NVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
REPORT ON
EVALUATION OF WASTE SOURCES
in InL
MEMPHIS, TENNESSEE AREA
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NATIONAL FIELD INVESTIGATIONS CENTER-DENVER
DENVER, COLORADO
AND
REGION IV, ATLANTA, GEORGIA
AUGUST 1972
CLEA
/ATE]
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
REPORT ON
EVALUATION OF WASTE SOURCES
IN THE
MEMPHIS, TENNESSEE AREA
NATIONAL FIELD INVESTIGAIONS CENTER-DENVER
DENVER, COLORADO
and
REGION IV, ATLANTA, GEORGIA
AUGUST 1972
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TABLE OF CONTENTS
Page
GLOSSARY OF TERMS ' vii
INTRODUCTION 1
DESCRIPTION OF AREA 5
PLANNED WASTE TREATMENT IN THE CITY OF MEMPHIS 7
SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS 8
THE BUCKEYE CELLULOSE CORPORATION 17
CHAPMAN CHEMICAL COMPANY .................. 24
DAY & NIGHT COMPANY
PAYNE COMPANY, COLLIERVILLE, TENNESSEE 30
DELTA REFINING COMPANY 35
E. I. DUPONT DE NEMOURS & COMPANY (INC.) . . . . 43
THE FIRESTONE-TIRE & RUBBER COMPANY 50
W. R. GRACE & COMPANY, AGRICULTURAL CHEMICALS GROUP 59
HUMKO PRODUCTS CHEMICAL DIVISION (POPE STREET) 67
HUMKO PRODUCTS CHEMICAL DIVISION (THOMAS STREET) ....... 73
HUNT-WESSON FOODS ' 81
ICI AMERICA INC. (FORMERLY ATLAS CHEMICAL) 88
INTERNATIONAL HARVESTER COMPANY,
FARM EQUIPMENT DIVISION 93
KIMBERLY-CLARK CORPORATION, MEMPHIS MILL 99
NAVAL AIR STATION MEMPHIS (84),
MILLINGTON, TENNESSEE .... 107
CITY OF MILLINGTON MUNICIPAL TREATMENT SYSTEM Ill
THE QUAKER OATS COMPANY 116
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TABLE OF CONTENTS (CONT.)
Page
JOS. SCHLITZ BREWING COMPANY 124
SMALLEY MAGNESIUM COMPANY, INC.
DIVISION OF PIPER INDUSTRIES, INC.
COLLIERVILLE, TENNESSEE 130
VALLEY PRODUCTS COMPANY 138
APPENDICES
A APPLICABLE WATER QUALITY REGULATIONS
B CITY OF MEMPHIS ORDINANCE NO. 460
C EPA SURVEY CORRESPONDENCE
ii
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LIST OF FIGURES
Figure No. Title Follows Page
1 Memphis, Tennessee, Vicinity Map 1
B-l The Buckeye Cellulose Corp.
Sampling Stations B-19-A, B-19-B 18
C-l Chapman Chemical Company & Valley
Products, Memphis, Tennessee
Sampling Stations C-22-A,
C-22-B, VP-23 25
DN-1 Day and Night Manufacturing Company,
Memphis, Tennessee
Sampling Station DN-16 31
DR-1 Delta Refining Company, Memphis,
Tennessee, Sampling Station DR-12 36
DP-1 E. I. duPont de Nemours and Company,
Memphis, Tennessee
Sampling Station D-9 44
F-l The Firestone Tire and Rubber
Company, Memphis, Tennessee
Sampling Stations F-18-A, F-18-B 51
G-l W. R. Grace and Company, Memphis
Tennessee, Sampling Station G-10 61
HP-1 HumKo (Pope), Flow Diagram 68
HT-1 HumKo Products Thomas Street,
Memphis, Tennessee, Sampling
Stations HT-ll-A, HT-ll-B 74
HW-1 Hunt-Wesson Foods, Memphis,
Tennessee, Sampling Station HW-13 81
ICI-1 ICI America, Inc., Memphis,
Tennessee, Sampling Station AC-20 89
IH-1 International Harvester, Memphis
Tennessee, Sampling Station IH-17 94
K-l Kimberly-Clark Corp. Memphis,
Tennessee, Sampling Station KC-14 101
iii
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LIST OF FIGURES (CONT.)
Figure No. Title Follows Page
M-l Naval Air Station Memphis (84)
Wastewater Treatment System
Sampling Station M-7 108
CM-1 City of Millington Wastewater
Treatment Plant, Millington,
Tennessee, Sampling Station CM-8 112
Q-l The Quaker Oats Company, Memphis
Tennessee, Sampling Station QO-15 117
S-l Jos. Schlitz Brewing Company,
Memphis, Tennessee
Sampling Station S-24 125
SM-1 Smalley Magnesium Company,
Collierville, Tennessee
Sampling Stations .PB-25-A, PB-25-E 133
C-l Chapman Chemical Company & Valley
Products, Memphis, Tennessee
Sampling Stations C-22-A,
C-22-B, VP-23 139
iv
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LIST OF TABLES
Table No. Title
1 Waste Sources Surveyed, Memphis,
Tennessee Area 3
2 Summary of Waste Loads 9
3 Summary of Pollution Sources and
Refuse Act Status 14
B-l Summary of Field Data and Analytical
Results, The Buckeye Cellulose Corp. 20
CC-1 Summary of Field Data and Analytical
Results, Chapman Chemical 28
DN-1 Summary of Field Data and Analytical
Results, Day & Night Company 33
DR-1 Delta Refining Company, Discharge
Analyses Reported to the Tennessee
Water Quality Control Board 38
DR-2 Summary of Field Data and Analytical
Results, Delta Refining Company 40
DP-1 Summary of Field Data and Analytical
Results, E. I. duPont de Nemours
& Company (Inc.) 46
F-l Summary of Field Data and Analytical
Results, Firestone Tire and Rubber Company 53
G-l Summary of Field Data and Analytical
Results, W. R. Grace & Company,
Agricultural Chemicals Group 64
HP-1 Summary of Field Data and Analytical
Results, HumKo Products Chemical
Division (Pope Street) 70
HT-1 Summary of Field Data and Analytical
Results, HumKo Products (Thomas Street) . 76
HW-1 Summary of Field Data and Analytical
Results, Hunt-Wesson Food? 85
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LIST OF TABLES (CONT.)
Table No. Title Page
ICI-1 Summary of Field Data and Analytical
Results, ICI America, Inc. 91
IH-1 Summary of Field Data and Analytical
Results, International Harvester Company 96
K-l Kimberly-Clark Corporation, Data Submitted
to the Tennessee Water Quality Control
Board 101
K-2 Summary of Field Data and Analytical
Results, Kimberly-Clark Corporation 104
M-l Summary of Field Data and Analytical
Results, Naval Air Station Memphis (84) 109
CM-1 Summary of Field Data and Analytical
Results, City of. Mi.llington
Wastewater Treatment Plant 114
Q-l . .Analyses of the Quaker Oats Discharge
to the Wolf River, Submitted to the
Tennessee Water Quality Control Board 118
Q-2 Summary 'of Field Data and Analytical
Results, The Quaker Oats Company
Discharge to Wolf Interceptor 121
S-l Summary of Field Data and Analytical
Results, Jos. Schlitz Brewing Company 127
SM-1 Summary of Field Data and Analytical
Results, The Smalley Magnesium Company 135
VP-1 Summary of Field Data and Analytical
Results, Valley Products Company 141
vi
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GLOSSARY OF TERMS
BOD - Biochemical Oxygen Demand (Five-day @ 20°C)
COD - Chemical Oxygen Demand
DO - Dissolved Oxygen
Kj-N - Kjeldahl Nitrogen as Nitrogen
NH -N - Ammonia as Nitrogen
NO--NO -N - Nitrite-Nitrate as Nitrogen
Org N - Organic Nitrogen
Total P - Total Phosphorus
TOG - Total Organic Carbon
cfs - flow rate given in cubic feet per second
gpm - flovr rate given in gallons per minute
mgd - flow rate given in million gallons per day
mg/1 - concentration given in milligrams per liter
yg/1 - concentration given in micrograms per liter
pmhos/cm - unit of specific conductance (mho the inverse
of the standard unit of electrical resistance, the
ohm) measured over a 1-centimeter distance, conven-
tionally made at 25°C.
vii
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INTRODUCTION
In southwestern Tennessee the Mississippi River is a navigable,
interstate stream [Figure 1]. Three of its tributaries, Nonconnah Creek
and the Loosahatchie and Wolf Rivers, are degraded by industrial and
domestic wastewater as they flow through the metropolitan area of Memphis,
Tennessee.
Region VI and Region IV offices of the Environmental Protection
Agency (EPA) requested that the National Field Investigations Center-
Denver (NFIC-D) undertake an evaluation of waste sources and water
quality conditions in the Memphis metropolitan area. A survey was
conducted -in February 1972, with.the following objectives: .
1. To evaluate the wastewater discharges from major industries
in the Memphis metropolitan area and to use this information
. in evaluating the U.S. Army Corps of Engineers Refuse Act
permit applications;
2. To evaluate the water quality of the Mississippi River upstream
and downstream from the wastewater discharges of the Nonconnah
?
and Wolf Interceptors and to determine whether or not water
quality standards are being violated;
3. To develop recommendations for appropriate action to abate water
pollution.
Pollution of interstate streams is subject to abatement under pro-
visions of the Federal Water Pollution Control Act of 1965 (FWPCA), as
amended (33 U.S.C. 466 et. seq.). .Water quality standards applicable
to the Mississippi River and interstate tributaries in the metropolitan
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Shelby County
County Mississipp
10
SCALE IN MILES
Figure 1 MEMPHIS,TENNESSEE Vici.ity Nap
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Memphis area have been established by the States of Arkansas, Mississippi,
and Tennessee and approved as Federal standards pursuant to the provisions
of the FWPCA [Appendix A]. The Rivers and Harbors Act of 1899 (33 U.S.C. 407)
prohibits the discharge of industrial wastes (refuse) into navigable waters
of the United States or into any tributary of a navigable water whereby
refuse matter flows into, such navigable water, without a permit from the
U. S. Army Corps of Engineers [Appendix A].
Permits to discharge into surface streams are required by the State
of Tennessee [Appendix A], In addition, the City of Memphis has an
ordinance, No. 460, on the Regulation of Sewer Use [Appendix B].
The waste source survey included determination of water supplies,
types of raw materials, and process additives used by industries, kinds
of products manufactured or synthesized, and sufficiency of 'wastewater
treatment processes. Effluents of nineteen industries, one military
installation and one municipal wastewater treatment plant were evaluated.
Prosecution of two industries, for 1899 Refuse Act violations, was
recommended in two separate reports prepared, earlier. This report recom-
mends those measures necessary, including Refuse Act litigation, to
abate pollution attributable to the remaining nineteen sources. [Indus-
tries and sampling locations included in this report are presented in
Table 1.]
Included in this report is a section on each waste source' that was
evaluated. The format used for presenting information on each waste
source is as follows:
A. Background Information ' includes general, historical, and
contacts;
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TABLE 1
WASTE SOURCES SURVEYED
MEMPHIS, TENNESSEE AREA
Sampling Location Station Name
The Buckeye Cellulose Corporation B-19
Chapman Chemical Company C-22
Day & Night Company DN-16
Payne Company, Collierville, Tennessee
Delta Refining Company DR-12
E. I. duPont deNemours & Company (Inc.) D-9
The Firestone Tire & Rubber Company F-18
W. R. Grace & Company, Agricultural Chemicals Group G-10
HumKo Products Chemical Division (Pope Street) HP-21
HumKo Products Chemical Division (Thomas Street) - HT-11
Hunt-Wesson Foods HW-13
ICI America Inc. (formerly Atlas Chemical) AC-20
International Harvester Company, Farm Equipment Division IH-17
Kimberly-Clark Corporation, Memphis Hill KC-14
Naval Air Station Memphis (84) , Millington, Tennessee M-7
City of Millington Municipal Treatment System DCM-8
The Quaker Oats Company QO-15
Jos. Schlitz Brewing Company . S-24
Smalley Magnesium Company, Inc. PB-25
Division of Piper Industries, Inc., Collierville, Tennessee
Valley Products Company VP-23
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B. Waste Sources and Treatment includes type of treatment
system and diagram of sampling and discharge locations;
C. Discussion of In-Plant Evaluation and Results includes
information on evaluation procedure, data from field and
chemical analyses, waste loads and their effects on the
receiving waters^ and visual observations;
D. Summary and Conclusions; and
E. Recommendations
Correspondence associated with the implementation of the survey is found
in Appendix C.
Assistance and support in the conduct of .this investigation was
provided by the following:
Enforcement Office, EPA, Region IV, Atlanta, Georgia;
Memphis and Shelby County Health Department; and
Tennessee Water Quality Control Board.
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. DESCRIPTION OF AREA
The Memphis metropolitan area, with a population of about 800,000,
is a large industrial and agricultural center located on the Mississippi
River in southwestern Tennessee. Almost all of this area is located in
Shelby County, Tennessee with a small suburban area extending south-
ward into DeSoto County, Mississippi. West Memphis, across the Mississippi
River in Crittenden County, Arkansas, is also part of this metropolitan
area [Figure 1], Other suburban and nearby (Tennessee) communities
include Woodstock, Millington, Ellendale, Arlington, and Collierville.
. A number of diversified industries in the area are important to
the economy of the tri^-state region. ^Products manufactured include beer,
vegetable, oils., paper products, animal feeds, agricultural and industrial
chemicals, pesticides, refinery products, farm machinery, heating and air
conditioning equipment, automobile tires, and textile and wood products.
In contrast to the hilly, urbanized areas of the City of Memphis
(situated on bluffs), the valleys of these tributaries (Loosahatchie and
Wolf Rivers and Nonconnah Creek) are low-lying and subject to flooding,
during high-flow stages, by backwater from the Mississippi. A levee
system has been constructed along the tributaries and along the Mississippi
River to alleviate flooding. An extensive storm drainage system has
been constructed, with pumping stations to lift storm drain flow over the
levees into the streams during high water stages. Many of the indus-
tries are located along the streams in areas protected by this levee system.
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6
Wolf River and Nonconnah Creek are interstate streams xdLth head-
waters in the State of Mississippi. Having a drainage-area of approxi-
mately 770 squares miles, the Wolf River is the largest tributary to
the Mississippi River in this area. Stagnation occurs in the lower
reach of the Wolf River during high stages on the Mississippi. Cypress
Creek and Leath and Workhouse Bayous are small tributaries to the Wolf
River draining urban and industrial areas.
The Loosahatchie River has a drainage area of several hundred
square miles. Big Creek, with a drainage area of about 137 square
miles, is the main tributary of the Loosahatchie.
Nonconnah Creek is a small stream with low flow. In its lower reach,
much of the flow consists of industrial wastes, sanitary sewer overflows,
and urban runoff. Nonconnah Creek discharges into McKellar Lake, a
slack-water arm of the Mississippi River. The lake is located in an old
channel of the river and is connected to the river by Tennessee Chute.
Backwater conditions created by high stages in the Mississippi frequently
produce stagnation in the lake. Cane Creek is a small tributary to
Nonconnah Creek draining an industrial area.
At Memphis the average flow of the Mississippi River is approxi-
mately 460,000 cubic feet per second (cfs). Extremes in the flow range
from 79,200 to more than one million cfs. (The low flow of record
occurred prior to the construction of the various large upstream reser-
voirs that now provide flow regulation. Such a low flow is not expected
to occur again.) High flows usually occur in the winter and spring
months, with lowest flows coming in the late summer.
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PLANNED WASTE TREATMENT IN THE CITY OF MEMPHIS
Presently the City of Memphis, has no municipal waste treatment system.
Municipal and industrial wastes collected by the Nonconnah and Wolf Inter-
ceptors are discharged, untreated, directly into the Mississippi River.
Two large secondary treatment plants (North and,South) are planned
to treat the wastewater collected by the Memphis regional wastewater inter-
ceptor system. The South plant, with a design capacity of 85 mgd, is
under construction and is scheduled for completion in July, 1974. Con-
struction of the North plant, with a design capacity of 135 mgd, is
scheduled to begin about January 1973, with completion in December 1976.
Delays in this schedule are evident in that lead elements such as plans
and specifications are not completed as of September .1972. A large-scale
regional interceptor system is now under construction in order to serve
these planned waste treatment plants. As interceptors are completed,
most industries are connecting to the system for disposal of industrial
wastes. All wastes collected by the Memphis Interceptor System are
discharged untreated into the Mississippi River. Few industries provide
any pretreatment of their wastes prior to discharge to the interceptor
system.
In 1970, about 90 mgd of mixed municipal and industrial wastes were
discharged into the Mississippi River from six large Memphis interceptor
outfalls. The Wolf Interceptor, to be serveJ by the North plant, and the
Nonconnah Interceptor, to be served by the South plant, are the two major
receivers of industrial wastes. An additional 43 mgd of industrial wastes
were discharged to tributary streams in the Memphis metropolitan area.
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' SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
A. CONCLUSIONS
Conclusions regarding each of the nineteen sources evaluated are
presented in the individual report sections. [A summary of the loads
contributed by the sources is presented in Table 2.] These conclusions
are summarized, as follows:
1. Industries that discharge inadequately treated or untreated
wastewaters into the Mississippi River, a navigable stream, either
directly or through the Wolf or Nonconnah Interceptors, include the
following:
The Buckeye Cellulose Corporation
The Firestone Tire & Rubber Company
HuniKo Products Chemical Division (Thomas Street)
International Harvester Company
The Quaker Oats Company
Jos. Schlitz Brewing Company
Valley Products Company
Average combined daily loads (in pounds) discharged by these firms
include:
139,000 BOD 116 .... Chromium
348,000 COD 17 .... Lead
129,000 TOC ' 20 .... Phenolic Materials
107,000 Suspended Solids 15 .... Copper
51,000 Oil & Grease 55 .... Zinc
2. Industries that discharge inadequately treated or untreated
wastewaters into the Wolf River, a tributary to a navigable stream, are:
The Firestone Tire & Rubber Company
HuinKo Products Chemical Division (Pope Street)
(Thomas Street)
ICI America, Inc. (formerly Atlas Chemical Company)
Kiirberly-Clark Corporation
The Quaker Oats Company
Smalley Magnesium. Company
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TABLE 2
SUrS-TARY OF WASTE LOADS
Company
Buckeye Cellulose Corp.
Process Water
Cooling Water
Day & Night Mfg.
Delta Refining
£. I. duPont
Firestone Tire & Rubber
Process Water
Cooling Water
'J . P.. Grace
HuriKo Products (Pope St.)
HumKo Products (Thomas St.)
Pretreated
Untreated
Hunt- Wesson Foods
ICI America
International Harvester
BOD*'
28,700
193
556
3,280
122
11,400 '
65,700
90,800
1,000
226
425
Suspended
Solids
34,500
150
866
184
7,000
5,860
6,020
557
3,980
43,500
53,400
2,020
34
2,830
Oil &
Grease
2,500
24
72
1,000
1,100
210
3,700
47,000
62,000
400
80
Total
Chromium Zinc . Cyanide'
9.2
0.47
2.3 2.6
1.07 .43
2.7 3.2 14
*
15.9
6.2
23.8 9.1 0.7
1.6
100 24.1
18.5 15.2
0.77
15.9 1.6
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TABLE 2 (continued)
SUMMARY OF WASTE LOADS'
Comp any
Kiir,berly--J ark
Naval Air Station Memphis
City of l-'illington
Quaker Oats
Jos. Schlitz Brewing
Sir.alley Magnesium Co.
Rinse 'Water
Chromium Treatment Pond
BOI^7
4,780
330
363
29,000
10,100
770
Suspended
Solids
12,700
1,050
454
17,000
3,460
74
Oil &
Grease
1,800
390
120
290
140
5
Total
Chromium
14.3
0.4
0.1
0.2
0.08
16.8
Zinc Cyanide
1.47
. 0.48
3.9
1.03
Valley Products
1,750
289
200
0.17
Loads 'are in Ib/day for all parameters,
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11
The average combined daily loadings (in pounds) discharged by these
firms include:
108,000 BOD 61 .... Phenolic Materials
63,000 TOC 35 .... Chromium
161,000 ...... COD 38 .... Zinc
76,000 Suspended Solids 16 .... Lead
63,000 Oil's Grease"
3. Two industries, W. R. Grace and Company and E. I. duPont de
Nemours and Company, discharge inadequately treated wastewaters to the
Loosahatchie River, a tributary of a navigable stream. The average com-
bined daily loading (in pounds) discharged by the two firms are:
120 .... BOD 1,280 .... Organic Nitrogen
1,980 .... TOC 1,990 .... Ammonia
' 3,390 .... COD 15 .... Cyanide
7,600 .... Suspended Solids 12 .... Zinc
1,200 .... Oil & Grease 27 .... Chromium
5 .... Lead
Ammonia, cyanide, zinc, and other metals in the DuPont discharge are
toxic to the fish and aquatic life of the river, and contribute to
*;V
violations of the water quality criteria.
4. Hunt-Wesson Foods and Delta Refining Company discharge inadequately
treated wastewaters into Nonconnah Creek, a stream that flows into f-fcKellar
Lake (a Mississippi River backwater). Chapman Chemical Company discharges
into the creek, through ditches on Company property, but contributes less
than 80 Ib/day of TOC and COD. However, the Chapman effluent contains
substantial quantities of Ramrod and Atrazine as \>7ell as other toxic
organic chemicals (the 350 lig/1 average concentration of Ramrod consti-
tuting a violation of the effluent level of 350 pg/1 set by the Memphis
* Excludes lead from The Firestone- Tire and Rubber Company discharge
F-18-B.
>'c*Ger.eral Water Quality Criteria for the Definition and Control of
Pollution iA the Waters of Tennessee.
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12
and Shelby'County Health Department). The average daily loadings (in
pounds) in the discharges are as follows:
1,550 .... BOD "470 . . . . Oil & Grease
6,220 . . . . TOC 93 .... Phenolic Materials
3,490 .... COD 0.53 .... Ramrod
0.20 . . . . Atrazine
*
Nonconnah Creek is classified as suitable for fish and aquatic life.
The waste loads discharged by these industries are detrimental to the
uses for which the stream is classified..
5. Industries which now discharge or plan to discharge liquid
wastes to the Memphis wastewater collection system, and which do not
meet pretreatment requirements of Memphis Ordinance No. 460 include
the following:
The Buckeye Cellulose Corporation
The Firestone Tire & Rubber Company
HumKo Products Chemical Division (Thomas Street)
(Pope Street)
Hunt-Wesson Foods
ICI America, Inc.
Kimberly-Clark Company
The Quaker Oats Company .
Jos. Schlitz Brewing Company
Smalley Magnesium Company
Valley Products Company
6. Construction of the South Plant is on schedule; however, the
.progress of the construction of the North Plant is considerably behind
schedule. Those industries whose discharges xvill reach the South Plant
must provide pretreatment consistent with City Ordinance No. 460 and
capability of the South Plant to adequately treat the industrial wastes.
Industries from which industrial wastes will be treated by the North
Plant must provide best practicable treatment prior to discharge to the
General Water Quality Criteria for the Definition and Control of
Pollution in the Waters of Tennessee.
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13
interceptor1- system in order to protect the receiving waters until the
North Plant is completed four to six years hence.
7. The discharges of inadequately treated or untreated wastes, as
enumerated above, to the Mississippi River and Wolf Fiver, both navi-
gable streams, and to Nonconnah Creek and the Loosahatchie River, both
tributaries to a navigable stream, are violations of Section 407, Rivers
and Harbors Act of 1899 (33 U.S.C.: 401-411). [The pollution control
facilities and the Refuse Act permit status of each source evaluated are
provided in Table 3.]
B. RECOMMENDATIONS '
Specific recommendations for each source of pollution are presented
in the individual report sections. These-recommendations -are summarized
as follows:
1. Recommendations were made, in the case of each Refuse Act vio-
lation, that a satisfactorily documented.commitment, including an imple-
mentation schedule, to the attainment of best'practicable treatment or
pretreatment in the case of discharges to the South Plant, be provided
by the industry. In the absence of such commitment, prosecution for
violation of the Refuse Act is recommended. The industries to which
this recommendation applies are:
The Buckeye Cellulose Corporation
Delta Refining Company
E. I. duPont de Nemours Company (Inc.)
The Firestone Tire & Rubber Company
W. R. Grace & Company
HuniKo Products Chemical Division (Pope Street)
(Thomas Street)
Hunt-Wesson Foods
ICI America Inc.
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TABLE 3
SUMMARY OF POLLUTION SOURCES
AND REFUSE ACT STATUS
Tame of Waste Source
The Buckeye Cellulose
- Present Treatment '
Stream. 3-19-A Process Waste
Adequate
No
Violation
of Refuse Act
Yes
Receiving Stream
Wolf Interceptor-North Treatment Plant
Permit
Application
Filed
No
Corporation
Chapman Chemical Company
Day & Night Company
Payne Company
Delta Refining Company
E. I. duPont de Nemours &
Company (Inc.)
The Firestone Tire & Rubber
Company
W. R. Grace & Company
Agricultural Chemicals Group
HumKo Products Chemical
Division (Pope Street)
Segregation only
Stream B-19-B Cooling Water No
None
Limestone Bed neutralization No
C-22-A
carbon filter C-22-B
None No
API separator, Air flotation, No
Two holding ponds
Segregation, neutralization, No
settling pond
Stream F-18-A Process Waste No
None
Stream F-18-B Cooling Water No
None
Neutralization and settling No
pond with oil skimmer
pH Control, air flotation No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Cypress Creek - Wolf River Yes
Nonconnah Creek Yes
City of Collierville and Wolf River . No
i
Nonconnah Creek Yes
Loosahatchie River Yes
Wolf Intercptor-North Treatment Plant No
Leath Bayou - Wolf River Yes
Loosahatchie River Yes
Workhouse Bayou - Wolf River Yes
North Treatment Plant
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TABLE 3 (Continued)
SUMMARY OF POLLUTION SOURCES
AND REFUSE ACT STATUS .
Name of Waste Source
HicnKo Products Chcra.'.cal
Division iTuomas otreet)
Present Treatment
Stream KT-ll-A
None
Stream HT-ll-B
Adequate
No
..No
Violation
of Refuse Act
Yes
Yes
Receiving Stream
Cypress Creek - Wolf River
Wolf Interceptor-North Treatment Plant
Permit
Application
. Filed
Yes
No
Hunt-Wesson Foods
ICI America, Inc.
(formerly Atlas Chemical)
International Harvester
Company .
Farm Equipment Division
Kiraberly-Clark Corporation
Memphis Mill
Naval Air Station Memphis (84)
City of Millington Municipal
Treatment System
The Quaker Oats Company
Jos. Schlitz Brewing Company
Smalley Magnesium Company, Inc.
Division of Piper
Industries, Inc.
Valley Products
pH Control, air flotation
Grease Trap No
Grease trap No
Neutralization No
In-Plant fiber filter No
Secondary biological system
Secondaiy biological system
Cooling water - Settling pond
Process water - None
In-plant controls
Stream PB-25-A Chromium
reduction, settling pond
Stream PB-25-B Rinse Water Only
None
None No
Yes
Yes
Yes
Yes
Cane Creek - Nonconnah Creek-South
Treatment Plant
Workhouse Bayou - Wolf River
North Treatment Plant
Mississippi River
Wolf River
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Big Creek - Loosahatchle River
! Big Creek - Loosahatchie River
Wolf River
Wolf Interceptor - North Treatment Plant
Nonconnah Interceptor - South Treatment
Plant
Wolf River
Wolf River
Yes
Yes
No
No
No
Yes
Nonconnah Interceptor - South Treatment
Plant
No
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16
International Harvester Company
Kinberly-Clark Company
The Quaker Oats Company
Jos. Schlitz Brewing Company
Smalley Magnesium Company
Valley Products Company
2. It is recommended that the discharge permits, to be issued by
the U. S. Army Corps of Engineers to discharges in the Memphis area,
limit discharges of those pollutants now causing violation of the Refuse
Act of 1399 to concentrations consistent with the best practicable
treatment and water quality standards for the Mississippi River.
3. A recommendation was made .that EPA, in cooperation with the
Tennessee Water Quality Control Board and the Memphis and Shelby County
Health Department, monitor the. quality of each wastewater discharge to
ensure compliance with applicable- criteri-a. -
-------
17
THE BUCKEYE CELLULOSE CORPORATION.
2899 JACKSON AVENUE
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The Buckeye Cellulose plant, located at 2899 Jackson Avenue, manu-
factures chemical intermediates for the plastics, viscose and paper-use
industries. Basically, the Company treats the cellulose fibers through
cleaning, dissolving, bleaching and finishing operations. Buckeye also
manufactures laminar sections that are converted into laminated print-
circuit boards used in the electronics industry. The major raw materials
incoming to this plant include cotton linters, cotton seed, and occasionally,
intermediate (thin) paperboard sheeting. Paperboard is readily dissolved
in solution and this lignin-cellulose combination is used in the manu-
facture of "rag content" specialty papers. Other rav? materials are
sulfuric acid, caustic soda, chlorine, acetone, and acetic acid.
Chronology of Contacts
On October 6, 1971, E. J. Struzeski, Environmental Protection Agency
(EPA), National Field Investigations Center-Denver (NFIC-D), and Hugh
Teaford, Memphis and Shelby County Health Department, conducted a pre-
liminary inspection of the Buckeye Cellulose plant. R. T. Turner, Plant
Manager, and J. Page, Assistant Manager, were apprised of the purpose of
the survey. Mr. Turner cooperated with the HP A .and granted permission
to sample the plant effluent.
-------
18
During January 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter to Mr. Turner [Appendix C], confirming the date
of the investigation and requesting written permission to sample. This
method was taken to advise Buckeye Cellulose that information provided,
as well as data regarding discharges from the premises of the Company,
may be used as evidence against the firm in abatement proceedings under
the applicable laws.
On February 2, 1972, Mr. Turner, in reply to Mr. Barlow's letter,
granted permission to sample [Appendix C].
At the time of the survey Mr. Turner indicated it was necessary for
a Buckeye Cellulose employee to accompany NFIC-D personnel during the
time they were in the plant to sample the effluent.
B. WASTE SOURCES AND TREATMENT
The major waste stream (B-19-A) [Figure B-l] originates in the pro-
cessing area and has been in contact with most of the raw materials.
This stream is dark in color and contains large amounts of organic
materials. Process x^astes are combined and discharged through a Parshall
flume into the Wolf Interceptor. Waste treatment is not being provided.
An application for a permit to discharge has not been filed with the
U. S. Army Corps of Engineers for this discharge. The second discharge
(B-19-B) is a stream that contains cooling water and filter washwater.
In the plant operation there are eight filters, and each is backwashed
six to eight minutes, three times per day. This effluent is discharged
without treatment to a ditch leading into Cypress Creek, thence to the
Wolf River.
