United States
Environmental Protection
Agency
Washington, D.C. 20460
July 1976
Clean Water
and
The Dairy Products
Industry

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                                                         16325
 To  Employees  and  Friends of  the
 Dairy Products  Industry:

   Tms booklet is about the dairy products industry
 and water pollution. It is  intended  to help you un-
 derstand how your industry—and  each other  indus-
 try in the United States—is affected by a law passed
 by Congress to reduce and eliminate water pollu-
 tion.
   There are more than 5,000 dairy products  plants
 in the United States.  They employ about  198,000
 men and women. They produce milk, cream, butter,
 cheese,  ice  cream  and  a variety of other  dairy
 products.
   But they also produce about 600 million pounds
 of wastes each  year.  Those  wastes  include  400
 million pounds  of  organic material,  equivalent to
 the  sewage  generated  by six and  one-half million
 people.
   Some  4,000 dairy plants send their waste dis-
 charges  to  publicly-owned sewage facilities  where
 the pollutants are treated along  with  wastes from
 homes and other industries. But about 1,400 dairy
 plants discharge their wastes directly into  water
 bodies.
   This booklet describes  what those  1,400  dairy
 plants must do to keep their wastes from polluting
 the Nation's waters.
   In  non-technical  language,  this booklet explains
 that:
   • The  technology exists to reduce water pollu-
 tion from dairy plants to safe  levels.
   •  Applying that  technology  costs money—but
 most  dairy plants can afford to make the necessary
 investments to control pollution.
   •  Pollution control  investments by  most  dairy
 plants will have slight impact on their financial con-
 dition and on the price consumers pay for  dairy
 products.
   This booklet also describes why some dairy  plants
 may not  be  able to comply with  pollution control
 standards and why, unfortunately, some jobs  in the
 industry may be lost or require relocation.
   In brief, this booklet discusses the facts of life
about water pollution—how it affects all of us,  why it
 must  be controlled, and what the law  requires the
 dairy industry to do  as its part of the national pro-
 gram to clean up our Nation's waterways.

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 The Problem
   You  and millions of other Americans have prob-
 ably seen the warning signs.  They say "no  swim-
 ming"  or  "no fishing" or "no  boating" or "beach
 closed" or "danger, do not drink the water."
   The signs are there because  the water is polluted:
 With raw  or poorly treated human wastes. With run-
 off from  city streets, farmlands, animal  feedlots,
 and mines. With  leaks and spills from ships. And
 with  wastes from industries—including  the  dairy
 industry.
   Each year,  some 402  million tons  of pollutants
 from human  activities enter  the Nation's waters.
 That's almost  two tons for every man, woman, and
 child in the United States. The pollutants include
 bacteria,  viruses,  organic materials,  animal fats,
 oil, acids,  metals, pesticides,  myriad other chemi-
cals, and hot water from power plant and industrial
 boilers.
   The pollutants make our waters  unsightly. They
can make the water unfit for drinking, for irrigation,

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 and for industrial use without expensive purification.
 Some pollutants rob water of the oxygen required to
 sustain fish and shellfish, making them unpalatable
 or downright unsafe to eat. Some pollutants speed
 the growth of  algae that clog  waterways,  disinte-
 grate,  and give off noxious odors. Some  pollutants
 endanger health. Some pollutants endanger repro-
 duction; they can cause  deformities and death  in
 various life forms.
   It is impossible to put a precise price tag on the
 cost of water pollution. But there is no doubt that
 water pollution  exacts a heavy toll. Dirty water costs
 the American people billions  of dollars a year—in
 water  purification bills, in  damage  to fishery  re-
 sources, in lost recreation, and in other ways.
   Water pollution,   in  short,  is a  major national
 problem.
   How did this come to pass? How did so many  of
 our waterways become  open  sewers?
   For many years, we thought our waterways could
 handle the waste products of human activities. The
wastes would decompose and disappear harmlessly,
 we thought. But we learned otherwise. We  learned
that we had overburdened the capacity of water  to
cleanse itself. We learned that  our streams, rivers
and lakes could no longer assimilate the sewage dis-
charges from increasing numbers of  people and the
increasing waste discharges from industry, agricul-
ture, and mining. We learned  that some pollutants
can never be assimilated;  they persist and accumu-
late in  nature, posing a  continuing danger to public
and ecological health.
  And  after  more than two decades of  generally
ineffective  attempts  to  control water pollution, we
also learned that a new approach  was  needed.

