FOLLOWUP MEETING
HOUSTON
HOUSTON, TEXAS
CONFERENCE
In the Matter off Pollution of the
Navigable Waters off Galveston
and its Tributaries.
ENVIRONMENTAL PROTECTION AGENCY
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60
FOLLOWUP MEETING
CONFERENCE
IN THE MATTER OF
POLLUTION OF THE NAVIGABLE WATERS OF
GALVESTON BAY AND ITS TRIBUTARIES
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held at
Houston, Texas
December 5, 1972
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TRANSCRIPT OF PROCEEDINGS
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A
CONTENTS
PAGE
Opening Statement - Murray Stein 5
T. P. Gallagher 9
H. C. Yantis, Jr 132
D. Whittington 1^7
G. J. Putnicki 180
K. Kirkpatrick 189
J. G. Wade 199
Summary - Murray Stein 207
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A followup meeting of the conference in the matter
of pollution of the navigable waters of Galveston Bay and its
tributaries, with specific reference to the Houston Ship Channe
was held at the Shamrock Hilton Hotel, Houston, Texas, Decem-
ber 5> 1972, commencing at 9 ofclock.
PRESIDING:
Mr. Murray Stein
Chief Enforcement Officer - Water
U. S. Environmental Protection Agency
Washington, D. C.
P-.
CONFEREES:
Mr. George Alexander
Deputy Regional Administrator
Region VI, U. S. Environmental Protection Agency
Dallas, Texas
Mr. Hugh C. Yantis, Jr.
Executive Director
Texas Water Quality Board
Austin, Texas
PARTICIPANTS:
Mr. Thomas P. Gallagher
Director, National Field Investigations Center
Denver, Colorado
Mr. Kenton Kirkpatrick
Grants Coordinator
U. S. Environmental Protection Agency
Dallas, Texas
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r * " " "
| PARTICIPANTS
George J. Putnicki, Director
Surveillance and Analysis Division
U. S. Environmental Protection Agency, Region VI
Dallas, Texas
Joan G. Wade, Alderman
City of Nassau Bay
Texas
Dick Whittington, Deputy Director
Texas Water Quality Board
Austin, Texas
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J. T. Adams, Jr.
Manager, Air & Water Conservation
Atlantic Richfield Company
P. O. Box 2451
Houston, Texas
Harless Benthul
Attorney
EPA, Dallas
Fred W. Bishop
Technical Director
Southland Paper Mills, Inc.
P. O. Box 149
Lufkin, Texas 75901
Joshua L. Brener
Project Manager
Bernard Johnson, Inc.
5050 Westheimer
Houston, Texas
Don M. Brown
Field Supervisor
State Health Department
Box 210
LaMarque, Texas
Grady E. Campbell
Eng. Technician
EPA, Houston
James L. Collins
Attorney
EPA, Dallas
M. J. Coloton
District Supervisor, Dist #7
Texas water Quality Board
Deer Park, Texas
T. L. Cox
Chemist
Charter International oil Co.
9701 Manchester Avenue
Houston, Texas 77012
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Nicholas Creel
Environmental Engineer
Crown Central Petroleum
P. 0. Box 1759
Houston, Texas
David A. Curtis
Biologist
EPA, Houston
Mauri Dial
Reporter
KTRH - KLOL Radio
Thomas L. Dickerson
KCOH Radio
5011 Almeda
Houston, Texas
Robert L. Douglass III
Assistant Director
Harris County Pollution Control
107 N. Munger
Houston, Texas
Fred Edison
Cameraman
KDRC - TV
8181 Southwest Freeway
Houston, Texas
Robert B. Elliott
Acting Chief, Permits Branch
EPA, Dallas
Fran Farrell
Chemist
EPA, Houston
Larry B. Feldcamp
Attorney
Baker & Botts
3000 One Shell Plaza
Houston, Texas 77002
K. A. Fisher
1800 Stoney Brook Drive, #203
Houston, Texas 77042
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4-1
Robert G. Fleming
Director, Central Operations
Texas Water Quality Board
P. O. Box 13246, Capital Station
Austin, Texas 78711
Tom Pox
News Broadcaster
KPRC - TV
8181 Southwest Freeway
Houston, Texas 77027
Brenda Gehan
Water Chairman
League of Women Voters - Houston
4986 Valkeith Drive
Houston, Texas
Fred W. Gerdes
Environmental Engineer
Petro-Tex Chemical
Box 2584
Houston, Texas 77001
L. A. Greene, Jr.
519 Medical Towers Bldg.
Houston,Texas
A. S. Grundy
Superintendent, Construction
G. G. Ross, Inc.
1711 Davon Lane
Nassau Bay
Richard D. Hall
Regional Environmental Control Manager
Diamond Shamrock Corporation
Deer Park Works
P. O. Box 500
Deer Park, Texas 77531
William E. Hall
Plant Manager
Sinclair - Koppers Co.
P. 0. Box 12188
Houston, Texas 77017
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4-C
Larry D. Hannesschlager
Biologist
EPA, Houston
Thomas P. Harrison, II
Director, Enforcement Division
EPA, Dallas
David M. Hays
Biologist
Texas Water Quality Board
2318 Center
Deer Park, Texas
Lavern R. Heble
Senior Environmental Engineer
Diamond Shamrock Corporation
P. O. Box 500
Deer Park, Texas
J. L. Henderson
Manager, Administrative Services
Champion International
P. O. Box 372
Pasadena, Texas 77501
Edward R. Ibert
Ex Director public Health
City of Pasadeaa
203 W. Shaw
Pasadena, Texas 77502
Clarence E. Johnson
Texas Water Quality Board
2318 Center Street
Deer Park, Texas
Jere M. Johnson
Supervisor, Environmental Engineering
Humble Oil Company
P. O. Box 3950
Houston, Texas
Joe W. Johnson
Projects Coordinator
City of Houston
P. 0. Box 1562
Houston, Texas
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Malcolm F. Kallus
Facility Manager, Houston Facility
EPA, Houston
Tom Kearns
Engineering Technician
Texas Water Quality Board
1005 Isabella, # 22
Houston, Texas
C. B. Kincannon
Engineer
Texas Water Quality Board
2318 Center
Deer Park, Texas
J. S. Kirkpatrick
Biologist III
Texas Water Quality Board
District 7
2318 Center Street
Deer Park, Texas 77536
Kenton Kirkpatrick
Grants Coordinator
EPA, Dallas
John Latchford
Director, Field Operations
Texas Water Quality Board
Austin, Texas
W. H. Leo
Assistant to the President
Armco
P. O. Box 723
Houston, Texas
O. W. Lively
Deputy Director, Enforcement Division
EPA, Dallas
R. M. Love
Environmental Coordinator
Enjay Chemical Company
Box 4004
Baytown, Texas
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Mrs. Susan S. Love
Chemist
Edna Wood Laboratories, Inc.
P. O. Box 14171
Houston, Texas 77021
William T. Manning
Hydrologist
Texas Water Quality Board, District 7
2318 Center
Deer Park, Texas 77536
D. P. Martin
Director, Air & Water Conv.
Gulf Oil Company - U.S.
P. O. Box 1519
Houston, Texas 77001
Carl E. Masterson
Biologist II
Texas water Quality Board, District 7
2318 Center Street
Deer Park, Texas 77536
Rex G. McDommell, jr.
Environmental Control Supervisor
Monsanto Company
P. 0. Box 1311
Texas City, Texas
William R. Miles
Environmental Engineer
Charter International Oil Company
Box 5008
Houston, Texas 77012
M. Dwayne Milner
Aquatic Biologist
EPA, Houston
Tim Morris
Chief Engineer, Field Operations
Texas water Quality Board
Austin, Texas
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H. Nugent Myrick
Associate Professor
University of Houston
2123 Winrock
Houston, Texas 77027
Matt Nations
Project Coordinator
Texas Water Quality Board
12631 Rocky Meadow
Houston, Texas 77024
Robert L. Pettit
Chemist
Arco Chemical Company
P. 0. Box 777
Channelview, Texas 77530
George J. Putnicki
Director, S & A Division
EPA, Dallas
Gordon J. Reno
Manager, Environmental Conservation
Shell Oil Company, Houston Refinery
P. 0. Box 100
Deer Park, Texas 77536
T. H. Rhodes
Environmental Conservation Advisor
Enjay Chemical Company
1333 West Loop South
Houston, Texas
C. H. Rivers
Staff Engineer
Shell Chemical
Box 2633
Deer Park, Texas 77536
Ben E. Royal, Jr.
Reporter
Texas City Daily Sun
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Richard Ryan
Production Engineer
The Upjohn Company
P. 0. Box 685
Laporte, Texas 77571
Harold Scarlett
Reporter
Houston Post
4747 SW Freeway
Houston, Texas
Frank G. Schlicht, Ph.D.
Biologist, Environmental Protection
Houston Lighting & Power Company
P. O. Box 1700
Houston, Texas 77001
H. Siegel
Senior Research Chemist
Shell Development Company
3737 Bellaire
Houston, Texas
A. Gene Smith
Supt. - Operations
Shell Oil Company
P. 0. Box 100
Deer Park, Texas
Glenn A. Stankis
Chemical Engineer
EPA, Houston
Sharron Stewart
Citizens Survival Com. Bx. Board
328 Redwood
Lake Jackson, Texas 77566
Gordon Stoltz
Chemical Engineer
Phillips Petroleum Company
Box 792
Pasadena, Texas 77501
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Joe P. Teller
Deputy Manager
Gulf Coast Waste Disposal Authority
910 Bay Area Blvd
Houston, Texas
Ray Verducci
Process Engineer
Sinclair Koppers
LaPorte Freeway
Joan G. Wade
Alderman
City of Nassau Bay
1526 Saxony Lane
Nassau Bay, Texas 77058
Janet Walker
Air Quality Chairman
League of Women Voters
5642 Valkeith
Houston, Texas 77035
Dr. J. E. Whitney
Chief, Laboratory Activities
EPA, Houston
Dick Whittington
Deputy Director
Texas water Quality Board
Austin, Texas
Richard C. wigger
Director of Environmental Quality
Champion papers
Knightsbridge Drive
Hamilton, Ohio
Carroll G. Wills
Attorney
National Field Investigations Center - EPA
Denver, Colorado
Edna D. Wood
President
Edna Wood Laboratories, Inc.
P. O. Box 14171
Houston, Texas 77021
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j'j -LiiG d'j'A'i i-i.-'-i'.ii'jT
MURRAY STEIIJ
MR. STEIH : The meeting is in session.
This meeting, called by the Environment a] Protection
Agency in cooperation with the Texas water pollution control
authorities, is designed to follow up on cur activities cealir^
with the pollution problem of the Houston Shin Channel. There
have been two sessions of an enforcement conference in 1971
dealing with the situation. We had extensively explored the
various aspects of the Houston Ship Channel pollution problem
at that time, and as those people in the room who nave been at
those sessions of the conference will recall, we have had
extended testimony and afforded everyone an opportunity for a
full exposition of their views.
Among other things, we established load -limits for
the channel, various requirements for discharges, and estab-
lished a technical committee to follow up with certain aspects
of the problem.
In the interim, the Congress has passed extensive
j and new Federal water pollution control legislation, legisla- !
i :
tion under which we are now operating and which will have a j
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Opening Statement - M. Stein
tremendous iinpact on discharges into the waters of the United
States of all sorts, municipal, industrial, and agricultural,
and also a, larp;e Impact on State programs and will involve a
reordering and realignment of Federal and State programs in
: order to mesh and carry out the purposes of the new law.
Not the least of these will be the issuance of per-
mits which will be required under the new Federal Act, and
under that new Federal Act either the States will be given
authority from the Federal Government to issue permits in
accordance with certain Federal guidelines or in lieu of that
the Federal Government will issue the permit, but in one way
or another the municipalities and the industries will have to
have one of these permits before they can discharge any
material into the navigable waters of the United States. If
they do so without such a permit, they will be violating the
law and that will be a violation of Federal law as well as
i State law. !
i • i
1 I think it is fair to say that the new legislation j
j
i
was designed to be a tightening up of water pollution control i
requirements throughout the country. It is also fair to followj
i
through that as a corollary that the new legislation did not
Intend by specific word, legislative history or implication
to state that any agreement that had been reached previously,
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Opening Statement - M. Stein I
time schedule or anything of that sort, would be made more
lenient by virtue of the new legislation. .
The nurpose of this meeting, therefore, is to try
to determine the progress we have made since the last confer-
ence, to determine what the technical committee has come up
with in its evaluation, and significantly determine how we
and the State of Texas together are going to move forward
with the new Federal legislation in order to achieve cleaner
waters for Texas and the .Nation.
We would like to have, as we always have had, full
participation by anyone who would like to make a statement.
I should indicate, though, that in view of the extensive, and
really extensive, proceedings we have had before we expect to
conclude this meeting today and we certainly would not expect
to go beyond 5 o'clock this afternoon.
Mow, if anyone in the audience would want to make a
statement, will you please put your name on a piece of paper '•.
or a card and get it up to me here with an estimated time that ;
you are going to speak. Hopefully we will be able to accom- j
modate everyone, but if necessary in order to meet the time !
schedule I may suggest that some of the people take a little i
less time to make their statements. I think that if we all j
cooperate we can get this program under way and we can bring j
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! Opening Statement - M. Stein :
t
; out any unresolved issues without taking an extraordinary \
I amount of time to do this. Let me assure you, we are not here
t
i to cut anyone off and if there are any special problems we
i will be glad to entertain them.
i
I At this point I would like to take the opportunity
i of introducing the two distinguished colleagues I have with -••
• me on the panel, although neither one of them needs an intro- i
; duction.
, To my left is Mr. Hugh Yantis, who has long been Mr. ;
I Water Pollution Control in the State of Texas and one of the
! most distinguished professionals in the entire country in the
i field of water pollution control.
; And to my right is Mr. George Alexander, the Deputy
i Regional Director for this regional office of the Environmental
I
! Protection Agency, with headquarters in Dallas.
i
| At this noint I would like to call on Mr. Alexander -.
i for the Federal presentation.
i ;
| Mr. Alexander. . !
i '•
\ i
i MR. ALEXANDER: Thank you, Mr. Stein.
i ;j
i »
I I would like to call on Mr. Tom Gallagher to present :
i ~ :
i
I a report on the proceedings in this matter through April of •;
1972. Mr. Gallagher is the Director of the Environmental ;
i
Protection Agency's National Field Investigation Center in i
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T. P. Gallagher
Denver, Colorado, and a member of this technical committee.
Tom.
THOMAS P. GALLAGHER, DIRECTOR
NATIONAL FIELD INVESTIGATIONS CENTER
DENVER, COLORADO
MR. GALLAGHER: Thank you, Mr. Alexander.
Mr. Chairman, conferees. I am going to present por-
ti
tions of a report titled^ Progress Report on Recommendations of
the Galveston Bay Enforcement Conference. I would like the
entire report entered into the record as if read.
MR. STEIN: Without objection, that will be done.
(The above-mentioned report follows:)
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10
PROGRESS REPORT
ON
RECOMMENDATIONS
OF THE
GALVESTON
BAY ENFORCEMENT
CONFERENCE
BY
GALVESTON BAY TECHNICAL COMMITTEE
TEXAS WATER QUALITY BOARD
AND
ENVIRONMENTAL PROTECTION AGENCY
October 1972
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TABLE OF CONTENTS
Section Description Page
LIST OF FIGURES ii
LIST OF TABLES ii
LIST OF ATTACHMENTS iii
I INTRODUCTION 1
I I SUMMARY OF CONFERENCE 6
III SHELLFISH RECOMMENDATIONS 16
IV A. DISINFECTION OF WASTE SOURCES 20
B. CENTRALIZATION OF TREATMENT FACILITIES 2k
V GALVESTON BAY WASTE SOURCE SURVEY 25
VI OIL AND GREASE REMOVAL 26
VII WASTE LOAD REDUCTION PROGRAM 31
VIII ORGANIC SLUDGE DEPOSITS - DISPOSAL OF*
DREDGING SPOIL 33
IX COLOR REMOVAL 39
X BOD ALLOCATIONS TO HOUSTON SHIP CHANNEL 46
REFERENCES - COLOR REMOVAL
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LIST OF FIGURES
12
Figure No. Title
VI1-1 Houston Ship Channel B.O.D. Loading
VII-2 Total B.O.D. Contributed by the Four
Major Texas City Industries
VI11-1 Volatile Solids Profile of Bottom Sludges
VI11-2 Volatile Solids (%) Profile of Bottom
Sludges
VI11-3 B.O.D^ Profile of Bottom Sludges
VI11-4 COD Profile of Bottom Sludges
VI11-5 Percent Oil and Grease Profile of
Bottom Sludges
Follows Page
32
33
35
36
36
36
36
LIST OF TABLES
Table No. Title Page
111-1 Chemistry Task Force 18
IV-1 Municipal Waste Discharges into Houston
Ship Channel and Calveston Bay 21
Vll-l Major Texas City Dischargers 33
VI11-1 Observations 35
VI11-2 Side Bay Analytical Data Summary 38
IX-1 Background Color Survey - Upper Galveston
Bay and Tributaries 42
X-l B.O.D. Allocations to Houston Ship Channel 49
ii
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LIST OF ATTACHMENTS
Attachment Title Pages
Texas Water Quality Board Order No. Al-1 to 8
71-0819-1 and Addendum
Texas Water Quality Board Order No. A2-1 to 7
69-9A
Houston - Galveston Area Council A3-1 to 8
Proposed Regionalization Program for
Waste Abatement
Public Hearing Notice on Proposed B.O.D. A**-] to 13
Allocations for Houston Ship Channel
iii
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I
INTRODUCTION
The Galveston Bay Technical Committee was formed by the Conferees'
of the Galveston Bay Enforcement Conference at the conclusion of the
first session in June 1971. The Technical Committee summarized testi-
mony offered at the first session and the Conferees adopted recom-
mendations at the second session in November 1971. Many of these
recommendations require periodic submittal of progress reports prior to
the time of full implementation. In accordance with these recommendations,
the Galveston Bay Technical Committee submits this first progress report.
Recommendations Number 4, 5 and 11 concerned adequate criteria and
sampling of shellfish harvesting areas to insure acceptability of the
product for consumption. The Food and Drug Administration has initiated
a nationwide sampling and analysis program to determine the toxicological
significance of oil and hydrocarbon residues in oysters. Preliminary data
from this survey are not yet available for general distribution. The
Texas State Board of Health and the Food and Drug Administration have
amended the sampling schedule in Galveston Bay to include, as far as
possible, data collection under the most unfavorable hydrographic and
pollution conditions. Alert levels proposed for heavy metal concentrations
in shellfish at the Food and Drug Administration Seventh National Shell-
fish Sanitation Workshop were not adopted. A committee has been formed
to study the problem and review available data at yearly intervals.
Recommendation No. 6 concerned effective disinfection of municipal
effluents and the centralization of sewage treatment plants. Grab
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15
samples of efffluents from 50 major municipal waste plants collected by
the Texas Water Quality Board in March 1972, indicated that a large
number of the plants were meeting the Texas Water Quality Board chlorine
residual requirements. However, total and fecal coliform concentrations
in the effluents of many plants were still excessive. Total and fecal
coliform are indicators of the possible presence of pathogenic organisms.
In general, those plants with larger contact times discharged effluent
with satisfactory bacteriological quality. In general, the unsatis-
factory bacteriological densities are related to either excessive solids
concentrations in the effluent, or short circuiting in the chlorine
contact tank, or both. Correction of the problem is being pursued on
a case by case basis by the Texas Water Quality Board. The Sims Bayou
plant of the City of Houston is the only major municipal waste source
without chlorination facilities. These facilities will be constructed
and in operation by December 1972.
With respect to the centralization of sewage treatment plants and
the elimination of small facilities, the Texas Water Quality Board has
issued an order to the City of Houston requiring the abandonment of a
number of obsolete plants and the diversion of these wastes to regional
and sub-regional systems. The Clear Lake area has also received a Texas
Water Quality Board order with the same objective. Compliance with these
Texas Water Quality Board orders is mandated before December 31, 1974.
Recommendation No. 7 called for a joint waste source survey of the
Galveston Bay area by" the Environmental Protection Agency and the Texas
Water Quality Board, in addition to other ongoing studies. This survey
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commenced during April 1972. It is presently anticipated that approxi-
mately one-half the waste effluent flow to the Houston Ship Channel will
have been analyzed,by October 1972. Results will be provided to t»ie
Conferees as soon as they become available.
Recommendation No. 8 called for 'the requirement of best reasonable
available treatment to minimize discharges of oil and grease. Texas
Water Quality Board permits are being amended to require oil and grease
concentrations in waste effluent to be not greater than 10 ppm.
Recommendation No. 9 called for a continuing reduction of waste
loads and amendment of Texas Water Quality Board permits to reflect these
reductions. Under present abatement schedules, the waste load to the
Houston Ship Channel will be reduced to about 60,000 pounds per day of
biochemical oxygen demand (BOD) by December 1973, from the present
100,000 pounds per day. The major waste sources in the Texas City area
will be reduced from the present 78,000 pounds per day to 13,800 pounds
per day in 1974 to 11,800 pounds per day in 1976.
Recommendation No. 10 called for an evaluation of the organic sludge
problem in the Houston Ship Channel with specific emphasis on the develop-
ment of suitable dredged spoil disposal areas. Examination of bottom
deposits by Texas A&M University showed highly organic material and
represents an important pollutional source. Some analyses indicate that
the Channel deposits contain material toxic or inhibitory to micro-
organisms'. EPA and the U. S. Army Corps of Engineers have proposed the
construction of a ringed diked spoil area on Atkinson Island. Further
studies of the environmental impact of this proposal are advisable.
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Recommendation No. 12 required an assessment of feasible processes
to accomplish color removal from waste sources. The Committee decided
that, although several ongoing research studies on color removal indicated
promising results, the technology was still not sufficiently developed
to require color removal processes be installed at the present time.
The Texas Water Quality Board permits do specify that such processes
will be installed when technological feasibility for general use is
demonstrated.
Recommendation No. 13 states that: "To meet present official
State-Federal water quality standards established for dissolved oxygen
in the Houston Ship Channel, it is expected that the maximum waste load
discharged from all sources will be about 35,000 pounds per day of five-
day BOD, including projected future development. The Texas Water Quality
Board in cooperation with technical personnel of the EPA shall review
existing waste discharge orders with the objective of allocating
allowable five-day BOD waste loads for sources discharging to the
Houston Ship Channel such that the probable 35,000 pounds per day maximum
shall not be exceeded," Such an allocation was made by the Technical
Committee and presented in a public hearing by the Texas Water Quality
Board in Baytown, Texas in February 1972. Major opposition to these
allocations was voiced at this hearing. The Texas Water Quality Board
is conducting an abatement program that will attain a total B.O.D.
effluent level of approximately 60,000 pounds per day by December 1973.
During this period, consultations will be held between the Texas Water
Quality Board and the Environmental Protection Agency with individual
waste dischargers to determine specific implementation dates by these
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18
waste sources for meeting Federal-State water quality standards for the
Houston Ship Channel. The present program of limiting effluents to
60,000 pounds per day is an interim step and may not meet presently
approved State-Federal water quality standards for dissolved oxygen in
the Houston Ship Channel.
Recommendation No. 14 directs an allocation of allowable waste
loads to Galveston Bay and all other tributary areas. The Clear Lake
area has received a Texas Water Quality Board order requiring the abandon-
ment of obsolete plants and the diversion of these wastes to regional and
sub-regional systems. The major waste sources in the Texas City area
will be reduced from the present 78,000 pounds per day to 13,800 pounds
per day in 1974 to 11,800 pounds per day in 1976. The City of Galveston
has been directed by a Texas Water Quality Board order to make extensive
improvements in the collection system and to provide expanded treatment
facilities by December 31, 1974.
Representatives of the Galveston Bay Technical Committee are:
Texas Water Quality Board:
*
Joe Teller - Formerly Deputy Director
Dick Whittington - Director, Field Operations
Robert Fleming - Director, Central Operations'
Environmental Protection Agency:
Thomas Harrison - Region VI, Dallas, Texas
Malcolm Kallus - Region VI, Dallas, Texas
*
Thomas P. Gallagher - National Field Investigations
Center-Denver, Colorado
* - Mr. Tellers' position on the Technical Committee has been assumed by
Mr. Tim Morris Chief, Field Support Section, Field Operations Division
of the Texas Water Quality Board.
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ii
SUMMARY OF CONFERENCE
(FIRST SESSION)
POLLUTION OF THE NAVIGABLE WATERS
OF
GALVESTON BAY AND ITS TRIBUTARIES
June 7-12 and November 2-3, 1971
The Administrator of the Environmental Protection Agency, in
accordance with section 10 of the Federal Water Pollution Control
Act, as amended (33 U.S.C. 1160), and his finding that substantial
economic injury results from the inability to market shellfish or
shellfish products in interstate commerce because of pollution, and
the action of Federal, &6ate, or local authorities, on April 13, 1971,
called a conference in the matter of pollution of the navigable waters
of Galveston Bay and its tributaries (Texas), The conference was held
June 7-12, 1971, at the Rice Hotel, Houston, Texas, and reconvened on
November 2-3, 1971, at the Shamrock Hilton Hotel, Houston, Texas.
Galveston Bay is located in southeastern Texas on the Gulf of
Mexico about 25 miles southeast of Houston, the largest city in the
State. The Galveston Bay estuarine system, consisting of four large
bays, Galveston, Trinity, East, and West Bays, and numerous smaller
bays, creeks and bayous, has a total surface area of about 533 square
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miles and is the largest estuary on the Texas coast. The combined
shoreline totals 245 miles.
The following conferees representing the State water pollution
control agency and the Environmental Protection Agency participated
in the conference:
TEXAS
Hugh C. Yantis, Jr.
ENVIRONMENTAL PROTECTION AGENCY
Richard A. Vanderhoof
Murray Stein, Chairman
Executive Director
Texas Water Quality Board
Austin, Texas
Director, Enforcement Division
Region VI
Environmental Protection Agency
Dallas, Texas
Chief Enforcement Officer - Water
Environmental Protection Agency
Washington, D. C.
The Chairman of the conference pointed out that:
1. Under the Federal Water Pollution Control Act, as amended
(33 U.S.C. 1160), pollution of interstate or navigable waters which
endangers the health or welfare of any persons is subject to abate-
ment under procedures described in section 10 of the Federal Act.
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8 21
2. Under the provisions of section 10 of the Act, the Admin-
istrator of the Environmental Protection Agency is authorized to
initiate enforcement procedures when he finds that substantial economic
injury results from the inability to market shellfish or shellfish
products in interstate commerce because of pollution subject to abate-
ment under the Act, and action of Federal, State, or local authorities.
3. The first step of these procedures is the calling of a
conference.
4. The purpose of this conference is to bring together represen-
tatives of the State water pollution control agency and the Environmental
Protection Agency to review the existing situation and the progress which
has been made, to lay a basis for future action by all parties concerned,
and to give the State, localities, and industries an opportunity to take
any indicated remedial action under State and local law.
In light of conference discussions, the following conclusions and
recommendations were reached by the conferees:
1. The Federal conferee concluded that there is occurrence of pol-
lution of interstate or navigable waters due to discharges from municipal
and industrial sources subject to abatement under the Federal Act.
The State conferee took the position that the conference was
called under the shellfish provisions of the Act and that while there is
pollution occurring in the waters covered by the conference, it has not
been demonstrated that substantial economic injury results from the
inability to market shellfish products in interstate commerce.
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2. While measures have been taken to reduce such pollution, they
are not yet adequate.
3. Delays encountered in abating the pollution have been caused
by the enormity and complexity of the problem.
A. The Food and Drug Administration, in cooperation with appro-
priate State regulatory agencies, will continue its recently initiated
national study of oil and hydrocarbon residues in oysters, including
those taken from Galveston Bay, with the objective of determining
toxicological effects, if any, of such concentrations. These data, and
any evaluations, will be made available to the conferees of the Galveston
Bay enforcement conference.
5. To insure that approved shellfish harvesting areas are properly
classified at all times, sampling for determining bacteriological
acceptability of areas for shellfish harvesting in Galveston Bay shall
continue to emphasize the most unfavorable hydrographic and pollution
conditions. The most unfavorable hydrographic and pollution conditions
will be determined by technical personnel of the Texas State Health
Department, in cooperation with the Food and Drug Administration and
other Federal and State and local agencies.
6. Effective disinfection of all waste sources contributing
bacteriological pollution to the Galveston Bay system will be provided.
The Texas Water Quality Board policy to this effect shall continue to
be implemented. Where effective disinfection is not presently being
accomplished, it is recognized that adequate measures are underway
-------
10 23
to secure that disinfection. These measures shall be effective by
December 31, 1971.
The Texas Water Quality Board will continue to implement its
policy requiring the elimination of small plants. The centralization
of facilities, wherever possible, and the halt of proliferation of
small plants will continue, consistent with existing appropriate pro-
cedures. The implementation schedule for this program, as initiated
by the Texas Water Quality Board, will be made available to the conferees
of the Galveston Bay enforcement conference not later than April 1, 1972.
7. The Environmental Protection Agency and the Texas Water Quality
Board will cooperate in a study of Galveston Bay. This study is presently
being conducted by the Texas Water Quality Board on all sources of muni-
cipal and industrial wastes permitted by the Texas Water Quality Board
to discharge effluent to Galveston Bay and its tributaries. These
examinations shall emphasize determination of complex organic compounds,
heavy metals and other potentially toxic substances, as well as oil and
grease, from each waste source. Recommendations and scheduling of
necessary abatement will be provided to the conferees as soon as they
become available. The Texas Water Quality Board permits and self-
reporting data system will be amended, as necessary, to reflect the
recommendations of this waste source survey. A progress report on
results of this study will be made to the conferees within six months
of the date of the reconvened session of the Galveston Bay enforcement
conference.
