PROCEEDINGS
                   VOLUMES
Conference
 In the matter of Pollution of
 the navigable waters of the
 Detroit River and Lake Erie
 and their Tributaries in the
 State of Michigan
                       SECOND SESSION
                       JUNE 15-18, 1965
U. S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

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                 VOLUME 5
Conference
In the matter of Pollution of
the navigable waters of the
Detroit River and Lake Erie
and their Tributaries in the
State of Michigan
SECOND SESSION J U N E 15-18, 1 965
        U.S. DEPARTMENT OF
   HEALTH, EDUCATION, AND WELFARE
        Public Health Service

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                  CONTENTS
                                                    PAGE:
OPENING STATEMENT
        By Mr. Stein

STATEMENT OF:

REPRESENTATIVE JOHN D. DINGELL

REPRESENTATIVE WILLIAM D. FORD

RICHARD D. VAUGHAN

GEORGE L. HARLOW

ERNEST PREMETZ

GOVERNOR GEORGE ROMNEY

GOVERNOR JAMES RHODES

REPRESENTATIVE WESTON E. VIVIAN

COLONEL EDWARD C. BRUCE

LIEUTENANT MAURICE S0 POWER

KENNETH MACKENTHUN

GERALD EDDY

RALPH PURDY
JOHN E. VOGT
C. C. CRUMLEY
AL BARBOUR
MERLIN DAMON
TODD Ao GAYER
JOHN CHASCSA
GERALD REMUS
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                                                       1-A
                 CONTENTS
 STATEMENT  OF:

 GERARD H.  COLEMAN

 GEORGE E.  HUBBELL

 GEORGE J.  HAZEY

 GENE  LITTLE

 JAMES D. OGDEN

 OLGA  M. MADAR

 FRED  E. TUCKER

 HAYSE H. BLACK

 ROBERT c.  MCLAUGHLIN

 FRANK KALLIN

 A. J.  VON  FRANK

 ROBERT P.  LOGAN

 JACK  T. GARRETT

WILLIAM R. DAY

 J. W.  TRACHT

C. D.  BARRETT, SR., M.D.

STANLEY DIROFF

WILLIS H. HALL

CLOSING STATEMENT
      Mr. Stein
PAGE:



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                                                         1230
             THURSDAY, JUNE 17, 1965



                   9:30 A. M.








             MR. STEIN:  May we reconvene?




             If we have to meet tomorrow, and as it looks



we very well will, we will have a slightly different loca-



tion.  The meeting will be in this building in the Lecture



Room, which will be marked when you come in.  I understand



the Lecture Room is Room 400, and there will be ample room.



             To get to the Lecture Room, you should come



in through the front door of the Museum.



             We will call on Mr. Oeming again.



             Mr. Oeming?



             MR. OEMING:  Chairman Stein and Mr. Poston,




the schedule this morning is to hear from municipalities




and other local governmental units who have expressed a



desire to present a statement.




             I have placed these in the order of taking the




Detroit area first, both with respect to municipalities and



governmental units, and then the industries in the Detroit



area, but starting out with the municipalities and govern-




mental units.



             With that, I would like to provide the oppor-



tunity for the City of Detroit to present its statement,

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                                                        1231
                  Gerald Remus
and at this time I would like to call on Mr. Remus.

               STATEMENT OF GERALD REMUS, MANAGER,
               SEWAGE TREATMENT WORKS, DETROIT,
                         MICHIGAN

             MR. REMUS:  Conferees, members interested in
this pollution problem:
             We have here presented to the Conferees a
report which I will not read in its entirety, and just dis-
cuss the essential points.  I would, however, like to have
this entered as part of a complete record.
             MR. STEIN:  Without objection, that will be
done, and will be entered as if read, including the charts
and mapSo

             (The Report of the Sewage Treatment Works,
City of Detroit, is as follows.)

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                                                      1232



                  G. Remus
         GREATER DETROIT'S PROGRAM




                  FOR




            POLLUTION CONTROL




              June 17, 1965
                SECTION I




                SUMMATION








              "Our conservation must not Just be the




 classic conservation of protection and development, but




 a creative conservation of restoration and innovation."




              These words were used by the President of the




 United States earlier this year in a message to Congress




 in which he provided guidelines for improving America's




 Natural Beauty.  From that message the words "stream




 renewal" have sprung.  When applied to the Detroit River




 the term is a new one.  But the practice of renewing the



 Detroit River has been under way for a quarter century.




              Detroit's stream renewal program has carried




 for many years the unglamorous title of "metropolitan




 sewage treatment system".




             Detroit's first step in this renewal pro-




gram was in 19^-0 with the opening of a sewage treatment




plant.

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                                                        1233



                   G. Remus



             In 1957 renewal efforts were accelerated with




a plant expansion program and added emphasis on a metro-




politan pollution control program.




             Since 1957, Detroit and the counties of Wayne,



Oakland and Macomb have spent more than $266,000,000 for




pollution control.  Detroit's share exceeds $75,000,000.



             The improvements can be measured, especially




in the upper Detroit River.  Yet much is to be done.  The



job of stream renewal is not complete.  Although the



Detroit area is regarded as a leader in the field of



pollution control, we are not content to rest with past



performances.




             As we see it, there are three major areas



in which we must work.



             One is to develop for the Detroit River



drainage basin an efficient, economical waste collection




system.  Another is to install the necessary treatment



processes as research, health standards and pollution con-




trol criteria dictate.  A third area concerns primarily



the beautification of our waters, which can be improved



greatly through the stabilization of water levels.  Such




a proposal is now being studied by the International Joint




Commission and is under consideration by the National




Rivers and Harbors Congress.

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                                                      1234




                   G. Remus




             One needs only to look at the topographical




map of the six-county Detroit area to see why one effective




sewage collection system is needed.




             Four major tributary rivers on the Michigan




side of the River—the Clinton, the Rouge, the Huron, and




the Raisin—drain into the Lake St. Glair - Detroit River -




western Lake Erie complex.



             These four rivers carry with them the septic




tank seepage, industrial wastes, street and field drainage




containing fertilizers, pesticides and insecticides of an




area of more than 3,200 square miles.




             Added to the growing Canadian petroleum and




chemical industry along the St. Glair River, these four




rivers negate much of the recent progress made in the




water quality of the Detroit River.  They also hamper




ftrther improvements.




             For example:




             The Clinton River, which because of its small




flow, is expected to be more than 50 per cent sewage plant




effluent in 15 years.  The Clinton River drains into Lake



St. Glair.




             The Raisin River, which flows directly into




western Lake Erie, and septic tank runoff from the area




are cited by the United States Public Health Service as

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                                                        1235
                   G. Remus
the cause  of the periodic contamination of the waters at
Sterling State Park.
             The present pattern of pollution control at
the local  level is highly fragmented.  There are more than
60 sewage  treatment plants in the six-county area.  The
result  is  a piecemeal approach which fosters costly dupli-
cation  of  facilities and service.
             A similar condition existed ten years ago in
the field  of water supply.  However, a metropolitan water
supply  system has been developed which proves that a regional
approach to a regional problem results in an economical,
efficient  service to participating communities.
             The benefits of the Detroit metropolitan water
system  are now enjoyed by 62 communities, including Detroit,
comprising more than 40 per cent of Michigan's population.
The Detroit area--unlike New York City for example--has an
abundant supply of fresh, high quality water at one of the
lowest  rates in the United States.
             In 1957 the Detroit Department of Water Supply
proposed an areawide pollution control system, organized
along the  same lines as the water system.  That plan was
expanded into a program adopted earlier this year by the
Detroit Board of Water Commissioners.  The expanded 1965
program carries the approval of the Michigan State De-

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                                                      1236



                   G. Remus




partment of Health, as did the 1957 program.



             Basically, that program calls for a -unified



method of cleaning the tributary streams leading to the



Lake-St. Glair - Detroit River - western Lake Erie complex.



             Areas and industry not now adequately served




by water pollution control facilities or which are not



served at all would be brought into a central system.



That  is expected to require $181,000,000 worth of con-



struction which can be financed locally without imposing



unreal fiscal burdens on homeowners or industry.



             The metropolitan Detroit stream renewal pro-



gram  also calls for the continuation of research experi-



ments to develop better methods of treating, especially



storm overflow and industrial wastes.




             Technicians in the field of waste treatment



have  not yet reached agreement on the criteria of treatment



needed for our Lake St. Glair - Detroit River - Lake Erie



complex.  A consensus is being sought by the responsible



agencies involved.



             A consensus also is necessary concerning the



data  collected by the United States Public Health Service



in the recent study of Detroit area waters.




             Important differences exist between the data




collected by the Federal technicians over two four-day

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                                                       1237

                   G-» Remus

periods and the data collected by local technicians over

the period of many years.  These differences involve BOD,

settleable solids, and suspended solids, each an important

measurement of water quality.

             The inconsistency of data exceeds the accept-

able limits of experimental error.

             For example:

                          DWS                 USPHS
                    Number of  Per Cent  Number of  Per Cent
                     Samples   Removal    Samples   Removal

Suspended solids      9125       ^9.5       16        39

Settleable solids     9125       84.3       16        52

BOD                   9125       37.2        8        17

             Detroit's program is dedicated, organized, and

financed so that as the area develops and the economy ex-

pands, the system will keep pace.  It is an area answer to

an area problem.

             The United States Public Health Service re-

port reflects only on technical aspects, and omits an ans-

wer for administration and financing, and fosters the con-

tinuation of piecemeal handling of a regional problem.

             Our treatment standards are ever improving,

and further improvements will be made as studies clearly

indicate what constitutes sound procedure.

             Secondary treatment  cannot be  recommended at

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                                                       1238
                   G. Remus
this time because we are not in agreement on the basic
data from which to form judgments, nor can anyone tell
how much the river's quality will be improved.
             We do not, however, intend to pause in our
stream renewal efforts.  We intend to offer help in all
areas, particularly downriver, with our financial and
administrative capability, to bring all areas up to State
standards.
             We are now experimenting with improved
filtration and chlorination methods at the Sewage Treat-
ment Plant.
             We are constructing and will continue to con-
struct another $50,000,000 worth of storm flow capacity,
which will further reduce the "first flush of the storm".
We will be stepping up considerably our cooperative pro-
gram with industry, so that only wastes than can be ade-
quately treated at the treatment plant will be accepted
into the system.  Wastes are ever changing, particularly
in the chemical, radioactive, and the new space age
metalurgy techniques.
             The USPHS report reflects only a bad situation
after it has occurred.  We believe that for the benefit
of industry, as well as for our operations, a good pre-
ventative pollution program will do the most good.  We

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                                                      1239
                   G. Remus

have already put this idea into action.

          The rapid increase of the areas we serve will

rapidly eliminate the great portion of the 177,000 septic

tanks of the drainage area, as well as many inefficient

subdivision treatment plants.

          Continued and expanded efforts will be directed

toward improving the quality of the waters of the main

tributaries that discharge into the Detroit River.  Installa-

tion of control and research instrumentation on Detroit's

system is underway and will be stepped up as soon as 50-50

matching funds become available under Federal study grants.

          Twenty-four hour control personnel will be on

duty and properly operating our many storm pumping stations.

We will be able to reduce considerably the storm flow problem.

          Grease, oils, and phenols will be reduced further.

Improved treatment will be installed for those wastes where

definite eliminating processes exist, and research with

pilot plant operation will be supported in every way with

Federal, State, and local officials.

          Our entire financial capability is committed to

expansion with gradual improvement.  Our financial position

is such that we can match funds and immediately step up our

research, our treatment standards, or our development, directly

in proportion to the additional funds that are made available.

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                                                     1239-A



                    G.  Remus




          Again, we reemphaslze that we intend to continue




our stream renewal program — by expanding our areawide




operations, by improving our treatment processes, with




special attention to pollution prevention, and by energetic




study to control the wastes for which technology has no




solution.




          And finally,  here and now, we challenge anyone on




the Great Lakes, particularly in southwest Wayne County, and




all communities on the  Rouge, the Huron, the Raisin, and




the Clinton Rivers to match our record of improvement and



to keep up with us in the future.

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                                         1239-B
       SECTION II
PROGRAM AND ACHIEVEMENTS
        THE ISSUE

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                                                     1240

                   6. Remus
             The Detroit River must be improved and the
issue is:  how can this be done best with  the available

money.

             The Detroit Department of Water Supply after

a thorough technical study in 1957 adopted & program to

clean up streams, recognizing that the job must be done on

an area basis, and that not only was it necessary to decide

on what had to be done but how it was to be administrated

aj£ financed.  Today our sewage system serves Detroit and

49 neighboring communities.

             The Detroit anti-pollution program calls for

the same methods of development that are being used to

build the metropolitan water system, now serving Detroit

and 6l neighboring communities--better than 40 per cent of

the State's population.  We all remember that ten years

ago Detroit was on short water supply, a difficulty that

has-now been corrected.

             We have gradually improved the Detroit River

down to the Rouge River—the area of our responsibility—

simultaneously handling the additional pollution load

brought about by the rapid development of  the metropolitan

area.

             In 1964, a Board of Sanitary  Engineering

experts reaffirmed that Detroit's program  of first or-

ganizing a regional system, with improved  treatment  to

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                                                      1241
                     G.  Remus

follow, would do more toward cleaning up all waters of the

area than would higher treatment standards for a limited

area at this time.

          Modern sewage treatment (secondary treatment

included) cannot eliminate many of the wastes that degrade

our waters.  We are researching all phases of this in

cooperation with Federal and State agencies.

          Pollution is an area problem, and correcting it

must be on this basis.  Our financing base and organization

have been and will continue to help the area, gradually

raising our standards throughout the entire drainage basin.


                 WHAT HAS DETROIT ACHIEVED?


          The City of Detroit has been developing and

Improving its metropolitan area pollution control program

continuously since its Sewage Treatment Plant went into

service in 19^0.  In 1957 our war on water pollution was

renewed by launching a $33,000,000 enlargement and improve-

ment program.  A rate Increase of 77 percent was asked for

and approved to finance this work.

              1.  Area Sewage Treated Since 1940.

          The initial treatment plant, interceptors, lift

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                                                       1242


                   G. Remus


stations and regulators were placed in service in 19^0,


at a cost of $7,379,000.  Provisions were made in the basic


design and construction for a plant that would serve


4,000,000 people.


             2«  1937 Program


             By 1957 the population served had reached


approximately 2,500,000.  The number of suburban communities


served had reached 35.  And another $32,79^,000 was com-


mitted by Detroit for pollution control facilities.


             The advantages of a metropolitan sewage dis-


posal system were established and now recognized, because


this commitment was one of the larger factors that
                                v

triggered additional interceptor,  treatment,  and pumping


station construction totalling $266,900,000 for the three-


county area of Wayne, Macomb and Oakland.


             Exhibits A and B delineate the program.


             The program was approved by the Michigan


Department of Health in 1958.  The Department of Water


Supply (DWS) and the Michigan Department of Health mutually


agreed that improved treatment processes would be adopted


when all factors, findings and technical data would clearly


indicate what the proper improvement should be for the


public's health and welfare.


             In 1963  the program was  amended to provide

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                                                       5.243




                    G.  Remus



 for the construction of an Interceptor to Oakland and




 Macomb Counties,  to eliminate the necessity for con-



 structing another treatment plant on the already over-



 loaded Clinton River.   Also, it was during this period




 that all of the domestic pollution going into the Rouge




 River was accepted into Detroit's treatment plant.



              The  work scheduled in the 1957 program which




 has been completed is:



              Additional sedimentation tanks



              Additional sludge filters



              Enlarged effluent conduits



              An emergency outfall



              Additional sludge incinerators



              Additional ash lagoons



              Smoke abatement at the Sewage Treatment Plant



              The  Northwest Interceptor



              Additional regulators and diversion devices



              Puritan Pumping Station




              Improved operation of the system during



 storm run-off



              Improved bacteriological treatment



 In addition, nearly $50,000,000 has been expended by the




 City of Detroit for additional relief sewers.  These sewers




also serve as  storm water storage devices and net to reduce

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                                                       1244



                   G. Remus




the amount of combined sewer overflows.




             3.  Progress



             The record shows that we and the munici-




palities of the Detroit metropolitan area are voluntary




leaders in actively controlling water pollution.




             All work done by the Detroit system was done




without the necessity of any court order.  And a "building




ban", caused by improper sewage facilities, was not




necessary in Detroit or any area that we provide service




for.








            WHAT WERE THE RESULTS?








             The condition of the Detroit River adjacent




to our service area, which is composed of Detroit and 50




suburban communities above the Rouge River, has been con-




tinuously improving even though the waste produced in the




area has increased rapidly due to industrial and commercial




expansion and residential construction.  It should be




recognized here that much of the area expansion was in



turn made possible by the existence of a suitable metro-



politan sewage disposal system.




             There are several measurements which establish



that the Detroit River is being improved:

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                                                      1245




                   G. Remus



             1.  Colifona Bacteria Reduction



             Continual tests are taken to evaluate the



quantity of harmful bacteria in the river.  Tabulated be-



low are the highest median coliform counts per 100 ml



found in a sampling range across the Detroit River down-



stream from Detroit's Sewage Treatment Plant outfall but



upstream from the mouth of the Rouge River.



Year  American Shore  Canadian Shore  I.J.C. Standard
1959
1960
1961
1962
1963
1964
68,000
23,000
53,000
l,6oo
580
930
11,300
4,300
4,300
9,300
4,300
3,350
2,400
2,400
2,400
2,400
2,4oo
2,400
The I.J.C. acceptable standard as agreed upon by the



United States and Canada is a coliform MPN median value



of 2400/100 ml.  The usual standard for bathing beaches



is that bacterial pollution shall not exceed 1000 organisms




per 100 mis.



             Thus, except during storm periods, the portion
                          f             '


of the river within the area of our responsibility meets




the bacterial requirements for approved bathing beaches.




             2.  Reduction of Combined Sewer Overflows




             Through improved operation of the Sewage

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                                                        1246




                   G. Remus




Treatment Plant and pumping stations and by the con-




struction of additional relief sewers and pumping stations,




we have been able to reduce the quantity of combined




sewer overflows as well as the solids content.  For example,




the quantity of storm flow pumped into the Conner's Creek




channel was reduced from 7,100,877,800 gallons in 1959 to




3,328,510,900 gallons in 1964 and the number of days on




which pumpage occurred was reduced from 6l to 41.  These




figures would have been much larger if the area were




served by separated sewers.




             3.  Reduction in Industrial Wastes Loading




             Since 19^8, the grease and oils found  in the




Detroit River have been reduced 79$, phenols 71#, ammonia




22$, cyanides 12% and suspended solids 51#.   It must be




recognized that oils, gasoline and other chemical pro-




ducts spilled anywhere in the Great Lakes drainage  basin,




whether caused by accident or by traffic, will eventually




find their way to our rivers and lakes through the  storm




drainage process, and it is doubtful, therefore, that they




can be entirely eliminated.  Where possible, these  wastes



must be controlled at the source.








             WHAT IS BEING DONE?









             1.  Work Under  Contract

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                                                       1247




                   G. Remus




             Nearly $2,200,000 worth of work is now under




contract for improvements at the plant:




             Improved and expanded sludge handling




facilities




             Improved sludge conditioning facilities




             Improved and expanded sludge filtration




capacity




             Development of a pneumatic ash handling




system




             Improved smoke abatement equipment




             Combined flow interceptor and pumping station




             2.  Operation and Maintenance




             Over $5,000,000 is being expended annually




for operation and maintenance of the sewage treatment




system.




             New filtration practices for half of the plant




are now functioning.




             Our forces are refurbishing all diversion




and regulating devices.




             Improved pumping techniques have kept all




interceptors and trunks cleaner, thereby reducing the




first flush of storms.




             3.  Suburban Service




             We are working with suburban communities

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                                                      1248
                   G. Remus
to arrange for providing sewage disposal service to addi-
tional areas throughout the metropolitan system and to ob-
tain the necessary storm water and sanitary sewage
collection capacity thereby eliminating many septic tanks
and reducing the pollution load on the Detroit River
tributaries.  (See Exhibits C and IX)
             4.  Relief Sewers
             The City of Detroit is proceeding to con-
struct another $50,000,000 worth of relief sewers which
will provide additional storm water detention.
             5.  Objectives
             Our program is to unify and coordinate
sewage disposal throughout the metropolitan area so that
all inhabitants of the area may enjoy the economies of a
large single system and be assured that their wastes are
being disposed of in a responsible manner.  Toward that
end steps are being taken to improve the adequacy and
efficiency of the treatment plant and collecting system,
and efforts are being made to reduce combined sewer spills.
             By expanding the system as the metropolitan
area builds up, the 177,000 septic tanks yet existent will
be gradually reduced.

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                                                      1249




                   G. Remus








               WHAT WORK  IS PLANNED?








             1.  Program




             The 1957 basic program will continue and




be expanded.




             The recently released report on Metropolitan




Sewerage  and Sewage Disposal, prepared for the Supervisors




Inter-County Committee by the National Sanitation Founda-




tion,  recommended  that about $180,000,000 worth of treat-




ment plant  and interceptor facilities be constructed in




the metropolitan area within the next 18 years, and that




the single  system  for the area be administered by the




Detroit Department of Water Supply because of its proven




ability and financial capability. (NSF Summary, Con-




clusions  and Recommendations - Exhibit A-l.  Copies of




full report available from National Sanitation Foundation.)




             The program  calls for expansion of the treat-




ment plant  under a design to serve an ultimate population




of 7,500,000 and construction of additional sanitary inter-




ceptors to  relieve and supplement the existing combined




flow interceptors.




             The Board of Water Commissioners has endorsed




the recommendations for expansion and plans  to proceed with

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                                                     1250
                   G. Remus
the work, in full recognition of the fact that the en-
tire metropolitan area will benefit by organizing under
one administration and pooling financial capability and
pollution control efforts.
             See Exhibits A-l, C, D, E, F and G.
             Detroit's basic program was not only sub-
scribed to by the Supervisors Inter-County Committee
(SICC) but also by another blue ribbon research committee.
Metropolitan Fund, Inc., endorsed this as the best type of
procedure. Their report was released in May, 19&5.
             2.  Major Projects
             Some of the major projects scheduled for
the near future are:
             Additional sedimentation tanks
             Interceptors for Oakland and Macomb Counties
             Complete monitoring of the system
             Remote control of the system
             Preventatlve sewer cleaning
             More disinfection
             Improved and expanded sludge filtration
capacity.
             Improved regulating and diverting devices
             Whatever treatment is necessary to protect
the public's health and welfare.

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                                                        1251




                    G.  Remus




              3.   Objectives




              The program as now planned  will  provide  for




 the interception of additional  sanitary  wastes not now




 treated,  the removal of a greater proportion  of  solid




 wastes and BOD,  and the reduction of  combined sewer




 overflows.  New  ideas for improved treatment  will be




 adopted as they  become perfected.




              4.   Deleterious Wastes




              Beginning this year,  the City will  Increase




 its annual expenditures $100,000 for  the purpose of stepping




 up enforcement action of the City's deleterious  waste or-




 dinances, by locating and stopping the dumping of excessive




 quantities of certain types of  industrial wastes into the




 metropolitan system.  It will be required that floating




 oils and greases, phenols,  cyanides,  and other undesirable




 synthetic or natural wastes be  treated at the source  because




 these wastes are more practical to treat before  becoming




 highly diluted.




              5.   Cooperation with  Industry




              The City will  work with  industry to find and



 adopt practical  methods for the pretreatment  of  objection-




 able types of wastes.   It has been found that some wastes




 can  be  converted to  an  acceptable  type of waste which




can then be discharged  into  the  sewer  system  without  en-

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                                                      1252




                   G.  Remus




dangering water quality.  This avenue provides one of




the greatest opportunities for improvement.




             6.  Water Program




             Prior to  1956 water shortages were plaguing




the Detroit suburban areas, such as is now the case in




many other regions of  the United States.   In 1956 the




Department of Water Supply began its program of financing




and constructing water transmission mains and pumping




stations in suburban areas to serve these areas.  The




areawide water problem has been solved and we are well




ahead of the problem.   The consumers are  enjoying the




lowest water rates of  any metropolitan area in the country.




             We are proceeding to handle  the sewage disposal




problem in the same effective manner under the provisions




of our 1957 program.




             In each of these programs (water and sewage




disposal) there exists an uneconomical portion of a com-




plete system development.  We refer to the potential re-




sidential, commercial  and industrial activity not yet



existent to properly finance the water and sewerage




utilities needed.  These have been financed by a com-




bination of Federal funds and under the portion of our




policy that allows us  to spend system funds even though




the service is not  self-supporting for five years.   This

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                                                      1253




                   G. Remus




has helped a great deal in aiding the metropolitan area




prosperity.




             7.  Stream Water Quality to be Renewed




             We believe that our program as planned will




provide a high degree of pollution control, and that its




beneficial effect upon the waters in the Detroit River




will be as great as can be achieved by the application




of any practical technology now known.




             We have been continually perfecting our pro-




gram to effectively control water pollution.  The water




supply and sewage treatment aspects of water quality con-




trol is one economic problem.




             The water shortages of 195^ have been




corrected.  The increased demand for water due to extra-




ordinary activity has also been provided for, and we are




organized to develop more supply as needed—all without




tax money.




             Likewise, the sewage treatment costs are now




paid for entirely on a revenue basis, and our financing



capability is ever-increasing.



             It follows,however, that we cannot finance




both area expansion and simultaneously raise treatment




costs more than threefold and still provide the services




to support area development.

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                                                       1254
                   G. Remus
             Since the cost of sewage treatment is added
to the cost of water, it follows that if either is raised
too high, the usage of water drops and net revenues do
not increase proportionately, and systematically by this
method we will destroy our financing base.

               WHAT IS REQUIRED?

             Effluent quality standards alone provide
no assurance of an effective waste water management
program.  Many other conditions are vital to a program
of pollution control.
             1.  One Administrative Agency
             A single metropolitan sewage disposal sys-
tem is essential since complete pollution control cannot
realistically be achieved if each community proceeds to
develop its own system.  A large single system also makes
it possible for the inhabitants of the area to fulfill
their pollution control responsibilities in a more economi-
cal manner.
             2.  Financial Assurance
             A sound and adequate financial base with good
prospects for its continuation is required to provide for
the continual  expansion,  improvement and operation of the

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                                                        1255



                    G.  Remus




 system.   All  financing to improve  the basic  system  is




 now  done  by revenue bonds, with  a  class  "A"  rating.  Tax




 money is  not  needed for orderly  system expansion.




              3.   Feasibility Studies  (Research)




              Standards set by regulatory agencies must take




 into consideration the economic  and physical  feasibility  of




 controlling each type  of pollutant as stated  in Section




 8 (g) of  the  U.S.  Water Pollution  Control Act  (PL 660).




              4.   Evaluation  of Economic  Impact




              The best  usage  of available water resources




 must be  carefully considered and reasonably  determined con-




 sistent with  the economic needs  of the region, the  effects




 on the health and welfare of the inhabitants  and the effects




 upon stream quality.




              5.   Fairness to All—"Reasonable Use Thereof"




              Those fulfilling their water pollution control




 responsibilities must  have reasonable assurance that the




 standards and objectives of  regulatory agencies will be




 consistent throughout  the area,  the State, the nation and




 in international boundary waters,  and that enforcement will




 be uniform for all,  whether  industry or  municipality.




              6.   What  Water  Quality is the Goal?




              It  is not enough to say that salts, solids,




BOD,  etc.  are too  high.   Firm assurances of  what our goal

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                                                        1256
                   G. Remus
 is must be given to the public.
             7.  The Existent Situation Must be Firmly
 Fixed
             If millions of dollars are to be committed
 toward improvement, there must be a definite statement on
 what the basic situation is, and agreed upon by all '
 agencies—Federal, State and local.  This has not been
 done.
             8.  Results Must be Predicted
             If certain treatments are adopted, then an
 accurate evaluation must be made of what the water quality
 of the streams will be after the costly construction has
 been completed.  This has not been done.

                  SECTION III
      EXHIBITS AND SUPPORTING STATEMENTS

               DETROIT'S RECORD
                U.S.P.H.S.  DATA

Coliform Bacteria    --      down       99.99$
Fecal Coliforms      —        "        99.99$
Fecal Streptococci   --        "        99-99#
Suspended Solids     --        "

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                                                      1257



                   G. Remus




Oil and Grease     —           down




Ammonia            --             "         22%




             Detroit's Plow --  540,000,000 gallons per




day represents a system of 3,000,000 people, plus a greater




portion of Metropolitan Detroit industry.




             Data and observation show the effluent is




rapidly diffused in the river.




             No deficiency of dissolved oxygen in the




river.




             Phosphates and Nitrates are the resultant of




the process.  There is no answer or solution to the prob-




lem of nutrients.




             Chlorides —  Water at head of Detroit River




shows 7-8 mg/1 chlorides, lower river 18 -44 mg/1.  The




U.S.P.H.S. Drinking Water Standards permit 250 mg/1.




             Storm Flow --  Data show 0.3 inches rainfall




is retained and treated by system.  One area retains and




treats 0.2 inches rainfall.  Sixty percent of all storm




run-off collected and treated.




             All bacteriological data on Detroit River from




the Rouge River up include the effect of the Detroit




Sewage Treatment Plant outfall.  --  D.W.S. Range 6A.




             River condition has improved even though




sewage and industrial load has increased.

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                                                        1258




                    G.  Remus




              Three  General Areas  of  the  Detroit River:




              1.   Above Rouge  River -




                  This  area Detroit is  responsible  for.




              2.   Rouge River  to Lake Erie  -




                  Receives much industrial  waste.   Sewage




 treatment plants  of Trenton,  Riverview and New Wayne  County




 plant at Wyandotte  were not studied.   Five foot sewer out-




 falls in Trenton  missed.



              3.   Raisin River -




                  Detroit has  no connection with the




 Raisin River.  The  pollution  from the  Raisin River plus




shorefront homes caused Sterling State  Park to be closed.




              Many recommendations have been made as to what




 the quality of the  effluents  should  be from sewage treat-




 ment plants and industry.




              There  is  no statement as  to what the  condition




 of the Detroit River and Lake Erie will  be or what quality




 can be expected.




              Separate  vs. Combined Sewers:




              The  data  distinctly  show  that no strong



 recommendation for  either type can be  made at this time.




              The  following were not  mentioned;




              Silt or suspended  solids  coming  down  the




 river -

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                                                  1259




                        G. Remus




            Every day 4,750 cubic yards goes down the



river.




            During dredging of Lake St. Glair and after




severe storms, this reaches 50,000 cubic yards.




            Boats --




            Both pleasure and freight boats add oils and




grease to the river.




            No control over salt on the streets and roads.




            Canadian pollution affects the southwest in-




take more than that from the United States.




            Low levels of the lakes and the effect of




this.




            Where are the beach areas on the Detroit River




below Belle Isle?




       WHAT DID THE U.S.P.H.S. REALLY FIND?




            DETROIT'S RECORD IS EXCELLENT








            1.  River Quality Protected by Detroit's




Voluntary Efforts




            To appreciate Detroit's contribution to




pollution control, one should consider what the situation




would be if sewers and treatment facilities were not avail




able for the countless thousands of Industries and

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                                                     1260
                   G. Remus
3,000,000 people in the area served by Detroit.  The high
quality of the Detroit River above the Rouge River, as sub-
stantiated by the U.S.P.H.S. findings, illustrates the
value of having an area served by a single responsible
agency.
             The construction of this vast and costly system
was a voluntary action of the City of Detroit prompted not
only be a recognition of its responsibilities but also by
its sincere desire to prevent unnecessary degradation of
the Detroit River.
             Detroit is continuing its program to reduce
the quantities of wastes being discharged into the river
and has plans for progressive improvements.
             2.  Municipal Effluent Comprises Less Than
\% of Flow in U.S. Waters
             While the U.S.P.H.S. report notes that Detroit
discharges 95$ of all municipal effluent going to the
river, it should also be noted that the flow from the
Detroit Sewage Treatment Plant is only a small fraction
of the average flow in the river as illustrated in
Exhibit 1.
             Detroit returns to the Detroit River a
volume of water approximately equal to that removed for
domestic and industrial use.

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                                                       1261




                   G. Remus




             3.  Research and Studies Needed




             If all effluent discharged to the river met




the proposed U.S.P.H.S. recommended criteria, there is no




assurance that desirable river quality will be achieved,




that aging of the lakes will be slowed or that desirable




aquatic life will thrive.  Npr is there any evidence that




what could be achieved by secondary treatment could not




be achieved equally as well or better by alternate means.








                STORMWATER RUN-OFF








             1.  Run-off Control a Tremendous Challenge




             In any contemplation of the effects or pro-




posals for the control of stormwater run-off, consider-




ation must be given to the fact that there are 227,920




square miles of drainage basin above the Detroit River.




None of this run-off can be considered as clean water




when in 19°^, an estimated 4,560,000,000 pounds of




fertilizers containing a considerable proportion of nitro-




gen and phosphorus was used in the drainage basin area.



In 1963, an estimated 55,500,000 pounds of pesticides were




used in the area.   A tremendous quantity of animal waste




bearing fecal coliform bacteria is discharged in this




drainage basin.   There are an estimated 177,000 private

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                                                       1262
                    G.  Remus
 septic  tanks  in the six-county area.   The  run-off  from
 roads and streets  contains vast quantities of chlorides
 and crankcase oil.   The physical dimensions of this  prob-
 lem make  it obvious that  collecting and  treating all storm
 run-off will  require much study and research plus  huge
 capital expenditures.
              2.  Regional Cooperation  and  Effort Required
              This  is not  to  say that storm run-off should
 not presently be controlled  where possible.   However,  con-
 trol within a small limited  area such  as metropolitan
 Detroit,  may  not have  an  appreciable beneficial effect on
 stream  quality,  and may have only a very minor effect  upon
 natural aging of the lakes,  known technically as eutro-
 phication of  the lakes.

                 COMBINED SEWERS

              1.  Advantages
              A combined sewer  system with  volumetric
 storage,  such as is being constructed by the  City  of
 Detroit,  permits the treatment  of 6o#  of all  storm
 run-off.   For the metropolitan  area having combined  sewers
 which is  served  by  the Detroit  system, this would  amount
to 58,800,000,000 gallons per year, which might reach  the

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                                                       1263




                   G. Remus



river without treatment if the area were served by




separated sewers.  In its stead, only 800 million gallons




of normal sanitary flow would not receive treatment, and




this would occur only when the river is already loaded



with polluted storm flow from high intensity storms.




Instead of having approximately 90 occurrences of storm



water discharges per year, the number will be reduced to




approximately 10 or less.



             This is very important to pollution control



in the Detroit River when viewed in relation to separated



sewer system studies conducted by the U.S.P.H.S. in Ann



Arbofc, Michigan.  There it was confirmed that storm water



run-off is grossly polluted, having high fecal coliform



bacteria counts as well as high solids concentrations.



Fecal coliform counts of 1,000,000 per 100/ml were not



uncommon.  Equally as important is the fact that the




Mfcbiai run-off from all storms carries the highest con-



centration of pollutants.  The initial run-off of all




storms can be collected and treated with a combined



sewer system.



             2.  Disadvantages of Separate Sewers



             Separated sewers do not appear to be a satis-




factory means of pollution control for the following




reasons:

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                                                        1264
                     G.  Remus

              a.  The cost of a separate system In an

existing area is not commensurate with the limited results

that could, possibly be achieved.   It is estimated that the

cost of sewer separation in the City of Detroit -only -would

exceed $1,745,000,000.

              b.  The poor quality of storm water run-off

from even the smallest storms would temporarily degrade the

receiving stream an excessive .amount of the time.

              c.  As a matterof practicality., it is virtually

impossible to maintain a separated system as such -without

some sanitary connections or infiltration.

          3.  U.S.P.H.S. Recognizes Problem


          Mr. James M. Quigley, Assistant Secretary of the

U. S. Department of Health, Education, and Welfare, reported

to 200 mayors at the National Legislative Conference of the

National League of Cities, held March 30 - April 1, 1965,

that no practical method exists for handling the problem of

storm water run-off.  See Exhibit H.

          4.  Detroit is Making Progress


          However, Detroit is taking constructive action

to limit the quantity and frequency of storm water over-

flows.  In addition to the construction of additional

storage devices, a million dollar system of monitoring

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                                                        1265




                   G. Remus




equipment and remote control devices will be installed




which will enable us to operate the system in a manner by




which spillage can be further controlled by means of peak




load anticipation. Small-1 nuisance spills will be elimin-




ated.




             5.  Corrective Action Taken on Leib Street




Sewer Overflows




             On April 15, 1965, we were notified of the




Leib Street sewer spills by the U.S.P.H.S.  Immediately




thereafter, studies were commenced to determine the cause




and to design corrective measures.  The problem at Leib




was not a case of overloaded interceptors or of improper




pumping  plant operation.  Adjustment of the height of a




diversion dam was all that was required.




             By April 26, 1965, effective action had been




taken to reduce the quantity, duration and frequency of




spills from the Leib Street sewer.  The design and con-




struction of all other existing regulating devices are




being reviewed and corrective action is being taken to




correct deficiencies.




             The U.S.P.H.S. addendum issued in May, 1965,




incorrectly stated that allowable flow into the Mt. Elliott




sewer is 180 cfs.  The controlling devices are set to

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                                                        1266
                   G. Remus
permit not more than lid cfs to enter the Mt. Elliott
sewer from the Dequindre interceptor.


                  ROUGE OUTFALL

             1.  Vital to Plant Reliability
             Prior to the construction of the Rouge out-
fall, the Michigan Department of Health and the City of
Detroit recognized a standby or auxiliary outfall was
needed to protect the quality of the river in the event that
the single Detroit River outfall failed and all flow had
to be passed through regulators to the river without treat-
ment.  In studies for the 1957 program, it was also deter-
mined that during high water elevations in the Detroit
River, the capacity of the plant would be restricted
unless a supplemental outlet was provided for use during
storm flow.  -Thus, the Rouge outfall was constructed for
use only in an emergency or for handling excess flows
during peak loads when the river elevation approaches
elevation 576.  This project was constructed with the
prior approval of the Michigan Department of Health and
the Water Resources Commission.
             2.  Effluent Chlorinated
             Chlorination facilities are provided in

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                                                      1267






                   G. Remus




the Rouge outfall to disinfect all peak flow excesses and



detention times are deemed to be adequate.  The outfall is



not to be considered as a bypass.




             3.  Performance Trials



             The outfall was used during a short trial



period in 1963 only for the purpose of evaluating its



effect upon the river and to gain experience on operating



the outfall since no way exists to evaluate these factors



other than through actual operation.  The first trial




period was immediately discontinued when it appeared the



river quality was being affected although the scheduled



trial had not been completed.



             Another attempt was made to experimentally



operate the Rouge outfall in the spring of 19&5 to



evaluate its suitability for prolonged use in the event




of need.  This trial also had to be discontinued before



we had an opportunity to experiment with possible corrective




measures as problems developed.  Thus, additional trial




periods will be required so that downriver communities may



be assured of protection in the event that it someday be-




comes necessary to use this outfall for its intended pur-




poses.



             4.  Sampling Results Show Satisfactory Effluent




             Sampling of the Rouge and Detroit Rivers  during

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                                                       1268



                       G. Remus




 the  trial  period In the spring of 1965 revealed that use




 of the Rouge outfall had no detrimental effect on the




 dissolved  oxygen in the Detroit River, that coliform bacteria




 counts in  the Rouge and Detroit Rivers showed no adverse




 effect on  stream quality, and that the Wy^ndotte raw




 water supply was not adversely affected.








                  STERLING STATE PARK








            In August 1961, Sterling State Park was




 posted as  unsafe for swimming by the Michigan Department



 of Conservation upon the advice of the Michigan Water




 Resources  Commission, which stated that coliform bacteria



 from the Detroit Sewage Treatment Plant was one of the




 largest contributors to the pollution at Sterling State Park.




            Source of Pollution




            The U.S.P.H.S. found good quality water at




 Sterling State Park, except for certain wind directions



 and after  storms.




            It has been established by the U.S.prH.S.




 that, under certain conditions, the Raisin River, as




 well as drainage from septic tanks in the area, is




 responsible for the pollution of and the closing of




Sterling State Park.

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                                                      1269
                   CL Remus

               BACTERIA - COLIFORM

             I.J.C. Standard:
             To date, the only generally accepted standard
agreed on by both. United States and Canada is as follows:
"Adequate protection of the waters should be provided if
the coliform MPlf median value does not exceed 2400 per
100 ml at any point in the waters following initial
dilution." — I.J.C. Report on Pollution of Boundary
Waters, 1951 - page 18.
             1.  D.W.S. Sampling Results
             D.W.S. sampling of the Detroit River shows
that the above standards are met in the area about the
Rouge River since 1961.  This is the area of the Detroit
River that the Detroit sewage system is responsible for.
             See Exhibit 2.
             Also, U.S.P.H.S. Findings, page 24.
             2.  Confirmation of D.W.S. Results by
U.S.P.H.S.
             The above results were confirmed by
U.S.P.H.S. Findings - page 21.  "There appears to be a
pronounced downward trend in coliform densities in American
waters near the shore, especially during the years 1962

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                                                     1270




                   G. Remus




 and 1963."  U.S.P.H.S. Findings - page 131.   "During




 dry weather, the Detroit River is of a satisfactory




 bacteriological quality as far as the mouth of the Rouge




 River.  These judgments are based upon the widely used




 standard for safe recreation—a maximum of 1000 organisms




 per 100 ml--and the I.J.C. objective of 2400 organisms




 per 100 ml."  The Detroit Sewage Treatment Plant outfall




 is above the Rouge.



             3.  Detroit River Above Rouge Meets Safe




 Recreation Standard




             U.S.P.H.S. Findings - page 131:  The above




 is for dry weather only.  However, D.W.S. monitoring of




 the Detroit River shows that, after a storm, the water




 quality returns to normal within a day.  This is due to




 the enormous flow in the Detroit River.




             4.  U.S.P.H.S. - 1962 Report




             On page 48 of the 1962 report, it stated that




 after the Dearborn Sewage Treatment Plant was abaondoned




 and the sewage sent to Detroit, 9$$ of the sewage bacteria



 in the area would be eliminated.




             5.  U.S.P.H.S. - 1963 - Findings




             In Table 8V - Summary of Treatment Efficiency,




Domestic Waste Surveys, Detroit River - U.S.P.H.S. Findings,




it states that 99-99# of the total coliforms, 99.99# of  the

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                                                        1271



                   G. Remus




fecal coliforms and 99.99#.of the fecal streptococci are




removed by the Detroit Sewage Treatment Plant.  During the




survey, the  average geometric mean of the effluent coliforms




was  245,  equivalent to bacterial population equivalent of




23 people.




              6.  U.S.P.H.S. Recommended Effluent Coliform




Standard




              U.S.P.H.S. Summary, Conclusions and Re-




commendations - pages 3 and 35  - recommends an effluent




with a monthly geometric mean coliform density of less




than 5000 organisms per 100 ml.  These standards are quite




rigid.  However, one must realize that at the present




time, these  are only recommendations.  These recommended




standards do not take into consideration the tremendous




flow in the  Detroit River and the fact that the Detroit




effluent  constitutes ,^2% of the flow in the U.S. half of




the  river.




              7.  Detroit Effluent Meets U.S.P.H.S. Re-




commended Standards with Present Equipment




              The performance at the Detroit Sewage Treat-



ment Plant during the U.S.P.H.S. surveys more than met




the  above standards with our present plant.  Secondary




treatment would not increase the bacterial removal.  The




present efficiency of the Detroit plant is satisfactory.

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                                                        1272




                   G. Remus




             See Exhibit 3.



             8.  Bacterial Pollution from Detroit Sewage




Treatment Plant is Insignificant.



             Using U.S.P.H.S. bar graphs 29V, in Findings -




page 242, which shows their data in Bacterial Population




Equivalent loadings at various points in the Detroit




River and adding to it only the BPE of the Detroit Sewage




effluent, it shows how little the effluent does affect the




coliform content of the Detroit River.



             One BPE is equivalent to 200 billion coliform




bacteria per capita per day.




             See Exhibit 4.




             9.  No Beach Areas in Detroit River Below




Belle Isle




             On page 19, U.S.P.H.S. - Summary, Conclusions




and Recommendations, it states:  "Pollution has necessi-




tated that all beach areas on the Detroit River below




Belle Isle be posted as unsafe for swimming."




             There are no beaches on the U.S. side of



the Detroit River until Lake Erie is reached.








                  OIL AND GREASE









             1.  Oil Must Be Controlled  at  Source

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                                                      1273


                   G. Remus

             Floating oil and grease, grease that settles

or adheres to settleable solids, can be effectively removed

at the Detroit Sewage Treatment Plant.  However, there are

sizeable quantities of soluble or emulsified oils that are

released by numerous industries and homes.  These oils
                                X
and greases cannot be removed by a sewage treatment

plant but must be controlled and removed before they

enter the sewer.

             2. D.W.S. Program with Industry

             It will be virtually impossible to remove

oils and greases from home discharge tci the sewers.

After July 1, 1965, the Detroit Department of Water

Supply will be responsible for policing the discharges

from industry.  It is our intention to ask for voluntary

cooperation from industry to continuously sample and

analyze their discharges, and to work with the industry

to improve rather than depend upon court action alone.

             A program to lower soluble oil discharges

to the sewer is underway with Chrysler Corporation.

             Should an industry refuse to cooperate, there

are sufficient city ordinances which are strong enough to

force compliance.

             3.  Oils from Many Sources


             The oil in the sewers comes  from innumerable

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                                                      1274
                   G. Remus
industries in the area, domestic oils and greases,
garages, gas stations, two thirds of storm run-off from
streets, etc.  The discharges from small industries,
garages, gas stations and homes, and street run-off, par-
ticularly when intermittent, are practically uncontrollable,
             4.  Detroit Responsible for Oils to Sewers
Only
             Detroit is responsible only for the oils
discharged to the sewers which reach the treatment plant
and not for the oils discharged by industries directly
to the river.  These are the responsibility of the in-
dustry under Water Resources Commission control.  During
heavy storms, when the storm waters exceed the capacity
of the treatment plant, the oils spilled on streets,
alleys and oil tank farms will flow to the river.  It
is impossible to control them.
             5.  Oils from Drainage Basin
             Oils spilled on roadways or other areas
throughout the entire drainage basin will reach the river
during storms by storm sewers or creeks.
             Ships,  including oil tankers, pleasure
craft and outboard motors, contribute oil to the Detroit
River.
             6.  Standards

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                                                        1275



                   G. Remus




             Other than visual observations, the U.S.P.H.S.




made no analytical determinations of the oil in the river.




Their recommended standard in the effluent, which is the




I.J.C. objective for municipal treatment plants and in-




dustries, Is 15 mg/1.




             Detroit ordinances permit oil discharges to




the sewers in concentrations averaging 25 mg/1 with maxi-




mum discharges up to 100 mg/1.




             Michigan Water Resources Commission permits




oil concentrations up to 100 mg/1 provided no visual evi-




dence of oil is seen on the river.  The U.S.P.H.S. re-




commended standard of 15 mg/1 is a rough one to meet.




This can be met only by lowering soluble oil discharges




at the source and by redesign of the oil and grease




collection system at the Sewage Treatment Plant.  Secondary




treatment would not do much for 
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                                                      1276




                   G. Remus








                     NITROGEN








             1.  No U.S.P.H.S. Recommended Standards




             There are no I.J.C. objectives for nitrogen




 in  the receiving waters.  On page 153, U.S.P.H.S. - Findings,




 it  states:   "A commonly accepted level of inorganic




 nitrogen compounds (nitrates, nitrites and ammonia) above




 which undesirable algae blooms can be expected to occur




 is  0.03 mg/1."




             On page 10, U.S.P.H.S. - Summary, the 0.03



 mg/1 is corrected to 0.30 mg/1.




             2.  Nitrogen Concentrations from Lake St.



 Glair Already in Danger Zone




             Already the U.S.P.H.S. data show that the



 nitrogen content of the water entering the Detroit River



 is high enough to cause algae blooms.  On page 153,




 U.S.P.H.S. - Findings, there are nitrate and ammonia




 nitrogen concentrations from .18 to .38 mg/1 at the



 head of the Detroit River.




             On page 255, 256, 257, Figures 42V, 43V, 44v,



 at Range DT 30.8w,  which is at the head of the Detroit




River,  the ammonia and nitrate nitrogen content is,




 .28 mg/1.   When organic N is considered, this value

-------
                                                       1277
                        G. Remus
becomes .42 mg/1, which la sufficient nitrogen to support
algae blooms.  Organic nitrogen will eventually be changed
to the inorganic forms preferred by algae through de-
composition and by bacteria.
            3.  Comparison of Nitrogen from Sewage
Treatment Plant Effluent with Nitrogen in River
            On page 11, U.S.P.H.S. - Summary, this statement
is made:  "The main source of nitrogen to the Detroit
River is the effluent of the main Detroit Sewage Treatment
Plant."
            Using U. S. Department of Agriculture figures,
we estimate there are approximately 4,560,008,000 pounds of
fertilizers used per year in the 227,920 square mile
drainage basin, or approximately 456,000,600 pounds of nitrogen,.
            Using U.S.PvH.S. data, Findings, page 238,
there are 276,900 pounds of nitrogen per day coming down
the Detroit River in U. S. waters alone.  Canadian waters
are not considered.
            The Detroit Sewage Treatment Plant adds
48,769 pounds of nitrogen per day (U.S.P.H.S. Data,
Table 7V. )
            The nitrogen load to the river from the
sewage plant is small compared to that already present.

-------
                                                        1278



                   G. Remus




             See Exhibit 5.



             Is the Detroit Sewage Plant effluent the




main  source of nitrogen to the Detroit River?  We think




not.



             4.  What Effect Would Secondary Treatment




Have  on the Nitrogen Load?



             Secondary treatment will not effectively




remove any of the soluble forms of nitrogen.  With




digestion of the sludge and return of the digested




sludge, absolutely no nitrogen is removed.  Some secondary




treatment pilot plants have been able to remove 50# of the




nitrogen, but this removal would not be as high on a




plant scale.



             5.  Nitrogen from Other Sources than Detroit




Sewage Treatment Plant




             Many industries discharge nitrogen to the




river as well as that from storm run-off, fertilizers,




dead and decaying algae, vegetation and many other sources.




             6.  Research Needs to be Done on Nitrogen



Removal




             Continuing accelerated research, now that




nutrients have become prominent may reveal improved and




presently unknown methods for nitrogen removal.  Secondary




plants built today may not be as efficient nor easily

-------
                                                        1279




                    G. Remus




changed when newer  methods are  developed.




             7.  Aging  of Lakes




             Nutrients, nitrogen and phosphorus, with




subsequent algae blooms and  the using up of oxygen by




decaying  algae are  one  of the main reasons for the aging




of the lakes.  Yet  there is  no  yardstick to judge this by.