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  To  Solve the  Problem
    In response to widespread public concern about
  the  sad condition of the  Nation's waterways, Con-
  gress enacted the  Federal Water Pollution  Control
  Act Amendments of  1972. The  1972 act built upon
  the  experiences of  earlier water  pollution  control
  laws. The  1972 act brought dramatic changes.
    What the 1972 law says, in  essence,  is that no-
  body—no city or town, no industry, no government
 agency, no  individual—has a  right  to  pollute  our
 water.  What was acceptable in the  past—the free
 use of our waterways as a dumping ground  for our
 wastes—is no longer  permitted.  From now on, under
 the  1972  law,  we  must safeguard our  waterways
 even if it means fundamental changes in the way we
 manufacture  products,  produce  farm  crops, and
 carry on the economic life of our communities.
    Congress declared that the objective of the 1972
 law is "to restore and maintain the chemical, physi-
 cal, and biological integrity of the Nation's waters."
    Congress established two goals in  the  1972 law:
 First, wherever possible by July  1983, achieve water
 quality that's clean enough for swimming and other
 recreational use, and  clean enough to protect fish,
 shellfish, and wildlife. Second,  by 1985, no more
 discharges of pollutants into our waters.
    How do we get from the dirty water of today to
 the clean water envisioned  for the future? The  law
 set in motion a new  national system of uniform con-
 trols on the  discharge of pollutants.
   How this system applies  to the dairy  industry is
 discussed  later.  First, consider how  the national
 system works, as  mandated by Congress and carried
 out by  the  U.S.  Environmental  Protection Agency
 (EPA) in cooperation with  State and local govern-
 ments:
   •  The  law requires EPA to establish national
 "effluent limitations" for industrial  plants—including
 dairy products plants. An  "effluent  limitation"  is
 simply the  maximum amount  of  a  pollutant  that
 anyone may discharge into a water body.

   •  By July 1, 1977, the law requires  existing in-
 dustries to  reduce their pollutant discharges  to the
 level  attainable  by  using  the  "best practicable"
water pollution control technology (BPT). BPT  is
determined by averaging the pollution control effec-
tiveness achieved by the best plants in the industry.

   • By July 1, 1983, the law requires  existing in-
dustries  to reduce  their pollutant  discharges still

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 more—to the  level attainable by  using the "best
 available" pollution control technology (BAT). BAT
 is  based on the best pollution control  procedures
 economically achievable.  If it is technologically and
 economically feasible  to  do  so,  industries must
 completely  eliminate pollutant discharges  by July
 1,  1983.

    •  The law requires new industrial plants to limit
 pollutant discharges to the  level attainable by meet-
 ing national  "standards of performance" established
 by EPA for new plants. A new plant must meet these
 standards immediately, without waiting for  1977 or
 1983. These new plant standards may require great-
 er  reduction of pollutant  discharges than the 1977
 and 1983 standards for existing plants. Where prac-
 ticable, zero discharge of pollutants can be required.
   •  The law requires industrial facilities that send
 their wastes to municipal treatment plants—as many
 dairies do—to  make  sure the  wastes can  be ade-
 quately treated by  the municipal plant  and will not
 damage  the municipal plant.  In some industries,
 discharges to municipal plants may thus have to  be
 "pre-treated." That is, the portion of the industrial
 waste that would  not be adequately treated or would
 damage  the municipal plant must be removed from
 the waste before  it  enters the municipal  system.

   • The law does  not tell  any industry what tech-
 nology it must use.  The law only requires industries
 to  limit  pollutant discharges to  levels  prescribed
 by  law.

  • The law also says that if meeting the 1977 and
 1983 requirements  is not good enough  to  achieve
water  quality standards, even tougher controls may
be imposed  on dischargers.

  • And while the  law requires industries to meet
the  national  discharge standards set for  1977, 1983
and for new  plants, the law also allows  a State  or
community  to  impose  stricter requirements if  it
wishes. The national  standards are  thus  minimum
requirements that all  industries must meet.

