I would be ineffective "in ameliorating or correcting all of the infant?s lite- threatening conditions. . . The amendment will probably be adopted when Congress reconvenes on 23 July. Surgeon General C. Ever- ett Koop has approved it as "reason- able and practical." and it has been endorsed by handicapped. right-to- lite. medical. and hospital organiza- tions. The only dissenter is the Ameri- can Medical Association. which has resisted all Baby Doe?related propos- als on the grounds that they intrude on medical decision-making. . HOLDEN $Dioxin Trial Pits Workers Against Monsanto The dioxin issue is back in court. A trial began iast month between a group of Monsanto employees and the company. The group alleges that the company's negligence, dating from an accident in 1949 that exposed some of them to dioxin. is responsible for many of their medical problems. The trial is being held in federal court in Charleston, West Virginia, near the tOwn of Nitro where the chemical com- pany has been operating a manufac- turing plant since 1929. Although the plaintiffs' group in- cludes more than 170 members. the first trial involves seven retired chemi- cal workers who are seeking $2.5 million each in damages from the company. according to their attorney W. Stuart Calwell. The trial is expect? ed to last several months. Depending on its outcome. the other plaintiffs' cases could be heard in a series of trials. he notes. Calwell will try to convince a jury that the chemical causes Specific medical problems in man. in doing so. he will raise issues simiiar to those in the Agent Orange case. which Viet- nam veterans brought against eight . chemical companies including Mon- santo. The veterans alleged that the dioxin-contaminated herbicide. Agent Orange. to which they were exposed in Vietnam, caused numerous health problems. A tentative settlement be- . tween the veterans and 'the chemical companies was reached out of court shortly before the trial was scheduled to begin (Sciepce. 25 May. p.849). Between 1949 and 1965. the com- pany's Nitro pliant was used for mak- ing the herbicide 2 .4 5- trichloro- phenol. or 2 4. 5- T, .which usually is contaminated with dioxin (specifical- ly. tetrachlorodibenzodioxin). Calwell says that documents obtained from Monsanto dating back to the early 1950 3 refer to "some substance" be- ing present ml the manufacturing pro- cess that affected the liver. kidney. and other organ systems of workers. Soon thereafter the company identi- fied dioxin asl the ?offending agent. Thus. despite the fact that ?Monsanto knew of the toxicology of this [menu- tacturing] process. .they continued to use it," he claims. He plans to call expert witnesses to testify that dioxin is responsible for liver disorders. ner? vous system;disorders. and abnor- malities in lipid metabolism among the Monsanto worikers. Monsanto says that chloracne. a skin rash is the only long- -term health effect that might result from the levels of exposure at the Nitro plant. ?We do acknowledge other short-term health effects due to exposure to high levels of dioxin," a company spokesman says. They include respiratory tract irritation. headache. dizziness. and nausea; muscle discomfort; and liVer . disorders. A recent study also indi- cates an "association" connecting dioxin exposure to gastrointestinal ul- cer incidence among those workers. the spokesman notes. "Contrary to what the plaintiff alleges. {Monsanto} was. conscientious in its effort- to de- crease worker exposure to dioxin. We have behaved responsibly in protect- ing workers from hazards based on our knowledge and the scientific ca- pabilities available." Exposure to chemicals besides dioxin will likely also be an issue dur- ing the trial. For example. until 1955. Monsanto made para-aminobiphenyl -at the Nitro plant. a chemical used in making rubber and now widely recog- nized for inducing bladder tumors in man. Monsanto says it monitors work- ers exposed to this chemical and con- tinues to pay their medical expenses. Piaintitfs' attorney Calwell says that he will try to show there is synergism between dioxin and other substances .:causing health problems among the chemical workers?JEFFREY L. Fox . and "inappropriate," ended an Briefing EPA Failed to Catch Missing Data on Larvadex When the Environmental Protection Agency (EPA) proposed to register a new pesticide called Larvadex last spring. it braced for controversy on claims that the compound might be carcinogenic. The pesticide will be fed to chickens to control flies that breed in their manure. and a residue will remain in the chickens and their eggs. This residue (melamine) has been linked with tumors in male rats (Sci- ence, 25 May. p. 851). However. the agency ran into an entirely unexpected problem. one that its toxicology checkers simply missed in earlier reviews. Although the safety studies submitted by the manufactur- er. Ciba- -Geigy. were sound on carci- nogenic risks. they failed to take full .measure of the chemical's fetotoxic (embryo- damaging) effects. This fact came to :light after EPA officials began sorting through the more than 100 cominents they re- ceived on Larvadex. Two letters from California state agencies and one from the Natural Resources Defense Council pointed to the same problem. in running tests on reproduction, re- searchers had recorded tetotoxic et- tects (such as a high rate of abortion or low birth weight) for all dose levels at which the chemical was fed. But they failed to ascertain one essential parameter?the dose at which no ef- fect is. seen. The EPA requires that this bottom end of the spectrum be clearly identified. Ciba?Geigy has been told. to redo one reproductive study. a task that will take at least 6 months. The company cailed the decision "disappointing" noting that the EPA has had the data on fetotoxicity in its files for almost 2 years. The decision has been awkward for the agency as well. The data on Lar- vadex have beenunder intense scruti- ny since August of 1983. when the ?emergency use" waiver under which Larvadex was be- ing used in 28 states. Farmers were told that the pesticide would be back on the market very soon. "When you do 7000 reviews a year." an official said. "you?re going to miss on some." MARSHALL 20 -. . 1 295 Micyt?nu?rg .. urn-i Dt-F?em-g ?0 rm iir. John?iliesse Hiciniga?nnoepartment 'of Public Health 3500 II. Logan Street . . . 09 Box. 30035 Dear John. RegardingJour discussions in lief-ch of this?ycgar concerning a case control study of birth defects during the 1970.197; time period in Hidiand County. will the Michigan Department. of Public Health be requesting that ouch a study be conducted?! As indicated in a-liar'ch 30. halo. Region cou?ld I 'fundA 'case contro?l study, however your request to Centers for Disease Control (CDC) and to EPA is required. The for conducting a case of birth defects in mama County we smug and have been discussed at length by Ir. tarry Edmond! of CDC. Mr. Charles Ponie. at iin'rvard- University. and use". There is stimulant 19 L119. in and birth guests ob:er.ved 4111:1139 the mD-ulh?c?ld have gun It, ausedi?iegosune? ?"to environments! i . .3 . He have?a unique opportunity in Hidiand'C'ohnty to study?ff any possibie reiatin'n- ships exist with chemical manufacture. fishlconsisaption. and other exposure routes and adverse reproductiw ?Items. 1 stronu'iy urge the HDPH .t'o fomliy. requestr that CDC .. in cooperation .uith Harvard University and u.s. EPA Region v, conduct a case controi study 01' birth defects in Hid?land County. Hithout aliom'a?l Bequest a can . .study cannot be initiated. hape that this?vaiuabie wport?iinit?'s" not missed. 1 Si ncero 1y . J. Hilton Clark. .CE FEE) liealth Effects specio'list - Toxic Hateria?ls Branch. . . Kenneth ?icon. ODPH . .. 0. Bruce 1. . .C. Fabinski. gun-Jul . August 25, 1964 Mr. haul Zugger Surface Water Quality Division Michigan Department of Natural Resources Box 30028 Lansing, Mi. 48909 Dear Mr. hugger: I am becoming increasingly concerned about Dow's past disposal practices. Enclosed you will find a report released by the city of Midland in 1980. This report, entitled, "Task Force 2000 Leisure Life Subcommittee Report of the Research Team on City Beautification? discusses erosion along the riverbanks The report states, "In one spot erosion has seriously exposed old landfill materials, and liquids from them are leaching into the river? The comments that follow that statement do not address the issue of what materials might be leaching into the river. The major concern is that it is I believe that this report clearly reflects the Midland community's attitude. Outward appearances always take precedence over health and environmental concerns. I believe that the dump referred to in this report was used by Dow and the city in the '40's. I also believe that the Midland Farmer's Market was built on top of the dump. This same area has become a very popular spot for picknickers, since the building of the "Tridge." Concerts are held next to the river, and people are encouraged to bring their children, picnic lunches, and blankets for a relaxing evening by the river. Most people are not aware that they are laying on top of an old landfill. Needless to say, this attitude concerns me. It makes you wonder how many other sites in the area might be paved and seeded over, but still posing a threat to people and the environment. I am also concerned that the DNR does not have a handle on the situation.. Were you aware when you issued the recent controversial discharge