oversight

Review of Waste Water Discharges of Sugar and Potato Plants at Easton, Maine

Published by the Government Accountability Office on 1971-06-22.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

Review Of Waste Water Discharges
Of Sugar And Potato Plants At
Easton, Maine B.165456
          .




BY THE COMPTROLLER GENERAL
OF THE UNITED STATES
                            COMPTWCXLER           GENERAL     OF      THE      UNITED   STATES
                                                WASHINGTON.    D.C.        20548




B-165456

Dear     Senator       Muskie      :

        This      report     is in response           to your      request        of March    18,
1970,     that      we determine       the extent          to which        waste    water   dis-
charges       to the Prestile          Stream~~-~~~~~~~-i’esuP~                       ‘of the
operations           of a sugar    plant        at Easton,        Maine.       We have been
requested         also “to determine            the current        status       of the control
of waste        water      at the sugar         plant    and at a potato-processing
plant     which        is located _ adjacent
                                      . .“/.VW,
                                              .I      to the sugar          plant.
          __ ,,._... 3 .a_’ .-                        - I .^. , ._ ‘-. .,,
        Although      our review      showed      that    operations         of the sugar
plant     resulted      in waste     water    discharges         to the Prestile
Stream,      the information         obtained       was not sufficient            to permit
our determining           the extent      to which     such discharges            occurred.
We were able,         however,     to determine         that     substantial        improve-
ments     had been made after           1968 in controlling              and reducing
waste    water     discharges      to thk Prestile           Stream.

        The more significant                        matters           disclosed             by   our   review   are
discussed    below.

BACKGROUND
                                                                       /                   I
        The sugar          plant      is leased           by Maine        Sugar       Industries,            In-
corporated,          from     the Aroostook               Development          Corporation,               and the
potato      plant      is leased          by Vahlsing,             Incorporated,             from       the Eas-
ton Development              Corporation.               The potato          plant       began       operations
in 1961,        by which         time     seven      lagoons         had been constructed                    to
hold    the waste          water      discharged            as a result           of the potato              plant
operations.            The sugar          plant      began operations                 in 1967.
                                                                                              /
        The Maine          Environmental              Improvement           Commissi&n            in July
1961 issued          a license          to Vahlsing,             Incorporated,             which        per-
mitted      waste      water       discharges           to the Prestile               Stream--a           maxi-
mum discharge            from potato             operations          of 480 gallons              a minute,
or about        700,000        gallons         a day.         The license           recognized,            how-
ever,     that     discharges           to the Prestile                Stream,        on any given             day,
might     exceed       700,000        gallons        because         of the use of a lagoon
system      for    storing         waste       water      and releasing             such stored             waste
water     during       periods        of high         streamflow.             One condition               of the
license       required         that     facilities            were to be provided                   for     sampl-
ing and measuring                the flow          of the waste           water       discharges.


                                       !%I-ii   ANNIVERSARY                   1921- 1971
B-165456



         A November       1965 license      granted     to Maine       Sugar     Industries
required        that   (1) facilities       for   measuring       the flow      of waste
water     be installed        before   the point       where    the waste       water       en-
tered     the lagoons        owned by Vahlsing,         Incorporated,          and (2) fa-
cilities       be provided        for sampling      the waste       water    from     the
sugar     plant.

         Prior      to 1967 certain          waste    treatment         facilities            were
built      for    the purpose        of separating          the solids           and oils        dis-
charged        from    the potato       plant.       One of the seven                lagoons       was
set aside         for    holding     the solids       and another           for      holding       the
oils.        A third      lagoon     was set aside          to store        fresh       water      for
fire     protection.            As of January        1967,     therefore,            four     of the
original         seven potato        lagoons     were being         used to hold              waste
water      and were interconnected                so as to equalize                the waste         wa-
ter    levels.         In addition,        two lagoons         or pits         were constructed
in 1966 to hold              the mudlike       wastes     discharged           from      certain
sugar      plant      operations,