  Setting limits on  industrial discharges  is only the
first step in controlling water pollution,  of  course.
The next step is to  make sure those limits are met.
And the law  provides the mechanism to  do that.

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 Permits

   The key to applying the effluent limits to indus-
 tries—including  the  dairy industry—is the national
 permit system created by the 1972 law. (The tech-
 nical  name  is  the  "national  pollutant  discharge
 elimination system," or NPDES.)

   Under the 1972 law, it is illegal for any industry
 to discharge any pollutant into the Nation's  waters
 without a permit from  EPA or from a  State that has
 an  EPA-approved permit  program.  Every industrial
 plant that discharges pollutants to a waterway must
 therefore  apply  for  a  permit.  Essentially all have
 done  so.

   When issued, the  permit regulates what  may be
 discharged, and the  amount of each  identified pol-
 lutant.  It  sets specific limits on the effluent from
 each  plant.  It  commits  the discharger to comply
 with all applicable national  effluent limits and with
 any State  or local  requirements that may  be im-
 posed.  If the industrial  plant cannot  comply im-
 mediately,  the permit contains a compliance sched-
 ule—firm target  dates by which pollutant discharges
 will  be reduced or  eliminated  as  required.  The
 permit  also  requires dischargers to  monitor their
 wastes  and  to  report the  amount and  nature of
 wastes  put into waterways.

   The permit, in essence, is a contract between a
 company and the government.

   This  combination  of national  effluent  standards
 and limits, applied to specific sources of water pol-
 lution by individual permits, with substantial penal-
ties for failure to comply,  constitutes the first effec-
tive nationwide system of water pollution  conrol.

   Now, what does all this mean to the dairy indus-
try? That's next.

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 The Dairy Industry's Pollution  Problems
   The  first step  in applying the 1972 law to the
 dairy  industry  is to identify the  industry's  water
 pollution  problems  and to find out what can  be
 done to solve those problems.
   To do that, EPA assembled all available informa-
 tion on the dairy industry. That included two major
 studies of the industry, one by a  private  research
 firm, the  other  by a university. Those  studies pro-
 vided  basic data  about the industry  and virtually
 all available information on the  technology of dairy
 products  processing. Then still more information
 was sought.

   Waste samples  were  taken and analyzed at dairy
 plants,  some  by  dairy  companies,  some  by inde-
 pendent laboratories, and some by EPA,  with  the
 cooperation of  dairy companies.  Information was
 obtained from State and local pollution  control agen-
 cies that have been monitoring  dairy  plants.  Dairy
 companies supplied additional  data. Another  uni-
 versity survey was undertaken.  The Dairy Industry
 Committee sent  out a voluntary  questionnaire that
 produced  still more data. And there were visits to
 dairy plants  and  conferences  with dairy  industry
 officials.

   Out of this extensive study emerged this picture:
   • The more than 5,000 dairy  plants  in the United
 States  discharge about  53  billion gallons  of waste
 water each year—about 31  billion gallons  into mu-
 nicipal treatment plants, and  22 billion gallons di-
 rectly into water bodies.
   • That waste contains about 400 million pounds
 of oxygen-robbing  organic material and about 200
 million pounds of solids.

   • The major  pollutant  in waste  discharges from
 dairy plants is organic material. When dumped  un-
 treated  into a  stream or river, this organic material
 is decomposed  by micro-organisms in  the  water.
 But  in  breaking down  the organic pollution,  the
 micro-organisms consume oxygen in the water. That
 degrades  water  by  depleting its oxygen  content.
 Oxygen  depletion,  in turn, can have a catastrophic
 impact on life in the water body, for fish and other
aquatic  animals and plants must have  dissolved
oxygen to survive.  When all the oxygen in a water
body is  used up, as frequently happens, the decay
of organic  matter  continues without oxygen.  As a
result noxious gases such as hydrogen sulfide and
methane are  produced.