Much of the aging is due to  the nitrogen from run-off in




the drainage basin.








                    PHOSPHATES








             1.  No U.S.P.H.S.  Recommended Standard




             There  are no U.S.P.H.S. recommended standards




or I.J.C. objectives for effluent discharges.  On page




11, U.S.P.H.S. Summary, it states: "Soluble phosphates




present in greater  concentrations than 0.015 mg/1 or 15




ppb reported as phosphorus,  in  combination with inorganic




nitrogen  compounds  in excess of 0.30 mg/1 and accompanied




by satisfactory environmental conditions such as light




and heat, may produce over abundant growths of algae,




with concomitant odors and detriment to fish life."




Insoluble phosphate can be converted to soluble phosphate.




             2.  Phosphorus  Content of Water Entering




Detroit River Already Above Danger Level

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                                                      1280



                   G. Remus



             On page 154, U.S.P.H.S. - Findings, it states




that the total phosphate content at the head of the Detroit




River averaged 0.03 - 0.30 mg/1.  Converting this value




to phosphorus, this would become 0.01 to 0.100 mg/1 P,




or 10 - 100 ppb phosphorus.



             On page 254, Figure 4lV, at Range DT 30.8w,




tb total average phosphate concentration is 0.19 rog/1,




or 0.062 mg/1 phosphorus, or 62 ppb.



             Thus, it would appear that there is already




sufficient phosphorus along with nitrogen entering the




Detroit River from above to cause algae difficulties in




Lake Erie.




             3.  Comparison of Sewage Treatment Plant




Effluent Phosphate with That in River




             On page 11, U.S.P.H.S. - Summary, it states:




"The main source of phosphates in the Detroit River is




the main Detroit Sewage Treatment Plant effluent."




             On page 238, U.S.P.H.S. - Findings, Table




39V, it shows 72,000 Ibs/day of total phosphate entering




the river and 218,600 Ibs/day in the lower Detroit River,




a difference of 145,600 Ibs/day.  The Detroit Sewage




Treatment Plant is said to discharge 145,000 Ibs/day




total phosphate, thus crediting the entire phosphate




increase to the Detroit plant.  Where is the industrial

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                                                       1281



                     G. Remus




load?  The sum of waste loadings to the river was



162,000 Ibs/day.



            4.  Would Secondary Treatment Remove Phosphate?




            The answer is no.  Even well run secondary



treatment pilot plants will remove only 10#.  A full-scale



secondary treatment plant would remove less.  This small



removal would have absolutely no noticeable effect on the



phosphate value in Lake Erie.



            5.  Many Phosphates Enter River from Other



Sources than Sewage Plant Effluents



            Phosphates enter the river from industrial



discharges, land run-off and storm water overflows.



            6.  Fertilizers - Source of Phosphate



            Using U. S. Department of Agriculture figures,



we estimate there are approximately 4,560,000,000 pounds of



fertilizers used per year in the 227,920 square mile drainage




basin, or approximately 274,000,000 pounds of phosphorus.



A certain percentage of this would be in the run-off to the



rivers and lake.




            7.  Aging of Lakes^



            Much of the natural aging of lakes is due to



the inherent stream phosphates and neither"-secondary or




tertiary sewage treatment can do anything to stop it.




            8.  Detergents  - A  Source of  Phosphate

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                                                       1282




                   G.  Remus




             Approximately 50$ of the content of house-




hold detergents is a phosphate.   The new detergents soon




to be sold also contain the same proportion  of phosphate.




The only change is that the new  ones are biodegradable




and will not cause foam in streams or sewage plants.








                    CHLORIDES








             1.  No U.S.F.H.S. Recommended Standards




             Neither are there any I.J.C.  objectives




for chloride.




             2.  U.S.P.H.S. Drinking Water Standards




             These standards permit a chloride content




of 250 mg/1 for a safe drinking  water.   The  average




chloride concentrations in the Michigan  waters of Lake




Erie ranged from 18 to 44 mg/1.




             3.  No Water Interference Due to Chloride



in Lake Erie




             On page 279, U.S.P.H.S. Findings, it states:




"Chloride levels found in the Michigan waters of Lake




Erie are three to five times higher than those found at




the head of the Detroit River but are not high enough to




interfere with water use."




             4.  Daily Loading  of  Chlorides  to  River  by

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                                                        1283




                   G. Remus




Detroit Sewage Treatment Plant is Insignificant in




Build-up in Detroit River




             There are 3,520,000 Ibs/day of chloride




entering the Detroit River and 10,080,000 Ibs/day in the




lower river.  The Detroit Sewage Treatment effluent adds




562,000 Ibs/day.




             See Exhibit 6.




             5.  Chloride Removal Difficult and Costly




             To reduce the chlorides in the treatment




plant effluent would approximate the removal of chloride




in sea water and cost from $500 to $1000 per million




gallons.




             6.  Salt on Streets and Roads




             Practically all main roads and streets in




the drainage basin are salted in the winter.  During the




summer months, many dirt roads are treated with calcium




chloride.




             Both practices contribute huge quantities of




chloride to the receiving streams through storm run-off.








                   PLANT SURVEYS








             1.  D.W.S. and U.S.P.H.S. Split Survey Samples




            Two 4-day plant surveys, ore in June, 1963, and

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                                                        1284



                    G.  Remus




 the other in  November, 1963, were conducted at the Detroit




 Sewage Treatment Plant.  Sixteen 12-hour composite samples




 were collected on  both the influent and effluent and  split




 with both laboratories receiving the same samples for




 bacteriological and chemical analysis.



              Standard Methods procedures were used.   The




 agreement between  the two laboratories should be within




 the limits of experimental error.




              2.  Criticism of Eight-Day Survey




              This  eight-day survey was used by the




 U.S.P.H.S.  to calculate the waste loadings discharged to




 the river,  to criticize the efficiency of the Detroit




 Sewage Treatment Plant in removing solids and BOD, to make




 damaging  statements regarding the operation of the plant,




 to  state  the  wastes from this plant were largely re-




 sponsible for the  degradation of the waters of the lower




 Detroit River and  to provide the major source of nitrogen




 and phosphate contributing to the fertilization of Lake Erie.




              We challenge and vehemently protest these




 damaging  statements with regard to solids and BOD removal



 and claim they were based on inaccurate analytical results.




 In  many instances,  the difference in results were beyond




 any^possible  experimental error.  The D.W.S. results




were in agreement  with long term analytical results,  the

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                                                       1285




                    G. Remus




 U.S.P.H.S.  results  were not.   The Detroit  Sewage Treat-




 ment Plant  removals were higher  than those claimed by




 the U.S.P.H.S.




              Secondly, two 4-day periods,  a total of eight




 days,is  too short a period of  time upon which to make such




 statements.   Sewage with industrial wastes is very variable




 and only long-term  results are meaningful.




              3.  U.S.P.H.S. Should Conduct Long-Term




 Plant  Survey




              The U.S.P.H.S. should either  accept long-




 term D.W.S.  plant data on suspended solids, BOD and phenol




 removals or run a long-term plant survey with both




 laboratories doing  the analyses  and comparing results be-




 fore issuing the type of statements that have been made.








          SUSPENDED SOLIDS - PLANT SURVEY








              1.  Variation in  Suspended Solids Deter-




 mination by U.S.P.H.S. and D.W.S. Beyond Limits of Ex-




 perimental  Error



              Period 1, June 16-19, 19^3:




              During this period, both the  influent and




 effluent suspended  solids results from both laboratories




are within the limits  of  experimental  error and  we  accept

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                                                        1286



                   G. Remus




their results.



                              U.S.P.H.S.        D.W.S.




Influent                       220 mg/1        228 mg/1




Effluent                       106  "          108   "




% Removal                       53              48.3



             Period 2, November 4-7,  1963:



             The two laboratories agree within experi-




mental error on the effluent suspended solids, but there




is absolutely no agreement on the influent  suspended




solids.  In fact, the minimum value found by the D.W.S. for




one sample only was 295 mg/1, which was much higher than




the average of 233 mg/1 found by the U.S.P.H.S.  On this




basis, we challenge the accuracy of the results on influent




suspended solids.








Influent




Effluent




% Removal




Ave.  % Removal



  Periods 1 and 2               39              49.1



             2.  Could the U.S.P.H.S. Samples from Detroit




and Wayne County Plants Have Been Mixed Up  in U.S.P.H.S.




Laboratory?




             Samples were collected from the two plants on
U.S.P.H.S.
233 mg/1
175 "
25
D.W.S.
357 mg/1
179
49.6

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                                                        1287

                   G. Remus

the same days.  The average influent suspended solids re-

sults for Wayne County Sewage Treatment Plant at Wyandotte

found by the U.S.P.H.S. laboratory agrees within experi-

mental error with results found by the Detroit laboratory

on the Detroit samples.

             For example:

                     Wayne County     Detroit      D.W.S.
                       U.S.P.H.S.   U.S.P.H.S.     	

Influent Sample

November 4-7, 1963      36? mg/1     233 mg/1      357 mg/1

             Since the same sample was analyzed in different

laboratories, there should be better agreement.  Could it

be that somehow the samples from the two plants got mixed

up?

             3.  U.S.P.H.S. Percentage Removal Too Low

             The percentage removal of suspended solids

shown by the U.S.P.H.S. was 39$.  This value is too low

and again points out the inaccuracies of 8-rday plant sur-

veys.  At no time has plant operation data shown percent-

age removals as low as 39$•

             The following percentage removal of suspended

solids has been obtained in the following years at the

Detroit Sewage Treatment Plant.

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                                                       1288



                   G. Remus




             Year              % Removal




             1962                50.4




             1963                51.1



             1964                58.4




             1965 (thru April)   49.0



             These facts are substantiated in U.S.P.H.S.




Findings, page 33, Figure 14-1.



             4. Secondary Treatment Would Provide No




Noticeable River Improvement.



             The amount of suspended solids contributed to




the river by the Detroit Sewage Plant is small in com-




parison to the vast amount of suspended solids normally




coming down the river from normal run-off after moderate




storms and during dredging in Lake St.  Glair.




             It is futile to attempt to lower the amount




of suspended solids in the lower river by instituting




secondary treatment.   The obvious way to decrease deposition




of solids in Lake Erie would be to limit run-off, but that




is virtually impossible.




             This is illustrated in Exhibit 7.



             5.  Suspended Solids Load in River Is Not



from Plant Effluent.




             The amount of suspended solids from the




Detroit Sewage Treatment Plant effluent  is minor compared

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                                                      1289
                   G. Remus
to the total amounts coming down the U.S. waters or con-
tributed by others on the way to Lake Erie.
             See Exhibit 8.
             6.  Aging of Lake Erie
             The deposition of the suspended solids in
Lake Erie when the velocity of flow decreases constitutes
a natural aging of the lake and has been going on since
the lake was formed.
             On page 279, U.S.P.H.S. Findings, it states:
"Suspended solids in Lake Erie in the vicinity of the mouths
of the Raisin and Detroit Rivers and near the shores have
reached levels which constitute damaging pollution.  The
solids settle on the lake bottom causing damage to aquatic
life.  By blanketing the bottom, sludge deposits are
killing eggs and essential fish-food organisms and de-
stroying spawning beds."
             Since this deposition of solids has been
going on since time immemorial, perhaps it is the in-
creased use of pesticides in the past few years that is
causing the damage to aquatic life.
             7.  U.S. Army Corps of Engineers - Letter
dated July 24, 1964, Regarding Sludge Beds in the Detroit
River
              "The Detroit  River,  from Zug Island to the

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                                                      1290





                   G. Remus




lower end of Bois Blanc Island (Bob-lo), has a history




of little or no deposition in either the through channel




(Fighting Island) or the Trenton Channel.  Deposition in




the amount of 100,000 c.y. is removed annually from the




Lower Livingstone Channel and in the amount of 200,000




c.y- from the East Outer Channel.  The material, con-




sisting of a silty sand, is deposited in the two areas




shown. "



             8.  U.S.P.H.S. Recommended Standards




             The recommended standard for suspended solids




in the effluent is 35 mg/1 .  There is no I.J.C. objective.








         SETTLEABLE SOLIDS - PLANT SURVEY








             1.  U.S.P.H.S. Inconsistency of Data Questioned




             The following data on settleable solids were




obtained by the U.S.P.H.S. and the D.W.S. laboratories on



the same samples.




                              Percentage Removal



                         U.S.P.H.S.         D.W.S.
Period 1                    75$             95. l




Period 2                    29"             8l.7"




Average                     52"             87-4"




             The U.S.P.H.S. results reveal low percentage



removal of settleable solids in period 2, quite similar

-------
                                                       1291
              G. Remus
to the low results for suspended solids in period 2.
Since the same sample is used for both determinations,
and since the D.W.S. results do not show a marked drop in
settleable solids, the possibility of a mix-up of samples
is strengthened.
             On two samples of period 2, higher settleable
solids in the effluent than in the influent were reported
by the U.S.P.H.S. laboratory.  For samples composited
hourly over a 12-hour period, this is illogical.  The
D.W.S. laboratory did not find this type of result.
             The settleable solids percentage removal
from plant records over the past few years shows no wide
variation in settleable solids removal.  The removals
were as follows:
             1962          -     93.0# removal
             1963          -     90.8"
             1964          -     93.0"    "
             1965 (to May) -     88.2"
             2.  Comments on Two Acceptable Standard
Methods
             It is difficult to compare the results on
settleable solids percent removal obtained by the two
laboratories since different analytical procedures were
used.   Both methods are listed in Standard Methods and

-------
                                                       1292
                   G. Remus




both are listed as acceptable.   One is a weight method




used by the U.S.P.H.S. and the  other is a volume method




used by the D.W.S.  The latter  one is usually used by




sewage treatment laboratories.   The Michigan Department




of Health lists both procedures in their laboratory




manual, but does not require a  settleable solids deter-




mination since it is meaningless in determining plant




efficiency.



             3.  Natural Aging  of Lake Erie




             The settleable solids contribute to the




natural aging of Lake Erie by depositing solids when the




velocity slows down.




             4.  U.S.P.H.S. Recommended Standard




             The recommended standard for settleable




solids is less than 5 mg/1.  The I.J.C. objectives do not




list a value for settleable solids.








             BOD AND DISSOLVED  OXYGEN








             1.  U.S.P.H.S. and D.W.S. Data During



Plant Survey Differ.




             Period 1 - June 16-19, 1963:




             BOD determinations were made for this period




only.  The two laboratories working on the same samples

-------
                                                       1293




                   G. Remus



agree on the average influent BOD but do not agree on the



effluent results.  While the accuracy on this determination




is not too good, the difference in values found are beyond




the limits of any possible experimental error.




                          U.S.P.H.S.         D.W.S



Influent                   132 mg/1       132.3 mg/1



Effluent                   109  "          86.8  "



% Removal                   \1%            34.4$




             The percentage removal found by the U.S.P.H.S.



laboratory is too low.  The removal found by the D.W.S.



laboratory agrees with plant data.  On June 17, the two



samples run by the U.S.P.H.S. show higher results in the



effluent than in the influent.   On 12-hour composite



samples, sampled every hour, one would not expect this.



The D.W.S.  did not find this situation.   The D.W.S.



chemists run this determination daily.




             2.   U.S.P.H.S. Results on BOD Do Not Agree



With Long Term Plant Removal




             The following long-term plant data are in



agreement with D.W.S. survey data.



             Year                 Removal BOD



             1962                   38.1#




             1963                   32.3"




             1964                   38.8"



             1965 (to May)          34.1"

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                                                       1294
                   G. Remus



             Percent reduction since 1942 showed an




 average  of 31%.  The U.S.P.H.S. figure of 1?# is too




 low.



             See Exhibit 9.



             Recently the following data were obtained




 from  recent plant records:




                       BOD




  Date    Influent     Effluent    % Removal
 5/28/65   126 mg/1     64 mg/1




 5/29      159    "      71  "        55"



 5/30      132    "      72  "        45"




 5/31      108    "      78  "        28"




 6/1       129    "      80  "        38"




             From the above, it is contended that the




 U.S.P.H.S.  results are in error.




             3.  Dual Criteria for BOD in Effluents of




 Industry  and Sewage Treatment Plants




             On  page 42, U.S.P.H.S. - Summary, Conclusions




 and Recommendations, the recommended standard for Scott



 Paper  Company's  effluent is a BOD below 85 mg/1.  The



 Detroit Sewage Treatment Plant is located across




 Jefferson Avenue, and the recommended standard for BOD




 is below  20 mg/1.  The flow from Scott Paper Company is




43.8 MOD.

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                                                      1295




                   G. Remus




             The effluent from the Detroit Sewage Treat-




ment Plant now meets the recommended  standard set for




Scott Paper Company without  secondary treatment.




             4.  Ample Dissolved Oxygen in the Detroit



River




             Prom June 18 to September 3, 1964, the D.W.S.




sampled various locations in the vicinity of the outfall




and down river.  Even in the upflow from the outfall there




was over 8 mg/1 dissolved oxygen, which for that water




temperature was over 90$ saturation.  There was some drop




in the mixed flow from the Rouge River, but the values were




far above the range in which secondary treatment would be




required.




             See Exhibit 10.




             U.S.P.H.S. sampling throughout the length of




the river supported the D.W.S. findings on dissolved oxygen,




and it must be remembered that their  results were for the




station nearest the U.S. shore which  would give the lowest




dissolved oxygen concentrations.  Even their lowest value




at Range DT 3.9 is above that requiring secondary treatment.




             See Exhibit 11.




             U.S.P.H.S. found the percent saturation of




dissolved oxygen at the station nearest the shore to be




ample.  It was 90$ saturation and over throughout the

-------
                                                         1296




                    G.  Remus




 river,  except for Range DT 3.9 where  it  was  approximately




 65$.   This latter value recovered to  100$ a  few miles  out




 in Lake Erie.  In no way was  the  need for secondary treat-




 ment  demonstrated.




              See Exhibit 12.



              5.   No Apparent  Justification for  Secondary




 Treatment at Present



              No lack of dissolved oxygen in  the Detroit




 River which will use up the BOD has been demonstrated.




              There  is  evidence  to show that  even with  in-




 creased load,  continued primary treatment  presents no




 danger  of oxygen depletion  in the river.   Even  considering




 only  one fourth  of  the flow in  the river,  the supply is




 now nearly 400$  greater than  the  demand.   With  additional




 dispersion of the effluent  in the future,  there would be




 even  less basis  for considering secondary  treatment  be-




 cause of oxygen  shortage  in the river.




              See Exhibit  13.




              6,   Quotes  from  U,S.P.H.S.  Findings on




 Dissolved Oxygen and BOD, Detroit River  and  Lake Erie



              Page 150;   "In no  reaches of  the Detroit




 River do levels  of  dissolved  oxygen cause  interferences




with water uses." .  .  .  "Future problems may result  if




oxygen-consuming waste  loads increase."

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                                                      1297




                   G. Remus




             Page 280;   "Levels of dissolved oxygen in




most of the Michigan waters of Lake Erie are sufficient




at this time to prevent interference with water use.




At the Mouth of the Raisin River, however, and to some




extent in the influence of the Detroit River, significant




decrease in oxygen content has occurred.  If oxygen-con-




suming materials continue to be added to the lake from the




Detroit and Raisin Rivers, DO deficits will occur and cause




serious problems."




             The dissolved oxygen values increased to




approximately 100$ saturation a few miles out in the




lake.




             Page 150;   "In the upper Detroit River, the




BOD ranged from 2 to 4 mg/1.  Below the Rouge River, the




average value increased to 8 mg/1 but returned to the




2-4 mg/1 range at the mouth.  BOD in the Rouge River




was less than 6 mg/1 during the period samples." . . .




"It is normal to find a BOD of 2 to 3 mg/1 in river




waters receiving natural drainage; a higher BOD may repre-




sent a drain on the dissolved oxygen present in the water."



             This is evidence to show the river is not




affected by the BOD added to it.

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                                                        1293




                    G. Remus








                      PHENOLS








              1.  Criticism of U.S.P.H.S. Analytical




 Results and Calculated Phenol Discharge to River;




              The eight-day average of the phenol content




 of the influent and effluent samples as determined by




 the U.S.P.H.S. is as follows:
Period 1
Period 2
Average
Influent
jag/1 (ppb)
809
307
558
Effluent % Re-
>ig/l jjjpb) moval
410
197
303
49
36
42
Lbs/Day
1760
765
1260
              Examination of the original data shows that




 the high value during period 1  was due to an extraordinarily




 high slug during one 12-hour composite sample.   This con-




 dition is not a common occurrence  and is not typical of the




 influent sewage.   The inclusion of this one  sample gives




 a false impression on the  phenol loading of  the  effluent.




 If this one  sample were omitted (and  in many other analyses,



 one sample was),  the influent sample  would have  shown 253




jig/1 (ppb) phenol and the  effluent 218 jug/1  (ppb).




              The  above points out  very strongly  the fallacy




 of using short  period sampling  on  sewage and sewage treat-

-------
                                                       1299



                   G. Remus




ment plants with industrial wastes present.




             Examination of the individual analyses during




period 2 reveals that five out of eight samples showed




higher phenol values in the effluent than on the influent.




On samples composited over twelve hours, one would not




expect results similar to the above.




             2. D.W.S. Records Show Lower Phenol Content




than U.S.P.H.S.




             The D.W.S. laboratory determines the phenol




content of the influent only since it is assumed that there




is little reduction in the plant other than that absorbed




or oxidized.  The loadings to the river were calculated.




The results were as follows:




Year                     Influent fcig/1)     Lbs/Day




1962                         128               571




1963                         118               538




1964                          49.8             237




1965 (thru April)             90               529




             The above loadings are approximately half




that obtained by the U.S.P.H.S.  It is believed that the



above loadings (and no reduction in the plant was used) are




closer to the true values.




             3.  U.S.P.H^S. Data on Phenol Stream Loadings




Show Discrepancies

-------
                                                      1300




                   G. Remus



             On page 239, Findings, a table shows that




their analytical findings show an increase of 500 Ibs/day




phenol in the entire Detroit River, yet the sum of waste




loadings is 2,680 Ibs/day.



             In Figure 30V, page 243 - Findings - Average




Daily Stream Loadings, it shows that there is no increase




in phenol loading to the river between Range DT 20.6,




which is above the Detroit Sewage Treatment Plant outfall




and the Rouge River and Range DT 17-4w which is below.



             On page 252, Figure 39V - Average Phenol Con-




centrations, it shows the same conclusion.




             Where is the phenol from the Rouge River and




the effluent?




             Obviously something is wrong with either the




analytical data or waste loadings calculations from muni-




cipalities and industry.




             Could the statement on page 9 - Summary:




"The major sources of phenol are the main Detroit Sewage




Treatment Plant Effluent." be in error?  We think so.




             4.  Phenols Must be Controlled at Source



             Although the U.S.P.H.S. Plant Survey 8V -



Summary of Treatment Efficiency - Findings, shows a phenol




reduction of 42$, it is questionable if any sizeable re-




duction takes place in the treatment process.  Phenol must

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                                                      1301



                   Cr. Remus


be controlled at the source.  This becomes the responsi-


bility of the Department of Water Supply after July 1,


1965.  It is virtually impossible to control phenol dis-


charges from disinfectants in the home.  It is recognized


that the phenol discharges are too high and we will work


to reduce them.


             5.  D.W.S. Program with Industry


             The same type of program as with oil and


grease, namely voluntary cooperation with industry and


working with industry to lower their phenol discharge will


be instigated.  Also, with laggards or non-cooperating in-


dustries, the ordinances now in force will be used to


their fullest extent.


             Most phenols discharged to the sewers from


industry come from soluble oils where they are used as


bactericides, paint stripper penetrants, disinfectants,



etc.
                      v

             Already Chrysler Corporation has specified


soluble oils without phenols and alkaline paint strippers


without phenol penetrants to lower phenol discharges to


the sewers.  We are considering asking that all industry


using the above supplies adopt similar specifications.


             6.  Many Phenols Discharge Directly to River



             Only the phenols  discharged to the  sewers

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                                                       1302





                    G. Remus




 enter  the  treatment plant.  Many  industries  discharge




 directly to  the  river.  This  is the responsibility  of  the




 industry under the  Water Resources Commission  control.




             7.  Effect of Secondary Treatment upon Phenols




             Secondary treatment  is not as effective in  re-




 moving phenols as elimination of  them at the source.   There




 are  biological phenol reduction plants which are  a  type




 of secondary treatment; however,  they are designed  and




 operated to  achieve phenol reduction only.   Average




 secondary  treatment plants of the activated  sludge  type




 remove little phenol.




             8.  Standards




             The U.S.P.H.S. recommended standard  (or




 I.J.C.  objectives)  is 20 jug/1 (ppb) in the effluent.




 This is difficult to obtain in a  large industrial and




 domestic system.  The I.J.C.  objectives for  the receiving




 waters are 2 jag/1 (ppb) average and a 5 >ug/l (ppb)  maxi-




 mum  value.




             9.  With few Exceptions, Phenol Concentrations



 in Lake Erie Meet I.J.C. Objectives



             On  page 27, Findings,it states:  "With few




 exceptions,  I.J.C.  objectives for average phenol  con-




 centrations  were met during the survey.  There is no




evidence that phenols in the  Michigan waters of Lake

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                                                         1303
                    G.  Remus




 Erie  constitute  interference with water  use  at  this




 time."








                   AGING OF LAKES








              1.   Natural Phenomena




              The aging of lakes has been taking place




 since geological times.   It is a natural phenomena that




 will  continue.   Man may speed up the  aging but, in spite




 of what he may  do,  man cannot stop it.




              2.   Causes of Aging




              Silt coming down a stream deposits its load




 where the velocity slows down, usually in a  large body




 of water.  Examples of this are the formations  of deltas




 at the  Mouth of  the Mississippi and Nile Rivers.  Another




 example is the  filling of man-made lakes such as Lake Meade,




              By  blanketing the lake bottom with silt,




 claims  are made  that aquatic life is  damaged.




              Nutrients such as phosphates and nitrates are



 the prime causative agents.  They fertilize  the lake,




 causing algae blooms,  if sufficient sunlight and heat




 are present. Algae will produce oxygen  and  serve as a




 source  of food  for fish. However, as the algae multiply




and die, they settle to  the bottom, decay, releasing the

-------
                                                         1304





                   G. Remus



nutrients again.  Oxygen from the water is used to accomplish




this  and thus a layer of oxygen deficient water rests just




above the deep portions of the lake.  This oxygen de-




ficient layer will cause fish-food organisms to die,




thus  affecting the fish population.



             3.  Accelerated Aging of Lake Erie




             Over the past 15 years, the aging of Lake




Erie  is said to have speeded up.  Increased fertilization




is alleged to be the cause.  While population and industry




have  increased their discharge of nitrates and phosphates




to the streams, so has larger and larger quantities of




fertilizers and pesticides been used, not only in cities




but on all farm lands.  A certain percentage is bound to




run off to the collecting stream.  Perhaps the increased  /




use of pesticides, more than silt, is the damaging agent




to aquatic life.  The increased use of detergents with




their phosphates also may be the cause of the acceleration



in aging.




             Lake Ontario has approximately the same




chemical content as Lake Erie since it receives most of



its water from Erie.  Yet Lake Ontario is not aging as



fast  as Lake Erie.  Lake Erie, a shallow lake, is warmer




tban  Lake Ontario.  Perhaps this is the difference be-




tween the two lakes.  If so, not very much can be done

-------
                                                      1305



                   G.  Remus




about it.  The aging process is so slow and so little




is known about it that there are no concrete measuring




sticks to go by.




             4.  Effect of Secondary Treatment Upon




Aging Process




             There is little that secondary treatment can




do to stop the aging process.  There are sufficient




nutrients coming into the Detroit River to cause fertili-




zation of Lake Erie already.  Secondary treatment would




lower phosphates and nitrates only slightly.  BOD is not




a problem in aging but the nutrients are.








            IS SECONDARY TREATMENT NOW




            THE ANSWER FOR LAKE ERIE?








             1.  Effect of secondary treatment on




             a.  Bacteria - The recommended standard can




be met easily with the present plant.  Secondary treat-




ment would not lower the bacteria discharge.




             b.  Oils - The only effective way to reduce




oils and grease is at the source.  This will be done.



Secondary treatment would not help.




             c.  Phenols - Phenols also must be reduced




at the source.  This will be done.  Secondary treatment

-------
                                                       1306




                   G.  Remus




would lower them only slightly.



             d.   Nitrogen - Without digestion,  secondary




treatment may reduce the nitrogen from 0 to 50#.   Soluble




nitrogen in the  form of ammonia or nitrates will  not be




removed.  With digestion, no nitrogen is removed.




             e.   Phosphorus - Secondary treatment will re-




move 10$ or less of the phosphates.



             f.   Chlorides - Secondary treatment  would not




remove.



             g.   Toxic Metals -  Secondary treatment would




not remove.  Most of these must  be prevented from entering




the sewers.



             h.   Suspended Solids - Secondary treatment




would remove from 60 to 95$ of the suspended solids.




Compared to the  suspended solids coming down the  river,




the reduction is minor,




             i.   Settleable Solids - These would  be




effectively removed.




             j.   BOD - The BOD would be lowered but this




is no problem in the Detroit River and Lake Erie.




             2.   Present Loadings to River and Effect




on Lake Erie




             On  page 279, U.S.P.H.S. - Findings,  it states




that the present loading of the following does not interfere

-------
                                                        1307




                   G. Remus




with water use - phenols, chlorides, ABS, pH, cyanide,



iron, toxic metals, dissolved oxygen.




             3.  U.S.P.H.S. Recommended Standards



             These recommended standards do not recognize



the natural loading of the Detroit River nor the waste



assimilating power of the river without harmful effect.



             4.  Effect of Suspended Solids



             While secondary treatment does an effective



job in removing these, it is questionable if an effluent




with 35 nag/1 of suspended solids would have any effect



on Lake Erie and the preservation of desirable aquatic



life.  The removal of about 450,000 Ibs/day out of approxi-



mately 11,000,000 Ibs/day suspended solids coming down the



river naturally would have small effect.  The aquatic life



may be killed by the increased use of pesticides.



             5.  Effect of Nutrients



             Nutrients are the real culprits in the Lake




Erie problem.  Neither phosphates or nitrates is effectively



removed in conventional secondary treatment plants.



             6.  Removal of Nutrients - Tertiary Treatment



             If the nutrients are not effectively removed




in the secondary treatment plant, U.S.P.H.S. - Summary,




Conclusions and Recommendations, page 35* states that a




technical committee should evaluate nitrogen and phosphate

-------
                                                         1308




                   G. Remus



removal and, if further facilities are necessary, the con-



ferees will consider making such a recommendation.  This



is tertiary treatment, which is not properly developed




as yet and extremely costly.



             7.  Performance Data - Secondary Treatment




Plants



             Several large secondary treatment plants



have no difficulty meeting the recommended U.S.P.H.S.



standards; however, several plants in operation have.



An example of the latter is the District of Columbia



Water Pollution Control Plant.  Their 1963-64 operating



data on the effluent show:



             Suspended Solids     -   46.1 mg/1



             BOD                  -   49.9  "



             Percentage removals were 66.6 and 69.2,



respectively.




             Several activated sludge treatment plants



receiving shock loads of industrial wastes report ex-



treme operating difficulties with some plant failures.



             8.  Raisin River Dissolved Oxygen



             One of the reasons for secondary treatment



is to prevent oxygen depletion in the Detroit River and



Lake Erie.  The Detroit River is not a problem but the




Raisin River is.  However, on page 50, U.S.P.H.S. -

-------
                                                       1309




                    G.  Remus



 Summary,  Conclusions and Recommendations,  approval  is



 given  to  maintain  the  dissolved  oxygen  in  the Raisin




 River  at  a minimum level of  3 mg/1.  This  is another



 example of a dual  standard.




              9.  Huron River Sewage Treatment Plants



              With  the  exception  of two  small primary



 plants, Rockford and Plat Rock,  which have adequate



 chlorlnation and few people, the remainder of the cities



 and towns have  secondary treatment.



              On  page 295, U.S.P.H.S. -  Findings, Table



 l6 VI,  the Huron River shows average stream concentrations



 of many wastes  such as chlorides and phosphates to be



 higher than that in the Detroit  River and  nitrogen and



 phenols to be in approximately the same range.



              The coliforms were  also quite high.  Evi-



 dently, secondary  treatment  has  not helped the Huron




 River.  The question is:   What would secondary treatment



 do for the Detroit River? Judging by the.  evidence, it




 would  do  very little at the  present time.







        COMMENTARY  FOR  EXHIBITS 1 THROUGH 13








              EXHIBIT 1 — River Flow vs.  Flow from




Sewage  Treatment Plant

-------
                                                      1310




                   G. Remus



             The U.S.P.H.S. Report states that effluent




from the Detroit Sewage Treatment Plant comprises 95#



of the municipal effluent being discharged to the Detroit



River.  It should simultaneously be noted that this same



quantity of effluent is equivalent to less than \% of the




average flow in the river.



             EXHIBIT 2 —  Coliform Median Values vs.




I.J.C. Objectives



             The objective of the I.J.G. is to hold the



bacterial contamination of the Detroit River to a coliform



median MPN value of less than 2400 coliform bacteria per



100 mis.  The water over and around the Sewage Treatment



Plant outfall has more than met this criteria for the past



four years while no improvement has been noted on the



Canadian side.



             EXHIBIT 3 —  Sewage Treatment Plant Efficiency



             This chart portrays the present efficiency



of our Sewage Treatment Plant which, according to U.S.P.H.S.



sampling data, receives the bacterial population equivalent



of 3*250,000 daily but discharges an average of only 23



BPE according to U.S.P.H.S. records.  This should suffice



to show that we do not take our responsibilities lightly



and are already contributing greatly to maintaining the




purity of the Detroit River.

-------
                                                       1311
                   G. Remus
             EXHIBIT 4 — Negligible Effect of Sewage
Treatment Plant on Conform Loading in River
             U.S.P.H.S. records show that the average
daily bacterial population equivalent (1 BPE = 200,000,000,000
coliform organisms) of the Sewage Treatment Plant effluent
is only 23.  Considering that this represents a removal of
better than 99.99$, further reduction of this figure would
be warranted only if other sources of gross coliform
pollution are detected and corrected.
             EXHIBIT 5 —  Proportionate Effect of Sewage
Treatment Plant on Nitrogen Loading in River
             This graph illustrates that there is a com-
paratively heavy nitrogen load in the river under normal
conditions which is in no way related to treatment plant
effluent, but is probably the result of commercial fertil-
izers and other materials being washed off the land.
Secondary treatment will not ordinarily remove nitrogen from
the effluent.
             EXHIBIT 6 —  Proportionate Effect of Sewage
Treatment Plant on Chloride Loading in River
             As can be seen here, a comparatively great
amount of chlorides is coming down the river at all times.
Complete elimination of chlorides in our effluent would
make virtually no noticeable change in the river even  if

-------
                                                         1312
                    G.  Remus
 a practical method for their removal were  known.   Much of
 the chloride loading comes as a result  of  the  use  of salt
 for traffic safety.
              EXHIBIT 7 —  Proportionate Effect of Sewage
 Treatment Plant  on Suspended Solids in  River
              The futility of trying to  clean up the river
 by instituting secondary treatment is clearly  shown here.
 In view of the vast  amount of solids passing over  our out-
 fall,  there is insufficient  justification  for  secondary
 treatment considering  that the  improvement would be virtually
 undetectable.  Normal  run-off from the  land and storm run-
 off would easily negate a $129  million  dollars worth of
 effort.   The obvious place to start is  on  the  collection
 and run-off problem, but the U.S.P.H.S. admits it  is not
 sure what the  economical answer would be.  Eutrophication
 of Lake Erie would hardly be slowed by  secondary treatment.
             EXHIBIT 8 —  Negligible Effect of Sewage
 Treatment Plant  on Suspended Solids in  River
             This chart also shows the  amount  of suspended
 solids contributed by  the Sewage Treatment Plant is minor
 compared to the  amount of solids coming in upstream or
 to the amount  added  by others.
             EXHIBIT 9 —  BOD  Removal  Record  for  Sewage
Treatment Plant

-------
                                                      1313
                    G. Remus
             The  Summary,  Conclusions  and Recommendations
of the U.S.P.H.S. report labeled our BOD reduction of Yl%
as "POOR".  Our analysis of  a portion  of their  same  samples
showed a reduction  of ^A%.  Shown here is a graph  of our
average percent BOD reduction for 22 years.  The long-term
average appears to  be about  37%, which cannot be called
"poor".
             EXHIBIT 10 --   Sufficiency of Dissolved
Oxygen in River - D.W.S.
             From June 18  to September 3* 1964> our  forces
sampled various locations  in the Detroit River  and found
that even in the  upflow from our outfall there  was over
8 ppm dissolved oxygen which, for that water temperature,
is over 90$ saturation.  There was some drop in the  mixed
flow from the Rouge River, but the values did not come
anywhere near the range where regulatory agencies might
require secondary treatment.
             EXHIBIT 11 --   PPM Dissolved Oxygen Not
Critical
             U.S.P.H.S. sampling more  than supported
our findings.  This chart  shows even at points  nearest
the U.S. shore,which undoubtedly would be the worst
condition, the dissolved oxygen was at or above 8 ppm
(which  is  in  the  range  of  100# saturation)  in the

-------
                                                      1314
                   G. Remus
vicinity of our outfall.  Even downstream the oxygen
concentration and the oxygen demand obviously do not
emanate from our Sewage Treatment Plant effluent.
             EXHIBIT 12 --  % Saturation Dissolved Oxygen
Not Critical
             Again the U.S.P.H.S. found that at stations
nearest the U.S. shore, the percent saturation was for
the most part near 90$ and in no way demonstrated any
need for secondary treatment.  Though a level of approxi-
mately 65$ was reached at Range DT 3«9» additional data
showed that within the next several miles into Lake Erie
there was rapid recovery.
             EXHIBIT 13 --  Dissolved Oxygen Depletion
Not Imminent
             This graph shows that even with increased
load,continued primary treatment presents no danger of
oxygen depletion in the river.  Even considering only
one fourth of the flow in the river, the supply of oxygen
is now nearly 400# greater than demand.  With additional
dispersion of the effluent in the future, there would be
even less basis for even considering secondary treatment.
The condition of the river is by no means oxygen critical
nor is there any danger of it becoming so as a result of
primary treatment plant effluent.
         (Exhibits 1 Through 13 follow.)

-------
                                          1315
                                    EXHIBIT
  120,000 -
  100,000.
   80,000-
Q

cr
LU
Q.
1
CD

z
o
60,000 _
   40,000 -
   20,000 .
        0
                  FLOW IN DETROIT RIVER
             S.T P. EFFLUENT

                      J
 RELATION OF DETROIT SEWAGE TREATMENT PLANT

 DISCHARGE TO AVERAGE DETROIT RIVER FLOW.

-------
RANGE 6A   ZUG ISLAND,   ACROSS OUTFALL TO CANADA
              DWS. 100 FT ABOVE  ROUGE  RIVER
                                                              1316
lOO^OCO,
           500
                    1000      1500
                        FT  FROM
   2000      2500

US.  SHORE
                                                       30OO

-------
AVERAGE DAILY
BACTERIAL POPULATION
EQUIVALENT IN DETROIT
SEWAGE TREATMENT
PLANT INFLUENT,


3,250*000; &&£.
        AVERAGE DAILY
        BACTERIAL POPULATION
        EQUIVALENT IN DETROIT
        SEWAGE TREATMENT
        PLANT EFFLUENT
        23 B.P.E.
SEWAGE
TREATMENT
PLANT
                           U.S.P.H.S. DATA
                                                  EXHIBIT 3
                                                            CO
                                                            M
                                                            -~J

-------
                                                                   1318
                                             EXHIBIT  4
•0,000
•0,000
«0,000
10,000





ADDEI
ST
1
) BY
P
,•



1
1-


TJ
OT It
> •• OT tO«
r I
OT
T.4W
MAN



1
OT
or



|
14 •» OT

:
:
:
t.lm OT








1.*
         AVERAGE  DAILY STREAM LOADINGS
                COLIFORM  ORGANISMS

                     DETROIT  RIVER

                    U. S. P. H. S.  DATA

-------
                                            1319
   350,000 -,
                                      EXHIBIT 5
   300,000.
   250,000.
a  200,000
UJ
Q.
o
a.
UJ
e>
o
o:
   150,000-
    100,000.
^    50,000_
         0.
                    LOWER DETROIT RIVER

                    AT MOUTH    \
             UPPER DETROIT RIVER
S.T.R EFFLUENT
                                  U.S.P.H.S. DATA
    TOTAL NITROGEN  IN UNITED STATES

    PORTION OF THE  DETROIT RIVER .

-------
                                                          1320
                                       EXHIBIT 6
                ADDED
                BY STP
M I
             AVERAGE DAILY STREAM LOADINGS
                       CHLORIDES
                       DETROIT RIVER
                      U.S. P. H. S. DATA

-------
100
> 90.
2 80.
c/>^ 7°~
i2 6°~
Q 0 40.
LU Q_
iz 30-
CL § 20.
c/) _j
Si f°-
0
^ DURING DREDGING
F IN LAKE ST. CLAIR





















S AFTER STORM
f












AVERAGE
/ ST. P. EFFLUENT
/S T P EFFLUENT WITH
s^. i.i . ^i i L.wi_i>i i vv i i n
! VSEC°NDARY TREATMENT
ESTIMATED AVERAGE DAILY STREAM LOADINGS OF SUSPENDED SOLIDS
AT RANGE 6A IN UNITED STATES AND CANADIAN  WATERS OF THE
                  DETROIT RIVER.
                                             EXHIBIT 7
                                                             CO
                                                             N>

-------
                                         1322
                                EXHIBIT  8
     20.,
^
Q
CC
UJ
CL
CO
Q
ID
0
Q_
O

I
Q
	 i
•M0J
o
CO
Q
UJ
O
z
UJ
a.
CO
ID
CO


18 -

™
16.

_
14.

_
12.

10.
8.

"
6J
—
4.

^m

2.
0
LOWER DETROIT RIVER J




























UPPER DETROIT RIVER
V














*













ST. P. EFFLUENT

1
M


• ,
• ,
*f ,
,
•-
' * *
r - -
'''-,
r ',
•

t * s

;
, ..

ts

;\ "^
-' .
,,':, "-s-
^






















                               U.S.PH.S. DATA

ESTIMATED AVERAGE DAILY STREAM LOADINGS
OF SUSPENDED SOLIDS IN UNITED STATES
WATERS OF THE DETROIT RIVER.

-------
           D.W.S.-22 YEARS OF DATA
100
ci
d 90-
00
u. 80-
o
z 70.
o
£ 60.
i.i 5O
UJ v v/_
cr
£ 40.
LU
•••»
O _^
oc 30
UJ
n
u 20-
e>
2 10.
UJ
^ 0










1 ^D.W.S.
i^ *M^^WJ ^
	 1. 	 t • ' j t ] 1 	 Mill 	
-r ' ' *— *, •—%-». ^ 1 f
; • ' ' '"''
-, % "* f .. J -. "^****
: ' "

U.S.P.H.S. -^0
- '' *
" :
'


-


















     1942  1945
1950
1955
                                           100
                                          . 90
                                          . 80
                                          -70
                                          . 60
                                          . 50
                                          .40
                                          .30
                                          .20
                                            10
                                           0
I960   1964
YEARLY AVERAGE PERCENT REDUCTION OF B.O.D. AT
DETROIT SEWAGE  TREATMENT PLANT.       EXHIBIT 9
                                    CO
                                    N)

-------
                                    EXHIBIT 10
-x
§: 10.0
•c
§
*" 8.O
1 6.0
1
r
* 2.O
Lake
St.Clalr O.O
IOO % SATURATION
/ (water temperature 72° to 79° F
/
^









1
:
*•
i
1

<
:
\
i

1






',
















?'
';'
;-i








n


'.

,
'-•
'•
;i









1
1
I
&
m
X:
Level above which
— secondary treat-
ment is not nor-
— mally required by
regulatory agencies
~v




           5A  over outfall 73
             (in surface boil)
BA
12
       DETROIT DEPARTMENT OF WATER SUPPLY

AVERAGE DISSOLVED OXYGEN CONCENTRATIONS

STATIONS lOOfl. AND 500ft. FROM U. S SHORE OF DETROIT RIVER
             June 18 to Sept. 3, 1964

-------
                                   EXHIBIT  II
                                                      1325
  ,   ZONE OF 100% SATURATION ;>
  U?I?M, varies inversely with water temp.)
                                             Level above which
                                             secondary treat-
                                             ment is not nor-
                                             mally required by
                                             regulatory agen-
                                             cies.
    OT }0 I*  OTiOt   DTI74W   DT 14 tw   01 » f

                   RANGE
                DETROIT RIVER
MINIMUM DISSOLVED  OXYGEN CONCENTRATIONS
                U.S.RH.S. DATA

-------
                                                           1326
                                        EXHIBIT \2
bl
5?
X
o
o
bl

8
in
5

o
I
   60-
40-
£  to-
                       ft
         DT 10
                  IO «   DT IT.4W   DT 14.••  OT ».7m

                           N OE
                                          OT »-•
                                                Zone above which
                                               .secondary treat-
                                                ment is not nor-
                                                mally req'd by re-
                                                gulatory agencies
                                                (°/o varies inverse-
                                                ly with water
                                                  temperature V
           AVERAGE PERCENT SATURATION
                 DISSOLVED OXYOEN
                   DETROIT  RIVER
                   U.S.R H.S. DATA

-------
                               .8
d

zi
0- <
f*f\ *
CI 1
w UJ
o o
z
UJ ^
?^ tO  < 0.

O CC CO
CO LJ Q
CO > 2
Q cr z>
—~ Cv
CD Q^ 2
< H 0
< Q H
> 2 -
"

7-


6_

5.

4.


3_

2.


l_

0

\D.O. IN






^D.O. IN
4
^




>D.O. IN
t


100% OF RIVER FLOW
177,100 cfs





50% OF RIVER FLOW
88,55acfs





23. 4% OF RIVER FLOW
41,400 cfs


B.O.D. OF SEWAGE TREATMENT PLANT
^4


	 	 	 — 	 	

X


2 z

_3 u. 	 | ^~
H °- Z
-5 !~5 H~
Zj ^ ^ >•
.4 £ 5 £ g
u, o: >- K
o H or Q_
_ *J ^*^. lit •*•• t f\
IB ^U ^^? wV
d < S S
GO ^ a- z)
"~ r-\ ^ Q O
LU ^ LU °-
HL_ —5 ._
•^ '^ 3?^
>l %oSo
$ o: K n
• i *^p *~
1— H Z _j
CO UJ O —
0 UJ Q o 2
1965
                   1980
2000
2020
RELATION  BETWEEN DISSOLVED OXYGEN IN THE DETROIT RIVER AND
THE SEWAGE PLANT EFFLUENT B.O.D.
                                               XHIBIT 13
                                  E

-------
                                                        1328



                    G.  Remus
                            II A"
                    EXHIBIT "A








           DETROIT SEWAGE DISPOSAL SYSTEM




         ENLARGEMENT AND IMPROVEMENT PROGRAM




                   July 22, 1957




              (AMENDED - August, 1963)








                     AMENDMENT








              AMENDMENT - August 1963 - to  the Detroit




 Sewage Disposal  System,  Enlargement and  Improvement




 Program dated July 22,1957.




              In  the last paragraph  of the  introduction




 add "and the  Clinton River Valley - Dequindre Road Inter-




 ceptor District  (Shown on Exhibit 1, Appendix - Proposed




 Service Area  Map,  Revised August,1963).




              To  the section entitled "Schedule" add:




 "1964-1975 Additional  Interceptor Dequindre Road Sanitary



 Sewage Interceptor,  Fourteen Mile Road to  the Clinton



 River  Valley  will  not  affect the  rates proposed herein



 inasmuch as a special  charge to reimburse  the Water




 Board  for the  construction,  operation and  maintenance




of the Dequindre interceptor will be collected from

-------
                                                       1329






                   G. Remus




the users thereof".




             Revise Exhibit 1 to show the Clinton River




Drainage Basin - Dequindre Road District in the Proposed




Service Area.








          DETROIT SEWAGE DISPOSAL SYSTEM




        ENLARGEMErfT AND IMPROVEMENT PROGRAM








             The Sewage Treatment Plant and the sewerage




interceptor system now requires additions and improvements




to provide:




             (a)  Proper facilities to handle the con-




tinually increasing sewage and ground garbage load.




             (b)  Proper facilities to control the ex-




cessive fly ash now being discharged into the atmosphere.




The City is under notice that it is violating the law on




this matter.




             (c)  Improved treatment methods.  As the




plant is called upon to handle more and more solids,




better methods of treatment are needed to remove a




greater percentage of solids from the sewage, thus




lessening the amount going to the river.




             (d)  Added reliability and proper capacity




to the interceptor system.  Work has been deferred on

-------
                                                      1330


                   G. Remus


this item for some time due to lack of funds.


             At the same time these steps are being taken,


it is recommended that certain additional areas be


connected to the system, namely: Dearborn, West Wayne


County, and Southeastern Oakland County (Shown on Ex-


hibit 1, Appendix - Proposed Service Area Map).  This


area addition will broaden the revenue base and make


greater use of the plant's designed capacities.


             Historical
                                                     \

             The Detroit Sewage disposal system was placed


in service in 19^0, and the total cost was $27,379,000


including plant and interceptor.  Up to 1956 additions


and improvements were added costing about $4,000,000.


In 1956 further improvements were made costing $6,500,000.


The present indebtedness amounts to $7,220,000 in the


form of revenue bonds.


             The sewage disposal system serves Detroit and


34 adjacent communities.  Exhibit 2, Appendix, indentifies


the communities that are now served.  A total of 2,677,000


people are now being served; 1,909,000 of these are in


Detroit and 758,000 in the suburbs.


             Garbage


             The ground garbage load is heavy and in-


creasing continuously because of the expanding use of

-------
                                                       1331



                    G.  Remus



 domestic  and  commercial  garbage  grinders.




              Some  suburban areas have practically 100 per




 cent  domestic garbage  ground  disposal service and the use



 of  these  units in  Detroit is  increasing rapidly.




              The original design of the Sewage Treat-



 ment  Plant  did not provide for garbage disposal.  This



 program provides the service  of  domestic and commercial



 ground garbage disposal  for all  the area.  Curves shown



 on  Exhibit  3> Appendix,  illustrate the importance of the



 pertinent factors  involved, such as sewage flow, sewage



 solids and  garbage, and  what  effect the years will have.