CHRONOLOGY         OF EVENTS

         Documentation           showing         the dates        that      a number         of changes
and additions          to the waste             water     control         facilities           occurred
was not available.                Nor were aerial              photographs              available         show-
ing the changes           which       occurred        at the complex                 between       1967 and
1970.      Because       neither        documentation            nor photographs                 were
available       and because           the sugar         plant       was not operating                  at the
time     of our review,           we relied          heavily        on discussions               with     em-
ployees      of the potato            and sugar         plants        in obtaining             information
on waste       water     control        facilities          and practices               at the complex.
Considerable         information           was obtained             from      two persons            primar-
ily    responsible         for     the waste         water     facilities--the                 plant      en-
gineer      and the chief            chemist.

Production          information

         Once     the sugar     plant   starts      production,        it operates          con-
tinuously         until    the campaign       ends-- barring        unusual     disruption.
The potato          plant,    on the other       hand,     normally      shuts    down on
weekends.           In 1967,    1968,   and 1969,        the potato       plant     operated


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246 days,         241 days,    and 234 days,    respectively.                          In the same
years     the     sugar  plant    operated   92 days,     93 days,                     and 107 days,
respectively.

January         1967   to   mid-1968

         The first        sugar   beet    campaign          was started        in January          1967.
In no case were we able                to obtain          documentation          which     showed
the volume         of waste      water    flowing         from    the sugar       plant,       not-
withstanding          the provision          in the license            granted       by the Maine
Environmental           Improvement       Commission           which    required        the instal-
lation      of facilities         for measuring             waste    water     discharges.
Our review         did show,      however,        that      reuse    of water        in the sugar
operation        substantially         reduced        the quantity          of waste       water
that     otherwise        would   have flowed           to the sugar          and potato         la-
goon systems.             Waste water        from     two of the four            main sugar          op-
erations       flowed       to the potato         lagoons,        and waste        water     from
the other        two operations          was pumped to the sugar                   lagoons.

         During        a 22-day      period        in May 1967 and a 21-day                     period
in June 1967,              an engineering            firm    measured          the volume         of waste
water      being       discharged        from      the potato         lagoon        system      to the
Prestile         Stream      and found         the volume          to be about           2 million        gal-
lons     a day.          According       to the engineering                 firm’s       report      and a
Vahlsing,          Incorporated,           official,          this    flow       was equivalent           to
the volume           of waste       water      being      discharged           from    the potato
plant      to the lagoon            system.          The company          official         also     advised
us that        the discharge           of 2 million             gallons        a day from         the po-
tato     plant       to the lagoon           system       was representative                 of the daily
discharge         during       periods       when the plant             was operating.

        The engineering              firm     also   estimated         the capacity         of the
four    potato      lagoons        to be about        18 million          gallons.         Since
about     2 million         gallons        of waste      water     a day were being             dis-
charged      to the lagoons,               the lagoons        would      have filled,        in
9 days if no discharges                    to the Prestile           Stream       had been made.
Therefore,        because        of the limited            waste     water      holding      capacity
of the lagoons,             it was necessary             to release         the waste       water        to
the Prestile           Stream.          According      to employees           of Vahlsing,           In-
corporated,          the discharge            of large      quantities          of waste       water
to the Prestile             Stream       was fairly        constant       until      mid-1968.

                                                      3
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         In addition           to the normal          flows      of waste        water     and the
discharges           to the Prestile           Stream       previously         described,         a
heavy      rainfall         on November        24, 1967,         when both        sugar      and po-
tato    plants         were operating,           swelled       the lagoons          and threat-
ened the contamination                   of the complex’s              freshwater         supply.       A
ditch      was cut        in a potato        lagoon       wall     to permit        a greater        flow
to the Prestile              Stream.        Shortly       thereafter,          the newest         and
largest        of the three           sugar    lagoons        began overflowing,               the im-
poundment           gave way,       and the contents             of the lagoons            flowed
into     the Prestile            Stream     and the complex’s               water     supply.        This
accident         forced      the sugar       and potato          plants      to shut       down for
several        days.

