, the Lake Erie Basin Office has sampled daily several

sites in the Detrex vicinity including station No. k,  a station (No. 2)

in the ditch just below Detrex containing only that company's discharges,

and a station (No.  l) at the Detrex sump  effluent.  The sump effluent

is probably the source of most if not all present mercury discharge.

Table 1 lists all the mercury analyses to date of samples from the

above three stations.


                                   6k   .
-------
                                   TABLE 1

         MSRCUBY ANALYSES OF  ^TTREX EFFLUENT AND RECEr/ING WATERS
Date
3-^-70
3-13-70
3-18-70
3-25-70
U-3-70
U-6-70
U-7-70
li-8-70
1*-
-------
                                  TABLE 1  (Cont'd)

         MSRCURY ANALYSES OF  DETRSX  EFFLUEIIT AND RECEIVING WATERS
                Sta. No. k                Sta.  No.  2            Sta. No. 1
 Date          Ditch mouth            Ditch beQow Detrex      Sump effluent
_J	mg/1    Ibs/day**	mg/1    Ibs/day***     mg/1   Ibs/day***

 5/11/70     0.006      1.2     -                         .    0.029    '0.5
Underlined analyses by Detrex;  all others by LEBO
*    Data obtained from Detrex  on h-lT-hd; data reported earlier
     by Detrex did not include  fy-9-70 analyses and showed <0.01 mg/1
     for U-8-and U-10-70.
**   Loadings based upon 23.3 rajd ditch flo.; which includes floT/7 from
     Detrex, Linie ",'eldin^,  and LD'IIC"? Aiv.
*-x-x-  Loauinrs oa.re^ upon 3.3^- ~~'^-  ~± "-'-•> :.:e'r-x c-/Jy.
     Loadings or.s?c upca 1.8? n^d froa Deurex auinp effluent  only
        f, of Drtrex total flow)
                              ;  66
-------
                                    67


     Data collected by the Lake Erie Basin Office on April 10 and later

(Table I) Indicate that discharges to the lake have, in fact, been sig-

nificantly reduced.  Loadings which had previously ranged up to 66 Ibs/

day have been reduced to less than 2 Ibs. per day.  However, simultaneous

data from the ditch at station No. 2 and a1\the sump effluent (station

No. I) Indicate that mercury still continues to be discharged by Detrex.

The data from station No. 2, which one would expect to show Intermediate

values between those of the sump effluent and the ditch mouth, were in
                                                  » .
most cases the highest.  The anomaly Is tentatively explained as being

the result of the sampling technique which most likely included some of

the "fluffy" sediment from the very shallow ditch waters.  The compara-

tively tow concentrations and loadings in the ditch mouth waters indicate

ihai much of the mercury has been oGtt!!p.a out in the ditch between

Detrex and the lake.  Sediment analyses at station No. 2 (see Table 2)

show that the ditch sediments do contain significant amounts of mercury.

     All  mercury In water discharged frcr;. ^he^ ditch, according to th.3

Ohio Department of Health, is attributable to Detrex since LInde Air

and Llnde Welding do not use or store mercury on the premises.  Analyses

of Llnde Air and LInde Welding effluents, as listed in Table 2, support

that assumption.

     Three plants discharge to the waste drainage ditch.  The names of

those plants and their average flows, according to the Ohio Department

of Health, are as follows:

                   Detrex          .   3.34 mgd

                   Linde Air         15.84  "

                   Linde Welding      4.I4  "

                           Total     23.32  "
-------
                                 68
     On o yearly average, according to the Detrex plent manager, the


piLant uses 2,750 gallons of water per minute or 3.9°" mgd, somewhat


higher than the above listed figure.  As 8 result of in-process


changes to April 21, 1970, also according to the plant manager,- approx-
                                           *

imately hk of the total Detrex flow or 1,200 gpm (l.73 mgd) has been


removed from the surnp, since it is mercury free.


     Beginning April 8, 1970, Detrex 'made a change in discharge practices


which it claims is responsible for the low effluent mercury concentra-


tions beginning April 8, 1970.  Prior to this time, ell Detrex waste


waters, including cooling waters, were discharged to the sump preceding


the ditch that flows to the lake.  The discharge change, claimed by


Detrex to have been motivated by economic considerations, involved the


removal of some cooling waters from the sump by bypassing the cooling


waters through over-sump pipec directly to the ditch.  With remove1 of


the cooling voters from the cuj-.p, the detention time of the remolding

                                                  >
waste discharged to the"sump is increased.  As a result larger quantities


of suspended mercury compounds become settleable and should be removed


in the sump.



                       STATE AND FEDERAL ACTIONS


     On April 10, 1970, after the Ohio Health Department had determined


that Detrex Chemical Corp. was s probable source of mercury discharge,


a visit was made to the plant by Robert Swain, Ohio Department of Health,


end Chris Potos, FWQA Lake Erie Basin Office.  They met with Robert


Baker, (plant manager), Robert Jones, John Kehm, and Dennis Ahistrom


of Detrex Corporation.  The purposes of this meeting were to learn
-------
                                  69
specifics of the Detrex operation and to determine mercury loss rates,   '

recent changes in the loss rates, end amounts  discharged to waters  of

the state.  At that time Detrex had already begun changing its  opera-

tions to divert "clean" vater from its mercury-containing vaste flow.

     On April 13, 1970 the Ohio Water Pollution Control Board issued

a "cease end desist" order to the Detrex Corporation.   It contained no

time limit for compliance.  A copy of this order end the reply  to it
                                                  » -
ere attached.  The Detrex reply, dated April 17,  claimed no mercury

discharge to the waters of the state.

     On April 17, 1970 Chris Potos end A. R. Winklhofer, FWQA Lake  Erie

Besin Office, met et Detrex vith Messrs. Robert Emmet,  Detrex Vice  Pres-

ident snd Robert Baker, plant jaanagcr, end vith Mr. Robert Swain cf th»
                          »
Ohio Department of Health to determine step" taken by  Detrex to elimin-

ate mercury discharges to waters of the State  as demanded in the State's

Cease and Desist order of April 13, 197C.

     According to the plant manager steps taken by Detrex es of April 17

vere es follows:

     1.  Floor washing stopped end ell mercury picked  up with vacuum
         cleaner since April 16, 1970.

     2.  Cell cleaning discontinued April 16,  1970 and no cells have
         been opened or cleaned since that time.

         Reference to 1. end 2. above—

              Detrex is installing B collecting tank and pump to collect
         floor vater, cell spent brine, cell wash water, end return it
         to the brine system, et which time cell cleaning will  be resumed.

     3.  Mercury treating has been stopped completely and indefinitely.
-------
                                70
     4.  The folloving indirect cooling voter streams are bypassing the
         sump:

              fl)  Hydrogen gas cooler - approximately 65 gpm
              (2)  Wash pump seel water cooler - approximately 100 gpm
              [3)  Brine heat exchanger - .600 gpm

     5.  Detrex is filtering 50$ caustic soda for the scrubber system
         (hypochlorite)
                          •

     Detrex is actively engaged in engineering the folloving changes to:

     1.  Reroute the brine dechlorination condenser vater to bypass the
         sump - approximately 500 gpm.
                                                  >• -
     2.  Provide a sump or catch basin for hydrogen seal pot vater,  nash
         pump seal vater, etc., which can then be returned to the  de-
         composer feed vater.                                          \

     3.  Provide tank, pump piping, etc. to use filtered caustic for
         neutralizing vaste sulfuric acid and chlorine vater.

     k.  Construct a veir in the effluent ditch to measure quantity of
         flow; can be used also as » sample point.