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  The measurement of pollutants that consume oxy-
gen  in  water is called  "biochemical  oxygen  de-
mand,"  or BOD. Water with  high  BOD contains  a
large  amount of decomposing organic  matter.  A
total lack of dissolved oxygen due to high BOD can
produce a  "dead"  water body in which fish,  for
instance, cannot live.
  •  Another major pollutant in   dairy  plant dis-
charges is suspended  solid waste, such  as coagu-
lated  milk,  particles  of  cheese curd, and in  ice
cream plants, pieces  of fruits and nuts. The mea-
surement of this pollutant is called  "total suspended
solids,"  or  TSS.
     These solids discolor  and cloud  water. They
  impair  photo-synthesis  in  aquatic plants. They
  can settle  on the bottom. When  they contain or-
  ganic  matter—as  dairy  wastes  do—the  bottom
  deposits become sludge  beds  that  can  further
  deplete the water's oxygen content. As the sludge
  decomposes, it gives off gases that  are toxic to
  aquatic life and cause odor problems.

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      In addition  to  the  adverse  esthetic and  eco-
    logical effects, suspended  solids in water from
    streams used by industry can interfere with many
    industrial processes. They can cause foaming in
    boilers,  damage  equipment,  and  impose high
    purification costs on  industries that need clean
    water to make their products,  such as the phar-
    maceutical  industry.
    • The key  point is  this:  Raw  wastes  from dairy
 plants contain excessive amounts  of  organic  ma-
 terials and suspended  solids. The wastes  thus have
 to be treated  before they can be discharged into  a
 water body.
    • Another key point is this: The major dairy in-
 dustry water pollutants—organic  material and sus-
 pended solids—can be treated  successfully.
    • Other identified pollutants  in  dairy plant wastes
 are phosphorus,  nitrogen, chlorides, and  heat. In
 general,  however, treating dairy  wastes  to  reduce
 the amount of organic material and suspended solids
 will keep these other pollutants at satisfactory  levels.
 In  isolated cases, some of the minor pollutants may
 be critical and may need special  treatment.

    • Another consideration is the acid or alkali con-
 tent of liquid wastes. This is called the "pH"  of the
 mixture. (Pure distilled water has a  pH of about 7,
 a strong acid solution has a pH of 1, and a strong
 alkali  solution  has a pH  of  14.)
   The pH of many individual wastes within a dairy
 plant fall outside  the acceptable range. In general,
 however,  the wastes are neutralized when they are
 mixed within a plant. And where necessary, pH can
 be  easily adjusted. Thus, pH poses  no serious pol-
 lution  problem for the  dairy industry.
   • Finally, research  also  revealed  that wastes
 from most dairy plants can  be  successfully treated
 by  municipal treatment plants and pose no dangers
 to  the  municipal  plants.  However,  in  some  situa-
 tions, a by-product of cheese-manufacturing—whey
 —may create problems in  some municipal  treatment
 plants.  Typically, whey  is composed of 93  percent
water and seven percent solids,  including 5 percent
 lactose. Where whey causes a  problem,  pretreat-
ment,  as previously  mentioned, may be  required
by  the municipality.
  In sum, the dairy industry's water  pollution  prob-
lems were identified—and it was determined that
water pollution from dairy  plants can be controlled
by  use  of  machinery and  methods  already in use
in some plants. The technology exists to do the job.                   10

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 The  Law and the  Industry

   With this  information  in hand,  EPA's next step
 was to prepare standards for dairy  plants under the
 1972 law. EPA did so, after considering many fac-
 tors:  the nature  of dairy plant raw  materials and
 wastes;  manufacturing  processes; the  availability
 and cost of pollution control  systems;  energy re-
 quirements and costs; the age and size of plants in
 the industry; and the environmental implications of
 controlling water pollution. (For instance, we would
 gain nothing  if, in controlling water pollution,  we
 created a new air or land pollution problem.)
   The proposed regulations were issued  December
 20, 1973.  They were sent to the industry and  other
 interested  organizations  for  review and  comment.
 They were  made public by publication  in the Federal
 Register. Comments were submitted by  dairy  com-
 panies and dairy  industry organizations,  by  State
 agencies, and by Federal agencies. EPA then  care-
 fully analyzed the comments and made appropriate
 changes  in the standards.
   On May  28, 1974, EPA issued the final standards
 for dairy plants to  follow in  order  to meet the  re-
 quirements of the 1972 law.
   The standards are contained in an official govern-
 ment  regulation published in the Federal Register.
 This regulation is supported by a detailed technical
 document  called  the "Development Document  for
 Effluent  Limitations, Guidelines and   New Source
 Performance  Standards for the Dairy Product  Proc-
essing  Point  Source Category."
   In brief,  here's what the regulation does:
   • Sets  limits on identified  pollutants that can
 be legally  discharged  by small and large plants in
 twelve sub-categories of the dairy products industry:
 milk receiving stations;- and  producers  of market
 milk; cultured products; butter; cottage  and cream
 cheese; natural  and process cheese;  fluid  mix  for
 ice cream and other frozen desserts; ice  cream and
frozen desserts and  novelties; condensed milk; dry
 milk; condensed whey; and dry whey.
   • Zeroes in on  the  major dairy industry pollu-                  "  ~
tants. It  establishes maximum limitations for BOD
and suspended solids that dairy plants can discharge
during any one day, and on an average over a thirty-
day period.
   • Sets limits that can be met by using the  "best
practicable control technology currently available"—
the 1977 requirement.