Mid-1968       to   June     1970

         The waste        water      holding       capacity        of the complex           remained
essentially         the same until             the summer of 1968.                  The discharge
of waste       water      from     the operations            at the complex            in July
1968--a      point      in time when the flow                  of water       in the Prestile
Stream      was low--resulted               in extremely           polluted       conditions          in
the stream.           This     situation         prompted        the construction             of sig-
nificant       additions         to increase          the waste         water     holding       capacity
of the complex            during       the summer and fall                of 1968.         Two new
lagoons      were added adjacent                 to the existing             potato      lagoons.
But the most significant                    addition        by far      was the creation              of a
huge impoundment             north       of the plants--named                Lake Josephine--
which      dwarfed      the total          capacity       of the other          holding       facili-
ties     of the complex.                (See pp. 7 to 9 for               a discussion          of the
current      holding        capacity        of Lake Josephine,)

       The recorded           cost    of the Lake Josephine           Dam, about
$324,000,       was charged         to Maine    Sugar    Industries.          Other    im-
provements        included       heightening      the impoundments          around     the
sugar     lagoons      and constructing         a canal     and a pump house           to
pump waste        water     from    the complex      to Lake Josephine.             The po-
tato   lagoons       were interconnected            so that     any discharging          to
%che Prestile         Stream     or pumping     to Lake Josephine           caused     the
level     of the waste         water     in the lagoons       to fall     simultaneously.

        Employees          of Vahlsing,     Incorporated,               stated      that,      because
of   the greatly           increased    capacity      for        holding       waste      water,

                                                    4
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discharges     to the Prestile   Stream were stopped         in mid-1968   and
did not resume until      about February      1969.    From February     1969
until    May 1970, the practices     concerning     discharges     to the
Prestile    Stream were as follows:

      1. A continuous      small   discharge    was maintained.

      2. During periods     of high streamflow       caused by rainfall
         or snow runoff,     which usually     occurred    in spring    and
         fall,  substantial    releases    were made until     the stream-
         flow was observed     to be lowering.

      3. During periods   of low       streamflow   in the     winter    and
         summer, the discharges         were substantially        reduced.

       In 1968 provision      was made to divert    waste water to a
sugar lagoon from one of the two sugar operations           previously
discharging     waste water to the potato      lagoon system.      Provi-
sion was made also for overflow         from the sugar lagoons       to com-
bine with potato       waste water at the Lake Josephine       canal.     Rain
01p SnOi: runoffs    from the area of the sugar plant,       for the most
part,    flowed   to this   same canal.

        In the fall    of 1969, the height         of Lake Josephine     was in-
creased,     providing     greater    holding   capacity.    In December 1969,
during    an attempt     to start     up a second pump at the Lake
Josephine     pump house, both pumps were short-circuited,               and it
took 6 days to repair          them.     For these 6 days, the potato       la-
goon system was opened to release              waste water to the Prestile
Stream and fresh water was released              to the stream from the
freshwater      impoundment      to reduce the adverse      effect   that the
waste water would have on the quality                of the water in the
Prestile     Stream.

        During our visits      in April,     May, and June 1970, we ob-
served that        (1) a sugar lagoon was overflowing          and combining
with waste water from the potato             lagoons,    (2) a continuous
small discharge        was occurring     from the potato     lagoons   to the
Prestile      Stream,   (3) rain or snow runoff        was carrying     lime al Id
mud residue       from the sugar operations         to the Lake Josephine
canal,    and (4) the level        of waste water in the potato         lagoon

                                        5
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    system      had dropped         noticeably         between      our visits       on April       16
    and April         27.     Upon inquiry,          we were told         that    a heavy     rain-
    fall     occurred        during     this    time    and that,       for    about    4 hours
    one evening,           the potato        lagoon     discharge       pipes     were opened
    wide     and waste        water    was discharged           to the Prestile          Stream.
    This action           appeared      consistent        with    the stated       discharge
    practices        of the complex.               (See p. 5.)