              Fly Ash



              The Board of Water  Commissioners are and have



 been  under  notice  for  some time  that the present operations



 of  the Sewage Treatment  Plant are in violation of the law




 because excessive  fly  ash is  ejected to the atmosphere as



 the result  of our  sewage solids  burning operations at 9300




 West  Jefferson.  Fly ash is spread throughout the neighbor-



 hood  resulting in  many complaints.  Improved combustion




 equipment with proper  appurtenances must be constructed




 to  correct  this condition.




              Improved  Treatment




              The sewage  treatment load has gradually in-




creased.  The  increase is now accelerated for a variety of

-------
                                                      1332




                   G. Remus



reasons.  Principal factors are addition of ground garbage,



increased per capita use of water and more industrial



wastes.  This means the transportation of more and more



tons of waste through the sewerage system to the treat-



ment plant.  An improved treatment method must be con-



sidered, under any conditions, to reduce the tonnage of



wastes discharged to the Detroit River.  Chemical precipi-



tation is the method most compatible with a comparatively



moderate capital expenditure, but it entails a much higher



operating cost.



             Schedule



             To properly handle the sewage-garbage load,



additional settling basins, filters, incinerators, treat-



ment facilities, and interceptor improvements, with



appropriate housing enclosures, have to be constructed.



             A schedule of construction with estimated



costs, by years, follows:



             1958-61




             Plant Additions



             Pour more sedimentation tanks.



             Enlarged effluent collecting channel.



             Overflow channel to Rouge River.



             Second filter building.




             Ten more vacuum filters.

-------
                                                      1333



                   G-. Remus



             Building for incinerating kiln.




             One incinerating kiln.



             Fly ash collecting equipment for this



kiln.



             1958-61




             Interceptor Additions and Improvements



             Second siphon at Fort and Bayside.



             Evergreen section of west interceptor -




Ford Road to Warren.



             Regulator and diversion works at West




McNichols and Rouge River.



             Control gates on Conner Creek outlet.



             Alteration of Conner Creek intake well as




a sanitary pumping station.



                             Total - $20,000,000.




             1961-63



             Plant Additions



             Second filter building.



             Six more vacuum filters.



             Second incinerating kiln.




             Fly Ash collecting equipment for this




kiln.




             Interceptor Additions




             Additional regulation and diversion  works



on master plan - relief outlet.

-------
                                                        1334
                   G. Remus
                              Total - $ 5,767,000.00
             1965-75
             Plant Additions
             Three more sedimentation tanks.
             Four more vacuum filters..
             Set up dismantled incinerator.
             Install improved treatment process.
 (Estimate based on chemical precipitation process.)
             Interceptor Additions
             Additional regulation and diversion works
 on master plan - relief outlets.
                              Total - $ 7j027,OOP.
                        Grand Total - $32,794,000.
             Construction costs based on E.N.R. index
 of 808 for Detroit.
             Recommendations are:
       ^     That the above schedule be adopted and that
we be authorized at this time to spend $20,000,000. and
that money be spent as required to carry out the program
as scheduled.  Three million dollars have accumulated
towards this program.  The remaining seventeen million
dollars will be financed by the issuance of revenue
bonds, to be issued as needed.
             Increased operating costs and  debt  service

-------
                                                        1335

                   G. Remus

result because of the Improvement to provide better ser-

vice.  Many localities are already receiving considerable

garbage disposal service, which is not included in the

present sewage rate.  To provide for this extra service

and to adjust for these inequalities, a rate adjustment

is recommended of 10 cents per 1000 cubic feet on the

basis of water used.

             The program is designed to provide Sewage

Treatment facilities for 4 million people by 1980;

approximately 2 million in Detroit and 2 million in

the adjacent suburban areas.

             The average Detroit family uses approximately

3000 cubic feet of water every three months, therefore, the

proposed increase of 10 cents per 1000 cubic feet would

add 30 cents to that family's quarterly water bill.

             Present rate —  Total Water and Sewage —

Per 1000 cu. ft.
                                               Subur- Subur-
                                                ban*   ban*

                                      Detroit* Muni-  Indivi-
                                               cipali- dual
                                               ties
First      10,000 cu. ft. per month   $1.05  $1.19-?   $1.23

Next       90,000 cu. ft. per month     .8?   1.00-£    1.04

All over  100,000 cu. ft. per month     .75    ,87-i     .91

-------
                                                      1336




                   6. Remus



             Proposed Rate —  Total Water and Sewage —




Per 1000 eu. ft.



First       10,000 cu. ft. per month   $1.15   $1.29-|   $1.33



Next        90,000 cu. ft. per month     .97    1.10-?    1.14



All over   100,000 cu. ft. per month     .85     .97-I    1.01



             *  Plus service charge.



             Exhibit 4 shows the general plan of additions



as they will be made at the Sewage Treatment Plant and how



the improvements will cover the area now owned by the



Department.



             (Exhibits 1,  2, 3A, 3B, 30, 3D, 3E and



4 follow.)

-------
                                                                         1337
                                                   CLINTON RIVER VALLEY-
                                                   DEQUINDRE RD.  DIST.
 FARMINGTON
    DIST.
                                                   EVERGREEN DIST.
5.E OAKLAND
                                                             LAKE SHORE DIST.
           H^HLAND I wH.it LAKE <» . ........p^rvcY.;. v^^-; •/•: •!
                                                      CLINTON , x-  v)
 MIDDLE
 ROUGE
DISTRICT
 LOWER
 ROUGE
DISTRICT
                                                OAKWOOO DISTRICT
                                                    27,500
                                                    I4CT.S
                        PROPOSED SERVICE  AREA

            DETROIT SEWAGE  TREATMENT PLANT

                         I960 POPULATION 4,084,000
                                                                ^s-c3    1956
                                                                 AV,",^>.y ~3~>~7~.f
                                                                 EXHIBIT  I

-------
                                                         1338
I
        PRESENT SERVICE AREA
DETROIT SEWAGE TREATMENT PLANT
         1957 POPULATION 2,605,000
                                                     EXHIBIT 2

-------
CITY OF DETROIT
                                                             1339
                                                 DIVISION OF ENGINEERING
                       DEPARTMENT OF WATER SUPPLY
 SEWAGE  TREATMENT PLANT- ENLARGEMENT PROGRAM
     POPULATION SERVED
     PAST, PRESENT AND  ESTIMATED FUTURE           SHEET NO.   I OF 5
COMPUTED BY   V.ANDERSON    DRAWN BY   M.S.Y.              DATE JUNE 7,1957
 
-------
CITY- OF DETROIT
                                                                       1340
                                                          DIVISION OF ENGINEERING
                       DEPARTMENT  OF WATER SUPPLY
 SEWAGE TREATMENT  PLANT - ENLARGEMENT PROGRAM
     SEWAGE PUMPAGE
     PAST, PRESENT  AND ESTIMATED  FUTURE          SHEET NO.  2 OF 5
COMPUTED BY  V.ANDERSON   DRAWN BY  M.S.Y.              DATE JUNE 7/1957
   900
a.
UJ
Q.
to
   800
   700
<
Z
   600
=J soo
 i
UJ
o
2 400
2
o_
UJ
O 300
1
a:
UJ
   200
   100
         NORTHWEST INTERCEPTOR
         CONNECTED TO
         SEWAGE PLANT-
                                    AVERAGE SEWAGE PUMPAGE
                                    IF AREAS PROPOSED BY THE
                                    D.P.W. ARE ADDED IN 1959
           AVERAGE SEWAGE
           PUMPAGE
           (FROM ANNUAL
           REPORTS)
            -SEWAGE PUMPAGE FOR
            MOST OF DETROIT UP
            TO 1955
                -AVERAGE SEWAGE PUMPAGE
                IF NO MORE AREAS ARE ADDED-
                AFTER 1956 - INCLUDES
                DETROIT AND 34 SUBURBS
                                                 T
                                                      AVERAGE SEWAGE PUMPAGE
                                                      FOR DETROIT ONLY
-ALL OF DETROIT SEWAGE
 CAME TO THE SEWAGE PLANT
 AFTER 1955
     1940     1945    1950
                               1955
  I960
 YEARS
1965
1970     1975   I960
                                                               EXHIBIT 3B

-------
 CITY OF DETROIT
                                                                       1341
                                                          DIVISION OF ENGINEERING
                      DEPARTMENT OF  WATER SUPPLY
 SEWAGE TREATMENT PLANT - ENLARGEMENT PROGRAM
     SUSPENDED SOLIDS  REMOVED IN SEDIMENTATION  TANKS
     PAST, PRESENT AND ESTIMATED FUTURE          SHEET NO.  3 OF 5
COMPUTED ey  V.ANDERSON   DRAWN ay   M.S.Y.             DATE JUNE 10,1957
g  800
U
o
8
o
z
LLJ
I  600
(0
(0
tr
cr
LU
o_
p
"J
O
<
a:
LU
   50°
   400
   300
   200
    100
                    ASSUMING 50% SUSPENDED
                    SOL/OS RECOVERY FROM 1957
                    TO 1962 SAME LINE INDICATES
                    SOLIDS GOING TO RIVER-
         SUSPENDED SOLIDS
         RECOVERED
          (FROM ANNUAL
          REPORTS)
                                            SUSPENDED SOLIDS
                                            RECOVERED FROM
                                            ENLARGED AREA
                                                                 -SUSPENDED
                                                            SOLIDS RECOVERED
                                                            FROM PRESENT AREA
                                                  CHEMICAL PRECIPITATION PROCESS
                                                  STARTING IN 1963 WILL INCREASE
                                                  SOLIDS RECOVERY TO 80* AND
                                                  DECREASE SOLIDS GOING TO
                                                  RIVER	
                                                   -DETROIT SOU OS
                                                            SUSPENDED SOLIDS
                                                            TO RIVER FROM
                                                            ENLARGED AREA-
                                                           ZSUSPENDED SOLIDS
                                                             TO RIVER FROM
                                                             PRESENT AREA
     1940    1945    1950    1955
                                        I960
                                      YEARS
                                               1965
1970
1975    I960
                                                               EXHIBIT 3C

-------
                                                                         1342
CITY OF DETROIT          DEPARTMENT OF WATER SUPPLY     DIVISION OF ENGINEERING
 SEWAGE  TREATMENT PLANT-ENLARGEMENT PROGRAM
     SOLIDS INCINERATED
     PAST, PRESENT AND ESTIMATED FUTURE          SHEET NO.  4 OF 5
COMPUTED BY   V.ANDERSON   DRAWN BY   M.S.Y.               DATE JUNE 7,1957
   900
                                             SEWAGE SOLIDS
                                             PLUS GARBAGE
                                             SOLIDS FROM
                                             ENLARGED AREA
                                                                        SEWAGE
                                                                     SOL/OS PLUS
                                                                   GARBAGE SOLIDS.
                                                                   (PRESENT
                                                                   AREA)
CHEMICAL
PRECIPITATION
PROCESS ADDED
           SEWAGE AND GARBAGE SOLIDS
           INCREASE TO BE EXPECTED IF
           AREAS PROPOSED BY THE D.P.W.
           ARE ADDED IN 1959
                                                                  SEWAGE SOL/OS
                                                                FROM ENLARGED
                                                                AREA
                    SEWAGE SOLIDS
                    PLUS GARBAGE
                    SOLIDS
     SEWAGE SOLIDS
     (PRESENT AREA)
           SEWAGE SOLIDS
           INCINERATED
           (FROM ANNUAL
            REPORTS)
    DETROIT ONLY
    SEWAGE SOLIDS
    BO?. RECOVERY
                                                               DETROIT ONLY
                                                               SEWAGE SOLIDS
                                                               SOX RECOVERY
     1940    1945
        1975   I960
                                                                 EXHIBIT 3D

-------
CITY OF DETROIT
                                                           1343

                                                DIVISION OF ENGINEERING
                   DEPARTMENT OF WATER SUPPLY


 SEWAGE  TREATMENT PLANT-ENLARGEMENT PROGRAM

    TOTAL SOLIDS- ENTERING & LEAVING SEDIMENTATION  TANKS

    PAST, PRESENT AND ESTIMATED FUTURE         SHEET NO.   5 OF 5

COMPUTED BY  V.ANDERSON   DRAWN BY  M.S.Y.            DATE JUNE 7, 1957

  2600
  2400
(/)
<
(0

^
Q
  2200
2000
cr
LU
Q.
z
p
(0
Q
1-
0
"~
   1800
   1600
   1400
   1200
   1000
   800
     1940   1945   1950    1955
                                I960   1965

                               YEARS
                                                1970    1975   I960


                                                       EXHIBIT 3E

-------
                                              fA/orfh Property Line
SEWAGE  TREATMENT PLANT
                      Feet
                                                                           FIRST STEP

                                                                           SECOND STEP

                                                                           THIRD STEP
                                                                                               JAN. 1963
                                                                                               AUG. 1961
                                                                                            REV.JUL. 1957
ADDITIONS BV
DRAWN BY
                 dc.rson
              . A. Amrr-,or>&~
      TRACED BV
      CHECKED BY
               •*•
ENLARGEMENT PROGRAM
  GENERAL PLAN SHOWING
   ADDITIONS IN STEPS
       CITY OF DETROIT
DEPARTMENT  OF WATER SUPPLY
   DIVISION OF ENGINEERING
                                                                                          B-IOOO
                                                                                           EXHIBIT

-------
                                                     1345
                   G. Remus


                  EXHIBIT A-l


         NATIONAL SANITATION FOUNDATION'S
     SUMMARY, CONCLUSIONS AND RECOMMENDATIONS


                     SUMMARY:
             While specific problems are discussed in
the text, it is the judgment of the Board of Consultants
that the present degree of treatment, namely primary, for
municipal waste discharges into the St. Glair - Detroit
Rivers complex, will remain sufficient for some time to
come.  This does not preclude the possibility of additional
treatment sometime in the future, contingent upon
             a.  continued study and evaluation of river
conditions, treatment methods and water quality objectives,
to determine what, if any, improved treatment is required;
             b.  determination that, if such improved
means of treatment are  indicated, they are definitely in
the public interest.
             In summary, the Board suggests the following
conclusions and recommendations:
             1.  The treatment of sewage will require,
during the next 55 years, the installation of facilities

-------
                                                        1346



                   G. Remus




at the site of the Detroit Sewage Treatment Plant costing




at least $34 million.  Of this amount, $12 million must be




provided prior to 1975 to provide for expansion of the



existing primary facilities to the design capacity of the



present plant which was based on 4,000,000 people.  Ultimate



requirements for primary treatment will require an addi-



tional $25 million for a total of $59 million.  If secondary



treatment should be indicated, an additional $129 million



would be required during the next 55 years with an addi-



tional $4l million for ultimate requirements or a total



of $170 million additional.  This $170 million is based



on complete secondary treatment in terms of present



knowledge.  In all probability, lesser sums would be re-



quired for a future determined improved treatment.



             2.  Present evidence indicates that:




             a.  the St. Glair River can assimilate primary



treated chlorinated wastes from the St. Glair area;




             b.  the Detroit River can assimilate primary



treated chlorinated wastes discharged into it near Zug




Island, and at Wyandotte and other presently used locations;



             c.  the degree of treatment for a future pro-



posed Lake Erie - Huron River plant need not be deter-



mined until some time in the future;




             d.  it has not been established on the basis

-------
                                                        1347




                   G. Remus



of  information presently  available to the Board that




secondary treatment  is  indicated at this time for any




plants  discharging into the St. Glair or Detroit Rivers.




This  does not preclude  the possibility of additional treat-



ment  sometime in the future.  The need for and time table



of  any  additional treatment should be determined after



the studies already  in  progress and those recommended by



the Board have been  completed.




             3.  The metropolitan area here considered



now has in the Supervisors Inter-County Committee an



overlying policy making council, and in the Detroit De-



partment of Water Supply  a regional water utility agency,



already serving 50 areas,outside of the City of Detroit,



with  sewerage, drainage and disposal facilities.



             4.  The Board recommends that the re-




sponsibilities of the Detroit Board of Water Commissioners



be  geographically expanded to cover the sewage disposal




facilities (other than  those of strictly local service) of




the metropolitan area.



             5.  The financing of the program delineated



should  proceed under the  general auspices of the agency



proposed in Item 4.  The  present practice of the use of




the revenue bond as  a source of money and user charges  as




the sources of repayment  should be continued, because of

-------
                                                        1348




                   G. Remus



its demonstrated maturity of application and attested




integrity in the financial market.



         CONCLUSIONS AND RECOMMENDATIONS;



             1.  The Six-County metropolitan area of South-




eastern Michigan encompasses some 3*951 square miles.  As



a service area it is governed by 221 autonomous govern-




mental units.



             2.  The population will reach 5.8 million



in 1980 and 8.5 million in the period 2000 to 2020.



             3.  Because of the topography of the whole



area most of it drains into the St.  Glair - Detroit  River



complex.  A smaller portion drains into the Huron and obher



river systems.



             4.  The Detroit Sewage  Treatment Plant  re-



ceives some 80$ of the present sewage flow in the metro-



politan area.




             5.  The comprehensive sewerage plan proposed



will entail the construction of some 184 millions of



dollars of main interceptors over the next 40 years.



             6.  The program for sewage collection leaves



the responsibility for the provision of laterals and sub-



collectors entirely in the hands of local political  units,



where it now resides.




             7.  The metropolitan area here considered now

-------
                                                         1349




                   G. Remus




has in the Supervisors Inter-County Committee an overlying




policy making council, and in the Detroit Department of




Water Supply a regional water utility agency, already




serving 50 areas outside of the City of Detroit, with




sewerage and drainage facilities.




             8.  The Board recommends that the responsi-




bilities of the Detroit Board of Water Commissioners be




geographically expanded to cover the sewerage and drainage




facilities (other than those of strictly local service)




of the metropolitan area.




             9.  The financing of the program delineated




should proceed under the general auspices of the agency




proposed in Item 8.  The present practice of the use of




the revenue bond as a source of money and user charges




as the sources of repayment should be continued, because




of its demonstrated maturity of application and attested




integrity in the financial market.

-------
                                                      1350


                   G. Remus



                   EXHIBIT "B"



              TRUE COPY CERTIFICATE


STATE OF MICHIGAN,)
                  ) ss.
  City of Detroit )

           CITY CLERK'S OFFICE, DETROIT

             I, THOMAS D. LEADBETTER, City Clerk of the

City of Detroit, in said State, do hereby certify that the

annexed paper is a TRUE COPY OF RESOLUTION adopted (passed)

by the Common Council at session of

                         September 3, 19&3

and approved by Mayor

                         September 9, 1963

as appears from the Journal of said Common Council in the

office of the City Clerk of Detroit, aforesaid; that I have

compared the same with the original, and the same is a

correct transcript therefrom, and of the wiiole of such

original.

                    In Witness Whereof, I have hereunto

                        set my hand and affixed the

                        corporate seal of said City, at

                        Detroit, this 25th

                        day of August  A.D. 1964

-------
                                                       1351
                   G. Remus

                        THOMAS D. LEADBETTER

                                      City Clerk

             By Councilman Ravitz:

             Resolved, That the Detroit Sewage Disposal

System Enlargement and Improvement Program of July 22, 1957

be amended to include the attached amendments (henceforth

to be known as the amendment of August, 1963) and the same

is hereby approved; and further

             Resolved, That the Board of Water Commissioners

be and it is hereby authorized to enter into the necessary

agreements with municipalities in the proposed service area

with the understanding all such agreements shall be sub-

mitted to the Common Council for approval; and further

             Resolved, That the Board of Water Commissioners

be and it is hereby authorized to finance, construct,

operate and maintain a Sanitary Sewage Interceptor along

Dequindre Road from Fourteen Mile Road to the Clinton River

Valley as soon as executed agreements with a sufficient

number of communities in the service area have been ob-

tained to assure the economic feasibility of the project.

             Adopted as follows:

             Yeas-Councilmen Beck, Brickley, Connor, Patrick,

Ravitz, Rogell, Van Antwerp, Wierzbicki and President Carey-9,

             Nays-None.

-------
                                                     1352



                   G. Remus








                   EXHIBIT "C"
            DEPARTMENT OF PUBLIC WORKS




           COUNTY OF OAKLAND, MICHIGAN




              550 SOUTH TELEGRAPH ROAD




              PONTIAC, MICHIGAN 48053




                PHONE FEDERAL 8-4585








                              October 20, 1964








Detroit Board of Water Commissioners




735 Randolph




Detroit 26, Michigan




Attn:  Mr. A. C. Michael




Re:  Extension of Dequindre Interceptor, north




     of 14 Mile Road.




Gentlemen:




             This letter is intended to inform you of




the plans and progress schedule of this department in



providing sanitary sewers for the Clinton River area



of Oakland County.




             Between March 11, 1964 and May 12,1964, we




received requests from the Townships of Avon, Pontiac,

-------
                                                    1353
                   G. Remus

Waterford and Independence and from the Village of Orchard

Lake to "acquire" a sewage disposal system for the Clinton

River area of Oakland County.  These requests were received

by the Board of Public Works and the Board of Supervisors by

resolutions #64-6-103 and Misc. resolution #4342, respectively

The system was established as a County system, and plans,

specifications and an estimate of cost are being prepared.

          We are planning to construct an interceptor sewer

along the Clinton River as shown on the attached sketch,

which will outlet into the Dequindre Interceptor at the

easterly county line.  The extension of the Dequindre Inter-

ceptor from 14 Mile Road, northerly to the Clinton River

will be done by the Detroit Water Board.

          Our construction plans will be completed by

approximately February 1, 1965> and we expect to have

construction started by the Spring of 1966.  Our preliminary

plans indicate a construction cost of $10,220,000 to serve

a population of 142,500.

                            Very truly yours,

                            DONALD ¥. RINGLER

                            Deputy Director

DWR/ha

-------
                                                      1354




                   G. Remus








                   EXHIBIT "D"








HARRISON TOWNSHIP               MACOMB COUNTY, MICHIGAN








                              June 10, 1965








Mr. Gerald Remus,




Superintendent,




Detroit Water Board,




Detroit, Michigan.




Dear Sir:



             Enclosed are copies of the Central Macomb




Sanitary Sewer Study Committee report and Minutes of the




meeting of the proposed Central Macomb Public Works




Authority on May 26, 1965.




             You will note the report of the Technical




Committee contain® many suggested routes of sewerage con-




veyance.  Also that the last paragraph of the Minutes of




the Meeting of May 26, 1965 requests that I present the




report of the Technical Committee to you for your findings




and report.




             It was suggested that your report and findings




be presented at a meeting of the group in Mt. Clemens, to

-------
                                                        1355



                    G.  Remus



be  scheduled at  your convenience.




              We  hope that  the  report  contains  the  information




necessary to aid you and your  staff in  arriving  at rea-




sonable  rate projections,  however, the  services  of the



Technical Committee; Macomb  County Planning  Commission;




and the  Macomb County  Health Department are  all  at your



disposal at  your request.




              I am sure we  are  all hoping for an  early re-



port.




                         Very  truly yours,



                         RALPH E. BEAUFAIT,



                         Supervisor,



                         Harrison Township.




REB:KFC.








    MEMBER OF THE MICHIGAN  TOWNSHIPS ASSOCIATION



38151  L'Anse Creuse Road - Mt.  Clemens,  Mich.  -  Phone




              Phone Howard 3-5837—3-5838








              The meeting was called to  order at  10:10 A.M.



by  Bill  G. Rowden who  was  requested to  conduct the meeting




in  the absence of Mr.  Ralph  Beaufait, Chairman.




              The Acting Chairman briefly reviewed  the




discussions of the Technical Committee consisting  of local

-------
                                                         1356




                   G. Remus



community engineers and representatives of the County



Health Department and the County Planning Commission held



on May 17,1965, pursuant to the requests of the group at




their meeting of May 12,1965, held in the offices of the




Detroit Water Board.



             Rowden indicated that the purpose of the



meeting was to review the findings of the Technical



Committee concerning the recommendations for conditions



under which the Detroit Water Board would be requested



to furnish rates for transportation and treatment of



sewage to the communities in the central Macomb area.



             In response to the Chairman's request, Mr. De



Decker explained in detail the Technical Committee's re-



commendations.  In general, these included a review of the



tables and maps prepared and previously distributed to each



of the communities Involved prior to the meeting.  The tables



listed seven major conditions concerning points of dis-



charge in the district involved and the population and




potential customer estimates for the years 1970, 1980



and 2000.




             Bridges and Damon indicated that they had



recently met with Mr. Morey Richmond of the Michigan



State Health Department and recommended that Mr. Richmond



be invited to subsequent Committee meetings.

-------
                                                        1357
                   G. Remus
             On inquiry concerning the population esti-
mates for Selfridge Air Force Base, Mr. Thomson indicated
the probability that the population would decrease from
the present 7,000 in the foreseeable future due to the
general switch to a reserved type of population period.
             Through the continued discussion, it was
pointed out that the recent federal study on the pollution
of the lower Detroit River and Lake Erie further illustrated
the importance for the eventual integration of the future
community and regional system of sewage collection and
disposal.
             With regard to financing, it was felt that
general bonding capacity would be imposed through a joint
community effort and that a more favorable bonding
capacity would result if the Detroit system could build
the major trunk lines to service the areas.   The dis-
cussion of probable financing would be further explored
at a later meeting when additional rate structure in-
formation is obtained from the Detroit Water Board.
             The need for making maximum use of the
existing local sewage treatment plant capacities was
again emphasized as an important feature of combining
community efforts prior to the time that a trunk inter-
ceptor line could be constructed to the regional system.

-------
                                                      1358



                   G. Remus



             It was concluded that immediate steps should




be taken to obtain from each community: (1) Inventory of



present treatment plant capacity; and (2) The outstanding



indebtedness remaining on the existing sewage treatment




plants.



             Rowden indicated that the current studies



of the County Planning Commission involve an inventory of



the facility systems throughout the County and urged the



cooperation of the communities to provide assistance in



collecting this information which would eventually be



assimilated into a report on the existing facility systems



in Mac.orab County.  The original data will be retained as



a data bank in the County Planning Commission's  office



for immediate and future use by groups such as this



Committee.



             It was indicated that the information to be



collected by the Macomb County Planning Commission would



be of vital use to the communities involved in exploration,



and their cooperation would be forthcoming when requested



by the County Planning Commission.



             It was concluded that Mr. Ralph Beaufait,



Chairman of the Committee, would submit under cover




letter on behalf of the Committee the table of requested




transportation and treatment charges as prepared by the

-------
                                                        1359
                   G. Remus
Technical Committee to Mr. Gerald Remus, Superintendent
of the Detroit Water Board.  He would further request that
Mr. Remus present his findings at a meeting to be called
in Mount Clemens.  In addition, the Technical Committee,
Mr. Charles Beaubien, member of the Detroit Water Board
from Macomb County, and Mr. Morey Richmond, Michigan
State Health Department, will be invited to attend this
meeting.
             Mr. Rowden was requested to prepare minutes
of this meeting.
             Meeting adjourned at 12:06 P.M.
                         Respectfully submitted,
                         BILL G. ROWDEN, Director
                         Macomb County Planning Commission


BGR:cmp

-------
                                                      1360




                   G. Rgmus
                            tlTj.ll
                   EXHIBIT  "E








                     Office of




         WAYNE COUNTY DRAIN COMMISSIONER




               3523 CADILLAC TOWER




               DETROIT 26, MICHIGAN




                  Tel. 963-9540




                  April 2, 1965








To The Honorable




Board of Supervisors




County of Wayne




1320 City County Bldg.




Detroit, Michigan 48226




Gentlemen:




             I have read with interest the "Report on




Metropolitan Environmental Study, Sewerage and Drainage




problems and Administrative Affairs," prepared by the




National Sanitation Foundation for the Supervisors



Inter-County Committee.



             It seems to me that th® title of this study




is misleading inasmuch as the subject of drainage is dis-




cussed only in relation to a definition of the existing




drainage basins or as an outlet for combined sewer over-

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                                                      1361



                   G. Remus




flows.  I find no specific proposals for long range




planning of surface water runoff.




             While there is an inherent relationship




between the amount of potable water used and the amount




of sewerage, no such relationship exists in storm water




drainage.  I question that storm water drainage, projects




can be financed on a revenue basis as the report appears




to recommend in paragraph 9 of the "Conclusions and




recommendations."




             I am in whole hearted agreement with the




recommendations that the responsibilities of the Board




of Water Commissioners of the City of Detroit be expanded




to cover the sewerage facilities of the Metropolitan




area and that the financing of this program be similar to




that used in the present expansion of the regional water




system.




                         Very truly yours,




                         HENRY V. HERRICK




                         Wayne County Drain Commissioner



SBP/rs

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                                                       1362
                   G. Remus
                   EXHIBIT "F"
              BOARD OF PUBLIC WORKS
                 COUNTY OF WAYNE
                              1230 First National Building
                                Detroit, Michigan 48226
                                       962-7670
                                     May 12, 1965
To the Honorable
Sewage Disposal & Water Supply Committee
Board of Supervisors, County of Wayne
1320 City-County Building
Detroit, Michigan (48226)
Att: Bernard E. Hanus
     Ass't'. Committee Clerk   Re:  S.E. Mich. Sewerage &
                                  Drainage Study Nat'l.
                                  Sanitation Foundation -
                                  SICC REF: Our Itr.
                                  dated 4/21/65
Gentlemen:
             The Board of Public Works, at its regular
meeting of April 13, 1965, received "A Report on Sewage
Disposal Problems" and "A Report on Metropolitan En-

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                                                         1363




                   G. Remus




vironmental Study - - - Sewerage and Drainage Problems -




Administrative Affairs", as prepared for the Supervisors




Inter-County Committee by the National Sanitation Founda-




tion, with your request for a written evaluation thereof.




             Preparatory to compliance with your request,




these reports were analysed by our staff and the resulting




"REVIEW OP NSF SIX-COUNTY SEWERAGE, SEWAGE DISPOSAL AND




DRAINAGE REPORT" offered for board consideration.




             In accordance with formal action taken at a




regular meeting of the Board of Public Works on May 11,




1965, we now respectfully submit this "REVIEW OF NSF SIX-




COUNTY SEWERAGE, SEWAGE DISPOSAL AND DRAINAGE REPORT" in




response to your request for a written evaluation of the




aforementioned National Sanitation Foundation Reports.




                         Sincerely




                         BOARD OF PUBLIC WORKS




                         By WAYNE G. RICE




                         Deputy Secretary




WGRrccs



encl:



  Ten (10) copies of "REVIEW. . ."

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                                                         1364



                   G. Remus








         REVIEW OF NSF SIX-COUNTY SEWERAGE,




        SEWAGE DISPOSAL AND DRAINAGE REPORT








             The report, in two volumes, covers sewage




 disposal problems in one volume and, aided by a U.S.




 Public Health Service Grant, covers sewerage and drainage




 and administrative matters in the second volume.




             The report on sewage disposal problems be-




 comes a defense of combined sewer systems and primary




 treatment of sewage, based principally on the thesis that




 to reduce or eliminate the overflow of storm water-sanitary




 sewage mixtures to the Detroit River, to chlorinate or




 otherwise treat such overflows, or to go to a more advanced




 degree of treatment of sewage cannot be "economically




 justified."




             The report on sewerage and drainage matters



 contains an analysis of population growth of the six-



 county area and a projection of population growth to the




 year 2020 and to the ultimate development of the area.




 A system of interceptors to bring sewage to the present




 major plants and to a future plant near the mouth of the




 Huron River is set forth.  This plan,for at least a part




of the area, has been Wayne County's master plan since

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                                                        1365




                   G. Remus




1958.  Estimates of cost at 1964 prices and a schedule



for completion of various parts of the program are set



forth.  The report supports the combined sewer system




of Detroit, but the recommended interceptor program is




for a separate system.  Administrative recommendations in-



dicate the desirability of a "central agency" to own and



operate the large plant and interceptor facilities.  The



report then points to the Detroit Water Board as the



agency to do this job, and recommends financing of inter-



ceptors and plant expansion on a revenue bond basis,



implying that the revenues of all presently connected




users of the Detroit system would be used as a "base"



for the revenue bond financing of the facilities.






          CONCLUSIONS AND RECOMMENDATIONS






             No action should be taken to either approve



or disapprove the section of the report on Sewage Dis-




posal Problems, until after the U.S. Public Health



Service Detroit River-Lake Erie report has been pub-



lished and has been received and evaluated.




             The sanitary sewage interceptor plan and



program should be approved in principle and the resulting




"Master Plan" adopted.  This creates a regional plan,

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                                                       1366




                   G. Remus



without the necessity of submitting the area to the con-



trol of a "central agency."  The counties of Wayne and



Oakland have rejected the "revenue bond" basis for the



construction of interceptor facilities in favor of the



"limited obligation contract bond" method.  It is re-



commended that this method be reaffirmed.



             The proposal to enlarge the Detroit Sewage



Treatment Plant to provide adequate and proper sewage



disposal service to an expanded service area, has merit,



and subject to certain controls, should be accepted.   The



charges for sewage disposal service should be uniform



throughout the area, and should be subject to MPUC regu-



lations.




             Existing agreements for financing and con-



structing facilities as well as service agreements should



remain in effect and future construction of inter-county



facilities should be constructed by inter-county agree-



ment.  Facilities within a county which serve only the



county and its municipalities should be financed and



constructed by that county.

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                                                        1367
                    G.  Remus

                    EXHIBIT "G"

                     BOAKD OF
             COUNTY ROAD COMMISSIONERS
                    WAYNE COUNTY
            7th FLOOR CITY-COUNTY BLDG.
              DETROIT,  MICHIGAN  48226
                     962-7670

                              May  6, 1965

 To the Honorable
 Sewage Disposal and Water Supply Committee
 Board of Supervisors
 1320 City-County Building
 Detroit, Michigan  48226
 Ladies and Gentlemen:
              Your  Honorable  Committee has previously
 referred to this Board,  with a  request for review
 and comment,  a two volume report prepared for the
 Supervisors Inter-County Committee by the National
 Sanitation Foundation.   The  subject of the report
being  Sewerage and Sewage Disposal Problems of the

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                                                      1368

                   G. Remus

regional area.  Our review and comment and recommend-

ations are transmitted herewith.



                              Respectfully,

                 BOARD OF WAYNE COUNTY ROAD COMMISSIONERS


                 	A. BARBOUR	
                 CHAIRMAN



                 VICE-CHAIRMAN


                 	WILLIAM E.  KREGER	
                 COMMISSIONER
Address All Communications To The Board and Not To

                 Individuals

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                                                       1369




                   G. Remus








            REVIEW OF SIX-COUNTY  STUDY




                         OP




        SEWERAGE AND  SEWAGE DISPOSAL PROBLEMS








             The  report  is divided into three parts —




 in  two  volumes:   The Sewerage Study, The Disposal Study,




 and The Study  of  Administrative Affairs.  The findings




 and conclusions constitute a plea that the development




 of  a  regional  sewage disposal system become the re-




 sponsibility of the  Detroit Water Board and that the




 City  be allowed to continue with  its present level of




 sewage  treatment  and continue to  discharge untreated




 mixtures of sewage and storm water to the Detroit River




 and Lake Erie  because to do otherwise "cannot be




 economically Justified."




             I.   Six-County Sewerage and Drainage Study;




             The  term "drainage"  in the title is somewhat




 misleading in  that the report makes only a superficial



 review  of the  existing natural drainage as it relates



 to  the  sanitary portion  of a separate sewer system, no




 study being given to the storm-water problems of the




 areas to be served by separate sewer systems.  The ad-




ministrative recommendations of the report relative  to

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                                                        1370




                   G. Remus



operation of facilities by Detroit probably could not be



extended to cover facilities to solve these problems.



             The population projections appear to follow



the projected lows of the spread in population predictions



for Michigan and the United States, and might thus be



conservatively low when, for purposes of design of



facilities it would appear that they should be con-



servatively high.  It does not appear proper to omit



or deduct industrial areas from the total area from which



design population is derived, inasmuch as no allowance



is then made in the final projection for industrial equiva-



lent population.



             The tabulation of interceptor systems, by



listing combined sewer capacity together with separate,



suggests that there is capacity in Detroit's combined



sewer capacity to carry the sanitary flow from the



separate systems to the sanitary interceptors.  The



difficulty is that, during times of storm as combined



sewers carrying sanitary flow, they discharge an



"enriched" sanitary sewage-storm water mixture to the



rivers which they parallel.



             In the comparison of separate sewer systems



Vs. combined sewer systems,the report appears to con-




tend that the separation of sewer systems is difficult

-------
                                                       1371
                   G. Remus
and expensive, if not impossible, to achieve; and that
a combined sewer system is more desirable.  One can
imagine the reaction of the U.S. Public Health Service
to these findings — a report supported by U.S. Public
Health Service funds, which praises the combined sewer system
with its attendant overflows to the Detroit River and its
built-in exposure to the hazard of flooded basements.
The discussion concerning a control of combined sewer
overflows concludes that combined sewer systems dis-
charging into Lake St. Glair are justified in providing
storage for a one-year storm, but that a study should be
made to determine whether such facilities can be economi-
cally justified on larger combined sewer outlets, and
that chlorination of storm overflow may have merit in the
case of Parmington, but chlorinating combined storm
sewage overflows cannot be economically justified.
             The section on interceptor system presents
a detailed program of coordinated separate sewerage systems
to serve the entire six-county area.  The program is
clearly feasible and a logical schedule for the orderly
completion of the entire system is set forth.  Assign-
ment of the responsibility for the development of this
system to the Detroit Water Board would mean  that this
responsibility and the accompanying authority would be

-------
                                                        1372




                   G. Remus




vested in an organization whose primary loyalty is to an



area amounting to 3.5$ of the six-county area and whose



present population is something less than half of the



six-county population and will be 29# of 1980 population,



25$ of 2000 population, 21# of 2020 population and less



than 9# of built-up population — and whose own com-



bined sewer system may soon require a multi-billion



dollar renovation in order to eliminate or greatly re-



duce the overflows of the storm water-sewage mixture to



the Detroit and Rouge Rivers.



             II.  Six-County Sewage Disposal Problems



             Perhaps the first governmental recognition



of the problem of pollution of the Detroit River and



other international waters was the Boundary Waters Treaty



between the United States and Canada in 1909, in which



each country agreed that boundary waters and waters



flowing across the boundary would not be polluted on either



side to the injury of health and property on the other.



It was not until 1938-1939 that the first really signifi-



cant steps toward pollution control were made, when the



Detroit Sewage Treatment Plant and the Wayne County Plants



at Wyandotte and Trenton and their sanitary interceptors



were placed in operation — construction having been




aided by k<5% Public Works Administration grants.  One

-------
                                                       1373



                   G. Remus




can imagine the plans for projects which were proposed in



the intervening thirty years and the rejection of those




plans on the basis that the then present methods were




adequate and that the proposed projects cost too much



money and could not be "economically justified".




             The report sets forth in some detail data



showing the volume and uniformity of flow of the Detroit




River, which is elsewhere sometimes recognized as being



a part of the greatest fresh water resource in the world.



The river is not really a river but a channel connecting



two lakes and, in fact, derives its name from the French



"D'Etroit" for "the strait".  The report limits its in-



vestigations to the Detroit River and the effects of



chlorinated primary sewage treatment plant effluent, but



asks without supplying an answer whether Lake Erie is able



to assimilate this waste discharged into it at the outlet




of the Detroit River.



             The mean annual flow of the Detroit River



is compared to the average daily flow of the Detroit



Sewage Treatment Plant to develop a "dilution ratio"



for the plant effluent.  The dilution ratios derived are




inconclusive because this factor becomes critical at




seasonal times of the year when less than average river




flow must receive higher than average plant  flow.   The

-------
                                                       1374




                   G. Remus



    dilution ratio is meaningless because of the physical



 impossibility of distributing the effluent across half



 of  the flow on the river.  The investigation of dilution



 factor is limited to sewage treatment plant effluent, no



 account being taken of upstream combined sewer diversions



 or  pumping station by-passes.  The 23# Trenton channel



 flow is based on 177,100 cfs flow and is probably some-



 what less at lower river flows.



             The study of "dilution ratio" leads to a



 discussion of dissolved oxygen in the stream and the



 satisfaction of Biochemical Oxygen Demand (B.O.D.) by



 that dissolved oxygen, and then exaggerates the amount



 of  available dissolved oxygen, by computing the total



 amount in the river in February and July.



             The discussion of solids in treatment plant



 effluent opens with a dramatic statement that 92# of



 settleable solids are removed at the Detroit Plant.



 In  modern sewage works practice, this test is generally



 recognized as being inconclusive and is not relied upon



 as  an index of plant efficiency,  it should not be ex-



 pected that suspended solids in the sewage which fail



 to  be deposited in the settling tanks of tbe plant



 where the flow velocity is in the range of several feet




per minute would be deposited in the river where the flow

-------
                                                        1375
                   G. Remus
velocity is several feet per second.  Rather, it should
be expected that deposition of sewage solids would occur
in boat wells and coves along the river-front and in Lake
Erie where velocities are much lower.
             The effect of application of chlorine is
illustrated by comparing chlorine applied with per cent
of demand satisfied.  The Michigan Department of Health
specifies application of chlorine in sufficient quantities
to produce a residual of chlorine in the effluent.  To
chlorinate to a percentage of chlorine demand requires
much less chlorine and is much more economical.
             The report repeats some of the defenses of
combined sewer systems contained in the separate volume
on Sewerage and Drainage Problems, and states that in
the Six-County Area,combined sewers will discharge mix-
tures of sewage and storm water 89 to 90 times a year
for about 2% of the time during the year.  The fact that
each overflow may produce an effect which lasts for
several days in the slower moving parts of the stream
along the shore and in Lake Erie is not taken into
account in the 2# figure, which thus becomes misleadingly
low; 25% to 30# is a more likely figure.
             The characteristics of the sewage produced
by the municipalities of the metropolitan area are de-

-------
                                                       1376




                   G. Remus



scribed, and the requirement and goals of good treat-



ment practice are listed.  The oxygen demand of the



plant effluent is then compared with the hypothetical



amount of dissolved oxygen available in the Trenton



Channel flow.  No account is made of additional con-



ditions of dissolved oxygen depletion by storm water



overflows, industrial wastes, or other causes.  The



necessary adjustments in application of chlorine to



plant effluent from approximately 88$ of chlorine demand



to approximately 130$ are recommended in order that con-



trol of coliform to conform with the requirements of the



Michigan Department of Health and with the standards of the



International Joint Commission on Pollution of Boundary



Waters may be assured.



             The expansion of facilities at the Detroit



Sewage Treatment Plant is projected at $12,000,000 to meet



the anticipated flow from 4,000,000 people.  This program



has been scheduled since 19^7, when a 10^ per 1,000 cubic



foot rate increase was inaugurated to support a



$32,000,000 program scheduled for completion in 1975.



For several years, construction of these facilities has



been assisted by federal grants of 30# to 50$ of cost.




             The discussion of other considerations,in-




cluding Eutrophication or aging of lakes because of the

-------
                                                        1377




                    G.  Remus



 addition of nutrients, concludes  that  aging of  Lake  Erie




 is taking place  but that,since  responsibility for  the



 aging process  is probably traceable  to several  sources,




 the requirement  for further  degree of  treatment of sewage




 cannot be justified.   Cyanides, Phenols,  Insecticides  and



 Detergents can be controlled by means  other than at  the




 sewage treatment plants.



             The report,  in  conclusion, finds that within



 certain limitations the Detroit River  is  capable of



 assimilating chlorinated  wastes from present sewage  treat-



 ment plant installations,  no recognition  being  given to



 the effects of storm water or other  diversions  superim-



 posed upon the plant effluents.   Nor has  any recognition



 been given to  the fact that  the conventional 5-day B.O.D.



 parameter does not reflect the  effects of the total  load



 on the waters  of Lake  Erie,  where the  ultimate  B.O.D.



 manifests itself.   The report further  finds that secondary




 treatment of effluent  discharged  into  the St. Glair  and



 Detroit Rivers cannot  be  justified.  The  door is left



 open,however,  to further  evaluation  of secondary treat-



 ment requirements  based upon present or future  studies.



             III.   Administrative Affairs




             The discussion  of  administrative affairs




 recites some of  the  available methods  for solving  metro-



politan  area problems,  and for a  variety  of reasons,

-------
                                                       1378
                   G. Remus
rejects all of these except one.  It is proposed to turn
over management of the "large central facilities" to the
Detroit Water Board, for the reason that revenue bond
financing of interceptors and treatment plants would then
be available.
             The dominance of the core city in sewerage
and sewage disposal matters as well as water supply should
be extremely difficult for the municipalities of the
region to accept, especially since it is proposed that
even an expanded "Board" would be Detroit-oriented, since
"Detroit representation should continue to have a majority
vote".  This is most contrary to the "appropriate criteria"
listed in the report.
             It is suggested that the Supervisors Inter-
County Committee become the overlying policy-making council.
It is not conceivable that the City of Detroit would shift
policy responsibility for facilities, where Detroit debt
is involved, to a Committee of Supervisors from other
counties.  The report concludes with a recommendation that
the "long precedent, high sophistication,maturity of
application, and attested integrity in the financial
market" of revenue bonds be the basis for the financing
of the needed facilities.  The implication is made that
the revenues from the Detroit System, as well as present

-------
                                                       1379
                   G. Remus
suburban users would be pledged in support of such revenue
bonds.  This is difficult to reconcile with the proposal
for Water Board management of facilities.
             Wayne County and Oakland County Communities
have rejected the revenue basis for financing interceptor
construction and have, by contract with the respective
counties, acquired interceptor capacity for their ultimate
needs.  Even to consider an area-wide advalorem tax is
wishful thinking but, by the County-Municipalities type
contract, each municipality may choose the advalorem
method of raising the funds to meet its obligation,  if
it desires to do so.  Revenue bonds may bear comparable
interest rates with the contract type bond; but "coverage"
and maintenance of reserve surpluses require a higher
revenue rate than is necessary if the obligation is
supported by the contract to make periodic interest and
principal payments, and the "rate" or revenue method is
preferred by the municipality.
             IV.  Conclusions
             The report tends to support Detroit's plea
for continued operation of its combined sewer system and
primary treatment plant in the face of pending action at
the Federal level to require that storm water diversion be
limited and controlled or even eliminated, and in antici-

-------
                                                        1380
                   G. Remus
pation of a Federally-conducted survey and report expected
to reveal the extent to which Lake Erie and the Detroit
River have been polluted and degraded by combined sewer
overflows and inadequately treated sewage.  There are
legal questions concerning Detroit's ability to carry out
the proposals contained in tfee reports, particularly in
view of the bonded debt of several of the facilities
proposed to be made part of the Detroit system.
             It is recommended that:
             1.  The NSP Six-County Report on Sewage Dis-
posal Problems should not be accepted or rejected until
after the U.S. Public Health Service Detroit River-Lake
Erie Report is received and evaluated.
             2.  Wayne County should reaffirm its adoption
of separate sanitary sewers as the only kind acceptable for
future construction in Wayne County, and that the NSF
should be requested to issue a report on storm water
drainage problems.
             3.  The Sanitary Interceptor Program set forth
in the Sewerage and Drainage Study be concurred in,  and
approved in principle.
             4.  The concept of the enlargement of the
Detroit Sewage Treatment Plant to provide an adequate and
proper degree  of  sewage treatment for the expanded  service

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                                                         1381



                   G. Remus



area of that plant, financed on a revenue basis, be




concurred in, but that the Water Board be required to




abandon its dual Sewage Disposal and Water Supply Rate




Schedule — a low rate for Detroit customers and a higher



rate for suburban users.  Review and control of rates by



an appropriate body should be required.




             5»  The existing contracts for financing,



construction and operation of sewerage and sewage dis-




posal facilities must remain in full force and effect.



             6.  Future requirements of facilities within



any county, for that county, be the exclusive jurisdiction



of that county.



             7.  -Any facility necessary to be constructed



by two or more counties be constructed and administered



under the provisions of Section 17 of Act 3^2 PA 1939 as



amended, which follows, with review of rates and changes




under the Sewer and Water Committee of the S.I.C.C.




                     ACT
             Sec. 17.  Any 2 or more adjoining counties



which have, by resolution of their respective Boards of




Supervisors, authorized and directed the establishment of




any of the improvements, facilities or services authorized




by this Act, may contract for the Joint establishment,




operation or maintenance of any such improvements, facili-

-------
                                                      1382




                   G. Remus




ties or services, or any portion thereof.  Such contract



shall provide for the establishment of an administrative



agency to be composed from the membership of the respective



county agencies, and such administrative agency shall have



and exercise all the powers and duties conferred upon a



county agency under the provisions of this act, except



as the same may be specifically limited by the provisions



of said contract.



             Any bonds issued to finance the construction



of improvements under such contract shall be the joint



obligation of all participating counties.

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                                                      1382-A




                    G. Remus
                           UTT"
                   EXHIBIT "H








          Excerpt from statement made at the National




          Legislative Conference of National League of




          Cities, Washington, D. C., March 30 - April 1,




          1965, by Mr. James M. Quigley, Assistant




          Secretary of the United States Department of




          Health, Education, and Welfare.








          "Another facet of the Federal Water Pollution




Program which is now pending before the Congress is worthy




of note.  The legislation contains a new provision which




recognizes that, particularly in our older cities, one of




the tough, difficult, hard to solve, almost impossible to




solve, water pollution problems arises from the fact that




many older sewer systems collect both sanitary sewage as




well as storm runoff.  The result is that we can build very




effective modern treatment plants, but every time it rains




the volume of water flowing through these combined storm




and sanitary sewers is so great that you have no alternative




other than to bypass the sewage treatment facility allowing




all the storm water to flow into the nearby river or stream.

-------
                                                       1382-B
                    G. Remus

"The result of this, of course, is the same as had the city

not built the sewer treatment facility in the first place.

          "It is worse because a high volume of storm water

flowing through the sewer system at a high speed, succeeds

in flushing out all the accumulated sewage.

          "Until and unless we can successfully lick this

problem, we are not going to do the job which needs to be

done in cleaning up the rivers and the streams of the country.

Recognizing this problem, the Congress is about to pass, I

say with reasonable optimism, an amendment to the Federal

Water Pollution Control Act which would permit our Department

to expend the sum of $20,000,000 a year on this problem for

the next four years.  This money could be used in experiment,

research, and demonstration projects trying to devise effective

ways and means to cope with this problem which comes from

the existence of combined storm and sanitary sewer systems.

We all recognize that tearing up all your streets today to

install separate storm sewers would be frightfully expensive,

terribly annoying to the taxpayer, and probably by the time

the whole thing was through, you would be lucky if you had

your sanity and amazed if you still had your office.

          "We are trying to avoid these horrible consequences

by searching for a way through the expenditure of seed money.