-------
B-19-B
MANHOLE
THE BUCKEYE
CELLULOSE CORP,
TO WOLF
RIVER INTERCEPTOR
A B-19-A
PARSHALL FLUME
LEGEND
A SAMPLING STATIONS
NOT TO SCALE
Figure B1 The Buckeye Cellulose Corp. Sampling Stations B-19-A, B-19-B
-------
19
An application for a permit to discharge has been filed with the
U.S. Army Corps of Engineers for the second discharge.
C. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure
A SERCO automatic sampler was used to collect samples of the process
waste discharge (B-19-A) to the Wolf Interceptor [Figure B-l] on Company
property at a point upstream of the Parshall flume. Beginning on February
22 and ending -February 25, 1972, a sample was collected every hour for
three 24-hr periods. At the end of each period the samples were composited
t
and aliquoted into the appropriate containers for shipment and analyses.
They were then transported to a mobile EPA laboratory, located in Memphis,
or shipped air freight-express to the NFIC-D laboratories (EPA). Whenever
possible, split samples were provided to personnel of The Buckeye Cellulose
Corporation. Grab samples were collected twice daily in order to obtain
temperature, pH, and conductivity and once daily for oil and -grease
analyses. Flow readings were taken from Company flow meters.
Grab samples were taken from the cooling-water discharge (B-19-B)
both during the filter backwash periods and during the time the discharges
contained only cooling water. Flow from this discharge was measured
by EPA personnel.
Discussion of Results
The proceso-wr.ter discharge (B-19-A) to the. City interceptor ranged
between 8.9 and 10.5 mgd [Table B-l]. The pH of the discharge ranged
between 9.9 and 11.0. The high pH is in "violation of Memphis Ordinance
-------
TABLE B-l
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
THE BUCKEYE CELLULOSE CORPORATION
2899 JACKSON AVENUE
February 22-25, 1972
Parameter-
Flow, mgd
pH
Temperature, °C
Conductivity,
jamhos /.cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil and Grease
Turbidity, JTU
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
8.9-10.5
9.9-11.0
28.5-34.5
1,700-2,100
320-400
680-1,160
1,610-1,780
330-45CP-', ,
2 160-2 26,0
23-49-'
20-220
0.0 3-0. 04
<0 .01
0.10-0.14
<0.01-
<0.03^-'-0.03
B-19-A
Average
360
693
1,700
420
2,210
32
88
0.04
0.12
<0.03
Load
Ib/day
28,700
75,700
136,000
34,500
183,000
2,500
2.9
9.2
Range
5.8-9.7
22.5-31.0
60-260
3-6
22-32
8-21
129-310
- /
55-20CF-'
0.02-0.06
<0. 01-0. 01
0.03-0.09
Q /
<0. 03^-' -0.09
B-19-B
Average
1.12
5
25
16
218
128
.0.03
<0.01
0.05
<0.07
Load
Ib/day
47
233
150
2,030
0.28
0.47
aj All units are in.mg/1 except as noted.
b_/ Range of two values.
cj Samples were analyzed after maximum preservation time had expired.
d/ Minimum detectable limit.
NJ
o
-------
21
No. 460 whi'ch prohibits the discharge of wastewater having a pH greater
than 9.5.
The wastewater contained an average of 28,700 pounds of BOD; 75,700
pounds, TOG; 136,000 pounds, COD; and 2,500 pounds of oil and grease.
This discharge is contributing to the degradation of the receiving waters
of'the Mississippi River downstream from Wolf Interceptor.
The reach of the Mississippi River that receives this discharge
from the Wolf Interceptor is.classified by the Tennessee Water Quality
Control Board for industrial uses, fish and aquatic life, irrigation,
livestock x^atering, wildlife, and navigation. Under the criteria
established by the State, there shall be no substances added to the
waters that xjill produce toxic conditions.
The second discharge (B-19-B) had a variable flow because of inter-
mittent filter backwash; however, the effluent averaged approximately
1.12 mgd and had a pH range of 5.8 to 9.7. The chemical and organic
contents were not large; COD and TOC levels averaged 25 and 5 mg/1,
respectively. Although the solids concentration was low, the turbidity
averaged 128 JTU. During the period of the survey .this discharge did
not exert a significant pollutional load on Cypress Creek.
D. , SUMMARY AND CONCLUSIONS
1. The Buckeye Cellulose Corporation discharges an average daily
loading of 28,700 pounds of BOD; 75,700 pounds, TOC; 136,000 pounds,
COD; and 2,500 pounds of oil and grease into the Wolf Interceptor. The
Wolf Interceptor discharges into the Mississippi River, a navigable strenri.
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22
2. There is no treatment by The Buckeye Cellulose Corporation of
the wastewater entering the Wolf Interceptor. The pH fluctuation and
the chemical and organic loading contribute to the violation of the
Federally approved water quality criteria for the Mississippi River
established by the Tennessee Water Quality Control Board.
3. Lack of a municipal waste treatment system results in raw
wastewaters being discharged directly into the Mississippi River via
the interceptor system.
4. The discharge of industrial wastes into the Mississippi River,
through the Wolf Interceptor, without a permit from the U. S. Army Corps
of Engineers, is a violation of Section 407, Rivers and Harbors Act of
1899 (33 USC: 401-413).
5. The high pH discharged by Buckeye Cellulose to the Wolf Inter-
ceptor violates the Memphis Ordinance No. 460.
6. The Buckeye Cellulose Corporation also discharges 47 pounds of
TOG and 233 pounds of COD per day to Cypress Creek. An application for
.a permit for this discharge has been filed with the U..S. Army Corps
of Engineers.
E. RECOMMENDATIONS
It is recommended that:
1. The Buckeye Cellulose Corporation adopt measures to recycle
part of its wastewater or to reduce the large volume of water being
discharged to the Wolf Interceptor.
2. The Buckeye Cellulose Corporation provide pollution control
facilities for its discharge to the Wolf Interceptor to reduce bio-
chemical oxygen demand, chemical oxygen demand, and suspended solids,
-------
23
to levels attainable employing best practicable treatment. These
levels are:
Component mg/1 Ib/day
BOD 30 530
COD 100 1,750
Suspended Solids 30 530
The pH of the wastewater discharges shall not be less than 6.5 nor
greater than 8.5.
3. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria herein outlined by December 30, 1974.
4. EPA, in coo-peration with the Tennessee Water Quality C.qntrol
Board and the Memphis and Shelby County Health Department, monitor
the quality of the wastewater discharged to ensure complianceiwith
Recommendations Numbers 1 and 2.
5. Upon failure of The Buckeye Cellulose Corporation to provide
a satisfactory documented commitment to achieve the goals identified in
Recommendations 1, 2 and 3, appropriate abatement proceedings be
initiated under the Rivers and Harbors Act of 1899.
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24
CHAPMAN CHEMICAL COMPANY
416 BROOKS ROAD
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
The Chapman Chemical Company is engaged in the blending, mixing, and
repackaging of purchased herbicides and wood preservatives. In addition
the Company repackages and ships inorganic acids. Production schedules
at Chapman Chemical vary greatly and are dependent upon demand for her-
bicides and wood preservatives. During peak production the plant operates
continuously; otherwise it operates only during the day shift. Approximately
100 people are employed.
The major chemicals handled at this plant are: pentachlorophenol;
sodium salts; Ramrod; Promitone; Atrazine; Petrolatum; pigments; caustic
soda: hydrochloric acid; aluminum chloride; Browicil; Karraex; sodium
trichloroacetate; and phenylmercuric lactate.
City water (0.13-0.17 mgd) is used for cooling, process, and
clean-up waters.
Chronology of Contacts
On September 8, 1971, W. C. Smith, E. J. Struzeski, and J. Hesson,
Environmental Protection Agency (EPA) National Field Investigations Center-
Denver (NFIC-D), met with J. P. Alrutz, Chapman Chemical Manager, Engi-
neering and Quality, to make arrangements for NFIC-D personnel to conduct
a preliminary inspection of the plant outfalls. Mr. Alrutz was apprised
of the purpose of the survey [Appendix C]. He cooperated with the EPA
repreentatives and granted permission to soavple the Chapman Chemical
Company effluent.
-------
25
On January 31, 1972, George Harlow, Chief, Enforcement Branch, EPA
Region IV, wrote a letter [Appendix C] to Mr. Alrutz, Chapman Chemical
Company, confirming the date of the investigation and requesting written
permission to sample. This method was taken to advise the Company that
information provided, as well as data regarding discharges from the
Chapman Chemical Company premises, may be used as evidence against the
firm in abatement proceedings under applicable laws. On February 2,
1972, Mr. Alrutz responded verbally'to Mr. Harlow's letter, granting'
permission to sample.
W. C. Smith and E. Mann, NFIC-D investigators, met with Dennis Beene,
Chapman (Chemical, 'on February 11, 1972, and made final plans to sample
the two Chapman outfalls.
B. WASTE SOURCES & TREATMENT
The majority of the effluent (discharges 001 and 002) [Figure C-l]
from Chapman Chemical is. cooling water with no apparent contact with
process material. These discharges are not subject to treatment.
The effluent from discharge 003 [Figure C-l] passes through pump
seals and has a pH of approximately 5 as it exits from the pumps. This
effluent is discharged across a limestone bed that neutralizes the acid
before the wastewater enters the west drainage ditch. About once per
month, this stream contains discharge from a vapor scrubber in the
aluminum chlorrMe manufacturing unit.
All three of these effluent streams (001, 002, 003) discharge into
the west ditch on the Chapman property. This ditch, as it enters the
-------
TO NONCONNAH CREEK
-N-
BROOKS ROAD
LEGEND
A SAMPLING STATIONS
WASTE DISCHARGE PIPING
NOT TO SCALE
Figure C 1 Chapman Chemical Cenpany and Valley Prodicls Memphis, Tennessee
Sampling Statiens C-22-A,C-22-B,VP-23
-------
26
property from the south, normally contains some flow. At the time of the
survey, the west ditch had a total flow of 0.2 mgd; the Chapman Chemical
«
Company contribution was 0.11 mgd. The flow in this west ditch discharges
into a stream that flows north to Nonconnah Creek [Figure C-l]..
The water that is used for cleaning floors and vessels in the area
flows into the east ditch. Prior to being discharged at .point 004
[Figure C-l] this effluent passes through a carbon filter. This flow into
the east ditch was 0.07 mgd. The east ditch flows north to an unnamed
stream that carries the combined east and west ditch effluent to
Nonconnah Creek.
An application for a permit to discharge has been filed with the
U. S. Army Corps of Engineers.
C. DISCUSSION OF 1N-PLANT EVALUATION. & RESULTS
Sampling Procedure
Wastewater flows were sampled on plant property at two locations
[Figure C-l]. The total flow in the west ditch (Station C-22-A) was
measured using a V-notch weir. The Chapman contribution to the total
flow was determined from City water usage meters. The floxtf in the east
ditch (station C-22-B) was estimated by using a container and stop watch.
Samples were taken at approximately 60-minute intervals using a
SERCO automatic sampler. The sampling xjas started at 8:00 AM February 22,
1972, and completed at 8:00 AM February 25, 1972. Twenty-four 1-hr
samples from the SERCO were composited into-one sample and an aliquot
was placed in the appropriate container designated for chemi.cal analyses.
The samples requiring immediate analyses were transported to a mobile
-------
27
EPA laboratory in Memphis. The other samples were preserved and shipped
by air freight to the EPA (NFIC-D) laboratory. Temperature, pH, and
0
conductivity were measured twice daily on grab samples at each location.
Discussion of Results
A summary of the analytical results from the Chapman Chemical dis-
charges to Nonconnah Creek is presented in Table CC-1. These data
indicate that the Chapman Chemical effluent discharges less than 80
pounds per day of TOC and COD. This effluent also contains 0.53 and
0.20 pounds per day of Ramrod and Atrazine, respectively. The average
concentration of Ramrod (850 yg/1) in the east ditch is in violation of
the effluent limit of 350 yg/1 set by the Memphis and Shelby County
Health Department.
D. SUMMARY AND CONCLUSIONS
1. The Chapman Chemical Company, because of its small volume of
flow, does not contribute substantial quantities of oxygen-demanding
materials to the receiving waters.
2. The concentration of Ramrod in the effluent is in violation of
the limit set by the Memphis and Shelby County Health Department.
E. RECOl'E-iENDATIONS
It is recommended that:
1. The Chapman Chemical Company provide pollution control facilities
or in-plant controls in order to reduce the level of toxic materials,
especially Ramrod, to that level set by the Memphis and Shelby County
Health Department.
-------
TABLE CC-1
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
CHAPMAN CHEMICAL
February 22-25, 1972
West Ditch-C-22-A
a/
Parameters-
Flow, gpm
pH
Temperature, °C
Conductivity,
y mhos /.cm
TOC
COD
Phenolic Materials
Copper
Cadmium
Zinc
Total Chromium
Lead
Ramrod, yg/1
Atrazine, yg/1
Range
6.8-7.1
11.5-16.0
140-240
26-40
15-61
0.06-1.60
0.03-0.05
Q /
0.14-0.24
b /
0.14-0.24
30-110
18-68
Average
78
31
35
0.57
0.04
<0.01
0.17
<0.01 .
0.17
60
49
Load
Ib /day
26
29
0.6
0.04
.0.14
0.20
0.06
0.05
East Ditch-C-22-B
Range
8.2-8.6
9.5-16.0
140-260
6-12
9-45
fo /
<0. 01-0 .12-'
<0 .01
0.04-0.11
<0 .01
0.03-0.16
250-1,200
99-360
Average
63
8
25
<0.05
<0.01
0.07
<0.01
0.09
850
270
Load
Ib/day
6
19
0.05
0.07
0.47
0.15
a/ All units are in mg/1 unless otherwise noted.
b/ Minimum detectable limit.
ro.
oo
-------
29
2. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with the
above mentioned recommendation.
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30
DAY AND NIGHT COMPANY
PAYNE COMPANY
DIVISION OF CARRIER CORPORATION
COLLIERVILLE, TENNESSEE
A.' BACKGROUND IN FORMAT I ON
General
Day and Night Company and the Payne Company, divisions of the
Carrier Corporation, produce.water heaters, heating products, and
air conditioners. The combined output is about 2,000 units per day.
Eight hundred people are employed. The plant operates five days a week,
with the majority of operations on two shifts (day and evening) and a few
operations on the third shift.
The units are. made .by cutting and bending steel plates into the
desired shape: then the surface is cleaned, treated, and painted.
The entire process involves cutting oils, a cyanide pickling
solution, sulfuric acid for etching, and a caustic, soapy solution
for washing. A phosphate compound is used as a binder for
enamel paint. Because the phosphate binder has not been satisfactory,
the Company plans to return to a chroiniurn-based binder.
The City of Collierville supplies 180,000 gallons of water per day.
It is used for cooling, washing, condensing, pickling, and preparation
of the metal for painting. The latter two uses consume nearly 95 percent
of the water. About 75 percent of the cooling-water is recirculated.
Chronology of Contacts
George Harlow, Chief, Enforcement Branch, EPA Region IV, wrote a
letter [Appendix C] during January 1972, to Reynold Kordatzky, Manager
-------
31
of Safety and Security, confirming the date of the investigation and
requesting written permission to sample. This method was taken to advise
the Day and Night Company that information provided, as xjell as data
regarding discharges from the premises of the Company, may be used as
evidence against the firm in abatement proceedings under the applicable 1-aws,
On February 3, 1972, Mr. Kordatzky, in a letter replying to
Mr. Harlow, granted written permission to sample.
The Day and Night Company was visited on Tuesday, February 15, 1972,
by E. Mann of the Environmental Protection Agency (EPA), National Field
Investigations Center-Denver (NFIC-D), and Bobby W. Fisher of the
Memphis and Shelby County Health Department. Day & Night's Manager of
Manufacturing Services, Peter Thompson, discussed the plant operations
and V7astewater dischargess Arrangements v,7ere made for sampling.
B. WASTE SOURCES AND TREATMENT
All of the waste streams, including the domestic waste, combine in a
manhole and are carried underground'to the City of Collierville waste
stabilization lagoon [Figure DN-1]. No treatment is being provided by
the Day & Night Company.
An application for a permit to discharge has not been filed with
the U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLANT EVALUATION & RESULTS
Sampling Procedure
The wastewater stream was sampled in a manhole on plant property
[Station DN-16, Figure DN-1]. A SERCO automatic sampler took one sample
-------
POPLAR AYE.
-N-
WATER METER
O
CITY WATER.*
SERVICE LINE
DAY & NIGHT
MFG. CO.
LEGEND
A SAMPLING STATIONS
FLOW TO
COLLIERVILLE
WASTEWATER
TREATMENT
PLANT
NOT TO SCALE
Figure DN1 Day and Nigkt Manufacturing Company Collierville, Tennessee
Sampling Station DN-16
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32
every hour for three 24-hour periods beginning on February 22 and ending
on February 25, 1972. At the end .of each period, the samples were com-
popited and aliquoted to the appropriate containers for shipment and
analyses. They were then transported to a mobile EPA laboratory located
in Memphis or shipped air freight-express to the NFIC-D laboratories.
Flow readings were taken from meters measuring water flow into the plant.
Grab samples were collected, twice daily for temperature, pH, and conduc-
tivity, and daily for oil and grease analyses.
Discussion of Results
The pH of the wastewater [Table DN-1] varied frora 5.4 to 10.7. The
organic content was moderate, with average daily loadings of 193 Ib of
BOB; 258 Ib, TOC; and 549 lb of COD. The cyanide concentration ranged
from 1.7 to 2.0 tng/1 and constituted an average daily loading of 2.6 lb.
This concentration of cyanide can be expected to have a detrimental
effect upon the biological treatment system at Collierville and, conse-
quently, the Wolf River to which the municipal wastewater is discharged.
D. SUMMARY AND CONCLUSIONS
1. The Day & Night Company, Payne Company, Division of Carrier
Corporation, discharges an effluent containing an average daily loading
of 193 pounds of BOD; 258 pounds, TOC; 549 pounds, COD: 868 pounds,
suspended solids; and 2.6 pounds of cyanide to the City of Collierville
treatment lagoon.
2. No pretreatment of the industrial waste stream is provided by
the Day & Night Company.
-------
33
TABLE DN-1
SUMMARY OF FIELD DATA 'AND ANALYTICAL RESULTS
DAY & NIGHT COMPANY
(Division of Carrier Corporation)
February 22-25, 1972
a/
Parameter-
Flow, mgd
PH
Temperature, . °C
Conductivity, umhos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Total Phosphorus
Turbidity, JTU
Cyanide
Copper
Cadmium
Zinc
Total Chromiumm
Lead
Range
6.169-0.179
5.4-10.7
20.5-24.0
220-6.50
60-240
58-345
172-634.
203-1,030
724-1,200
11-23 , ,
6.3-7.4^
230-650
1.7-2.0
0.04-0.07
c /
1.2-71.9
<0. 01- -0.09
0.06-0.07
Average
131
174
373
593
894
17
6.8
400
1.8
0.05
<0.01
1.6
<0.04
0.07
Load
Ib/day
193
258
549
868
. 1,310
24
10
2.6
0.08
2.3
1.0
aj All units are in rag/I unless otherwise noted.
b/ Range of two values.
c/ Minimum detectable limit.
-------
34
3. Cyanide (1.7-2,0 rag/1; 2.6 Ib/day) discharged from the Day &
Night Company to the City of Collierville treatment lagoon can adversely
affect the biota in the waste treatment system, thereby reducing treat-
ment efficiency.
4. The Day & Night Company is considering the use of a chromium-
based binder in its operations. This would increase the chromium
loading going to the Collierville treatment lagoon. This lagoon cannot
be expected to remove the chromium from the wastewater prior to discharge
to the Wolf River.
E. RECOMMENDATIONS
It is recommended that:
1. Pretreatment be provided by the Day & Night Company, Payne
Company, Division of the Carrier Corporation, for the removal of cyanide
from the discharge to the City of Collierville treatment lagoon. Con-
centration of cyanide in the effluent shall be limited to no more than
0.1 mg/1. Also, pH control should be provided; the pH of the effluent
shall be maintained between 6.0 and 9.0.
2. If a chrorr.ium-based binder is adopted, pretreatment of the
effluent be required to reduce the metal to a concentration of 0.1 rag/1
before wastes are discharged to the City of Collierville treatment lagoon.
3. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with Recom-
mendations Numbers 1 and 2.
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35
DELTA REFINING COMPANY
P. 0. BOX 9097
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The Delta Refining Company plant is an integrated refiner)' that pro-
cesses approximately 30,000 barrels of crude oil per day. Crude oil barged
up the Mississippi is processed into gasoline; propane; jet fuels; naphtha;
kerosene; diesel fuels; heating oils (Nos. 2, 5, and 6); asphalt; and
petroleum solvents. The Delta refinery provides for desalting of crude
oil. Company wells supply water '(app-rox. 0.32 mgd) that is used in the
following areas: cooling, 0.27 mgd; boiler feed, 0.15 rogd; process,
0.16 mgd; and sanitary system, 0.02 mgd.
The plant operates continuously; 235 people are employed.
Chronology of Contacts
On October 7, 1971, W. C. Smith, Environmental Protection Agency (EPA),
National Field Investigations Center-Denver (NFIC-D); Joseph Alleman, Baton
Rouge Field Station, EPA; and Sobby W. Fisher, Memphis and Shelby County
Health Department visited the Delta Refining Company and spoke with
Paul Upton, Refinery Superintendent, about the Memphis area water quality
survey. He cooperated with EPA personnel and granted permission to sample.
During January, 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter to Mr. Upton [Appendix C] confirming the date
of the investigation and requesting written permission to sample. This
method was taken to advise the Delta Refining Company that information
provided, and data regarding discharges from the premises of the Company,
-------
36
may be used as evidence against the firm in abatement proceedings
under applicable laws. Written permission to sample was provided to
«
EPA in a letter to Mr. Harlow dated February 3, 1972 from Mr. Prator,
President, Delta Refining Company.
EPA personnel visited Delta Refining Company again, on February 11,
1972, and final arrangements were made for sampling.
B. WASTE SOURCES AND TREATMENT
Sanitary sewage plus other unspecified streams varying from 0.02 to
0.29 mgd are discharged to the Nonconnah Interceptor. Surface water
drainage flows through a ditch into Nonconnah Creek [Figure DR-1]. Process
wastes, primarily from the catalytic cracker, are treated in an API sepa-
rator followed-by impair''flotation unit'. A 30-in. diameter underground
line carries the wastewater to a series of holding ponds. Storm
water also enters this drainage ditch and is diverted to the second
holding pond by means of a dam. The combined.effluent discharges to
tshe ditch draining to Nonconnah Creek.
A 3-in. diameter caustic line had. previously entered the drainage
ditch and flowed directly to Nonconnah Creek. The Company reports that
this line has been terminated; however, at the time of the survey,
water was flowing in this part of .the ditch. This flow may have been
from the caustic line or seepage from the ditch above the dam [Figure
DR-1].
Data submitted to the Tennessee Water Quality Control Board
[Table DR-1] indicate that the effluent was caustic and high in
phenolic materials and in oil and grease.
-------
STORM SEWER
X,
COW ISLAND RD.
(FISHER ST.]
' MALLORY AVE
REX FLOATATION TREATER
-(SI-
SEPARATOR
FROM PROCESS UNITS
30" CONCRETE
UNDERGROUND SEWER
15" UNDERGROUND SEWER
HOLDING POND
DRAINAGE
DITCH.
LEGEND
A SAMPLING STATION
15" UNDERGROUND
SEWER
DR-12'
NOT TO SCALE
Figure DR1 Delia Refining Company Memphis,Tennessee
Sampling Station DR-12
HOLDING POND
TO NONCONNAH
CREEK
-------
37
An application for a permit to discharge has been filed with the
U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure
The effluent of the Delta Refining Company was sampled at the holding
pond discharge only [Station DR-1-2, Figure DR-1]. Company personnel
insisted on this location, as opposed to the junction of the treatment
system discharge with the unknown waste source shown in Figure DR-1.
They felt that the latter location would include backflow from a battery
operation downstream from the ditch [Figure DR-1]. A SERCO automatic
sampler collected one sample every hour for three 24-hr periods from
February 18 to 21, 1972. At the end of each period the samples were
composited and aliquoted to the appropriate containers for shipment and
analyses. They were then transported to a mobile EPA laboratory in
Memphis or shipped air freight/express to the EPA NFIC-D laboratory.
Flow readings were taken from a chart recorder at the API separator.
Grab samples were taken twice daily for temperature, pH, and conductivity,
and daily for oil and grease analyses.
Discussion of Results
At the time of the survey the flow (0.35 mgd) was about half the
.flow reported in the U. S. Army Corps of Engineers permit application.
Previous analyses submitted to the Tennessee. Water Quality Control
Board [Table DR-1] indicate that, compared to the other months, the
phenol and oil and grease concentrations during the time of the survey
(February, 1972) were exceptionally low.
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38
TABLE DR-1
DELTA REFINING COMPANY
DISCHARGE ANALYSES REPORTED TO THE TENNESSEE
WATER QUALITY CONTROL BOARD
Range Average
September, 1971
pH 9.0-9.6
Oil & grease (rag/1) 5.3-123.8 55.4
Phenolic materials (mg/1) 21.0-83.3 35.6
October, 1571. . .
pH . 8.2-9.6
Oil & grease (rag/1) 10.2-53.9 31.1
Phenolic materials (mg/1) 8.3-51.3 34.7
November, 1971
pH 9.2-10.8
Oil & grease (mg/1) 22.3-188.5 76.5
Phenolic materials (mg/1) 31.6-56.7 40.8
February, 19 72
pH 9.0-10.4
Oil & grease (mg/1) 1.0-57,2 11.1
Phenolic materials (mg/1) 1.3-19.5 7.5
-------
39
The pH of the discharge ranged from 6.9 to 9.2 [Table DR-2]. Previous
analyses submitted by the Company [Table DR-1] reveal that it is not
uncommon for the pH to exceed 9.5. The concentration of oil and grease .
averaged 25 mg/1, or 72 Ib/day. Past records for September and November,
1971 [Table DR-1] show that the concentration exceeded 100 mg/1. The .
concentration of phenolic materials, during the survey, averaged 32 mg/1,
or 92 Ib/day. In addition, there was an average of 556 Ib of BOD; 447 Ib,
TOC; 853 Ib, COD; and 1.07 Ib of chromium discharged per day to Nonconnah
Creek. This reach of Nonconnah Creek is classified by the Tennessee
Water Quality Control Board for use for fish and aquatic life, livestock
watering, and wildlife. Under the criteria established by the State
no pollutants shall be added to the water in quantities that may be
detrimental to any of these uses.
Delta Refining Company is' contributing to the degradation of Nonconnah
Creek. Should Delta decide to incorporate this waste stream into the City
interceptor, the discharge must be treated further in order to insure that
the pH remain below 9.5 and the oil and grease level remain below 100 mg/1
as specified in the Memphis City Ordinance No. 490. In the event the
discharge to Nonconnah Creek is continued, Delta Refining must further
treat the waste stream by adopting the best practicable control technology
currently available.
D. SUMMARY AND CONCLUSIONS
1. The Delta Refining Company discharges an average daily loading of
556 pounds of BOD; 447 pounds, TOC; 853 pounds, COD; 72 pounds, oil and
grease; 92 pounds, phenolic materials; and 1.07 pounds of chromium into
Nonconnah Creek.
-------
40
TABLE DR-2
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
DELTA REFINING COMPANY
February 18-21, 1972
a/
Parameter-
Flow, mgd
pH
Temperature, °C
Conductivity, ymhos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Turbidity, JTU
Phenolic materials
Cyanide
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
6.9-9.2
17.5-20.0
2,800-3,500
170-210
115-190
191-372
34-83
1,340-2,710
19-29
7-90
'<25026/
-------
41
2. The process water undergoes partial treatment before being dis-
charged to Nonconnah Creek.
A
3. The drainage ditch that diverts storm water to the holding ponds
has a high probability of overflowing or seeping to a ditch downstream
and, thereby, bypassing the treatment system.
A. The discharge of oil and grease, phenolic materials, chromium,
and the chemical and organic'load by the Delta Refining Company into
Nonconnah Creek contributes to the violation of the Federally approved
water quality criteria established by the Tennessee Water Quality
Control Board.
5. The Delta Refining Company has applied for a discharge permit
from the U. S. Army Corps of Engineers.
E. RECCTS-fEL'IDATIONS
It is recommended that:
1. Delta Refining provide .pollution control facilities in order to
reduce biochemical oxygen demand, and toxic or hazardous materials
to levels attainable employing best practicable treatment. These levels
are:
Component Ib/bbl crude Ib/day
BOD .6.7 201
Phenolic Materials . 0.05 1.5
Oil and Grease 2.7 SI
2. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 60, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30, 1974.
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42
3. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of the process waste discharge to ensure compliance with the
recommendations above.
4. Upon the failure of the Delta Refining Company to provide a
satisfactory documented commitment to achieve the goals identified in
Recommendations 1 and 2 appropriate abatement proceedings be initiated
under the Rivers and Harbors Act of 1899.
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43
*' E. I. DUPONT DE NEMOURS & COMPANY (INC.)
P. 0. BOX 27038
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The DuPont facility in the Memphis area is a petrochemical plant
engaged in the manufacture of general industrial and agricultural
chemicals. The plant uses an electrolytic process for the production
of sodium and chlorine; a catalytic process for the manufacture of
hydrogen, cyanide, hydrogen peroxide, and ammonia; and a chemical
synthesis to manufacture sodium cyanide and sodium perborate. The
major raw materials used in this operation are sulfuric acid, natural
gas, air, and sodium chloride.
Approximately six hundred people are employed here and this plant
operates continuously.
Water for plant use is provided by nine deep wells on Company
property. .
Chronology of Contacts
On October 4, 1971, W. C. Smith of the Environmental Protection
Agency (EPA) National Field Investigations Center-Denver (NFIC-D);
Joseph Alleman, Baton Rouge Field Station, EPA; Bobby W. Fisher and
Hugh Teaford, Memphis and Shelby County Health Department, conducted
a preliminary inspection of the DuPont plant. DuPont representatives
E. M. Burton, Ray Pittman, and John Kloss were apprised of the purpose
of the survey. Dr. Burton, the plant manager, cooperated with the EPA
and granted permission to sample the DuPont effluent.
-------
44
During January 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter to Dr.. Burton [Appendix C] confirming the date
of the investigation and requesting written permission to sample. This
method was taken to advise DuPont that information provided, as well as
data regarding discharges from the premises of the Company, may be used
as' evidence against the firm in abatement proceedings under the appli-
cable laws.
On February 3, 1972, Dr. Burton, in reply to Mr. Harlow's letter,
granted EPA permission to sample [Appendix C].
At the time of the survey Dr. Burton indicated it was necessary
for a DuPont employee to accompany NFIC-D personnel during the time
they were in the plant to sample the effluent.
