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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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.)
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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
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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 -
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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 .
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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.
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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
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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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-------
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-------
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-------
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-------
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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
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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.
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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.
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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.
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473
G. J. Remus
Now, in this interceptor construction, we agreed
to provide service for Mount Clemens. Mount Clemens has
agreed they would have an engineering study made which they
did. And about 2 weeks ago, their study came in and said,
"You should join the Detroit system." Within the week,
they had hired another set of engineers. And within that
same week, we already knew the conclusion was going to be
the opposite.
Now, it is those type of things that we think
there has to be pressure put on to either do it or not do
it. But I don't think that we should be committing $169
or $159 million worth of construction and then be badgered
with that type of stuff.
I would like to point out while we are in this
same area that we are building through the city of Warren
a 12-foot sewer. That sewer is big enough to take care of
Warren's requirements as per our contract with Macomb County.
We are going to holler from here to kingdom come if they
should suddenly get a grant because we are building that
property through there at their request. And we did it
when they had a building ban. And we corrected it after-
wards .
I would like to point out, and I will refer to
that later, that Warren has now challenged the State and
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474
G. J. Remus
Federal Government on their grant program. And if they
should win, I would point out that that is probably the last
intercept that the central system will build. Because if
we cannot depend on our revenues, we cannot build for the
future.
This interceptor situation, of course, is paid
for entirely by the revenues we expected to collect and by
the revenue bonds we issued for our portion of the construc-
tion.
I would like to refer to a part of this problem
which is not in our stipulations. But by the very nature
of the fact that we commit our money to where we get the
best results, we have gotten deeply involved with the storm-
flow as it is now. I will use one example. On May 25 this
year, we had an average rainfall of .47 of an inch over the
city of Detroit that lasted for 45 minutes. And the inten-
sity was as much as .95 of an inch. All of that was treated.
If it had not been, there would have been a large tonnage
going to BOD and solids going to the Detroit River.
In doing this, it cost us considerable extra
money in our operations because we pump our system which is
made up of several 16-foot tunnels, two 12 by 17 foot
channels. And we keep it empty, particularly just prior to
a storm. And we have just recently put in operation a
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475
G. J. Remus
monitoring and telemetering system data logger which the
Federal Government helped pay for — roughly 50-50 — wherein
we have 138 sensor units throughout the city that give us
sewer levels, storm intensity, the rapidity with which it
goes across the city. And we think for the first time that
we are beginning to make some real progress with this
stormflow.
I mention this because I don't see how we can put
in an activated sludge plant with all the construction at
the sewage plant without also going at this stormflow
system. We expect to expand that to the area. And in that
way, we will be able to know when a storm comes in from
Toledo to Lansing and Flint and Ontario and the whole area.
There is a part of our operations that, again, is
not reflected in the stipulations. And that is what we call
pollution prevention. Mr. Kallin of Ford Motor Company only
talks about those things that they are under the gun on. He
forgot to mention that we are taking a good slice of his
problem up in Sterling Township and taking care of it for
him as we are for General Motors, as we are for Chrysler.
Of particular importance is the fact that in the
area that we serve, the Clinton River down to the Rouge
River, there is no industry in the white or yellow area that
discharges into the Detroit River or into the receiving
-------
476
G. J. Remus
waters. All their waste goes through the public system.
We do the job for them to the extent that our system can
handle their wastes. We have the proper ordinances, and
we have about 6 men working on it all the time, to work
cooperatively with industry to get our system in such a
shape that we can handle our wastes. And if we can't, they
have to put them in a preparatory position so they can be
handled.
Some of the principal ones, one that isn't men-
tioned in the report, is Scott Paper Company. And, of
course, that isn't under the gun right now. But that plant
was right across from our sewage plant. On the basis of
the orders given it, it would have had to shut down if we
hadn't worked out a program with them because they had no
space to build facilities. They are paying us today on the
basis of the extra wastes we treat for them a little better
than $580 a day. And it was with the cooperative effort
with them because they felt it was important.
There are plenty of examples of what I think has
to have a great deal of pressure. And that is pollution
prevention, partly to control what comes into our system,
partly — somebody referred to salt. Last year, there were
406 million pounds of salt in the metropolitan area dumped
on the streets.
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477
G. J. Remus
Now, I hear some conversation it doesn't do any
harm. Are we going to wait until the mess is here and
then clean it up? If we are going to do that, people that
are in our type of job will be forever under the lash of
somebody. Because if we are going to wait until these
messes are created, then you are never going to clean them
up.
We have the same comments on other heavy metal
wastes, on detergents. We think that a better job could be
done there. Our common counsel has adopted a ruling to ask
the State to adopt the law asking that not more than 10
percent phosphate be allowed on the market.