-------
                                                      1382-(




                    G. Remus



"We hope we can demonstrate that there are ways and means



of doing this job, ways of coping with this problem, that



are less expensive, less annoying, and more effective than



tearing up our streets and putting in a totally new sewer



system in our cities."
                        # •*

-------
                                                         1383
                  Gerald Remus
             MR. REMUS:  1 would also like to place in the
record that we received this report on May the llth.  Today
is June 17th, and a large technical problem of this kind,
when preparing a report on it, may create a situation where
we have made some statements in the report that should be
double-checked.
             We do not know that those are in there, but
if they are, we would like to have the privilege of correct-
ing it.  After all, on our report, nobody had time to edit
it for seven months.
             MR. STEIN:  Well, how about our giving you
seven days after this is over to edit it before we close
the record?  I know you can handle that.  Is that all right?
             MR. REMUS:  That wiM be satisfactory.
             MR. STEIN:  All right.
             MR. REMUS:  Again I want to point out that I
am only going to discuss principal points relative to what
we are now doing and what we intend to do in the future.
             The problem, from our standpoint, develops
this way:  Today the national policy is directed towards
stream renewal.  I would just like to point out that De-
troit started in 1940.
             The issue, of course, is not whether the river
has to be cleaned up.  The Detroit River must be improved.

-------
                                                         1384
                  Gerald Remus

The issue is, how can this best be done with the available

money that we have to work with?

             From our standpoint, first things first.  In

1940, Detroit built a 27 million dollar plant and put it in,

and it has gradually been improved, interceptors have been

built, repumping facilities have been built, more equipment

has been installed, and we will continue on that course.

             But at that time, and as time developed, it

became apparent that you could not develop one sewage sys-

tem for each municipality in the area, and someone had to

figure out a method whereby we could develop one system

for the area, or at least substantially so.

             In 1957, this program was reaffirmed.  I just

want to point out that today there are 61 sewage systems

in this drainage basin on United States shores, and if we

had not in 1957 developed a program whereby some of these

communities, instead of being organized together with a

central city to develop systems, we would have had in ex-

cess of 100.

             Using that as a basis to work with, it follows
then, how do you best handle this problem?  Can it be

handled piecemeal?  Our answer to that, of course, is it

cannot.

             So there are three basic factors that must be

-------
                                                       1385
                   Gerald Remus

met.  We must have an administrative setup, we must have

a method of financing available to us, and then we must

have a program of gradual improvement.

             To point out how that has progressed, we would

just like to review the record.

             The entire program is based on the same type

of governmental and contractual arrangement that is worked

out for the water program.  It is a program whereby, on a

revenue base, with contracts that are prepared between the

central city and the suburbs, we provide a service and

charge for that service.  The contract specifically goes

for water and sewage, that we will provide that service

at cost.

             The contract specifically says that as im-

provements are available and can be made, we will make

them.

             Specifically, in 1957, we said that we would

adopt intermediate treatment or chemical precipitation,

and we have been making some progress on that, and we are

doing a lot of research work on it.
             Sticking to the business aspect, the contracts

provide that the system will gradually develop in one uni-

form way, that everyone will be doing their part, large

and small.  That gets us out of this business where every-

-------
                                                       1386
                   Gerald Remus

body sits on the sideline and pokes at Detroit and says,

"Come on, get going.  What about the rest of you?"

             I think you will notice that in these proceed-

ings, the biggest effort is directed towards Detroit.  A

large amount of that is because those who do the poking

towards Detroit don't have to do anything themselves.

             In 1964, the program we were on was reaffirmed.

The six counties of this area looked at it and said, "Let's

get the work going to the standpoint of the entire drain-

age basin."  In order to do that, we had to have three

conditions met.

             One is how to administer it; second, how to

pay for it; and, third, what has to be done?

             The areawide approach was reaffirmed last

Friday by this Metropolitan Fund, Inc., a blue ribbon com-

mittee that again looked at this business of how to handle

the services for an area.  Again they said one area serves

for the area on a utility basis.

             That is nothing new.  We knew that.  In fact,

we have it in law as far as our electric service is con-

cerned, our communications, and our gas company operations.

             Now the issue is further expanded to the ef-

fect that the impression is created that if we spend enough

money, if we reach high enough as far as expenditures are

-------
                                                      1387
                  Gerald Remus
concerned, that we will have a clean stream down there,
and that we have answers for all the problems that exist.
             Of course, as I go through my report, I will
point out that which we know the answers to, what we are
doing about it, and those that we do not know answers to,
and what we think should be done.
             Before I go on, again 1 want to point out
that both water and sewage, the two essential services
you need to make an area prosperous, have been organized
on a business basis in the metropolitan Detroit area in
a method that has not been used anywhere else in the
country.
             In the water program, we are further ahead
than we are in the sewage program, and of course we would
expect to be, but the sewage program has developed far
more rapidly than apparently the public has been aware
of.
             Today we serve 49 communities besides De-
troit.  We have picked up all the additional pollution
load that was in the Detroit River, all the additional
pollution load that has developed due to the large indus-
trial expansion in the area that we serve, and, on top
of that, we have improved the Detroit River.  I will
reflect on those factors in a little while.

-------
                                                      1388
                  Gerald Remus
             With the administrative setup of having an
areawide commission to operate the system, we are then
asked to determine or to reveal to you or review with
you what money has been spent.
             I mentioned the 27 million dollars in 1940
to build a plant.  In 1957, another 32.8 million dollars
was committed for improvement.
             This improvement within the Detroit system,
and the fact that they were building dams around Detroit
for lack of proper sewage facilities, initiated a program
that got the ball rolling, to the extent that since 1957
there has been $266,900,000 spent for collection and
treatment of wastes of our area, of Macomb, Oakland and
Wayne Counties.
             The 1957 program, when it was adopted as to
what we were going to do, was reviewed with many agencies,
and we expressed very clearly what we were going to do.
We worked with the State Board of Health on what we would
do, what construction would take place.
             And again I point out that we used revenue
bond financing for all our work, and in order to issue
bonds we must have solid data to work from, we must have
a good organization as far as being able to carry that
out,  and we must be able to show results and say what

-------
                                                       1389




                  Gerald Remus




those results will be ahead of time, or otherwise we can't




get the financial backing we need to do the necessary con-



struction .




             The work schedule since 1957 roughly was due



to the fact that we built additional sedimentation tanks,




additional sludge filters, large effluent conduits, emer-




gency outfalls, sludge incinerators, repumping facilities,



improved operations systems during storm runoffs, improved




bacteriological treatment, and, in addition, there is now



and will be continued for some time a 50 million dollar



program for enlarging the size of our storm sewers, which



are designed so they will fit into the system and help in



abating the storm flow operation.



             I want to make just one overriding statement




here, that in the Detroit area, this is the only area



where we have been making real good progress on having




an organization to do an areawide job which is essential*




We have the financing basis to do that which we have com-




mitted ourselves to, and we are doing it, and the results




show that we have.



             A great deal of the data that 1 will now re-




fer to in these coming paragraphs here you will find in




the U. S. Public Health Service report.  I think, however,




I should call your attention to the fact that they didn't

-------
                                                    1390




                    Gerald Remus



highlight it.   The parts that were highlighted were



those that needed his attention, and I use that statement



or sing the song in reverse.  They accentuate the



negative and eliminate the positive.



            Now, the method whereby we determine whether



we are getting results on the Detroit River are these



coliform reductions.



            In 1959 a median value was 68,000 per



one hundred ml.  That is the actual bug count.



            In I960, 23,000.



            In 1961, 53,000.



            In 1962, 16 hundred.



            In 1963 580.



            In 1964 930.



            The agreed-upon level between the United



States and Canada is 24 hundred.



            The data I read to you includes the sewage



plant outfall, but does not include the Rouge River



involvement.



            Incidentally, the Canadian shores showed in



the range of 9 thousand, 4 thousand, 33 hundred at this



time compared to our 580 and 930.  I did not know until



I read the United States Public Health Service report



that there was a standard for beaches, bathing beaches,

-------
                                                   1391
                     Gerald Remus
but there are indications that It Is 1 thousand
organisms per ml as the  standard.    So, except for storm
flows and on the basis of bacteria count, we meet their
standards for the quality of water that you need to swim
in as far as a beach is  concerned.
            Now, this was done by a great deal of
expenditure of money for additional chlortnation,
additional diffusion, additional settlement basins, as I
pointed out, and we think more can be done in this
business of disinfectants, but we believe that the
sewage plant has done about as good as it should be
required to do as far as this particular phase of it alone
is concerned.
            In fact, the median values for the sewage
plant effluent for the year was the equivalent of the
organisms that would be  developed in the waste of 23
people; and, remember, we have close to three million
people on the system.
            Since 1948 the grease and oil found in the
Detroit River has been reduced 79 per cent; the phenol
71 per cent; ammonia 22  per cent; cyanide 72 per cent;
and syspended solids 51  Per cent.
            I would review Just a little bit this data
again, because I would like to call your attention to

-------
                                                     1392




                  Gerald Remus



 the  fact  that  the United States Public Health Service



 report  follows along with  this type of improvement.



 The  work  we  have now under construction for improvement



 is approximately 2,200,000 dollars of work at the  sewage



 plant for additional filters so that we can increase



 our  detention  time.



             We have a  sedimentation basin*  We have



 improved  smoke abatement equipment going in.  We are



 developing improved sludge conditioning facilities,



 and  we  are improving our grease handling equipment.



 In addition, we spend  better than 5 million dollars a



 year Just in operating costs.    We are doing an



 extended  Job in resetting  our regulators so as to



control  the storm flow  that goes to the River.



             This is a  large job and takes a great  deal



 of study  to  properly set it, because it is an



 evaluation of  dry weather  flow versus storm flow.



             Now, Just  one  thought as to whether we are



 up the  ladder  high enough  on this treatment process.



 The  point that I wish  to make is that by taking care of



 the  area  development it was possible for us to collect



 those wastes that would not have been taken care of,



 and  the record shows this  to be a factj even if we had



 Increased our  treatment level, the net result for  the

-------
                                                     1393





                    Gerald Remus



 River would have been negligible, If improved at all.



             The reason I mention that is that it is



 for that reason that it is imperative that we set up a



 system to collect the waste at a reasonable treatment



 standard before we raise the standards,  and when we



 do raise those standards, they should be raised on the



 basis of a reasonable and regular improved factor,



 knowing what we want to do and what results we would



diow after we have a new treatment process that is



 adopted.



             The objectives, of course,of our operations



 here are to continue to expand the collection system.



 Our objectives and our actions already indicate that



 the gradual improvement of treatment has taken place.



             We are formally committed to the State



 Board of Health to put in improved or chemical precipita-



 tion as a treatment process, and that we are working on



 and spending a lot of money to try and bring the one



 great problem that exists in the area under better



 control, namely, the storm sewer operations.  This



eliminates one of the serious problems which I reflected



 on Just a second ago, that if we do not  expand the



system there will be no machinery available to gradually



 eliminate the 177 thousand septic tanks  that yet exist

-------
                                                    1394
                      Gerald Remus
 in the City;  nor will there be any machinery available
 to help eliminate these little sewage plants that were
 developed  for one suburb only, and now that the
 area has developed they are grossly overloaded.
             Our program for the future, as far as we
 are concerned is to keep to the objectives that  I have
 Just mentioned.
             Now what will this cost to develop a system,
 to make the gradual improvements to the treatment,
 to take care of what has to be done in this drainage
 basin;so that we do not become stymied in the develop-
ment of this apea, it will take 180 million dollars worth
of plant and interceptor facilities in the next 18 years.
             We have the financing rate set up so that we
 can finance that construction.
             You of Detroit will remember that in 1957
 we raised the sewage plant rate 77 per cent so that
 we could build a financing base that would support
 revenue bond financing so that these improvements could
 be made gradually with the revenue officer recognizing
 in some areas that the first few years the revenues will
                                     *
 not support the development.    This revenue base must
 be protected.   We have a plant that will take care
 of 4 million people at the present treatment standards,

-------
                                                  1395
                   Gerald Remus
and we know that we have a little less than 3 million
on there, so this becomes a part of what should be done
to develop.
            Now, the major work that we plan for con-
struction in this development Is again a repltltlon of
what I have already mentioned:  additional sediment
basins, Interceptors for Oakland and McComb Counties;
complete monitoring system of our storm flow so that
we can better control ourustorm flow; preventatlve
sewer cleaning; more disinfection; expanded sludge
flltralon capacity; Improved regulating and diverting
devices; and whatever treatment Is necessary to protect
the public health and welfare.
            Now, there are several points of this Job
that we think are subject to a consldrable amount of
review; and we think that much progress can be made
on two fronts.  One Is one I have already reflected on,
and that was the storm flow.   The second one, however,
that we believe a businesslike program can be developed
on Is one that we must and will develop a program whereby
wt will control and work out a treatment process with
those Industries that have special treatment problems.
Many of the factors that come into our plant cannot
be treated by the plant and therefore should not be

-------
                                                   1396
                 Gerald Remus
allowed in.   I am referring to phenols, oils of some
nature.   I would like, however, to point out what I
mean by that.    I see Mr. Baldwin of Chrysler Company
up here.   On two points  we were able to work out
with them an improvement that involved some treatment
by them, and then something that with our system we
were able to take care of critical oil wastes effectively
with a minimum of cost to them, and as a result with
their effluent being handled in our system.
            Secondly, we have developed what we think
is an indication of what can be done and what must be
done in this process of pollution control.   We call
it preventative pollution development, or you can use
any type of terminology you want; but this idea of
preventing this situation developing is the fact that
they now by grinding oils for the purpose of their
processing,that does not include phen&L, one of the
culprits that we have to continually contend with.
            We think that every industry in the area—
particularly when you recognize that our wastes are
changing each day, particularly the wastes of the
chemical industry, the radioactive industry, the high
concentration of new materials that are used in the
processing of these metallurgical products that are

-------
                                                    1397
                    Gerald Remus
used in our space program, we think it is particularly
important that we know what those are before we get
in the business of trying to take them out of the plant
and throw them in the river.
            There Is a limit to what a modern treatment
plant can handle.   In our position, I want to make it
very clear that we intend, with business, to work very
cooperatively, that we intend to do this on a preventative
basis, that we do not believe it could be done by us
using police action.     We believe that the end result
will be good for the industries in that it will save
them money; it will help us in our processing so that we
will know what will be coming in there.  And I want to
make it very clear that with this type of operation
we have before us a method of financing this approach.
            The City of Detroit this July has set up for
the first time the operation in the Department of Water
Supply on this phase of this problem.
            Now, there is one phase of the points that
I want to touch on a little bit, and that is the relative
questions of water and sewage treatment.   It is our
opinion that water supply and sewage treatment is one
economic problem, and unless we can find other means of
doing this Job, of handling it, except with money, then we
have to treat it as one economic problem.

-------
                                                     1398
                  Gerald Remus
            To show what can happen, I would like to
Just cite one example; that we, if we adopted all the
treatment processes that we think might help the river,
and even if we could get ahold of the money, we would
have to raise our rate in excess of 380 per cent for
sewage treatment.    We all know that water supply atid
sewage treatment is billed on one bill in Detroit.
That would constitute almost, or approximately doubling
the bill every family woultf get in Detroit. In some of
our suburbs ft would be more.
            If you doubled the water bill in Detroit, as
was done in Flint,where the rate was increased 50 per
cent and the usage dropped 33 per cent—a strong indicator
that if you do not use good progressive business
practices in the operation of your system, that it isn't
long that you can Just overload yourself with obligations
that will ruin your entire business operation.
            That, of course, is the thing that we watch
very closely because we have an AA rating on our bonds
or investments base for water; we have an A rating
on our sewage; and for the benefit of the people from
the Detroit government here on the Water Board, I
would Just like to point out that that is better than
a 00 bond in the City of Detroit.

-------
                                                     1399




                    Gerald Remus



            I would like to reflect on what the U. S.



Public Health data shows has occurred in the Detroit



area; and I would Just point to some of the factors.



The coliform bacteria has decreased 99.99 per cent; the



fecal conforms have decreased 99.9 per cent; fecal



streptococci 99.9 per cent; suspended solids 51 per cent;



oil and grease 79 per cent; ammonia 22 per cent;



chlorides in the lower river 18 to 44 per ml--U. S.



Public Health Service, milligrams per liter, U. S.



Public Health Service drinking water standard permitted,



250 milligrams per liter.



            We also read in their record that our sewage



and storm water system is large enough so that when we



have storms that we can retain up to three-tenths of an



inch of rainfall, the first flush of a storm to that



extent which does the most damage when it rushes to the



r iver.



            The data that I read to you is the data that



is measured below the sewage plant outfall, so that no



one gets concerned about the record showing that we are



moving it down-river, and in effect doing a situation



there that causes us Just to move our dirt to some other



area.



            Again I want to make it very clear, so that

-------
                                                      1400
                    Gerald Remus

is not misunderstood, the factors that I have given you

that are in there from our records -- the factors that are

in here — that were also reaffirmed and are mentioned in

the U. S. Public Health Service report, are data that was

prepared in the process of this report and ours; total

reports below the "sewage plant outfall.  So, the effects

of this waste from 3 million people, with the greater

portion of all the industrial wastes of the metropolitan area

included, are included in this program or in this data.

          Now, there are some factors that I want to bring

in here that I think: cause us a great deal of concern.  I

don't mean I think; I know it does.

          The report of the Department of Water Supply shows

that on the suspended solids, from 9*125 samples, that we

had a removal of 49.5 percent of those suspended solids.

The U. S. Public Health Service record shows that they took

16 samples, and the percent of removal was 39 percent, or

10 percent less.

          Our record shows that we took better than 9 thousand

samples on settleable solids, and that our removal was 84.3

percent for the system for that period of time, that is,

over quite a number of years.

          The U.S. Public Health Service samples of

-------
                                                     1401
                    Gerald Remus

16 shows 52 percent, almost half.

          Likewise, as to the BOD, in 9 thousand samples or

better there was a removal of 37.2 percent.  The U. S.

Public Health Service samples of 8 show a removal of

17 percent.

          Now, we believe that that is too wide a margin,

and we believe that if statistical data of this kind is

published and is used to support various positions that

various people may take, you have just about cut off our

capability of developing a system, because anybody can take

this contradictory data, when we wish to issue revenue

bonds, and go up to Lansing when the Municipal Financing

Commission wishes to act on it, and say, "Well, we think

they are not giving you the true facts.  Here is what the

facts are."  As a result of that, the two positions make it

impossible for us effectively to issue revenue bonds.

          I say that, because the State law says you cannot

issue revenue bonds if you have a lav/suit, or an impending

lawsuit.  Anybody can start a lawsuit in Michigan for 16 bucks

now; and certainly, if we wanted to improve the plant, why

this is wide open data for no progress.  So, before any deci-

sions can be made on secondary treatment or any other improvement,

-------
                                                    1402
               Gerald Remus
this data must be resolved.    Our data has never
sufficiently supported the necessity for secondary
treatment.    We have very energetically supported
Improved treatment; but I wish also to point out that
our finance base in 1957 that was established was built
to improve the system on a basis of treatment standards
that were agreed upon  between the State health officials
and the Detroit Water Board; it was based on the fact
that we would make certain expansions to the system,
to the collection system, to the site of the plant,
and that is now firmly financed; that if we, however,
take on another obligation of the type that our
consultants tell us will be 129 million dollars, on top
of the l8l million dollars that we have committed our-
selves to, then, of course, we break our financing back
and we, are not in a position to proceed.
            So, if the higher forms of treatment
after we get the data reviewed clarly shows that
secondary treatment will improve the river, if it
clearly showed the nature of the improvement, which is
not now shown, and if it clearly shows that we will be
able to keep the wastes under control, then, of course,
with the additional money that could be made available,
we could probably proceed on that matter,but we are

-------
                                                      1403



                   Gerald Remus



 not in a position at this time to make that decision In



 that way. We do not Intend to pause on our stream



 renewal efforts.    We Intend to continue on the program



 adopted In 1957 and reaffirmed In 1964.     We are



 actively engaged In various types of research now,  and



 we shall cooperate with any agency that has any capability



 or in any way toward improving our research program,



 because we believe that in this area a great deal has



 to be done.



             I am talking about such wastes as sulphates



 and nitrates.    I am talking about the storm flows which



 Mr. Quigley, Assistant Secretary of Health, Education,



 and Welfare reported on to the National League of Cities



 about a month ago where he said there is no practical



answer for that.



             I want to just make one further comment.



 I am referring also to uhe so-called aging of the lakes



 and of all the things that were found.   It surprises



 me that U. S. Public Health Service's report couldn't



 find the 50,000 cubic yards of dirt that go down the



 Detroit River every time we have a storm, or the 4700



 cubic yards that go down every day that cause most  of



 your dredging problems, and we have letters from the



 Army engineers that so indicate.

-------
                                                     1404
                     GeraldRemus
            So, in ay fins I conclusion here,  I Just
want to point out that we intend—we again  re-
emphasize  that we intend to continue our  stream renewal
program by expanding our area-wide operations,  by
taproving our treatments, with  special attention to
pollution  prevention, and by energetic study  to control
the wastes , for which the technology today has no
sollution.
            And finally here now—and I will  get it  in
the record tliat we challenge anyone on the  
-------
                                                        1405
                    Gerald Remus

questions.  Is your challenge to the communities on the

Great Lakes extended to Chicago?  That removes better than

90 percent.

          MR. REMUS:  No, I did not mention Chicago, and

I didn't know that Chicago was doing it.

          MR. STEIN:  Anyone on the Great Lakes, you said.

I just wanted to clarify that.

          MR. REMUS:  What do you mean, "removes 90 percent"?

          MR. STEIN:  B.O.D. and solids.

          MR. REMUS:  That wasn't how I read your report

on Chicago.

          MR. STEIN:  Did you read our report on Chicago?

          MR. REMUS:  I looked it over pretty good.

          MR. STEIN:  Well, that is what Chicago says.   I

won't dispute it, and we didn't.

          One other point in clarification before we go on.

Since you did mention Secretary Quigley's remarks, and  I

was called down to speak to the Secretary on this, the

point is, I don't know that he said — or we think that

he said -- that there was no practical answer as to

overflow from storm sewers.  As a matter of fact, we

think in the case in Washington, D. C., we did come up

with a practical answer.  The Congress evidently thinks

-------
                                                      1406
                  Gerald Reraus
 it might be different.     They  have  appropriated  20
 million dollars  for demonstrations.     They wouldn't
 think that  you could demonstrate unless they thought it
 very well might  be  answered.
             I think the question here  is to devise--
 or the report says,  as  I understand  the Public*  Health
 Service report,  to  set  up  a study  to see what could
 be devised  as an answer as to storm  water overflows.
 We were with the Michigan  people,  as you know,  in the
 Miami River—you remember  some  of  the  communities up
 there had storm  water problems, and  they came up  with what
 they thought were practical answers.    They were  smaller
 communities, it  is  truej but I  don't know that  Mr.
 Quigley—and I am Just  saying this for the  record—has
 ever said that there was no practical  answer as to
 storm water overflows*
             As a matter of fact, I think; MarinefrtQ,
 Wisconsin,  has a program,  if you will  remember, Mr.
 Oemlng—
             MR.  OEMING:    Yes.
             MR.  STEIN:   —to eliminate storm water overflow
 over the next ten-year  period.
             MR.  REMUS:   Could I give you the reference
en  that?

-------
                                                      1407




                    Gerald Reraus



             MB.  STEIN:  The City engineer came in and



 told  us what he  was going to do.



             MR.  REMUS:    No; I mean Mr.  Quigley's



 statement.    Mr. Quigley1s statement is  recorded in



 essence the way  I said  it in a speech before the  National



 League of Cities; and a copy of his speech can be



 obtained from Mr. Hemey, who is the executive head



 of the National  League  of Cities—executive secretary.



             MR.  STEIN:    Mr. Remus, I didn't Just



 glance at that speech;  I read that speech,  and everyone



in our organization read that speech and the sentence



 you refer to.    It very well may be your opinion that



 Mr. Quigley said that.    It is not ours; nor is  it  Mr.



 Quigley's.



             MR.  REMUS:   As a matter of fact,  we  do  not



 subscribe to it, either, because I pointed  out that



 we have had a great deal of improvement  in  our storm



 flows.    The Conner Creek complex, we have reduced that



 overflow from 7  billion to 3 billion.    We have reduced



the number of spills from 6l to 4l.   We think we  can do



more  by the so-called control of our system whereby we



would operate our system more to keep the interceptors



empty, particularly at  a storm flow  so  that the



first flush can  go to a sewage plant.    We have built

-------
                                                     1408



                   (Jerald Remus



 an overflow at the sewage plant  which has  Just been



 completed.   It is not working as effectively as we would



 like,  but the  reason  is  that  our chlorination equipment



dbesn't behave  the way we wanted  it  to,  but we are



 going  to improve  that.   So, I am not  saying to you



 we aren't going to do anything,  but I am saying that



 the treatment  in  the  plant, the  improvement of the plant



 will do very little as long as we have these other



 problems and don't get them improved.



             We believe that the  concentration of effort



 for what moneys we can get hold  of  under our program should



 be directed toward reducing the  storm flow,  toward



 intercepting the  wastes  that  would  not  go  to any sewage



system  if we didn't expand the system,  and  that we  would,



 by secondary treatment no, but by chemical precipitation



 yes, be able to finance  the necessary improvements.



 I am talking strictly from what  we  can  pay for,  and I



 wouldn't dare  talk from  any other basis because it would



 be misleading  to  do so.



             MR. STEIK:   Well, I  can see we are in  a



 substantial measure of agreement that  something can



 be done on  storm  water overflow.



             I  have Just  one more thing for clarification.



 At the beginning  of your remarks, Mr.  Remus, I took a

-------
                                                    1409



                  Gerald Remus



 note of a sentence I thought that you said, and I



 want to clarify this, if this is what you said:   that



 in 1957* as long ago as that, you decided on improved



 treatment, on intermediate treatment, which meant



 precipitation, and you were happy to report as of the



 present time you were making progress and doing



 research.



             Was that your statement?



             MR. REMUS: Correct.   I would like to read



 you the paragraph in the report of 1957, which is an



 exhibit in your report, where it says "improved



 treatment methods."     The plant is called upon to



handle more and more solids, better methods of treatment are



 needed to remove the greater percentage of the solids



 from the sewage treatment plant.



             In the letter that we received from the



 State Board of Health, it was clearly defined that



this meant an intermediate form of improvement or



 probably chemical precipitation.



             MR. STEIN:  And this has been considered



 since 1957?



             MR. REMUS:  Well, we have been doing some of



it;  that's right.



             MR. STEIN:   In other words, that is

-------
                                                      1410



                  Oerald  Remus



 substantially correct, that you are making progress,



aid research is being  done?



             MR.  REMUS:    Correct.



             MR.  STEIN: All right. Are  there any questions?



 Mr.  Oeming,  do you  have  any?



             MR.  OEMING:   Well,  I had  a  question, Mr.



 Chairman.



             Mr.  Remus, on this  additional  or Improved



 treatment process,  what  was the program  in 1957, not



with respect  to what the  Improved treatment process would



 be,  but  as  to timing.



             MR.  REMUS: Well, the first steps—the first



moneys we could  get  ahold of were being geared speci-



 fically  toward holding the treatment standards  as they



 were then substantially  and Intercepting what wastes



 there were around the periphery of our system,  because



 we felt  it would do no good to  raise our level  and



 not  Intercept those wastes.      The timing was, I believe,



 spelled  out,  and I  don't want to be held to this exactly,



 but  I think  we said that by 1965 we should be at the



 secondary treatment,  or  at the  chemical  precipitation



 process.



             MR.  OEMINQ:  Well, then, you  said this



 program  was  reaffirmed in 1964. Did this  change by

-------
                                                     1411


                   Gerald Remus


19655 starting In 19^5* you would be in the Improved


treatment process, when you reaffirmed that— Do you


remember what I am speaking about?


            MR. REMUS:  Well, what we said, in 1964, or


what the board of consultants said in 1964 was that as


the specific cures were found for specific wastes,


those would be adopted.   And we think that some of the


ones on Improved treatment that I have already reflected


on have been done, such as we chlorinate more than we


ever have, and we are in the process of evaluating pre-


chlorlnation.    We are buying four large drum filters


s> that we can filter more and thereby extend the sedimen-


tation time.  The pre-chlorinatlon we think will drop


out more wastes as far as our sedlmentlon is concerned,


more solids, and in that area is where we have been


working.


            MR. OEMING:  Well, then, there wasn't a


reaffirmatlon, was there, of the time schedule?


            MR. REMUS:   No, it is sort of a continuation.


            MR. OEMING:  I see; all right.


            MR. STEIN:  .Iiet us see if I understand you:


The time schedule indicated that there was going to


be this chemical intermediate treatment ty 1965* is


that what you said?

                                 \
            MR. OEMING:  No, no; this isn't what  I said.

-------
                                                           1412

                   Gerald Remus

             MR. REMUS:  Improved treatment.

             MR. OEMING:  Mr. Remus has said that by

1965 they would Install improved treatment processes.

That was the original 1957 program.

             MR. STEIN:  What did that improved treatment

mean?  Is there anything specific?

             MR. OEMING:  The estimate of cost I think

that vjas made at that time was included in this program

based on chemical precipitation.

             MR. STEIN:  Ribht.
                          «*
             MR. OEMING:  Now, what I asked Mr. Remus

was, in 1964 he said the program was reaffirmed, and I

wondered if this meant, in so far as time was concerned.

             MR. STEIN:  That in 1965 we would have this.

             MR. OEMING:  Well, it would start.

             MR. STEIN:  Yes.

             MR,, OEMING:  And I think his answer was that --

             MR. REMUS:  You member that the 1965 data --

I am not sure that that was specifically 1965; I think

it was in the range of 1965 to 1967, in that area.

             MR. OEMING:  Yes.

             MR. REMUS:  I would also want to make it

clear that the board of consultants that reviewed our

program at the request of six counties did not specifically

-------
                                                    1413



                   Gerald Remus



 reflect on chemical precipitation.  They Just said that



 improved treatment should be made in those areas where



 definite Indicators were as to what they are.



             MR.  STEIN:  But, again,  I want to Just



 clarify this and understand this; (1) they said



 improved treatment, and there was then an assumption,



 either directly or impliedly this time that that would



 be secondary, chemical  precipitation, and (2)  there  was



 no mention this time of the date as to when this would



 happen; right?



             MR.  OEMINQ: Well, I guess Mr. Remus better



answer.    I think that  is what I understand.



             MR.  REMUS:  Well, I don't know whether I  am



 understanding it properly, but let  me say this, that



this period of time of the mid '60s, we felt we would be



 ready to go at it at the improved treatment.   One of



 those probably improved treatment methods would be



 chemical precipitation.



             The  program that the six-county people re-



 viewed, as far as I know, they did  not reflect on the



 chemical precipitation.



             MR.  STEIN:    Did they mention a date when



 this improved treatment, chemical precipitation—



             MR.  REMUS:    I don't remember it that way.

-------
                                                  1414



                   Gerald Renius



 All they said was that we would continue In improving



 on the treatment of those wastes for which we had



 definite answers for.     That was their recommendation.



             MR.  STEIN:    Well, this is the question I



 would like to ask:  Since at least intermediate treatment



and chemical precipitation were considered In 1957*  and



 you are making progress and doing research,  do you  think



 we have definite answers now, or we have to have a



 little more research and make a little  more progress?



             MR.  REMUS:  To the present  time we do not



 feel that we definitely recommend a method of construction,



            MR. STEIN:   All right.   I think I am



 clear now.    Do you have any further questions?



             MR.  OEMING:    No.



             MR.  STEIN:    Mr. Poston?



             MR.  POSTON:   I am glad that Mr.  Remus  has



 conceded that this  river must be cleaned up,  which



 follows along with  Governor Romney,  Governor Rfa&des,



 with the Conservation  Commission, and the Public Health



 Service.   I think  everybody in general is agreed



 that there must  be  additional clean up  in this stream.



 And Mr. Remus also  indicated that  stream renewal is



 going to be kept up, and I think this Is in the right



 direction.

-------
                                                  1415
                 Gerald Remus
             I noted that you talked about this chemical
 precipitation, and I would like to pursue that a little
 further,  this being a type of Intermediate treatment
 that  obviously the City must have investigated,  and
 I wondered if they had information on installation
 elsewhere, or where they might have been  operated con-
 tinuously to give some idea of the kind of results,
 whether they were successful, and then how much this
diemlcal precipitation might be expected to cost  in
 terms of installation and operation.
             MR. REMUS:   Well, you have got about five
 questions there.
             MR. POSTON:    Yes.
             MR. REMUS: The chemical precipitation,  from
air standpoint—we have done the following things:
             We have put dlffuser nozzles  in our  sedimen-
 tation basins going in and along the  lines hoping that
  we could do some chlorinatlon there;  oxidation
 that  would help the situation.
             We have half the plant on a filtration
 process,  using as a water agent  the Palmer; we are
 continuing with Palmer; we are continuing with that
contract  for another year—another six months, excuse me,
             We are also in the process of evaluating

-------
                                                   1416



                  Gerald Remus



the use of these dewatertng agents by injecting them



in our sedimentation basins, hoping that it will drop



out more  solids.      The laboratory analysis indicatefe



t hat it would.    It probably has been that every  time



we start  with this type of a situation we get in a



position  of a large industrial system like this; the



quality of the wastes change; and we get a concentration



of a different quality of material so that the formulas



that have been perfected for the treatment at the  time



will not work in the next hour or two; and in that area



we haven't been able to get uniform results, and as such



we cannot commit a large amount of money.   Until we



know the  answer we couldn't evaluate the cost.      But



we do not think it would be exorbitant; and then  we are



even hoping that we could carry it under our regular



financing operation if we had to.



            MR. POSTON:   Isn't it true that Minneapolis,



Minnesota, built a chemical precipitation plant many



years ago and that this was never really used and now



they are  going to activated sludge processes as a  way



to handle their pollution problems?



            MR. REMUS:   I don't know.



            MR. POSTON:   I wanted to ask also if  your



southwest water intake wasn't located in Canadian  waters.

-------
                                                     1417



                   Qerald Remus



            MR. REMUS: Well, first, are you asking me,



did I make that decision, or was I involved with it?



I wasn't.



            MR. POSTON:   No.



            MR. REMITS:  Secondly, I don't think it



should be in the location where it is.    I expressed



that opinion when it was being built there.  I don't



think,however, that secondary treatment, or any form



of treatment would have changed that position, because I



don't think it is wise to build a water plant below a



situation whereby accidental spills or anything of that



kind can Involve your water supply.   The only way sou



can cure that problem is move Detroit away;  but I would



like to point out, however, that that is the very



issue that we are talking about on our sewage program,



that unless we develop one system for the area and unless



we get ourselves in a position so we don't get our



supply—that we don't get our wastes and that we don't



get our collection and direction systems all tangled up,



we are going to pay very expensively for the type of



development we are doing.



            MR. POSTON: This, then, probably is a factor



in your location of other intakes in Lake Huron?



            MR. REMUS:  Well, that was strictly, as I

-------
                                                     1418
                   Gerald Remus

mentioned  earlier, an  economic problem, because  we  have

contracts  with Flint;  we have contracts as  far north as

Pontiac; we  have  contracts  in a  considerable number of

Macomb  County; so there were two factors  involved,  or

possibly more, but two principal factors  whJc h were

that  in 1959 when we presented our program  the Army and

Civil Defense people were very insistent  that  we couldn't

pit  all  this  industrial load on one intake up at  the head

of  Belle Isle, so for  reliability purposes  they  Insisted

that  we be some fifty  miles separated on  this  type  of

a broad system.   That  was one of the reasons.

             The second reason is by us locating

it  up there  we were able to work out a program with

Flint so that they paid a portion of it,  and again  I

vent to  recite Just a little bit  of the business  processes

that  cause us to  have  to function the way we do;

that  it would have cost 167 million dollars, if  I

remember those figures right, for Flint to  go  alone and

Detroit to go alone; that by combining our  efforts  we

were  able  to do it for 117  million; that  by that  saving

alone,  it  amounted to  3 million  6 hundred thousand

dollars.

             That  is why we  wanted those contracts,

because we could  provide water cheaper for  all that

-------
                                                    1419



                   Gerald  Remus



are on  the  system.




            And  then  a  third basic  reason  would be  this



business  of putting an  intake below a  large  industrial



complex where, even if  you  had  the  highest quality  of



treatment,  you still  wouldn't be using good  judgment in



pitting  it there, because  you would  be  subjected to  all



the accidents that can  happen in a  large complex of this



kind.   Costwise  that  isn't  justified because you have



to spend  too much  money in tfee development  of your plan



to be able  to effectively provide water.     Now we



are going to serve water  out here but  it is  going to cost



us more to  do it.



            MR.  POSTON:     I note that Wyandotte has a



number  of procedures  that they  go through  to provide



additional  protection in  their  water treatment plant,



and I wondered what measures in the sewage plant you



take to protect  the downstream  water users,  whether they



have alarm  systems, extra chlorination facilities,  and



this type of thing, and I wondered  what safeguards  you



have,to provide  a  continuous operation that  would protect



the downstream water  users.



            MR.  REMUS:  Well, we used  to notify them



every time  we had  any trouble,  but  if  you  will remember,



you were  here, in  the 1962  report they read  records from



it back to  1940  or earlier, on  every telephone caH, and

-------
                                                     1420
                 Gerald Remus
 then appended it Into the record in such a way that
 it indicated we failed each time we told them
 there was something of an unusual nature coming down.
 In my estimation they broke off any necessity or any
 chance we had of reporting it to them on unusual material
 cr waste.
             MR. STEIN:   I don't understand that; why?
             MR. REMUS:   I couldn't tell you.
             MR. STEIN: Why did you break off?
             MR. REMUS: We were giving that information
 as a neighborly situation so that if we had an unusual
 sludge or oil—
             MR. STEIN:   I understand that, but you said
 they did something in 1962 which you figured you didn't
 have to give it to them.     Don't you think they would
 sbill be neighborly? Generally cities would do that.
             MR. REMUS:   If they hadn't put the worst
 on what we called them and put it into your record on
how many times the sewage  plant broke down, probably that
 factor will be yet in existence.  It can be established
 Jf it can be done in a businesslike way.
             MR. STEIN: Do you mean to say before 1962
 you were neighborly to the people of the  city of
 Wyandotte to protect them when a sludge came down,
 b ut you were unhappy on something that the Wyandotte
 water plant put in a 1962 report , and because of this

-------
                                                     1421
                 Gerald Remus
you are not giving them the information any more?
            MR. REMUS:   No; we have all the information
available; some of the State people, and everything
else; but we took an extra effbrt to call them on every
little thing.
            MR. STEIN: But, I mean you are not calling
any more since 1962?
            MR. REMUS:   No, not with that interpretation,
            MR. STEIN: Well, how about the people of
Wyandotte?  Don't you think it would be neighborly to
let the people know?
            MR. REMUS: If the connotation isn't placed
on it every time we call them that the plant broke down
and that you people get a big report on it, then yes,
we would do it.   We will do it now if it can be done
in a businesslike way, but we cannot do it on a propa-
ganda basis.
            MR. STEIN:    I think your position is clear,
Mr. Remus.
            Do you have any more questions?
            MR. POSTON:   You said something about lake
aging, but I missed your connection and your presentation
about aging.    Will you clarify your comment on lake
aging?   Do you think that Detroit might have contributed

-------
                                                    1422
                    Gerald  Remus
 to this lake aging?
             MR. REMUS:   Well,  I think we  contribute;
 but let us  establish also  that the aging  of  the  lake  has
 gone on before  ever Detroit  was here.   It started when
 the earth was born. And  I  pointed out  that there are
 50,000 cubic yards  of dirt going down  the river  on a
 stormy day  from this entire  basin; on  that day we put in
 240 tons, roughly,  of solid  material.     I grant you
•Hie wastes are somewhat different, like phosphates and
 nitrates which  act  as nutrients, now make the problem
m ore complex; but to create  in the minds  of  the  public
 that it is  possible to correct this by putting in
 secondary treatment gets a little—and that  is the
 image that  is gradually  being  created,  and that  is the
 image I am  trying to point out wasn't  even reflected  on.
             MR. POSTON:    I  wondered whether in  your
 water intakes that  are located in Canadian waters,
 whether there is any reason  to believe, or any agreement
 with the Canadian officials  that they  will protect you
 from pollution  on the other  side of it  in  this location,
             MR. REMUS:   I  believe only,to my knowledge,
 the  extent  of that  is written  into the  International
 Joint Commission records as  to what the mutual agreement
 between .the  U.  S. and Canada is.

-------
                                                   1423
                    Gerald Remus

          MR. STEIN":  Do you have any further questions?

          MR. POSTON:  No.  I think that is all.

          MR. STEIN:  Well, I wonder if I may raise a

question.  I think we need this for clarification, if

the conferees and Mr. Remus would go at this.  I think

there were several statements made on differences in

figures in suspended solids, settleable solids, and B.O.D.

          Now, I wonder (l) if we can.  I do not know

whether our people or anyone else can have a comment on

this.

          Secondly, I wonder if they can be reconciled or

not.

          Thirdly, I want to know whether for the purpose

of these deliberations it makes any difference.

          Now, I think you have raised the question, and

I think it is a good one; but, I wonder, do you have any

of the technical staff that can possibly comment on the

apparent inconsistencies in the figures, Mr. Poston?

          MR. POSTON:  Well, I do not think right at this

time.

          MR. REMUS:  I would like to point out that

from a technical aspect I, myself, would probably go

-------
                                                    1424
                   Gerald Remus
 along with Mr.  Stein—whether It  la Important or not
 Is another thing—but  from a  financing aspect, It Is ira-
p ortant,  because If we want to move and expend money we
 do not leave  an open door for anybody to start some
 entanglement  so we cannot get our financing.
            MR. STEIN:   I would  agree with you;  I
 couldn't  agree  with you more  on that, Mr.  Remus;  unless
the other*  conferees have any points; but I think these
 are measurable  figures, and I do  think that when  and
If you have to  go before the  bond market,  that all
 agencies  should have these figures reconciled; State,
 Federal,  and  Local; so we don't Jeopardise any financial
 position.    I  do not  believe that, from my experience,
that this  necessarily will occur.
            You know your local situation  and the laws
of Michigan better than I do.   But from my experience
 I haven't run into this on this kind of an issue.   I
 haven't run into a hold-up yet; but this can  be
 reconciled.
            Mr. Oeming, do you want to make a statement?
            MR. OEMING: Well, Chairman Stein, you asked
 a question whether we  should  not  try to resolve some of
 these questions here at this  time.   It seems to  me that
 there are not only issues raised  with respect to  the

-------
                                                        1425
                      Gerald Remus

data, itself, but with respect to the analysis and

interpretation of the data that Mr. Remus has raised here

which are not properly — cannot properly be resolved at

a conference of this type.  It seems to me that this is

subject to a different kind of proceeding than we are

involved in here; and they need to be resolved, certainly.

          MR. STEIN:  Right.

          MR. OEMING:  But this is not the time, it seems

to me, to get into this thing.

          MR. STEIN:  Right.  My question was directed

toward methodology, not on the interpretation, and I

would agree with you.  Very often when we have come up

with different figures, sometimes we find someone has

used a Phelps index; someone has used a little different

method of measurement, and very often, pretty rapidly at

the conference we can indicate if there were slightly

different techniques being used that we did not have an

irreconcilable difference.  So, I don't know that this

situation was the same here or not. Perhaps we had

better wait, and if this comes up again, as Mr. Poston

says, or we do get information of that, we shall leave

the record open so that you can put it in.  Because I

would like to see just how far we can go on this before

-------
                                                   1426



                    Gerald Remus



 the conferees  come  to a  determination.



            MR.  POSTONs     I  should  think  that we  should



mke some  comment on these.



            MR.  STEIN: But  you would want  a  little more



 time.



            MR.  POSTON:   I would need a little more time



 to do  that.



            I  do have one comment.     Mr. Remus Indicated



 that the  report  accentuated the negative and elimination



 of the positive, or something to that effect; and  I



 would  say this depends on how you look at  it; whether



 you are thinking in terms of  the polluter  or the user,



 and the user,  I  am  sure, would agree with  us on that



 in your report that pollution should be cleaned up.



            MR.  STEINs Do you want to comment?



            MR.  REMUS:   I  would just like to sum  up



 once again what  our position  is:  We continue to expand



the system; we continue  to  improve our treatment;  we



 will support the research that has to be done to find the



 answers.



            We think the report should clearly delineate



 which  part of  this  you have answers  for and  what those are,



 and we think you should  have  a very  firm position  on what



 the quality of the  stream will be after we do all  of

-------
                                                    1427
             Gerald Remus
 this expensive thing,  and after that Is done,  then we
diall take the next step.
             MR. STEIN:   Mr. Remus,  I understand that we
 are prepared to comment If we take a little recess.
 I didn't want any comment on the data problem  to be
 made while you weren't here; and If you could  wait until
 after recess, perhaps  we could take a ten or fifteen minute
 recess and come back and clear that up and go  forward.
 Is that all right?
             MR. REMUS:    It would strike me,  particularly
 since some of our samples were taken and divided in
 our processes,and our  treatment or our tests did not
 give the same answers  in some cases that your  tests did,
 that it cannot be resolved here.  It costs to  be done—
             MR. STEIN:  No; but I think there  should be
 fair comment to get the record clear to see what the
issue is.   I do not know that we are going to  resolve
 anything,  but I think  you should be  here to hear the
 fair comment.  I think in many areas where there is
 a discrepancy, the best we can do is define an issue; and
 I would like to see how carefully we can come  to defining
 an issue by preparing  this comment.     I think that the
 people out there, the  little human computers we have, have
 been working on this,  and Mr. Poston Indicates that he

-------
                                                   1428




                  Gerald Remus



 is not  In a position  to make his  comment  on  these



 technical facts until he  speaks to  the  technical people



 that  have done this computation.     With that, I  suggest



 we recess for fifteen minutes.



            MR. OEMINO:   I would like  to comment, Mr.



 Chairman, for Just a  moment.



            MR. STEIN:   Yes.



            MR. OEMING:   I have  a  comment about this.



            MR. STEIN:  Yes?



            MR. OEMINO-: Well, I don't know what you



 expected to obtain from this conference,  but it seems to



me that you are certainly here to explore what Issues



there  are.



            MR. STEIN:   Yes.



            MR. OEMING:  And the  Issues are clear  to me.



 Mr. Remus has raised  some Issues.    The  report of the



 Public  Health Service is clear.     I see no purpose



 in now  beginning  a debating society here.   The record



Is made, and if you need to resolve  this issue, this is



 not the place to  do it at a conference.   The time comes



 for this when proceedings are taken to  Initiate or apply



 the findings.



            MR. STEIN:   I do not know  that  we are going



 to have a debate.     The question here  that Mr. Remus

-------
                                                   1429
                 Gerald Remus
raised, there  Is a  ten per cent  difference  in  suspended
solids; 50 per cent difference in  settleble solids,  and
a  considerable difference  in BOD.
             If the  comment—and  I  think this is  a  material
point  that has to have comment—if Mr.  Poston  wants
to say that  these are differences  in the measure and we
have to resolve them technically, this is fine.
             All I am saying, though, is if  by  the  comment
we can get closer to the  issue and narrow the  issue, I
would  like to  have  them have an  opportunity,to see what
they are  going to comment  on these figures.   The
closer we can  get together and the narrower we can
make the  Issues, the sooner we aa?e going to resolve  any
situation; and I am not looking  for a debate at  all.
             MR. OEMINQ:   0. K.
             MR. STEIN: Do  you have one  more comment, Mr.
Poston?
             MR. POSTON:     I have  one question about the
figures in your Department of Water Supply  and Sewage
Treatment annual report,  operating report,  and it  shows
that in the  year 1962-1963 you removed  some 123,000
tons of suspended solids,  and  that you  burned  some 93*000
tons.   I wondered  what happened to the difference of some
30 or  40  thousand tons of  solids.

-------
                                                   1430
              Gerald Remus
            MR. REMUS:   I couldn't answer that unless
I analyzed the data.   But since you raised the point
we shall look It over and correct it.
            MR. POSTON:   Is there other sludge treatment
than incineration?
            MR. REMUS:   No.
            MR. POSTON:    0. K.
            MR. REMUS:  There might be an error there.
            MR. POSTON:  This difference is put back into
the stream, is it?
            MR. REMUS:   No; there is no way of getting it
there.
            MR. POSTON:  Well, I—
            MR. REMUS:    We shall look at it and see
what it is.
            MR. STEIN:  May we recess for fifteen minutes?
            MR. REMUS:   If that is all you can find
in the report that is contradictory, why—
            MR. POSTON:   Where does 30 thousand tons go
to?
            MR. STEIN: By the way, Gerry, don't run off.
            MR. REMUS:   I will stay here for two days,
if necessary.
            MR. STEIN:  All right.
            (Whereupon a short recess was taken.)

-------
                                                   1431



                    Gerald Remus



               ^  STEIN:    May  we  reconvene?    I  hope



we  can get  on  with thia.   Mi*.  Post on,  I  would suggest



that  we give you or your  representative an opportunity



to  make one short comment.



            Mr.  Poston, I ask  that on this issue we



confine ourselves to  perhaps a  single comment, and not



get into'a  real  technical discussion, and then we shall



allow Mr. Remus,  or any representative  of his  to make



any statement  that  they wish.     Do you have any comment



or  do you have a  representative?



            MR.  POSTON:   I have  asked  Mr. Vaughan to



make  a brief statement to clarify the discussion of



Mr. Remus and  the differences  in  values.



            MR.  STEIN:    Mr. Vaughan?



            MR. VAUQHAN:  Thank you.    I shall try to



make  this as brief  as I can.      I would like to make



a few statements.   After  a 30-minute review it is a



little bit  too ttuantitative, but  I shall  do the best I



can.



            First of  all, I would like  to comment on the



fact  that In our  report—that Is  In the Public Health



Service report—we  have published the long-term results



of  the Detroit sewage treatment plant operating records;




on page 33.

-------
                                                    1432



                     Gerald  Remus



             Second,  during  Mr.  Remus's  comparison of



 9 thousand samples  over several years with our Intensive



 surveys,  which were  conducted on  a  24-hour basis



 for two,  four-day periods this  is not unusual.     There



 might not be some difference in there.      However,



 we did split samples with Mr. Remus which he  has  in his



 report, and which he mentioned  that there is  some



 disagreement between their  results  and  the Public Health



 Service-results.



             I would  like to say that we furnished Mr.



 Remus—that Is through the  State  Health Department—



with our results,  our analytical results,  so that  he



 might compare these  with his own  chemical results.



             We did not hear from  him until this morning



 that there was any  difference.



             Now,  as  far as  the  three things:    In



 suspended solids  I noted that there Is  some disagreement



 in the percentage of removal, but there Is very



 little disagreement; in fact, well  within the tests,



 as to the amount  during that four-day period  that went



 into the  river.      On their report, on page  L-l—



 I could just mention this to you—their effluent  was  106



 milligrams per liter—no, ours  was  106; theirs was 108.