B. WASTE SOURCES AND TREATMENT
.The domestic waste from the plant is treated in an Imhoff tank
prior to being combined w±th the industrial effluent [Figure DP-1] .
The major wastes that contain cyanides are sent to a thermal reaction
unit for cyanide oxidation. The balance of the industrial waste is
treated in a neutralization system. This system [Figure DP-1] consists
of a neutralization-settling pond with a detention time of eight hours
and a baffled, mechanically agitated holding pond with a detention time
of two hours. The effluent from this system is combined with the cooling
water and with the effluent from the Imhoff tank prior to being dis-
charged into the Loosahatchie River through a 48-in. drop line with a
diffuser below the low water level. An emergency chlorine dump is
included in the treatment system.
-------
SANITARY SEWAGE
PROCESS
WASTES^
LEGEND
A SAMPLING STATION
NOT TO SCALE
Figure DP-1 E.I.duPonl deNemours and Company Memphis,Tennessee
Sampling Station D-9
-------
45
An application for permit to discharge has been filed with the U. S,
Army Corps of Engineers.
C.. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure
The discharge to the Loosahatchie River (D-9) was sampled on
Company property at a point upstream of the inlet to the 48-in. pipeline
(Figure DP-1).
A SERCO automatic sampler was used to collect an hourly sample
during three 24-hr periods beginning on February 18 and ending February
21, 1972. At the end of each period the samples were composited and
aliquoted into the appropriate containers for shipment and analyses.
They were then transported to a mobile EPA laboratory in Memphis or
shipped air freight/express to the NFIC-D (EPA) laboratories. A split
sample was provided for the E. I. duPont Company personnel each time
a composite was made. Grab samples were.collected twice daily in order
to obtain temperature, pH, .and conductivity and once daily for oil and
grease analyses. Flow readings were taken from Company flow meters
for the neutralization system. In order to obtain the total effluent
flow stream flow measurements were made of the combined cooling water/
domestic effluent, and this value was added with that from the neutral-
ization system.
Discussion of Results
During the time of the survey between 9.6 and 12.8 mgd of waste-
were being discharged from the DuPont plant [Table DP-1). This
-------
TABLE DP-1
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
E. I. DUPONT DE NEMOURS & COMPANY (INC.)
February 18-21, 1972
46
a/
Parameter-
Flow, mgd
pll
Temperature', °C
Conductivity, ymhos/cm
TOC
COD
Suspended Solids
Total Solids
Oil and Grease
Total Kj-N
N as NH3
Organic N
N as NO- -NO £
Total Phosphorus
Turbidity, JTU
Cyanide
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
9.6-12.8
7.4-9.7
26.0-32.0
900-1,250
8-17
22-38
32-100
459-886
5-19
8.4-9.2
7.4-7.7
1.0-l.jj.
^0 .05
. 1.36-1.44
5-14
0.16-0.18
0.02-0.03
<0.01
0.03-0.05
0.03
0.03-0.07
Average
13
32
76
720
10
8.9
7.6
1.4 .
<^Q ,05
1.39
8
0.17
0.03
<0.01
0.04
0.03
0.05
Load
Ib/day
1,200
2,760
7,000
65,600
1,000
720
670
120
123
14
2.3
3.2
2.7
4.5
j3/ All units are in mg/1 except as noted,
b/ Minimum detectable limit.
-------
47
discharge contained 1,200 pounds of TOC; 2,760 pounds, COD; 7,000
pounds, suspended solids; and 1,000 pounds of oil and grease per
day. In addition, of the 720 pounds of total nitrogen, 670 pounds
were ammonia. These loadings correspond to low concentrations (7.6
mg/1 ammonia) ; however, the large volume of wastex^ater being dis-
charged makes the pollutional load substantial. The Memphis and
Shelby County Health Department states that DuPont had been told
about the high ammonia content in discharges in the past and had
been advised not to exceed a concentration of 1.5 mg/1. This request
has not been met.
The cyanide loading averaged 14 pounds per day. When combined
with 3.2 pounds of zinc; 2.7 pounds of chromium; and 4.5 pounds of lead,
the combination could be highly toxic. [A summary of these data is
presented in Table DP-1.]
The waters of the Loosahatchie River are classified by the Tennessee
Water Quality Control Board for use as habitat for fish and aquatic life;
the DuPont discharge is detrimental to the water quality for this use.
At present, the DuPont Company does not have any plans to connect
the wastewater discharge to the City of Memphis Interceptor. Therefore,
additional wastewater treatment facilities or techniques must be
incorporated before the effluent is suitable for discharge into the
Loosahatchie River.
D. SUMMARY AND CONCLUSIONS
1. E. I. duPont de Nemours and Company (Inc.) is discharging an
(«
effluent containing an average daily load of 1,200 pounds of TOC;
-------
48
2,760 pounds, COD; 7,000 pounds, suspended solids; 1,000 pounds, oil
and grease; 670 pounds, ammonia; 14 pounds, cyanide; 3.2 pounds, zinc;
2.7 pounds, chromium; and 4.5 pounds of lead into the Loosahatchie
River, a tributary of the Mississippi River.
2. The treatment facilities provided by the DuPont Company are
not sufficient to reduce the pollutional load in the stream.
3. The ammonia, cyanide, zinc and other metals in the DuPont dis-
charge to the Loosahatchie River may be highly toxic, and therefore,
violate the Rivers and Harbors Act of 1899 and the water quality
criteria for fish and aquatic life established by the Tennessee Water
Quality Control Board.
4. E. I. duPont de Nemours and Company (Inc.) does not presently
plan to connect into the City of Memphis sewer interceptor.
RECOMMENDATIONS
It is recommended that:
.1. E. I. duPont de Nemours and Company (Inc.) provide in-plant
measures for water conservation and re-use and improved pollution
control facilities.
2. E. I. duPont de Nemours and Company (Inc.) provide pollution
control facilities to reduce the loads of pollutants in the effluent, to
levels attainable employing best practicable treatment. These levels are;
Component mg/1 Ib/day
Cyanide 0.01 0.7
BOD 10 670
Total Chromium 0.05 3.4
Zinc 0.05 3.4
Ammonia "1.5 100
Suspended Solids 20 1,330
COD 40 2,660
-------
49
3. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria herein outlined by December 30, 1974.
4. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with Recom-
mendations Numbers 2 and 3.
5. Upon the failure of the E. I. duPont de Nemours Company (Inc.)
to provide a satisfactory documented commitment to achieve the goals
identified in Recommendations 1, 2, and 3, appropriate abatement pro-
ceedings, under the Rivers and Harbors Act of 1899, be initiated.
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50
*' . FIRESTONE TIRE AND RUBBER COMPANY
P. 0. BOX 7128
MEMPHIS, TENNESSEE
A.. BACKGROUND INFORMATION
General
The Firestone plant in Memphis is one of the largest of the 55
Firestone factories in the U.S. and overseas. The Memphis factory
was completed around 1936. The raw materials received by the plant
include natural and synthetic rubber, nylon, rayon, and polyester
materials together with steel bead wire, pigments^ and oils. At this
factory Firestone assembles and cures rubber tires;'compounds and mixes
rubber materials; processes tire components, and engages in inspection,
warehousing, and shipping. End products consist of heavy duty tire's, \
flaps, retread tires, and passenger tires.
A unique feature of the Memphis factory is the Firestone Xylos
Recovery or Reclaim Plant. The Xylos plant receives scrap tires and,
by means of shredding, cooking, etc., reconditions old rubber for
re-use. Part of the reclaimed rubber is used in the Memphis plant
and the remainder is distributed to other Firestone plants. The Xylos
plant generates a major portion of the liquid waste loads from this
Firestone installation. Much of this waste load is from the sludge
tank discharge inside the Xylos plant.
Chronology of Contacts
On October 6. 1971, E. J. Struzeski, Environmental Protection Agency
(EPA) National Field Investigations Center-Denver (NFIC-D), and Hugh
Teaford, Memphis and Shelby County Health Department, conducted a pre-
liminary inspection of the Firestone plant. Clarence Colby, Plant
-------
51
Engineer, was apprised of the purpose of the survey. He cooperated
with the EPA and granted permission to sample the plant effluent.
During January 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, x^rote a letter to Mr. Colby [Appendix C] confirming the
date of the investigation and requesting written permission to sample.
This method was taken to advise Firestone that information provided, as
well as data regarding discharges from the premises of the Company, may
be used as evidence against the firm in abatement proceedings under the
applicable laws.
On February 1, 1972, Mr. Colby, in reply to Mr. Harlow's letter,
granted EPA permission to sample [Appendix C].
B. WASTE SOURCES AND TREATMENT
. Rubber fines and soluble organic compounds originating in the rubber
reclaiming plant are the major waste constituent.
The Firestone plant uses in-plant controls, but there is no treat-
ment of the wastes being discharged. The effluent from the plant is
divided into two streams; the first being the "heavy" or highly con-
centrated waste. This effluent flow (F-18-A) is measured in a Parshall
flume and then discharged to the Wolf Interceptor [Figure F-l]. The
second effluent (F-18-B) is designated as cooling water and is discharged,
without being measured, into Leath Bayou and thence via Cypress Creek
to the Wolf River.
An application for a permit to discharge has been filed with the
U. S. Army Corps of Engineers for effluent F-18-B. No application has
been filed fo^ F-18-A.
-------
WOLF
INTERCEPTOR
co
co
co
co
-N-
'A
CORRINE AVE.
J} _,__
\ * WOLF j p «
WOLF
INTERCEPTOR
COOLING
, WATER
FLOW |
MEASURINGI
WELL |
PROCESS
WASTES
U_
THE
FIRESTONE
TIRE AND
RUBBER
COMPANY
FIRESTONE BLVD.
LEGEND
A SAMPLING STATIONS
NOT TO SCALE
CO
CO
Figure F1 The Firestone Tire and Rubber Company
Memphis, Tennessee Sampling Stations F-18-A, F-18-B
-------
52
t.
C. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure
The discharge to the Wolf Interceptor (F-18-A) was sampled on Company
property at a point downstream from the flow-measuring device [Figure F-l].
A SERCO automatic sampler was used and, beginning on February 22 and
ending February 25, 1972, a sample was collected every hour for three
24-hr periods. At the end of each period the samples were composited and
aliquo£ed to the appropriate containers for shipment and analyses. They
x^ere then transported to a mobile EPA laboratory in Memphis or shipped air
freight/express to the NFIC-D (EPA) laboratories. Grab samples were >col-
lected twice daily in order to obtain temperature, pH, and conductivity
and once daily for oil and.grease analyses. Flow readings were taken
from a Company flow meter.
The discharge .to Leath Bayou (F-18-B) was sampled at the point where
the 72-in. cooling-water pipe discharged into the stream [Figure F-l].
A SERCO automatic sampler was used and, beginning on February 22 and
ending February 25, 1972, a sample was collected every hour for three
24-hr periods. These samples were handled in the manner previously
described. Grab samples were taken twice daily in order to obtain
temperature, pH, and conductivity measurements. Effluent flow measure-
ments were conducted by EPA personnel.
At the time of the survey, the Firestone Tire and Rubber Company
was discharging between 0.13 and 0.39 mgd wastewater to the Wolf Inter-
ceptor. Thic discharge (F-18-A) had a pH between 4.7 and 5.8 and con-
tained 1,700 ing/I BOD, 3,860 mg/1 TOG, and 9,130 rag/I COD [Table F-l].
-------
TABLE F--1
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
FIRESTONE TIRE AND RUBBER COMPANY
February 22-25, 1972
Parameter-
Flow, mgd
PH
Temperature, °C
Conductivity,
pnihos/cm
BOD
TOG
COD
Suspended Solids
Total Solids
Oil and Grease
Turbidity, JTU
Phenolic Materials
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
0.13-0.39
4.7-5.8
37.0-39.0
400-775
1,600-1,800
3,550-4,160
6,120-13,800
1,680-3,300
3,450-6,030
3r>.'F-/-860 '
40-220
3.5-5.8-'
0.03-0.34
<0.01-'-0.03
5.9-9.3
0.02-0.04
0.45-0.76
F-18-A
Average
1,700
3,860
9,130
2,510
4,460
530
150
4.5
0.18
<0.02
7.3
0.03
0.59
Load
Ib/day
3,280
7,720
21,300
5,860
9,920
1,100
9.7
0.46
15.9
0.05
1.3
Range
6.9-7.2
23.5-26.0
160-200
8-30.
38-76
51-325
. 168-527
20-220 ,
C 1
0.26-0.33^'
0.06-0.27,
(? /
0.09-0.21
ci /
. <0. 03-' -0.03
F-18-B
Average
4.94^
17
56
146
290 ,
4,100
83
0.3
0.15
0.15
<0.03
Load
Ib/day
700
2,310
6,020
12,000
12.4
6.2
6.2
a_/ All units are in mg/1 except as noted.
W Single instantaneous reading.
_c/ Range of two values.
_d/ Sample analyzed after maximum preservation time had expired.
e/ Minimum detectable limit.
-------
54
These values corresponded to average daily loadings of 3,280 pounds
of BOD; 7,720 pounds, TOC; and 21,300 pounds of COD.
The wastewater was turbid (150 JTU, avg) and contained 2,510 mg/1
(5,860 Ib/day) suspended solids and 4,460 mg/1 total solids. In addition,
the effluent being discharged contained 1,100 pounds of oil and grease
(580 mg/1) and 9.7 pounds of phenolic materials (4.5 mg/1).
The Memphis Ordinance No. 460 prohibits the discharge of wastewater
having a pH below 5.5, oil and grease concentration exceeding 100 mg/1,
or a high content of phenolic materials. These heavy loadings of oxygen-
demanding materials in the wastewater will cause an excessive loading
on the xjaste treatment facilities (North Treatment Plant) that are to
be constructed by the City of Memphis. Phenolic materials and oil and
grease may be toxic to the biota in the treatment system, thereby reducing
the effectiveness of the treatment.
The reach of the Mississippi that now receives the discharge from
the Wolf Interceptor is classified by the Tennessee Water Quality
Control Board for industrial uses, fish and aquatic life, irrigation,
livestock watering, wildlife, and navigation. Under the criteria
established by the State there shall be no substances added to the
waters that wiM produce conditions detrimental to these uses.
The Firestone Tire & Rubber Company has a second discharge (F-18-B)
into Leath Bayou which drains to Cypress Creek and thence to the Wolf
River. This discharge had a greater flow (4.94 mgd), and the TOC and COD
concentrations were 17 mg/1 and 56 mg/1, respectively. These values cor-
respond to a daily average discharge of 700 pounds of TOC and 2,310 pounds
-------
55
of COD. An instantaneous measurement for oil and grease was exceptionally
high with a concentration of 4,100 mg/1. Further, 12.4 pounds of
phenolic materials were being discharged.
Although Firestone has taken certain in-plant measures to segregate
strong waste streams to prevent their discharge to Leath Bayou, the
Company must further remove the source of oil and grease and of phenolic
materials from this discharge. This waste stream should then be combined
with the stream now going to the interceptor and be pretreated.
D. SIM-IARY AND CONCLUSIONS
1. The Firestone Tire and Rubber Company in Memphis, Tennessee
discharges, into the. llississippi River through the V.'olf Interceptor,
wastewater containing 1,700 rng/1 BOD, 3S860 mg/1 TOC, 9,130 rag/1 COD,
2,510 mg/1 suspended solids, 580 mg/1 oil and grease and 4.5 mg/1 phenol.
These values amount to an average daily loading of 3,230 pounds of BOD;
7,720 pounds, TOC; 21,300 pounds, COD: 5,860 pounds, suspended solids;
1,100 pounds, oil and grease; and 9.7 pounds of phenolic materials. A
U. S. Army Corps of Engineers discharge permit application has not been
filed for this effluent.
2. Firestone does not provide pretreatment before the waste-
water enters the sewer system.
3. Lack of a municipal waste treatment system results in. untreated
industrial wastewaters being discharged directly to the Mississippi
River via the interceptor system.
/
4. The high contents of oxygen-demanding materials, solids, oil
and grease, and phenolic materials, and the pH fluctuation in the
-------
56
Firestone discharge contributes to the violation of the Federally approved
water quality criteria for the Mississippi River, as established by the
Tennessee Water Quality Control Board.
5. The pli range and the concentrations of oil and grease and phenolic
materials violate sections of the Memphis City Ordinance (No. 460).
6. The discharge of industrial wastes, with high pollutional loadings,
into the Mississippi River v/ithout a permit from the U. S. Army Corps of
Engineers is a violation of section 407, Rivers and Harbors Act of 1899
(33 USC: 401-413).
7. In the contact stabilization sewage treatment plant, which is
planned to eventually treat wastcwater carried by the Wolf Interceptor,
the oil and grease and phenolic materials in the. Firestone discharge
may be toxic to the biota in the treatment system, and thereby impair
the treatment of municipal wastes.
8. The Firestone Tire & Rubber Company also discharges an effluent
containing high concentrations of oil and grease, and average daily
loadings of 700 pounds of TOC; 2,310 pounds, COD; 6,030 pounds suspended
solids; and 12.4 pounds of phenolic materials into the Wolf River via
Leath Bayou and Cypress Creek. An application for a permit to discharge
has been filed xdLth the U. S. Army Corps of Engineers for this effluent.
9. The absence of treatment of this stream causes material toxic
to fish and aquatic life to reach the Wolf River and thereby violates
the Rivers and Harbors Act of 1899.
10. Although the Firestone Tire & Rubber Company is practicing
in-plant stream segregation to'prevent strong wastes from entering the
Wolf River, the waste segregation program has not succeeded in removing
a significant pollutional load from the discharge:
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57
E. RECOMMENDATIONS
It is recommended that:
1. Firestone Tire & Rubber Company provide pollution control
facilities for its discharge to the Wolf Interceptor (F-18.-A) in order
to reduce biochemical oxygen demand, chemical oxygen demand, solids,
oil and grease, and phenolic materials to the levels attainable
employing best practicable treatment. These levels are:
Component mg/1 Ib/da3r
BOD 30 60
COD 100 200
Suspended Solids 30 60
Oil & Grease 5 10
Phenolic Materials .0.1 0.2
The pH of the wastewater discharges shall be not less than 5.5 or
greater than 9.5.
2. The waste segregation program adopted by Firestone be further
applied to the waste stream entering Leath Bayou (F-18-B) in order to
remove the high oil and grease, and phenol content from this discharge
and to combine it with the other strong process wastes that must be
pretreated before discharge to the Wolf Interceptor. Pollutants in
this discharge should be reduced to the levels attainable employing
best practicable treatment. These levels are:
Component mg/1 Ib/day
Suspended Solids 30 1,250
Oil & Grease 5 200
Phenolic Materials 0.1 4.0
3. An implementation schedule for the pollutaion control facilities
be established as follows:
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58
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30, 1974.
, 4. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with Recom-
mendations Numbers 1, 2, and. 3.
5. Upon the failure of the Firestone Tire & Rubber Company to
provide a satisfactory documented commitment to achieve the goals
identified in Recommendations 1, 2, and 3 appropriate abatement
proceedings be initiated under the Rivers and Harbors Act of 1899.
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59
W. R. GRACE & COMPANY
AGRICULTURAL CHEMICALS .GROUP
P. O.-BOX 27147
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The plant of W. R. Grace & Company, Agricultural Chemicals Group,
is situated on the Loosahatchie River about five miles north of the City
of Memphis. This plant receives natural gas, sulfuric acid, caustic
soda, tnonoethanolamine, and other products and is principally engaged
in the synthesis of ammonia from natural gas and of urea from ammonia
and carbon dioxide.
The plant operates continuously and employs approximately 350 people.
The water (1.9 mgd) used by the plant is provided by deep wells on
Company property.
In May, 1971, the Tennessee Water Quality Control Board advised
W. R. Grace of standard-s for the various pollutants in its discharge.
The State commented on excessive concentrations of urea that, in turn,
hydrolizes to ammonia and carbon dioxide; cyanide is also a potential
decomposition product of urea. The State warned W. R. Grace that the
zinc in the ef.fluent, when combined with cyanide, results in syner-
gistic effects. The Tennessee Water Quality Control Board recommended
the following effluent limitations:
pH 6.0-9.0 Turbidity 50 units or less
Cyanide 0.01 mg/1 or less Total Chromium 0.05 mg/1 or leso
BOD 10 mg/1 or less Zinc 0.1 rag/l or less
Color 50 units or less Ammonia 1.5 mg/1 or less
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60
The f&llowing compliance schecVile was recommended for W. R. Grace:
For correction of chrome and zinc discharges;
Submittal of preliminary engineering report: July 1, 1971
Submittal of plans and specifications: October 1, 1971
Initiation of construction: . February 1, 1972
Initiation of operation: April 1, 1973
For correction of ammonia and other discharges:
Submittal of preliminary engineering report: Juljr 1, 1972
Submittal of plans and specifications: January 1, 1973
Initiation of construction: July 1, 1973
Initiation of operation: July 1, 1974
In September 1971, the Memphis and Shelby County Health Department
noted that the W. R. Grace effluent continued to show a high ammonia content
Chronology of Contacts
On October 4, 1971, Wayne C. Smith of the Environmental Protection
Agency (EPA), National Field Investigations Center-Denver (NFIC-D);
Joseph Alleman, Baton Rouge Field Station, EPA; Bobby W. Fisher and
Hugh Teaford, Memphis and Shelby County Health Department, conducted
a preliminary inspection of the W. R. Grace & Company plant. Robert M.
Stewart, Plant Manager, and Frank Applegate, Assistant Plant Manager,
were apprised of the purpose of the survey. Mr. Stewart said that he
would answer any questions the EPA posed but would have to confer with
his legal staff before granting permission to sample the W. R. Grace
effluent. On October 6, 1971, Mr.. Stewart granted permission to sample
this discharge.
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61
During January 1972, George llarlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter to Mr. Stewart [Appendix C], confirming the
date of the investigation and requesting written permission to sample.
This method was taken to advise W. R. Grace that information provided,
and data regarding discharges from the premises of the Company, may
be used as evidence against the firm in abatement proceedings under
the applicable laws.
On February 3, 1972, Mr. Stewart,' in a rep'ly to Mr. Harlow's letter,
granted permission to sample [Appendix C].
At the time of the survey Mr. Stewart indicated it was necessary
for a W. R. Grace employee to accompany NFIC-D personnel during the
time they were in the plant to sample the effluent.
B. WASTE SOURCES AND TREATMENT
- The process water from the- production of ammonia and urea is the *
major contribution to the presence of alkalinity, total solids, ammonia,
and urea. This wastex^ater may contain cyanides.
Domestic wastewaters at W. R. Grace are treated in an Iinhoff tank
prior to "being mixed with the industrial wastewaters. These combined
wastes flow into a settling pond, and the pond effluent passes into a
small final lagoon [Figure G-l]. The floating oil on this final lagoon
is removed by an oil skimmer and burned. The effluent from the lagoon
flows, via an open ditch, into the Loosahatchie River.
An application for a permit to discharge has been filed with the
U. S. Army Coips of Engineers.
-------
LEGEND
A SAMPLING STATION
PLANT AREA
W.R.GRACE AND
COMPANY
NOT TO SCALE
-N-
Figure C-l W.R.Grace and Company Memphis,Tennessee
Sampling Station C-10
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62
C. DISCUSSION OF IN-PLANT EVALUATION & RESULTS
Sampling Procedure
The discharge to the Loosahatchie River (G-10) was sampled on
Company property at a point upstream of the flow measuring device
[Figure G-l], A SERCO automatic sampler was used, and beginning on
February 18 and ending February 21, 1972, a sample was collected every
hour for three 24-hr periods. At the end of each period the samples
were composited and aliquoted to the appropriate containers for shipment
and analyses. They x^ere then transported to a mobile EPA laboratory
in Memphis or shipped air freight/express to the NFIC-D (EPA) laboratories,
Whenever possible, the W. R. Grace Company personnel were provied with
a split sample. Grab samples were taken twice daily in order to obtain
temperature, pH, and conductivity and once per day for oil and grease
analyses. Flow readings were taken from Company flow meters.
Discussion of Results
At the time of the survey, between 1.30 and 1.95 mgd of wastewater
i
was being discharged to the Loosahatchie River. The pH varied between
6.8 and 8.8. The BOD averaged 10 mg/1 and the turbidity ranged from 9
to 13 JTU. All of these levels were just within the limits recommended
by the Tennessee Water Quality Control Board.
The discharge contained an average daily loading of 122 pounds of
BOD; 779 pound::, TOC; 634 pounds, COD; and 21 pounds of oil and grease.
The nutrient level was very high. The ammonia concentration averaged
111 mg/1 and the organic nitrogen averaged 99 mg/1. These corresponded
to average loa.dings of 1,320 and 1,170 pounds per day, respectively.
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63
The Sdate recommended limit of 1.5 mg/1 (18.8 Ib/day) ammonia in the
effluent has not been adhered to.. The concentration of zinc averaged
0.77 mg/1, or 9.1 Ib/day, and the cyanide averaged 0.06 mg/1. This is in
excess of the State recommended levels of 0.10 mg/1 zinc (or 1.25 Ib/day)
and 0.01 mg/1 cyanide. In addition, the synergistic effects of zinc and
cyanide increase the toxicity of the waste stream. The chromium con-
centration averaged 2.0 mg/1 (23.8 Ib/day), a value that was also in
excess of the limit recommended by the State (0.05 mg/1 or 0.63 Ib/day).
The receiving waters of the Loosabatchie River are classified- by the
Tennessee Water Quality Control Board for fish and aquatic life. The
discharge by the W. R. Grace Company makes the water unfit for this use
and, therefore, violates the water quality standards. [A summary of
these data is .presented in Table G-l.j
The wastewater treatment provided by W. R. Grace is inadequate
for handling the toxic load. The Company had not followed the imple-
mentation schedule suggested by the State. Furthermore, W. R. Grace
has not been making a satisfactory effort to improve the treatment of
its discharge. The wastewater can be highly toxic and is contributing
to the degradation of the water quality of the Loosahatchie River.
D. SUMMARY AND CONCLUSIONS
1. W. R. Grace & Company discharges, to the Loosahatchie.River,
an average daily loading of 122 pounds of BOD; 779 pounds, TOC; 634
pounds, COD; 210 pounds, oil and grease; 1,320 pounds, ammonia; 1,170
pounds, organic nitrogen; 0.7 pounds, cyanide; 9.1 pounds, zinc; and
23.8 pounds of chromium.
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64
TABLE G-l .
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
W. R. GRACE & COMPANY
AGRICULTURAL CHEMICALS GROUP
February 18-21, 1972
Parameter-
Flow (mgd)
PH
Temperature (°C)
Conductivity (umhos/cm)
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Total Kj-N
N as NH
Organic-N
N as NO^-NO
Total Puospnorus
Turbidity (JTU)
Cyanide
Copper
Cadmium
Zinc
Total Chromium
Range
1.30-1.95
6.8-8.8
32.5-37.5
1,600-2,300
10-11
45-83
20-107
26-61
709-981
. 12-21
160-270
70-150
87-12JD
0.05^'
0.14-0.22
9-13
0.01-0.0.2
0.01
0.67-0.85
1.4-2.4
Average
10
67
51
47
868
17
210
111
"b/
0.05^
0.19.
12 .
f /
0.06-7
0.02
0.01
0.77
2.0
Load
Ib/day
122
779
634
557
10,300
210
2,480
1,320
1,170
2.2
0.7
0.19
0.12
9.1
23.8
_a/ All units are in rag/1 except as noted.
b_/ Minimum detectable limit.
c/ One value.
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65
2. Th'e levels of ammonia, zinc, cyanide, and chromium in the W. R.
Grace discharge stream are in excess of those recommended by the
Tennessee Water Quality Control Board. These toxic contaminants vio-
late the Rivers and Harbors Act of 1899 and may violate the water
quality criteria of the Loosahatchie River which is classified by the
Tennessee Water Quality Control Board for fish and aquatic life.
3. The wastewater facilities provided by the Company are not adequate,
Although an abatement schedule has been set by the Tennessee Stream Pol-
lution Control Board, W. R. Grace and Company does not appear to. be making
any attempt to improve these facilities.
4. An application for a permit to discharge has been filed with
the U. S. Army Corps of Engineers.
E. RECOMMENDATIONS
It is recommended that:
1. W. R, Grace & Company improve waste treatment facilities in order
to reduce the ammonia, cyanide, chromium and zinc in the discharge to
the levels recommended by the Tennessee Water Quality Control Board.
2. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30, 1974.
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66
3. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance, with the
Recommendation Numbers 1 and 2.
A. Upon the failure of the W. R. Grace & Company Agricultural
Chemicals Group to provide a satisfactory documented commitment to
achieve the goals identified in Recommendations 1 and 2, appropriate abate-
ment proceedings under the Rivers and Harbors Act of 1899 be initiated.
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67
HUMKO PRODUCTS
CHEMICAL DIVISION
POPE STREET
P. 0. BOX 398
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The HumKo Products (Pope Street) facility is a chemical plant that
manufactures fatty acids, glycerides, and nitrogen derivatives from
animal and vegetable fats, fish oils, and other natural fats. The
process consists of refining, hydrogenation, hydrolysis, and distillation,
The plant operates continuously and employs 225 people. The water
supply for this operation is provided by the City and this water is
used for cooling, processing, and cleaning.
Chronology of Contacts
On October 6, 1971, W1. C. Smith, Environmental Protection Agency
(EPA), National Field Investigations Center-Denver (NFIC-D), Joseph
Alleman, Baton Rouge Field Station, EPA, and Bobby W. Fisher, Memphis
and Shelby County Health Department, conducted a preliminary inspection
of the HumKo Products (Pope Street) plant. HumKo Products Manager of
Design Allen Fritsche and Plant Manager Robert Wiggins were apprised of
the purpose of the survey. Mr. Fritsche cooperated with EPA and granted
permission to sample the plant effluent. (Mr. Fritsche was acting in
behalf of Curt Meierhoefer, Vice President, Engineering, during this
plant inspection.)
George Hcrlow, Chief, Enforcement Branch, EPA, Region IV, wrote a
letter [Appendix C] during January 1972 to Mr. Fritsche, confirming the
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68
date of the investigation and requesting written permission to sample.
This method was taken to advise HumKo Products (Pope Street) that
information provided, as well as data regarding discharges from the
premises of the Company, may be used as evidence against the firm in
abatement proceedings under the applicable laws.
On February 3, 1972, Mr. Meierhoefer, in reply to Mr. Harlow's
letter, granted EPA permission to sample [Appendix C].
At the time of the survey Mr. Wiggins indicated it was necessary
for a HumKo employee to accompany NFIC-D personnel during the time they
were in the plant to sample the effluent.
B« WASTE SOURCES AND TREATMENT
The. major source of waste is the process water that normally con-
tains large amounts of organic materials. Prior to discharge into
Workhouse Bayou and thence to the Wolf River, the wastex^ater is pre-
treated for oil and grease removal by means of pH control and an air-
flotation unit.