permit to Dow, that this landfill was contributing to the pollution of the Tittabawassee River? Is this landfill being factored into the upcoming permit for the City of Midland Wastewater Treatment Plant? have you asked Dow and the City of Midland if there are any other old landfills along the riverbanks and in floodplain areas, that might be contributing to the pollution of the river? If these questions have not been asked, I consider it to be an extememe oversight on the part of the Surface Water Quality Division. if you have requested this information, would you please send if?: 'i . '3 v. page two August 25, 1984 Paul Zugger I have talked to the Environmental Enforcement Division about this landfill, and it is my understanding that there will be an investigation by the Groundwater Quality Division. However, I would hope that in the meantime, your division would evaluate the impact on the river. This evaluation would not be complete until you request that how and the City of Midland identify all old disposal sites. One of my major complaints in the past has been the haphazard method the state has used for identifying contaminated sites. We have exprags-d tile concern many times regarding the state's Site Assessment Program. Remedial Action Section missed several Midland sites last year. Just holding public hearings is not enough. The burden of identifying contaminated sites falls on the shoulders of citizens. If you miss the public hearing and the comment period, your site might not make the list. Why isn't that burden shifted to industry where it belongs? I get the feeling in Midland, that I'm playing hide and go seek with the city and Dow. They both know where many of these old disposal sites are located, but aren't telling. The situation is so absurd, that I actually considered having a contest to see who could identify the most sites. The winner would receive an all expense paid trip to the 152 acre Salzburg Hazardous Waste Landfill. New York recently passed a "Community Right to know bill. This bill requires all industries to identify where they've buried their wastes for the past thirty years. This is as it should be, of course. It's their garbage, and they should be accountable for it. The DNR needs to become more agressive in this regard. I am often amazed that the DNR does not even ask simple questions, such as, ?are you aware of any old disposal sites that might be contributing to the ground and surface water pollution?" I would hope that you take this information seriously, and respond accordingly. sometimes the responses I receive are simply paper shuffling, and more time seems to be spent figuring out why the situation can't be addressed at this time. i would a3k that you coordinate your efforts with Groundwater Quality, hazardous Waste, Environmental Enforcement, and Remedial Action Section. I believe that the agency's past piecemeal approach to evaluating sites has many times resulted in evaluations that were deficient in scope. I believe that the enclosed report supports my concern that the present system 5.1? .1. near page three August 25,1984 Paul Zugger of identifying contaminated sites is woerully inadequate. I am also enclosing for your review Dr. Irving Selikoff's testimony before the Subcommittee on Natural Resources, Agriculture Research and Environment. Dr. SeliKoff states in his testimony that the technology exists to measure dioxin at 2.1 quintillions. It is not clear if he is talking about soil or water at that point, but I thought you should be made aware or his testimony, as it could impact the Dow permit. I would like your response to this testimony. I will look forward to hearing from you soon. Sincerely, Diane hebert, director ECOMM 2505 East sugnet Cour: Midland, Mi. 48b40 o.c Dr. Ronald SKoog Dave Dempsey James Truchan Frederick Brown Dan Schultz Senator Carl Levin Congressman Donald Albosta Thomas Scott Del Rector Andy nogarth Rick Johns Iarry Holcomb enclosures MICHIGAN DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION BUREAU POINT SOURCE STUDIES SECTION Report of a Municipal Nastewater Survey Conducted at I MIDLAND HASTENATER TREATMENT PLANT All Outfalls No. 550009 AUG 1 3 1984 NPDES Pennit No. M10023582 Midland County Midland, Michigan March 23?04, l981 i Survey Summary I Nastewater monitoring was performed during one twenty-four hour sur vey period starting Monday, March 23, l98?. The results of this survey are compared to the final limitations in'the facility's National Pollutant Discharge Elimination System (NPDES) Pennit, N0. M10023582 in Table 3. This comparison shows that the survey not meet the 30?day loading limitations or the 30-day and 7-day concentration limitations-for BOD and phosphorus removal was less than 80%. All other limitations were met. - The survey results are compared to the results reported on the facility's Operating Report (MOR) in Table 3. All results compare well except for total phosphorus which was reported lower on the facility's MDR than the survey result. A portion of the composite sample was split with the facility for com- parison of laboratory analysis. This comparison is in Table 4. The total .phosphorus results found by the E.P.B. laboratory were greater than those found by the Midland Nastewater Treatment Plant. . The results from this survey are compared to the results from the previous survey done on July 22-23, l980 in Table 5. The total phosphorus results at the effluent for this survey were greater than the nesults from the last survey. The sludge being hauled from the plant for landfill was sampled and the results are in Table 2. Survey Comments The following substances were found in measurable amounts at outfall 560009 (00l): benzene, tetrachloroethylene, trichloroethylene and 1,2 dichloroethylene. Samples taken at the influent contained all of these substances except tetrac loroethylene but also contained toluene- The results of these tests are in Table Tum-h.- s. u. STATE OF MICHIGAN .fluu? g3 7 NATURAL nesouncas COMMISSION ?51? THOMASJ.ANDERSON - E. n. CAROLLO JAMES J. BLANC HARD Governor $5525 i. 353:3? DEPARTMENT OF NATURAL RESOURCES o. STEWART MYERS STEVENS T. MASON BUILDING RAYMOND POUPORE Box 30023 HARRY H. WHITELEY LANSING. MI 48909 RONALD O. SFTOOG. Director August 17, 1934 Ms. Diane Hebert, Director ECOMM 2505 East Sugnet Court Midland, Michigan 48640 Re: City of Midland Wastewater Treatmen Plant Discharge Permit .3 Dear Ms. Hebert: Following is our re5ponse to your August 4, 1984 letter to us regardingl the draft NPDES permit for the City of Midland. i l. Toxic effluent limitations - There currently are no toxic parameters required to be monitored for because work being done to determine toxic effluent limitations has not been completed. The City is required to complete an industrial pretreatment program. As part of this program a survey of industries discharging to the wastewater treatment plant and wastewater sampling of these discharges is i conducted. We receive this information, review it and decide what parameters, if any, are to be included in the permit. This is expected to be completed and the permit modified, if necessary, within the next year. we decided not to wait for the completion of this work while holding up issuance of the permit. 2. Enclosed with this letter are cepies of the draft permit, briefing memo/fact sheet containing relevant background information and a 1981 point source survey conducted at the facility. There have not been any point source surveys conducted since 1981. This information h0pefully will answer any additional questions you have. There will be no Freedom of Information Act charges associated with this request. If I can be of furthe? assistance, please let me know. Sincerely, A 51:; u/James Blue Permits Section Surface Water Quality Division 517-373-8088 i 3-sm25 . . ?3:3 1mm, - . 14?s. {35: ?13STATE OF MICHIGAN NATURAL RESOURCES COMMISSION JAMES J. BLANCHARD. Governor DEPARTMENT OF NATURAL RESOURCES o. STEWART MYERS STEVENS T. MASON BUILDING RAYMOND POUPORE BOX 30028 HARRY WHITELEY LANSING. MI 48909 RONALD O. SKOOG. Director Ms. Diane Hebert, Director ECOMM 2505 East Sugnet Court Midland, Michigan 48640 Re: Dear Ms. Hebert: August 17, 1984 City of Midland Wastewater Treatment Plant Discharge Permit Following is our reaponse to your August 4, 1984 letter to us regarding the draft NPDES permit for the City of Midland. 1. Toxic effluent limitations - There currently are no toxic parameters required to be monitored for because work being done to determine toxic effluent limitations has not been completed. The City is required to complete an indus trial pretreatment program. As part of this program a survey of industries discharging to the wastewater treatment plant and wastewater sampling of these discharges is conducted. We receive this information, review it and decide what parameters, if any, are to be included in the permit. This is expected to be completed and the permit modified, if necessary, within the next year. we decided not to wait for the completion of this work while holding up issuance of the permit. 