     5.  Install caustic filter backwash tank.

     Detrex was urgently advised by Mr. Potos on April 171

     1.  to cease and desist mercury dis^arges to Lake Erie immediately

     2.  that the ditch and the multiple industry-used-settling pond
         were not to serve as treatment devices for mercury removal.
         Detrex discharges were to be made free of mercury prior to
         leaving Detrex property

     3.  to hire a consulting engineer to build a vaste treatment  system
         to permanently free Detrex discharge waters of mercury

     4.  to keep FWQA and, ODH intimately informed thixnigh progress reports

     On April 21, 1970,  Mr.  Potos again visited Detrex along vith  NFIC (FWQA)

representatives, Messrs. John Hyland and Laurence Muir, end the Ohio

Health Department's Earl Richards, James Shay,  and Robert Svain, to further

discuss the mercury problem and additional actions to hasten its abatement.
-------
                                  71
     On 8 yearly average,  according to the  plant manager,  Detrex uses




2,750 gallons of water per minute,  vith maximum water use  occurring  in




summer.  Based, on in-process changes to April 21,  1970,  approximately




kk percent of Detrex waste water (1,200 gal/min) has been  determined




"by Detrex to be mercury free,  and es a result removed from the  sump.




It is a Detrex objective as of April 21 to  recycle waste streams that




contain mercury back to the process in an enclosed system  if at all  poss-




ible.  Optimum process operations with least  possible mercury discharge




are expected by Detrex in two to three weeks.   If  the mercury-laden




streams are impossible to recycle,  according  to Detrex,  the sump effluent




will be treated as soon as a practical and  economically  feasible means



becoiTiCC Available.  According to Detrex,  the  best  brains in the calor-alkali




industry are working on the problem in a  crash-program effort.  If this




effort does not meet with success,  Dstrex h&s agreed to  our demand to




hire consulting chemists and engineers to solve the problem.  Presently



this route is not favored by chlor-alkali people since they feel they



know more about mercury (production, use, treatment) than  any practicing



consulting chemist or engineer.  The State  of Ohio is in complete agree-



ment with Detrex thinking in this respect.  Mr. Potos mentioned to them



that ion exchange and reverse osmosis are now on a practical state of




the art basis.



     In an attempt to minimize the effect of  expected seasonal  increases




in precipitation and consequent runoff on ditch sediment resuspension



and scouring, Potos suggested that Detrex dredge the ditch from the  sump




to the settling pond.  Detrex exceeded this request by volunteering  to



excavate a new ditch and complete fill in the old  (see map).
-------
                                 72
                                   »

     Daring the weekend (April 18 end 19) the settling pond was "being


gfven its spring dredging by Linde Welding end the Union Carbide Corp.


vh'ich owns the entire area and leases segments to various industries.


The pond dredging does not seem to have effected mercury concentrations


at the ditch mouth approximately one mile distant, at least not through


April 20, 1970.  Dredgings from the pond are purportedly trucked'to


State-approved land fill ereas according to the Ohio Department of


Health.                                           *


     The Lake Erie Basin Office has sampled stations 1, 2,  3,  k,  5,  7, 8,
                                                                        \
9, end 11 daily from April 17 through April 2k.  Station 11 is influent


to the plant.  Sampling will continue less frequently efter April 2k,  1970.


     Table 2 lists other miscellaneous mercury sampling analyses in the


vicinity of Detrex.  At sampling station No. 9, east branch of the ditch,


mercury presence is likely the result of "beck up vater from Detrex as


•there nre no known discharges of any hini 1.0 this branch.


     The samples, both sediment and water, taken by the Lake Erie Basin


Office ere analyzed colorimetrically by that office using Dithizone with


chloroform extraction.


     Along with the attached map is a table of Lake Erie Basin Office


analyses to date in the Detrex area, (Table 2).
-------
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-------
-------
JA?•£?£> A. RiiODSS. Governor
     ~<;roc;o; i/:' iical'.r.


   •150 If.-.st To.v:. Street

   C«'/.u:.-.'ji;s. Or..o 43216
PUBLIC IiEAL7!i COUNCIL'
 Ricl.ard V. Brur.r.u:, S.D.ti.
             Cht.;::..ar.
 J. IIo\varc Kolrr.of,. ;.:.C.
             Vice Chair-.
 Ra!;>h K. Rarr-s.-iyor. M.B.
 J. F. V.cr.r, P'.i.G.
 Phillip T. Kr.iOb, '.;.D.
 Lloyd E. Larrick. :.'..D."
 J. Bruce V.'er.jcr, D.V.M.
                                                                  April  13,  1970
           3strex CiieivL cells  Industries,  Inc.
           Chlorine -Allcali ?lan^
           P.O.  Box 670
           Ash^abula, Ohio   t^OO^

           Attention:  R. L. Baker,  Plant Mgr.

           Gentlenen:

           You  are hereby ordered to cease and  desist tr.e discharge of liquid
           industrial waste  comiainins any aecurial compounds to waters of the
          ' state.

           /.rv  concentrations of mercury in th^ raw vaier used in  your plant
           will be Baleen into cons ideraz ion in  the compliance with the order.

           Please advise this office as to your compliance with the above
           order.

           Yours very truly,
           2. W.  Arnold, M.D.
           Director of Health
           C2RTIPIZ3 MAIL
                                                  75
                                                                         APR 1  5 1970
                                                                       .MOUST; ' • is
-------
           DETREX  CHEMICAL  INDUSTRIES,  INC.
                                    »
                          Chlorine - Alkali Plant
                              P. D. DQX 670
                           ASHTA8ULA. OHIO

                            April 17,  1970
•State of Ohio
 Department of Health
 450  East Town Street
 P.O. Box 118
 Columbus, Ohio    43216

 Attention:  Dr.  E.' W.  Arnold, Director of Health

 Dear Sir:

     We received, April  15,  1970, your order "to  cease and desist the discharge
 of liquid industrial waste containing any mercurial compounds to waters of
 the
     We had -previously taken effluent water samples at our discharge into
 Lake Erie on April 9th and April 10, 1970.   Further samples were taken on
 April 14th and again on April  16th.  In addition,  lake bottom samples
 east, north and west of the discharge ware  taken on April 15th.
               *^
     Using analysis methods approved by the State  of Ohio, we have obtained
 negative mercury results on each of the above samples.

     In accordance with the above analytical results, we state that the
 Detrex Chemical Industries, Inc. Chlorine-Alkali Plant at Ashtabula, Ohio is
 not discharging mercurial compounds to waters of the state.

                                      Very truly  yours,

                                      DETREX CHEMICAL INDUSTRIES, INC.
                                      Robert L.  Baker
                                      Plant Manager
 :\I3/nkv
-------
        APPENDIX III

Inventory of Industries Using
  Mercury in the Lake Erie
                77
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-------
                               79
1,  Paper mills in Michigan were checked for the use of mercury.



    Two mills use mercury in surfacing compounds and lose about



    two pounds per year.







2.  Spot checks of other waste discharges from Chrysler Corp.,




    Monsanto, Penvalt Chemicals, Wyandotte Chemicals (other than




    outfall W23 at FM 13.3), and Consolidated Paper revealed no



    detectable mercury.
-------
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           APPENDIX IV
FISH ANALYSED FOR MERCURY CONTENT
  BUREAU OF COMMERCIAL FISHERIES
     TECHNOLOGICAL LABORATORY
       ANN ARBOR, MICHIGAN
                86
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               APPENDIX V
 STANDARDS FOR MERCURY AND HEAVY METALS




LAKE ST. CLAIR - LAKE ERIE DRAINAGE AREA
-------
              FEDERAL-STATE WATER QUALITY STANDARDS AMD USPFS  , /
          DRINKING WATER STANDARDS FOR MERCURY AND HEAVY METALS-7
                 -LAKE 'ERIE-LAKE ST. CLAIR DRATOAGB AREA

   The National Technical Advisory 'Committee on Water Quality Criteria 'states:
   "Surface waters should be free of substances attributable to discharge^or
   wastes as follows:  materials, including radionuclides, in concentrations
   or combinations which are toxic or which produce undesirable physiological
   responses in human, fish and other animal life, and plants."

