POLLUTION
CONTROL
TECHNOLOGY
ASSESSMENT
•*•»-
U.S. ENVIRONMENTAL PROTECTION AGENCY
NATIONAL ENVIRONMENTAL RESEARCH CENTER
CINCINNATI, OHIO
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EPA-670/9-74-006
POLLUTION CONTROL TECHNOLOGY ASSESSMENT
Proceedings
of an
Environmental Resources Conference
Sponsored by:
U.S. Environmental Protection Agency
and
Columbus Laboratories of Battelle Memorial Institute
May 1-3, 1974
Columbus, Ohio
NATIONAL ENVIRONMENTAL RESEARCH CENTER
Cincinnati, Ohio
October 1974
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CONFERENCE COMMITTEE
Co-Chairmen
F. M. Middleton, National Environmental Research Center,
U.S. Environmental Protection Agency
D. L. Morrison, Battelle-Columbus Laboratories
Planning Committee
National Environmental Research Center, USEPA
F. M. Middleton
C. J. Dial
Battelle-Columbus Laboratories
D. L. Morrison
C. R. Smithson, Jr.
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PREFACE
The need for studying the technological, economical, social, and environmental aspects of
pollution control is always present. Therefore, this multifaceted assessment of our water pollu-
tion control technology is timely.
The Columbus Laboratories of Battelle Memorial Institute and the U.S. Environmental Pro-
tection Agency's National Environmental Research Center, Cincinnati, sponsored the conference.
Divided into five sessions, the conference focused on the impacts, direct and indirect, on water
quality which resulted from various actions taken by Government and industry, in response to
environmental control regulations.
We wish to express our gratitude to the many who contributed to the success of the
conference.
We acknowledge with appreciation the assistance of Mrs. Lucille G. Pierson of Battelle-
Columbus and Mrs. Elaine Cole of NERC-Cincinnati, who gathered and compiled these pro-
ceedings.
With the exception of the preliminary pages, NERC-Cincinnati has produced this report as
received from Battelle Memorial Institute.
Publication of these papers by the U.S. Environmental Protection Agency does not imply
endorsement of either the conclusions or of any commercial product mentioned in these proceed-
ings.
The Chairmen
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CONTENTS
Conference Committee ............................. ii
Preface .................................. iii
INTRODUCTORY REMARKS
F. M. Middleton, U.S. Environmental Protection Agency. ............. 1
SESSION I: TECHNOLOGY ASSESSMENT
Moderator: F. M. Middleton, U.S. Environmental Protection Agency
Technology Assessment
G. Strasser, Strasser Associates, Inc ..................... 4
Scope and Purpose
D. L. Morrison, Battelle— Columbus Laboratories ................. 9
SESSION II: LEGISLATIVE MANDATE AND STANDARDS
Moderator: N. Drobny, Battelle— Columbus Laboratories
Industrial Viewpoint — Legislative Mandate and Standards
B. M. Kostelnik, The Anaconda Company .................... ^2
Highlights of Legislation
R. H. Johnson, U.S. Environmental Protection Agency
The Role of Domestic Council at the White House
N. E. Ross, Jr., Domestic Council .................. 22
Congressional Outlook on Environmental Control Legislation
G. E. Wood, House Public Works Committee ................... 28
Limestone Scrubber Sludge — An Example of Air Pollution Converted to
Solid Waste
P. W. Spaite, Environmental Consultant ................ oo
Cross— Media Impacts with Solid Wastes
W. C. Bucciarelli, Pennsylvania Department of Environmental Resources ...... 43
Pollution Abatement Resulting in Cross Media Impacts: Radiation
A. Schoen, U.S. Atomic Energy Commission ...............
Impacts and Consequences of Existing Hazardous Waste Management
Legislation
R. S. Ottinger, TRW Systems Group ...................... 50
Impacts and Consequences of Existing Legislation on Water Pollution
Control
J. F. Byrd, Proctor & Gamble Company ..................... 53
National Commission on Water Quality
J. G. Moore, Jr., National Commission on Water Quality .............. 59
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SESSION III: CONTROL TECHNOLOGY
Moderator: A. Trakowski, U.S. Environmental Protection Agency
A Systems Analysis for SOX Control Technology Research & Development
G. J. Foley, J. 0. Smith, U.S. Environmental Protection Agency,
and W. R. Schofield, Air Products & Chemicals, Inc. .............. 66
Solid Waste Control Technology and Its Application
R. W. Eldredge, Environmental Consultant ................... 77
Radioactive Waste Generation and Management
J. J. DiNunno and A. W. De Agazio, NUS Corporation .............. 82
Hazardous Waste Management
W. H. Swift, Battelle-Pacific Northwest Laboratories .............. 97
Industrial Control Technology & the 1972 Water Pollution Control Act
C. F. Guarino, Philadelphia Water Department .................. 102
SESSION IV: ACTIVITIES INDIRECTLY AFFECTING WATER POLLUTION CONTROL
Moderator: C. J. Dial, U.S. Environmental Protection Agency
Land Use and Water Quality
E. H. Clark, Council on Environmental Quality ................. 114
Resources and Water Quality
J. K. Klitz, International Business Machines Corporation ............. 120
The Impact of Energy Self-Sufficiency on Pollution Control
K. E. Yeager, U.S. Environmental Protection Agency ............... 130
SESSION V: ASSESSMENT OF FULL UTILIZATION OF WATER POLLUTION
CONTROL TECHNOLOGY
Moderator: G. Strasser, Strasser Associates, Inc.
Environmental Quality Improvement Through Systematic Implementation of
Pollution Controls
N. Dee, U.S. Environmental Protection Agency,
H. Reiquam, El Paso Natural Gas Company, and
P. Choi, U.S. Environmental Protection Agency ................. 150
Health Assessment of Full Utilization of Water Pollution Control
Technology
L. A. Plumlee, U.S. Environmental Protection Agency .............. Igl
Cost-Benefit Analysis of Water Pollution Control
D. P. Tihansky, U.S. Environmental Protection Agency ............. jgy
Guiding Technological and Social Change
S. Lundstedt, Ohio State University ...................... 179
CLOSING REMARKS
F. M. Middleton, U.S. Environmental Protection Agency .............. 139
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INTRODUCTORY REMARKS
F. M. Middleton
Deputy Director
National Environmental Research Center
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
Good Morning, I am Frank Middleton,
Deputy Director of the National Environmental
Research Center of the USEPA in Cincinnati,
Ohio, and co-chairman of this Conference. I
would like to add my welcome to that of
Dr. Sunderman. Also, I want to thank you for
coming to this Conference. This is the third
of a series of conferences on environmental
matters that have been jointly sponsored by
the NERC-Cincinnati and Battelle-Columbus.
The 1971 Conference was held on Design of
Consumer Containers for Reuse or Disposal,
and in 1973, a Conference on the Cycling and
Control of Metals was held here at Battelle.
Objectives in holding these conferences are
to address highly pertinent and timely topics
of concern to the Nation. Proceedings of
all these Conferences are made available to
the scientific and technical community and
to leaders in policy-making positions in the
country. We will have proceedings from this
meeting.
I would like to tell you a little bit
about the National Environmental Research
Center in Cincinnati so that you will under-
stand our role here and our role in environ-
mental research. Those of us closely associ-
ated with environmental research often
passively assume that others know a great
deal about our organizations and how they
work, but many surveys indicate that this is
not so. In a recent survey of 3,000 people
selected from a cross-section of the American
public, only 10 percent of the people were
able to name U.S. Environmental Protection
Agency unaided. When the Agency's name was
mentioned, another 48 percent said yes, they
had heard of it; the remaining 42 percent
had not heard of the agency. Among even
those who were aware of EPA, 40 percent indi-
cated that they Knew almost nothing about
the agency and only 19 percent said they
knew a fair amorunt about the agency. In
August 1971, the Environmental Protection
Agency developed the concept of National
Environmental Research Centers to integrate
the research and monitoring activities of
the agency. The centers were established
in Cincinnati, Ohio; Research Triangle Park,
North Carolina; and Corvallis, Oregon. A
year later the fourth National Environmental
Research Center was established in Las Vegas,
Nevada. These centers were developed along
a thematic basis so that each NERC would
play a specific role in the mission of the
agency. The programs, however, are not
limited exclusively to the theme, but the
theme serves as the foundation and nucleus
for each of the installations. In Cincinnati,
the theme is technology development, and it
is our activity and interest in this area
that led to the development of this seminar.
Our programs are heavily oriented toward
wastewater and drinking waters, but we also
have substantial programs in the area of
automobile emissions toxicology, solid and
hazardous waste research, methods develop-
ment and quality assurance, radiological
activities, and industrial waste control
and oil and hazardous waste spill technology
investigated at a satellite laboratory in
Edison, New Jersey. Hence, the subject
matter of this conference is of significant
importance to the activities of EPA at
Cincinnati as well as at the other National
Environmental Research Centers.
We have gone through, and are still
going through, a period of passing far-
reaching legislation in the environmental
field.
Technology developments for the control
of pollution have been proceedings with some
vigor. Standards and regulations for our
control of pollutants are appearing almost
daily, and already, a new National Water
Quality Commission is beginning work on the
study of the technological, economic, social.
1
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and environmental aspects of achieving efflu- We have assembled an outstanding group
ent limitations and goals set forth for 1983 of experts to talk, and we want this to also
by the Federal Water Pollution Control Act be a discussion meeting. Hopefully, this
Amendments of 1972. We, therefore, believe conference will fulfill these aims. More
that it is quite timely that our water pol- specific details on the aims and objectives
lution control technology be assessed from of the Conference will given later this
a number of viewpoints. morning.
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/
Moderator:
F. M. Middleton
U.S. Environmental Protection Agency
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TECHNOLOGY ASSESSMENT
(Mid-1974)
Gabor Strasser
President
Strasser Associates, Inc.
1502 Highwood Drive
Arlington, Virginia 22207
ABSTRACT
This paper does three things. First, it discusses what technology assessment is. This
is done in terms of (1) the reasons for technology assessment, (2) the concept, (3) the
context, (4) the definition, and (5) the label of technology assessment. Next, (6) the
need for something like technology assessment is discussed; this is then followed by
(7) an examination of who should do what and why in the technology assessment area, leading
up to (8) the establishment of the Office of Technology Assessment in the US Congress.
Second, this paper discusses some of the similarities and differences between techno-
logy assessment on the one hand, and environmental impact assessments and statements on
the other.
Third, the paper examines the newly created Office of Technology Assessment (OTA) in
the US Congress.
INTRODUCTION
I appreciate the opportunity to address
this audience on technology assessment. As
you were just told, I have been involved in
this subject for some time, and talked about
it on numerous occasions to various audien-
ces. Hence, when an opportunity such as
this one arises, the question that inevi-
tably comes to my mind is this: What can I
say that I have not said sometime, some-
where before?
Based on your show of hands, it seems
that most of you would welcome a brief syn-
opsis as to where technology assessment came
from, and what it is intended to accomplish.
For this reason, repetition of parts of
some of my previous talks should cause no
problem, and therefore I will organize my
presentation along the following three
.lines:
(1) What thechnology assessment is.
(2) How technology assessment differs
from environmental impact assessments and
statements.
(3) Organization of the Office of
Technology Assessment (OTA) in the Congress.
WHAT TECHNOLOGY ASSESSMENT IS
Reason for technology assessment
In recent years we have become increas-
ingly concerned about the deterioration of
the quality of human life. Due to unfore-
seen, deleterious side effects, certain
innovations like DDT, which have done a
great deal of good in some ways, have en-
dangered or degraded our lives in others.
The pollution of our lakes and streams
assaults our senses. Rapid population
growth and the concentration of poeple in
urban regions have created severe disharmo-
nies.
Concept
Since technology plays a highly signifi-
cant as well as a visible role in the so-
lution of many of our problems, there has
arisen a desire to "preplan" the use of
technology better. The objective of this
preplanning is to minimize the potential de-
leterious side effects of our actions. This
has given rise to the technology assessment
concept.
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Context
But what we do or do not do is really up
to our socio-political system, not to our
scientific-technical establishment, however
extensively many of our industrial products
and government programs may depend on sci-
ence and technology. Furthermore, science
and technology represent only one set of
the many "enabling mechanisms" that help us
attain our objectives. Others lie in such
areas as economics, management, labor, po-
litical science, institutional arrangements,
etc. It is the integrated use of these en-
abling mechanisms, under the direction of
our socio-political system, that can make
the difference between success and failure.
It is a mistake to look primarily at tech-
nology when something has gone wrong. It
is also wrong to search primarily for tech-
nological solutions, since the best solu-
tions generally involve a combination of
technology and other means, or even a com-
bination of non-technological means with-
out any new technology.
Definition
For this reason, most authorities broa-
den the concept of technology assessment to
include a great deal more than what ordina-
rily comes to mind when we use the term
technology assessment, namely: A systematic
planning and forecasting process that de-
lineates options and costs, encompassing
economic as well as environmental and so-
cial considerations, that are both exter-
nal and internal to the program or product
in question, with technology-related "bad"
as well as "good" effects.
Label
Hence the label of "technology assess-
ment'1 was found to be wanting, since it im-
plies a narrower interpretation than what
we mean by the concept today. This has
caused considerable confusion. One mani-
festation of this confusion is a concern by
some that we may be talking about technology
arrestment, rather than assessment. It is
generally felt, however, that it is too late
now to change the label without further com-
pounding the confusion. Instead, we decided
to give "technology" a much broader inter-
pretation than what Webster has given it.
In short, we view "technology" in "tech-
nology assessment" as a variety of "things,"
whether these are "technical" or not, in
the strictest sense of the word.
Why is something like technology assessment
needed?
The fundamental concept of technology
assessment is not new, not even in its broa-
der interpretation. What is new, however,
is that today's problems that need techno-
logy assessment have become more numerous,
more severe, and more complex. Also public
awareness of these problems has become more
acute, and insistence that something be done
about them has become more vocal.
Scientists and engineers are often sur-
prized when they find that problems of urban
blights, social unrest, environmental pol-
lution, inadequate educational opportunities
and health care deficiencies do not respond
neatly to scientific and technological ini-
tiatives. Even the systems approach, which
worked so well in the 1950s and 1960s for
developing complex missile systems and for
putting man on the moon, simply cannot be
used here for at least two important reasons:
(1) The objectives are much more
diffuse, relating less to economics and
"hard" science and engineering.
(2) The disciplines involved are much
more heterogeneous, and we have not yet
learned how to orchestrate them for coordi-
nated assaults on our problems.
The apparent need for technology assess-
ment as an integral step in the planning,
organizing, and implementing of our acti-
vities today is an outgrowth of changes
that have been taking pl^ce over the past
several decades, some of which are:
(l)Technology and management tech-
niques are providing more and more leverage,
often with more severe consequences, shorter
lead-times and greater impacts.
(2) Mistakes made are becoming more
costly; there is an increase in the irrever-
sibility of many of our actions.
(3) There is less damping; our envi-
ronment is becoming less forgiving of abuses.
(4) Our goals are becoming more comp-
lex, and call for correspondingly increas-
ingly complex interdisciplinary approaches.
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Who should do what and why?
Office of Technology Assessment (OTA)
Who should do technology assessment? The
answer is simply "everybody"' whose contemp-
lated actions may unintentionally but ad-
veresely affect the environment ( physical
as well as social) in which he operates.
Why? It is a simple matter of striving
not to cause indiscriminate damage to the
environment in which we live. The govern-
ment has an obligation to see to it that
beneficial programs in one area do not
cause more damage in another to the net
detriment of the public. It is in the
interest of industry not to be viewed by
the public, and hence its markets, as the
"exploiter"of the public's physical and
social environments.
Hence, it is difficult to argue with the
concept. It is when we talk about imple-
mentations that the issues become contro-
versial.
Now that technology assessment is insti-
tutionalized, will it tend to turn to tech-
nology arrestment? Definitely not, if we
keep two requirements in mind, both of which
are consistent with the spirit of the move-
ment or concept.
(1) Technology assessment, as practiced
within the Office of Technology Assessment
of the US Congress, must not even resemble
some regulatory entity. It should be some
sort of staff function, to generate unbiased
assessments, by laying out options and
"costs" for the public to scrutinize and for
the government (and especially Congress) to
study and act upon. An improvement in the
quality of public debate, legislation, and
program management, through a better under-
standing of the many variables at play, will
be the true measure of the effectiveness of
a technology assessment function, or more
specifically of the Office of Technology
Assessment (OTA).
(2) Technolgy assessment must not stifle
basic research, scientific innovation, or
creativity. Rather it should help us gain
badly needed insights into our world of
ever increasing complexity, so that in turn,
our decisions and actions could become more
reasoned and hence more rational.
Public Law 92-484, the Technology
Assessment Act of 1972, created near the
end of 1972 the Office of Technology
Assessment (OTA) within the Congress of
the United States.
What is most significant about this de-
velopment is that perhaps for the first
time, our legislative branch, which autho-
rizes and appropriates all federal funds,
and which makes the laws that govern us all,
can have within its midst a high calibre,
sophisticated, analytical capability to help
it understand the multitude of issues of
ever - increasing complexity, which Congress
must resolve and act upon. The potential
national marginal utility of OTA is inesti-
mably great!
HOW TECHNOLOGY ASSESSMENT DIFFERS FROM
ENVIRONMENTAL IMPACT ASSESSMENTS AND
STATEMENTS
To an audience such as this one, with
extensive representation from the Environ-
mental Protection Agency (EPA), the question
posed by the above sub-heading should be
one of considerable interest.
Both, technology assessment, and environ-
mental impact assessments and statements
address the deleterious side effects of our
actions. But, while EPA's primary concern
is with the physical environment, techno-
logy assessment concerns itself with a
broader spectrum, that also includes among
others the social environment. Yet, it is
not an easy matter to find topics which can
be clearly placed within the purview of EPA
or OTA at the exclusion of the other.
Two examples come to mind, which may be
appropriate subjects for technology assess-
ment, but not for attention by EPA.
(1) Potential genetic manipulations
and their impacts on our general social fab-
ric (present and future), and
(2) Large national data banks (compu-
terized) , and their implications for in-
vasion of privacy.
Such examples are difficult to identify,
and the the two major differences between
EPA and OTA do not derive primarily from
differences between their respective substan-
tive jurisdictions. The two major differen-
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ces derive, instead, from the following si-
tuations:
(1) The law which established EPA
requires that each Federal entity prepare
environmental impact assessments and state-
ments with regard to their contemplated
actions, that might affect the environment
adversely; and then these statements are to
be reviewed and acted upon by others, con-
ceivably interfering with the initially
contemplated program.
Technology assessment, as presently
institutionalized in OTA, addresses issues
on a highly selective as opposed to some all
encompassing basis. The primary objective
of OTA is to inform the public and aid Cong-
ress in its deliberations. It is a "staff
function" to be informative...to delineate..
to enlighten...etc., as opposed to anything
even resembling some regulatory function,
or some other, able to bring about injunc-
tions.
(2) EPA and its functions and respon-
sibilities are within the executive, while
those of OTA are within the legislative
branch of government.
THE INSTITUTIONALIZATION OF TECHNOLOGY
ASSESSMENT IN THE OFFICE OF TECHNOLOGY
ASSESSMENT IN THE UNITED STATES CONGRESS
Public Law 92-484 calls for a 13 member
Technology Assessment Board, including six
Senators and six Congressmen, equally divi-
ded among Democrats and Republicans. Du-
ring an odd-numbered Congress a Senator ser-
ves as the chairman, and a Congressman as
the vice-chairman. During an even-numbered
Congress the roles are reversed.
The make-up of the Board as of this wri-
ting is as follows:
Sen. Edward M. Kennedy (D-Mass.) Chairman
Rep. C. A. Mosher (R-Ohio), Vice Chairman
Sen. E. F. Rollings (D-S.C.)
Sen. H. H. Humphrey (D-Minn.)
Sen. C. P. Case (R-N.J.)
Sen. R. S. Schweiker (R-Pa.)
Sen Ted Stevens (R-Alaska)
Rep. J. W. Davis (D-Ga.)
Rep. 0. E. league (D-Tex.)
Rep. M. K. Udall (D-Ariz.)
Rep. C. S. Gubser (R-Calif.)
Rep. M. L. Esch (R-Mich.)
E. Q. Daddario, Director OTA, (13th member)
In addition there is a twelve-member
Technology Assessment Advisory Council, com-
prized of ten public members, the Comptrol-
ler General and the Director of the Cong-
ressional Research Service of the Library
of Congress.
The make-up of the Advisory Council as
of this writing is as follows:
Dr. Harold Brown, Chairman
Dr. Edward Wenk, Jr., Vice Chairman
Mr. J. Fred Bucy
Mrs. Hazel Henderson
Mr. Lester S. Jayson
Mr. J. M. (Levi) Leathers
Dr. John McAlister, Jr.
Dr. Eugene P. Odum
Dr. Frederick C. Robbins
Mr. Elmer B. Staats
Dr. Gilbert F. White
Dr. Jerome B. Wiesner
The Director of OTA is former Congress-
man E. Q. Daddario. The staffing of the
Office is currently under way.
Just exactly how OTA will fare, and how
effective it will eventually become, is just
too early to tell.
First, OTA will have to get institution-
ally anchored to the existing system. New
organizations are rarely readily accepted
by the entrenched ones which they join.
Second, OTA will have to earn the respect of
a kaleidoscopic variety of constituents
through proving its credibility, by lay-
ing out options that are sound, and sets of
likely consequences as impartially as the
"value-free" nature of such consequences
will permit, and by refraining from taking
unique stands on issues which should be
left to members of Congress, but making it
easier for them to do so more rationally.
And, finally, by assuring for cause, that
it, OTA, will not be likened in any fashion
to regulatory agencies.
OTA is indeed faced with some Herculian
tasks. Its success to get institutionally
rooted, and to build the respect and cre-
dibility it needs, will depend in no small
measure on the subjects it will be asked
to assess initially.
Should OTA confront, too early in the
game, highly controversial, emotionally
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charged topics, where "battle lines" have
already been drawn, and powerful people
have already taken virtually irrevocable
positions, then OTA will get "swamped" and
dismissed as an "ineffective instrument."
On the other hand, should OTA get invol-
ved at the other end of the spectrum with
safe trivia, then it will be viewed as
irrelevant, and simply "written off."
Initially OTA will have to address issues
in the middle of the spectrum, where the
subject is important enough to command
attention, but not so important or contro-
versial (due to past history) as to jeopar-
dize the demonstrability of OTA's utility.
OTA will need some early "wins." By "wins"
I mean public recognition of its utility.
I do not wish to imply that OTA should
stay away from highly sensitive issues in-
definitely. Quite the contrary! But, first
things first. I am talking about getting
OTA into a position to be able to address
important issues, but without being threat-
ened in the process for the wrong reasons.
Another pitfall that OTA is facing, con-
cerns the balance between in-depth, high
quality assessments that take months and
years, that OTA is likely to support one
way or another, and high quality quick-
reaction capabilities to assist Congress
quickly, when it needs it. The former type
of efforts can be and already are being
supported by such organizations as the
National Science Foundation (NSF). The
latter, quick reaction capability is still
to be established. If OTA is to be able
to provide this, it will have to heavily
draw on the technical and intellectual
wherewhital of its very own OTA staff.
Also, OTA is anything but immune to the
political vageries, over which it has vir-
tually no control.
Hence, whether OTA succeeds or fails, will
depend on a number of items.
(1) The appropriate selection of the
mix of issues, that OTA can manage to get
itself involved in.
(2) Political vagaries over which it
has no control.
(3) Last but not least the very staff
of OTA. Should they fail to establish with-
in their midst a high calibre, substantive,
imaginative, politically astute capability,
which does not have to go out on contract
to respond to Congressional inquiries, with
the "best 'quick' answer under the circum-
stances," then the effectiveness of OTA as
a potential instrument will have been comp-
romized, irrespective of what else will
happen on other fronts.
Which way OTA will end up ultimately,
is simply too early to tell as of this
writing.
REFERENCES AND BIBLIOGRAPHY
This address is based on numerous arti-
cles, papers and lectures by the author,
appearing in such places as :
(1) Chapter in book: Science and Tech-
nology Policies, coedited by the author,
and published by Ballinger, Cambridge,
Massachusetts, 1973.
(2) International conferences, meetings
at;Tokyo, Japan (Japan Industrial Planning
Association); Paris, France (Organization
for Economic Cooperation and Development);
Milan, Italy (NATO) ; England; Germany, etc.
(3) Testimony before the US Congress-
(4) Lectures at various universiti^- e.g.
UCLA, Carnegie Mellon, Rutgers, etc.
(5) Various publications, such as: Harvard
Business Review; Research and Development
R&D; Society of Automotive Engineers, Inc.,
etc.
(6) Participation in panels and conferen-
ces of such organizations as: NAE, NAS, OST,
IEEE, ASCE, etc.
(7) Examination of current pieces in the
open literature as authored by others.
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SCOPE AND PURPOSE
D. L. Morrison
Manager, Energy/Environmental Programs Office
Battelle
Columbus Laboratories
505 King Avenue
Columbus, Ohio 43201
ABSTRACT
As an introduction to the overall meeting, this paper states the scope and purpose
of the meeting, what the initial aim is to discussions and problem solving. It deals
with the matters to be covered as well as the matters which may arise during presentation
and discussion. This conference is an experimental conference in which, hopefully,
solutions to pollution control technology can be recognized and the interrelationships
between each pollution type are dealt with in a manner whereby an answer or solution can
be presented. This conference will address the basic steps involved in pollution control
technology assessment. The conference itself provides a means for communication among
some of the interested parties.
TEXT
Environmental problem-solving has
been a learning experience. Through direct
approaches to pollution problems, many
technological solutions have been developed
to control pollution. This progress, how-
ever, has enabled us to see the elements of
environmental quality more clearly and it is
now apparent that we are better transformers
of environmental problems than we are
solvers.
This conference is an experimental
conference. It is not concerned with water
pollution control technology directly. It
is assumed that water pollution control
technology is or can be made available to
allow the control of water pollutants to
any degree desired. The scope of the con-
ference is directed at the assessment of
this water pollution control technology and
with the identification of the secondary
effects that are brought about in our
attempts to achieve clean water. The intro-
duction to the subject of technology assess-
ment previously made has set the stage for
the broader perspectives to be addressed.
Through this conference we wish to explore
the subject of environmental quality
through an assessment of pollution control
technology.
Solutions to pollution control tech-
nology begin with the recognition that
there are many interrelated factors. The
assessment of the impacts of pollution
control technology requires an identifica-
tion of those sectors that may be impacted
by the technology itself and by the by-
products produced in the pollution control
process. The assessment, by its very
nature, requires effective communications
and discussions among all of the principals
involved. These include, of course, the
scientists and engineers directly dealing
with pollution control technology; social
and behavioral scientists dealing with
many of the human factors of the problem;
economists directing their attention to
the monetary costs and benefits of control
technology; the legislators who establish
the general goals for environmental
quality through laws; enforcement agencies
which set regulations; the industrialists
and municipalities who are confronted with
-------
the need to control water pollutants; and,
of course, the general public upon whom
all of the factors impact. The attainment
of improved environmental quality requires
solutions to pollution problems that con-
sider all of the impacted sectors. The
final step in the technology assessment
involves the recognition and the explicit
statement of the environmental trade-offs.
This conference will address the
basic steps involved in pollution control
technology assessment. The methodology
for pollution control technology assess-
ment will be discussed. Stated simply,
the methodology for technology assessment
provides a means to explicitly address the
interrelated elements of pollution control
technology. This involves the identifica-
tion of the media that may be affected by
pollution control technology and a consid-
eration of the cross-media impacts involved
in the solution of any problem. In res-
ponse to legislation regulations are set
for one medium with little concern for the
other media that may be involved. It is
clear by now, however, that solutions to
air pollution control problems often
result with residuals that have an impact
on water quality and produce solid waste
disposal problems. In a similar fashion,
sludges produced by wastewater treatment
processes must be dealt with in an appro-
priate manner, otherwise air pollution
problems from incineration can result or
land must be allotted for disposal of these
particular wastes.
In addition to the media, the
various types of environments must be
encompassed in the technology assessment.
Each of the three broad environments — the
physical, the biological, and the human
environment--must be considered by itself
and in relation to the others.
Problem understanding is the second
major element to be addressed through this
conference. The speakers on the program
represent many disciplines with various
points of view. It is expected that
through these presentations, the many
variables will be identified which must be
faced in pollution control technology.
The conference itself provides a
means for communication among some of the
interested parties. While it is necessary
to develop solutions to environmental
control problems, the very understanding
of the problem depends upon communication
of the secondary and higher order effects
by the impacted sectors. The alternatives
to pollution control cannot be developed
without communication among all impacted
sectors.
It is now well recognized that
environmental quality can only be achieved
if there is involvement by the impacted
groups. The final step, of course, of
pollution control technology assessment is
the commitment to take an appropriate
action which maximizes the benefit to the
largest number of people and minimizes the
costs involved both from a monetary and
an environmental point of view.
10
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/
Moderator:
N. Drobny
Battelle-Columbus Laboratories
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INDUSTRIAL VIEWPOINT
LEGISLATIVE MANDATE AND STANDARDS
Bernard M. Kostelnik
The Anaconda Company
25 Broadway
New York, New York 10004
ABSTRACT
The concern of industry over the numerous new regulations and legislation regarding
their business is great. Each new regulation must be faced squarely and an attempt
must be made to comply. In many cases this may be the beginning of the end for some
companies, or in others a contradiction to an already established regulation. The
industrial firms who must live with new legislation should be given a better opportunity
to comply by being consulted by EPA officials and others in a lawmaking capacity before
contradictive or unrealistic legislation is passed on to the industries, thus saving a
great deal of money and distress for everyone concerned.
TEXT
I think Ray Smithson invited me here
for two reasons. First of all, he knows
that. I consider that Battelle did an over-
all fine job on the water effluent guide-
lines study it did for the primary copper,
lead and zinc smelting and refining
activities, and secondly, I think he knows
that I may not often enlighten but I often
provoke discussion, so I think I fit into
the panel.
We all, of course, must and do take
seriously at this point all the environ-
mental legislation that is affecting us.
We are living with it every day. We seem
to be besieged by armies of EEA people,
state people, and local people, to the
point that all this environmental legis-
lation together seems to be the current
version of the full employment acts of the
1930's. When executives ask me just what
could happen to them under this legislation
I usually tell them two stories, and it
usually has a pretty good effect.
The first one is about the fellow
who had been involved in nefarious affairs
who got caught for the first time. I'm
not suggesting a similarity between this
man's activities and the executives of
whom I speak. It was a new experience for
him to go through the trial, and finally
he was found guilty. He'd been asking his
lawyer all the way along what happened
next. After the guilty verdict came in,
he asked what happened next, and the lawyer
answered, "your're going to jail, I'm
going to lunch." It illustrates the old
axiom that lawyers never lose. Now we have
in environmental legislation, with its many
criminal penalties, a new potential loser
in the executive who refuses to tkae these
new laws seriously.
The other tale I like to tell execu-
tives is another criminal law joke which
isn't applicable, but I wish it were. I've
been told that this is based on an actual
case. The defendant in his late fifties
was brought before the judge after having
been found guilty and sentenced to 20 years.
He says, "Your Honor, I'm old and I'm sick;
I'll never live out that sentence." The
judge looks at him dispassionately and says,
"Do the best you can."
Unfortunately, I feel that particu-
larly in the water pollution field the
best is often not enough. I think EPA and
industry obviously take different viewpoints
about what the best is, but I feel that
there is an air of unreality about the way
some of these standards are developed, and
I'll touch on that a little later.
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Since this is something of a free
form panel without prepared talks, in
which my role is to reflect industry's
viewpoints, I'd like to touch briefly on
several points. A speaker earlier men-
tioned environmental impact statements.
The new vogue now is for state laws to add
their own legal requirements for environ-
mental impact statements. I think they're
unmitigated disaster up to this point.
As an example, we applied in Montana
for a variance last spring when certain
standards were going to take effect on
July 1. Of course, we'd been telling the
state all along that they were unreal
standards, so we did apply for a variance
for the period ending June 1974. One year
later we're just about to amend our state-
ment to ask for another variance for the
next year ending June 1975 because we've
hardly gotten off the ground on our appli-
cation for the first year.
The first thing the state did was
get in the environmental impact statement
game and that's taken the better part of a
year just to mess around with that because
in fact, they're practicing on us. They
don't have the time, the people, the staff,
the experience, and yet they're trying it.
It's on the books as the thing to do and I
think it's just another element of legis-
lative disaster. One direct impact on
industry is that every step of the way
we're being asked for information. Our
people are spending half their time in
legislative offices, in the agency offices,
and it's just a long wheel-spinning
experience.
I for one in that particular case
would have preferred to see us just sit
back and say "Well, you passed the law, you
passed unrealistic regulations, now go
ahead and enforce them," and I think we'd
have been much better off. I think we
might have had the matter resolved by now,
certainly at the trial level. I feel that
industry, more and more, is finally coming
to the realization that if it's convinced
that a particular set of standards is just
completely erroneous and unachievable and
that they have a strong technical and legal
position, they ought to just stand pat and
litigate some of these things. I noted
that EPA has some 400 pending cases, so
clearly others share my views.
Sometimes the wrong companies test a
law or regulation. We had a case in
southern New Jersey where for years when
you'd drive down the southern part of the
Turnpike you knew that when you got to this
area you had to watch yourself because a
substantial cloud would often be covering
the road. There were some accidents and
many close calls due to poor visibility,
yet it's that company that chose to fight
the New Jersey regs, which had weaknesses
which should have been stricken. Of
course they lost, and we all went down
with them.
So, although in that case the regs
were very weak and very bad in some
respects, bad cases make bad law or
sustain bad law.
Someone mentioned energy and the
environment. I think economics, energy and
the environment are becoming much more
closely intertwined and appreciated.
Though not directly on point, I'd like to
read a couple of sentences from a news
clipping reporting on a hearing before the
the New Jersey Department of Environmental
Protection on a proposal to build a two-unit
oil-fired electric generating power plant
on a 186-acre tract consisting of marsh,
sand, and grass on the Raritan Bay. To the
surprise of many, several hundred people
showed up. They had an 8-hour public
session, and with four or five exceptions
everybody was vociferously in favor of the
power plant, so I think things are changing.
This was and is a rather depressed area.
One fellow said after he had been listening
to the opponents, "We've heard here what's
good for the fish, what's good for the
birds, what's good for the plants, but
nobody has told us what's good for the
people." This was a retired resident who
was arguing in favor of the power plant.
If you know that section of New Jersey,
it's right at the bend down from New York
harbor. It really is an awfully nice area
but the conservationists picked it out as
a wetland area and had it so designated.
They're holding tightly to it, opposing any
development of any sort in that area.
Another fellow at this hearing said,
"This is a staged crisis; the problem is
not ecological but economic. I believe in
ecology where it belongs. This state and
this area are industrial. We will never
have a wild animal kingdom here. We need
electric power. We need jobs. We need tax
13
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returns that can help us save and restore
our towns." These were the local people
who would be most directly affected, most
directly impacted and they came out in
force because people are finally coming to
realize in states like New Jersey -- and
the unions particularly are coming to
realize this -- that the 8 and 9 and 10%,
and in the case of certain construction
trades 14 and 16% unemployment has some
causes which you don't find in the news-
papers. This reminds me that at a hearing
last week in Washington a fellow from a
chemical company said that EPA had publicly
announced that only 30 plants shut down
last year in the U.S. because of pollution
requirements. He said that his company
alone shut down 5 last year, and couldn't
believe that his company was 16% of the
national shutdown experience last year. I
feel about the New York Times and its
environmental coverage the same way certain
Republicans do about its political report-
ing. We just don't get balanced coverage.
Getting back to employment statistics
as they relate to environmental quality,
union and others are starting to realize
the connection, and you can detect this
even in the New Jersey Legislature, which
has rushed through many harsh measures in
the past with little debate. To have the
type of hearing I've reported on occur in
New Jersey has been a severe surprise for
some of the environmentalists, but I think
economics are really coming to the fore.
People just aren't working through
large areas of New Jersey in the construc-
tion trades. Many companies, making no
fanfare about it, have been going else-
where. My company is going to expand
greatly our existing refinery out West
rather than the one in New Jersey. Another
copper company which has been in New Jersey
for decades has announced it's going to
spend $100 million in Texas and build a
completely new refinery down there. So
the New York metropolitan area is really
getting -hurt to the point where people are
sitting up and taking notice.
As I said, in a forum such as this I
usually try to provoke some discussion of
differing viewpoints. I may succeed by
stating my opinion that one of our big
problems today is Senator Muskie. I think
we all greatly respected his environmental
efforts back in the late 60's. 1 took part
in the hearings on the Clean Air Act in
1967 and 1970, and he was really on top of
his subject; he really knew his stuff. He
asked very searching questions, he was very
close to his subject. It seems to me that
since he was bitten by the presidential bug
he's turned largely into a liability on
this issue. I don't think he knows his
subject well anymore. His interests may be
elsewhere. I think other people are to a
great extent writing his script for him.
These are harsh words about Senator Muskie,
but deserved when one considers all the
good he could be doing. I think he is
going to be the loser in the end because I
think the pattern has to emerge that some-
thing significant has to be done with the
Clean Air Act and the Water Act or we're
all going to be in trouble economically in
very short order. Just look at the growth
in funded debt of heavy industry over the
past several years.
One of our competitors announced
recently a new smelter in New Mexico, and
quoted some figures. Out of a $200 million
capital cost, somewhere between 25% and 30%
of that capital investment is going to be
spent just on air pollution control; this
is without even getting to the water area.
On the energy end, something around 85% of
the kilowatt hours forecast are going to be
used to drive these pollution controls.
Now if that isn't the tail wagging the dog
I don't know what is. But this is the way
things are going.
Permit me one more example. I like
to give practical examples, especially when
so many agency people are in the audience,
for I can't help believing that some of the
people in the agencies really don't realize
what's going on in what we call the "real
world".
Bunker Hill filed an affidavit in the
toxic pollutant water hearings last week.
Just to touch on a couple of essential
points, their mine in the Kellogg, Idaho
area has been there since 1885. They've
just spent a number of millions of dollars
in putting a new treatment plant in, which
I gather everybody agreed is the best prac-
ticable control technology currently avail-
able. Even with it, Bunker Hill said they
won't get anywhere near meeting the toxic
standards being proposed. EPA says, "Well,
evaporate. Build ponds and let it evaporate
and move the sludge out." Bunker Hill says
to do that it will take 10,000 acres, or a
16 square mile lake, for an evaporation
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pond sufficient to do that. The valley
in which they exist is 9 miles long and a
half mile wide. Even assuming they had
the space, which they don't, and assuming
that seepage is going to have to be con-
trolled with an impervious liner, they said
it would cost $397 million to do this. As
I recall, that's more than the company's
net worth, but these are the things that
we face in these totally unreal require-
ments. Bunker Hill further says that using
methods proposed by EPA would cost $13
million a year and use enough energy to
support a 400,000 population, and still not
meet their toxic standards. And so they
analyzed everything that EPA proposes, and
said in their affidavit that "implementa-
tion of the proposed standards would force
Bunker Hill's operations to cease." 6,000
jobs in that area of Idaho is an awfully
large percentage of the working force.