             In the  second tests ours was 175; theirs  was



 179.

-------
                                                   1433
                  Gerald Remus

          That showed that ours was just a little less

than theirs.

          Now, on the matter of settleable solids, we

used a different technique.  Standard method recognizes

two techniques for this; one on a volume-per-volume basis

run, In how much settles out in an Imhoff cone, and is

expressed as milliliters per liter.

          We use a graphometric test of weight per volume

which is milligrams per liter, and that is how we reported

it in our book.

          So, since two tests are used, it is conceivable

that two different results could have been obtained.

          In the last thing, on B.O.D., there is some

difference in the two, which, of course, we haven^t had

time to completely analyze.

          We would like to state, though, that one of

the most Important things from this was how much bio-

chemical oxygen demand was discharged Into the river.

We state in our report an average of these, of 525,000

pounds.  In the Supervisors Intercounty Committee, which

I understand was taken from the Detroit operating records,

they estimate 500*000 pounds over a long-term period was

discharged in the river.  I think this is pretty close.

This is all I have.

-------
                                                      1434




                  Gerald Remus




          MR. STEIN:  Thank you, Mr. Vaughan.  If




Mr. Remus is here and wants to comment, fine.  Or, if he




wants to come up at any other time, if he Is not desirous




of doing so now, and wishes to make his comment on this,




I am sure he will be welcome.




          Does that complete this?




          MR. POSTON:  That completes it.




          MR. STEIN:  May we proceed, Mr. Oeming?



          MR. OEMING:  Yes, Mr. Chairman.  At this time




I would like to provide the opportunity for a statement




by the Supervisors Intercounty Committee.  This statement




will be introduced by Mr. Gerard Coleman, Executive




Director of the Supervisors Intercounty Committee; and




a second portion of the statement will be given by Mr.



George Hubbell.




          Mr. Coleman?

-------
                                                        1435

             Gerard H. Coleman

       STATEMENT BY GERARD H. COLEMAN,
          EXECUTIVE DIRECTOR OF THE
      SUPERVISORS INTER-COUNTY COMMITTEE

             MR. COLEMAN:  I am Gerard H. Coleman,
Executive Director of the Supervisors Inter-County
Committee, a governmental organization comprising
the six southeast Michigan Counties of Macomb, Monroe,
Oakland, St. Glair, Washtenaw and Wayne.
             Since its inception, eleven years ago,
the Supervisors Inter-County Committee has concerned
itself with the problems of fresh water supply and the
pollution thereof.  In 1957* the Committee furnished
the Detroit Metropolitan area with a master-plan for
the supply and distribution of water.  This initial
study now provides the basis for the Detroit Water
Board serving over 60 communities in the Detroit area
with fresh water.
             As a corollary to the water study, the
Inter-County Committee proposed that the entire problem
of sewerage, drainage and sewage disposal be examined
for possible solutions on a Metropolitan area wide basis.
When this conference was originally convened in March,
1962, we submitted to you the scope and involvement of
this well-planned study.

-------
                                                       1436
             Gerard H. Goleman

             On the occasion of the reconvening of your
conference, I am pleased to note that our study has been
completed.
             I know that the participants of this con-
ference are well aware of this study and its contents,
and I do not intend to belabor the organization or re-
sults of our investigation.
             I are pleased to advise you that Mr. George
E, Hubbell, member of the Board of Consultants, for the
study will speak more directly of the study and its
recommendations.
             There are a few points that are important
to recognize regarding the SICC sponsored study and
which explain why we are so justly proud of its com-
pletion.
             First, this study represents one of the
first efforts to provide an area-wide solution to sewer-
age and pollution problems in a major metropolitan area -
an area encompassing 4,000 square miles, 2l4 political
jurisdictions, and over 4,300,000 inhabitants.  The
undertaking of this study evoked cooperation on behalf
of the many diverse political instrumentalities found
in this vast urban area.
             Second, it evinced a financial partnership,

-------
                                                        1437
             Gerard H. Coleman

between the local units of government and the Federal
Government.  More important, these two interests were
joined most generously by private enterprise - namely,
the industrial, financial, commercial, and small busi-
ness firms in this six-county area.  This tri-party sup-
port JLs a remarkable facet of this study.
             Third, the study was conducted by an im-
partial and most respected organization - The National
Sanitation Foundation.  In turn, the Foundation em-
ployed a Board of Consultants which was comprised of
three of the most knowledgable experts in the Ration
namely: Louis R. Howsbn, George E. Hubbell, and Abel
Wolman, Chairman.
             Fourth, the study is now in the process
of implementation on a metropolitan area-wide basis.
The six SICC counties have the study under advise-
ment and have begun joint discussions that will lead
to the implementation of the recommendations contained
in the study.
             We are not unmindful of recent publicity
regarding alleged conflicts between the SICC study and
this Federal survey of the Detroit River and Western
Lake Erie.  Close examinations of the two reports in-
dicate a confirmation of similar conclusions arrived

-------
             Gerard H. Goleman

at separately, and that these far outweigh dissimilari-
ties .
             The southeast Michigan metropolitan area
has made substantial progress in the past in meeting
its responsibilities toward the problems of water
pollution.  With the completion of the Supervisors'
Inter-County Committee sponsored study, our achieve-
ments will certainly be not less w but will be even
greater.
             Thank you.

-------
                                                   1439



                Gerard H. Coleman.



            MR. STEIN:  Thank you, Mr. Coleman.



Are there any questions?



            MR. POSTON:  I have no questions.



            MR. STEIN: As always, Mr. Coleman, It Is



a pleasure to be associated with you, and thank you for



a very helpful instructive report; and your type of



attitude, as I hope ours is, is to meet each other



at least halfway, and I am sure that is the way the



problems can be solved.



            Thank you very much.



            MR. COLEMAN: Thank you.



            MR. OEMINO:  I believe, Mr. Chairman, and



Mr. Poston, that Mr. Hubbell has some further remarks



relating to Mr. Colemanfs statement.

-------
                                                        1440

             George E. Hubbell

               STATEMENT OP
         GEORGE E.  HUBBELL, ENGINEER

             MR. HUBBELL:  On December 10, 1964, the
Trustees of the National Sanitation Foundation sub-
mitted to the Supervisor's Inter-County Committee two
reports, the first  being a report on Metropolitan En-
vironmental Study,  Sewerage and Drainage Problems, and
Administrative Affairs and the second, a Report on
Sewage Disposal Problems.  Both of these reports
covered the Six-County Area of Southern Michigan,
consisting of Monroe, Washtenaw, Wayne, Oakland,
Macomb and St. Clair Counties.  These reports were
prepared for the Foundation by a Board of Consulting
Engineers consisting of Louis R. Howson, George E.
Hubbell, and Abel Wolman, Chairman.
             The Foundation has asked the Board to
submit a statement interpreting their report on Sewage
Disposal Problems in terms of the factual information
included in the Public Health Service Findings of April,
1965.  In making this Statement, I represent the Con-
sulting Board.
             The Board wishes to emphasize that their
principal objective was the development of an overall
long range sewerage plan for the protection of the

-------
                                                      1441

             George E. Hubbell

Health and Welfare of the present and future people in
the area.  The Board is for clean water, giving due con-
sideration to the realities of present and future con-
ditions.  We are here concerned with the condition of
the Detroit River and Michigan Waters of Lake Erie.
These waters carry both natural and man-made pollutants.
Our endeavor is to control the character and amount of
man-made pollutants, and to utilize the waste assimilating
capacity of the waters as long as this can be done within
the stated objectives.
             The Board fully realizes that such use of the
waters must be compatible with health, industry, agri-
cultural needs and practices, recreation, fish and wild-
life, and transportation, all in relationship to the
economic and social needs of the people who have chosen to
live and work in Southeastern Michigan.  In assessing the
various uses of the waters we must be realistic and under-
stand that it is not possible to return these waters to
their original natural state.  The Board has endeavored
to determine, in terms of health, industry needs, recrea-
tion and other uses, an overall sewerage plan to best meet
the needs of the people, their way of life and their
manner of employment.  We have endeavored to improve our
knowledge of interrelationships which require some com-

-------
                                                      1442

             George E. Hubbell

promises between the several factors involved.  At this
time we have only partial understanding of some of these
needs and methods of compromise.  The Board and the
Foundation wish it well understood that they desire to
work continuously and cooperatively in the solution of the
problems.
             The principal difference between the Boardrs
recommendations and the HEW recommendation involves the
understanding of conditions in the waters and their use
and what should be done or can be done at this time and
in the future with improved understanding.
             For the Detroit River, the question of
character and quantity of man-made pollutants resolves
itself to three (3) categories:
             1.  Overflow from combined sewers;
             2.  Degree of treatment of municipal waste
water;
             3.  Degree of treatment of industrial waste
water.
             The Board's position with regard to each of
these categories in terms of the HEW Findings is as follows:
             Overflow from Combined Sewers:
             The Board estimates that the cost to Detroit
alone to separate their sewers would be 1.7 billion dollars.

-------
                                                     1443
             George E. Hubbell

Prom a practical standpoint, it is both excessively
costly and almost physically impossible to separate
effectively the existing Detroit combined system serving
Detroit and certain surrounding areas.
             The Board did recommend the construction of
the North Interceptor to remove sewage from Detroit's
combined system served by the Detroit River Interceptor.
This construction will reduce the estimated 1980 sewage
carried during overflow to that from 21 people per acre
instead of 52 people per acre, or permit the River Inter-
ceptor to provide 1.1 c.f.s. per 1,000 population inter-
ception rate.  This increased rate, more than double  the
present, together with storage in the combined system,
will improve control of storm water overflows.
             It is the Board's judgment that frequently
combined overflow spills occasioned by rains of low in-
tensity create a nuisance and every effort should be  made
to eliminate such spills.  Infrequent spills of combined
sewage occasioned by high intensity rainfall have little
overall persistent effect on the Detroit River.
             The HEW Findings indicate that the discharge
from both combined and separate storm sewers carry coliform
densities ranging in the millions per 100 ml and far exceed
the HEW proposed waste water treatment plant effluent

-------
                                                        1444

             George E. Hubbell

standard of less than 5000 organisms per 100 ml.  Dis-
infection of storm water overflow by the use of chlorine
was studied by the Board.  There are numerous physical and
technical problems involved in such a program involving
as it does at least 124 points of storm water overflow
each of which would require chlorination facilities.  At
present no significant information is at hand to indicate
the need for or overall effectiveness of chlorinating
combined storm sewage overflow.
             The HEW Findings indicate for the period of
test that the Ann Arbor separate storm sewer discharge
had higher suspended solid concentrations than the over-
flow from the Detroit combined sewers.  Both systems
tested showed phenols, nitrogen and phosphate in the
overflow, the concentrations in general being higher in
the Detroit System.
             The HEW Summary on Page 55 states with re-
gard to overflow from combined sewers "a specific method
of approach to the solution of this problem is not now
evident".
             The Board wishes to call attention to the
fact that the Detroit area has made real progress in
constructing control measures for storm water over-
flow,  many of which have only recently been completed.

-------
                                                      1445

             George E. Hubbell

             In the Board's judgment, it is not feasible
with large existing combined sewer systems to eliminate
combined storm sewage overflows.  It is possible to ob-
tain information on the frequency, and the duration of
combined overflow, together with chemical, physical and
bacterial analysis.  To relate this information to health,
welfare, esthetics and economics is a very difficult task
and to date has not been accomplished.
             Degree of Treatment of Municipal Waste Water;
             The Board has stated that "It has not been
established, on the basis of information presently avail-
able to the Board, that secondary treatment is indicated
at this time for any plants discharging into the St. Glair
or Detroit Rivers.  This does not preclude the possibility
of additional treatment sometime in the future.  This con-
tingency, however, should rest on research underway and
proposed, diligently pursued to determine what, if any,
improved treatment is required".
             With reference to the Detroit, Wayne County
(Wyandotte, Trenton and Grosse lie) plants, the HEW
Summary recommends that additional facilities be provided
to provide a minimum of secondary treatment to reduce
effluent suspended solids to 35 mg/1, settleable solids
to 5 mg/1, oil to 15 mg/1, BOD to 20 mg/1 and bacteria

-------
                                                     1446

             George E. Hubbell

to 5000 organisms per 100 ml.
             These results are those obtainable, in general,
by the use of the activated sludge treatment method
commonly referred to as secondary treatment.
             The Detroit plant now serves 2,806,000 people.
By 1975 to 1980 it is estimated that the plant will serve
4,000,000 people and by the year 2020 some 5,450,000
people.  Considering the year 2020 primary plant addi-
tions are estimated to cost $34,000,000 and secondary
treatment additions $163,000,000.
             For immediate construction to serve
4,000,000 people primary plant additions are estimated
to cost $12,000,000 and secondary treatment additions
$106,000,000.
             In terms of the present average householder
who must bear the costs the immediate construction and
operation requirements are estimated-to be 2.6 times as
much per year for secondary treatment as compared to
primary treatment.
             The Board is fully aware of the present trend
toward the concept of providing secondary treatment re-
gardless of the assimilation ability of the receiving
stream or of any demonstrable improvement to the health,
welfare and economy of the people of the affected area.

-------
                                                      1447
             George E. Hubbell

             With due consideration of this trend,
the Board recommended expansion of primary treatment
facilities with continued study to determine the
future course of action.
             With reference to bacterial removal, it
has been demonstrated that the present average coliform
content of 15,000 per 100 ml. in the Detroit effluent
can be reduced to an average content of 1000 organisms
per 100 ml by the  application of additional chlorine
over and above the amount now in use.  Thus, to provide
effluent bacterial control, it is not necessary to go
to secondary treatment to meet the proposed HEW standard
of 5000 organisms per 100 ml.
             With reference to Detroit effluent Bio-
chemical Oxygen Demand and Detroit River Dissolved
Oxygen, the Board indicated that with a dissolved
oxygen content of 8 ppm in the River above the present
Detroit Plant outlet there would, at all times, be not
less than 4 ppm dissolved oxygen below the outlet.  At
the present time,  the Detroit Plant effluent is essentially
confined to the waters flowing down the Trenton Channel.
By 1980, the Board estimates, based on primary treatment
an effluent loan of 650,000 Ibs. per day with a cal-
culated ratio of DO/BOD of 2.7 in the Trenton Channel

-------
                                                      1448
     \
             George E. Hubbell

based on 8 ppm DO.
             Minimum Dissolved Oxygen concentrations,
as reported on Page 152 of the HEW Findings, show 9.0
ppm above the Detroit Sewage Plant Outlet and 5 PP» at
the outlet of the Detroit River.
             On Page 150 of the HEW Findings, it is
stated "In no reaches of the Detroit River do levels
of dissolved oxygen cause interferences with water
uses" and "Future problems may result if oxygen con-
suming waste loads increase.
             On Page 280, of the HEW Findings, "Levels
of DO in most of the Michigan waters of Lake Erie are
sufficient at this time to prevent interference with
water use."
             With reference to Detroit River BOD, the
HEW Findings on Page 150 indicate upper Detroit River
BOD from 2 to 4 mg/1., below the Rouge River 8 mg/1, and
at the mouth of the river at Lake Erie 2 to 4 mg/1.
             These results indicate that from a BOD
standpoint, the Detroit River is discharging the same
quality of water into Lake Erie as it receives from
Lake St.  Glair, and confirms the Board's judgment as
to the ability of the river to assimilate primary
plant effluent.

-------
                                                      1449
             George E. Hubbell

             The Board has recognized the fact that
future BOD loadings on the Detroit Biver may require
limitation of the Detroit Plant effluent BOD.  Such
limitation may be obtained through intermediate treat-
ment methods other than the HEW Summary recommendations
of secondary treatment.
             With reference to solids in the effluent,
the Board recommended "that solids be so effectively re-
moved that those remaining will not be visible to the
eye, and will not create sludge banks in the river or
lake".
             During the HEW survey of the Detroit Treat-
ment Plant, as shown in Table 8-V, suspended solids re-
moval averaged 39#> settleable solids 52#, and BOD re-
moval 17#.  During 1964, the Detroit Treatment Plant
averaged 59# removal of suspended solids; 93.6# of
settleable solids ad 37-4# of BOD.  Thus, actual yearly
operating efficiencies were considerably higher than the
efficiencies during the HEW test runs.
             Removal of solids by sedimentation is to a
considerable degree a function of time of settling.
During 1964, the average settling time at the Detroit
Plant was 0.95 hours.   Future conditions may well in-
dicate the necessity of increased sedimentation time to

-------
                                                  1450




               George E. Hubbell




meet the requirements of effluent solid load.  The




Board's recommendation was based on adequate primary




sedimentation with maximum control of floating solids,




oil and grease.



          During 1964, the Detroit Plant influent




contained 1,680,000 Ibs. of suspended solids each day.




The plant operated at 59 percent efficiency, discharging




690,000 Ibs. to the river.  These finely divided solids




uniformly disbursed in the Trenton Channel flow are




equivalent to 3 mg/1.




          The HEW Findings on Page 149 indicate the




upper Detroit River mid-stream carries from 5 to 10 mg/1




suspended solids out of Lake St. Glair with values of




15 to 20 mg/1 near the American shore.  Assuming a uniform




suspended solid concentration of 6 mg/1, the entire




Detroit River carries a daily load of 5,850,000 Ibs. of




suspended solids out of Lake St. Glair.




          The Detroit primary effluent contributes




about 10$ of the present initial suspended solid load




passing down the Detroit River.  With secondary treat-




ment, this could possibly be reduced to 3$ of the initial




load in the River.  In the Board's judgment, the beneficial




effect from making such a reduction in the suspended




solid load in the Detroit River on the health and wel-

-------
                                                       1451
             George E. Hubbell

fare of the people of the area has not been demonstrated.
             With reference to cyanide, phenol and ferrous
iron in the influent and effluent of the Detroit Treatment
Plant, the Board recommended a major effort, through
available control ordinances, to keep excessive amounts
out of the sewers.  In the Board's judgment, source con-
trol of these wastes is required.
             With reference to eutrophication or aging
of lakes because of the addition of nutrients, the Board
took the position that it was reluctant to recommend, at
this time, secondary treatment for sewage in order to
prevent an aging process which will undoubtedly continue
in Lake Erie, but whose manifestations are still minor.
This reluctance is emphasized furthermore by the fact
increased treatment, as now practiced, reduces in no
material sense the amounts of phosphorous and nitrogen,
the primary causative agents of eutrophication.
             On Page 153 of the HEW Findings, this state-
ment occurs - "A commonly accepted level of inorganic
nitrogen compounds (nitrates, nitrites, and ammonia)
above which undesirable blooms can be expected to occur
is 0.03 mg/1."  (This is evidently a misprint and should
be 0.30 mg/1).
             On Page 255 of the HEW Findings, average

-------
                                                        1452




                     George E. Hubbell



nitrate-N concentrations in the Upper Detroit River are




0.17 rag/1 and at the river outlet  0.27 mg/1.



            On Page 256 of the HEW Findings, average



ammonia-N concentrations in the Upper Detroit River are




0.11 mg/1 and at the river outlet  0.33 mg/1.



            Thus average inorganic nitrogen con-



centration leaving Lake St. Clair  is 0.28 rag/1, and



entering Lake Erie 0.60 tng/1.



            On Page 254 of the HEW Findings, average



phosphate concentrations in the Upper Detroit River are



0.18 mg/1 and at the river outlet  0.52 mg/1.



            It would appear that sufficient nitrogen



and phosphate enter the Detroit River from Lake St. Clair



to provide for abundant growth of algae in Lake Erie



regardless of the Inevitable addition of nitrogen and



phosphorus from the Detroit Plant effluent.



            On Page 11 of the HEW Summary, it states,



"The main source of nitrogen to the Detroit River is the



effluent of the main Detroit Sewage Treatment Plant."




Also,  "The main source of phosphates to the Detroit River



is the main Detroit Sewage Treatment Plant effluent."



            On Page 31 of the HEW Summary it states,



"While artificial fertilization of the Michigan Waters  of




Lake Erie is a severe problem, no recommendations

-------
                                                       1453

              George  E. Hubbell

 are made  at  this  time  concerning the  installation  of
 specialized  treatment  facilities designed to  reduce
 phosphorous  and nitrogen compounds  in the effluent of
 municipal waste treatment works.  Proper  operation of
 secondary treatment  facilities  of the activated sludge
 type will result  in  significantly greater removal  of
 these  constituents than  that  produced by  primary treat-
 ment alone.'1.1
              It is the Board's  judgment that  the present
 installation of secondary treatment would not materially
 reduce the quantity  of nitrogen and phosphorous in the
 Detroit Plant effluent below  that now being discharged,
 and that  the construction of  secondary treatment
 facilities at Detroit, at this  time,  would not  signi-
 ficantly  reduce the  artificial  fertilization  of the
 Michigan  Waters of Lake  Erie.
              On Page 35  of  the  Summary, it states  "A
 Technical Committee  appointed by the  Conferees  will
 evaluate  actual phosphate removal of  the  secondary treat-
 ment plant after  it  Is in operation.   On  the  basis of
 this evaluation,  if  further facilities for the  removal
 of phosphates are necessary,  the Conferees will consider
 making such  a recommendation.   A .similar program will
be put into effect concerning removal of nitrogen compounds

-------
                                                       1454
             George E. Hubbell

             The Board cannot accept this type of
approach as justification for requiring secondary treat-
ment on the basis that perhaps it will solve the
problem.
             Degree of Treatment of Industrial Waste
Water;
             Under Michigan Law, the 104 industrial es-
tablishments discharging wastes directly into water
courses in the Six-County Area are answerable to the
Michigan Water Resources Commission.
             The Board recognized that while many of the
44 industrial plants discharging industrial waste directly
into the Rouge and Detroit River had established waste
control, sufficient uncontrolled waste discharges remain
as to adversely affect water quality,  particularly in
the Rouge River.
             The Board indicated that  continued effort
on the part of the Water Resources Commission and the
industries should result in the reduction of the existing
industrial pollution.
             IN SUMMARY:
             The Board recommends that for the Detroit
Plant, additional primary facilities be provided to meet
the 4,000,000 population requirements, and that if im-

-------
                                                      1455

             George E. Hubbell

proved means of treatment eventuate,and they are de-
finitely in the public interest, they should be in-
corporated into increased degrees of treatment where
applicable in th.e Six-County Area.  The next several
years should provide ample time for intensifying the
studies required to provide a better understanding of
the behavior of the Detroit River and Lake Erie than is
now at hand.  In this period, laboratory,^ field, and
model studies should be developed to provide clear con-
ceptions of diffusion-dispersion phenomena and the bio-
chemical capacity of the waters to receive and assimilate
sewage treated to various degrees of stability.  It is
only upon the findings of these expanded studies that
one would be warranted in suggesting the time at and
extent to which additional degrees of treatment, if any,
would be required by future conditions.

-------
                                                    1456
          George Hubbell
            MR. STEIN:  Thank you, Mr, Hubbell«
            Are there any comments or questions, Mr.
Poston?
            MR. POSTON:   I note that your report Indi-
cates that the benefit from secondary treatment, does
not warrant—because of BOD and nitrogen removal, do not
provide the benefits.    I wonder If you take Into
account in the benefits from slime growth, of general
appearance of the water and use of the water.
            MR. HUBBELL:   Mr. Poston, it is the Board's
judgment that it would not benefit.
            MR. POSTON:   With regard to secondary treat-
ment and removal of the phosphates, we had testimony, or
we heard reports Indicating that phosphates are reduced
in properly operated secondary-type treatment plants,
and you indicate that this wouldn't be the case in the
case of Detroit, because there was some—
            MR. HUBBELL:  We felt that there would not
be a significant reduction at the present time with
the knowledge available on phosphate removal.
            MR. POSTON:    You are aware that like
plants in Chicago have phosphates in their effluent and
they are reduced in the magnitude of fifty per cent?
            MR. HUBBELL:   Yes, fifty per cent.

-------
                     George Hubbell




            MR. POSTON:  Are you referring, then,, to the




removal of phosphates, in secondary treatment as contrasted




to chemical treatment?  Do you think that phosphates in




secondary or activated sludge type would not be removed?




            MR. HUBBELL:  We recommend that continuing




studies be made on the development of intermediate




processes to determine the benefits that could be arrived




at by using such process, and this would include phosphate




removal.




            MR. POSTON:  That is all I have, Mr. Chairman.




            MR. STEIN:  Mr. Oeming?




            MR. OEMING:  Yes, I have a couple of questions,




These are Intended, Mr. Hubbell, to try to clear up in




my mind some problems here that I do not interpret




correctly, maybe.  Do you see any discrepancy in your




statements with respect to this combined sewer overflow




problem?  In your statement, for instance, on page 3 you




say, "It is the Board's judgment that frequent combined




overflow spills occasioned by rains of low^er intensity




create a nuisance, and every effort should be made to




eliminate the spills."  Then you say on page 4,




"It is not feasible with large combined systems to




eliminate combined sewer overflows.  Then you go on




to say, "It is a very difficult task."  I don't know

-------
                                                     1458



              George Hubbell



here whether you are—all of this refers to eliminating



or what, about modifying.



            MR. HUBBELL:    It was my intent—and I am



sorry it wasn't more clearly stated—that without any



control on a combined system or with a separate storm



system, every time it rains over something like .03



Inches you get a discharge of storm water; and this can



occur numerous times in this area, maybe up to a hundred



times a year.   It is possible to control—to eliminate



the overflow from this small type of rainfall and reduce



the number of overflows to perhaps one-third of this



amount; and those overflows being attributed to high-



intensity rainfalls—and we feel, and the Board felt



very strongly that every effort should be made to provide



control measures on the combined sewer systems to reduce



the frequency of spills.



            In fact, that is being done all over the



metropolitan area today.



            MR. OEMINO:   You are not against—



            MR. HUBBELL:  So that I am well understood,



I am not against attempting to alleviate discharge of



combined sewers, to reduce the amount and the frequency.



In fact, I have been working toward that for a good many



years.

-------
                                                    1459



              George Hubbell



            MR. OEMINQ:  But your reservation is about



the complete elimination?



            MR. HUBBELL:    My reservations is the com-



plete elimination.



            MR. OEMINO:  I seej all right.



            Now, Mr. Hubbell, on page 5, you make an



exception here to the possibility of additional treatment.



You qualify it to the extent that it should rest on



research under way and proposed.    I wonder if you



could be a little more specific as to Just what you had



in mind in the way of research under way and proposed.



            Let us take research under way, first.



            MR. HUBeELL:   Research under way I believe



can refer to all of the research that the Public Health



people are doing now on phosphate removal and nitrogen



removal and other methods of treatment, and the use



of Palmers and perhaps a method of treating sewage that you



or I have never even dreamed of to date.    We do not



know. And I know that there is a tremendous effort



and a tremendous amount of money being spent on research



to develop Increased economical methods of removing



nitrogen and that sort of thing, and this is what we



meant, as well as the type of thing that Mr. Remus



spoke about that they are doing at their own plant there.

-------
                                                     1460
                   George Hubbell
            I understand at the Wyandotte plant they are
in the process of conducting research on the use of
Palmers, and to get out material that is not presently
being taken out by primary treatment.
            MR. OEMING:   One more question, Mr. Hubbell:
You recommend pretty strongly that the cyanide phenol
and ferrous iron in the influent and effluent of the
Detroit plant be controlled through available ordinances
to keep them out of the sewers.   Is it your Judgment
that there is an effective way that can be relied upon
as an effective way to maintain continuing control day-
to-day over long periods of time of these substances,
as compared with treatment?
            MR. HUBBBLL:   I personally think that it
is far more effective to keep them out of the sewer
than it is to put these things in 500 million gallons
of water and then try to get them out at the sewage
plant, and I believe that the various municipalities
do have adequate ordinances and that they can be
enforced, and I mean enforced without undue hardship on
industry.
            I think Mr. Remus has made an excellent
statement of the approach that is going to be taken
by the City with regard to this.

-------
                                                     1461
             George Hubbell

            MR. OEMINQ:   I am Just asking for your

experience, whether this is the test way to approach this

problem, or how do you view It?

            MR. HUEBELL:    Personally I think it is the

best way.    I think that the discharges from industry

should meet ordinances and should be controlled into a

public sewer system.

            MR. OEMINQ:  Thank you, Mr. Hubbell; that is

all the questions that I have.

            MR. STEIN:   Mr. Hubbell, in your summary

statement you indicate that it is the Board's decision

that this is what they should do in the next several

years, rather than the recommendations made in the

Federal report that what should be done is intensified

studies made to give us a better understanding of what

happens in the Detroit River and Lake Erie; isn't that

right, that that probably—

            MR. HUBBELL:   I didn't understand your

question.   I don't think I quite understood that.

            MR. STEIN:   Here, as I understand it, you

say the next several years should provide ample time

for intensifying the studies required to provide a

better understanding of the behavior of the Detroit River

and Lake Erie than it now has.  That is, the State

-------
                                                     1462
                   George Hubbell
Federal agencies would be well advised in the next several
years possibly to concentrate on intensified studies.
            MR. HUBBELL:  It is my understanding that
this is going to be done.
            MR. STEIN:    Yes; but this is your
recommendation?
            MR. HDBBELL:   Yes.
            MR. STEIN: Well, now, the point is that the
things to look for in the study is the question of how
wastes can be diffused and dispersed and the capacity of
the water to receive and assimilate it; right?
            MR. HUBBELL:  We felt this way, and I
appreciate—this is a philosophy—
            MR. STEIN:  That is right.   I shall say
that, Mr. Hubbell, and I appreciate your point of view,
and this is a philosophy.   As you know, the Federal law
has considered that in a Statement of Purpose on this,
and I will say that as far as I know, this was reminis-
cent to me of the reports I used to read when I first
started in the business.
            I think this is a philosophy that has been
maintained by many people; but there possibly these
days might be a slightly different philosophy, and I
think there can be an accommodation.

-------
                                                    1463



                  George Hubbell



            Are there any further comments or questions



that you have?



            Thank you very much for a very helpful



comment.



            MR. HUBBELL:  Thank you very much.



            MR. STEIN:   Mr. Remus has asked to make



a short statement, if we may have him.



            MR. REMUS:    Mr. Coleman raised a question



about the difference between burned solids and the



total solids that we took out of the sewage plant.



The difference was that hauled away, that was in our



ash; and I would like also to hold our report open for



a couple of minor corrections we would like to make in



it, and if anything develops in the analysis of that



which we are not now aware of, I believe it was indicated



we would have a week open; is that correct?



            MR. STEIN:   Yes.   Pardon me, do you have



any objection?



            MR. OEMINO:   I have no objection.



            I Just want to know, Mr. Remus, do they



apply to the general issues that you raised, or have they



to do with data, itself?



            MR. REMUS:   No; it is some of the statements



that are made in the report.  If you read them, they are

-------
                                                    1464
                 Gerald Remus

not very  explanatory and then there la  one figure

that  I want  to recheek.

             MR. OEMING:  That is all right.    I  Just

van ted to  know.

             MR. STEIN:   Yes; this will be open, and we

shall do  that.

             Do you have anything else?

             MR. REMUS:  That is all.

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

             MR. OEMING:   Mr. Chairman, at this  time

I would like to provide the City of Wyandotte an oppor-

tunity to present a statement.     I believe this is to

be made by Mr. George Hazey.

-------
                                                    1465






                George J.  Hazey









                 STATEMENT OF




       GEORGE J.  HAZEY,  GENERAL MANAGER




              CITY OP WYANDOTTE




       DEPARTMENT OP MUNICIPAL SERVICE




              WYANDOTTE, MICHIGAN









              MR.  HAZEY:   The Federal  Report,  as  a re-




 sult  of a two year Federal-State investigation of water




 pollution in the Detroit  River - Lake Erie  Area,  pre-




 sents both general and  specific recommendations  for




 abating water pollution in these waters.




              As  these recommendations are reviewed, it




 is  interesting to observe that they include several important




 items to assure  a proper  program of pollution control.




 They  are:




              1.   Requiring wastes to  be  of  a  given con-




 centration in the effluent prior to discharge.




              2.   A regular program of monitoring  these




 waters.




              3.   The establishment of a  Public Health




 Service  Pollution Control Surveillance station in the




 lower section of  the Detroit River.




The City  of  Wyandotte uses the waters of the  Detroit River

-------
                                                      1466





               George J. Hazey




as the source of its public water supply.  In 1950 a




new raw water intake line was constructed and the crib




located in a zone of acceptable water quality.  Since




there are no recognized standards of quality, nor




effective pollution control measures, specifically




for the protection of raw water quality at intakes




this source began to deteriorate in 1953.




             Daily plant operating records and the



findings of the Public Health Service survey establish




present day water quality.




             Since 19^8 our water plant has been operating




with a free chlorine residual in the finished water.   High




and varying ammonia concentrations interfere with this




practice, requiring higher chlorine dosages which in-




creases treatment costs.




             Phenols require expensive treatment pro-




cedures to effect their complete removal.  When phenols



and ammonia are present at the same time and each vary




in concentration, treatment procedures cannot always in-




sure a palatable water.




             When consumers receive water with the




characteristic medicinal taste and odor, complaints are




in order, and often doubts are expressed as to the




safety of their supply.  The cost of these treatment

-------
                                                      1467




               George J. Hazey




procedures should not be borne by the customer.




             Phenols and ammonias should be reduced to




their lowest possible concentration before discharge in-




to the receiving stream.




             In the 1951 report of the International Joint




Commission on the Pollution of Boundary Waters, it was




recommended that in the treatment of municipal wastes,




that, a program of more efficient or secondary treatment




be inaugurated at as early a date as possible; and that




a median coliform M.P.N. value not exceeding 2400 per




100 ml., be considered as the objective for bacterial




control to attain reasonable stream sanitation.




             Our plant records indicate that for the past




53 months the median M.P.N. value of 2400 per 100 ml. was




attaiad only 39-6$ of the time at our intake source]




             While water purification processes have




made notable advances over the past few years, there is




no reason why these processes should have the added re-




sponsibility of waste treatment.  It is time that standards




for the quality of waste waters was established and en-



forced to protect all water uses.




             We respectfully request this Conference to




review the findings of the survey, and then consider




the recommendations of the Federal Report, and further,

-------
                                                      1468




                     George J.  Hazey




to accept them in the interest  of protecting present uses




as well as those of the future.




            Our abundance of fresh water is a gift of




God.  The Detroit River should  be a thing of beauty, a




priceless recreation and industrial facility.  It is




our duty to protect it for all  citizens rather than for




those who would use it  and then pollute it to such a




state that it is unfit for others to use and enjoy.




            Thank you for the courtesy of appearing




before this Conference.

-------
                                                    1469
                  George Hazey

            MR. STEDTi    Thank you, Mr. Hazey.   Are

there any comments or questions?

            MR. POSTON:   You comment about the per

cent of time that the coliform met the Joint Commission

recommendations.   I wondered whether you have any

observation as to the trend in this water quality.

Has it improved, stayed the same, or is it better since

this study started in 1962?

            MR. HAZEY:   In 1962, the last nine months

of that year there was an average of about a 44 per cent

reduction when compared to the same periods the previous

year in 1961.

            The first two months of 1963 there was a

66 per cent reduction, but the trend has gone the other

way since that time.

            MR. POSTON:   In other words, there was an

improvement, and then it dropped off?

            MR. HAZEY:   Yes.

            MR. STEIN:  Mr. Hazey, I note by the map that

Wyandotte is below Detroit.   Is your water intake below

the water intake for Detroit?

            MR. HAZE?:  That is correct.

            MR. STEIN: Do you have it, for the national

position, at least, the choitfe that Mr. Remus indicated,

-------
                                                     1470
                      George Bazey
Detroit might have gone above or below—you did not
think you could get your water intake much above its
discharge point, or do you?
            MR. HAZEY:  To get our intake above this
point?
            MR. STEIN:    Yes.     You do not think that
would be equally feasible for your city?
            MR. HAZEY: That's right; it would be a pretty
costly expenditure, that is true.
            MR. STEIN:   But the point that I see on the
map  is very clear, that while Detroit may have the
option, as Mr. Remus has pointed out, on the water intake
*ove and below, it is pretty hard for a smaller community
like Wyandotte to place its water intake and have it
equally feasible to be anywhere but below the Detroit
waste discharge?
            MR. HAZEY: That's right.   Our intake, when
they established the filtration was back in 1918 and it
has  been in that position since then.
            MR. STEIN:  There has been some suggestion
about putting the discharge point at another place.  How
come you have kept it there?
            MR. HAZEY:   I didn't get your question.
            MR. STEIN:  There has been some question

-------
                                                   1471



                George Hazey



 raised  about  the  possibility of your moving that  point



of intake.   Why do you keep it where you are keeping  it?




            MR. HAZEY:   It was originally suggested that



 we go into Canadian waters because the waters on  the



 other side of the international boundary were of  better




 quality,  but  the  permit that was granted by the Canadian



 Government is simply a permit for the installation of a



 structure—period—and to install any facility on the



 Canadian  side we  would have no insurance as to



 the quality of the water being maintained at ths same



 quality at the time you might put the structure in there.



            MR. STEIN:  Thank you.



            MR. OEMTNG:   Mr. Hazey, I have one question



 here—it  may  be a question, and it may be an attempt to



 rectify what  might be a misunderstanding on your  part.



 At the bottom of  page 2 you refer to the recommendations



 of the International Joint Commission; and I wonder



 if you have checked this with the actual recommendations



of the International Joint Commission.



            MR. HAZEY:  In reference to what?



            MR. OEMING:   With respect to this program



 of secondary  treatment at as early a date as possible.




 Are you certain that this is correct?



            MR. HAZEY: Well, I would have to check.    I

-------
                                                     1472



                 George  Hazey



 may have  read  a  different  portion.



             MR.  OEMING:  Could  I help you out?



             MR.  HAZEY:   Yes, fine.



             MR.  OEMING:    This,  Mr.  Chairman, Is  the report



of the  International  Joint  Commission, Washington-Ottawa,



 1950,  as  adopted by  the two  governments,  IT.  S. and



 Canada.



             I  am asking Mr.  Hazey to read the answer



 to question  4  which  was posed to the International  Joint



 Commission,  and  the  answer given by  the Commission  to



 this question.



             MR.  HAZEY:     "Treatment of municipal wastes



 by sedimentation and disinfection of the  effluent is



 urgently  needed  and  should be undertaken  as  an Initial



 step by all  municipalities where all phases  are not



 afforded  such  primary treatment.




             "This should be  followed by a more efficient



 or secondary treatment  where necessary In order to  meet



 the requirements of  the objectives."




             MR.  STEIN:   Isn't that what he said here?



             MR.  OEMING:    No, he did not.



             MR.  STEIN:   He  said "a  program  of more



 efficient or secondary  treatment on  page  2.




             MR.  OEMING: That is different.   I think

-------
                                                     1473
                 Qeorge Bazey
the record is all right.   Just leave it set.
            MR. STEIN:    0. K.    Are there any further
questions?
            MR. POSTON:     I wondered, Mr. Bazey, whether
you received in the last year any notification of water
quality  changes, of the quality of wateas that was coming
down  to  your intake prior to their reaching your intake.
            MR. HAZEY:   I am not aware of any.  From
what  source?
            MR. POSTON:  Well, any source.
            MR. HAZEY:    No, I am not aware of any.
If I  interpret your question correctly, Mr. Poston,
it is, is anyone advising us of a possible change in
vater  quality?
            MR. POSTON: Right.
            MR. HAZEY:   I am most certainly not
aware of any.
            MR. POSTON:   I think that is all.
            MR. STEIN:  While we are waiting, I would
like the record to show here the problem that we are
faced with in these philosophies, that the conferees
are faced with, with Mr. Bazey and Mr. Hubbell coming up.
Mr. Bazey is downstream talking about wanting to improve
water quality as soon as possible, because it is his

-------
                                                      1474



                George  Bazey



 business  to  try to  treat  a  water supply and  protect



the  people he is serving;  and  the question  here  of Mr.



 Hubbell1s philosophy  is to  study and  try to  find  out the



 capacity  of  the stream  to receive and assimilate



 sewage.



             Now,  the  question here  is to try to get an



 accommodation, and  you  can  see we have to  have  in mind,



 respecting both philosophies, is how  the operator of the



 water works  is going  to feel  seeing  this  water every day



 while we  go  around  surveying  the assimilative capacity of



ttiis water to stabilize  sewage; and  I  think right  with



t hese two statements  you  can  very well see the  real



 acute problem that  faces  us in this field  and faces the



 conferees.



             Mr. Oeming?



             MR. OEMING:   I would like to  pursue  Mr.



 Boston's  question and Mr. Hazey's answer a little about



this notification business.    Do you  mean  to say,  Mr.



 Hazey, that  you know  of no  case  where the  State or the



 other State  agencies  do not notify  you when  they  know



 of  something that might have  happened above,that  would



 affect your  intake?



             MR. HAZEY:    I may have misinterpreted Mr.



 Boston's  question.    I am  simply trying to  recall, but

-------
                                                    1475




                  George Bazey



 I am not aware at the present time.   I might clarify



this question by saying that In my present position of



 general manager of Municipal Service, I have someone



 else presently at the water plant, and I may have not



 exactly checked the records.    I was thinking In



 terms solely of a few instances where something has



 occurred and we were not notified.



             MR. OEMINQ: But this isn't —



             MR. HAZEY:   I cannot say right now one hundred



 per cent of the time, if I may clarify it.



             MR. OEMING:  But a notice might have gotten



 to your plant superintendent?



             MR. HAZEY:    This is possible.



             MR. OEMINO:   Instead of you?



             MR. HAZEY: This is possible.



             MR. OEMING:   All right.



             MR. STEIN:  Are there any further comments



 or questions?



             MR. POSTON:     No.



             MR. STEIN:   If not, thank you very much, Mr.



 Hazey, for an Illuminating statement and looking at



 this from a little different point of view.



             MR. HAZEY: Thank you.



             MR. OEMING:   I have one more statement,

-------
                                                    1476
Mr. Chairman, this morning by Grassy Isle Township,
and I believe Mr. Merle E. Solomon, Supervisor, has
a statement to make.      Is Merle Solomon present?
(No response.)
            MR. STEIN:   I guess not.
            MR. OEMING:   Mr. Chairman, with respect—
this concludes the notices I have received from muni-
cipalities and governmental units who responded to my
invitation to present statements at this conference.
If there are any others that want to make a statement,
I am not aware of it.
            I notified them all by letter and invited
them to make statements, and this is the time for
the Detroit area municipalities and governmental units
to make their statements.
            (No response.)
            MR. STEIN:   If not?
            MR. OEMING:   There are none.
            MR. STEIN:  The rest of the program, I under-
stand, of statements, will be industrial statements; is
that correct,  sir?
            MR. OEMING:  That is correct.
            MR. STEIN:   We shall stand recessed until
1:40 p. m.
            (Whereupon at 12:10 p. m. a recess was
 taken for luncheon.)

-------
                     AFTERNOON SESSION








            MR. STEIN:  May we reconvene.  Mr. Oeming?




            MR. OEMING:  Mr. Chairman and Mr. Poston,




before starting with the appearances for this afternoon




I would like to make an announcement.  I have had many




requests for copies of the PHS report, copies of the




State report, and some requests for,the transcript of




the previous conference proceedings in 1962.  We have




some copies of each of these reports with us, and I




would like to refer your requests to the employees of




the Water Resources Commission who are here.




            Mrs. Struhsaker, would you stand, please, so




people will know whom to contact, and Mrs. Frost.  They




will try to service your requests, and if they cannot




service them, they will take your names and mail you your




requests.




            Now, Mr. Chairman, in opening the session




this afternoon I would like to provide the opportunity,




first of all, for the statement to be presented on behalf




of the Michigan State Chamber of Commerce by Mr. Gene




Little.




            Mr. Little.

-------
                                                      1478
                 Gene Little
            STATEMENT OP GENE LITTLE,

        MANAGER OP NEWS AND INFORMATION,

       MICHIGAN STATE CHAMBER OP COMMERCE


             MR.  LITTLE:   Mr. Chairman and members of the

 Commission,  gentlemen, and ladies:

             I am here in the role as  a substitute  this

 afternoon for Mr. Harry R. Hall, the  executive  vice-

 president of the Michigan State Chamber  of Commerce,  and

 with your permission I will read his  statement  at  this

 time.

             MR.  STEIN:  Would, you: ident if y;, yourself?

             MR.  LITTLE:   Pardon me.     My name is Gene

 Little, and  I am manager of news and  information for

 the Michigan State Chamber of Commerce.

             I want to be as positive  as  I  can in stating

 that the Michigan State Chamber of  Commerce does not

 favor pollution.   In fact, the records  will show  that

 our Water Resources Committee,  and  our policy making

 board of directors have frequently  urged more action in

tills field and have been active In seeking  a state-wide

 water use policy that would offer more positive controls

 on the use of this vital resource.

-------
                                                       1479
                    Gene Little

             Our concern here today,  however,  Is with the

 public  statements that have minimized the extensive and

 productive  efforts on the part of industry in general

 to  improve  disposal facilities leading to the diminution

of pollution in all of our waters,  and particularly the

 Detroit River.   We are eincerely concerned about  the

 reports that over-simplify the problem and stigmatize

 industry without giving any credit or consideration for

the  costly work that has been progressing in almost every

 industry involved on the Detroit  River.

             At a later date the Michigan state Chamber

of Commerce  hopes to document this progress with facts and

 figures that will refute further  the now discredited

idea that Industry cares nothing,  whatsoever,  about the

 pollution problem, and is merely  interested in disposing

of waste matter in complete disregard of the public

 interest.

             To make our position  clear, I would like  to

 refer you to a policy that was approved in January of

 1963 by the Board of Directors of  the Michigan state

 Chamber of  Commerce.    In that policy statement we called

 for a clear-cut policy on a state level that  would pro-

 vide for a  general over-all program  that would "provide

 active  and  sympathetic guidance and  coordination of

-------
                                                       1480




                       Gene Little




water resource management and development to the end




that all beneficial water needs may be most fully and




permanently met."



            In a later policy on water pollution,




adopted in December of 1963, we stated the following:



         "The Michigan State Chamber of Commerce believes:




            1.  That the discharge of pollutional wastes




into the waterways of the State should be controlled.



            2.  That while the primary objective of




pollution control must be the protection of the public




health, other objectives add impelling reasons for




protecting the State's water resources, such as the



need for the use and reuse of surface waters and ground



waters which receive and dilute the liquid wastes.




            3.  That decisions on the type and degree



of treatment and control of wastes and the disposal and




utilization of adequately treated waste water, must be




based on thorough consideration of all the technical,




economic, and related factors involved in each portion



of each drainage basin.




            4.  That the public' must be made fully aware




of the hazards of pollution and of the workable means




for control,  so that it will sponsor and support




construction and proper operation of all necessary

-------
                                                     1481
                  Gene  Little

 facilities.

             5.   That industry shall  recognize  and  accept

 its  responsibilities for the  proper  treatment  and

 control  of its  wastes.

             6.    That  local units  of government  should

 install  and  operate adequate  facilities.

             7.  That the  State of Michigan must be

 responsible  for the administration of adequate State

 and  Interstate  (not Federal)  pollution  control programs,

 which must be supported  by increased budgets,  and

 adequately staffed by  well-trained and  compensated

engineers, scientists,  and other personnel and  that the

 administration  of pollution control  be  firm, effective,

 and  equitable."

             The  question under discussion here today

 seems to be  "Are we winning the pollution battle on the

 Detroit  River?"

             Almost everyone has a  different definition

 of the word  "pollution."   To some,  water is polluted if

 it is anything but pristine pure.    To  others  it is

 polluted only if it exceeds certain  criteria as established

 by law.

             Some place in between  these two extremes,

 there is room for a flexible,  workable  program that

-------
                                                    1482




                       Gene Little




would utilize the waters of Michigan in the best




interests of the five main areas of concern — industry,




municipalities, agriculture, and recreation and wildlife.




            To meet the needs of these areas of




interest, Michigan must be assured of safe, pure and



adequate supplies for the home, factory, and farm; stream-




flows sufficient to assimilate municipal and industrial



wastes while maintaining suitable habitat for fish and




wildfowl; stable levels and quality suitable for body-




contact recreation; the protection of our cities and farms




from floods, and our land and beaches from erosion.




            For the past fifteen years Michigan has




moved steadily forward in all of these areas of




endeavor.  However, disagreements exist as to how



effective our program in Michigan has been.  To the




sportsman and the fisherman, any waste disposal to our




water courses is a matter of concern.  To the indus-




trialist and to local governments, the stream is an




indispensable vehicle to assimilate and remove waste



effluents.




            But to the Water Resources Commission, the



objective must be one of assuring all interests with




water of the quality required for their various competing

-------
                                                      1483
                   Gene  Little
uses,  within  the  framework of  reasonableness  as  provided
by Michigan Law.
            Neither the Commission,  nor industry,  nor any
governmental  body, can  wave a  magic  wand and  expect
troubled  waters to be corrected.     It  takes  long
years  of  study, as evidenced by the  report under
d iscusslon today  which  took two years to compile,  and
to identify the proper  restrictions  necessary for  any
given  waste disposal.     It takes  technical know-how,
time,  and money,  to put in operation the complex
facilities required to  comply  with these restrictions.
            The Michigan program is  recognized across
the  nation as one of the most  effective. It  has been
held up as a  model program, as evidenced in the  last
year1s hearings before  the Committee on Public Works  of
Hie House  of Representatives.
            MR. STEIN:    Did you want that—
            MR. LITTLE:  Did I skip  a sentence there?
            MR. STEIN:  There was a sentence in your
statement  which said "Most of Michigan's chronic  pollution
cases  have been solved, or are at  this  moment being
solved."       Do  you want that stricken?
            MR. LITTLE:    No.
            Most  of Michigan's chronic  pollution cases

-------
                                                      1484




                         Gene Little




have been solved or are at this moment being solved.




           - The Michigan program is recognized across




the nation as one of the most effective.  It has been




held up as a model program, as evidenced in the last



year's hearings before the Committee on Public Works of




the House of Representatives.




            Former Representative Harold Ryan said that




"Michigan has assumed the highest place of all fifty



States in the nation of eliminating and reducing pollu-




tion in the streams of the State of Michigan."




            Representative John A. Blatnik,  in his




remarks said this:  "I will say this for the record:  If




all States were doing the job that your State of Michigan




is doing, and has been doing, we would not have any matter




of standards coming up before us."




            It is ironic then that we should be meeting



here today as one of the first States to undergo such




a thorough and exhaustive study as evidenced in the




report now under discussion.




            So, let us look at some recent facts that




have been published both in the report and in Water




Resources reports that indicate tremendous progress in




pollution control.