   Specific nuraberical criteria for toxic sub stances have been included in
   water quality standards as follovrs:
   State          Metal

Indiana       Cadmium
              Chromium (hexavalent)
              Lead
              Silver
              All Toxic Materials

Michigan      Chromium
               (hexavalent)

New York    -  No Specific Criteria

Ohio          Cadmium
              Chromium
               (hexavalent)
              Lead
              Silver
              Iron (certp.in rivers
               on Ohio-Pa, border
               only)
              A31 Toxic Materials
   Criteria
Values in mg/1

    0.01
    0.05
    0.05
    0.05         2/
    0.1 96-hr TLn£'

    0.05
    0.01
    0.05

    0.05
    0.05
    1.5
    0,1 1*8-hr TLm
Use Classification
to Which Applied

  Water Supply
  Water Supply
  Water Supply
  Water Supply
  Fish & Wildlife

  Water Supply
  Water Supply
  Water Supp.ly
    *-
  Water Supply
  Water Supply
  Water Supply
  Aquatic Life end
  Recreation
Pennsylvania  Manganese
              Iron (Total )
              Iron (Dissolved)
    1.0
    1.5
    0.3
  All User,
  All Uses
  All Uses
!_/   Heavy metals considered:  cadmium, chromium, copper, iron, lead,
     manganese, silver, and zinc.
2/   The TLm is the concentration of a toxJf; mateHsl wM.ch produces
     death to one -ha If of the test orcnrisur; in a bio?.r,say test within
     a specified length of time (e.g. U8 hours or $6 hours).
                                       93
-------
     APPENDIX VI




CHRONOLOGY OF EVENTS
-------
                       CHRONOLOGY OF EVENTS


March. 24, 1970
                                                             i
      The Canadian Federal Department of Fish and Forestry banned the

sale and export of fish caught commercially within the Canadian bound-

aries of Lake St. Clalr because concentrations of mercury In some of

the fish made them unfit for consumption.  The decision was made as a

result of a research report which showed pickerel caught In the lake

contained as much as seven parts per million mercury (ppm).  Subse-

quent laboratory reports Indicated a somewhat lower figure of 1.36 pprn

which, however, is still almost three times as great as 0.5 ppm level

considered acceptable for fish procured for export by federal food and

drug authorities In both Canada and the United States.  The Ontario

Water Resources Commission Identified one Dow Chemical of Canada

Limited chlor-alkalf plant  at Sarnia, Ontario as the source of mercury

pollution to the St. Clalr River,

      FWQA Regional Office learned from Mr. Ralph Purdy, Executive

Secretary, Michigan Water Resources Commission, that he had written

letters to chlor-alkali plants in the state to find out who was using

mercury cells.  He reported that the Wyandotte Chemical Company on the

Detroit River  uses mercury cells and that he was conducting discussions

with them to  learn about the  disposition of their mercury bearing wastes.

March 26. 1970

      Coordination achieved with Michigan agencies, Ontario Water

Resources Commission, Bureau  of Commereia! Fisheries, and Food and

                               95
-------
                                 96


 Drug Administration.   FV/QA* Lake Huron  Basin Office  Initiates  a  water

 and sediment sampling program for the  St.  Clalr  River,  Lake St. Clalr,

 Detroit River,  and Western Shore of  Lake Erie.   Advised that  Field

 staffs of the Bureau  of Commercial Fisheries, Great Lakes Fisheries

 Laboratory,  Ann Arbor, and the Department  of Natural  Resources, would

 be conducting a fish  sampling program  and  that arrangements were  being

 made for the Wisconsin Alumni Research Foundation  (WARF), Madison,

 Wisconsin to analyze  the fish samples. Learned  that the Michigan

 Health Department and the Michigan Water Resources  Commission were

 getting samples from  water Intakes,  treatment plants and Industrial

 outfalls for analyses of mercury at  the Lansing  laboratory.

 March 27. 1970

        FWQA Lake Huron Basin Office  begins collecting water and
       .-..                .•       '••••.•.          '".*.
 sediment samples from the Wyandotte  Chemical plant. '     '

 April 2, 1970

        Regional Director, GLR, chaired an. Informal  meeting at FWQA

 Headquarters, Washington, D. C., with  Bureau of  Commercial Fisheries,

 Bureau of Sports F.Isheries and Wildlife, Food and  Drug Administration,

 and Ontario and Canadian Federal representatives.   The meeting  was

 called to obtain a better understanding of the mercury problem  and

' to exchange information.  It was the consensus of  the representatives

 present that the mercury problem is  serious and  of  international  con-

 -cern.  It was also agreed that an inventory of mercury uses to

 determine waste concentration was needed and that  sampling should

 continue In order that the problem may be  completely defined.
-------
                     •  .          97
 J\pr11 8, 1970
             •             v                   •            -
        .Governor Ml I liken of Michigan advises sportsmen not to eat
  fish caught from Lake St.- Clalr and the Detroit and St. Clalr Rivers.
  April 10J 1970                   .  '                  .-            .
                          "                .             t
I         A meeting of Ontario, Michigan, and Ohio representatives was
  held In Toronto, Ontario to share Information and explain how deci-
  sions were reached for Ontario to place a ban on fishing In Lake
  St. Clalr, St. Clalr River, and Detroit River.  Federal people from
  Canada and'the United States were Invited as observers.  Mr. O'Leary
  of the Lake Huron Basin Office, represented the FWQA Great Lakes
  Region at the meeting.
         Rperesentatlves of all agencies agreed that sampling and
  testing must continue In order that the problem may be completely
  defined.                •           ..'  •             •             .
         Mr. Kerr, Federal Energy and Resources Minister, described  .
    f                *              *
  the action that has been taken to halt any further mercury discharge
  from the presently known source of pollution on the Canadian side of
  the boundary In this area, and Governor Mllflken stated that he had
  received an assurance today that the  presently known source on the
  Michigan side had today  Instituted procedures to eliminate  future
  mercury contamination of the water from Its facility.
          It was agreed that  future action will be taken  In a  coordinated
  way  so tnat all  involved agencies may take similar action.
         The representatives of  the States of Ohio and Michigan agree
  with those from Ontario that a ban on fishing  in Lake  Erie  Is not
-------
                                  98  .
                                   • *
      .                •
 Indicated at this time.  Their respective agencies agreed to
                        ' • 4            '      •
'exchange Information from their sampling and  testing programs.
              *                                       *            •
        Governor MI I liken announced the* following actions and

 agreements:

        I.  Michigan will  Institute proceedings to close Lake St.  Clalr

 and the St. Clalr River to all ftsntng as a precautionary measure

 pending further study;       •                 .                    ;

        2.  Michigan, Ontario, Ohio FDA and the U. S. Federal  Water
              *     •               i   ' *                  '

 Quality Administration  agreed to cooperate In developing further

 Information on  the Detroit River and Lake Erie;

        3.  Participants In the meeting agreed to continue and

 accelerate efforts to eliminate mercury contamination from all

 sources;

       .4.  All  parties  agreed to consult with various other

 authorities prior to taking actions  affecting waters of the Great

 Lakes;               •               .                       ^

        5.  AlI  parties  agreed to participate, with other author-

 ities.  In Investigating additional dangerous  substances as to kinds,

 amounts and effects;

        6.  AlI  parties agreed to recommend the convening of a

 conference of the Governors and Prime Ministers of the Great  Lakes

 States  and Provinces;

        •7. .Al!  parties  agreed to urge all  respective federal  bodies

''to Initiate actions  to  Investigate sources of mercury contamination

 In alt  states and provinces.
-------
                               99  ..   -


       Ohio Department of Health determines Detrex Chemical  Company
    •                                   "      '    *
                       • *                  •

of Ashtabula, Ohio a proba'ble source of rrsrcury contamination.



       RVQA Lake Erie Basin Office, Cleveland Initiates a water


sampling program In Lake Erie and tributaries and participates



in an Inspection of the Detrex Chemical Company plant.



       Uyandotte Chemical plant ceased mercury waste discharges to



the Detroit River at.12:30 p-.m.  Mercury enriched waters are now


being discharged In holding facilities for chemical treatment.



April 13, 1970



       Governor Rhodes of Ohio announced a ban on commercial fish-



Ing In Lake Erie.


       Ohio Water Pollution Control Board issued a "cease and



desist" order to Detrex Chemicals Company.


       FV/QA Lake Huron Basin Office personnel met with Michigan


State officials.  The MWRC agreed to supply one man to aid  In the


field work collecting sediment samples and to share duplicate



samples for verification purposes.  MWRC to continue sampling


effluents In the area.