6,000 jobs would go, without considering
the ripple effect, of course, on the whole
area. And it's just sheer disaster that
these are the things that would happen.
My own company in Anaconda, in Butte,
Montana, alone would need a lake 7,000
acres in dimension, and with the impervious
liner requirements costing somewhere
between $30,000 and $50,000 an acre, you
are talking of a quarter of a billion
dollars. Amazingly, this overkill doesn't
seem to bother many at EPA, who say, "Well,
this is the thing you should do. We don't
want an ounce seeping into the ground.
We don't want an ounce being discharged."
I think the heart of the problem
right now is EPA management. EPA is
hiring some bright young men, who really
want to dig in and find out what's going
on. I'm really impressed with the caliber
of the younger people over the last 12 to
18 months. Unhappily, EPA still has too
many people at the middle management level
who play what I call a "low number game".
They just search the literature to find
the lowest number they can find, though
it may have evolved in a wholly different
context.
These low numbers are publicly
promulgated apparently with no sense of
embarrassment. For a while we used to
laugh and say they couldn't be serious,
but we know darned well they are now. My
company can offer a sad example of the
number game on the air side. I read
recently where the Foundry Association
said that well over 300 foundries have
shut down in the last 2-1/2 years because
of air pollution requirements. We have a
little foundry that serves our refinery in
New Jersey. It operates 2 days a month on
an average and it's in the middle of a lot
of tall buildings where you really couldn't
see it or the emissions from it from the
boundary of our property. The test in New
Jersey is emissions, not ambient conditions
beyond your property line. So we spent
$60,000 in installing what they agreed was
the best technology. It didn't comply and
totally unembarrassed they came back and
said, "You control it to the standard or
shut it down." We're still running. They
haven't come after us yet. I think if
they do we've got to just make a stand
against such unreasonableness.
Getting back to my friend from the
chemical company, and to the subject of
legislation, there's a section in the
Water Act which I call the blackmail
provision. It very properly in the first
part of it sayd that an employee can
administratively raise charges that his
employment was affected either by being
terminated or substantially affected in
some other way because of activities of
his in the pollution control field against
the company working to the detriment of the
company. That's fine, a good provision.
But it goes on to say that anybody who
feels that his job was ended because of
pollution control, or is threatened, can
also initiate these administrative
proceedings. Of course, the long and short
of that is that when a company finally
totes up the control bill that it's facing
it just quietly shuts the place down and
leaves, rather than blame pollution costs
and face a bureaucratic nightmare. That's
never counted as a closing due to unrealis-
tic control demands. EPA says with some
justification that usually these are old
facilities, largely outmoded. Nonetheless,
they had been operating for decades,
producing products and offering employment.
Our plant in Perth Amboy has been
there since the 1890's. We've spent
capital rebuilding the tankhouses and
various portions. They've been largely
built inside but the darn place is 80
years old and we've been operating for 80
years, just as Bunker Hill has been mining
for 85 years. There's been no devastation,
no epidemics of this, that or the other in
the way of health effects. These are the
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realities which must be put on the legis-
lative scale and weighed before it's too
late.
Getting back to the trouble with
existing legislation, as I see it, I think
that even EPA acknowledges today that
timing is one of the big statutory
problems. Toxic standards are supposed to
be implemented and achieved in one year.
That's an absurd requirement and I think
even EPA acknowledges that's so. They are
in favor of going to Congress and taking a
more realistic look at it and putting in a
more realistic schedule. But again, I say
the low number game is a large part of the
problem, and I think EPA middle and top
management is essentially accountable for
allowing this to develop. Most of the EPA
top management are lawyers these days,
from Mr. Train down. When standards such
as have been proposed lately get to
management, I find it hard to believe that
they bring their people in and say, "Now,
where did you get this number? Why just
one number? Where does it come from?
What's the reliability of it? Of the
fellow who found it? Do you have confi-
dence in the methods that he used? What
does industry say about this? What do
they say is achievable?" Every time I go
to an advisory meeting or to a meeting at
the EPA technical staff level, I ask,
"Why can't you have a lawyer here to hear
these things as we develop them?" They
say, "Well, you'll have to take that up
with legal counsel." That's what we've
been trying to do! You just can't get a
handle on EPA at its middle levels. It's
a big amorphous blob. Many of the growing
pains are understandable, but nonetheless
frustrating. You go to a certain point
with the technical people and they say,
"Well, you have a point there, but that's
outside my jurisdiction." You say, "Whose
jurisdiction is it?" "Well, it might be
So-and-so in this section, but of course,
he left last month, or it might be So-and-
so in that section, but he's in California."
One complicating factor I'm convinced
exists is a middle management level with
bad emotional bias that really isn't
giving the complete input to top manage-
ment it should. A healthy skepticism at
top EPA levels with its own staff input,
and not just with industry's input, would
be a favorable development.
How many of you had my experience?
You have a man spend 16 days, maybe 2 or
3 people spend 16 days, getting up
requested data, you send it in, and it gets
buried somewhere. It never gets out of the
files in Durham. You realize this later
when you talk in Washington with an
assistance administrator when he says, "I
never heard of that."
I've used my allocated time. I hope
my far-ranging observations and criticisms
will stimulate a profitable discussion
period.
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HIGHLIGHTS OF LEGISLATION
R. H. Johnson
Deputy Assistant Administrator for Water Enforcement
United States Environmental Protection Agency (EG-335)
Washington, D.C. 20460
ABSTRACT
The FWPCA requires EPA to regulate the discharge of pollutants from "point sources"
into our nation's waters. Federal control under the Water Act follows a two-phase
process. First, standards must be set, telling each industry the general degree of
pollution control technology that it must adopt. Second, permits must be issued for
each specific plant discharging waste into the water, detailing in precise terms what
each plant may discharge, and including a compliance schedule with an enforceable
sequence of actions to assure that each industrial facility will meet permit specifica-
tions in a timely manner. Point sources discharging directly into navigable waters must
meet discharge limitations based on effluent standards or water quality standards, which-
ever is stricter. These limitations are based primarily on the availability of pollution
control technology. In general terms, existing dischargers must adopt best practicable
control technology currently available by mid-1977 and best available economically
achievable technology by mid-1983. In addition, new plants must install "best available
demonstrated control technology", which under our guidelines is translating into a middle
ground somewhere between the 1977 and 1983 requirements. Now that the implementation of
the 1972 amendments to the Federal Water Pollution Control Act is underway, it is also
useful to look at other Federal environmental laws to see how they may impact water
pollution control. We have environmental legislation, proposed or enacted, covering
such diverse problems as land use, the discharge of toxic substances, the protection of
fish and wildlife, and others. The regulation of these problems could indirectly affect
water quality, although the impact is not very significant in all cases. In some cases,
however, portions of a bill can have a direct impact on water quality. The 1972 amend-
ments to the Federal Insecticide, Fungicide, and Rodenticide Act, for example, provide
a clause that specifies general environmental protection. The House version of the Safe
Drinking Water Act of 1973 expands the control of the Federal Water Pollution Control Act
amendments of 1972. The Clean Air Act has requirements which, if mismanaged, could
potentially cause water pollution problems. EPA is aware of these interrelationships
and prevents negative impacts through the implementation of our standards and regulations.
FWPACA AMENDMENTS OF 1972
On October 18, 1972, Congress passed
the Federal Water Pollution Control Act
Amendments of 1972. It provides new
enforcement tools for combating pollution
and increased Federal grants for construc-
tion of waste treatment facilities and
euthorizes additional funds for research
into problems and solutions to pollution.
In enacting the new legislation, Congress
stated that it is the national goal that
the discharge of pollutants into navigable
waters be eliminated by 1985. As an inter-
im goal, it is stated that there be
attained by July 1, 1983, water quality
which provides for the protection and
propagation of fish and shellfish and
provides for recreation in or on the
water. In order to achieve such goals,
the Act requires establishment of effluent
limitations based on technology for the
achievement of "best practicable control
technology currently available" by July 1,
1977, and "best available treatment
economically achievable" by July 1, 1983.
These effluent limits apply to point sources
discharging to navigable waters.
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Permit Program
A major facet of this law was the
establishment of a new national permit
system called the National Pollutant Dis-
charge Elimination System (NPDES). Under
this program, industrial, municipal, and_
other point source dischargers must obtain
permits setting forth specific limitations
on the discharge of pollutants into the
navigable waters of the United States.
As of April 15, about 900 major per-
mits and over 5,000 minor permits have
been issued.
State Approvals
This new permit system is national in
scope, involving both Federal and state
participation. The objective is a state
administered permit program.
We have approved 9 states to operate
the national permit program. They are
Connecticut, Vermont, Michigan, Ohio,
Wisconsin, California, Oregon, Washington,
and Delaware. Hearings have been held on
4 others: Nebraska, Montana, Mississippi,
and Georgia, and approval of these addi-
tional 4 states is anticipated. Another
five to seven states should be approved by
September of this year, bringing the total
to about twenty.
We and our regional offices are work-
ing closely with states to get them to
take over permit issuing responsibility,
and in many states, joint programs with
EPA for permit issuance are being carried
out even though the state has not requested
formal approval. We expect that by the end
of this calendar year about 25 states will
have received formal approval.
Permit Requirements
The basic requirements of the permit
program, such as final implementation dates
and effluent limits are consistently
applied nationwide regardless of whether a
state or EPA is running the program. Every
discharger qualifying under the point
source and navigable water definitions must
apply for a permit if it has not already
done so under the first national discharge
permit program established by Executive
Order 11574. The 1899 Refuse Act was the
basis for that program.
Permits issued under the NPDES have
a basic format of effluent limits, a
compliance shcedule, and monitoring re-
quirements. The 1977 and 1983 dates are
targets to be.viewed as the outside limits
for compliance. The Act envisions that in
meeting effluent limitations, there may be
stages of compliance described as the at-
tainment of levels of substantial improve-
ment even before these legislative dates.
The compliance schedule may contain
dates for achieving certain levels of
progress such as preparation of engineer-
ing reports, final construction plans,
beginning and completion of construction,
and finally, operation of facilities.
Interim dates and requirements are speci-
fied in the permit as a means of monitor-
ing progress and minimizing slippage. For
each interim date, the permittee must sub-
mit a written notice of compliance or
noncompliance with the interim require-
ments. Where such interim dates may not
be appropriate, reports of progress will
be required at least every nine months.
The permits may, therefore, have more
than one set of effluent limits. Limita-
tions may be expressed as concentrations
where the rate of pollutant generation is
not directly linked to the production
effort, such as in mining, or where other
requirements, such as toxicity, apply.
The effluent limits are described in terms
of average and maximum kg (Ibs.) per day.
They are based on national effluent guide-
lines established under the Act or water
quality standards, whichever is more
stringent.
Best Practicable Control Technology
and Best Available Technology
The new Act charges the Administrator
with the task of publishing regulations
providing "Guidelines" for uniform effluent
limitations for point sources from indus-
trial categories. These effluent limita-
tions reflected in the permits are the
ones which shall require the application
of the Best Practicable Control Technology
Currently Available for the 1977 target
date and Best Available Technology Economi-
cally Achievable for the 1983 target date.
Three things are identified in the regula-
tions.
First, they give meaning to the terms
"Best Practicable" and "Best Available"
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when applied to the various categories of
industries. In defining "Best Practicable"
and "Best Available" for a particular
category, such factors as the age of the
equipment and facilities involved, the
process employed, the engineering aspects
of the application of control techniques,
process changes, and non-water quality
environmental impact (including energy
requirements) are taken into account. In
assessing "Best Practicable Control," a
balancing test between total cost and
effluent reduction benefits is made.
"Best Available" technology is the highest
degree of technology that has been demon-
strated as capable of being designed for
plant-scale operation, so that costs for
this treatment may be much higher than for
treatment by "Best Practicable" technology,
so economic feasibility is a factor in
interpreting "Best Available" treatment.
Cost effectiveness for either standard
is to be confined to consideration of
classes or categories of point sources and
will not be applied to an individual point
source within a category or class.
Second, having interpreted "Best
Practicable" and "Best Available," guide-
lines are being published which will deter-
mine what "effluent limitations" are to
be imposed on dischargers. In these guide-
lines, the degree of pollution abatement
attainable through the application of the
"Best Practicable Control" and "Best Avail-
able Technology" in terms of amounts of
constituents and chemical, physical, and
biological characteristics of pollutants
are identified. These guidelines can then
be applied in setting specific effluent
limitations on dischargers.
Third, the regulations identify con-
trol measures and practices to eliminate
the discharge of pollutants.
We have issued final guidelines for
21 industrial categories,* and others (such
* Fiberglass, Beet Sugar, Cement, Feed-
lots, Rubber, Flat Glass, Phosphates,
Ferroalloys, Asbestos, Electroplating,
Meat, Inorganics, Cane Sugar, Plastics and
Synthetics, Grain, Fruits, and Vegetables,
Fertilizers, Non-Ferrous Metals, Leather,
Soaps and Detergents •
as Timber, Dairy, Pulp and Paper, Builders
Paper, and Pertroleum) are under a defini-
tive schedule for finalization prior to
publication in the Federal Register. Not
later than July 1, 1977. publicly-owned
treatment works must meet effluent limi-
tations based on "information" which the
Act requires the Administrator to publish.
The "information" describes the degree of
effluent reduction attainable through
application of secondary treatment. This
"information" was published by EPA in the
Federal Register on August 17, 1973.
NPDES permits are also required for pub-
licly-owned treatment works.
Water Quality Standards
The new Act includes the concept of
water quality standards in 1977 and 1983
achievements. Water Quality Standards
which were adopted and enforced under the
old FWPCA for interstate waters continued
in effect and could be updated, and new
ones were to be established for intra-
state water bodies where not previously
adopted by the states. This revision
process (303(a) and (b)) is essentially
complete. If water quality standards can-
not be protected by the application of
best practicable control technology for
industries and secondary treatment for
municipal wastes before 1977, then efflu-
ent limitations will be set which will
protect water quality standards. Before
1983, if best available treatment and its
equivalent for municipal facilities will
not contribute to attainment of water
quality which will protect public water
supplies, agricultural and industrial
uses, protection of a population of fish
and wildlife, and allow recreational
activities, more stringent effluent limi-
tations are to be imposed. The review and
revision process which will ascertain
whether current water quality standards
provide this protection will take place
between October 18, 1975, and October 18,
1978.
OTHER ENVIRONMENTAL LEGISLATION
Now that I have described the imple-
mentation of the National Pollutant Dis-
charge Elimination System Permit Program,
I would like to discuss other environ-
mental legislation and how it can impact
water pollution control.
19
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Federal Insecticide, Fungicide,
and Rodenticide Act and its
1972 Amendments
This Act provides an excellent exam-
ple of how environmental legislation can
include provisions that protect the en-
vironment from any harmful impact that
may result from its implementation.
Under the FIFRA and its amendments,
pesticide regulation is accomplished
basically through the registration pro-
cess. To obtain registration, a manu-
facturer must submit data to EPA to show
that: (1) the product would be effective
for the intended purpose when used as
directed and (2) label warnings and cau-
tions when followed are adequate to
protect man, livestock, wildlife, and the
environment.
Several sections of this Act provide,
through our regulations, specific require-
ments that prevent harmful impact to the
environment. These are Sections 7, 3(d),
4, 8, and 19.
Section 7 deals with the registration
of establishments and specifies which
establishments must be registered, the
procedure to obtain registration, the
requirement that the registration number
must appear on the label by October 21,
1974, and the report requirements for
registered establishments.
Section 7 was incorporated in the new
pesticides legislation as a result of the
Mississippi River fishkill which illumi-
nated the need for a government agency
to be empowered to require information on
the location of establishments engaged in
pesticides activities. This knowledge,
plus the mandatory identification of the
establishment's registration number on
the label of each pesticide product, en-
ables Agency employees to determine the
producer of the pesticide and the precise
location in which it was produced.
The pesticides production, sales, and
distribution information acquired from
submission of producer reports will pro-
vide the Agency with a national profile
of pesticides activities and will thus
enable it to develop a more effective
enforcement program so as to minimize any
adverse environmental impact that might
arise from misuse of a certain pesticide
chemical.
Section 3(D) "classification" pro-
vides further protection to the environ-
ment. This involves classifying pesti-
cides for general or restricted use. EPA
must clearly define what criteria will be
applied in identifying those products
which may cause an "unreasonable adverse
effect" on the applicator or environment.
Two major drafts have been completed and
distributed to interested parties.
Section 4 "certification". Acute
health effects and localized environmental
effects are largely associated with the
improper handling and use of pesticides by
the individual applicator. Certification
can be a basis for ensuring that pesti-
cide users have sufficient practical
knowledge to protect themselves and others
from acute health effects and to prevent
the most common types of localized
environmental damage. Our proposed regu-
lations require such knowledge for certi-
fication.
Section 8, "maintenance of records".
Our proposed regulations require records
on the disposal or storage of pesticides
and their used packages and containers
and the disposal and storage of excess
amount of pesticides including, without
limiting the foregoing, the method or
methods of disposal, date or dates of
disposal, site or sites of disposal. Also
required are records of any factual infor-
mation regarding any adverse effect on the
environment by any pesticide.
Section 19. "Pesticides and con-
tainers; acceptance, disposal, and
storage". In our proposed regulations we
discuss procedures not recommended for
disposal of pesticides and containers.
One of these disallows water dumping or
ocean dumping, except in conformance with
regulations developed pursuant to the
National Marine Protection, Research, and
Sanctuaries Act of 1972.
In another part of these guidelines,
the effects of subsurface emplacement of
liquid by well injection and the fate of
injection materials is discussed. It
20
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states that "well injection should not be
considered for pesticide disposal unless
all reasonable alternative measures have
been explored and found less satisfactory
in terms of environmental protection."
The Clean Air Act
The implementation of this law pro-
vides us with a specific example of how
compliance with some of its requirements
could potentially cause water pollution
problems. There are two available methods
to meet EPA's S02 (sulfur dioxide) stan-
dards: the use of low-sulfur fuel and
flue gas desulfurization (scrubbers). The
use iof scrubbers produces a sludge waste
which could be disposed in the water. Any
such waste disposal into navigable waters
is, of course, controlled by the 1972
amendments to the FWPCA. However, in this
case the sludge produced is a manageable
problem and can be disposed of properly
either through the use of a lined disposal
pond or a solidification process. In addi-
tion, Judge Tamm, in Essex Chemical Corpo-
ration v. Ruckelshaus, quoted Judge
Leventhal's statement in Portland Cement
that "we cannot imagine that Congress in-
tended that 'best' could apply to a system
which did more damage to water than it
prevented to air" as particularly apropos
in a discussion of the issue of the dis-
posal of sludge produced by scrubbers.
The President, in his message to
Congress when sumitting Reorganization
Plan No. 3, 1970, which created EPA,
described as the primary reason for estab-
lishing EPA the need to interrelate and
coordinate all our anti-pollution efforts
in order to avoid the harmful side effects
some control actions may produce on the
environment. He wanted to ensure that
when a problem arises such as the potential
water pollution of the wastes produced by
the scrubbers, there would be sufficient
coordination within one organization to
prevent this potential from becoming an
actual problem.
The Drinking Water Act and
the Ocean Dumping Act
Not all environmental legislation has
mandates which if mismanaged can poten-
tially cause a negative impact on some
other area of the environment. The pro-
posed Drinking Water Act, for example,
would actually expand our current water
authorities. The House version of the Safe
Drinking Water Act of 1973 provides for a
comprehensive state underground injection
control program and provisions for a stand-
by chlorine allocation program for drinking
water and wastewater treatment. All three
versions of the bill, the Senate version,
the House version, and the Administration's
version provide for more Federal super-
vision and control of drinking water than
there has ever been in the past.
The Federal Marine Protection, Re-
search, and Sanctuaries Act, better known
as the Ocean Dumping Act, is another law
that expands our authorities to control
water pollution. The law generally pro-
hibits dumping material into the terri-
torial sea or the contiguous zone of the
United States without a Federal permit. In
addition, a person, regardless of his
nationality, may not depart a United States
port with material intended for dumping
anywhere in the world's oceans unless he
has first obtained a Federal permit to do
so. High-level radioactive wastes and
radiological, biological, and chemical
warfare agents may not be dumped or
transported for dumping by persons subject
to the first two provisions I just
mentioned. As of last week, fifty-five
ocean dumping permits had been issued, and
four enforcement actions had been taken.
21
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THE ROLE OF DOMESTIC COUNCIL AT THE WHITE HOUSE
Norman E. Ross, Jr.
Domestic Council
Room 218, OEOB
Washington, D. C. 20016
The Domestic Council in the minds of many may be unclear as to its official duties,
but this body of men is important as behind the scene brokers who get to the President
and help him formulate his domestic policies. How policy is made and how legislation
is acquired or vetoed is an intricate task, and one that takes time, knowledge, and an
understanding of all facets of the immediate matter. This process is explained as Mr.
Norman Ross sees it from his view point as Associate Director of the Domestic Council.
I'd just like to tell you how we go
about making policy or go about not making
policy with respect to various pieces of
legislation and legislative initiatives. I'd
like to familiarize you with the structure
of the Domestic Council as it appears in a
recent issue of the Nations Business. "We
are behind the scenes brokers, the little
known, low key guys that get to the
President and help him in the formulation
of his domestic policies." Now the actual
Council itself, the Domestic Council,
consists of the President, Vice-President,
the various Cabinet officers with the ex-
ception of the Secretary of State and the
Secretary of Defense. These two Secre-
taries serve on the National Security
Council. Also serving on the Domestic
Council is the Director of the Office of
Management and Budget, Administrator of
the Veterans Administration and the
Administrator of the Environmental Pro-
tection Agency. This group has a staff
currently consisting of 13 professionals
and it is these professionals that have the
responsibility of looking at the various
initiatives that are raised throughout the
Federal Government involving domestic
programs and putting them together in a
coherent way to be presented to the
President, to the Congress, or to the
general public. Now, we receive input
for the development of these initiatives
or these recommendations that go to the
President via the cabinet officers and we
operate on a system in which the Cabinet
officers actually run the show. In order
for these Cabinet officers to do this we
have established a number of Domestic
Council committees in various sub-
stantive areas. One that you are pro-
bably familiar with in the area of natural
resources, environment, is chaired by the
Secretary of the Interior, Roger Morton,
and it's co-charied by the Secretary of
Agriculture, Earl Butz. Sitting on this
committee are those agency heads that
have programs in the natural resources
and environment areas. The Admini-
strator of the Environmental Protection
Agency, Secretary Dent of Commerce,
NOAA being in that particular group. The
Secretary of Army, Corps of Engineers,
also is included as well as the Chairman
of the Council on Environmental Quality,
Russ Peterson. Then we have various
smaller groups that look at individual
problem areas. For example, in the
development of the administrations
position on the Clean Air Act, just what
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amendments should we, in fact, think
about, if amendments are, in fact, in
order. It's a very basic question and
questions like this we give to these
committees to do the necessary technical
work on. To do the necessary leg work to
make recommendations to the chairman
and then the chairman make recommend-
ations to the President. Now what are
some of the things that we look at?
There is the general structure and these
committees are generally chaired by the
various assistant secretaries that have
responsibilities or administrators in that
particular area. The one on air quality
that I just mentioned is chaired by, when
he was here, Bob Samsom; now chaired
by Roger Strelow in EPA. We have others
on world food policy; we are looking at the
critical commodity shortages, water re-
sources and we are thinking about forming
a new one on climate with the National
Science Foundation, and in the Department
of Commerce, the National Oceananic and
Atmospheric Administration. So this is
the structure by which we go about our day-
to-day work.
Now what are some of the things that we
look at when we are attempting to decide
on the posture or direction to take in the
formulation of national legislation? One
of the first things we look at, is existing
legislation that either may mimic that or
legislation that has expired and we'll look
at what do we want to do that's different, if
anything. For example, in the Congress of
this session, we are looking at legislation
on reverse commodities. I'll use this as
an example. In this particular case we
are looking at the renewal of legislation
dealing with sugar, for example. Now, the
Farm Bill of 1973 laid a new policy direct-
ion for dealing with all agricultural pro-
grams. That is, we are now moving
toward a free market system. In other
words we are going to get the government
out of the business, a very basic kind of
an approach. The President had some
problems with the farm bill, administrat-
ion signed it however and we are working
with what we have. Now, it's time for us
to look at the other commodities which
were not in fact included under that very
broad mandate.
Sugar is an example so we look at the
question and then at the time we have to
recommend legislation. Congress has
asked us for our point of view so we ask
ourselves some very basic questions.
What problems did we have with the old
legislation? Well, one, it's old and there-
fore it's not consistent with what we've
done all along. These are the kinds of
problems. We don't have the free market
dictating a price for example. We have
problems with that. They talk with Cuba.
We have problems with employment looking
at where sugar is in fact marketed here in
the United States what is, in fact, wrong.
So we ask ourselves not only what we've
done before but we also ask ourselves and
force ourselves to look at the current
economic situation with respect to sugar.
The price of sugar is very high as you well
know on the domestic market and the world
market. So we ask ourselves the economic
questions that relate to any piece of leg-
islation. Then we ask ourselves a very
difficult question. The question that is
often very elusive these days is that of
the political ramifications of the process
and in this political ramification we like to
think that we use a very systematic way.
We like to think that we do research and
we really use it. We look at who is
going to raise opposition to it and that's a
research project. Then we go to the
various departments, in this case the
Department of Agriculture, and say who
would you think would vote for that part-
icular bill, who would not vote for that
particular bill and what impact would this
have on whether or not we'll get it, what
impact would this now go on any variations
there may be because we were given a
position.
Now in this particular bill, the Sugar Bill,
there were a number of recommendations
for having sugar be treated like every
other commodity and make it inclusive
23
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under the philosophy of the free market
approach but then we thought about those
sudden Democrats that this means a lot to,
we thought about the difficulties of actually
pushing a bill through this year and so put
all this in a little hopper and we came up
with the answer that it's best not to change
sugar legislation this year.
We do the same thing on environmental
legislation. We do the same thing on any
piece of legislation. We do the same
thing on any piece of legislation that we,
in fact, look at and almost always there is
not unanimity with respect to a given re-
commendation. Verse, agency has verse
secretaries who will vote depending upon
(1) the person's feelings, (2) the bureau-
cracies, and (3) they just don't really
understand the case. And we did the same
thing or this kind of thing year before last
when we were looking at the course to take
with respect to solid waste. Whether or
not we'd let the act expire, •whether or not
we would revise the act, whether or not we
would put anything up in place of it. We've
just completed the same kind of internal
process with respect to amendments to
legislation, the need for them. The Clean
Air Act, for example. How we went about
formulating our national policy with re-
spect to the Clean Air Act. This is a more
difficult thing to do primarily because of
the track record the administration has had
with respect to the environment. Now the
environmental movement came about in
'69 and '70 and '71 we were really going
full steam ahead. We have some very basic
pieces of legislation during the current
Administration, there were some 20 bills
introduced to do various kinds of things
with respect to improving the environment
from purely grant research, the estab-
lishment of various agencies through
Executive Orders or through Acts of
Congress, cleaning up our air and our
water, pesticides, noise, and you name it.
So it was very difficult to do this because
the first thing that we hear in looking at
various positions to take with respect to
legislation is that of the public, the public
apathy and that's another very important
role in any kind of national policy--just
how the public is going to feel.
The question is asked, how will the public
take this ? and those that have been
interested all along in clean air and clean
water will look at this if we were to change
as an affront, as an attack. We have lost
our credibility with respect to the envir-
onmentalists and we are backing away from
our historical positions, and that is not the
thing to do. So then what can you use to
balance that, recognizing that there is a
problem? Then we look at the problem
itself. It just so happens that during the
last two quarters we were in a pinch for
various kinds of petroleum products; oil
embargoes or lack of refineries or for
whatever reason, we just didn't have enough
fuel and there were long lines, so the phrase
was coined right along that we are exper-
iencing an energy shortage and therefore
we should do something about it. The
general public initially didn't have this
feeling so we didn't take any action on it.
We recognize that as a problem, we want to
negotiate with the oil-producing nations and
we are going to see about using that
approach as a method of solving the problem.
It didn't quite work. We were able to get
some relief from the lack of shipment of
oil but it wasn't enough. So then we de-
cided on what other alternatives couK in
fact, be used. Before going the legislative
route we will try using what we refer to as
our jawboning strategy. First, we are
going to go out and we're going to tell the
general public that you are really going to
have to turn down your thermostat, you are
going to have to wear a sweater or you're
going to have to car pool. We '11 have to
convince the general public that conser-
vation efforts are important and they are in
fact, necessary. Secondly, we are going
to have to work on the industries. The
public must tell the industry that they are
going to have to do their part. Recog-
nizing that this is a capitalistic society,
that's a basic problem. That s a very
24
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difficult kind of thing but nevertheless
this is a part of our strategy, our jaw-
boning strategy before going the legislative
route. We tried those things and now we
have an assessment period in which we
look at just how effective they have, in
fact, been and based upon that assess-
ment in this particular case, we were able
to convince ourselves that the strategies
used heretofore are not as effective as we
needed them to be.
So what else is available to us? We listen
to what the industry is saying, and they
say that the reason for the current problems
that we are having with respect to energy
center primarily around the unrealistic,
the very very rigorous environmental
controls that have been layed upon us.
Well we ask the question, "Well, how do
you arrive at this conclusion?" (1) The
technology has not been demonstrated, the
technology is not in place for us to do all
these kinds of things that the current laws
mandate. That is, we don't have those
black boxes that we can tag on the end of
our smoke stacks to clean up all of the
particulates and the sulfur oxides and the
other polluntants that are eminated there-
from. We don't have the technology without
going out of business to plug something on
the end of pipe to prevent the discharge of
deletery substances into the water, for
example. You are going to just run us out
of business so we listen. Then we ask the
legislature, the governors. The governors
are very syspathetic to the point of
industry and to their constituencies. They
say we've really got to do something about
these clean air laws, these water laws or
the environmental laws because they are
just not workable and we need more
flexibility, we need more variances. I
can't afford for you to close down Los
Angeles because of the presence of nitro-
gen oxide, smog or other harmful
polluntants. I'm not convinced as a
governor that the technology exists for me
to tag on a converter to my car and I never
want to tag on a converter to my car to
clean this up and it's just too much of a
problem so you' ve got to do something
about this Federal government because
you are the only one that's smart enough to
do this. We tell them, "Write to your
Congressman". We go back to the drawing
board and we put all this together and we
come to the conclusion that we've got to do
more. We've tried to jawbone, we've tired
to look at this administratively, we've
talked to the governors, we passed our
support, we've tried to turn a switch on at
some times, turn a switch off at other times
to help with these problems and it just
hasn't worked. What are we going to do?
Well, maybe the only thing to do is, in fact
make new legislation or to amend the leg-
islation that is currently in existence and
boy, when you come to that point then you
really, are committed.
The administration will amend the Clean
Air Act then it's on the front pages. Then
the Congress in also attempting to address
the problem and they will amend the Clean
Air Act or they will amend various other
pieces of legislation for political reasons or
for reasons of recognizing that a problem
exists so that's the case in which they beat
us to the punch and they have amended the
law, the Clean Air Act. So we've got them
interested in the Clean Air Act and then the
legislation is sent to the President. We
really want them, boy, this is really great.
However, we really want some other things
too. By the way, since you are thinking
about helping us out, we want a new bureau-
cracy to help manage this broad problem of
how to go about being independent with
respect to our energy needs by 1980.
Congress sends down a bill to the President
that has all this in it and we look at it and
say, yes there is the Clean Air Act amend-
ment. Did we want it? No, we didn't really
want that one, here is the agency that we
really want, wait there's a problem here,
it's against my basic philosophy of rolling
back prices for oil, I just can't sign that,
you see. So then you say. Well, please
Mr. President, you know we've got all
these other things in there, all these other
goodies. Well, we really can't -- cross
that out. So we veto the legislation so
25
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so we're right back at the start again. So
we go up again and say, guys, you really
did a good job but those windfall profits
you've got to take out of there and then we
have all these other nice things, and by the
way since you are doing it, what about
those bills on reclamation that will all
help with this overall problem? Most
national legislation is so broad in scope
that it cannot really be compartmentalized,
even if you look at health insurance or man
power or housing, the issues are inter-
related and sometimes closely knit.
So in looking at legislation, we look at the
remifications each individual piece will
have on the whole system and we try that
approach. We try to come up with what we
refer to as a comprehensive piece of
legislation to solve our needs and we try
that. We push that and we see what
happens. In many cases such as in the
Clean Air Act because of the technical
problems here, we've had some very basic
technical problems that we can't just
stand up on a soap box and cite unequivoc-
ally that we have the answers to it. For
example, in the area of controlled
technology for the sulfur oxides. We just
can't say unequivocally that the technology
has been demonstrated and is in place to do
these kinds of things, therefore you don't
need some leeway. We cannot say that
technology is in fact in place so that we
can, in fact, meet the auto emission
standards. We need more time. We need
more flexibility and the pieces so we try the
comprehensive approach to take care of
all these problems at one time. In many
cases it works and in other cases we fail
and this is one case in which we actually
failed to get a handle on the Clean Air Act
separately and there are still many bills
up on the hill that will address this and
related problems, but they are not such
that we can really say, boy these are the
ones we want and these are the ones we
don't want.
Now we are going to be doing the same
thing with respect to the amendment to
the 1972 Water Pollution Control Law.
We've got some very basic national policy
decisions to be made. Some of these
decisions are going to be forced on us by
external means. For example, the
Supreme Court has recently agreed to hear
a case with respect to the so-called im-
poundment of money for waste water treat-
ment facilities. The court will hear the
case from the court circuit and the case
from the New York, Ruckelshaus versus
the defendent, the environment. So we are
now asking ourselves the question, why
does he have to spend all that money and
what will it do to the economy? I might
not do anything. We look at our track
record, we look at the money that has al-
ready beenaithorized and ask the additional
question, how much of that has been
allocated and we see only a third of it out of
a total of $1. 6 billion that has been actually
obligated so maybe the program itself can
handle the outflow or the budget guide, the
outlay. How much money and how fast it's
going to be spent or drained from the
treasury.
The next question we've got to ask ourselves
is what are we going to do next with respect
to water legislation? The need survey
completed by the Environmental Protection
Agency recently illustrates that there's
just no way that we can do all that's needed -
within the allowable time of the existing
piece of law, that we have to address that
issue. What do we do next, do we amend
it to allow sufficient time, do we amend it,
spend the $9 billion that we haven't spent if
we win the court case? What other kinds of
things do we want to do different ? Do we
have enough flexibility in our effluent
guidelines, for example. The industries are
saying this will run us out of business. Then
we have in another corner a study that's
being made to see if we can in fact meet the
1980 goals of zero discharge and see what
the economics will be, see what the social
implications will be. See what policy
implications will be for new legislation,
continuing legislation to amend it. Just
to say forget about it is just impossible.
Well all these kinds of things are going on
and someplace in the universe before the
26
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the 1975 budget, all this is going to come
together and we are going to look at what
we are going to have to print in the budget
for 1976 and hopefully by then we'll have a
handle on the effluent discharges, and what
we can do.
We need to have signal from Mr.
Rockefellow on how he is coming up to
make any recommendations on meetings
the standards, meeting the requirements
of the existing laws. We need a chance
to go out and jawbone with the government
to see how well they are doing with basic
planning. We'll talk to the researchers to
see, if they have solved the problems of
surface water contamination. We ask,
have you looked at the difficult problems
of solving the norpoint sources of pollution?
Just where do we stand? Do we need more
money for this ? Do we need more time
for that? Is this going to affect the
accomplishment of the goals that have
been layed out already in the statutes or
can we just forget about it? We ask
agencies to do this, we ask consultants to
do this. We go around to the various
associations; the governors, the mayors,
the counties and ask the questions. Not
the question of funding because we always
get the same answer so we stop asking, do
you have enough money, how are you
coming with building sewage, this kind of
thing. No, there's not enough money,
we'll never have enough but we ask our-
selves the question, is the water getting
cleaner and we've really been surprised.
Last year we asked that question on a
national survey and the answer was, no,
the water is getting dirty, we need more
money. We have now stopped asking that
question, but those are the kinds of
questions that we are asking ourselves now.
The tempo is going to pick up and we have
a very important part to be made on this
piece of legislation for the 1976 budget,
how much money we are going to spend in
it ? Really now is the time to think and
talk about amendments to it, whether or
not we are going to extend the act, what
the Congress is going to do. If we do
nothing we'll probably get it anyway.
Are we going to take the initiative, what
form and under what conditions ? So
those are the kinds of things that we look
at, hopefully in a coherent kind of way,
and looking at the directions to take,
the decisions to be made with respect to
the development of national legislation.
Thank you.
27
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CONGRESSIONAL OUTLOOK ON ENVIRONMENTAL CONTROL LEGISLATION
G. E. Wood
Committee on Public Works
U.S. House Of Representatives
2165 Raybum House Office Building
Washington, D. C. 20515
ABSTRACT
This paper on the congressional outlook for environmental legislation was prepared
from a transcript of a presentation made by the writer from notes at the Environmental
Resources Conference On Pollution Control Technology Assessment. The paper is intended
to review possible environmental control legislation in the areas of water, air, solid
waste and radiation pollution. Particular attention is given to the immediate legislative
outlook on water pollution control. The review of the legislative outlook on water
pollution control is based upon a review of experience to date in the implementation of
the 1972 Amendments to the Federal Water Pollution Control Act.
I always enjoy the opportunity to
participate in meetings of this type. It
is a privilege. It also serves a most use-
ful purpose for members of the Committee
staff to meet with professionals like your-
selves to discuss environmental control
legislation.
As you know, I do serve as one of the
counsels on the Committee on Public Works
of the House of Representatives. The
Committee has jurisdiction in the House of
Representatives over the Federal Water
Pollution Control program. However,
because of the division of jurisdiction
in the House of Representatives, Public
Works does not have jurisdiction as the
Senate Public Works Committee does over
air, solid wastes, noise, and radiation.
This means, and I hope everyone under-
stands what I'm saying, that I'm making
somewhat of a disclaimer of special
expertise on air, solid waste, noise and
radiation. However, I will address these
areas as well as water pollution.
This is necessary because there has
been in the past a leapfrogging of legis-
lation from the air bill, to the water
bill, to the air bill, and back to the
water bill. Each time it gets a little
bit bigger with a few more golden nuggets
in it for everyone, There has not been
the type of coordination in my opinion
between the environmental areas that there
should be.
You know, in discussing the water bill,
I've used a little anecdote in the past.