Now, if you are referring to page 8, you will see
what construction would be done by the $90 million that I
have referred to. I would like, however, to talk a little
bit about the money, the financing.
On the basic $80 million that we have, we ordered
$74 million of contract. But on the basis of the $80 million
that was scheduled — and the last part of it will be awarded
this month — the Federal Government should have provided
$44 million. The State should have provided $20 million.
And we should have provided $20 million. That is on the
basis of the law that is on the land.
Since the Federal appropriations were not financed,
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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.)
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(1D.C3'!(;.'„;-
E. W.
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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
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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-
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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.
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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-
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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
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-------
- 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.
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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.
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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
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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.)
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604
LAKE ERIE
ENFORCEMENT CONFERENCE
PROGRESS REPORT
REPORT TO THE CONFEREES
Detroit, Michigan
Submitted by
THE NEW YORK STATE DEPARTMENT OF HEALTH
HOLLIS S. INGRAHAM, M.D., COMMISSIONER
-------
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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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
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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.
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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
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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
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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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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-
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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
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648
L. A. Van Den Berg
carbonates. The high density is responsible for the rapid
deposition in bottom sediments where they persist, become
subject to sediment transport and are available to the
aquatic life.
Metallic mercury can be oxidized readily to divalent
mercury ions under the conditions present at the bottom of
lakes and rivers. This has been shown to occur experimentally
as well. The divalent inorganic mercury produced has an
extremely strong affinity for organic muds and is methylated
in the bottom sediments. Divalent organic mercury, when
methylated, is readily released from the sediments into the
water.
Many fish are bottom feeders or feed upon organisms
which are bottom dwellers and therefore the hazard of mercury
ingestion becomes very great. Pish also absorb mercury from
the water through the gills and possibly the scales.
Since biological concentration of mercury occurs,
the accumulation of mercury in the food chain is a matter of
grave concern. A recent report indicates a magnification or
concentration of mercury of over a million in the protoplasm
of bacterial species. It has been demonstrated that the con-
centration from water to pike is in the order of 3,000 or more.
Uses of Mercury
Sources of mercury in the environment principally
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649
L. A. Van Den Berg
•come from industrial processes utilizing a form of mercury
and the use of mercurial products by man.
The industrial uses in 1968 are listed as follows:
These values are in thousands of pounds.
1. Electrical apparatus 1,492
2. Electrolytic preparation of
chlorine and caustic soda 1,326
3. Paints 803
4. Charging new installations of
chlorine and caustic soda cells 630
5. Industrial and control instruments 581
6. Agricultural uses 260
7. Dental preparations 158
8. Catalyst preparations 145
9. Laboratory uses 151
10. Pharmaceuticals 32
11. Pulp and paper uses 31
12. Amalgamation 20
Mercury is used as the cathode in the electrolytic
manufacture of chlorine with caustic soda and hydrogen as
by-products. Cell recharging to make up the various losses
from this process was 26 percent of the total mercury used
in 1968 by all industries. To maintain the mercury inven-
tory it required purchases of 1.3 million pounds of mercury
in 1968. Weak spent brines, acids from the chlorine driers,
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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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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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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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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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L. A. Van Den Berg
•may also be resolubilized by the waterbody dependent upon
environmental conditions such as pH, temperature and concen-
trations of other metals present. Some of these metals may
also be detrimental to aquatic organisms when concentrated
in the food web.
Summary and conclusions, page 1.
1. Data provided for the Bureau of Commercial Fisheries,
Technological Laboratory, Ann Arbor, Michigan, show that
mercury was present in fish throughout the St. Clair River-
Lake Erie system. Concentrations (parts per million, wet
weight) in the edible portions of various fish were: Keep
in mind the F.D.A. limit 0.5 ppm.
Yellow Perch 0.32 to 1.70
Northern Pike 0.64
Coho Salmon 0.24 to 0.96
Carp 0.08 to 0.28
White Bass 0.53 to 0.80
Steelhead less than 0.15
Walleye Pike 1.4 to 3.57
Channel Catfish 0.32 to 1.8
Gizzard Shad 0.24
Sucker 0.88
Sheepshead 0.24
2. Available information indicates that no measurable
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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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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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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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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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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
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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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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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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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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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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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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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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
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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.
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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
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. 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
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-------
-------
-------
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
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w
V
\
V
V
t
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L.
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f
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•
(Outlet
'
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t
Earth Dike |-|
1 7 / 1 1 1 I f 1 1 1 \ III
1 1>^
Reaction Pond
O
a>
c
c
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a:
c
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0
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Limestone Storage §
FWOA
Sample Pt.
/ W23
if Discharge
"X I3.5MGD
kj
$
1
^
^ Q
1 k
^i
^ i
^0 1
1
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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.
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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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