April 14. 1970


       FWQA Great Lakes  Region Basin Offices provided with  a list


of chlor-alkali plants and asked to  Investigate as sources  of


possible mercury pollution.



April 16. 1970
            #   "

       The Wyandotte  Chemical Company  was  Issued  a court order to


cease discharges of  mercury  wastes  In  any  form or amount.   The plant


ceased operation of  the  mercury  cell room  at 6:20 p.m.
-------
                               100

April 21, 1970


       Secretary of the Interior Walter J. HIckel  announced his


Department Is Initiating a massive campaign to clean up Lake Erie,


as a result of reports of lethal .discharges of mercury Into the Lake


and Into the Detroit River which empties Into Lake Erie.


       In a series of steps, Secretary HIckel announced taking the


following action:


       — An enforcement conference on Lake Erie will  be reconvened


In Detroit, followed by enforcement workshops In Toledo, Cleveland,


Loraln, Sandusky, and Ashtabula, Ohio; Erie, Pennsylvania; and
                                          »
Lackawanna, New York.                   '


       ~ The Secretary's special investigative task force has been


assigned to obtain firsthand ijp-to-date data on the entire water


pollution problem in the Lake Erie watershed.
       ••''."    — -                .              .  .  •' *t?***}>fr~-,-._ • -

       — Increased monitoring and research will be Initiated at the


Fish and Wildlife Service's Great Lakes Fishery Laboratory at
   •                                                         *
Ann Arbor, Michigan, on the toxlcity of mercury and other metal com-

pounds and their effect on fish and other aquatic life.


       — The Fede'ral Water Quality Administration has been directed

to Identify and prepare a list of all toxic substances now being

discharged in waters throughout the United States.


April 23, 1970-

       Assistant Secretary for Water Quality and Research, Carl Klein,


directed the Commissioner, FWQA, to take necessary Immediate action


to translate the Secretary of the Interior's announcements of April 21
-------
                            101
Info positive action.-  Ha also asked that the Task. Force assigned
    • •          •         "4                  *


to obtain firsthand up-to-date data on the entire vzater pollution
                                                  •
                 /

problem In Lake Erie and coordinate with. Michigan, New York,  Ohio



and Pennsylvania.



April 29, 1970                         •    *



       Prime Minister John P. Roberts of Ontario called a conference



for June to discuss pollution problems In Lake Erie.   The Prime Minister



Invited the Prims Minister of Quebec and the  Governors of Illinois,



Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania and



Wisconsin.                            '   '                  -



April 30, 1970                  .



    --  Governor Rockefeller of New York announced that the Department



of Agriculture and Markets began placing all  fish caught commercially



In LaKe Erie under seizure to'.protect consumers from mercury contamlna- .



tlon.  The Department of Conservation advised sports fishermen against



eating fish taken from Lake Erie.  This action was taken after analysis



of several New York fish samples showed levels of mercury In excess



of 0.5 ppm considered acceptable for sale by  the Food and Drug Admin-



istration.  The Governor announced that the State Health Department



also had tested drinking water taken from Lake Erie and that It had



been found fully safe for human consumption.



       Staff members of the FWQA Great Lakes Region met with members



of the Secretary of the  Interior's Task Force to develop plans for



action required to  Implement the Secretary's announcement of April 21.



Recommendations for appropriate, field  investigations and research



projects v/ere  developed  for Headquarters' consideration.
-------
                                  102




 May 1, 1970




        The State of Ohio rejected 11,300 Ibs. of fish caught in Ohio




" waters of Lake Erie because of high levels of mercury (greater than




 0.5 ppm.)  The rejected fish were from 8 commercial catches of 5




 fisheries and were primarily white bass, sheephead and catfish caught




 in the western basin and the western end of the easterly basin of




 Lake Erie.  The samples analyzed consisted of UOO fish and contained




 mercury ranging from 0.51 to 0.6k ppm.  The State of Ohio made the




 analysis.




 May k, 1970




        Governor Warren Knowles of Wisconsin issued a 30-day emergency




 order closing 35 miles of the Wisconsin River for fishing due to mercury




 contamination.  The Wisconsin Department of Natural Resources issued




 a cease and desist order to Wyandotte Chemical Corporation of Port




 Edwards to halt the discharge of mercury laden wastes into the Wisconsin




 River.




        The Assistant Commissioner for Enforcement FWQA was requested




 by the Commissioner, Erie County Department of Health to conduct an




 extensive water and bottom sampling program for toxic materials




 and substances not only in the western basin but throughout Lake




 Erie.  The Commissioner also requested a re-evaluation of the 19^7





 compliance schedule to determine whether any of the municipalities



 and industries not in compliance are contributing toxic  discharges.




 May 5, 1970



        A representative from the Ohio Department of Health visited




 Reactive Metals Inc.,  Metal Reduction Plant in Ashtabula , Ohio to
-------
                                 103


obtain information pertaining to mercury discharges.  Samples from the

plant effluent and receiving tributary were collected for analyses.

May 6, 1970

       Representatives from the Ohio Department of Health, and FWQA.,

Lake Erie Basin Office, either visited or contacted by telephone

the following industries to obtain information regarding mercury usage:

       Bailey Metal Co., Wlckllffe, Ohio

       General Electric Co., Cuyahoga Plant, Cleveland, Ohio

       General Electric Co., Large Lamp Engineering and Pilot Plant,
                                                    Cleveland, Ohio

       Standard Oil Co. of Ohio, Cleveland, Ohio

       The FWQA, Lake Erie Basin Office collected sediments samples

from the Buffalo River for mercury analyses.

       An effluent sample from the Cleveland Easterly Sewage Treatment

Plant was obtained for mercury analysis by Lake Erie Basin Office.

May 7, 1970

       Representatives from the Ohio Department of Health, and the FWQA.

Lake Erie Basin Office visited the following industries to obtain in-

formation pertaining to mercury usage:

       National Aeronautics & Space Administration, Lewis Research Center,
                                                     Cleveland, Ohio

       Lincoln Electric Co., Cleveland, Ohio

       General Electric Co., Powder & Wire Plant, Euclid, Ohio

       General Electric Chemical Products Plant, Cleveland, Ohio

M&y 8, 1970

       Regional Director, FWQA. Great Lakes Region presented testimony
-------
on mercury contamination in the Great Lakes to the Subcommittee on
  •
Energy, Natural Resources and Environment of the Senate Commerce

Committee at Mount Clemens, Michigan.

       Secretary of the Interior announced that the fifth  session of

the Lake Erie Enforcement Conference would be held on June 3, 1970 at

Cobo Hall in Detroit, Michigan.

       Representatives from the Ohio Department of Health  and the FWQA

Lake Erie Basin Office either visited or contacted by telephone the

following industries to obtain information pertaining to mercury usage:

       Union Carbide Corp., Electronic Components Div., Cleveland, Ohio

       Union Carbide Corp., Carbon Products Plant, Cleveland, Ohio

       Union Carbide Corp., Edgewater Works, Cleveland, Ohio

       I. Miller Inc., Cleveland, Ohio

       Merian Instrument Co., Cleveland, Ohio

       Schuemann-Jones Co., Cleveland, Ohio

       B. F. Goodrich, Avon Lake, Ohio

       E. I. DuPont de Nemours Co., Cleveland, Ohio


       Representatives from the New York State Health Department and

FWQA, Lake Erie Basin Office visited the Allied Chemical Co., Buffalo,

New York Dye Division, to obtain information on mercury usage.  The

New York State Health Department requested the Allied Chemical Co. to

minimize the discharge of mercury and to report immediately of their

steps for compliance.

May 9, 1970


       Allied Chemical Corporation of Syracuse, New York diverted their
-------
                                  105





mercury bearing vastes to their  settling ponds.  Previously wastes were




discharged to  streams flowing into Onadaga Lake.  The  settling ponds




"being used for mercury wastes may still, however, overflow  into  streams



flowing into Onadaga Lake.