I would like to review it with you here
today. This concerns a plumber (and of
course plumbers are in the news recently
anyhow). The water pollution law and the
resultant regulations are most complex
and difficult to understand. Many areas
of the government are burdened with similar
problems. There was a plumber who wrote
the Bureau of Standards that he used and
found hydrochloric acid excellent for
cleaning out clogged drains and wanted to
know if this was safe to do. Well, the
Bureau of Standards wrote back. They
have bureaucrats there just like myself
and other staff members in the Congress.
They stated "Our studies and research
reveal that the efficacy of hydrochloric
acid for the purpose stated in your letter
is without question, however, the use of
28
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it results in a corrosive residue which
is incompatible with metallic permanence."
This was to a plumber.
The plumber read this and interpreted
it. He wrote back "I'm glad to hear that
you think that my idea's a good one and you
go along with it." The Bureau wrote to him
again stating, "We must point out to you
without qualification that we can under
no circumstances assume responsibility
for the resulting toxic and noxious resi-
dues from the employment of hydrochloric
acid in plumbing uses to which you have
put it. We must strongly urge that you
resort to alternative procedures that
will not have the deleterious consequences
we alluded to in our earlier communica-
tion." Well our friend the plumber
received this with joy. He read it and
said boy that's a lot of big words and
that's great. He wrote back one more time
and said "Thank you very much for agree-
ing with my recommendation. I really
appreciate it." The Bureau finally got
smart and wrote him a letter saying
"Stop using hydrochloric acid. It eats
the hell out of the pipes."
Well, the plumber finally got the
message. This is one of the problems
that we have with the water pollution law.
It is extremely complex and extremely
difficult to understand. EPA hasn't
always followed congressional intent.
Also, even some of us who would like to
think we are familiar with the law are
having one terrific job with the regula-
tions. There are a lot of i's that have
to be dotted and in some respect I have
been a little critical of EPA.
Not so much on the House side but
certainly on the Senate side, every time
EPA turns around and does something which
doesn't have all the i's dotted, there
is a request for GAO to come in and inves-
tigate. This has happened, I don't know
how many times so far, several for sure.
It's been threatened more. That hasn't
helped the program.
You know we were talking about
plumbers, here just a minute ago. There's
one more little story I'd like to tell
you about plumbers. There was a lawyer
who had one heck of a problem with a drain
pipe and he called in a plumber. The
plumber came and he worked on it for one
hour. The lawyer asked well what's the
tariff, how much is it going to cost me?
The plumber replied cooly, $50. The lawyer
exclaimed, $50! Incredible, I've been to
school for nine years and I only make
$30 an hour! The plumber looked at him
and said "I know, I only made $30 an hour
when I was an attorney."
So this is a good time for most plumb-
ers. Everywhere but Washington, that is.
I know in downtown Washington there are
a lot of plumbers running around unemployed
right now. At least three of them were
attorneys and there was a public relations
man in the group too.
But all that aside and back to the
matters before us, there is one most impor-
tant piece of environmental legislation
currently going through the Congress. It
doesn't fall under the guise of environment-
al legislation but rather it's called
House Resolution 988 which would reform
the structure, jurisdiction, and procedures
of the House of Representatives by amending
the rules of the House of Representatives.
H. Res. 988 would establish a new committee
on energy and environment which would have
legislative jurisdiction over energy and
energy resources, the environment, including
environmental policy, land-use planning,
coastal zones, air and water quality, noise
control, ocean dumping, and disposition
of solid waste and conservation of resour-
ces. It would have jurisdiction over all
water, including research and development
but not water resource development, naviga-
tion and dams, etc. It would include
irrigation, reclamation, and possibly deep-
water ports. The Committee would have juris-
diction over public lands, parks and recrea-
tion, and wildlife.
As you can see, as far as the environ-
ment is concerned, the Committee on Public
Works now has jurisdiction over water
pollution, Interstate and Foreign Commerce
has air, noise and solid waste. Interior
has land use. Different committees have
different jurisdictions. Because that
creates legislative problems in the
Congress and because it detracts from the
quality of legislation this proposed legis-
lation could have far-reaching impacts. The
fragmentation that currently exists in the
Congress and the House would be eliminated
29
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and it would be possible for the environ-
ment committee to develop comprehensive
and lasting expertise in the area. Right
now we can't do that. It's just impossible.
OK. So I'm an attorney and I'm an
engineer and I've spent a lot of time on
water pollution. However, for the last
six months I've spent most of my time on
water resource work, disaster relief,
deepwater ports, and various other assor-
ted things, not water pollution.
You all are the professionals. Most
of you spend 100 percent of your time work-
ing on water pollution control. In Congress
the staff who helped the members write
the water pollution legislation, once the
bill is passed, has to turn to other
things, thereby losing continuity.
I think the change in the organiza-
tion of the House could have very impor-
tant, very far-reaching, and very benefic-
ial results. The attorneys and technicians
available to the Congress would be able to
use their water pollution background or
air pollution background in other environ-
mental areas and vice versa. There would
be a greater recognition of the fact that
you can't have water pollution legislation
without considering air pollution, solid
waste disposal, noise, etc. The quality
of the work product might be improved
substantially. But in any event, it's a
good proposal supported by members of our
Committee. I hope all of you would support
it.
Now, let's talk about the 1972 Amend-
ments to the Water Pollution Control Act.
When the committee was working on the
amendments, it was felt by all involved
in their development that they were a sig-
nificant advance in the field of water poll-
ution control. Further, it was felt the
conference report that the House and Senate
worked out together was superior to the
bills that were put out by either the House
or Senate. The bill was complex and there
were problems but in general it was pretty
well supported.
As you know, good judgment is the fruit
of experience and experience as often as
not is rooted in bad judgment and in the
past perhaps in some of the water pollution
control programs there was some bad judg-
ment. Perhaps there may have been some
bad judgment in the development of the
existing 1972 Amendments. That was a time
of very strong environmental pressures.
The Congress is reviewing the law and is
working on it right now. We have held
hearings. They are expected to resume.
The Water Pollution Law, when it was
passed, was based upon four cornerstones
and one keystone. Somewhere along the path
of implementation perhaps a couple of those
were misplaced. The cornerstones were
comprehensive planning and much of that has
gone by the wayside; adequate financing
and we just heard some comments on that;
research and development for the future,
that's probably in pretty good shape; and
a workable law competently administered by
EPA. The law was extremely complex, EPA has
had some real growing pains in implementing
it so some of the cornerstones are a little
bit shaky.
The keystone to this new legislation
was even more important and that was
the combination of cooperation between the
Federal agencies and the state and local
governments. I wish I could stand here
today and say that I was completely convinc-
ed that the keystone was solidly in place
and was holding the program together rather
than sometimes working as a millstone.
There has been an awful lot of consternation
between the states and EPA as to who's doing
what and to whom. We worked hard on this
legislation and one thing that we really
spent a lot of time onwas to try to get the
permit program out to the states. Now we
had some conversations this morning that
so far permit programs have been approved
for only 9 or 10 states. There are reasons
for part of this and these reasons are the
complexity of the regulations piled on top
of the number of regulations that the law
requires. Let me emphasize, one thing Con-
gress really wanted was to get the confoun-
ded permit program out to the states, because
that's the place where there was some hope
of having the number of people available to
do the job. So far, a year and a half later,
there are only 10 states that are currently
qualified.
The states must be allowed to partici-
pate and contribute. They need Federal
support and encouragement. They aren't
getting enough. We heard OMB a month or two
back state they were thinking about cutting
out program grants for the states. Well,
on the one hand, the law says, "states, herte
a big job to do, run with the ball." On
the other hand, we have somebody saying,
30
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"no-no, can't have all the money". Some
of the states are coming back in and say-
ing, as I saw in a recent letter from
Governor Tribbitt of Delaware to Russell
Train, "clarify this for us if you will
because we are considering forgetting state
participation." Now, they have not dropped
it and EPA has clarified the situation,
but the State of Delaware for one was ready
to back out and say, "Manage the damn prog-
ram, we don't want it if you aren't going
to help us pay for it." Well, part of that
has been squared away but it's this kind
of a constant consternation between the
states and EPA or OMB that creates pro-
blems.
Now, what's going to happen as far as
environmental control legislation is con-
cerned in the next few months, next year.
The Congress is sort of playing a little
bit of a game right now with the adminis-
tration. The age of the environment is
in full swing but the pendulum is on its
way back just a little bit. However, the
Congress is reluctant, I think, to say,
let's make some changes to ease up on
environmental legislation. The Adminis-
tration also is reluctant to say, let's
ease up on environmental legislation.
In the water area, there are some
amendments which may be necessary. We
heard a few minutes ago about what's going
to happen in municipalities in 1977 when
the money's not available and they haven't
done the job. Well, what's going to happen
to industries on December 31, 1974, when
they don't all have permits and are
subject to citizen suits and 309 actions
and everything else.
Congress is going to have to take
some steps. Our Committee has asked EPA
in recent hearings to make their recommenda-
tions on legislation. EPA is supposedly
diligently working on these recommendations.
It remains to be seen who will speak first,
but somebody has to do something rather
quick.
The law requires municipalities to
have secondary treatment installed by
July 1, 1973. When we were working on
the 1972 Amendments we put in $5, $6, and
$7 billion for three fiscal years for
treatment works construction. At that
time, the Congress was being sorely cri-
ticized by the Executive for putting in
exorbitant numbers which were unreal
because their studies said $14 billion
was all that was needed. Two years later
the next estimate came out, $60 billion.
In September there will be a new estimate
which I predict will be $100 billion. In
February there'll be another estimate
which may be higher than that.
We have a massive, massive, massive
program,a lot of which revolves around
nonpoint sources and combined sewers
which are eorbitantly expensive. Nobody
really has a real good idea of what to do
about them right now. The money will not
be available to provide 75 percent grants
to all municipalities to do the job in
1977.' If the money were available, the
job wouldn't be done by 1977, anyhow
because there are plants under construction
right now that are going to take 5, 6, 7
years, perhaps, before they can be constructed
Congress is going to have to do some-
thing about this problem. Wiether it will
be a moving back of the 1977 date for
municipalities, whether it will be a giving
to EPA discretion to waive that requirement
for certain plants, or what form it would
take I'm not prepared to say right now
because I frankly don't know. I'm not
sure what recommendations EPA will make.
I suspect, however, it may be along the
line of giving EPA some discretion.
What's going to happen on July 31,
1977, as far as industry is concerned?
Again, I can't make a prediction but you've
got to recognize that section 315 establish-
ed the National Commission on Water Quality,
which is chaired by Governor Rockefeller
and which includes as its members Senator
Maskie, Senator Howard Baker of Tennessee,
Congressman Bob Jones of Alabama, Congress-
man Bill Harsha of Ohio. This Commission
has the job of evaluating the impacts of
meeting or not meeting the 1983 require-
ments for best available technology. This
is not no-discharge; that's not part of
1983 per se. No-discharge is a 1985 goal
which isn't mandated anywhere in the law.
A lot of people have some misconceptions
on that. It's not mandated anywhere. It's
a focal point for planning; it's a focal
point for research and development.
Let me be critical of EPA for a minute.
I think EPA in the development of regula-
tions has gotten carried away with what
the Congress may have intended with regard
31
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to no discharge. We see a lot of regula-
tions being promulgated with no-discharge
as their basis. No-discharge, if it's
practicable, if it's economic, if the eco-
nomic, social, and environmental aspects
can be met, is fine. Some sort of a bal-
ancing test was intended. But no-dischar-
ge by 1985 is a goal, a focal point for
research and development. It is not a
requirement. There are no words in that
law anywhere that require no-discharge,
in 1983, '77, '85 or any other year. EPA,
as I say, has gotten carried away on that.
However, as far as industry is concerned,
I don't believe there will be significant
changes in the law until such time as
Governor Rockefeller's commission makes
its recommendations with regard to 1983.
The President is required by December
31, 1974, to allocate the treatment works
Construction grant funds for fiscal year
1976. That means that Congress sometime
this year, probably around September, is
going to have to decide what level of
authorizations will be available for treat-
ment works construction over the next 1,
2, or 3 fiscal years. At that time we will
probably have in hand, as I said before,
a study demonstrating needs somewhere
in the range of $100 billion. We will also
have in hand a law which requires certain
things to be done by 1977 and 1983.
The Congress is also faced with infla-
tion, a deficit budget, and competing de-
mands for the tax dollar. It's hard to
say whatis going to happen. It may not be
realistic to expect too much in the way
of expansion of the dollars for that
program.
Another major issue that I think the
Congress will address, perhaps this summer,
is, what is secondary treatment for muni-
cipalities? Whether the Congress will
do anything about it remains to be seen.
It is a very very important issue. Secon-
dary treatment, again, is required by 1977.
The definition for secondary treatment was
promulgated by EPA. It is completely law-
ful and is not inconsistent with the intent
of Congress. It is questioned, however,
whether the definition should be the same
for all parts of the country. Congressman
Johnson of California recognized this when
the bill was before the House and put a
statement in the record which was not suff-
icient in the face of the legislative
language to provide flexibility. Look at
places like Puerto Rico, Hawaii, or the
Northern Pacific Coast, or Alaska where
there is deep water or fast currents. Per-
haps it's not reasonable at a time where
dollars are limited to require a plant
in Puerto Rico where there can be deep
ocean outfalls, or a plant in Seattle, or
a plant wherever it might happen to be to
have secondary treatment when effluents
are discharged into deep salt water. I
don't know the best answer, but this is
an issue the Congress may address.
There is another problem the committee
may review. It was clearly intended to
provide an incentive for industry to parti-
cipate in municipal treatment works.
There are, in fact, a number of incentives
in the law to encourage industry to partici-
pate in municipal treatment works. Now, we
hear varied arguments from different people
saying the law itself is keeping industry
from participating in municipal treatment
works.
Probably, in June or July, the Investi-
gation and Review Subcommittee of the Public
Works Committee, will hold a series of
oversight hearings on the impact
of Public Law 92-500 on industry. We
held a series of hearings on the impact on
municipalities and the municipal ororram.
The hearings will help inform the committee
on how the law is being implemented. Also,
they would be intended to help EPA have a
better understanding of the committee's
intent. In some areas, the intent isn't
necessarily being realized.
Congress at some time is going to have
to take a good look at subsurface disposal.
Congress is going to have to take a good
look at nonpoint sources. As far as Public
Law 92-500 is concerned, most of the focus
on nonpoint sources was for added research
and development rather than controls.
Congress may take a good look in the next
couple of years at water quality standards
and their impact. Another area i* drinking
water supply which Congress is looking at
right now. Congress will be busy in
water pollution control in the next few
years.
Turning now to air pollution,we see
similar problems. In view of the sluggish-
ness with which air pollution control was
being tackled across the country, Congress
attacked the national effort to clean the
air from two direction^ in 1970.
32
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Reaffirming its intent to lower the
pollutant level so that it has no adverse
effect on man and his environment,Congress,
in the first section of the Act directed
EPA to set limits on the total amounts of
six major pollutants that could be present
in the air at any given time. In the
second section, it ordered automobile
emissions rolled back 90 percent from 1970
levels.
These directives were accompanied by
tightened time limits and with a compre-
hensive schedule which regulates the imple-
mentation and enforcement of ambient air
quality standards by the individual States.
In doing so, public health and welfare ra-
ther than cost and other economic and
social criteria remained paramount consider-
ations. While levels of atmospheric contam-
ination could vary with individual air
quality control regions, they could not
drop below the ambient standard. Emission
standards for new sources by individual
pollutant, special national standards
for contaminants designated as hazardous,
and the opportunity for citizens to sue
sources and government agencies for non-
compliance with the provisions of the Act
were to provide added impetus for accelera-
ted efforts to clean up the Nation's air
and decrease further contamination.
Petitions to delay implementation,
oversight hearings and court cases in the
past three years have given a good indica-
tion of the areas for which amendments woUcf
be sought. Four areas in particular were
singled out for dispute: ambient air
quality; pollutant levels set by the
standards; availability of control tech-
nology; and costs vs. benefits.
Mandatory maintenance of existing
clean air levels, notwithstanding limits
set by the ambient air standards, was
tested and upheld in the courts in non-
degradation suits. These decisions were
based on the congressional intent of
"enhancement" expressed in the Act.
However, the split vote by the Supreme
Court to uphold this decision which had
been rendered by a lower court indicated
that further clarification of this point
by law may be necessary.
Disputes involving pollutant levels
allowed by the ambient air quality stan-
dards, as well as emissions of individual
pollutants permitted by the automobile
standards and the new source regulations
pointed up the uncertainties surrounding
data indicating current and projected
damage to public health and welfare. The
issue of needlessly strict limitations
was raised by polluters as well as by
citizens and Members, and bills introduced
to weaken the requirements on the grounds
of insufficient evidence that current stan-
dards were necessary testify to the eager-
ness with which a study on health effects of
air pollution, requested by the National
Academy of Sciences by the Senate Public
Works Committee, is anticipated.
When requesting a delay in standard
enforcement, polluters have continuously
and consistently cited the unavailability
of adequate cost-effective control tech-
nology. Auto manufacturers have obtained
a reprieve, possibly until 1978, with these
arguments. Industrial sources and power
plants, whether or not they were converting
to coal due to the energy crunch, have
been granted variances and delays on the
same grounds. The drive to permit the use
of tall stacks and intermittent control
systems which disperse, rather than dec-
rease, the pollutant load in the ambient
air, is based on the same argument, despite
the law's statement that emissions must
be limited at the source.
The matter of abatement costs, their
scope emphasized in EPA and other govern-
mental estimates as well as by projections
furnished by industrial polluters and by
municipalities facing considerable changes
when implementing existing regulations,
has become a major issue. No reliable data
of potential benefits of the expensive
abatement procedures have come to light.
Costs to the national economy and to the
lifestyle of U.S. citizens if air pollution
remained largely unabated were not presented
in a convincing manner. These doubts were
expressed in proposed legislation, in over-
sight hearings, and even in less than force-
ful action bv EPA when confronted with
violations of the law's provisions.
As the Act approaches its expiration
date, it is becoming apparent that the
issues mentioned will be expressed in
amendments proposed in the Congress as
well as by the Administration. Bills
concerned with delays pending better and
less expensive control technology, the
waiver of standards until non-polluting
fuels again are plentiful, mandatory
33
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consideration of costs involved, the pro-
hibition of drastic control measures such
as transportation control plans, and legal-
ization of pollution dispersal methods
are already on the books. Administration
proposals include, in addition, delays
in those State clean air plans found to
have regulations which are more stringent
than necessary to meet primary standards;
replacement of emission or performance
standards by design or equipment standards,
i.e. Federal preemption to waive regula-
tions of new sources in order to demon-
strate new, equally effective, and cheaper
control technology; temporary waiver of
requirements to permit the use of coal
by industry and power plants; and a hands-
off Federal policy in matters of significa-
nt deterioration in areas with high air
quality (although State and local govern-
ments could set standards preventing
deterioration if they wanted to do so.)
The study on health effects of air
pollution by the National Academy of
Sciences, and a second report on costs and
benefits should be ready in early fall,
and will hopefully, clarify at least to
some extent whether there is continued
justification to base national clean air
legislation primarily, and almost
exclusively on public health and welfare
considerations. The reports may also help
to determine whether the law should con-
tinue to include requirements which are
beyond present attainment, as an incen-
tive to cause air pollution control to
move forward.
Solid waste legislation receives
attention from Congress. Federal involve-
ment in solid waste legislation began
with the enactment of the Solid Waste
Disposal Act of 1965 (P.L. 89-272). The
limited research authority prescribed under
the Act for developing solid waste dis-
posal technology accentuated the need for
new legislation. The passage of the
Resource Recovery Act in 1970 (P.L. 91-
512), changed the emphasis of the federal
program from solid waste "disposal" to
solid waste "recovery" and "recycling".
According to the National Center for
Resource Recovery, "one of the motivating
factors in the creation of the Resource
Recovery Act of 1970 was to assess the
effects of recommended programs and
policies prior to implementing them.
Comprehensive studies on a wide range of
policy-related topics were deemed necessary,
in order to establish a firm b^sis for
federal approaches to resource recovery and
the field of solid waste management."
While the Resource Recovery Act lacked
standard setting and enforcement powers,
the Act did require that special studies
and demonstration projects on recovery o*
useful energy and materials be undertaken.
In addition, it provided grant*: to the
States and municipalities for resource
recovery systems and improved solid waste
facilities. Six demonstration projects
throughout the country are currently being
funded by the Environmental Protection
Agency unde" the Resource Recovery Act.
In the major study reouired under the
Act (Report to Congress on Resource
Recovery), EPA concluded that "there has
been sufficient technology development
to allow extraction of materials and energy
from mixed municipal wastes; however,
few full scale recovery plants exist."
One of the primary reasons which has been
continuously cited is the lack of adequate
markets for recovered materials. This
deficiency, according to the National Center
for Resource Recovery, "was felt to be
partially the result of federal policies,
such as tax subsidies of virgin materials
and a reluctance to force internaliza-
tion of the costs of environmental degra-
dation." EPA, however, feels that "addi-
tional incentives (for recycling, other
than GSA paper purchasing specifications,
Defense Department procurement policies,
and Treasury Department industrial revenue
bonds) are not considered desirable at
this time." Instead, EPA is providing
technical planning assistance to the States
so that the States can set up their own
solid waste management plans, including
privately managed resource recovery and
energy conservation projects wherever
feasible.
Since the Resource Recovery Act
(which has already been extended one year
through FY 1974) is scheduled to terminate
on June 30, 1974, Congress has recently
conducted hearings in an attempt to define
the solid waste "problem" and develop a
"workable" solution.
Of the major solid waste bills now
under consideration, the Administration's
bill (the "Hazardous Waste Management Act
of 1973") has the most limited federal role.
34
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The bill (H.R. 4873) would recpire the
Administrator of EPA to identify hazardous
wastes, establish treatment and disposal
standards for such wastes, and establish
guidelines for State programs to implement
these standards.
The "Comprehensive Waste Management
and Resource Recovery Act," (H.R. 13176),
introduced by Congressman Rogers, would
assure that State and local solid-waste
management practices are designed to the
maximum extent feasible to realize certain
objectives of national policy.
Toward this end, the proposed legisla-
tion establishes a new Federal-State-local
review system for solid waste management
and resource recovery. There are five
basic elements to this system: (1) gen-
eral national objectives; (2) specific
requirements; (3) authority for the
Administrator of the Environmental Protec-
tion Agency to prescribe guidelines to
effectuate the general national objectives
and the specific requirements listed in
the bill; (4) State waste management and
resource recovery plans which must, to the
maximum extent feasible, effectuate the
general national objectives and must comply
with specific requirements and EPA guide-
lines; and (5) plans developed by local
government which States are to review and
adopt as their own if they meet the fore-
going requirements.
Congressman Tiernan and Senator
Hart have also introduced companion omni-
bus bills (H.R. 11878 and S.2753) on
solid waste management this Congress.
The bills divide the legislation into
major policy areas, including transporta-
tion policy, federal procurement, product
standards and regulation, unsafe disposal
practices, energy recovery, etc. The
bills set up federal guidelines and regula-
tions for many of the areas and require
reports to Congress on freight rates
and hazardous wastes.
Finally, Senator Domenici has recently
introduced legislation (S. 3277) amending
the Solid Waste Disposal Act. The bill is
aimed primarily at encouraging full recov-
ery of energy and materials from municipal,
industrial, and other solid wastes wherever
practicable by 1985, and at providing
for controls over hazardous wastes. The
bill also requires EPA to establish an
Office of Energy and Resource Recovery
to implement these objectives with maxi-
mum cooperation between Federal, State,
local, and private sectors.
From the pending legislation, there
seems to be general agreement for the need
of a Federal regulatory program of hazar-
dous wastes control, a program of resource
recovery and energy conservation (on the
Federal, State and/or local levels), a
study and/or review of Federal policies
which discriminate against secondary mater-
ials, and enforcement mechanisms to carry
out the general purposes of these areas.
However, further analysis indicates
that there is no consensus as to the spe-
cific approach which Congress should take
to effectuate these policy considerations
in a national solid waste management prog-
ram.
Radiation is an area where more and
more attention is required by Congress.
Legislation to deal with one or another
aspect of radiation and radioactive mater-
ials in the environment can be reasonably
expected during the next several years.
Mich of the proposed legislation will
probably relate to radiation and radioactive
materials from civil use of nuclear power,
however legislative attention may also
turn to radiation and radioactive materials
from non-nuclear sources.
Legislation dealing with measures to
control and limit possible exposure of
the public to radiation and radioactive
materials from civil use of nuclear energy
is increasingly likely to be introduced
because of two trends. First, the general
assumption that nuclear powerplants will
increase rapidly in number and by the end
of the century will supply more than half
of all the electricity generated which
will represent about 25 percent of the
forecast annual energy input into the U.S.
economy. Presently the 44 licensed nuclear
power plants provide about 6 percent of
U.S. electrical generating capacity.
As of March 27, 1974, the situation for
commercial nuclear power plants was as
follows:
44 plants licensed to operate
54 plants with construction permits
105 plants on order
19 letters of intent
222 total
35
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26,990 Megawatts electrical
52,289 Mwe
114,464 Mwe
21,440
_
214,183 Mwe
The spent nuclear fuel from these
plants will be the source of enormously
radioactive wastes which will have to be
transformed into some solid, stable form
and then stored perpetually, i.e. for
several centuries at least. Operation
of these plants and the supporting nuclear
industry will also produce quantities of
low level radioactive wastes which will
probably be buried. Finally, the milling
of uranium and thorium ores will produce
large piles of tailings which contain
naturally radiative materials that give
off radioactive gases radon and thoron.
The second factor is an increasingly
well organized and articulate opposition
to nuclear energy. Ralph Nader, for
example, has now become an active opponent
to nuclear power and there are proposals
that future construction of nuclear power-
plants should be banned or at least sus-
pended until absolute proof is provided
that catastrophic releases of radioactive
wastes cannot occur in any conceivable
circumstance.
Types of legislative proposals relat-
ing to radioactive materials from nuclear
power can include the following.
The Atomic Energy Act presently pre-
empts the setting of standards for routine
emission of radioactive wastes from nuclear
powerplants to the Atomic Energy Commiss-
ion. While these quantities are small in
terms of radioactive materials naturally
present in the environment, some State
governments have attempted to impose
emissions standards more stringent than
those of the AEC. Past bills to so
authorize the States have not been acted
upon. Similar bills can be expected.
At present it is not clear who will be
responsible for building and operating the
facilities for perpetual storage of high
level radioactive wastes, and burial
grounds for low level wastes. Four
commercial burial grounds now exist, but
their future may be uncertain. No facility
now exists for final storage of high level
wastes and proposals by the AEC to build
a demonstration storage facility in Kansas
a few years ago led to substantial and
effective opposition from Congressman
Skubitz.
A permanent storage facility will be
needed because the nuclear industry can
temporarily store only a limited amount
of radioactive wastes. Legislation will
probably be needed, either to make this
storage the function of the Federal
Government, or to provide special incen-
tives for a privately financed and operated
venture -- such as waiver of antitrust
restrictions on an installation jointly
funded by companies in the nuclear industry,
tax relief, etc.; and to specify the
responsibilities of the private entity.
In principle the regulation of tailings
from uranium mills, and perhaps thorium
mills, is the responsibility of the State
governments. However current problems with
such tailings at some mills indicates that
the respective responsibilities of the
State and Federal Government and private
owners are unclear. Legislation to clarify
these respective responsibilities may be
necessary.
While the probabilities of a catastro-
phic release of large amounts of radioactive
wastes from a nuclear powerplant or a fuel
reprocessing plant are considered to be
very small by the AEC, there is no absolute
assurance that such a release can never
occur regardless of circumstances. Should
a large release occur, particularly near
a populated area, a number of emergency
measures would have to be taken to warn
and advise local authorities and the
public. AEC licensing procedures require
the operator of a nuclear powerplant to
have emergency plans, however the adequacy
of these plans for actions to be taken
outside the plant boundaries may be some-
what in doubt in terms of the abilities
of local jurisdictions to take swift and
correct measures. Legislation may be
seen needed to provide technical advice
and assistance and financial assistance to
local jurisdictions near large nuclear
facilities to keep emergency plans and
key personnel ready for use. Likewise,
the responsibility of the Defense Civil
Preparedness Agency of the DoD and General
Services Administration in its emergency
preparedness role may need expansion or
clarification as these relate to planning
for large scale nuclear emergencies.
Bills have fteen introduced in the past
for a temporary or permanent moratorium
36
-------
upon nuclear power plants because of the
risks perceived by the sponsors from the
possible large scale release of radio-
active materials in an accident, because
of the requirements for perpetual storage
of high level wastes, and because of
fears that nuclear materials (Uranium-235
and plutonium) might be stolen for
terrorists, criminals or foreign agents.
To date no hearings have been held on
such proposals.
The rapidly increasing use of micro-
wave and other electromagnetic radiations
and lasers in communications and industry
increases the prospects of electromagnetic
pollution of the environment. At present
no single Federal agency appears to have
responsibility or much interest in this.
The Federal Communications Commission's
statutory responsibility is limited to
consideration of interference between
different categories of electromagnetic
radiation use with little, if any, atten-
tion to public health or environmental
aspects. Federal legislation is limited
mainly to the Radiation Control for
Health and Safety Act of 1968, P.L. 90-602,
which authorizes performance standards
for electronic products sold in inter-
state commerce that emit such radiations,
but this legislation does not extend to use
of such products, or to licensing of their
operators. The initial thrust of regulat-
ion under this Act has been directed at
dental and medical x-ray machines and at
microwave ovens.
Legislation could be anticipated that
would require investigation of the public
health effects of an increasing presence
of such radiations in the environment of
the home or workplace; and to regulate
their emissions.
Probably the largest source of ex-
posure to radiation in the United States
is from the use of x-ray machines in
dentistry and medicine. Bills have been
introduced to provide for Federal licens-
ing of x-ray technicians. While no action
has been taken in the past, it seems like-
ly that such bills for such licensing, or
to set minimum standards for State licens-
ing, will be introduced. Such legislation
could extend also to operators of powerful
industrial x-ray and laser equipment.
Radioactive materials such as radium
can be extracted from nature. Many others
are artificially produced in nucleT reac-
tors. A third source for artificial radio-
active materials is large machines, such
as cyclotrons and linear accelerators.
The choice of radioactive material for a
particular use in medicine, research or
industry de^nds upon the technical
qualities of the radiation desired and
also upon economics of production. It
seems likely that machine produced mater-
ials will increase in the future.
However the responsibility for regulating
these materials is vague. In principle it
could belong to the States, but few states
have amended their radiation control legis-
lation to specify these manmade materials.
Also it could be assigned to the Atomic
Energy Commission which directly, or
through the states regulates possession
and use of reactor produced radioactive
materials. Legislation could be anticipated
to clarify and assign the regulatory res-
ponsibility.
In closing, I would just like to say
one thing and that is to emphasize the
good impacts that can come out of the re-
organization I discussed earlier. Congress
is limited in its dealing with legislation
and its dealing with the administration
in all the varied areas of environmental
control. A committee which would have
jurisdiction over all aspects of pollution,
including air, water, solid wastes, etc.
would be able to apply this expertise
on a continuing basis and have a continuing
and detailed oversight function which now is
not as effective as it could be. The
overall impact and effectiveness of
environmental control legislation would be
enhanced. I see the possible reorganiza-
tion of the Congress as something very good,
something that can be very effective.
This would be the most important environ-
mental legislation of this Congress.
37
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LIMESTONE SCRUBBER SLUDGE-AN EXAMPLE OP
AIR POLLUTION CONVERTED TO SOLID WASTE
P. W. Spaite
Environmental Consultant
6315 Grand Vista Ave.
Cincinnati, Ohio
45213
ABSTRACT
Federal air pollution legislation provides authority for regulation of
emissions of sulfur oxides and authorizes the research, development and
demonstration work needed to provide improved systems for its control.
Exercise of the powers conferred, by the U.S. Environmental Protection
Agency and predecessor organizations, has led to substantial application of
lime and limestone scrubbing systems in the utility industry. These
processes capture sulfur oxides and produce a sludge which has potential
cross-media environmental impact. The importance of this potential impact
is presently a subject of considerable controversy. This paper briefly
considers events which have led to application of lime/limestone scrubbing
systems and discusses the general nature of the waste disposal requirement.
Sludge disposal technology is discussed and opinions relative to the
overall importance of this problem are expressed.
INTRODUCTION
The Clean Air Act of 1970 and
the predecessor Air Quality Act pro-
vide authority both for regulation
of emissions of sulfur oxides and
for Federal support of the research,
development and demonstration of
technology for control of emissions
from industrial processes. Since
the legislation was enacted many
sulfur oxide control regulations
have been promulgated at both the
State and Federal level. The
Federal authority to conduct research,
development and demonstration has
been used to promote development of
flue gas cleaning systems for control
of power plant emissions of sulfur
oxides. Particular emphasis has
been given to work on development of
lime and limestone wet scrubbing
systems which collect the sulfur -and.
produce a calcium sulfite/sulfate
sludge with potential for pollution
of streams and/or underground water
supplies if it is not properly
disposed of.
The legislative provisions for
Federal participation in development
of control technology is quite
broad. Authority to participate in
all types of research, from bench
through full scale demonstration
projects is explicit. It is clear
that development of environmentally
sound methods for control of major
air pollutants was intended. This
is evidenced by the broad nature of
the R&D authority which was con-
ferred and by specific recognition
of the need to consider ultimate
disposal of potential pollutants.
The actions of the Federal agencies
in execution of their responsibility
38
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for development of sulfur oxides
control systems have also reflected
general recognition of the need to
assure that control of air pollu-
tion does not lead to other serious
environmental impacts. The approach
to development of lime/limestone
scrubbing systems can be analyzed to
specifically illustrate this concern.
The Federal Approach
In 196? Congress first author-
ized expenditure of funds for
development of sulfur oxide control
systems. At this time a Federal
activity intended to complement
work being done by industry was be-
gun. Federal work was concentrated
on non-proprietary control approach-
es which were felt to have widest
potential applicability. Early in
the program limestone scrubbing
research and development was identi-
fied as an activity considered
especially appropriate for Federal
attention. The wide availability of
limestone, the anticipated prefer-
ence of utilities for a process with
no by-product to market, and early
activity on the part of equipment
vendors to develop limestone based
scrubbing systems all suggested that
such processes would find substant-
ial, industry-wide application. On
the basis of this expectation work
on lime and limestone systems was
given highest priority.
The early Federal programs
demonstrated recognition of the
necessity for controlling potential
environmental impacts of limestone
scrubbing systems in several ways.
Closed-loop operation, where no
untreated scrubbing liquor would be
discharged, was set up as a process
requirement. It was also recognized
that solid waste disposal would be a
significant economic factor and some
work was undertaken to identify
possible uses for sludge; for
routine sludge disposal no work was
undertaken on development and demon-
stration of methods. It was felt
that methods that were technically
and economically feasibly for other
large scale, high volume disposal
operations would be adaptable to
limestone scrubber sludge. This
assumption, made in the late 1960s,
still appears to be basically sound
but increasing sensitivity to all
possible environmental impacts,
coupled with increased awareness of
the importance of sludge disposal
technology as a factor in accep-
tance of flue gas desulfurization
systems has lead to a closer examin-
ation of all disposal options by
both government and industry groups.
At present evaluation and optimiza-
tion of environmentally sound
approaches to scrubber waste dis-
posal is one of the immediate
objectives of a substantial
national program.
The Nature of the Problem
The chemistry of lime and lime-
stone scrubbing is now understood
well enough to permit fairly accur-
ate estimates of the amount and
general character of sludge that
will be produced when lime or lime-
stone scrubbing is used. It was
reported in a recent study of
sludge disposal options in the
State of Ohio that a "typical" Ohio
power plant burning J.3% sulfur
coal with 12% ash and utilizing a
limestone scrubbing system would
produce almost l| million tons per
year of waste composed basically of
CaSO-j/CaSOlf, sludge containing some
unreacted CaC03, fly ash, and
water.1 For lime scrubbing the
amount would be slightly less. The
solid waste produced by a plant with
limestone scrubbing is about three
times what it would be for the same
plant without S02 collection.
This quantity of material rep-
resents a substantial disposal
problem but the amounts are not
extraordinarily large when compared
to other solid wastes which are now
being handled. This can be illus-
trated by considering Table 1 which
shows data from the Ohio study.
This report shows the amount of
solid waste which would be produced
if 85% of the Ohio power plants
which are expected to be operating
in 1978 were equipped with limestone
scrubbing. The amount of solid
39
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and the like. Ponds lined to prevent
leaching and eliminate overflow,
various dewatering methods, chemical
fixation, and other related technol-
ogy appears to be potentially applic-
able.
Development and Demonstration of
Sludge Disposal Method's'
The three approaches which are
being used or considered for dispos-
al of limestone scrubber sludge
include l)ponding,in well designed
facilities, 2)treatment to dewater
or stabilize the sludge prior to
ponding or landfilling and 3process-
ing of sludge to produce lightweight
aggregate or some other useful prod-
uct. At present prospects for util-
ization of large quantities of sludge
are not considered good. Ponding
and landfill are expected to find
widest usage in the near future. It
has been reported that 6Q% of the
existing or planned U.S. install-
ations will employ ponding, the
balance are planning for treatment
and landfill. Ponding is the least
desirable solution from the stand-
point that it renders land unusable
until it is reclaimed. It appears
however to be a fairly well develop-
ed art which would be adaptable to
present problems. Treatment to re-
duce volume and increase stability
will increase land use efficiency
but may be too expensive to be econ-
omically attractive in some situa-
tions .
The possible water pollution
sources from either ponding or land-
fill operations are run-off water or
leachate which may contain soluble
toxic species, excess levels of sulf-
ate or chloride, excessive dissolved
or suspended solids, or excessive
chemical oxygen demand. It has not
been established whether any of the
above potential problems represent
serious threats. It seems clear
however that leaching and run-off
must be prevented to assure that
ground water or stream pollution
does not occur.
Numerous methods for disposal
of scrubber waste in economic, non-
polluting ways are receiving atten-
tion. Techniques for dewatering
are being investigated to evaluate
their effectiveness in reducing the
percentage of water in the sludge
below the 50$ which is typical of
material which has been allowed to
settle in a pond. Thickeners, filt-
ers and centrifuges are being con-
sidered for this application. Also
systems for oxidation of sulfite to
sulfate are being studied as a
means for improving the settling
and handling characteristics of
sludge. In addition chemical and
physical characteristics of the
sludge itself are being studied in
some detail to provide better data
for design of suitable ponding
systems and provide information
which will be useful in development
of improved processes for further
treatment or conversion of sludge.
Other work is underway to
develop and demonstrate various
"fixation" processes which would
convert the sludge to stable land-
fill material and methods for con-
version of the sludge to light-
weight aggregate for use in con-
struction, as stabilized road bed
material, and related uses are
being evaluated.
The extent of this work is
described in a report presented in
the past year that indicated '-hat
some 13 utilities were either ...r -
ively engaged in sludge disposal or
were planning or developing dis-
posal systems. In addition at
least four companies were said to
be engaged in work to develop or
demonstrate chemical fixation
processes and work to find ways to
utilize sludge was underway in
several other organizations. This
is all in addition to a significant
amount of federally supported work.