2. Enclosed with this letter are memo/fact sheet containing re c0pies of the draft permit, briefing levant background information and a 1981 point source survey conducted at the facility. There have not been any point source surveys conducted since 1981. This information hopefully will answer any additional questions you have. There will be no Freedom of Information Act charges associated with this request. If I can be of further assistance, please let me know. 31026 I 1 Sincerely, 2.4m. u/James Blue Permits Section Surface Water Quality Division 517-373-8088 1.1 HASTEHRTER CITY HANRBERIBITY DF RHNUHL REP. FDR HASTEHATER DEPT. 77-73 MODERN EXPLORERS i . EQUSE LIBRARY. ONLY Mr. C. R. Miles City Manager City of Midland Midland, Michigan 48640 Subject: Annual Report For The Wastewater Department Fiscal Year 1977-78 Dear Mr. Miles: During the past year the Wastewater Treatment Plant processed a total of 2,590,600,000 gallons of wastewater for an average of 7,097,500 gallons per day. The solids that were removed in the treatment facilities and pumped to the sludge holding tanks totaled 5,587,900 gallons. The solids were thickened in the gravity holding tanks, then processed through the Zimpro thermal sludge conditioning system at 370~3800 F. for approximately 20 minutes. The combi- nation of heat, air and pressure resulted in a breakdown of the cellular structure of the solids allowing a further gravity thickening to occur, concentrating into 2,122,300 gallons. The thickened sludge was dewatered on vacuum filters leaving 3,750 cubic yards of sludge that was trucked to the sanitary landfill. This sludge contained 3,023,600 pounds of dry solids that had been removed from the wastewater. A total of 625 trips were made to the landfill to dispose of the sludge from the vacuum filter process. MICHIGAN DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION BUREAU POINT SOURCE STUDIES SECTION Report of a Municipal Nastewater Survey Conducted at I MIDLAND HASTEWATER TREATMENT PLANT All Outfalls No. 560009 AUG 13 ?984 NPDES Pennit No. M10023582 n.?wn - Midland County Midland, Michigan March 23~24, l981 Survey Summary Hastewater monitoring was performed during one twenty-four hour survey period starting Monday, March 23, l98l. The results of this survey are compared to the final limitations in the facility's National Pollutant Discharge Elimination System (NPDES) Pennit, No. M10023582 in Table 3. This comparison shows that the survey results did not meet the 30?day loading limitations or the 30?day and 7-day concentration limitations for BOD and phosphorus removal was less than 80%. All other limitations were met. The survey results are compared to the results reported on the facility?s Operating Report (MOR) in Table 3. All results compare well except for total phosphorus which was reported lower on the facility's MOR than the survey result. A portion of the composite sample was Split with the facility for com? parison of laboratory analysis. This comparison is in Table 4. The total ph05phorus results found by the E.P.B. laboratory were greater than those found by the Midland Hastewater Treatment Plant. The results from this survey are compared to the results from the previous survey done on July 22-23, 1980 in Table 5. The total phosphorus results at the effluent for this survey were greater than the results from the last survey. The sludge being hauled from the plant for landfill was sampled and the results are in Table 2. Survey Comments The following substances were found in measurable amounts at outfall 560009 (001): beggene, tetrachloroethylene, trichloroethylege and 1,2 lene. Samples taken at the influent contained all of these substances tetrac loroethylene but also contained toluene. The results of these tests are in Table 2. 0.0. samples were taken directly at outfall 560009 (00l) and also at an opening in Lingle Drain of the outfall. Both sets of results are in Table 2. - . 1 Nastewater Treatment The Midland Nastewater Treatment Plant is a tertiary plant with phosphorus removal facilities. The entering wastewater flows to a comminutor, a grit cham? ber, primary settling tanks, first stage trickling filters, intermediate settling tanks, secondary trickling filters, activated sludge tanks, final settling tanks, multi media sand filters for tertiary treatment, and chlorine contact tank. Ferric chloride and a polymer are added for phosphorus removal. The treated- wastewater is diScharged to Lingle Drain via outfall 560009 (00l). The plant is also equipped with a raw sewage retention basin. Sludge is thickened, treated by a zimpro wet oxidation process, vacuum filtered, and trucked to a landfill or used as a soil conditioner. A treatment flow sheet supplied by the plant is given in Figure l. The location of the plant is shown in Figure 2. Survey Procedure The flow and samples were obtained as follows: 0utfall Flow Measurement Sampling Methods 560009 (00l) Plant totalizer. Submergible sampler individual grab samples. Site (Before . Individual grab samples only. Discharge to Tittabawassee 'River) Influent 5?Aliqu0t grab composite individual grab samples. A submergible sampler obtained samples at a continuous rate. Extractable organic composite samples are collected by the grab composite method. A grab composite consists of a series of individual grabs composited into one sample. I I An individual grab is a single instantaneous sample. i 1 Samples were analyzed by the Environmental Protection Bureau Laboratories located in Lansing. 4 Samples were preserved according to Table 6. The results of the physical, chemical and bacteriological analyses are presented in Tables 1 2. Letter codes for laboratory results are defined in Table 6. -3- Mid1and Nastewater Treatment P1ant Tab1e 1 Ana1yses of composite samp1es. Outfa11s 560009 (001) Inf1uent Survey Period From 3-23?81 1145 3-23-81 1150 To 3-24-81 - 1145 3-24-81 1150 Computed f1ow rate1 (M3/day) (28,700) -- /1 kg/dag mg/1 000 50 1,000 I 0005 16 1 460 Nitrite nitrate nitrogen-N 0.04 1 Ammonia nitrogen-N 13 370 - Kje1dah1 nitrogen?N 18 520 Orthophosphates?P 0.64 18 Tota1 phosphorus?P 1.1l 32 3,3 Suspended so1ids 6 200 Disso1ved so11ds 680 20,000 Tota1 cadmium (Cd) 0.02 Tota1 chromium (Cr) 0.05 -- Tota1 copper (Cu) 0.02 -- Tota1 nicke1 (Ni) 0.05 -- Tota1 1ead (Pb) 0.05 h- Tota1 zinc (Zn) 0.05 -- _2 Tota1 iron (Fe) 0:18 5.2 09/1 ug/1 20051242 0.11 0.1 PCB 1254 0.1 0.1 PCB 1260 0.1: 0.1 Buty1benzy1 phtha1ates (BBP) 1 i 412 Bis(2-ethy1 hexy1) phtha1ates (DEHP) 4.5 0.13 1) Di-n?buty1 phtha1ates (DBP) 1 5_3 Phen01ics 1 - F1ow rates used in the computation of kg/day (obtained from company tLta1izer). To obtain MGD mu1tip1y M3 /day by 0.0002642 To obtain 1bs/day mu1tip1y kg/day Ly 2. 205 9 Mid1and Wastewater Treatment P1ant Tab1e 2 Ana1yses of grab samp1es. Nitrite Residua? Feca1 nitrate Ammonia Kje1dah1 Ortho- Date Time Temp:l pH1 Ch1orine co1iform 0.0. B005 nitrogen nitrogen nitrogen phogphates? S.U. mg/1 cts/100 m1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 mg/1 560009 (001) - 3?23-81 1 45 103-23?81 1635 10.5 7.1 160,000 BC 7.5 56 12 0.08 14 ,17 0.62 3-23-81 2250 9.0 7.4 530,000 HT 5.0 PT -- -- -- 3-24-81 0730 9.0 7.5 390,000 HT 7.2 68 19 0:01 15 18 0.62 3-24-81 1145 10.0 7.4 220,000 GC 7.2 -- -- Geo. Mean '50,000 . 3-23-81 1645 93-23?81 2300 103?24-81 0750 9Tota1 Tota1 Susp. diss.- Tota1 Tota1 Tota1 Tota1 Tota1 Tota1 Tota1 0&8 0&6 phosphorus?P so1ids so1ids cadmium chromium copper nicke1 1ead zinc iron I.R. Grav. mg/1 mg/1 mg/1 mg/1 mg/1 - -"mg/1 mg/i mg71 560009 (001) 3?23-81 1635 0.86 6 720 0.02 0.05 0.02 0.05 0.05 0.05 0.3 1 2 3-24-81 0730 1.0 9 650 0.02 0.05 0-02 0.05 0.05 0.05 0.58 3 - 2 Other Carbon Ch1oro- Tetrach1oro~ Trich1oro? 1,2 Dich1oro? aromatic Benzene tetrach1oride form Styrene ethy1ene ethy1ene ethy1ene - To1uene hydrocarbons ug? ug/1 uo/1 ug/1 ug/1 ug/1 ug/1 ug/1 ug/1 560009 1001) 3-23-81 1635 3-24-81 0730 Inf1uent 3-23-81 1630 84 5 45 10 5 INT. 270 15 3-24-81 0710 51 1 13 10 1 16 170 Cadmium Chromium Copper Nicke1 Lead Zinc Iron mg/ kg 1119/ kg mg/ kg mg/ 159. rag/kg. mg/ kg ME 3?24-81 0725 5 90 750 20 270 890 57;000 a 1 - Va1ues detennined in the fie1d at time of samp1ing. Mid1and Mastewater Treatment P1ant Tab1e 3 Comparison of survey resu1ts with the faci1ity's NPDES Permit and Month1y Operating Report. NPDES Permit Fina1 Survey Resu1ts1 fersmeter Limitations March Month1y Operating Report 30-day 7-day Month1y Month1y Average Average Average Maximum - 3?23-81 3-24-81 .560009 (001) Flow (M3/day) .. 31,000 36,200 27,800 27,600 20,700* 7-day Average 0005 (mg/(12, 19) (kg/day) 198 297. 307 363 389 4J6 460 Suspended so1ids (mg/(kg/day) 614 920 142 157 166 138 200 Disso1ved?oxygen (mg/1) 7.8 min. 7.2 7.5, 5.0, 7.2, Month1y Max. 7'2) Tota1 phosphorus-P (mg/1) 1 -- 0.43 0.90 0.70 0.70 1.1 (0.86, 1.0) Remova1) not <80 88.5 min. 81.8 82.5 83.9 67 pH (S.U.) not <6.5 nor >9.0 min. 6.6 7.2 6.9 6.8 (7.3, 7.1, 7.4, 7.5, 1 - Survey resu1ts are for the composite samp1e. Grab samp1e ranges are shown in parentheses P1ant tota1izer va1ue. To obtain MGD mu1tip1y M3/day by 0.0002642 To obtain 1bs/day mu1tip1y kg/day by 2.205 7.4) Tabie 4 Comparison of the 1aboratory Hastewater Treatment Piant a -5- anaiytica] reguits obtained by Midiand nd the Environmentai Protection Bureau from the spiit.composite sample. Outfaii 8005 Suspended solids Total phosphorus?P Ammonia nitrogen?N 560009 (001) Midland HHTP E.P.B. mg/i mg/1 18 16 4. I 6 0.61; 1.1 13.4 - 13 Infiuent Midiand WHTP E.P.B. mg/1 mg/1 3.40 3.3 -7- Midland Nastewater Treatment Plant Table 5 Comparison of the previous survey results with the results obtained in this survey. Outfall 560009 (00l) Survey Date From 7-22?80 3-23-8l To 7?23-80 3?24-81 mg/l - mg/l COD . 52 50 BOD5 10 16 Nitrite nitrate nitrogen?N . 