    DISCUSSION         WITH    MR.    FREDERICK        VAHLSING,         JR.

             On October          8, 1970,       we met with         Mr. Frederick
    Vahlsing,        Jr.,      president        of Vahlsing,          Incorporated,           and Maine
    Sugar      Industries.            Al though       Mr. Vahlsing         agreed      that     flows       of
    waste      water      from     sugar     operations        occurred        essentially          in the
    manner       as described           above,      he took      the position          that     flows       of
    waste      water      from     the sugar       plant      were minor.           He stated         that
    a large        amount      of the water           used in the sugar             operations          was
    recirculated            or evaporated           into    the atmosphere           and was not dis-
    charged        as waste        water.       We could       not determine           actual       flows
    because       measuring          devices      had not been installed                  in accordance
    with     the conditions             of the licenses            and because         we were unable
    to evaluate           the factor’of           evaporation.           A consulting           engineer-
    ing firm’s          report       dated     February       1970,     however,       estimated          the
    flow     of waste         water     from sugar        operations         at about        2,000      gal-
    lons     a minute.

            Mr. Vahlsing           stated      that     previous       practices        meant      little
    now    because :

            1.    He had instructed            his staff     at        the complex      to       make       no
                  more discharges            to the Prestile             Stream  except          during
                  spring  runoff.

1
             2.   Subject      to 1 above,    all waste     water  from  sugar                     and po-
                  tato    operations    was to be held       in the present                      lagoon
                  system     (including    Lake Josephine).
.

             3.   The contents       of Lake Josephine                 would   be used to irri-
                  gate   crop  fields       during   summer            months,   as was done
                  successfully       during      the summer            of 1970.

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         On October        29, 1970,       we visited       the complex       and confirmed
that     the waste       water    level     in Lake Josephine            had been substan-
tially      reduced      from what       it was in June 1970.               We observed,
however,        a small     discharge       from    the potato        lagoon    to the
Prestile        Stream.       We asked      the Maine       Environmental         Improvement
Commission         and Northern         Maine    Regional      Planning      Commission
whether       there     had been any complaints               concerning      the irriga-
tion     practices       of Vahlsing,         Incorporated,         during    the summer
of 1970 and received              a negative        reply.

          Mr. Vahlsing        stated    that,      at most,         340 million         gallons      of
waste       water  could     be expected         from a good sugar               beet    campaign
 (120     days)   and about         510 million         gallons       from     a potato      cam-
paign       (235 days)      making     a total        of about        850 million        gallons
each      year.    He contended,          however,          that    about      30 percent        of
this      waste   water     would     be lost       through        evaporation        and seepage
into      the ground.        Mr. Vahlsing           stated       also    that    Lake Josephine
would       hold  about     1.3 billion         gallons,           Therefore,       according        to
Mr.     Vahlsing,      there      is no present          or future         waste    water      prob-
lem     at the sugar        and potato        plants        at Easton.

         In   light       of Mr.    Vahlsing’s     statements,       the problem     con-
cerning       pollution        of   the Prestile       Stream    appears     to be resolved.
However,         the resolving         of this   problem       is predicated     upon the
following          conditions.

         1.   That    no discharges           will         be made   to the Prestile          Stream
              which    will   violate         the        stream’s    classification.

         2.   That Lake Josephine            is able    to hold    the           waste    water
              resulting        from  sugar     and potato   operations                each year
              that      cannot    be discharged      to the Prestile                Stream     un-
              der the condition           set forth     in 1 above.

         3.   That     irrigation        practices          during    the   summer     months
              will     be effective.

         4.   That,   in the        .event  the          capacity    of Lake     Josephine     is
              not sufficient            to hold          the waste     water,    such capacity
              is increased.