An application for a permit to discharge has been filed with the
U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLMT EVALUATION AND RESULTS
Sampling Procedures
The discharge to Workhouse Bayou (HP-21) was sampled on Company
property at a point downstream from the air-flotation unit. [Figure HP-1].
A SERCO automatic sampler was used and, beginning on February 22 and
ending February 25, 1972, a sample was collected every hour for three 24-hr
periods. At the end of each period the samples were composited and
-------
-N-
PRETREATMENT
FACILITY'
TO WOLF RIVER
BELZ
INVESTMENT
HUMKO PRODUCTS
PLOUGH
INDUSTRIES
HUMKO
PRODUCTS
BELL AVE.
WORKHOUSE
BAYOU TO
WOLF RIVER
PLOUGH
INDUSTRIES
OWENS
ILLINOIS
GLASS
LEGEND
A SAMPLE POINT
NOT TO SCALE
Figure HP-1 Humko (Pope) Flow Diagra
in
-------
69
^ into the appropriate containers for shipment and analyses.
They were then transported to a mobile EPA laboratory in Memphis or
shipped air freight/express to the NFIC-D (EPA) laboratories. Whenever
possible, a split sample was provided the personnel of HumKo Products
(Pope Street). Grab samples were taken twice, daily in order to obtain
temperature, pH, and conductivity and once daily for oil and grease
analyses. Flow readings were taken from Company flow meters.
Discussion of Results
At the time of the survey HumKo was discharging an average of 0.7 mgd
of wastewater to Workhouse Bayou and thence to the Wolf River. The dis-
charge was caustic, x^ith a pH range of 7.8 to 11.5 [Table 1IP-1] . The
effluent contained a daily average loading of 11,400 pounds of BOD;
4,240 pounds, TOC; and 21,500 pounds of COD. .These loads correspond
to concentrations of 2,070 mg/1 BOD; 748 mg/1 TOC and 3,930 mg/.l COD.
In addition, there were 3,700 pounds oil and grease (630 rag/1) and
22 pounds phenolic materials (3.7 mg/1). Although IIumKo Products (Pope
Street) has installed an air flotation unit to pretreat its waste, the
system is not adequate. As a result, a high strength waste is being
discharged into the Wolf Paver via Workhouse Bayou.
The reach of the Wolf River receiving the discharge from Workhouse
Bayou is classified for fish and aquatic life. The strong waste now
being discharged by the HumKo firm can be detrimental to the water
quality for this use.
Company officials plan to connect the discharge from the Pope
Street plant to the City of Memphis interceptor system. According
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70
TABLE 11P-1
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
HUMKO PRODUCTS CHEMICAL DIVISION
(POPE STREET)
February 22-25, 1972
Parameter-
Flow, mgd
pll
Temperature, °C
Conductivity, ymhos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease.
Turbidity, JTU
Phenolic Materials
Cyanide
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
0.6 09-0 '.748
7.8-11.5
28.5-36.0
1,200-8,000
1,500-2,900
670-800
1,800-5,700
123-1,300
2,280-3,540
330-860
450-1,000
0 o / "7 n
U . £- '4 / \J i
<0.02-
0.06-0.10
<0.01-7
0.19-0.44
<0. 01- -0.02
0.12-0.16
Average
2,070
748
3,930
685
2,770
630
650
3.7
0.08
0.28
<0.02
0.14
Load
Ib/day
11,400
4,240
21,500
3,980
15,900
3,700
1 O
£.£.
0.43
1.6
0.78
a./ All units are in mg/1 except as noted.
b/ Minimum detectable value.
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71
to the Memphis Ordinance No. 460, Article 5(j) prohibits the discharge
of any waste having a pH in excess of 9.5. Article 5(b) prohibits
concentrations of oil and grease exceeding 100 mg/1. In addition, it
is prohibited to discharge wastewater containing phenolic materials
or BOD and COD in such quantities that would cause a significant load
on the sewage works. The discharge from HumKo Products violates these
aspects of the City Ordinance. Further treatment of the wastewater
stream must be provided for by HumKo Products in order to make the
effluent suitable for discharge to the City interceptor.
D. SUMMARY AND CONCLUSIONS
1. HumKo Products Chemical Division (Pope. Street) is discharging
an average daily load of 11,400 pounds of BOD; 4,240 pounds, TOG; 21,500
pounds, COD; 3,700 pounds, oil and grease: and 22 pounds ot phenolic
materials into Workhouse Bayou which drains into the Wolf River. This
discharge is a violation of the Rivers and Harbors Act of 1899.
2. Although an air flotation unit has been installed to pretreat
the waste, the system is inadequate, and the HuraKo discharge is grossly
polluting Workhouse Bayou.
3. If HumKo Products connects to the City sewer system, the pH,
the concentration of oil and grease and phenolic materials, the large
amounts of chemical and organic matter, would violate the Memphis
Ordinance No. 460.
E. RE COMMENDATION S
It is recommended that:
1. HumKc Products (Pope Street) provide additional pollution
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72
control .facilities to reduce the pollutants to the levels attainable
employing best practicable treatment. These levels are:
Component mg/1 Ib/day
BOD 30 170
COD 100 560
Suspended Solids 30 170
Oil & Grease 5 30
Phenolic Materials 0.1 0.6
2. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30, 1974.
3. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with Recom-
mendations Numbers 1 and 2.
4. Upon the failure of HuraKo Products Chemical Division to provide
a satisfactory document to achieve the goals identified in Recommendations
1 and 2 appropriate abatement proceedings be initiated under the
Rivers and Harbors Act of 1399.
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73
HUMKO PRODUCTS
(Thomas Street).
P. 0.. BOX 398
MEMPHIS, TENNESSEE
A.' BACKGROUND INFORMATION
General
The HumKo Products (Thomas Street) operation is a chemical plant
engaged in the manufacture of edible vegetable and salad oils. They
are made by refining, bleaching, deodorizing, and plasticizing
fats and oils. Water (approx. 6.2 mgd) used by the plant comes from
wells on Company property. This water is used for cooling and processing.
The plant employs 410 people and operates continuously.
Chronology of Contacts
On October 6, 1971, W. C. Smith, of the Environmental Protection '
Agency (EPA), National Field Investigations Center-Denver (NFIC-D):
Joseph Alleman, Baton Rouge Field Station, EPA; and Bobby W. Fisher,
Memphis and Shelby County Health Department, conducted a preliminary
inspection of the HuraKo Products (Thomas Street) plant. HumKo Products'
Manager of Design Allen Fritsche and Plant Manager J. Crafton were apprised
of the purpose of the survey. Mr. Fritsche cooperated with EPA and
granted permission to sample the HumKo Products (Thomas Street) effluent.
(Mr. Fritsche was acting in behalf of Curt Meierhoefer, Vice President,
Engineering, during this plant inspection.)
George Harlow, Chief, Enforcement Branch, EPA, Region IV, wrote
a letter [Appendix C], during January 1972, to Mr. Fritsche, confirming
the date of the investigation and requesting written permission to
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74
sample. THis method was taken to advise HumKo Products (Thomas Street)
that information provided and data regarding discharges from the premises
of the Company may be used as evidence against the firm in abatement
proceedings under the applicable laws.
On February 3, 1972, Mr. Meierhoefer replied to Mr. Harlow's letter,
granting EPA permission to sample [Appendix C].
At the time of the survey Mr. Crafton indicated it was necessary for
a HumKo. employee to accompany NFIC-D personnel during the time they were
in the plant to sample the effluent. B. E. Benson and U. Z. Hardy of
NFIC-D, on February 16, 1972, made final sampling arrangements.
B. WASTE SOURCES & TREATMENT
The major discharge (approx. 5.0 mgd) is pretreated by pH control
and air flotation for 'oil and grease removal prior to being discharged
to the Wolf Interceptor. The second effluent stream (approx. 1.2 mgd)
is discharged, without pretreatment, into Leath Bayou, Cypress Creek,
and eventually into the Wolf River. A U.S. Army Corps of Engineers
permit application has been filed for the second discharge, but none
has been -filed for the major effluent stream that discharges into the
Wolf Interceptor. The sanitary wastes plus boiler blowdovni are dis-
charged to the Wolf Interceptor. The two major process-waste streams
were designated at HT-ll-A (untreated) and HT-ll-B (treated) for this
survey [Figure HT-1],
C. DISCUSSION OF IN'-PLANT EVALUATION & RESULTS
Sampling Procedure
Wastewater flows were sampled on plant property at the designated
locations [Figure HT-1]. Flow from the major wastewater stream (HT-ll-B)
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\
-N-
DISTRIBUTION BOX
HT-11-B
f
HUMKO PRODUCTS PLANT AREA
MANHOLE f
HT-11-A
LEGEND
SAMPLING STATION
TO WOLF
INTERCEPTOR
DITCH TO
WOLF RIVER
NOT TO SCALE
Figure HT1 Humko Products Thomas Street Memphis,Tennessee
Sampling Stations HT-11-A, HT-11-B
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75
was determined using the flow device located downstream from the air flota-
»
tion unit. The flow from the second discharge (HT-ll-A) was estimated by
subtracting the flow at discharge HT-ll-B from the total water intake.
A SERCO automatic sampler was used at each location, and, beginning
on February 18 and ending February 21, 1972, a sample was collected every
hour for three 24-hr periods. At the end of each period the samples were
composited and aliquoted into the appropriate containers for shipment and
analyses. The samples requiring immediate analyses were transported to a
mobile EPA laboratory in Memphis. The other samples were preserved and
shipped by air freight to the NFIC-D (EPA) laboratory. Temperature, pll,
and conductivity were measured twice daily on grab samples at eacli location.
Also, grab samples were collected once daily for oil and grease analyses.
Discussion of Results
A summary of the analytical results from the HumKo (Thomas Street)
plant is presented in Table HT-1. The data from sampling station HT-ll-B
indicate that HumKo (Thomas Street) is discharging a hot effluent (101-
105 °F) with'a pH range of 3.0-11.4 to the Wolf Interceptor. Average
loads of 65,700 Ib of BOD; 6,620 Ib, TOC; 113,000 Ib, COD; 43,500 Ib,
suspended solids; 47,000 Ib, oil and grease; 10 Ib, phenolic materials;
9.3 Ib, copper: 24.1 Ib, zinc; 100 Ib, chromium; and 4.8 Ib of lead per day
were being discharged to the City interceptor and, subsequently, into the
Mississippi River. Data from sampling station HT-ll-A showed that HumKo
was discharging an effluent containing 90,800 Ib of BOD; 44,700 Ib, TOC;
110,000 Ib, COD; 53,400 Ib, suspended solids; 62,000 Ib, oil and grease;
26.1 Ib, phenolic materials; 15.2 Ib, zinc; 18.5 Ib, chromium; and 12.2 Ib
lead per day to Cypress Creek which drains into the Wolf River.
-------
TABLE HT-1
SUMMARY OF FIELD DATA AND ANALYTICAL.RESULTS
HUMKO PRODUCTS (THOMAS STREET)
February 13-21, 1972
Parameters-
Flow (mgd)
pli
Temperature, °C
Conductivity
(umhos/cm)
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Turbidity (JTU)
Phenolic Materials
Cyanide
Copper
Cadmium
Z inc
Total Chromium
Mercury, yg/l
Lead
"T-ll-A
Range
1.15-1.34
2.6-9.9
33.0-49.5
1,000->8,000
2,200-15,000
720-6,350
4,820-24,100
128-3,400
5,650-58,100
170-15,000
230-300
1.3-4.8,
<0.02-
0.16-0.47
0.02-0.07
0.24-2.5
0.95-2.7
0.7-5.3
0.32-1.9
Average
8,570
4,220
16 , 400
5,040
32,200
5,800
540
2.5
<0.02
0.31
0.04
1.45
1.75
2.3
1.2
HT-11-A
Load
90,300
44,700
110,000
53,400
339,000
62,000
27
3.3
0.44
15.2
18.5
0.024
12.2
HT-ll-B
Range
4.62-5.41
3.0-11.4
39.0-43.5
500->8,000
990-2,100
100-200
739-4,680
181-1,600
4,420-9,790
370-2,000
80-700
0.22-0.28
<0.02-
0.20-0.24
0.02-0.03
0.46-0.75
1.3-3.1
0.8-13.6
0.09-0.13
Average
1,54(£7
157
2,670
1,030
6,870
1,100
370
0.24
0.22
0.02
0.57
2.4
5.3
0.11
IIT-ll-B
Ib/day
65,700
6,620
113,000
43,500
165,000
47,000
10
9.3
1.0
24.1
100
0.23
4.8
ji/ All units are in mg/1 unless otherwise noted.
b_/ Average of two numbers.
c/ Minimum detectable limit.
-------
77
Article IV, Section 4(c), City of Memphis Ordinance No. 460
prohibits the discharge of an effluent having a pll less than 5.5.
Section 5(j) prohibits the discharge of wastes having a pH greater than
9.5. The data [Table. HT-1] indicate that the stream discharged to the
City interceptor is violating this regulation. Section 5(b) prohibits a
discharge containing oil and grease concentrations in excess of 100 rag/1.
The HT-ll-B discharge had an average oil and grease concentration of
1,100 mg/1. Section 5(e) prohibits the discharge of wastes containing,
among other metals, copper, zinc, chromium and lead. Concentrations of
these metals in the HumKo (ThoTnas Street) discharge were 0.22; 0.57;
2.4; and 0.11 rag/1 respectively. This corresponds to 9.3 Ib of copper;
24.1 Ib, zinc; 100 Ib, chromium; and 4.3 Ib of lead.
The discharge., by the HumXo Products (Thomas Street) plant, of refuse
(carbonaceous materials; oil and grease; suspended solids; copper; zinc;
chromium; and lead) into the Mississippi River via the Wolf Interceptor
without a permit from the U. S. 'Army Corns of Engineers, constitutes a
violation of Section 407, Rivers and Harbors Act of 1899 (33 USC: 401-413).
D. SUMMARY & CONCLUSIONS
1. The IhimKo Products (Thomas Street) plant discharges an effluent
containing an average daily loading of 65,700 pounds of BOD; 6,620 pounds,
TOG; 113,000 pounds, COD; 43,500 pounds, suspended solids; 47,000 pounds,
oil & grease; 10 pounds, phenolic materials; 9.3 pounds, copper; 24.1
pounds, zinc; and 100 pounds of chromium to the Wolf Interceptor that
discharges into the Mississippi River.
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78
2. Lack of a municipal waste treatment system results in raw
wastewater being discharged directly into the Mississippi River via
the interceptor system.
3. Discharge of industrial wastes containing high biochemical
oxygen demand, total organic carbon, chemical oxygen demand, suspended
solids, oil and grease, and other pollutants into the Mississippi River
without a permit from the U.S. Army Corps of Engineers is a violation
of Section 407, Rivers and Harbors Act of 1899 (33 USC: 401-413).
4. High concentration of oil and grease, phenolic materials, and
of chromium, and variations in pH violate sections of the Memphis City
Ordinance on the Regulation of Sewer Use.
5. In addition, HuraKo Products discharges an untreated effluent
containing an average daily loading 'of 90,800 pounds of biochemical
oxygen demand; 44,700 pounds of total organic carbon; 110,000 pounds
of chemical oxygen demand.: 53,400 pounds of suspended solids; 62,000
pounds of oil and grease; 27 pounds of phenolic materials; 15.2 pounds
of zinc; 18.5 pounds of chromium; and 12.2 pounds of lead into Cypress
Creek and thence into the Wolf River. This waste discharge also vio-
lates the Rivers and Harbors Act of 1899.
E. RECOMMENDATIONS
It is recommended that:
1. HumKo Products (Thomas Street) provide pollution control facili-
ties, for the stream that discharges to the Wolf Interceptor (HT-ll-B),
in order to reduce biochemical oxygen demarul, chemical oxygen demand,
suspended solids, oil and grease, and toxic or hazardous materials to
-------
79
the levels»attainable employing best practicable treatment. These
levels are:
Component mg/1 Ib/day
BOD 30 1,250
COD 100 4,100
Suspended Solids 30 1,250
Oil & Grease 5 210
Phenolic Materials 0.1 4.0
Chromium 0.1 4.0
2. HumKo Products (Thomas Street) provide pollution control facili-
ties, for the stream that discharges to the Cypress Creek (HT-ll-A), in
order to reduce biochemical oxygen demand, chemical oxygen demand,
suspended solids, oil and grease, and toxic or hazardous materials to
the levels attainable employing best practicable treatment. These
levels are:
Component mg/1 Ib/day
BOD 30 305
COD . 100 1,000
Suspended Solids 30 305
Oil & Grease 5 50
Phenolic Materials' 0.20 2.0
Chromium 0.10 . 1.0
3. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30,'1974.
4. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with Recom-
mendations Numbers 1 and 2.
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80
5. Upon.the failure of HumKo Products Chemical Division to provide
a satisfactory documented commitment to achieve the goals identified in
Recommendations 1, 2, and 3 appropriate abatement proceedings be
initiated under the Rivers and Harbors Act of 1899.
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81
HUNT-WESSON FOODS
P. 0. BOX 2674
MEMPHIS, TENNESSEE
A. BACKGROUND INFOR>fATI ON
General
Over the past three to four years the Hunt-Wesson (Memphis) plant
has beea under considerable pressure from the Tennessee Water Quality
Control Board and from the.Memphis and Shelby- County Health Department
to establish -proper waste treatment and to cease gross pollution in
Cane Creek. About two years ago the Company undertook a rather com-
prehensive engineering study intended to formulate alternative methods.
of reducing plant waste loads. Little action has been taken since then.
The Tennessee Water Quality Control Board has recently ruled that
Hunt-Wesson Foods -must reduce, its plant effluent BOD level to 20 mg/1
or less; the Memphis and Shelby County Health Department-is requesting
that this maximum BOD be held between 5 and 10 mg/1.
Until approximately November of 1963, Hunt-Wesson was operating under
a series of conditional waste discharge permits from the State of Tennessee.
Although it was understood that a conditional State permit was granted to
cover the period from Hay 1969 to !-'ay 1970, neither the Company nor the
local health department officials ever received a copy of this permit
statement from the State.
Plant wastes are still being discharger' to Cane. Creek [Figure
HU'-l] although arrangements have been made to connect the discharge to
the Nonconnah Interceptor.
The Hunt-Wesson plant is a large, edible-oil refining complex. The
-------
\
*
*
f
X
v WILLIAMS 11L
HUNT
WESSON
FOODS,
INC
WAS!
^DISCW
1 1 \H W -.
^ 1 HIOIUolA I
*
i
f
I
*
.13
MIX1N
BOX
G
LEGEND
A SAMPLING STATION
-N-
TO CANE CREEK
TRIBUTARY OF
NONCONNAH CREEK
NOT TO SCALE
Figure HW-1 Hunt Wesson Foods,Inc.Memphis,Tennessee
Sampling Station HW-13
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82
firm employs 225 persons and operates continously. The plant receives
its water (approx. 2.3 mgd) almost entirely from wells. The total is
divided as follows: 1.3.1 mgd for cooling purposes; 0.12 mgd for boiler
feed; 0.79 mgd for process; and 0.01 mgd or less for sanitary purposes.
None of the streams are recycled.
Under varying conditions the plant can make partially refined oils
for the market, or receive partially refined oils and complete the process.
Crude cottonseed and soybean oils are converted to edible vegetable oils
and shortening products by means of caustic soda treatment; hydrogenation;
steam distillation; bleaching; and deodorizing. The vacuum steam strip-
ping process for deodorizing the vegetable oils is currently responsible
for 75 percent of the BOD waste load and 25 percent of the waste volume
from the Company refinery.
Chronology of Contacts
The Company was visited by E. J. Struzeski, Jr., Environmental Pro-
tection Agency (EPA), National Field Investigations Center-Denver (NFIC-D),
EPA, on October 7, 1971. Hunt-Wesson Plant Manager D. C. VanSickle and
Production Manager 1-lobert Gunther conducted a tour of the facilities
and explained the processes and waste'rfater treatment. George Harlow,
Chief," Enforcement Branch, Region IV, EPA, wrote a letter [Appendix C],
during January 1972, to Mr. Gunther advising him of the date of the
investigation and requesting written permission to sample. This method
was taken to advise Hunt-Wesson Foods that information provided as well
as data regarding discharges from -the Company premises may be used as
evidence against the firm in abatement proceedings under the applicable
-------
83
laws. On February 3, 1972, Mr. Gunther, in reply to Mr. Harlow's letter,
granted EPA written permission to sample.
a
On February 11, 1972, NFIC-D investigators W. C. Smith and E. Mann met
with Messrs. Gunther and Wadley to make final arrangements for sampling.
B. WASTE SOURCES & TREATMENT
Process water, washings from the caustic soda treatment and filtration-
absorption processes, and filter backwash are collected in a common drain
that feeds into a "home-made" oil-grease separator equipped with provisions
for continuous skimming [Figure HW-1], Skimmings are reported to be returned
to the plant for reprocessing. Detention time in the separator (8-ft water
.depth) is approximately 12 to 15 minutes. The separator effluent is then
directed to a junction manhole. At this point the effluent combines with
a relatively large, clear flow of wastewater judged to be cooling waters
from the plant.
Hunt-Wesson has executed a contract with.the City to connect the
plant effluent into the Monconnah Interceptor.
An application for a permit to discharge has been filed with the
U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLANT EVALUATION & RESULTS
Sampling Procedure
The Hunt-Wesson discharge was sampled on the plant property, where
all waste streams combined in a mixing box [Station HW-13, Figure HW-1].
From February 18 to 21, 1972, a SERCO automatic sampler collected one
sample every hour for three 24-hour periods. At the end of each period
-------
84
the samples were composited and aliquoted to the appropriate containers
for shipment and analyses. Then frhey were transported to a EPA mobile
laboratory in Memphis or shipped air freight/express to the NFIC-D (EPA)
laboratories. Grab samples, were taken twice daily in order to obtain
temperature, pH, and conductivity and were- collected once daily for
oil and grease analyses.
Discussion of Results
The pH of the discharge varied from 2.0 to 7.1 [Table HW-1]. An
effluent containing average daily loading of 998 Ib of BOD; 5,740 Ib,
TOG; and 2,590 Ib of COD was being discharged to Cane Creek. The
concentration of oil and grease ranged from 7 to 34 mg/1; this value
amounts to an average daily loading of 400 pounds.
The reach of Nonconnah Creek into which Cane Creek drains is
classified by the State Board for fish and aquatic life. The strong
pollutional load that Hunt-Wesson discharges into Cane Creek causes the
receiving waters of Nonconnah Creek to deteriorate in quality.
Should Hunt-Wesson connect to the City Interceptor it would be
necessary that pfl be maintained between 5.5 and 9.5 as specified in
Memphis Ordinance 460.
If Hunt-Wesson continues to discharge into Cane Creek the Company
must build treatment facilities comparable to the best practicable control
technology currently available and achieve effluent conditions of less
than 20 mg/1 each of BOD and suspended solirls and less than 5 mg/1
oil and grease.
-------
85
TABLE HW-1
SUMMARY OF FIELD DATA .AND ANALYTICAL RESULTS
HUNT-WESSON FOODS
February 18-21, 1972
a/
Parameters-
Flow (mgd)
PH
Temperature, °C
Conductivity, ymhos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Total Kj-N
HH--N
Org-N
NO,., NO -N
? 3
ToEal P
Turbidity, JTU
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
2.0-7.1
. 25.. 5-39.0
180-360
26-100
226-374
32-336
75-151
226-374
7-34
0.4-4C)
<0 . 1-
0.4-4.0,
^0.0 5
0.16-0.20
8-24h/
<0.01g-y
<0.01
O.Q3-0.05
<0.01
<0. 03^- -0.03
Average
2.3
52
299
135
105
299
21
1.7, /
D /
1.7
-------
86
D. SUMMARY & CONCLUSIONS '
1. The Hunt-Wesson plant discharges an effluent containing an
average daily loading of 998 pounds of BOD: 5,740 pounds, TOC; 2,590
pounds, COD; and 400 pounds of oil and grease into Cane Creek, which
flows into Nonconnah Creek (a tributary of' the Mississippi River).
2. Treatment of this discharge consists of a small oil-grease
separator; it is not sufficient- to provide adequate treatment of the
wastewater being discharged into Cane Creek. This discharge violates
the Rivers and Harbors Act of 1899.
3. The Company has failed to meet the 20 mg/1 BOD effluent limita-
tion set by the Tennessee Water Quality Control Board or the 10 rng/1
effluent BOD level recommended by the Memphis and Shelby County Health
Department. Although the Company has been under constant presure from
City and State officials, in the past two years it has made few attempts
to improve the wastewater treatment facilities.
E. RECO^iENDATIONS
It is recommended that:
1. If Hunt-Wesson continues to discharge to Cane Creek the Company
must provide pollution control facilities to reduce the biochemical
oxygen demand, chemical oxygen demand, suspended solids, and oil and
grease to the levels attainable employing best practicable treatment.
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87
These levels are:
Component mg/1 Ib/day
BOD " 20 330
COD 30 1,520
Suspended Solids 20 . 380
Oil & Grease 5 90
3. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30, 1974.
3. If the Hunt-Wesson discharge is connected to the interceptor
.system the pH be maintained between 5.5-9.5.
4. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of the wastewater discharge to ensure compliance with Recom-
mendation Numbers 1, 2 and 3.
5. Upon the failure of Hunt-Wesson .Foods to provide a satisfactory
documented commitment to comply with Recommendations 1, 2 or 3, appro-
priate abatement proceedings be initiated under the Rivers and Harbors
Act of 1399.
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88
ICI AMERICA, ING.
1285 POPE STREET
MEMPHIS, TENNESSEE
A.. BACKGROUND INFORMATION
General
ICI America, Inc. (formerly Atlas Chemical Company) is engaged
in the production of food emulsifiers by a batch process. The plant
receives vegetable oils, lard, tallow, and glycerin that are reacted,
in the presence of a catalyst, to form mono-glycerides and edible oils.
Other raw materials include sodium hydroxide, lime, and phosphoric acid.
The plant operates 2 shifts per day, 5 days per week and employs
approximately 28 people.
Water used in thin plant is provided by the City of Memphis.
Chronology of Contacts
On October 5, 1.971, W. C. Smith, Environmental Protection Agency
(EPA), National Field Investigations Center-Denver (NFIC-D): Joseph
Alleman, EPA Baton Rouge Field Station; Bobby W. Fisher and Hugh Teaford,
Memphis and Shelby County Health Department' conducted a preliminary
inspection of the ICI America plant. Mr. F. Zawicki, Plant Manager,
was apprised of the purpose of the survey. He cooperated with the
EPA and granted permission to sample the plant effluent.
During January 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter confirming the date of the investigation
and requesting written permission to sample. This method was taken to
advise ICI America that information provided, and data regarding dis-
charges from the premises of the Company, may be used as evidence
-------
89
against the firm in abatement proceedings under the applicable laws.
On February 1, 1972, S. A. LaRocca, Supervisor, Sanitary Engi-
neering, in a reply to Mr. Harlow's letter, granted EPA permission to
sample [Appendix C].
B. WASTE SOURCES AND TREATMENT
At the time of the survey a small grease skimmer was the only
treatment for the discharge. The discharge flows from the grease
skimmer into a ditch that carries the waste to Workhouse Bayou and
then to the Wolf River. This waste will go to the City of Memphis
interceptor system when the interceptor is completed.
An application for a permit to discharge has been filed with the
U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure
The discharge to Workhouse Bayou (AC-20) was sampled on Company
property just downstream from the grease skimmer [Figure ICI-1]. A SERCO
automatic sampler was used, and, beginning on February 22 and ending
February 25, 1972, a sample was collected every hour for three 24-hr periods,
At the end of each period the samples were composited and aliquoted to the
appropriate containers for shipment and analj'ses. They were then trans-
ported to a mobile EPA laboratory in Memphis or shipped air freight/express
to the NFIC-D (EPA) laboratories. Whenever possible the ICI America
Company personnel were provided with a split sample. Grab samples were
collected twice daily in order to .obtain temperature, pH, and conductivity
and once daily for oil and grease analyses. Flow was measured by EPA
personnel and checked with Company water meter figures.
-------
col
-N-
TO
WORKHOUSE
BAYOU
AC-20A TO WOLF
RIVER
I
ICI
f i
AMERICA INC.
1
1
^J
HUMKO
PRODUCTS
PROPERTY LINE
HUMKO PRODUCTS
LEGEND
A SAMPLING STATION
.WASTE DISCHARGE
PIPELINE
NOT TO SCALE
Figure ICI1 ICI America Inc.Memphis, Tennessee
Sampling Station AC-20
-------
90
Discussion'of Results
The discharge from ICI America was highly carbonaceous, with concen-
trations of BOD, COD, and TOG of 470, 7455and 275 mg/1, respectively
[Table ICI-1]. Because the flow rate was low (0.02-0.08 mgd) this effluent
did not constitute a large discharge load. The oil and grease concen-
tration was excessive, with values ranging from 50 to 290 mg/1. This
situation indicates that the grease skimmer provided for the discharge
stream cannot do an adequate job of removing the large quantity of oil
and grease present.
There are many wastewater treatment practices available in current
technology to adequately treat a highly carbonaceous stream also con-
taining oil and grease. The low volume of flow and the near absence of
toxic material make the discharge more amenable to treatment.
The reach of the Wolf River that receives the discharge from ICI
America is classified by the Tennessee Water Quality Control Board
for use for fish and aquatic life. The oil and grease discharged by
ICI America mmay be detrimental to this use.
D. SUMMARY AND CONCLUSIONS
1. The discharge stream from ICI America contains average levels
of 470 rag/1 BOD; 275 mg/1 TOC; 745 mg/1 COD; and 140 mg/1 oil and grease,
and contributes an average load of 226 Ib of BOD; 133 Ib, TOC; 359 Ib,
COD; and 80 Ib of oil and grease per day.
2. Because of the low flow rate the chemical and organic load to
the Wolf River is not excessive; however, the treatment provided
is not consist-&nt with best practicable treatment.
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91
TABLE ICI-1
SUMMARY OF FIELD DATA MV ANALYTICAL RESULTS
ICI AMERICA, INC.
February 22-25, 1972
a/
Parameter1-
Flow, mgd
PH
Temperature °C
Conductivity, umhos/cm
BOD
.TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Turbidity, JTU
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
0.02-0.08
6.9-7.5
22.0-43.0
130-270
340-560
220-310
640-803
17-86
170-602
50-290
25-38 .
0.01-0.03
<0.01-7
0.08-0.15
<0.03-7-0.04
Average
470
275
745
56
447
140
34
0.02
0.11
<0.04
Load
Ib/day
226
133
359
34
267
80
0.05
aj All units are in mg/1 except as noted.
b/ Minimum detectable value.
-------
92
3. The grease skimmer provided by ICI America does not sufficiently
treat oil and grease and the carbonaceous matter in its discharge.
4. ICI America, Inc., officials plan to connect the wastewater
discharge to the City of Memphis interceptor system when it is completed.