8. The Texas Water Quality Board will continue its review of each
waste source discharging to Galveston Bay and its tributaries, and will
-------
11
amend those permits as necessary to insure that the best reasonable
available treatment is provided relative to discharges of oil and grease.
The Texas Water Quality Board will cooperate with EPA and local govern-
ments in determining what treatment is the best reasonable available
treatment. It is recognized that improvements in technology will be
incorporated into future permit revisions. A progress report will be
made to the conferees within six months of the date of the reconvened
session of the Galveston Bay enforcement conference.
9. The ongoing review and amendment by the Texas Water Quality
Board of existing permits recognizes that greater reductions of waste
will be required of waste dischargers to the Galveston Bay system to
meet water quality standards. The conferees note that in the past
three years the organic waste load being discharged into the Houston
Ship Channel has been lowered from about 430,000 pounds per day of BOD
to 103,000 pounds per day of BOD. Any amendments to existing or new
Texas Water Quality Board waste control orders as a result of this
program will prohibit dilution as a substitute for treatment. A progress
report on continuing reduction of waste loads will be provided to the
*
conferees within six months of the date of the reconvened session of the
•
Galveston Bay enforcement conference.
10. A characterization and evaluation of the water quality signi-
ficance of materials from pollution sources contained in the organic
sludge dredged from the Houston Ship Channel shall be conducted. Based
on the results of this evaluation and examination of present spoil
disposal areas, recommendations will be made by the Texas Water Quality
-------
12 25
Board and the Environmental Protection Agency on location of suitable
spoil disposal areas and other appropriate action to minimize or eliminate
deleterious effects on water quality.
11, If alert levels for acute and chronically toxic or growth
inhibiting factors are developed by the Food and Drug Administration for
shellfish from all approved national growing waters, including Calveston
Bay, the appropriate Texas agencies and the Environmental Protection
Agency, in cooperation with the Food and Drug Administration and other
appropriate Federal agencies will work to develop requirements for the
same characteristics in waters approved for shellfish harvesting.
12. Chemical constituents causing color in waste effluents, such
as those from pulp and paper mills, shall be reduced to natural background
in area waters as soon as practicable as stated in existing Texas Water
Quality Board waste control orders. A report on feasible processes to
accomplish this recommendation shall be submitted to the conferees
within six months of the reconvened session of the Calveston Bay enforce-
ment conference.
13. [To meet present official State-Federal water quality standards
established for dissolved oxygen in the Houston Ship Channel, it is
expected that the maximum waste load discharged from all sources will be
about 35,000 pounds per day of five-day BOD, including projected future
development. The Texas Water Quality Board in cooperation with technical
personnel of the EPA shall review existing waste discharge orders with
the objective of allocating allowable five-day BOD waste loads for sources
-------
13 26
discharging to the Houston Ship Channel such that the probable 35,000
pounds per day maximum shall not be exceeded.] A report will be made
to the conferees on the results of this review by April 1, 1972. The
allocation for. each waste source as determined by the Texas Water Quality
Board, in cooperation with the EPA, shall be attained by December 31, 1974.
Interim dates to determine progress toward compliance of the assigned
allocation shall be established for each waste source by May 1, 1972.
The conferees also recognize that discharge of other waste
constituents shall as, but not limited to, chemcial oxygen demand,
suspended solids, complex organics, and other toxic materials also con-
tribute to the pollution of Galveston Bay and its tributaries. An
allocation of allowable waste discharges for these pertinent parameters
from each waste source will be established by technical personnel of the
Texas Water Quality Board and the EPA consistent with best available
treatment practices and such allocation will be reported to the conferees
by September 1, 1972.
The conferees recognize that technical considerations may
require a reassessment of this schedule in the case of some of the muni-
cipal and Industrial waste sources to be considered. These necessary
reassessments will be determined by technical personnel of the Texas
Water Quality Board and the EPA, and recommendations concerning schedule
changes will be made to the conferees at six month intervals.
The foregoing recommendations shall not be construed as in any
way foreclosing or interfering with Federal, State or local statutory
proceedings relating to the authorization, amendment, or revocation of
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14 27
Federal or State waste discharge permits or orders, nor shall such
recommendations operate to delay or prevent the creation or operation
of regional waste disposal systems such as the contemplated Gulf Coast
Waste Disposal Authority.
14. All waste sources which discharge directly to Galveston Bay
and other tributary areas, including Clear Lake, shall have allowable
waste loads allocated by June 30, 1972, consistent with best available
treatment practices. This allocation shall include interim dates for
accomplishment of required waste treatment and/or waste treatment
facilities which will be in operation by December 31, 1974. The Texas
Water Quality Board will cooperate with EPA and local governments in
determining what treatment is the best reasonable available treatment.
15. The following recommendation was not susceptible to joint
agreement by the conferees:
Re: Houston Lighting and Power Cedar Bayou Power Plant
(a) The Texas conferee's recommendation— the once through
cooling system, with discharge to Trinity Bay, proposed
for the Cedar Bayou plant shall be carefully monitored
to determine whether damage to aquatic life is occurring
and/or water quality is being deleteriously affected.
If such effects are shown, Houston Lighting and Power
Company will take immediate steps to correct the situation.
(b) The Federal conferee's recommendation—no discharge of
cooling water from the Cedar Bayou plant to Trinity Bay
-------
15 28
shall be permitted. The Houston Lighting and Power
Company shall be required to abate the waste heat load
by incorporation of a system utilizing recirculation
and reuse of cooling water to Tabbs Bay and adjacent
waters or location of additional units at suitable
alternative sites.
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16 29
III
SHELLFISH RECOMMENDATIONS
1. Recommendations
The Food and Drug Administration, in cooperation with appropriate
State regulatory agencies, will continue its recently initiated national
study of oil and hydrocarbon residues in oysters, including those taken
from Galveston Bay, with the objective of determining toxicological
effects, if any, of such concentrations. These data, and any evalu-
ations, will be made available to the Conferees of the Galveston Bay
Enforcement Conference.
To insure that approved shellfish harvesting areas are properly
classified at all times, sampling for determining bacteriological
acceptability of areas for shellfish harvesting in Galveston Bay shall
continue to emphasize the most unfavorable hydrographic and pollution
conditions. The most unfavorable hydrographic and pollution conditions
will be determined by technical personnel of the Texas State Health
Department, in cooperation with the Food and Drug Administration and
other Federal and State and local agencies.
If alert levels for acute and chronically toxic or growth inhibiting
factors are developed by the Food and Drug Administration for shellfish
from all approved national growing waters, including Galveston Bay, the
appropriate Texas agencies and the Environmental Protection Agency, in
cooperation with the Food and Drug Administration and other appropriate
Federal agencies will work to develop requirements for the same character-
istics in waters approved for shellfish harvesting.
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17
2. Discussion
During the summer of 1971, the Food and Drug Administration
initiated a nationwide survey of oil and hydrocarbon residues in oysters
to determine possible toxicological significance of these concentrations.
The Texas State Department of Health has collected oyster meat samples
from Galveston Bay for analysis by the FDA laboratory in Dallas, Texas.
Plans are underway to establish two permanent sampling stations in
Galveston Bay for quarterly analysis of oil and hydrocarbon residues.
Preliminary results of the initial sampling have not yet been made
available by the FDA for general distribution. The study is continuing.
After reviewing available historical sampling data, the FDA, in
cooperation with the Texas State Department of Health has placed increased
emphasis on regulating shellfish and water sampling under the most
unfavorable hydrographic and pollution conditions to insure that shell-
fish harvesting areas are properly classified from a bacteriological
standpoint. The sample collection schedule has been adjusted to more
clearly reflect these conditions. To carry out these new procedures,
additional personnel have been hired.
At the Seventh National Shellfish Sanitation Workshop conducted by
FDA in Washington, D. C., on October 20-22, 1971, the consensus of opinion
was, that while there is a need for some form of alert levels for heavy
metals, it would not be practical to publish any official numerical levels
for metals in shellfish at this time. The proposed levels which were
rejected are shown in Table III-l.
The National Shellfish Sanitation Program acting upon the decision
of the Workshop to establish a permanent Chemistry Task Force, has
30
-------
3118
1.
CHEMISTRY TASK FORCE
TABLE III-l
Proposed Alert Levels be Established for the Following Metals
in the Species and Areas Indicated:
Metal
Cadmium
Cadmium
Cadmium
Cadmium
Species
Oyster
Oyster
Hard Clam
Soft Clam
Area
Northeast
Southern
Northern & Southern
Northern & Southern
Interim i
Alert Level
3.5 ppm
1.5 ppm
0.5 ppm
0.5 ppm
Lead
Lead
Lead
Oyster
Hard Clam
Soft Clam
Northern & Southern
II
II
2.0 ppm
4.0 ppm
5.0 ppm
Chromium
Chromium
Chromium
Oysters
Hard Clam
Soft Clam
2.0 ppm
1.0 ppm
5.0 ppm
Zinc
Zinc
Zinc
Zinc
Zinc
Oysters
Oysters
Hard Clam
Soft Clam
Surf Clam
Northeast
Southern
Northern & Southern
it
u
2,000 ppm
1,000 ppm
65 ppm
30 ppm
20 ppm
Copper
Copper
Copper
Copper
Copper
Oysters
Oysters
Hard Clam
Soft Clam
Surf Clam
Northeast
Southern
Northern & Southern
175 ppm
42 ppm
10 ppm
25 ppm
5 ppm
Mercury
Mercury
Mercury
Oysters
Hard Clam
Soft Clams
0.2 ppm
0.2 ppm
0.2 ppm
* Drained Wet Meats
Workshop Action
After much discussion on the proposal, the consensus of opinion was
that while there is a need for some form of levels for heavy metals,
it would not be practical from an industrial viewpoint, to publish
any official numerical le-els for metals in shellfish at this time.
(This statement is taken verbatim from the FDA Synopsis of Workshop •
Seventh National Shellfish Sanitation Workshop.)
-------
19 32
appointed a tentative committee consisting of members of FDA, EPA,
Virginia Institute of Marine Sciences, the States, the industry and the
academic community. This group will have authority to set such alert
levels for heavy metals, pesticides, oil and hydrocarbons, etc., as
additional data and information collected indicate.
-------
20 33
IV
A. DISINFECTION OF WASTE SOURCES
1. Recommendation
Effective disinfection of all waste sources contributing bacterio-
logical pollution to the Galveston Bay system will be provided. The
Texas Water Quality Board policy to this effect shall continue to be
implemented. Where effective disinfection is not presently being
accomplished, it is recognized that adequate measures are underway to
secure that disinfection. These measures shall be in effect by December
31, 1971.
2. Discussion
A review of the chlorine residual data obtained from the Texas
Water Quality Board self-reporting system showed most plants to be in
compliance with the disinfection criterion of 1.0 ppm chlorine residual
after a 20-minute contact time. Those plants not meeting this criterion
were sent a letter requiring compliance by December 31, 1971. In
addition, total and fecal coliform results were not satisfactory at some
sources where the chlorine residual criterion is being met. See Table
IV-1. If a facility was unable to meet the December deadline due to
inoperative or inadequate equipment, the Texas Water Quality Board was
to be notified by letter of the reason for not complying, the corrective
procedures proposed, and the time schedule for placing disinfection facili-
ties into operation.
Because major construction was required, some" plants were unable to
meet the December 31 deadline. One large plant operated by the City of
-------
TABLE IV-1
MUNICIPAL WASTE DISCHARGES INTO HOUSTON SHIP CHANNEL AND GALVESTON BAY
SOURCE
Alvin, City of
Bad iff MUD
Baytown - West Main
Baytown - Bayway
Baytown - East District
Bellaire, City of
Cleveland, City of
Conroe, City of
Dayton - Northeast
Plant
Dayton - Southeast
Plant
Friendswood - Plant
No. 1
Galveston - Airport
Galveston - Main Plant
Galveston - Teichman
Galveston Co. WCID #1
Galveston Co. WCID #12
Harris Co. WCID #55
Houston, City of
Northside
Sims Bayou
Chocolate Bayou
Clinton Park Plant
FWSD #23
West District
Southwest
WCID #47
WCID #51
Northwest
FLOW
MGD
1.9
0.25
0.864
0.612
1.1
2.3
0.2
1.9
CONTACT
TIME
MIN
15.7
25.8
44
65
22.8
13.2
67.6
1,9.3
0.2
0.24
52.1
37.4
0.2
0.9
8.5
0.033
0.5
0.23
0.95
65
37
1.5
0.38
1.1
9.0
24.0
1.6
1.5
4.5
10.8
29.8
15.6
100
41.7
8.4
30.6
7.5
0
0
37.4
28.3
15.9
30.7
57.4
20.6
26.0
CHLORINE
RESIDUAL
MG/L
1.1
1.3
3.0+
0.4
1.3
3.0+
0.0
0.9
3.0+
2.8
1.3
1.5
1.?
1.2
3.0+
0
1.2
0
0
0
2.3
1.5
1.0
0.9
2.4
3.0
1.0
COLI FORM (MPN)
TOTAL
28,000
460,000
11,000
460,000
11,000
95
460,000
460,000
1'23
1,100
1,100
23
?2.4 x 106
23
750
46 x 106
24,000
110 x 106
2.4 x 105
11 x 106
1,100
11,000
640,000
90
0
240,000
460,000
FECAL
^2,400
460,000
2,400
460,000
11,000
15
460,000
460,000
£23
460
1,100
4
i2.4 x 106
23
750
24 x 106
24,000
46 x 106
2.4 x 10 6
11 x 106
460
4,000
640,000
90
0
240,000
150,000
REMARKS
Two baffles
No baffles
Air mixing
Clarifier
Air mixing
26 baffles
Out of order
One baffle
Air mixing
Three baffles
Two baffles
Two baffles
Two baffles
One baffle
Clarifier
Out of order
Four baffles
No facilities
No chamber
No baffles
Three baffles
One baffle
One baffle
Three baffles
Three baffles
ro UJ
-------
TABLE IV-1 (Cont'd)
SOURCE
La Marque, City of
League City
Main Plant
Glen Cove
Liberty - Main
- Treetop
Mount Bel view
Montgomery Co.
FWSD #2
New Caney ISO
- Porter Elementary
Pasadena
Northside West 1A
Deepwater
Plant #3
Northside East IB
Saconas, George
South Houston
Stuckey, Doyle
Texas City - Main Plant
- Plant #2
West University
FLOW
MGD
1.5
1.4
CONTACT
TIME
MIN
10.3
0.6
0.105
0.35
0.022
0.079
0.1
0.024
0.014
1.98
1.8
17.8
27.6
36.2
unknown
36.2
672
82
563
242
393
0
1.98
0.03
0.15
0.023
2.6
0.8
1.08
108
6
814
4
65
22
62
CHLORINE
RESIDUAL
MG/L
1.7
3.0+
2.8
1.4
0
0.6
0
0
0
0.5
1.6
COL I FORM
TOTAL
225,000
93
9
110,000
11 x 106
^240,000
240,000
93,000
11 x 106
150
1,500
(MPN)
FECAL
150,000
93
4
110,000
11 x 106
46,000
240,000
93,000
4.6 x 106
150
1,500
2.0
2.1
0.1
0.0
0.5
3.0+
2.8
3.0+
460,000
240
460,000
46 x 106
2.4 x 106
150
15
23
460,000
240
240,000^
46 x 106
2.4 x 106
43
9
23
REMARKS
One baffle
No baffles
One baffle
Out of order
Four baffles
Four baffles
One baffle
Clarifier
Clarifier
Clarifier +
contact
chamber
2 mile 36-in.
line past
sample
point
Clarifier
No baffles
One baffle
One baffle
Ten baffles
13 baffles
Six baffles
N)
NJ
CO
VJ1
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36
23
Houston, Sims Bayou, was known to have no chlorination facilities. The
Texas Water Quality Board, in participating in the development of the
Conference recommendations, agreed that all plants would have adequate
disinfection equipment in operation by December 31, 1971, with the
exception of the City of Houston Sims Bayou plant.
The schedule for completing the new facility at the Sims Bayou
plant along with improvements at other Houston plants, is given in
Board Order 71-0819-1 and the addendum to that Order. Refer to Attach-
ment No. 1
Grab samples were collected and analyzed by Texas Water Quality Board
personnel at 50 major municipal plants in the Conference area. This study
was conducted to determine the reliability of existing chlorination
facilities and the effect of chlorination °n the municipal effluents. The
survey took place from March 27 through March 29, 1972. Only those plants
discharging directly into Galveston Bay or into the Bay's tributaries were
sampled. Sampling and testing were done in accordance with Standard Methods.
The chlorine residual was measured by the orthotolidine method utilizing
the Hach Chlorine Test Kit. Four samples were lost during transnortation
or analysis.
The results of the survey are as follows:
1. Forty-nine of the fifty plants sampled have chlorination facilities.
2. One chlorinator was out of order.
3. The chlorination facility at the Sims Bayou plant, City of Houston,
is under construction and will be in operation by December 31, 1972.
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37
4. The Texas Water Quality Board will continue to enforce regu-
lations for effective disinfection and where disinfection is
found to be ineffective, the problem will be pursued until it
is adequate. In support of the program, the City of Houston
Health Department will expand its bacteriological surveillance
of waters within its territorial jurisdiction. These data will
be forwarded to the Texas Water Quality Board and the City of
Houston sewer department for appropriate action.
B. CENTRALIZATION OF TREATMENT FACILITIES
1. Recommendation
The Texas Water Quality Board will continue to implement its policy
requiring the elimination of small plants. The centralization of
facilities, wherever possible, and the halt of proliferation of small
plants will continue, consistent with existing appropriate procedures.
The implementation schedule for this program, as initiated by the Texas
Water Quality Board, will be made available to the Conferees of the
Galveston Bay Enforcement Conference not later than April 1, 1972.
2. Discussion
This policy calls for the development of regional systems and the
abandonment of outdated facilities where and whenever practical. Appli-
cations for new plants have been denied when the possibility of a tie-in
to an existing system exists. This will continue to be a State-wide
policy of the Texas Water Quality Board.
In accordance with this approach, Board Order 71-0819-1 (Attachment
1 ) requires the City of Houston to abandon a number of obsolete plants
and to divert these wastes to regional and subregional plants. The
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38
25
implementation dates for these diversions are included in Attachment
__]__). Completion dates will fall before December 31, 1974. Firm
commitments for the abandonment of obsolete or unnecessary plants and
for the development of regional plants have been established as a result
of the Clear Lake Board Order, 69-9A. (Attachment 2)
Attachment No. 3 is a tabulation of sewage plants affected by
the proposed Houston-Calveston area regional plan. This plan was pre-
pared for the Houston-Calveston Area Council as a long range concept to
be modified as population growth dictates. The tabulation includes those
plants whose roles in regionalization are firmly established by Board
Order Nos. 69-9A and 71-0819-1.
V
GALVESTON BAY WASTE SOURCE SURVEY
1. Recommendation
The EPA and the Texas Water Quality Board will cooperate in a study
of Galveston Bay. This study is presently being conducted by the
Texas Water Quality Board on all sources of municipal and industrial
wastes permitted by the Texas Water Quality Board to discharge effluent
to Galveston Bay and its tributaries. These examinations shall emphasize
determination of complex organic compounds, heavy metals and other po-
tentially toxic substances, as well as oil and grease, from each waste
source. Recommendations and scheduling of necessary abatement will be
provided to the Conferees as soon as they become available. The Texas
Water Quality Board permits and self-reporting data system will be
amended, as necessary, to reflect the recommendations of this waste
source survey. A progress report on results of this study will be made
-------
39
26
to the Conferees within six months of the date of the reconvened session
of the Galveston Bay Enforcement Conference.
2. Discussion
The joint EPA-Texas Water Quality Board waste source survey commenced
on April 17, 1972. The purpose of the survey is to develop information
on waste constituents other than biochemical oxygen demand such that an
allocation of the constituents among individual waste dischargers con-
sistent with best available treatment practices as detailed in Recom-
mendation 13. It is presently estimated that approximately one-half the
effluent waste flow to the Houston Ship Channel will have been sampled
and analyzed by October 1972. Results of these evaluations will be
provided to the Conferees as soon as they become available.
VI
OIL AND GREASE REMOVAL
1. Recommendation
The Texas Water Quality Board will continue its review of each waste
source discharging to Galveston Bay and its tributaries, and will amend
those permits as necessary to insure that the best reasonable available
treatment is provided relative to discharges of oil and grease. The
Texas Water Quality Board will cooperate with EPA and local" governments
in determining what treatment is the best reasonable available treatment.
It is recognized that improvements in technology will be incorporated
into future permit revisions. A progress report will be made to the
Conferees within six months of the date of the reconvened session of
the Galveston Bay Enforcement Conference.
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27
2. Discussion
The most effective process for the removal of oil and grease from
an aqueous waste is gravity separation followed by biological treatment.
Efficiencies of removal greater than 99 percent can be expected. Re-
moval by gravity separation alone is much less effective.
Based upon a review of the literature, the best reasonable available
treatment for continuous flows of oily waste is gravity separation
followed by aerobic biological treatment. This procedure will normally
produce an effluent containing less than 10 mg/1 of oil and grease as
measured by the Soxhlet extraction method.
The traditional method of treatment of oil and grease wastewaters
from industrial, business, and domestic sources has been gravity separation.
This process gained popularity for a number of reasons, among which are
recovery of valuable product or resource, ease of maintenance, and low
capital and operating costs. However, the efficiency of the process is
limited by the settling velocity of the oil globules and the degree of
emulsification. Although the standard API separator is designed for
15 micron diameter globules, the literature indicates this design will
remove only 84 percent of 120 to 150 micron diameter globules and con-
siderably poorer performance is attained on oil particles smaller than
this.
An improvement on the basic gravity separator which has proven
effective is the installation of parallel plate baffles set at a 45°
angle to the vertical. These may be upflow or downflow baffles or a
combination of both. The principle involved which improves performance
-------
28
is reduction of the required settling distance of the globules. Experi-
mental results on this type unit have demonstrated removal of all globules
larger than 90 microns, 93 percent of 60 to 90 microns and 80 percent of
30 to 60 microns.
Another process which has proven effective in a number of industrial
applications is that of dissolved air floatation. This is fundamentally
a secondary treatment process and should be preceded by a gravity
separation unit to remove the easily separable solids. The process
utilizes the formation of very small air bubbles caused by rapid decom-
pression of the water and dissolution of the dissolved gases in the water.
This process may involve drawing a vacuum on water saturated with air at
atmospheric pressure or, the method commonly used, saturation of the water
with air at several atmospheres pressure with bubble formation occurring
on release to atmospheric pressure. Bubble formation occurs on par-
ticulate surfaces and additional suspended matter may be adsorbed on
the air-water interface as the bubble rises to the surface. Coagulants
may be introduced to the waste stream prior to air floatation to enhance
the efficiency of the process. Reported effluent levels for dissolved
air floatation plus chemical, aids for coagulation are in the range of
5 to 25 mg/1 while those for the floatation process alone are 25 to
100 mg/1.
Other candidate physical-chemical processes are chemical coagulation-
flocculation, filtration, and heating. Although these processes are
generally very effective in oil and grease removal, they are rarely if
ever utilized exclusively for this purpose due to the comparatively high
capital and operating costs.
-------
29
Biological treatment of oily wastes has proven to be an effective
means of treatment under certain conditions. Typically the concen-
trated oily waste streams are pretreated by gravity separation and the
effluent blended with other waste streams prior to biological treatment.
Although investigators have demonstrated biological decomposition of
hydrocarbons by aerobic systems, the primary mechanism of removal in an
activated sludge system is believed to be adsorption of the oil onto
the biological floe and subsequent removal by sedimentation and excess
sludge wasting. However, if the oil loading is excessive, the settling
characteristics of the sludge may be impaired, resulting in solids loss
out of the sedimentation basin and plant upset. The limiting concen-
tration for activated sludge processes is believed to be between 25 and
50 mg/1.
Trickling filters, while not as susceptible to upset, are also con-
centration limited and rely on the same basic principles as activated
sludge for oil removal. The limiting concentration is that which is
sufficient to coat the biological slime on the filter media thereby
blocking oxygen transfer and substrate removal.
The magnitude of the oil and grease waste problem in Texas is indi-
cated by a survey taken by the Texas Water Quality Board in 1971 on the
industries located on the Houston Ship Channel and in the Baytown area.
"Grab" or individual samples were taken from 18 industries comprising
approximately 70 percent of the total oil and grease discharges authorized
by the Texas Water Quality Board. The total computed daily oil and grease
discharge for these 18 industries was 20,200 pounds; extrapolated for the
-------
30
remainder of the authorized discharges, an estimate of 28,800 pounds
per day was derived. The average concentration of the discharges varied
between 16 and 25 ppm oil and grease.
The effects of oil and grease on estuarine systems has been the
subject of a great deal of controversy and investigation in recent years.
The issues were brought into focus by the wreck of the "Torrey Canyon"
off the coast of England and more recently by the spill off the coast
of California at Santa Barbara. Both of these incidents occurred near
heavily populated beaches and resulted in bird and fish kills.
Studies of oily wastes discharges on receiving streams have indi-
cated that a definite sequence of events follow introduction of oil
emulsions into the stream. Oil globules from the emulsions were trapped
in the biological material which agglomerated into a settleable floe and
carried the oil down with it. The settled solids quickly became anaerobic
after deposition during warm weather. The net result was a fairly rapid
physical separation of the emulsified oil from the flowing water. Most
of the oil was stored in sludge banks during low flow conditions.
It has been determined that mineral oil emulsions will degrade
aerobically, at typical summer temperatures with 50 to 80 percent reduc-
tion per week. However, laboratory studies indicate little, if any,
decomposition under anaerobic conditions.
In summary, it appears that gravity separation followed by bio-
logical treatment equivalent to activated sludge affords the best treat-
ment for oily wastes with the least capital investment if a biological
plant is required for other waste streams and the oil concentrations can
be kept to acceptable levels for the biological system. Systems of this
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31
type have been demonstrated to be 99+ percent effective in oil and
grease removal.
Although effluent levels of below 5 ppm oil and grease have been
reported with biological systems, the treatment efficiency fluctuations
of biological systems with varying climate conditions and hydraulic
loadings and the accuracy of the Soxhlet extraction method would indi-
cate that 10 ppm may be a more reasonable goal. It is recommended
that abatement facilities for process wastes containing oil and grease
be installed and maintained such that the effluent will contain the
minimum amount of oil and grease but in no case to exceed 10 ppm.
All new waste control orders for process discharges issued for
industries discharging into the Houston Ship Channel will reflect this oil
and grease policy. Existing waste control orders for process discharges
will be amended to the new level when they are reviewed as the result of
information obtained during the intensive waste source survey.
VII.
WASTE LOAD REDUCTION PROGRAM
1. Recommendation
The ongoing review and amendment by the Texas Water Quality Board
of existing permits recognizes that greater reductions of waste will be
required of waste dischargers to the Galveston Bay system to meet water
quality standards. The Conferees note that in the past three years the
organic waste load being discharged into the Houston Ship Channel has
been lowered from about 430,000 pounds per day of BOD to 103,000 pounds
per day of BOD. Any amendments to existing or new Texas Water Quality Board
waste control orders as a result of this program will prohibit dilution as
a substitute for treatment. A progress report on continuing reduction of
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HOUSTON SHIP CHAN:IEL
B. Q. D. LOADING
500
Measured Load
400
Predicted Load
300
S
w
CO
Q
P..
en
§
5
g
200
100
1968
1969
1970
1971
1972
TIKE
FIGURE Vll-l
1973
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32
waste loads will be provided to the Conferees within six months of the
date of the reconvened session of the Calveston Bay Enforcement Con-
ference.
All waste sources which discharge directly to Galveston Bay and
other tributary areas, including Clear Lake, shall have allowable waste
loads allocated by June 30, 1972, consistent with best available treat-
ment practices. This allocation shall include interim dates for accom-
plishment of required waste treatment and/or waste treatment facilities
which will be in operation by December 31, 1974. The Texas Water Quality
Board will cooperate with EPA and local governments in determining what
treatment is the best reasonable available treatment.
2. Discussion
The major sources of pollution entering Galveston Bay are those
industries and municipalities located along the Houston Ship Channel
and in the Texas City area. Significant reductions of wastes dis-
charging to the Houston Ship Channel have been accomplished since 1968.
Approximately 430,000 pounds of B.O.D. were being discharged daily
into the Channel in 1968. This load had been reduced to approximately
100,000 pounds per day by the summer of 1971. Figure VII-1 represents the
reduction of waste discharges to the Houston Ship Channel with respect
to time. The figure indicates a slight increase in the load for November
and December 1971, reflecting seasonal fluctuations as reflected by the
Texas Water Quality Board self-reporting system.
A further reduction of approximately 6,000 pounds per day is expected
with the projected completion of a communal treatment facility for five
industries on the Channel. This planned facility will treat effluent
-------
TOTAL B. 0.D. CONTRIBUTED BY THE FOUR MAJOR
TEXAS CITY INDUSTRIES
Implementation
Date
Present
Jul> 1, 1973
DJC. 31, 1973
Sept. 1, 1974
July 1, 1976
J 53,970
42,663
13,765
.,765
New Treatment Facility
78,073
i
2
i
•a.
I
4
i
5
I
6
I
7
1
8
T 1
9 10
BOD, Pounds x 104
Union Carbide
Phase I
American Oil
Monsanto
Union Carbide
Phase II
FIGURE VI1-2
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48
33
from Atlantic Richfield Company, Crown Central Petroleum Company, Petro
Tex, Goodyear and U. S. Plywood - Champion Paper Company.