The cost for utilization of
any of the disposal methods still
appears to be uncertain. Estimates
have been reported to vary from
f5,000/acre to 130,000/acre for
ponding, (l) For a 1,000 mw plant
40
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waste from other sources is shown
for comparison purposes. It can be
seen that the amounts of sludge
would be modest by comparison with
the waste from phosphate fertilizer
production even when the unrealis-
tically high percentage of 85%
control is assumed. This seems
especially significant when it is
considered that 80% of the phosphate
fertilizer waste is generated in
Florida and that much of the total
for the state is concentrated in a
relatively small area.
Even on a national basis pro-
jections for sludge disposal rates
do not seem excessive in comparison
with other sources of waste. At
present about 10,000 raw of the gener-
ating capacity in the U.S. has been
equipped with lime or limestone
scrubbing. Forecasts for rate of
increase in the nationwide usage of
all flue gas cleaning vary widely
but they average in the neighborhood
of 100,000 mw by 1980. Using the
same assumptions with respect to
sulfur content, plant load factor
etc., which were used for the Ohio
estimate and assuming that 75% of
flue gas cleaning is limestone scrub-
bing the calculated national sludge
production rate for 1980 would come
to about 150,000,000 tons per year
(75,000,000 t/yr dry basis). This
would be a modest increase in the
total national solid waste output
which amounts to billions of tons
per year for mining alone. From
this it would appear, that the quan-
tity of material to be dealt with
will not be unreasonable and will in
fact be small compared with solid
waste which is produced by some other
industries.
Quantity of material obviously
is not the only consideration.
Potential problems which may be
associated with the unique chemical
and physical characteristics of
sludge must be weighed. The exact
character of sludges will vary with
many factors associated with type
of scrubbing (lime or limestone),
composition of coal and limestone
reactant, and other factors that
will be peculiar to a given site.
It is possible to generalize to
some degree however and the "typical"
sludge composition as defined by
the previously discussed Ohio study
is as follows:
50% Solids, 50% Water
Solids Composition
CaS03
CaSOlj,
CaC03-12%
Fly Ash-
Trace Elements
There has been some speculation
that toxic species originating in
the limestone or fly ash may con-
taminate surface or underground
water if improper disposal methods
are used. Also sludges from some
systems have been reported difficult
to handle because of low density
problems attributed to high CaS03
content. There is however no infor-
mation to show that limestone scrub-
ber waste could not be processed
using methods applicable to process-
ing of other solid wastes such as
power plant fly ash, sludge from
treatment of acid mine drainage,
municipal refuse, gypsum slimes and
gypsum sludges from phosphate
fertilizer production, coal process-
ing refuse, waste from extraction of
metals (ferrous and non-ferrous)
TABLE I. COMPARISON OF MAJOR SOLID WASTE DISPOSAL PROBLEMS
Waste Material
Quantity Disposed of Annually
(Metric Tons)
Phosphate Rock Slime from Fertilizer Mfgr 36,000,000 (1967) <4-6% solids
Gypsum from Fertilizer Mfgr 25,000,000 (1973) 85-90% solids
Fly Ash from Power Generation 9,^00,000 (1978) 80% solids
Scrubber Sludge from 85% of Ohio Power 15,000,000 (1978) 50% solids
Plants (Fly ash not included)
41
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For a 1,000 mw plant 1,100 acres
have been estimated necessary for
sludge generated over 20 years. (2)
The cost per ton of wet sludge
assuming $20,000 per acre comes to
about $.?0/ton dry basis). The cost
of chemical fixation of sludge has
been estimated at about $2.50 per ton
(dry basis) exclusive of hauling
cost by one company offering a
system, (l) Another company which
is evaluating chemical fixation of
sludge from their scrubbing reports
total disposal cost of about $17/ton
(dry basis) including hauling. It
seems reasonable to suppose that the
cost will normally fall somewhere
between these two extremes. Also it
is interesting to note even at $10.00
per,-ton (dry basis) that the operat-
ing cost for sludge disposal will be
in the neighborhood of -4 to .8 mils/
Kwh for plants with a reasonably long
remaining life and a relatively high
load factor. This would be an impor-
tant operating cost amounting to
something like 20-40$ of the total
annualized cost for scrubbing; And
this amount is significant when com-
pared to the lOmils/Kwh which power
might cost if produced without flue
gas cleaning. At this cost for
sludge disposal limestone scrubbing
might not be competitive with other
sulfur oxide control options. On
the other hand incremental costs of
this magnitude would not make the
process economically impractical
where control was important and other
remedies are not readily available.
Limestone scrubbing will likely be a
least-cost solution in some situa-
ions and in others may be the only
practical means for SOx control.
SUMMARY
In summary it would appear that
limestone scrubber sludges will pre-
sent a new waste management problem
of some importance. It has not been
shown however that it will be any
more difficult to handle than other
solid waste problems which are sim-
ilar in magnitude and of a similar
nature. It does not appear that dev-
elopment of basically new technology
will be needed. Rather, it seems to
be a situation where existing tech-
nology should be applied to opti-
mize land usage and insure against
water pollution.
Limestone scrubbing technology
was developed pursuant to legisla-
tion which appears to give adequate
recognition to control of cross-
media impacts. The agency mainly
responsible for demonstration of the
technology has taken reasonable act-
ions to assure that it has overall
environmental acceptability.
In conclusion it appears that
the general approaches which led to
development of limestone based
scrubbing systems were sound and it
seems that the process itself will
prove to be a useful tool.
REFERENCES
1. "Evaluation of Lime/Limestone
Sludge Disposal Options", Radian
Corp. for U.S.E.P.A., EPA-^50/
3-7^-016 (Nov. 1973).
2. Jones, J. W., "Waste Products
from Throwaway Flue Gas Cleaning
Processes-Ecologically Sound Treat-
ment and Disposal.", Control Systems
Laboratory, U.S.E.P.A., Research
Triangle Park, N. 0. (May 1973)
42
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CROSS-MEDIA IMPACTS WITH SOLID WASTES
W. C. Bucciarelli
Chief, Division of Solid Waste Management
Dept. of Environmental Resources
P. 0. Box 2063
Harrisburg, Pennsylvania 17120
Compensation for interrelated, overlapping and occasionally opposing environmental
control requirements assure that coordination policies must be developed which maximize
program efforts and limit interagency impacts. As an example solid waste has evolved as
"The Third Pollution" next to water pollution and air pollution with sufficient impact to
assure increases in total solid wastes for each increment of decrease achieved in water
and air control programs. The need for standardization and consolidation of program
goals, rules, regulations, policy developments and enforcement activities between State
agencies, interstate agencies and Federal programs is detailed. Each new level of
environmental control established on the State or Federal level results in new barriers
to existing control programs. The constraints brought about in this manner can best be
minimized through uniform program development efforts designed to lessen impacts.
The importance of solid waste as "The
Third Pollution" evolved slowly in this
country over the last fifty years and it
was only in the last ten years that the
need for establishing uniform solid waste
control programs in this country was
recognized.
In the development of new programs
such as this there occurs many instances
where existing and proposed regulations
Interface and often times overlap. Any
thorough discussion of air quality, water
quality or solid waste control program
effectiveness must of necessity involve
consideration of the interrelationships,
the overlaps and the interfaces of one pro-
gram with the other resulting in numerous
inter, intra and extra agency policies,
agreements, understandings and formalized
review and approval procedures. This type
of discussion would also, of essence,
require the disclosure of effects on the
general environment surrounding, the
effects on commerce in the area, traffic
patterns, effects on land use past, present
and future, the sociological effects,
health effects, energy crisis and various
and sundry side-effects not the least of
which include the effects on hunting and
fishing in the area and for a radial dis-
tance of at least ten miles.
No program, of the nature of a solid
waste management program, would be effec-
tively established and implemented today if
it were not for the urgent overpowering
need for such a control program.
As the concern is broadened for
righting the wrongs man has brought about
in his environment the need for more
stringent standards and procedures for
control of air emissions is advanced and
the necessity to further treat and polish
the effluents from waste water carriage
systems becomes manifest. With each air
quality standard revision and with addi-
tional water quality standard applied
there occurs concurrently an increase in
the quantity of solid waste and generally
a reduction in quality of the solid waste
to be managed. That is to say more solid
waste of an increased level of hazard has
to be managed, processed and disposed.
At the same time methods of disposing
of solids interrelate with control programs
43
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for air and water quality. Land disposal
methods for solids which presently accounts
for a full 90% of the solid waste generated
in Pennsylvania, has a basic and signifi-
cant impact on water quality. Incineration
and energy and resource recovery approaches
to solid waste management, such as pyroly-
sis and refuse as fuel purposes, result in
added impacts on air quality control pro-
grams .
The concept of land use planning which
is rapidly evolving today will place new
limitations on existing control of programs,
and set restrictions which will require
major modification of current environmental
control programs. An example already seen
in Pennsylvania is the thrust to exempt
prime agricultural land from such uses as
sanitary landfill as exemplified in Penn-
sylvania House Bill No. 1234, and a recent
Commonwealth court decision on constitution-
al amendments gives high priority to the
conservation of our natural, scenic,
aesthetic and historical resources.
The move toward resource recovery of
solids seems to be stimulating a headlong
jump into capital intensive projects which
utilize technology which has barely been
defined let alone fully tested or evaluated.
The evolvement of the green revolution
is resulting in a wide scale assertion that
incineration solely for the purpose of
refuse volume reduction is wasteful and that
sanitary landfill is the least desirable
method of coping with the nation's ever-
growing volumes of waste. Ironic that the
method which is least desirable can be cost-
ed out to be the least expensive and most
controllable environmentally. Today public
sentiment seems to grasp for the undeveloped
technology of resource recovery and recy-
cling and energy recovery. Little careful
consideration has been given to the adverse
environmental impacts which may result from
the undeveloped technologies which we are
expected to apply. This is said not to
minimize the importance of resource recov-
ery projects or approaches but to point out
the need to improve the methods of land
disposal of solid waste to the end of
minimizing adverse environmental impact.
Since no matter how much solid waste may
be reduced via resource recovery approaches
in the future the urgent overpowering need
for land disposal will always be present.
In fact, one thing is evident, should the
technology prove satisfactory the bulk of
the materials pulled off stream would be
those of a non-hazardous nature and the
remainder would be hazardous to a large
percent, which ultimately would require
improved disposal methods and more coordin-
ation with other environment related con-
trol programs. Already the Federal Environ-
mental Protection Agency is promoting the
passage of Senator Baker's Senate Bill No.
1086 entitled "Hazardous Waste Management
Act of 1973" which would set up Federally
controlled and operated solid waste dispo-
sal sites.
Paramount to all of the aforementioned
approaches is the need for interagency
understanding, cooperation and considera-
tion. There exists, quite often, inter-
related, overlapping and sometimes opposing
requirements which one official agency
places upon another as a result of existing
laws. As an example a municipal sewage
treatment facility which is to be construct-
ed affects the responsibilities of the Air
Quality Control Program, Solid Waste Manage-
ment Program and the Water Quality Manage-
ment Program. At present, in Pennsylvania
a coordination policy has been established
wherein the procedure for review and
approval for such a permit is coordinated by
the Department of Environmental Resources
to allow for a maximum of efficiency, a
minimum of review time and a limited inter-
agency impact to the applicant. Upon
receipt of a permit for the treatment plant
the applicant possesses a functional waste
water treatment facility, with an incinera-
tor for sludge processing and a suitable
site for disposal of remaining solids and
ash residue.
In setting up a solid waste disposal
site,e.g., a sanitary landfill many consid-
erations must be made by the applicant.
The proposed site must first conform with
the existing solid waste management plan
established for the area or region served
by the proposed site. Requirements for
highway access must be met through consul-
tation with the Department of Transporta-
tion. The zoning requirements of the town,
township and county must be considered.
The fears and objections expressed by
neighboring residents must be dissipated.
The Labor and Industry Department require-
ments for safety must be met. The local
municipal building codes must be adhered
to. The legal ramifications must be met
44
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concerning title transfers and lease
arrangements. All of these things must
have been considered by the applicant
before applying for our permit.
Once the permit is applied for, then
there is an interaction between Geologists,
Soil Scientists, Aquatic Biologists,
Engineers, Environmental Protection
Specialists, Solid Waste Specialists and
Sanitary Engineers. The interaction here
assures that standards of air, water
quality and solid waste management are met
with necessary provisions to prevent future
problems from occurring. The Clean Streams
Law, The Air Quality Standards, and The
Solid Waste Management Act are applied and
all requirements are met. Then and only
then is a permit issued. Somewhere with-
in this complicated sounding procedure
there must be an understanding reached
between each agency and the applicant. In
all cases there will be some interrelated,
overlapping and, occasionally, some oppos-
ing requirements which are placed by one
official agency upon the requirements
already mandated by law to another. Also,
gaps occur where existing controls do not
cover certain aspects of an environmental
problem. For all of these reasons, new
laws, new controls, and new concerns
become necessary.
As regulatory solid waste responsibili-
ties increase more types of waste are
given more specific attention thereby
increasing the maze and complexity of
bureaucratic "red tape" in the communica-
tion process so disliked by those affected.
Control of coal refuse wastes from coal
mining operations in Pennsylvania is a
good example:
Pennsylvania Deep Bituminous and Anthracite
Mines produced 82,000,000 tons of coal in
1972 with 30% waste (24,600,000 tons).
Bituminous and Anthracite Mining Acts
passed to control mining activities.
Early 1960's Air Pollution Commission
Regulation I passed to deal with air
pollution problems.
1965 Clean Streams Act passed to deal with
water pollution problems.
1967 Bond Issue passed $500 million to
extinguish and prevent fires, control acid
mine drainage, refill and reclaim mines
and prevent subsidence.
1968 - As result of tragedies Coal Refuse
Act passed. Primarily concerned with
stability.
1968 - Solid Waste Management Act passed.
Prior to 1971 responsibility divided
between Department of Health, Sanitary
Water Board, Department of Mines and
Mineral Industries.
1971 - New Department of Environmental
Resources created which combined adminis-
tration of laws under one Department.
Survey of 135 active coal piles with 93
contributing to air, water and safety
problems. Also, an estimated 1200
abandoned coal piles exist.
1973 - Environmental Quality Board adopted
new Coal Refuse Regulations pursuant to
the Coal Refuse Act. Its purpose is to
prevent general environmental problems,
require restoration and show proof of
financial responsibility.
Today, more than ever before, the need
for standardization and consolidation of
program goals, rules, regulations, policy
development and enforcement activities is
obvious. Actions should be taken to bring
about uniform program development thus
assuring only minimal conflict between
requirements of one control agency over
those of another. All this without a
consequent loss in environmental quality.
Although the statement is relatively easy
to make, the follow-through to action
appears more difficult with each added
level of environmental control.
The Federal Water Pollution Control Act
was welcomed by me when it was shown to
provide some monies for solids controls.
Yet it appears to have set up a barrier
between the Solid Waste Management Program
and the benefits to be derived from this
Federally sponsored Act. It appears
obvious that the Federal Hazardous Waste
Act, once enacted, will set up similar
constraints.
An understanding of the cross media
program responsibilities established by
new legislation can be obtained by looking
at the key provisions of the Federal
Hazardous Waste Management Act which calls
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for Federal authority to regulate the
treatment and disposal of hazardous wastes.
These provisions include:
1. Authority to designate wastes as
hazardous by EPA.
2. Authority to regulate treatment/dispo-
sal of selected waste categories by the
Federal Government at the discretion of EPA.
3. Authority for setting of Federal
treatment/disposal standards for designated
waste categories.
4. State implementation of the regulatory
program subject to Federal Standards in
most cases.
5. Authority for coordination and conduct
of research, surveys, development and
public education.
Since the purpose of the proposed Act
is to overcome inadequacies in existing
laws to provide controls over hazardous
waste management practices it appears
necessary to increase the effectiveness
of The Clean Air Act of 1970 and the
Federal Water Pollution Control Act of
1972. The legislative authorities avail-
able for the control of hazardous waste
deposition on land are not sufficient to
result in properly controlled disposal to
prevent the consequent migration of such
wastes into the air, water and land media.
All that can be done is to weigh the
benefits derived against the limitations
established and to strive to minimize the
impacts.
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POLLUTION ABATEMENT RESULTING IN CROSS MEDEA IMPACTS: RADIATION
A. Schoen
Chief, Environmental _Pro_t act Ion Branch
Division of_Qperational Safety
U.S. Atomic Energy Commission
Washington, D.C. 20545
As Mr. Spaet indicated earlier, the
objectives in presentations this afternoon
are for the speakers to examine ways in
which the implementation of the national
legislation related to the control of the
pollutants, the particular type of pol-
lution with which the speaker is concerned,
will result in negative impacts on water
quality and/or create the need for water
pollution control technology. The fact of
the matter is that the nature and imple-
mentation of the legislation dealing with
the control of radiation and radioactivity
as a potential environmental pollutant is
unique for two basic reasons. One, because
it is not limited to the protection of any
one environmental medium but encompasses
all aspects of the protection of man and
his environment from the potential hazards
associated with radioactivity. This aspect
is not entirely unique because pesticide
and solid waste legislation is not media-
oriented but pollutant-oriented. Secondly,
the legislation dealing with control of
radioactivity is not only related to con-
trolling the impact of potential pollutants
on the environment but is concerned with
the control and regulation of the develop-
ment and utilization of the entire technol-
ogy which is the source of the potential
pollutant. This makes it unique in com-
parison with all other forms of environ-
mental protection legislation.
The national legislation dealing with
the protection of man and his environment
from radiation hazards, i.e., the Atomic
Energy Act of 1954, as amended, differs
substantially from the development and
implementation of other environmental
protection legislation in three very
important ways. I regret that in the time
allotted I can only illustrate the very
major differences that exist in the
development and implementation of this
legislation but I think they will serve
to make the basic points I had in mind.
You may recall that the atomic energy
program was conceived during the war as a
Manhattan Engineering District project
which was solely oriented toward the
development of an atomic weapon. The con-
cept of developing peaceful uses of atomic
energy was not fully implemented until
1946 when the Atomic Energy Commission was
created and part of its mission, in addition
to continuing the development of the weapons
technology, was to seek to develop peaceful
uses of atomic energy.
Unlike the Federal Water Pollution
Control Act, the Clean Air Act, and other
environmental protection legislation, the
Atomic Energy Act was not developed as
remedial legislation designed to correct
and improve an environmental pollution
problem that had already developed as a
national problem. It was, in fact, a very
comprehensive piece of legislation, delib-
erated over a very long period of time,
designed to authorize and provide for
Federal control of the development of a new
technology, the peaceful uses of atomic
energy, at its very inception before a
public safety or environmental hazard was
allowed to develop. This evolutionary
process accounts for two of the major
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differences between the Atomic Energy Act
and the other specific pollution control
and environmental protection legislation.
First, the Act required that protection of
the health and safety of the public be an
integral part of the development, utiliza-
tion, and control of the peaceful uses of
atomic energy. It must be remembered that
deliberation of the Atomic Energy Act was
conducted in a national and public atmos-
phere that was still very newly impressed
with the awesome consequences of the use of
atomic weapons so that protection of the
public health and safety was incorporated
as a paramount consideration in the develop-
ment of the legislative requirements for
the control and regulation of the develop-
ment of peaceful uses. It must also be
remembered that, at that time, there were
no public or political pressures to proceed
posthaste with the development of peaceful
uses of atomic energy. It was conceived
of as a potential resource but, unlike the
environmental movement, there were no
emotional pressures generating tremendous
political pressures on Congress and the
Administration to proceed hastily with the
development effort. Secondly, the Act,
did not only provide for the control and
regulation of the effluents or their en-
vironmental effects but it provided for the
control and regulation of the entire
technology including research and develop-
ment, site selection, design, construction,
and operation of atomic energy facilities,
and for regulation of the possession and
use of the related radioactive materials.
I know of no other technology or industrial
development that is so completely regulated,
"from the cradle to the grave," in such a
comprehensive fashion.
The third important difference between
the Atomic Energy Act and other environ-
mental protection legislation is that the
Act was not concerned with the protection
of a particular environmental medium, such
as air or water, but required the protection
of man and his environment from all potential
radiological hazards both in his working
environment and in the environment outside
the facility. It included not only concern
for the release of radioactive materials in
the form of contaminated airborne or water-
borne effluent streams but the problems
associated with direct radiation, a somewhat
unique property of this pollutant. It also
was concerned with protecting land, food
stuffs, and all environmental media as well
as such aspects as regulation of the trans-
portation of the material so that it would
not become an environmental problem.
The Atomic Energy Act and its imple-
mentation also provided for the conduct of
the necessary research and development to
study the effects of radiation on man and
his environment. Over the years such ex-
tensive and substantial research has been
done that radiation is generally acknowl-
edged by many as being the most thoroughly
studied and best understood of the potential
industrial and environmental hazards with
which man is confronted. I want to empha-
size that I don't mean to imply that all
the answers are in hand. I am saying that
in the field of radiation protection, ex-
tensive research has been conducted on
biological effects, genetic effects, and
environmental impacts, which are now only
beginning to be considered in connection
with other types of pollutants.
The atomic energy program also provided
for the development of the necessary technol-
ogy for the measurement, evaluation, and
control of radiological hazards and the
development of the technology, essentially
a completely new technology, for 'the treat-
ment, disposal and storage of the unique
kinds of waste generated in the application
of atomic energy to peaceful uses so there
was a related waste disposal and waste
treatment technology evolving as the develop-
ment of the peaceful uses was proceeding.
As a result of this concept of overall con-
trol and regulation of the development and
use of the entire technology, there are, in
fact, no negative cross-media impacts
associated with environmental radiation
and radioactivity which are not or should
not be factored into the development of the
technology. Again, I want to emphasize
that all the problems are not solved. In
fact a good deal of the mechansim for
attacking them is included in the legislation
that provides for the development, control,
and regulation of atomic energy. There will
be many who will argue that the job is not
being done well enough and there are other
aspects that warrant consideration. The
fact of the matter is that, as a result of
the national regulatory process, the develop-
ment of the peaceful uses of atomic energy
is conducted in more of a goldfish bowl
atmosphere than the development of any
other technology, through public review of
regulations and public hearing processes
as well as the adversary proceedings that
are a sign of the times. The impact of
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radioactivity and radiation on all environ-
mental media including some not considered
in connection with other types of environ-
mental pollutants are incorporated in any
evaluation of the environmental effects of
radioactivity.
In summary, whereas in other environ-
mental protection legislation, one form
of media is being considered without the
commensurate concern for the impact of
stresses imposed on other media, the
nature of the atomic energy legislation
deals with the total technology and the
total concept of control and regulation.
It deals not only with all media but
with all sources of environmental impact
and with regulating the entire developing
technology.
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IMPACTS AND CONSEQUENCES OF EXISTING HAZARDOUS WASTE MANAGEMENT LEGISLATION
R. S. Ottinger
TRW Systems Group
One Space Park, 01-2030
Redondo Beach, California 90278
ABSTRACT
The control and proper disposal of the over 10 million tons of hazardous wastes
generated annually by United States industry has the potential of eliminating the non-
point source water pollution traceable to such wastes. The proposed Hazardous Waste
Management Act and similar legislation will cause the concentration and disposal of the
wastes to specific land sites which will be selected, designed, constructed, and moni-
tored to ensure perpetual isolation of the wastes from the environment. Experience with
improper land disposal provides many examples of contamination of surface and ground
waters, a condition which must be avoided. Accordingly, methodology for site selection,
technology for hazardous waste stabilization and site containment, and techniques for
monitoring, halting and reversing accidental contamination of surface or subsurface
waters must be developed to assure the ultimate effectiveness of not only hazardous waste
legislation but also of air and water pollution legislation.
INTRODUCTION
Discussion of the impacts and conse-
quences of existing hazardous waste
management legislation requires, first, a
definition for the term "hazardous waste",
and, second, a conceptual expansion of the
word "existing" to include both enacted and
pending legislation. The accepted current
definition of "hazardous waste" is "any
waste or combination of wastes which pose
a substantial present or potential hazard
to human health or living organisms because
such wastes are lethal, nondegradable,
persistent in nature, biologically magni-
fied or otherwise cause or tend to cause
detrimental cumulative effects" (1). This
definition, while not precise, does present
a framework against which a particular
waste might be classified as hazardous.
Enacted federal legislation applicable to
hazardous waste management is embodied
primarily in water pollution laws although
specific legislation is under consideration.
In the following the limitations of the
present legislation will be discussed
briefly. The need for comprehensive
hazardous waste management legislation will
be illustrated and some proposed legislation
will be discussed. Finally, the technolog-
ical implications of the proposed
legislation will be described.
TEXT
Current control over hazardous waste
management at the federal level is provided
primarily through the Federal Water
Pollution Control Act (FWPCA), as amended.
The Federal Water Pollution Control Act is
designed specifically to protect streams,
lakes, coastal waters, and underground
aquifers by providing limits on the quan-
tities and concentrations of various
pollutants that may be released to them by
an industrial facility. Those facilities
which store or treat hazardous wastes are
required by FWPCA to properly treat pro-
cessing effluents and any effluents from
storage area drains. When hazardous waste
management activities result in non-point
source discharge, however, no control is
provided by FWPCA. Since a major technique
commonly utilized for the disposal of
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hazardous wastes, landfill, provides a non-
point source of water pollution, the
effectiveness of FWPCA for limiting envi-
ronmental pollution caused by hazardous
waste is seriously impaired.
The necessity for controlling the
treatment and disposal of hazardous waste
has been established through a number of
incidents of environmental contamination
traceable to improper waste management.
Landfills and treatment lagoons are often
the villians in such incidents. For
example, a burial 30 years ago of arsenic
compounds on agricultural land in
Minnesota recently caused the hospital-
ization of several persons who drank water
from a well located near the burial site.
Arsenic compounds apparently had leached
into the aquifer supplying the well. In
1972 an Iowa chemical manufacturing firm
attempted to open burn the insecticide,
phosdrin, grossly contaminating the plant
area. Approximately a ton of pesticide
had to be neutralized and taken to a
commercial hazardous waste disposal site.
In June of 1967 a dike containing an
alkaline waste lagoon in Virginia collapsed
and released approximately 400 acre-feet of
alkaline fly ash waste. The slug of
contaminant killed over 206,000 fish in
the Clinch River and Norris Lake.
Attention given to the disposal of
chemicals by ocean dumping resulted in
Congressional hearings which focused
interest on the entire field of hazardous
waste disposal. The lack of definition of
what constitutes hazardous wastes and the
lack of knowledge of the effects of treat-
ment and disposal practices of hazardous
wastes were both indicated in the hearings.
The Congress in Section 212 of the Resource
Recovery Act of 1970 directed the EPA to
prepare a comprehensive report to Congress
on storage and disposal of hazardous
wastes which would include: (1) a list of
hazardous waste materials, (2) current
methods for disposal of such wastes,
(3) recommended methods of reduction,
neutralization, recovery, or disposal of
such materials, (A) an inventory of
possible sites for a National Disposal
Site System, (5) an estimate of the cost
of developing and maintaining such a
system, and (6) other information as
appropriate. As a result of this direction
the requested information base was synthe-
sized for the use of both industrial and
governmental waste generators and managers.
The information base generated to
support the Report to Congress (1) defined
both the requirement for and the practi-
cality of comprehensive hazardous waste
management legislation. Consequently the
Environmental Protection Agency drafted
proposed legislation which was subsequently
introduced to Congress as the Hazardous
Waste Management Act. The Hazardous Waste
Management Act and other similar proposed
legislation are formulated to assure
environmental protection through the con-
trol of the storage, treatment, and
disposal of hazardous wastes. It is
expected that hazardous wastes will be
controlled from the time they are generated
to the time they are disposed of in an
adequate manner. The major features of
this legislation are: (1) wastes will be
classified with respect to their potential
hazards, (2) methods and/or standards of
performance will be specifically prescribed
for management of most wastes, and (3)
control and enforcement methodology will
parallel that used for the air and water
pollution regulations.
Since the quantity and concentration
of hazardous wastes will increase due to
the stricter air and water pollution regu-
lations now in effect it is particularly
important that such legislation be enacted.
Although proper and appropriate technology
for the adequate disposal of most hazardous
waste is available, often it is far more
expensive than the technology currently
utilized. Even if proper treatment is not
expensive it may not be applied due to
lack of legal requirement.
Adequate treatment and disposal
methodology and technology for managing
many hazardous wastes require further
development. For example, methods for
stabilizing wastes so that they may be
safely landfilled are commercially avail-
able for application to some wastes and
under development for others. Special
disposal sites may have to be developed to
provide for perpetual care of wastes which
cannot be sufficiently stabilized. The
Report to Congress located a number of
sites which might be utilized for this
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purpose. To ensure the adequacy of such
special disposal sites, techniques"for
site monitoring must be developed.' Also
the behavior of landfills must be better
understood before assigning wastes to find
disposal by this technique. Industry and
government can both help the hazardous
waste situation by developing manufacturing
processes which do not produce hazardous
wastes.
The ultimate effectiveness of air and
water legislation is dependent on assuring
that the resulting pollutant residues do
not contaminate the environment. To
provide the necessary assurance, legis-
lation must be enacted to require the
management of such hazardous wastes.
(1) Report to Congress on Hazardous Waste
Disposal. U.S. Environmental Protection
Agency, June 30, 1973.
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IMPACTS AND CONSEQUENCES OF EXISTING LEGISLATION ON WATER POLLUTION CONTROL
J. Floyd Byrd
Proctor & Gamble Company
Thank you Jim, Ladies and Gentlemen.
When one speaks of legislation in the field
of water pollution control, there is one
act which stands out above all others, the
Federal Water Pollution Control Act of 1972
known as Public Law 92-500 (PL92-500).
This is a landmark piece of legislation,
the most important act ever passed by
Congress in the field of water pollution
control.
I 'will speak as an industrialist in dis-
cussing this legislation and its impacts
and consequences.
Representing the views of industry towards
the impacts and consequences of the Federal
Water Pollution Control Act of 1972 is a
pretty tall order. As a matter of fact, it
might well be an impossible task for anyone
representing a divergent group such as
industry to present a consensus point of
view. In the first place, the Act is a
highly complex document which was evolved
over a period of 18 months of hearings,
witnesses, and statements. Including input
from industrial trade associations as well
as technical and professional societies.
Many disciplines participated in the
framing of the Act which included engineer-
ing, biology, sociology, economics, etc.
And, of course, lay citizens groups were
involved in the framing of the Act. The
Act covers 100 pages of meaty print.
Because so many different points of view
have been incorporated into the Act, I
doubt that everyone in industry agrees with
every provision of the document. But I do
believe that most of my fellow industrial
representatives applaud the intent of the
Act and agree with many of its provisions.
I personally believe that, by and large, in
spite of its faults, the Act is a good one.
If properly administered by EPA and if
amended as necessary to reflect the cold
facts brought out by experience, the Act
will achieve the nation's goals of clean
streams at reasonable costs in reasonable
time frames.
Before going further, I want to make this
point. The Act is now on the books. It is
a law of the land. The debating is over
and now is the time to get the job done
right. I think the objective of all
sectors of American society, including
industry, is to see to it that the Act
works in the most effective and the most
expeditious manner possible. Also, since
we Americans are now realizing that our
natural resources and our finances are no
longer limitless, we must do this at accept-
able costs. My intent, therefore, is to
offer constructive comments from an
industrial viewpoint on how to make the Act
work better to achieve our goals of clean
streams. I intend to also touch on needed
amendments to make the Act more realistic.
Let me briefly set the stage by discussing
the situation in the U.S. prior to enact-
ment of this legislation.
First of all, during the 50's and 60's the
U.S. approached the problem of environ-
mental control rather slowly and hesita-
tingly but also logically and rationally.
This approach was pretty much formalized
in the Water Quality Act of 1965. The
Water Quality Act of 1965, the predecessor
of the present act which I will discuss
later, was really an idealistic act which,
if everything else were also idealistic,
would have worked beautifully. The philos-
ophy of this Act was quite simple. All
streams have a given assimilative, or self-
purification capacity to absorb, dilute,
and destroy wastes without any adverse
effects on the stream water quality. There-
fore, all wastes were to be treated to the
extent that the remaining residual wastes
could be assimilated by the stream without
adverse effect on the water quality of the
receiving streams. Under the 1965 Act,
water quality standards were established
for all interstate streams. The entire
emphasis under the old water quality act was
on the assimilative capacity of the stream.
In a sense, the assimilative capacity of a
stream was viewed as a replenishable natural
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resource to be utilized in the interests of
economy.
This ideal engineering approach for many
reasons just didn't work. First of all,
the bill didn't have enough enforcement
teeth in it. Secondly, the process of cal^
culating the assimilative or purification
capacity of a stream is not the easiest
mathematical procedure. Furthermore,
although it sounds simple in concept there
are administrative and enforcement chal-
lenges to allocating the assimilative
capacity of the stream to the various waste
discharges. The States just did not have
the manpower and expertise to carry out
this complex task.
For these reasons, an entirely new approach
or philosophy was adopted in the recently
enacted legislation, the Federal Water
Pollution Control Act of 1972, known as
Public Law 92-500 (PI92-500). This Act
placed its emphasis entirely on effluent
or treatment standards. All wastes are to
be treated to the same extent regardless of
the assimilative capacity of the stream.
Uniform and very high standards of treat-
ment for all wastes are called for in the
Act regardless of the needs of the
receiving streams. Admittedly, administra-
tion and enforcement procedures are made
easy by this seemingly simplistic approach.
Therefore, this Act is truly a landmark
piece of legislation and a radical depar-
ture from the past.
If this controversial Act is implemented as
written without amendments, it will cost
the Nation hundreds of billions of dollars
in the next decade.
Now let's take a look at the main features
of the Act. As I noted previously, funda-
mentally the Act makes a radical departure
from the concept of using to the maximum
extent possible the assimilative capacity
of the stream. This precious characteris-
tic of streams, replenishable and valuable,
is ignored and not used. Stream water
quality standards are not the guiding
criteria. Rather, effluent standards are
established and the waste must be treated
to a standard effluent. The waste dis-
charged to the Mighty but Muddy Mississippi
must be treated to the same extent as a
discharge to Mill Creek, or to the Fen-
holloway River, or to any other small
creek in the U.S.A. The emphasis is on
effluent or treatment standards. The only
thing that can be said in favor of this
concept is the ease with which it can be
administered and enforced.
Let's examine the provisions themselves:
1. The Act requires that by 1977 all
industrial wastes discharged directly to
receiving bodies of water shall be treated
with "the best practical control tech-
nology". This is somewhat equivalent to
secondary or biological treatment or about
90% BOD and suspended solids removal. This
applies to municipal sewage also. The
United States Environmental Protection
Agency (EPA) has been in the process of
developing the effluent guidelines for
various generic such as paper, steel, etc
industries defining "best practical control
technology". These effluent guidelines
vary from industry to industry. Philo-
sophically, this is an acceptable goal.
All wastes from an ethical standpoint
should receive some treatment. Furthermore,
the technology for this degree of treatment
is generally available and at acceptable
costs. The catch is to define best prac-
tical control technology.
2. By 1983 the best available control
technology must be applied to all indus-
trial wastes discharging directly to
receiving bodies of water. Generally, this
degree of treatment is much greater than
classical secondary (biological) treatment
and ranges between 95 and 99% removal
depending on the industry. EPA is also
developing definitions of best available
control technology for the various generic
industries. I want to emphasize again that
95 to 99% waste removal or best available
control technology is required by 1983 re-
gardless of cost and energy requirements
even if the quality of the receiving stream
is so good as to not require such high
degrees of treatment.
This requirement, which could cost the
nation hundreds of billions of dollars,
should be scrutinized by our policymakers.
To require best available control technology
costing billions without a proportional
improvement in water quality is wasteful.
Best available control technology should be
applied only to meet water quality standards
for substandard streams and only for those
streams of some social, recreational, or
economic value. To apply best available
control technology to up-grade a tiny
stream running dry much of the season and
54
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which offers no recreational or social
value to the local region is misusing our
valuable money and resources.
Application of best available control
technology is certainly desirable in many
cases but such high degrees of treatment
should be applied judiciously and not to
every discharge in the U.S.A. The tech-
nology exists to obtain 95 to 99% removals.
The cost of the technology, thanks to work
being done by the USEPA at the Taft Center
in Cincinnati and consultants such as
Battelle, is coming down. But it is still
expensive and should be applied only when
needed.
3. Now let's get to the real bomb of the
entire Act. This bomb is called the zero
discharge clause. PL92-500 calls for a
national goal of complete eliminations of
all pollutional loads to streams of the
U.S.A. by 1985. It means all of the wastes
from all of our industrial plants must be
dried up by 1985. Zero means zero! And
this goes even for domestic wastes.
Obviously this objective of zero dis-
charges is technically and economically
impractical as well as absolutely unne-
cessary for the environment. Remember, air
and water do have an assimilative capacity
and can absorb some waste. But the concept
of eliminating all pollution has consider-
able appeal to well meaning but uninformed
citizens.
I would like to discuss further this con-
troversial concept of zero discharge which
is mentioned in the Act. Zero discharge is
set up as an idealistic goal which should
be achieved. Actually, I feel that zero
discharge would be detrimental to the
environment, rather than helpful. To
require zero discharge of waste to
receiving streams is putting blinders on
oneself so that all one sees is the
receiving stream and not see the total
environment consisting of the air and the
land. Zero discharge of wastes to
receiving bodies of water ignores the
optimum or total impact of certain opera-
tions on the overall environment. The old
law of conservation of matter states that
if one removes something from a waste dis-
charge, it has to go somewhere else. If it
is incinerated, the products of combustion
go up and could be an air pollutant. If it
is hauled to a landfill area, it is a land
pollutant and could leach out and pollute
ground water and surface waters. Also in
incinerating the wastes, which one might
otherwise discharge into a receiving stream
with no adverse effect on the water quality,
one is using up some form of energy, such
as fuel, which is a non-replenishable
natural resource. I do not have to tell
you about the so-called fuel crisis going
on.
Therefore, any approach to pollution
control must consider the optimum effect on
the entire environment — land, air and
water. Zero discharge ignores this concept
and states that we should protect the water
100 percent and the land and air be damned.
Putting on my conservationist's hat for one
moment, and I am a long-time member of the
Sierra Club and the Colorado Mountain Club,
I see no logic in zero discharge since such
a goal can adversely affect land, air and
energy resources. As an industrialist, all
I see in the zero discharge concept is a
large expenditure of money without
improving the environment. Fortunately,
the Act does not call for zero discharge as
a National "policy". "Policy" as you know,
is enforceable as a law and enforceable in
the courts.
The Act calls for a goal of zero dis-
charges by 1985. A goal does not have the
effect or impact of law and is not enforce-
able in courts. Therefore, the goal is
something we strive for and, if we do not
quite make it because of the laws of
economics and the laws of nature, okay —
we tried and at least came closer to Utopia.