E. RECOMMENDATIONS
It is recommended that:
1. ICI America, Inc. provide pollution control facilities for its
discharge to reduce biochemical oxygen demand, chemical oxygen demand,
suspended solids, and oil and grease to the levels attainable employing
best practicable treatment. These levels are:
Component mg/1 Ib/d ay
BOD 30 15
COD 100 50
Suspended Solids 30 15
Oil and Grease 5 2.5
2. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete Construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30, 1974.
3. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of the ICI America, Inc., discharge to ensure compliance
with Recommendations 1 and 2.
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93
INTERNATIONAL HARVESTER COMPANY
FARM EQUIPMENT DIVISION
3003 HARVESTER STREET
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The International Harvester Company plant at this location is a
completely integrated farm machinery manufacturing facility. Starting
with iron ingots as the raw material, this plant, through a series of
operations, produces finished farm equipment. The various processes
include: casting; shearing; bending; machining; welding; assembling;
washing; plating; and painting of fabricated pieces. Water used in
this plant is supplied by the City of Memphis.
Approximately 2,200 persons are employed at the plant that operates
continuously, five days per week.
Chronology of Contacts
On October 5, 1971, W. C. Smith, Environmental Protection Agency
(EPA) National Field Investigations Center-Denver (NFIC-D); Joseph
Alleman, Baton Rouge Field Station, EPA; Bobby W. Fisher and Hugh Teaford,
Memphis and Shelby County Health Department, conducted a preliminary
inspection of the International Harvester plant. R. E. McClure, Plant
Manager, was apprised of the purpose of the survey. Mr. McClure cooper-
ated with the EPA and granted permission to sample the plant effluent.
During January 1972, George Harlox?, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter to Mr. McClure [Appendix C], confirming the
date of the investigation and requesting written permission to sample.
-------
94
This means'was taken to advise International Harvester that information
provided, and data regarding discharges from the premises of the Company,
may be used as evidence against the firm in abatement proceedings under
the applicable laws.
On February 2, 1972, Mr. McClure, in reply to Mr. Harlow's letter,
granted EPA permission to sample the Company's.effluent [Appendix C].
B. WASTE SOURCES AND TREATMENT
The major process waste from this plant originates in the plating
process. The main characteristics of this waste are excessive amounts
of chromic acid, paint products, chromium, zinc, and oil and grease.
The chromic acid dragout, from the plating process, is passed over
a. limestone bed and then blended with alkali wastes designated for
neutralization. Acid phosphate liquors that must be neutralized are
blended with alkaline cleaners and effluents from the powerhouse. Excess
spray paint is precipitated and coagulated by means of alkali additions.
These wastes are all combined into a 72-in. pipe that empties into a
ditch discharging to the Mississippi Paver.
An application for a permit to discharge has been filed with the
. U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLANT EVALUATION ALTj RESULTS
Sampling Procedure
The discharge to the Mississippi River (1H-17) was sampled on Company
property at a point downstream from where the 72-in. pipe empties into an
open ditch [Figure IK-1]. A SERCO automatic sampler was used, and begin-
ning on February 22 and ending February 25, 1972, a sample was collected
-------
-N-
72" OUTFALL
DITCH
IH-17
_P_R_0_CJ_SS WASTE DISCHARGE
I
I
INTERNATIONAL
HARVESTER
LEGEND
A SAMPLING STATION
NOT TO SCALE
Figure IH1 International Harvester Memphis, Tennessee
Sampling Station IH-17
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95
every hour for three 24-hr periods. At the end of each period the samples
were composited and aliquoted to the appropriate containers for shipment
and analyses. They were then transported to a mobile EPA laboratory in
Memphis or shipped air freight/express to the NFIC-D laboratories (EPA).
Grab samples were taken twice daily in order to obtain temperature, pH,
and conductivity measurements. Flow readings were taken from Company
water-use meters.
Discussion of Results
The effluent discharged by International Harvester to the Mississippi
River contained an average daily loading of 425 pounds of 30D: 5,300
pounds, TOC: and 1,'630 pounds of COD.
In addition to having.this.chemical and organic 'loading, the effluent
also contained 15.9 pounds of chromium and 9.2 pounds of lead. These
figures correspond to average concentrations of 1.2 rag/1 chromium and
0.7 rog/I lead. [A summary of these data'is presented Table IH-1.]
The reach of the Mississippi receiving this discharge is classified
by the Tennessee Water Quality Control Board for industrial use, fish
and aquatic life, irrigation, recreation, livestock watering, wildlife,
and navigation. Discharges containing loading such as those from
International Harvester, and especially the heavy metals, violate the
water quality criteria set forth by the State for these specific uses.
The treatment presently provided by International Harvester is net
adequate to protect the quality of the receiving waters. An implementation
schedule must be adopted for the timely abatement of this pollution source.
-------
TABLE IH-1
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
INTERNATIONAL HARVESTER COMPANY
February 22-25, 1972
96
a/
Parameteir-
Flow , mgd
pH
Temperature, °C
Conductivity, umhos/cm
BOD
TOG
COD
Suspended Solids
Total Solids
Turbidity, JTU
Cyanide
Copper
Cadmium
Zinc
Total- Chromium
Lead
Range
1.59-1.66
4.5-7.9
. 20.5-22.0
180-230
21-39
314-437
100-152
142-260
314-437
b3}-45 c/
<0. 02-' -0.03-
0.03-0. 1Q
<0.01-'
0.11-0.12
0.5-1.6
0.3-1.2
Average
31
387
122
206
387
36
<0.02
0.06
<0.01"7
0.12
1.2
0.7
Load
Ib/day
425
5,300
1,680
2,830
5,300
0.8
1.6
15.9
9.2
_a/ All units are in rag/1 except as noted.
b_/ Minimum detectable limit. '
_c/ Samples analyzed after maximum preservation time had expired,
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97
D. -SUMMARY AND CONCLUSIONS
1. The International Harvester Company discharges to the Mississippi
an effluent containing an average daily load of 425 pounds of BOD; 5,300
pounds, TOC; 1,680 pounds, COD; 15.9 pounds, chromium; and.9.2 pounds
of lead. The discharge of these toxic materials to the Mississippi River
is'a violation of the Rivers and Harbors Act of 1899.
2. International Harvester is not providing adequate treatment of
wastewaters being discharged to the Mississippi River.
3. The presence of zinc and chromium and t!,ie pH fluctuation in the
International Harvester discharge violate Federally approved water quality
criteria established by the Tennessee Water Quality Control Board.
E. RECOMMENDATIONS
It is recommended that:
1. International Harvester provide pollution controls to reduce
the loads discharged to the Mississippi River to the levels attainable
employing best practicable treatment. These levels are:
Component . mg/I Ib/day
BOD ' 30 400
COD 100 1,400
Suspended Solids 30 ' 400
Oil and Crease 5 68
Zinc 0.1 1.3
Total Chromium 0.1 1.3
The pl-1 be controlled and maintained between 6.0 and 9.0.
2. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
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98
- Meet treatment criteria outlined herein by December 30, 1974.
3. EPA, in cooperation v;ith Jrhe Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process v/aste discharges-to ensure compliance with Recom-
mendations Numbers 1 and 2.
A. Upon the failure of the International Harvester Company to
provide a satisfactory documented commitment to achieve the goals
identified in Recommendations 1 and 2 appropriate abatement proceedings
be initiated under the Rivers and Harbors Act of 1899.
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99
KIMBERLY-CLARK CORPORATION
MEMPHIS MILL
P. 0. BOX 7066
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The Kimberly-Clark Corporation manufactures a full line of paper
products including facial tissue, toilet tissue, napkins, etc. The
Company employs 1,560 people to operate the plant continuously. The
plant has eight wells that provide an average of 7.84 mgd water, used
as follows: 0.36 mgd for cooling-water; 0.04 mgd, boiler-feed; 6.9 mgd,
process-water; 0.275 mgd, sanitary system; and 0.05 mgd for other needs.
Incoming pulps (bleached and unbleached) and some secondary fibers
are beaten and re-pulped. The stock is passed through a "save-all" to
partially recover fibers from the water medium. Fast dyes, tetrasodium
pyrophosphate, sulfuric acid, animal glue, lime, talc, and various other
agents are added to the stock in order to obtain certain properties. The
material is subsequently directed to paper machines where the creped
paper wadding is formed. The creped paper is then converted to the
various paper products. Although different colored items are manufactured,
the plant was making only white products during the survey.
Chronology of Cojntacts
On October 5, 1971, W. C. Smith, Environmental Protection Agency (EPA),
National Field Investigations Center-Denver (NFIC-D); Joseph Alleman,
Baton Rouge Field Station, EPA, and Bobby W. Fisher and Hugh Teaford,
Memphis and Shelby County Health Department, visited the Kimberly-Clark
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100
Corporation and discussed the Memphis Area Water Quality Survey. They
spoke with Kimberly-Clark Plant Manager John Rezba, and Paul Schubert, who
were at first hesitant to allow EPA to sample; but, after some discussion,
permission was granted.
In January, 1972 George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter [Appendix C] to Mr. Rezba confirming the date
of the investigation and requesting written permission to sample. This
method was taken to advise the Kimberly-Clark Corporation that information
provided, and data regarding discharges from the company premises, nay
be used as evidence against the firm in abatement proceedings under the
applicable laws. On February 3, 1972, in a reply letter to Mr. Harlow,
Mr. Rezba granted EPA written permission to sample.
The Kimberly-Clark Corporation was again visited on February 15, 1972,
by E. Mann of EPA, NFIC-D, and Mr. Fisher of the Memphis and Shelby County
Health Department in order to make final arrangements for sampling.
B. WASTE SOURCES AND TREATMENT
There are two principal discharges front the Kimberly-Clark mill.
The first consists of industrial wastes from the re-pulping process.
The discharge is high in color, turbidity, BOD, COD, solids, and
nitrogen. Data submitted to the Tennessee Water Quality Control Board
[Table K-l] reveal that the average BOD level exceeds 100 rag/I and the
suspended solids concentration is usually above 200 mg/1. When these
concentrations are coupled with a flow ranging from 6-8 mgd, they
constitute a sizable loading. The discharge is pumped through a 24-in.
pipeline to the Wolf River [Figure K-l].
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101
TABLE K-l
KIMBERLY-CLARK CORPORA!ION
DATA SUBMITTED TO THE
TENNESSEE WATER QUALITY CONTROL BOARD
Parameters . Range Average
September, 1971
Flow (mgd) 5.8-7.9 6.9
Suspended Solids 129-359 203
BOD 120-128 124
October,, 1971
Flow (ragd) 6.0-7.9 6.8
Suspended Solids 137-417 257
BOD 91-151 115
February , 19? 2
Flow (mgd) 6.9-7.7 7.3
Suspended Solids 225-411 287
BOD 208-231 219
a_l All units are in mg/1 unless otherwise noted.
-------
-N-
KIMBERLY
CLARK
CORP.
LEGEND
SAMPLING STATION
NOT TO SCALE
Figure K 1 Kimberly Clark Corp.Memphis ,Tennessee
Sampling Station KC-14
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102
There'is no treatment of the wastewater discharged to the Wolf River.
However, the Company employs certain in-plant measures to reduce the waste
load entering the water. The waste stream is filtered over a "save-all" to
recover fiber before discharge; water from the tissue machines is recycled;
process-water containing fibers is segregated from other waste streams;
and the chemical used to obtain wet strength in the product has been
changed, thereby reducing the amount of phosphate required.
The second discharge consists of backwash from the intake water
treatment system, in which iron is removed from the well-water by
means of the Walker Process. This effluent comprises 14 percent
of the waste-x^ater and is discharged directly into the Wolf River.
An application for a permit to discharge both streams has-been filed
with the U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLANT EVALUATION & RESULTS
Sampling Procedure
From February 18 to 21, 1972, the process-water discharge from the
Kimberly-Clark Corporation was sampled inside the plant at a point where
the Company took samples for its own analyses. Their automatic sampler
took two aliquots every 35 seconds and composited them in a large con-
tainer for an 8-hr period. At the end of each 8-hr period, Company
personnel took a 1-gallon sample and preserved it on ice. After 24 hours,
EPA personnel picked up the three 1-gallon samples, composited them, and
aliquoted them to the appropriate containers for shipment and analyses.
Samples requiring immediate analyses were transported to a mobile EPA
laboratory in Memphis. The remainder were preserved and shipped by
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103
air freight to the NFIC-D (EPA) laboratories. Readings for temperature,
pH, and conductivity were taken daily. Grab samples were taken once
daily for oil and grease analyses.-
Discussion of Results
The BOD, TOC, and COD levels averaged 77, 209, and 411 mg/1, respec-
tively [Table K-2]. Because the measured flow ranged between 7.35 and
7.80 mgd, this amounted to a.daily average loading of 4,780 pounds of
BOD; 13,100 pounds, TOC; and 25,900 pounds of COD being discharged into
the Wolf River. In addition, the wastewater stream carried 12,700
pounds of suspended solids, 39,100 pounds of total solids, and 1,800
pounds of oil and grease per day. The reach of the Wolf River receiving
the discharge from Kimberly-Clark is classified, by the Tennessee Water
Quality Control.Board, for use as a habitat for fish and aquatic life.
The high organic, chemical, solids, and oil and grease levels can be
detrimental to fish and aquatic life and constitute a violation of these
Water Quality Criteria. .
Company officials plan to connect the wastewater discharge to the
City of Memphis interceptor system. The large volume of water combined
with the concentrations of pollutants will cause a considerable loading
on the river. The Company should take measures to treat the effluent
in such a manner that the bulk of the water could be recycled within
the plant.
D. SUMMARY AND CONCLUSIONS
1. The Kimberly-Clark Corporation discharges an effluent containing
4,780 pounds of BOD; 13,100 pounds, TOC; 25,^00 pounds, COD; 12,700 pounds,
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104
TABLE K-2
SUMMARY OF FIELD DATA .AND ANALYTICAL RESULTS
KIMBERLY-CLARK CORPORATION
February 18-21, 1972
Parameters-
Flow (ragd)
pH
Temperature, °C
Conductivity, ymhos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil and Grease
Turbidity, JTU
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
7.35-7.80
7.0-7.9
' 25.5-26.5
360-600
18-140
158-250
.340-451
40-490
375-738
14-49
38-180
0.04
<0.01^
0.04-0.60
<0. 01^-0. 01
<0. 03^ -0.10
Average
77
209
411
197
622
28
103
0.04
<0.01^
0.23
<0.01
0.05
Load
Ib/day
4,780
13,100
25,900
12,700
39,100
1,800
2.5
14.3
3.4
a/ All units are in mg/1 unless otherwise noted.
b/ Minimum detectable limit.
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105
suspended solids; 39,100 pounds, total solids; and 1,800 pounds of oil
and grease per day into the Wolf River.
a
2. The Kimberly-Clark Corporation has taken certain in-plant
measures to control pollution. These measures are not sufficient to
reduce the load being discharged to the Wolf River. There is no
treatment of the effluent stream. This discharge is a violation of
the Rivers and Harbors Act of 1899.
3. An application for a permit to discharge the two wastewater
streams has been filed with the U. S. Army Corps of Engineers.
E. RECOI-iMENDATIONS
It is recommended that:
1. Kimberly-Clark Corporation crr.ploy improved in-plant controls
to reduce the amount of water used.
2. Kimberly-Clark provide pollution abatement facilities in order
to reduce the load of pollutants to the levels attainable employing
best practicable treatment. These levels are:
Component mg/1. Ib/day
BOD 30 1,600
COD 100 5,280
Suspended Solids 30 . 1,600
Oil and Crease 5 270
3. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974,
- Meet treatment criteria outlined herein by December 30, 1974.
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106
4. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with Recom-
mendations Numbers 2 and 3.
5, Upon the failure of the Kiraberly-Clark Corporation to provide
a satisfactory documented commitment to achieve the goals identified in
Recommendations 1, 2, and 3 appropriate abatement proceedings be
initiated under the Rivers and Harbors Act of 1S99.
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107
NAVAL AIR STATION IffiMPHIS (84)
MILLINGTON, TENNESSEE
A. BACKGROUND INFORMATION
General
The Naval Air Station Memphis (84) provides basic training in
aircraft maintenance. Domestic wastes from the Air Station are treated
by a secondary treatment system. This system serves a total popula-
tion of 8,000-10,000 people.
All water used on the Station is provided by deep wells.
Chronology of Contacts
On January 18, 1972, W. .C. Smith and G. A. Stone, Environmental
Protection Agency (EPA), National Field Investigations Center-Denver
(NFIC-D) conducted a preliminary inspection of the Naval Air Station.
E. 0. Miller, Manager, Utilities, was apprised of the purpose of the
survey. Mr. Miller cooperated with the EPA representatives and granted
permission to sample the treatment plant effluent.
During January 1972, George Harlow, Chief, Enforcement Branch,
EPA, Region IV, wrote a letter to Mr. Miller [Appendix C] confirming
the date of the investigation and requesting written permission to sample,
This method was taken to advise Naval Air Station Memphis (84) that
information provided, and data regarding discharges from the premises
of the Naval Air Station may be used as evidence against the facility
in abatement proceedings under the applicable laws.
On February 4, 1972, Commander Jloughton of the Naval Air Station
Memphis (84), in reply to Mr. Harlow, granted permission to sample
[Appendix C]. ' °
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108
B. WASTE SOURCES AND TREATMENT
The primary sources of waste at Naval Air Station Memphis (84)
are domestic wastes and wash-down "from the aircraft maintenance area.
The treatment system is a secondary biological system consisting
of four Irahoff tanks, two trickling filters, four final settling tanks,
and a chlorine chamber [Figure M-l],
C. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure
The discharge to Big Creek (M-7) was sampled on Naval Air Station
property at a position immediately downstream from the secondary
clarlfiers [Figure M-.1]. A SERCO automatic sampler was used, and,
beginning on February 13 and terminating on February 21, 1972, a sample
was collected every hour for three 24-hr periods. At the end of each
period the samples were composited and aliquoted 'to the appropriate
containers for shipment and analyses. They were then transported to
a mobile EPA laboratory in Memphis or shipped air freight/express to
the NFIC-D (EPA) laboratories. Grab samples were collected twice
daily in order to obtain temperature, pH, and conductivity and once
daily for oil and grease analyses. Flow readings were taken from the
Naval Air Station flow meters.
Discussion of Results
At the time of the survey the discharge from the Naval Air Station
was flowing at the rate of 2.2 mgd. Average concentrations of 18 mg/1
BOD, 25 mg/1 TOG, 45 mg/1 COD, 57 mg/1 suspended solids, and 21 mg/1
oil and grease were found [Table M-l]. Operation procedures should be
-------
LIFT
STATION
PRIMARY EFFLUENT
T
IMHOFF TANKS
DISTRI-
BUTION
BOX
PROPOSED BYPASS
FINAL EFFLUENT
TO BIG CREEK
BYPASS
-M-7
CHLORINE
DETENTION
CHAMBER
DOSING
CHAMBER
PROPOSED
IMHOFF
TANK
d-
FINAL
SETTLING
TANKS
SECONDARY
SLUDGE
1 ---- 1
PROPOSED
RECIRCULATION
PUMPS
SLUDGE DRAINOFF LINE
JX
-N
DRIED SLUDGE TO LANDFILL
EIGHTEEN SLUDGE DRYING BEDS
LEGEND
PROPOSED CHANGES FOR FUTURE
POPULATION OF 15,000
A SAMPLE LOCATION
Figure M-l Naval Air Station Memphis (84) Millinglon, Tennessee
Waslewater Treatment System
-------
TABLE M-l
SUMMARY OF FIELD DATA -AND ANALYTICAL RESULTS
NAVAL AIR STATION MEMPHIS (34)
February 18-22, 1972
109
Parameter-
Flow, mgd
pH
Temperature, °C
Conductivity, umhos/cra
BOD
TOC
COD
Suspended Solids
Total Solids
Oil and Grease
Total Kj-N
N as NH
Orpanic M
N as NO-NO.
' /
Total Phosphorus
Turbidity, JTU
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
6.9-7.1
. 12-17
550-660
16-20
19-35
44-46
' 45-65
329-528
8-45
7.2-12.0
4.4-9.2
r\ H r» p
n /
<0.05i/
9.8-14.8
7-10
0.03-0.04
<0.01
.0.07-0.09
<0. 01-0. 03
0.07-0.1
Average
2.2
18
25
45
57
431
21
9.1
6.4
2.7
CO .05
12.8
8
0.03
0.08
<0.02
0.08
Load
Ib/clay
330
460
830
1,050
7,910
390
170
120
50
240
0.6
1.47
0.4
1.47
_a/ Ml units are in mg/1 unless othert-jise noted,
b/ Minimum detectable limit.
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110
practiced so that the suspended solids level is less than 30 rag/1
and the oil and grease concentration is maintained below 5 rag/1. The
Ct
nutrient concentration was not excessive; the total nitrogen and
total phosphorus concentrations averaged 9.1 and 12.8 rag/1, respectively,
Heavy metals were present only in trace amounts.
D. SUMMARY AND CONCLUSIONS
1. The Naval Air Station .Memphis (84) provides secondary treat-
ment for its wastewater before discharging it to Big Creek.
2. The effluent from the wastewater treatment plant contains
average levels of IS rag/I BOD, 25 mg/1 TOC, 45 mg/1 COD, 57 mg/1
suspended solids, and 21 mg/1 oil and grease. The nutrient level
and heavw metals concentration were not excessive.
E. RECOMMENDATIONS
1. It is recommended that the Naval Air Station Memphis (84)
control the quality of the effluent in order to maintain biochemical
oxygen demand and suspended solids concentrations below 30 mg/1,
oil and grease levels below 5 mg/1, and toxic materials and heavy
metals in trace amounts.
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Ill
CITY OF MILLINCTOM WASTEWATER TREATMENT PLANT
M1LLIKGTON, TENNESSEE
A. BACKGROUND INFORMATION
General
The sewage treatment plant is a secondary system designed to treat
the domestic waste for the City of; Millington. There are no major
industries that discharge into this system.
Past records, for February 2-4, 1971, indicate that BOD removal, ef-
ficiencies averaged about 62% and suspended solids removal efficiencies
averaged around 73%. These removal efficiencies do not reflect adequate
operation of a secondary treatment plant.
Chronology of Contacts
On January IS, 1972, W. C. Smith and G. A. Stone, Environmental
Protection Agency (EPA) National Field Investigations Center-Denver
(NFIC-D) , conducted a preliminary Inspection of. the municipal sewage
treatment plant. City 'of Millington Water Superintendent John Clement
was apprised 'of the purpose of the survey. Mr. Clement cooperated with
the EPA personnel and granted permission to sample the plant effluent.
During January 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wro_e a letter to Mr. Clement [Appendix C], confirming the
date of the investigation and requesting written permission to sample.
This method was taken to advise the City of Millington that information
provided, as well as data regarding discharges from the. premises of the
municipality, may be used as evidence against the City in abatement pro-
ceedings under the applicable laws.
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112
On February 2, 1972, Mr. Clement, in reply to Mr. Harlow's letter,
granted permission to sample [Appendix C].
v
B. WASTE SOURCES AND TREATMENT
The domestic waste to be treated by this plant originates from the
City of Millington (population 10,000).
The existing secondary wastewater treatment plant, designed for 2.0 mgd,
consists of the following [Figure CM-1] : grit removal, comr.iinutor, primary
clarifiers (2), trickliiig filters (2), final clarifiers (2), chlorine
chamber and two anaerobic digesters. One digester is cracked and does
not operate properly.
Effluent from this plant is discharged to Big Creek and then to the
Loosahatchie River.
The City of Hillington plans to connect to the City of Memphis
interceptor system when the North Treatment Plant is constructed and
operative.
C. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure.
The discharge into Big Creek (CM-8) was sampled on the City property
.immediately downstream from the chlorine chamber [Figure CM-1]. A SERCO
automatic sampler was used, and, beginning on February 18 and ending February
21, 1972, a sample was collected every hour for three. 24-hr periods. At
the end of each period the samples were composited and aliquoted into the
appropriate containers for shipment and analyses. They were then trans-
ported to a mobile EPA laboratory in Memphis or shipped air freight/express
-------
CLARIFIER
CLARIFIER
TRICKLING
FILTER
TRICKLING
FILTER
SECONDARY
CLARIFIER
SECONDARY
CLARIFIER
CHLORINE
CONTACT
CHAMBER
RETURN SECONDARY
SLUDGE
WASTE SECONDARY
SLUDGE
1
dANAEROBIC f^^
DIGESTERS I )
k 4
V
_L
SLUDGE DRYING BEDS
\
DRIED SLUDGE
TO LANDFILL
LEGEND
A SAMPLING STATION
NOT TO SCALE
igure CM1 City of Millington Waslewater Treatment Plant, Millinglon, Tennessee
Sample Station CM-8
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113
to the NFIG-D (EPA) laboratories. Grab samples x?ere collected twice
daily in order to obtain temperature, pH, and conductivity and once
daily for oil and grease analyses. Flow readings were taken from City
flow meters.
Discussion of Results
The effluent from the municipal waste treatment plant ranged from
0.65 to 1.0 rngd. The plant discharged an average daily loading of 363
pounds of BOD; 452 pounds, TOC; 845 pounds, COB; and 454 pounds of
suspended solids [Table CM-1]. These values correspond to average con-
centrations of 50, 62, 116, and 64 rag/1, respectively. Effluent concen-
trations of less than 30 mg/1 for BOB and suspended solids should be
achieved. The oil and grease concentration averaged 16 mg/1; this
concentration should be kept below 5 mg/1. The nutrient level was
moderate, having average concentrations of 19 mg/1 total nitrogen and
l-'i ng/1 total phosphorus. The heavy metal concentration is low
[Table CM-1].
At the time of the survey, the volume of wastewater being treated
was below the average design flow. The facilities are designed to be
adequate for handling the wastewater, and measures should, therefore,
be taken to operate the system more efficiently.
D. SUMMARY AND CONCLUSIONS
1. The etfluent from the Millington Wastewater Treatment Plant
contains average concentrations of 50 mg/1 BOD, 62 mg/1 TOC, 116 mg/1
COD, 64 mg/1 suspended solids, 16 ir.g/1 oil and grease, 19 mg/1 total
nitrogen, and 14 mg/1 total phosphorus.
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114
TABLE CM-1
, SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
CITY OF MILLINCTON WASTEWATER TREATMENT PLANT
February 18-21, 1972
Parameter
Flov/, mgd
pll
Temperature, °C
Conductivity, umhos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Total Kj-N
N as. NH
Organic N
N as HO -N02
Total Phosphorus
Turbidity, JTU
Copper
Cadmium
Zinc
Total Chromium
Lead
Range
0.65-1.0
6.8-7.4
9-14.5
700-750
32-69
52-78
107-123
23-120
434-764
14-19
18-20
12-14
6-8
<0.05^ _
11.4-17.7
18-23
<0.01
0.04-0.08
<0.01-/-0.02
<0. 03-0. 04
Average
50
62
116
64
613
16
19
13
7
14
21
0.02
0.07
0.01
Load
Ib/day
363
452
845
454
4,460
120
141
92
49
103
0.15
0.48
0.1
0.3
a_f All units nre in mj»/l except as noted.
b/ Minimum detectable limit.
-------
115
2. The plant was operating below the average design flow.
D. RECOMMENDATIONS
It. is recommended that:
1. The City of Millington Wastewater Treatment Plant exercise
better operational procedures to improve removal efficiencies.
2. The BOD and the suspended solids concentration in the effluent
be kept below 30 mg/1; the oil and grease level should be maintained
under 5 mg/1.
3. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor the
quality of the effluent to ensure compliance with Recommendations 1 and 2,
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116
THE QUAKER OATS COMPANY
P.O.' BOX 8035
MEMPHIS, TENNESSEE
A. BACKGROUND INFORMATION
General
The Quaker Oats Company is a major producer of furfural. Corncobs,
rice hulls, cottonseed hulls, and wood chips are reacted, over a catalyst,
with sulfuric acid in an autoclave. Furfural is recovered from the vapors,
and a portion of it may be converted to furfural alcohol, furan, tetra-
hydrofuran, and poly-tetra-methylene-ether-glycol. The ligno-cellulose.
residues are dried and recovered as salable by-products.
Approximately 550 tons of raw materials are employed to produce t'>2
tons of end products per day. Four Company wells supply 3 mgd of water
that is used for cooling, boiler feed, and processing. . City of Memphis
water (0.02 mgd) is used for the sanitary system.
The Company employs 215 people to operate the plant continuously.
Chronology of Contacts
On October 7, 1971, E. J. Struzeski, Jr. of the Environmental Pro-
tection Agency (EPA) , !\7ational Field Investigations Center-Denver (NFIC-D)
met with Technical Department Manager L. A. Grosmaire and Plant Manager
R. K. Fincher. At that tirne they gave the EPA representative a tour of
the plant and explained the operations. Messrs. Grosmaire and Fincher
were, at the same time, informed of the approaching investigation.
In January, 1972, George Harlow, Chief, Enforcement Branch, EPA
Region IV, wrote a letter to !:tr. Fincher confirming the date of the inves-
tigation and requesting written permission to sample. This means was
-------
117
taken to advise The Quaker Oaks Company that information provided and
data regarding discharges from the premises may be used as evidence
against the firm in abatement proceedings under the applicable laws,.
On February 4, 1972, Mr. Fincher, in replying to Mr. Harlow's letter,
granted EPA personnel permission [Appendix C] to sample in the plant
area of The Quaker Oats Company.
The plant was re-visited (February 15), and arrangements were made
for sampling.
B. WASTE SOURCES & TREATMENT
The Company has two wastewater streams. The first consists of strong
process v/astes (0.9 mgd) and sanitary sewage (0.1 mgd) that are discharged
without treatment to the City interceptor [Figure Q-l]. The firm has recently
taken measures to segregate these strong wastes into a separate stream.
The second waste stream, containing approximately 2 mgd of cooling water
with dissolved salts, filter backwash, and boiler ash, i-s discharged
through the main plant drainage ditch to the Wolf River. Ash residue
from the power plant is slurried to a 50 x. 350 ft ash settling pond
located at the rear of the plant property. Sediment is removed from the
pond about once a year. Detention time varies from 50 minutes to a few
hours and the overflow enters the main plant drainage ditch which in turn
leads to the Wolf River via a series of lakelets (abandoned gravel pits).