   • Sets more stringent limits that can  be met by                     11

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 using  the  "best available technology economically
 achievable"—the  1983 requirement. (For  an  ex-
 ample of the difference between the 1977 and  1983
 standards,  consider this: By July 1, 1977, a  large
 milk receiving  station must  limit its discharge of
 organic waste  (BOD) to 0.048 of a  pound per 100
 pounds taken into the plant. By July 1,  1983, the
 BOD  discharge  must  be  lowered  to  0.010  of a
 pound per  100 pounds taken into the plant.)

    •  Lessens the economic  impact on small  dairy
 plants by easing their control requirements—a major
 change from the originally proposed limits.
    •  Requires that the pH (acidity or alkalinity) of
 dairy plant discharges be within  the range  of 6.0
 to  9.0.
    •  Establishes performance standards  that  new
 dairy plants must meet without waiting for 1977 or
 1983.  For the dairy industry, the new plant stand-
 ard is the same as the  1983 standard for  existing
 plants. (In some industries, the new plant standard
 may require greater control of pollutants, based on
 new technology  not  readily  applicable to existing
 plants.)
    • Allows flexibility  in applying  pollution controls
 to  meet the 1977 standard in special cases.
    • Does not  require zero  discharge  of any pol-
 lutant by a dairy plant. Zero discharge is technically
 possible  in  the  industry.  But the  cost would  be
 prohibitive for most if  not all  plants  in the industry.
   • Does not tell dairy companies what technology
 to  use to meet regulations. The standards only re-
 quire dairy  companies to limit pollutant discharges
 to levels found  attainable by  using best practicable
 control  technology.
  An amendment to the regulation issued February
 11, 1975, says this: Existing dairy products plants
that send their wastes to publicly-owned treatment
plants may  do so without pre-treating the wastes. A
municipal plan  may establish its own requirements,
however, to prevent problems. For example, equali-
zation  may  be  required  so as to  prevent the  dis-
charge  of a heavy surge of whey which may upset
or interfere with the  operation and  efficiency  of a
public  treatment plant.
  What does all this mean—to dairy companies, to
those of you who work in dairy plants, and  to the
public? Please read on, for that's discussed next.
                                                                    12

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 Impact of the Guidelines

   Now let's consider some questions that you  may
 very well be asking yourself at this point about the
 impact of pollution control on the dairy industry.

   1.  Can dairy plants  meet the  1977 limitations?
 That  is  technologically,  can they reduce their  dis-
 charges of pollutants to the levels required by 1977?
   Based on all  available  information, the answer is
 yes. Most existing dairy plants can meet the 1977
 standards. In fact, it's  estimated that  10-20 percent
 of some 1,400 dairy plants that are required to meet
 the 1977 standards are already  doing so. It's  esti-
 mated  that by  meeting the 1977 standards, dairy
 plants will reduce their discharges of organic  ma-
 terials  by about 90-95 percent,  and  of  suspended
 solids by about 85-90 percent.  And  meeting  the
 1983  standards will  then  bring  even greater re-
 ductions in pollutant discharges.
   Moreover, existing  dairy plants that do not want
 to invest in pollution control equipment  may  have
 the option, depending on where they are located, to
 tie into a municipal treatment plant. And the tech-
 nology  exists for municipal  plants to  handle dairy
 wastes  safely. Most dairy plants are small and most
 —about 90  percent—are  already connected to mu-
 nicipal treatment systems. The reason: It's generally
 good  economics to share in the costs of a  larger,
 more efficient treatment plant than for a small plant
 to go it alone.