So the Act as finally passed is an improve-
ment over the original concept in the
original Senate bill. The word "policy" in
the original proposal has now been replaced
by the word "goal" in the final Act as
passed.
One of the key factors which will affect
industry for the next decade or so is the
definition of best practical control tech-
nology (BPCT) and best available control
technology (BACT). As you know, the Fed-
eral Act requires that by 1977 all
industrial wastes must receive the best
practical degree of treatment. Further,
the Act states that by 1983 all industrial
wastes will receive the best available
degree of treatment. Now, EPA and industry
working together will need the wisdom of
Solomon to define best practical degree of
treatment which must be applied in the next
several years to all industrial wastes.
Developing these guidelines and standards
55
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which will define best practical control
technology has, because of the compressed
time frame, generated some controversy.
Some industries feel the effluent guide-
lines are too strict and unrealistic.
Obviously growing pains are inevitable in
such a complex task compressed by the Act
in such a short period of time.
The various contractors retained by EPA to
define best practical control technology
for industrial wastes are working closely
with various trade associations represent-
ing industry. By and large it looks like
reasonable guidelines will be developed
after much discussion and debate. However,
I would like to make certain points as
follows:
1. EPA in developing the guidelines should
keep them flexible with a considerable
amount of discretionary authority in their
application left to the individual regional
administrators. Industrial plants vary
considerably in their ability to reach
various efficiencies of waste treatment. A
new plant with good housekeeping might be
able to obtain very easily the definition
of best practical control technology. But
what is the best practical control tech-
nology for a newer plant and process may
not be the best practical control tech-
nology for an older plant with older
processes. As long as the water quality of
the receiving waters is protected, there
should be a range of values which can be
applied to plants depending on the process
involved or their ages.
Many industries justify individual plants
on the economies of that individual plant.
If a tremendously high degree of treatment
is going to be imposed at great expense on
a plant which is older and perhaps only
slightly better than marginal in its payoff,
then it may be in the best interests of
that company to shut down that plant. Jobs
are lost and there is economic hardship
without any appreciable improvement in the
stream. The important thing in applying
the definitions of BPCT to specific situa-
tions is to be sure the quality of the
water is protected. As long as this is
achieved, why shut down a plant just to
adhere to rigid standards? Let's be flex-
ible as well as just and fair.
2. Another factor which I think is very
important in defining the best practical
control technology comes in the terms and
definitions used. The worst possible way
to describe the quality of a discharge from
industry is in terms of concentrations. A
concentration says nothing about the total
pounds of waste going into a receiving body
of water and after all the effects on the
receiving body will be determined by the
pounds or quantity of waste going in and
not the concentration. Furthermore, if we
put limits on concentrations, then this
discourages water conservation and encour-
ages dilution by sloppy practices resulting
in wasted water. Fortunately, I see EPA
developing their definitions and their
standards in terms of pounds of waste
material per unit production. I would like
to take my hat off to EPA for encouraging
the contractors to talk in terms of
quantities and not concentrations. On a
number of occasions at the municipal and
state level I have run into limitations on
waste expressed in terms of concentration,
such as ppm rather than in terms of pounds.
When applied to such things as BOD and
suspended solids, this is a rather meaning-
less limitation. It says in effect that a
small discharge consisting of 10 gpm flow
at 100 ppm BOD is no different from a dis-
charge of 10,000 gpm flow at 100 ppm BOD.
The fact that the latter discharge in-
volves 1000 times more BOD in terms of
pounds is totally ignored and neglected.
It is the number of pounds of BOD, not
concentration, which affects the water
quality of the receiving stream. So let's
forget concentrations as a limiting factor
except in unusual cases.
Furthermore, if an industry discharged into
a municipal system 10 gpm at 200 ppm BOD
but the municipality limited the discharge
to its treatment works to 100 ppm, the
industry would tend to engage in slop.7
procedures in the use of water in order to
dilute down to 100 ppm BOD. The limita-
tions in concentrations would encourage the
industry to use once-through water so as to
lower the concentration of its discharges
down to 100 to be acceptable to the muni-
cipal system. Hence, we're discouraging
what we want to encourage the most —
economic reuse and recycle of water. Only
in the limited case of toxic material
should concentration also be utilized as a
control method.
The Act requires that EPA publish a list of
what it considers to be toxic material and
later establish standards of discharge for
these toxic materials. This will prove a
difficult and challenging job. EPA must
use the most talented professionals in the
56
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field to carry out this extremely difficult
task which can vitally affect industry.
And now a few specific points I'd like to
discuss from my vantage point as an
industrialist. First of all, the Act does
correctly encourage the joint treatment of
industrial and domestic wastes into large
centrally located regional waste treatment
systems, either run by the municipality or
a public or private utility such as a
sewerage district. The joint or combined
treatment of wastes because of the
economy's scale-up gives the best unit
costs for waste treatment. Both the
industrialist and the taxpayer gain by
joint efforts. A proliferation of little
waste treatment facilities, both industrial
and municipal, is not the wisest approach
to pollution control.
Now, although the Act encourages this
joint approach, the Act also proceeds to
require both sewer service charges for
industrial wastes going into municipal
systems and pretreatment requirements for
certain industrial wastes going into muni-
cipal systems. These two requirements,
while necessary, can, if made too restric-
tive and inequitable, kill the very concept
that Congress has established in the Act.
If the sewer service charges developed are
inequitable and demand that industry pay
more than its fair share of the costs, this
might drive industry to treatment works of
its own, thus killing the economies of
joint approach. The industry pays a higher
price for its own little treatment facility
and the individual taxpayers will,pay more
for a municipal system that is smaller in
size and does not enjoy the economies of
scale-up.
Furthermore, if the pretreatment require-
ments for industrial wastes discharged to
municipal systems are excessively stringent,
then industry may be forced to needlessly
treat its own wastes.
Pretreatment for pretreatment's sake should
not be required of industrial wastes. Only
those industrial wastes which are not
effectively treated in a conventional
municipal system or those industrial wastes
having an adverse effect on the processes
of a conventional municipal system should
be pretreated prior to discharge to a
municipal system for treatment by the
municipality. All other wastes should be
accepted into municipal systems for treat-
ment by the municipality. This assumes
that the capacity is available. In fact,
even if the capacity is not available, it
should be added to the treatment facilities
to accommodate the industrial wastes at the
expense of the industry involved. I want
to strongly emphasize that we in industry
do not want to be subsidized. We are will-
ing to pay our fair and equitable share of
waste treatment through an equitable sewer
service charge.
At present, guidelines for pretreatment are
being developed by EPA and its contractors.
These guidelines during the preliminary
review by a committee of the Water Pollu-
tion Control Federation looked fairly rea-
sonable and practical. We have recommended
certain changes in the, but by and large,
they look good to me as an industrialist.
The drafted guidelines protect the muni-
cipal system from abuse by industrial
wastes and at the same time encourage
industrial use of a municipal system.
I also know that various representatives of
the Water Pollution Control Federation and
certain other trade associations have
reviewed the first draft of the sewer
service charges by which industry will pay
its fair share of waste treatment. This
draft proposal also looks reasonably good
but with certain inequities to industry
still built in. We have forwarded our
comments to EPA for their consideration.
And now I would like to pose two basic
questions on the impact of the law on our
economy and precious natural resources.
1. How do these national treatment stan-
dards impact upon the Nation's economy?
In other words, what are the costs to
achieve these goals?
2. What is the effect on these standards
on energy? What are the energy require-
ments?
Before I answer these questions, I want to
remind all of you again that total removal
of waste to a receiving stream is unne-
cessary; all streams have a certain
assimilative or self-purification capacity
to destroy wastes without adverse affect on
the water quality of the stream in question.
And now costs
It is not too expensive to remove perhaps
57
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the first 90 or 95% of the waste material
from a discharge. However, to get the last
one to three percent can involve tremen-
dously escalating costs. It may take as
much money to remove the last one or two
percent as it did to remove the first 95 to
97%.
I have heard estimates ranging from 200
billion to three trillion as the cost of
achieving the zero discharge goals as
specified by the law.
To achieve secondary treatment alone in
1977 for all remaining municipal wastes not
so treated will cost, by conservative
estimate, about 60 billion.
And'now let's grapple with the energy sit-
uation
It is estimated that the 1977 goals of
B.P.T. (best practical technology or 90-95%
removals) will increase electrical consump-
tion by 20% or so. Remember this goal is
easy; we've been doing it for years and the
technology is available and yet even this
easy goal will add 20% to our national
electrical requirements. But how about the
1983 and 1985 goals of B.A.T. (best avail-
able technology or 95-99% removals) and
zero discharge.
As slide I shows: 1) There is a tremendous
increase of electrical needs as we go
beyond 90% BOD removal. For example, at
95% BOD removal we may use about 0.7KWH///
BOD removal; however, going from 95 to 98%
removal increases the electrical needs to
1.4KW. In other words, to get 3% addi-
tional BOD removal, we must double our
energy consumption. I also think this
table 2) emphasizes how power consumption
escalates as we remove each additional per-
centage of pollutional load by waste treat-
ment processes.
% REMOVAL RANGE
to 87%
87 - 97%
97 -100%
ENERGY REQUIRED FOR
% POINT REMOVAL
1
10
100
Remember, PL92-500 does not even mention
energy in the entire Act. The law was
enacted in October, 1972 when the energy
crisis was a small cloud on the horizon
which no American wanted to even admit
existed.
Well, how do we change PL92-500? It may
be easier than you think. Congress, in
enacting PL92-500, recognized the impact
on our economy of trying to achieve the
1983 goals of best available control tech-
nology of 95 to 99% removals for all
industrial wastes. Congress was aware that
this clause in the Act is highly controver-
sial as was the zero discharge clause.
Therefore, in the Act Congress provided for
a mid-course correction by late 1975. This
correction will be achieved by a National
Study Commission consisting of five members
of the U.S. Senate, five members of the
U.S. House of Representatives, and five
members to be appointed by the President.
Governor Rockefeller was appointed by
President Nixon as a member from the
general public and he is also Chairman of
the Commission.
Governor Rockefeller's views are well known.
Rockefeller intends to develop studies show-
ing relative costs for each stage of stream
clean up and an estimate of the benefit
derived from the expenditures at each stage.
Using costs and benefits he hopes this
Committee can make sound, rational
recommendations to Congress towards amend-
ing PL92-500. The Governor and his staff
have stated that energy requirements as
well as money will enter the picture in
determining national goals in water clean-
up efforts.
Each citizen should follow closely these
studies and exert his influence towards
effective, practical, and achievable
national goals for cleaning up the nation's
waters. A team effort consisting of all
segments of our society is necessary to
clean-up our environment at acceptable
costs. Furthermore, the decision making
process should be carried out by an
informed public using information which we
technical people generate.
1.4
a 1.2
I
I
n 0.8
0.4
WASTE REMOVAL EFFICIENCY
100 95 90 85
* BOD WASTE REMOVED
58
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NATIONAL COMMISSION ON WATER QUALITY
J. G. Moore, Jr.
Program Director
1111 18th Street, N. W.
P. 0. Box 19266
Washington, D. C. 20036
I hardly know exactly what to say to
this particular audience. I've tried to
get some feel for what you might be inter-
ested in. I understand that there's al-
ready been some reference to the Commis-
sion. This organization was created by
Section 315 of the Federal Water Pollution
Control Act Amendments of 1972. It's ori-
gin relates to the dispute between the
House and the Senate as to what should be
done with the various deadlines or require-
ments of the Act. And so the Commission
grew out of controversy. There was a deci-
sion to continue attention to the question
of the effluent limitations that are pre-
scribed for 1977 and 1983.
The Commission's direct charge as
stated in Section 315 is to take a look at
the 1983 requirements of the statute. The
language reads as follows: The Commission
shall "make a full and complete investiga-
tion and study of all the technological
aspects of achieving and all aspects of the
total economic, social, and environmental
effects of achieving or not achieving the
effluent limitations and goals set forth
for 1983 in Section 301(B)(2) of this Act."
That charge is very specific. The Commis-
sion is to look at the 1983 requirements.
The Commission, however, early in its deve-
lopment, decided to also examine the 1977
requirements for both municipal and indus-
trial discharges as they might impact
achievement of the 1983 goal and require-
ments. In a similar way. the Commission
determined also to characterize what was
likely remain to be done after 1983 so as
to reach the 1985 goal of the elimination
of the discharge of pollutants into the
nation's waters. The 1983 water quality
goal is "that wherever obtainable, an
interim goal of water quality which pro-
vides for recreation in and on the water
be achieved" by that date. So that there
is both a legal requirement for certain
effluent limitations and a water quality
goal for 1983.
The Commission was authorized an
appropriation of $15 million of which $10
million has already been appropriated.
There is, however, a statutory deadline
for the Commission's report, October 18,
1975. Approximately six months elapsed
before the presidential appointments were
made and nearly a year elapsed before
there was a staff board, at least enough
staff to get underway. And so, one year
of the Commission's three years had ex-
pired before the Commission really got its
work started. The Presidential appointees,
besides Gov. Rockefeller, are Dr. Edwin A.
Gee, Executive Vice President, Du Pont,
William R. Gianelli, recently retired dir-
ector of the California Department of
Water Resources, Raymond Kudukis, Director
of Utilities for the city of Cleveland,
Ohio, and the late Carl E. Wright, a mem-
ber of the Arkansas Water Pollution Con-
trol Agency. Mr. Wright died recently of
a heart attack and has not been replaced
on the Commission. Senators from the
Public Works Committee are Jennings
Randolph from West Virginia, Muskie from
Maine, Bentsen from Texas, Baker from
Tennessee and Buckley from New York. The
Congressmen from the House Public Works
Committee are Blatnik from Minnesota,
Jones from Alabama, Wright from Texas,
Harsha from Ohio, and Grover from New
York. The Executive Director is Gen.
Frederick Clarke who retired last year
as chief of the U. S. Army Corps of Engi-
neers.
59
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You will note from the makeup of the
Commission that it includes in its Con-
gressional membership three Democratic
members from each of the Public Works
Committees and two Republican members from
each of those Committees. Its makeup is
such that we have all shades of opinion
with regard to the 1972 Water Pollution
Control Act Amendments. In fact, the Com-
mission members, I doubt seriously, could
agree, at this point even, to the meaning
of some of the language in the Amendments
themselves. We've spent a great deal of
time getting agreement on a very brief
statement of the Commission's study out-
line .
If any of you are interested in get-
ting a copy of this brief statement if
you will give me your card before the
night's over, or write your name and ad-
dress on a piece of paper, I will be glad
to have it mailed to you. It's a very
brief statement of what it is the Commis-
sion expects to do. That statement is
being elaborated in its various sections
and those elaborations will be available
to you or anyone who might have an inter-
est in some particular area of the Commis-
sion's study.
Unfortunately, I suspect that one of
the things that's happening is that every-
body has some complaint about the effluent
limitations, the EPA interpretation of the
law, or some unexpected consequence of the
statute. All somehow expect the National
Commission on Water Quality to correct
their problem as they see it. If we were
to tackle all the problems that have thus
far been mentioned to us I am sure that we
could not complete the work of the Commis-
sion by the deadline. The mere addition
of some examination of the 1977 require-
ments and the 1985 goal of the elimination
of the discharge of pollutions will in
themselves substantially add to what it is
the Commission staff will have to do.
The Program Staff is organized into
four major subject matter units: techno-
logy assessment, environmental assessment,
economic and social impact, and institu-
tional. There is also a unit responsible
for program planning and coordination and
the usual administrative support units, a
general counsel, a public affairs staff,
and the normal administrative services that
have to be performed in organizations like
this. We expect to have about 75 staff
people and including staff assistants we
now have about 65 of those on board.
These staff assistants are selected pri-
marily by the members, which is to say each
member selects a staff assistant and he is
resident with the Commission staff at the
Commission offices. These assistants are
assigned to various operating units depend-
ing upon their own training, experience
and interests.
I want to devote some time to the
specific study areas on which the Commis-
sion will concentrate. These are the areas
where our efforts will be placed in terms
of both money and time. Incidentally, we
do not intend to do the work internally.
We will contract with various concerns
across the country to undertake this work
for the Commission, so when I say the Com-
mission will do these things, we will do
these things under contract. Of the total
appropriation of $15 million, about $12 1/2
million will be used for contract research
with external organizations.
We begin with an attempt to describe
the nation's water quality and quantity;
we would like to establish a baseline of
the nation's water quality as a means for
examining future impacts of the elimination
or reduction of pollutant discharge. This
will be done under contract with concerns
that have worked with water quality data
and have the capabilities to predict future
water quality based upon reduction or eli-
mination of discharge of pollutants. This
baseline will be used primarily for the
environmental assessment of the impact of
the 1977 and 1983 requirements as well as
the ultimate goal of the elimination of
discharges.
In the capabilities and cost of tech-
nology section, the staff is responsible
for taking a look at the municipal treat-
ment requirements as they relate to secon-
dary treatment for 1977, and best practi-
cable waste treatment technology over the
life of the works for municipal treatment
facilities for 1983. There will also be
some attention to the question of the possi-
bility of the elimination of discharge from
municipal waste treatment facilities. When
I say elimination in terms of municipal
wastes, however, this does not mean the
removal of the pollutants themselves, but
the possibility of disposal by methods
other than the direct discharge into receiv-
ing waters. For industries, we will do an
BO
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analysis of all of the effluent limitations
and the economic bases produced by EPA for
the effluent limitations. When I say we'll
do all of them that means we'll take a look
at all the classifications EPA has delin-
eated and all the effluent limitations pre-
scribed for those classifications. Obvious-
ly we will devote more attention to some
than to others. We already have selected
as many as six or eight to which we will
devote special attention and these are
those classifications where the waste dis-
charges are substantial or their polluting
effect is substantial or they represent
significant segments of the economy. In
some sense this means we will attempt to
second guess EPA's effluent limitations
and I suppose there is no way to avoid that
impression. We will begin first with the
economic analysis to determine whether or
not that analysis appears to be reasonable.
There will also be a look at the technolo-
gical solutions recommended in the develop-
ment documents produced by EPA to determine
whether or not there might be other techno-
logies that could be utilized. Now we have
not yet crossed the bridge of whether we
will attempt to develop, or might be in a
position where we would have to develop,
alternative technologies that would set
at different effluent limitations for some
of the-se industrial classifications. Our
general feeling is that we would merely
point out the problems that arise with the
effluent limitations as prescribed by EPA.
If we do, in the course of the work, deve-
lop some impressions as to what the efflu-
ent limitations should have been, we may
very well furnish that information first
to the EPA but it could conceivably end up
eventually in the Commission's final report.
That's primarily the work of the cost and
capabilities technology section. Their
product or the product of their work,
the costing of these various effluent
limitations, will become the input for the
economic analysis that is required under
the statute.
For the economic analysis, we will
also attempt to develop projections of
gross national product and government and
income expenditure to 1985. This is a
year-by-year projection as a basis for
attempting to determine the impact of the
cost of the effluent limitations. Using
the information produced by the cost and
capabilities technology unit, the economic
unit will them attempt to trace the cumula-
tive effect of all the industries trying to
meet both the 1977 and 1983 requirements
simultaneously, and make some determination
as to the impact upon governmental income
and expenditure, particularly as that item
is affected by the municipal waste treat-
ment construction grants program.
For environmental assessment, the
Commission will attempt to characterize
what should be the chemical, physical, and
biological composition of the water that is
necessary restore and maintain the inte-
grity of the nation's waters, which is a
phrase used in the statute and what would
be required in order to meet the statute's
water quality objective. In the economic
impact analysis, we will use econometric
input/output models, where they are avail-
able; and we have determined to use the
one that presently is housed in the EPA
called "SEAS" with some additions which
will be developed and funded by the Com-
mission. Now modeling, we recognize, is
merely one of several tools that can be
utilized in this area. In the ecological
or environmental area, models are less
developed and have less reliability perhaps
but we will examine the possibility of
utilizing such models as do exist. But in
the environmental arena this work will be
primarily done as a series of analytical
processes rather than an attempt to per-
fect any existing modeling effort. The
assumption will be made that the 1977
requirements will be met whether they are
met in '77 or later, and that the 1983
requirements will be met whether they are
met in '83 or later. An attempt will be
made to characterize what will then be
the quality of the nation's waters if
those effluent limitations were reached.
We will also attempt to characterize what
would be the quality of the nation's waters
if the elimination of discharge of pollu-
tants was realized at any date. The pur-
pose is to try to compare what might have
to be spent to reach, in terms of cost,
of what the cumulative economic effect
might be, of reaching the 1977 and 1983
requirements and the elimination of the
discharge of pollutants — what might
be the benefit that might be realized in
terms of environmental change.
The environmental assessment is pro-
bably the one that's most difficult to
do, unless it's the social impact question.
We recognize that the reaching or not
reaching the 1983 requirements and other
requirements and goals of the Act can have
61
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social impact. One of the things we are
concerned with is what happens in those
instances where marginal industries close
as a result of the effluent limitations
and on the other side of the equation what
benefits accrue as the result of improved
water quality. The utilization of leisure
time in terms of water-oriented recreation,
the health effects of changes in water
quality, and even questions of shift in
employment as a result of achieving or not
achieving the effluent limitations will be
examined.
In the institutional area, the Commis-
sion's concern is to try to evaluate the
federal, state, regional, local arrange-
ments for achieving water quality objec-
tives, and try to determine whether or not
these could be improved, in a realistic
sense rather than in an idealistic sense,
and how the system might be tied together
better so that the work is concentrated
on achieving improvement in water quality
rather than a lot of energy used up in
irritations, and abrasions, and frustra-
tions between the various levels of govern-
ment. The institutional area is one in
which a number of Commission members have
an interest, several of us on the staff
have been involved in various levels of
this type of administrative effort and we
also have an interest in the institutional
question. Some hope that this will be the
most fruitful part of the Commission's
work but one of the problems with institu-
tions is that they don't change rapidly.
We have, in the water field, had a multi-
plication of water agencies rather than a
dimunltion of water agencies. This tends
to complicate the interrelationships at all
levels of government.
The regional assessment studies we
originally conceived as a means for trying
to relate what otherwise would be national
statistics and implications to some geo-
graphic areas so that people could deter-
mine what was the impact of this particular
statute on their locality. We looked ini-
tially for representative bodies of water,
lakes, rivers, and coastal areas, to which
we felt others might be able to relate.
We started with a rough list of 36 in the
country intending to select as many as ten.
Over time, the concept of the regional
studies has changed somewhat. With 15
Commission members coming from different
parts of the nation's geography there is
always a pressure to get a river in "my"
area, and there's been some of that type
discussion. It is also probably true that
where we might see similarities I am not
sure that residents in the various areas
would see the same thing. They may not be
as representative as we had hoped they
might. They may be more illustrative of
what the problems are likely to be. One
of the things I think that happens in
evaluating a national program like this
is that a national statistic doesn't touch
you. If I say that the cost of this pro-
gram is going to a $100 billion over the
next five years that does not necessarily
hit any one of us except that that's a
pretty substantial figure. But if I were
to tell you that it was going to cost you
$17.30 a month for the next ten years, that
is a figure that has a great deal more
impact on you individually. We had hoped
that we would be able to disaggregate, if
you will, the national statistics we
inevitably will come up with. I think we
will have some success with this but the
character of these various regional assess-
ments is undoubtedly changing and will
change as we attempt to scope them.
I'm going to give you the names of the
various regional studies we will do with
the understanding that we have not yet
scoped these, nine of these were only
chosen a week ago Wednesday, and we get
approval from the Commission before we
detail what is to be done in each one of
these areas. Each one will be scoped to
where it is manageable; that is to say,
we will scope these in such a way that we
concentrate on the differences where the
differences are important but we also
would attempt to do a fairly uniform analy-
sis where the data will support that
approach. In other words, these could be
microcosms of the national study in some
of the regional areas. The rivers are the
Merrimac, Nashua, the Hudson, the Delaware,
the Kanawha, a tributary of the Ohio, the
main stem of the Ohio from Pittsburgh to
Cairo, Lakes Michigan and Erie (that one
obviously will have to be narrowed consi-
derably) , the Chatahoochie Flat-Appalachi-
cola system along the Alabama/Georgia bor-
der, the Houston ship channel-Calves ton
Bay, the Colorado River (obviously is a
massive one, but one that we felt was
absolutely necessary because of the ques-
tion of irrigation water use, the normal
background salinity that comes from runoff,
and the.potential development of oil shale
in the upper basin), and the Yellowstone,
62
-------
a tributary to the Missouri — selected
largely because it is as yet undeveloped.
However, the coal deposits in Montana that
will ultimately or may ultimately be
developed as a result of the pressure and
demands for increased energy will undoubt-
edly have an impact on the Yellowstone.
The intent here was to pick one undeveloped
river basin subject to development to
characterize that particular type of envi-
ronment. The San Francisco Bay/Central
Valley is one that is obviously too large
geographically, but does represent a signi-
ficant bay system along with a complex of
irrigation and industrial discharges.
Lake Washington/Puget Sound was chosen
primarily because this is one area in the
country where there have been substantial
improvements over time in water quality,
done largely by reducing the discharges of
pollutants.
As to what's likely to come out of
what the Commission does, obviously when
you hear it, and when we read it and even
when we discuss it, there appears to be
entirely more than can be done in the time
we have. I generally have encouraged the
program staff to be broader rather than
narrower in their initial undertaking,
recognizing that over time some of things
we would like to do will fall by the way-
side simply because of the absence of ade-
quate data or methodology, in some cases.
Whether or not we can produce something
meaningful is also related to the politi-
cal issues involved. I make no secret of
the fact that we have at least four poten-
tial presidents, vice presidents, or can-
didates on the Commission. They are
evenly divided so far between Republicans
and Democrats. That has a bearing on what
the Commission sees as the Commission's
role. I will admit that it has been very
difficult at times to get Commission agree-
ment on some very, what appear to be, very
simple language, what you would regard to
be relatively simple language, because of
the history of the development of the stat-
ute itself. So there is a political hazard
in what we are undertaking. As to the
expectation that people have about what it
is the Commission can do for them, we
already have had massive contacts from
industry about the effluent limitations; we
have had extensive contacts with environ-
mentalists and public interest groups; and
from the states themselves as to the pro-
gress of this program. We in fact have in
the public affairs unit an individual —
one person full time — in each of those
areas. We have a full time liaison with
industry, a full time liaison with the
environmentalists and public interest
groups, and a full liaison person for all
governmental levels — federal state, •
local and regional governmental units, |
simply because of the pressures that
these people feel and would like to exert j
in terms of what the Commission might
ultimately report.
The staff does not, at this point in
time, intend to develop recommendations.
That is to say, none of our work programs
will be scoped so as to get recommendations
from contractors. The staff does intend,
and I am committed to the professional
staff people who have been brought on
board in these various subject matter
units, that they will be allowed to pro-
duce a professionally sound document. The
staff intends to write the initial Commis-
sion report. Whether or not we achieve
that is also involved in a general ques-
tion of the relationship of the staff to
the Commission. Undoubtedly the question
of recommendations will come, the question
of recommendations will undoubtedly occur
and we will I am sure develop impressions.
Some of us on the staff begin with biases.
The point I make about mine is that mine
are really objective opinions and I am
just combating all those other biases I
encounter. But, it's hard to avoid them
if you've had any exposure to this pro-
gram before.
There is a real opportunity for a
group like this to make a contribution
and because the Commission is made up in
an unusual way, a mix of Congressional
members with Presidential appointees, it
has an opportunity to do something that
not all Commissions have had. You've
heard of Executive Commissions where they
develop detailed recommendations and
nothing ever happens. Well, one thing for
sure, if this Commission can develop
recommendations that the Congressional
members support, we can expect that those
members will see to it that these recom-
mendations will at least get introduced
to the Congress. On the other side of the
coin, if this Commission develops recommen-
dations that the Congressional membership
will not support, then obviously there is
little chance of making an impact on the
law itself. And I would remind you, if by
virtue of the accident of the way the poli-
63
-------
tics lines up, there is or there could be,
a majority if you split on partisan lines,
there would be a Republican majority on
the Commission, with two from each House
and five Presidential appointees, presum-
ably all Republicans; that would give a
majority of nine, which would be a control-
ling majority if the issue were split
strictly on party lines. I would hasten
to add that this statute has not been
handled that way, generally speaking. The
statute generally has been rather substan-
tially supported in the Congress and I
would not anticipate that the issue will
be raised in such a way, if I can get them
formulated properly, that the issues will
not be raised in such a way as to encourage
the possibility of a split along party
lines. It makes some difference the way
an issue is framed but certainly that
possibility does exist.
64
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Moderator:
A. Trakowski
U.S. Environmental Protection Agency
-------
A SYSTEMS ANALYSIS FOR SOX CONTROL TECHNOLOGY
RESEARCH & DEVELOPMENT*
G. J. Foley1, J. 0. Smith1, and W. R. Shhofield2
SUMMARY
A systems analysis of SOX stationary
source control technology is being devel-
oped with several objectives in mind:
To gather all available infor-
mation and forecasts on SOx
emissions, applicable control
technology, costs and standards
into a versatile easy-to-use system
of data and models.
To determine the economic, environ-
mental and energy impact upon the
Nation of applying the most appro-
priate SOX control technology to
existing and near future emission
sources such that standards are
met in an economic fashion.
To project and quantify the potential
benefits of possible SOX control
technology R&D on the capability
to meet standards and to assess the
economic, environmental and energy
impact of this compliance with
standards.
To allocate resources within budget
constraints toward that R&D which
has the highest potential benefit
for reasonable cost and risk.
To assist the energy generating and
consuming communities in develop-
ing environmentally and economi-
cally sound plans for future growth.
The system will include an emissions
inventory for major sources of SOX and
cost and performance models for SOX control
technologies. These technologies include
flue gas cleaning, coal cleaning, coal
conversion to gas or liquids and process
or combustion modifications. Forecasts
will be used to project the growth of the
major emission sources of SOX, to estimate
the time of availability of certain control
technologies, and to indicate the most
promising areas for R&D. The system will
be capable of determining the most appli-
cable control technology for a particular
source, and selecting an optimum design
which meets SOX standards while minimizing
cost and other impacts. For a set of R&D
programs, the system will determine and
rate the sensitivity of cost and the other
impacts to each (or combinations) of these
programs. The system can also evaluate
the impact of potential future occurrences,
such as changes in standards, energy short-
ages, and construction limitations.
A summary of the development work per-
formed to date and planned for the future
is presented.
INTRODUCTION
As required by the Clean Air Act of
1970, the Environmental Protection Agency
named SO as one of the major air pollut-
ants to Be controlled. For several years
before this, however, R&D was being per-
formed by government and private industry
to develop technologies which could be used
*Presented at Fourth Annual Environmental Engineering and Science Conference, Louisville,
^Control Systems Laboratory, USEPA, Research Triangle Park, N.C. 27711
'Senior Staff Engineer, Corporate Enaineering Department, Air Products & Chemicals, Inc
Allentown, PA 18105
66
-------
to control sulfur oxide emissions. To date,
approximately $120 million has been spent
by government and private industry on
research and development work directed at
controlling SO from stationary sources,
which account for 97% of the total SO
emissions. Over 100 different processes
have been proposed and developed, at least
to the bench scale, for removal of SO
from stack gases. Similarly, numerous pro-
cesses for removal of sulfur and sulfur
compounds from fuels and raw materials have
been investigated. Finally, modifications
of and alternatives to the combustion pro-
cess and other industrial processes have
been considered which reduce the amount of
sulfur oxide formation.
A summary of the nationwide emissions
of SOX is shown in Table 1 for the year
1971. SOX comes primarily from combustion;
i.e., the electric utilities, industrial
heating and steam raising, commercial,
institutional and residential space heating
and incineration of wastes account for 82%
of emissions.
Presently, eight technology areas are
considered to be usable for control of SOx
emissions. These are:
1. Stack gas scrubbing with throwaway
scrubbing agents.
2. Stack gas scrubbing with regener-
ation of the scrubbing agent.
3. Physical or mechanical coal
cleaning.
4. Chemical coal cleaning.
5. Production of a sulfur free In'gh-
Btu gaseous fuel (substitute
natural gas) from coal or oil.
6. Production of a sulfur free low-
Btu gaseous fuel from coal or oil
for use in an advanced power cycle
electricity generation process.
7. Production of a low sulfur liquid
fuel from coal.
8. Desulfurization of high sulfur
oi 1 s.
For each of these technologies, there are a
number of different processes in varied
stages of development, many with government
support. For example: five stack gas
scrubbing processes are being demonstrated
at pilot or commercial scale with EPA
support. Six more are in the planning or
construction phase.
Table 1. ESTIMATED NATIONWIDE SOY EMISSIONS, 1971
A
Source
106Ton*/year 106Mg/yr
Transportation
Electric utilities
Industrial combustion
Res./comm. combustion
Smelters
Sulfur recovery plants
Sulfuric acid plants
Other industrial processes
Solid waste disposal
Miscellaneous
TOTAL
1.0
20.1
4.2
2.1
4.0
0.9
0.6
0.6
0.1
0.1
33.7
0.9
18.2
3.8
1.9
3.6
0.8
0.6
0.6
0.1
0.1
30.6
3.0
59.6
12.5
6.2
11.8
2.7'
1.8
1.8
0.3
0.3
100.0
*A1though EPA policy is to express all quantities in metric
units, this paper uses a few non-metric units for convenience.
Users familiar with the metric equivalents should use the following
factors:
Non-metric
Multiplied by
Equals metric
Btu
°F
Ib
ton
ton
252.00
5/9(°F-32)
0.45
907.18
0.90718
cal.
°C
kg
kg
Mg
67
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A SYSTEMS ANALYSIS
It is clear that considerable R&D is
being performed on SOX control technologies,
and yet more will be required before the
SOX emission problem is overcome, especially
from non-utility sources. The task of
allocating R&D funds for SOX pollution con-
trol in an optimum manner is complex and
difficult. It is being done each day, how-
ever, by government and private industry.
This task is further complicated by the
rapid changes in energy availability,
national regulation and economic growth.
A flexible, versatile tool is being
developed in the form of a systems analysis
to assist in allocating R&D funds and making
other decisions in light of uncertain
future. Specifically, the system analysis
for SOX control technology has several ob-
jectives:
1. To gather all available informa-
tion and forecasts on SOX emiss-
ions, control technology, cost
and standards, into a versatile
and easy-to-use system of data and
models.
2. To determine the economic, environ-
mental and energy impact upon the
nation to apply the most applic-
able SOX control technologies to
existing and near future emission
sources such that standards are
met in an economic fashion.
3. To project and quantify the poten-
tial benefits of possible SOX
control technology R&D on the
ability to meet standards and to
assess the economic, environmental
and energy impact of this compli-
ance with standards.
4. To allocate resources within bud-
get constraints toward that R&D
which has the highest potential
benefit for reasonable cost and
risk.
5. To assist the energy generating
and consuming communities in
developing environmentally and
economically sound plans for
future growth.
A decision analysis methodology will
be used to achieve objectives 3 through 5,
which will start with an organized infor-
mation base (objectives 1 and 2) containing
today's knowledge about emissions, control
technology, costs and standards. This data
and information base is called a "determin-
istic model" because it enables a specific,
unique answer to be determined based upon
today's knowledge. The deterministic
approach fails when applied to areas influ-
enced by future variables as is the case in
R&D allocation. To assess events in 1980,
a range of values for future variables
should be considered. This can lead to
excessive computation to explore the entire
range of each uncertain future variable.
The uncertainty in the value of a
future variable can be represented by a pro-
bability curve. A ''probabilistic approach"
can then be used to determine an answer
also in the form of a probability curve.
This is computationally feasible and also
defines the uncertainty in the value of the
answer. The probabilistic approach is well
founded in the science of decision analysis
and can be implemented using the technique
of decision tree analysis. Typical
future variables should include: 1) the
availability of coal, 2) the availability
of clean fuels, 3) the cost of coal, 4) the
cost of limestone, 5) sulfuric acid de-
mand, 6) labor costs, and 7) levels of
enforcement on SOX abatement.
The systems analysis will also con-
tain an "information phase" which will
determine the benefit of obtaining better
information in terms of reducing the un-
certainty of the answer. An example of
better information would be reducing the
uncertainty in the value of a future
variable by narrowing its probability
distribution. The value of additional
information could then be compared by the
cost of obtaining it.
A SYSTEM OF DATA AND MODELS
At present, the deterministic phase
exists as a system of data and models of
emissions, control technology and costs.
The data base consists of a stationary
source emissions inventory based on 1971
data for:
1. Utility boilers.
2. Industrial boilers.
3. Smelters.
4. Sulfur recovery plants.
5. Acid plants.
The sources of the data are the EPA's
National Emissions Data System (NEDS),
which contains some confidential data ob-
68
-------
tained from industry, the Federal Power
Commission For,67 data, the National Coal
Association 1972 edition of Steam-Electric
Plant Factors, Chemico's report on Engineer-
ing Analysis of Emission Control Tech-
nology for Sulfuric Acid Manufacturing Pro-
cesses and Processes Research Incorporated's
report on Characterization of Claus Plant
Emissions.
From the SOX emissions inventory, some
statistics were generated. Six states re-
presenting 29% of the total U. S. utility
capacity contribute 54.5% of the utility
sulfur emissions. These states are Ohio,
Pennsylvania, Illinois, Indiana, Kentucky
and Michigan which are all centered around
major coal fiels of the U. S. Of the total
U. S. utility sulfur emissions, 95.4% come
from 22 states, all in the eastern half of
the country. Table 2 gives a national
breakdown of the utilities fuel consumption
in 1971. Only 7.5% of the total fuel was
burned in exclusively gas fired boilers
which would not need some form of SO
control. The remaining gas was used^in
multiple fuel boilers.
Table 2. FUEL BURNED BY UTILITIES IN 1971
Plant size
Coal
Oil
Gas
0-100
101-200
201-400
401-600
601-800
801-1000
1001-1200
1201-1400
1401-1600
1601-3000
2.11
3.02
7.68
9.29
6.37
4.58
7.03
4.02
1.91
8.59
54.60
0.65
1.57
3.07
3.52
2.33
1.69
0.68
0.60
0.95
1.05
16.11
2.89
3.06
4.62
4.66
3.03
5.15
1.21
2.04
1.09
1.54
29.29
Figure 1 shows that significant re-
ductions can be made to the national
utility SOX emissions by cleaning up re-
latively few of the largest plants. For
example, 75% of the utility SOX emissions
come from approximately 200 plants (sizes
greater than 400 MW) and 90% come from 350
plants (sizes greater than 200 MW).
The SOX emissions from the respective
smelters are shown in Table 3. Three states
contribute 65% of the total U.S. non-ferrous
smelting industry SOX emissions -- Arizona,
Texas and Montana. In addition, approxi-
mately 50% of the emissions comes from the
10 largest plants which are over 125,000
tons/year capacity whereas 75% comes from
20 plants which are over 75,000 tons/year.
There are 35 plants in the U.S. with a
total capacity of 3.6 million tons/year.