0.03 0.04 Ammonia nitrogen?N l7 13 Kjeldahl nitrogen?N 22 18 Orthophosphates?P 0.21 0.64 Total phosphorus-P (Effluent) 0.36 l.l Total phosphorus-P (Influent) 4.l 3.3 Suspended solids 5 6 Dissolved solids 480 680 Total cadmium (Cd) 0.02 0.02 Total chromium (Cr) 0.05 0.05 Total copper (Cu) 0.02 0.02 Total nickel (Ni) 0.05 0.05 Total lead (Pb) 0.05 0.05 Total zinc (Zn) 0.05 0.05 Total iron (Fe) 0.80 0.l8 ug/l PCB l242 0 0 PCB l254 0 0 PCB 1260 0 0 DEHP 5 3 4 5 Other phthalates _Table 6 Sample Preservation Parameter COD TOC D.0. Total Metals Microbiology Oil Grease Acid Base?neutral Extractables Preservative l0 drops conc. ml (to pH Fixed on sitednops 10% sodium_thiosulfate/125 ml to deehlorinate sample. - 10 drops conc. ml (to pH Dechlorinated (if needed) with sodium thiosulfate (l drop 0.14l N/mg/l ml). Purgeable Organics All samples cooled to and preserved upon collection and chain of custody maintained. Lab Letter Codes - Indicates material was analyzed7for but not detected. Trace. - Results based upon colony counts outside the acceptable range. Estimated value; value may not be accurate. FC Fewer than 20 colonies were observed on the filter. GC - Number of colonies counted greater than the upper limit (80 for Total Coliform, 60 for Fecal Coliform, for Fecal Streptococcus). I HT - The recommended maximum laboratory holding time was exceeded before analysis. PT - Recommended laboratory preservation technique not used. . INT. - Interference encountered during an analysis resulted in not obtainable value.' Survey by: Contact with Management: Certified Operator: Hydrocarbon Analyses by: Physical, Chemical Bacteriol Distribution MM 6/24/81 ogical Analyses by: Report by: Ralph Reznick, Environmental Engineer William Long, Water Quality Investigator Edward Hamilton, Hater Quality Technician Steven Young, Assistant Plant Superintendent Arthur Maas, Plant Superintendent Environmental Protection Bureau Laboratory Environmental Protection Bureau Laboratory Ralph Reznick . Edward Hamilton Point Source Studies Section Environmental Services Division Environmental Protection Bureau Tichigan Dept. of Natural Resources 1. nun. mums 3-4500 FunIncl: TRICILJNG nu [l8 ?mm Ian-um: Inning near 54400 snunma w- Hm P: Icnvutn . swan: a; sun" m: I'llhl count-urn Owns." - a?uao mun-n :0 mac: mam I "?50 "a PUIIPS fume: - I saws: you . an at - narurr leb'?? I i swam? arr arr rut-v Wanner cunts . I may: . I tounuzuuou sumac (can? 5 .. 510nm: numu CLEMED I: ?cu nu has i cum-nu count! at . OKIOAT ION OXIOIZCD VIEUU II ?on -r sums: nuns I rmcuuma amulet Figure 1: MIDLAND. MICHIGAN TREATMENT PLANT PROCESS SCHEMATIC Figure 2 Midland Nastewater Treatment P1ant I75 CITY RD. ll Treatment:P1ant?x ,r . CHEN 1.1 CITY BF HIDLAHB ANNURL REP. FDR HASTEHAIER DEPT. 77-73 3W (3 E) hl l. C1l? E.f? LIBRARY ONLY Mr. C. R. Miles City Manager City of Midland Midland, Michigan 48640 Subject: Annual Report For The Wastewater Department Fiscal Year 1977-78 Dear Mr. Miles: During the past year the Wastewater Treatment Plant processed a total of 2,590,600,000 gallons of wastewater for an average of 7,097,500 gallons per day. The solids that were removed in the treatment facilities and pumped to the sludge holding tanks totaled 5,587,900 gallons. The solids were thickened in the gravity holding tanks, then processed through the Zimpro thermal sludge conditioning system at 370?3800 F. for approximately 20 minutes. The combi- nation of heat, air and pressure resulted in a breakdown of the cellular structure of the solids allowing a further gravity thickening to occur, concentrating into 2,122,300 gallons. The thickened sludge was dewatered on vacuum filters leaving 3,750 cubic yards of sludge that was trucked to the sanitary landfill. This sludge contained 3,023,600 pounds of dry solids that had been removed from the wastewater. A total of 625 trips were made to the landfill to dispose of the sludge from the vacuum filter process. II ?3 cm 1.1 EASTEHRTER cm Harman/cm DF nmmun AHHURL REP. FDR DEPT. 77-73 3W (3 E) hi P'l. FQIS game: usmmr om Mr. C. R. Miles City Manager City of Midland Midland, Michigan 48640 Subject: Annual Report For The Wastewater Department Fiscal Year 1977-78 Dear Mr. Miles: i During the past year the Wastewater Treatment Plant: processed a total of 2,590,600,000 gallons of wastewater'for an average of 7,097,500 gallons per day. I The solids that were removed in the treatment facilities and pumped to the sludge holding tanks totaled 5,587,900 gallons. The solids were thickened in the gravity holding tanks, then processed through the Zimpro thermal sludge conditioning system at 370?3800 F. for approximately 20 minutes. The combi? nation of heat, air and pressure resulted in a breakdown of the cellular structure of the solids allowing a further gravity thickening to occur, concentrating into 2,122,300 gallons. The thickened sludge was dewatered on vacuum filters leaving 3,750 cubic yards of sludge that was trucked to the sanitary landfill. This sludge contained 3,023,600 pounds of dry solids that had been removed from the wastewater. A total of 625 trips were made to the landfill to dispose of the sludge from the vacuum filter process. I a - CHEH 1.1 HASTEHATER CITY BF RNNUAL REP. FDR HASTEHATER DEPT. 77?78 JW (3 E) bl l. C>f2 F213 fugue LIBRARY (mu Mr. C. R. Miles City Manager City of Midland Midland, Michigan 48640 Subject: Annual Report For The Nastewater Department Fiscal Year 1977?78 Dear Mr. Miles: During the past year the Wastewater Treatment Plant processed a total of 2,590,600,000 gallons of wastewater for an average of 7,097,500 gallons per day. The solids that were removed in the treatment facilities and pumped to the sludge holding tanks totaled 5,587,900 gallons. The solids were thickened in the gravity holding tanks, then processed through the Zimpro thermal sludge conditioning system at 370-3800 F. for approximately 20 minutes. The combi- nation of heat, air and pressure resulted in a breakdown of the cellular structure of the solids allowing a further gravity thickening to occur, concentrating into 2,122,300 gallons. The thickened sludge was dewatered on vacuum filters leaving 3,750 cubic yards of sludge that was trucked to the sanitary landfill. This sludge contained 3,023,600 pounds of dry solids that had been removed from the wastewater. A total of 625 trips were made to the landfill to dispose of the sludge from the vacuum filter process. CHEN 1.1 HASTEHATER CITY HANRBERIEITY UF HIDLAHD ANNUAL REP. FUR HASTEHQTER DEPT. 77?78 JW (3 E) F'l. C)Miles City Manager City of Midland Midland, Hichigan 48640 Subject: Annual Report For The Wastewater Department Fiscal Year 1977-78 Dear Mr. Miles: During the past year the Wastewater Treatment Plant processed a total of 2,590,600,000 gallons of wastewater for an average of 7,097,500 gallons per day. The solids that were removed in the treatment facilities and pumped to the sludge holding tanks totaled 5,587,900 gallons. The solids were thickened in the gravity holding tanks, then processed through the Zimpro thermal sludge conditioning system at 370?3800 F. for approximately 20 minutes. The combi- nation of heat, air and pressure resulted in a breakdown of the cellular structure of the solids allowing a further gravity thickening to occur, concentrating into 2,122,300 gallons. The thickened sludge was dewatered on vacuum filters leaving 3,750 cubic yards of sludge that was trucked to the sanitary landfill. This sludge contained 3,023,600 pounds of dry solids that had been removed from the wastewater. A total of 625 trips were made to the landfill to dispose of the sludge from the vacuum filter process. CHCH 1.1 HASTEHPTER CITY 0F MIDLAND AHNURL HEP. FDR HASTEHATER DEPT. 77-78 3% (D E) F3 LIBRARY ONLY Mr. C. R. Miles City Manager City of Midland Midland, Michigan 48640 Subject: Annual Report For The Wastewater Department Fiscal Year 1977-78 Dear Mr. Miles: During the past year the Wastewater Treatment Plant processed a total of 2,590,600,000 gallons of wastewater for an average of 7,097,500 gallons per day. - The solids that were removed in the treatment facilities and pumped to the sludge holding tanks totaled 5,587,900 gallons. The solids were thickened in the gravity holding tanks, then processed through the Zimpro thermal sludge conditioning system at 370?3800 F. for approximately 20 minutes. The combi? nation of heat, air and pressure resulted in a breakdown of the cellular structure of the solids allowing a further gravity thickening to occur, concentrating into 2,122,300 gallons. The thickened sludge was dewatered on vacuum filters leaving 3,750 cubic yards of sludge that was trucked to the sanitary landfill. This sludge contained 3,023,600 pounds of dry solids that had been removed from the wastewater. A total of 625 trips were made to the landfill to dispose of the sludge from the vacuum filter process. 1 Federal Register] Vol. 49. No. 77 I Thursday. April ?19. 1984 I Unified Agenda 16379 EPA WA Current and Prolected Docket No. 0-8206. FTS: 8-382-5819. Agency Contact: Thomas Whalen. Environmental Protection Agency. 547). Washington. DC 20400. 202 382- 5819 HIN: 01. NPDES NEW SOURCE AND SHORT APPLICATION FORMS (REVISION) Legal Authority: 33 USC 1311 I CWA 301 CFR Citation: 40 CPR 122 Abstract: This action will develop an NPDES application form for new manufacturing. commercial. mining. and silvicultural operations. Besides obtaining information necessary for setting ef?uent discharge limitations. it will also help permit writers to determine whether the facility is a new source. This action will also develop a short. two-page application form for use by non-process wastewater dischargers. These dischargers usually contain only materials such as sanitary wastes and non-contact cooling water. Timetable: Action Date FR Cite NPRM 06/00/84 Final Action 04/00/85 Small Entity: No Additional Information: SAR No. 1725. ?33426-2970. Agency Contact Gait Goldberg. Environmental Protection Agency. (EN- 330}. Washington. DC 20460. 