If all planned abatement facilities remain on schedule, B.O.D. dis-
charges to the Hous ton Ship Channel will be reduced to approximately
60,000 pounds per day by December 1973.
Less progress has been made in reducing waste loads from the Texas
City area. Four industries account for most of the B.O.D. discharged
from the area. Table 1 lists the four major industries and their present
discharge.
Table 1
Major Texas City Dischargers
Discharger
Monsanto
Monsanto
Unioji Carbide
Union Carbide
Texas City Refinery
American Oil
TOTAL
Flow (MGD)
56.0
19.5
9.02
0.90
1.34
15.44
BOD5
(ppd)
24,428
2,487
31,144
5,817
290
13,907
78,073
Figure VII-2 illustrates the scheduled implementation of improved
treatment at the four major plants.
VIU
ORGANIC SLUDGE DEPOSITS
DISPOSAL OF DREDGING SPOIL
1. Re commendation
A characterization and evaluation of the water quality significance
of materials from pollution sources contained in the organic sludge
dredged from the Houston Ship Channel shall be conducted. Based on the
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results of this evaluation and examination of present spoil disposal
areas, recommendations will be made by the Texas Water Quality Board
and the Environmental Protection Agency on location of suitable spoil
disposal areas and other appropriate action to minimize or eliminate
deleterious effects on water quality.
2. Discussion
This report summarizes the analytical findings presented in Technical
Report #8 - Estuarine Systems Project, Environmental Engineering Division,
Texas A&M University. The study was funded by the following State and
Federal agencies: Federal Water Pollution Control Administration,
National Science Foundation, Texas Engineering Experiment Station, and
Texas A&M University.
During the Spring of 1970, Texas A&M University conducted extensive
field investigations of the quantity and quality of the benthai deposits
contained in the Houston Ship Channel and its tributary bays. Analyses
conducted on the sludge samples include volatile solids, BOD5, COD, oil
and grease. Samples were obtained from stations located along the entire
channel length and from various points within the channel cross section.
Core samples were also taken in three of the side bays.
Main Channel
Table VIII-1 gives a physical description of the sludge core samples
taken at stations along the channel. The physical characteristics vary
considerably. An interest trend is the increase in deposit thickness
and the visible oil content above mile point 14.
Figure VIII-1 is a volatile solids profile of the deposits. The scatter-
ing of the data points at each station indicates the variation in volatile
-------
200,000
14J
50,000
1200+-00
1000+00
800 f 00
CORPS
600+00
STATIONS
4OO+00
200+00
0+-00
FIGURE VIII-1
VOLATILE SOLIDS PROFILE OF BOTTOM SLUDGES
n
i
-------
TABLE VIII-1 Observations*
51
35
Description of Sludge
Sample Depth of Sludge Core and
Location (mile) Collected in Sampler (ft.) Underlying Material
0
2
3.5
6
8
10
12
16
18
20
22
2k
1.6
No Sludge
1.5
.5
2.5
3.5
3.0
3.5
2.0
3.0
3.0
Grayish Sludge Material
on Red Clay Bottom
Black Sludge, No Under-
lying Material Picked
Up by Sampler
Black Sludge on Gray
Clay Bottom
Gray and Red Clay
Black Sludge on Gravel
and Clay Bottom
Dark Gray Sludge and
Clay Material
Black Sludge on Clay
Bottom
Black Sludge on Bed of
Red Clay
Black, Oily Sludge on
Bottom of Red Clay
Black Sludge on Red
Clay Bottom
Black, Oily Sludge on
Red Clay Bottom
Black Sludge on Red
Clay Bottom
Black Sludge on Red
Clay
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52
36
solids content within a given cross section. The quality variation
within a cross section is verified by analyses of the other parameters.
Figure VIII-2 is a longitudinal profile of the percent volatile solids con-
tained in the sludge. This is a steady increase in the percent vola-
tile solids from Morgan's Point, mile point 0 (8%), to the Turning Basin,
mile point 24 (11%).
Profiles of BOD5 and COD, Figures VIII-3 & VIII-4 indicate a significant
variation in the COD and to a lesser extent the BODj of the benthal
deposits. The COD of the sludge more than doubles above mile point 12.
This finding should be expected because of the heavy concentration of
municipal and industrial discharges above this point. The BOD^ data
shows a similar trend.
A very significant finding is the increase in BOD5 values with in-
creased dilution of the samples. Several dilutions were made for each
BOD analysis. As the percent^ of the sample in the BOD bottle decreased,
i.e., an increase in dilution, the oxygen uptake increased. Not all of
the samples displayed this phenomenon; however, enough did to make the
finding significant. In some analyses, diluting the sample to one-fourth
its initial concentration more than doubled the calculated BOD. The im-
plication is that some of the benthal deposits contain toxic materials
that reduce biological activity.
Figure VIII-5 shows a steady increase in the percent of oil and grease
from Morgan's Point to the Turning Basin. The average oil and grease
content of the sludges appears to be approximately 0.5 percent.
Side Bay Delta
Core samples were taken of the deposits in three side bays tribu-
tary to the Ship Channel. Scott, Burnett, and Upper San Jacinto bays
-------
20
16 14 12 10 8 6
CHANNEL MILES FROM MORGANS POINT
FIGURE VIII-2
VOLATILE SOLIDS (%) PROFILE OF BOTTOM SLUDGES
-------
200,000
I5O.OOO
'•
,n
•-•
00
I
'
8
100,000
50,000
20
18 16 14 12 10 6
CHANNEL MILES FROM MORGANS POINT (TAMU)
FIGURE VIII-3
BOD3 PROFILE OF BOTTOM SLUDGES
o
1 '
-------
200,000
190,000
o
S 100,000
50.0OO
/*
1
24
i
/
' •
,
V
p*
•
/
g
i
r
2
i
a
1
s
ft
'••
y
}*,
}
•
•v
<"
3
s
<>
«
'
•••'••'
»•-
I
•*
'--I
*
1
*•
•••
•
V
:
1
i
••
-
i
.-*
,~
.•
™-
i
>.--
-*•
^
MM,
'
Y
•
-— .
'
-
>'
s/
H
*
-
n
•
-
•i
|
-»
1
m
B
-•
E
^
-•
!
*
!
«—
i
5
~p
-
•1
^
•
-•
r
-f
•MM
CHANNEL MILES FROM MORGANS POINT ( TAMU)
FIGURE VI11-4
COD PROFILE OF BOTTOM SLUDGES
-------
<
p
111
• -
UJ
IT
(9
•
24 22
20 18 16 14 12 10 6 6
CHANNEL MILES FROM MORGANS POINT (TAMU)
FIGURE
OIL AND GREASE PROFILE OF BOTTOM SLUDGES
-------
57
37
were sampled to determine the effect of sludge deposits on the quality
of the waters in the bays. Table 2 lists the BOD^, COD and volatile
solids for a composite sample of the sediments in each bay. Physical
descriptions of the core samples are included in the tabulation. Only
the sample taken from Scott Bay demonstrates a significant BODc. The
r J
ratios between BOD5, COD and volatile solids values found in Scott Bay
to those found at adjacent sampling stations in the Ship Channel are
1:3, 1:2 and 1:2 respectively. The presence of significant levels of
pollutants in the Scott Bay deposits may be due to the location of
Enjay Chemical Company's waste outfall in the bay.
Conclusions
1. The benthal deposits contained in the Houston Ship Channel and its
tributary bays represent an important pollutional source.
The deposits located above mile point 12 are of considerably worse
quality than those below or of those in the side bays. However, the
effect of the side bay sludges on the water quality of those shallow
waters may be very important.
2. The BOD analyses indicate the Channel deposits contain materials
toxic or inhibitory to microorganisms.
Recommendations
Spoil sites should be located where the dredged material is permanently
removed from the Channel and its tributaries. These sites should be
adequately diked and-protected to prevent runoff from the areas.
Representatives of the U. S. Corps of Engineers and the EPA have
proposed the construction of a diked spoil area on Atkinson Island.
As proposed, spoil material will be deposited within the diked area
until the final elevation of the island reaches 12 feet above MSL. The
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38
TABLE VIII-2 -Side Bay Analytical Data Summary'"
Upper San Jacinto Bay
(ppm) (ppm) (ppm) Volatile
Sample BODg COD Volatile Solids Fraction %
Description
C 1,560 25,700 25,150
B
5.7 2'-0" Grey -
Black Material
on Clay Bottom
2'-2" Grey -
Black Material
on Clay Bottom
2'-0H Grey Sandy
Sludge on Sand
Bottom
Burnett Bay
C 1,710 23,080 2U.030
6.0 5'-3" Black Anae-
robic Material,
Lighter Color
at Bottom
3'-5" Black at
Top, Grey Near
Bottom
V-2" Anaerobic
Material Black
at Top Grey
Near Bottom
Scott Bay
C 6,2**0 37,300 29,000
B - -
7.3 V-6" Black at
Top, G.rey Near
Bottom
5'-0" Black at
Top, Grey Near
Bottom
V-5" Black to
Grey With Sand
-------
59
39
ultimate use of the spoil islands has not been decided, but recreation
and wildlife refuge have been mentioned as possible uses. The EPA
representative suggested the Texas Water Quality Board and EPA conduct
a joint productivity study of the area to determine the environmental impact
of the project.
IX
COLOR REMOVAL
1. Recommendation
Chemical constituents causing color in waste effluents, such as
those from pulp and paper mills, shall be reduced to natural background
in area waters as soon as practicable as stated in existing Texas Water
Quality Board waste control orders. A report on feasible processes to
accomplish this recommendation shall be submitted to the Conferees within
six months of the reconvened session of the Calves ton Bay Enforcement
Conference.
2. Discussion
Major contributors of colored waste include paper mills, tanneries,
textile mills, dye manufacturers and electroplating shops (R-8). Of
these, only paper mills are known significant contributors in the geo-
graphical area of interest. The brown color in paper mill effluent is
related to the lignin in the effluent, and lignin resists biological
attack. Only a small part of the BOD of lignin is determined in a five-
day test, but a significant long term BOD is reported (R-l)(R-ll). For
this reason, color in paper mill effluents may be an indicator of oxygen
demand, whereas in most cases it is not.
-------
60
40
Current Operation
Values of current effluent quality for municipal plant discharges
are usually not reported in the literature, but two sources cite colors
of 30 and 75 color units (R-10)(R-4). Activated sludge plants can remove
more than 90 percent of the influent color but trickling filters are less
efficient and primary treatment alone is much less efficient (R-9).
File data on chemical plants records one petrochemical plant effluent
as high as 150 color units (R-15). The State of California considers
150 color units as the maximum value for a "good source of domestic water
supply (R-5). Since (1) the data available on color in municipal and
industrial effluents is sparse, and (2) the data collected reveals
relatively low color values, one can conclude that color is usually
not a problem where wastewater is subjected to good secondary treatment.
By contrast, current effluent quality for paper mills is in the range
of 500-1,000 color units (APHA, Pt-Co), while typical raw blended kraft
effluent itself averages about 2,000 (R-16) (R-14) (R-6). Several pro-
cesses are used to make paper, and the type of process has a significant
bearing on the type of waste discharged (R-17). A limited amount of
test data on paper plant effluents in the Houston Ship Channel area
gives values ranging from 100 to 1080 color units (R-15). Activated
sludge secondary treatment units normally remove about 10-15 percent
of the color in these effluents, and this unit process is frequently
used to treat paper mill discharges (R-17). The relative inefficiency
of biological processes in terms of color removal accounts for the high
color remaining in the effluents.
Best Practice
Treatment of municipal waste with activated carbon can reduce the
color from 30 to 3 units, where it is most likely a candidate for reuse
(R-10). Ion exchanging can reduce kraft paper mill bleaching waste from
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61
1500 to 200 Pt-Co units (R-12). Pilot plant data on "massive" lime
treatment processes indicate that greater than 90 percent of the color
can be removed from raw bleached kraft effluent. A color of 200-400
units could be expected. Carbon columns following in series with lime
treatment can further reduce color to less than 30 units. Costs for
these treatment steps are relatively high (R-16) (R-3) (R-14).
Background Color in Calveston Bay and Tributaries
On April 17, 1972 a survey was conducted to determine the background
color of the Houston Ship Channel, Upper Calveston Bay, and the tribu-
tary streams within the estuarine system. Surface to bottom composite
samples were collected at each site with the analyses being made by the
EPA lab in Houston. All sampling and analyzing procedures were per-
formed according to Standard Methods. The attached table includes the
location and color value for each sample. (Table IX-])
Three samples were obtained in the Houston Ship Channel. The first
sample was taken at the confluence of Sim's Bayou and the Channel,
above the Champion Paper discharge. The next was taken at Green's
Bayou below the Champion discharge. The influence of the Champion
discharge (160 APHA units) is apparent. The remaining sample taken at
the Monument shows the influence of the Southland Paper discharge
(180 APHA units). The average color for Ship Channel water was 42 APHA
units for this particular day.
The average color content of the waters in the side bays is 72
units, slightly higher than the Channel. This increase is expected due
to the relatively large land - water contact area found in the shallow
side bays.
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62
42
TABLE IX-1
BACKGROUND COLOR SURVEY -
UPPER GALVESTON BAT AND TRIBUTARIES
Apparent
Sample Location or Description Color Units (APHA, Pt-Co)
Houston Ship Channel at Sims' Bayou 30
Champion Paper Effluent Plume 160
Houston Ship Channel at Green's Bayou 46
Southland Paper Effluent Plume 180
Houston Ship Channel at Monument 50
San Jacinto River at IH-10 70
Burnett Bay 100
Scott Bay 65
Tabbs Bay 55
Upper Galveston Bay at Barbour's Cut Channel 65
Trinity Bay between Umbrella Point & Smith Point 48
Galveston Bay between Smith Point & Eagle Point 39
Galveston Bay at Ship Channel Marker #65 33
Galveston Bay at Morgan's Point 44
Cedar Bayou at IH-10 47
Green's Bayou at IH-10 60
Buffalo Bayou at N. Main St. Bridge 32
Bray's Bayou at IH-45 42
Hunting Bayou at IH-10 40
Sims' Bayou at State Highway 225 80
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63
Samples taken in Upper Galveston Bay show an average color of 46 units.
The average color found in the streams tributary to the Houston Ship
Channel was 50 APHA units. The decrease in color of the Channel water
from that found in its tributaries is probably due to dilution by the
relatively colorless municipal effluents and the underflow of bay water.
Conclusions
The background color in natural waters is a highly variable quality
parameter. The color of unpolluted water can vary from clear to almost
black. Color is an aesthetic problem; the extent of the problem is
determined by the individual observer.
The color from most municipal and industrial effluents is minimal.
The color in paper mill effluent is contributed by tannins and lignins
which are found in most naturally colored waters. These compounds
represent an oxygen demand in the stream; however, the biological reaction
rate is so slow that the stream oxygen resource is not appreciably affected.
The very low reaction rate also makes color removal by biological treat-
ment impractical. Physical-chemical methods for removal of color from
paper mill wastes are technically possible but are economically pro-
hibitive at this time.
The background color of the tributary waters of the Galveston Bay
system is higher than that found in the Ship Channel. This is true even
after the discharge of colored effluents from two large paper mills. The
difference between the maximum color found in the Ship Channel and that
in Upper Galveston Bay is statistically insignificant.
Recommendations
In an estuarine system such as Galveston Bay, the increase in color
contributed by waste discharges is small. Requiring extensive color
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44
IX. COLOR REMOVAL
REFERENCES
(R-l) Bloodgood, D. E. and Klaggar, A. S. "Decolorizing of Semi-chemical
Bleaching Wastes". Proceedings of 16th Industrial Waste Conference,
Purdue University Engineering Extension Series, Bulletin No. 109,
1961, p. 351.
(R-2) Ford, Davis L., Personal communication, March 24, 1972.
(R-3) Herbet, A.J. and Berger, H.F., "A Kraft Bleach Waste Color Reduction
Process Integrated with the Recovery System". Proceedings of 15th
Industrial Waste Conference, Purdue University, May, 1954, p. 465.
(R-4) Lindstedt, K.D., Bennett, E.R. and Work, S.W., "Quality Considerations
in Successive Water Use", J. of WPCF, V. 43, No. 8, August, 1971,
p. 1681.
(R-5) McKee, J.E. and Wolf, H.W. eds., Water Quality Criteria, The
Resources Agency of California, State Water Quality Control Board,
Publication No. 3A, 1963.
(R-6) Moggio, W.A., "Color Removal from Kraft Paper Waste", Proceedings
of 9th Industrial Waste Conference, Purdue University, May, 1954,
p. 465.
(R-7) Murphy, N.F. and Gregory, D.R., "Removal of Color from Sulfate
Pulp Wash Liquors), Proceedings of 19th Industrial Waste Conference,
Purdue University, May, 1964, p. 59.
(R-8) Nemerow, Nelson L., "Color and Methods for Color Removal",
Proceedings of llth Industrial Waste Conference, Purdue University,
May, 1956, p. 584.
(R-9) Nemerow, N.L. and Doby, T.A., "Color Removal in Waste Water
Treatment Plants", Sewage Ind. Wastes 30, 1958, p. 1160.
(R-10) Parkhurst, J.D., Dryden, F.D., McDermott, G.N., English, John,
"Pomona Activated Carbon Pilot Plant", J. of WPCF, V. 39, No. 10,
Oct., 1967, p. R 70.
(R-ll) Raabe, E.W., "Biochemical Oxygen Demand and Degradation of Lignin
in Natural Waters", J. of WPCF, V. 40, No. 5, May, 1968, P. R145.
(R-12) Rohm and Haas Company Technical Brochure, "Decolorization of Kraft
Pulp Bleaching Effluents Using Amberlite XAD-8 Polymeric Adsorbent",
Rohm and Haas, August, 1971, p. 3.
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65
45
(R-13) Small wood, C., Jr. and Fortune, D.L., "The Measurement of Color
Pollution in Streams", Proceedings of 14th Industrial Waste
Conference, Purdue University, May 1959, p. 509.
(R-14) Smith, Donald R. and Berger, Herbert F., "A Chemical-Physical
Wastewater Renovation Process for Kraft Pulp and Paper Wastes",
J. of WPCF, V. 40, No. 9, Sept., 1968, p. 1575.
(R-15) Texas Water Quality Board Files
(R-16) Thibodeauz, L.J., Smith, D.R. and Berger, H.F., "Wastewater
Renovation Possibilities in the Pulp and Paper Industry", Chemical
Engineering Progress Symposium Series 90, V. 64, 1968, p. 178.
(R-17) U.S. Department of the Interior, FWPCA, The Cost of Clean Water,
Volume III. Industrial Waste Profiles No. 3 - Paper Mills, U.S.
Government Printing Office, Washington, D.C., 1967.
(R-18) Wakeley, J.H. and Nemerow, N.L., "Measurement of Objectionable
Stream Colors Resulting from Wastes", Proceedings of 13th Industrial
Waste Conference, Purdue University, May, 1958, p. 465.
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66
removal in waste effluents using today's technology, will greatly in-
crease treatment costs while resulting in an insignificant improvement
in the Bay. The Texas Water Quality Board will require color reduction
when technology becomes feasible as specified by existing waste control
orders.
X
BOD ALLOCATIONS TO HOUSTON SHIP CHANNEL
1. Recommendation
To meet present official State-Federal water quality standards
established for dissolved oxygen in the Houston Ship Channel, it is
expected that the maximum waste load discharged from all sources will be
about 35,000 pounds per day of five-day BOD, including projected future
development. The Texas Water Quality Board, in cooperation with technical
personnel of the EPA, shall review existing waste discharge orders with
the objective of allocating allowable five-day BOD waste loads for sources
discharging to the Houston Ship Channel such that the probable 35,000
pounds per day maximum shall not be exceeded. A report will be made to the
Conferees on the results of this review by April 1, 1972. The allocation
for each waste source as determined by the Texas Water Quality Board,- in
cooperation with the EPA, shall be attained by December 31, 1974. Interim
dates to determine progress toward compliance of the assigned allocation
shall be established for each waste source by May 1, 1972.
The Conferees also recognize that discharge of other waste con-
stituents such as, but not limited to, chemical oxygen demand, suspended
solids, complex organics, and other toxic materials also contribute to the
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67
pollution of Galveston Bay and its tributaries. An allocation of allowable
waste discharges for these pertinent parameters from each waste source will
be established by technical personnel of the Texas Water Quality Board and
the EPA consistent with best available treatment practices and such
allocation will be reported to the Conferees by September 1, 1972.
The Conferees recognize that technical considerations may require
a reassessment of this schedule in the case of some of the municipal and
industrial waste sources to be considered. These necessary reassessments
will be determined by technical personnel of the Texas Water Quality Board
and the EPA, and recommendations concerning schedule changes will be made
to the Conferees at six month intervals.
The foregoing recommendations shall not be construed as in any way
foreclosing or interfering with Federal, State or local statutory pro-
ceedings relating to the authorization, amendment, or revocation of Federal
or State waste discharge permits or orders, nor shall such recommendations
operate to delay or prevent the creation or operation of regional waste
disposal systems such as the contemplated Gulf Coast Waste Disposal
Authority.
2. Discussion
A program was undertaken in December 1971 to allocate all permitted
BOD discharges into the Houston Ship Channel such that the total load
would not exceed 35,000 pounds per day. In developing the BOD allotment,
no technical conferences were conducted with the affected entities. The
reductions were generally balanced between industrial and municipal dis-
charges. To meet the d-lowable limits set on BOD and other pollution
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68
48
parameters; advanced treatment is necessary. The proposed allocation
made no allowance for future growth in the area.
Public hearings were held on February 7 and 8, 1972, in Baytown to
discuss the revised requirements for municipal effluent. Similar hearings
were held on February 9, 10 and 11 to discuss the proposed industrial
effluent criteria. The public hearing notices, allocations and related
documents are contained in Attachment 4, and Table X-l.
It is acknowledged that the BOD allocation did not take into account
the record of progress towards abatement by many of the sources or
potential growth in the area and is based upon an equal treatment level
for all sources regardless of present abatement practices. The hearings
were scheduled in the afternoons and evenings to provide the opportunity
for all interested parties to participate. The majority of testimony,
however, was offered by the municipal and industrial sources to which these
allocations apply. Very little general public participation was manifest.
The overwhelming impact of the testimony offered was that the allo-
cations proposed were technologically impractical and economically
unfeasible.
As a result of these hearings, Texas Water Quality Board has decided
to pursue a program of abatement consistent with the requirements of best
practicable control technology currently available as determined by the
Texas Water Quality Board and the Environmental Protection Agency. Under
this program, waste discharges to the Houston Ship Channel from both
municipal and industrial sources will be reduced to less than 60,000
pounds per day by December 1973. During this period, consultations will
be held between the Texas Water Quality Board and the Environmental
-------
TABLE X-l
B.O.D. ALLOCATIONS TO HOUSTON SHIP CHANNEL
Industrial Discharges
Naao
Anchor Hocking Glass Corp.
Armco Steel Corporation
WCO #
Ashland Chemical Company
Atlantic Richfield
PAGE 1
Permitted Discharge (Avg.) Present Discharge (Avg.)
Flow BOD BOD Flow BOD
Page MGD mg/i Ibs/day MGD Ibg/day
Propoisd Discharge (Avg.)
Flow BOD BOD
MGD rog/1• Ibs/day
01170
00509
01
01
02
04
5 & 6
07
08
91
92
10
0.028
0.72
no reg.
no reg.
4.80
no reg .
no reg .
35.00
0.72
2.60
20 < 10
10 60
25 1001
11
100
100 217
0.062
0.77
no discharge
no discharge
3.47
no discharge
no discharge
16.00
0.48
no discharge
82
32
58
100% Cool-
ing water
16
no
0.028
0.72
*
*
3.47
*
*•
35.00
0.48
discharge
10
10
10
no net
increase
13
< 10
60
290
52
allowed
00549
00392
11
12
13
14
IS
16
01
01
2.60
no reg.
no reg.
no reg.
1.08
no reg.
1.33
no reg.
100 217
25
50 575
1.50
no discharge
no discharge
no discharge
1.26
no discharge
0.60
0.98
2888
21
200
427
injection
*
#
*
1.08
*
0.60
*
or incineration
10
20
90
100
Process waste to
separated
& added
to # 2 outfall
02
03
04
05
06
7.50
no reg .
no reg.
no reg.
0.36
100 6255
no reg.
4.80
0.029
0.08
1.57
0.23
3681
<1
7
681
12
4.8
*
*
1.57
0.23
20
20
10
800
262
20
LO
cr\
-------
TABLE X-l (Cont.)
Industrial DiaeharoM
Nwn« WCO #
Celancse Plastic Company
Charter International Oil
Chemical Exchange Processing Co, 00786
Cook Paint & Varnish Company
Crown Central Petroleum
Diamond Shamrock Corporation
E. I. DuPont de Nemour & Co.
Enjay Chemical Company
Ethyl Corporation
Page
PAGE
Permitted Discharge (Avg.)
Flow BOD BOD
MOD rog/1 Ibs/day
Present Discharge (Avg.)
Flow BOD
MOD Ibs/day
00544
00535
00786
00427
00574
00749
00305
00474
00610
00492
01
01
02
01
01
01
02
03
01
01
02
03
04
05
06
01
01
01
02
0.425
2.16
0.72
0.144
0.08
4.00
O.Q6
0.39
3.80
98.00
42.00
0.65
4.80
3.0
8.00
0.20
3.68
4.75
15
50
50
100
no reg.
125
125
no reg.
100
20
20
50
30
20
no reg.
50
90
220
no reg.
53
900
300
120
4,170
897
325
634
16, 346
17,514
163
801
3,336
150
6,752
0.37
1.45
0.03
0.025
0.25
2.14
0.50
no discharge
0.11
2.90
89.40
28.88
0.003
2.44
no discharge
7.00
0.14
3.32
4.919
12
1,512
<1
11
95
2,490
261
45
17
373
193
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TABLE X-l (Cont.)
Industrial Diacharqes
Nam* HCOtt
Goodyear Tire & Rubber Co. 00520
Heaa Terminals 00671
Houston Lighting & Power 01031
Hughes Tool Company 01046
Humble Oil & Refining 00592
Ideal Cement Company 00456
Lubrizol Corporation 00639
Olin Corporation 00649
Pennwalt Chemical Corporation 00445
Petroleum & Mining Division 00635
Petro Tex Chemical Corporation 00587
Phillips Petroleum Company
Premier Petrochemical
Rnichold Chemical Inc.
Rohm end Haas
OOS15
00975
01061
01045
00662
00458
Paga
PAGE 3
Permitted Discharge (Avg.)
Flow BOD BOD
MOD rog/1 Ibs/day
Present Discharge (Avg.) Proposed Discharge (Avg.)
Flow BOD Plow BOD BOD
MGD Ibs/day MGD mg/1 lbs/d«
01
02
01
01
1.650
2.50
0.108
1.12
40
60
100
10
550
1,251
90
93
1.470
2.48
0.057
0.79
131
331
19
132
1.47
2.48
0.057
1.12 no
10
13
20
net
122
269
<10
increase
01
02
03
04
05
01
02
01
02
03
01
02
01
02
03
04
05
06
01
01
01
02
03
02
03
01
01
01
01
01
02
03-
0.104
0.092
0.207
0.587
0.090
no reg.
25.00
0.50
0.075
0.030
1.00
no reg.
12.700
1.490
7.050
0.034
0.450
to be
assigned
0.20
0.72
1.00
6.25
0.90
1.900
5.000
0.100
0.090
0.15
0.02
1.728
0.072
Baual to
20
20
10
15
no reg.
50
30
30
20
100
no reg.
no rrg.
no reg.
20
no reg.
no rr.g.
50
60
25
100
35
50
no reg.
2
2
100
100
100
BO
or b*tl:e>r
18
15
17
73
no reg.
10,425
125
19
5
834
<10
83
361
209
5,212
263
792
<10
<10
125
17
1,441
48
than Zone
0.104
0.092
0.207
0.50
0.090
no discharge
19.35
0.40
no discharge
no discharge
0.72
12.112
no discharge
2.744
no discharge
5.459
0.168
0.10
1.19
0.98
4.66
0.42
2.443
no report
0.178
0.125
0.17
0.045
2.60
0.13
II Roar 'a
<10
<10
<10
103
<10
3,228
26
155
23
64
29
3,134
83
115
<10
<10
181
375
8,542
146
0.104
0.092
0.207
0.50
*
*
19.35
0.40
no discharge
no discharge
0.72
*
12.112
1.490
2.744
0.034
0.450
0.10
0.72
1.00
4.66
0.42
1.900
*
0.100
0.090
0.15
0.02
1.728
0.072
10
10
10
13
13
13
20
10
20
13
10
20
20
5
2
2
20
20
20
20
<10
<10
17
54
2,098
43
120
<10
17
78
84
777
70
79
<10
<10
25
3
268
12
-------
TABLE X-l (Cont.)
IndUBtrir».l Dificharereg
Naae
Shell Chemical Cor.pany
Shell Oil Company
PAG2 4
Permitted Discharge (Avg.)
Flow BOD BOD
'present Discharge (Avg.) Proposed Discharge. (Avg.)
l-'low BOD Plow BOD BOD
Sinclair Xoppors Cheraieal Co.
Sinclair Petro-V r.iical Co.
Smith A. O. Cor;,- ration
SKS Industries, Ir.c.
Southland Papar Mills
Stauffer Chemical Company
Stav.ffcr Chemical Company
Tcnnoco Ch.etiical," Inc.
Texna In.V-ruinenti:
Union S^ruity Cooporati/e
rxchirarjo
Upjohn Company, Tho
Vnitcel States cypuvn Co.
U.S. .Industrial Ch'-v. i~;il
V,'.',.. rlv, ;od
.ator runncff only.