Analysis of the wastewater discharged to the Wolf River [Table Q-l]
is submitted monthly to the Tennessee Water Quality Control Board. The
data for September and October (1971) revealed that the chemical and
-------
TO WOLF INTERCEPTOR
WASTE DISCHARGE
LEGEND
A SAMPLING STATION
NOT TO SCALE
Figure Q-l The Quaker Oats Company Memphis,Tennessee
Sampling Station QO-15
-------
118
TABLE Q-l
ANALYSES OF THE QUAKER OATS DISCHARGE TO THE WOLF RIVER
SUBNITTED TO THE TENNESSEE JWATER QUALITY CONTROL BOARD
Range Average
September, 1971
pH . 7.6-10.9
Temp. °F ' . 72-94
BOD, mg/1 3-17 17
COD, mg/1 26-37 30
Flow, mgd 1.3-3.5 2.4
October, 19 ?l
pH . . 8.2-10.0
Terap. °F ' 72-98
BOD, ng/I 2-47 IS
COD, rap,/I 25-43 ' 32
Flow, mgd 1.0-2.5 1.68
February, 1972
pH 2.35-9.84 ''
Temp. °F 65-86
BOD, rag/1 12-74 ' 34
COD, mg/1 7-47 21
Flow, mgd 1.95-3.1 2.6
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119
organic pollution was low; the BOD and COD averaged approximately 18
and 31 rag/1, respectively. (Analyses made during February 1972
[Table Q-l] indicate that this stream was not grossly polluted.)
For the discharge to the Wolf River via Cypress Creek, the Quaker
Oats Company has applied to the U. S. Army Corps of Engineers for a permit.
C. DISCUSSION OF IN-PLANT EVALUATION & RESULTS
Sampling Procedure
The discharge to the Wolf Interceptor was sampled, on Company pro-
perty, in a manhole where the various waste streams are combined
[Figure Q-l]. A SERCO automatic sampler was lowered into the manhole,
andjbeginning on February 18 and ending February 21, 1972« a sample was
collected every hour for three 24-hr periods. At the end of each period
the samples were composited and aliquoted into the appropriate containers
for shipment and analyses. They were then transported to a mobile EPA
laboratory in.Kemphis or shipped air freight/express to the NFIC-D
laboratories (EPA). Whenever possible, a split sample was provided
for The Quaker Oats Company personnel. Grab samples were taken twice
daily in order to obtain temperature, pH, and conductivity and once
per clay for oil and grease analyses. Flow readings were taken from
Company flow meters.
4
Discussion of Results
The hot effluent (140-145° F) had a pll range from 4.8 to 7.4 and con-
tained average loads of 29,000 Ib of BOD, 25,400 Ib, TOC: and 54,000 Ib of
COD that were being discharged to the Mississippi River via Wolf Interceptor.
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120
These values correspond to concentrations of 3 ,970,. 3,430, and 7,590 mg/1,
respectively. [A summary of the analytical results of The Quaker Oats
Company discharge to the Wolf Interceptor is shown in Table Q-2.] The
total and suspended solids loadings averaged 88,100 and 17,000 Ib/day,
respectively.
Article IV, Section 4(c), City of Memphis Ordinance No. 460
prohibits the discharge of wastes having a pH less than 5.5. Section
5(a) prohibits the discharge of a liquid having a temperature higher
than 150°F. The temperature of.the Company discharge is under this
limit; care must be taken to avoid exceeding it. Section 5(h) prohibits
the discharge of materials that exert unusual BOD and COD demands such
as those listed above.
The reach of the Mississippi River that receives the discharge from
the Wolf Interceptor is classified by the Tennessee Water Quality Control
Board for industrial uses; fish and aquatic life; irrigation; livestock
watering: wildlife; and navigation. Under trie criteria established by
the State, pollutants that will be detrimental to any one of these uses
or that will produce toxic conditions shall not be added to the waters.
The presence of PCB Ardor 124S (22 yg/1) can be harmful to fish and
aquatic life.
Even though the Wolf Interceptor will eventually go to a wastewater
treatment plant, pretreatinent of the wastewater must be provided by The
Quaker Oats Company in order to reduce the magnitude of the load as
well as to decrease the concentration of non-biodegradable material.
-------
TABLE Q-2
* .
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
THE QUAKER OATS COMPANY DISCHARGE TO WOLF INTERCEPTOR
FEBRUARY 18-21, 1972
121
a/
Parameters
Flow, mgd
pH
Temperature, °F
Conductivity,
urahos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Turbidity, JTU
PCB Arc lor 1248,
UB/1
Copper
Cadmium
Zinc
Total -Chromium
Lead
Range
0.764-0.932
4.8-7.4
140-145
6,000-8,250
3,100-5,600
1,800-4,330
4,820-9.400
1,300-2,800
11,700-13,100
3-67
90-130
10-42
0.15-0.16
0.02-0.08
0.39-0.84
0.01-0.04
0.16-0.25
Average
3,970
3,480
7,590
2,400
12,500
44
105
22
0 . 16
0.05
0.56
0.03
0 . 20
Load
Ib / d ay
29,000
25,400
54,000
17,000
88,100
290
0.16
1.1
0.35
3.9
0.20
1.4
&J All units are in mg/1 unless otherwise noted,
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122
C. SUMMARY AND CONCLUSIONS
1. The Quaker Oats Company discharges without treatment an effluent
to the Wolf Interceptor containing an average daily loading of 29,000
pounds of BOD; 25,400 pounds, TOC; 54,000 pounds, COD; 17,000 pounds,
suspended solids; and 83,100 pounds of total solids.
2. Lack of a municipal waste treatment system results in raw waste-
waters being discharged directly to .the Mississippi River via the inter-
ceptor system.
3. The temperature and pK range of the discharge approach the
limits set forth in Memphis City Ordinance No. 460.
4. The discharge of The Quaker Oats Co-.-p.pany to the Mississippi River
and the presence of PCB Arclor 1243 contributes to violations of the
Federally approved water quality criteria established by the Tennessee
Water Quality Control Board.
5. The Quaker Oats Company discharges a second waste stream to the.
Wolf River. Based on Company data this effluent was not sampled.
6. To discharge to the Wolf River The Quaker Oats Company has
applied for a U. S. Army Corps of Engineers permit. However, the dis-
charge of the second industrial waste stream with high TOC, COD,
BOD, and solids loadings, into the Mississippi River via the Wolf
Interceptor without a permit (U. S. Amy Corps of Engineers) is a vio-
lation of Section 407, Fivers and Harbors Act of 1899 (33 USC: 401-413).
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123
D. RECOMMENDATIONS
It is recommended that:
1. The Quaker Oats Company provide adequate treatment in order to
reduce the highly carbonaceous and toxic load from its effluent to the
levels attainable employing best practicable treatment. These levels are:
Component mg/1 Ib/day
BOD .30 200
COD 100 660
Suspended Solids 30 200
PCS None None
Oil and Grease 5 30
The pll shall be maintained between 5.5 and 9.5.
2. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973
- Complete construction June 30, 1974
- Meet treatment criteria herein outlined by December 30, 1974.
3. EPA in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department will monitor
the quality of the discharge.
4. Upon the failure of The Quaker Oats Company to provide a
satisfactory documented commitment to achieve the goals identified in
Recommendations 1 and 2, appropriate abatement proceedings under the
Rivers and Harbors Act of 1899 be initiated.
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124
JOS. SCHLITZ BREWING CO!H?ANY
P. 0. BOX 18309
HOLIDAY CITY STATION
MEMPHIS, TENNESSEE
A. ' BACKGROUND INFORMATION
General
The Memphis plant of the Jos. Schlitz Brewing Company presently
makes 100,000 barrels of beer per month using barley, malt, corn, and
hops as the raw materials.
The plant began operation in August 1971, and production is expected
to increase.. While the plant was being built, certain in-plant measures
were adopted in order to reduce the load to the sewer. The effluent
from the spent-grain press is- centrifuged, and the liquor is seat to
a concentrator where it is reduced to a thick syrup, Th.is is then
remixed with the spent grain and sold as a product.
Water is supplied from Company wells. About 1.5 mgd is used on
production days and 0.4 mgd on non-production clays. It is used in the
following areas: making beer-14%; sanitary system-1%;.cooling water-25%;
makeup water for cooling towers and evaporative condensers-10%; and
washdown and clean-up-50%. Approximately 95 percent of the water used
for cooling is recycled.
The Company employs 300 persons to operate the plant continuously
5 days a week. This schedule will change as production increases.
Chronology of Contacts
Assistant Plant Manager Pat Reilly was contacted both by telephone
and by letter on January 12 and 20, 1972. W. C. Smith of the Environmental
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125
Protection Agency (EPA), National Field Investigations Center-Denver
(NFIC-D), informed him of the coming investigation in the Memphis area.
t>
During January 1972, George Harlow, Chief, Enforcement Branch, Region IV,
EPA, wrote a letter to Mr. Reilly [Appendix C], confirming the date of
the investigation and requesting written permission to sample. This
method was taken to advise the Jos. Schlitz Brewing Company that infor-
mation provided and data regarding discharges from the premises of the
Company may be used as evidence against the firm in abatement proceedings
under the applicable laws.
On February 2, 1972, Mr. Reilly granted, in a reply letter to
Mr. Harlow, written permission for EPA to sample.
On February 11, 1972, W. C. Smith and E. Mann of NFIC-D, EPA, net
with Mr. Reilly and James Humble of Sch.li.t2. The Company personnel gave
the EPA representatives a tour of the plant and explained the water uses
and discharges. Arrangements were then made for sampling.
B. WASTE SOURCES AND TREATMENT
All brewery wastes are collected within the plant and discharged
through a Parshall flume, sampling station S-24, [Figure S-l] to the
Nonconnah Interceptor. There is no pretreatment except for the in-plant
measures used to recover spent grain and liquor and to recycle cool-
ing water.
An application for a permit to discharge has not been filed with
the U. S. Army Corps of Engineers.
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-N-
BURBANK ROAD
E.RAINES ROAD
r
JOS.SCHLITZ
BREWING CO.
PARSJALL FLUME
S-24
TO
NONCONNAH
INTERCEPTOR
LEGEND
A SAMPLING STATION
NOT TO SCALE
Figure S1 Jos.Schlitz Brewing Company Memphis,Tennessee
Sampling Station S-24
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126
C. DISCUSSION OF IN-PLAMT EVALUATION AMD RESULTS .
Sampling Procedure
a
The discharge was sampled in a Parshall flume [Figure S-l] on Company
property. From February 22 to February 25, 1972, a SERCO automatic
sampler collected one sample every hour for three 24-hr periods. At the
end of each period the samples were composited and aliquoted to the
appropriate containers for shipment and analyses and were then trans-
ported to an EPA mobile laboratory in Memphis or shipped a±r freight/express
to the EPA NFIC-D laboratory. -Flow readings were obtained from a Company
flow meter. Grab samples were collected twice daily for temperature, pH,
and conductivity and once per day for oil and. grease analyses.
Di sc.uSF.Jon of Results
, The pll of the discharge ranged from 6.2 to 10.5. The effluent con-
tained an average of 10,100 pounds of BOD; 6,81.0 pounds, TOG; and 19,600
pounds of COD per day to the Mississippi Paver via the Nonconnah Interceptor.
This corresponded \:n -.verage concentrations of 1,230 rag/I BOD, 833 ir.g/1
TOG, and 2,410 mg/1 COD [Table S-l]. .
Article IV, Section 5(j), City of I'emphis Ordinance No. 460 prohibits
the discharge of wastes having a pH greater than 9.5. Section 5(h)
prohibits the discharge of materials which exert unusual BOD and COD
requirements.
The reach of the Mississippi that receives the discharge from the
Nonconnah Interceptor is classified by the Tennessee Water Quality
Control Board for industrial uses; fish and aquatic life; irrigation;
livestock watering; wildlife; and navigation. Under the criteria
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127
TABLE S-l
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
JOS. SCHLITZ BREWING COMPANY
February 22-25, 1972
a/
Parameter-
Flow (rogd)
pH
Temperature (°C)
Conductivity (ymhos/cm)
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Turbidity (JTU)
Ran^e
0.940-1.033
6.2-10.5
21.5-31.0
200-800
1,100-1,300
760-940
2,140-2,640
324-544
1,570-2,010
6-29
50-80
Averase
1,230
833
2,410
428
1,730
18
67
Load
Ib/day
10,100
6,810
19,600
3,460
14,500
140
_a/ All units are in ing/1 except as noted.
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128
established by the State, pollutants shall not be added to the water
in quantities which may be detrimental to any of these water uses.
Brewery wastes, characteristically high in organic loadings and
free from toxic chemicals and heavy metals, are readily treatable by
current water pollution control technology practices. These practices
must be adopted to reduce the load being discharged to the City sewer.
D. SUMMARY AMD CONCLUSIONS
1. The Jos. Schlit.?. Brewing Company discharges an untreated
effluent containing an average daily loading of 10,100 pounds of BOD;
6,810 pounds, TOC; and 19,600 pounds of COD into the Mississippi River
via the Nonconnah Interceptor.
2. The Jos. Schlitz Brewing Company takes certain in-plant measures
to segregate strong spent-grain wastes from the discharge. This procedure
does not sufficiently reduce the load being discharged.
3. Lack of a municipal waste treatment system results in raw waste-
waters being discharged directly into the Mississippi Paver via the. inter-
ceptor system.
4. The pH range and high BOD, COD, and TOC loadings violate sections
of the Memphis City Ordinance No. 460.
5. Discharge, into the Mississippi River, of industrial x^astes con-
taining high BOD, COD, and TOC loads without a permit from the U. S. Army
Corps of Engineers is a violation of Section 407, Rivers and Harbors Act
of 1399 (33 U-S.C.; 401-413).
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129
E. RECOMMENDATIONS
It is recommended that:
1. The Jos. Schlitz Brewing Company maintain the pll of the dis-
charge stream between 5.5 and 9.5, and provide pollution control
facilities in order to reduce biochemical oxygen demand, chemical
oxygen demand, and suspended solids to the levels consistent with City
Ordinance No. 460 and comparable with domestic sewage. These levels are:
Component mg/1 Ib/day
BOD . 240 2,000
COD 960 8,000
Suspended Solids 300 2,500
Oil.and Grease 100 800
2. An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria herein outlined by December 30, 1974.
3. EPA, in cooperation with the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department, monitor
the quality of process waste discharges to ensure compliance with the
Recommendations Numbers 1 and 2.
4. Upon the failure of the Jos. Schlitz Brewing Company to provide
a satisfactory documented commitment to achieve the goals identified in
Recommendation.-. 1 and 2, appropriate abatement proceedings under the
Rivers and Harbors Act of 1899 be initiated.
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130
THE SHALLEY MAGNESIUM COMPANY
A DIVISION OF PIPER INDUSTRIES, INC.
719 PIPER STREET
COLLIERVILLE, TENNESSEE
A.- BACKGROUND INFORMATION
General
The Smalley Magnesium Company, a division of Piper Industries, is
a producer of magnesium battery cans. The cans are formed from magnesium
rod and tubing through various mechanical processes using a graphite
lubricant. After the cans are formed, they must be thoroughly cleaned.
This is accomplished by passing them through three baths in series and
by rinsing them after each bath. The first bath, a caustic one, consists
of sodium hydroxide, trisodiuru phosphates and a wetting agent; the
second bath contains glacial acetic acid, sodium nitrate, and water;
the third is a solution of sodium nitrate, and calcium fluoride.
The Company employs 35 people and operates round the clock six
clays a week.
A plant well supplies 250,000 gallons of water per day. A small
portion is used as make-up water for the baths and as cooling water for
the cutting process. The bulk of the water is employed in rinsing the
cans after each bath.
In 1969 the Sisal Icy Magnesium Company (then Piper Brothers Plow
Worl<.s, Inc.) was discharging wastewater containing chrome to the City of
Collierville sanitary sewer system which introduced the wastes into
the stabilization lagoon. In July 1969, Memphis and Shelby County Health
Department officials discovered that the chromium wastes discharged to
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131
the Collierville treatment lagoon by the Company killed many of the
organisms necessary for the decomposition process and that the lagoon's
effluent contained about 3 mg/1 chromium.
The Company was told to remove its wastewater from the sanitary
sewer. The Health Department officials discussed this matter with both
the Company owner and the manufacturing engineer. Verbally, they agreed
that plating, would be kept to a minimum for a few months and that waste-
waters would be collected in a pond and batch treated to a safe level
(approved by the health officials) before being discharged. There would
be no unapproved discharges. The Company later increased the scope of
the plating operationsj and Company officials made plans to have proper
treatment facilities constructed. Batch treatment (under previous condi-
tions) would be allowed to continue until the new facilities were completed,
In July 1970, Memphis and Shelby.County and State Health officials vis-
ited the plant and observed, untreated wastewater entering the storm sewer-.
Although the source of the discharge was the collection pond, it amounted
to an untreated overflow. Samples of the discharge were taken; the con-
centration of chromium was found to be 900 mg/1.
During an unexpected visit to the Company on September 24, 1970,
State Health officials found that wastes were discharged from the plant
without being routed to the holding pond.
This series of actions prompted the Tennessee Water Quality Control
Board and the Memphis and Shelby County Health Department to issue a
warrant to the Piper Brothers Plow Works, Inc. for violation of the
Tennessee Public Nuisance Ordinance. The Company x-;as found guilty of
violating this ordinance.
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132
Chronology of Contacts
During January 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter [Appendix C] to Jim Baird, Manufacturing
Engineer, advising him of the date of the investigation and requesting
written permission to sample. This method was taken to advise the Smalley
Magnesium Company that the information provided, and data regarding
discharges from the premises'of the Company, may be used as evidence
against the firm in abatement proceedings under the applicable laws. On
February 3, 1972, Mr. Baird in replying to Mr. Harlow's letter granted
EPA written permission to sample the .effluent.
The Smalley Magnesium Company was visited on Tuesday, February 15,
1972, by E. Mann of NFIC-D, EPA, and Bobby W. Fisher of the Memphis and
Shelby County Health Department. Mr. Baird discussed plant operations
and explained the wastewater treatment and discharges. Arrangements were
made for sampling.
B. WASTE SOURCES C. TREATMENT
At the time of the survey two separate waste streams were being dis-
charged. From 150,000 to 200,000 gallons per day (gpd) of cooling water,
caustic and acidic rinse water, and sanitary sewage empties into an open
ditch that discharges to the Wolf River.
The second (chromium waste) stream now undergoes treatment before
discharge. Concentrated chromium wastes and chromium rinse water are
being discharged batchwise to a pond (approx. 25,000 gpd) where the pH
is adjusted for the proper treatment conditions. The contents of the
pond are pumped through pipes where sulfur dioxide is added, in-line
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133
in order to convert hexavalent chromium to the trivalent form. The pH
is again adjusted with a 25% sodium hydroxide solution to achieve the
proper precipitating conditions, and the wastewater is discharged to a
second pond of approximately .113,000 gallon capacity.
After settling in the second pond for about one day^ the water is
discharged to a ditch through a pipe located one foot below the surface
of the pond. At the time of the NFIC-D visit the chromium sludge in the
bottom of the settling pond was being dredged, and in add it ion* caustic
was unavailable for treatment measures. As a result, two of the three
days that had been planned for sampling the chromium pond were eliminated
from the schedule. Further, the pond lining appeared to be torn and
seepage i^as probably occurring.
Both of these effluent?; normally go to the City of Collierville
treatment lagoon. However, on occasions, and during the time of the
survey, the City facilities were overloaded. Therefore, the municipal
sewer line was closed to the Company. Consequently, the discharge over-
flowed into the Wolf Paver. No permit application has been filed with
the U. S. Army Corps of Engineers.
C. DISCUSSION OF IN-PLANT EVALUATION & RESULTS
Sampling Procc?.care
The rinse water was sampled at the point where it discharged to the
ditch [Figure SN-1] that drained to the. Wolf River. Beginning on
February 22 and terminating February 25, 1972, a SERCO automatic sampler
collected one sample every hour for three 24-hr periods.
-------
-N-
POPLAR AVE.
DITCH TO
WOLF RIVER
SMALLEY
MAGNESIUM
CHROMIUM
REDUCTION
LEGEND
A SAMPLING STATIONS
WASTE DISCHARGE PIPING
PB-25-A
NOT TO SCALE
Figure SM-1 Smalley Magnesium Company Collierville, Tennessee
Sampling Stations PB-25-A,PB-25-B
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134
At the end of each period the samples were composited and aliquoted
to the appropriate containers for shipment and analyses. They were then
transported to a mobile EPA laboratory in Hcmphis or shipped air freight:/
express to NFIC-D (EPA) laboratories. Grab samples were collected twice
daily for temperature, pl-^ and conductivity.
The discharge from the chromium pond, sampled on February 25, 1972,
began at 12:00 noon. At that time two grab samples were collected for
chemical analyses, including oil and grease. Temperature, pH, and con-
ductivity readings were taken periodically until the termination of the
discharge at 2:20 PH. Readings x-;ere obtained from a flow-measuring
device located at the pond outlet.
Discussion of Results
The rinse-water discharge was acidic with a pM range,of 4.3 to 6.2.
The water contained an average daily loading of 770 pounds of BOD; 253
pounds, TOG; and 667 pounds of COD. These loadings correspond to concen-
trations of 690, 216, and 571 mg/1, respectively, and to a flow rate of
125,000 to 228,000 gpd [Table SM-1].
The chromium treatment pond, discharge was caustic, with a pH range
of 11.3 to 12.3. The effluent contained an average of 160 rag/1 chromium
or 16.8 Ib in the 12,600-gal. discharge.
The section of the Wolf River receiving these discharges Is classi-
fied by the State of Tennessee for use for domestic raw water supply,
industrial, fish and aquatic life, recreation, irrigation and livestock
watering, and wildlife. The discharge of chromium and the heavy BOD, COD,
-------
TABLE SM-1
SIS-DIARY OF FIELD DATA AMD ANALYTICAL RESULTS
THE S?fALLEY MAGNESIUM COMPANY
February 22-25, 1972
Parameter
F10',7
pH
Temperature, °C
Conductivity,
umhos/cm
BOD
TOC
COD
Suspended Solids
Total Solids
Oil & Grease
Turbidity, JTU
Phenolic
Materials
Copper
Cadmium
Z inc
Total Chromium
Mercury, yg/1
Lead
Rinse and
Ran.^e
125,000-228,000 gpd
4.3-6.2
11.5-18.5
370-500
130-1,800
64-505
150-1.320
34-92
270-1,790
7-45
<0. 05^-0 .05
0.02-0.21
f ^ - 'c /
0.33-1.6
0.04-0.06
0.2-0.7
0.03-0.07
Cooling
Average
690
216
571
56
°0 Q
5
20
<0.05
0.00
<0.01-/
0.87
0.05
0.5
0.04
Water
Load
Ib/day
770
253
667
74
930. ,
r-D_/
0.11
1.03
0.08
0.75
0.06
Chromium Treatment Pond
Load
Range Average Ib/day
12,600 gal /batch
11.3-12.3
17.5-20.0
30,000-34,000
0.05r-( 0.005
0.08^ 0.006
O.OfF-7 0.005
120-200 . 160 16.8
0.28-^ 0.03
All units are in mg/1 unless otherv-/ise noted.
b_/ One value.
c/ Minimum detectable limit.
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136
and TOC loading may be in violation of the Tennessee Water Quality
Criteria that prohibit the addition of toxic substances and other
pollutional loads.
It is evident that the City of Collierville treatment system cannot
adequately treat the wastewatcr from Smalley Magnesium. Facilities at
the Company plant should be installed to treat the acid waste stream in
order to increase the pH and to yield BOD and suspended solids concen-
trations below 30 rag/1.
Current technology and careful control of the chromium waste treat-
ment system could produce an effluent having a chromium concentration
below 0.1 mg/1. The present system at Smalley Magnesium should be improved
or replaced with one that could satisfactorily treat the strong wastes.
D. SUMMARY AMD CONCLUSIONS
1. The Smalley Magnesium Company discharges an effluent containing
an average daily load of 770 pounds of BOD; 253 pounds, TOC; 667 pounds,
COD; and 16.8 pounds of chromium into the Wolf Paver.
2. The Smalley Magnesium Company is discharging its wastes into the
Wolf Paver because the City of Collierville has not accepted the effluent.
3. There is no treatment for the rinse water discharged; treatment
for chromium wastes is inadequate, resulting in high concentrations of
.chromium discharged into the Wolf River.
4. The presence of chromium in the effluent to the Wolf Paver and
the low pH and chemical and organic loading in the rinse-water dis-
charge violate the water quality criteria established by the Tennessee
Water Quality Control Board.
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137
5. Discharge into the Wolf River of industrial wastes, containing
high BOD, TOC?and COD loads and heavy metals, without a permit from the
U. S. Army Corps of Engineers may violate Section 407, Rivers and
Harbors Act of 1399 (33 U.S.C.: 401-413).
E.. RECOMMENDATIONS
It is recommended that:
1. The Sraalley Magnesium Company provide treatment facilities for
the rinse water stream in order to increase the pH and to reduce the
BOD and suspended solids to a concentration of 30 rag/I and reduce chrome
concentration to 0.1 ing/1. These levels are attainable by employing
best practicable treatment. .
2. An implementation schedule lor the pollution control facilities
be established as follows:
- Initiate construction June 30, 1973.
- Complete construction June 30, 1974.
- Meet treatment criteria outlined herein by December 30, 1974.
3. The Sraalley Magnesium Company file an application for a perr.it
to discharge with the U. S. Army Corps Engineers.
4. Upon the failure of the Smalley Magnesium Company to provide
a satisfactory documented commitment to achieve the goals identified in
Recommendations 1 and 2, appropriate abatement proceedings under the
Rivers and Harbors Act of 1899 be initiated.
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138
VALLEY PRODUCTS COITANY
384 BROOK AVENUE
MEMPHIS, TENSESSEE
A. BACKGROUND INFORMATION
General
The Valley Products Company is a chemical plant that manufactures
industrial chemicals and soaps. This plant uses animal fats and oils as
raw materials? these are converted into industrial soaps. Water from
the Memphis distribution system is used for cooling, processing, and
clean-up in the plant area. The Company employs 27 people to operate
the plant on one shift, five days per week.
Chronology of Contacts
On October 7, 1971, 11. C. Smith of the Environmental Protection
Agency (EPA), National Field Investigations Center-Denver (NFIC-D) and
Joseph Alleinan, KPA, Baton Rouge Field Station, conducted a preliminary
inspection of the Valley Products plant. Janes A. Breazeale, President,
Valley Products, was apprised of the"purpose of the survey. Mr. Breazeale
indicated that the plant effluent is discharged to the City of Memphis
interceptor and that his firm had not filed a permit application.
Mr. Breazeale cooperated with the EPA and granted permission to sample
the Valley Products effluent.
During January 1972, George Harlow, Chief, Enforcement Branch, EPA,
Region IV, wrote a letter to Mr. Breazeale [Appendix C] confirming the
date of the investigation and requesting written permission to sample.
This method was taken to advise the Valley Products Company that infor-
mation provided and data regarding discharges from the premises of the
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139
Company may be used as evidence against the firm ii} abatement pro-
ceedings under the applicable laws.
On February 4, 1972, Mr. Breazeale, in replying to Mr. Harlow's
letter, granted EPA permission to sample [Appendix C].
B. WASTE SOURCES AND TREATMENT
Waste from Valley Products Company containing organic matter,
grease, and suspended solids is discharged to. the Nonconnah Interceptor ''-'
without pretreatment. Effluent flow is continuously measured and
recorded. The process waste stream is identified as VP-23 [Figure C-l].
The Company has not filed for a U.S. Army Corps of Engineers permit appli-
cation for this discharge.
C. DISCUSSION OF IN-PLANT EVALUATION AND RESULTS
Sampling Procedure
The wastewater flow (sample station VP-23) was sampled on plant ''' "~
property., downstream from the flow-measuring device, before discharge to
the Nonconnah Interceptor [Figure C-l]. Samples were collected at --^ ':'
approximately 60-minute intervals using a SERCO automatic sampler. The-' ;fr> "1-!f"r
sampling began February 22, 1972, and was completed February 25, 1972.
Twenty-four 1-hr samples from the SERCO were composited into one sample,
and a fixed aliquot was placed in the appropriate container for shipment
and analyses. Samples requiring immediate analyses were transported to a
mobile EPA laboratory in Memphis and the other samples were preserved
and shipped by air-freight to the EPA NFIC-D laboratory. Grab samples
were collected twice daily for temperature, pH, and conductivity, and
once daily for oil and grease analyses.
..il.!.' CUI
-------
TO NONCONNAH CREEK
-N-
BROOKS ROAD
LEGEND
A SAMPLING STATIONS
WASTE DISCHARGE PIPING
NOT TO SCALE
Figure C1 Chapman Chemical C»npany and Valley Products Memphis, Tennessee
Sampling Stations C-22-A,C-22-B,VP-23
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140
Discussion'of P.esults
At the time of the survey, the Valley Products effluent [Table VP-1]
had a pH range of 5.6-9.0 and a temperature range of 17.0-51.0 °C. The
discharge to the City interceptor contained average loads of 1,750 pounds
of BOD; 1,100 pounds, TOG; 2,260 pounds, COD.; and 200 pounds of oil and
grease. The concentrations of BOD, TOG, COD, were 4,630.rag/1, 3,7GO mg/1
and 7,760 mg/1, respectively.
Article IV Section 5(b), City of Memphis Ordinance No. 460 prohibits
the discharge of oil and grease in excess of 100 rng/1. The discharge from
Valley Products had an average concentration of 560 mg/1 oil and grease.
D. SUMMARY AND CONCLUSIONS
1. The Valley Products Company discharged nn untreated effluent thfit
contained an average daily load of 1.750 pounds of biochemical oxygen.
demand; 1,100 pounds, total organic carbon; 2,260 pounds, chemical
oxygen demand;, and 200 pounds of oil and grease into the Mississippi
River via the Monconnah Interceptor.
The average concentrations for oil and grease and for BOD, TOC,
COD were high. These were:' BOD, 4,630 mg/1; TOC, 3,760 mg/1; COD, 7,760
mg/1; and oil and grease, 560 mg/1.
2. The presence of a high concentration (560 mg/1) of oil and
grease is in violation of the Memphis City Ordinance No. 460.
3. Discharge into the Mississippi River of industrial wastes con-
taining high BOD, COD, TOC, and oil and grease concentrations, without
a permit from the U.S. Army Corps of Engineers is in violation of Section
407, Rivers and'IIarbors Act of 1899 (33 U.S.C.; 401-413)
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141
TABLE VP-1
SUMMARY OF FIELD DATA AND ANALYTICAL RESULTS
VALLEY PRODUCTS COMPANY
February 22-25, 1972
a/
Parameter-
Flow (mgd)
pll
Teraperature_, ° C
Conductivity (jjmhos/cm)
BOB
TOG
COD
Suspended Solids
Total Solids
Oil & Grease
Turbidity (JTU)
Phenolic Materials
Atrazine (jjg/1)
Copper
Cadmium
Zinc
Total Chromium
Lead
P.an.Rs
0.0025-0.0693
5.6-9.0
17.0-51.0
900-15,000
3,300-7,300
1,720-4,900
6,338-10,100
356-2,200
6,410-23,500
160-930
200-550
0.3-1..'.
6-33
0.05-0.07
0.02-0.04
0.18-0.67
<0.0.1-/-0.04
0.16-0.25
Average
4,630
3,760
7,760
3,130
14,200
560
340
1.2
15
0.06
0.03
0 . 42
0.02
0.19
Load
Ib/day
1,750
1,100
2,260
2S9
5,260
200
0.38
0.005
0.02
0.01
0.17
'0.06
_a/ All units are in mg/1 except as noted.
b/ Minimum detectable limit.