                                                     7
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        The capacity              and structural        soundness       of Lake Josephine
are considered             extremely        important.        An engineering        firm    using
topographical            maps estimated           the capacity        of Lake Josephine          at
about     500 million             gallons.       Mr. Vahlsing       advised     us that     the
engineering          firm      had not considered           increases       in the height        of
the impoundment              at Lake Josephine           made subsequent          to the engi-
neering       firm’s       visits        to the site.       The engineering         firm    ad-
vised     us that        its      estimate     was no longer        valid     in view    of
Mr. Vahlsing’s              statement       that    the capacity        of Lake Josephine
had been increased.

        On October         20, 1970,         we asked    for    and received          an esti-
mate of the holding               capacity      of Lake Josephine            from      the Corps
of Engineers.             The   Corps      of  Engineers      in   preparing        its     esti-
mate also        used topographical             maps and photographs              plus      infor-
mation     we had obtained             in June 1970 from           employees        of Vahlsing,
Incorporated,            as to the height           of the impoundment.                This     infor   -
mation     took      into    consideration          the increase        in the height              of
the impoundment            at Lake Josephine.              The Corps       estimated          the
holding       capacity       of Lake Josephine           at about       500 million           gal-
lons.

        In view    of the wide variation              in the estimates         and the
importance      of this       factor,    we asked       Mr. Vahlsing      if he would
make available         to us whatever         survey     data   he had to support
his estimate       of 1.3 billion         gallons.         He stated    that    no cur-
rent    survey    data     existed    and that       he had prepared        his esti-
mate by using        a car speedometer           and other      data  in estimat-
ing the average          depth     of Lake Josephine.

         To resolve      the differences             in the estimated         capacity      of
Lake Josephine,         we requested             the Corps      of Engineers      to send
a survey      team to Easton,            to develop         as good an estimate          as
possible      within     the time        limits      established.         The survey      was
to be made during            the week beginning              November     30, 1970.       On
November      25 your      office      advised      us that       Mr. Vahlsing       had agreed
that     the topographic          survey       of Lake Josephine          was a good idea.
On November         27, however,         Mr. Vahlsing          advised    us that      he wanted
to accompany         the survey        team when it was at Easton                and that
he could      not arrange         his    schedule       to enable      him to be at Easton
B-165456



during     the week of November        30.    The survey    was therefore
postponed.        Mr. Vahlsing   later     advised    us that   he could                   be   at
Easton     during    the week beginning       January    11, 1971.

         On December         8, 1970,      we, called       the Chief,          Engineering
Division,         New England       Division,         Corps     of Engineers,           to ob-
tain     his views         on performing        a topographic           survey      of Lake
Josephine          during    the week beginning             January        11, 1971.         He
stated      that       the heavy     snow cover        would      probably       cause     the sur-
vey measurements             to be inaccurate.              He stated         also    that     the
snow cover          would    make access        to areas        around      the lake       ex-
tremely       difficult        and that       he would      prefer      to have the survey
performed          when the climatic           conditions         were more suitable.

         We advised    your       office   in December     1970          that  we were fi-
nalizing      the results         of our review     and would            make no further
request     of the Corps          of Engineers    to per’form            a topographical
survey.



         We believe        that    a significant        effort      was made,        beginning
in mid-1968,          to bring      the sugar        and potato       plants’       waste     wa-
ter    discharges        to the Prestile          Stream      under     control.         Improve -
ments     were made at the complex                to substantially             control      dis-
charges       of waste       water    from    the plants        to the Prestile            Stream.
This     control      was not possible           with    the facilities           existing
before      mid-1968.

        Failure      to install        measuring       devices       to record       the vol-
umes of waste          water    leaving      the sugar        operations        and entering
the potato        lagoon     system,     as well       as the failure            to measure
the discharges           to the Prestile          Stream,      makes it        impossible     to
determine       the actual        volume     of waste       water      discharged       or to
determine       the extent        that    sugar     operations         have contributed
to discharges          to the Prestile           Stream     in the past.

         In   regard   to the control     of waste      water  from    future      op-
erations        at the sugar   and potato    plants,       much depends        upon the
capability         of Lake Josephine    to hold      the waste    water      from

                                                 9