WCOtt
00402
00403
oo:.?3
oo 3'i'i
00^72
Olr"">2
Ol.V'.O
00541
00542
00002
01225
01205
00663
00353
00534
00640
Page
01
02
01
02
03
04
05
06
07
08
09
10
11
12
01
01
01
01
01
01
02
01
01
01
01.
01
01
03
01
02
01
02
03
MGD
6.10
no reg.
1.44
0.288
0.144
0.'576
no reg.
0.086
0.216
no reg.
'0.266
4.752
no reg.
2.664
0.55
2.66
0.850
0.115
50.00
1.13
0.045
l.CO
1.00
0.644
0.0015
0.58
0.50
0.0200
0.90
0.43
44.00
no rcy.
no reg.
mg/1
100
10
30
20
10
10
20
15
30
5,087
120
72
24
48
7
,33
1,189
MGD
5.79
1.47
ro discharge
0.044
0.72
0.062
0.049
0.178
4.47
Iba/day
1,076
49
4
36
2
6
11
671
MGD m
6.10
*
1.44
no discharge
0.044
0.58
*
0.086
0.05
*
0.178
4.47
g/1 ID:
13
10
13
10
10
13
13
13
runoff from dredging
50
100
50
50
50
100
20
20
20
100
20
16
150
100
3
25
40
50
1,109
459
1,109
354
48
41,700
108
8
167
834
107
/aaj
661
120
5
48
8
5
19
485
ope]
60
92
314
22
<10
,339
67
<10
108
112
36
<1
97
30
98
23
,109
—J
ro N>
-------
73
53
Protection Agency with individual waste discharges to determine specific
waste load allocations and implementation dates by these sources for
meeting the Fe'deral-State water quality standards for the Houston Ship
Channel. The -present program of limiting effluents to 60,000 pounds per
day is an interim step and is not expected to meet presently approved
State-Federal water quality standards in the Houston Ship Channel nor
the Conferees' Recommendation Number 13. This program of reduction of
wastes to less than 60,000 pounds per day of five-day BOD will represent
a reduction of greater than 85 percent from vaste loads discharging to
the Houston Ship Channel during 1968.
-------
ATTACHMENT NO. 1
TEXAS WATER QUALITY BOARD
ORDER NO. 71-0819-1
AND
ADDENDUM
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Al-l
TEXAS WATER QUALITY BOA^D
P. O. Box 13246
Capitol Station
Austin, Texas "/G711
ORDER HO. 71-0819-1
AN ORDER of the Texas V7eitcr Quality Board ordering and
establishing dates for the completion of certain
improvement projects and studies pertaining to
the sewerage- facilities owned by the City of
Houston.
PREAMBLE
In order to acrure that the effluents being released by the City of
Houston, Texas, from its several sewage treatment plants are brought in
an orderly and timely fashion into compliance with applicable waste con-
trol orders issued by the Texas Water Quality Board and to abate the
present pollution of waters within arid adjoining the City of Houston, the
Texas VJater Quality Board has ordered the City of Houston to undertake
a sanitary sewerage system improvement program.
The purpose of this order is to clearly set forth some portions of
the improvement program which the Texas Water Quality Board has directed
the City of Houston to complete and the timetable for the completion of
various phases or portions of this program.
The completion dates shown in this order are considered by the Board
to be reasonable and proper, and were determined after due consideration
had been given to the dates contained, in the City of Houston's Waste
Treatment Progress Report of August 19, 1971, during a public hearing held
by the Board on August 19, 1971.
It is the intent of the Texas VJater Quality Board that the City p.dher
to the dates established and unless tho particular phase or portion or the
improvement program cue for completion is completed on or before the re-
quired date, or unJesr the City has requested r:id the Board approved for
acceptable reason or reasons ar. extension of tho improvement program; the
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Al-2
Board herein places the City of Houston on notice that it intends to seek
such relief as may be indicated in the courts. Kow, therefore,
BE IT ORD;:i£D DY TI2J TEXAS WATER QUALITY BOARD:
I. DEFINITIONS FOR THIS ORDER:
A. "Board" means the Texas Water Quality Board.
B. "City" means the City of Houston, Texas.
C. "Executive Director" means the Executive Director of the
Texas Water Quality Board.
D. "Staff" means the staff of the Texas Water Quality Board.
II. Report Regarding Project Completion Dates
A report outlining completion dates for the following projects will
be submitted to the Board on or before December 1, 1971:
(a) abandonment of the unpermitted plant at Western Acres and
the sewage treatment plants outlined on pages 8, 14, 21, 22, 25,
41, 45, 46, 47, 49, 55, 58 of the City's Waste Control Order
flo. 10495, (b) the enlargement of sewage handling facilities at
sewage treatment plants covered by pages 15, 16, 30, 43, 44, 65,
and 69 of the City's Waste Control Order No. 10495, (c) provide
sludge handling and chlorination facilities at the Sims Bayou
sewage treatment plant, (d) provide treatment for the waste from
the water treatment plant covered by page 68 of the City's Waste
Control Order No. 10495. After review and concurrence with these
completion dates by the Board, they will becone part of this
Board Order.
III. Bacteriological Study
In order to determine the efficacy, or lack thereof, of the sanitary
sewerage system in abating the bacteriological pollution of the
various drainageways within the City, and to identify the sourca
or sources of excessive bacterial pollution; the City Water Pollution
-2-
76
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77
Al-3
Control Division of the City Health Department is directed to con-
tinue and expand its bacteriological water quality sampling proorar.u
The sampling points shall be located so as to determine tha imp"u:t
of the varioxis treated effluent discharges and known recurring
overflows, zjud in cooperation with the Texas Water Quality Board's
District 7 staff. The data generated by this program shall be
forwarded at appropriate regular intervals to the Texas Water
Quality Board and appropriate persons in the City Administration,
including the Sewer Department.
IV. Report Regarding Chlorination and Suspended Solids
A report outlining (a) the reason or reasons for the lapses in
chlorination at the various plants and programmed corrective
action, and (b) the capability of the various permanent sewage
treatment plants as identified in the City's progress report of
August 19, 1971, to comply with suspended solids requirements
when fully loaded will be submitted to the Board on or before
March 1, 1972.
V. Overflow of Raw Sewage, McGregor Park
The City is directed to take positive action to expedite the
project to eliminate the recurring overflow of raw sewage into
Brays Bayou adjacent to McGregor Park. A report on the action
taken will be submitted on or before March 1, 1972.
VI. Correction of Existing Inadequate Conditions
The City is directed to take immediate action to correct the follow-
ing conditions (the page numbers refer to Waste Control Order No. 10495}
(1) no flow recorder—Chocolate Bayou plant, p. 9.
(2) inadequate flow measuring device—F.W.S.D. 17, p. 15.
(3) industrial waste problem—F.W.S.D. 17, p. 15.
(4) improperly handled screening—F.W.S.D. 17, p. 15.
(5) no sludge disposal facilities—New Homestead plant, p. 23.
(6) no flow measuring device—Easthaven, p. 65.
(7) inoperative flow recorder—F.W.S.D. 34, p. 69.
(8) inoperative sludge collector and mechanical aerator—W.C.I.D.
44-1, p. 47.
(9) bypass from aeration tank—Airport, p. 78.
-3-
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Al-4 78
A report on the corrections accomplished will be submitted on or
before March 1, 1372.
VII • Apply for VJaste Control Orders
The City is directed to file with the Texas Water Quality Board
appropriate applications or other documents and to take such
4-
other actions as may be appropriate to secure valid waste control
orders for the sewage treatment facilities listed below. To
facilitate the securement of such waste control orders, the City
shall consult with the Hearings and Enforcement Division of the
Texas Water Quality Board by November 1, 1971 on the documents
required and shall submit in an expeditious manner such documents
as may be determined.
Expire Page Name Expiration Date
8 Chatwood Place 12-31-60
14 Fontaine Place 12-31-66
15 F.W.S.D. 17 6-30-67
21 Gulf Palms 12-31-68
22 Gulfway Terrace 12-31-63
25 Lake Forest 12-31-6S
29 longwoods 6-30-67
44 W.C.I.D. 34 12-31-68
45 W.C.I.D. 39 12-31-66
46 W.C.I.D. 42 12-31-65
47 W.C.I.D. 44-1 12-31-6S
49 W.C.I.D. 44-3 12-31-68
— Western Acres —
W.C.I.D. 82
VIII. Sludge Disposal Facilities
The City is directed to submit by Decerier 1, 1971 a report on an
analysis of the adequacy and reliability of the sludge disposal
facilities at the Northside and Sims Bayou plants. The report
should outline- alternates available to rectify deficiencies found,
if any.
IX. Infiltration Abatement Program
The City is directed to continue and complete its existing infil-
tration study and abatement program as set forth in the report
dated Kovenibar 16, 1970. Further, the City is directed to submit
by May 1 each year a report on the progress made.
-4-
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79
Al-5
X. Funding Sanitary Scv.'orarje System
Tlio City is directed to provide the funding necessary to effectuate
the recommendations enumaj.fitcd in this Board Order.
XI. Long-Range Sr.nltary Sewcraye Planning
The City is directed to keep its long-range sanitary sewerage
plan current.
With respect to implementing the long-range plan, the City is
directed to exercise the provisions of extraterritorial legis-
lation to accomplish the following:
(1) Insure that alterations which may from time to time be required
in the long-range plans of the City and the Houston-Galveston Area
Council are fully coordinated in such a manner that the plans
remain compatible.
(2) Insure that proposed sanitary sewerage facilities or modifi-
cations to such facilities within the extraterritorial jurisdiction
area are compatible with the City's long-range plan.
(3) Insure that the design and construction of facilities within
the extraterritorial jurisdiction area conform with the minimum
requirements of the City.
In the City's comments on applications to the Texas Water Quality
Board for waste control orders, the City will furnish to the Board:
(1) an analysis showing that the sanitary sewerage facilities
proposed are compatible with the regional plan, (2) the City's
approval or rejection of the plans and specifications, including
arrangements made for construction inspection, for such facilities,
and (3) the City's approval of the plumbing code to be required
in the area served by the particular entity involved.
XII. EXTENSION OR WAIVER: If at any time it becomes evident to the City
that difficulty will be experienced in complying with the completion
dates enumerated in this order, the City shall immediately request
-5-
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A] -6
80
by letter addressed to the Board's Austin Office to be placed on
the next Board Meeting agenda to rcquc.sU that the completion di-rlo
or dates be extended or waived. The City shall, upon notification
that they have been placed on the agenda, have a representative
or representatives attend the Board Meeting to presc. t their
reason, or reasons for requesting an extension or waiver. The
Board will, upon considering the data or evidence presented,
Determine the acceptability of the reasons, £r.d notify the City
in vnriting that the request for an extension or v/aiver as the
case may bo is granted or denied.
XIII. EFFECTIVE DATE: This order is effective immediately upon its
adoption by the Board.
XIV. NOTIFICATION PROVISION; The Executive Director is directed to
send a copy of this order to the City of Houston, Texas.
XV. SEVERANCE CIAUSE: If any provision, sentence, clause, or phrase
Of this order is for any reason held to be invalid, such invalid
portion shall not affect the validity of the remaining portions
of this order. The Board hereby declares that it vrould have
passed the valid portions of this order irrespective of the fact
that any one or more portions be declared invalid.
Passed and approved this 19th day of August, 1971
Xllugh 'C.
/
is, .Jr., Executive Diructorv
/"
TEXAS V3TER QUALITY BOARD
jkvTW^'
CHAIRMAN
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A,-7 8l
ADDENDUM TO BOARD ORDER NO. 71-0819-1
Article II of this order requires the City of Houston to
submit to the Texas Water Quality Board a report containing
completion dates for a number of projects. This report
has been received and reviewed by the Board. The Board
concurs with the completion dates, which are shown on the
following pages, and hereby incorporates them as require-
ments of this order.
Passed and approved this day of , 1972.
TEXAS WATER QUALITY BOARD
GORDON FULCHER, CHAIRMAN
(Seal)
ATTEST:
Hugh C. Yantis, Jr., Executive Director
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82
ADDENDUM TO BOARD ORDER 71-0819-1
Page
8
25
14
45
46
21
22
20
47
49
15
16
30
43
44
65
69
68
68
Name
Western Acres
Chatwood Place
Lake Forrest
Fontaine Place
WCID #39
WCID #42
Gulf Palms
Gulf way Terrace
WCID #20
WCID #44-1
WCID #44-3
FWSD #17
FWSD #23
West District
WCID #32
WCID #34
Easthaven
FWSD #34
Sims Bayou
Sims Bayou
Water Treatment
Plant
Completion
Action Date
Abandon 03-11-72
Abandon 12-15-72
Abandon 12-15-72
Abandon 08-15-73
Abandon 08-15-73
Abandon 08-15-73
Abandon 06-01-74
Abandon 06-01-74
Abandon 12-31-74
Abandon 04-30-73
Abandon 04-30-73
Enlarge 06-30-73
Enlarge 12-01-72
Enlarge 04-30-73
Enlarge or Abandon 12-31-74
Abandon 12-31-74
;
Enlarge 07-01-74
Enlarge 12-31-72
Chlorination 12-31-72
Provide Sludge Facilities 12-31-72
Provide Treatment 12-30-74
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83
ATTACHMENT NO. 2
TEXAS WATER QUALITY BOARD
ORDER NO. 69-9A
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84
13 Oy Lavaca Street
Anatin, '.Texas VSJ701
ORDSU. .KO, C
AW ORUEH of the Voxels Wfttcr Quality Bowd determining
that the region?.! plan, contemplated in Texas
Miifccr Quality Board Crdcr Ho. G.9-2, has fciled
to Materialize within r. reasonable tir.se period;
further determining that the ira.Tie.di*'.tc ireplo-
mentc'ttion of the Puvanccd vcvstc trcatr-.ent and
other roquij:cr.ie«ts contained in Section 3-
(ptcjeo f. and 5) of that Crdcr is ncccsstiry to
prer.orvc <<.ncl Kniutain the quality of v/ate-r in
Clear L«"/.c and to prevent the continued pol-
lution Oj" the lal:c-; ordering all dischargers
of domestic Wcistewaters vdthin the Clear Lc.l;e
Watershed to co.T.ply with the aforeraantiontd
requirements within such period of tir^c as is
rcftsoncMy required but not to exceed two (2)
years from the dato of the adoption of tV.s
Order; ordering that these requirements be
made a part of the waste control orders (permits)
held by these waste dischargers; and establish-
ing a procfrcCr.i for compliance with these require-
ments.
W1EHE?>S, under the provisions of Texas Water Quality Board
Order Ko. 69-S, the Board announced:
"That in the event that the plan for the protection of Clea::
Lake, contemplated in this Order, fails to materialize vithiii
reasonable time limitations, the Board will, of necessity, be
compelled to consider and seelc more stringent permit require-
ments for each waste discharger in the watershed. These
requirements will be determined on a cace-by-case basis bot
generally vould include the following quality paransters:
" (a) Five day biochemical oxycjan demand and total suspended
solids not to exceed 12 ng/1.
" (b) Chlorir.o residual of 2 tag/1 after one hour detention
tine ancl as measured by the orthotolodine tost or other
accepr«-;blc test.
"(c) Nutrients in the effluent will i»a removed as follovs;
Nitrogen sh.ill not be regulated and phosphorous, in
-------
85
A2-2
any fori.i, ::h:dl not c-.-xx-c-d 1.0 i.'.^/J..
" (d) A fully trained and c-o.vtif icd operator will be- avail--
able to the plant at nil tinier a»Jd a satisfactory
operation and maintenance program wj 11 be required.
" (c) Mach discharge will be adequately nsonitored t.o insure
permit compliance and detect inadequacies of operation.
Laboratory services will be made available, by eontrr.et
or otherwise, to the end that a sanpling and analyticitl
program is established to monitor effluent quality on
a continuing, basis. "
VJHEREAS, the Board, upon full evaluation of the progress made
in achieving the rcgionalixation of sewerage services in the Clear
Lake area, finds that, in passage of one year from the date of the
adoption of Order 69-9, the planning and the initiation of the con-
struction of the regional waste collection, treatment and disposal
system contemplated in that Order has not been successfully accom-
plished-.
YJHEREAS, the Board finds that the continued discharge of
wastevators at the presently ciuthorized levels of treatment is caus-
ing and will continue to cause the water quality degradation of
Clear Lake and jeopardize its further utility as a recreational body
Of water; and
WHEREAS, the Board finds that, on a long-range basis, the
preservation of Clear Lake requires the use of a regional sower
system or systems properly designed according to sound engineering
and scientific practices and the Board further finds that its long-
standing policy to encourage end foster regional systems will require
the follov.-ing-.
(A) Whenever, in the jud:j.r.cnt of the Board, it appears that
it is technically and economically fcar.ible for any vnr.te
dischr-rging entity within the watnrshed, be it ranniciprJ.
-------
A2-3 86
or j Mtlur.trinl, to join into it rc-yicnal r:y.:toi.i on an
ownership, a contract or other Giitisiactciy l.-a:;].';,
the connection or tie-in with the- syulc-M will Lc
required.
(D) YThenover, in the judgment of the Bocird, it appears
thnt a local government will construct, operate and
administer a regional system in tin area and the system
is found to be necessary to preserve and maintain the
waters in the State, the Board will, pursuant to the
provisions of the Texas Water Quality Act, designate
the area in need of the system and designate the appro-
priate local government as the responsible operating
entity.
WHEREAS, the Board finds that until such tirce as a regional
sever system or systems are developed, the irunediate implementa-
tion of advanced waste treatment requirements is necessary; and
WHEREAS, the Board, in Order G3-S, has previously recognised
the fundamentally different nature of industrial wastes as opposed
to domestic wastes and has alreridy determined that because the spe-
cifics of advanced waste treatment for an industry are not properly
amenable to a general order, it will be necessary to review all
industrial operations within the watershed on a case-by-case basis
and require the equivalent of advanced waste treatment. Now, there-
fore,
BE IT ORDERED BY THS TEXAS WATER QUALITY BOARD;
1. That all waste dischargers within the Clear Lalce Watershed
(excluding those discharges that have already been diverted
out of the watershed and excluding those dischargers pursu-
ing the acceptable alternatives contained in this Order) j-re
hereby ordered to improve and upgrade thoir vnstc tres:tr.».ont
facilities and operations in accordance vith Socticn 3
-------
A2-4
87
Ko. GO- 9.
2. That the advanced waste ti cat men I and other rermircnoftts
contained in Order G9--9 bo iind the came arc hereby incor-
porated into and made i:n oi.-c-rativo part of the waste
control orders (permits) held by those waste dischargers,
3, That the construction and other work necessary to achieve
satisfactory complicince with these new requirements be
completed cis soon as is reasonably possible but not in
excess of two (2) years from the date of the adoption of
this Order.
4. That each waste discharging entity within the watershed
shall, on or before October 1, 1970, provide the Board
with written evidence that it proposes to:
1. Divert its wastes to some other watershed according
to an acceptable plan; or
2. Combine its wastes with that of son-.o other entity
operating a sewerage system; or
3. Totally contain its wastes so that no discharge will
be made; or
4. provide tertiary or advanced waste treatment as per
this Order.
5. That, in the case of industrial waste dischargers, a
similar written document shall be submitted within the
same -tine limitations but that such written evidence
shall contain the industry's evaluation of the applica-
bility of the general order to their particular waste-
watcrs and their proposals concerning coapliance with
the purposes of this Order.
6. That because of the variety of techniques by which ad-
vanced waste trcatinc.-iiU can be achieved, the specific
-------
A2-5
requirement.:; for a i>."u:i.i.c-u]ai: v/ti^t.c cli i;chr.r
-------
A2-6
89
TO i'ii::::i.r. j>ivi:r::;joi! or V;;.:;T;:.:A'JY:::::
1. By Docciiibor 1, 1ST/G, submit a written report
contiiini.ncj a clci-.fript.ion of the specific con-
struction anil other arrangc-monti; necessary to
iuiplciuonb the particular alternative choucn.
2. By February 1, 1971, submit a written report
detailing the proposed fiscal or other program
to be followed in irr.pleiTicntijig the alternative.
3. After February 1, 1971, quarterly progress reports
shall be submitted until such time as the alter-
native is fully implemented.
8. That the reports and. other written evidence of compliance
required by this Order shall be sent to the following
address;
Texas Water Quality Board
1103 La vac?. Street
Austin, Texas 7S701
ATTN: FieJ.d Services
9. That the Field Services Section shall maintain a special
file which shall be a complete record of the compliance
with these vital reporting provisions and that the Field
Services Section shall review each report submitted and
keep the Executive Director apprised as to the status
of each entity in meeting the provisions of this Order.
10. That the Executive Director be instructed to undertake
a program to insure full compliance with this Order, to
keep the Board apprised of the status of coinplic'.nce with
the Order, ?.r.d to sc-olc, in appropriate cases, the fullest
possible prosecution of any violations of the terns and
-------
A2-7 90
provi.••.».<>:!.- of tiii j; Ordor.
11. 'j'iKit ths provisions of this Oicloi. thai) ).>« iipplj.ci.ibl-.! to
nil waste discluirgcs v/ithin the Clear J.ai:u WaterGiiecl in-
cJucliny thoca waste cliKcliaryos nvtthuirizccl by Vc:-:;:? V.'o't;:r
Quality Uoard V.'ciste Control Or ticca issued to tlic entities
listed in Exhibit A of this Order.
Issued this the 2Gth day of August, 1970.
TEXAS WATER QUALIT/ BOARD
Gordon lislchcr, Chairman
(Seal)
ATTEST:
Hugh C. Yantis, Jr., Executive Director
-------
91
ATTACHMENT NO. 3
HOUSTON - GALVESTON AREA COUNCIL
PROPOSED REGIONALIZATION PROGRAM
FOR
WASTE ABATEMENT
-------
GREENS BAYOU A1EA
TKQ3
WCO #
10962
10876
10962
106GO
10919
10699
10610
Owning
Agency
Cypress-
Fairbanks
I.S.O.
Harris
County
FWSD #61
Cypress-
Fairbanks
I.S.D.
City of
Jersey
Vill'age
White Oak
Dev. Co.
Oak Glen
Bldg. Co.
Mayflower
Invest. Co.
i
Southern
San. Corp.
:
Receiving
Stream
White Oak
Bayou
White Oak
Bayou
Greens Bayou
! White Oak
. Bayou
; White Oak
i Bayou
[ Greens Bayou
Halls Bayou
Halls
Bayou
Design I
Capacity '
(Avg. Flow) !
0.025
0.100
0.064
0.066
0.050
0.500
0.500
0.350
i Estimated
[ Current
I Lead
0.075
0.100
0.060
0.066
0.019
None
0.02-3
0.350
Role in Proposed Plan
Phase into Regional System between
1975 and 1990.
Phase into Regional System by 1990.
Phase into Regional System between
1975 and 1990.
Phase into Regional System by 1990.
Phase into Regional System by 1990.
Phase into Regional System by 1990.
Phase into Regie nail System between
1975 and 1990.
Phase into Regional System between
1975 and 1990.
\c.
r\.
-------
GREENS 3AYCU AREA
TWQB
WCO #
10648
10518
10756
10809
10825
10419
10694
10453
Owning
Agency
Trailer
Park
Harris Co.
FWSD #45
Northern
Terrace
No. Houston
Ind.
Imperial
Valley
West Road
Receiving
Stream
Design
Capacity
(Avg. Flow)
f
Greens
Bayou
I Greens Bayou
: Ha 11s Bayou
Greens Bayou
t
•Greens Bayou
; Greens Bayou
I.D. •
si
Powell ' s
Nursing
Home
Durkee
Manor
Jetero
Lumber Co.
Galco
Utilities
!
;
• Halls Bayou
•Halls Bayou
Greens Bayou
Halls Bayou
Unknown
0.053
a. 300
Unknown
0.300
0.550
0.019
0.250
0.012
0.108
Estimated
Cxx.vrent
Load
Unknown
0.053
0.259
Unknown
1.100
0.100
0.019
0.122
0.013
0.12.2
Role in Proposed Plan
Phase into Regional System between
1975 and 1990.
Phase into Regional System between
1975 and 1990.
Phase into Regional System between
1975 and 1990.
None
Phase into Regional System in 1990
or shortly thereafter.
Phase into Regional System in 1990
or shortly thereafter.
Phase into Regional System between
1975 and 1990.
Phase into Regional System between
1975 and 1990.
Phase into Regional System by 1975.
Phase into Regional System in 1975
or shortly thereafter. >
i
fo
tjj
-------
GREENS BAYOU AREA
TWQB
WCO #
10953
10436
10495-
78
10236
10679
10785
10495-
14
10495-
45
10451
Owning
Agency
Aldine ISD
Crest San.
Corp.
Houston
Int.
Airport
Oakw'ilde
V7ater Co.
Chatwood
PI.
Harris Co.
WCID #74
Sequoia
Estates
City of
Houston
'City of -
Houston
Harris Co.
WCID #76
i
Receiving
Stream
Greens Bayou
Greens Bayou
; Greens Bayou
Halls Bayou
Greens Bayou
! Greens Bayou
' Greens Bayou
Halls Bayou
Halls Bayou
Greens Bayou
Design jj Estimated
Capacity | Current
(Avg. Flow) I Lead
0.035
0.075
0.200
0.245
1.000
0.250
0.400
0.280
0.522
0.300
0.035
0.144
0.150
0.245
0.500
0.250
0.003
0.200
0.522
0.260
Role in Proposed Plan
Phase into Regional System by 1975.
Phase into Regional System by 1975.
None
Phase into Regional System shortly after
1975.
Phase into Regional System by 1990.
An additional 0.65 mgd planned for in
the near future will make the plant
suitable until about 1990.
Use until about 1990.
Phase into Regional System by 1975.
Phase into Regional System by 1975.
Phase into Regional System between
1975 and 1990.
5*
I
Vi
-C
-------
fKEENS BAYOU AREA
177Q3
V7CO #
10737
10336
10495-
23
10495-
71
Owning
Agency
Harris Co.
WCID #69
Eastex
Oaks
City of
Houston
City of
Houston
Receiving
Stream
Greens Bayou
[ Greens Bayou
i Halls Bayou
i
Greens Bayou
i
i
i
!
i
Design
Capacity
(Avg. Flow)
0.565
1.000
1.250
0.300
Estimated
Current
Load
0.432
0.144
0.8G7
0.1'iS
Role in Proposed Plan
Phase into Regional System in 1975
or shortly thereafter.
Phase into Regional System by 1990.
This plant is being expanded to 5.0 mgd
and will serve as Regional Plant.
Phase into Regional System between
1975 and 1990
10
-t-
$
-------
TXQB
WCO #
10400
10990
11109
:
|
Owning | Receiving
Agency 1 Stream
City of | Cedar Bayou
Belvieu |
Barbers | Cotton Bayou
Hill ISO I
R
Lincoln t Cedar Bayou
Cedars Sub-|
division |
HHM Corp. I
f
Cedar Bayouj,; Horsepen
Mobile Home
Lakliv Inc.
R. R.
Herring ton
Sr.
Dutton &
Gray
Bay Ridge
Subdivisioi
j Bayou
;
Cotton Bayou
r
Cotton Bayou
• Trinity Bay
Design
Capacity
(Avg. Flow)
0.075 mgd
0.015 mgd
Q.0025 mgd
0.04 mgd
0.012 mgd
0.012 mgd
I Estimated
! Current
' i'xsad
\
0 . 3. mgd
Unknown
Unknown
Unknown
Unk nown
Unknown
Unknown
Role in Proposed Plan
Abandoned by 1990.
None
Phase out upon completion of regional
system.
Phase out upon completion of regional
system.
Phase out upon completion of regional
system.
Phase out upon completion of regional
system.
Phase out upon completion of regional
system.
VI
vo
-------
TEXAS CITY - LA MARQUE AREA
TV7QB
wco #
10770
10627
10172-
01
10173-
02
10375-
01
10375-
02
10410
10435
Owning
Agency I
!
Bay View
MUD
Bacliff MUI
Galyesfcon
Co. 'WCID
No. 1
ST? #1
Calves ton
Co. WCID
.No. 1
'STP #2
City of
Texas City
STP No. 1
City of
Texas City
STP No . 2
City of
La Marque
Bayou
Vista Sub-l
division
if
I Receiving
' Stream
Galveston
Bay
i Houston
; Lighting &
1 Power
• Outfall
' Dickinson
Bayou
Dickinson
Bayou
Moses Lake
Moses Lake
( Highland
i Bayou
| Highland
i Bayou
•
Design
Capacity
(Avg. Flow)
0.25
1.00
1.20
0.50
5.00 '
0.80
1.90
0.05
i
r
j Estimated
Cu Trent
1 Load
1
O.OL
0 .12
0.50
0.06
5.00
0.61
1.90
0.04
Role in Proposed Plan
Abandoned by 1990.
Abandoned by 1990.
Expanded to 2.4 mgd before 1980.
Replaced by regional plant A before 1990.
Expanded to 1.0 mgd before 1980. Replaced
by regional plant A before 1990.
Expanded to 14.0 mgd, becomes Regional
Plant B.
Expanded to 1.6 mgd before 1975.
Abandoned by 1990.
Expanded to 3.0 mgd before x980.
Abandoned by 1990.
>
\f>
Abandoned by 1990. ^
-------
CLEAR LAKE AREA
7WQB
wco #
10495,79
10495,55
10405, 58
10522
10539
Sbne
Sone
Owning
Agency
Receiving
Stream
Houston •*• | Through
(SE Plant) i ditches to
| Clear Creek
Houston 1 j Through
(Beverly * ditches to
Hills)
i Clear Creek
Houston ^ | Through
(Eastridge)
Harris Co .