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142
E. RECOMMENDATIONS
It is recommended that:
1. Valley Products provide pollution control facilities in order
to reduce biochemical oxygen demand, chemical oxygen demand, suspended
solids, and oil and grease to the levels consistent with those in City
Ordinance No. 460 and comparable to domestic sewage. These levels are:
Component mg/1 Ib/day
BOD 240 30
COD 960 320
Suspended Solids 300 . . 100
Oil & Grease 100 30
2. -An implementation schedule for the pollution control facilities
be established as follows:
- Initiate construction June 30-, 1973,
- Complete construction June 30, 1974.
- Meet treatment criteria herein outlined by Decenber 30, 1974.
3. KPA, in cooperation with the Tennessee Water Quality Control Board
and the Memphis and Shelby County Health Department, monitor the quality
of process waste discharges to ensure compliance with the Recommendations
Numbers 1 and 2.
4. Upon the failure of the Valley Products Company to provide a
satisfactory documented commitment to achieve the goals identified in
Recommendations 1 and 2, appropriate abatement proceedings under the
Rivers and Harbors Act of 1399 be initiated.
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APPENDIX A
APPLICABLE WATER QUALITY REGULATIONS
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A-l
APPENDIX A
APPLICABLE WATER QUALITY REGULATIONS
The Mississippi River is an interstate and navigable stream. McKellar
Lake, the Wolf River, and Nonconnah Creek are interstate waters tributary
to the Mississippi River and, therefore, tributaries of a navigable stream.
Pollution of interstate streams is subject to abatement under provisions of
the Federal Water Pollution Control Act, as amended (33 U.S.C. 466 et. seq.)<
Water quality standards applicable to the Mississippi River and its inter-
state tributaries have been established by the states of Arkansas, Missis-
sippi and Tennessee and approved as Federal standards pursuant to the pro-
visions of the Water Quality Act of 1965. The Rivers and Harbors Act of
1899 is applicable to discharges of industrial wastes to navigable waters.
iAll three states require waste sources to obtain permits in order to dis.-
charge to surface streams. These water quality regulations are discussed
below.
A. REFUSE ACT PERMIT PROGRAM (RAPP) ''
The Rivers and Harbors Act of 1899 prohibits the discharge
of industrial vrastes to navigable waters without a permit from
the U.S. Army Corps of Engineers. Section 13 of the Act, referred
to as the Refuse Act of 1899, makes it unlawful to discharge from
any "...manufacturing establishment, or mill of any kind, any
refuse matter of any kind or description whatever other than that -
flowing from streets and sewers and passing therefrom in a liquid
state, into any navigable water of the United States, or into any
tributary of any navigable water from which the same shall float
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A-2
or be'washed into such navigable water..." provided that a dis^-'-v
charge may be permitted under certain conditions specified by
the Corps of Engineers.
Executive Order No. 11574, signed by President Nixon on
December 23, 1970, tightened enforcement of the Refuse Act of
1899 by requiring that all sources of industrial wastes dis-
charging to navigable waters or their tributaries must apply
to the Corps of Engineers by July 1, 1971, for permits to
continue such discharges.
B. FEDERAL WATER POLLUTION CONTROL ACT
Enforcement Conference Requirements
Section 10(a) of the Federal Water Pollution Control Act5
as amended (hereafter referred to as the Act), provides that
"the pollution of interstate or navigable waters In or ad- . . ~ .
jacent to any State or States ... which endangers the healthc. ' "v
or vrelfare of any persons, shall be subject to abatement as - /- '' y r
provided in this Act".
One step in securing such abatement is the calling of a -
Federal-State Enforcement Conference. Section 10(d) of the
Act provides the following basis for calling such a conference:
^
"the Secretary shall also call such a conference whenever,
on the basis of reports, surveys or studies, he has reason to
believe that any pollution referred to in subsection (a) and
* Prior to May, 1966, the Act was administered by the Secretary of'Health,
Education, and Welfare. The Secretary of the Interior then administered
the Act until December, 1970, when this function was transferred to the
Administrator of EPA.
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A-3
endangering the health or welfare of persons in a State other
than that in which the discharge or discharges originate is
:ring; ...".
Section 10(d)(l) also provides several ways in which an
enforcement conference could be called to consider pollution of
interstate streams in the Memphis metropolitan area. If pollution
originating in one State endangers the health or welfare of
persons in another State or States, the Administrator may call
a conference "whenever requested by the Governor of any State
or a State water pollution control agency, or (with the con-
currence of the Governor and of the State water pollution con-
trol agency for the State in which the municipality is situated)
the governing body of any municipality1'. When pollution is
confine'd to one State , the Administrator nay call a conference
only at the request of the Governor of that State.
Sections 10 (c) and (g) of the Act provide means for abating pollution
which is causing violations of the Federal-State water quality standards
discussed above. Section 10(c)(5) provides that a. notice shall be issued
to violators of the standards at least 180 days before an abatement actio-..
is initiated in the courts. If reasonable action is not taken by the
violators within the 180-day period to secure abatement of pollution, a
direct court action can be requested under .the provisions of Section 10(g).
In cases where the discharge or discharges causing the violations are
located in a different State than the locat.ion of the violations, the
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A-4
. ^Administrator of EPA can request the Attorney General to bring suit on be-^ :Yi..;.
half of the United States to secure abatement of pollution. In cases :>'
where the discharges and violations are located in the same State, the
written consent of the Governor of that State is required before court
action can be requested.
With regard to violations of Mississippi or Arkansas standards for the
Mississippi River by pollution from the waste sources in Memphis, Tennessee,
direct court action could be requested by the Administrator. For viola-
tions of standards for the Mississippi River in Tennessee and for the Wolf
River, McKellar Lake and Nonconnah Creek by pollution from Memphis sources,
the consent of the Governor of Tennessee would be required prior to initia-
ting court action.
State Certification
.:'..-, Section 21(b) of the Federal Water Pollution Control Act, as amended
..- by the Water Quality Improvement Act of 1970, provides that "Any applicant -.
,:ir ifor a Federal license or permit to conduct any activity including, but not\ ;
limited to, the construction or operation of facilities, which may result
--in--any discharge into the navigable waters of the United States, shall ' '
provide the licensing or permitting agency a certification from the State
in which the discharge originates or will originate, or, if appropriate,
.from the interstate water pollution control agency having jurisdiction
over the navigable waters at the point where the discharge originates or
wil-l originate, that there is reasonable assurance, as determined by the
State or interstate agency that such activity will be conducted in a
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A-5
manner which will not violate applicable water quality standards."
All industrial waste sources applying for discharge permits under the
provisions of the Refuse Act are required to obtain a State certification
as discussed above. In addition, other activities such as construction of
structures in navigable waters, because such activity requires a Federal
permit, must also obtain a State certification.
Discharges to navigable waters existing prior to April 3, 1970;, are
allowed until April 3, 1973 to receive certification.
Federal rules regulating the discharge of oil "to navigable waters
were established on September 11, 1970, pui~suant to the provisions of Sec-
tion ll(b)(3) of the Federal Water Pollution Control Act, as amended by
the Water Quality Improvement Act of 1970. These rules prohibit discharges:
of oil to navigable waters from any source which: , ...
"(a) Violate the applicable water quality standards, or . ; . ; \'
(b) Cause a film or sheen upon or discoloration of the sur^ , i.
face of the water or adjoining shorelines or cause a
sludge or emulsion to be deposited beneath the sur-
face of the water or upon adjoining shorelines .1!
Waste discharges in the Memphis area must comply with these rep,ula-«
tions .
Section 10(c) of the Act, as amended by the Water Quality Act of 1965,
provides that the States be j^iven the opportunity to establish by June
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A-6
s-tV), 1967, water quality standards applicable to all interstate and coastal tv ;...
waters. These standards were to consist of water quality criteria appli- ~:..;
cable to each interstate stream or portion thereof and a plan for implemen-
tation and enforcement of the criteria. Arkansas, Mississippi*and Tennessee'
established such standards and submitted them for Federal approval as
.required. Details of the standards of each State are discussed in the . -
following paragraphs.
C. STATE STANDARDS
Arkansas
- Water quality standards applicable to all interstate streams in - .
Arkansas including the Mississippi River were established by the Arkansas
Pollution Control Commission in June 1967,.'and-were subquently.fully '
approved as Federal standards on August 7, 1967. ."/' '>'>'/.
I-....".. In general, the Arkansas water quality criteria applicable to '/'.-.- <'r:'::c.rj
. the Mississippi River are equal to or less restrictive than the Tennessee -.-- ? r >
iwjor. Mississippi criteria assigned to the same waters. An important;exception' .-
occurs in the reach between Loosahatchie Bar and the Tennessee-Mississippi
state line. Tennessee established no bacteriological criterion for this
reach. Thus, the Arkansas criterion is limiting.
Mississippi
The structure of the Mississippi standards is similar to that of the
Tennessee standards. Water uses were designated for each stream reach -..;- -
and specific water quality criteria established for each water use. Miss-
issippi designated fish and wildlife as the only water use for the
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A-7
Mississippi River. The specific criteria for fish and wildlife uses .are
comparable to the Tennessee criteria with the exception of the 4.0 mg/1
minimum limit for dissolved oxygen concentrations. This limit is not
federally approved.
No waste sources in the Memphis vicinity were listed in the Mississippi
implementation plan.
Tennessee
In the Memphis area, water quality standards vrere established for
McKellar Lake, Nonconnah Creek and the Wolf River in addition to those
for -the Mississippi River. Standards were not established for the only
other sizeable stream in the area, the Loosahatchie River, because it is
an intrastate stream.
. n.\. [Designated water uses to be protected and stream reach boundaries
are summarized in Table A-l.J
- Tennessee requires secondary treatment or the equivalent as the
minimum level of waste treatment for all discharges to interstate waters.
Secondary treatment is defined as 75 to 90 percent removal of the 5-day
biochemical oxygen demand and from 80 to 90 percent suspended solids re-
moval .
The revised Tennessee State Standards are in the Water Quality Cri-
teria that follow.
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Stream
TABLE A-I
DESIGNATED WATER USES
A-8
Water Uses
Mississippi River
Mississippi River
River-
Wolf River
1 . .
Nonconnah Creek
Nonconnah Creek
Lake
-Mississippi Rivet-
Mississippi River
Mississippi-Tennessee State
Line to upstream end of
Loosahatchie Bar
Upstream end of Loosahatchie
Bar to Kentucky-Tennessee
State Line
Mouth to L & N Railroad
Bridge
L & N Railroad Bridge to
Mississippi-Tennessee State
Line
Mouth to bridge on
Winchester Road
Winchester Road to Head-
waters in Fayette County
Arkansas
Missouri-Arkansas State
Line to Louisiana-Arkansas
State Line
Mississippi-Tennessee State
Line to Mississippi-Louisiana
State Line
Industrial, fish &
aquatic life, irri-
gation, livestock
watering & wildlife,
navigation
Domestic raw water
supply, industrial,
fish & aquatic life,
irrigation, recreation,
livestock watering &
wildlife, navigation
Fish & aquatic life
Domestic raw water
supply, industrial,
fish & aquatic life,
recreation, irrigation,
livestock watering &
wildlife
Fish & aquatic life,
livestock watering
& wildlife
Fish & aquatic life,
recreation, livestock
watering & wildlife
Industrial, fish &
aquatic life, recrea-
tion, navigation
Partial body contact
recreation, fish &
aquatic life, assimila-
lation of treated wastes,
navigation
Fish & wildlife
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A-9
i." GENERAL WATER QUALITY CRITERIA FOR THE DEFINITION AND CONTROL OF
POLLUTION IN THE WATERS OF TENNESSEE
Adopted on May 26, 1967
Amended on November 17, 1967, May 22, 1970, October 26, 1971, and
December 14, 1971
Tennessee Water Quality Control Board
The Water Quality Control Act of 1971, Chapter 16/4 Public Acts of 1971
as Amended by Chapter 386,.makes it the duty of the Water Quality Control
Board to study and investigate all problems concerned with the pollution
of the ..waters of the State and with, its prevention, abatement, and control
and to establish such standards of quality for any waters of the State
in relation to their reasonable and necessary use as the Board shall deem
to-be in the public interest and establish general policies relating to
existing or proposed future pollution as the Board shall deem necessary
to ;accomplish the purpose of the Control Act. The following general con-
siderations and criteria are officially adopted by the Board as a guide
in determining the permissible conditions of waters.with respect to pol-'
lution and the preventive or corrective neacurcs required to control
jpojLlutipn in various waters or in different sections of the same waters.
GENERAL CONSIDERATIONS
, , , 1.. Waters have many uses which in the public interest are reasonable
and necessary. Such uses include: sources of water supply for
domestic and industrial purpos.es; propagation and maintenance
...-.i ;,. -tof fish and other desirable aquatic life; recreational boating
and fishing; the final disposal of municipal sewage and indus-
trial waste following adequate treatment; stock watering and
irrigation; navigation; generation of power; and the enjoyment
of scenic and esthetic qualities of the waters.
2. The rigid application of uniform water quality is not desirable
. o.r. reasonable because of the varying uses of such waters. The
assimilative capacity of .a stream for sewage and waste varies. . ...
depending upon various factors including the following: volume
of flow, depth of channel, the presence of falls or rapids,
rate of, flow, temperature, natural characteristics, and the
nature of the stream. Also the relative importance assigned
. . - to each use will differ for different waters and sections of1
waters throughout the stream.
3. To permit reasonable and necessary uses of the waters of the
State, existing pollution should be corrected as rapidly as
practical and future pollution controlled by treatment plants
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A-10
lUvrr,. o>.»- or other measures. There is an economical balance between "the"1'"'
' cost of sewage and waste treatment and the benefits received.
Within permissible limits, the dilution factor and the assimi-
lative capacity of surface water should be utilized. Waste
recovery, control of rates and dispersion of waste into the
streams, and control of rates and characteristics of flow of
waters in the stream where adequate, will be considered to be
a means of correction.
4. Sewage, industrial wastes, or other wastes, as defined in The
Water Quality Control Act of 1971, Chapter 164 Public Acts of
1971, as amended by Chapter 386, shall not be discharged into
or adjacent to streams or other surface waters in such quantity
and of such character or under such conditions of discharge in
, relation to the receiving waters as will result in visual or
olfactory nuisances, undue interference to other reasonable
:j ,. and necessary uses of the water, or appreciable damage to the
natural processes of self-purification. In relation to the
various qualities and the specific uses of the receiving waters,
.'-. : no sewage, industrial wastes, or other wastes discharged shall
- -.'--r-.--.be responsible for conditions that fail to meet the criteria
of water quality outlined below. Bypassing or accidental spills
will not be tolerated.
..-.,_,._.. The-criteria of water quality outlined below are considered as
(..-i.. .,/ i..: guides in applying the water quality objectives in order to
insure reasonable and necessary uses of the waters of the State.
;i :£ v -!< :- *n order to protect the public health and maintain the water ''
suitable-for other reasonable and necessary uses; to provide
. .- ;\ for future development; to allow proper .sharing of available
water resources; and to meet the needs of particular situations,
additional criteria will be set. - -.
CRITERIA OF WATER CONDITIONS
1. Domestic Raw Water Supply
(a) Dissolved Oxygen - There shall always be sufficient dis-
solved oxygen present to prevent odors of decomposition
and other offensive conditions.
(b) pH - The pH value shall lie within the range of 6.0 to 9.0
and shall not fluctuate more than 1.0 unit in this range
<">ver a period of 24 hours.
(c) Hardness or Mineral Compounds - There shall be no substances
added to the waters that will increase the hardness or
mineral content of the waters to such an extent to appre-
ciably impair the usefulness of the water as a source of
domestic water supply.
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A-11
(d) Total Dissolved Solids - The total dissolved solids shall
at no time exceed 500 mg/1.
(e) Solids, Floating Materials and Deposits - There shall be
no distinctly visible solids, scum, foam, oily sleek, or
the formation of slimes, bottom deposits or sludge banks
of such size or character as may impair the usefulness of
the water as a source of domestic water supply.
(f) Turbidity or Color - There shall be no turbidity or color
added in amounts or characteristics that can not be reduced
to acceptable concentrations by conventional water treat-
ment processes.
(g) Temperature - The maximum water temperature change shall
not exceed 3°C relative to an upstream control point. The
temperature of the water shall not exceed 30.5°C and the
maximum rate of change^shall not exceed 2°C per hour. The
temperature of impoundments where stratification occurs \
will be measured at a depth of 5 feet, or mid-depth which-
ever is less, and the temperature in flowing streams shall
be measured at mid-depth.
(h) Microbiological Coliform - Coliform group shall not exceed
10,000 per 100 ml. as a monthly average value (either MPN
or MF count); nor exceed this number in more than 20 per
cent of the samples examined during any month; nor exceed
20,000 per 100 ml. in more than five per cent of such
samples. These values may be exceeded provided the organ-
isms are known to be of nonfecal origin. No disease pro- ~
ducing bacteria or other objectionable organisms shall be
added to sur-face waters which will result in the contami-
nation of said waters to such an extent as to render the
water unsuitable as sources of domestic water supply after
conventional water treatment.
(i) Taste or Odor - There shall be no substances added which
will result in taste or odor that prevent the production ;
of potable water by conventional water treatment processes.
(j) Toxic Substances - There shall be no toxic substances
added to the waters that will produce toxic conditions
that materially affect man or animals or impair the
safety of a conventionally treated water supply.
(k) Other Pollutants - Other pollutants shall not be added.
to the water in quantities that may be detrimental to
public health or impair the usefulness of the water as
a source of domestic water supply.
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A-12
2. Industrial Water Supply.
(a) Dissolved Oxygen - There shall always be sufficient dis-
solved oxygen present to prevent odors of decomposition
and other offensive conditions.
(b) pH - The pH Value shall lie within the range of 6.0 to 9.0 '
and shall not fluctuate more than 1.0 unit in this range
over a period of 24 hours.
(c) HardneWs or Mineral Compounds - There shall be no substances
added to the waters that will increase the hardness or
mineral content of the waters to such an extent as to ap-
preciably impair the usefulness of the water as a source
of industrial water supply.
- -; (d) Total Dissolved Solids - The-total dissolved solids shall .
at no time exceed 500 mg/1.
(e) Solids, Floating Materials and Deposits - There shall be
no distinctly visible solids, scum, foam, oily sleek, or
the formation of slimes, bottom deposits or sludge banks
of such size or character as may impair the usefulness of
the water as a source of industrial water supply.
:/.:" cX'f) Turbidity or Color - There shall be no turbidity or color
added in amounts or characteristics that can not be reduced
r.-crc., to acceptable concentrations by conventional water treat-
ment processes.
(g) Temperature - The maximum water'temperature change shall
_^u. not exceed 3°C relative to an upstream control point. The
temperature of the water shall not exceed 30.5°C and the
maximum rate of change shall not exceed 2°C per hour. The
temperature of impoundments where stratification occurs
will be measured at a depth of 5 feet, or mid-depth which-
ever is less, and the temperature in flowing streams shall
be measured at mid-depth.
(h) Taste or Odor - There shall be no substances added that .
will result in taste or odor that would prevent the use
of the water for industrial processing.
(i) Toxic Substances - There shall be no substances added to
. . the waters that may produce toxic conditions that will-.
adversely affect-the water for industrial processing.
(j) Other Pollutants - Other pollutants shall not be added to
_ . the waters in quantities that may adversely affect the
water for industrial processing.
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A-13
3. Fish and Aquatic Life.
(a) Dissolved Oxygen - The dissolved oxygen shall be maintained
at 5.0 mg/1 except in limited sections of the stream receiving
treated effluents. "In these limited sections, a minimum
of 3.0 mg/1 dissolved oxygen shall be allowed. The dissolved
oxygen content shall be measured at mid-depth in waters having
a total depth of ten (10) feet or less and at a depth of five
(5) feet in waters having a total depth of greater than ten
(10) feet. A minimum dissolved oxygen content of 6.0 mg/1
shall be maintained in recognized trout streams.
(b) pH - The pH value shall lie within the range of (^.5 to 8.5
and shall not fluctuate more than 1.0 unit in this range
over a period of 24 hours.
(c) Solids, Floating Materials and Deposits - There shall be no
distinctly visible solids, scum, foam, oily sleek, or the
formation of slimes, bottom deposits or sludge banks of
such size or character that may be detrimental to fish and
aquatic life.
(d) Turbidity or Color - There shall be no turbidity or color
added in such amounts or of such character that will mate-
rially affect fish and aquatic life.
(e) Temperature - The maximum water temperature change shall
not exceed 3°C relative to an upstream control point. The
temperature of the water shall not exceed 30.5°C and the
maximum rate of change shall not exceed 20°C. There shall -
be no abnormal temperature changes that may affect aquatic
life unless caused by natural conditions. The temperature
of impoundments where stratification occurs will be measured
at a depth of 5 feet, or mid-depth whichever is less, and
the temperature in flowing streams sha£l be measured at
mid-depth.
(f) Taste or Odor - There shall be no substances added that will ""
impart unpalatable flavor to fish or result in noticeable
offensive odors in the vicinity of the water or otherwise
interfere with fish or aquatic life.
(g) Toxic Substances - There shall be no substances added to
the waters that will produce toxic conditions that affect
fish or aquatic life.
(h) Other Pollutants - Other pollutants shall not be added to '
. . the waters that will be detrimental to fish or aquatic life.'
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A-14
4. Recreation.
(a\ Dissolved Oxygen - There shall always be sufficient dis-
solved oxygen present to prevent odors of decomposition
and other offensive conditions.
(b) pH - The pH value shall lie within the range of 6.0 to
9.0 and shall not fluctuate more than 1.0 unit in this
range over a period of 24 hours.
, (c) Solids, Floating Materials and Deposits - There shall be
no distinctly visible solids, scum, foam, oily sleek, or
the formation of slimes, bottom deposits or sludge banks
of such size.or character that may be detrimental to
recreation.
(d) Turbidity or Color - There shall be no turbidity or color
added in such amounts or character that will result in an
objectionable appearance to the water.
(e) Temperature - The maximum water temperature change shall
not exceed 3°C relative to an upstream control point. The
temperature of the water shall not exceed 30.5°C'and the
maximum rate of change'shall nqt exceed 2°C per hour. The
. . ,. temperature of impoundments where stratification occurs
will be measured at a depth of 5 feet, or mid-depth which-
ever is less, and the temperature in flowing streams shall
be measured at mid-depth.
.. .:(f) Microbiological Coliform - The fecal coliform group shall
not exceed 5,000 per 100 ml. as a monthly average value .
nor exceed this number in more than 20 per cent of the
samples examined during any month nor exceed 20,000 per
100 ml. in more than five per cent of such samples. In
those waters that are physically suitable and available
to the public for water-contact recreation the fecal
coliform concentration shall not exceed 1,000 per 100 ml.
in any two consecutive samples collected during the months
of May through September. Water areas near outfalls of
domestic sewage treatment plants are not considered suitable
for water-contact recreation.
(g) Taste or Odor - There shall be no substances added that
will result in objectionable taste or odor.
; (h) Toxic Substances - There shall be no substances added to
the water that will produce toxic conditions that affect-
man or animal.
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A-15
Other Pollutants - Other pollutants shall not be added to
the water in quantities which may have a detrimental effect
on recreation.
&
5. Irrigation
(a) Dissolved Oxygen - There shall alv/ays be sufficient dis-
solved oxygen present to prevent odors of decompsition
and other offensive conditions.
(b) pH - The pH value shall lie within the range of 6.0 to 9.0
and shall not fluctuate more than 1.0 unit in this range
over a period of 24 hours.
(c) Hardness ^ Mineral Compounds - There shall be no substances
added to tue water that will increase the mineral content
to such an extent as to impair its use for irrigation.
(d) Solids, Floating Materials and Deposits - There shall be
no distinctly visible solids, scum, foam, oily sleek, or
the formation of slimes, bottom deposits or sludge banks
of such size or character as may impair the usefulness of
the water for irrigation purposes.
(e) Temperature - The temperature of the water shall nofc be
,. .- raised or lowered to such an extent as to interfere with
its use for irrigation purposes.
(f) Toxic Substances - There shall be no substances added to
water that will 'produce toxic conditions that will affect . .
the water *or irrigation. . .
(g) Other Pollutants - Other pollutants shall not be added to
the water in quantities which may be detrimental to the
waters used for irrigation.
6. Livestock Watering and Wildlife
(a) Dissolved Oxygen - There shall always be sufficient dis-
solved oxygen present to prevent odors of decomposition
and other offensive conditions.
(b) pH - The pH value shall lie within the range of 6.0 to
9.0 and shall not fluctuate more than 1.0 unit in this
range over a period of 24 hour^.
(c) Hardness or Mineral Compounds - There shall be no sub-
stances added to water that will increase the mineral -
content to such an extent as to impair its use for live-
stock watering and wildlife.
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A-16
(d) Solids, Floating Materials and Deposits - There shall be
no distinctly visible solids, scum, foam, oily sleek, or '
the formation of slimes, bottom deposits or sludge banks
of such size or character as to interfere with livestock
watering and wildlife.
(e) Temperature - The temperature of the water shall not be
raised or lowered to such an extent as to interfere with
its use for livestock watering and wildlife.
(f) Toxic Substances - There shall be no substances added to
water that will produce toxic conditions that will affect
the water for livestock watering and wildlife.
(g) Other Pollutants -. Other pollutants shall not be added to
the water in quantities which may be detrimental to the
water for livestock watering and wildlife.
7. Navigation
(a) Dissolved Oxygen - There shall always be sufficient dis-
solved oxygen present to prevent odors of decomposition
and other offensive conditions.
(b) K-ardness or Mineral Compounds - There shall be no sub-
.- :. stances added to the v;ater that will increase the mineral
content to such an extent as to impair its use for
navigation.
^.. o ..,:;.'. (c) Solids, Floating Materials and Deposits - There shall be
' ' no distinctly visible solids, scum, foam, oily sleek, or
-.,-; the formation of slimes, bottom deposits or sludge banks
of such size or character as to interfere with navigation.
(d) Temperature - The temperature of the water shall not be
raised or lowered to such an extent as to interfere with
its use for navigation purposes.
(e) Toxic Substances - There shall be no substances added to
r-t , , -. water that will produce toxic conditions that will affect
the water for navigation.
(f) Other Pollutants - Other pollutants shall not. be.,;!added to
the water in quantities which may be detrimental to the
waters used for navigation.
- These-, rcriteria should not be construed as permitting the degradation of
higher quality water when such can be prevented by reasonable pollution
control measures. The above conditions are recognized as applying to
waters affected by the discharge of sewage f»nd/or industrial waste or
other waste and not resulting from natural causes.
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A-17
DEFINITIONS
1. Conventional Water Treatment - Conventional x
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A-18
TENNESSEE ANTIDEGRADATION STATEMENT
1. The Standards and Plan adopted are designed to provide for the
protection of existing water quality and/or the upgrading or
I "enhancement" of water quality in all waters within Tennessee.
It is recognized that some waters may have existing quality
better than established standards.
2. The Criteria and Standards shall not be construed as permitting
the degradation of these higher quality waters when such can
be prevented by reasonable pollution control measures. In this
regard, existing high quality water'will be maintained unless
and until it is affirmatively demonstrated to the Tennessee
Water Quality Control .Board that a change is justifiable as a
result of necessary social and economic development.
3. All discharges of sewage, industrial wast.e, or other waste
shall receive the best practicable treatment (secondary or the
equivalent) or control according to the policy and procedure
of the Tennessee Water Quality Control Board. A degree of,
treatment greater than secondary when necessary to protect the
water uses will be required for selected sewage and waste dis-
charges .
4. In implementing the provisions of the above as they relate to
interstate streams, the Tennessee Water Quality Control Board
will cooperate with the appropriate Federal Agency in order to .
assist in carrying out responsibilities under the Federal Water
Pollution Control Act, as amended.
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A-19
D. STATE DISCHARGE PERMITS
All three states in the Memphis area have some form of discharge per-
mit requirement. The Tennessee stream pollution control law contains
provisions that authorize the Tennessee Stream Pollution Control Board
to issue discharge permits. The Board has establishejj general regulations
that specify the conditions under which a permit may be issued. All dis-
charges of sewage, industrial wastes or other wastes are required to
obtain a permit. The discharge permits stipulate the conditions that must
be maintained in the discharged effluents by means of limiting concentrations
on specific waste constituents and other restrictions. In effect, the
discharge permits set effluent requirements.
The Tennessee regulations also provide that a "Tolerance Permit"
may be issued in cases where pollution cannot be immediately abated and
the .discharge is not immediately dangerous to.health. Abatement of
pollution must be achieved within a reasonable time period.
Several of the industrial waste sources in the Memphis*area have
received discharge permits. A number of sources are discharging under these
tolerance permits with inadequate or no treatment. A common justification
for such permits is that the waste source plans to connect to the Memphis
sewerage system when a planned interceptor rHewer is completed in the
vicinity.
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APPENDIX B
CITY OF MEMPHIS ORDINANCE NO. 460
REGULATION OF SEWER USE
-------
B-l
CITY OF MEMPHIS ORDINANCE NO. 460
REGULATION OF SEWER USE
Article IV on the use of the Public Sanitary Sewers states in Section 4:
No person shall discharge or cause to be discharged any of the following
described waters or wastes to any public sanitary sewers:
(a) Any gasoline, benzine, naphtha, fuel oil, or other flammable or
explosive liquid, solid, or gas.
(b) Any waters or wastes containing toxic or poisonous solids,
liquids, or gases in sufficient quantity, either singly or
by interaction with other wastes, to injure or interfere with
... any sewage or waste water treatment process, or any sanitary > '
sewer system, constitutes a hazard to humans or animals, create
. : a public nuisance, or create any hazard in the receiving waters^
;. of the sewage or wasteswater treatment plant, including but not "
limited to cyanides in excess of one (1) mg/1 as CN in the '-
wastes as discharged to the public sanitary sewer.
(c) Any waters or wastes having a pH lower than 5.5, any other
corrosive property capable of causing damage or hazard to
structures, equipment, and personnel of the sewage works.
(d) Solid or viscous substances in quantities or of such size capable
of. causing obstruction to the flow in the sewers, or other inter~> -
ference Xvdth the proper operation of the sewage works such as, -
but not limited to ashes, cinders, sand, mud, straw, shavings, '
, metal, glass, rags, feathers, tar, plastics, wood, unground- ;'
garbage, whole blood, paunch manure, hair and fleshings,
.; . entrails, paper dishes, cups, milk containers, etc., either
xvhole or ground by garbage grinders.
Section 5 states specifically that the substances prohibited are:
(a) Any liquid or vapor having a temperature higher than one hundred
fifty (150°) F. (65°C).