202 428- 2970 RIM: 82. REQUIREMENTS FOR APPLICATION FOR VAEIANCES Legal Authority: 33 USC 1311 CWA 311 CFR Citation: 40 CFR 125 Abstract: Section 301(c} of the Clean Water Act prgvides In: on commie mode of the strict requirements of BAT controls for non- toxic. non?conventional pollutants. This regulation will establish application ground rules and national criteria for granting variances from BAT requirements. Timetable: Action Date FR Cite 00/00/00 Small Entity: Lindetermined Additional Information: SAR No. 1401. FPS: 8-382-2724. Agency Contact: Karen Sharer, Environmental Protection Agency. 220), Washington. DC 20400. 202 382: 2724 am: seas-M01 63. WAIVERS FROM BAT FOR NONCONVENTIONAL POLLUTANTS UNDER 301(6) (REVISION) Legal Authority: 33 usc 1311 I own 301 CFR Citation: 40 CPR 125 Abstract Section 301(3) allows NPDES permit applicants to equal a waiver from BAT ef?uent limitations for nonconventional pollutants when the applicant can show that a less stringent permit limit will not utterfere with the attainment or maintenance of water quality and will not outings human health or the environment. This regulation will establish guidelines for evaluating waiver applications. Timetable: Action Oat. CH. NPRM 04/00/64 Final Action 03/00/85 Small Entity: No Additional lnlormation: SAR No. 1634. Flaws-mm Agency Contact: Robert Canimi. Environmental Protection Agency. (EN- 330]. Washington. DC 20400. 202 426- 7010 BIN: 2040-AA02 4.1 COMPLIANCE. exrsasios FOR TECHNOLOGY son DISCHARGE (REVISION) Legal Autho?ty: 33 USC 1811 I CWA 301 CPR Cmuon: 4O CFH 125 Abstl'a?: Section 3010:) allows industrial dischargers to request an . extension of the compliance date for EAT until July 1. 1987 if they Will install an hmovstive technology. This technology must produce either: af?uent reduction greater than BAT. or same ef?uent reduction at signi?cantly lower cost. it must also have the potential for industry-wide application. Timetable: Action on rs cs. menu sens/so 45 FR szsos NPRM 09/21/81 46 FR 4859? Final Action 04/00/34 Smell Entity: No Additional iniormation: SAR No. 1000. Was-7010. Agency Contact: Marilyn Goods. Environmental Protection Agency. 330). Washington. DC 201160.282 us- 7010 BIN: 2040-AA03 EFFLUENT coloeuuss son . FIGANIC CHEMICALS mo rus'ncs AND FIBERS (REVISION) Priority: Major Legal Authority: 33 use 1311 I cwa 301; 33 USC1314 I CWA 304; 33 USC 1316 CWA 306; 33 USC 1317 I CWA 307: 33 USC 1481 I CWA 501 CFFI Citation: 40 CFR 414; 40 CFR 416 Abstract: The Agency has proposed BAT. NSPS and pretreatment standards for the organic chemicals portion of this industry (SIC 2805. 2809]. Pollutants include aromatic chlp_ripated hbeons. compounds. and metals. EPA also proposed BCT. BAT. NSPS. and pretreatment standards for the plastics and portion of this industry 2821. 2823. 2024). Pollutants or concern include phenols. acrolein. vinyl chloride. and metals. Timetable: Action Due FR Cite NPRM 03/21/83 48 FR 11828 Notice 8/00/84 Final Action 02/00/85 Smell Entity: Undetermined Additional information: SAR No. 1415. Analysis: HIA Agency Contact: Lil. Fer-ht. Environmental Home Agency. 552). Washington. DC 20400. an ass. 71m RIN: 2040-AA05 0. sea?dwa Elsderal Register] Vol. 49. No. 77 I Thursday. April ?19. 1884 I Unified Agenda 1637!? Current and Prolected Ruiamakinga Docket No. 082-00. 3-382-5819. Agency Contact: Thomas Whalen. Environmental Protection Agency. 547]. Washington. DC 20400. 202 382- 5819 RIN: 2040-AA71 01. NPDES NEW SOURCE AND SHORT APPLICATION FORMS (REVISION) Legal Authority: 33 USC 1311 I CWA 301 CFR Citation: 40 CFR 122 Abstract: This action will develop an NPDES application form for new manufacturing. commercial. mining. and silvicultural operations. Besides obtaining information necessary for setting ef?uent discharge limitations. it will also help permit writers to determine whether the facility is a new source. This action will also develop a short. two-page application form for use by non-process wastewater dischargers. These dischargers usually contain only materials such as sanitary wastes and non-contact cooling water. Timetable: Action Date FR Cite 06/00/84 Final Action 04/00/ 85 Small No Additional information: SAR No. 1725. PPS: 8426-2970. Agency Contact: Gail Goldberg. Environmental Protection Agency. (EN- 336]. Washington. DC 20480. 2'02 438- 2970 RIN: 2040-AAOO 82. REQUIREMENTS FOR APPLICATION FOR 301(0) vanmaces Legal Authority: 33 USC 1311 CWA 311 CFR Citation: 40 CFR 125 Abstract Section 301(c) of the Clean Water Act pLovidesIor variances on osmotic minds of the strict requirements of BAT controls for non- toxic. non- -conventional pollutants. This regulation will establish application ground rules and national criteria for granting variances from BAT requirements. Timetable: Action Date FR Cite NPRM 00/00/00 Small Entity: Undetermined Additional Information: Na. 1404. 8-382-2724. Agency Contact: Karen Shaisr. Environmental Protection Agency. (PM- 220). Washington. DC 20400. 202 302- 2724 RIN: 2040-AA01 83. WAIVERS FROM BAT FOR NONCONVENTIONAL POLLUTANTS UNDER 301(6) (REVISION) Legal Authority: 33 USC 1311 CWA 301 CFR Citation: 40 CFR 125 Abstract Section 301(3) allows NPDES permit applicants to request a waiver from BAT effluent limitations for nonconventionai pollutants when the applicant can show that a less stringent permit limit will not interfere with the attainment or maintenance of water quality and will not endanger human health or the environment. This regulation will establish guidelines for evaluating waiver applications. Timetable: Action Date PR Cite NPRM 04/00/84 Final Action 03/00/05 Small Entity: No Additional information: SAR No. 1634. ?38428?7010. Agency Contact Robert Cantilii. Environmental Protection Agency. 330]. Washington. DC 20460. 208 428- 7010 RIN: 2040-AA02 . COMPLIANCE EXTENSION FOR 8 QNOVATIVE TECHNOLOGY DISCHARGE (REVISION) Legal Authority: 33 use 1011 I CWA 301 CFR Citation: 40 CHI ?38 Abstract Section 3010:) allows industrial dischargers to request an . extension of the compliance date for BAT until July 1.1987 if they will install an innovative technology. This technology must produce either: (1) ef?uent reduction greater than BAT. or same ef?uent reduction at signi?cantly lower cost. It must also have the potential for industry?wide application. Timetable: Action Date FR Cite ANPRM 09/19/80 45 FR 82509 NPRM 09/21/81 46 FR 46597 Final Action 04/00/84 Small Entity: No Additional information: SAR No. 1808. ?3:8426-7010. Agency Cont-Ct: Marilyn Goods. Environmental Protection Agency. (EN- 338]. Washington. DC 20480. as: 038- 7010 NIH: 2040-AA03 EFFLUENT GUIDELINES FOR RGANIC CHEMICALS AND PLASTICS AND FIBERS (REVISION) Priority: Msior Legal Authority: 33 USC 1311 CWA 301-, 33 0501314 CWA 304; 33 use 1316 CWA 306; 33 use 1317 CWA 307; 33 use 1461 CWA 501 CFR Citation: 40 CFFI 414; 40 CFR 410 Abstract: The Agency has proposed BAT. NSPS and pretreatment standards for the organic chemicals portion of this industry 2885. 2809}. Pollutants include aromatic chlorinated phenolic compounds. and metals. EPA also proposed BAT. BPT. NSPS. and pretreatment standards for the plastics and portion of this industry (SIC 2021. 2023. 21321). Pollutants of concern include phenols. acrolein. vinyl chloride. and metals. Timetable: Action om FR Cite NPRM 03/21/83 48 FR 1182;: Notice 8/00/84 Final Action 02/00/85 Small Entity: Undetermined Additional information: SAR No. 1415. Analysis: FilA Agency Contact: EH. Fat-sin. Environmental Protection Agency. [Wil- 7190 RIN: 2040-AA05 iv 3 . .i Edorai Register! Vol. 49. No. 77 I Thursday. April ?19. 1984 I Unified Agenda 16379 Current and Projected Rulemskings Docket No. 0-82-06. 8-382-5819. Agency Contact: Thomas Whalan. Environmental Protection Agency. 547). Washington. DC 20400. 202 382- 5019 RIN: 01. NPDES NEW SOURCE AND SHORT APPLICATION FORMS (REVISION) Legal Authority: 33 USC 1311 I CWA 301 CFR Citation: 40 CFR 122 Abstract: This action will develop an NPDES application form for new manufacturing. commercial. mining. and silvicultural operations. Besides obtaining information necessary for setting ef?uent discharge limitations. it will also .help permit writers to determine whether the facility is new source. This action will also develop a short. two-page application form for use by non-process wastewater dischargers. These dischargers usually contain only materials such as sanitary wastes and non-contact cooling water. Timetable: Action Date FR Gite NPRM 06/00/84 Final Action 04/ 00/ 85 Small Entity: No Additional information: SAR No. 1725. 1818-4220-2970. Agency Contact Call Goldberg. Environmental Protection Agency. 330). Washington. DC 20460. 202 428- 2970 RIN: 2040-AA00 82. REQUIREMENTS FOR APPLICATION FOR 301(6) VARIANCES Legal Authority: 33 USC 1311 I CWA 311 CFR Citation: 40 CFR 125 Abstract Section 301(c] of the Clean Water Act prgvides In: var-ignces on economic grounds of the strict requirements of BAT controls for non- toxic. non-conventional pollutants. This regulation will establish application ground rules and national criteria for granting variances from BAT gequirements. Timetable: Action Date FR Cite NPRM 00/00/00 Small Entity: Undetennined Additional information: SAR No. 1404. 8-382-21712-4. Agency Contact: Karen Sharer. Environmental Protection Agency. 