May 11, 1970



       A representative from the  Ohio Department of  Health  contacted by



telephone the  following industries to obtain information pertaining to



mercury usage:



       Barshaw Chemical Co., Cleveland, Ohio



       Bellows Electric Co., Akron, Ohio



       Effluent samples from Detrex Chemical Co., Euclid Sewage Treatment



Plant, and Cleveland Westerly and Southerly Sewage Treatment Plant were



obtained for mercury analyses by FWQA Lake Erie Basin Office.




       The Director, Lake Erie Basin Office notified the Regional



Director, Great Lakes Region, that the Allied Chemical Co.,  Buffalo,



New York is a  source of mercury in the Lake Erie Basin.  He recommended



that New York  State Health Department issue a desist order.



       Wayne C. Bellaman, Regional Sanitary Engineer for the Pennsylvania



Department of Health, announced the following:



              1.  Declared that concentrations of mercury in the waters



of Lake Erie used for municipal and industrial water supply by the



City of Eire are within the limits safe for domestic and industrial



use and consumption.  No concentrations of mercury in excess of 0.005



mg/1 were found in samples of raw water collected from both of the




City water works.
-------
                                 106





              2.  Selected municipal and industrial waste discharges



were sampled, including the effluent from the City of T^rie Sewage




Treatment Plant and the Hammermill Paper Co.  No concentrations  of




mercury have been confirmed in these discharges in excess of those



from the waters withdrawn by the City of Erie and the Hammermill Paper



Co. from Lake Erie.




              3.  The Erie County Health Department has been assisting



in this investigation by checking hospitals and industries connected




to the Erie sewer system.  No potential major sources of mercury are



known to exist within the Erie portion of the Lake Erie Basin.



              k.  Assured that if mercury is found in any of the waste




discharges in excess of 0.005 mg/1. enforcement action will be initiated



immediately to require immediate and complete abatement.



              5.  No mercury has been found in the tissue of fish




collected from Lake Erie in excess of 0.5 mg/1 limit set by the



Federal Pure Food & Drug Administration and the World Health Organization.




May 13, 1970



       Ontario and Michigan officials met in Toronto to reconsider the



fishing ban and arrive at an agreement for possible reopening of fish-



ing in Lake St. Clair, Detroit, and St. Clair Rivers.  It was agreed that



a catch and release restriction be imposed by both governments which will




make possession of fish illegal.



       Effluent samples from the National Aeronautics & Space Admini-



stration,  Lewis Research Center, were obtained for mercury analysis



by FWQA.,  Lake Erie Basin Office.
-------
                            107





May lU, 1970




       Ontario Officials announced the reopening of sports fishing




in Canadian waters of Lake St. Clair and the St. Clair and Detroit




Rivers.  No catch and release restrictions were imposed; however,




warnings on the eating of fish were made.




May 1$, 1970




       Governor Milliken of Michigan announced that a statement will




be issued next week on Michigan's decision to relax the sports fishing




ban on U. S. waters of Lake St. Clair and the St. Clair River.




       Officials of the New York State Conservation Department closed




all fishing in Onondago Lake at Syracuse because of mercury contami-




nation.  The State Conservation Department also recommended that




fish caught in Lake Ontario and the Oswego River not be eaten.




       The Wisconsin Department of Natural Resources held a public




hearing concerning Wyandotte Chemical Corporation of Port Edward's




discharge of mercury wastes to the Wisconsin River.




       Regional Director, New York State Health Department, Syracuse,




sent a telegram to Allied Chemical Corporation, Solvay, New York




asking the Corporation to present the Department of Health a defi-




nitive time schedule for complete elimination of mercury from their




liquid waste discharge.  Allied Chemical was asked to respond by




May 25, 1970.  Similar instructions were transmitted to Olin Mathie-




son Corporation of Niagra Falls, New York.  The Olin Mathieson




Corporation was asked to meet with State Officials to discuss a




suitable time schedule.
-------
                                108


       Representative from the Ohio Department of Health and FWQA,
 *
Lake Erie Basin Office visited the General Electric Company, Cleveland

Lamp Plant, to obtain information pertaining to mercury usage.


       A representative from FWQA, Lake Erie Basin Office visited the

General Electric Company, Bucyrus Lamp Plant,to obtain information

pertaining to mercury usage.

       Effluent samples from General Electric Technical Products Plant

were obtained for mercury analyses by Lake Erie Basin Office.  The

Regional Director, Great Lakes Region, advised the Deputy Commissioner,

New York Department of Health, of findings pertaining to Allied

Chemical, Buffalo Dye Division, and requested to be kept abreast of

any enforcement action that may be pending.  The New York Depart-

ment of Health requested Allied Chemical Company to submit a  schedule

to eliminate mercury discharges.

May 18, 1970

       Representatives from the FWQA, Lake Erie Basin Office, Ohio Dept.

of Health, and the NFIC, Cincinnati, met in Columbus, Ohio to exchange

mercury data.

May 19, 19TO

       Representatives from FWQA, Lake Michigan Basin Office and Illi-

nois State Sanitary Water Board visited the Monsanto Company of

Sauget, Illinois to inspect plant operations and sample plant effluent

and sludge from the brine reaction tank.
-------
                                                      725



                        A. M. Shannon






          MR. STEIN:  All right.  Any comments or questions?




          (No response.)




          I didn't want to belabor the point, but when they




talked about detectable limits, they talked about all below




5 ppb.  And you were 500 percent lower than that for your




detectable limit on 1 ppb.  That is a big spread.




          All right, thank you.



          Any comments?




          (No response.)




          Mr. Purdy, did you have someone else?



          MR. PURDY:  Dr. Shannon from the Detroit Water




Bureau would like to be heard.






               STATEMENT OF ALBERT M. SHANNON




           CHIEF, WATER AND WASTEWATER TREATMENT



               DETROIT METRO WATER DEPARTMENT






          DR. SHANNON:  Mr. Chairman, conferees, ladies



and gentlemen, my name is Albert M. Shannon, and I am chief




of Water and Wastewater Treatment for the Detroit Metro



Water Department.  I would like to make a brief statement




on the results of our monitoring program for mercury, both




at our two raw water intakes and on the incoming raw sewage




and the plant effluent at our sewage treatment plant.



          One of our intakes, the Waterworks Spartan plant,
-------
                                                       726

                         A.  M.  Shannon

r
 is  indicated  on  the  upper  end  of  Belle  Island,  the  upper

 Detroit  River.   The  southwest  intake is located off the

 northern tip  of  Fighting Island in  Canadian  waters.  And

 that  is  in  the lower Detroit River.

          To  date we have  determined the mercury in 36 daily

 24-hour  composite samples,  also 12  weekly composite samples,

 making a total of 48 samples.  And  to date,  we  found no

 measurable  quantities of mercury.   And  the limit of our

 accuracy sensitivity is  2  parts per billion.

          Now, since May 11, we have run daily  24-hour

 composite samples of raw sewage and also the plant  effluent.

 And that is 25 samples of  raw  sewage and 25  samples of plant

 effluent.   And none  of these samples showed  the presence of

 detectable  quantities of mercury.   And, again,  here the

 limit is 2  parts per billion.

          That's all. Thank you.

          MR. STEIN:  Two  parts what?

          DR. SHANNON:  Two parts per billion.

          MR. STEIN:  O.K.  Thanks.

          Did you ever find mercury in  your  drinking water

 here?

          DR. SHANNON:  No, none  at all.

          MR. STEIN:  But  again,  you see what we have had

 here. We are up with the  third figure  — 5,2  and  1.  And
-------
                                                        727




                        A.  M.  Shannon






I think my suggestion is that  we try to get together on  this




if we haven't gotten together  yet.   And I  ask  Mr.  Van Den




Berg to do this because we  are getting out the report.




          We should make a  proposal  for what we think is




the detectable limit that we are going to  go down  to, and




if you don't find you have  a consensus on  that, you better




get together with the other people who are doing these




tests and come up with something that you  can  agree on.




Because unless you have this,  we are never going to get  the




program off the ground.




          I say this, not only for mercury, but we are going




to have to do this for every toxic  substance if we are going




to deal with it.




          MR. LYON:  I think if we  are going to do this, Mr.