            The 1964 status report of the Michigan Water

-------
                                                    1485
                Gene Little
Resources Commission indicates that 316 out of 488
industrial and commercial establishments received an
"A" rating; and 120 firms were reported to receive a
"B" rating.
            'During the past few years, 38 out of 42
industries on the Detroit River met certain objectives
laid out by the Water Resources Commission to abate
pollution.
            While the PHS report mentions the downward
trend in major pollutants in recent years by simply saying
they have been reduced by more than 50 per cent, actual
figures show the following downward trend in major
pollutants:
                 Oils               down 80$
                 Phenol             down 78$
            Cyanides                down
            Ammonia                 down
            Suspended solids        down 63$
      The Public Health Service report also offers some
pertinent statements which indicate a downward trend.
But strangely these have not been found in any publicity:
                 Samples during the past four years
            indicate a pronounced downward trend in
            coliform densities, especially during the
            years 1962 and 1963.

-------
                                                     1486
                   Gene Little

                 These records indicate a substantial

            reduction in monthly geometric mean

            coliform densities during 1962 and 1963.

                 Monthly geometric mean values in several

            Detroit River sewage treatment plant

            effluents Indicate substantial reduction

            during the past few years.

                 Although these concentrations (Phenol)

            are not yet significant enough to cause

            major interference with water use .

                 While present oxygen levels in the lake

            (Erie) do not yet cause major Interference

            with water use .   .

                 There is no evidence of damage to Lake

            Erie water use by phenols at this time.

                 While present levels (chlorides)  do not

            interfere with water use, the year by year

            increase at the Monroe Water intake is noted
            as a warning.


            These statements indicate that our progress
is being recognized by the Federal Government, and by

others that are familiar with the changing patterns of
industrial and suburban growth.

-------
                                                      1487
                   Gene Little

            Complete  objectivity is indispensable in

developing and administering so vital a resource as our

water.    We cannot afford  to set policies and promulgate

programs  that would benefit one special group to the

exclusion of others.  Failure to see the whole picture

can  lead  to serious conflict and injury and may greatly

limit the future utilization of this great natural

resource.

            To listen to the alarmist who says that

we are being overwhelmed by our own filth is Just as bad

as listening to those who say there is no pollution.

We must be realistic  in our approach and focus public

attention upon a  realistic and meaningful objective

of providing reasonable use for all interests.

            The Michigan State Chamber of Commerce is

firmly convinced  that pollution control in the future,

as it has in the  past, will continue to improve as our

sustained  investment in time and money in research and

facilities continue to bear fruit.

            We believe that pollution control should

proceed as a partnership program, with the Federal

Government serving as one of the coordinating and

guiding partners, rather than dictating standards that

would, without question, determine the location and

growth of our industries and our cities.

-------
                                                      1488
                  Gene Little

             Thank you very much.

             MR.  STEIN:   Thank you.   Are there any

 comments or questions,  Mr. Poston?

             MR.  POSTON:   No,  I think not.

             MR.  STEIN:     Mr.  Oeming?

             MR.  OEMING:   I have norte.

             MR.  STEIN:      Mr. Little,  I have one or

 two I would like explained.

             MR.  LITTLE:   Yes.

             MR.  STEIN:    On the first page  of your

statement you say "We  are sincerely  concerned  with the

 reports that over-simplify the problem."

             I wonder  if you could specify the report

 you are referring to.     Do you mean the 350-page report

 here (indicating), this report of Mr. Remus,  or the

 exhaustive State report—and let me give you  the whole

 thing at once—or your other question when  you worry

 about reports over-simplifying the  problem, on page 4 of

 your statement you say "It is  Ironic then that we should

 be  meeting here  today as one of the first states to

 undergo such a thorough and exhaustive study  as evidenced

 in  the report now under discussion."

             Which report are you talking about?

             MR.  LITTLE:    I think  Mr.Hall  is referring

-------
                                                     1489
                    Gene Little

 to  the  publicity that has been generated.

             MR.  STEIN:   Which publicity?

             MR.  LITTLE:   In all the newspapers,  radio,

 television,  and  so on.

             MR.  STEIN: Do you have any specifics?

 Do  you  mean  the  newspapers and the television  are over-

 simplifying  the  problemj is that your view?

             MR.  LITTLE:  No.   They are over-simplifying,

 I think,  the role of Industry in solving their problems.

 This is—

             MR.  STEIN:   You are saying that newspapers

a nd television are oversimplifying the role of industry

 in  solving the problem?

             MR.  LITTLE:   This is Mr. Ball's statement.

             MR.  STEIN:   Thank you.

             Mr.  Oeming?

             MR.  OEMING:   Next, Mr. Chairman,  I would  like

 to  provide the opportunity for Mr. James D. Ogden to pre-

sent a statement.   I believe he is accompanied by Miss

 Olga Madar.

-------
                                                      1^90




                      James D. Ogden








              STATEMENT OF JAMES D. OGDEN,



      ADMINISTRATIVE ASSISTANT TO WALTER P. REUTHER,




      INTERNATIONAL UNION, UNITED AUTOMOBILE WORKERS








            MR. OGDEN:  Thank you, Mr. Chairman.




            My name is James D. Ogden.  I am adminis-




trative assistant to Walter P. Reuther, President of the




United Auto Workers union.



            I want to thank your committee for this




opportunity to make our presentation on the total subject




of pollution in the Detroit River-Lake Erie complex.




            Our report and our presentation will go to




the basic points that all sectors, both private and




public, have a responsibility in the area of meeting




the problem of water pollution in the greater metropolitan




area.




            We are particularly concerned with the



responsibility of city government, State government, as




well as Federal Government.  We were heartened by the




presentation by the Honorable Governor Romney, as well



as the Honorable Governor Rhodes of the State of Ohio.




We would call to their attention and respectfully




suggest that in both instances and in both States that

-------
                                                        1491
                    James G.  Ogden
 they view the program of Governor Nelson  Rockefeller in
the State  of New York.    Now,  as  I understand It,
 Governor  Rocketftller1s program has not  had money appro-
 priated,  and no basic progress has begun,  but at least
 his program—the  time is now—points up the problem of
water pollution, puts the State of New York on record
 as recognizing the  problem and suggests some possible
solution.
             This  past month  Miss  Madar  and myself  had
 the pleasure of Joining a boat trip on  the lower echelons
cf the Detroit River and up through the  Rouge River.
 That boat trip disclosed to  us graphically some  of the
 sources of pollution of the  Detroit River, and we  would
 suggest that those  industries  that are  situated  along
 the Detroit and Rouge Rivers,  as  well as  the City  of
 Detroit,  and the  outflow problem  from the  City of
 Detroit sewage system all have to be dealt with
 dramatically if we  are going to meet the  problem of
 pollution in the  Detroit River and Lake Erie.
             As an addendum to  our presentation here
 today—and we shall have copies of this for all  of you,
 we have a booklet entitled "In Pursuit  of Greatness,"
which is  a reproduction of President Johnson's message
 on natural beauty,  and I would particularly call your

-------
                                                       1492
                 James 0.  Ogden

 attention to the introductory remarks  by Mr.

 Reuther,  which go to the  basic philosophy of  our

organization as it applies to  the  subject of pollution.

             Mr.  Chairman, at  this time,  I would  like

 to  Introduce Miss Olga Madar,  who will make the  pre-

 sentation on behalf  of the U.  A.  W.

             Thank you very much.

-------
                                                       1493
                  Olga  Madar
            STATEMENT OF OLGA  MADAR

 INTERNATIONAL UNION,  UNITED AUTOMOBILE WORKERS


             MISS  MADAR:    Mr.  Chairman,  conferees, and

 guests:     As Mr. Ogden has said,  I  am here as a

 representative  of the UAW,  and  at  the  request of Mr.

 Walter Reuther, president of  the United Auto Workers

 of America.

             The UAW has approximately  350,000 members

In  the  area  surrounding the  Detroit River  and Lake Erie.

 In our activities we  have attempted  to provide energetic

 and purposeful  leadership in  all aspects  of the

 community life, outside as  well as inside the auto

 plants.

             For many  years  the  UAW has lent its weight

 to campaigns for  neighborhood conservation, urban

 renewal,  beautification of  the  city  and country, and

 restoration of  water  resources.   We  have urged planning

 for the future, for the increased  demands that will

 inevitably  be placed  on our recreational  resources by

an area population projected  to reach  5-|  million by 1980.

We have recognized that the pollution  of  our waters,

especially  the Michigan waters  of  Lake Erie, is growing,

-------
                                                       1494
                    Olga Madar
 not  lessening.     Our 350,000 area members  represent
nearly 350,000  families, each eager  to preserve and
 expand opportunities  for swimming, fishing, and
toating.  Accordingly,  we welcomed the cooperation of the
 Michigan Water  Resources Commission  and the U. S.
 Department  of Health,  Education, and Welfare in the
 battle against  pollution.
            This cooperative  effort  began on the most
 sold scientific basis  that could be  asked:  a two-and-
 a-half year, $750,000  study project.    A staff of
 about 30, with  headquarters at the Naval Air Station at
 Grosse lie, spent  nearly two  years studying the River,
 the  Lake, and the  wastes pouring into them.     Their
final report is staggeringly  thorough, detailed, and
 precise.  The study project was concluded with the
presentation of conclusions and recommendations, each of
 them fully  explained and justified by the scientific
 findings.    I  think I can speak for the UAW when I say
 that we find the report completely convincing.
            We  in  the  UAW feel a special responsibility
for leadership in abating pollution which originates in
 automobile  plants  or associated industries.   But we
 represent citizens of  this area as well as  auto workers,
 and  the Public  Health  Service report prepared for this

-------
                                                     1495
                      Olga Madar

 conference Indicates, beyond the possibility of any

doubt,  that several of our municipal installations also

 add pollution to these waters.     There have been some

n ewspaper stories and statements by individuals which

Interpret this report as an insult and an affront to

 Detroit and Its municipal government.     Such an

Interpretation is at best a disappointing response to a

 growing nation-wide concern with protecting water

 resources, and at worst a cynical tactic to avoid taking

the necessary remedial action.

             The Chairman of this conference has emphasized

that this is not an adversary proceeding.    No one is

teing indicted here, and no orders will be Issued.   The

 Public Health Service study and recommendations were

made, at Federal expense, at the request of John

 Swainson, the former Governor of Michigan.

             The conferees and other participants here to*

 day are being given an opportunity to  discuss these

 recommendations, to offer new ones, and amend the old

 ones,  and to debate means of abating pollution.  To

 whatever program of action the  conferees adopt that will

 stop pollution in the Detroit River -  Lake Erie complex,

 the UAW pledges Its full support.

             Critics of the Public Health Service report

-------
                                                     1496
                  Olga  Madar
 have expressed puzzlement  that  Detroit's  existing
 sewage treatment plant,  once  considered ultra-modern,
 should now be termed inadequate.   There should be
 nothing puzzling about this.  Detroit's population  has
 multiplied six times since 1910.    Its Industry has grown
 accordingly,  and so, naturally, have  its  waste dis-
charges.  Detroit's supply  of  water always has  and
 always will remain exactly the  same.   It should be
 obvious that, if we discharge Increased amounts of
 wastes into the same quantity of  water, more advanced
 treatment will be required.
             The urgent problem  of the pollution of  Lake
 Erie presents a separate,  equally important reason  for
ttie installation of further treatment  facilities by  the
 municipalities of the  Detroit area.   The  particular
 pollution problem In Lake  Erie—aging—is not  new.   It
 is a problem in which  recent  technological advances have
 added to our understanding.   We know  now  that  Lake  Erie
 changes every year, becoming  more and more like a bog
 and less and  less like a clear  lake.    We know now the
 causes of this aging process, and what we can  do to
 slow It down.   If nothing else works, certain
 types of chemical treatment may  render wastes less
 damaging to the lake.   The Public Health  Service

-------
                                                     1497
                  Olga Madar
 recommendation for secondary treatment is, in fact,
 the minimum and the least expensive means of improving water
 quality in the Lake.
             And I would think it safe to suggest that
the most expensive waste treatment that could be designed
 could not begin to reach the value of Lake Erie merely
for industrial and navigation purposes.   The recreation
value, present and potential, of Lake Erie is beyond
all dollar estimates.
             The recommendations for further waste treat-
ment in Detroit are in no way a condemnation of the
 excellent work done until this time by our public water
and sewer departments.    No more do the recommendations
for industrial waste treatment represent a condemnation
of Detroit's industries.    Many of these plants have
exercised Initiative and public spirit in providing
waste reductions, particularly in new plants.
             Incidentally, may I Just state, personally,
 that after my trip in the Detroit River, and particularly
in the Rouge River, I have been contemplating buying a
new ear this year, and I have been looking at many of
them, and I have come to the conclusion that the
engineering detail and the styling are equally in all
cars quite good, and it is a question of personal taste;

-------
                                                     1498
                 Olga Madar

 and if I do this on the basis of personal taste now,

 however, in regard to my concern about water pollution,

 I have a pretty g^ori;Mea cof what ear I will not buy.

 Now,  that is on my own that I make this comment.

 I will go back to the testimony (laughter).

             May I repeat:    Many of these  plants have

 exercised initiative and public spirit in providing

 waste reductions, particularly in new plants.    If

 various interested groups,  government afld private, now

 find  that both municipal and industrial polluters require

some prodding to accelerate  their construction of

 treatment facilities they should not be surprised.

 Nor should they be alarmed  if some of those establishments

asked  to make expenditures for treatment facilities do a

bit of protesting.     It would be a poor businessman who

 was too anxious to spend his stockholders'  money.   Sim-

 ilarly, few cautious city officials are eager to commit

 city funds to new construction without the  clearly

 expressed support of the voters.

             That support is almost universal in Detroit.

 We in the UAW will do our best to see that  it is

 expressed not only here but also in Ohio and Canada.

 We hope that many other groups of private citizens will

 join  us in making explicit  to city and Industry officials

-------
                                                     1499
                 Olga Madar

 alike our pleas—no, our demands—for clean water In the

 Detroit River and Lake Erie.

             To achieve this, we endorse:

             (1)  The concept of "stream renewal" urged

 by a panel at the recent White House Conference on Natural

 Beauty which would establish a national goal of water

 beautification similar in scope to urban renewal.

             (2) A minimum requirement of secondary

 treatment in Detroit as well as other municipalities,

 unless it is demonstrated, without doubt,  that less

 treatment will suffice.

             (3)  Effective local,  state and Federal

 action to require industry to install adequate systems

 to avoid water pollution.

             (4)   Designation by the Federal Government

 of the Detroit River - Lake Erie complex as a model

 demonstration area where every known and accepted  waste

 treatment technology would be used.

             (5)   Establishment of a national policy which

 would require Industry to provide  satisfactory methods

 of treating waste products resulting from the production

of new products.

             (6)  Increased federal grants to encourage

 area-wide pollution control projects.

-------
                                                      1500
              Olga Madar

            We call upon the Governors of Ohio and

Michigan and the Mayors of Cleveland and Detroit to pro-

vide the leadership in soliciting the support of President

Lyndon B. Johnson, appropriate  'ederal agencies, and the

involved industries in achiving these objectives.  We

pledge the fullest support of the UAW.

            Attached is a copy of President Johnson's

Message on Natural Beauty, with a foreword by Walter P.

Reuther, President of the UAW.  This brochure is

published and distributed by the UAW Recreation Department

as a public service,

            Mr. Chairman, I thank you for this opportunity

to present this testimony on behalf of UAW.

            MR. STEIN:   Thank you.   Do you have any

comments or questions?

            MR. POSTON:    I would like to ask Miss

Madar—I know of Walter Reuther1s interest in pollution,

having been up there, requested to appear in a meeting.

I am wondering, though, what is the local unit of your

United Auto Workers, what do they report in on the matter

of water pollution and water quality in the Detroit area?

            MISS MADAR:   When you talk about the local

units, you mean the local unions?

            MR. POSTONs Right.

-------
                                                     1501
                  Olga Madar

            MISS MADAR:  We have many of our membership

who are vitally concerned about the pollution of the

Detroit River, and as you would gather, being citizens

of their community, first, they are boaters, they are

fishermen; they are concerned, therefore, about the

pollution in the Detroit River, and have Indicated

their concern to us.

            This is in addition to Mr. Reuther1s personal

interest.   He, of course, is concerned about the member-

ship and their desires, and we have long had a national

policy in terms of doing whatever we could to retain and

to improve the waters.

            Does that answer your question?

            MR. POSTON:   Yes.

            MISS MADAR:   We have good response, let me

say.  Our position on this one is a very popular position

with our membership.

            MR. POSTON: Thank you.

            MR. STEIN: Do you have any questions, Mr.

Oemlng?

            MR. OEMINQ:    I do not have any.   I think

this is a very elucidating report, Miss Madar.   Thank

you very much.

            MISS MADAR: Thank you.

-------
                                                       1502
                     Olga Madar
            MR.  STEIN:   Miss  Madar,  I  have  just  a
 question  of clarification.   I  think I follow all  your
 points, but I would  like to  call particular  attention
 to your fourth recommendation.
            You  say  "Designation by the Federal Government
 of the Detroit River-Lake Erie complex  as a model
 demonstration area where every known  and accepted waste
 treatment technology would be used."
            This is  fine, except I have had,  maybe you
 know, some bad experience in Federal  administration in
 dealing with demonstration areas, and Obviously one of
the things we like in a  demonstration  area is that the
 people in the area and  the industry be  ready and  willing
 to accept the demonstration.
            Now, if  there were recommendations made about
 secondary treatment  or  certain requirements,  I understand,
 at least  from some people here in a County report, it
 is indicated that we have to study the  River further  and
 find  out  what the River can  absorb, and everything is
 going along fine.
            I am not sure from listening to  the City  and
 reading the report what they are supposed to do there.
            For  example, we  have another large city,
 Chicago,  where they  have secondary treatment.  They

-------
                                                      1503
                 Olga Madar
have employed the latest methods to get rid of their
sludge.  At the latest conference they pledged to insure
full industrial treatment of all the industries within
their Jurisdiction, and that they are obtaining funds
to chlorinate their effluent on a year-round basis, and
that is with secondary treatment.
            It would seem if we had to choose between
cities for a demonstration—and we welcome your sugges-
tion as valuable—but I think the people of Detroit in
this area have to meet this part way to be eligible for
a demonstration.
            MISS MADAR:  Mr. Stein, I agree with you
completely on this, and the concept here is based on
indicating to the general population a prototype of
what can be done and that this not necessarily be
confined to just one area, but scattered throughout the
U, S.; so that in terms of the encouragement we now
have from the population about concern in this regard,
this will give them some demonstrations of what is
achievable if concerted effort is made.
            However, in regard to your point, as I said,
I agreed completely and I am really hopeful that this
is the approach that will be used for instance in the
City of DetrP.it, because it is the same kind of approach

-------
                                                     1504
                  Olga  Madar
 In which we  have  had much experience  in  terms of
 getting Federal assistance in urban renewal,  in  poverty

 programs,  and  In  many  other kinds  of  projects.
             We cannot  adopt practices which in effect
 are contrary to what are  enunciated,  for Instance,
 In the  President's message on natural beauty.
 If we expect to have cooperation from the Federal Govern-
m ent then  we must do the  things here  to  encourage and
 get additional support from the Federal  Government.
             MR. STEIN: That is good.  Miss Madar, we
 would be delighted to  come in here with  our technical
 assistance,  financial  assistance, and demonstration
 programs,  but  In  order to do that, as you point  out,
 we need the  cooperation from you.  I  do  not doubt it
 very well  may  be  effective.     I think  the problem
 coming  in  here wearing our enforcement hats,  forcing our
 way in  with  a  shoehorn indicates there is a different
 attitude in  the approach  in the locality.   In all demon-
 strations  we must have a  response from the locality
 involved , wishing that demonstration and wishing
 the work to  be done.    We stand ready to cooperate
 wherever we  see grounds to do so.
             MISS  MADARs   Thank you.
             MR. STEIN:  Thank you.
             Mr. Oeming?

-------
                                                      1505
                 Olga Madar
            MR. OEMING:    Mr. Chairman, Mr. Poston,
I would like the opportunity at this time for the Great
Lakes Steel Corporation to present a statement.    I am
not sure who the spokesman is going to be.   I will leave
it up to him to introduce himself.

-------
                                                       1505-A




                  Fred E. Tucker








           STATEMENT OF FRED E. TUCKER




   COORDINATOR OF INDUSTRIAL HEALTH ENGINEERING




            NATIONAL STEEL CORPORATION




                       FOR




           GREAT LAKES STEEL CORPORATION








             MR. TUCKER:  Mr. Chairman, Conferees,




Ladies and Gentlemen:




             My name is Fred E. Tucker.  I am the




Coordinator of Industrial Health Engineering for National




Steel Corporation having primary responsibility for




matters involving air and stream pollution control at




National Steel.  Great Lakes Steel Corporation is a




division of National Steel Corporation and I appear




before you today to make a statement concerning the




facilities operated by Great Lakes Steel Corporation as




listed in the Public Health Service Report on Pollution




of The Detroit River, Michigan Waters of Lake Erie, and




Their Tributaries.




             I would like first to take this opportunity




to compliment the Public Health Service personnel who




participated in the Detroit River-Lake Erie Project.




The data presented  in  the  "Findings"  section  of  the

-------
                                                        1506
                  Fred E. Tucker
"Report Gn Pollution of the Detroit River, Michigan
Waters of Lake Erie, and Their Tributaries" is an
excellent comprehensive study of water conditions, uses,
and needs of this important watercourse.  I am sure that
the information contained in tMs report will be most bene-
ficial to the Michigan Water Resources Commissions,
municipalities, and industry in their progressive stream
pollution control programs.  I would like to take this
opportunity to comment on progress in stream pollution
control at Great Lakes Steel Corporation and the material
contained in the "Summary, Conclusions, and Recommendations"
section of the Public Health Service Report.
             Great Lakes Steel was built in Ecorse in 1929
and 1930 and its first steel was made in August 1930.  Its
Blast Furnace Division dates back to 1902 when Blast Fur-
nace "A" was first constructed at the River Rouge site by
the M.A. Hanna Company.  In 1930, you may recall, this
country was in the Great Depression and most of us, in-
cluding the Federal Government, were more concerned about
prosperity than about pollution.
             The sharp contrast between stream pollution
control then and now was pointed out in a statement made
for our Midwest Steel Division at Portage, Indiana, by
K.G. Jackson in March of this year  at  the Chicago water

-------
                                                       1507



             Fred E. Tucker



enforcement conference.  Our Midwest Steel plant was



placed in operation in 1960, and in his statement in



Chicago, Mr. Jackson described a costly elaborate and



highly efficient waste treatment facility designed and



constructed as an integral part of this modern plant.



The water effluent from Midwest Steel was given a clean



bill of health by the Chicago conference.  (It is well to



note that this is a finishing plant and does not have all



of the problems of stream pollution control associated



with an integrated steel plant such as we operate here



in Detroit.)  My point is this, our Midwest Steel plant



demonstrates National Steel Corporation's willingness to



meet current stream pollution control requirements in new



construction.  This always has been and will continue to



be the attitude of National Steel - to design new con-
          /


struction to meet the needs of the day.  The standards



on stream pollution control requirements are changing



at an accelerated pace to meet the alleged needs of the



day.  It is not reasonable to expect industry to be con-



stantly rebuilding and replacing stream pollution con-



trol equipment to meet these constantly changing standards.



It is our belief, that unless some real damage can be



related to a specific effluent, which was equipped with




control facilities acceptable  at the time  of  installation,

-------
                                                        1508



                  Fred E. Tucker




that these facilities should be accepted as adequate




throughout the useful life of the equipment.




             This is the problem faced by any industry




which must operate some older facilities in the fast




changing stream pollution control standards field.  As




recently as April 1965, we were under orders by the State




of Michigan to limit suspended solids to 85 ppm in our




effluents; in May 1965, just one month later, it was




recommended by the Federal Government that we reduce our




solids effluents to 35 ppm; in April one company was under




State orders to limit phenols to 600 Ibs/day and in May the




Federal Government recommended a limit of 20 ppb or 66 Ibs/




day; we went along for years with no established limits




on ammonia-nitrogen and are suddenly informed that this




constituent must be limited to 2.0 ppm.  My point, gentle-




men, is this, we are not opposed to progress or the develop-




ment of new limits based on new knowledge; we are con-




cerned, however, when these limits are applied to certain



existing control facilities.




             Through the years, Great Lakes Steel Cor-




poration has, in good faith, installed stream pollution con-




trol equipment to meet requirements of the State of Michigan.




These requirements are as restrictive and well enforced as




any we have encountered throughout the country.   If the

-------
                                                        1509




                  Fred E. Tucker




conferees at this conference accept the newly recommended




Federal effluent standards across the board, virtually




all of this equipment will immediately become obsolete




and unacceptable.  We propose to the conferees, therefore,




that they consider what might be called a "useful life" con-




cept in the adoption of standards.  That is to say that all




existing equipment, installed by approval of the State of




Michigan Water Resources Commission and operated to meet




Orders of Determination of that Commission, be permitted




to operate throughout the useful life of that equipment.




As this equipment is replaced or materially modified, or




as new installations are made for stream pollution con-




trol, that new standards which may be recommended by the




conferees could then constitute the new Orders of Deter-




mination of the Commission.  It is our contention that the




effluent standards recommended by the Public Health Ser-




vice in the Detroit River Report, for the most part, are




presently unattainable and not suitable for this purpose.




             Perhaps I should go through these effluent




standards as recommended for industry and municipalities




in the "Summary, Conclusions and Recommendations" of the




Public Health Service report.  They are as follows:




             Suspended Solids           35 ppm




             Settleable Solids           5 ppm

-------
                                                      1510



                  Fred E. Tucker




             Phenol                20 ppb




             Oil                   15 ppm




             Ammonia                2 ppm




             Iron                  17 ppm




             BOD                   20 ppm




             pH                    5.5 - 10.6



             The recommended Public Health Service




standards for suspended and settleable solids are to my




knowledge the lowest ever recommended for a major water-




course such as the Detroit River.  They cannot be met with




any control equipment available to industry at this time.




             MR. STEIN:  Mr. Tucker, pardon me.  Where




did you get that 17 for iron?




             MR. TUCKER:  I believe it is in the Summary,




is it not?




             MR. STEIN:  I didn't see it, and I checked




with Mr. Poston.




             MR. TUCKER:  I understood it was.




             MR. STEIN:  All right.




             MR. TUCKER:  If I am wrong there, we will



correct it.




             MR. STEIN:  Let's proceed on that assumption.




All right, thank you.




             MR. TUCKER:  For example we recently rebuilt



our Blast Furnace clarifiers to provide the finest equip-

-------
                                                      1511
                   Fred E.  Tucker
merit  available  at  this time  for solids  removal.   Twenty-
four  hour  composite  samples  from this improved effluent
ranged  from  42  to  86 ppm with  an average  of  60 ppm  sus-
pended  solids.   Settleable solids ranged  from 16  ppm  to
38 ppm  with  an  average of  36.5 ppm.  These numbers  repre-
sent  good  operation  of the finest equipment  available to
industry at  this time  and  yet  this effluent  comes no where
near  meeting the standards recommended  by the Public Health
Service.   We recommend therefore careful  consideration of
these standards in light of  existing control equipment
capabilities.
              The recommended Public Health Service  standard
of 20 parts  per billion of phenol  would limit our entire
Blast Furnace-Coke Plant Division  on Zug  Island to  an
effluent containing  onlv 15  ibs.  of penol per day.  At
the two coke plants  operated by National  Steel Corporation;
one located  in  Weirton, West Virginia,  and the other here
in River Rouge,  we operate the  only two known methods of
phenol  removal  available at  this time.  These are the
Podbielniak  phenol extractor at Weirton,  West Virginia,
and the Wilputte dephenolizing process  at River Rouge.
As noted in  the  Federal report,  Great Lakes  Steel had a
daily loading of 370 Ibs.  of phenol per day  to the  Detroit
River.   We believe that such a loading, using the best

-------
                                                       1512



                       Fred E. Tucker




available control equipment, Is reasonable, and that no




damage to legitimate water use results from this effluent.




For the conferees to accept the 20 ppb standard recommended




by the Public Health Service would in effect be for them




to say that no coke plants can be operated on the Detroit




River.  I am sure that this is not the intention of the




conferees or the Public Health Service.  We recommend




careful consideration of this standard in light of existing




control equipment capabilities.




            We have no disagreement with the recommended




15 ppm standard on oil.  It is a restrictive standard,




but one which is considered necessary by the State of




Michigan to protect migratory birds on the Detroit River.




Such a standard can be met with available equipment and is



for the most part being met by operations at Great Lakes




Steel Corporation.  All oil-bearing wastes are being




treated at Great Lakes Steel prior to discharge to the




Detroit River.




            We believe establishment of a limit on




ammonia is premature at this time.  I cannot speak for  other




industries, but we in the steel industry were not aware of




ammonia as a possible pollutant until March of this year.




We do not know the extent of our ammonia discharges,




damage if any to the receiving waters, or methods of

-------
                                                      1513
                  Fred E. Tucker
control.  It is our suggestion that the conferees under-
take a study of ammonia-nitrogen to determine the extent
of the problem and practical means of control prior to
acceptance of a standard.
             We have no disagreement with the recommended
standards for iron or pH and will outline later in this
statement Great Lakes Steel's progress toward elimination
of this problem.
             Although the Public Health Service report
gives casual recognition to waste treatment controls in-
stalled by industry to treat waste waters entering the
Detroit River, emphasis is placed time and again on the
point that water quality is deteriorating due to additional
loadings by industrial wastes.
             Quoting from the summary and conclusions on
page 1, paragraph 1;
             "Pollution of the Detroit River will become
progressively worse unless effective action is taken
immediately."
and again on page 3, paragraph 2;
             "While there is some evidence that water
quality is improving, because of increased water uses
damages are increasing, and unless remedial action is
taken immediately the usefulness of  the water  resources

-------
                                                       1514




                   Fred  E.  Tucker




 of the  Detroit  area may be destroyed  completely by




 pollution."




 and again  on  page  5, paragraph  7)



              "Reports of these  investigations  show the




 progressive deterioration  of  the Detroit River water




 quality from  headwaters to mouth due  to municipal  and




 industrial waste discharges."



              These repeated references would certainly




 lead one to believe that all  industry cited in the  report




 has been systematically increasing their waste loadings




 to the  Detroit  River.   However, we find on page 6,  para-




 graph 1, the  following  statement;




              "Comparison of waste loadings discharged to




 the Detroit River  during the 19^8 IJC survey and the 1963




 Public  Health Service survey reveals  over 50$  reduction




 in phenols, cyanide, oil and  suspended solids  from  in-




 dustrial sources during the 15-year period."




              This  factual  data  contradicts the  earlier




 suppositions  of alleged increased industrial pollution




 and shows that progress is  being made in control of in-




 dustrial wastes.   This  50$  reduction  in loadings has




 occurred while  industry, at least Great Lakes  Steel




 Corporation,  has been rapidly expanding production  in




the Detroit area.

-------
                                                         1515



                  Fred E. Tucker




             Waste loadings at our Great Lakes plant




have been reduced markedly over the past 10 years.  A




comparison of waste loadings  (Slide 1), from the Great




Lakes Steel Corporation, using data reported by the




Public Health Service in 1955 and 1963 and our own




company data collected in April 1965,shows a sharp re-




duction in loadings for a number of industrial waste




products.  During this period, steel production increased




at the Great Lakes plant by 8l$.  Waste loadings to the




Detroit River by Great Lakes Steel have been significantly




reduced and will continue to be reduced as we will point




out more specifically later in this statement.




             I would now like to cover in some detail all




of the outfalls from Great Lakes Steel Corporation which




enter the Detroit River.  This section of our statement




will describe all treatment facilities installed and




operating at Great Lakes and will place special em-




phasis on improvements in treatment practices which




have been made since May and July 19&3 when the survey




of industrial effluents was conducted for this conference.




                  Blast Furnaces




             Great Lakes Steel Corporation operates four




blast furnaces at Zug Island in River Rouge indentified as




A, B, C and D furnaces (Slide 2).  Gas from these furnaces

-------
                                                       1516



                  Fred E. Tucker



carries quantities of dust, consisting principally of




coke, limestone, ore, sinter, and pellet particles.



These particles must be removed before the gas is



suitable for use as fuel, to prevent air pollution and



fouling of gas lines and combustion equipment.  Cleaning




is accomplished by a three-stage system (Slide 3) con-



sisting of a dry dust catcher to trap the large particles,



wet scrubbers and wet electrostatic precipitators to



capture smaller particles.  The dirty water from the



scrubbers and wet precipitators is pumped to two 80 foot



clarifiers (Slide 4) where it is cleaned prior to dis-



charge through No. 5 sewer.



             Data collected during the July 1963 survey



shows 33*550 pounds per day of suspended and settleable



solids going to the river from these clarifiers.



             At the time of the 1963 survey, a major



change was beginning to unfold in blast furnace practice



at Great Lakes Steel.  Due to increased hot metal require-



ments, pellets were being included in the blast furnace



burdens to replace ore and sinter.  Pellets are dense



spherical agglomerates produced from iron ore concentrates



which are indurated (fired) to give surfaces which resist



abrasion.  Their addition to the burden increases pig




iron production  at the blast  furnaces.  They  also  re-

-------
                                                       1517
                  Fred E. Tucker
suit in marked changes In the amount and particle size
of blast furnace dust.
             In 1961 during a test run of pellets on "B"
blast furnace at Great Lakes Steel, it was determined that
a 50 per cent pellet burden reduced dust production from
105 Ibs. per ton of pig iron to 45 Ibs. per ton of pig
iron or 57$.  There was also, of course, an increase in
pig iron production which amounted to 100 tons per day
partially offsetting the reduction in dust loading.  The
particle size of the dust is reduced resulting in a larger
percentage of the dust being carried to the clarifiers.
Today the four blast furnaces at Zug Island are using
approximately 60$ pellets in the burden.  (It is expected
that pellets will constitute a larger percentage of the
burden in the future.)
             To treat the finer particle size dust in the
gas washer water, the clarifiers at Zug Island were com-
pletely rebuilt in 1964.  With the approval of the Michigan
Water Resources Commission, they were converted from a two
compartment design with top and bottom rakes to a single
compartment design with a bottom rake only.  This, plus
other changes, has resulted in a reduction in total solids
to the river to 9,900 Ibs/day, 6,600 Ibs of which are
settleable after one hour.  This improvement over the

-------
                                                      1518




                  Fred E. Tucker



33,500 Ibs/day reported in 1963 meets requirements of



the November 1951 Order of Determination of the Michigan



Water Resources Commission.  These units are currently



operating at a collection efficiency of better than




98 per cent.



             Coke Plant



             Great Lakes Steel Corporation operates two



coke plants on Zug Island.  Two batteries of 146 ovens con-



stitute the older No. 1 plant and two batteries of 148



ovens are located at No. 2 coke plant.



             Coke plant effluents at Zug Island are con-



fined to two sewers.  No. 1 coke plant effluents are re-



leased through No. 4 outfall and No. 2 coke plant effluents



are released through No. 8 outfall.  These outfalls are the



two principal sources of phenol at Zug Island, while No.



5 outfall from the blast furnace clarifiers contributes a



smaller amount of phenol.



             A general rule of thumb for phenol pro-



duction from coke plants is that approximately 0.5 Ibs.



of phenol is produced per ton of coal coked.  The Great



Lakes Steel Corporation coke plants use approximately



7,200 tons of coal per day.  The Public Health Service




report lists a loading of 370 Ibs. of phenol per day from




our total operation at Zug Island.  Based on this data,

-------
                                                       1519






                  Fred E. Tucker




the efficiency of phenol removal at Zug  Island is approxi-




mately 90 per cent.  Such an efficiency  represents a high




degree of treatment for coke plant and blast furnace




operations  in the steel industry.




             Control of phenol at Zug Island consists of




treatment and containment of phenol bearing liquids.




Ammonia liquor, which contains the highest concentration




of phenol at the coke plant, is treated  in a Wilputte




dephenolizing tower shown in this slide  (Slide No. 5).




Phenol is removed by a caustic solution  to produce sodium




phenolate which is marketed commercially.  All remaining




phenol bearing waste liquids are contained in a closed




system and  distributed to the four coke  quenching stations




at Zug Island.  These solutions are then used to quench




incandescent coke, thus preventing these wastes from




entering the Detroit River.  A small portion of the phenol




is retained on the coke and eventually finds its way to




the blast furnace clarifiers resulting in a small phenol




loading at  the No. 5 outfall.



             Phenol treatment practices  at our Great Lakes




Steel Corporation Coke Plant-Blast Furnace operations




provide the best control available to the steel industry




at this time.  Following the 1963 Public Health Service




survey, a comprehensive study of phenol  treatment practices

-------
                                                      1520
                  Fred E. Tucker
was undertaken by Great Lakes Steel Corporation.  It was
concluded that although treatment practices were optimum
for this operation, improved housekeeping, maintenance
and surveilance were desirable to prevent accidental
discharges of phenol bearing wastes.  To this end a waste
control task force was appointed at Zug Island, made up
of operating, maintenance and laboratory personnel.  This
task force was assigned responsibility to maintain two-
hour surveilance of all outfalls, inspection of all
possible sources of accidental spills, and recommendations
for improved maintenance and operation of all waste treat-
ment facilities.  This action has resulted in more con-
sistent and reliable operation of treatment facilities
and a marked reduction in the occurrence of accidental
discharges of all wastes originating on Zug Island.
             It is our conviction that phenolic effluents
from the Great Lakes Steel Corporation Coke Plant and
Blast Furnace operations, under present treatment practices,
do not interfere with the beneficial uses of the waters
of the Detroit River.  All effluents meet requirements of
the November 1951 Order of Determination of the Michigan
Water Resources Commission.
             80" Mill
             The 80" hot strip mill (Slide 6) in River
Rouge was placed in operation on August 31, 1961.  It

-------
                                                         1521

                  Fred E. Tucker

was the first modern 80" mill  designed to  roll 1,000 Ib

per inch  of width constructed  by'  the  steel  industry.

             In  the design  of  this new mill,  (Slide 7) a

consulting firm  specializing in industrial  waste control

was hired to assist in the  design of  waste  treatment

facilities and our own engineers  drew upon  their own ex-

tensive experience in high  speed  steel strip  production.

An Order  of Determination adopted by  the State of Michigan

Water  Resources  Commission  on  June 25, 1959 described con-

ditions of effluent water quality to  be met by this new

mill.  On September 3, 1959> detailed drawings were sub-

mitted to the State describing treatment facilities to be

installed by Great Lakes Steel on the 80" mill.  These

plans  were approved by the  Michigan Water Resources Com-

mission by letter in September, 1959-  The  letter reads

as follows:

             "It is our opinion that  your proposal offers

reasonable promise of being capable of reducing the oil

and solids content in your  waste  discharges to accept-

able limits and  the plans are  approved."

             We  shared the  opinion of the Michigan Water

Resources Commission and proceeded to construct this

rather impressive facility.  The  following  slide shows its
                                                        »
extensiveness.

-------
                                                       1522

                  Fred E. Tucker

             The overall size of this scale and oil re-

moval plant (Slide 8) is 442 feet by 41-1/2 feet covering

a ground area of 18,343 square feet.  It was designed to

handle a waste water flow of 46 million gallons per day.

During the July 1963 survey by the State, the flow was

measured at 42.13 m.g.d.  The waste water first enters

a scale pit (Slide 9) which is 40 feet by 4l feet by 12

feet deep, providing a retention time of 3 to 4 minutes

where the very large particles of scale are removed; it then

flows to a primary sedimentation basin which is 59 feet 6

inches by 4l feet by 12 feet deep providing a retention

time of 5 to 7 minutes, where additional large particles

are settled prior to pumping ti> the (Slide 10) secondary

sedimentation basins.  There are four secondary sedi-

mentation basins, each basin sized at 151 feet by 20

feet 9 inches by 12 feet 6 inches deep, providing a re-

tention time of 25 to 30 minutes for settling (Slide 11)

of fine scale particles and oil flotation and skimming.

             Scale is removed daily from the scale pit

and primary sedimentation basin by clamshell (Slide 12).

Fines are removed by a yard crane from the secondary

basins as required.  Approximately 8,000 tons of scale

are removed per month and transported to the sintering
    0
plant.  The 1963 survey of these outfalls by the State

-------
                                                       1523




                  Fred E. Tucker




of Michigan showed wide variations in solids concen-




trations.  During two separate sampling periods, suspended




solids varied from 31 ppm to 86 ppm.  This averaged 59 ppm




suspended solids to the river.




             Based on our scale recovery data averaging 270




tons per day scale removal and the loading to the river re-




ported by the Public Health Service, this scale recovery




system operates at an efficiency of 93-^ per cent.  This




facility, installed with the approval of the Michigan




Water Resources Commission in 1959 and placed in operation




in August 1961, was the finest Hot Strip Mill scale re-




moval system every installed by any major steel company.




However, today, it does not meet the new effluent stand-




ards recommended by the Public Health Service.  In fact,




today there is no equipment available to meet these




standards.



             Oil is skimmed from the secondary basins at




a rate of 700 to 800 gallons per month.   The 1963 State




survey showed an oil loss of less than 15 ppm to the




river.  This meets State requirements, IJC objectives and



Public Health Service criteria.  Oil is removed by tank truck




to the Ecorse plant where it is dewatered and used as open




hearth fuel.




             Although  this  facility was installed in 1961

-------
                                                        1524




                  Fred E. Tucker




 according  to the best available engineering know-how,




 was  approved by the State of Michigan, and operates at  a




 high rate  of efficiency, we recognize that a small amount




 of fine particulate matter imparts a color to the Detroit




 River for  a short distance from our outfall.  Although  we




 do not believe this color interferes with any beneficial




 use  of the Detroit River, we have conducted a number of




 research test programs in an effort to develop means to




 improve this outfall.  These investigations have pro-




 duced no ready solution to this problem, and we are




 considering a new series of tests to determine the feasibility




 of high rate filtration.  The fine particles which cause




 the  color  at the river are produced at the finishing stands




 on this mill.




             Ecorse Plant - Great Lakes Steel




             Hot metal produced at the Zug Island Blast




 Furnace Division of Great Lakes Steel is shipped by rail




 to the Ecorse plant where, in combination with scrap, it



 is refined to produce finished steel products.  The Ecorse




 plant consists of open hearths, basic oxygen furnaces,




 blooming and slabbing mills, a hot strip mill, bar mills,




 continuous picklers, cold rolling mills, and annealing




 facilities.  All of these facilities may require water  for




cooling,  scale removal,  or chemical dilutions.  Some of

-------
                                                        1525



                  Fred E. Tucker




this water is contaminated in the steelmaking and




finishing processes and must be treated prior to dis-




charge to the Detroit River.  All of the process water at




Ecorse, which may be contaminated with oils, greases, or




solids in the steel-making and finishing process is treated




prior to discharge.  This amounts to approximately 105




million gallons per day which is approximately 90 per




cent of the total water used at the Ecorse plant.  The




remaining 10 per cent is cooling water and waste pickle




liquor.  Sanitary wastes are handled in separate sewers




and delivered to the city sewage system.  I will discuss




briefly each of the six outfalls at Ecorse which handle




process water and the treatment applied to this water




prior to discharge to the Detroit River.




             Outfall No. 2




             This is a 60" sewer handling a flow of approxi-




mately 6 m.g.d.  This sewer in 1963 received water from 7




skin mills and the three 3-stand tandem mills.  Since 1963




we have eliminated operation of two skin mills and during




construction of a new 5-stand tandem mill have diverted all



tandem mill waste water to No. 3 outfall.  Following the




1963 Public Health Service survey, it was found that




waste acid was leaking through a broken sewer into No0 1




oil basin causing a low pH and high iron level in the No.

-------
                                                       1526




                  Fred E. Tucker




2 outfall.  This has been corrected by locating a new




waste pickle liquor outfall north of No. 2 oil basin.




The result of these changes is that since the 1963 sur-




vey, we have materially improved the quality of effluent




at No. 2 outfall.  Changes have also been made in pickling




practice resulting in improvements in waste pickle acid




loadings.  These changes will be discussed later in this




statement.



             The treatment facility at this outfall was




installed in December 1955.  (Slide 14)  This installation




known as No. 1 settling basin is 240 feet long, 4o feet




wide and 20 feet deep.  Oil is skimmed continually and




decanted from the basin every 24 hours.  Although this




is primarily an oil basin, scale and bottom slude are re-




moved as required and amounts to approximately 700 tons




per year.




             Outfall No. 3




             This is an 84" sewer handling a flow of




approximately 50 m.g.d.  This sewer in 1963 received




water from the 96" hot strip mill and some pickle line



rinse water.  As noted earlier, due to construction of a




new 5-stand tandem mill, No. 3 outfall is presently re-




ceiving water from the three 3-stand tandem mills.  During




1963, No. 2 settling basin, which serves No. 3 outfall,

-------
                                                        1527



                   Fred E.  Tucker




was  receiving waste  sulfuric  acid  from  a leak  in  the  acid




sewer  resulting in a low pH and high  iron values.  As




noted  earlier,  this  leak has  been  corrected and pH and  iron




values are now within acceptable limits.  The  addition  of




tandem mill water  to this  effluent has  not resulted in  any




reduction in  efficiency of oil and solids removal in  No.




2  settling basin over results reported  in 1963.




              The treatment facility (Slide 15) at this




outfall was installed in November  1956.  This  installation




known  as No.  2 settling basin is 5^0  feet long, 40 feet




wide and 20 feet deep.  Oil and solids  removal are handled




in the same manner as that reported for No. 1  basin.




Solids removal  amounts to  3*000 to 5>000 tons  per year.




A  primary scale pit  located at the 96"  hot strip mill




removes most  of the  heavy  scale produced by the mill  be-




fore this process  water is delivered  to No. 2  settling




basin.




              Outfall No. 4




              This  is a 72" sewer handling a flow of approxi-




mately 30 m.g.d.   As reported in the  1963 survey, this  out-



fall receives water  from the  No. 1 open hearth, 21" billet




mill,  40" blooming mill, and  the 10"  and 14" bar mills.




Primary scale pits are  located at  the blooming mill and




bar mills for heavy  scale  removal.

-------
                                                         1528




                  Fred E. Tucker




             The treatment facility at this outfall was in-




stalled in June 1957.  (Slide l6)  This installation known




as the No. 3 settling basin is 565 feet long, 40 feet wide




and 20 feet deep.  Oil and solids removal are handled in




the same manner as basins 1 and 2.  Solids removal amounts




to 2,000 tons per year.



             The three settling basins (Slide 13) described




above handle a total flow of 86 m.g.d.  For most plant




processes, they represent secondary treatment with primary




scale and oil removal taking place at each major process.




             On April 23, 1953, installation of these




three basins was approved by the Michigan Water Resources




Commission.  In their letter of approval, the Commission




wrote the following:




             "This proposal you have developed appears to




offer reasonable promise of being capable of reducing the




oil content of your discharges to acceptable limits.  It




represents the most practical and effective approach




to the problem that we can think of and because of the




physical limitations you must contend with, it overcomes



most of the disadvantages that would be found in other




methods that could be devised.  Approval of these plans




is therefore granted."




             In 1964,  these  basins  (Slide 18)  removed

-------
                                                        1529



                  Fred E. Tucker




4,000,000 Ib of  oil  from outfalls  2, 3, and 4 at Ecorse.




This oil is dewatered and used as  open hearth fuel.




(Slide 19)  We believe these  facilities to be adequate




for oil and scale removal on  these three  outfalls.  (Slide




20)  However, in our constant search for  improved methods




of oil removal,  in April 1965 we installed on a test basis




an automatic oil removal unit.   (Slide 21)  If proven




feasible, these  units will be installed on these basins to




provide continuous removal of oil,  thus eliminating the




possibility of accidental discharges to the Detroit River.




             This is a continuous  belt oil removal  system,




and the benefit  of this installation, of  course, is to




avoid the problem of having to manually decant oil  from the




basins.  This poses  a considerable problem for us and for




many other industries.  The oil  is continually removed on




the belt, drains from the little slot shown on the bottom.




             Of  course, this  is  a  small section that was




put in to check  the  installation of our plant.  Since this




report has been  written, we have purchased a number of these




units, 24-inch units.  They will be installed at our oil




basins in Ecorse.




             New 5-Stand Tandem  Gold Rolling Mill




             As  noted earlier in this statement, Great




Lakes Steel Corporation is committed to installation of

-------
                                                        1530



                  Fred E. Tucker




the finest available stream pollution control equipment on




new facilities.  During the third quarter of this year,




Great Lakes Steel will place in operation a new five-stand




tandem mill, the finest cold rolling mill installed to date




in the steel industry.  Waste water treatment facilities




installed with this mill will provide excellent treatment




for control of oil.  This mill will replace one 3-stand




tandem mill and two single-stand skin pass mills.  This




slide (Slide 22) shows this mill under construction at




our Ecorse plant.




             The primary stream pollution control benefit




derived from this mill is in its basic operating design.




Older design tandem mills used oil on a direct application




system.  Oil and water were applied to the rolls, used




once, and discharged to the sewer.  This new 5-stand mill




will be equipped with a recirculating oil system.  Oil in




solution will be recirculated through filters and used over




and over again on the mill.  At the end of its useful life,




the oil will be dumped to a holding tank, treated by an air




flotation process to float the oils to the surface, and




skimmed.  The oil will be centrifuged and reused at the




continuous picklers.  The clarified waste water will be




discharged to the No. 1 settling basin for further




clarification prior to discharge to the Detroit River.

-------
                                                       1531



                  Fred E. Tucker




             Removal of the oil at the mill will signi-




ficantly reduce oil loadings at the No. 1 settling basin




and thereby reduce the possibility of accidental oil




discharge to the river.




             This is another example of Great Lakes Steel




Corporation's willingness to provide the best available




stream pollution control equipment on new installations.




I mentioned earlier the excellent stream pollution con-




trol program built into our new Midwest Steel Division




the controls installed on the new five-stand tandem mill




at Great Lakes are even more advanced than those so highly




acclaimed at Midwest Steel, in addition, the new Great Lakes




tandem mill provides water conservation, in that water re-




quirements are much less on a recirculating tandem mill




than on a direct application mill of the same capacity.




             Outfall No. 11




             This is a 60" sewer handling a flow of approxi-




mately 10.8 m.g.d.  As reported in the 1963 survey, this




outfall receives water from the No. 3 slabbing mill.  A



primary scale pit is provided to collect heavy scale pro-



duced at this operation.  A secondary scale pit (Slide 23)




installed with the slabbing mill in 1953 and as shown in




the next slide, is 66 feet long, 16 feet wide and 36 feet




deep.  A water level of 9 feet is maintained at the skimmer.