WCID 81
.Clear Lake
City Water
Authority
1
NASA-MS C
Pasadena 1
(El Carey)
F ditches to
| Clear Creek
! Turkey Creek,
, Clear Creek
; Korsepen
: Bayou, Middle
' Bayou, Mud
'. Lake, Clear
[ Lake
i Clear Lake
Clear Lake
Design
Capacity
(Avg. Flow)
3 . 0 mcrd
0.368 mgd
0. 28 mgd
0.25 mgd
2.25 mgd
0.31
Unknown
Estimated
Current
Load
N.A.
0.40 mgd
0.12 mgd
0.25 mgd
1. 75 mgd
0.25-0.50 mgc
.04 rigd
Role in Proposed Plan
Serve as subregional plant; to be completed
1973.
Abandon when Houston SE plant is put in
operation.
.
Abandon when Houston SE plant is put in
operation.
Abandon when Houston SE plant is put in
operation.
Serve as subregional plant after advanced
treatment modifications completed
(probably early 1973)
Abandon after connection is made to CLCWA
Abandon after connection is made to CLCWA
1 The role for these plants has been
firmly established by Board Orders
69-9A and 71-0819-1.
VjJ
1
vo
00
-------
TEXAS CITY - IA MARQUE AREA
Tr'.TQ 3
VJCO #
10336-
02
10836-
01
106*0
10174
10958
10861
10771
;
Owning
Agency
Receiving
Stream
i
Flamingo | Basford
Isle Corp. f- Bayou Tribu-
1 tary Canal
Flamingo | Basford
Isle Corp. £ Bayou Tribu-
City of
Hitchcock
Calves ton
Co. WCID
No. 8
Sun
'Meadows
MUD
Safari
Mobile
Home
i
Texas City
'Dike
Marina
i
\
> tary Canal
k
; Basford
Bayou
; Highland
i Bayou
i
',
| Dickinson
; Bayou
[ Magnolia
: Bayou (A
! Dickinson
, Tributary)
1 Calves ton
j Bay
j
i
i
1
Design
Capacity
(Avg. Flow)
0.20
0.20
0.50
0.04
0.01
0.007
0.0005
:
Estimated
Current
Load
...
None recordec
0.29
0.03
0 . 005
None recordec
None record-
ed
Role in Proposed Plan
Not yet constructed; replaced by
regional plant after 1990.
Replaced by regional plant after 1990.
Expanded to 1.2 mgd before 1975.
Replaced by regional plant before 1990.
Expanded to 0.50 mgd before 1975.
Replaced by regional plant before 1990.
Served by Clear Creek Planning Sub.
Served by Clear Creek Planning Sub.
Serves an isolated area.
VjO
1
OO
vo
vo
-------
ATTACHMENT NO.
PUBLIC HEARING NOTICE
ON
PROPOSED B.O.D. ALLOCATIONS
FOR
HOUSTON SHIP CHANNEL
100
-------
101
GORDON fULCHCR
CHAIRMAN
LISTER CLARK
VICC-CHAIHUAN
J. DOUG TOOLE
HARRY P. BURLEIGH
TEXAS WATER QUALIT\>BOAR
JAMES U CROSS
J. E PEAVV. MD
BYRON TUNNCLL
HUGH C. YANTIS. JR.
EXBCUTtVC DlftCCTOft
PH 47S-2S9I
AX. S12
314 WEST IITH STHEE
P.O. BOX 13248 CAPITOL STATION
AUSTIN. TEXAS
- -<•<
PUBLIC HEARING NOTlCf; . .M_l~V
Pursuant to the recommendations adopted at the recent Galveston
Bay Enforcement Conference the pollutant load on the Houston Ship
Channel will be lowered such that the aggregate biochemical oxygen
demand (BOD) load will not exceed 35,000 Ibs. per day in order
that approved stream standards will be met. Comparable reductions
in other pollutants will also be required.
Therefore, the Texas Water Quality Board will conduct a public
hearing to amend all waste control orders for industrial effluents
discharged into the Houston Ship Channel and its tributaries
(exclusive of the San Jacinto River above the Lake Houston Dam) in
order to achieve the above specified BOD loading. These waste
control order holders are listed in Table I . The Board will also
discuss altering other quality parameters specified in the individual
waste control orders including but not necessarily limited to
total residue, total suspended solids, volatile suspended solids,
settleable matter, chemical oxygen demand (COD), oil and grease,
color, heavy metals, toxic compounds, free and floating oil, debris,
foaming or frothing material and others . In addition, possible
regionalization or combination of waste treatment facilities of
both domestic and industrial waste dischargers will be discussed
where appropriate.
The public hearings for amending the industrial waste control
orders will be held on February 9, 10 and 11 in the Baytown Civic
Auditorium, 2407 Market Street, Baytown, Texas. These public
hearings will commence at 2:00 p.m. on February 9 and 10 and 8:30 a.m.
on February 11. This time schedule has been selected to enable
any citizens who desire to participate to attend the public hearings.
The Texas Water Quality Board desires that those persons and
entities who will be directly affected by these public hearings
be informed of the levels of waste treatment which will be required
to meet the established goals. In particular, increases in both
capital and operating costs are expected to result from the new
(continued)
-------
102
A4-2
Public Hearing Notice
Page 2
requirements of the Board. These public hearings will provide an
opportunity for discussion of all aspects of these vital issues.
The public hearings may be continued from time to time and from
place to place as necessary to develop the record.
Issued this 13th day of January 1972.
Hugh C. Yantis, Jr., Executive Director
Texas Water Quality Board
-------
TABLE I
INDUSTRIAL WASTE CONTROL ORDERS TO BE AMENDED
103
Name
Waste Control
Order Number
Page
Airco Welding Products
Air Products & Chemical, Inc.
Allied Fence Corp.
Anchor Hocking Glass Corp.
Aquaness Chemical Div.
Ashland Chemical Company
Atlantic Richfield
•
•
•
••
H
Baroid Div. Nat Lead Co.
H
Big Three Welding Co.
Brown Oil Tools
H
11
00655
01280
01212
01170
00761
00549
00392
00392
00392
00392
00392
00392
01198
01198
00306
00687
00687
00687
01
01
01
01
01
01
01
02
03
04
05
06
01
02
01
01
02
03
-------
Name
Cameron Iron Works
Cargill Inc.
Celanese Plastic Company
Charter International Oil
ii
Chemical Exchange Processing
Cook Paint & Varnish Co.
Crown Central Petroleum
Diamond Shamrock Corp.
Diamond Shamrock Corp.
Dresser Industries, Inc.
Dresser Magcobar '
E.I. Dupont de Nemour & Co.
Eddy Refining Co.
Waste Control
Order Number
00357
01247
00544
00535
00535
Co. 00786 '
00427
00574
00574
00574
01000
J00749
00305
00305
00305 '
00305
00305
00305
01262
01211
00474
01018
Page
01
01
01
01
02
01
01
01
02
03
01
01
01
02
03
04
05
06
02
01
01
01
-------
A4-5 105
Name
Enjay Chemical Company
Enjay Chemical Company
Ethyl Corporation
Waste Control
General American Transportation 01308
ii
General Portland Cement Co.
Gibraltor Galvanizing Co.
Goodyear Tire & Rubber Co.
H
Grief Bros. Cooperage Corp.
Groendyke Transport Co.
n
Gulf Coast Portland Cement
Gulf States Asphalt Co., Inc.
Helmerick & Payne Inc.
Hess Terminals
Hooker Chemical Corp.
ter Number
00610
01215
00492
00492
00492
01308
01308
00312
01019
00520
00520
01217
01057
01057
01021
01058
01385
00671
00733
00733
Page
01
01
01
02
03
01
02
01
01
01
02
01
01
02
01
01
01
01
01
02
-------
106
Name
Horton & Norton, Inc.
Waste Control
Houston Lighting & Power Co.
Houston Lighting & Power Co.
Houston Natural Gas
Hughes Tool Company
Ideal Cement Company
John Mecora & Proler Corp.
ler Number
00683
00684
00839
01026
01027
01031
01032
01032
01033
01033
01033
01286
01046
01046
01046
01046
01046
00456
00456
00456
01017
Page
01
01
01
01
01
01
02
04
01
02
03
01
01
02
03
04
OS
01
02
03
01
-------
A4-7 107
Name
Waste Control
Kennecott Copper Corp.
Koppers Co . , Inc .
Lead Products Co . Inc .
Lone Star Cement Corp.
«
Lubrizol Corporation
•
Merichem Company
Missouri Kansas Texas RR
Murray Rubber Company
National Biscuit Company
•
«
National Supply Division
Olin Corporation
•
M
M
It
H
Parker Bros. & Co., Inc.
M
H
Order Number
01260
01034
01030
00580
00580
00639
00639
00485
01197
01222
01298
01298
01298
01036
00649
00649
00649
00649
00649
00649
00668
00797
00801
Page
01
01
01
01
02
01
02
01
01
01
01
02
03
01
01
02
03
04
05
06
01
01
01
-------
108
Name
Parker Bros. & Co. Inc.
•
Pennwalt Chemical Corporation
Petro Tex Chemical Corp.
Waste Control
Petrochemical Investment Corp.
Petroleum & Mining Division
Petrolite Corporation
Philip Capey Mfg. Co.
Phillip Petroleum Company
Phosphate Chemical Inc.
H
Plastic Applicators, Inc
PPG Industries Inc.
M
Premier Petrochemical
Reddy ice Div.
Reichold Chemical Inc.
Rohm and Haas
ler Number
00806
00809
00587
00587
00587
00587
01301
00635
00347
00660
00815
00815
00975
01061
01194
01194
01150
01224
01224
01045
01279
00662
00458
Page
01
01
01
01
02
03
01
01
01
01
02
03
01
01
01
02
01
01
02
01
01
01
01
-------
A4-9 109
Name
Waste Control
Rohm and Haas
•
Rollins-Purle Inc
Sand & R Oil Co.
Shell Chemical Company
•
Shell Oil Company
•
•
M
•
•
Ht
"
-
•
«
•
Sinclair Koppers Chemical Co.
Sinclair Petrochemical Co.
Smith A.O. Corp.
Smith Industries, Inc.
Order Number
00458
00458
01429
01063
00402
00402
00403
00403
00403
00403
00403
00403
00403
00403
00403
00403.
00403
00403
00393
00391
00672
00686
Page
02
03
01
01
01
02
01
02
03
04
05
06
07
08
09
10
11
12
01
01
01
01
-------
A4-10 110
Name
SMS Industries Inc.
Southern Pacific Co.
•
Southland Paper Mills
Southland Paper Mills, Inc.
Southwest Chem. & Plastic Co.
Stran Steel Corp.
Stauffer Chemical Co.
•
Stauffer Chemical Co.
Superior Oil Company
Swift Agricultural Chem. Corp.
Tenneco Chemical, Inc.
Tenneco Oil Company
Texaco, Inc.
Waste Control
Texas Instruments
Todd Shipyards
Jer Number
01062
01180
01181
01160
01161
01229
01259
00541
00541
00542
01232
01421
00002
00440
00413
00413
00413
00413
01172
01225
01159
Page
01
01
01
01
01
01
01
01
02
01
01
01
01
01
01
02
03
04
02
01
01
-------
HI
.Name
Tube Associates Inc.
Union Carbide & Chemical Co.
Onj on Equity Cooperative
Exchange
United States Gypsum Company
H
Upjohn Company, The
U.S. Industrial Chemical
U.S. Industrial Chemical
Waste Control
Uvalde Rock Asphalt Co.
Zavalla Sand Company
er Number
01423
01173
01205
00353
00353
00663
00534
00534
00640
00640
00640
00785
00545
Page
01
01
01
01
03
01
01
02
01
02
03
01
01
-------
GORDON FULCHER
CHAIRMAN
LESTER CLARK
VICE-CHAIRMAN
J. DOUG TOOLC
HARRY P. 8URLEICH
TEXAS WATER QUALITY BOARD
314 WEST I1TH STREET 7B7OI
P.O. BOX 13246 CAPITOL STATION 78711
AUSTIN. TEXAS
January 17, 1972
A4-12 112
JAMES U. CROSS
J. E. PEAVV, MO
BYRON TUNNELL
MUCH C. YANTIS. JR.
EXECUTIVE DIRECTOR
PH. 475-2631
A.C. S12
P:DW
To the Holder of Waste Control Order No.
Gentlemen:
In accord with the enclosed notice, a public hearing will be held
with the objective of lowering the authorized 5-day BOD load on the
Houston Ship Channel to 35,000 Ibs. per day and to also require
reductions in other pollution parameters. It is our intention to
require, insofar as possible, a comparable effort by all of the in-
dustrial waste dischargers in the area covered by the notice. We
have attempted to define the effluent quality for each waste control
order holder on the Houston Ship Channel pursuant to this objective.
It must be recognized that the waste load allotment to the various
individual waste control order holders is as yet imperfect, and
that the individual allotments may and undoubtedly will be altered
as additional data is developed during the course of the hearing
and/or subsequent conferences. Consequently, the attached table
showing the effluent requirements for the various industries is
being furnished to you to indicate the magnitude of the necessary
waste treatment effort, and to assist you in preparing for the
hearing.
You should come to the hearing prepared insofar as possible, to
discuss fully your company's capability to comply with the proposed
effluent quality, and the date by which compliance can be attained—
bearing in mind the December 31, -1974 deadline imposed by the findings
of the EPA Shellfish Enforcement Conference. The testimony relating
to time requirements should be broken into sections with time inter-
vals or interijn dates for the accomplishment of engineering, financing,
and construction specified.
-------
A4-13 113
It is recognized that minimizing the number, within limit, of waste
treatment facilities by the creation of regional or subregional
waste disposal systems is a desirable goal and this is recognized
in the recommendations of the EPA Shellfish Enforcement Conference.
In view of the necessity of maintaining the BOD load below 35,000
Ibs. per day now and in the future, the treatment levels required
to maintain this requirement dictate that advance waste treatment
practices be employed. This factor lends additional weight to the
desirability of regional or subregional systems. Minimizing the
number of treatment facilities, particularly if owned and operated
by one entity such as the Gulf Coast Waste Disposal Authority, will
enhance the ability to provide for future industrial and municipal
growth ancf remain with the specified 35,000 Ibs. per day. For these
reasons, we would suggest that you give very serious and immediate
consideration to participation in a regional system.
Very truly yours,
Hugh C. Yantis, Jr.
Executive Director
ccs: W. A. Quebedeaux, Jr., Ph.D., Director
Harris County Pollution Control Department
L. D. Farragut, M.D., Director
Harris County Health Department
The Honorable Jim Clark
Texas House of Representatives
Honorable Bill Elliott
Harris County Judge
Mr. Joe Resweber
Harris County Attorney
Mr. Jamie H. Bray
Commissioner - precinct 2
Mr. L. Jack Davis, General Manager
Gulf Coast Waste Disposal Authority
Texas Water Quality Board District 7
-------
T. P. Gallagher
MR. GALLAGHER: Thank you.
On January 7, 1972, Mr. William D. Ruckelshaus,
Administrator of the Environmental Protection Agency, sent a
i
i
i letter to Mr. Hugh C. Yantis, Executive Director of the Texas
!
j Water Quality Board, officially transmitting the recommenda-
i
j tions of the Galveston Bay Enforcement Conference. I would now
i
i like to read these recommendations:
• 1) The Federal conferee concluded
that there is occurrence of pollution of inter-
state or navigable waters due to discharges from
municipal and industrial sources subject to
abatement under the Federal Act.
The State conferee took the position
that the conference was called under the shell-
fish provisions of the Act and that while there
is pollution occurring in the waters covered by
this conference, it has not been demonstrated
that substantial economic injury results from
the inability to market shellfish products in
interstate commerce.
2) While measures have been taken to
reduce such pollution, they are not yet adequate.
3) Delays encountered in abating the
-------
! T. P. Gallagher
pollution have been caused by the enormity and
complexity of the problem.
4) The Pood and Drug Administration, in
cooperation with appropriate State regulatory
agencies, will continue its recently initiated
national study of oil and hydrocarbon residues in
oysters, including those taken from C-alveston Bay,
with the objective of determining toxicological
effects, if any, of such concentrations. These
data, and any evaluations, will be made available
to the conferees of the Galveston Bay enforcement
conference.
5) To insure that approved shellfish
harvesting areas are properly classified at all
times, sampling for determining bacteriological
acceptability of areas for shellfish harvesting
in Galveston Bay shall continue to emphasize the
p.ost unfavorable hydrographic and pollution con-
ditions. The most unfavorable hydro/graphic and
pollution conditions will be determined by tech-
nical personnel of the Texas State health Depart-
rvent in cooperation with the rood ana I";rug
Administration and other Federal, State and local
115
-------
116
T. P. Gallarher
agencies.
6) Effective disinfection of all waste
sources contributing bacteriological ccllution tc
the Galveston Bay system will be provided. The
Texas Water Quality Board policy to this, effect
shall continue to be implemented. Where effective
disinfection is not presently being tcccmpjished,
it is recognized that adequate measures are under-
way to secure that disinfection. These noasurec
shall be in effect by December 31, 1971.
The Texas Water Quality Board will
continue to inrolement its policy regarding the
elimination of snail plants. The centralization
of facilities, wherever possible, and the halt of
proliferation of small plants will continue, con-
sistent with existing appropriate procedures. The
implementation schedule for this pro~rair,, as
*
initiated by the Texas Water Quality Beard, will
be made available to the conferees of the Galvesten
Bay enforcement conference not later than April 1,
1972.
7) The Environmental Protection Agency
and the Texas Water Quality Board will cooperate
-------
117
i
T. P. Gallagher :
in a study of Galveston Bay. This study is pres-
ently being conducted by the Texas Water Quality
Board on all sources of municipal and industrial
wastes permitted by the Texas Water Quality Board
to discharge effluent to Galveston Bay and its
tributaries. These examinations shall emphasize
determination of complex organic compounds,
heavy metals and other potentially toxic sub-
stances, as well as oil and grease, from each
waste source. Recommendations and scheduling of
necessary abatement will be provided to the con-
ferees as soon as they become available. The
Texas Water Quality Board permits and self-
reporting data system will be amended as neces-
sary to reflect the recommendations of this waste
source survey. A progress report on results of
this study will be made to the conferees within
6 months of the date of the reconvened session
of the Galveston Bay enforcement conference.
8) The Texas Water Quality Board will
continue its review of each waste source dis-
charging to Galveston Bay and its tributaries
and will amend those permits as necessary to
-------
_118
i
T. P. Gallagher |
insure that the best reasonable available treat-
ment is provided relative to discharges of oil and
grease. The Texas Water Quality Board will co-
operate vfith EPA and local governments in determin-
ing what treatment is the best reasonable available
treatment. It is recognized that improvements in
technology will be incorporated into future permit
provisions. A progress report will be made to the
conferees within 6 months of the date of the re- i
i
convened session of the Galveston Bay enforcement !
conference. :
i
9) The ongoing review and amendment by !
, the Texas Water Quality Board of existing permits i
I j
I recognizes that greater reductions of waste will |
j i
i be required of waste dischargers to the Galveston !
j j
j Bay system to meet water quality standards. The I
conferees note that in the past 3 years the organic j
waste load being discharged into the Houston Ship
!
Channel has been lowered from about ^30,000 Ibs/day i
of BOD to 103,000 Ibs/day of BOD. Any amendments
to existing or new Texas Water Quality Board waste
control orders as a result of this program will
prohibit dilution as a substitute for treatment.
-------
119_
T. P. Gallagher
A progress report on continuing reduction of waste
loads will be provided to the conferees within 6
months of the date of the reconvened session of the
Calves ton Bay enforcement conference.
10) A characterization and evaluation
of the water quality significance of materials
from pollution sources contained in the organic
sludge dredged from the Houston Ship Channel shall
be conducted. Based on the results of this evalu-
ation and examination of present spoil disposal
areas, recommendations will be made by the Texas
Water Quality Board and the Environmental Protec-
tion Agency on location of suitable spoil disposal
areas and other appropriate action to minimize or
eliminate deleterious effects on water quality.
11) If alert levels for acute and
chronically toxic or growth inhibiting factors
are developed by the Food and Drug Administration
for shellfish from all approved national growing
waters, including Galveston Bay, the appropriate
Texas agencies and the Environmental Protection
Agency, in cooperation with the Food and Drug
Administration and other appropriate Federal
-------
120
T. P. Gallagher
agencies, will work to develop requirements for
the same characteristics in waters approved for
shellfish harvesting.
12) Chemical constituents causing
color in waste effluents, such as those from
pulp and paper mills, shall be reduced to natural
background in area waters as soon as practicable
as stated in existing Texas Water Quality Board
waste control orders. A report on feasible
processes to accomplish this recommendation shall
be submitted to the conferees within 6 months of
the reconvened session of the Galveston Bay
enforcement conference.
13) To meet present official State-
Federal water quality standards established for
dissolved oxygen in the Houston Ship Channel, it
! is expected that the maximum waste load discharged
|
| from all sources will be about 35>000 Ibs/day of
I
| 5-day BOD, including projected future development.
The Texas Water Quality Board in cooperation with
technical personnel of the Environmental Protection
Agency shall review existing waste discharge orders
with the objective of allocating allowable 5-day
i
; j
-------
T. P. Gallagher
BOD waste loads for sources discharging to the
Houston Ship Channel such that a probable 35,000
Its/day maximum shall not be exceeded. A report
will be made to the conferees on the results of
this review by April 1, 1972. The allocation for
each waste source as determined by the Texas Water
Quality Board, in cooperation with the EPA, shall
be attained by December 31, 197^. Interim dates
to determine progress toward compliance of the
assigned allocation shall be established for each
waste source by May 1, 1972.
The conferees also recognize that dis-
charge of other xvaste constituents, such as but
not limited to chemical oxygen demand, suspended
solids, complex organics, and other toxic materi-
als, also contribute to the pollution of Galveston
Bay and its tributaries. An allocation of allow-
able waste discharges for these pertinent parameters
from each waste source will be established by
technical personnel of the Texas Water Quality Board
and the EPA consistent with best available treatment
practices and such allocation will be reported to
the conferees by September 1, 1972.
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122
T. P. Gallagher !
The conferees recognize that technical
considerations may require a reassessment of this
schedule in the case of some of the municipal and
industrial waste sources to be considered. These
necessary reassessments will be determined by
technical personnel of the Texas Water Quality
Board and the EPA, and recommendations concerning
schedule changes will be made to the conferees at
6-month intervals.
The foregoing recommendations shall not
be construed as in any way foreclosing or inter-
fering with Federal, State or local statutory
proceedings relating to the authorization, amend-
ment, or revocation of Federal or State waste
discharge permits or orders, nor shall such recom- :
mendations operate to delay or prevent the crea-
j tion or operation of regional waste disposal systems
such a.s the contemplated Gulf Coast Waste Disposal
Authority.
14) All waste sources which discharge
directly to Galveston Bay and other tributary
areas, including Clear Lake, shall have allowable
waste- loads allocated by June 30, 1972, consistent
-------
T. P. Gallagher
with best available treatment practices. This
allocation shall include interim dates for accom-
plishment of required waste treatment and/or waste
treatment facilities v.'hich will be in operation by
December 31, 1974. The Texas Water Quality Board
will cooperate with EPA and local governments in
determining; what treatment is the best reasonable
available treatment.
15) The following recommendation was
not susceptible to joint agreement by the con-
ferees, regarding the Houston Lighting and Power
Cedar Bayou Power Plant:
( a) The Texas conferee's recommendation—
the once-through cooling system, with
discharge to Trinity Bay, proposed for
the Cedar Bayou plant shall be carefully
monitored to determine whether damage to
aquatic life is occurring and/or water
quality is being deleteriously affected.
If such effects are shown, Houston
Lighting and Power Company will take
immediate steps to correct the situation.
(b) The Federal conferee's recommendation—
-------
12*4
T. P. Gallagher
no discharge of cooling water from the
Cedar Bayou plant to Trinity Bay shall
be permitted. The Houston Lighting and
Power Company shall be required to abate
the waste heat load by incorporation of
a system utilizing recirculation and
reuse of cooling water to Tabbs Bay and
adjacent waters or location of additional
units at suitable alternative sites.
Having read the recommendations, Mr. Chairman, I would
j now like to summarize the progress toward implementation of I
i
i !
! those recommendations.
The Galveston Bay Technical Committee i
was formed by the conferees of the Galveston Bay
enforcement conference at the conclusion of the !
first session in June 1971. The Technical Com-
mittee summarized testimony offered at the first
session and the conferees adopted recommendations ;
at the second session in November 1971. Many of
these recommendations require periodic submittal
of progress reports prior to the time of full im-
plementation. In accordance with these recommenda- !
i
tions, the Galveston Bay Technical Committee submits i
-------
_ 125
T. P. Gallagher
this progress report.
Recommendations Numbers 4, 5 and 11
concerned adequate criteria and sampling of
shellfish harvesting areas to insure accepta-
bility of the product for consumption. The
Food and Drug Administration has initiated a
nationwide sampling and analysis program to
determine the toxicological significance of oil
and hydrocarbon residues in oysters. Prelimi-
nary data from this survey are not yet available
for general distribution. The Texas State Board
of Health and the Food and Drug Administration
have amended the sampling schedule in Galveston
Bay to include, as far as possible, data collec-
tion under the most unfavorable hydrographic and
pollution conditions. Alert levels proposed for
heavy metal concentrations in shellfish at the
Food and Drug Administration Seventh National
Shellfish Sanitation Workshop were not adopted.
These alert levels are included in this report as Table IiI-1 en
page 18.
A committee has been formed to study the problem
and review available data at yearly intervals.
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126
——1
T. P. Gallagher
Recommendation No. 6 concerned effective
disinfection of municipal effluents and the cen-
tralization of sewage treatment plants. Grab
samples of effluents from 50 major municipal waste
plants collected by the Texas Water Quality Board
in March 1972 indicated that a large number of the
plants were meeting the Texas Water Quality Board
chlorine residual requirements.
| These results are shown in Table IV-1 on pages 21 and 22.
I Total and fecal coliform concentrations in the
effluents of many plants were still excessive. Total
and fecal coliform are indicators of the possible
presence of pathogenic organisms. In general, those
plants with longer contact times discharged effluent
with satisfactory bacteriological quality. The un-
satisfactory bacteriological densities are related
to either excessive solids concentrations in the
effluent or short circuiting in the chlorine contact
tank or both. Correction of the problem is being
pursued on a case-by-case basis by the Texas Water
Quality Board. The Sims Bayou plant of the city of
Houston is the only major municipal waste source
without chlorination facilities. These facilities
-------
127
T. P. Gallagher
will be constructed and in operation by December
I 1972.
I
i The Texas Water Quality Board order requiring the installation !
| |
1 of chlorination at Sims Bayou is shown as part of Attachment 1.!
i ' !
i
i With respect to the centralization of
i !
i j
! sewage treatment plants and the elimination of I
! * I
j small facilities, the Texas Water Quality Board >
I has issued an order to the city of Houston re-
!
j
I quiring the abandonment of a number of obsolete
I
I plants and the diversion of these wastes to
i
| regional and subregional systems. The Clear
i
I Lake area has also received a Texas Water Quality
!
j Board order with the same objective.
i
! These orders are included as Attachments 1 and 2 and the
i
t
I regional!zation program for the Houston-Galveston Area Council
j
j is shown as Attachment 3.
i
| Compliance \vith these Texas Water Quality Board
i
I
j orders is mandated before December 31, 197^.
i
j Recommendation Mo. 7 called for a joint
1
i waste source survey of the Galveston Bay area by
i
j the Environmental Protection Agency and the Texas
i
! Water.Quality Board, in addition to other ongoing
! studies. This survey commenced during April 1972.
L..
-------
128
i
i T. P. Gallagher
i
It is presently anticipated that approximately
one-half the waste effluent flow to the Houston
i Ship Channel will have been analyzed by October
i 1972. Results will be provided to the conferees
; as soon as they become available.
i Recommendation No. 8 called for the
i
requirement of best reasonable available treat-
i
i ment to minimize discharges of oil and grease.
; Texas Water Quality Board permits are being
i
. amended to require oil and grease concentrations
i in waste effluent to be not greater than 10 ppm.
! Recommendation No. 9 called for a con-
i
I tinuing reduction of waste loads and amendment of
i
Texas Water Quality Board permits to reflect these
j
reductions. Under present abatement schedules,
the waste load to the Houston Ship Channel will
be reduced to about 60,000 pounds per day of
biochemical oxygen demand by December 1973 from
the present 100,000 pounds per day. The major
waste sources in the Texas City area will be re-
duced from the present 78,000 pounds per day to
13,800 pounds per day in 1974 to 11,800 pounds
per day in 1976.
-------
129
_—,
T. P. Gallagher ]
i
Recommendation No. 10 called for an :
evaluation of the organic sludge problem in the
Houston Ship Channel with specific emphasis on !
the development of suitable dredged spoil dis- ;
!
posal areas. Examination of bottom deposits by !
Texas A&M University showed highly organic
material and represents an important pollutional
source. Some analyses indicate that the channel
deposits contain material toxic or inhibitory to
microorganisms. EPA and the U. S. Army Corps of
Engineers have proposed the construction of a
ringed diked spoil disposal area on Atkinson
Island. Further studies of the environmental
impact of this proposal are advisable.
Recommendation No. 12 required an
assessment of feasible processes to accomplish
color removal from waste sources. The committee
decided that although several ongoing research
studies on color removal indicated promising
results, the technology was still not sufficiently
developed to require color removal processes be
installed at the present time. The Texas Water
Quality Board permits do specify that such processes
-------
130
T. P. Gallagher :
will be installed when technological feasibility :
for general use is demonstrated.