   2.  Can dairy plants  meet the  1983 limitations?
 That  is technologically,  can they  reduce their  pol-
 lutant discharge to the  lower levels required  by
 1983?
   Again the  answer  is  yes.  Most existing  dairy
 plants can meet the  1983 standards.  In  fact,  sev-
 eral  plants  in the  industry are already  surpassing
 the  1983  standards.  They are  now  discharging
 cleaner  waste  water  than called  for by  the  1983
 standards.

   3.  Can new plants meet the new source perform-
 ance  standards?                                                   -  -
   Yes.  Good management and housekeeping with-
 in a plant can  reduce  the amount of wastes  gen-
 erated in the first place. That plus installation  and
 effective use of known and proven waste treatment
 processes can keep dairy plant pollutant discharges
 at or below the  levels required by regulation.

  4. Can the dairy industry afford to meet the 1977
water pollution  control requirements?
  Again the  answer is yes.  Most dairy companies                     13

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 can afford to do so.
   It's estimated that  meeting the 1977 standards
 will cost the dairy industry about $90 million. (Part
 of that has already been invested, for many required
 facilities  are already  installed.) Annual operating
 costs  are estimated at about  $10-15 million. The
 new   investment  in   pollution  control  facilities
 amounts  to  from 5-25 percent of  the  industry's
 present  investment  in plant and  equipment;  the
 exact  amount will vary depending on the  type of
 dairy products manufactured and the  size of a plant.
   Put another way, a $l-million  dairy  plant  may
 have to spend anywhere from $50,000 to $250,000
 for pollution  control. And in  terms of annual costs,
 the pollution  control  pricetag will vary from 0.2 per-
 cent to 1.5 percent  of sales. For  a  dairy company
 with sales of $1 billion a year, the cost of pollution
 control may thus range from $2-15 million a  year.

   5. Can the dairy industry afford to  meet the 1983
 water  pollution control  requirements?
   Again the  answer is yes.  Most dairy  companies
 can afford to do so.
  It's  estimated that added investment and annual
cost to meet the 1983 standards will be less than
half  of that required for 1977.  Moreover, much  of
                                                                    14

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the additional investment can  be returned in the
form of valuable materials recovered by using better
in-plant controls.
   Indeed, some dairy plants may find that their net
cost to control water pollution may be almost zero.
And a  few dairy plants may actually realize  a net
profit on their pollution control  investments, thanks
to recycling—the recapture, sale, and use of ma-
terials now being discharged as wastes.
   So far we've talked about dairy plants that  can-
technologically and financially—meet the 1977 and
1983 standards.  Now a tougher question:

   6. What about dairy plants that cannot financially
meet the  1977 standards? What  will happen to
them?
   About 100 dairy plants may have to close  down.
They are marginal and relatively inefficient. Indeed,
some of those small plants may have already closed
—for reasons not related to pollution control—since
these estimates were made  in  early 1974.
   For the men and women affected, the loss wi!! be
real, of course. It will mean relocating to another
job  in the dairy industry, or perhaps  entering an-
other career.  For some,  it may mean moving to
another community. For  others, it may  mean  early
retirement.
   EPA recognized the very real  human problem. As
originally proposed, the 1977 standards could have
forced about 573 plants, employing several  thous-
and workers, to shut down. The final 1977 standards
for small  plants were therefore eased. Any further
easing of the  1977 standard would have meant the
continuing discharge of raw wastes—or business as
usual,  regardless of water pollution. And  business
as  usual with water pollution  is simply no longer
environmentally tolerable and  is thus not allowed
under  the 1972 law. It  should be noted  that the
regulation  will create new jobs  in construction and
maintenance of  new pollution control facilities.
   In sum, the price of restoring and maintaining the
quality of our waterways for the benefit of all may
indeed  be costly to those who can only stay in
business by continuing to pollute.