(b) Any water or waste containing fats, x^ax, grease, or oils, whether
emulsified or not, in excess of one hundred (100) mg/1 or con-
taining substances which may solidify or become viscous at tem-
-- peratures between thirty-two (32°) and one hundred fifty (150°)
F. (0° and 65°C).
(c) Any garbage that has not been properly shredded. The instal-
lation and operation of any garbage grinder equippped with a
motor of three-fourths (3/4) horsepower or greater shall be
subject to the review and approval of the Approving Authority.
(d) Any waters or wastes containing strong acid, iron pickling
. wastes, or concentrated plating solutions whether neutralized
or not, except by special permission of the Approving Authority.
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B-2
Section 5 (con't)
(e) Any waters or wastes containing iron, chromium, copper, zinc,
and similar objectionable or toxic substances; or wastes
exerting an excessive chlorine requirement, to such degree that
any such material received in the composite sewage at the sewage
treatment works exceeds the limits established by the Approving
Authority for such materials.
(f) Any waters or wastes containing phenols or other taste- or odor-
producing substances, in such concentrations exceeding limits
which may be established by the Approving Authority, as nec-
essary, after treatment of the composite sewage, to meet the
requirements of the State, Federal, or other public agencies of
jurisdiction for such discharge to the receiving waters.
(g) Any radioactive wastes or isotopes of long half-life (over 100
days) without special permit. The. radioactive isotopes I-^ and
p32 used at hospitals are not prohibited if properly diluted at
the source.
(h) Materials which exert or cause:
(1) Unusual concentrations of inert suspended solids (such as,
but not limited to, Fullers earth, lime slurries, and lime
residues) or of dissolved solids (such as, but not limited
to, sodium chloride and sodium sulfate).
(2) Unusual SOD, chemical oxygen demand, or chlorine require-
ments in such quantities as to constitute a significant
load on the sewage treatment x^orks o
' , (3) Unusual volume-of flow or concentration of-wastes constituting
"slugs" as defined herein.
. (i) Waters or wastes containing objectionable substances which are
not amenable to treatment or reduction by the sewage treatment
processes employed, or are amenable to treatment only to such
degree that the sewage treatment plant effluent«cannot meet the '
requirements of the Regulatory Agency.
(j) Any waters or wastes having a pH in excess of 9.5.
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APPENDIX C
EPA SURVEY CORRESPONDENCE
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ENVIRONMENTAL PROTECTION AGENCY
WATER QUALITY OFFICE C-l
DIVISION OF FIELD INVESTIGATIONS-DENVER CENTER
BUILDING 22 , ROOM 410 , DENVER FEDERAL CENTER
DENVER, COLORADO 80225
TO WHOM IT MAY CONCERN:
This is to introduce Dr. Wayne C. Smith, a Chemical Engineer employed
by the Environmental Protection Agency, Division of Field Investigations -
Denver Center, Denver, Colorado.
Dr. Smith's visit to your premises is in relation to an industrial
waste survey of the Mississippi River drainage area. With your -permission,
the. liquid waste discharge (s) from your premises will be included 'with
those sampled during this survey. The. purpose of -the survey is to collect:"
information and water quality data which will be used as the basis for:
(1) evaluation of Corps of Engineers permits as required under the River-
. and .Harbor Act of 1899; (2)- de-termination of present water quality '
^conditions in the Mississippi River, Memphis area, and it's tributaries;- r
. Devaluation of the individual and collective impacts of wastewater --«--
harg.e.s on the beneficial water uses of the Mississippi River and1" its ("
tributaries; (4) determination of water pollution control needs within
the area; and (5) abatement proceedings as necessary or warranted under
the River and Harbor Act of 1899, the Water Quality Act of 1965, and/or
other applicable local, State, and Federal laws.
Your cooperation in the conduct of this survey is essential to the-
success of the Clean Water effort, and is therefore earnestly solicited.
Sincerely, - : -~
Thomas F. Gallagher
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ENVIRONMENTAL PROTECTION AGENCY '
REGION IV ' ' c-2
... !''. 1421 Fuachtree St., N.E., Atlanta, Georgia 30309
January 31, 1972
Dr. M. B. Burton -
Manager - . '
E. I. DuPont Company . . '.. .- ' -
P. 0. Box 27038
Memphis, Tennessee 38127 ' . ' ' . " "
Dear Dr. Burton: ".'.'
This confirms notification, provided to you by Dr. Wayne C. Smith
of the Environmental Protection. Agency, of a water quality and waste
source'-investigation which is to be conducted in the Memphis area by. - - .
the Environmental Protection Agency during the period Fel^ruary 7 through
"March 3> 1972. With your permission, the liquid waste discharge(s) . .
from'your premises will be included with those sampled during this -
survey.. The purpose of the survey is to colle'ct infcflnation and water
quality data which will be used as the basis "for: (l) evaluation of
Corps of"Engineers permits as required under the River and Harbor Act
of l899j (2) determination of present water quality conditions in
the Mississippi River and its tributaries; (3) evaluation of the
individual and collective impacts of wastewater discharges on the
beneficial water uses of the Mississippi River and its tributaries;
-(U)- determination of water pollution control needs within the area; . . .- . ,
and-"(5-)-' abatement proceedings as" necessary or warranted under-the- - - . r
River-and Harbor "Act of 1899? "t^-e Water Quality Act" of 19$5 > a.nd/or ; -"-
other applicable local, State and Federal laws. This means is taken - .
to advise you that information provided by you, as well as data regarding
"discharges from your Company's premises, may'be used as evidence against- },;
"your-^Company in abatement proceedings under the applicable laws'. -- - -''x-->
You are requested to provide to this office, not later'than
February U, 1972, written permission for Environmental Protection Agency
representatives to conduct waste di'scharge sampling, analysis, and flow
measurement, as may be required in the course of the investigation.
"Your cooperation in the conduct of this investigation is essential -in
to the success of the Clean Water effort, and is therefore earnestly
solicited.
. Sincerely, ' . '
GEORGE L. HARLOW
Dr. Wayne C. Smith " Chief> Enforcement Branch
Denver Field Investigation Region IV
Center
Identical letter forwarded to all addressees on attached list.
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C-3
LIST OF ADDRESSEES
(For notification letter - Memphis Survey, 1972)
Dr. M. B. Burton, Manager
E. I. DuPont Co.
P. 0. Box 27038
Memphis, TE 38127
Mr. R. E. McClure, Manager
International Harvester Co.
P. 0. Box 268
Memphis, TE 28101
Mr. John Rezda, Manager
Kiinberly Clark Corp.
P. 0. Box 7066
Memphis, TE 38107
Mr. Paul Upton
Delta Refining Co. '
P. 0. Box 9097
Memphis, TE 38109
Mr. Clarence Colby, Plant Engineer
Firestone Tire and Rubber
P. 0. Box 7128
Memphis, TE 38107
Mr. D. C. VanSickle, Manager
Hunt-Wesson Foods, Inc.
P. 0. Box 2674
Memphis, TE 38102
Mr. Daniel Marks
Velsicol Chemical Co.
P. 0. Box 8127
Memphis, TE
Mr. Geoffrey Rollings, Plant
Manager
Whittaker Textile Service Center
615 East Bodley Ave.
Memphis, TE 38106
I
Mr. Robert M. Stewart, General
. Manager
W. R. Grace & Co.
P. 0. Box 27147
Memphis, TE 38127
Mr. Zawicki, Manager
Atlas Chemical Industries, Inc.
1285 Pope Street
Memphis, TE 38108
Mr. Allen J. Frx.tsche, Manager
of Design
Humko Products
P.O. Box 398
Memphis, TE 38101
Mr. Jim Breaseale
Valley Products
416 East Brooks Road
Memphis, TE 38109 ' '
Mr. R. K. Fincher, Manager
Quaker Oats Company '""
P. 0. .Box 8035
Memphis, TE 38108
Mr. R. T. Turner, Manager
Buckeye Cellulose '
2899 Jackson Ave.
Memphis, TE 38108
Mr. J. P. Alrutz, Manager,
Engineering & Quality
Chapman Chemical
P. 0. Box 9158
Memphis, TE 38109
Mr. J.^m Baird
Piper Brothers ;"
695 West Poplar
Collierville, TE 38017 0-
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C-4
List of Addressees for Memphis Survey (Continued)
Day and Night Company
Payne Company
97 South Byhalia
Collierville, TE 38017
Mr. Pat Reilly, Assistant Plant
Manager
Schlitz Brewery - P. 0. Box 18309
Holiday City Station
Memphis, TE 38118
Mr. E. 0. Miller
Naval Air Station Memphis (84)
Millington, TE 38054
Mr. John Clement
City of Millington
4836 Navy Road
Millington, TE 38054
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SC-0511 I!EV. 5-C4
I
I. DU PON.T DE NEMOURS & COMPANY
' -' -, !MC.UMtH'HAlT.:>
P. O. Box 27058
MEMPHIS, TENNESSEE 33127
ElBCTROCHEMICALS DEPARTMENT
C-5
February 3, 1972
Mr. George L,. Harlow
Chief, Eniorcernent Branch
JReciion IV
*j
Environmental Protection Agency
1421 Peachtres St., N. E.
Atlanta, Georgia 30309
Dear Mr. Harlow:
In reply to your letter of January 31,' 1972, this is to advise that
the Memphis Plant, E. I. du Pont de Nemours & Company grants per-
mission for Environmental Protection Agency representatives to conduct
waste discharge sampling, analysis and'flow-measurement of waste water
discharciect to the Loosahatchie River at this location during the period
February 7 through March 3, 1972,
.-.: ' The nature of our operation requires that visitors on our site ' ~"~ '
unfamiliar with our processes and products be escorted for their own
safety and well being. Consistent with this policy, -we grant this per-
-mission with the understanding that your employees conducting the--*'- ' -
requested program will be escorted while on our site, .
We understand that waste water samples are to be split. We will,
of course, want to discuss with your representatives the analytical
methods to be used in. order to ensure uniformity.
We are looking forward to their visit with the expectation of a
successful sampling campaign.
Very truly yours,
Ky B, Burton
Plant Manager
MEBrcm
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INTERNATIONAL HARVESTER COMPANY
FARM EQUIPMENT DIVISION
MEMPHIS WORKS
C-6
3003 HA iVvtlSTI'K S T R F. E T
MEMPHIS. TENNESSEE 38101
TEI.EPHONC AKGA COPE 901
357-531 1
A O O R i: S E H r. F-1, Y TO
P. O. BOX 2G3
MEMPHIS, TENNESSEE 38101
February 2, 1972
Environmental Protection Agency,
Region IV
1421 Peachtree Streett, N.iL
Atlanta, Georgia 30309
Attention: Mr. George L. Harlow,
Chief
Dear Mr. Harlow:
I received your letter this morning informing'roo that your group will
be making a water quality and waste source investigation in the Memphis
ares during the period of February 7 through March 3S 1972, and l-Jcniphis
Works "intarnation;-;). Harvester Company is included in the survey,
1 have'not: heard from Doctor Wayne C. Smith since he- made a visit with
us several jncmths ar;,o; but, we did tell him at that t.iree- we would co-
operate with his 'study;-
Please advise me when this survey is to be conducted st this Works
and I will make available to you an Engineer to assist in any way
you deem necessary.
REMcL/aab
cc: J, We Wegener
'R. E- McLure
Plant Engineer
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C-7
I
I -M B:'E R-L'Y r CLARK' CO -R P.0.RATION
February 3, 1972
Mr. George L. Harlow
Chief Enforcement Branch
Environmental Protection Agency, Region. 4
1421 Peachtree Street, N0 E..
Atlanta, Georgia 30309 '
Dear Mr. Harlow:
This is to acknowledge receipt of your letter dated January 31,
and will constitute .the written permission requested for the
En.vironmen.tr.1 Protection Agency representatives to conduct waste
discharge sampling and flow measurement on our premises during
the period February 7 through March 3, 1972, and,ana] ysls as-
required. . '
In-.view of the concern expressed during Dr. Smith's visit regarding"
, the. suitability of our normal sampling" location for this purpose,, we
would call to your attention another point which may be more suitable
in.that it will allow a sample to be taken just prior to the outfall dls-'''>
charge into the Wolf River. We assume that ifcleqiiate advance notice
will be given so that we may have personnel available, take the
necessary safety precautions, and efficiently accomplish the required
sampling and flow measuring.
r
During Dr. Smith's visit, it was also indicated that there would be no
objection to splitting the samples so that we may run an independent
analysis. "We will plan on doing this.
It is our intention to cooperate with E. P. A. in the conduct of this
investigation in any reasonable way to assure the success of the clean
water effort.
Sincerely yours, .., .
/
-b~ . ''John Rczba
Memphis Mill Manager
tamoliis fv'i,'1
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C-8
iMMllJ^J .REFINING COMPANY
p. o. box 9097 memphis lenr.essee 38109
February 3, 1972
Mr. George L. Marlow
Chief, Enforcement Branch
Enviromiient.al Protection Agency ' .
Region IV' ' - .
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Harlow: ; .
By your letter of January 31, you have requested permission
for your agency representatives to survey and take samples
of our plant water effluents. We extend a welcome to meaibers
-of your team, to conduct this survey of our operations during
your Memphis inspections February 7 through March 3, 1972,
Perhaps when your representative arrives he can clarify for
us how the cooperation you solicit, and which you 'shall re-
ceive from us, can best be afforded when at the same time
you advise us that the data that' yov. 'obtain from your-, inspec-
tion here "may be used as evidence against" -- us. Of our
cooperation you can be assured. Our corporate objectives for
improving our environment are absolutely parallel to those of
'which your mission is directed. '
[Sincerely,
RTP:gh
X. T. PRATEH, president
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l
be Firestone Tire & Rubber Company. c-9
» j
HAKVEY S FIRESTONE TOUNDEK
EMCKAL OFFICES . * . MEMPHIS, TENNESSEE
AKRON. OHIO 44517. I
I
381O7
MEMPHIS PLANT
P. O BOX 71.->8
February 1 , 1 972
Krc George L. Harlcw .
Chief, Enforcement Branch, Region IV
Envircn^srital Protection Agency . ...
1^21 Peaehtree Stc, N» Eo . ' ' .
Atlanta, Georgia 30309
Dear Mrt Rarlow:
Youi- letter of January 31, 1972 requested that we-provide,
not, later than February }i, 19725 written permission for Environ- _
mental Protection Agency representatives to include the liquid
waste discharge(s) from our premises v.'ith those sampled during
the Memphis area survey to be made February 7 through March 3?
1972t We are av/tfre of the fact that information and/or data
regarding discharges from our company's premises may be used ' '
'against us in abatement proceedings under applicable laws. Due'
to the corrective actions to date and our .desire to cooperate
with environmental improvement, we wo-old intend, to comply with
applicable laws and make our contribution to the clean water :""-
effort, .
Access to Q.UT surface water, discharge is outside the plant
fence* If it is desired to inspect our new industrial wa'ste
sewer facility which discharges into the-'citysewerage systemS(_
entry to the fenced'area will be via the gate on Corrine 'Avenue.,'
Before any activity is undertaken, contatst should be made with
the writer or with Mr* E. H« Stanfielcl so clearance and orienta- .
tion can be arranged.
Please consider this as written permission and/or invita-
tion, for Environmental Protection Agency representatives to con*-
duct'waste discharge sampling, analysis and flo^j measurement as
may be required in the course of the Memphis area investigation,,.
Very truly yours9
| CC/eb
Clarence Colby
Plant Engineer
1
io ne
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Ifc'Vfl C-10
HUNT-WESSON FOODS
Pou Oilicc Box 2674
Memphis. Tennessee 35702
90V 274-6410
February 3, 1972
Mr. George L. Harlow, Chief
Enforcement Branch
Environmental Protection Agency
Regional IV
1421 Peachtree St. N.- E. . . .'
Atlanta, Georgia 30309
Dear Mr. Harlow:
This is to be taken as permission for the Environmental
Protection Agency Representative to conduct waste discharge
sample analysis and flow measurements at the Memphis Refinery
of. Hunt-Wesson Foods, Inc. We would like advance notification
as to when your representative, is scheduled to visit our
operation.
We would like to take this opportunity to advise you
that we are not to be held liable in any respect for personnel
representing the Environmental Protection Agency in the confines
of our plant. We understand that the}' are solely under the
responsibility of the Environmental Protection Agency.
You can be assured that we will cooperate with any
representative of the EPA during their conduction of
activities at.our operation. If we can be of any further
assistance -in the meantime, please advise.
Sincerely,
Hunt-Wesson Foods, Inc.
B. D. Gunter
Plant Manager
BDG/pe
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I
I
ELSICOL CHEMICAL CORPORATION
09 Warford Street..- Memphis, Tennessee. 38108 Area Code 901 -324-U01
C-ll
February 1, 1972
Mr. George L. liar low
Chief, Enforcement Branch.
Environmental Protection .Age
Region IV '
1421 Peachtree Street, N. E..
Atlanta, Georgia 30309
Dear M.t. Harlow;
This letter is to advise you of our permission
to conduct sampling, analysis, and flow measurement
of the liquid waste discharges from our premises"
as requested in your letter of January 31, 1972.
We understan.d 1:he period of the survey is to be
'from February 7 through March 3, 1972.
Very truly yours
VELSICOL CHEMICAL CORPORATION
? '3> -f sT* **ffl -"^
,'.-£. uV-
Daniel R. Marks
Technical Superintendent
DRM/lran
\
cc: V7. J. Anthony
. Neil Mitchell
M. Lissner
R. Owen
-------
.,./f V"'?' v->v
\>-''-'\/ifv £ & *!< T --
r
i
i
i
C-1Z
COnPORATIO'N
MAILING ADDRESS:
POSTOrHCE BOX 416
MEMPHIS. TENNESSEE 381O1
2, 1972
TEXTILE SERVICE CENTER
615 EAST BODLEY
MEMPHIS, TENNESSEE 381O6
TELEPHONE: (9O1) 948-7711
Mr. George L. .Harlow
Chief, Enforcement Branch
Region IV
Environmental Protection Agency
1421 Peachtree St., N. E.
Atlanta, Georgia 30309
Dea'r Mr. Harlow: .
With reference to your letter of January 31,- 1972, in \vhich you requested
permission to evaluate our effluent, we are presently constructing new
sewers which will collect our plant effluent and ultimately tie into the
City sewer system. Also, we are currently conducting studies of our
effluent .for the Corps of Engineers, State of Tennessee and City of
Memphis. .
In view of these undertakings, we respectively request that you delay
your study for 30 days. In the event our construction and studies are
not complete at that time, we will be in touch with you just as soon as
we know something definite.
Very truly yours,
;w Products Development Manager
RL/tcv
CC: Stephen Biller
G. I. Hollings
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C-13
w. R. Q R/4 O E <& co.
AGRICULTURAL CHEMICALS GROUP Ll^LI3TOT/J
P.O.SOX 37147 MEMPHIS, TENN. 38IZ7 PH ON E: 357-3311
February 3, 1972
Mr. George L. Harlow, Chief
Enforcement Branch, Region IV
Environmental protection Agency
1421 Peachtree Street, N. E. '
Atlanta, Georgia 30309
Dear Mr. Harlow:
Dr. Wayne C. Smith and Mr. J. C. -Alleman of the Environmental Pro-
tection Agency and representatives of the Memphis 'and Shelby County
Health Department visited with us last October 4 to discuss the Agency's
plan, to conduct a water quality and waste source investigation in the
Memphis area. As a result of this meeting and later telephone conver-
sations which I had with Dr.. Smith, we understood that Dr. Smith would
forward to us details of his program as it applied to our plant. We
understand these details will provide- for W. R. Grace & Co. receiving
a portion of all samples taken, at our plant. We also understand his pro-
g.i-am-will not require entrance to the manufacturing area, of our operation
\yher-.e confidential operating information could be involved. On the basis
of the above understandings, I verbally agreed with Dr. Smith on
October 7, 1971, tha.t we would cooperate with the Environmental Pro-
tection A.gency in this survey. This letter will confirm this agreement
with Dr. Smith.
Please have Dr. Smith contact F. L. Applegate, Production Manager,
or E. M. Smith, Manager, Urea and Utilities Department, to arrange
for entry to our waste treating facilities.
Very truly yours,
W. R. GRACE & CO.
Agricultural Chemicals Group
R. M. Stewart, General Manager
Memphis, Big Spring, and Aruba
.R MS: s m
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C-14
i w 2 . ;-..
.-.-. ^.:^ -I \j i
r -r'^i'itv^c v
m G n
11 1 o i 4
Wilmington, Delaware 19899
(302) G58-9311
February -3, 1972
Mr, George L. liar low
Chief, Enforcement Branch
Region IV
Environmental Protection Agency
1421 Peachtree Street, N.E.
Atlanta, Georgia .30309
Dear Mr..H.arlow:
This is to reply to your letter of January 31, 1972,
addressed to Mr* Zawicki, Manager, "Atlas Chemical Industries,
Inc.,". . Please be informed that, the name of this 'Company was
changed effective January'1, 1972, to that which appears on ' '.
this letterheado
We are pleased to grant permiss.ion to representatives
of the Environmental Protection Agency to conduct waste discharge
sampling, analysis and flow measurement as may be required at the
Memphis Plant. You are requested to provide us with specific
dates when your representatives desire to visit. 'We have limited
plant personnel, available to conduct and assist your representa-
tives in their investigation and we trust that you will cooperate
in arranging o.t schedule of visitation to suit our mutual convenience.
If you have any questions or wish to discuss this matter
further, pleas-e contact us. We shall, in any event, anticipate'
your reply with .respect to arranging an appropriate visitation .
scheduleo ' '
Very truly yours,
' ' - CENTRAL ENGINEERING DEPARTMENT
S. A. LaROCCA, SUPERVISOR
SANITARY ENGINKERING
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I
C-15
.-.'., ' Division of
HUMKO, PRODUCTS . Kraftco Corporation
'White Station-Tower. P. O. Box 398 . . , ;
38101 , ' . . February 1, 1972
Mr. George L. Ha'rlow
Chief, Enforcement Branch, Region IV
Environmental Protection Agency
1421 Peachtree St. N. E.
Atlanta, Georgia 30309
Dear Mr. Harlow:
This is to acloiowledge receipt of your letter of January 31,
'1972, to our Mr. Allen J. Fritsche.
Your request for written permission to conduct waste dis-
charge sampling, analysis, and flow, measurements as
required for your investigation has been forwarded to our
appropriate corporate official. I will promptly reply to
your request after receiving the necessary authorization.
Yours very truly,
Curt Meierhoefer
Vice President - Engineering
CM /eg
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C-16
Division of
IHUMKO PRODUCTS [;- .._'.. Kraffco Corporation
White Station Tower, P. O. Box 398, '
Memphis,Tennessee 38101 . " ' . February 3, 1972
Environmental Protection Agency
Region. IV
1421 Peachtree Street, N. E.
Atlanta, Georgia 30309
Attention: Mr. George L. Harlow, Chief ' ' .
Enforcement Branch, Region IV
Gentlemen:
Pursuant to your letter of January 31, 1972, HumKo Products
authorizes the Environment Protection Agency to conduct such
waste disposal sampling, analysis and flow measurement as
may be required in connection with the water quality survey to
be conducted in the Memphis area from February 7, 1972, through
March 3, 1972.
It is our'understanding that all data in regard to such sampling,
analysis and flow measurement will be held confidential by the
EPA unless used as evidence against HumKo in abatement pro-
ceedings under applicable laws.
Sincerely,
Curt Meier'Koefer
Vice President - Engineering
CM/cg
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P. O. DOX Q03S
HOLLYWOOD STATION
MEMPHIS.. TENN. 381O8
February 4, 1972
Mr. George L. llarlow, Chief .
Enforceifient Branch, Region IV
Environmental Protection Agency
1421 Pe.achcree Street, N. E. .
Atlanta, Georgia 30309 . . r ' .
Dear Mr. Harlov;: . .
The Quaker Oats Company will be pleased to cooperate with.your
agency in conducting a water quality and waste source investigation.
Your representatives have our permission to sample, analyze and make flow
measurements at our Memphis Chemical Plant.
I am sure you understand that access to some areas of the plant
is restricted because of proprietary process information that might be
divulged to a visitor. I am sure that you can complete your survey without
visiting these areas, and that this will in no way deny you information on
any waste discharge.
We will be happy to instruct your representatives concerning
plant safeTy regulations and will assist them in any way we can.
Yours very truly,
THE QUAKER OATS COMPANY
'C.
R. 1C. Firicher
MANAGER
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c-19
v The Buckeye' Cellulose Corporation j(^ j £.:'*>Ftr'^
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I
. 0. Box 8407 February 2, 1972
Mr, George L. Harlow
Environmental Protection Agency
1421 Peachtree Street, K. E.
Atlanta, Georgia 30309
Dear Mr. Harlow:
We -have received your letter of January 31 requesting that we provide
you with written permission to conduct waste discharge sampling analyses
and flow measurements in the course of an investigation which representa-
tives of the' Agency will be conducting in the Memphis area during the period
of February 7 through March 3, 1972'. In the spirit of . cooperation with the
purposes which your agency is seeking to accomplish, we- arc pleased to pro-
vide you with this permission.
We believe it is worth pointing out that, over a considerable period
of .'time, we hax'e been working closely with the appropriate authorities in
the State of Tennessee and the City of Memphis' in connection with matters
relevant to your survey. Because of this fact and also because of the
statutory -obligations imposed. upon the Agency under the Federal Water Pol-
lution Control Act as amended, we respectfully request that your investiga-
tion be conducted jointly with these state and local agencies. We are tak-
ing the liberty of sending a copy of this letter to each of them so that
they will be aware of our position in this matter.
r Very truly yours,
T. R. Turner
Plant Manager
afw \
cc: Mr. S. Leary Jones, Executive Secretary
State of Tennessee Stream Pollution Control Board
Mr. John L. Phillips, Director of the Division of Pollution Control
Memphis-Shelby County Health. Department
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I
1
SMAILEY MAGNESIUM COMPANY, IMC. 020
D I V I S I 0 ,\< 0 i: PIPER I i-i n IJ S T H I E S. I N C.
719 PIPER STREET. COLLIERVILLE. 1 l-NNESSEE 380)7 901/853-4761
February 3, 1972
Mr. George L.'Harlow
Environmental Protection Agency
1421 Peachtree St., N.E. "" '
Atlanta, Georgia 30309
Reference: Your letter to Piper Brothers of. 1-31-72
Dear Sir:
This letter is to authorize the Environmental
Protection Agency Representatives to conduct waste
discharge sampling, analysis, and flow measurement,
as may be required.
To re emphasize the conversation with Dr. Smith
o-f E.P.A., our waste discharge is of an intermittant,
nature. I've will be shut down .during the period from
February loth to February 21st to -have the sludge
pumped from -our lagoon. . - Sampling can be taken any
time during the period, of February 23rd to March
If these dates so .not meet your schedule, please
advise as once so that we may reschedule.
Thank you for your cooperation in this matter.
Please advise- if any further information is needed.
r Very truly yours,
'SMALLEY MAGNESIUM CO.
James V/. Baird
Mfg. Engineer
JB/dd
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. C-21
DAY & NIGHT COMPAKY
. PAYNE COMPANY
COLLIKUVII.U:, TK.X.VKSSKK 38017
February 3} 1972
ENVIRONMENTAL PROTECTION AGENCY
Region IV
1421 Peachtree Street, N.E.
Atlanta3 Georgia
ATTN: MR. GEORGE L. HARLOW
CHIEF, ENFORCEMENT BRANCH
Dear Mr..Harlow:
This is in response to your letter dated January 31, 1972 and
acknowledgement of the- request for permission and cooperation
in conducting waste discharge sampling, anaylsis, and flow
measurement.
Regular plant, hours are Monday through Friday - 8:00 .a.m. to
-4:30 p.m. and I, or a Management representative, will be
available to assist your representatives upon their arrival.
Sincerely;,
Reynold Kordatzky
Manager of; Safety & Security
/gni. .
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JOS. SCHLITZ BREWING COMPANY 0-22
MILWAUKEE, WISCONSIN 5320.1
PLANT , - ' ' ' . ' . .
. npx 18309 '"- . February 2, 197-2
HOLIDAY CITV STATION .
S, TENNESSEE
Mr. George L. Harlow
Chief, Enforcement Branch
Environmental Protection Agency
1421 Peachtree St., N. E.
Atlanta, Ga. 30309 . .
Dear Mr. Harlow:
We are in receipt of your correspondence dated
January 31, 1972 regarding the forthcoming
survey to be conducted by the Environmental
Protection Agency.
By copy of this letter, the Jos. Schlitx Brewing
'Company grants "... permission for Environmental
Protection -Agency representatives to conduct
waste .discharge sampling, analyses and flow
measurement" associated with the operation of
the brewery in Memphis, Tennessee.
As I am sure you are aware, Dr. Wayne Smith has
scheduled the survey team to proceed with the.
investigation and collection of data during the
week of February 21, 1972. We, most assuredly,
will cooperate in every way possible with the
survcvy team while at the Jos. Schlitz Brewing Co
Sincerely,
PARrbw / Patrick A. Re illy
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NAVAL AIR STATION MEMPHIS (84)
MILLINGTON, TENNESSEE 33054
Code PWU
' 4 February 1972
Mr. George L. Mar low
Chief, Enforcement Branch
Environmental Protection Agency
Region IV . .
1*421 Peachtree St. NtE. ;
Atlanta, Georgia 30309
Dear Mr0 Ha flow:
This is to notify you that the Environmental Protect ion. Agency,
representatives have permission to conduct waste di-scharge sampling
and analysis as necessary at this activity as requested in your letter
of 31 January 1972,
fs l A I
Re' \J. HOUGHTfi>;
Copy to: - - ^R, CEC, usf^
Mr. Jira Carr . pVlBLIC WORKS OFFICER
South Div NAVFAC . . By direction of the Commanding Officer
Charleston SC
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k HOMAS F*. HALL,
MRS. LOIS UrrCLMAN,Cl.Cm'.
fjourd
SRLfS V,'. BAKED
. HAHVC.LL. JR.
D HOLLINGSWORTH
V.'. S. HOV/Af»D
C. V.'. MALLY
MCKELVY
. V.'AGES
' Milling Ion, Tennessee
February 2, 1972
c-24
Mr. George L. Harlow, Chief,
Enforceriient Branch Region IV,
Environmental Protection Agency
1421 Peach tree Street, I
E.
Atlanta, Georgia
Dear Mr. Harl ow:
30309
As requested by your letter of January 31,
1972, the Environmental Protection Agency
is hereby granted pernn ssi on .t-o take any
samples, make any tests or other procedures
to evaluate the discharge wastes from-our
wastewater and water treatment facilities.
Vie are prepared to cooperate with-your
representatives in every possible way.
Clean water is our responsibility also.
It is requested that we be supplied with a
copy of data taken from our facilities.
Very tru ly yours ,
U'^L^c-' L-.^&L^-^s.,?^--
(/
Jotm Clement,
V/ater Superintendent,
Ci ty of Hi 11i ngton .
OC:maf
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