220]. Washington. DC 20460. 202 302- 2724 am: 83. WAIVERS FROM BAT FOR NONCONVENTIONAL POLLUTANTS UNDER 301(6) (REVISION) Legal Authority: 33 usc 1311 I own 301 CFR Citation: 40 CFR 125 Abstract Section 301(3) allows NPDES permit applicants to request a waiver from BAT ef?uent limitations for nonconventional pollutants when the applicant can show that a less stringent permit limit will not interfere with the attainment or maintenance of water quality and will not endanger human- health or the environment. This regulation will establish guidelines for evaluating waiver applications. Timetable: Date Action FR Cite NPRM 04/00/84 Final Action 03/00/85 Small Entity: No Additional information: SAR No. 1834. Mme. Agency Contact: Robert Ceniilli. Environmental Protection Agency. 330]. Washington. DC 20460. 202 420- 7010 RIN: 43). COMPLIANCE EXTENSION FOR suowmvs TECHNOLOGY son mousrew. DISCHARQE Legal Authority: 33 USC 1811 CWA 301 AOCFR125 -- -- Abetl'act: Section 3010:) allows industrial dischargers to request an extension of the compliance date for BAT until luly 1. 1987 if they will install an innovative technology. This technology must produce either: effluent reduction greater than BAT. or (2) samaeffluent reduction at significantly lower cost. it must also have the potential for industry-wide application. Timetable: Action Dela FR Cite ANPRM 08/19/80 45 FR 02509 NPRM 09/21/81 46 FR 46597 Final Action 04/00/84 Small Entity: No Additional Information: SAR No. 1808. Agency Contact: Marilyn Goods. Environmental Protection Agency. 338}. Washington. DC 20480. NZ 4% 7010 RIN: 2040-AA03 a: EFFLUENT GUIDEUNES FOR 0 RGANIC CHEHICALS AND PLASTICS AND FIBERS (REVISION) Priority: Major Legal Authority: 33 USC 131: I ch 301: 33 use 1314 I CWA 304; 33 USC 1316 I own 306; 33 usc 1317 I CWA 307; 33 use 1461 I cm 501 CFR Citation: 40 CFR 414; 40 CFR 416 Abstract: The Agency has proposed BPT. BAT. NSPS and pretreatment standards for the organic chemicals portion of this industry 2885. 2869}. Pollutants include aromatic compounds. and metals. EPA also proposed BAT. BPT. NSPS. and pretreatment standards for the plastics and portion of this industry 2821. 2823. 2024). Pollutants of concern include acrolein. vinyl chloride. and metals. Timetable: Action Date FR Cite NPRM 03/21/83 48 FR 11828 Notice 8/00/84 Final Action 02/00/35 Small Entity: Undetermined Additional Information: SAR No. 1415. Analysis: HIA Agency Contact: EH. Farah, Environmental Probation Agency. [Wil- 552). Washington. DC 204%. 282 382- 7190 BIN: 2040-AA05 deral Register] Vol. 49. No. 77 Thursday. April 19. 1984 I Unified Agenda 16379 Current and Projected Rulemakinga Docket No. 6?82-06. FIB: 3-382-5319. Agency Contact: Thomas Whalen. Environmental Protection Agency. 547]. Washington. DC 20480. 2.02 302.- 5019 RIN: BI. NPDES NEW SOURCE AND SHORT APPLICATION FORMS Legal Authority: 33 USC 1311 I CWA 301 CPR Citation: 40 CFR 122 Abstract: This action will develop an NPDES application form for new manufacturing. commercial. mining. and silvicultural operations. Besides obtaining information necessary for setting ef?uent discharge limitations. it will also help permit writers to determine whether the facility is a new source. This action will also develop a short. two-page application form for use by non-process wastewater dischargers. These dischargers usually contain only materials such as sanitary wastes and non?contact cooling water. Timetable: Action Date FR Cite NPRM 06/00/84 i-?mal Action 04/00/85 Small Entity: No Additional Information: SAR No. 1725. FrS:8-426-297o. Agency Contact Gail Goldberg, Environmental Protection Agency. (EN- 336}. Washington. DC 20460. 202 428- 2970 2040-AA00 02. REQUIREMENTS FOR APPLICATION FOR VABIANCES Legal Authority: 33 USC 1311 I CWA 31: CPR Citation: 40 CFR 125 Abstract Section 301(c) of the Clean Water Act prgvides Inr var?nces on gr_o_1?nds of the strict requirements of BAT controls for non- toxic. non-conventional pollutants. This regulation will establish application ground rules and national criteria for granting variances from BAT requirements. Timetable: Action Dot. FR Clio NPRM 00/00/00 Small Entity: Undetermined Additional information: BAR Na. 1404. PPS: 8-382-2724. Agency Contact: Karen Sharer. Environmental Protection Agency. (PM- 220). Washington. DC 20460. 202 382- 2724 Rm: 83. WAIVERS FROM BAT FOR HONOONVENTIONAL POLLUTANTS UNDER 301(6) (REVISION) Legal Authority: 33 usc 1311 I 301 cm Citation: 40 CFR 125 Abstract Section 301(3) allows NPDES permit applicants to request a waiver from BAT effluent limitations for nonconven tional pollutants when the applicant can show that a less stringent permit limit will not interfere with the attainment or maintenance of water quality and will not endanger human - health or the environment. This regulation will establish guidelines for evaluating waiver applications. Timetable: Action Date FR Cite 04/00/34 Final Action 03/00/05 Small No Additional information: BAR No. 1034. ?53425-7010. Agency Contact: Robert Cantiiti. Environmental Protection Agency. 330). Washington. DC 20480. 202 428- 7010 . RIN: COMPLIANCE EXTENSION FOB TECHNOLOGY FOR DISCHARGE (REVISION) LogaIAuthorlty: 33USC 400FR125- Abstract Section 3010:] allows industrial dischargers torequeatan extension of the complimoe date for BAT until July 1. 1987 if they win install an irurovative technology. This - technology must produce eiiha: (ill effluent reduction greater than BAT. or same ef?uent reduction at signi?cantly lower cost. it must also have the potential for industry-wide application. Timetable: Action Dela Fill Clo ANPHM 00/19/80 45 02509 09/21/31 48 FR 46587 Final Action 04/00/54 Small Entity: No Additional information: SAR No. 1110s. Agency Contact: Marilyn Gouda. Environmental Protection Agency. 330}. Washington. DC 20480. as: 48- 7010 BIN: 2040-AA03 EFFLUENT GUIDELINES FOR RGANIC CHEMICALS AND PLASTICS AND FIBERS (REVISION) Priority: Major Legal Authority: 33 USC 1311 cwa 301; 33 0301314 CWA 304; 33 use 1316 CWA 308; 33 USC 1317 CWA 307; 33 usc 1461 Iowa 501 CFFI Citation: so CFR 414; so OFF 416 Abstract The Agency has proposed BAT. NSPS and pretreatment standards for the organic chemicals portion of this industry (SIC 2865. 2809). Pollutants include armtic compounds. and metals. EPA also proposed BCT. BAT. NSPS. and pretreatment standards for the plastics and portion of this industry (SIC 2821. 2823. 2824]. Pollutants of concern include phenols. acrolein. vinyl chloride. and metals. Timetable: Action Date FR Cite NPRM 03/21/83 48 FR 11828 Notice 8/00/84 Final Action 02/00/85 Small Entity: Undetermined Additional Information: SAR No. 1415. ?8032-7190. BIA Agency Contact: EH. Persist. Environmental ?Dietitian Agency. (Vt/ll- 552). Washington. DC 20480. 282 302- 7190 W05 -0 I adore! Register] Vol. 49. No. 77 I Thursday, April 19. 1984 Unified Agenda Existing Regulations Under Review Timetable: Small Entity: No Agency Contact Gary . Environmental Protection Agency. PM- Actlon Date FR Cite Additional lntorrnetlon. REVIEW - H. . - 223. Washington. DC 20400. 202 383- Begin Review 06/00/84 Paperwork Reduction 2741 500 Review 06/00/85 8-382-2741. BIN: 2070-4303 ENVIRONMENTAL PROTECTION AGENCY (EPA)?Toxlc Substances Control Act (TSCA) Completed Actions COMPLETED RULEMAKINGS 75. GOOD LABORATORY PRACTICE STANDARDS CFR Citation: 40 CFR 792 Esmestsw Reason Date FR Cite Final Action 11/29/83 48 FR 53922 Small Entity: Undetermined Agency Contact Dr. Irwin Bsumai 202 382-4241 . BIN: 76. 1903 DECISION ON TEST RULES FOR ITC PRIORITY CHEMICALS, LISTS 1-6 - Citation: 40 CFR 790 Completed: Date FR Cite Final Decision 12/31/83 Small Entity: No Agency Contact: Gary Time 202 47!- 8130 RIN: 2070-M25 77. DECISION ON TEST RULE FOR FORMAMIDE CFR Citation: Not applicable Completed: Dete FR Cite Final Action 12/29/83 48 FR 57365 Small Entity: No Agency Contact: Gary Timm 202 475- 0130 RIN: 2070-AA66 [Flt Dec. u-esea Filed onset; an] ENVIRONMENTAL PROTECTION AGENCY (EPA)?Cleln Water Act (CWA) Current and Projected QUALITY MANAGEMENT EGULATIONS (REVISION) Legal Authority: 33 USC 1258 I CWA 106; 33 USC 1288 I CWA 208; 33 USC 1313 I 303 CFR Citation: 40 CPR 35 Abstract The Clean Water Act authorizes EPA to provide grants and other assistance to States and other governmental jurisdictions to develop and implement water quality management programs. EPA is revising the existing regulations to simplify the requirements and to remove 821.. aspects of the regulations that 93 undulyaetailed amend e. Timetable: Action Date FR Cite NPRM 10/19/82 47 FR 46688 Final Action 07/03/84 Smell Entity: No Additional Information: SAR No. 1802.. Agency Contact: Carl Myers. Environmental Protection Agency. (WH- 554]. Washington. DC 20460. an 382- 7100 HIN: 2040-AA37 79. OSIMPLIFYING CONSTRUCTION GRANTS REGULATIONS (REVISION) Legal Authority: 33 USC 1381 I CWA 201 CFR Cltatlon: 40 CFR 35. Appendix A Abstract: A revised interim ?nal regulation describing allowable and unallowabie costs for construction grant projects was published Febmary 17. 1934. This rule will not be published as a a ?nal rule until after Congress acts on reauthorizstion of the construction grants program. Timetable: Action Date FR Cite NPRM 11/06/81 40 55220 NPRM 05/12/82 47 FR 20470 interim Final Rule 05/12/82 47 FR 20450 Revised interim 02/17/84 49 FR 6224 Final Rule . Fhal Action 06/00/86 Smell Entity: No Additional WOWSAR No. 1722. Docket No; 6-814. 5382-7277. Agency Contact: William Kramer. Environmental Protection Agency. (WH- 595). Washington. DC 20460. 