   7. What about the 1983  standards?  Will  any
more dairy plants have to close because  of those
standards?
   Here the answer is no. No additional plant clos-
ings are expected as a result of the 1983 standards.

   8. How will the 1977  and 1983 standards affect
consumers? What impact will they have on the price
of dairy products?                                                    15

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    Here  are  some  estimates  for  several  dairy
 products:
    Butter—It's estimated that meeting the 1977 and
 1983 standards  may cause a  1.1  percent increase
 in the wholesale price of butter. If that increase  is
 passed on to  consumers, it would mean an increase
 in the retail price of butter of less than one cent a
 pound.
    Cheese—It's estimated that there  may be  a 0.4
 percent increase in the wholesale  price of cheese.
 If passed on to consumers,  that would mean an in-
 crease of three-tenths of a cent per pound of cheese.
    Milk—About 90 percent of the large milk proces-
 sors  are  already  linked to  municipal   treatment
 systems.  For  the remaining  large  milk plants that
 discharge their wastes directly  into  water bodies,
 it's estimated that  meeting  the 1977  and  1983
 standards may cause the price of  milk to increase
 by one-tenth of 1 percent.  For a  half-gallon of milk
 that now retails  for 75 cents, that would mean  a
 price hike of  less than  a tenth of a penny.
   Ice Cream—About 90 percent of large ice cream
 plants are already linked  to  municipal treatment
 systems.  For  the remaining  plants that are direct
 dischargers,  it's estimated that meeting the  1977
 and 1983 standards may raise prices by 0.9 to 1.2
 percent. For a half-gallon of ice  cream that retails
for $1.69, that could mean  a  price increase of up
to two cents.
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   Canned Milk—It's estimated that there may be a
 0.6 percent increase in the price of canned milk. If
 passed on to consumers,  that would  mean  an in-
 crease of one-tenth of a cent per twenty-cent can of
 milk.
   Thus, water  pollution  control  requirements for
 the dairy industry will have a negligible impact on
 the price of dairy  products.
   9. What about  the productive capacity  that will
 be lost if about a hundred dairy  plants do  indeed
 shut down?
   It's  estimated that those plants account for only
 0.2 percent of the industry's production. The slight
 drop in the industry's production can be more than
 made up by other  plants.
   Thus, water  pollution  control  requirements for
 the dairy  industry will have  no long-range  reper-
 cussions in terms of supplies of dairy products  or
 industry growth. And the standards will not affect
 the Nation's  balance of trade with other countries;
 they will  not  affect  exports of dairy products and
 will not cause  an  increase  in  imports  of dairy
 products.
   In sum, except for about 100 small plants that are
 already having trouble staying in business, the U.S.
 dairy industry can meet the water pollution control
 requirements mandated by the 1972 law. The result
 will be cleaner water for all of us  to enjoy and less
 waste of usable dairy products.


 Some  Final Words

   The effluent guidelines  for the dairy industry and
 other industries are  only part of the comprehensive
 program set in motion by the 1972 law to  clean up
 the Nation's  waters.  Among other things, the law
 also requires municipal treatment plants  to meet
 certain discharge standards by 1977 and 1983. The
 law increased Federal aid  to help local governments
 build sewage treatment  facilities. The  law  estab-
 lished  planning procedures for State and local gov-
 ernments to more  effectively control water  pollution
 from all sources,  in  cooperation with  the Federal
 government. The law streamlined and strengthened
 the  enforcement provisions of the water  pollution
 control program.
   In total, the 1972 law provides formidable new
tools "to restore and maintain the chemical, physi-
cal, and biological integrity of the Nation's waters."
   With the cooperation and hard work of State and
 local governments, and of industry, progress has
already been made toward cleaning up our  rivers,                     17