-------
                                                      1532




                  Fred E. Tucker




This installation is covered by a Michigan Water Resources




Commission Order of Determination dated November 28, 1951.




At the time of installation of this facility, it was con-




sidered adequate for scale and oil removal at the No. 3




slabbing mill.  Since that time, however,  flows have in-




creased, and although considerable scale is being removed




(approximately 11,000 tons per month),  turbulence in the




basin makes oil skimming very difficult.




             Prior to receipt of the Federal report, we




were considering installation of an additional secondary




oil basin and settling pit at this location to reduce oil




concentrations below 15 ppm.  However,  the new criteria




for solids cannot be met by any conventional settling basin,




For this reason, we have shelved these  plans and are con-




sidering a study of high rate filtration similar to that




proposed for the 80" mill effluents.




             Acid Pickling Wastes




             During the industrial effluent sampling




period in May 1963, at which time data  was collected by




the Public Health Service for this conference report,



Great Lakes Steel was operating four horizontal con-




tinuous sulfuric acid picklers.  All of the waste acid




from these picklers was going to the Detroit River




following dilution with plant cooling water.  The acid

-------
                                                       1533



                     Fred E. Tucker




load amounted to approximately 158,000 Ibs. per day.  In




May of 1964, to reduce acid discharges and improve produc-




tion capabilities, Great Lakes Steel began pickling with




hydrochloric acid instead of sulfuric acid.  Due to the




rapid rate of reaction of HC1, nearly complete




utilization of the acid is possible and instead of re-




leasing waste sulfuric acid at a concentration of 8 to 10




per cent, we are now able to release a smaller amount of




waste hydrochloric acid and at a concentration of approxi-




mately 0.2 per cent.  This has reduced acid loadings to




the river to approximately 6,000 Ibs. per day versus the




158*000 Ibs. per day loading with sulfuric acid pickling --




a reduction of 152,000 Ibs. per day -- equal to 96.3 per cent,




            A process has been developed in Europe called




the Reuthner Hydrochloric Acid Recovery Process, to recover




hydrochloric acid and dry iron oxide from waste acid pro-



duced in the Reuthner Tower pickling process.  Although there




are a number of process changes necessary to be worked out




to apply this recovery process to the weak acids produced




in a horizontal continuous pickler, we are optimistic that




a similar roasting process will permit us to almost com-




pletely eliminate wastes of any kind from the steel pickling




process.

-------
                                                          1534


                  Fred E. Tucker



             Conclusions



             We believe that Great Lakes Steel Corporation,



in cooperation with the Michigan Water Resources Commission,



has shown a great deal of steady progress in the control



of stream pollution at its Zug Island, Hot Strip Mill and



Ecorse plants.  This progress over the past ten years has



resulted in significant reductions in waste loadings from



these plants even though steel production at these plants



has increased approximately 80 per cent during the same



period.  The United States Public Health Service Report



under review here today, states that water quality 'in the



Detroit River is deteriorating due in part to increased



industrial pollution.  This is not the case at Great Lakes



Steel and we believe the record should be corrected to show
          »


past, present, and future stream pollution control progress



at Great Lakes Steel through cooperative efforts with the



Michigan Water Resources Commission.



             The Public Health Service Report also recommends,



(and incidentally, to our knowledge for the first time in


any Federal conference), tailored industrial waste effluent



standards.  As we have pointed out earlier, these recommended



standards are in some cases unprecedented, unreasonable,



impractical and confiscatory.  Some are certainly unnecessary



to protect water uses on the Detroit River.   They also do

-------
                                                       1535



                   Fred E.  Tucker




not  recognize  those  companies  which  have  -  in  good  faith  -




invested millions  of dollars to install facilities  to




meet Orders  of Determination of the  State of Michigan.  We




recommend  to the conferees that these  installations be




given some degree  of recognition and not  be placed  in




immediate  violation  by a new set of  Federal standards,




many of which  are  presently unattainable.




             The Public Health Service Report  does  stress




the  importance of  maintaining  as near  as  possible 100 per




cent operation of  equipment installed  to  control waste




effluents.  The March 1962 Federal conference  pointed up




the  need to  maintain waste treatment facilities at  maxi-




mum  efficiency and performance.  To  this  end Great  Lakes




Steel Corporation  established  stream pollution control




task force groups  at each  plant to maintain a  visual in-




spection of  all facilities and effluents  every two  hours.




Where these  inspections indicate deficiencies  in equipment




or operations,  corrective  steps are  taken as soon as




possible.  These task force groups meet regularly to dis-




cuss stream  pollution control  and recommend improved



practices  which result in  reduction  in waste loadings




or water use.




             The steel industry is currently undergoing




widespread technological change.  Great Lakes  Steel

-------
                                                         1536




                  Fred E. Tucker




Corporation is in the forefront of this technological




progress and as changes in operating practice are made,




improved methods of waste treatment and water conser-




vation are being and will be established.  We urge the




conferees to recognize the progress that has and is




being made in industrial stream pollution control on




the Detroit River.   This conference and study report




have been beneficial to all in stressing the importance




of stream pollution control and pointing out deficiencies




in waste treatment  practices.   We appreciate the




opportunity to constructively comment on the Public




Health Service Report and relate in detail to the con-




ferees stream pollution control progress at the Great




Lakes Steel Corporation.




             Thank  you.

-------
                                                       1537
    TEN YEAR COMPARISON OF WASTE LOADS
Blasf Furnace Thickeners
   Suspended Solids
   Settleable Solids
   Iron
   Ammonia-Nitrogen
                       Waste Loadings In Pounds Per Day
                         1955
1963
1965
86,200
81,500
29,300
671
37,850
33,550
5,146
NAD*
9,898
6,605
NAD*
395
Ecorse Plant
   Suspended Solids      19,800      8,400
   Settleable Solids       11,800      6,800
   Oil                    8,400      8,100
   Iron                  43,700     49,000
   Acid                284,000    158,000
           NAD*
           NAD*
           8,100
          35,000
           6,000
                          NAD = No Analytical Data

-------
        SLIDE No. 2

General View of Blast Furnaces
Ln
CO
00

-------
                SLIDE No.  3

Dry Dust Catcher, Wet Scrubbers,  Precipitators
Co
MD

-------
SLIDE  No. 4

 Clarifiers
Ui
*>
O

-------
    SLIDE  No.  5
Dephenoli zing Towers

-------
  SLIDE No.  6

80"-Mill Interior
-P-
NJ

-------
  SLIDE No. 7
80"-Mill Exterior
                                                                                 U>

-------
           SLIDE No. 8
Scale and Oil  Removal Plant-80" Mill

-------
       SLIDE  No.  9
Primary Sedimentation Basin

-------
        SLIDE No.  10
Secondary Sedimentation Basins

-------
   SLIDE No.  11
Water After Settling

-------
SLIDE No.  12

Scale Removal
Ui
£-
00

-------
       SLIDE No.  13
Oil Skimmers on Detroit River

-------
SLIDE No.  14
No. 1 Skimmer

-------
SLIDE No.  15
No. 2 Skimmer

-------
L
                         —    ;    -~ .  •»£>*
                                                         SLIDE No.  16
                                                         No. 3 Skimmer
ro

-------
 SLIDE No.  17
Skimmer Closeup

-------
  SLIDE No. 18

Water Comparison
M
Ui
Ln

-------
SLIDE  No. 19

Skimmer Outlet
Ln
Ln
Ln

-------
SLIDE No.  20
 Skimmer Belt

-------
    SLIDE No.  21
Skimmer Belt Operotion

-------
 SLIDE No. 22

5 — Stand Tandem
                                                                               Ul
                                                                               Ln
                                                                               00

-------
                                                  1559
    SLIDE  No.  23




No. 3 Slab Mill Scale Pit

-------
                                                     1560
                 Fred  E.  Tucker

             MR.  STEIN:   Thank you,  Mr.  Tucker.

 I shall see what we can  do about  getting your pictures

 reproduced  In the record.

             MR.  TUCKER:  All  right.

             MR.  STEIN:   We are getting  quite  a  few,  and

 depending on the cost; If  we  cannot swing this  cost,  there

 will be a notation made  where they  are  available  on  file,

 but I shall do my best to  see that  they are reproduced.

             Are  there any  comments  or questions?

             MR.  POSTON:    I think Mr. Tucker  is to be

 commended here for the detailed report.   I had  a  couple

of questions; one, particularly, about your treatment

 work at the 80-inch strip  mill.

             MR.  TUCKER:    Yes.

             MR.  STEIN:   Which you  have  constructed  over

 a period from about 1959 to 1961?

             MR.  TUCKER:    I believe that is correct.

             MR.  STEIN:     About two and  a half  or three

 years.

             MR.  TUCKER:  Right.

             MR.  POSTON:  Is that  a  pretty usual time?

             MR.  TUCKER:  This is  not limited  to the

 treatment plant, itself.   This apparently was  the tlire

 necessary for the construction of the facility  and I

-------
                                                     1561



                   E. Tucker



believe the first date Indicates the date at which



we went to the State, which would be in the planning



stage.



            MR. POSTON:    I see.



            MR. TUCKER:   We do not approve any plans



until they have been reviewed by the State of Michigan.



            MR. POSTON: It could be quicker than that



then, is what you are saying?



            MR. TUCKER:  On the installation of the



treatment facilities certainly could have been quicker



and was.   This was a matter of approving the plans,



design, and construction of the mill.    We try to get



these things done as much in advance as possible, par-



ticularly those portions of the plant which must be



approved.



            Another thing, you talked of surveillance



or checking every two hours on the waste load to the



stream visually.    I wonder, do you do analytical work,



sampling at regular intervals?



            MR. TUCKER:    We do not have any, what you



might call routine sampling program of all of our



effluents.    Where we feel we have a problem that



necessitates sampling to determine the source of the



problem or the magnitude of the problem, we do institute

-------
                                                      1562
                 Fred E. Tucker
a sampling program.  But this Is not a routine sampling
program for all of our outfalls.
            MR. BOSTON:   You do have facilities that
from time to time can make analytical determinations of
things like ammonia?
            MR. TUCKER:   Oh, yes; all of these samples
that were taken, In your 1963 report, were split with
Great Lakes Steel, and we did exactly the same
analysis that you did.
            MR. STEIN:  Did it come out the same way?
            MR. TUCKER:  We didn't complain (Laughter).
            MR. POSTON:     I think that is all I have.
            MR. STEIN: This is an excellent report, as
we always get from your company, Mr. Tucker,
            There Is one question that I have, and this
is a fundamental one, and I wonder if we can get to
this, and this is whether the requirements—I don't know
whether I would call them standards, but I think we are
talking about the same things—the requirements recommend-
ed in the Federal report are attainable?
            Now, I wonder if it would be helpful, Mr.
Oeming—we have Mr. Hayee Black here—if we could possibly
hear his Judgment on that, and try to arrive at a
conclusion after a brief comment.

-------
                                                      1563
               Fayed E. Tucker
            MR. OEMING: All right.
            MR. STEIN:   Mr. Black, you have heard this
report. Do you think we could have your comment briefly
on whether these requirements In the Federal report are
attainable; and then we will let Mr. Tucker respond
to whatever you may want to report.

-------
                                                      1564
                 Hayse H. Black
             STATEMENT OP HAYSE H. BLACK,

         INDUSTRIAL WASTE CONSULTANT FOR

           THE PUBLIC HEALTH SERVICE


            MR. BLACK:   I am Hayse Black, Industrial

Waste Consultant for the Public Health Service.

            I, too, have enjoyed listening to this

report.   At one time I was quite familiar with the

operations at this plant.

            Mr. Chairman, may I preface response to your

request with a brief statement here?   We are confronted

with an attempt to use some values which will help us

protect the receiving waters.   We have been talking about

effluent ^standards, and it is pretty difficult to divorce

them from stream standards.

            Some fifteen years ago, the International

Joint Commission set up some objectives based on what

this group thought, and I refer to a technical advisory

board—what this board thought was necessary in the

streams, and they suggested taking samples after initial

dilution,  which meant some distance below the outfall.

            The findings in this report have gone a little

further and attempted to translate some of those objec-

tives into effluent criteria.

-------
                                                        1565
                        H. H. Black
            These values that have been recommended would
have to be used with engineering Judgment.  We are not
told here where these samples will be taken, except they
are referred to as effluent requirements.
            The statement in the report is rather clear
in that it says these are not attainable.  Having just
received this report, I haven't been able to make com-
putations, as the author of the report has.  Admittedly,
20 parts per billion phenol is pretty severe.  The place
where you take your sample, however, that, presumably,
would be the effluent of the outfall to the river from
this part of their plant, and if it develops that this
value is too low for the dilution in this outfall for
them to meet with all known methods of phenol recovery,
we will just have to accept it.
            On the other hand, that doesn't mean that
this can be applied to other sources of phenol.  That's
where I would like to point out that these values must be
used with some engineering judgment.  If we will have to go
back to do a Job, we must go back to the process that we are
using -- in this instance we are talking about phenol, the
dephenolization processes that are used at Great Lakes
Steel, benzol extraction, to be specific.  At one time they
were using this effluent from their benzol extraction to
quench  coke.   I  think you  said  they were  still  doing  that.

-------
                                                      1566
                    H.  H.  Black
             MR.  TUCKER:   That's right.
             MR.  BLACK: Which is taking two methods here
 to reduce  phenol,  which is  commendable.
             Now, if they  are  using two  methods to reduce
 phenol and you still can't  meet this  20 parts per
 billion, then  I would  hope  that our control agencies
 would take cognizance  of  what they have done in this in-
 stance and act -accordingly.
             Now, I haven't  given you  a  firm answer as
 to whether these are attainable or not, and I don't think
 anyone else can, without  making some  computations.
             I  would hope  that these comments might
 apply to some  of your  future  participants  here, because
 this question  may come up again.   What we are confronted
w ith here  is an attempt to  translate  stream criteria
 back to effluent criteria,  and values have been used
 that would apply pretty much  across the board, and that
is not easy.    This means that  each case will have to
 be considered  individually, and certainly  we can expect,
if these are recommended,  these values to serve as, shall
 we say, a  goal—the word  "objective"  has been used; most
cf us don't care for the word  "standard"—it means the
same thing, but I would hope that in our effort now to use
 these criteria,  that we bring into the  picture in every

-------
                                                       1567
                  H. H. Black

 case the dilution that is afforded in the outfall,

along with the facilities that have been provided, and, as

 has been pointed out admirably here, with some of the

 best known facilities at this time, and they are still

 trying to improve.

             But to give you a dogmatic answer as to the

 feasibility of complying with these effluent criteria

 is more than I would care to give in a dogmatic answer.

             MR. STEIN:  Mr. Oeming, do you have a

 question?

             MR. OEMING:   I pass.

             MR. STEIN:  Mr. Tucker?

             MR. TUCKER:  I would like to comment, first,

 to the effect that Mr. Black is an individual whom I have

 admired for quite some time as being one of the most

 knowledgeable people and one of the most knowledgeable

 control officials in the iron and steel industry of anyone

 I know.

             I think he has made some good points here,

and I am sure that any standards—and we assume that these

 numbers would be used as standards, and I realize that

 an assumption is a dangerous thing to do—would be

 applied to our outfalls at Great Lakes Steel.

             He mentioned the sampling location and the

-------
                                                      1568
                 H. H. Black

advantage  that you canttake of dilution, and I have often

heard you, Mr. Stein, comment on dilution very

emphatically.

            Some companies have the advantage of a small

number of  outfalls.  We operate one steel plant that has

four outfalls.   We can take advantage of dilution where

we run into numbers of this type.   At Great Lakes Steel,

we operate, I believe, 26 outfalls, and in most cases

each outfall serves an individual facility, and here we

must take  the full brunt of contamination, if we shall

call it that, and we get very little benefit of dilution.

            When we design a new facility also and go

to the control officials for approval, we must get

approval on the basis of the effluent from that

particular control facility, and not necessarily from

the effluent going directly into the river.

            So, I appreciate the comments that Hayse has

made.   I  agree with them, and I think if these numbers

are used as objectives and used with discretion, with

consideration for the particular features of a particular

plant, that they might be applicable.

            MR. STEIN: Thank you, Mr. Tucker.   I know

you do not speak for the whole steel industry, but I hope

the whole  steel industry feels that way about Mr. Black,

his comments, possibly here, in Chicago, and on the Mahoning.

-------
                                                     1569
                 H. H. Black
            Are there any further questions at this
time?
            MR. BOSTON:     No, I think not.
            MR. STEIN:    Thank you very much, Mr.
Tucker.
            MR. OEMING:   Mr. Chairman, at tH. s time I
would like to provide the opportunity for a statement
by the McLouth Steel Corporation.    I believe Mr.
Robert McLaughlin is here to present a statement.

-------
                                                      1570




                     Robert C. McLaughlin









              STATEMENT OP ROBERT C. McLAUGHLIN,




      VICE PRESIDENT, PUBLIC RELATIONS AND PUBLIC AFFAIRS,




                  McLOUTH STEEL CORPORATION









            MR. MC LAUGHLIN:  My name is Robert C.




McLaughlin.  I am vice-president, public relations




and public affairs, of the McLouth Steel Corporation.




That immediately tells you I am not an engineer, but




I did not write the portions of this report that have




to do with scientific facts and findings.  I was




thinking to myself, while I was seated there listening




to this wonderful report from Great Lakes, "If I ever




lose these notes I am really a cooked goose."  But




inasmuch as we are not quite as well known perhaps




as our big and older brother and respected competitor




at Great Lakes, I think a brief history of McLouth




Steel Corporation may be in order.




            We were organized under the laws of Michigan




in 193^.  McLouth Steel Corporation is engaged in the




production and finishing of flat rolled carbon and




stainless steel.  The corporation is a major producer




of such products in the Detroit area, with a capacity to




produce 2^530,000 net tons of steel ingots annually.

-------
                                                      1571
                   Robert C.  McLaughlin

 Its three plants are located at Detroit,  Trenton,  and

 Gibraltar,  Michigan; and its principal business offices

 are located at 300 South Livernois Avenue,  Detroit,

 Michigan, 48217.

             Until 19^8,  the  Corporation conducted  a  rela-

 tively minor steel conversion business at its Detroit

plant.

             During 19^8, as  an initial step toward inte-

grating its operations,  the Corporation began the con-

struction of its Trenton plant to house its  first primary

 steelmaking facilities  consisting of four electric

 furnaces with a rated annual capacity of  about 500,000

 net tons of steel ingots,  and hot rolling facilities.

 The year 1951 was the first  year that saw this operation

 go into production.

             Between 1953 and 1955* the Corporation under-

 took a large expansion  program which more than tripled

 its steelmaking capacity.    The bulk of this expansion

 occurred at the Trenton plant.   It included an ore  dock,

 two ore bridges, a blast furnace, a new type oxygen

 process steelmaking plant  with three Vessels—which,

 incidentally, was the first  plant of its  kind in the U. S.—

 two additional electric furnaces, a slab  heat furnace,

 a  roughing mill, a continuous hot rolling mill, and

-------
                                                      1572
                  Robert G.  McLaughlln
 auxiliary finishing equipment.  At the same time,  the
 Corporation constructed a new plant at Gibraltar to house
a four-stand tandem cold reducing mill.  This facility
 was first operated in 1955.     Other major equipment
at Gibraltar now includes annealing furnaces, two  temper
rolling mills,  and the necessary finishing equipment—
 which was added from time to  time, a hydrochloric acid
 pickling line—first operated In 19^3.
             During 1957 the Corporation undertook a
 second major expansion program  which included a second
 blast furnace,  a sintering  plant,  additional oxygen process
 steelmaking equipment, and  an ore  dock extension.    Most
 of this expansion program also  occurred at our Trenton
 plant.
             The Corporation does not operate coke ovens.
 Coke for use in the blast furnace  is purchased from
outside sources.
             For a brief description—and this will be
 brief—of waste treatment facilities at the Trenton Plant:
             The Trenton plaflt's combined total contamin-
 ated water presently averaging  18,500 gpm flows to a
 waste treatment plant located at the southeast corner of
the property.
             The water first passes through a series of

-------
                                                      1573
               Robert C. McLaughlin


three trash screens and three grit chambers which are


operated in parallel.   The grit chambers have mechanical


scrapers and oil skimmers.


            Effluent from the grit chambers passes to


two parallel mixing chambers which are equipped with


underflow arid overflow baffles.   Pre-neutralized waste


sulfuric acid pickle liquor is introduced in this


section.   Four mechanical mixers and an air blower


provide aeration and disperse the sludge into the total


water flow.


            The water flow is then split to pass to the


center well of three final clarifiers.  A coagulant aid


is added at these wells at the rate of 0.6 ppm to aid


the settling of solids.  Tanks are provided with oil


skimmers, sna trhe 
-------
                                                      1574
              Robert C. McLaughlin
of soluble oil wastes are directed to a large holding
pond which has sufficient holding time to allow the oil
emulsion to break and the oil rises to the top where it
is skimmed off.   Effluent from this pond passes to a
second settling pond and then to a skimming pond to
recover any remaining oil.
            The second sewer system collects all other
contaminated waste in either of two primary holding
ponds.    Each pond has an 84-hour holding capacity.
Caustic soda is added to control pH as directed by
an automatic PH control system.    The holding ponds
have sufficient capacity to protect against hydrochloric
acid contamination which can result from pipe breakage
or other accidents.
            Overflow from the primary pond enters a
secondary settling pond which empties to the skimmer pond
before entering Prank and Poet Drain.
            Mr. Chairman, I would like to call attention to-
and I won't take time to review it here—page number 6
of this report, which contains detailed descriptions of
our water clarification installations and the  time
when they were installed.
            MR. STEIN: That will be included in the record
as if read.

-------
                                                       1575
                Robert C. Mclaughlin

            MR. MC IAUGHLIN:  Thank you, sir.  I would

like to say that this equipment described in detail

represents a capital investment of several million

dollars plus costly maintenance and operating expenses.


GENERAL COMMENTS;

            We believe that the limits on the operation

of the Corporation's water clarification system as pre-

scribed by the Michigan Water Resources Commission are

as stringent as it is possible to meet today.  With

considerable effort and the expenditure of large sums

of money we have been able to substantially meet those

limits.      Further improvements can be made only

as adequate equipment can be built following the advancement

of technological developments in this area.

            The oil concentration limits proposed by the

U. S. Department of Health, Education and Welfare are

acceptable and satisfactory.  Their recommendations on

limits of iron concentration are also reasonable and

acceptable.   We believe that the recommended limit,

which was discussed by the representative of Great Lakes,

of 35 mg/1 on total suspended solids is completely

impractical.  Today's manufacturers of water clarification

equipment will not guarantee less than 85/1 and at the

-------
                                                      1576
               Robert C. Mclaughlin

present time there Is no possible way of meeting this

requirement.   In our Judgment the limit of 5 mg/1 on

settleable solids is also impractical.

            While we are in no position to comment on

the report other than the information which concerns our

Corporation, we do take serious exception to some obvious

errors or mlsstatements regarding McLouth Steel Corpora-

tion. The report states that a substantial quantity of

phenols are passed into the river by McLouth.   We do

not own nor do we operate a coke plant.   The only phenol

in the waste water from the Trenton plant would be

that remaining in the coke charged to the Blast Furnace.

This, of course, is a very insignificant amount.

            The report also condemns the*Corporation

concerning oil contamination.    Records which have been

maintained since 1961, and are on file at the Michigan

Water Resources Commission offices will show this accusa-

tion to be incorrect.   The water clarification system

at the Trenton plant has been operating under a Supple-

mental Order of Determination of the Commission since

January 1, 1961.   Monthly statements showing dally

operating results have been submitted to the Commission

since that date.    The records indicate that there

was accidental discharge of oil to the river only twice

-------
                                                      1577
               Robert C. MeLaughlin
during this period which covers 38,280 operating hours.
The two discharges were less than one hour each.   These
records also show that the suspended solids returned to
the river have been reduced by 80 per cent during
this period.
            The Gibraltar plant has successfully
operated 99 per cent of the time within the limits
established by the Michigan Water Resources Commission.
Infrequent failures to meet these limits have occurred
because of pipe or tank defects allowing acid and
ferrous chloride to enter the Prank and Poet Drain.  The
treatment system was changed in May of this year.
Accidental loss of this material can now be contained
and treated before it is released.   We do not
anticipate any further failures of this type to occur
again.
            We believe that we at McLouth Steel Corpora-
tion have accomplished satisfactory results and we take
great pride in our water clarification system.    It was
constructed at the time the original plant equipment
or subsequent new plant equipment was installed, and it
was designed and constructed in cooperation with the
Michigan Water Resources Commission.  The water
clarification equipment Installed at our Trenton plant

-------
                                                  1578




                     Robert C. Mclaughlin




is as modern and the operation as advanced in technology




as is known today.



            We have received the utmost cooperation from




the Michigan Water Resources Commission and their expert




advice has made it possible for much of the progress



which we have been able to attain.  The Corporation




has made every effort to operate the equipment within




the limits established by the Commission and intends




that the operation will be further improved as new tech-




nological advances are developed.




            It has always been McLouth Steel Corporation's




policy that industry has a full moral requirement not to




pollute the natural waters of our land.  We intend that




this policy will be maintained and we are hopeful and




anxious that Improvements in the system will continue.




            We welcome the opportunity to comment on the




report submitted by the U. S. Department of Health,



Education, and Welfare, and assure our cooperation in any




further information that may be required.




            Mr. Chairman, thank you very much.

-------
                                                      1579
                  Robert C. McLaughlin
                WATER CLARIFICATION
                  INSTALLATIONS
TRENTON PLANT

1.  90' Dorr Thickener

2.   Filter #1

3*  2 - 75' clarifiers

4»   Acid Treatment System

5.  Recirculating System -

    Oxygen Process Furnace #1

6.  Reclrculatlng System -

    Oxygen Process Furnace #2

7.  Filter #2

8.  Lime addition system

10. 8 centrifuges & Dorr thickener

11.  Modification to centrifuges

12. Drags for grit chambers

13. Covers over thickeners

14. Oil Skimmer clarifier Clearwell

15. Grit chamber flight sprays
WHEN INSTALLED
August 23,

August 1, 1958

Nov. 30, 1954.

April 1, 1957



May 15, 1958.



May 15, 1958.

January 15, I960.

May 30, 1959.

May, 1961.

Nov. 5, 1962.

August 1, 1963.

Nov. 15, 1963.

June 18, 1965.

Under construction,

-------
               Robert  C. McLaughlin
                                                       1580
GIBRALTAR  PLANT
WHEN INSTALLED
 I.  Roll  coftlant recovering system



 2.  Roll  coolant recovering system



 3.  32,000,000 gallon lagoon



 4.  Remodeling of above lagoon



 5.  Oil skimmer



 6.  Caustic tank



 7.  pH control



 8.  Waste treatment system
 September, 1961.



 July, 1963.



 1955



 1957



 April, 1957.



 September, 1963.



 September, 1964.



 Under construction-



 to be completed



 July 7,  1965.
NOTE;




               This equipment represents a capital



investment of several million dollars plus costly



maintenance and operating expenses.

-------
                                                       1531
               Robert C. McLaughlln

               MR. STEIN:  Thank you, Mr. McLaughlln.

               Do you have any questions?

               MR. POSTON:   I was going to ask whether

there are surveillance procedures in effect at McLoufch

Steel to determine the effectiveness of the treatment

at all times.

               Mr. Tucker indicated that Great Lakes

looked at their effluents every two hours.  Does McLou&h

have practices in that regard?

               MR. MCLAUGHLIN:    Yes.   I think Mr.

Oeming could answer that question better than I.   But,

we have very detailed surveillance, don't we?

               MR. OEMING:  That is correct, Mr. Poston;

there are reports submitted monthly.

               MR. POSTON: Thank you.

               MR. STEIN:  Do you have any questions?

               MR. OEMING:   No, I have no questions.

               MR. STEIN: Thank you, Mr. McLaughlln.

               Mr. Oeming?

               MR. OEMING:  At this time I would like to

call upon the Ford Motor Company.    Mr. Prank Kallln,

I believe, has a statement to make.

-------
                                                      1582



                    Prank Kallln








             STATEMENT OF PRANK KALLIN



             FORD MOTOR CORPORATION








               MR, KALLINi   Mr. Chairman Stein, Mr.



Boston, Mr. Oeming, and members of the Water Resources



Commission:



               My name is Prank Kallin.   Our report is



going to be in the form of a letter, and the letter Is



signed by Mr. C. A. Dunlap, director, plant engineering



office, and it is directed to Mr. Oeming.

-------
                    Frank Kallin                        1583
                 FORD MOTOR COMPANY




 PLANT ENGINEERING                  THE AMERICAN ROAD




      OFFICE                       DEARBORN,  MICHIGAN









                               June 10, 1965








 Mr. Loring F. Oeming




 Executive Secretary




 Michigan Water Resources Commission




 200 Mill Street




 Station B




 Lansing, Michigan









 Dear Mr. Oeming:




              Thank you for your  letter of May 10, 19^5^




 regarding the reconvened public  conference beginning




 on Tuesday,  June  15,  19^5» at  the  Detroit Institute of




 Arts.   We at Ford Motor Company  appreciate this  opportunity



 to comment on the proposed Public  Health Service Report.




              We believe that over  the  years Ford Motor




 Company has  demonstrated its sincere concern with the




 preservation of water resources.   For  example, the




Company has spent more  than $5 million for the in-

-------
                                                        1584
                     Frank Kallin

 stallation of waste  treatment facilities in the Rouge and

 Monroe Plants alone, including blast furnace thickeners,

 oil removal clarifiers, a final cooler, recirculation

 system for the control of cyanide from coke oven operations,

 a well for underground disposal of phenol bearing wastes

 and extensive oil skimming devices at the head end of

 our Boat Slip in the Rouge Area.  At our Monroe Plant,

 a most complete water and waste treatment plant was

 constructed in 1950  and was increased in size in 1956.

             In addition to the equipment mentioned

 above, the Company puts emphasis on a constant program

 of  "good housekeeping" and maintenance aimed at reducing

 pollution at the source.  In this connection, the Company

 has voluntarily taken steps to purchase degradable deter-

 gents in order that  the nuisances resulting from deter-

 gent foam will be minimized.

             Ford Motor Company's interest has been fur-

 ther demonstrated by its wholehearted cooperation with the

 various Federal and  state agencies to provide basic data

 on various industrial operations.  Typical are the co-

 operative studies with the Public Health Service and the

 Michigan Water Resources Commission including extensive

 detailed surveys of  operations at our coke ovens and by-

products plants in order to obtain waste characteristics.

-------
                                                        1585
                    Frank Kallin

which could be compared to operating experiences at other

similar coke oven operations.

             In considering the Public Health Service

Report, we find a number of points to which exception

might be taken.  Our objective, however, is to be con-

structive.  Therefore, in making our observations, we do

not seek to be argumentative but only to keep the problem

and our efforts to solve it in proper focus.

             In evaluating the Report, we have utilized

the Water Resources Commission Staff reports on waste water

surveys made at our Rouge Plant which were submitted to us

under date of July 2, 1964 and July 22,1964 and also the

Staff reports on waste water surveys made at our Monroe

Plant which were furnished to us under date of July 1,

1964 and November 8, 1964.  In essence, these reports

included the analysis of the 24-hour composite samples

taken at various outlets from the Rouge Area and the

Monroe Plant.

             First,considering potential oil losses at

the Rouge Plant, on page 1?6 of the "Findings" which

support the Report, it is stated that "Ford Motor Company

discharges 900 gallons per day  (of oil) which can often be

observed as a thin film on the water surface of the Rouge

River."  At the same time, on page 4l of the Report, the

-------
                                                       1586
                   Frank Kallin

Public Health Service appears to support an oil removal

limitation in the effluent of 15 mg/1 which would represent

approximately 5,000 gallons of oil per day in the total

waste water flow from Ford Rouge operations.  Ford's daily

discharge of oil as alleged in the report is, accordingly,

far below what would be permitted by a standard of 15 mg/1,

and yet the Report indicates dissatisfaction with present

oil loss conditions in the Rouge River.  We believe this

apparent conflict illustrates the weakness of applying

a specific oil effluent limitation to determine the ade-

quacy of oil waste control, and that the method under

which the Michigan Water Resources Commission now evaluates

the adequacy of oil waste treatment facilities, namely

continuous visual surveillance by helicopter and by boat

is a superior method.  The application of standards in

terms of parts per million to oil losses, regardless of

what proportions may be made, is in our view unworkable

and unlikely to achieve the results desired by the regulatory

authority.

             It should also be noted that since the Michigan

Water Resources Commission and the Public Health Service

surveys were made in 1963-^- (which formed the basis of

the Public Health Service Report), a greatly improved oil

recovery system has been completed and placed in operation

-------
                                                         1587
                     Frank Kallin

 at the north end of the Ford Boat Slip in the Rouge Area.

 This type of installation is a first of its kind,  and its

 operation to date has been most successful.

              As we have previously advised the Michigan

 Water Resources Commission, we are presently engineering

 the installation of an additional skimmer and oil  recovery

 unit to be located upstream of the Schaefer Road bridge

 on the Rouge River.  Some of the equipment has been ordered,

 and it is anticipated that this facility will be in oper-

 ation by the first of September this year.  This device is

 designed to collect residual oils which come from  the

 effluent of our oil removal facilities just west of

 Schaefer Road and also to collect oil which may come down

 the Rouge River from properties and operations upstream of

 the Ford Rouge Plant.

              In order to improve further the operation

 of the oil recovery system at the north end of the Ford

 Boat Slip, collection facilities and an additional treat-

 ment tank are being provided in our Dearborn Engine Plant.

 They will collect and treat all spent soluble oil  and

 washer solutions and remove emulsified oil before  the

 water phase is discharged to the Dearborn Engine Plant

 sewer system.  We believe that the amount of oil passing

under  the  skimming  device  at  the north  end of  the  boat

-------
                                                         1588
                    Frank Kailin

 slip  is minimal, but undoubtedly the treatment of spent

 soluble oil and washer solutions will further improve

 the oil control program in the Rouge Area.

             Turning now to steel pickling liquor (iron

 concentrations), it is our view that any reductions should

 be made in conjunction with a change in the basic pickling

 process.  Alternative means such as attempting to neutralize

 pickling liquor with lime or lime derivatives result in

 sludge disposal problems impractical at the Rouge Plant.

 The two 24-hour surveys we have previously mentioned in-

 dicated a total plant loss of iron of 13,86l Ibs. and

 24, 536 Ibs. respectively.  The Public Health Service's

 recommended limitation of 17 PPM (page 4l of the proposed

 Report) would permit a total discharge of iron over a

 24-hour period of 56,712 Ibs. in the Rouge Plant effluent,

 or more than twice that actually discharged.  At the

 present time, Ford is reviewing the feasibility of changes

 in its pickling process.  Based on preliminary engineering

 information available at this time, it is believed possible

 that changes may be developed which will reduce the amount

 of spent pickling liquor discharged to the Rouge River

 substantially.

             Insofar as suspended and settleable solids

from Rouge area operations are concerned, we do not con-

-------
                                                        1589
                    Frank Kallin
sider this to be a major problem in view of the particular

location of the Rouge Plant and the minor effect on Rouge

River dredging.  The Ford Motor Company's computed con-

tribution to the total Rouge River dredging represents

only 1.7% of the total volume of dredge material removed

each year by the U. S. Corps of Engineers.  Nevertheless,

we expect to reduce the amount of this material appreciably

as a result of proposed process changes in certain manu-

facturing operations in the Rouge Area.

             For example, proposed process changes at the

Dearborn Glass Plant will result in a substantial reduction

of sand discharged to our boat slip (which incidentally,

is owned and maintained by Ford).  This change is part of

a long range program and will be completed by approximately

the year 1969.

             Insofar as phenol and ammonia are concerned,

our Steel Division management is reviewing possibilities

to reduce further the amount of these chemicals resulting

from coke oven operations in the Rouge Area.  We should

point out, however, that the total pounds of phenol from

these operations are well below the 600-pound limitation

stipulated by the Michigan Water Resources Commission

and, contrary to the statement in the Report, do not

exceed this limit.

-------
                                                        1590
                    Frank Kaliin

             Turning now to the Public Health Service's

recommendations with respect to our Monroe Plant, we be-

lieve that the proposed limit of .025 PPM of cyanide is

entirely too stringent.  For the past 8 years, we have

been operating our Monroe facilities within a limitation

of 1 PPM and, insofar as we have been able to determine,

this concentration has not had any adverse affect on

the Raisin River or Lake Erie.   We appreciate, however,

that it may be advisable to consider a reduction of the

1 PPM to a lesser amount at such time as further improve-

ments are made in the Raisin River upstream from this

plant.  But because of this plant's particular location

in a heavily industrialized area at the mouth of the

Raisin River at Lake Erie, this limitation in our judg-

ment should not be less than .3 PPM.  In our opinion,

this concentration would not have any adverse affect on

the Raisin River and Lake Erie—particularly if imposed

at the point of outlet so that  the actual concentration

in the Raisin River would always be less than .3 PPM.

             Regardless of these considerations, a

significant process change will be made in the plating

process at Monroe which will further reduce the total

pounds of cyanide from this plant.

             On page 52  of  the Report,  it  is  stated

-------
                                                        1591
                     Frank Kailin
that "The effluent from the Company-owned sewage treat-

ment plant (at Monroe) is not chlorinated."  This is

incorrect, because the effluent is and has been chlorinated

for 365 days a year.  Also, the statement that "The

quantity of oil released to the Raisin River through a

dilution canal outlet is excessive even though the con-

centration remains below 15 mg/1" is unrealistic because

it does not recognize that the Lake F.rie water entering

this plant includes other soluble materials (oil, etc)

approaching or exceeding 15 mg/1.

             Again, Ford Motor Company appreciates the

opportunity to comment on the Public Health Service Re-

port.  The problem of pollution is important and compli-

cated.   Progress toward solution will depend upon good

will, common sense, and perseverance.  Ford Motor

Company will continue to do its part.



                         Very truly yours,

                         T. A. Dunlap, Director

                         Plant Engineering Office

-------
                                                     1592
                  Frank Kallin
               MR. STEIN: Thank you.   Are there any
comments or questions of Mr. Kallin.   Mr. Poston?
               MR. POSTONt   Mr. Kallin, what Is the
Ford Motor Company policy relative to sampling and
analysis of waste effluents?
               MR. KALLIN:  Well, at our Monroe plant,
for example, we have operators 24 hours around the clock.
In other words, the operators who have the chemicals,
and so forth, so it is a continuing program.
               MR. POSTON: Do they make a daily analysis
of effluents?
               MR. KALLIN:     Yes, sir.
               MR. POSTON: Do you know the particular
tests?
               MR. KALLIN:  Well, cyanide, chrome,
either soluble or oil; that is about all I can think of,
offhand.
               MR. POSTON:   I think that is  all I have.
               MR. STEIN: Do you have any questions,
 Mr. Oemlng?
               MR. OEMING:    No questions.
               MR. STEIN:  Thank you very much, Mr. Kallin,
for your statement.
               At this time we shall recess for ten

-------
                                                     1593


minutes.

               (Whereupon a short recess was taken.)

               MR. STEIN:   May we reconvene?  Here is

the tentative schedule that we are thinking of having:

We are going to try to push ahead as much as we can

this afternoon.  The best Indication Is, If we do

not get all completed this afternoon, we shall reconvene

In the lecture room here at 9:30 tomorrow morning.

               Now, I may change that If we have quite

a bit tomorrow when we come to the end of the day, and

move that time up.

               About noon we expect to get through with

all the presentations, and the discussion among the

conferees.   Then we shall recess for lunch sometime

in the afternoon, and we shall be able to announce at
  *
the noon recess tomorrow when the conferees will recon-

vene again, and then the conferees will have an announce-

ment for you on the conclusions, and where we go from

here.

               Mr. Oemlng, will you call the next person,

please?

               MR. OEMING:    Mr. Chairman, at this time

I would like to introduce for the record communications

received by me from this conference, from the Allied

-------
                                                     1594
Chemical Corporation Plastics Division, the Allied



Chemical Corporation Solvay Division, and the Allied



Chemical Corporation General Chemical Division.



               I shall leave these with the recorder here



and with your permission I would like to have these



entered into the record.



               MR. STEIN:  They will be entered into



the record as if read.

-------
                                                       1595
                 PLASTICS  DIVISION




           ALLIED  CHEMICAL  CORPORATION




                    DELRAY P.  0.




                DETROIT  17,  MICHIGAN




                 VINEWOOD 2-4400









                              May 27, 1965




Mr. Loring F.  Oeming




Executive Secretary




Water Resources Commission.




Michigan Department of  Health




200 Mill Street




Lansing, Michigan  48913









Dear Mr. Oeming:




             This  is  to advise you of the actions taken




and facilities  provided at  the Detroit plant of Plastics




Division, Allied Chemical Corporation, in the past



for pollution  control.  The current effluent at such




plant, as you  know, meets with the approval of the




Commission's staff (1), and as noted by the USPHS in




their April 1965 report does  not  interfere with current




uses of water from  the  Detroit River or Lake Erie.





             To date,  some  $250,000.  in  capital has

-------
                                                         1596
been expended by us at said plant to install control




facilities, which is a substantial investment for such a




small operation.  In addition to normal containment equip-




ment and segregation of process waste streams from cooling




waters, the plant is equipped with a solvent dephenolizer




for treating process wastes and with an oil-water separator




for handling the combined process-plant drainage discharge.




The dephenollzer is removing 99.6$ of the phenolics from




the process wastes.  These phenolics along with tars and




oils recovered by the separator are returned to process.




             Operation of these facilities is costing us




about $24,000 per year in direct operating expenses as well




as services, such as laboratory control.  This routine con-




trol includes automatic proportional sampling and flow




recording of the treated plant effluent, with frequent




visual inspection of the discharge.  This proportioned




sample is analyzed daily for critical waste constituents




to maintain a close monitor of the effectiveness of the




control facilities.  In addition the dephenolizer process



streams are checked daily for phenolic content and used




as control for the adjustment of operating variables to



maintain its high efficiency.








Note:  (1)  Ltr. RWP/OGU, dated 6/4/64.

-------
                                                        1597
             We continue to strive for further gains in




pollution control through a never ending program of em-




ployee education to the necessity of in-plant control




over process losses and the maintenance of good house-




keeping practices.  You may be assured this program of




necessary control over what the plant discharges will




continue.








                         Very truly yours,




                         0. G. UITTI




                         Works Manager




OGUrdp

-------
              SEMET-SOLVAY DIVISION




           ALLIED CHEMICAL CORPORATION




                   P. 0. BOX 58




             DETROIT, MICHIGAN 48231




                  PHONE 842-4400









                              June 10, 1965









Water Resources Commission




200 Mill Street




Lansing, Michigan 48913




Attention: Mr. Loring F. Oeming




           Executive Secretary









Dear Sirs:




             Reference is made to the Commission's




letter dated May 10, 19^5 enclosing a copy of the report




of the U.S. Department of Health, Education and Welfare,



Public Health Service on pollution in the Michigan




portion of the Detroit River and Lake Erie.




             It is noted the Report states as follows




with respect to this Company's Detroit plant:




             "Wastes discharged from this source, with

-------
                                                      1599




the exception of oil discharges as reported by the




Michigan Water Resources Commission, were not found to




interfere with existing water uses in the Detroit River




or Michigan Lake Erie."  (Summary, page 40)




            This favorable situation was brought about




by the expenditure prior to 1962 of substantial amounts




of money to control our plant effluent.




            It should also be noted that the discharge




of oil is not inherent in the plant processes and im-




provements in our regular program of good housekeeping




and testing of effluent have been effected to avoid



chances of malfunctioning and accidental discharges.




            In the report of the Joint Federal-State




Conference of March 27-28, 1962, control of wastes at




this plant was rated as adequate.  The survey conducted




by the Commission in April and May, 1963, showed a re-




duction in phenol discharge of more than 99.9$ from a




previous survey made in 1955 and that no significant



amounts of any pollutants were being discharged.  Follow-




ing this survey and by letter of July 8, 1963> the Com-




mission advised that the plant had been placed in




classification A.  In letter dated February 18, 1964,




the Commission commented on our "very impressive record."




            It is requested that this statement be

-------
                                                      1600
attached to and incorporated in the  record of the  re-



convened public hearing to  be held during the period June



15-17 at the Detroit  Institute of Arts.



                           Respectfully  submitted,



                           A.  J.  Kussling




                           Plant  Superintendent

-------
                                                       1601
            GENERAL CHEMICAL DIVISION




            ALLIED-. CHEMICAL CORPORATION




                800 MARION.,AVENUE




             RIVER ROUGE 18, MICHIGAN




                 VINEWOOD 1-4460









                              June 11, 1965




                              Corrected Copy









Water Resources Commission




State of Michigan




200 Mill Street




Lansing, Michigan 48913




Attn: Mr. Loring F. Oeming, Executive Secretary









Dear Mr. Oeming:




             With reference to your letter of May 10, 1965,




we thank you for sending us a copy of the full report of




the U. S. Department of Health, Education and Welfare,




Public Health Service, on the pollution in the Michigan




portions of the Detroit River and Lake Erie.  The re-




port is quite exhaustive and will undoubtedly be of





great value to your continuing control program.

-------
                                                       1602
             In a report of this magnitude it is under-




standable that errors and omissions may occur.  Since




we have observed several with respect to reported data




covering operations of this Company's Detroit Works, we




request that this letter and all attachments be incor-




porated in the proceedings of the June 15 public con-




ference and made a part of the record thereof.  Specifically,




we should like to make the following points:




             (1)  On page 7 of the "Findings", in the




section on "Sampling Analysis", we can find no mention




of the change in procedure for analyzing C. 0. D. (Chemical




Oxygen Demand) in waters, which change we understand was




made by the USPHS at Grosse lie sometime during the middle




of 1963.  The difficulty with the original analyses, as




we understand it, was one of chloride interference, which




gave erroneously high C. 0. D. results.   Accordingly,




although C. 0. D. results obtained before such change




were known to be highly questionable, in the case of our




Detroit Works, the C. 0. D. range is listed in Table 9-V



with no indication that the results may well be incorrect.




Attached are copies of letters to the writer from Mr.




R. W. Furdy, Water Resources Commission dated January




24, 1964,  and February 25, 1964, and my letter to Mr.




Purdy dated February 21, 1964, summarizing this sit-

-------
                                                       1603




uation.  Undoubtedly^ this same Inaccuracy applies to




other industries along the River.




            (2)  In Table 9-V of the "Findings", we




question some of the other results reported for con-




taminants in this Works' effluents.  It should be pointed




out that practically all of these concentration figures




are the results of just two 24-hour composite samples of




our two effluent sewers and one raw water intake.  It is




most misleading to report concentrations of contaminants




in plant effluents without showing similar contaminant




concentrations in intake raw water.  For example, range of




suspended solids in our Works' effluent is shown in Table




9-V as 22-79 ppm.  However, in the raw water feed, the




range of the same contaminant was 18-46 ppm.  In one of




the two 24-hour surveys, our total plant effluent contained




1120 Ibs/day less suspended solids than that entering the




plant in the raw water feed.  It seems inconsistent, there-




fore, that in Table 10-V, the average daily loading



from our Works to the River is shown as 1135 Ibs. suspended




solids, which we assume was derived by totaling one 24-hour




survey's result of 2270 Ibs. suspended solids and,




instead of crediting the Works with removing 1120 Ibs.




of suspended solids during the second day's survey, a




figure of 0 was used, thus yielding the average of 1135

-------
                                                        1604
Ibs.  The correct figure, in our opinion, should be 575




Ibs/day suspended solids.  Applying this same procedure,




the chlorides figure in Table 10-V should be 285 Ibs/day,




and not 456 Ibs., as reported.



             (3)  Another example is the range for phenols,




shown as 5-62 micrograms per liter.   This plant has no




phenol discharges whatsoever, so that if these analyses




were correct, the phenol concentrations must have been




in the raw water feed.




             (4)  Also in Table 9-V, we question the




range of acid concentrations shown as 8-1050 mg/liter.




The pH range shown is 5.8-7.7.  It is quite obvious




that the acid classification as indicated is ambiguous.




We believe it would be impossible for the effluent to




contain free sulfuric acid in concentrations of 1050 mg/liter,




which is 0.105$, and yet have a 5.8  pH.  The two 24-hour




composites showed a pH range of 6.9  to 7.2 and reduced




alkalinity (or acid) of 6 to 60 mg/liter in the case of




two sewer sample composites and an actual increase in



alkalinity range of 4-6 mg/liter in  the case of the




other two sewer composites.




             We appreciate being given the opportunity




to submit the .above for the record.   You may be assured




of our sincere interest and continued cooperation in

-------
                                                       1605
the Water Resources Commission's water pollution con-




trol program.









                         Yours truly,




                         C. W. Albin




                         Superintendent




CWA/jw




Attach:

-------
                                                          1606
             MR. OEMING:   Now I would like to afford




the Allied Chemical Corporation, Solvay Process




Division, the opportunity to present a statement.




             I think the statement is to be presented




by Mr. Von Frank.

-------
                                                      1607
               A. J. Von Prank


           STATEMENT OF A. J. VON PRANK,
           ALLIED CHAMICAL CORPORATION


               MR. VON PRANK:     Mr. Chairman,
conferees, and guests:
               My name is A. J. Von Prank.   I am
employed by Allied Chemical Corporation as a specialist
in Industrial wastes and in water quality matters.
               As stated by the Chairman, statements of
each of the three plants have been submitted for the
record.  I think the performance of those three plants—
               MR. STEIN:     Can you hear him back
there?
               VOICES:   No.
               MR. VON PRANK:   Solvay Process Division
of Allied Chemical Corporation operates an alkali plant
at 7501 West Jefferson Avenue, in Detroit, Michigan.
Boundaries of the property include bpth the Detroit
and Rouge Rivers.
               Its major product is soda ash (chemical
name - sodium carbonate), a basic heavy tonnage chemical
of industrial Importance, used in the manufacture of
glass, in cleaning compounds, as the major industrial

-------
                                                      1608
                A. J. Von Prank

alkali and a host of other uses.  Because of the low

cost of its product, 1.5-2 cents per pound, producing

facilities are invariably located close to sources of

raw materials.  Soda ash exists in the natural state

as "trona" in some of our Western States, notably

Wyoming.  Because of this developing supply, no price

advances have been possible for eight or nine years

to accommodate rising costs for the manufactured product.

               The plant produces soda ash by the

standard Solvay ammonia-soda process.   The basic raw
materials used are:

               (l)  Salt (ordinary sodium chloride)
which is pumped as brine from Canada.

               (2)   Limestone.

               (3) Weak ammonia liquor from coke oven
operations elsewhere.