Table 3. SOX EMISSIONS FROM SMELTERS
Smelters
IP6 Tons/Year
Copper
Zinc
Lead
3.0
0.7
0.3
377
75.0
17.5
7.5
100.0
The industrial boiler emissions in-
ventory is incomplete because several major
states are missing from the data base. There-
fore no statistics are available. However,
work is currently underway to complete this
inventory.
The SOX emissions from sulfuric acid
plants depend upon type of plant, raw feed
material and type of product but are in two
forms — acid mist and sulfur dioxide. Three
southern states -- Florida, Texas and
Louisiana -- contribute 41% of the total U.S.
acid plant SOX emissions. In addition, 50%
of the emissions come from the 50 largest
plants which have over 800 tons/day capacity
and 75% is accounted for by adding the
next 50 plants over 450 tons/day capacity.
There are 251 plants with a total capacity
of 11,000 tons/day.
As with the other industries, a
significant reduction in emissions can be
achieved by cleaning up relatively few
sulfur plants. The 15 plants over 300
tons/day capacity account for 50% of the
sulfur emissions whereas the next 25 plants
of size 120 to 300 tons/day comprise the
next 25%. There are 164 plants in the U.S.
with a total capacity of 17,650 tons/day.
Six SOX technology areas have been
considered to date for inclusion in the
system. These are:
1. Throwaway flue gas cleaning (wet
limestone scrubbing process).
2. Regenerable flue gas cleaning
(WeiIman-Lord/Allied Chemical pro-
cess).
3. High-Btu gasification (Lurgi coal
gasification process).
4. Chemical coal cleaning/coal lique-
faction (solvent refined coal pro-
cess) .
69
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5. Low-Btu gasification with advanced
power cycle (Lurgi coal gasifica-
tion process).
6. Modified combustion techniques
(Westinghouse Research Labs
fluidized bed combustion process).
Detailed cost models have been developed for
the processes associated with the first four
technology areas. These technologies are all
applicable to new or retrofit installation
on combustion sources. The latter two
technologies are applicable to new combustion/
power generation facilities only. Cost es-
timates have been developed for these. The
two flue gas cleaning processes are appli-
cable to smelters, acid plants and sulfur
plants; however, the regenerable process is
more likely to be used.
The process and cost models were pre-
pared for the four processes by relating
the key process variables (design capacity,
operating rate, % sulfur, etc.) with equip-
ment sizes, utility consumption (cooling
water, process water power, natural gas and
steam), raw material requirements, and by-
products, if any. The cost models estimate
the total capital investment and the annual
operating costs. The total capital invest-
ment is a function of the key process
variables, the retrofit difficulty factor
and the location. The relationships in
these models for total capital investment
and total operating cost are shown in
Figures 2 and 3.
The cost models have been developed
using U.S. Gulf Coast 1973 costs as a basis.
In order to predict plant costs for other
locations, factors have been developed which
relate construction labor costs at various
locations to Gulf Coast labor costs. Table
4 lists the relative labor costs as
determined for twenty-one cities. Table 5
lists average location factors for each
state. Costs are generally highest in the
Northweastern quarter and lowest in the
South and Gulf areas. Total plant invest-
ment (TPI) is related to major equipment
costs, E, other material costs, M, labor
and costs, L, and location factor, F by the
following equation:
TPI = a (E + M) + b L F
when the coefficients a and b generally
range in value from 1.29 to 1.55 and 1.60
to 1.92 respectively and the higher values
represent a 20% contingency for the un-
certainty which might exist in a new process.
The cost models for the wet limestone
process and the Wellman-Lord/Allied Chemical
process were applied to utility boiler
emissions inventory to determine the capital
and operating costs to control SOX emissions
from each plant. The boilers in a plant
were visualized to be retrofitted with
scrubbing equipment beginning with the largest
boiler until the overall plant emissions
were less than 1.2 Ibs S02 per million Btu
of fuel burned by the plant. Assumptions
were made concerning load factors, fuel
split and retrofit difficulty within a
plant. The total capital required in $/KW
of plant capacity and the incremental cost
of electricity in mils/Kwh due to the stack
gas scrubbing are shown in Figures 4 and 5
for the two processes. The costs shown here
are not the costs for controlling the total
plant capacity but rather for controlling
enough boilers to meet the specified
emission level. The location factor has
been incorporated into these calculations.
The results of exercising the cost
models for high-Btu SNG (substitute natural
gas) production and for solvent refined coal
indicated that plant location and coal cost
have the largest effect on the gas cost while
percent sulfur and coal type have a slight
effect. Costs increase with sulfur content
of the coal (1-5 to 2£ per %) and increase
with decreasing coal quality, i.e. gas cost
is less for bituminous coal than for lignite.
Figure 6 gives a comparison of costs for the
two products for mine mouth plants. The
costs of SNG are given an accuracy of plus
or minus 10% or 8 to lltf/MMBtu whereas the
costs of SRC are given 30% or 18 to 24tf/
MMBtu. These accuracies are based upon the
state of development of the processes.
Cost models have yet to be developed
for the low-Btu gasification process with
combined cycle power generation and the
fluidized bed combustion process. In addi-
tion, some of the cost models need modifica-
tion to make them applicable to other emission
sources beside utilities. Cost models may
also be developed later for technologies such
as physical or mechanical coal cleaning,
desulfurization of high sulfur oils or
residual oil gasification.
70
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Table 4. LABOR COST LOCATION
Location
Atlanta
Baltimore
Birmingham
Boston
Chicago
Cincinnati
Cleveland
Dallas
Denver
Detroit
Houston
Kansas City
Los Angeles
Minneapolis
New; Orleans
New York
Philadelphia
Pittsburgh
St. Louis
San Francisco
Seattle
FACTORS FOR MAJOR U.S. CITIES
Location Factor
1.10
1.41
1.16
1.23
1.52
1.53
1.86
1.07
1.03
1.73
1.00
1.37
1.44
1.54
1.16
2.08
1.82
1.52
2.01
1.45
1.21
Table 5. AVERAGE LABOR COST LOCATION FACTORS FOR EACH STATE
State
Alabama
Alaska
Arizona
Arkansas
Cal ifornia
Colorado
Connecticut
Delaware
D. C.
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Ma i ne
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Location
factor
1.2
2.1
1.3
1.2
1.5
1.2
1.7
1.4
1.4
1.2
1.1
2.0
1.3
1.7
1.6
1.5
1.4
1.5
1.1
1.2
1.4
1.3
1.7
1.5
1.1
State
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Location
factor
1.6
1.3
1.4
1.4
1.2
2.1
1.3
2.1
1.2
1.3
1.6
1.4
1.2
1.6
1.3
1.1
1.3
1.2
1.1
1.2
1.2
1.4
1.2
1.5
1.5
1.3
71
-------
Table 6.
PRODUCTION GROWTH IN SOV EMITTING INDUSTRIES
X
Industry
Copper smelting
Zinc smelting
Lead smelting
Sulfuric acid
Sulfur recovery
1972 1960-1972
Production Growth Rate
(100 tons) (%/yr)
1.87 1.7
0.76 -0.4
0.65 4.9
31.5 4.9
1.9* 4.2
1980
Production
(10b tons)
2.40
7
0.85
46.0
2.7*
*long tons
PROJECTING INTO THE FUTURE
To achieve the objectives that were
mentioned earlier, the systems analysis
requires considerable information about the
future. This future information includes
the following:
1. Cost and availability of fuels.
2. Growth of the major SO emitting
industries.
3. Time of availability of different
control technologies.
4. R&D investment required to develop
or improve each control tech-
nology.
5. Probability of success of R&D.
6. Changes in emission standards.
7. Availability of capital.
8. Investment, fabrication and
construction lags in each industry.
Several techniques exist for forecast-
ing or predicting the future. Four
techniques have been used or will be used
in this system analysis. These are:
1. Trend extrapolation.
2. Delphi.
3. Encoding of uncertainty.
4. Impact analysis.
Trend extrapolation has been used to pre-
dict the growth of the major SO emitting
industries. For example, the tcital elect-
ric power production in the U.S. is projec-
ted to increase at the same rate as today;
that is, by 7.0% per year through 1985.
However the growth of conventional thermal
plants will drop to from 7.6%/year in the
1960-1970 period to 5.5%/year after 1980
and 4.4%/year after 1985, with nuclear
plants showing growths of 12.7%/year and
13.5%/year after 1980 and 1985 respectively.
These projections are based on historical
growth rate and do not take into account
the possibility of reduced electrical de-
mand due to energy conservation programs
or increased demand to supply environ-
mental upgrading programs.
Trend extrapolation indicates that
industrial boiler capacity growth should
be 3.5%/year viol' the breakdown being
2.1%/year for coal fired, 5.2%/year for
gas fired and 1.4%/year for petroleum
product fired. However, this does not
take into account the fuel shortages
or the possible actions to make boiler
operations more efficient as a result of
high fuel prices. Table 6 shows the
projected growth of several industries.
A panel of experts was set up and
Delphi techniques were employed to make
projections about R&D programs for SO
control which are underway or anticipated.
The Delphi technique consists of providing
the panelists with a stimulus in the f?rm
of a questionnaire which requires ther to
make projections about the future. Ine
answers must be numerical in form but
may consist of specifying the range of the
answer rather than a specific value. A
statistical analysis of the answer from
the panelists is made and this serves as
a basis for a second questionnaire. This
questionnaire is aimed at making the panel-
ists rethink their answers and revise
them toward reaching a consensus, if that
is possible. Subsequent rounds are used
to further improve the answers and reach
a consensus wherever possible.
The Delphi technique was used to con-
sider eight SO technology areas -- throw-
away and regenerable flue gas scrubbing,
high and low Btu gasification, coal lique-
faction, physical and chemical coal clean-
72
-------
ing and fluidized bed combustion. Within
each area the following subjects were
explored:
1. Applicability of the technology
to different emission sources.
2. Timing of commercial acceptance.
3. Cost and timing to successfully
complete major R&D programs
and projects.
4. Probability of success of these
major R&D programs and projects.
Some useful information was obtained by
the Delphi technique especially with
respect to the application areas, the
probability of success and some of the
timing. The Delphi forecasts of pollution
control technology usuage by coal fired
utility boilers and of markets for coal
conversion products in year 2000 are shown
in Tables 7 and 8. But on the whole, it
was not successful. The major reason for
the lack of success was that the subject
matter was too broad. The panelists were
selected so that the broad range was cover-
ed; no panelist, however, was knowledgeable
enough in all subjects. Therefore only a
few could contribute to each subject. The
broad subject matter also led to lengthy
questionnaires which required much more
time to complete and to analyze than was
originally anticipated. The overall
conclusion was that Delphi is a viable
technique if the subject matter is relativ-
ely narrow and if there is adequate time
available to complete the number of rounds
required to reach an acceptable consensus.
Table 8. DELPHI FORECAST OF MARKETS FOR
COAL CONVERSION PRODUCTS
Market
High Etu Gas
Residential
Commercial
Industrial
Other
TOTAL
Low Btu Gas
Commercial
Industrial
Utility
TOTAL
Liquid Fuel
Utility
Refinery
Other
TOTAL
60
25
14
1
1 \JU
2
24
74
100
29
6G
5
1'JO
It is currently felt that more
success may be possible by using a
personal interview of an expert by a train-
ed observer to extract future projections
and to encode the uncertainty in these
projections. A statistical analysis can
be used on the results of several interviews
to obtain the desired future information
in the form of a probability distribution.
Methods of encoding uncertainty either
require the expert to assign probabilities
Table 7. DELPHI FORECAST OF POLLUTION CONTROL TECHNOLOGY BY COAL-FIRED UTILITY 130ILERS
IfJ YEAR 2000
Control Technology
Flue gas cleaning
Coal cleaning
Combustion modifications or
advanced combustion system
Other
No control
TOTAL
Coal Consumption
(1015 Btu)
5.9
3.5
C.C
3.7
17.5
21.1
1CO.G
73
-------
to a range of values or to assign values
to a range of probabilities. However
this can be done in an indirect manner
where the expert answers a series of
simple questions which involve choosing
between two or more alternatives. The
answers are then translated into a prob-
ability distribution. It is planned to
use this technique to reinforce and supple-
ment the future information which was
obtained from trend extrapolation and Del-
phi .
The impact analysis methodology is a
technique for tracing the relationship
between future variables. This methodology
employs experts to encode the relationship
between future events that can affect a
major variable. For example, consider the
following items which would affect the
price of coal in 1980:
1. Costs of coal in 1979.
2. Wages of miners.
3. Prices of competitive fuels.
4. Demand for coal.
5. Rate of inflation.
6. Energy crisis worsening or
slackening.
7. Deep mines or strip mines.
In an impact analysis, the experts
consider the items in the list two at a
time and rate the impact of one upon the
other and vice versa. Possible ratings
would be:
1. Strongly and positively related.
2. Strongly and negatively related.
3. Moderately and positively related.
4. Moderately and negatively related.
5. Weakly and positively related.
6. Weakly and negatively related.
7. Unrelated.
The effect of one variable upon a second
would not necessarily be the same as the
effect of the second upon the first. With
this information and probability distribu-
tions for the values of each of the vari-
ables, statistical analysis can be used
to project the cost of coal in 1980 and
the sensitivity of this cost to the other
variables. This technique will also be
employed in the development of the prob-
abilistic phase of the systems analysis.
CONCLUSION
A systems analysis methodology is being
developed for evaluation and comparison
of SO control technologies and SO R&D
decision making. The system shoula be
available for use toward the end of this
year. The systems analysis will have the
following structure:
1. Deterministic phase.
a. Emissions inventory.
b. Process and cost models for
control technologies.
c. Emissions standards.
d. Fuel availability and alloc-
tion.
e. Sensitivity analysis of proce-
sses and costs.
2. Probabilistic phase.
a. Projections about future costs,
emissions and standards.
b. R&D costs, timing and prob-
ability of success.
c. Applicability and availability
of technology.
d. Impact analysis of future
variables upon one another.
3. Informational phase.
a. Value of new information and
improving existing informa-
tion.
b. Cost of obtaining new or
better information.
4. R&D allocation phase.
a. Rank R&D programs by benefit/
cost and other impacts.
b. Sensitivity analysis of R&D
timing and level of resources.
The system will be capable of determining
the most effective control technology for
a given source and select a design which
meets SO emission standards while minimiz-
ing cost and other impacts. In the alloca-
tion of resources to R&D programs, the
system will permit R&D programs to be rated
and ranked as to benefit, cost and other
effects. The sensitivity of R&D timing
and level of funding can also be explored.
ACKNOWLEDGEMENT
The Control Systems Laboratory of
the Environmental Protection Agency would
like to recognize the Monsanto Research
Corporation of Dayton, Ohio, the M.W.
Kellogg Company of Houston, Texas, and the
Stanford Research Institute of Menlo Park,
California, whose work under contract to
the EPA provided information for this
paper.
74
-------
20 40 60
UTILITIES SOX EMISSION, % OF TOTAL
Figure 1. U.S. utility industry SO
emissions.
100
MAJOR EQUIPMENT COSTS
OTHER MATERIAL COSTS
DIRECT FIELD CONSTRUCTION
LABOR COSTS
FIELD ADMINISTRATION
SUPERVISION
FRINGE BENEFITS
AND PAYROLL BURDEN
CONSTRUCTION EQUIPMENT
AND TOOLS
CONTINGENCY
Figure 2. Relationship between factors
included in total capital investment.
OPERATING LABOR
AND SUPERVISION
MAINTENANCE LABOR
AND MATERIALS
PLANT SUPPLIES
RAW MATERIALS
UTILITIES
WASTE DISPOSAL
DIRECT COSTS
PAYROLL OVERHEADS
PLANT OVERHEADS
INDIRECT COSTS
TOTAL OPERATING COSTS
DEPRECIATION
INTERIM REPLACEMENTS
FEDERAL AND LOCAL
TAXES
INSURANCE
COST OF MONEY
FIXED COSTS
3. ,'lelationsiiip ^otween factors included in the total oneratinq costs.
75
-------
100
WELLMAN-LORD/ALLIED CHEMICAL SCRUBBING
WET LIMESTONE SCRUBBING
400
800 1200
PLANT SIZE, MW
1600
2000
o
o
•a:
K-
•z.
LU
LU
CC
O
5 2
WELLMAN-LORD/ALLIED
CHEMICAL SCRUBBING
1 — WET LIMESTONE SCRUBBING
400 800 1200
PLANT SIZE, MW
1600
Figure 4. Estimated capital required to
install scrubbing on existing utilities
to meet emission limit of 1.2 Ib SCWMMBtu
of fuel burned by the plant.
Figure 5. Estimated incremental cost of
electricity for existing utilities to
meet emission standard of 1.2 Ib S02/MMBtu
of fuel burned by the plant.
76
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SOLID WASTE CONTROL TECHNOLOGY AND ITS APPLICATION
R. W. Eldredge, P.E.
Environmental Consultant
1628 Redpol1 Court
Naperville, Illinois 605^*0
ABSTRACT
Both the quantities and composition of today's solid waste are changing radically not
because of consumer attitudes, but as a result of the strict application of pollution
abatement programs. Industries are producing sludges and slurries as a result of in-house
abatement practices. Typically, these waste contain high moisture contents. The waste
products which have been removed from air and water and the water content as presented for
disposal are requiring a reassessment of the present technology of disposal and processing.
The technologies in existance have always been allowed minor emissions as a tolerable level
of operation. The emerging abatement programs combined with the potential hazards re-
presented by the industrial discharges, increasing volumes and exotic sources makes the
zero pollutant discharge criteria appear difficult if not impossible to attain. Obviously,
increased sophistication will be required of our disposal techniques or some reasonable
limitation of discharge must be established. The costs attributed to the control of solid
waste can best be described as a complex interrelationship of costs derived from the en-
forcement of air and water abatement programs. The costs are rising at an alarming rate.
The utilization of new and sophisticated technologies may do little to relieve the pro-
jected cost burden.
INTRODUCTION
The control technology for solid waste
management was represented by the most sim-
plistic of solutions until the early 1960's.
The open dump, a few incinerators and a
handfull of composting operations re-
presented the extent of the technology
offered. In fact, until the passage of the
Solid Waste Management Act of 1965, most of
the disposal technology was based on the
control of large volumes of nrlxed waste
from every conceivable source.
In most municipalities the problem was
one of logistics. The number of stops re-
quiring collection, the required truck size
for most economical operation and the
economy of volume reduction through in-
cineration or the best location to dump the
waste with least effort and least citizen
objection were the problems faced by almost
every community of any size.
The Solid Waste Management Act of 1965
supported investigation and demonstration
of new concepts and technologies. The fed-
eral act expressed the first real concern
for the environment in addition to the
logistic problems indicated. In response,
both private enterprise and public works
groups intensified their efforts toward the
development of new equipment and refined
management methods.
STATE ACTIVITIES
Probably the greatest change in the
control of solid waste came about as a re-
sult of the Act's support of state pro-
grams. Most states redirected their think-
ing, accepting a role of environmental
planning for better waste management in
lieu of the former "Fire-fighting" concept
(acting only during utmost emergency at the
behest of citizen outcry).
77
-------
Open dumps were outlawed on the basis
of the obvious presence of rodents and in-
sects and the ever present air pollution by
decomposition and fires. Some incinerators
were closed as their operation succeeded in
reducing volume at the cost of local air
quality. Many collection systems were up-
graded to include compaction type vehicles
with closed bodies to prevent litter, odor
and provide increased tonnage capacity.
The States interests in most cases re-
sulted in new legislation providing higher
standards of operation, permit procedures
and enforcement activities. These new pro-
grams emphasized the environmental aspects
of controlling solid waste and most have
relied heavily upon the related legisla-
tion which limits the emissions into the
air and waters of the State.
Air and water pollution control
practices were developed around natural
movement of air and water and the biological
and chemical changes taking place within the
element. Solid waste management principles
recognizes those same changes as evidenced
by the pollution of air and water. The
location of pollution is a direct result of
its origin, but if the production source is
solid waste, the location may occur without
relation to its real origin. The movement
is ordained by man, and unrelated to wind
or stream direction, velocity or volume.
Because of this difference in manners of
movement, State solid waste regulations
rely heavily upon the control of pollution
resulting from waste after its man-directed
movement. Air and water pollutant limita-
tions are the most frequently identified
solid waste control regulations.
POLLUTION CONTROL AND SOLID WASTE
As an example, sanitary landfill rules
are replete with statements limiting the
impact of air and water bourne emissions
from the facility. In most every instance,
the regulations require that no adverse
effects may occur, or at the very least that
those effects noted should not limit ad-
jacent aquifer uses. The results of these
obvious concerns has been the development of
concepts as encapsulation and/or treatment
of effluents from sanitary landfill sites.
The complete containment of separation of
waste for all time is much more difficult
to accomplish than it may first appear.
Storm water, ground water and moisture in
wastes as delivered complicate the process
considerably. The development of volatile
acids and gases are the common results of
anaerobic decomposition. In the presence
of biodegradable materials, moisture in any
form accelerates this action. The exclu-
sion of all water is difficult if not im-
possible to accomplish, even if partially
accomplished the elimination of water
passage may be a true example of the cup
that runneth over-eventially.
With the concern for containment comes
the further consideration of the possible
treatment of the escaping liquid. This
liquid, leachate, reflects the waste
characteristics within the fill and is pre-
sent in quantities representing the ad-
ditions received through groundwater and
precipitation. The treatment of leachate
can be accomplished as a part of community
wastewater treatment. Under those con-
ditions, the collected leachate is combined
with sanitary sewerage for treatment at the
municipal plant. As with the treatment of
industrial waste sources the compatabi1ity
of the municipal process and leachate is a
most important consideration. Treatment
plants can be upset by heavy concentrations
of metal salts. The smaller the treatment
plant, the greater the chance that leachate
may be an incompatable addition.
The alternative to the municipal treat-
ment system is on-site treatment, usually a
facility requiring the addition of lime,
settlement, acidification, and possibly
chlorination before discharge to a nearby
water course.
The result of either leachate treatment
process is a sludge, which upon removal
from the system must be deposited somewhere.
The sludge solids are returned to fill in
much the same manner as a filtrate or cen-
trate is returned to the primary stage of
the treatment plant. In truth, the process
of leaching and treating may be repeated ad
inf i n i turn.
INCREASING COSTS
Both the provision of impermeable
barriers in support of the encapsulation
concept and the provision of leachate treat-
ment to reduce the pollutional flow increase
the costs of sanitary landfill greatly.
Early estimates of typical landfill costs
78
-------
ranged from $1.25 to $1.75 a ton for well
operated sanitary fills. Membranes and
treatment on-site or in municipal facili-
ties may indeed add $1.00 or more to each
ton hauled. Costs are, of course, based on
the quantity received or managed and great
variations in overall cost are encountered
as the quantities and exact site require-
ments are varied. Suffice to say that the
added cost of water pollution control can
easily increase operating costs by 100
percent or more.
INCREASING QUANTITIES
The amount of waste received at a dis-
posal site has been estimated by various
persons for various purposes. Depending
upon the reason for the estimate, it may
include household waste, commercial waste,
industrial waste, agricultural waste, min-
ing or mineral wastes, or almost any waste
identified. This statement is fact, except
that many waste sources now appearing were
not in existence as little as five years
ago.
The impact of present day air and
water pollution control legislation has
created a new and somewhat unique waste
product pollution control sludges. These
sludges, containing those materials which
have previously been declared a pollutant,
are quite different from the wastewater
treatment plant sludges previously relegated
to landfills. They, like the leachate pre-
viously described, contain concentrated
quantities of potentially toxic materials
the reason for their removal from air or
water.
SPECIAL WASTES
Not only does the presence of poten-
tially toxic materials in concentrated
quantities present a landfill disposal pro-
blem, but the presence of moisture in the
sludges accelerates and supports anaerobic
conditions in mixed fills in a manner which
increases the volume and intensity of
leaching. Increasing sludge solids content
to approximately 50 to 60% will reduce the
leaching potential or at the very least de-
lay its occurrence. Unfortunately the costs
of increasing the percentage of solids in
sludges are not in direct proportion to the
advantage gained. Increasing percentages
of solids require increasing dollar ex-
penditures for each increment of gain.
SURVEY
OF
INDUSTRIAL
WASTES
Waste
Types
Treatment
Alternatives
From "Pretrcatmenl of Liquid Industrial Wastes"
Roy F. Vcston, Inc.
Thus, not only are greatly increased
quantities of waste to be expected, the
wastes are anticipated to be highly toxic
and of marginal composition for the direct
incorporation into a landfill using present
standards.
It is also of interest to analyse the
materials leached from the site. The in-
dustrial sludges have already been removed
from water once. Most chemical reactions
occurring during the removal are reversible
and the landfill leachate may, therefore,
resemble quite closely the industrial
sludges placed in the fill if and when the
leaching does occur.
Preparing sludges for proper disposal
in a landfill, in many instances, may re-
quire an intermediate processing to reduce
79
-------
the possibility of a reconstitut ion of the
pol1ution potent ial .
SPECIAL LANDFILLS
It has been suggested by some that
special "industrial waste" landfills may be
in order. Industrial sludge fills would be
constructed in isolated areas where isola-
tion and the high pH conditions required to
retain the metal ions and toxic salts could
be continually maintained. Locations where
acceptable geology for such disposal sites
may restrict this concept to use where
ground water supplies already are unusable
and the annual precipitation is minimal.
The State of California has developed a
landfill classification system which relies
on such practices to safely dispose of
hazardous materials. The precipitation
evaporation relationships in the West may
be of considerable value in such operations.
In most of the nation, actual locations
for such a facility can not avoid produc-
ing extraordinary total costs for transpor-
tation and disposal In summary, the
nations hazardous waste program may require
sophisticated landfill sites with leachate
collection systems combined with special-
ized transport methods to dispose of wastes
wastes which until recently have been un-
known.
SPECIAL PROCESSES
Landfills are not the only treatment of
solid wastes that will receive the brunt
of increased sludge contributions. Al-
though neither composting nor incineration
is suited to the disposal of all sludge,
both methods have been employed for that
purpose in specific instances.
Composting with municipal sludges has
been successfully demonstrated both with
municipal solid waste and select materials
such as wood chips. This process produces
a soil conditioner of rather limited nu-
trative value. Some of the major concerns
expressed are the same as those related to
the land spreading of sludge, the con-
centration of heavy metals in the soil may
occur. While trace metals can be valuable
nutrients, excessive amounts of metal ions
can be toxic to plants and animals. In-
dustrial sludges may be compatible with
land spreading and composting techniques,
but each situation requires an examination
with care and consideration. It is doubt-
doubtful that 1andspreading of raw or com-
posted industrial sludge will be accepted
on any great scale.
Incineration of some sludges will re-
duce organic content or provide chemical
combinations which through additions of
heat may establish non-soluable residues.
Where organic content can be reduced, the
pollution potential may also be reduced,
but not necessarily in direct proportion to
the energy, effort and costs expended. It
is doubtful that thermal processing methods
will be extremely popular until such time
as auxiliary fuel may be of greater avail-
ability. Municipal refuse as an auxiliary
fuel source may be of value, however, the
economics of utilizing refuse to process
sludge are closely related to the total
costs of municipal waste incineration.
The costs of incineration has been
rising due to the interest in providing new
installations with separation, salvage,
automation, air and water emission controls,
Whether the industrial sludge can be
economically incinerated may not be the
question. Without chemical changes the
sludge may be more acceptable when
"diluted" by the total incineration residue
and, therefore, incineration could become
the method of choice.
NEW DIRECTIONS FOR CONTROL
The Clean Air Act and the Federal Water
Pollution Control Act include provisions
which require the separation of contaminents
from air and water. Recent emphasis on the
control of hazardous pollutants has in-
creased the number of industries which are
required to consider processes for solids
removal usually in the form of sludges.
It may be that the concepts expressed
herein are somewhat confusing and are ex-
ceptional examples of what may occur using
present technology. I personally do not
believe that they lack realism, for many of
the instances have come to my atten-
tion through clients and fellow engineers.
The Illinois Pollution Control Board
in recent action fined both the city and
the industrial source. The Board indicated
its intent to continue to fine both the
system into which they were discharged.
These and similar actions nationwide will
alert municipalities to the acute problems
of industry.
80
-------
California has established a landfill
rating system such that wastes of high
toxicity can be disposed into secure sites
with minimal risk to the environment.
Another state has embarked upon some-
what different industrial (guaranteed high
pH) landfill concepts. In this instance,
the State required that 330 pounds of waste
per day containing .00k percent zinc on a
dry weight basis with a potential for
leaching less than 0.0165 pounds/day, to be
disposed of in a special isolated landfill.
The local landfill receiving 300 tons or
more each day was felt to be an obviously
dangerous disposal concept, as the volatile
acids in the fill might chelate the zinc
from the sludge (pH.10.5+).
Here, at a cost of thousands the
industrial waste process produced 330
pounds a day of a waste that could be dis-
posed of at a rate of less than $2.00 per
ton only to discover that the true cost
were 10 to 20 times greater - and the
alternative was to scrap the plant and use
a different process for production and
to date, none exist.
In another instance, a small oil re-
processing refinery (8 to 10,000,000 gal-
lons/year) embarked upon a industrial waste
water treatment program, only to find that
the process was too costly to continue
operation. Now those oils originally re-
claimed and refined must find their way to
disposal sites, incinerators or other less
desirable locations. The problem was not
solved it spread and a valuable resource
was lost forever. State and local of-
ficials are now desperately searching for
methods of disposing of waste oils, some
are even considering reprocessing re-
fineries as if the concept is new and
un ique.
A recent news release from an Eastern
corporation indicates that the lead removal
from the sludge left over from processing
the 100 to 150 million gallons of waste
automotive oil refined annually would yield
approximately 1% lead equal to some of the
low grade ores now mined commercially.
The corporation would like to contract
for the removal of this lead content in-
dicating that by itself it might not be a
profit making venture, however, the pro-
hibition of sludge in landfills, the serious
threat of air pollution resulting from its
incineration might justify the lead re-
clamation. A new industry or an elabora-
tion of the existing oil reclamation
industry may be in the offing.
SUMMARY AND RECOMMENDATIONS
As we approach the period in time when
zero pollution discharges are to become a
reality, a true concern for the total cost
and total processing must be maintained.
New and improved methods of returning used
materials to the environment and a reason-
able understanding of the realities of con-
trol must be established. We are seriously
deficient in our analysis of the true costs
of regulation and its impact upon our
economy. The processes may be simple, but
the implications are not.
References
1. Report to Congress on Hazardous
Waste Disposal, U. S. Environmental
Protection Agency, June 30, 1973-
2. Calspan, Buffalo, New York,
News Release, April 3, 1974.
3- Waste Discharge Requirements For
Waste Disposal to Land. Disposal
Site Design and Operation Informa-
tion, State Waste Resources Control
Board, State of California,
Novemb er 1972, Rev. December 1972.
A. "Ultimate Disposal of Residual
Liquids and Solids from Pollution
Abatement Efforts." Eldredge, R. W.
16th Annual Mtg., AICHE, March 18,
1971-
5. "Pretreatment of Liquid Industrial
Wastes", L. Scully, Assistant
Project Engineer, Roy F. Weston,
Inc., Presented at the University
of Wisconsin, March 197^-
81
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RADIOACTIVE WASTE GENERATION AND MANAGEMENT
J. J. DiNunno
A.W- De Agazio
NUS Corporation
4 Research Place
Rockville, Maryland 20850
ABSTRACT
Radioactive wastes are produced at all steps in the nuclear fuel cycle. The difficult
waste management problems are experienced at the power reactors and reprocessing plants
where fission products must be separated from effluent streams and retained for ultimate
disposal. It is at these points in the fuel cycle where the various techniques for waste
management and control must be employed to prevent adverse impact upon the environment.
For liquid radioactive waste processing, filtration, ion exchange, evaporation, and holdup
for radioactive decay are the techniques most often utilized while filtration and holdup for
radioactive decay are most frequently used to process gaseous streams. These processes
have been effective either alone or in various combinations to reduce radioactive effluents
from nuclear facilities to levels substantially below those levels existing naturally.
INTRODUCTION
The emphasis of this conference is on
Water Pollution Control Technology Assess-
ment. Yet the discussion of the manage-
ment of radioactive wastes resulting from
the use of uranium as a fuel source for
power generation does not lend itself to
the narrow category of liquid wastes.
Radioactive wastes in liquid forms do
occur, but control of these are best exam-
ined within the context of total waste
management - air, solids and liquids-
since all could have impacts on water
pollution.
Before entering into a presentation of
radioactive effluent control technology,
particularly to a group that may not be too
familiar with the nuclear fuel cycle and the
sources of radioactivity resulting therefrom,
a brief summary will be made to depict the
processes over which control must be
exercised. Emphasis will be placed upon
the power reactors since these are the
nuclear facilities proliferating at a rela-
tively rapid rate throughout the country.
THE NUCLEAR FUEL CYCLE
Commercial power reactors currently in
operation or under construction in the
United States are fueled by slightly enrich-
ed uranium; that is, fuel in which the per-
centage of the uranium - 235 isotope in the
uranium mixture is higher than the 0.7 per-
cent found in nature. The uranium ore from
the mines is processed at the uranium mills
to recover a semirefined product consisting
of uranium oxide, UgOg. This product
from the mill, called "yellowcake" is the
feed material for conversion to gaseous
uranium hexafluori.de, UFg, required by the
gaseous diffusion process. The gaseous
82
-------
diffusion process alters the relative
abundance of the isotopes in the mixture by
separating the feed material into two
streams - one enriched in the lighter iso-
topes and the other depleted of the lighter
isotopes.
In a power reactor, the uranium is in
the form of uranium dioxide pellets sealed
within zircaloy tubing. Thousands of
these fuel loaded tubes make up the reactor
core.
Up to this point in the fuel cycle all
of the radioactive waste products are those
which had existed in nature - no new radio-
active material has been created. However,
in the reactor, the fuel undergoes fission
creating lighter fission fragments, many
of which are radioactive, from the uranium.
Additionally, neutron activation of materi-
als surrounding the fuel such as impurities
in the coolant, fuel cladding, and struc-
tural materials produces radioactive
materials.
When the fuel is replaced, after per-
haps three years exposure in the reactor,
there is still a significant amount of
uranium - 235 remaining in the so-called
spent fuel elements; in addition, some
fissionable plutonium isotopes have also
been created by neutron absorption in the
non-fissioning uranium - 238 isotope
present in the fuel. These "spent" fuel
elements contain a substantial value of
unburned fuel and are transferred to re-
processing facilities for the recovery of
these values. The recovered uranium is
then re-cycled starting at the conversion
to uranium hexafluoride and the plutonium
is retained for future fabrication directly
into fuel.
Typical reactor systems operating
with the maximum design fission product
levels in the coolant would only result in
about l/1000th of the fission product
radioactivity escaping from the fuel. We
should note here that this radioactivity is
not released directly to the environment,
but is contained within the reactor coolant
system. Other systems are installed to
remove as much of this radioactivity as
possible so that only a small fraction of
the radioactivity circulating with the cool-
ant escapes to the environment.
In the fuel recovery process, the
fission products which have been so care-
fully retained within the fuel element during
its life in the reactor core are separated
from the uranium and plutonium to permit
reuse of the latter in new fuel. It is at
this stage of the fuel cycle that long term
management of radioactive wastes becomes
especially important. One metric ton of
uranium fuel will produce about 200 million
kw-hr of electric power - roughly the
annual consumption of 25 ,000 persons in
the United States. Reprocessing this
amount of spent fuel gives rise to about 0.4
to 0.8 cubic meters of high level liquid
waste or about 0.04 cubic meters of solid
waste. The typical reprocessing plant
capacity is on the order of 1 to 5 metric
tons of fuel per day. Figure 1 depicts the
nuclear fuel cycle.
SOURCES OF RADIOACTIVITY
Mining, Milling, Enrichment and Fuel
Fabrication
The mining of uranium ores is the
starting point in the production of fuel for
nuclear power plants. These ores contain
oxides or uranium in relatively low concen-
trations, mixed or combined with other
minerals. The radioisotopes associated
with the uranium ores are the naturally-
occurring decay products of uranium. The
radioactive wastes resulting from mining
are primarily those associated with air-
borne dust and the released radon and its
daughter products. In deep pit mining,
the concentration of these airborne con-
taminants is controlled by the volume of
air used in ventilation. When airborne
dusts are a problem the air may be filtered
and in special cases, if necessary, the
miners may use respirators to limit their
exposure to radiation. For a large part of
the uranium mined in the United States,
83
-------
THE NUCLEAR FUEL CYCLE
URANIUM MINES
-A MILLS
CONVERSION
TO UF6
ENRICHING
t
RECOVERED
URANIUM
r
PLUTONIUM
L
REPROCESSING
WASTE STORAGE -*-
BY-PRODUCTS
X
CONVERSION
TO FUEL
REACTOR
Figure 1. The Nuclear Fuel Cycle (From WASH 1250}
-------
open pit mining techniques are employed,
in which case the radon problem is
virtually non-existent.
The next step in preparing the uranium
for use in fuel fabrication is the milling
and concentration of the oxide. The urani-
um-bearing ores are crushed into a rela-
tively fine form in preparation for leaching
of the uranium. Since the uranium is only
a small fraction - generally less than 1%
of this material - the bulk of it remains as
tailings for disposal as both solid and
slurry wastes. The quantities of uranium
oxides and of radium sulphate in these
wastes are limited purposely since they
are valuable. The radioactivity of the
uranium is not a controlling factor at this
stage - much more important is its chemi-
cal toxicity. The solid and slurry wastes
are often deposited on a tailings pile
where leaching of radium and escape of
radon can occur. Recent trends are toward
drying these wastes and stabilizing them
with landscaping after covering them with
soil thus minimizing their movement in
the environment.
Uranium oxide is converted next into
uranium hexafluoride, which can be easily
maintained in a gaseous state as required
by the gaseous diffusion process.
Uranium from the reprocessing of spent
reactor fuels are also recycled through the
enrichment plant. Gaseous wastes from
the chemical conversion step are filtered
prior to release to the environment.
After enrichment the uranium hexa-
fluoride is converted again to an oxide
for use in the fabrication of reactor fuel
elements. Fuel fabrication gives rise to
various types of liquid, gaseous and
solid wastes which are slightly contami-
nated with uranium, its daughter products
and plutonium (when recycled materials
are used).
Nuclear Power Plants
In a nuclear power plant, radioactive
materials are formed by the nuclear
process. The principal radioactive
materials formed are the fission products.
The quantity of fission products formed is
small in terms of mass; in a large power
plant this will amount to only several kilo-
grams each day. The shorter-lived radio-
nuclides contribute substantially to the
total inventory of radioactivity in terms of
curies. After a few weeks of operation of
a power reactor, the fission product inven-
tory might be about 40% of what would
exist after a two year operating period.
More importantly, as will be explained
later, all but a very small fraction of the
radioactive fission products remain con-
fined within the fuel element where they
were formed. The quantity of fission pro-
ducts within reactor fuel elements will
depend upon: (1) the power level of the
reactor, (2) fuel residence time in the
reactor, (3) elapsed time from reactor shut-
down.