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streams, lakes and harbors.  Industries  and govern-
ments at all  levels have already invested consider-
able amounts of  money  to  reduce and eliminate
water pollution.  But much still remains to be done.
Both  industry and government will have  to  invest
still more money if the clean water program is to be
successful—if we are to have water that is safe  and
healthful for  drinking, for use by  industry and agri-
culture,  for  swimming and boating,  for fish  and
wildlife.
   It's  estimated that the total  cost of  the  water
cleanup  program  will be  $51 billion dollars in the
ten-year period  from 1973  through  1982. That's
$5.1  billion a year to clean up the Nation's waters-
compared to  the $13 billion a year that water pollu-
tion now costs the American people. Clearly, water
pollution control is an economic bargain  as well as
an  environmental  necessity.
   EPA Administrator Russell E. Train  has summed
it  up  in  these words:
   "The  benefits of our pollution  control expendi-
tures  far exceed their costs. We really  do not have
the option  of not  paying environmental costs at all.
We have the option only of deciding in which form
we shall pay them:  in the form of pollution  control
costs  or increasing  health hazards, of  higher  elec-
tric bills or  higher doctor bills.  Moreover,  to the
degree that we  put  off paying  the costs of cleanup
and control,  we  not only  allow the  buildup of
pollutants to  increasingly more dangerous levels but
ensure that the  task of control  and cleanup will be
far more difficult and costly."

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 How To Cut  Wastes By Really Trying

   Engineers estimate that about  half  the water
 pollutants generated  in some dairy plants  can be
 eliminated  by  improved  in-plant procedures  and
 better housekeeping in the plant. Some examples:
   More attention can be given to controlling spills.
 Start-up  and shut-down operations can be reduced
 and controlled. Some raw materials can  be  sal-
 vaged and  recycled  instead of discharged. Some
 by-products can be salvaged  and sold  as feed or
 food products  instead of  discharged. Product  loss
 and water  use  can be reduced by education  pro-
 grams for management and plant operators. Clean-
 ing operations can be made more efficient and thus
 the amount of  water  and cleaning chemicals used
 can be reduced. And plant design changes can  also
 produce less waste in some dairy plants.
   Here's what  happened  at one dairy plant that
worked at better waste control through in-plant  and
 housekeeping  changes:  In 1968,  the  plant  dis-
 charged  86,000 gallons  of wastewater,  containing
 1,950 pounds of organic wastes, each day.  By 1972,
production  was up and the wastewater flow was up
to 110,000 gallons  per day—but the organic waste
discharge had dropped to 900 pounds a day.
  The Simplest  Method

     "Plant people  should  exhaust the in-plant
  short-of-treatment  approach as  the  soundest
  and  simplest  method of controlling a  waste
  problem. In addition to coming  to grips with
  the pollution  problem, such action  will also
  result  in cost reductions  through  improved
  production  efficiencies,  reductions in  losses,
  and reductions in water usage."

       —Kenneth S. Watson, Director of Environmental
         Control, Kraftco Corporation, Glenview,  III.
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 Want More Information?
   If you'd like additional information about the dairy
 industry and  water pollution, or about water pollu-
 tion in general, the following publications are avail-
 able from the sources shown:

   "Effluent Limitation Guidelines and Pretreatment
 Standards  Application  for  the   Dairy  Products
 Processing Industry Point Source Category."  Reprint
 from May  28, 1974 Federal Register. EPA. Free.

   "Effluent Limitation Guidelines and Pretreatment
 Standards for Certain Categories." Reprint  from
 February 11,  1975 Federal Register. EPA. Free.

   "Highlights of the Federal Water Pollution  Con-
 trol  Act Amendments of 1972." EPA. Free.

   "The  Marine Protection, Research,  and Sanctu-
 aries Act  of  1972—Ocean Dumping  Highlights."
 EPA. Free.

   "A Drop to  Drink." EPA. Free.

   "A Citizen's Guide  to Clean Water." EPA. Free.

   "Development Document for Effluent Limitations
 Guidelines and New Source Performance Standards
 for the Dairy Product  Processing Point Source Cate-
 gory." U.S. Government Printing  Office, Washing-
 ton,  D. C. 20402. GPO Stock No. 5501-00898, GPO
 Catalog No. EP 1.8/3:014.  Price-$2.05.

   "Economic Analysis of Effluent Guidelines  for the
 Dairy Products  Industry."  Economic Analysis Div-
 ision (PM-220), EPA. Free.

   To obtain single copies  of the free  publications
available from EPA, write:  EPA Public Information
Center (PM-215), Washington, D.  C. 20460.
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