Recommendation No. 13 states that: "To
meet present official State-Federal water quality
standards established for dissolved oxygen in the
Houston Ship Channel, it is expected that the maxi-
mum waste load discharged from all sources will be
about 35,000 pounds per day of 5-day BOD, including
projected future development. The Texas Water
I
| Quality Board, in cooperation with technical per-
sonnel of the EPA, shall review existing waste dis-
charge orders with the objective of allocating
allowable 5-day BOD waste loads for sources dis-
charging to the Houston Ship Channel such that the
probable 35,000 pounds per day maximum shall not
be exceeded." Such an allocation was made by the
Technical Committee and presented in a public
hearing by the Texas Water Quality Board in Baytown,
Texas, in February 1972.
The notice of this hearing is included as Attachment ^ and the !
proposed allocations are shown in Table X-l on pages ^9 through
52.
Major opposition to these allocations was voiced
-------
131
~~ ..--... . .. _ ._ _ .,
T. P. Gallagher
at this hearing. The Texas Water Quality Board is
conducting an abatement program that will attain a
total SOD effluent level of approximately 60,000
pounds per day by December 1973. During this
period, consultations will be held between the
Texas Water Quality Board and the Environmental
Protection Agency with individual waste dischargers
to determine specific implementation dates by these
waste sources for meeting Federal-State water
quality standards for the Houston Ship Channel.
The present program of limiting effluents to
60,000 pounds per day is an interim step and may
not meet presently approved State-Federal water ;
quality standards for dissolved oxygen in the Houston ;
Ship Channel.
Recommendation No. 14 directs an alloca-
tion of allowable waste loads to Galveston Bay and
I
j all other tributary areas. The Clear Lake area has
j
received a Texas Water Quality Board order requiring
the abandonment of obsolete plants and the diversion
of these wastes to regional and subregional systems.
This is Attachment 2 in this report.
The major waste sources in the Texas City area
-------
^ 132
T. P. Gallagher
will be reduced from the present 78,000 pounds
per day to 13,800 pounds per day in 1974 to
11,800 pounds per day in 1976. The city of Gal-
vest on has been directed by a Texas Water Quality
Board order to make extensive improvements in the
collection system and to provide expanded treat-
ment facilities by December 31, 1974.
This completes my presentation, Mr. Alexander.
MR. ALEXANDER: Thank you, Mr. Gallagher.
MR. STEIN: Are there any comments or questions?
MR. YANTIS: Not any questions of Mr. Gallagher. Just
some brief general comments, if I may at this time, Mr. Chair-
man.
MR. STEIN: Certainly.
HUGH C. YANJTIS, JR., EXECUTIVE DIRECTOR
TEXAS WATER QUALITY BOARD
AUSTIN, TEXAS
MR. YANTIS: In line with the policies long followed
by the Chairman of the Water Quality Board, I would like to
take note of the people on our staff who deal with the news. j
Miss Jean Ferris is sitting over here, and for the Federal
Government Mr. Eddie Lee. I don't know whether there is
-------
K. C. Yantis, Jr. 1
i
anyone else with Eddie or not. He may have walked out. I
I would like to note that the working press is here. ;
Harold Scarlett is the only one that I know by name. I wonder
if the other two would stand up and tell what news media they
do represent.
MISS DIAL: My name is Mauri Dial. I am with KTRH
Radio here in Houston.
MR. ROYAL: Ben Royal with the Texas City Daily Sun.
MR. YAHTIS: Thank you.
In another sense, always to know with whom we are
communicating, there are a great many people here from the
State staff. I would like for each one of you to stand up
briefly just so we can kind of get a head count from the Texas
Water Quality Board staff.
(A number of people stood up.)
MR. STEIN: They had better not have a vote here.
(Laughter)
MR. YANTIS: flow, how many people are here from the
Federal staff? If you would, please.
(A number of people stood up.)
MR. YAiv'TIS: Now, I see a sprinkling of people who
represent industry. I would like for each one of you to stand
if you are a direct industrial representative of any kind.
-------
H. C. Yantis, Jr.
(A number of people stood up.)
MR. YANTIS: Now, I see several people from local
governments, at least I think they are. Are there any people
from the local governmental subdivisions of the State present?
( A number of people stood up.)
MR. YANTIS: I was going to introduce Joe separately.
(Laughter)
I would especially like to take note that the State
| Health Department has one or more representatives back there.
1 Would you please stand.
(A number of people stood up.)
MR. YANTIS: The State Health Department would have
had more representatives present except for the failure of a
letter to be delivered that asked them to be present, but since
i
I they are very deeply involved in shellfish sanitation they have
i
I had a very major part, not only historically but throughout
i
j this conference, in all matters relating to the conference and
especially the shellfish, and I am sorry that they did not have
more time to have fuller representation.
Somewhere back in either the Bible or Shakespeare
or someplace like that there is an old proverb that goes,
approximately: The old order changeth and giveth way to the
new. Mr. Joe Teller, who just stood up back there, was the
-------
• _____ 135
H. C. Yantis, Jr.
Deputy for the Texas Water Quality Board when these conferences
began and under his direction practically all of the State's
presentation was developed. I would like for Joe to stand up
and be recognized historically as the person who helped put all
this together. (Applause)
(Mr. Teller stood up.)
MR. YANTIS: And now he has gone from the frying pan j
into the fire, working with the local governmental unit out
where people can really shoot at you.
I noted with some amusement, I guess I would say—you
know, things are funny always when they happen to somebody
else—the State and the Federal Government, and this conference
especially, have encouraged the elimination of small sewage
treatment plants in favor of larger systems and regional sys-
tems, but let me suggest when you try to eliminate one that the
owner doesn't want to eliminate you can have some real conver-
sations take place (laughter), and I think that Mr. Scarlett
has been aware of some of these. He has taken note of them in
the paper.
I suppose the most important thing that I would say,
when I came into the room I noted the Christmas tree down here
at the end of the row of tables. While technically Christmas
comes once a year, I think that the spirit of it ought to come
-------
_ 136
-H. C. Yantis, Jr. j
all year long and especially I think the spirit cf It should be
the spirit in which a conference of this nature -. -.- the work
growing out of the conference will be conducted. ":'o do it any
other way is simply the wrong way.
I also remark, not ing Mr. Stein's comments, there has
been a new Federal law. It is very detailed and very different
from anything that we have ever had. It does say in the very
beginning that water pollution'control is a State responsibility
and shall be done by the States. At the same time the amount \
i
of money available to the States under this law is, for Texas, j
about half of what we have had in the past and this is a :
severe handicap to the Texas program. But nearly everything i
that is to be done coming out of the shellfish conference, the |
!
techniques, the procedures, are also required under the new ;
Federal law.
I really see no advantage to trying to ride two
*
horses at once, because there is a certain amount of red tape,
and the new law says, which is very down-to-earth language, that
they want to eliminate paper work. That is right in the law.
I have heard the Congressman who wrote it say v,^ \jant to cut
red tape.
And, Mr. Alexander, some of the tape I wish you would
cut has to do with the Public Law 660 grants for the city of
-------
137
I H. C. Yantis, Jr.
i
i
i Houston which have been promised to them for, lo, these many
»
! months and which are in the state of promised but not in cash. !
j i
i j
j MR. ALEXANDER: I think we will have a report on thati
I this morning, Mr. Yantis, that, will make you very happy.
i
j MR. YANTIS: I trust that they will make the Mayor
i even happier than they have made me.
i
| But in the sense that there is a certain amount of
i
j staff time, administrative thought and detail that goes into
carrying forward the work coming out of the shellfish con-
ference, since the same work would be developed under the new
Federal law in the ordinary procedures that we are following
and would be following, it seems to me that we could simplify
things a great deal by simply going at the close of this con-
ference under the Federal law and have this meeting today be
the last meeting of the shellfish conference, since it would
not seem, in view of this fact situation, to be productive
beyond this point as a vehicle in which to work.
So I would like to suggest to the Chairman of this
meeting that we keep in mind the fact that we may have used
this vehicle well and to the fullest, but now there is another
more convenient vehicle under which it might be best that we
work.
Thank you, Murray, for the opportunity to speak.
-------
138
H. C. Yantis, Jr.
I did forget one thing. Except for Al Greene, whom
I know by sight, how many of you are here who simply represent j
the general public and have no direct connection with industry j
or government otherwise? j
(Two or three ladies stood up.)
|
MR. YANTIS: Thank you very much. j
!
MR. STEIN: That shows you why we have pollution j
i
i
control the way we do. I
i
MR. YANTIS: Mr. Stein, if the ladies are like my j
i
wife, it doesn't take very many of them to make a majority.
MR. STEIN: I know that, but they have got to stay
here all the time and they are here on their own time and own
money, while the rest of us are getting paid to sit here. We
usually can outwait them.
MR. YANTIS: Thank you for the opportunity to make
these comments. The major portion of the presentation for the
State will be made under the direction of Dick Whittington, who
is now Deputy, the position which Joe Teller did hold, and
unless it is appropriate later on in the meeting I would have
no more personal comments.
MR. STEIN: Thank you. We welcome your comments at
any time, Mr. Yantis.
I would like to Join with Mr. Yantis in endorsing the
-------
1-39
General Discussion
spirit of Christmas for all of us here. However, I would hope
that the one aspect of Christmas doesn't take over as it usu-
ally does, whenever they invoke the spirit of Christmas and the
Feds are around, immediately they concentrate on us being Santa
Glaus. (Laughter)
MR. YANTIS: Well, Mr. Glaus, it was awfully good
for you to be here anyhow. (Laughter)
MR. STEIN: I have two comments or questions for Mr0
Gallagher and the rest.
One, and I was out of the country for the past couple
of weeks, but I did, even where I was, read a newspaper report
on color removal in the paper industry from Georgia Pacific up
in Maine, in the St. Croix River, indicating that by using
their lipe recovery process they were going to be successful
in removing color.
Now, I wonder, Mr. Gallagher, I recognize the recom-
mendations made on color being held off until something devel-
ops, but I wonder, in view of that Georgia Pacific announcement
and the wide publicity it received, whether possibly another
look at what they are doing up there might be in order or
whether someone has looked at that.
MR. GALLAGHER: Not at that particular one, Mr.
Stein. It was too recent to report on at this session.
-------
140
General Discussion
But I think that your overall thrust is correct that
the technology for color removal is Just about at the thresh-
hold of being incorporated, I would say, now as generally
demonstrable treatment for color.
MR. STEIN: Again, you know, I have tremendous re-
spect for Georgia Pacific because we have had a lot of dealings
with them, but their announcement was that they are going to
patent this and make this available internationally to people
who want color removal, and I would think that the claim should
!
|
be looked at rather closely because they are not given to making
i
i
claims idly or lightly. If they say that they are removing i
i
color, I think that probably would be something that we should j
look at very, very carefully, and if it can be applied to the
paper companies in the Houston Ship Channel in line with the
recommendations, I suggest that it be given full consideration
and evaluation.
MR. GALLAGHER: We will be pleased to do that.
MR. YANTIS: I think it is very appropriate, Mr.
Stein, to look at new developments always and also they should
be used where they can be in the context of the ongoing economy j.
MR. STEIN: Right.
MR. YANTIS: The last figures that I saw that
analyzed the cost of color removal indicated that the cost of
-------
General Discussion ;
color removal was approximately equal to the profit in making j
the paper. At that point, I mean our desire may be to remove
color, it simply is not feasible in the competitive paper |
market so there has to be an additional step some place that -
I :
I lets the color removal be taken out in competition with other :
i
I paper mills that may not be in the United States and in the
i
i
i face of the overall economic situation. There is a real prob-
!
I lem in how much you can do and stay alive.
j MR. STEIN: Oh, that is true. That is the reason I
' always like to give credit to the ones we give and that is why
j I mentioned Georgia Pacific. They have very admirable charac-
i
' teristics as a corporation and one of their most admirable '.
j characteristics is having a penchant for not running a plant ;
I " ;
I where they can't make a profit. If they claim that they are I
removing the color and it is successful, I am sure that that is!
not eating up the profits in their plants. Otherwise they :
wouldn't be putting this forward. i
j
And I would be willing to bet my bottom dollar that ;
that is the essential part of the credo of Georgia Pacific i
in presenting a process of pollution abatement, that it is !
I
economically feasible. ;
i
MR. YANTIS: Well, I certainly sunport your remarks
about looking into it and if it is feasible I certainly expect
-------
142
1 General Discussion
t it to be required in this area.
MR. STEIN: The rest of what I have to say is a
comment, because I think this will lead to the statement
that you made before about the recommendation for the
! conclusion of the conference. I don't think we are pro-
i |
! ceeding in the conference any more.
j f
I But we have a problem that I think has been
i pointed out by Mr. Gallagher in his report. To take one i
! - I
! item, if what he states is correct and we are thinking j
i • I
! in terms of limiting discharge of BOD to 35,000 pounds 1
i i
i |
j in the aggregate in the Houston Ship Channel, and the
! I
| State of Texas has a program to get down to 60,000 pounds'
i • i
! lay December 1973--I am making no judgment on the reason-
i
I ableness or unreasonableness of that program—the entire
| question of the issuance of permits or, indeed, the
i
I question of the Federal Government turning over to the
j State the authority to issue the permits, will relate to
coming to some kind of agreement among the Federal
Government, the State and others to reach an equitable
approach to these matters.
I think we are going to face that in various
areas of the country, and the Houston Ship Channel is a pjrime
example of relatively slack water, a big city, and a lot
L
of
-------
General Discussion
industries discharging into a limited watercourse,.when the
permit requirements may be for the individual, possibly, a
little more stringent than what we consider Class A require-
ments if the plant were located somewhere else. This may be
the cost of doing business in an area like this.
I am not sure that we will be able to resolve that
kind of thing without meetings of this kind. They won't be
done under the conference technique, but I would suspect that
we would have to give the industries, local government, the
States and us an opportunity to get this worked outj and I
think this will probably be more fruitful in the end than
either a turning over of the delegation or authorization of
the program to the State or a denial of a permit to any city
or industry. That is not the object. I think we all recognize
we have a very difficult technical problem to meet the objec-
tives if the 35,000 is going to be valid at all, and the only
way that that can give is by continuous discussion until we have
resolved all the issues here. I am not sure we have done that
yet.
MR. YANTIS: Well, this is true. But I would expect
that that type of continuing conversation, which actually is
going on now, would be between the staff of the Texas Water
Quality Board and the staff of the Dallas EPA office. That is
-------
_____ 144
General Discussion
a perfectly ordinary part of the Dallas office work in
administering the proposed Federal permit system in its
own region and we have those meetings now.
As a matter of fact, to some degree—and Mr.
!
Whittington, I am sure, could talk to this more than I !
j
or maybe some of the others—EPA-Dallas already has drafted
|
out, and I would say these are working inhouse drafts, nolj
for publication, various drafts of what we think might !
well be required for the various industries throughout
the State. We haven't come to any necessary full agree- j
i
ment on all of them as yet. We are talking about them. !
But the only suggestion that I have here is that
!
the conferences you mentioned are necessary, they do exist!
and will continue to exist, but under the Federal law I
think they would be an absolutely ordinary part of the j
|
regional-State relationship rather than a special relation!
i
ship between the State and the Washington office. j
MR. STEIN: Oh, I think you are probably right. j
i
But I think this is a matter of internal organization. I wa$
i
more interested in the other aspect of this. Since these|
i
decisions are so important, I am not quite sure we should)
do this by technical staff meetings only, but we really
should give the public from time to time a peek at what we
-------
General Discussion
are doing—
MR. YANTIS: Mr.—
MR. STEIN: —before we come up with the final
conclusion— i
MR. YANTIS: Mr. Stein— !
MR, STEIN: —and let the industries and the citizens1
groups and the local governments participate.
MR. YANTIS: This is one of the points where I think ;
the State is and has always been ahead of the Federal Govern- !
ment. I could list quite a number of other things too, but
that would be a whole other meeting. (Laughter)
The original recommendation was modified to read as
it now does to point up that so far as the participation of the
State agency is concerned, we participate under State law, and
quite desirably, a State law which requires that every permit
to be amended have a public hearing, full and absolute dis-
closure, notice in the newspaper and by mail to a great list of
people. Every action that we take is taken in public, follow-
ing public hearings, and likewise all of the decisions about
the Houston Ship Channel and more especially those about the
individual waste dischargers are made in public. And I would
hasten to make sure you realize that only about half of them
are industry, the other half are just people, cities, primarily
-------
146
General Discussion
t
Houston but others, and we not only set forth our views i
and comments and knowledge in public hearings but anyone
else can. And what is equally important, the person
making the discharge has an absolute right in public to
say his part, and it is important that the person who
makes a discharge also be fully heard and be heard in public^
i
So I would say that under State law even far
I
more than under Federal law there will be public hearings'
I !
I at every step and we could not and would not proceed in I
i
i
any other fashion. j
i
Which, of course, is one reason that I was intro-j
I
ducing the press. As the Chairman of our agency always says,
they are the principal ways by which hearings and the work of the
agency are made known to the public. More people read
papers than go to public hearings, I can assure you.
MR. STEIN: I would hope so. (Laughter)
MR. YANTIS: Oh, I don't know about that.
MR. STEIN: But I'am glad we are in complete agree-
ment on that, and we are all in agreement, I guess, that we should
do this in the most public manner. The only thing that I can tel]
you is you would like to go public but go public with our
regional office and not the Washington office of EPA. I
have never made that distinction. I always thought we were one
-------
1*17
. |
General Discussion j
government.
But I can appreciate your view.
MR. ALEXANDER: Mr. Stein, if it is all right with
you, I feel like we are sort of left in the middle here. Mr.
Whittington has the last half of the report on this technical
committee to tell us what has happened from April up until now.
So if it is all right with you I would like to call on Mr.
Whittington, whom Mr. Yantis has just introduced as the Deputy
Director of the Texas Water Quality Board and a member of this
technical committee.
Mr. Whittington.
DICK WHITTINGTON, DEPUTY DIRECTOR
TEXAS WATER QUALITY BOARD
AUSTIN, TEXAS
MR. WHITTINGTON: Thank you, Mr. Alexander.
One result of the Galveston Bay Enforcement Conference
i
I
was the formation of the Galveston Bay Technical Committee, a j
committee which Mr. Gallagher has already pointed out is com-
posed of personnel from the staffs of the Texas Water Quality
Board and the EPA. This committee has prepared a formal report
of the progress being made in water quality management in the
Galveston Bay area pursuant to the recommendations of the
-------
148
D. Whittington
conferees and it has been presented to this public meeting.
That is the red book. In addition to this formal report, it
was felt that an informal presentation relative to the progress
being made in reducing pollutant loads and improving the water
quality of the Galveston Bay complex would be relevant and
timely. This is such a report.
Three geographic areas account for the majority of
waste loads discharged into the Galveston Bay complex. These
are the Houston Ship Channel, the Texas City area, and Galveston
Island. These areas will be discussed separately.
Galveston Island is the first.
The largest waste discharger on Galveston Island is
the city of Galveston. The city is committed to a number of
Improvements to its sewerage system, including modifications
and expansion of the main sewage treatment plant. When these
modifications are complete, the BOD contribution to the bay
from this plant is expected to be reduced from a 1972 average
so far of about 4,000 Ibs/day to about 1,100 Ibs/day. This
represents a BOD reduction of 72 percent. The contract for
the construction of these facilities was executed in October
1972 and completion is scheduled to be in 1973.
The second of these three areas is the Texas City
area.
-------
; 149
_ ^
D. Whittington !
!
In January 1972 the BOD load emanating from the
Texas City area amounted In the aggregate to approximately
95,000 Ibs/day of BOD. This is somewhat different from the
one in the report that Mr. Gallagher presented inasmuch as
this number does include municipal contributions, whereas the
report of the technical committee in the red book does not.
This load has been reduced to approximately 82,000 Ibs/day
by the installation of waste treatment facilities by the
I
j Monsanto Company.
i
j This is shown on the slide on the screen. Also, for
j those of you who cannot see the screen, it is page 3 of the
little handout.
It is anticipated that the waste treatment facilities
presently under construction by the Gulf Coast Waste Disposal
Authority and scheduled for completion in 1973 will lower the
aggregate Texas City area daily BOD load to about 50,000 Ibs/
day, a decrease of approximately 30,000 Ibs/day. A waste con-
trol order issued by the Texas Water Quality Board on November
29, 1972, requires the American Oil Company to construct waste
treatment facilities to be completed in mid-1971* which will !
lower the aggregate Texas City area load to approximately
40,000 Ibs/day. Further scheduled waste treatment facilities |
are expected to lower the aggregate BOD load to about 10,000 j
-------
150
_ = I
D. Whittington
Ibs/day by 1975. This is a 90 percent reduction from the BOD
load of 95,000 Ibs/day in early 1972. j
i
The third of the areas which I wish to discuss is
the Houston Ship Channel.
As reported at the original meeting of the shellfish
enforcement conference in June 1971, the BOD load imposed on
the Houston Ship Channel at that time was approximately 130,000
Ibs/day. The load had been decreased to that value from the
1968 load of 430,000 Ibs/day, a reduction of about 70 percent.
In September 1972 the aggregate BOD load on the Houston Ship
Channel was 117,000 Ibs/day.
I*~ was anticipated that the startup of the expanded
city of Houston Northside Plant would result in a further de-
crease in the BOD load. This happened, I think, in December
I
of 1971. Contrary to expectations, when this plant was placed i
|
into operation, difficulties encountered with the sludge handl-
i
ing facilities, compounded by the increased biological sludges j
i
!
generated, resulted in a BOD load increase from this facility. I
Additional sludge handling facilities, expected to correct this
|
problem, are under construction. They are scheduled for com- i
i
pletion in March 1973. Should these facilities perform as i
i
expected, the aggregate BOD load on the Houston Ship Channel i
I
should be decreased to approximately 70,000 Ibs/day in early
-------
D. Whittington
1973. Further waste treatment improvements presently under
j
i construction by Rohm & Haas, Ethyl Corporation, and others,
i
i
should decrease the aggregate BOD load to approximately 60,000
I
Ibs/day during 1973. The.se improvements should result in a 50
percent reduction in the 1971 BOD loads. .These are the changes
which have been made in the waste loads.
i I would like to now discuss with you briefly the
i
i
response of the Galveston Bay complex system to these changes
in waste loads, specifically the Houston Ship- Channel.
At the outset, the water quality in the Houston Ship
Channel remains unsatisfactory. Nevertheless, improvements are
becoming apparent.
Figure 2, which is page 5 of the handout, also shown
on the screen, shows the average BOD concentration at various
locations along the Houston Ship Channel. BOD concentrations,
I
represented by the solid bars, are averages from the Galveston j
i
Bay water quality survey conducted by the Texas State Depart-
!
ment of Health for the period 1963 through 1967. The patterned
!
bars represent 1971-1972 Texas Water Quality Board stream moni-j
toring data. This, figure indicates that the BOD concentrations
at all stations along the channel except Morgan's Point during
the period 1971-1972 are approximately one-half those measured
in 1963-1967. The Morgan^ Point sampling station is influenced
-------
152
D. Whittington
more heavily than sthe others by the better quality bay water
i
i
and it shows no particular trend one way or the other. i
We considered that this graph represents positive !
proof that an improvement in the quality of the water of the
Houston Ship Channel has occurred over the past 5 years. !
I would like to go on with this discussion and dis-
cuss with you dissolved oxygen.
j
At the original meeting of the enforcement conference!
held in Houston in June 1971 the Texas Water Quality Board
reported that the dissolved oxygen concentration at Morgan's
Point appeared to be responding to the decreasing waste loads
being imposed upon the channel, but that there had been no
significant response at that time in the upper reaches of the
channel. It was indicated, however, that a response was
anticipated. We are encouraged to note that this response
has become manifest. ,
I would direct your attention to the slide on the
screen. This particular slide is also shown on page 6 of the
handout.
This graph portrays the dissolved oxygen profile for
the Houston Ship Channel from Morgan's Point to the Turning
Basin at various periods of time. It will be noted that the
average dissolved oxygen has steadily improved over the years.
-------
153
D. Whittlngton
The lower line, shows the dissolved oxygen concentrations which
existed in the lower channel during the period July through
December of 1955. These data are included in an article
entitled "An Ecological Survey of the Houston Ship Channel
and Adjacent Bays" published in the Publications of the
Institute of Marine Science.
The next line up portrays the dissolved oxygen pro-
file which existed in the channel during the period July
through December of 1968. These data were collected by the
Texas A&M University and are available from the Environmental
Engineering Division.
You will note that the dissolved oxygen improved
over the 1955 values.
The next line up portrays the dissolved oxygen
profile which existed in the channel during 1971. These data
were also collected by Texas A&M University.
I
{
The top line represents the dissolved oxygen profile !
which existed in the channel during the period January through
September 1972. These data were collected by the Texas Water ]
j
Quality Board District 7 office and are available from the |
i
Texas Water Quality Board.
It will be noted that a substantial improvement in
the dissolved oxygen profile occurred during 1972. We would
-------
154
D. Whittington
hasten to point out that even with this improvement the
dissolved oxygen concentration is from time to time zero in
the upper reaches of the channel and we do not consider the
channel to be in acceptable condition. Further improvements
are needed and will be made.
Now I would like to show you a slide which is not
in the handout but which I think is significant. This partic-
ular slide was constructed from data collected by Texas A&M
!
i
| University and it shows the miles of the Houston Ship Channel
i
j which have been brought into compliance with the 2 mg/1 oxygen
i
j requirements since 1969 broken into two forces of summer months
l
i and winter months.
You note in 1970 there was Just a very, very slight
j improvement in the summer months, maybe 0.2 of a mile or some-
i thing of the sort. In 1971 It was about 4.5 miles and in 1972
about 5.5 miles. Those mileages would be measured from the
1969 values.
The winter months show somewhat the same picture,
with a few larger numbers than you would expect because of the
cooler temperatures.
Now, there is a little peculiarity in these data in
the sense that the summer months for 1971 show a better situ-
ation than the winter months, and I have no explanation for
-------
155
D. Whittington
this. But I do think that this slide does represent a positive
improvement in the dissolved oxygen situation in the Houston
Ship Channel. j
Next I would like to discuss with you bacteriological
quality.
Bacteriological quality again, as indicated with
dissolved oxygen, is still unsatisfactory. This is largely
due to the lack of chlorination at the city of Houston's Sims
Bayou plant. Chlorination facilities are under construction
and completion is expected by March 1, 1973. The city did
i
t
i have a construction accident which delayed the completion of
i
these facilities by 3 months. They were originally scheduled,
as you will recall, for completion in December of this year.
Nevertheless, with respect to bacteriological
quality, some progress has been made in Improving the quality
in the lower reaches of the Houston Ship Channel. For example,
at the San Jacinto Monument, the geometric mean of the coliform
most probable number data show an MPN of 2,044 for the 1972
data.
This graph is reproduced on page 7 of your handout.
This is contrasted to the geometric mean of 25,000
for the period 1963 through 1967, inclusive. It will be noted
that the 1972 value is only 8 percent of the 1963-1967 value.
-------
156
D. Whittington
Similar data for Morgan's Point shows an MPN reduction from
500 to 80. This is shown on page 8 of the handout.
With respect to biological quality, commencing in
February- of 1972 the District 7 office of the Texas Water
•
Quality Board commenced a biological monitoring program of
the Houston Ship Channel. This program was commenced on
October 19, 1971, following the appearance of shrimp, crabs
and fin fish in the channel approximately 2 miles upstream
from the San Jacinto Monument. This was the first occurrence
of this type of aquatic life at this point in the channel for
many years. Since that time, fin fish, shrimp, and crabs have
been present in the water at this location on every occasion
that the district office has sampled.
During the 1972 regular sampling runs made under this
program until November, no fin fish, crabs, or shrimp have been
recovered at the sample station located 11 miles upstream from
the San Jacinto Monument. On the most recent sampling run,
November 28, 1972, the best water quality conditions to date
were measured and marine fin fish and crabs were recovered at
this station. To our knowledge, this is the farthest point
upstream that this type of aquatic life has been noted in
recent years. These migrations are indicative of a general
improvement of water quality in the Houston Ship Channel.
-------
. __ _15_7
D. Whlttlngton
In addition to shrimp, crabs ana fin fish, the
District 7 office has sampled plankton populations at five
stations on the Houston Ship Channel in February, March, May,
June, August, and September 1972. The species diversities of
the plankton population at the various stations are shown in
Figure 6. This is page 10 of your handout. It will be noted
that species diversity increased from 0.4 at the Turning Basin
to 1.4 at Morgan's Point. A species diversity of around 2.0
is generally indicative of unpolluted or natural conditions.
These data indicate that the biological conditions of the upper
portion of the Houston Ship Channel are generally poor. How-
ever, the areas around the monument and Morgan's Point have
shown a marked increase in both number of species and total
individuals.
Based on physiochemical, bacteriological, and
biological data, it has been demonstrated by the foregoing
discussion that the water quality in the Houston Ship Channel
has been improved by the pollution abatement efforts made. Ever
though progress has been made, additional improvement is re-
quired and will be forthcoming.
The next thing that I would like to discuss is the
Joint Texas Water Quality Board-EPA waste source survey.
Recommendation No. 7 of the Galveston Bay Enforcement
-------
D. Whittington i
i
Conference dictates that the Texas Water Quality Board and the j
j
Environmental Protection Agency cooperate in an intensive waste i
source survey of the waste dischargers to the Galveston Bay ;
complex for the purpose of determining for the various waste
dischargers the implementation schedules for meeting Federal- ''•
State water quality standards. This joint effort commenced in '
April 1972 and has progressed in a satisfactory manner. ;
A complete field survey consists of a preliminary ;
conference followed by a 3-day composite sampling program. The ;
preliminary conference is held with a company's technical
representatives to orient the sampling team and to gather back- !
ground data. After a thorough evaluation of the background :
data, the sample team selects appropriate sampling points and j
!
returns to the plant site for the intensive sampling effort. !