Structural materials used in the reactor
core and the components which confine the
reactor coolant will corrode and erode
slightly with time - but enough to create
fine particulates identified broadly as
"corrosion products". These corrosion
products, along with other impurities
dissolved in the coolant, circulate through
the core of the reactor, where neutron
bombardment causes them to become radio-
active. The quantities of radioactive
materials so formed are small compared
with the fission products, and consist
commonly of radioisotopes of elements
such as iron, chronium, cobalt and manga-
nese. Some type reactors use boron in
the reactor core and core coolant to control
the fission process. Neutron absorption
by boron leads to the formation of tritium,
a radioactive isotope of hydrogen. Tritium
formation also occurs as a result if water
is the coolant, or neutron absorption by
deuterium - a natural isotope of hydrogen
found in ordinary water.
Although the kinds of radioactive
wastes produced as by-products of the
fission process are basically the same for
all uranium fueled reactors the character-
istics of the effluents from plants can
vary appreciably, depending upon the
85
-------
reactor coolant and steam cycles used.
The radioisotopes in the effluent streams
in turn influence strongly the design of
particular waste treatment systems.
Objectives in nuclear power plant rad-
waste system design are to process and
recycle waste streams so as to minimize
both the volume and the radioactivity
levels of the effluents wherever practical.
WASTE MANAGEMENT TECHNIQUES
During the course of operation of a
power reactor, small amounts of the radio-
active fission products contained within
the fuel elements will escape through de-
fects which cannot be completely eliminat-
ed in the canning surrounding the fuel
material. Because of this, power reactors
are designed to operate with a certain
amount of radioactivity circulating with
the reactor coolant as a result of operating
with a small fraction of defective fuel.
The amount released, however, is a small
fraction of the radioactive fission products
contained in the fuel elements. The
released fission products initially appear
as dissolved material in the reactor cool-
ant while the activation (corrosion) prod-
ucts may appear as dissolved or suspended
material.
Waste management techniques now in
use for gaseous wastes are delay and
decay, filtration, and low temperature
adsorption on charcoal. Delay and decay
refer to the storage of waste for a long
enough time to decrease the associated
treatment problem by permitting some radio-
activity to decay before release. The use-
fulness of this technique as a means for re-
ducing activity levels in gaseous wastes
depends on the half-lives of the isotopes
pres-ent. Gases are then filtered to remove
particulate material and released through
stacks to the atmosphere. Specially
treated charcoal filter beds may be used
to remove iodine. Low temperature ad-
sorption is useful in providing delay and
decay of short-lived noble gases.
Liquid waste management systems
employ four basic treatment techniques to
reduce levels of radioactivity. These are
delay and decay; filtration, evaporation,
and demineralization. In the case of
reactors in which once-through cooling
systems are used, a final reduction in
liquid radionuclide concentrations is
achieved by dilution of the wastes in the
condenser cooling water.
The delay and decay technique used in
the treatment of liquid waste is identical
in principle to that for gaseous waste, al-
though in practice little reduction in liquid
radioactivity levels is achieved. Radio-
nuclides in liquid radioactive wastes tend
to have relatively long half-lives in com-
parison to the practicably achievable delay
time in the plant. The relatively long
delay time needed to achieve an appreci -
able reduction in liquid waste radioactivity
levels would result in an excessive inven-
tory of waste liquid onsite. It is estimated
that it would take about 40 days to reduce
the radioactivity levels of typical liquid
waste by a factor of about five.
Filtration is a useful treatment of
liquid waste streams which contain sus-
pended particulate contaminants. Filtration,
however, is employed usually in conjunc-
tion with other methods of treatment either
as a pretreatment to remove particulate
material which could interfere with or re-
duce the efficiency of a subsequent process
or as a final barrier to prevent the gross
release of activity resulting from process
failure such as the release of resin fines
from an ion exchanger. Various types of
filters are used including sand filters,
activated carbon, precoat, fibrous and
metallic filters.
Evaporation separates water from non-
volatile dissolved and suspended radio-
active wastes. This process concentrates
and reduces the volume of the wastes and
reduces the activity level of the effluent.
The efficiency of this technique for radio-
active waste treatment can vary widely
depending on the characteristics of the
-------
radioactive materials involved. A reduc-
tion of 100 to 1000 in the activity level
can be achieved, depending on the design
of the evaporator. If volatile radioactive
materials such as iodine or ruthenium are
present, the overall reduction in activity
level may be substantially less. Tritium,
of course, being incorporated as water,
would be unaffected. Evaporation is a
common method of treatment of liquid
wastes because streams having a relatively
high content of dissolved solids can be
accommodated. It is, consequently, a
suitable process for use in conjunction
with subsequent ion exchange treatment
of the distillate from evaporators .
The efficiency of demineralizers (ion-
exchangers) in the treatment of waste
streams depends on the type, composition
and concentration of waste liquid, the type
of exchange resin, radionuclides present,
and operating procedures. The reduction
achieved in activity levels may be as low
as 2 or as high as 10 . Only wastes con-
taining relatively low dissolved and sus-
pended solids can be processed by ion
exchange because otherwise bed depletion
occurs rapidly. Suspended solids tend to
clog an ion exchanger and reduce its opera-
ting efficiency. Thus, the use of ion ex-
change treatment is restricted to radio-
active wastes with low total dissolved
solids and low suspended solids. Filtra-
tion is always used as a pretreatment.
Boiling Water Reactors (BWR)
One of the two types of light water reactors
being marketed and operated on a large
scale presently is the boiling water reactor
(BWR). In this type reactor (Figure 2),
water is circulated through the reactor core
where it is heated to boiling. A pressure
is maintained on the boiling coolant so
that the boiling temperature is elevated
resulting in high-pressure, high-tempera-
ture steam which is used to drive a turbo-
generator. The exhaust from the turbine is
then cooled in a condenser and recirculated
through the reactor core. Water is used to
cool the condenser. The basic operation
of such a plant, apart from the nature of the
heat source, is similar to that of a fossil-
fueled installation.
To maintain high thermal efficiency,
turbines are operated at a low backpressure
generally on the order of 1 to 2 inches of
mercury. Hence, the low pressure end
seal for the turbine shaft is supplied with
high pressure steam to prevent air inleak -
age. The steam to the seal leaks both into
the low pressure end of the turbine and to
the atmosphere. Air inleakage, however,
is not completely eliminated from the
system, therefore, an air removal system
continually removes non-condensible gases
from the condenser. This includes any
gaseous fission products leaking into the
coolant from the fuel.
Other sources of radioactive effluents
in BWR's are reactor containment purging,
radwaste treatment system and various
other system tank vents.
A typical early BWR off-gas system is
shown in Figure 3. Non-condensible gases
are drawn from the main condenser through
steam jet air ejectors and condensers into
a delay line, where they are retained
typically for 30 minutes depending upon
design details. After this delay time, the
gases pass through a high efficiency par-
ticulate filter and are discharged through
the stack. The stack is usually about 300
feet high, although its actual height is
influenced by site topography. The gaseous
wastes consist principally of the isotopes
of the noble fission products krypton and
xenon and some activation products of
oxygen and nitrogen. The isotopic compo-
sition of the krypton and xenon depends on
the radiation characteristics of the reactor
fuel and on the age of the mixture at the
time of release, because many isotopes of
krypton and xenon have a relatively short
half-life. Radioactive particulates appear
in the gaseous waste as a result of the de-
cay of noble gas precursors and isotopes
of some of the more volatile elements, such
as iodines, will be carried over as a gas.
87
-------
TURBINE
DEMINERALIZER
HEATERS
Figure 2. Boiling Water Reactor System
A
STEAM FROM
REACTOR 1
fTURBINE|/
\/
GLAND FROM SECONDARY VENTILATION AND
LEAKAGE VACUUM PUMP DISCHARGE
HOLD-UP
~\
COSD^NSATE [CONDENSER — HZXj- HRECOMBINER^-\/^ »
RETURN TO * .cj-rno CONDENSER
REACTOR EJECTOR OFF GAS
HOLD-UP
t
P
C
A
-
S
T
A
C
K
-il
E--'-,-1
P- ROUGHING FILTER
C- CHARCOAL ADSORBER
A- HEPA FILTER
Figure 3. BWR Gaseous Waste System (From WASH 1250)
-------
Table 1 shows the typical mixture of
BWR off-gases after a 30 minute delay.
Note that much of the activity release is
represented by nuclides with relatively
short half-lives.
In the latest BWR designs, provisions
are being made to greatly reduce the dis-
charge of these short half-lives.
In the latest BWR designs, provisions
are being made to greatly reduce the dis-
charge of these short-lived noble gases.
This is accomplished through use of char-
coal beds (Figure 4) to delay the noble
gases for a considerably longer time to
permit substantial radioactive decay. This
has little influence on release of krypton
85 at the reactor site since this radio-
nuclide has a half-life of about 10 years,
but its contribution radiation in the
vicinity of the plant is negligible. Table 2
shows the typical releases from the latest
BWR off-gas systems.
A typical BWR liquid radwaste process-
ing system is shown in Figure 5 . The
unique feature of this system is the segre-
gation of wastes by chemical and physical
properties. Influent is collected and
processed according to its classification
as high-purity (equipment drains), low-
purity (floor drains), and chemical or
laundry wastes. Contents of equipment
drains are filtered and demineralized, and
can then be either used again in the plant,
or measured and discharged. Plant floor
drains, chemical wastes and laundry
wastes are filtered and discharged from the
plant. Since the laundry wastes tend to
foul filtering media, they are processed
separately through their own filter.
The constituents of radioactive liquid
waste from a BWR are activated corrosion
products, and fission products. The
fission product levels are attributable to
traces of uranium that may be found on the
outer surfaces of the fuel cladding and to
leakage from fuel elements through cladding
defects. The relative contribution of leak-
ing fuel elements depends, of course,
directly upon the number of leaking fuel
rods and the severity of the breaks.
The major sources of solid radioactive
wastes at BWRs are contaminated filters,
precoat filter media and spent demineralizer
resins. These wastes are first centrifuged
to remove excess water then solidified with
concrete in 55 gallon steel drums. The
drums are normally stored three to six
months before shipped offsite for permanent
burial. Several hundred are shipped each
year from a typical BWR installation.
Pressurized Water Reactor (PWR)
In a pressurized water reactor, PWR (Figure
6), the reactor coolant is not allowed to
boil. Instead, the high temperature, high
pressure liquid is pumped to a steam
generator where heat is transferred to water
contained in a separate circulation loop.
The water in this sytem is allowed to boil
producing the required motive steam for the
turbo-generator. Since the entire reactor
coolant system is maintained at high
pressure, there is no requirement to con-
tinually remove non-condensible gases
from the coolant and consequently the
residence time of dissolved gases in the
coolant is considerably longer than in a
BWR.
Gases are removed from the PWR cool-
ant by reducing the temperature of a side
stream and relieving the pressure. The non-
condensible gases relieved are collected in
a vent header and led to the gaseous waste
processing system.
A typical early PWR gaseous radwaste
system is shown in Figure 7. The waste
gases from various sources are collected
in a vent header and discharged by a waste-
gas compressor into one of several decay
tanks. When a tank reaches a set pressure
and activity level it is isolated and a
second tank is placed in service. Gas is
held for decay for from one to two months
before being discharged through a filter to
89
-------
TABLE 1. TYPICAL BWR OFF-GAS MIXTURE USING 30 MINUTE HOLDUP*
Nu elide
Half-Life Range
Release Rate
Kr-89
Xe-137
Xe-135m
Xe-138
3.2 to 17 minutes
35,790 ^Ci/sec
Kr-87
Kr-83m
Kr-88
Kr-85m
1.3 to 4.4 hours
41,430
Xe-135
9.2 hours
17,550 jiCi/sec
Xe-133m
Xe-133
Xe-131m
2.3 to 12 days
5,220 ^Ci/sec
Kr-85
10. 4 years
10
TOTAL 100,000 nd/sec
Adapted from information published by J.M. Smith, November,
1960.
STEAM FRO:,;
REACTOR
CCNO£NSATE
RETURN TO
REACTOR
GLAND
SEAL
LEAKAGE
HOLD-UP
CONDENSER
OFF GAS
HOLD-UP
P- ROUGHING FILTER
C- CHARCOAL ADSORBER
A- HEPA FILTER
Figure 4. Modified BWR Gaseous Waste System
90
-------
_TABLE 2. TYPICAL BWR OFF-GAS MIXTURE USING CHARCOAL DELAY SYSTEM*
Nuclide Half-Life Range Release Rate
Kr-87
Kr-83m
Kr-88
Kr-85m
Xe-133m
Xe-133
Xe-131m
84 Kr-85
1.3 to 4.4 hours 179 pCi/sec
2.3 to 12 days 573 ^Ci/sec
10. 4 years 10 /iCi/sec
TOTAL 762 fid/sec
Assumes about 50 tons of charcoal at 70F yielding 24 hour holdup for Kr
and 16.6 days for Xe. Gas to holdup system same as for Table 1.
COS?SRASGAETEl-»RECrCLE
FROM
EQUIPMENT -
DRAINS
FROM
PLANT
FLOOR
DRAINS
COLLECTOR
FOR HIGH
WASTE
FROM LAB
DRAINS AND
DECON-
TAMINANTS
FROM
LAUNDRY.
DRAINS
»
— •
PURITY
*aSTE
FLOOR DRAIN
WASTE
COLLECTOR
CHEMICAL
WASTE
COLLECTOH-
NEUTRALIZER
r
FILTER
DEMIN-
ERAUZER
— » SAMPLE
TANK
© ©
FILTER
• ©
1
i
r*
.
LAUNDRY
(DETERGENT)
DRAIN TANKS
(21
-
FILTER
OEMIN- /
ERALIZER^
/it a i it/ /L
\ —
'»ii 1 1 f 1 1
: EVAPO-
' S4MPLE
— •' TANKS
/ (2)
////// ///
S
iin/li/
' |_ CONDENS
' , TAN
i '//////
©
1
1
^
rn
.ATE'
< '
/ / /,
S SAMPLING POINT ^-'
(T) SOLID WASTE TO PACKAGING
f"J ADDED FOR MAX RECYCLE
R RADIOACTIVITY MONITOR
CANAL
Figure 5. BWR Liquid Waste System (From WASH 1250)
91
-------
TURBINE
PRESSURIZER
CORE
HEATERS
Figure 6. PWR Reactor System
PRIMARY COOLANT
SYSTEM OFF-GAS
. RECYCLE TO PRIM.
COOLANT SYSTEM
AIR SUPPLY
CONTAINMENT BUILDING
P-ROUGHING FILTER
C-CHARCOAL ADSORBER
A-HEPA FILTER
Figure 7. PWR Gaseous Waste System (From WASH 1250)
92
-------
the environment from a building vent.
Since these gaseous wastes are small in
quantity and contain minimal activity,
dispersal from an elevated stack is not
necessary.
In the newer systems, the decay
tanks have been replaced by charcoal delay
beds resulting in significantly longer delay
times. The newer systems also process
the effluent from the condenser air removal
system to delay any radioactive gases
which might leak from the reactor coolant
to the steam system at the steam genera-
tors. Table 3 shows typical PWR gaseous
releases.
A typical PWR liquid radwaste system
is shown in Figure 8. Wastes from various
sources are collected in separate tanks
and, when ready for processing, are dis-
charged to the waste-holdup tank. This
tank serves primarily as a batching tank
for the waste evaporator. The distillate
from the evaporation process is condensed
and stored in a condensate storage tank
before discharge from the plant. The con-
centrates are collected and stored for
processing through the solid radwaste
system.
Wastes which consist primarily of
reactor coolant, are collected in holdup
tanks . After filtration and demineralization
of these wastes the boric acid evaporator
serves primarily to recover boric acid and
primary grade water. The boric acid evap-
orator condensate, after being filtered and
demineralized, can be recycled to the
primary coolant make-up tank or measured
and released to the discharge canal.
Solid radioactive wastes from a PWR,
although they may differ somewhat from
those collected in a BWR are generally
handled in the same manner. That is, by
encasing or solidifying with concrete in
steel drums which are then buried.
EVALUATION OF CONTROL TECHNOLOGY
Previous sections of this paper have
briefly touched upon the sources of radio-
active effluents and the basic control
methods used to minimize the amounts of
these releases to the environment. How-
ever, we have said little about the ability
of these control methods to remove and
minimize. Unfortunately, there is relative-
ly meager data regarding the performance of
such systems and what little data that
does exist is frequently contradictory. For
example, an examination* of operating
data for several pressurized water reactors
revealed overall decontamination factors
for liquid wastes (defined as the ratio be-
tween the activity that would have been
released if there were no waste processing
and the activity actually released) which
varied from less than 200 to more than
250,000. Even more disconcerting, how-
ever, is the fact that the low value was
obtained from a plant which became opera-
tional nearly eight years later than that
which resulted in the highest value of
decontamination. This study was done in
1972. Today, the AEC requires more
detailed reporting of the isotopic content
of wastes discharged. Hopefully, this
will yield some data which will be useful
in predicting system performance under
various operating conditions.
The regulations governing the quantities
of radioactivity in reactor effluents allow
nuclear power plants to contribute, at most,
an exposure increase to any individual only
a few percent above that which the individ-
ual might get due to normal background.
(These backgrounds vary more than a few
percent from location to location). The
USAEC regulations require that nuclear
power plants be designed, constructed and
De Agazio, A.W. "Fact and Fiction
About Waste Disposal Systems",
Presented at the American Nuclear
Society Meeting, Las Vegas, Nevada.
June 18-22, 1972.
93
-------
TABLE 3. TYPICAL PWR GASEOUS RELEASED
Nuclide Release^ Ci/vear
Kr-85m
Kr-85
Kr-87
Kr-88
Xe-131m
Xe-133m
Xe-133
Xe-135m
Xe-135
Xe-138
TOTAL
3.6
285
2
6
11.6
2.6
158
1.2
9.2
1.2
480 curies/year
Assumes charcoal holdup system
providing about 3.5 days Krypton delay
and 67 Xenon delay; 7 tons charcoal
at 70F-
operated so as to keep levels of radio-
active materials in effluents as low as
practicably achievable. Further, to assure
that such releases are as low as practi-
cable, each license authorizing reactor
operation includes technical specifications
which govern the release of radioactive
effluents. Currently, most specifications
typically limit the average annual release
of radioactivity in liquid effluents to 5
curies, excluding tritium although these
specifications are flexible and allow for
periods of higher than average release due
to equipment malfunction. Table 4
summarizes the mixed fission product and
activation product discharge in liquid
effluents by operating reactors for the
years 1970 to 1973. This table demon-
strates that the technology exists to con-
trol radioactive releases in liquid effluents
to very low values. Separate pathway
analysis for exposure of man and other
living organisms to these effluents indi-
cate that the radiation impact to the bio-
sphere is acceptable and commensurate
with the benefits derived from the availa-
bility of electric power.
94
-------
• OEMINERAUZER]
EQUIPMENT
DRAINS '
B LOWOOWN
*
TO
DRUMMING
STATION
-HOEMINERALIZER
RM)
RECYCLE
•DISCHARGE
J
RECYCLE
f
WASTE
MONITOR
TANK
l
LABORATORY
DRAINS,
DECONTAMINANTS
TO
DRUMMING
STATION
SPENT
RESIN
STORAGE
TANK
1 C 1
RECYCLE
FLUSH WATER
TO
REACTOR
COOLING
SYSTEM
REACTOR
MAKEUP
WATER
STORAGE
TANK
DISCHARGE
FILTER
RADIATION
MONITOR
Figure 8. PWR Liquid Waste System (From WASH 1250)
95
-------
TABLE 4. LIQUID EFFLUENT COMPARISON BY YEAR
Mixed Fission and Activation Products
Curies
Facility 1970
Boiling Water Reactors
Oyster Creek 18.5
Nine Mile Point 28.0
Millstone 1
Dresden 1 8.2
Dresden 2,3
LaCrosse 6.4
Monticello
Big Rock Point 4.7
Humboldt Bay 2 . 4
*Pilgrim
Quad Cities 1,2
*Vermont Yankee
Pressurized Water Reactors
*Maine Yankee
Palisades
Yankee 0.03
Indian Point 1 7.8
R.E. Ginna 10
Connecticut Yankee 6 . 7
H.B. Robinson
San Onofre 7.6
Point Beach 1,2
*Surry 1
Nonwater Reactors
Peach Bottom 1 0.006
Fermi
1971
12.
32.
19.
6.
23.
17.
0.
3.
1.
-
-
1
2
7
2
2
1
01
5
8
1972
10.
34.
51.
6.
22.
48.
2.90 x
1.
1.
1.
2.
0
6
5
75
1
5
-6
10
09
4
45
41
None
-
-
0.
81.
0.
5.
0.
1.
0.
-
0.
0.
01
1
96
9
74
54
15
007
01
0.
6.
0.
25.
0.
4.
0.
30.
1.
0.
0.
0.
0169
81
0206
4
375
78
862
3
53
0252
0209
222
Plants operated less than 1 year.
90
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HAZARDOUS WASTE MANAGEMENT
W. H. Swift
Battelle Memorial Institute
Pacific Northwest Laboratories
P.O. Box 999
Richland, Washington 99352
ABSTRACT
A recent program conducted for the Office of Solid Waste Management Programs of the
Environmental Protection Agency in response to Section 212 of the Resource Recovery Act
of 1970 is summarized. The program dealt with the evaluation of the need for a system of
national disposal sites, the technology required, the cost involved on a national scale,
and policy options for implementation.
INTRODUCTION
Over the past three years, the Envi-
ronmental Protection Agency has been in-
volved in responding to Section 212 of the
Resource Recovery Act of 1970. This sec-
tion raised a number of questions which
included the need for:
1. A list of materials that should be
regarded as hazardous in the context
of disposal;
2. An evaluation of current disposal
methods;
3. Recommended methods for reduction,
neutralization, recovery, or
disposal;
4, Inventory of possible sites; and
5. An estimate of cost including the
best means for equitable distribu-
tion of this burden.
Also in Section 212, the Congress
defined hazardous wastes to include "...
radioactive, toxic chemicals, biological
and other wastes which may endanger public
health and welfare." This rather terse
definition leaves much to be desired from
the standpoint of management and regula-
tion of hazardous wastes.
Finally, the Congress asked for a re-
port and a plan for the creation of a sys-
tem of national disposal sites, apparently
with the idea in mind that the Federal
Government is itself a major producer of
hazardous materials, e.g., chemical and bio-
logical warfare agents, obsolete munitions,
etc.; and that overall, the problem was of
such magnitude that a national approach
was called for.
EPA's response to the mandate in Sec-
tion 212 has gone forward to the Congress
as a report(1) and the proposed Hazardous
Waste Management Act of 1973. This paper
summarizes some of the highlight findings
associated with the study leading to the
report to the Congress.
THE NATIONAL DISPOSAL SITES STUDY
At the outset, it is important to
note that Section 212 is not the only re-
cent Congressional reference to hazardous
materials. For example, the Federal Water
Pollution Control Act Amendments of 1972
contain Section 307 dealing with toxic and
pretreatment effluent standards and Sec-
tion 311 relating to oil and hazardous
substances liability. Congress also in
1972 passed the Environmental Pesticides
Control Act and the Marine Protection Re-
search and Santuaries Act, both containing
reference to the problem of hazardous
wastes. Proposed legislation is also in
the Congress relating to regulation of
toxic substances.
Thus it is apparent that the nation
as a whole is expressing rather broad con-
cerns in the area of hazardous materials
and wastes.
97
-------
Study Overview
As mentioned previously, Congress did
not provide a definition of "hazardous" in
the sense of a definition that could be
utilized as a working tool either for iden-
tifying a hazardous waste, for designing
treatment processes or disposal methods,
or for development of regulatory programs.
The problem in definition arises
firstly from the fact that the term
"hazardous" is inherently a relative as
opposed to an absolute term. A second
difficulty is that we recognize many types
of hazards:
1. Flammability - usually an acute
rather than a chronic hazard, but
under certain circumstances can be
latent in a disposal operation.
2. Reactivity - either directly as an
explosive or indirectly as in com-
bination with a second material.
3. Toxicity - to humans, to animals,
and to plants, either terrestrial or
aquatic. Note here also that toxi-
city can manifest its action via a
number of pathway and exposure
mechanisms, e.g., inhalation, dermal
contact, ingestion.
4. Radioactivity - ionizing radiation
in general.
5. Bioconcentration - not a hazard in
itself, but can be highly signifi-
cant as experience with certain
heavy metals suggests.
6. Irritation and Allergenic - skin and
mucous membrane exposure.
7. Genetic Activity - carcinogenic,
mutagenic, and teratogenic.
In addition to the term "hazardous"
being a relative one, it has two distinct
connotations one of which relates to the
intrinsic nature of the waste or material
itself, or the amount of damage it can do-
to man and the environment. The second
connotation relates to extrinsic factors
such as the degree of exposure including
quantity, behavior, delivery mechanisms,
and circumstances surrounding exposure.
In the intrinsic connotation, the informa-
tion required for assessing the degree of
hazard is specific to the waste; in the
extrinsic connotation, the assessment is
dependent upon the individual waste manage-
ment or disposal systems.
That people have struggled with the
classification and designation is evidenced
by the fact that in 1970 there were more
than 30 classification systems addressed
to hazardous materials during transporta-
tion operations alone and, in general, none
of these fully addressed human and envi-
ronmental protection in any complete sense.
As an initial step, development was
undertaken of a model that would enable
the decision as to whether a waste was
hazardous or not. Figure 1 illustrates
the logic by which it is possible to come
to some rational judgment as to when a
waste should be considered. In effect, the
model consists of a series of screens, one
or more for each mode of hazard. The mesh
size of the screens are set based upon
past experience and upon generally accept-
ed available standards for public health
and environmental protection.
A note of caution is in order:
unfortunately, the majority of the availa-
ble quantitative information on hazard
properties refers to relatively pure com-
pounds and generally not to practical
waste materials.
The above rationale does not take in-
to account the extrinsic factors mentioned
earlier, e.g., quantities involved, degree
of population exposure, etc. It should be
apparent that simplistic application of a
designation system independent of the ex-
trinsic factors would result in adminis-
trative and regulatory chaos. As a conse-
quence, some priority-of-concern must be
inserted into the system.
In addition to the basic questions of
designation and priority, the management
of hazardous wastes involves a number of
other technical, economic, and administra-
tive issues that distinguish it from other
solid waste problems. The technical
issues are:
1. Wastes are Mixtures - and the hazard-
ous ones are no exception. The dif-
ference, however, is that the hazard-
ous constituent may constitute only
a small fraction of the total
quantity.
2. Multiplicity of Sources - generation
of public and private sources.
3. Time Dependence - wastes will vary
with industrial technology and per-
haps most particularly with
98
-------
FIGURE 1
GRAPHIC REPRESENTATION OF THE
HAZARDOUS WASTE DECISION MODEL
WASH STREAMS
DOES WASTE CONTAIN
RADIOACTIVE CO'-STITUTES
>MPC LEVELS?
NO
IS WASTE SUBJECT TO
EtlOCO\Ct\TRATION?
I NO
IS WASTE FiAW.VteiLITV
INNFPA CATEGORY 4?
NO
IS WASTE REACTIVITY
IN NFPA CATEGORY f>
NO
DOES WASTE HAVE AN ORAL ID
< SO mo 'I7
NO
1 S WASTE 1 IvHALATI ON TOX 1 C 1 TY
-------
2. The role of regulation - regardless
of what implementation option is
elected, it is apparent that a regu-
latory element must be involved if
the system is to work at all.
3. Perpetual Case - in certain instances
it may be impossible to completely
inert a hazard and administrative
provision must be made for storage
in perpetuity.
4. Finally, there is already some con-
siderable private involvement in pro-
cessing and disposal of hazardous
wastes and private industry is by far
the largest producer of these wastes
and hence the benefactor of the
operations resulting in their genera-
tion. Thus, the administrative sys-
tem must include major private
sector involvement.
In working with these issues, Battelle
undertook initially to develop a national
picture of how much and what types of hazar-
dous wastes should be of concern. This
effort extended particularly along the
lines of trying to characterize how wastes
appear in the real world. Radioactive
wastes were also covered in the study but
present a distinctly different problem of
less general interest.
It was concluded that the aggregate
quantity of nonradioactive hazardous wastes
being produced today in the United States
amounts to approximately 10 million tons
annually. These wastes include miscellane-
ous inorganic compounds, halogens and inter-
halogens, miscellaneous organic materials,
pesticides, and organo-halogen compounds.
Present and potentially applied hazard-
ous waste mangement methods, including pro-
cessing and disposal, were also evaluated
(a total of some 39 physical, chemical, and
biological processes were included) leading
to selection of nine physical/chemical pro-
cesses. Biological processes were rejected
because of the toxic nature of hazardous
wastes and the expected variable chemical
character and throughput which would tend
to continuously upset such operations. The
processes finally selected include:
1. Neutralization (of acids and bases)
2. Oxidation (of cyanides and other
reductants)
3". Reduction (of chromium-6 and other
oxidants)
4. Precipitation (removal of heavy
metals)
5. Flocculation, sedimentation, and fil-
tration (for separation of solids
from liquids
6. Carbon sorption (removal of organics)
7. Incineration (of combustible wastes)
8. Ammonia stripping (for ammonia
removal)
9. Evaporation (concentration of waste
brines).
On a national basis, and using the
above processes, a model processing facili-
ty design was developed and estimates pre-
pared of capital and operating costs. In
practicality, it is expected that plant
sizes, specifics of design to accommodate
feed stocks peculiar to the service area,
and geographic distribution will evolve as
a consequence of market forces. A reasona-
ble prediction, however, is that the natio-
nal needs can be met in the near term with
five large-sized and fifteen medium-sized
processing plants. On this basis, the
overall national costs will be about $800
million in capital investment and about
$580 million per year for operating costs.
Disposal methods for liquid and solid
wastes generated by the processing facility
include ocean dumping and deep well injec-
tion for liquid brine wastes which do not
contain hazardous constituents and land-
filling for solid wastes. Landfills con-
sist of two types: 1) secured landfills
especially designated for the disposal of
sludges containing significant concentra-
tions of hazardous substances (e.g.,
arsenic), and 2) conventional landfills for
burial of solid wastes which do not contain
significant concentrations of hazardous
substances. Perpetual surveillance must be
maintained over the secured landfill as in
a radioactive waste burial site.
Figure 2 illustrates the model overall
process flow diagram. Typical investment
for such a plant would be about $24,000,000
with an operating cost of about 20 cents per
gallon of waste received and incineration
cost of about $175 per ton.
In addition to the engineering work
described, examination was made of the ques-
tions of plant siting and financing consi-
derations, and federal and state legislation
and regulations, and our findings are in-
cluded in the final report.(2)
100
-------
FIGURE 2
CONCEPTUAL MODULAR FLOW DIAGRAM
DISTILLATE WITH AMMONIA
GASEOUS
WASTE TO
ATMOSPHERE
Status of Technology
In the main, the process technology
for the management of hazardous wastes
currently exists. However, certain techni-
cal aspects require further resolution.
These include:
1) The impact of air and water regula-
tions on residuals management is
unclear.
2) Improved criteria are required for
ultimate disposal and perpectual care.
3) Disposal site evaluation and selection
criteria need to be more adequately
developed.
4) Better means for accommodation of non-
hazardous residuals need to be
formulated.
References
(1) Report to Congress on Hazardous Waste
Disposal, U.S. Environmental Protec-
tion Agency, June 30, 1973.
(2) Program for the Management of Hazardous
Wastes. Report Prepared for the U.S.
Environmental Protection Agency, July
1973.
101
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INDUSTRIAL CONTROL TECHNOLOGY & THE 1972 WATER POLLUTION CONTROL ACT
C. F. GUARINO
Commissioner, Phila. Water Department
1180 Municipal Services Building, Philadelphia, Pa.
ABSTRACT
A summary of recently enacted regulations is given with a discussion of their
effects on the operation and expansion of Philadelphia treatment plants. The discus-
sion is directed to portions of the Act where additional research seems necessary to
ensure adequate, but reasonable, environmental management. Areas of possible con-
flict with other environmental laws are also pointed out. The potential impacts on
Philadelphia of eliminating ocean dispersal are also presented. Philadelphia has pro-
jected both potential cost effects and environmental effects of such action. One such
result could be considerable delays in plant upgrading due to the lack of a viable alter-
native in the highly populated Philadelphia area.
INTRODUCTION
After reading the information con-
cerning this meeting and its purpose, I
concluded that I should speak here today
in an effort to contribute the municipal
viewpoint.
TEXT
As a municipal spokesman, then,
the idea of the conference is good and cer-
tainly needed. The conference is asking
'Do we have the technology to meet out
needs' ? and I am assuming that the needs
are not simply the requirements of the law
but the requirements for achieving a prop-
er quality in the Nation's waters. Further,
if we do not have the technology, where
are we short and what do we need to do?
The fact that this meeting is being
held at Battelle and jointly sponsored by
the Cincinnati group of the EPA leads me
to believe that this is a way of ascertain-
ing whether present research efforts are
adequate and, if not, what type of re-
search should be done in the future .
I am certainly grateful for this
opportunity to participate and relay some
thoughts and I have many concerning
the laws, present technology, and what I
feel we need now, as well as in the future .
I must admit that I am surprised
by many facets of PL 92-500, the major
water law, and PL 92-532, which is the
Marine Protection and Sanctuaries Act.
Perhaps many of you have not felt
the impact of the Marine Act, but those
municipalities that are close to the
ocean or have the advantage of dispersing
sludge at sea have been influenced by
this law. The law seems to contain con-
tradictions which could drastically change
the method of sludge disposal used by
coastal cities, all to the detriment of
the environment.
102
-------
All of us in the field must have
studied these major laws and attempted
to explain to ourselves their necessity,
or more simply, how they came to be
written as they are. I believe that all of
us - whether we agree or do not agree,
generally speaking, with all the facets of
the law have concluded that the laws are
necessary, despite any faults, and a giant
step towards halting many abuses of our
natural resources and producing a better
place for us and our children to live.
It is my feeling, however, that the
laws are a result of the impatience of
both Congress and the general public for
progress in cleaning up the environment.
Many of the inadequacies come from a
desire for a common denominator in
order that the laws can be implemented
nationally.
Unfortunately, the common denom-
inator concept ignores many things that
we as engineers or scientists have learned.
Most important of these is that all streams
are not equal and that all streams as well
as other bodies of water, be it lakes or
the ocean, need not be treated equally.
It is also apparent that the laws are
so ambitious in their attempt to be com-
plete that they have actually handicapped
their own implementation. I feel this way
because the EPA, in attempting to follow
the letter of the laws, has found it necess-
ary to prepare very intricate and time-con-
suming requirements thus making imple-
mentation of the laws very difficult.
It is not my intention to dwell too
much on the laws, but it certainly would
have been dishonest of me not to tell you
of the need for clear laws and simpler,
uncomplicated regulations. As it stands
now, people like myself, whose responsi-
bility it is to follow the law, are not able
to do so.
They say that one picture is worth
a thousand words. Not too long ago, as
shown in Figure 1, if I were required to
build a treatment plant, I would simply
write for permission from the State, re-
ceive a reply and a permit, and construc-
tion would begin. Now the procedure is
somewhat like that represented in the
'rat maze1 shown in Figure 2. I wish to
remind you that, as the figure states,
this is only part of what is actually re-
quired.
I don't blame any one agency for
this, it just seems that to correct a mis-
take in the past, we must now check with
every agency that has some relationship
with plant construction before we can pro-
ceed. The odds of clearing through all
of these agencies unscarred and un-
thwarted are remote. There is always
someone against something no matter how
noble it may appear to be.
It is ironic to us in trying to build
treatment plants that while I have plans
and specs ready to advertise for $100
million of work towards cleaning up the
Delaware River, I can't do so because
there are so many handicaps from in-
filtration/inflow analyses to an environ-
mental impact statement which must be
cleared. I know there is some justifica-
tion for all this, but the net result is a
slowdown.
Concerning technology assessment,
I will try to summarize what we have done
and what we are doing in Philadelphia. I
would like to tell you some of our problems,
as well as the problems we will have to
solve, in attempting to both implement the
law and to improve the quality of the en-
vironment. I say that because they aren't
always the same.
All dischargers into the Delaware
River have received an allocation. This
was determined, by a mathematical model,
to be the amount of carbonaceous BOD
the river could take at the discharger's
point of entry and still enable the river to
meet the quality and use requirements.
Figure 3 gives the allotment of all
three Philadelphia plants. What should be
noted here is that, even though the basic
103
-------
1
3
TECHN,CAL REVIEW
CONSTRUCTION
OVERSIMPLIFIED VERSION
OF HOW TO BUILD A
TREATMENT PLANT
TE ENVIRONMENTAL
— ASSESSMENT
STATEMENT
MOVING FflST ENOUGI
"3
H-
8
COMMONWEALTH OF PA.
DEPT. OF HEALTH
i
REQUEST CONSTRUCTION
PERM IT
RECEIVE CONSTRUCTION
PERMIT
CITY OF PHIL A.
WATER DEPT
FORMER BUREAUCRATIC SYSTEM
UNOX PILOT PROGRAM RESUJS-&W 8 S.E.
PHASE SEWAGE RTq F/M MLVSS EFFLUENT % REMOWLs"
SOURCE (Hli) (PPlTl BOO SOL 600 SS BOD SOL BOD SS
<§
DRBC ALLOCATIONS
1 SOUTHWEST 1.6 0.45 3450 6 18 89 90 84
II SOUTHWEST 1.0 0.94 2830 15 10 20 85 82 84 PLANT CARBONACEOUS
OXYGEN DEMAND
HI SOUTHWEST 0.8 155 25OO 17 19 87 83 80 NORTHEAST 69,300
SOUTHEAST 33,200
1 SOUTHEAST 1.2 0.83 2660 9 6 19 91 89 78
SOUTHWEST 37,300
BODs
40,500
19,400
21,800
II SOUTHEAST 0.7 1.87 2110 7
7 93 93 91
BOD5 (mg/l) REQUIRED TO MEET ALLOCATION IN 1990 S.E.-I7 S.W-12
* REMOVALS FOR SECONDARY PROCESS ONLY
-------
law at this point in time requires second-
ary treatment, regardless of what per-
cent you remove, you must keep the qual-
ity of your discharge below the point where
it will adversely affect the river. As time
goes on, I believe we will see more of
this type of river quality control. After
all the river does not recognize 5-day BOD
it recognizes total impact BOD. It follows
that you cannot apply the success formula
from some other city, be it New York or
Chicago, to Philadelphia due to differences
in the quality and capacity of the receiving
streams.
We conducted a series of pilot plant
studies which are still in progress today.
Figure 4 will give you some results of
this pilot plant work and based on these
results, we have chosen for two plants
the Northeast and Southwest Plants -
the Unox or oxygen process over the con-
ventional or chemical-physical treatment.