202 382- 7277 NIH: 2040-AA70 00. OSIMPLIFYING CONSTRUCTION GRANTS REGULATIONS (REVISION) Legal Authority: 33 USC 1361 I CWA 201 CPR Citation: 40 cm 35.2205 Abstract: This rule proposes to specify a maximum allowable project cost which will limit increases on grants for construction of publicly owned treatment works This limit is intended to provide additional incentive for communities to manage their grant funds as efficiently as possible. It will limit the allowable cost increase for grants awarded after the effective date of this rule. Timetable: Actlon Date FR Cite NPRM 02/17/04 49 FR 6113 Final Action 07/00/84 Final Action 10/00/35 E?ectlve Smell Entity: No Additional information: SAR No. 1722. 1ti?i? gFederal Register] Vol. 49. No. 77 Thursday. April 19. 1984 I Unified Agenda Existing Regulations Under Review Timetable: Small Entity: No agency mangoes? Deutsch. Hm . Vironmen BC 1011 . - 3:32:1le ggiwmsim. Dc mAio'l?Win. End Rel/law 06/00/85 FTS: 3-382-2741. RIN: ENVIRONMENTAL PROTECTION AGENCY (EPA)?Toxlc Substances Control Act (T SCA) COMPLETED RULEMAKINGS 75. GOOD LABORATORY PRACTICE STANDARDS CFR Citation: 40 CFR 792 Completed: Reason Date FR Cite Final Action 11/29/83 '48 FR 53922 Small Entity: Undetermined Agency Contact: Dr. Irwin Baumel 202 302-4241 . RIN: 76. 1983 DECISION ON TEST RULES FOR ITC PRIORITY CHEMICALS. LISTS 1-6 - CFR Citation: 40 790 Completed: Reason Date FR Cite Final Decision 12/31/83 Small Entity: No Agency Contact: Gary Timm 475- 8130 RIN: 2070-AA25 Completed Actions 77. DECISION ON TEST RULE FOR FORMAMIDE CFR Citation: Not applicable Completed: Reason Date FR Cite Final Action 12/29/83 40 FR 57365 Small Entity: No Agency Contact: Gary Timm 202 475- 0130 BIN: 2070-AA66 mono. unscented 01-th mm] eel/seems?? ENVIRONMENTAL PROTECTION AGENCY (EMU?Clean Water Act (CWA) Current and Projected Rulemakings QUALITY MANAGEMENT EGULATIONS (REVISION) Legal Authority: 33 USC 1256 CWA 106: 33 USC 1288 I CWA 208; 33 USC 1313 .CWA 303 0101' Citation: 40 CFR 3513 Abstract: The Clean Water Act authorizes EPA to provide grants and other assistance to States and other governmental jurisdictions to develop and implement water quality management programs. EPA is revising the existing regulations to simplify the requirements and to remove 3111.. eggs-late of the regulations that 239 unduly-detailed or in exible: ?Timetable: Action Date FR Cite NPRM 10/19/62 47 FR 46680 Final Action 07/00/84 Small Entity: No Additional Information: SAR No. 1802., Agency Contact: Carl Myers. Environmental Protection Agency. 554]. Washington. DC 20460. 202 382- 7100 RIN: 79. OSIMPLIFYING CONSTRUCTION GRANTS REGULATIONS (REVISION) Legal Authority: 33 USC 1361 CWA 201 CFR Citation: 40 CFR 35. Appendix A Abstract A revised interim final regulation describing allowable and unallowsble costs for construction grant projects was published February 17. 1904. This rule will not be published as a final rule until after Congress acts on reauthorization of the construction grants program. Timetable: Action Date FR Cite Previous NPRM 11/00/81 46 FR 56220 05/12/02 4? FR 20470 Interim Final Rule 05/12/82 47 FR 20450 Revised Interim 02/17/84 49 FR 6224 Final Rule Final Action Smell Entity: No Additional MWBAR Nortnz. Docket No; 601-5. ll: 8-382-7277. Agency Contact: William Kramer. Environmental Protection Agency. (WH- 595], Washington. DC 20460. 202 332- 7277 RIN: 2040-AA70 80. .SINPLIFYING CONSTRUCTION GRANTS REGULATIONS (REVISION) Legal Authorlty: as use 1351 I CWA 201 CPR Citation: 40 CFR 35.2205 Abstract: This rule proposes to specify a maximum allowable project cost which will limit increases on grants for construction of publicly owned treatment works (POTWSL This limit is intended to provide additional incentive for communities to manage their grant funds as efficiently as possible. It will limit the allowable cost increase for grants awarded after the effective data of this rule. Timetable: Action Date FR Cite NPRM 02/17/84 ?9 FR 0113 Final Action 07/00/04 Final Action 10/00/85 Effective Small Entity: No Additional Information: SAR No. 1722. I. . is 16378 Federal Register] Vol. 49. No. 77 I Thursday. April 19. 1984 Unified Agenda Existing Regulations Under Review Timetable: Small Entity: No angeincy Contact: cat-t3; Dextoch. Action Date FR on. Additional information: REVIEW ?mm" 8 9? . gjg?gg Paperwork Reduction 22.52.1Washington. DC 20480. 202 302- 3-382-2741. BIN: 2070-11803 ENVIRONMENTAL PROTECTION AGENCY (EPA)?Toxlc Substances Control Act (T SCA) Completed Actions COMPLETED RULEMAKINGS 75. GOOD LABORATORY PRACTICE STANDARDS CFR Citation: 40 CFR 792 Complete? . Reason Date FR Cite Final Action 11/29/83 48 FR 53922 Small Entity: Undetermined Agency Contact Dr. Irwin Home] 202 382-4241 . RIN: 2070-AA13 76. 1983 DECISION ON TEST RULES FOR ITC PRIORITY CHEMICALS. LISTS 1-6 - CFR Citation: 40 CPR 799 Completed: Reason Date FR Otto Final Decision 12/31/83 Small Entity: No Agency Contact: Gary Titan: 202 475- 8130 RIN: 2070-AA25 77. DECISION ON TEST RULE FOR FORMAMIDE CFFI Citation: Not applicable Completed: Reason Onto FR Cite Final Action 1329/33 48 FR 57365 Small Entity: No Agency Contact: Gary Time: ms 475- 8130 RIN: 2070-AA66 an] I Ill-?? ENVIRONMENTAL PR AGENCY (Emil?Clean Water Act (CWA) QUALITY MANAGEMENT EGULATIONS (REVISION) Legal Authority: 33 USC 1256 I CWA 106: 33 USC 1288 I CWA 208; 33 USC 1313 CWA 303 cm Citation: 40 cm 35's Abstract: The Clean Water Act authorizes EPA to provide grants and other assistance to States and other governmental jurisdictions to and implement water quniir; management programs. is revising the existing regulations to simplify the requirements and to remove BEL aspects of the regulations that _a_i;e unduly detailed omexiblz Timetable: Action Date FR Cite NPRM 10/19/82 47 FR 46668 Final Action 07/00/84 Small Entity: No Additional information: SAR No. 1802.. Agency Contact Carl Myers, Environmental Protection Agency. 554}. Washington. DC 20460. 202 see- 7100 2040-M37 79. .SIMPLIFYING CONSTRUCTION GRANTS REGULATIONS (REVISION) Legal Authority: 33 USC 1381 201 CFR Citation: 40 CFR 35. Appendix A Abstract: A revised interim ?nal regulation describing allowable and unallowable costs for construction grant projects was published February 17. 1984. This rule will not he published as a a final rule until after Congress acts on reauthorization of the construction grants program. Timetable: Action Previous NPRM 11/06/81 NPRM 06/12/82 47 FR 20470 Interim Final Rule 05/12/82 47 FR 20450 Revised Interim 02/17/84 40 FR 8224 Final Rule Final Action Small Entity: No . Additional "11m 1722. Docket No; 0-816. 8-382-7277. Dot. 48FR55220 08/00!? Current and Protected Flutemalringe Agency Contact: William Kramer. Environmental Protection Agency. 595]. Washington. DC 20460. 202 382- 7277 RIN: 2040-AA70 BO. .SIMPLIFYING CONSTRUCTION GRANTS REGULATIONS (REVISION) Legal Authodty: 33 USC 1361 own 201 CFR Citation: 40 cm 35.2205 'Abetract: This rule proposes to specify a maximum allowable proiect cost which will limit increases on grants for construction of publicly owned treatment works This limit is intended to provide additional incentive for communities to manage their grant funds as ef?ciently as possible. It will limit the allowable cost increase for grants awarded after the effective date of this rule. Timetable: Action Date FR Gite 02/17/84 49 FR 6113 Final Action 07/00/84 Final Action 10/00/85 Effective Small Entity: No Additional information: SAR No. 1722. ll I 16378 Federal Register/ Vol. 49. NO. 77 I Thursday. April 19. 1984 Unified Agenda Existing Regulations Under Review Timetable: Small Entity: NO Agency Contact: Gilly Deutsch. . Environmental Protection Agency. PM- Actlon Date FR Cite Additional Information. REVIEW . . 23. Wash ton. DC 20460. 202 322: Begin Review 06/00,? ?ggnomrv. Paperwork Reduction 27? End Review 05/00/55 FPS: 34332-2741. 20704303 ENVIRONMENTAL PROTECTION AGENCY (span?Toxic Substances Control Act (T SCA) Completed Actions coup/Lamp nuusquINGs 76. 1953 DECISION 0N TEST RULES DECISION 0N TEST RULE FOR ,5 GOOD LABORATORY PRACTICE {'0an ITCO PRIORITY CHEMICALS. FORNAMIDE STANDARDS 5 Citation: Not applicable CFR Citation: 40 CFR 792 Guam": 4? 799. Completed: Completed: Reason om FR cm Reason om FR cm on. Final Action 12/29/53 43 FR 57355 Final Action 11/29/33 43 FR 53922 Final mm" 12?3"? Small Entity: NO Small Entity: Undetermined Agency Contact Dr. Irwin Baumel 202 382-4241 . BIN: Small Entity: No Agency Contact: Gary Timm 202 475- 8130 RIN: 2070-AA25 Agency Contact: Gary 202 475- 0130 BIN: zero?M65 Don 00-13-00; 345 all] nuns coo: m7 ENVIRONMENTAL PROTECTION AGENCY (EPAi?Clean Water Act (CWA) Q.) WATER QUALITY EGULATIONS (REVISION) Legal Authority: 33 USC 1256 I CWA 106: 33 USC 1288 CWA 208; 33 USC 1313 I CWA 303 crn? Citation: 40 CFR 356 Abstract The Clean Water Act authorizes EPA to provide gm '3 and other assistance to States and other governmental jurisdictions to develop and implement water quality management programs. EPA is revising the existing regulations to simplify the requirements and to remove an aspects Of the regulations that :33 unduly detailed OmeinJ-la IN Timetable: Action Date FR Cite NPRM 10/19/82 47 F-?ii 48868 Final Action 07/00/84 Smell Entity: No Additional Information: SAR NO. was. Agency Contact: Carl Myers. Environmental Protection Agency. 554}. Washington. DC 20480. 