When analytical data from the sampling program is j
j
available, a draft of a final report is made. These drafts j
!
are Jointly prepared by the Texas Water Quality Board and the j
I
Environmental Protection Agency field offices. After review by j
the joint Texas Water Quality Board-EPA technical committee, the
report is finalized and discussions are held with the discharg-
ing industry or municipality relative to the findings and
recommendations of the final report.
-------
159
D. Whittington
i
The effort to date has been directed to industries
and municipalities discharging into the Houston Ship Channel.
As of October 1, 1972, a total of 19 preliminary conferences
with industries and municipalities have been held. Fourteen
waste sources have been sampled and two final reports have been j
completed. The waste sources already surveyed represent
approximately 83 percent of the BOD load on the Houston Ship
Channel.
In the interest of reviewing the major waste dis-
chargers first, the intensive waste source survey effort is
now being directed to the Texas City area. Preliminary con-
ferences have already been held with the major industries in
the Texas City area and sampling is scheduled to commence in
December. It is anticipated that the sampling work in the
Texas City area will be concluded sometime in January 1973.
With the advent of the 1972 amendments to the
Federal V/ater Pollution Control Act, the National Pollutant
Discharge Elimination System was inaugurated. This system is
to be administered by the Environmental Protection Agency.
Provisions are made>in the Act for the administration of this
program to be transferred to the States if the State program
conforms to the provisions of the Act and guidelines to be
promulgated by the Administrator of EPA. The Act envisions the
-------
16 o
i —
I D. Whittington
i
I
I EPA providing continued supervision of the program. The status
! of the transfer of this program to the State of Texas is as yet
unresolved. And Mr. Yantis and Mr. Stein discussed this previ-
ous ly.
Now, regardless of who actually issues the permits
regulating the various waste dischargers to the Galveston Bay
complex, it is expected that the intensive waste source survey .
I
findings will be utilized in the continuing effort of deriving i
appropriate effluent limitations and implementation schedules.
In summary, Mr. Chairman, programs presently under
way are expected to reduce the pollutant load from Galveston
Island 72 percent during 1973, from the Texas City area 90
percent by the end of 1975, and from the Houston Ship Channel
! 50 percent by the end of 1973. It is recognized that this
I reduction may not be adequate, and joint efforts by the Texas
] Water Quality Board and the EPA are continuing which will re-
j
suit in continued reductions.
We are encouraged to note that the water quality in
the Houston Ship Channel continues to improve. Improvements !
: t
have been noted in phyBiochemical measurements, bacteriological j
I
measurements, and most significantly by the migration of marine |
i
fin fish, crabs and shrimp into areas of the channel where they
have not been seen for many years.
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161
1
D. Whittington I
i
i
i
!
Mr. Chairman, that concludes my report. j
MR. STEIN: Mr. Whittington, would you like this
whole report, including the Charts, to be included into the j
record as if read?
MR. WHITTINGTON: Yes, sir, I would. i
MR. STEIN: Without objection, that will be o.c:\e.
(The above-mentioned report follows:) !
-------
162
Water Quality Report
Galveston Bay Complex
State of Texas
Prepared for
Public Meeting, Galveston Bay Enforcement Conference
Houston, Texas
December 5, 1972
by
Texas Water Quality Board
-------
163
TABLE OF CONTENTS
I . INTRODUCTION
II. CHANGES IN POLLUTION LOADS
A. Galveston Island
B. Texas City Area
C. Houston Ship Channel
III. IMPROVEMENTS IN THE HOUSTON SHIP CHANNEL WATER QUALITY
Ao Biochem_cal Oxygen Demand
B. Dissolved Oxygen
C . Bacteriological Quality
D. Biological Quality
E. Summary
IV. JOINT TWQB-EPA WASTE SOURCE SURVEY
V. SUMMARY
-------
164
WATER QUALITY REPORT
GALVESTON BAY COMPLEX
STATE OF TEXAS
I. INTRODUCTION
One result of the Galveston Bay Enforcement Conference was the
formation of the Galveston Bay Technical Committee - a committee
composed of personnel from the staffs of the Texas Water Quality
Board and the EPA. This committee has prepared a formal report
of the progress being made in Water Quality Management in the
Galveston Bay area pursuant to the recommendation of the conferees
and it has been presented to this public meeting. In addition to
this formal report, it was felt that an informal presentation rela-
tive to the progress being made in reducing pollutant loads and in
improving the water quality of the Galveston Bay complex would be
relevant and timely. This is such a report.
II. CHANGES IN POLLUTION LOADS
Three geographic areas account for the majority of waste loads
discharged into the Galveston Bay complex; these are the Houston
Ship Channel, the Texas City area, and Galveston Island. They
will be discussed separately.
A. Galveston Island. The largest waste discharger on Galveston
Island is the City of Galveston. The City is committed to a
number of improvements to its sewerage system, including modifi-
cations and expansion of the Main Plant. When these modifications
are complete, the BOD contribution to the Bay from this plant is
expected to be reduced from a 1972 average of about 4,000 pounds/
day to about 1,100 pounds/day. This represents a BOD reduction
of 72%. The contract for the construction of these facilities
was executed in October 1972, with completion scheduled in 1973.
B. Texas City Area. In January 1972, the BOD load emanating from
the Texas City area amounted in the aggregate to approximately
95,000 pounds/day of BOD. This load has been reduced to approxi-
mately 82,000 pounds/day by the installation of waste treatment
facilities by the Monsanto Company.
It is anticipated that the waste treatment facilities presently
under construction by the Gulf Coast Waste Disposal Authority
and scheduled for completion in 1973 will lower the aggregate
-------
165
Texas City area daily BOD load to about 50,000 pounds, a decrease
of approximately 30,000 Ibs/day. A waste control order issued by
the Texas Water Quality Board on November 29, 1972, requires the
American Oil Company to construct waste treatment facilities to
be completed in mid-1974 which will lower the aggregate Texas City
area load to approximately 40,000 Ibs/day. Further scheduled waste
treatment facilities are expected to lower the aggregate BOD load
to about 10,000 pounds per day by 1975. This is a 90% reduction
from the BOD load of 95,000 pounds/day in early 1972 (see Figure 1).
C. Houston Ship Channel. As reported at the original meeting of
the Shellfish Enforcement Conference in June 1971, the BOD load
imposed on the Houston Ship Channel at that time was approximately
130,000 pounds/day. The load had been decreased to that value
from the 1968 load of 430,000 pounds/day, a reduction of about
70%. In September 1972, the aggregate BOD load on the Houston
Ship Channel was 117,000 pounds/day„
It was anticipated that the startup of the expanded City of Houston
Northside Plant would result in a further decrease in the BOD load.
Contrary to expectations, when this plant was placed into operation,
difficulties encountered with the sludge handling facilities, com-
pounded by the increased biological sludges generated, resulted in
a BOD load increase from this facility. Additional sludge handling
facilities, expected to correct the problem, are under construction.
They are scheduled for completion in March 1973. Should these
facilities perform as expected, the aggregate BOD load on the
Houston Ship Channel should be decreased to approximately 70,000
pounds/day in early 1973. Further waste treatment improvements
presently under construction by Rohm & Haas, Ethyl Corporation,
and others, should decrease the aggregate BOD load to approximately
60,000 pounds/day during 1973. These improvements should result
in a 50% reduction in the 1971 BOD loads.
III. IMPROVEMENTS IN THE HOUSTON SHIP CHANNEL WATER QUALITY
At the outset, the water quality in the Houston Ship Channel
remains unsatisfactory. Nevertheless, improvements are becoming
apparent.
A. Biochemical Oxygen Demand. Figure 1 shows the average BOD
concentrations at various locations along the Houston Ship Channel.
The BOD concentration represented by the solid bars are averages
-------
166
FIGURE I
TEXAS CITY
BOD Load Contributed by Major Dischargers
too
oo
o
>»
o
•o
*x
in
•a
§ 60
o
a.
«*-
o
(A
TJ
§
O
a
o
OQ 20
0
New treatment facilities
in operation
. . . ............ — - — MONSANTO -Cooling water
separation and primary
treatment
.UNION CARBIDE-Phase I
Secondary
.MONSANTO ~ Treatment
•-UNION CARBIDE-Phase IE
CM
tr
P2
CM
h-
0)
IO
js.
0)
rO
N
0)
g
8
(O
r-
>
-------
167
from the Galveston Bay Water Quality Survey for the period 1963-
1967. (1) The patterned bars represent 1971-1972 Texas Water Quality
Board stream monitoring data.<2) This figure indicates that the
BOD concentrations at all stations along the Channel except Morgan's
Point during the period 1971-1972 are approximately one half those
measured from 1963-1967. The Morgan's Point sampling station is
influenced more heavily than the others by the better quality bay
water. Figure 2 is positive proof of an improvement over the past
five years in the quality of water in the Houston Ship Channel .
B. Dissolved Oxygen. At the original meeting of the Enforcement
Conference held in Houston in June 1971, the Texas Water Quality
Board reported that the dissolved oxygen concentration at Morgan's
Point appeared to be responding to the decreasing waste loads being
imposed upon the Channel, but that there had been no significant
response at that time in the upper reaches of the Channel. It
was indicated, however, that a response was anticipated. It was
encouraging to note that this response has become manifest.
Figure 3 portrays the dissolved oxygen profile for the Houston Ship
Channel from Morgan's Point to the turning basin at various periods
of time. It will be noted that the average dissolved oxygen has
steadily improved over the years. The lower line shows the dissolved
oxygen concentrations which existed in the lower Channel during the
period July through December of 1955. These data are included in
an article entitled "An Ecological Survey of the Houston Ship
Channel and Adjacent Bays" published in the Publications of the
Institute of Marine Science.' '
The green line portrays the dissolved oxygen profile which existed
in the Channel during the period July through December of 1968.
These data were collected by Texas A&M University and are available
from the Environmental Engineering Division.^
It will be noted that the dissolved oxygen concentrations in the
Channel increased slightly between 1955 and 1968.
The red line portrays the dissolved oxygen profile which existed
in the Channel during 1971. These data were also collected by
Texas A&M University.^4'
The blue line represents the dissolved oxygen profile which existed
in the Channel during the period January through September 1972.
These data were collected by Texas Water Quality Board District 7
-------
HOUSTON SHIP CHANNEL
14.0
12.0
•
10.0
Q_ 8.0
03 E
6.0
4.0
2.0
1
1
1
'
__i • •
xg
XX
xx
Rx
XX
XX
XV
•"^A
R5<
Rx
R5<
X>c
xx
x5<
x>
x$
xS<
>Cx
>so
80
SOx
es?
x>
>Cx
>$
jcr
Xx
S?v
f^ri
Xx
XV
60
60
60
XX
X><
60
1
i !
1
Turning Sim's Green's Monument Morgan's
Basin Bayou Bayou Point
n i
'63 -'67 '71 -'72
Average Average
o\
oo
-------
HOUSTON SHIP CHANNEL
169
Jan.-Sept
1972
(TWQB)
(5 sample
Jan.- Dec
1971
(TAMU)
(35 samples)
July-Dec.
1968
(TAMU)
(45 samples)
July-Dec
1955
"(Humble)
(24 samples)
T
Turning
Basin
12
Channel Miles
8
0
Morgan's
Point
-------
Houston Ship Channel
170
o
o
o
o
at
San Jacinto Monument
1963-67
CM
O> O
O O
1972
-------
Houston Ship Channel
171
:: 500
o
o
o
"^ 400
a. 300
o>
o
a>
o>
o
200
100
at
Morgans Point
1963-67
1972
8
-------
172
representatives and are available from Texas Water Quality Board,
Austin, Texas.(2)
It will be noted that a substantial improvement in the dissolved
oxygen profile occurred during 1972. We would hasten to point
out that even with this improvement, the dissolved oxygen is from
time to time zero, and we do not consider the Channel to be in
acceptable condition. Further improvements are needed, and will
be made.
C. Bacteriological Quality. Bacteriological quality of the
Houston Ship Channel is still unsatisfactory. This is largely
due to the lack of chlorination at the City of Houston's Sims
Bayou Plant. Chlorination facilities are currently under construc-
tion, with completion expected by March 1, 1973.
Nevertheless, some progress has been made in improving the bacterio-
logical quality in the lower reaches of the Houston Ship Channel.
For example, at the San Jacinto Monument (See Figure 4), the
geometric mean of the coliform most probable number data .show an
MPN of 2,044 for the 1972 data,^2' as opposed to a geometric mean
of 25,000 for the period 1963 through 1967 inclusive.t1) It will
be noted that the 1972 value is only 8% of the 1963-1967 value.
Similar data for Morgan's Point shows an MPN reduction from 500
to 80 (See Figure 5).
D. Biological Quality. Commencing in February 1972, the District 7
office of the Texas Water Quality Board has conducted a biological
monitoring program of the Houston Ship Channel. This program was
commenced on October 19, 1971, following the appearance of shrimp,
crabs and fin fish in the Channel approximately 2 miles upstream
from the San Jacinto Monument. This was the first occurrence of
this type of aquatic life at this point in the Channel for many
years. Since that time, fin fish, shrimp, and crabs have been
present in the water at this location on every occasion that the
district office has sampled.
During the 1972 regular sampling runs made under this program until
November, no fin fish, crabs, or shrimp have been recovered at the
sample station located 11 miles upstream from the San Jacinto
Monument. On the most recent sampling run (November 28, 1972) the
best water quality conditions, to date, were measured and marine
fin fish and crabs were recovered at this station — to our know-
ledge, the farthest point upstream that this type of aquatic life
-------
Plankton Diversity Indices for the Houston Ship Channel
o
CHANNEL MILES
-------
has been noted in recent years. These migrations are indicative
of a general improvement of the water quality in the Houston Ship
Channel.
In addition to shrimp, crabs and fin fish, the district office has
sampled'plankton populations at five stations on the Houston Ship
Channel in February, March, May, June, August, and September, 1972.
The species diversities of the plankton population at the various
stations are shown in Figure 6. It will be noted that species
diversity increased from 0.4 at the turning basin to 1.4 at
Morgan's Point. (5) A species diversity of around 2.0 is generally
indicative of unpolluted or natural conditions. These data indicate
that the biological conditions of the upper portion of the Houston
Ship Channel are generally poor; however, the areas around the
Monument and Morgan's Point have shown a marked increase in both
.number of species and total individuals.
E. Summary, Based on physicochemical, bacteriological, and biolo-
gical data, it has been demonstrated by the foregoing discussion
that the water quality in the Houston Ship Channel has been improved
by the pollution abatement efforts made. Even though progress has
been made, additional improvement is required and will be forthcoming
IV. JOINT TWQB-EPA WASTE SOURCE SURVEY
Recommendation number 7 of the Galveston Bay Enforcement Conference
dictates that the Texas Water Quality Board and the Environmental
Protection Agency cooperate in an intensive waste source survey
of the waste dischargers to the Galveston Bay complex for the
purpose of determining the various waste dischargers implementation
schedules for meeting Federal-State water quality standards. This
joint effort commenced April 1972 and has progressed in a satis-
factory manner (See Figure 7). A complete field survey consists
of a preliminary conference followed by a three-day composite
sampling program. The preliminary conference is held with a
company's technical representatives to orient the sampling team
and to gather background data. After a thorough evaluation of the
background data, the sample team selects appropriate sampling points
and returns to the plant site for the intensive sampling effort.
When analytical data from the sampling program is available, a
draft of a final report is made. These drafts are jointly pre-
pared by the TWQB and EPA field offices. After review by the
joint TWQB/EPA technical committee, the report is finalized, and
discussions are held with the discharging industry or municipality
relative to the findings and recommendations of the final report.
11
-------
JOINT TWQB-EPA INTENSIVE WASTE SOURCE SURVEY
FIGURE 7
— -•• r
ENTITY
Ethyl Corporation
DuPont
Crov;n Central Pet.
S inclair-Koppers
H umta 1 e
Petro-Tex, Inc.
Shell Chemical
Arco Refining
Champion Papers
Southland Pnp->r
City of Houston
(Northside & Si.Tis SIP)
Goodvear Synthetic
( Rubber)
Olin Corp.
Shell Oil
Diamond Shamrock
(Deer Park)
Diamond Shamrock
(Greens Bayou)
Tenneco
Premier Pe'.ro Chem.
Pl-r. 11 ips Co.
Roir:nr,-P' rlc
Charter Oil
Reichhold Chemical
Union Carbide
Union Carbide
American Oil
Monsanto
Armco
COV.rE HENCE
•i/12/72
4/14/72
4/2 ,/72
5/3/72
5/4/72
VB/72
:;./9/72
5/10/72
5/24/72
5/25/72
5/31/72 &
c/28/72
Vl/72
-V8/72
b/21/72
6/28/72
7/13/72
7/19/72
7/26/72
3/2/72
• 10/2/72 &
10/12/72
10/19/72
10/26/72
10/31/72
11/7/72
11/14/72
11/21/72
. SCHED.UL
SAMPLING
4/17/72
4/25/72
5/4/72 &
6/7/72
7/10/72
6/19/72
5/15/72
5/30/72
5/23/72
6/26/72 &
6/15/72
7/24/72
9/5/72 &
9/11/72
6/13/72
0/21/72 &
8/28/72
10/10/72
9/25/72
1Q/1V72
10/24/72
12/72
12/72
12/72
p
DATA
COMPLETION
6/17/72
V14/72
5/17/72
8/2/72
8/11/72
6/8/72
8/2/72
8/2/72
8/14/72
8/14/72
11/72
8/2/72
10/30/72
COMPLETE
REEQBT
8/14/72
9/20/72
10/20/72
\J\
-------
176
The effort to date has been directed to industries and municipalities
discharging into the Houston Ship Channel. As of October 1, 1972,
a total of nineteen preliminary conferences with industries and
municipalities has been held. Fourteen waste sources have been
sampled and two final reports have been completed. The waste
rources already surveyed represent approximately 83% of the BOD
load on the Houston Ship Channel.
In the interest of reviewing the major waste dischargers first.
the intensive waste source survey effort is now being directed to
the Texas City area. Preliminary conferences have already been
held with the major industries in the Texas City area and sampling
is scheduled to commence in December. It is anticipated that the
sampling work in the Texas City area will be concluded sometime
in January 1973.
With the advent of the 1972 amendments to the Federal Water Pollution
Control Act, the National Pollutant Discharge Elimination System was
inaugurated. This system is to be administered by the EPA. Provi-
sions are made in the Act for the administration of this program to
be transferred to the States if the State program conforms to the
provisions of the Act and guidelines to be promulgated by the
Administrator of EPA. The Act envisions the EPA providing continued
supervision of the program. The status of the transfer of this
program to the State of Texas is as yet unresolved.
Regardless of who actually issues the permits regulatinc the various
waste dischargers to the Galveston Bay complex, it is expected that
the intensive waste source survey findings will be utilized in the
continuing effort of deriving appropriate effluent limitations and
implementation schedules.
V. SUMMARY
In summary, programs presently under way are expected to reduce the
pollutant load from Galveston Island 12% during 1973. from the
Texas City area 90X. by the end of 1975, and from the Houston Ship
Channel 50/J by the end of 1973. It is recognized that this reduction
may not be adequate, and joint efforts by the Texas Water Quality
Board and the EPA are continuing which will result in continued
reductions.
13
-------
177
We are encouraged to note that the water quality in the Houston
Ship Channel continues to improve. Improvements have been noted
in physicochemical measurements, bacteriological measurements,
and most significantly by the migrations of marine fin fish,
crabs and shrimp into areas of the Channel where they have not
been seen for many years.
14
-------
178
REFERENCES
(1) Galveston Bay Water Quality Survey (1963-1967) . May, 1968.
Texas State Department of Health, Austin, Texas.
(2) Stream Monitoring Program Computer Print-Out. 1971-1972.
Texas Water Quality Board, Field Operations Division,
Surveillance Section, Austin, Texas. Unpublished.
(3) Chambers, Gilbert V. and Albert K„ Sparks. 1959. An Eco-
logical Survey of the Houston Ship Channel and Adjacent Bays.
Publ. Institute of Marine Sci., Vol. 6, p. 213-250.
(4) Houston Ship Channel Water Quality Data. 1968 and 1971.
Texas A&M University, Environmental Engineering Division.
Unpublished.
(5) Water Quality Related Trends and Conditions of the Confined
Houston Ship Channel. 1972. Texas Water Duality Board,
Field Operations Division, Austin, Texas. Unpublished Report
by District 7 Office.
15
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179
D. Whittington
MR. STEIN: Before we throw this open for comment, 1
would like to say, Dick, that it was an excellent report indeedj
As you know, I have listened to many State reports and Federal
reports through the years. I think this was succinct, candid,
and to the point.
Thank you very much.
MR. WHITTINGTON: Thank you.
MR. STEIN: Are there any comments or questions?
j4
MR. ALEXANDER: I have none.
Thank you, Mr. Whittington. We appreciate it very
much.
MR. WHITTINGTON: Thank you, sir.
MR. ALEXANDER: Mr. Stein, I would like to call on
Mr. George Putnicki of the Environmental Protection Agency.
Mr. Putnicki is the Director of our Surveillance and Analysis
Division, which is in charge of the laboratory facilities that
EPA has in Houston, and I would like for him to report to the
conference on what resources have been put into this conference
carrying out its recommendations.
Mr. Putnicki.
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180
G. J. Putnicki
GEORGE J. PUTNICKI, DIRECTOR
SURVEILLANCE AND ANALYSIS DIVISION
U. S. ENVIRONMENTAL PROTECTION AGENCY, REGION VI
„ DALLAS, TEXAS -
MR. PUTNICKI: Mr. Chairman, conferees, and ladies
and gentlemen.
My name is George Putnicki. I am the Director of
the Surveillance and Analysis Division of the Environmental
Protection Agency, Region VI, Dallas, Texas.
In order to implement the conferees' recommendations
for the called conference in the matter of the pollution of the
navigable waters of GalvestonBay and its tributaries held at
the Rice Hotel in Houston, Texas, on June 7 through June 12,
1971, and reconvened at the Shamrock Hotel November 2 and 3,
1971, a facility was established at 6608 Hornwood in Houston,
Texas. This facility has a total area of 13,040 square feet
and contains chemical, biological, and microbiological labora-
tories, offices, storage area, conference rooms, and a library.
Currently housed at this facility are 16 full-time
permanent and 4 temporary Environmental Protection Agency
professional, technical, administrative, and clerical personnel
and 4 full-time Texas Water Quality Board chemists.
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181
i
G. J. Putnicki !
' With the current complement of Environmental Protec- '
j tion Agency and Texas Water Quality Board personnel, this facilr
! ity is capable of running the following physical, chemical, \
'' biological, and microbiological analyses on a routine basis: >
: pH, temperature, BOD, COD, nutrients, color, chlorides,
; cyanides, phenols, sulfates, sulfides, solids, pesticides, ;
i !
| coliforms, both total and fecal, fecal streptococci, static
!
i bioassay, 27 heavy metals, complex organic analyses, total
i
i '
\ organic carbon, and total inorganic carbon.
|
i The major pieces of equipment include a gas chromato-
j graph, mass spectrometer, two other gas chromatographs, one i
!
atomic absorption unit, one total organic carbon analyzer, one
infrared spectrophotometer, and a technicon auto analyzer.
I
I In addition it contains a fully-equipped microbio-
I
logical laboratory and a biological laboratory with static and !
flow-through bioassay capabilities. In addition to the fixed
laboratory equipment, this facility also operates a mobile
i
!
biological laboratory equipped for flow-through bioassay. For j
I
i
use in stream and estuarine sampling, the facility operates a j
25-foot Bertram boat powered with a twin 110 horsepower inboard/
outboard engine, has an 18-foot flat-bottomed boat powered with
a 25 horsep.ower outboard engine, and has a 16-foot Crestliner
powered with a 40 horsepower outboard engine.
-------
182
G. J. Putnicki
The facility is utilized as a joint Environmental
Protection Agency-Texas Water Quality Board facility. Sampling
crews, that Dick mentioned earlier, conducting intensive point !
i
source surveys consist of one EPA and -one Texas Water Quality
Board staff personnel. Sampling equipment, vehicles and boats
are all shared by the two agencies. The analytical laboratory
load is shared by the two agencies and the data generated is
jointly evaluated.
In addition to the water quality monitoring activities
being conducted at this facility—I recognize this is a water
conference but I feel I should mention this—it is also the
focal point for a coordinated city, county, State and Federal
ambient air monitoring activity. Personnel from the facility
assist in the cooperative project to operate an air monitoring
trailer in the downtown Houston area. The air monitoring trailer
is equipped to measure NOg, carbon monoxide, suspended partlcu-
late matter, and plans are under way to add equipment capable
of measuring ozone. EPA facility personnel also assist State
and local air pollution control personnel in calibration and
maintenance of other ambient air monitoring equipment located
in this area.
It is anticipated that the current Federal-State
waste source surveys being conducted at this facility will be
-------
183
------- |
G. J. Putnicki |
i
i
expanded to include similar intensive point source and inten- i
sive basin surveys in other high priority basins in the State
of Texas. This facility's personnel will continue to respond
i to emergencies such as major oil and hazardous materials spills,,
provide technical assistance to State and local agencies, and !
support other ongoing EPA-Texas Water Quality Board programs.
The operation of this facility is considered unique
in that Federal, State and local personnel are pooled to con-
duct the necessary field investigations, laboratory analyses,
i
i and data evaluations to efficiently fulfill our responsibilities
as recommended in the conference held last year.
This facility will be formally dedicated in January
1973- I would like to take this opportunity to extend a wel-
come to those in attendance to visit this facility and see your
tax money at work.
In closing I would like to introduce the EPA facility
manager, who is in attendance, I hope, Mr. Malcolm Kallus.
There he is.
Thank you very much.
MR. ALEXANDER: Thank you, Mr. Putnicki.
MR. YANTIS: Mr. Chairman, I wonder if I could ask a
question that has bothered me for a number of occasions?
MR. STEIN: Yes.
-------
184
I " '"' !
I G. J. Putnicki I
| |
i MR. YANTIS: Speaking of tax money, we have a State I
i " !
I Health Department laboratory which we have historically used i
i ' ;
! and which, of course, works on a cost basis for the "water
i j
! Quality Board. We have used in this area the tax-supported i
I I
i laboratory of the city of Houston, which, with a predictable
i .
I workload, can handle a great many things. The Texas ASM :
i
i
j system has a fairly major laboratory facility down somewhere ;
! :
i around the LaPorte area and they look to us for a great deal
j of their workload, which, of course, supports them financially
i ;
! and without our workload and our payment for the analyses they ;
I have made they could hardly exist. We have this new Federal :
laboratory.
j I have some casual curiosity as to how are all of
i these coordinated to make sure that our tax money is used
I efficiently, that we simply do not have more laboratories
than we need?
MR. STEIN: Do you want to try that, George?
MR. PUTNICKI: Sure.
As far as our facility is concerned, I think that I
can very well say it is one of the best coordinated Federal-
State activities that we have going on. You need a program
when you walk into that laboratory because you don't know a
State man from a Federal man. This is the kind of an operation
-------
185
G. J. Putnicki
I think that makes some sense instead of duplicating a bunch
of effort where we are going two different directions. We are
working together on a problem and I feel very good about the
fact that we are doing the job and doing it with the least cost.
Now, the other facilities you mentioned, I am famil-
iar with the A&M portable laboratory facilities down around
Morgan's Point. I think they are excellent facilities. They
have their specific projects that they are working on, many of
which, incidentally, are funded by EPA through the research
programs. They have one function; we have another function at
j Monterey Park.
I think that we can in fact justify a large laboratory
in this metroplex where we have a couple of million people or
several million people and along with the people come environ-
mental problems.
MR. STEIN: Are there any other comments?
I would like to associate myself with'what Mr. Yantis
said. I have always been puzzled. I recognize that you have
done a job in that laboratory you have of integrating the people
there, but there was another thrust to Mr. Yantis' question.
This is not the only problem because you are not the
only laboratory and we always have this question of various
people having laboratories and getting them at various stages
-------
186
r """"
G. J. Putnicki
and the question, I think, that is vital for all of us is
the coordination of those laboratories. I think that is
something we have to pay increasing attention to. As a
matter of fact, this has been acu-tely brought home to me.
Very often when we have a national program where we are
gathering evidence, I often find that getting the same
sample to different laboratories gets different results.
We have to put in a crash program, so that when these
fellows split a sample of the same material between one
laboratory in one part of the State and another in anothejr
part of the State, or one in one part of the country and
another in another part of the country, they come up with
the same answer.
But I think Mr. Yantis is speaking to a very,
very fundamental problem. So when we set up any facilities.
I
I in order to get the biggest bang for the buck out of our i
: !
; i
i tax dollar, we have to work out a way of getting them
i
| integrated. I know that is difficult, and that is cer-
i
) tainly part of what we are trying to do in our Federal
i
| programs by meetings like this with the State. Maybe
everyone isn't happy, but I suspect you are going to havej
to do the same thing with the laboratories in order to
get them together and not fritter away tax funds.
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187
G. J. Putnicki
MR. ALEXANDER: Mr. Stein, with your permission I
would like to comment on that.
MR. STEIN: Yes.
MR. ALEXANDER: This is a concern to many, many people!,
and as a matter of fact, right now it is a great concern to
Congress and OMB. As a matter of fact, they have impounded all
laboratory construction funds until there can be a complete
j evaluation made of the many laboratory facilities that are
available, and there are not going to be any more new ones, and
i possibly there are going to be a number closed to get these
efficiencies that we need with the tax dollars.