Chairman, we should not, I  suspect,  be only concerned with




the detectable limit, but also the  range of accuracy of  the




test of the detectable limit.




          MR. STEIN:  I think  that  is one  of the big factors.




I think the ability of everyone to  do the  test and the




accuracy of the test are two of the  factors which  go into




what we universally say is  the detectable  limit.




          MR. LYON:  Because we found with our fish, there




was a 3-to-l relationship between two laboratories of the




FDA — one in Cincinnati, one  in Chicago.   So it isn't merely
-------
                                                      728

                         R. W. Purely
 «r
a question of detectable limit, but also a question of the

accuracy of the test.

          MR. STEIN:  These are the issues.

          By the way, don't think this is anything special

because we have had this over and over again in every other

substance—every other thing we have dealt with in this

field.  Not only have we had it, Food and Drug has it, and

everyone else has got the same problem.  But, gentlemen,

this just has to be worked out if we are going to move.

          Are there any other questions or problems?

          (No response.)

          If not, thank you very much, sir.

          MR. PURDY:  Mr. Stein, I have passed out a state-

ment to all the conferees and to the stenographer, that I

would like to have placed in the record as if read.  It

covers the mercury contamination problem here in Michigan

and the action that we have taken on it.  There are cer-

tain parts,in view of Mr. Atwood's statement yesterday^that

I would have liked to have gone over in detail.  But because

of the lateness of the hour, I think I will pass it up.  But

I do not agree that State and Federal officials knew about

it and didn't take action on it.

          This was a matter of where the mercury problem

was not recognized.  As soon as it was recognized, action
-------
                                                        729




                         R.  W.  Purdy






was taken on it.  Mr. Atwood didn't say it as a part of




this report, but I noted it in the paper.   It stated the




State agencies failed to take action until the newspapers




forced them to do so.




          Again, I do not agree this is the case.  And my




statement will show that it was not.




          MR. STEIN:  Without objection, that will be




entered into the record as if read.




          (The above-mentioned statement follows in its




entirety.)
-------
                                                                            730
                    STATEMENT OF R. W. PURDY, EXECUTIVE SECRETARY
                         MICHIGAN WATER RESOURCES COMMISSION

                       Regarding Mercury Contamination Problem

                                   June 3, 1970


 I  am  pleased to have this opportunity to discuss the problems of environmental contami-
 nation by mercury compounds.  We are very concerned over this matter and the State of
 Michigan has placed high priority on fully investigating and dealing with the problems
 of mercury contamination.

 The recent mercury contamination problem in the Lake St. Clair - Detroit River area came
 as a  near total surprise, without warning or anticipation.  It seems that nobody recog-
 nized the problem of mercury contamination in the United States prior to the emergence
 of certain problems within the last year.  In view of the limited, although catastrophic
 world experience with the problem, the lack of knowledge and apprehension over mercury
 throughout the United States at both State and Federal levels is a complete paradox.

 In spite of the history of mercury contamination, the problem was largely unrecognized
 in this country.  The pollution problems of the St. Clair River, Lake St. Clair, the
 Detroit River and Lake Erie have been thoroughly studied and extensively documented.
 In April of 1965, the U.S. Public Health Service of the Department of Health, Education
 and Welfare, now the Federal Water Quality Administration, with the cooperation of the
 Michigan Water Resources Commission, completed an exhaustive report on the pollution of
 the Detroit River, Michigan waters of Lake Erie, and their tributaries.   There was no
 mention of mercury problems in that report.

 The State of Michigan is also actively participating in the Lake Erie Federal-State
 Enforcement Conference and in the pollution studies of the International Joint Commission.
 The possibility of widespread mercury contamination has never been considered in these
 studies until the last two months.

 We have on many occasions collected and analyzed samples of the wastewater effluent from
 the Wyandotte Chemical  Plant which was until  recently discharging mercury compounds in
 its wastewater.  This testing was undertaken  in the development of an appropriate water
 pollution control program for this plant.  The mercury levels of this discharge were
 never considered since the need was unknown.

 In April, 1968, the report of the National  Technical Advisory Committee  on Water Quality
was published by the Federal Water Pollution  Control Administration.  This document was
 considered the most comprehensive document on water quality requirements at that time.
 It was the work of 5 subcommittees  involving  some 90 experts in the field of water pol-
 lution.   There was only a very brief mention  of mercury and there was no indication of
 its possible significance.

 In this  discussion, my point is not to justify our own lack of knowledge about mercury
 contamination of the environment but rather to emphasize a gap, a rather serious gap,
 in our present environmental protection programs.  The current mercury crisis developed
 almost overnight without warning; however,  the contamination has apparently existed for
 some time.  I strongly believe that we must take appropriate steps to ensure that any
 similar problem is recognized and countered in the early stages before serious damage
 results.
-------
                                                                             731
We first became aware of the possibility of mercury contamination in  the Great Larkes  at
a meeting on February 11, 1970 in Toronto,  Canada of the International  Joint Commission's
Advisory Board on Control of Pollution of Boundary Waters.   At that meeting, Canadian
officials indicated their concern over the  possibility of mercury contamination and re-
ported that studies were underway.

The following day, we began to investigate  possible sources  of mercury.   Of the three
chlor-alkali plants in Michigan, we found one which used mercury in its  process.   This
was the Wyandotte Chemical Company plant on the Detroit River.  Subsequent investiga-
tions revealed that this plant was discharging with its wastewater 10 to 20 pounds of
mercury per day.   At the time of initial contact with the Wyandotte Chemical Company,
the full impact of the mercury problem was  not yet known.  Company officials were cautior
about the possible pollution problem and were asked to ascertain the  exact amount of
mercury being consumed and lost.  The Company was also advised to begin an immediate
study of ways to abate the discharge of mercury.

Later in March, laboratory analyses of fish from Lake St. Clair area  waters conducted by
a California laboratory were received by Canadian officials  and because of high levels
of mercury residues, 12,000 pounds of fish  caught in Lake St.  Clair were seized by
Canadian officials.  Two weeks afterwards,  Ontario banned all  fishing on the St.
Clair River, Lake St. Clair, and the Detroit River.

A series of steps were instituted to evaluate the level of  mercury in the environment
and to pin-point possible sources in the Lake St. Clair-Detroit River area and in the
rest of the state as well.

Fish samples were collected by the Department of Natural Resources from Lake St.  Clair
for analysis by the Detroit Office of the Food and Drug Administration.   Later, fish
from throughout the state were collected for testing by the Food and  Drug Administration
and the Michigan Department of Agriculture.  We endeavored  to  enlist  the cooperation of
all laboratories in the area as quickly as  possible.  We found that only the Food and
Drug Administration could readily undertake mercury analysis.   Arrangements were subse-
quently worked out for the analysis of various samples with the Federal  Water Quality
Administration's Grosse lie (Michigan) laboratory, the Wisconsin Alumni  Research Founda-
tion's laboratory which was under contract with the Bureau  of  Commercial Fisheries,
the Phoenix and School of Public Health laboratories of the University of Michigan, and
the Dow Chemical  Company at Midland which offered its assistance.

Arrangements were also made to cooperate with the Ontario Water Resources Commission and
with the Ohio Department of Agriculture.

In succeeding days, the following additional steps were taken  to further define the mag-
nitude and scope of possible mercury contamination throughout  the state:

     a.  The Michigan Department of Public Health undertook to immediately test
         all public water systems using the St. Clair River, Lake St. Clair, or
         the Detroit River as a water supply source.  A sampling program of domes-
         tic water supplies in this area continues on a weekly basis  and will re-
         main in effect as long as considered necessary.
-------
                                                                               732
      b.- To  identify other uses of mercury or mercury compounds, all 35 pulp and
         paper mills in Michigan were contacted by telephone.  In addition, letters
         were sent to some 700 industries, commercial establishments and individuals
         requesting information on the use of mercury and also on the use of arsenic,
         cadmium, lead or any other heavy metal.  Response to this request has been
         good and information continues to be received.

      c.  Arrangements were made for the analysis of wastewater samples from some
         three dozen municipal sewage treatment plants throughout the state which
         treat industrial waste and might therefore contain mercury in their dis-
         charges.

      d.  Bottom sediment samples were collected at the mouths of major rivers
         entering the Great Lakes and also below municipal and industrial waste
         treatment plant outlets.  Fish samples were collected at these same
         locations.

      e.  The Department of Public Health undertook to examine persons in the Lake
         St. Clair area who were heavy fish consumers to ascertain if there were
         any adverse effects from the mercury contamination.