202 382- 7100 BIN: 2040-AA37 70. OSIMPLIFYINO CONQTRUCTION GRANTS REGULATIONS (REVISION) Legal Authority: 33 usc 1381 I CWA 201 CPR Citation: 40 CHI 35. Appendix A Abstract: A revised Interim ?nal regulation describing allowable and unallowsble costs for construction grant projects was published February 17. 1984. This rule will not be published as a a final rule until after Congress acts on reauthorization of the construction grants program. Timetable: Action Date FR Cite 11/06/81 46 FR 55220 NPRM 05/12/82 47 FR 20470 Interim Final Rule 06/12/82 47 FR 20450 Revised Interim 02/17/84 49 FR 6224 Final Rule - . Final Action 00/00/08 Smell Entity: No Additional intern-senses No. 1m. Docket No; Yrs: 5332-7277. . . Current and Projected Agency Contact: William Kramer. Environmental Protection Agency. 595]. Washington. DC 20400. 202 382- 7277 HIN: 80. QSIMPLIFYING CONSTRUCTION GRANTS REGULATIONS (REVISION) Legal Authority: 33 0501361 CWA 201 cm Citation: 40 cm 35.2205 This rule proposes to specify a maximum allowable project cost which will limit increases on grants for construction of publicly owned treatment works This limit is intended to provide additional incentive for communities to manage their grant funds as ef?ciently as possible. It will limit the allowable cost increase for grants awarded after the effective date of this rule. l'l'nm- -- 1 Action; Duh FR Cite NPRM 02/17/84 49 FFI 8113 Phil Action 07/00/84 Action 10/00/85 Ellectlve Small Entity: NO Additional Information: SAR No. 1722. ?t August 25 Had hr. haul hugger Surface water quality Division Michigan Department of Natural iesources box 3002b Lansing, Mi. 48909 Dear Mr. hugger: I am becoming increasingly concerned about Dow's past diaposal practices. Enclosed you will rind a report released by the city of Midland in 1980. This report, entitled, "Task Force 2000 Leisure Life Subcommittee Report of the Research Team on City Beautification" discusses erosion along the riverbank The report states, "In one spot erosion has seriously exposed old landfill materials, and liquids from them are leaching into the river? The comments that follow that statement do not address the issue of BEER materials might be leaching into the river. The major concern is that it is I believe that this report clearly reflects the Midland community's attitude. Outward appearances always take precedence over health and environmental concerns. I believe that the dump referred to in this report was used by Dow and the city in the '40's. I also believe that the Midland Farmer's Market was built on top of the dump. This same area has become a very popular spot for picknickers, since the building of the "Tridge." Concerts are held next to the river, and people are encouraged to bring their children, picnic lunches, and blankets for a relaxing evening by the river. Most people are not aware that they are laying on top of an old landfill. Needless to say, this attitude concerns me. It makes you wonder how many other sites in the area might be paved and seeded over, but still posin a threat to people and the environment. I am also concerned that the DNR does not have a handle on the situation._ Were you aware when you issued the recent controversial discharge permit to Dow, that this landfill was contributing to the pollution or the Tittabawassee River? Is this landfill being factored into the upcoming permit for the City of Midland Wastewater Treatment Plant? nave you asked Dow and the C137 0: Midland ii there are any other old landfills along the riverbanks and in rlOOdplain areas, that might be contributing to the pollution of the river? If these questions have not been asked, I consider it to be an extememe oversight on the part of the Surface Water Quality Division. if you have requested this information, would you please send it to me? I page th August Paul hugger have talKed to the Environmental Enforcement Division about this landfill, and it is my understanding that there will be an investigation by the Groundwater Quality Division. However, I would hope that in the meantime, your division would evaluate the impact on the river. This evaluation would not be complete until you request that how and the City of Midland identify all old disposal sites. One of my major complaints in the past has been the haphazard method the state has used ivr identifying contaminated sites. We have exprae 3 concern many times regarding the state's Site Assessment Program. Remedial Action Section missed several nidland sites last year. Just holding public hearings is not enough. The burden of identifying contaminated sites falls on the shoulders of citizens. If you miss the public hearing and the comment period, your site might not make the list. Why isn't that burden shifted to industry where it belongs? I get the feeling in Midland, that I'm playing hide and go seek with the city and Dow. They both know where many of these old disposal sites are located, but aren't telling. rhe situation is so absurd, that I actually considered having a contest to see who could identify the most sites. The winner would receive an all expense paid trip to the 152 acre Salzburg Hazardous Waste landfill. New York recently passed a "Community Right to Know bill. This bill require all industries to identify where they've buried their wastes for the past thirty years. This is as it should be, of course. It's their garbage, and they should be accountable for it. rhe DNR needs to become more agressive in this regard. I am often amazed that the DNR does not even ask simple questions, such as, ?are you aware of any old disposal sites that might be contributing to the ground and surface water pollution?" I would hope that you take this information seriously, and respond accordingly sometimes the responses I receive are simply paper shuffling, and more time seems to be Spent figuring out why the situation can't be addressed at this time. i would ass that you coordinate your efrorts with Groundwater Quality, hazardous Waste, Environmental Enforcement, and Remedial Action Section. I belieVe that the agency?s past piecemeal approach to evaluating sites has many times resulted in evaluations that were deficient in scope. belieVe that the enclosed report supports my concern that the present system page three- August 29,1984 Paul Zugger of identifying contaminated sites is woerully inadequate. 1 am also enclosing for your review Dr. Irving Selikoff?s testimony before the Subcommittee on Natural Resources, Agriculture Research and Environment. Dr. Selikofr states in his testimony that the technology exists to measure dioxin at 2.1 quintillions. It is not clear if he is talking about soil or water at that point, out I thought you should be made aware or his testimony, as it could impact the Dow permit. I would like your response to this testimony. I will look forward to hearing from you soon. Sincerely, Diane Hebert, director 2505 Eas. sugnet Cous: Midland, Mi. 48b40 c.c Dr. Ronald Skoog Dave Dempsey James Truchan Fredericx Brown Dan Schultz Senator Carl Levin Congressman Donalc Albosta Thomas Scott Del Rector Andy nogarth Rick Johns Larry Holcomb .enclosurus 3?1 i - . - 1'51"; - :w.-.-- . .. . . .. . 1M I .. gm the. mm?Quin? Isak-11"? Ml Chlgan I 151: I 1 15.Ii- . at .. . 1 14.3555.hen. new.091? a; -.-. 3" 1- .. 1F ?w 4i.12BYJULIE MORRISON 'ttorne'y Robert Whittakersald the a. Daily News staff writer 1a live. - . clausehas become outdated. A Wortd War I-era heusing'ahonage ?But Dow wanted theemployees attorney". 18710? F35 that .. and the Dow Chemical Co.?3301ution t6; haVe their eyes open and be aware of. complete.ly.- he sald; - NO one eVen it havele?: reminderswith many Mid- What they were .. - - land resldenta. .: . - . gaff?. 3. .1 Len. wagihr?ligtr a 24 hour Ehimmall PlaPt?ggThe glagse hasnotbgenaconcern to ?i j, Included In the property Insurance an a 1 wasnohsyan t_ - many homeowners, either, the attoira" jg"; documents for many homes located 0m. were on all mght, she saldney?ssaid,sinceanyonemovin - it whatatpne tame was Dow. land is- at .. Etau?fah-?s geyennoarrled. .Jand knowsDow calls thecity game?" - . . clause protecting the.- Chemicalfcom??i forward'rta? :3?5f'PeopleE?gsually "4 1' pany from liability for ?smokes; gases? 1 .. -.- . . :Ha?dlon?sai'd'. on move to ui near4.1- . - . e: timeescape Orpase from the properties? 213?de ?9913??a??S?iWate'a?bout 3-1-23? '5 of the Dow-Chemical Co?! overthe resi- how allal?Y?thgS are. the 52'whoho?ght ohe'fa Doivlotlli?ew ahotit?a?j? 9 17:7 '1 2. - dential land. - :1up?g??t?3t?mie iti'?j?: new} H: 31-13,. J. Fri." .The clalise was included in titleaduzz-En are.? 55555341: 5 ing the early. part of the century when clan-Eyes}; Dow sold some of its land to its employi g-Elause has meaning today; ?g 35 ,op?eratlounffx?a?se a ees. said co pany spokestman Marya . doa?t know ?rhat? a'oourtrwohld?dogi'sp?eu?v?f? out? 1its shohe?ib?rnih??i?oal: 9 Beth Cur?saugr- -- .11: ea rang: 553?; :ijsaz, with and tinder-? were ?ying?ahd falling on"? El?n? - "During World ?But that's what in theory it (the (the street and on 1. . Mrs._ clauselmeanS-YQ? could?gtpue DOW if; th'e'clearifalr??tahdard's I - Curtiss said.. f'Dow, to be a'good oom'3'1 something really'na?tj?o?chrred. You'- . .. ?w Withey don?t?o? thatanymo're .1 2r. . I pany,sold some ofits reallyloutdatedg'RL-iln?i - a that . 3-3-5511? '3Ha?z loixqi?":13 er:- 4 .4 - tuna..- .me 1-PEDDLING norw available foi- ferit'at the 'city'?ano?erliverjr . Eleanor and and weremrovided brthe Midland FoundationL - .- . . Jim Pearce try out the new paddle hoatsion'the' f-(DajlyNews photo-by Glenn M- Roberts) 9:11,. . . - -, 1 Tittab?i?assee Rivei? boats 'h . . 3 4.. E'Fann . "Hi-I-