               Soda ash is made by adding ammonia and
carbon dioxide to salt brine from which sodium bicarbonate

precipitates.  The bicarbonate is filtered and converted

to dry soda ash by heat.   The ammonium chloride solution

from the filters is distilled with lime for the recovery

of ammonia which is recycled in the process.   Both the
lime and carbon dioxide used here are produced by burning

limestone in kilns.

-------
                                                     1609
                 A. J. Von Prank

               Waste liquors from the distillation
step constitute the most Important single waste from the

manufacturing process.   This waste represents 2 million

gallons of effluent per day.   It contains all the

chlorides in the original brine, the calcium which had

been used to free the waste of ammonia in the distilla-

tion step, and the settleable and suspended Inert solids.

               Approximately 15-20 MOD of cooling water
is pumped from the Detroit River for cooling purposes,

and is returned there after one pass through its own

cooling water sewer system.   The total number of out-
falls into the river system numbers eight including those

for the process wastes.   The enormous variation in con-
centration reflected in Table 9-V (which is after page

176 in detailed USPHS report, entitled "Findings"),
which might be construed as disorderly control, in reality

reflects analyses of the essentially clean used cooling

water on one hand and maxima for process wastes on the

other.
               Segregated sanitary sewage is discharged

into the Detroit sewerage system.
               The problems with the 1-2 MQD process

waste effluents as stated on page 38 and page 40 of the

USPHS Summary Report, which covers discharges into the

-------
                                                      1610
                 A. J. Von Prank
Upper Detroit River and into the Rouge River from the
Solvay Plant, are:
         1.  Suspended and settleable solids
         2.  Chlorides;
and by that I mean the sum of the suspended and settleable
solids.
               Relative to separable solids content
in wastes from this plant, the record should reflect
that they are now about 10 per cent of what they were in
1947 when the USPHS also surveyed the river.  The earlier
report refers to "suspended solids" only and comparative
data show:
                       19^7 Ibs/day     CURRENT Ibs/day
Suspended Solids        1,228,000          130,000
               Most of this reduction occurred before
195^ and reflects production dislocation to some extent,
but also reflects attention directed at this recognized
problem by the plant.
               The solids discharged are composed mainly
of calcium carbonate with lesser quantities of calcium
sulfate, magnesium hydroxide and sand.    As such, they
are not dissimilar to some natural sources of separable
solids in many streams throughout the county.   They
present no health hazard.
               Up to the time of this conference, there

-------
                                                      1611
               A. J. Von Prank


has been no reason to believe that the quantity


of separable solids discharged from Solvay's plant


represented any significant interference with water use


within reasonable distances from the outfall.  Because


of the 90 per cent decline in separable solids in the


1950's, this company felt it has been operating in a


responsible and satisfactory manner.    If it is the


judgment of this conference that further abatements are


essential in the broad public interest, then this company,


of course, is willing to comply within the limits of


technical and economic feasibility.


               The recommendations of the Summary


Report are for removal facilities capable of producing


an effluent with maximum concentrations of (a) 35 mil-


ligrams per liter of suspended solids, and (b) 5 milli-


grams per liter of settleable solids.     We are not in


a position at this minute to estimate capabilities in


approaching these rigorous standards, which, when


related to current effluents would require better than


a 99.5 per cent removal.    We are in the process of


initiating the appropriate technical and feasibility


studies.


               Relative to the chloride content of the


process wastes, we concur with the Judgment expressed

-------
                                                      1612



                I. J. Von Prank



on page 10 of the USPHS Summary Report that current



chloride concentrations are not yet significant enough



to cause major Interference with water use, although



future action may be necessary to prevent an undesirable



situation.    The reasoning behind this assessment, of



course, is related to the results of the USPHS survey which



show chloride levels in the Detroit River substantially



below the concentrations at which concern is expressed



for the quality of drinking water and for corrosion of



steel surfaces In Industrial operations.    Average



values are reported as ranging from 9-69 mg/1 at the



mouth of the Detroit River.   USPHS Drinking water stand-



ards show a value of 250 mg/1 above which tastes may occur.



There is little industrial concern about life of steel



equipment in relation to waters containing less than



50 mg/1 of chlorides.



               The USPHS expresses a proper concern about



an over-all increase as a potential problem in the public



waters.   For perspective, the record should show that



chlorides from Solvay's operations have substantially



decreased in the same base period.   The report on the
        /


19^7 USPHS survey—which, incidentally is referred to



elsewhere as the IJC survey; I believe the Public Health



Service did the field work—of the plant's effluent

-------
                                                     1613
                I. J. Von Prank
compares as follows:
                      19^7 Ibs/day      CURRENT Ibs/day
Chlorides                2,646,000          690,000
               Sales dislocations have been responsible
for most of this, though Improved plant practices and house-
keeping has contributed to this reduction, mostly
accomplished by 1954.
               The Summary Report recommends  (pp. 38
and 40) "The Industry begin investigation of satis-
factory methods of disposing of chlorides and alternate
methods of disposal of concentrated brines, such as sub-
surface disposal."
               We accept this direction willingly, but
in fairness to the national soda ash industry and for
the record, I should state the problem has been re-
ceiving considerable technical attention for over ten
years.    A number of Investigations have been pursued
along the lines of recovering a useful by-product that
might recover some of the costs of treatment.    These
include cement additives, snow melting compounds, use
for hygroscopic purposes, etc.    None, to date, offers
promise as a route for other than a small fraction of the
waste available.  This matter is reflected in a report
entitled "Report on wastes from the Soda-Alkali Industry

-------
                                                      1614
                I. J. Von Prank
in Response to a Request from the N.T.T.C.I.W." and is
dated August, 1961.
               Relating to the pace at which the potential
problem of chlorides in water may approach -us, considera-
tion must be given to the fact of the developing "trona"
source'which acts as a strong depressant on any growth
of the manufactured variety.
               Thank you.  That concludes the statement.
               MR. STEIN:   Thank you very much.
               Mr. Poston?
               MR. POSTON:   I have no questions.
               MR. STEIN:     Mr. Oemlng?
               MR. OEMING:   I have no questions.
               MR. STEIN:    Mr. Von Prank, this industry
of yours fascinates me.    I guess that 1961 report might
have been written in answer to us.    The thing that
always puzzles me is that we have these dislocations of
marketing, and when we talk about a byproduct that might
use up some of the salt, the indication is that the
marketing potential is limited because the product is
so heavy that once you transport it out of your immediate
marketing area there is a competitor there who can beat
your price.
               Then you speak about the "trona" salts,

-------
                                                      1615
                I. J. Von Prank

which presumably has to be taken all across the

country.    How does It compete with Cape May or in

Saltville, Virgina, and so forth?  If you have a

limited marketing area because of the weight of the mat-

erial and your transportation costs, how does the

trona salts out in the West represent a danger?

               MR. VON PRANK:   I think there is a very

simple answer to that, Mr. Stein, and it is the simple

fact that the cost of transportation plus the cost of

mining equals what the manufactured variety can do,

delivered within a reasonable distance from the plant.

               Now, this admittedly, almost every one

of these situations is peculiar to the precise product

that we are dealing with.    I thought I detected a little

  sense  in your remark about generalizing on this.

               There have been many instances where

the reverse has been true.

               MR. STEIN:   I am not generalizing on this

as far as a marketable product, but there is a limit in

marketability.   Now, as I understand the industry, here

is the problem:   In most of the soda ash plants—and,

by the way, I am not singling your plant out, because

as far as I know every one is the same—most of the soda

ash plants are located on a large body of water where you

-------
                                                       1616




                      L. J. Von Prank




can get the raw materials, carbon dioxide, and so




forth.  The ones that are located on the ocean, perhaps




from a pollution point of view, are in the best position




with the regulatory authorities, because they put the




chlorides in the ocean and they more or less go free.




But the point is, none of the soda ash plants do anything




with the waste, other than this housekeeping you talked




about, bhat is, with the chlorides which form the



waste but discharge them into a viater course, for the




natural reason that you are in a big water course, as




you know.  Some of the plants are on headwaters, the small




ones, and we do have a big problem with them.  The only




solution so far we have been faced with is either underground




discharge or closing the mill.




           Now, I think we may have a problem, as was




pointed out, with this Increasing chlorides discharge




in the area here, faced with an industry like yours,




which even though it has cut down, is obviously a




large chloride distributor compared to other industries.




If really the trade or the state of the art permits no




other disposaljthan a discharge into a water course




as a first step, then we may be faced with a real problem.




I say this to you not in an "enforce" sense, but in a




"resource" sense, and in the sense of something that we

-------
                                                    1617
                   A. J. Von Frank

all have to work on.     I do not like to see the

decline of any industry, and I expect that with

certain industries such as the coal industry where

you have many areas devastated by acid mine drainage,

for example, from the long-range point of view, or the

pulp and paper industry, where about half their waste

goes down the street, I expect your industry is in the

same position, that as the country is going to grow

and as we are going to have stricter and stricter

control inevitably on all sorts of contaminants, it

seems to me it behooves the soda ash industry to find

some way so that a plant can begin getting rid of its

wastes rati*er than putting it into the stream; because

then in spite of that, I am sure the trona market is

going to expand and expand and expand.

               Again, I think this is an investment that

all the people in America have in keeping your Industry

alive; and I see this over the horizon.

               You probably know the plants in other

locations where we have real acute problems, and unless

your industry does something and has some imaginative

break-through on this, we tend to get Into very-very

sticky situations.

               MR. VON FRANK:   I do not think you have

-------
                                                     1618
                A. J. Von Frank

said anything really that I or people in the Industry

would disagree with.    They are aware of this.   They

are aware of the pressure on it; they are aware that

this is a contribution of chlorides and ultimately you

can get too much.    We know this.  And certainly the

direction and sriggestlon of Washington is well

warranted.    I think it is good to do this periodically.

               The other side of the coin that I want

to address myself to is in the sense of immediate

pollution here.   I had to read the language at least

twice to find out that the statement by the Public Health

Service as to these chlorides discharges is not at this

minute a pollution problem.   It is more of a potential

one; and that the wording of the recommendations of the

Public Health Service are for investigation to find

solutions, which is basically what you said.

               MR. STEIN:   I think with your industry

unless you get a new break-through or an underground

discharge, I don't know what we can do, but I do think

as I read the investigatory report, it was that there

are certain industries which cannot have complaints about

the chloride content in the water now, and this does not

relate to steel pipe,and  —  I think we could ask Mr.

Vaughan a question on that.  Obviously,where you have

-------
                                                      1619
                  A.  J.  Von Prank
 concentration of chloride, even as you have in the water
 going up to 69,  that for certain industries while this
 may not be a danger to  water,  you may not be able to
 take it as drinking water.    If you had a chemical
 industry or paper industry that are trying to do something
of that kind, you might  run into a problem with chlorides
of that type.
                Now,  again, Mr. Vaughan answered that
 question that he thought that  certain industries were
 not satisfied with the  water o^iality because of this right
 now, and I don't know how acute that is.    But I am
 not sure that he was Just speaking about a potential.
                MR. VON  PRANK:    I realize you do not want
 to have me on here all  afternoon, but Just one comment.
                MR. STEIN: Surely.
                MR. VON  PRANK:  This business of industrial
 retirements on water,  I think there is a highly mistaken
 notion.
                Obviously, somebody making antibiotics
 wants extremely pure water, and he will never get that out
 of a river; there is no Industry around, and particularly
 my own chemical  industry, who  is ever going to take water
 out of a stream, no  matter how best we put it, mountain
 stream or otherwise, that does not expect some type of

-------
                                                       1620
              A. J. Von Frank

minimal preparation for it; and I could belabor this

point for quite a while, and some of the references

I am sure that you have in the back of your mind are

in that category.

               MR. STEIN:   No.

               MR. VON PRANK:   Is it socially proper to

bring your water up to such a state that—

               MR. STEIN:   I think we are in substantial

agreement.

               MR. VON FRANK:   I know we are; right.
                  s
               MR. STEIN:   I think the key phrase here

is "minimal preparation."     I think minimal preparation

is a course, being in municipalities or being in industry.

Those industries with special requirements obviously have

that.

               The question here is a question of Judgment

again, as are all questions, in knowing when something

ceases to be minimal preparation and really is a burden

that should be taken care of by the discharger upstream.

               Now, again, I Just say this to your

company:    I recognize the problem, but I am sure that

unless something happens in the industry as a whole we

are going to be in for some really serious trouble.

               MR. VON FRANK:   Very good; we have got it.

-------
                                                       1621
                     A. J. Von Frank

               MR. STEIN:  Thank you.

               MR. OEMINGs    I would now like to call on

Mr. Robert P. Logan.

-------
                                                       1622
              Robert 1?. Logan

          STATEMENT OP ROBERT P. LOGAN
                 ON BEHALF OF
              SCOTT PAPER COMPANY
               DETROIT, MICHIGAN

             MR. LOGAN:  Mr. Chairman, Conferees and
Ladies and Gentlemen.
             Eighty-one years ago one of the first chemi-
cal pulp mills in this country was constructed near the
confluence of the River Rouge and the Detroit River.  Eight
years later paper machines were added.  Pulp and paper
manufacture has been carried on there ever since and today
this mill, operated by Scott Paper Company since 195^-j pro-
duces about 250 tons of paper products per day.
             The Scott mill at Detroit employs about
700 people and contributes nearly $14 million annually
to the economy of the surrounding region, including
$1 million spent for pulpwood cut by small independent
suppliers in the thumb area of Michigan.
             Production of pulp at our Detroit mill is
by the so-called Mltscherlich process, one of the first
chemical processes used to produce wood pulp.  In this
process, chips of wood are cooked with calcium bisulfite
to dissolve the wood sugar and the lignin, leaving be-
hind the fibers of cellulose.  The sugar and lignin are
in dilute solution and, in the Mitscherlich process,

-------
                                                       1623
              Robert P. Logan
as we practice  it* recovery  is not economically feasible.
             Now consider the manufacture of paper
where large quantities of fiber are pumped, circulated,
washed, and formed into sheets.  Throughout, great
quantities of water are required as the transporting
medium.  Some of the fiber is extremely small.  One con-
sequence of this is that, despite every effort to the
contrary, some  fiber inevitably remains in the water
when it is returned to the river.
             Thus, the effluent from the pulp and paper-
making processes at our mill contains wood sugars, lignin—
which is closely related to the biologically inactive
material developed in the spongy floor of a forest—
some calcium bisulfite, and wood fiber0  If it were
economically and technically feasible to recover com-
pletely and reuse these materials this would certainly
be done.  The recovery and reuse of all this waste is
no more feasible than is the operation of a household
with complete recovery of all waste.
             These, then, are the facts of our situation:
We operate a pulp and paper mill.  Complete recovery of
all waste products is impractical.  Large quantities
of water are used and carry off waste products to the
river.
             Concern has been expressed as to the
effects of these waste materials on the water quality

-------
                                                          1624




                     Robert P. Logan




of the receiving stream and we meet today to discuss




these matters as they are described in the Report on




Pollution of the Detroit River, Michigan Waters of Lake




Erie, and their Tributaries, published by the U. S.




Department of Health, Education, and Welfare.




            The Summary, Conclusions and Recommendations




of the Report suggest that Scott Paper Company discharges




into the river an excessive quantity of suspended solids




and of oxygen-consuming materials.  Recommendations




are made ". . .to prevent interference with navi-




gation and fish and wild-life propagation."  In




another part of the Report, specifically the Findings,




it is implied that our mill is discharging excessive




quantities of phenols, zinc, and copper.  We would like




to consider these recommendations which have been made,




to comment on them, and to tell something of what we have




done in the past and what we propose to do in the




future concerning the effluent from the mill.




            First, let's consider the implied charge




that we are discharging excessive quantities of copper,




zinc, and phenols.  We make no use of copper or zinc




compounds in the preparation of our products.  We do




use machinery which, in part, is constructed of these




metals.  However, if we were losing as much copper

-------
                                                     1625

              Robert P. Logan

zinc to the river as is suggested by the Report, we
would be experiencing an intolerable corrosion of ex-
pensive machinery that would require frequent equip-
ment replacement for us to continue to operate.  No
such replacement is necessary.
             We suggest that further analyses might
explain this reported presence of metals.  We have not
made these analyses because we have had no reason in
the past,nor do we have any now, to suspect such losses.
             The third material, phenol, also is not
used in the preparation of our products.  Pulpwood is
used, of course, and it is known that ligneous
compounds derived from wood will produce a phenol-like
color reaction with the aminoantipyrine test presumably
used in the study.  We would like to point out that
there is no evidence that these wood compounds are
toxic to aquatic life or involved in the production
of tastes in water.
             Now we come to the more specific concerns
expressed in the Recommendations in connection with our
effluent, specifically suspended solids and oxygen-
consuming material.  In spite of our best efforts we
do, in fact, contribute more suspended solids to the
river than we would like.  Because of our concern,

-------
                                                      1626
              Robert i. Logan
Scott Paper Company has taken positive action in this
area.  Since 1954, expenditures amounting to $1,000,000
have been made for equipment and improvements designed
to reduce suspended solids losses.  It is estimated
that these improvements have resulted in the elimination
of about 3>700 tons of suspended solids per year which
otherwise would go to the river.  We have accomplished
this by reducing suspended solids losses from 206 Ibs.
per ton of production to 135 Ibs. per ton of production,
a reduction of 35$.  Water usage has been reduced during
the same period from 190,000 gallons per ton to 120,000
gallons per ton.  In a mill as old as the one concerned
these are creditable improvements.  In addition we
have for some years operated a clarifying pond which
removes a considerable quantity of solids from the
effluent which otherwise would go toths river.  We
dredge this pond and are removing solids at the rate
of 4,000 cubic yards per year and disposing of them
as land fill.
             In spite of all this we recognize that
our suspended solids losses are still too high and
during the past several years we have discussed the
problem  at length with  engineers  of the Michigan
Water Resources Commission.  Because of these losses

-------
                                                        1627
              Robert (f. Logan

the Water Resources Commission has found it necessary
to classify our mill as being one with inadequate con-
trol.  In view of this classification we have more
recently been discussing what further steps we might
take to improve our situation with respect to sus-
pended solids.  A first step would be to install a new
screen in the woodroom, a source of a large quantity of
these solids.  Engineering on this installation was
completed in February of this year and the screen
will be installed during our July shutdown.
             But we recognize that even this, helpful
as it will be, will not be adequate to reduce the solids
in the plant's effluent to the level urged by the Water
Resources Commission.  Consequently we have, at the
urging of the Commission's engineers, decided to con-
struct a modern waste clarifier and have for some months
been making necessary flow and concentration measure-
ments to enable us to provide a rational design for this
installation.  Solids removed will be concentrated by
filtration or centrifugation and hauled away for land
disposal or incineration.  A preliminary estimate of
the cost of this installation is $1,000,000 plus an
annual operating cost of $100,000.
             At Scott Paper Company we have recognized

-------
                                                       1628
               Robert i. Logan

that suspended solids in our effluent have created
problems.  We are taking steps to eliminate these
problems.
             The Report goes on to recommend that the
effluent of the Scott mill be treated to reduce its
B.O.D. (Biochemical Oxygen Demand) or oxygen-consuming
capacity, to 85 parts per million.  Before proceeding
further, we wish to emphasize that,  contrary to the im-
pression some might have from reading the Report, the
effluent from a sulphite pulp and paper mill does not
resemble untreated domestic sewage.   The oxygen-con-
suming capacity of the effluent is due largely to the
pressence of wood sugar.  The other major constituent
is lignin, the cementing material in wood.  There are
no coliform or disease-causing bacteria in this waste.
             The Report makes its recommendation con-
cerning B.O.D. in order "... to prevent inter-
ference with navigation and fish and wildlife propagation."
We do not think the Report means to imply that oxygen-
consuming material interferes with navigation so we
assume that its concern is with fish and wildlife
propagation.  We further assume that the concern is
for the oxygen resources of the river and lake without
adequate supply of which fish and wildlife may suffer

-------
                                                       1629





              Robert tf. Logan





interference.



             What does the Report  say about the oxygen



resources of the concerned waterways?  On Page 1 of the



Conclusions we find the statement, "Declining levels of



dissolved oxygen in the lower Detroit as it enters Lake



Erie are approaching the danger point, indicating trouble



in the future unless appropriate remedial action is



taken."  We will consider this statement in detail later



but let's see what else the Report says about the



oxygen resources of the waterways.



             On Page 8 of the Conclusions we read,



"While the present oxygen level in the Detroit River



does not cause major interference with water uses,



the drop from 100 percent saturation in t&e upper



River to 67 percent in the lower is a warning of dire



consequences in the future . . . ".  Apparently no



major adverse consequences of the present oxygen level



were found; the implied minor consequences are not
                                                        /


described.  The 67 percent saturation in the lower



River will be examined later.



             On Page 150 of the Findings we find "In



no reaches of the Detroit River do levels of dissolved



oxygen cause interference with water uses."  On Page



280 of the Findings we find "Levels of DO (dissolved

-------
              Robert £. Logan

oxygen) in most of the Michigan waters of Lake Erie
are sufficient at this time to prevent interference
with water use."
             On Page 21 the Report states, "Most of
the Michigan waters of Lake Erie displayed high levels
of dissolved oxygen."  And further, "While present
oxygen levels in the lake do not yet cause major inter-
ferences with water use, the drop to 4»8 mg/1 repre-
sents a threat to water uses in the Lake."
             So it seems that there is no interference
at present with water uses due to dissolved oxygen
levels, but the Report expresses some concern for the
future.
             What are these oxygen levels at present?
This (slide) is Figure 12-V of the Findings.  It shows
average percent saturation of dissolved oxygen but
note that it depicts conditions only at the sampling
station nearest the U.S. shore.  Conditions are
poorest, as one would expect, in the lowest reach of
the River as indicated by the data for the station
nearest the shore on sampling range DT 3.9.  But the
river is wide here, almost four miles wide.  What are
conditions like elsewhere on this sampling range ex-
tending from Maple Beach to Bar Point in Canada?

-------
                                                        1631

              Robert  P. Logan

             This  (slide) is Figure 12-V with bars in-
dicating conditions elsewhere on the sampling range.
These data relating to conditions measured in 1962
were kindly supplied by the HEW Detroit River-Lake
Erie Project and illustrate that conditions across
the range are much better than those at the station
nearest the shore.  It seems reasonable to look at
the whole river, not just one part of it.
             Here  (slide) is Figure 12A-V which shows
minimum dissolved  oxygen concentrations for stations
nearest the U. S.  shore.  We have added at station
DT 3.9 bars indicating conditions elsewhere on the
sampling range.  These data, again relating to 1962
conditions, were supplied by the Detroit River-Lake
Erie Project.  Again we find minimum conditions across
the sampling range to be much better than might be
supposed if one merely considers the station nearest
the shore.  We think that many aquatic biologists
would agree that these minimum conditions, found only
once during the survey, are more than adequate for the
fish and wildlife  involved.
             On Page 163 of the  Report we find a section
entitled Trends in Water Quality.  Its opening sentence
reads, "One approach to evaluating trends in water

-------
                                                          1632

              Robert P. Logan

quality and pollution abatement is to compare existing
water quality levels and waste discharges with those
found during past surveys."  The Report compares,
in great detail, levels of total coliform organisms,
phenols, and chlorides found in the Detroit River in
1962-63 by the Project with levels found in 1946-48
by the International Joint Commission survey.  Un-
fortunately, no comparison is made for dissolved
oxygen or B.O.D.  We think such comparisons would be
both interesting and instructive.
             Figure A (slide) shows minimum dissolved
oxygen found across sampling range DT 3.9 by the
I.J.C. in 1946-48 (green or solid) compared with the
data found by the Project in 1962-63 (red or dashed).
This comparison is interesting.  It indicates that
the dissolved oxygen level for minimum measured con-
ditions was at least as good and possibly better in
1962-63 than it was in 1946-48.  This implied trend
in water quality scarcely supports the statement on
Page 1 of the Conclusions of the Report, "Declining
levels of dissolved oxygen in the lower Detroit as
it enters Lake Erie are approaching the danger point,
indicating trouble in the future unless appropriate
action is taken."  The "... dire consequences

-------
                                                       1633
              Robert P. Logan

in the future . .  . ", which the Report predicts cannot
be anticipated from a trend which indicates an im-
provement in water quality as measured by dissolved
oxygen.
             Although the Report does not give detailed
data for Biochemical Oxygen Demand,it would be interesting
to know what the trend is for this parameter of water
quality which is a measure of the amount of oxygen
required to stabilize organic matter.  Data supplied
by the Project show that 24-hour composites over a
four-day period in June 1964 taken at the station
6,500 feet from the U. S. shore on sampling range
DT 3.9 had an average B.O.D. of 2.0 parts per millon.
Samples taken l6 to 18 years ago by the I.J.C. at the
same station had an average B.O.D. of 2.3 parts per
million.  Again the trend shown by the data is one
of improvement.
             On Page 150 of the Findings we read,
"It is normal to find a B.O.D. of 2 to 3 parts per
million (or 2 or 3 mg/1) in river waters receiving
natural drainage; a higher B.O.D. may represent a
drain on the dissolved oxygen present in the water."
The data supplied by the Project for the station
6,500 feet from the U.S. shore on Range DT 3.9 show

-------
                                                        1634

              Robert P. Logan

an average B.O.D. of 2.0 parts per million.
             On Page 150 of the Findings we also read,
"In the upper Detroit River, the B.O.D. ranged from
2 to 4 mg/1."  Compare this with the 2.0 mg/1 (parts
per million) reported by the Project for the lower
River.
             We do not mean to be critical of the
B.O.D. data.  At best the determination is difficult;
precise data are not always obtainable for river B.O.D.
when the concentrations are low.  The B.O.D. exerted
by oxygen-consuming material added near the River
Rouge to sampling range DT 3.9 is only a matter of
about 15 hours.  For example,  the oxygen-consuming
material in the effluent from the Scott mill would be
expected to consume less than 1/20 of 1 mg/1 of oxygen
by the time it reached range DT 3.9 if it were uniformly
distributed across the river.
             Now even though Figure 28-V in the Findings
tells us that effluents discharged near the River Rouge
will be distributed across the river on range DT 3.9
nearly to Bar Point, it is probable that much of these
effluents will tend to stay nearer the western shore.
Just to emphasize the point let us assume that the
Scott effluent mixed with only 1/20 of the total Detroit

-------
                                                      1635
               Robert P. Logan

River flow. That portion of the river would then
experience less than 1 ppm oxygen depletion by the time
it reached range DT 3.9.  And the other 95# of the
river would experience none at alii
             Pollution may be defined as the condition
existing when the natural ability of a water course
to assimilate a material without damage to other water
uses is exceeded.  It appears to us that the oxygen-con-
suming material added to the Detroit River is assimi-
lated by this huge flow of water and does  aot hinder
other water uses.  The B.O.D. at the mouth of the river,
as nearly as it can be measured, does not exceed that
at its head.  As measured, it was lower in 1964 than
in 1946-48.
             The dissolved oxygen resources of the
Detroit River are tremendous.  It has been estimated
by the Board of Consultants to the Southeastern
Michigan Sewerage and Drainage Study that the Detroit
River carries, as a minimum, 8,900,000 pounds of
dissolved oxygen per day.  This is equivalent to
the oxygen-consuming capacity of the untreated
sewage of 53,000,000 people.
             Data supplied by the Detroit River-Lake
Erie Project demonstrate that at no place or time did

-------
                                                       1636

              Robert >P. Logan

oxygen in the Detroit River drop below a level con-
sidered adequate by most aquatic biologists.  The wastes
from the Scott Paper Company mill are not capable of
consuming more than one-half of one percent of the
oxygen in the Detroit River by the time it reaches
its mouth.
             The Report on Pollution of the Detroit
River, Michigan Waters of Lake Erie presents data,
draws conclusions, and makes recommendations relating
to the effluent of the Scott Paper Company's Detroit
mill and the water which receives it.   Some of these
data relate to the quantities of zinc, copper, and
phenols said to be in our effluent.   We respectfully
suggest that, since we use no copper or zinc in the
preparation of our products, such materials could
only come from corrosion and that the quantities re-
ported (some 60 tons per year) are of such magnitude
that the need for replacement of expensive machinery
would be quite evident to us.   No such replacement is
necessary.  We think additional analyses are needed.
             As far as phenols are concerned we do not
use these either but suggest that lignin or its com-
pound from wood may be producing phenol-like reactions
in the color test employed.  We know of no evidence that

-------
                                                        1637

              Robert P. Logan

these ligneous compounds produce tastes in water or are
toxic to fish and wildlife.
             Another recommendation calls for the re-
duction of the B.O.D. in our effluent.  We do not be-
lieve that the data presented demonstrate any
significant increase in the B.O.D. of the Detroit River
nor do they demonstrate any significant damages TCO the
water resources of the Detroit River or to Lake Erie as
a consequence of our effluent.  We do not believe that
it is demonstrated that the B.O.D. of our waste or the
zinc copper and phenol claimed to be in our waste are
capable of creating any problem whereby, in the words
of the State of Michigan Public Act 245 of 1929 as
amended, "... any fish or migratory bird life may
be destroyed or the growth or propagation thereof pre-
vented or injuriously affected or the value of lawfully
taken fish or game is destroyed or impaired .  . . ".
             The recommendation is made that suspended
solids in our effluent be reduced.  We have made sub-
stantial progress in this area and are working closely
with the engineers of the Michigan Water Resources
Commission to achieve additional reductions.   In a
few weeks we will install a new screen for our wood-
room wastes.  For some months we have been gathering

-------
                                                      1638

              Robert 3P. Logan

necessary design data for the proper design of a waste
clarifier which will cost an estimated $1,000j000 and
involve a substantial operating cost of about $100,000
per year.
             At Scott Paper Company we are aware of the
need to protect our water resources.  Over the years we
have cooperated with the engineers of the Michigan Water
Resources Commission to find ways to meet this need.
We hope to continue this cooperation.

-------
                  Robert P. Logan                   1639



            MR. STEIN:  Thank you, Mr, Logan.



            Do you want these charts to appear in



the record?



            MR. LOGAN:  Yes, we would like that.



            MR. STEIN:  They will appear In the record.
            (EIGHT  CHARTS FOLLOW)

-------
            u
            K
            K
            O
            O 60

                                                                                                       1640
                        OT 50 8W     OT tO t     DT IT «W    DT 14 6*     DT • T«     DT 3.*
                                                                       -}        •'**"••!*>
                                                                       •—       -       sy°..
M  I
                                                    ItAkt
                                DETROIT  RIVER-LAKE   ERIE  PROJECT
                           AVER AQE   PERCENT   SATURAT10 N

                                  STATION  NEAREST U.S.  SHORE
                                           DETROIT   RIVER
                           U S  T>»*JlR T M E N T III \M\ HI  | II  I HI 11  U lU^^'injU I I II II I

                                 REGION   V        GHOSSE I L  E , MICHIGAN

-------
        DT108W    DT206    OT.74W   DT.46*    DT87*     DT ! 9
                DETROIT  RIVER-LAKE  EPiE  PROJECT


MINIMUM   D I SjjaJ-VED  OXYOEN  .CCLhLCE NTRATIONS

                  STATION  NEAREST U.S. SHORE
                         DETROIT   RIVER
           U S "-a^P ARTMENT  OP HEA L.T H, EDUCATION. %
                              HE A LTff-a m
                                G RO S3 f  ' _ E  M I C H i r,

-------
DT SO 8»    OT iO.«     DTI74W    OTI46*    DT8TW     DT5
       DETROIT  RiVER-LAKE ERIE  PROJECT

  AVERAGE  PERCENT   SATURATION
           OIS-TOT-VED   OX Y0EN
        STATION  NEAREST US  SHORE
                DETROIT  Ri v E R
  U S  O£PflRTMEN*  '.'  MfcHtlM. tL/j.AllOX,1), *E  '0"f
              PUBLIC HEALTH •*. f. H , • r. I
       R C G i 0 N  v        G ^ 0 S S f    t  M r " 0 ^ *<

-------
F.GUREA   SAMPLING RANGE  DT3.9
           MINIMUM   D.O. VALUES
   -• 9
SURVEY
I.J.C. H.E.W
                5OOO       1OOOO      150OO
                  FEET  FROM U.S. SHORE
                                      200OO

-------
         100 ,
        u
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        O
        a «o
        a
        3
        ^-
        t
                                             DT • TW   OT J »
M I
                                                                   \V'
                                                                           1644
                      DETROIT  RIVER-LAKE ERIE PROJECT
                  AVERAGE  PERCENT  SATURATION
                      ^^rrsTrrvrtr-trrTT^w*
                       STATION NEAREST U.S. SHORE
                             DETROIT RIVER
                  U S 1H&A RTMENT OF *£AXI±l . E OUC 4UM^^TE L F A R E
                      REGION  V
                                   GROSSE I L E , MICHIGAN

-------
   DETROIT  HivEP-LAKE  ERIE PROJECT
AVERAGE  PERCENT SATURATION
   	  DISSOLVED—CTXY GEN
 S' STATiON NEAREST U.S. SHORE
          DETROIT RIVER
0 > l> t, (' A n J M I N 1 l>> « • *« V I H . L U U I. A I I u »«rT» * I i ' • » (
      "            -M B w i c 1
               &HOS&I ' L e M i c «> G * N

-------
         RIVER-LAKE  ERIE
  STATION  NEAREST  US  SHORE
         DETROIT  RIVER            /


REGION  V        fflWsSE ,LE.  «,CM1GAN

-------
FIGURE A
                  uS'sa fc P
AN
             MINIMUM   D.O. VALUES
                  5000        100OO       15000
                   FEET  FROM U.S. SHORE
                        20OOO

-------
               Robert P. Logan
            MR. STEIN:  Are there any comments or
questions, Mr. Boston?
            MR. POSTON:  No; not at this time.
            MR. OEMING:  I have none.
            MR. STEIN:  Thank you.
            Well, I Just have one.  I see the recommenda-
tions of the report.  I do not see that this necessarily
goes as to phenols or as to copper, but maybe I am
mistaken.
            MR. LOGAN:  No, sir, the recommendations
of the report are not—we thought there was an implied
charge in the various places in the findings where
phenols and copper are mentioned as exceeding certain
IJC requirements.
            MR. STEIN:  Mr. Logan, I don't know what
these investigators do; and I think I can safely speak
for Mr. Oeming and Michigan here; I have watched them
in-their regulatory function, while Mr. Adams was here,
and Mr. Oeming and ourselves, and I think we both believe
the same. We do not deal with implied charges.  We say
it; or it isn't.
            MR. LOGAN:  Perhaps the term is not correct.
Tables 95, 10V, 11V, and 15 V comment on this.
            MR* STEIN:  But I do not think there is

-------
                   Robert P. Logan                  1649



an implication.  Unless someone says it directly or



makes a recommendation, that isn't an actual item.  I



have read the reports of the Michigan Water Resources



Commission for years, and as far as I know, they have



the same rule.



            MR. LOGAN:  We are very pleased to hear



that, Mr. Stein.



            MR. STEIN:  I do have one other thing.  You



say pollution may be defined as the condition existing



when the natural ability of a watercourse to assimilate



a material without damage to other water use is exceeded.



            Part of my function is statutory drafting.



I have read every state law, foreign law, and Michigan



law, and read their definitions of pollution.  I have



gone through the Federal laws.  I have gone through



every dictionary; but where did you get this definition?



            MR. LOGAN:   I think that there are many



definitions.  I did not mean to imply that this was a



legal definition by any means.



            MR. STEIN:  Is it found in any dictionary?



            MR. LOGAN:   No, not at all.  It is found



in some writings, though.



            MR. STEIN: All right; thank you.



            MR. LOGAN:  You are welcome, sir.

-------
                                                     1650
               Jack T. Garrett

               MR* OEMING:   Mr. Chairman, I would now

like to provide the opportunity for Monsanto Chemical

Company to present a statement.   I believe Mr. Jack

Garrett is here.

-------
                                                       165J
                  Jack  T. Garrett
           STATEMENT  OP J.  T. GARRETT,

         MANAGER  OF POLLUTION ABATEMENT,

                MONSANTO COMPANY


               MR. GARRETT:    Mr. Chairman, conferees, and
ladles and gentlemen:

               My name is Jack T. Garrett.   I am the
manager of pollution abatement in the Chemical Department
of the Monsanto Company at  St. Louis, Missouri.

               In accordance with Monsanto's express
policy, our Trenton Plant has for years practiced the
principles of "good neighborliness" in connection with
its waste disposal problems.     We have cooperated with
the Michigan Water Resources Commission, the City of
Trenton, and Wayne County through the years.  During this
time we have improved our waste handling and disposal
procedures, for both esthetic and economic reasons, and
the total investment involved is very substantial.   It
has never been necessary for the regulatory agencies in
this area to order us to make any adjustment in our
waste handling procedures or to build any new facilities.
Whenever any production expansion has necessitated a
change in our waste control facilities we have discussed

-------
                                                     1652



               Jack T. Garrett



such changes and had proposed remedies approved by the




State before proceeding with the expansion.



               At the present time we are working on a



long-term program of in-plant reduction of sewered



production values.  This program has, as two of its



major objectives, the reduction of pollutants discharged



to our multi-lagoon treatment system and the recovery of



these values for economic reasons.



               At the present time we do not know where



this program will leave us in connection with our



soluble phosphate discharges.  Certainly there will be



less| but how much less we cannot say until the program



has been completed and evaluated.



               We were certainly dismayed to find the rec-



ommendation that we reduce our soluble phosphate discharge



by 80 per cent in the Public Health Service report (p. 46,



"Report on Pollution of the Detroit River, Michigan



Waters of Lake Erie and their Tributaries - Summary,



Conclusions, and Recommendations," dated April, 1965).



      Although Phosphates are necessary nutrients in the



growth of algae, so are hundreds of other materials,



including water, a whole host of trace essential elements,



nitrogen, and others.




               To our knowledge, there is no evidence

-------
                                                      1653
                    Jack T. Garrett

that phosphates, of themselves, cause excessive algae

growth, all other factors being constant.    Even the

Public Health Service Report just mentioned is vague

about this point.   We have never witnessed excessive

algae growths in our own lagoons, although there

certainly is evidence of algae in these lagoons as there

is in the river and all other rivers we have any

knowledge of, and there was, I am sure, when old Port

Detroit was the only man-made establishment contributing

to the pollution of the river in this area.

               We feel that the recommended 80 per cent

reduction is unrealistic, and we do not understand how

this figure is derived.    We therefore request that this

recommendation be deleted from the conferees'  report and

no specific per cent reduction be required until scien-

tific justification is available.

               Nevertheless, we Intend to continue to

reduce this discharge of soluble phosphates and any

other pollutants we might contribute to the lowest possible

level consistent with intelligent economics.

               Thank you.

               MR. STEIN: Thank you.   Are there any

comments or questions?

               MR. POSTON:   I don't think I have any.

-------
                                                       1654
                   Jack T. Garrett
               MR. STEIN?  Do you have?
               MR. OEMING:   I have none.
               MR. STEIN? Thank you very much, Mre
Garrett.
               MR. OEMING'.  The Wyandotte Chemical
Corporation has Indicated that It has a statement to
present.     I would  like to call on Mr. Day, I believe,
of the Wyandotte  Chemical Company.

-------
                                                        1655



                 William R. Day








           STATEMENT OP WILLIAM R. DAY,




CORPORATE SECRETARY, WYANDOTTE CHEMICALS CORPORATION








                MR. DAY:   Mr. Chairman, conferees,  and



 not somnolent attendees:




                MR. STEIN: They are non-somnolent



 after that introduction.




                MR. DAY:   My name Is William R.  Day,



 corporate secretary of Wyandotte Chemicals Corporation,



 and our residence is on the east bank of the Trenton



 Channel of the Detroit River.



                I have the following statement to be made



 on behalf of Wyandotte Chemicals Corporation.



                First of all,  we commend the  Department



 of Health, Education, and Welfare on the thoroughness



 of its report.  The Intense detail,  and volume of the  data



 collected is admirable. This report, as Its  introduction



 and background notes, can appropriately be regarded as the




 culmination of 50 years of public and private agency



 investigations of Detroit River water quality.



                I might say that I hope these words  of




 commendation approach those which have previously been



 made today on behalf of a well-known outstanding labor



 organization.   (Laughter.)

-------
                                                      1656
                 William R. Day

            Our admiration of the report must, however,

be tempered with realism.  So, when we come to the

conclusions and recommendations, we feel obliged to

point out some of the practical realities of industrial

pollution control achievement in so far as Wyandotte

Chemicals is specifically concerned.

            The report recommends with respect to our

North and South Plants, that:

        1.  Facilities be provided capable of producing

an effluent not to exceed:

            a.  Suspended solids concentration of 35 mg/1

            b.  Settleable solids concentration of 5 mg/1.

        The basis for the selection of these solids

concentration limits cannot clearly be derived from the

report.

            The suspended and settleable solids standards

of 35 mg/1 and 5 mg/1, respectively, are, of course,

used throughout the report as recommendations to be

achieved by municipal and industrial plants.   I believe,

as Mr. Black characterized it, it is an across -the -boar<3

standard limitation or objective.    We cannot help but

feel that these standards have been arbitrarily selected

without adequate consideration of the practicability of

their achievement or their effects on the river water

-------
                                                      1657
               William R. Day

quality.  The standard for suspended solids, particularly,

approaches, if It does not exceed, the limit of

capability of presently available sedimentation methods

for solids removal, such as lagoonlng or mechanical

settling.  In our view, this standard which, on a

calculated basis, would only permit a suspended solids

increase from an average of 7.5 ppm in the upper river

to an average of 8.0 ppm at the mouth, is unnecessarily

restrictive.  We find it difficult to comprehend the

purpose served by such a low level of suspended solids.

            Pursuing the subject from a more realistic

viewpoint, we must point out that Wyandotte Chemicals

has recently spent $25,000 in upgrading its solids-

carrying waste handling system, and the company's

management has approved a further $250,000 Investment

to this end.   In addition, several other projects are

under engineering study which will incorporate solids-

carrying waste, now discharged into the river, Into the

solids treatment system.  Thus, we seek an improvement

in solids removal from river effluent within the realm

of practicality.  We prefer this approach to the will-o-

the-wisp pursuit of the Federal Report's recommended

35 mg/1 on suspended solids and 5 mg/1 on settleable

solids.

-------
                                                       1658
                   William R. Day
            The report further recommends that Wyandotte
Chemicals Corporation "continue the Investigation of
satisfactory methods of disposing of chlorides, and al-
ternate methods of disposal of concentrated brines,
such as subsurface disposal."   Actually, we have
already taken more positive steps in this area.  Since
the industrial survey on which this report is based was
made, we have built and have in operation a calcium
chloride plant which, at capacity, removes as a salable
product 420,000 pounds per day of chlorides previously
discharged to the river as waste from our North Plant
Solvay Process operation.  At present, this is the only
technologically practical means for control of chlorides
from the Solvay Process operation, and it is strictly
limited by the market demand for calcium chloride.  ¥e
are investigating the possibility of subsurface disposal
for the remainder of the wastes from this process, but
consider this a long-terra project requiring the solution
of a number of technical problems in which the prospects
of success are debatable.
            An engineering study Is In progress on the
recovery and re-use of waste brine from our electrolytic
cell chlorine operation. Although we shall continue the
chloride reduction program, we must remark the Federal

-------
                                                       1659



                     William R. Day




Report's own statement that these concentrations




are "not yet significant enough to cause major inter-




ference with water use."  We shall keep trying, not




because this report is unable to decide whether chlorides




are good or bad, but because of that urge, pervasive




in the chemical industry, to convert waste products into




useful products.




            As a Detroit Industry which has been proud




of its Michigan Water Resources Commission "A" (Control




adequate ) Rating for many past years and running,  we can




state with assurance that we will continue our efforts to




maintain that rating.  We will continue to investigate and




install waste control facilities which are capable of




economical and practical achievement and which will




contribute to a useful change in river water quality.




But frankly, we harbor little hope for the attainment




of any theoretical standards which are impractical and




unproductive of identifiable results,




            I thank you.




            MR. STEIN:  Thank you, Mr. Day.




            Have you any comments, Mr. Poston?




            MR. POSTON:  No comments.




            MR. OEMING:  I have none.




            MR. STEIN:  Just one question, or two.

-------
                                                      1660
                  William R. Day
            You emphasized, through the report—and I
appreciate the practicality and the realism.   When you
talk about the calcium chloride plant which at capacity
removes a salable product of 420,000 pounds a day of
chloride previously discharged to the river, and say that
it is strictly limited by the market demand for calcium
chloride, that means when you cannot sell the salt you
do not use it, you Just put it in the river?
            MR. DAY:   No.   This means that—I think
the report mentioned something like 1,300,000 pounds
per day of chlorides, going from the corporation's plant
to the river.   We cite this because by reason of
putting in the calcium chloride plant which extracts
the calcium chloride from the 1,300,000 pounds, thereby,
when the plant is going at capacity there will be 420,000
pounds less going in the river.
            MR. STEIN:  That is the question I am asking,
if that figure is strictly limited to the market.
Supposing you cannot sell calcium chloride, you are
not going to run that plant and take out that 420,000
pounds a day?
            MR. DAY:  I think that statement, the demand
being able to take it, Is out of an abundance of pre-
caution. Right today, Mr. Stein, we cannot make enough
calcium chloride.   We ar® very happy about it.

-------
                                                      1661
                  William R. Day
            MR. STEIN:  All right; thank you; that Is
the question.
            MR. OEMING:  I would now like to call upon
Pennsalt Chemicals Corporation.   Is Mr. Tracht In the
audience ?
            MR. TRACT:   Yes.

-------
                                                        1662




                 J. ¥. Tracht








            STATEMENT OF J. ¥. TRACHT,



         PENNSALT CHEMICALS CORPORATION







            MR. TRACHT:   Mr. Chairman, conferees, members



of the Commission, and guests:



            My name is J. ¥. Tracht, and I am the cor-



porate representative of Pennsalt on air pollution



and water pollution control matters.



            This statement over the name of Mr. MeWhister,



our vice-president,  was sent in a tetter to, Mr. Oeraing



on June 4,  and the date of this is June 7.  Unfortunately,



ire did not have extra copies made for you gentlemen here,



but I shall leave my statement with the recorder.

-------
                                                          1663
                     J. W. Tracht
                               June  7)  1965


              STATEMENT of the  Pennsalt Chemicals Cor-

 poration  on  the  findings  of  the  cooperative Federal-State

 investigation of pollution in  the Michigan portions of

 the  Detroit  River and Lake Erie  as  given  in the April.

 1965 report  of the U.  S.  Department of Health, Education

 and  Welfare,  Public Health Service.


              From preliminary  study of the full report,

 our  technical people consider  this  investigation to be a

 comprehensive and well-conducted survey of the river and

 lake conditions.

              As  a matter  of  Company policy, we are in

 accord with  the  objective of reducing  the pollution in

 the  Detroit  River.   Major expenditures have been made at

 these and other  Pennsalt  locations  over the past five years

 for  installations for pollution  control.
              We  will continue  to cooperate with the Water

 Resources Commission of the  State of Michigan in the

 program to improve  the conditions in the Detroit River.

 Engineering  studies are underway on additional corrective

measures  toward  this end.

              As  regards the  specific recommendations  made

-------
                                                         1664
                     J.  W.  Tracht


in the report, we consider the limits of suspended solids

concentration of 35 milligrams per liter and of settleable

solids concentration of five milligrams per liter to be

unnecessarily severe and not practicable to realize.   The

basis for setting these recommended levels is not stated

in the report.  The following is offered to illustrate

the severity of these recommended limits.  Should the total

waste flow from all municipal treatment plants and industrial

plants contain solids concentration at these levels,  the

average concentration of suspended and settleable solids

in the Detroit River would be increased by less than  one

miligram per liter (one part per million).  This increase

would be but a small fraction of the total of suspended and

settleable solids already existing in the river above

Belle Isle.

             We ask that tJaeas recommended levels be re-

considered and that more realistic figures be established.

Any levels of concentrations so established should, of

course, take into account the conditions in the river

water reaching our plants,  both as the result of natural

runoff and of municipal and industrial wastes discharged

to the river above the Pennsalt location.



                         Original  signed by

                         G.  Me  WHISTER
                         Vice-President

-------
                                                      1665
                J. W. Tracht
            We apprfelate the opportunity of making
this statement.
            MR. STEIN: Thank you, Mr. Traoht.  Are there
any comments or questions?
            MR. POSTON:  Mo questions.
            MR. OEMZNO:   I have none.
            MR. STEIN:  Thank you for the statement.
            Mr. Oemlng?
            MR. OEMING:  Now, Mr. Chairman, I have one
letter that I would like to request be entered Into the
record.
            This  Is addressed to me at the Water Re-
sources Commission, from the E. I. duPont De Nemours &
Company, by the plant manager, and I think this con-
stitutes the only statement or comment that they have.
            MR. STEIN: Without objection, that will
be entered In as  If read.

-------
                                                         1666
           E.  I. DU PONT DE NEMOURS & COMPANY




                   Incorporated




                  P. 0. Box 4508




                 Ecorse 29, Mich.









                              June 10, 1965








Water Resources Commission




200 Mill Street




Station B




Lansing, Michigan 48913




Attention: Loring F. Oeming, Executive Secretary









Gentlemen:




             Thank you for your letter of May 10, 1965




advising us of the reconvened conference on the Detroit




River on June 15, 19^5.  We do not plan to submit any




statement but we will be following the progress of the



conference with interest.




             We are aware of the fact that the pH of




our effluent stream is lower than the limit of 5.8 which




has been set by your office.  This matter is under in-




tensive study and we are working on plans for alleviating

-------
                                                        1667
this condition.  We will then get in touch with you




promptly to review the problem and our proposals for




meeting it.









                    Very truly yours,




                    C. LEISURE




                    Plant Manager

-------
                                                       1668
            MR. OEMING:  All right.   Now, Mr.
Chairman, this represent* all the industries  in the
Detroit area that have responded or indicated to me
their desire to present a statement at  this conference.
            As I Informed you earlier,  by a letter  of
Harch 10 to all of the industries mentioned in  the
report, they were informed that they could have the oppor-
tunity to make a statement; and I have  no others at
this time who have told me that they so wished.
            MB. STEIN:  Mr. Oeming, let me ask  you:
Do you think if we started at 9:30 we could complete
the presentation by noon tomorrow, or would you think
we would need more time.      I would like your
judgment on this.
            MR. OEMINO:  My best guess  is that  if you
started at 9:30 that you ought to be able to  finish by
12:30.
            MR. STEIN:   All right, that would  be fine.
We shall stand recessed until 9:30 tomorrow,  meeting in
the lecture hall in this building. Enter through the main
entrance and follow the signs.
            (Conference adjourned until June  18, 1965,
at 9:30 a. m.)
                           * U. S. GOVERNMENT PRINTING OFFICE : 1965 O - 792-121 (Vol  V)

-------