I think Mr. Putnicki hesitates to say because I am
on him all the time about it. We have this problem within the
region and we are making great progress towards overcoming it.
I would say that the Houston laboratory operation
with the State of Texas is the most efficient within this
region, and without bragging it is the .most efficient within
EPA.
MR. PUTNICKI: Glad you said that.
MR. STEIN: Great. That shows you, with the concern
for the tax dollar and where we are, I know I am in the State
of Taxes now. (Laughter)
MR. PUTNICKI: Mr. Stein, I think that this internal
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188
G. J. Putnicki
laboratory problem of EPA is not exactly what Mr. Yantis had
reference to. He had reference to the university laboratories,
other State laboratories.
MR. STEIN: Yes.
MR. PUTNICKI: And I think that these are all Justi-
fied. They each have a specific function, a different function.
I think Just very recently you saw the data that was
obtained by Texas A&M University from their survey. This is
not a duplication of what we are doing. This is complementing
or supplementing the work that the Texas Water Quality Board anc
EPA are doing in the way of sampling on the ship channel and
Galveston Bay.
MR. STEIN: I appreciate your point of view. I wish
I could be as certain and as optimistic as you are.
Thank you.
MR. ALEXANDER: Thank you, Mr. Putnicki.
MR. YANTIS: George, after you give me a set of
samples and your analyses I will send them out to Edna Wood
back there and find out if you did them right. (Laughter)
MR. ALEXANDER: Mr. Stein, I would now like to call
on Mri Ken Kirkpatrick for a report on the grants program that
Mr. Yantis was interested in earlier in the city of Houston.
Mr. Kirkpatrick is Director of the Office of Grants
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189
_ . -)
K. Kirkpatrick
I
i
Coordination in Region VI of the U. S. Environmental Protection!
Agency in Dallas, and I think he can give us a current report
as of this morning as to where this stands.
KENTON KIRKPATRICK, DIRECTOR
OFFICE .OF GRANTS COORDINATION
U. S. ENVIRONMENTAL PROTECTION AGENCY, REGION VI
DALLAS, TEXAS
MR. KIRKPATRICK: Thank you, Mr. Alexander.
Mr. Chairman, conferees, ladies and gentlemen.
The Office of Grants Coordination of the Environ-
i
mental Protection Agency, Region VI, in conjunction with the
Texas Water Quality Board, is responsible for administering j
i
the program that provides grants to municipalities to construct
necessary treatment facilities. I think this program is more
commonly known as the P.L. 660 program. The city of Houston j
I
|
has participated in this program in the past and currently has j
10 active grants with a total project cost of $19.2 million.
Of this number, six grants were made on March 29, 1971, which j
contained special conditions requiring certain action by the
city of Houston before payments would be released by the EPA.
These stipulations pertained to:
1) Expediting an Infiltration Abatement Program,
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190
X. Kirkpatrick
2) Increasing the drying facilities at the
Northsids Sludge Disposal Plant,
3) Updating the city's master plan for sewer
facilities, and
4) Developing an industrial waste control
ordinance.
i
Recently, the Environmental Protection Agency notified the city
that the intent of these conditions has been satisfied and pay-
ments in excess of $4 million are being released today.
In May 1972 two grants were awarded to the city with
the provision that advanced levels of treatment be added to
these projects when waste load allocations pursuant to Recom-
mendation No. 1*J of the Galveston Bay Enforcement Conference
are developed. This same condition has been applied to grants
for 12 other communities in the Galveston Bay Enforcement Con-
ference area.
The city of Houston submitted three applications to
the Texas Water Quality Board in August 1972. To date one of
these has been received through the Water Quality Board by the
Environmental Protection Agency. The total project costs for
these works amounts to $8.5 million. The city has notified the
EPA that three additional projects were approved by the Houston-
Calves ton Area Council of Governments in October 1972 and
-------
K. Kirkpatrick
applications for grant funds are forthcoming. These works have
an estimated total cost of $13.4 million. Reportedly, although;
I don't have all the details here, eight other projects have
been formulated with anticipated submittal dates in 1973 by the
city of Houston. The total cost of these facilities is esti-
mated at $27 million.
I
i
Several communities have received grant funds to
i
comply with the Texas Water Quality Board Order 69-9A, which j
r
I
requires advanced waste treatment in the Clear Lake watershed. |
]
Clear Lake City, Houston, Gulf Meadows, League City, Nassau Bay,
and Webster have received construction grants for tertiary
treatment which has either been completed or is under way
having a total cost of $756,000.
Thank you, Mr. Chairman. This concludes my report.
MR. STEIN: Thank you.
Are there any comments or questions?
Mr. Yantis.
MR. YANTIS: Ken, do I understand that of the works
that have been undertaken by the city of Houston and which were
eligible for reimbursement under the P.L. 660 program, I am
talking really about payments on projects that were due and
ready, that Houston is now up to date on all the money, let's
say, owed by the Federal Government or is there still some more?
-------
192
K. Kirkpatrick j
i
i
MR. KIRKPATRICK: No, sir, I believe this brings them-
i
up to date as of this day. j
MR. YANTIS: I surely thank you and I know that the i
i
city of Houston thanks you, because it is most necessary that \
i
these funds be made available if work is to proceed and con- j
j
tinue. ;
You mentioned Clear Lake and I do have a question. !
i
I will have to ask some of my own staff also. But a few ;
i
moments ago one of the city councilwomen or city council per- !
sons, depending upon your persuasion, from Nassau Bay asked me j
i
a question as to the enforcement of this Order 69-9A. |
Now, all of you will know that the Board sought i
futilely for a long, long time to bring about the creation of j
i
i
one or more regional systems in order to preserve Clear Lake.
There was great difficulty in getting adequate local coopera-
tion. There was difficulty in getting approval of the various
kinds of plans that were made by the various planning review
bodies. There was disagreement between the Federal and State
Government over the definition of tertiary treatment.
And during all of this time, which went on for some
few years, the problem around Clear Lake was simply not improvec
because the sewage treatment plants did not know whether to go
tertiary, what level of tertiary, or wait and join a regional
-------
19 3_
K. Kirkpatrick
system or whether a regional system would ever exist.
Ufcll, part of the discussion, the technical discussion,
revolved around whether a 5 ppm BOD type effluent with some
phosphorus removal was needed or whether a 12 ppm BOD type ef-
fluent as suggested by tine State was needed, and we picked that
because it was a presently-proved simple form of add-on
waste treatment that could be done with minimum dislocation.
There vas created, after discussions with the Federal
* >
Government, an investigation of Clear Lake and a mathematical
model to try to show mathematically the level of waste treatment
that we would have to get if we were not to have a regional sys-
tem which appeared to be unreachable. By the way, that mathe-
matical model, which is essentially complete but there is some
additional work being done on it, showed some rather surprising
I
i
things which later on we can show. In effect it shove that the !
i
interchange of water from Galveston Bay is so overwhelming that i
what puny little man does to Clear Lake is almost of no impor-
tance. The bay sloshes in and out and that controls the quality
in the bay.
However, following the dictates of my freshman chemis-
try which always said if a little is good a lot is better, I
guess it is still true that if you have got too much waste
treatment you haven't been hurting a thing, though you may have
-------
K. Kirkpatrick
wasted some money.
But the point I was getting down to, the enforcement
of Order 69-9A has been dependent almost entirely upon the Pub-
lic Law 660 grants in fact being made to the 20 or 30 sewage
treatment plant owners in that area, and I do not know at the
moment, though maybe you or the staff does, has there been full
technical agreement as to what effluent quality we are design-
ing toward and have Public Law 660 grants become eligible
around the lake to be made without any restrictions at all?
In other words, can we now move out and expect the
grants to be made or are there still things to be resolved?
MR. KIRKPATRICK: To my knowledge of those projects
that have come to us in EPA through your office, the require-
ments of 69-9A are being met as it was prescribed by the Board,
and their advanced waste treatment and whatever add-on is made
that may have been necessary to comply with that order are bein
funded as part of the project.
i
MR. YANTIS: O.K. Dick probably has more informa- j
i
tion than I.
MR. WHITTINGTON:' Well, I have no specific information
relative to any particular grant application.
With respect to the 5-5 12-12 difference of opinion,
this, of course, was to be resolved by the mathematical model
-------
195
i
! K. Kirkpatrick
I and then the study pursuant thereto, and this, as you previ-
!
! ously pointed out, has not been totally completed and the
i
! matter still is at the moment unresolved. An extension of time
i i
| i
! has been granted relative to the enforcement of this thing until
i
I the conflict can be resolved, but hopefully this should be j
! I
I shortly. \
I i
I MR. STEIN: Do you concur in that? ]
I
] MR. KIRKPATRICK: Yes, that is my understanding of
i
I it.
| MR. ALEXANDER: Ken, there haven't been any grants
i held up because of this conflict, though, have there?
! MR. KIRKPATRICK: No, there have not been.
j MR. YANTIS: You mean not lately?
MR. KIRKPATRICK: No, no, not lately. (Laughter)
MR. ALEXANDER: They are not now—
MR. KIRKPATRICK: These are being processed in
I accordance with what Dick has indicated here and with the
i
69-9A Order.
MR. STEIN: You are going to have to know what you
are going to design to.
Let me kind of try to bore in on this question and
maybe Dick and you can answer it.
Do you think that the result of the mathematical
-------
196
General Discussion
model will lead to an answer one way or the other or are you
still going to have to kick this around?
MR. WHITTINGTON: Well, we have, at least at staff
level, I think, agreed that we would abide by the findings of
the study should everyone be convinced of the validity of the
study. Of course the whole conflict revolved around two things:
One, the level of BOD removal which would be required, and
secondly, the phosphorus removal issue as to—I think this did
not necessarily involve the grant program, but the level of
phosphorus removal has, of course, surfaced as to whether or
not the removal of phosphorus from the effluents discharging
into Clear Lake will actually result in an improvement in the
eutrophic condition of Clear Lake because of the large exchange
with Galveston Bay water which occurs.
MR. STEIN: No, I know what the issue is, at least
I am certain that I know what the issue is. But the question
that I have--obviously the decision you are going to make is
going to affect the design both on BOD and phosphorusj not
only design, it is going to affect the cost.
MR. WHITTINGTON: That is correct.
MR. STEIN: Because if you go up higher the costs
increase very rapidly.
The question that I have, again this is a real
-------
197
General Discussion
fundamental question and I would like to hear from the EPA too,
are we satisfied that we are going to abide by the results of
this technical study and mathematical model in the Clear Lake
area or do we have some policy or other kinds of considerations
beyond the mathematical model which we may not be sure of but
we are going to have to go beyond that to resolve this ques-
tion?
MR. WHITTINGTON: Mr. Stein, Mr. Teller and myself
met with Mr. Matthews and others of EPA-Dallas and it was
agreed at that meeting, as I said, at staff level that in the
5-5 12-12 controversy we would all abide by the findings of
the mathematical model.
MR. STEIN: Is that right?
MR. KIRKPATRICK: Yes.
MR. STEIN: Well, say this for the record.
MR. KIRKPATRICK: Yes, for the record, this is
essentially the agreement that we have reached.
MR. STEIN: All right. Then that is great. I think
what we have to do is we have got a methodology, we are waiting
on the results and you are going to get the answer.
Now, when will this be completed?
MR. KIRKPATRICK: Would you like to speak to this?
MR. WHITTINGTON: I believe the timing is 6 weeks.
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198
General Discussion
MR. STEIN: Six weeks from now we should have an
answer one way or another?
MR. WHITTINGTON: That is as my memory serves me.
MR. STEIN: That is close enough. All right, thank
you.
MR. YANTIS: Upon that agreement grant applications
from that area would be processed on whatever routine basis
was enforced at that time?
MR. KIRKPATRICK: Yes, sir.
MR. YANTIS: O.K. Thank you.
MR. STEIN: Thank you.
MR. ALEXANDER: Thank you, Mr. Kirkpatrick.
MR. YANTIS: Did the lady fron. Clear Lake or Nassau
Bay have any additional questions?
MS. V/ADE: No, but I have a comment. May I—
MR. STEIN: We have to get you on the record to
hear you.
Do you want her to—-
MR. YANTIS: Yes, I would certainly like to be able
to listen to what she has to say.
MR. STEIN: By the way, come up here and identify
yourself for the purpose of the record.
-------
.._... _ _ 199
I J. G. Wade
i JOAIJ G. WADE, ALDERMAN
i
I
! CITY OF NASSAU BAY
! TEXAS
j
i
I MS. WADE: I am Joan Wade. I am an Alderman from the
!
: city of Nassau Bay. You probably noticed me whisper to Mr.
! Hugh Yantis, to Mr. Ed Lee of the EPA, and to John Latchford,
i
because I keep hearing you talking about determination of
standards based on a mathematical model that won't be available
for 6 weeks. We have had advanced waste treatment in operation
since April of this year and our lab tests are showing less
I than 3.0 ppm BOD, less than 1.0 ppm total suspended solids, and
I believe we have been down to about 1.6 phosphorus. I don't
even hear you mentioning phosphorus now. j
However, the standards originally under 69-9A were
12-12-1 and EPA was 5-5-1. What happened to phosphorus? And
why can't we meet these standards? We are already doing it.
MR. STEIN: They did mention 5—
MR. YANTIS: The debate had to do with the fact that
the State order adopted after 2 or 3 years of public hearings,
and these are things I said a year ago or more, after a great
deal of judgment evaluation by all of the people involved in
writing the order, especially judgment concerning the kind of
-------
200
H. C..Yantis, Jr.
advanced waste treatment that was readily and reasonably avail-
[ able and finable and operable at that time, the judgment by
the State was that 12 BOD, 12 suspended solids, and 1.0 ppm
j phosphorus removal would probably, because there was no way of
|
j being certain, preserve Clear Lake as the people wanted it
preserved and this was the order finally adopted by the Board.
The thing that distressed us, as we said earlier,
and we are not trying to rub salt .in an old wound, was that
shortly after the issuance of the State order, which had been
! known to the Federal Government throughout its long period of
development, they decided that they would review plans on the
basis of 5 BOD and 5 suspended solids and 1.0 ppm phosphorus
or they would not make a Public Law 660 grant. We felt that
they were in error and neither side wanted to give way. We
felt that there was simply no need for going to the lower
values and the Federal Government felt that, well, they were
certainly possible whether there was need or not and so they
insisted on them, and this was coupled with the fact that there
had been efforts to make regional sewer systems in that area.
So we were faced with various informal cr formal
Judgments that said grants for sewage treatment plants should
not be made because there is going to be a regional sewer
system some day in this area and that is where the grant money
-------
201
1
H. C. Yantis, Jr.
ought to go and we don't want to fund temporary plants. So
they were thought to be not even eligible to get a grant.
Then at other points it was simply that unless they
are designed to 5-5 they don't get a grant and we felt this
was unnecessary and a waste of money.
So the idea came about of making a mathematical model
to try to show technically what actually was needed, and this
was a technique which was simply not available to us during all
the development of the order; we didn't have the money, we
! didn't have the mathematical model or anything else.
Some months ago it became possible to make a mathe-
matical model and to do the other technical support work,
much of it was biology and so on, to tune up the model and to
try to show whether it was a good model or a bad model. And
this is the thing that was to resolve the design problem and
you simply can't design a sewage treatment plant efficiently
until you do know the levels to which you are designing.
Now, the thing that I said, and this is on the most
preliminary basis, we have never relaxed the requirement of
1.0 ppm for the phosphorus content of an effluent, because as
a Judgment matter we knew it could be met fairly reasonably
by techniques available. We also knew that it might not be
met all the way but we weren't sure, nobody was sure, and
-------
2O2
H. C. Yantis, Jr.
apparently from your figures you are getting down to about 1.6
but you are not necessarily getting down to 1.0.
I The other thing, though, that the model is about to
i
i show is that the phosphorus coming in from Calves ton Bay is so
j absolutely overwhelming that it actually makes no difference
i '.
whether you take out phosphorus or not. It probably says
the same thing about BOD. ]
j So if all we are dealing with is public health, then •
i
i all you have to do is a real heavy job of chlorination. But
i
I if you are dealing with the eutrophication of the bay, we come
up against the fact that Galveston Bay and the tide appear to
i
i
I control Clear Lake, not what man is doing. So this in a
i
i technical sense—and I am speaking before all the facts are in-
really shows that maybe Clear Lake is exactly the way it is
going to be no matter what anybody does to it.
But on the other hand, whether the Board feels that
it ought to relax its order, I can't speak for the Board, I
don't know. But we have gone into a program that from the
esthetic standpoint, from the community acceptance standpoint,
most of the people around Clear Lake want Clear Lake to be a
desirable body of water which they can use for water recreation
j
without even worrying about it, without being offended in any '
way by it. So I doubt that there will be any opposition to
-------
203
H. C. Yantis, Jr.
tertiary treatment on the basis that it certainly is going to
be good for the bay but is not necessarily going to be the con-
trolling factor in the bay, by which I mean Clear Lake.
But anyhow, my comments arise from the fact that the
lady's question said when are we going to enforce the order
which does require people to build tertiary treatment plants.
And my response is whenever the Public Law 660 funds are avail-
able without limitation, because I don't think that the order
would be feasible or reasonable to have all of this work done
without grants if in fact grants are in the culture of our time,,
And so this complicated answer to a relatively strai
forward question is that the order is about to be enforced
} because grant money is about to be available, subject, of
course, to various statements that have been made by my Board
and by some of the—at least Senator Bentsen's office. We are
going to get about half the grant money we have been getting in
the past, and this is not exactly helpful to the State as a
whole.
I hope I haven't got everybody more confused now than
they were when we started.
MR. STEIN: Well, I think it was a technical dis-
cussion. Really it is very clear; if you read it in the record
I am sure it will come out. But I think Mr. Yantis put this
-------
204
M. Stein
thing forward. Let me try this at the risk of doing it
again.
I think what we have said is that we have a
I
j mathematical model to resolve an alleged difference be-
!
i tween Federal and State governments. Now, whether one is
I right or the other is right, I think the facts will have
i
j to show that, and it is a question here of whether more
i
i
f or additional advanced waste treatment is necessary. I
I
i
I suspect, Hugh, that the preliminary determinations you have in-
j
i dicated are right—that the channel dominates Clear Lake.j
i !
I Now, I think the sole question you have to get !
i I
j here, as we have in other places, and this hasn't come up
i . i
i yetj is whether you are dealing with a question of eutro-
i phication of the whole channel and whether this is one of
! the bodies of water that you have to be worried about
i
phosphates in the channel. I don't know that you are or
not. But if you are not, you may be home free in Clear
Lake in putting in additional treatment on what we have said.
Now, the problem in dealing with phosphate
removal or other advanced waste treatment techniques is
that sometimes you get involved with conceptualism,
policy, emotionalism, or something of that kind. What wt
have here is parties that cannot agree. What they do agree
on is a methodology of checking something out and that both sides
-------
205
M. Stein
are going to abide by the results. We have a situation
here where the State and the Federal Government are about
6 weeks away from touchdown. We will get the results,
and I think as far as I am concerned—and I think Mr.
Yantis, and I don't want to speak for Mr. Alexander but
I hope he will join with this—that as the results of
this mathematical model will turn up and all sides are
agreed in advance to abide by the result, this will
settle the ball game.
MR. YANTIS: Murray, of course everybody knows
that a computer is basically an idiot.
MR. STEIN: Right.
MR. YANTIS: It can only count very fast, that
is all it can do.
Now, all the highways in Texas are designed by
computers and when they are built they are too small when they
are finished. It doesn't really prove that a computer was not
useful, but it does prove that it is not exactly a genius.
j We always would add to whatever the computer
i
| shows us an element of judgment and the human privilege
of making decisions and policies. Remember, the popula-
tion is going to grow around Clear Lake.
I wouldn't have anyone sit around and wait for the
Board to withdraw its order or amend it or weaken it, because:
-------
. 206
General Discussion
it is probably reasonable on the basis of judgment and experi-
ence, it is probably a desirable and reasonable order. It may
give us a little more treatment than the computer says we need,
but I just don't think that the Water Quality Board has sur-
rendered its human Judgment to a computer as yet.
MR. STEIN: I hope I didn't suggest that. I suggested.
the issue here, as I understand, was between 12-12-1 and 5-5-1.
MR. YANTIS: That is correct.
MR. STEIN: And presumably the methodology that you
are going to come up with would resolve that. I am not sug-
gesting that any result coming up from this methodology would
result in a relaxation of the 12-12-1.
MR. YANTIS: The only thing I really want to point
out is that we are approaching the time, apparently, when grant
funds will be available to bring about the completion of
Order 69-9A.
MR. STEIN: This can be off the record.
(Off the record)
I
MR. STEIN: Let us take a 15-minute recess. Then we
will come back and conclude.
(Recess)
MR. YANTIS: Mr. Stein has just asked if I want to
make a statement and the answer is no, I do not. (Laughter)
-------
207
General Discussion
Thank you, Mr, Stein.
Mr. Stein, I do want to make a statement, really, and
I would include Mr. Alexander in these remarks.
Having known you for a number of years and been asso-
ciated with you very closely in this series of hearings, and
having known Mr. Alexander since he assumed his position up in
Dallas and is now a conferee on this particular conference, it
really has been a pleasure, a rewarding experience, and I mean
that quite sincerely, to deal with, discuss and evaluate prob-
lems with men of such undoubted good will and sincerity, and I j
want to thank you both and compliment you both for the extremely
fine attitude and work that you have brought to this conferencej
MR. STEIN: Thank you.
SUMMARY
BY
MURRAY STEIN
MR. STEIN: I think we can summarize the meeting
rather rapidly.
You know, this is a distinct pleasure for me in this
summary because what I would like to use is the paper that Dick
Whittington of Texas submitted. I think he said it as well and as
tersely as it can be said here, and let me just read this.
-------
! Summary - M. Stein
i
!
I This is just two sentences right from his paper. And it is
i . |
j No. Ill in his paper. What he said, and I think this sum- i
j marizes the situation: I
i j
! At the outset, the water quality in the !
i
i
J Houston Ship Channel remains unsatisfactory. Never-
i
! theless, improvements are becoming apparent.
; And I think this is correct.
i
! Now, since we have this as our text, if the water \
j !
I remains unsatisfactory and we can see that improvements are i
! !
i becoming apparent, how do we move under the new law to the next i
I stage in getting these further improvements so we can change
I
that sentence? And the key in the goal we have to get to is
"The water quality in the Houston Ship Channel is satisfactory."
That is what we have to say.
Under the new law and the new procedures, the tech-
nique, it seems very clear, is that the municipalities and the
industries are going to require a permit. Each and every one
of them for the point discharges is going to require a permit.
The law authorizes us to allow the State of Texas to issue
these permits, but if they don't we are going to have to issue
them ourselves.
I think we all should be agreed that if we are going
to look at the purpose and Intent of the new law, and the way
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Summary - M. Stein
we have viewed this that the primary rights and responsibilitie;
for pollution control rest with the State, 'that the most desir-
able thing and the way to handle this is for the Federal Govern-
ment and Texas as soon as possible to get together so we can
get the necessary papers and Texas can issue the permits to the
dischargers into the Houston Ship Channel and that these will
have the full sanction of the Federal law when Texas issues
these permits. If we go back, though, we have to, I think, come|
up with a program that is going to assure that when the condi-
tions of these permits are carried forward that we can say that
the condition of the waters of the Houston Ship Channel are
going to be satisfactory.
In order to do this, there is going to have to be an
allocation of a discharge load among the various dischargers
into the Houston Ship Channel which may require some deep soul-
searching and some very heroic action, possibly, on the part of
the cities and industries here.
The Houston Ship Channel is like several other places
in the country, one of the places where you have a relatively
slack body of water, big city, other urban development, and a
lot of industry all discharging into the same body of water.
If we are going to create satisfactory conditions, the kind of
waste loading will have to be carefully apportioned among all
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_ „_.. . |
Summary - M. Stein i
the various dischargers concerned and in order to meet that
very tight apportionment that you have, the kind of treatment :
required will be at the very forefront of municipal and indus-
trial treatment. ;
As another part of our activity, we are coming up
with guidelines, effluent guidelines, for municipalities and
for the various industries in the country. I would suspect in .
the Houston Ship Channel that certainly as a minimum the very '•
best that we put out in these guidelines will have to be met, :
and in many cases these results will practically have to be ;
exceeded in order to meet these requirements. I would suggest, i
and I think that we have a rather excellent working relationship
i
With the State, that we get a program under way where the per- j
mits to be issued by the State of Texas, or whoever is going j
to issue them, individually or in the aggregate, can assure that!
!
we are going to meet certain minimum requirements in the Houston!
i
Ship Channel. j
i
I think there is another aspect to this program In j
dealing with these permits that may be overlooked. Whether the
State or the Federal Government issues these permits, I think
a violation of the permit, if you violate one now, you are going
to be in violation not only of a State law but a Federal law as
well, and there is going to be a considerable measure of checkink
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Summary - M. Stein
on whether you are in compliance or not. This is one of the j
aspects of the program that you have to consider. I think ;
i
I pollution control is developing this way. \
i
Perhaps you can use one or two analogies in this. j
One I used before, it is like either the water company or ;
the electric company or the telephone company. If their service-
breaks down everyone knows it and there is a big protest. That,
I guess, is what is going to happen once the permits get issued,
because everyone is going to know if you are not operating
satisfactorily. It is not just a question of getting these
very advanced facilities in. You are going to have to run
them.
The other analogy I use, and this is the kind of :
discipline that many of us don't have, we are going to go pub- '
lie on this. Now, I know when all of us make a mistake or I •
make a mistake in the office, very often I can crumple up a ;
piece of paper and throw it in the wastebasket and start over
again, and no one except myself knows I made that mistake, but ;
in the environmental field, particularly in a field like this
where we have a lot of people together, once we have got this
permit out and once you have made the mistake, this is going to
be like being in your football stadium here and going out for
that pass when you have got a clear shot for the touchdown and j
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Summary - M. Stein
that pass goes through your arms. Every guy in that
stadium and a hundred million people on TV, maybe, are
going to know you goofed. This is what I think we have
to keep in mind with this program.
I think that through the conference, through
the Galveston Bay study, through the joint work with our
lab, through the continuing work with the region and the
State, we have a firm basis and understanding with the
State on the factual situation. I would like to call
everyone's attention to that—that on the facts I don't believe
there has been a scintilla of difference between the State and
Federal authorities. There is complete agreement on the facts.
The next step in working this out, since we now
have a strong regional concept, is for the State to work
with Mr. Alexander and his group in the regional office.
Of course, we will have to work out a system whereby we
come to a pretty detailed agreement on how we are going tjo
approach Galveston Bay, how the allocation of the waste
loadings are going to be made, and then get on with the issuance
*
of the permits to the various industries and the municipalities
involved. I would suggest to industries and municipalities, if
you haven't done this already, that they get in touch with either
Mr. Yantis, the regional office, trade association, whomever thej
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213
I i
[ Summary - M. Stein i
!
i
i deal with, to get the guidelines for their industries and
|
j ber;in to think in terms of what a fair allocation is.
One last point which is possibly going to compound
| this, but we all have to think about this. I don't think we can
j
!
j think of the Houston Ship Channel and the Houston area,as stron
I j
| and as powerful and as progressive as it is, as the end of the -
i :
I road. I think the industry, the population is going to need ;
! "
i
! :
I some room for expansion, and when we think in terms of room :
j for expansion there has got to be some kind of leeway. If we '
!
! use every ounce of the allowable effluent limitations, then
you are going to be faced with the fact that any new industry
!
! that is going to come in is going to have to practically go
i
to a completely closed cycle. This may be the thing that you
| may have to think to now. But even if we do that with the
industry you are not going to go closed cycle, at least not in
the foreseeable future, with municipal wastes, and the popula-
tion is going to grow if the industry is going to grow. So you
have to not only design a program that is going to abate the
i
pollution in Galveston Bay, get those waters into satisfactory I
i
condition, but we have to provide a cushion for future growth j
i
!
and future expansion. !
Now, I am confident from listening to the technical
staff and from my association with Mr. Yantis and Mr. Alexander
-------
Summary - M. Stein
that you have the personnel in the State and in our regional
office to accomplish this and go forward with this goal. I
hope this will be resolved very soon and that we can go forward
with the program.
I know there are certain industrial and municipal
representatives here. I think it is to everyone's advantage
to resolve this soon.
We have a statutory date in that law where you have
to comply with the conditions of the permit not later than July
1977* If we come up with a resolution of that now, you have got
a pretty good bite in order to do that. However, if you wait
a year or a "ear and a half or more before the Federal Govern-
ment and the State may resolve differences or before you get a
i permit, instead of having 4.5 years to do something you may
jhave 3 years or less. This is going to mean the difference
j
| between operating and trying to get to the top kind of treat-
i
ment on a crash program or a program where you are going to be
able to proceed at a more regular pace, and you are going to have
some cushion for inevitable little mistakes or setbacks.
But I think it behooves us all for the Federal Govern-
ment and the State to come to this agreement rapidly and for us
to come to an agreement with individual point sources, individ-
ual industries, and individual plants as soon as possible so
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Summary - M. Stein
the permit can be issued and you can get working with as much
leadtirae as you possibly can get under the law. Every day we
delay means a shorter time fuse because the Congress has set
that end date already. That is enshrined in the law.
This is the message I would like to leave. I think
with the good will we have of the State and the region we can
do it. We can accelerate that if we get the cooperation and
the good will of the industries and municipalities involved.
*
With that I would like to thank you all for partici-
pating, and I hope we are on our way to a clean Galveston Bay.
We stand adjourned.
(Whereupon, at 12 o'clock the hearing was adjourned.)
«O.S. GOVERNMENT PRINTING OFFICE: 1973 514-155/322 1-3
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