Only  two significant discharges of mercury compounds were located in the State of
Michigan.  The Wyandotte Chemical Plant on the Detroit River and a General Electric
Company plant located at Edmore, Michigan which discharged its waste to a tributary
of the Pine River.  Wyandotte Chemical proceeded to install a temporary treatment
facility which cut its mercury discharge by 80 to 90 percent to less than 2 pounds
per day.  This reduced discharge was subsequently found unacceptable and a temporary
injunction was obtained by the Michigan Attorney General prohibiting any further
mercury discharges.  Wyandotte Chemical then shut down its mercury cell chlor-alkali
operations.

Wyandotte Chemical has since formulated a plan which has been accepted by the Water
Resources Commission and entered in a circuit court consent order whereby all  process
wastewater containing mercury will be recycled to a cavity located 1200 feet underground
from  which the company obtains its salt supply.  The Company will treat the wastewater
to remove the maximum amount of mercury before recycling and is further required to
have  permanent above ground control facilities in operation in one year.  The above
ground recycling system is expected to cost about $1.5 million and when installed will
be the most sophisticated mercury control  facility known to exist in the world.

The Edmore plant of the General Electric Company was notified that all discharges con-
taining mercury must be ceased immediately or the Attorney General would be requested
to take appropriate legal action.  The Company proceeded to promptly halt all  mercury
discharges.

On April 11, Governor Milliken together with appropriate state officials conferred in
Toronto, Canada with representatives of the Canadian Federal  Government, the Province
of Ontario, U.S.  Federal  agencies, and the State of Ohio.  A key objective of the
meeting was to review the information collected by the Canadians and obtain their
assessment of the situation.   A seven point joint program was agreed upon, including
the closing by Michigan of Lake St. Clair and the St. Clair River to all fishing.
-------
                                                                            733
Later, Michigan indefinitely postponed the opening  of  the  commercial  fishing walleye
season in Lake Erie and initiated a program to  screen  all  commercial  fish  catches  in
Lake Erie for actionable levels of mercury.

As the situation presently stands, the Lake Erie commercial walleye season remains closed
We have been informed that virtually all  commercial  fishing in  the Michigan waters of
Lake Erie has stopped.   Sportfishing is permitted in Lake  Erie  however  the possession
of walleye, white bass  or sheepshead is prohibited.  The same regulations  have  also been
applied to sportfishing in Southern Lake Huron  principally because of the  migratory
habits of walleye.

In Lake St. Clair, the  St. Clair River and the  Detroit River, sportfishing is permitted
on a catch and release  basis only.  Possession  of any  fish from these waters is  illegal.
The Ontario ban on all  fishing in the St.  Clair River, Lake St.  Clair and  the Detroit
River has been discontinued.

We do not know if the mercury content of fish in Lake  St.  Clair is increasing or de-
creasing.  In order to  attempt to make such a determination, a  special  sampling  program
will be initiated to monitor particular species of fish from Lake St. Clair.  It is
planned to collect a statistically significant  sample  in July and again in the  fall for
purposes of comparison.

In investigating possible sources of mercury, we learned that mercury and  mercury
compounds are used in numerous and diverse everyday operations  such as:

     --in diaper laundries;
     --in marine and acrylic based paints;
     —in the manufacture of acetylene, polyvinylchlorides, chlorine  and caustic soda;
     --in seed, lawn and pulpwood fungicides;
     —in hospitals;
     --in mercury seals in trickling filter sewage treatment plants;
     --in mercury batteries;
     --and in paper making plants.

Possible sources of mercury, although generally small  ones, are present throughout our
society.  It is clear,  therefore, that mercury  sampling must become an  integral  part of
regular water quality and environmental monitoring.

As a result of the extensive amount of mercury  sampling that has been completed, we now
have a good estimate of the magnitude of mercury in the water environment. No  measur-
able mercury was found  in any water supply system obtaining its  water from the  St. Clair
River, Lake St. Clair,  Detroit River, or Lake Erie.  Sampling analysis  of  (a) certain
industrial wastewaters, (b) sewage in communities where industries discharge wastes to
municipal sewer systems, and (c) river bottom sediments at the  mouths of major  rivers
entering the Great Lakes and at locations  below municipal  and industrial discharges
indicated no mercury or only trace amounts.  This confirms our  earlier  belief that only
Wyandotte Chemical Corporation at Wyandotte and General Electric Company at Edmore were
the only sizeable dischargers of mercury or mercury compounds in the  state.
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                                                                            734
The Federal Water Quality Administration has completed extensive tests of
bottom sediment samples from Lake St. Clair, the Detroit River, and Lake Erie.   Their
results show no significant amounts of mercury in the sediments of the Michigan portion
of Lake St. Clair.  Mercury has been found in the sediments of the Detroit River below
the Wyandotte Chemical outfall and has been found in Lake Erie sediments in very low
levels over a wide area.

In regard to these contaminated sediments, we do not know the effective life of the
mercury constituents.  One source has suggested the effects of the pollution may last
for 10 to 100 years unless the mercury is made inactive either by its physical  removal
or by elimination of its biological availability.

We are evaluating the feasibility of removing contaminated sediments through dredging.
It has been estimated that to dredge a strip 150 feet wide, 3 feet deep and 1 mile long
of the Detroit River would cost approximately one-half million dollars.  The cost of
dredging Lake Erie, due to the large area involved, would be enormously expensive.
Dredging, moreover, could conceivably cause significant environmental damage includ-
the Possible additional releases of mercury compounds to the aquatic environment.
No conclusion has been reached as yet on the possibility of any dredging.  Efforts
are also underway to determine whether there is any possible way to chemically
neutralize or bind the mercury in bottom sediments within the affected area.  Results
to date do not indicate any practical method of chemical treatment of the contaminated
bottom sediments.

As I have stated previously, the contamination of the environment by mercury compounds
represents a serious fault in our present environmental protection programs.  Looking
back at the serious incidents which occurred in Japan and Sweden, our lack of knowledge
about the use, disposal, effects and other characteristics of mercury compounds now
appears incredible.  It is clear however, that we must institute adequate methods of
safeguarding the environment from any future catastrophies.  I see four areas which are
in need of urgent action:

     1.  A broadened environmental sampling and monitoring program to
         identify all possible environmental contaminants;

     2.  Better information on the use and disposal of the thousands of
         products, raw materials, catalysts, by-products and waste products
         involved in industrial  production;

     3.  Increased efforts to investigate the environmental effects of the
         many industrial chemicals and other substances presently in use
         and a systematic program to evaluate all new products before they
         are marketed;

     4.  A national clearing house to coordinate all  of the above activities
         and to help alert pollution control officials regarding emerging and
         potential problem situations.

On our part, Michigan has taken new initiatives to increase our efforts to safeguard the
environment.  Governor Milliken has introduced legislation to:
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                                                                            735
     1.  Require the registration of all  manufactured products,  processes,
         production materials, by-products and waste products  by all  indust-
         ries and businesses within the state which discharge  industrial
         wastewater.

     2.  Impose a surveillance fee on all commercial and industrial  enterprises
         which use the waters of the state for waste disposal  purposes.   The
         revenue raised by this surveillance fee will be used  to augment  the
         state's pollution detection, surveillance, and control  capability.

The additional funds and information that will be made available through  these measures
will enable us to provide increased protection for the environment and for our citizens.
We strongly urge that new national efforts also be undertaken  and we offer our coopera-
tion and assistance in any way possible.

Thank you.
-------
                                                       736
          MR. STEIN:   Are there any other comments or




questions?




          (No response.)




          If not, I would like to thank you all for coming.




