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
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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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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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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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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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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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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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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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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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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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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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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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SECTION II
PROGRAM AND ACHIEVEMENTS
THE ISSUE
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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.
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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
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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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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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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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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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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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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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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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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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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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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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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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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
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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
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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
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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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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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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
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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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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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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-
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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
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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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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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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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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
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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
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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
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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
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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
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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. -
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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.
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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,
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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
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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
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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
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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.
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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.
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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
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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
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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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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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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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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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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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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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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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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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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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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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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
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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
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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
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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
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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
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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-
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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
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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,
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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
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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-
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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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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-
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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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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.
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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.
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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."
# •*
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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.
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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
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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-
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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
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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.
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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
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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
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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,
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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
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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
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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
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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,
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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
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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
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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.
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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.
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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
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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,
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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
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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.
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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
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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?
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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
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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.
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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.
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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
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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
K
K
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.
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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
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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
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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.
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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
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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.
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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
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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.
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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.
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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
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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)
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