135 



1 RO^ M. HARRIS 



2 given a roiniraum of primary treatment to achieve: (a) re- 



3 raoval of all settleable solids, and (b) removal of a 



4 minimum of 70 percent of all volaLilt suspended solids in 



5 i tlie total mill effluent. We fully support the general 

 5 concept of prim^ary treatment for all wastes, but do not 



7 believe that the 70 percent removal of volatile suspended 



g j solids is achievable at all aiills with standard piciojary 

 9 treatment. In addition, the report does not document the 



70 percent removal requirement for volatile suspended 

 solids as being necessary toachieve a particular water 

 quality in the waste discharge area. 



For example, this requirement can be easily 



14 met by Crown Zellerbach, Simpson-Lee, Scott at Anacortes, 



15 and Rayonier , but cannot be easily met by Georgia-Pacific 

 15 and Weyerhaeuser without the use of settling aids. For 

 17 example, Georgia-Pacific presently has a suspended solids 

 Ig loss of 43 pounds per ton of production. After primary 



19 treatment, the loss should be 19 pounds per ton or a 



20 reduction of 59 percent. Rayonier loses 70 pounds per ton 



21 at present, but after primary treatment should lose 



22 approximately 21 pounds per ton for a reduction of 71 per- 



23 cent. 



24 So we prefer to require primary treatment 



25 1 for removal of all settleable solids and to base the 



10 

 11 

 12 

 13 