I think we had a very, very productive session.  As with all




the sessions, they do take some time.  I think we made a




lot of progress in evaluating where we are in the cleanup




on Lake Erie and the municipal and industrial sources,  I




think it is fair to say that while the purpose of these




conferences is to emphasize the slippage, the laggards and




the places that didn't come through, if you look at the




program as a whole, you will find that we are making very




substantial progress in moving towards the cleanup of Lake




Erie.  Municipalities and industries are putting in these




remedial facilities.




          We will be getting local information in the various




workshops we conduct the week after next.  I would suggest




when all that material is in, we will call the conferees




back, I hope for a very brief session, where we can come up




with conclusions and recommendations.




          We have all made certain commitments here that I




hope will be forthcoming.  One, and I think an important




one and one that should not be overlooked, is the precedent




we have established for the State and the Federal Water
-------
                                                        737
Quality Administration to get together on the recommendation




on dredging before any deposits containing mercury are even




disturbed.  I think that may serve to be a pattern for the




country where we have this.




          The second thing,  if these dredgings are to be




disturbed, we are going to come up with a joint recommenda-




tion on where they are to be placed.




          I think we have a program here of either stopping




significant discharges of mercury into Lake Erie or taking




appropriate action.  I think all the significant sources




we know of have been named here.  We are going over those




and we should be on our way in a week.  Either they are




going to be stopped, or action is going to be taken by the




State or Federal authorities to stop them.  I think we have




taken quite a leg up on attempting to deal with the problems




inherent in controlling a toxic material such as mercury.




As far as I know, this is the first little baby step towards




a tremendous program in this whole area.




          I don't think it could have been done with a




better group of people than the people we have here in the




Lake Erie States.  I hope we are going to be able to develop




something that is going to show the way for the Nation to




get at the mercury problem and the whole question of disposal




of toxic substances.
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                                                       738
          For those of you who have stayed with us,  you may




just barely be able to see the complexity of the problem we




have to deal with.  But we are going to move forward and




meet it, I am sure.




          Are there any other comments or questions?




           MR. PURDY:  Mr. Stein, on your suggestion of a




meeting following the workshops and following this conference




here, I have in mind what took place at the so-called execu-




tive session of the Lake Michigan Enforcement Conference.  I




think we need to have citizen participation.  And it seems




to me that the meeting today and the workshop gives the




opportunity for citizen participation.  And unless we are




just going to talk something to death, we need that oppor-




tunity of gathering in an executive session so that the con-




ferees can reach recommendations and conclusions and put




something on the road here.




          And I have no objection to the open executive




sessions if we can draw up an agenda, limit the discussion




to the conferees, and move forward on recommendations and




conclusions.  If it is impossible to do this in an open




executive session, I would request that we make it at least




a semi-closed executive session so that we do more than




just talk.




          MR. STEIN:  Right.  I agree with that suggestion.
-------
                                                      739
          Let me tell you, we have opened up these proceed-



ings, as you know, in the past.  We have no secrets.  And



we have always tried to have our proceedings public, includ-



ing our executive sessions.  But if people are going to



think that part of the social revolution requires them to



come in and be heard at every meeting or disrupt the meeting



if they are not going to be heard, then we are just going to



have to resort to going into a room where we are just going



to allow the conferees and their immediate staff and



exclude the public.



          Again, I talked about being stupid and abusing



the privilege.  If that is what people want to do, they are



welcome to do it.



          I think in the Chicago situation, we were faced



with the extraordinary situation where people came in and



demanded to be heard.  And at least my judgment was that



they felt it was their public duty and they were making a



contribution to the good of mankind if they could get their



heads opened, particularly if there was a TV camera around.



We had about 18 TV cameras.



          In addition to that, we had some officials who I



think felt it was their public duty to have an opportunity



to open some heads.  So all the ducks were on the pond.  And




I think you have a very difficult situation in those cases.
-------
                                                       740
          Now, I deplore this,  and I think if we are going
f


to be faced with this, Mr. Purdy,  there is going to be no



alternative but to get a small  room, go in and lock the door



and go on with our business.   I would like you to come in and



see what we do.  But unless the public is mature enough to



recognize that it has been given a full opportunity to talk,



we are going to have a different type of executive session



from now on.  The people's privilege is there to see us go



through this, but when the time comes for an executive session,



we have to make a decision.



          MR. PURDY:  I am not criticizing your handling



of that meeting.  I just think there is not that much time



available.



          MR. STEIN:  That's right.  That is right.  I



couldn't agree with you more.



          Are we all set?



          MR. POOLE:  I commended him privately for his



handling of the Chicago meeting.  So I can't criticize him.



He had no alternative.



          MR. STEIN:  Are there any other questions or comments?



          (No response.)



          If not, thank you very much.  And we stand adjourned.



          (Whereupon, at 4:32 o'clock p.m., the hearing



adjourned.)
-------
                       CITY  OF  EUCLID
                       ENGINEERING DEPARTMENT
                           585 EAST 222nd STREET
                             EUCLID, OHIO 44123                             '
                                (216) 731-6000
 HABEY J. KNIJTH
)8BBCHSflBa{pa8aa                                               STANLEY L CESEN
     Mayor                                                       City Engineer

TONY J. SUSTARSIC
Administrative Director                June 29 * 1970
          Department of Interior
          Federal Water Quality Administration
          Washington, D. C. 202^2

          Attention:  Mr. Murray Stein
                      Chief of Enforcement

          Dear Sir:

                At the April 15th meeting of the Ohio Water Pollution
          Board, the City of Euclid made a presentation outlining
          the status of its pollution abatement program.  A copy  of
          this statement is enclosed.

                We feel that you should have a copy of this statement
          so that you will know that Euclid is progressing to the
          utmost of its ability in the pollution abatement program.

                                           Very/-truly yours,
                                           Stanley
                                           City Engineer
           LC:mb
            .cl.
          cc:   Mr. George Harlow, Director
                Lake Erie Basin Office
                Mayor Harry J. Knuth
                Administrative Director T. J. Sustarsic
-------
STATEMENT TO THE WATER POLLUTION CONTROL BOARD MEETING, APRIL 15, 1970

Mr. Chairman, Members of the Board, interested citizens:
    "t
    f The City of Euclid regrets that it was unable to comply with the original
timetable for proposed improvements and additions to its wastewater treatment
plant-. Problems associated with the site of the existing treatment plant de-
layed the submission of the engineering report and subsequent council action.
The Board was apprised as to the nature of these delays when the new target
dates were set.

      At the present time, Euclid is operating under a Water Pollution Control
Board Permit which expires October 15» 1970 and complying with the conditions
thereof as follows:

  1.  A pilot plant study is under way to determine the processes which can
      best be used at the present treatment plant site for secondary treatment
      and phosphate removal.

  2.  Upon receipt of the engineer's report of the findings of the pilot plant
      study and recommendations derived therefrom, and with the concurrence
      of the State Department of Health, the City will authorize the preparation
      of detail plans and specifications for the improvements to the treatment
      facilities.

  3.  Detail plans and specifications for sludge disposal facilities are in
      the process of preparation.

  k.  Our present treatment plant facilities are being operated satisfactorily
      by licensed operators, a fact which was confirmed by a recent inspection
      by the Health Department. Monthly and annual operating reports are being
      submitted to the Health Department.

  5.  The program for reducing the amount of storm water in the sanitary sewers
      is being carried out vigorously. In several areas, new sewers and
      connections have been built, are under construction or are being designed
      which will result in the elimination of storm water from the sanitary
      sewer system.

  6.  The City is continuing its monitoring of industries discharging wastewater
      to the Euclid sanitary sewers and drains. A City permit system is used.
      Industries which perform pretreatment submit monthly operating reports
      to the City.  These reports are reviewed by the City's wastewater chemist.
      Frequent visits are made to plants and samples from the sewer system are
      collected and tested periodically.

      The City of Euclid expects to have construction of its wastewater treat-
ment plant improvements completed by December 1, 1972.

                                      Respectfully submitted
                                      The City of Suelid
      ft U. S. GOVERNMENT PRINTING OFFICE : 1970 O - 407-609 (Vol. H)
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North Wacker



                60606
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