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MURL MILLER 



"Provide primary treattnent of all solids- 

 bearing wastes to provide for (a) reonoval of all settle- 

 able solids and (b) 70 percent removal of volatile sus- 

 pended solids." 



These are arbitrary requirements, not 

 specifically related either to practicality in fact, 

 feasibility, nor to specific mill conditions. Errors in 

 assessment of loads generated by a mill or differences in 

 their operating efficiencies or nature of product produced 

 are important. 70 percent removal might be easily attain- 

 able in one mill, impossible in another. We believe that 

 the criteria should be the demonstrated requirements of 

 water quality in the receiving waters. 



In summary, our examination of the Project 

 report leads us to acknowledge that in extremely limited 

 areas and under limited conditions of tide and weather, 

 in situ tests produced juvenile salmon mortalities. 

 We concur that these mortalities were probably due to 

 sulfide generation from the shallow water sludge deposits. 

 Our discussion has described changes which render the 

 Project data obsolete. 



We agree with the Project's findings that 

 the deep-water diffuser is an effective method of waste 

 disposal. We find the Project's attempts to demonstrate 