We have operated pilot plants at all
treatment plants and have found that the
wastes from various sections of the City
respond differently. This shouldn't sur-
prise anyone, but it should certainly
alert us that the choice of treatment is
risky if you do so from a text book or
simply from the literature.
Philadelphia industry has a big im-
pact on the waste of the Northeast and
Southwest Plants, but in spite of that the
Unox process was able to accomplish very
good removals. The oxygen process has
many advantages as shown in Figure 5.
However, the oxygen process as well
as the conventional methods do require a
lot of power; that is, 45 KW per 100 Lbs.
BOD removed. The energy crisis has ac-
cented the need for a process that requires
a minimum of maintenance and supervision
Accordingly, for the last several years,
we have piloted different size rotating
units. Figure 6 is a schematic diagram
of the process.
We have tested these at all the
plants and at the present time, we have a
large scale pilot unit in operation at the
Southeast Plant. The rotating contactor
required 34 KW per 100 Lbs. BOD re-
moved. Although I have not come to a
firm conclusion, my feelings are very
strong that I will choose a rotating con-
tactor for the Southeast Plant. The plant
will have a capacity of 140 MGD. As the
results in Figure 7 show, we were able
to surpass removal levels experienced
by the Unox process.
INSTRUMENTATION & AUTOMATION
Instrumentation and automation of
the treatment process will produce a
uniform effluent. Figure 8 shows what
can be accomplished once the process has
been automated. Instrumentation and
automation is vital for small plants as
well as large. The main deterrent are
the sensors necessary to pace the treat-
ment process.
Philadelphia, however, is planning
to automate wherever possible. We have
found out that as you go through the pro-
gram writing, which is part of computer
control, the logic required takes some of
the art out of operating a treatment pro-
cess and makes it more of a science,
Until we are able to apply more instrumen-
tation and automation to the treatment
plants throughout the country, treatment
plant efficiency will vary from plant-to-
plant, operator-to-operator, etc. I have
visited many plants in the last few years
and have found very few operating at
what I would call optimum efficiency.
For the most part, plant operators
are busy keeping the mechanics of the
plant in operation and spend a minimum
amount of time in actually controlling the
process. Many of the operators do not
have the proper education to control a
biological or chemical process and are
using rules of thumb to operate.
Perhaps this facet of operation will
be corrected, but I think it won't be for
quite some time. What we need is in-
strumentation and automation to auto-
matically assure a good effluent.
105
-------
"3
H-
<§
H
WHY OXYGEN ACTIVATED SLUDGE CHOSEN
I CONSISTENT TREATMENT OF STRONGER WASTES ( HIGH
SOLUBLE BOD )
2. MORE ECONOMICAL THAN CONVENTIONAL
3. LESS LAND AREA REQUIRED
4. GOOD SLUDGE SETTLING CHARACTERISTICS
5. LESS SLUDGE GENERATED
<§
H
CD
CD
IMPROVED
' OPERATION
0>
-o
qpd/ft8
1.4
2.6
3.0
NE BIO-SURF
REMOVALS *
BOD SS
95.7% 92.8%
95.2% 96.1%
94.0% 95.0%
VARIATION IN EFFICIENCY CAN BE REDUCED
BY IMPROVED OPERATION
NOT INCLUDING PRIMARIES
-------
We have worked out most of the de-
tails to instrumentate and automate the
new Philadelphia plants. Figure 9 shows
what we are now using at the Southwest
Plant to automate the operation of a pri-
mary tank. Figure jo shows the basic
method that we will use to automate the
Unox process.
AUTQMAUC SLUDGE. PUMPING
SOUTHWEST TREATMENT FACILITY
OXYSEN CONTROL SYSTEM
-CROSS
COLLECTOR
AREA
OUTPUT SIGNALS
ON-OFF FOR PUMP
AND COLLECTORS
TO CONCENTRATION
TANK*
Figure 9.
As I mentioned, the big drawback
are the sensors to determine suspended
solids as well as BOD. At one time, I
thought nothing would replace BOD. How-
ever, I have changed my mind.
As we look toward advanced treat-
ment, tertiary treatment and, finally,
water re-use, the BOD does not com-
pletely fill our needs. It is apparent that
there is much more in wastewater than
is registered by the BOD test.
Philadelphia's giant chemical firms
such as Rohm & Haas and Allied Chemical
VENT
CAS
OXYGEN
ANALYZER
SEQUENCER
*-txl-
[H BIAS I "@—\
_ —y- -,—- VALVE
I ^—AERATI
n
n
D
n
Or-
n
n
n
-SURFACE
AERATOR
:>HUT-OFF VALVE
FLOWMETER
F = FLOWMETEH
= ELECTRICAL SIGNAL
F'i;;,ure 10.
Company pour thousands of pounds of- or-
ganics into the City sewer system each
day.
These organics are the result of
synthesis of organic compounds they sell.
These companies readily admit they are
not able to identify all the byproducts. If
these opganics do not register a BOD or if
they are not oxidized in any reasonable
time frame, they could easily be found in
our water supply.
It is my feeling that tests like COD
are becoming more important and will be
used in the control of the treatment pro-
cess, particularly where advanced treat-
ment, tertiary treatment, or re-use is
intended.
We have attempted to determine the
compounds that enter our treatment plants.
107
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We have not been able to complete this
work, but we have found some interesting
data. A spectrographic analysis of the
influent of the Northeast Plant showed the
presence of many compounds that we have
not been able to identify. A spectro-
graphic analysis of the effluent gave
similar results . In the effluent analysis,
many of the influent compounds are no
longer present, but other unknown com-
pounds have appeared.
Truly, there is a need for a good chemi-
cal test to more completely evaluate
treatment plant performance since there
is more to be evaluated than the impact
of suspended solids or oxygen depletion
in the receiving stream.
As for tertiary or advanced treat-
ment, there have been volumes devoted
to this topic but in my opinion, we have
not found an economic method. Methods
available today are extremely expensive
and could not be used by large or even
medium-size cities without a tremendous
increase in cost to the customers.
It is my guess that a cost/benefit
analysis would not justify the construc-
tion of advanced or tertiary treatment
facilities in Philadelphia. The cost of
the present expansion program in Phila-
delphia will produce a 50% increase in
rates to the people of Philadelphia. Ter-
tiary treatment would more than double
this increase.
PRETREATMENT OF INDUSTRIAL WASTE
Since there is so much industry in
Philadelphia, it does have a considerable
impact on our treatment process and
since we consider industry part of the
City and a part of our prosperity, we are
concerned as to what the impact of the
water laws would be on them.
Proven and economically justifiable
techniques for pretreatment of industrial
wastes are needed in order to implement
the intent of the '72 law. This statement
is particularly true for urban based in-
dustries where space is either not avail-
able or only available at an extremely
high cost.
The key word here is "proven".
No industry can really afford to purchase
equipment which upon installation does not
solve their problems. The creation of
deadlines in the law, which I do not feel
are realistic, has fostered a need for a
type of panic investment.
Some large firms can support equip-
ment manufacturer's research and devel-
opment, but the facts are, for example,
that a great deal of air pollution control
equipment sold in the last 5 years has had
to be discarded as scrap. Even though
some large firms have been able to afford
this type of research, most medium and
small size firms cannot afford to do this.
Even such mundane problems as re-
moving grease and oil, particularly where
an industry does not have the required
area, is very difficult.
We wonder if there is any method of
obtaining the suggested limit of 100 mg/1
of hexane extractables through pretreat-
ment. Our knowledge on the subject indi-
cates that perhaps this can be done. As
far as we are concerned, however, it is
in the developmental stage.
Contrary to general belief, simple
neutralization is not really simple. Re-
liable systems to meet the intent of the
law still need to be developed. Having
worked with industry, I know their prob-
lems. I would have hoped the law would
have allowed the affected industries to
obtain necessary grants to pursue research
to solve the many problems that plague
them. I feel sure something could be
worked oat to the extent that any patents
be owned by the US Government. I
further feel that unless this is done, pro-
gress in solving our industrial waste
problems will be slow.
Also, research is needed into the
problems created by the removal of pol-
108
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lutants through pretreatment. For ex-
ample, some of the heavy metals in
plating waste can be removed by pH ad-
justment and hydroxide precipitation,
but after this is done what is done with
The second is the development of
management techniques and related tech-
nology that can uniformly and accurately
assess the impacts of all disposal alter-
natives including ocean disposal.
Philadelphia's digested sludge
exceeds the criteria of the act for only two
elements; mercury and cadmium in the
'solid phase'. The analysis procedures
used to determine these concentrations
are in draft form and many EPA Regions
have analytical methods of their own .
Here is an area where further develop-
ment is needed.
Also, it is unclear from the
wording of the Act as to what is intended
by the distinction between solid and liquid
phases for mercury and cadmium when all
other substances are limited by the bio-
assay test. Philadelphia's discharge
rates and bioassay results are well within
the criteria but we may be forced to aban-
don the ocean by concentrations of mer-
cury and cadmium that have already met
the toxicity limitations. The criteria ap-
pear to .be protecting organisms found in
the barge, not marine organisms.
To effectively implement PL 92-
532, serious consideration must certainly
be given to the validity of restricting ocean
disposal by concentration values in the
sludge which .are by no means an indica-
tion of concentrations expected in the ocean
after discharge and instantaneous dilution.
Once analytical procedures are
established and the scientific validity of
the limiting concentrations is proven,
technology for removing substances like
heavy metals must be developed.
This will afford an option, pres-
ently unavailable to ocean dumpers, of
either removing the objectionable material
or removing themselves from the ocean.
However, sludge will not be a major source
of metals and, unless a major technical
breakthrough occurs, metal recovery from
sludge will be expensive and will not "pro-
duce" an offsetting quantity of usable metal.
the materials you have removed? In
Pennsylvania, none of our landfills will
accept this type of waste. It is clear that
research and development of approved
disposal techniques are needed, but this
is a secondary goal. The primary goal
would be to recycle as much of the waste
as possible. Past developments of re-
cycling techniques have been hindered by
an abundance of raw material. Even
though I do not have a crystall ball, it is
easy to predict that within a few years,
we will see numerous shortages in the way
of iron, aluminum, copper and many other
materials.
Research is also needed for substi-
tutes. For example, the vast majority of
cadmium plating done in Philadelphia is
for Federal Specification QQP-416. We
wonder if this specification is necessary
for all parts or can a substitute such as
zinc be used. In fact, can substitute coat-
ings be developed? Also, some firms have
found substitutes for mercury in their latex
paints. Can all firms switch? If not,
why not develop suitable substitutes. The
same can be said for other metal pigments
in paints and inks.
As we examine industry and look
around us, we see many things in their
manufacturing which will produce either
a treatment problem or have an impact on
the environment in which we live. It ap.-
pears that a general re-appraisal of how
we live is necessary.
To complete this section on indus-
trial pretreatment, I will state, without
any doubts, that industry will not meet the
'77 requirement of the law because they
do not have the means or technology nec-
essary.
SLUDGE DISPOSAL
There are two basic requirements
for implementing the Marine Protection,
109
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Research and Sanctuaries Act. One is the
development of technology that will re-
move substances from the waste that are
above the limits of the criteria.
In writing the Marine Protection
Act, the authors apparently were able to
project the impacts on the ocean environ-
ment of the many substances listed in the
criteria. In the meantime, however, no
one including the EPA has been able to
document by field surveys, even where
Philadelphia's sludge goes after discharge,
much less what the impacts have been.
How can this be? It would seem that a law
with such obvious economic impacts would
be based on what can be shown to be harm-
ful instead of speculation.
One problem we have encountered
along these lines is the relocation of our
dump site. Philadelphia, in a study per-
formed by the Franklin Institute Research
Laboratories, was unable to find any ef-
fects of our dumping at a site 12 miles off
the coast. In spite of this, we were
moved to a 52 mile site, but we were
moved before an adequate baseline of the
site could be made. Now it will be very
difficult to determine anything about our
dumping because there is too little data on
which to base a comparison. The situation
is further complicated by a nearby acid
waste dump site which appears to be inter-
acting with the sludge site.
This situation points out the need
for study of the proper management of
dump sites. If two or more different
wastes are being discharged, the inter-
action of these wastes may produce effects
at the site totally different from the effects
of the materials considered individually.
This case makes comparison of individual
wastes to the criteria meaningless. It may
be that grouping of compatible waste dis-
charges is needed to avoid hazardous in-
teractions, or on the other hand, to pro-
mote any beneficial interactions. In either
case, much work is needed.
If ocean disposal of digested sludge
is potentially harmful to the ocean, then
the same potential exists for other meth-
ods such as land disposal or incineration.
PL 92-532 requires that dumpers of waste
which exceed the criteria investigate al-
ternative means of disposal.
Investigation of alternatives is
not the problem, but how to evaluate the
relative impacts on the environment has
not been clearly established. It is im-
plicit in the passage of the Act that these
benefit/damage relationships are known
for the ocean, but this is meaningless
without the same consideration for other
means of disposal. Further, once the
acceptable means of distributing pollutants
are established for other segments of the
environment, a comprehensive study of
the relative value of each segment must be
made. Only after this is accomplished
can municipalities and industry make
design decisions on the best means of ul-
timate disposal.
To illustrate this need, the re-
ports generated as a result of our permit
requirements for research into alterna-
tives warrant discussion.
There are three choices for ul-
timate disposal of sludge solids; the at-
mosphere, the land, the water. In the
report entitle "Report on Management of
By-Product Solids from Water Pollution
Control Plants" by our consulting engin-
eers, Greeley and Hansen, the alterna-
tives available tp Philadelphia were eval-
uated on the basis of economic, practical,
and environmental concerns.
Economically, all alternatives
to ocean dispersal were shown to be much
more costly to the City . The present
cost to the City for ocean dispersal (in-
cluding the recent 175% increase) is ap-
proximately $17.00 per dry ton of raw
sludge. The average cost of the 9 land
dispersal alternatives considered was
approximately $40. 00 per dry ton, an in-
crease of 135%. The incineration (atmos-
phere ) alternate is expected to cost on the
order of $62. 00 per dry ton, a 264% in-
crease. Ocean dispersal is by far the
most economically, attractive disposal
method.
110
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Large areas of available land do
not exist in the highly populated north-
eastern United States. This means that
long distance transportation methods are
needed which would increase operating
difficulties, adverse public reaction,
energy consumption, and costs.
Also, land spreading may not be
done in winter months due to runoff prob-
lems and therefore requires large storage
facilities. Composting is also expected
to have some problems due to cold weather
reducing pile temperatures and research
is underway at this time to determine the
extertt of weather effects. Incineration
processes need stack gas scrubbing to
meet air pollution standards and will re-
quire extensive maintenarir.fi.. Of all the
alternatives, ocean dispersal was shown
to have the least operating problems.
The environmental evaluation
showed similar potential hazards are as-
sociated with all dispersal methods. The
potential for heavy metal introduction to
the food chain exists for both ocean and
land dispersal. Clams and other filter
feeders could ingest the metals and thus
be available for harvesting and ultimately
human consumption. In a similar manner,
crops grown on sludge enriched soil could
be ingested by livestock and also be avail-
able for human consumption.
Microorganisms associated with
sludge pose threats whether introduced
directly to ocean waters or indirectly
through percolation to ground waters.
Air pollution hazards are unique to incin-
eration processes since operation of air
scrubber equipment has been insufficient
to date. Incineration is also a high energy
consumer, as is land spreading when com-
pared to barging to sea.
The report states that both sea
dispersal and land dispersal have the ad-
vantage of supplying nutrients to nutrient-
deficient areas. The report also points
out, however, that sea dispersal has the
advantage of diluting potentially hazardous
materials that land dispersal does not,
while land dispersal does provide some-
what better control.
Overall, ocean dispersal did not ap-
pear more hazardous to the environment
than the other alternates considered and
if aesthetics and public relations are con-
sidered, it appears as the best choice
again.
In spite of the considerations listed
above, Philadelphia may be required to
choose one of the alternatives to ocean
disposal simply because we exceed cri-
teria that has been put into effect before
sufficient knowledge of the impacts on the
total environment was developed.
One final note on sludge disposal.
Effluent criteria for Philadelphia necessi-
tates upgrading all three treatment plants
to full secondary systems. Secondary
treatment will, by its nature, increase
the volume of sludge and the amount of
potentially hazardous materials it con-
tains. Ocean criteria, however, dictate
a reduction in the amounts of potentially
hazardous material in the sludge before
disposal, as do incineration and land-
based alternatives. This somewhat
paradoxical situation also implies that a
system for assessing impacts of laws and
regulations on all parts of the environment
is needed.
SUMMARY
I hope that I have given you an idea of
some of the things that we are doing in
Philadelphia as well as some things that
must be done if we are to meet environ-
mental requirements. It is my feeling
that because of the growing shortage of
raw materials, we will have to develop
better methods for recycling with the net
result of less wastage.
As far as secondary treatment is con-
cerned, I do think we have the ability to
accomplish this if we' use a common yard-
stick of BOD and Suspended Solids. How-
ever, if we intend going beyond secondary,
we need methods which are practical and
economical and we must use other tests
111
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such as the chemical oxygen demand (COD)
particularly if we intend recycling. There
are signs that the generally accepted con-
cept of B-Coli as an indicator is now being
considered pathogenic. I would suspect
that this will change the bacteriological
requirements of both drinking water and
the effluents from sewage treatment plants.
The rotating contactor has tremen-
dous possibilities since it requires little
power as well as supervision. Much work
is to be done concerning storm overflows.
The huge quantities involved present real
problems as far as treatment is concerned.
This is a particularly tough problem in
large cities like Philadelphia where each
time it rains, sewage plus stormwater
enters the river.
Finally, in my opinion, the biggest
problem continues to be sludge disposal.
It is one thing to remove pollution it is
another to safely and economically dispose
of the pollution you have removed.
112
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V
A
V
c
Moderator:
C. J. Dial
U.S. Environmental Protection Agency
-------
LAND USE AND WATER QUALITY
E.H. CLARK
COUNCIL ON ENVIRONMENTAL QUALITY
722 Jackson Place, N.W.
Washington, D.C. 20006
ABSTRACT
The interaction betweenland use and water pollution promises (along with
the air pollution/land use interaction) to become one of our most important
environmental issues. There are two aspects to the problem. The first is
the impact of alternative patterns of land use on water quality. The
second is the impact of water quality regulations on land use. The impor-
tance of land use patterns on water quality in urbanized areas is indicated
by the fact that urban runoff promises to be the most important source of
water pollution in urban areas after the 1977 water pollution control
standards are met. The other side of the problem will be more evident over
the next few years. The location of treatment plants and intercepter and
collector sewers will be a most important influence on how land is used.
The water quality maintenance regulations will also have a substantial
impact on land use decisions.
INTRODUCTION
It has always discouraged me
that we often approach our environ-
mental problems with such a narrow
focus. We see a water pollution
problem and we set out to correct it,
with little concern about the air
pollution, solid wastes, or land use
effects that may result. But now we_
are finding that we have gone about
as far as we can,and perhaps further
than we should have, with this single
focus approach. Things are more
frequently running into one another.
And, more pertinent to the topic of
this paper, they are all running
into the problem of land use.
There is increasing — perhaps
not yet widespread, but increasing—
realization that many pollution
abatement programs are impacting land
use. Their impacts may be substan-
tial. And they may be detrimental—
the land use impacts resulting from
pollution abatement efforts may end
up generating more pollution.
The other side of the issue is
just as important, and in the long
run perhaps even more important.
Although tens of billions of dollars
are spent on pollution abatement,
efficiently achieving the degree of
environmental quality we want may
still require influencing patterns
of land use and development. Land
use questions — what should land
114
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be used for, how should it be devel-
oped, how should different parcels
of land be hooked together — are
where it all comes together. If we
can efficiently and effectively deal
with land use, we will have accom-
plished a great deal in efficiently
and effectively dealing with many of
our environmental problems.
In this paper I will briefly
touch on some of the interactions
between land use and water pollu-
tion. I do not claim to be an
expert in this field — in fact
there may now be no such thing —
but I can discuss some of the pre-
liminary work we are doing at the
Council on Environmental Quality
which is relevant to the issue.
My discussion is divided into
two parts. The first deals with
some ways in which different pat-
terns of land use have different
effects on water quality. And the
second will look at the opposite
side of the issue — how efforts to
improve water quality affect land
use.
Land Use_and Waste Water
The first thing we can say
about the effect of land use on
water pollution concerns the gene-
ration of sewage — domestic and
industrial. My comments on this
are rather obvious, and I include
the subject for the sake of com-
pleteness, not because I have any-
thing particularly profound to say.
Clearly different land activities
generate different amounts of pol-
lution. It makes a fair amount of
difference whether there is a paper
mill or 20 houses or a golf course
located out there on the back forty.
One can, therefore, control the
amount of waste water generated by
controlling what type of activities
take place on the land. Hopefully
such controls would be oriented
toward the amount of pollutants
actually discharged to the environ-
ment rather than the gross amount
generated before abatement takes
place. After all, it is possible —
perhaps not likely but still
possible — that the 20 houses with
their leaky septic tanks or the golf
course with its heavy nutrient and
pesticide laden runoff may be worse
than the paper plant.
There is a potentially more
interesting point in regard to such
planning, however. There may be
potential synergisms between pol-
luters such that the total amount
of pollution generated by an inte-
grated group is less than the sum
of the pollution generated by all
of them independently. For instance,
there are possible uses for the
waste heat in the cooling water
from power plants. There are also
isolated examples such as the
Sparrows Point Steel Mill which makes
use of treated effluent from Balti-
more City. There is potential use
for many effluents in irrigation
where the nutrients in the effluent
water can grow something we want
rather than green lakes. If such
potential synergisms are more common
than these few examples suggest, the
grouping of such activities — which
is a land use issue — may result in
reduced pollution at a lower cost.
A real benefit.
Non-Point Sources
Let me go on to what I think is
a more important interaction between
land use and water pollution. This
is the issue on non-point source
water pollution, and particularly
the problem of urban runoff. This
problem has received relatively
little attention in the water pollu-
tion control legislation or in the
EPA guidelines and regulations; but
is potentially very important to our
efforts to clean up our waterways.
115
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Let me review some results from a
recent study undertaken for the ^
Council on Environmental Quality.
Urban runoff is a major source of
pollution in urban streams. In
fact — comparing storm water runoff
with wastes processed by municipal
systems — after we achieve second-
ary treatment (85% B.O.D. removal)
of our municipal wastes, urban run-
off becomes the major source of
pollution in most cities. The CEQ
study looked at 8 U.S. cities, and
estimated that, once secondary
treatment was in effect, storm water
runoff would be responsible for 40
to 80 percent of the municipally
generated BOD in the river. Not
only is it a major source of BOD,
once the municipal and industrial
sewage is adequately treated, it is
the major source of settleable
solids, pathogens and bacteria. It
is also likely to be a major contri-
butor of such toxic pollutants as
lead and mercury. A moderate sized
city contributes significantly more
of these pollutants in urban runoff
than will a typical industrial dis-
charge.
So storm water runoff is a
serious problem. It is also a pro-
blem that is strongly affected by
land use. There are several differ-
ent levels on which the relationship
between runoff and land use can be
considered. At the regional level,
there is a question of whether there
is sufficient land available in an
appropriate location to serve as
detention basins for at least the
first flush of runoff. It is this
first flush — the first 1/3 to 1
inch of rainfall — that contains
over 85 percent of the pollution.
If we could capture this first flush.
**
hold it for a while, let it out
slowly, perhaps treating it before
we do, we would have much of the
urban pollution problem taken care
of. It would not be too expensive
and would significantly improve our
streams. This is an issue for land
use planning at the regional level.
At another level — more
appropriate to the community or
neighborhood — one is concerned
with the question of whether differ-
ent land development patterns make
any difference on the amount of
storm water runoff. The CEQ (in
association with HUD and EPA) has
just completed another study called
The Costs of Sprawl that attempts to
look at this issue along with other
environmental and economic effects
of alternative development patterns
The findings of this study are
fairly consistent across all the
environmental and economic costs
that were measured. Does density
or good planning make a difference?
The answer most definitely is yes.
The amount of urban runoff is essen-
tially determined by the amount of
paved area there is. The more paved
area — in homes, roads, parking
areas — the more runoff and the
more storm water pollution. Not
only is there more runoff from
developed areas, but there is likely
to be more sediment as well. Some
standard comparisons of sediment
production are given in Table 1.
If you ask the question in terms
of how different development pat-
terns affect the amount of pollution
generated by a thousand families,
you find that clustering homes may
reduce urban runoff by 25 percent,
but that increasing density saves
*Anne M. Vitale and Pierre M. Sprey,
Total Urban Pollution Loads: The
Impact of Storm Water, study done by
Enviro Control, Inc. for the Council
on Environmental Quality, 1974
**Real Estate Research Corporation,
The Costs of Sprawl, (Washington,
D.C., U.S. Government Printing
Office, 1974)
116
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more. A clustered high density
development (apartment buildings)
may generate only one fifth as much
storm water runoff as a conventional
single family neighborhood with the
same number of dwelling units.
However, with the denser develop-
ments, the amount of storm water
runoff per acre is somewhat slightly
higher. This increased runoff per
acre also means that the pollution
may be more concentrated, which of
course will create worse situations
in the stream. Thus increased
densities will result in a lower
total amount but probably a higher
concentration of pollution unless it
is controlled.
TABLE 1. LAND USE AND SEDIMENT
Land Use
Sediment
Production
Wooded
Agricultural
Vacant & Open Space
Developed, Urbanized
Under Construction
100 t/sq.m/y*
300 t/sq.m/y
200 t/sq.m/y
700 t/sq.m/y
2300 t/sq.m/y
*tons/sq.mile/year
Source: Interstate Commerce
Commission on the Potomac River
Basin, Land Runoff; A Factor in
Potomac Basin Pollution, (Harris-
burg, Virginia, July, 1967)
This then brings us to the next
level of concern. This is the fact
that at a level of detail appropriate
to a neighborhood or less, there are
a number of design modifications
that can be made to reduce the amount
of storm water runoff and therefore
the amount of storm water pollution.
If you take a given amount of land
and develop it at a high density,
you will have enough land left over
to permit the construction of tempo-
rary holding basins which will catch
the runoff and allow it to seep into
the ground, thus eliminating the
discharge of these pollutants into
the streams. Such a holding basin
will be dry most of the time and
can serve as a park, as part of a
golf course, or even in one case I
have read about as tennis courts.
This type of design modification
will not only reduce the amount of
pollution, but will also reduce the
flooding problems that often appear
in rapidly developing areas, and by
recharging groundwater supplies will
help advert water shortages. This
is a clear instance in which
imaginative use of the land can
avoid several potentially serious
water resource problems.
At a finer level of detail, similar
types of facilities can be and are
being built to catch the runoff from
parking lots, roof tops, and so
forth. Present design standards seem
to serve primarily to ensure that as
much of the runoff pollution as pos-
sible gets to the stream as quickly
as possible. For instance, in some
places it may be better to leave the
curbs off the streets and allow the
storm water to run off the edge of
the road to seep into the ground.
There are a number of similar design
modifications that can be carried
out which will make a substantial
impact upon the very serious problem
of storm water pollution.
Thus we have two ways in which
land use affects water pollution; the
first concerning sewage generation
and the second concerning storm water
runoff (which is the more important
of the two). Even with reduced
population growth rates, a very
large amount of urbanization is going
to occur in this country before the
end of this century — about as much
as has occurred in the past 2 decades.
Where and how this urbanization is
going to take place will have a
very substantial effect upon the
quality of our urban waters.
117
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For all the money we spend
to clean up our municipal and indus-
trial wastes we may still remain
frustrated in our efforts to obtain
really clean water if we don't deal
with the problem of storm water run-
off. And it appears as if the
easiest and least expensive way to
deal with this problem is through
better use of our land.
The Other Side of the Picture
As mentioned in the introduction,
there is another side to the water
pollution/land use issue I would
like to address briefly. We have
indicated our concern about the
effects of land use on water pollu-
tion. But water pollution, water
pollution control, and water pollu-
tion control regulations also affect
land use.
To deal first with the question
of the impact of water pollution and
water quality improvement upon land
use, I can only observe that there
is a significant tendency as our
rivers and lakes become cleaned up,
for water front land to become much
more valuable and built up. This
has been documented in some research
studies, and is apparent to anyone
observing building trends in most
cities. Large office buildings or
luxury apartment houses are beginning
to line our urban water fronts. In
some ways this is a disturbing trend,
for these developments may effec-
tively be blocking the public from
taking advantage — receiving the
benefits of — the improved water
quality they have paid for. There
are, I think, potentially serious
problems of income distribution
involved here, which is not a ques-
tion for this conference. But we
ought to recognize that water qual-
ity improvement can and does affect
significant changes in the price of
and use of riparian land. This
factor would argue strongly for co-
ordinating land use planning with
water quality improvement.
If we want to make the improved
water quality available to the gen-
eral public, the acquisition of
water front park lands and the like
can be done more easily and inexpen-
sively if it proceeds rather than
follows the clean up effort.
The way in which we attempt to
control water pollution has probably
a more important, and certainly a
more widespread impact on land use.
The construction grants program is
most significant in this respect,
particularly the monies allocated to
the construction of sewers. The
availability of sewer facilities has
long been important, and is becoming
more important in determining
whether or not, and how land will be
developed — particularly at the
urban fringe. Where there is vacant
sewered land, houses will be built.
If there is relatively little such
land, denser development will take
place — there will be relatively
more apartments and town house de-
velopments. When there is a surplus
of such land, relatively low density
development is more likely. However,
if there is no vacant sewered land,
the more wealthy will construct
single family homes on large lots
with septic tanks (if the soil is
suitable)w and large developers will
probably "leapfrog" out beyond the
urban fringe and serve their devel-
opments with small package treatment
plants.
Thus, the rate at which sewers
are extended strongly impacts land
use. If extended rapidly they will
support (and to some extent stimu-
late) low density urban sprawl. If
extended too slowly, they may create
similar problems. There is probably
and optimal rate of extension which
will lead to preferred development
patterns in preferred locations,
although we do not yet have the
ability to determine this optimal
rate. Nevertheless, it is clear
118
-------
that sewer construction has a most
important impact on land use, an
impact which ought to be carefully
assessed when planning new sewer
facilities.
Among other actions being taken
to control water pollution which may
impact land use are the permit pro-
grams, the new source performance
standards, the industrial effluent
guidelines and the section 208 plans.
It would take too long to analyze
each of these in detail, so let me
summarize some of the possible
impacts.
The ability to issue discharge
permits gives the water pollution
control agency direct control over
the location decisions of individual
polluters. The agency can refuse to
issue the required permit unless it
approves of where the factory is
constructed.
The industrial effluent stan-
dards, on the other hand, may
eliminate many of the incentives
formally provided by municipal sewers
to the location of firms. Combined
with the requirements regarding pre-
treatment of waste water before it
is discharged into municipal sewers,
and reimbursement of the municipality
for the total cost of treating
industrial waste, these regulations
will tend to reduce industry use of
municipal systems. This reduced
dependency will result in firms
being freer in deciding where to
locate and could result in their
moving to unsewered areas where the
land is less expensive. In this
manner, they could accelerate urban
sprawl. The regulation's effect
will be greater if the water pollu-
tion regulations induce old
facilities to cease operation before
they otherwise would have.
The new source performance
standards will provide some counter-
acting inducements — at least up
through 1982. if the new source
standards are much stricter than the
standards for old plants, they will
provide an incentive for firms to
keep the older plants in operation
longer than they otherwise would
have. This would tend to contain
urban sprawl.
Finally — at least for this
discussion — there are the section
208 plans. These are general area
plans which will be directly con-
cerned with the effect of develop-
ment patterns on water quality. If
these plans are solely concerned
with water quality, a natural
tendency would be to call for a
dispersal of waste water discharges
so that the streams are not sub-
jected to heavy concentrations of
pollutants. In terms of dissolved
oxygen, such concentrations are more
detrimental than spreading the same
amount of pollution over a wider
area. Thus the 208 plans may also
tend to promote urban sprawl.
Conclusion
That is a brief look at the
land use implications of some of the
water pollution control regulations.
Clearly they provide a complex set
of incentives, many of which counter-
act one another. The complexity of
the situation is increased several
times over when all the air pollu-
tion control regulations are also
taken into account. What is good
for water quality may not be good
for air quality and visa versa. It
is impossible to tell at this point
where it will all come out. It is,
however, a most important issue.
Unless the land use effects of the
various regulations are carefully
considered in their development and
implementation, they may generate
development patterns, which accord-
ing to the analysis in the first
part of the paper, will increase
the amount of pollution generated.
119
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RESOURCES AND WATER QUALITY
J. K. Klitz*
International Business Machines Corporation
P. 0. Box 1900
Boulder, Colorado 80302
ABSTRACT
This paper discusses the use, consumption, and pollution of water by
the resource-acquisition and manufacturing industries in the United States.
Once it is established that the flow of materials through the materials
cycle (acquisition, processing, use, recovery, and disposition) affects
water quality, a review of material and natural resource supply and demand
trends, both domestic and foreign, is given.
INTRODUCTION
Since the environment is both
the source of materials and the sink
for the waste or byproducts of pro-
duction and use, materials and the
environment interact at each step in
the flow system. Water quality is
especially affected in its use by
resource acquisition and manufactur-
ing industries (materials indus-
tries). The acquisition, processing,
use, and disposition of water, plus
the pollutants discharged into it,
all affect the quality of available
water. Conversely, the quality of
water affects its use. Many uses
of water are prevented by its natu-
ral salinity in arid regions. More-
over, increases in salinity may
result from irrigation. Pollution
by municipal and industrial wastes,
and in some cases by agricultural
and urban runoff, often makes
streams unfit for uses such as rec-
reation and the propagation of fish,
and adds to the costs of condition-
ing water for other uses. Such
pollutants as sediment, temperature,
deviations, or biological nutrients
may also limit water uses.
USE AND CONSUMPTION OF WATER BY
SELECT NONRENEWABLE
RESOURCE INDUSTRIES
Mining Industry
The mining industry requires
substantial quantities of water.
Water use is concentrated in the
production of a few commodities.
More than 65% of the water withdrawn
is used in the following five major
operations: quarrying sand and
gravel, drilling and secondary
recovery of petroleum and natural
gas, removing phosphate rock and
iron ore, and natural gas processing.
In 1965 the mineral industry
withdrew an estimated 3.2 b.g.d
(Table 1). Of this water, 64% was
used for processing and 27% for
cooling. About 6% was used in min-
ing operations and the remainder for
boiler feed and sanitary service.
Water consumption in 1965 was
about 0.7 b.g.d. — almost 25% of
the total U. S. consumption. The
^Former staff member of the National Commission on Materials Policy.
120
-------
Table 1. Past and projected water requirements for the
minerals industry in the United States
1965
Gross
Recirculation ration
Withdrawal
Discharge
Consumption
*b.g.d.: Billions of
11
3
3
2
0
gallons
(in
.10
.43
.24
.48
.76
per day
1980
b.g
20
4
4
2
1
.d.)*
.0
.9
.1
.9
.2
2000
33.
7.
4.
3.
1.
0
0
7
3
4
Source: National Commission on Materials Policy Report, June 1973
relatively high consumption rate is
due in part to the temperature and
aridity of the areas in which much
of the mineral industry is located.
The industrial practice of multiple
recirculation of process and cooling
water through ponds and cooling
towers, however, causes large losses
through evaporation even in humid
climates. About 20% of the waste
water discharged presently receives
some treatment — pH control, pre-
cipitation, or settling. The over-
all effectiveness of these processes,
however, is not known.
Except in certain arid areas in
the West, water supplies for mineral
industry withdrawals are not a major
problem. However, industry's wastes,
including drainage and seepage from
mines and pits, contribute to water
pollution. Acid mine waste from
coal fields in humid areas is a
serious pollutant.
Coal Gasification
The most recent studies and
estimates of water needed for a 250
million cubic feet per day synthetic
natural gas plant indicate a require-
ment of approximately 100,000 g.p.m.
circulated in the plant with actual
consumption that could be as high as
20,000 g.p.m.
The Department of the Interior's
projections of energy requirements
indicate that 5,500 billion cubic
feet of synthetic gas may be needed
by the year 2000, of which 90% would
come from coal. An industry of this
size would require large volumes of
water for circulation, with consump-
tion amounting to about 20% of the
total.
Oil Shale
The water needs for consumptive
use in a million-barrel-a-day shale-
oil industry are estimated to approx-
imately 100 to 170 m.g.d. These
estimates represent requirements for
production of a high-quality shale
oil syncrude, including a partial
refining of crude shale oil that
involves hydrogeneration.
The Department of Interior ten-
tatively projects the annual produc-
tion of 1,500 million barrels of
shale oil by the year 2000. This
would mean consumption of about 400
to 700 m.g.d. at the rates estimated
above. The oil shales with a devel-
opment potential are located largely
in the upper Colorado region, whose
sparse water resources are already
heavily committed. However, large
amounts of ground water are avail-
able to support initial developments.
Over time, increasing amounts of
surface water will be required.
Ultimately, surface water supplies
may limit the size of the shale oil
industry to perhaps 3 to 5 million
barrels of production per day.
Manufacturing
Water use for manufacturing and
processing of materials is concen-
trated in relatively few large estab-
lishments. About five major indus-
try groups (food and kindred pro-
ducts, pulp and paper, chemicals,
121
-------
Table 2: Typical water consumption for a 50,000 bbl/day oil
shale plant.
Assumptions: (1) Process sequence includes underground mining,
surface retorting, processed shale disposal
by wetting and compaction, upgrading of shale
crude by partial hydrofining.
(2) Process cooling primarily by aerial condensers.
(3) Raw shale - 30 GPT: processed shale wetted with
20% water for compaction.
Mining
Crushing (dust control)
Retortinga
Processed Shale Disposal
Shale Oil Upgrading
Other (Personnel, construction, etc.)
TOTAL
Net Water Consumed
Cubic Ft/Sec.
0.3 - 0.4
0.2 - 0.3
0.8 - 1.0
3.4 - 5. 8b
2.0 - 2.5
0.1 - 0.6
6.8 -10.6
a In situ operation would eliminate most of these water requirements.
If slurry disposal were to be used, this maximum could be as high
as 7.0 cu. ft./sec.
Source: Man, Materials, and Environment, NAS, 1973
primary metals) accounted for 90%
of total water withdrawals.
Water withdrawals for manufac-
turing are a function of the gross
water demand and the recirculation
rates that are employed within the
plants. Recirculation rates are,
in turn, influenced by the avail-
ability of water, water quality
requirements for manufacturing oper-
ations, water costs, treatment costs,
and effluent discharge requirements.
Table 3 projects improvements in
the rates of recirculation similar
to those observed among manufac-
turers in the period 1954 to 1963,
and indicates that water withdrawals
per unit of production will decrease.
However, the more stringent
treatment requirements for efflu-
ents are likely to cause manufac-
turers to recirculate and reuse
water and treated effluents at
higher rates than indicated in
Table 3. High costs for effluent
treatment, which produces waste
streams of a quality suitable for
inplant reuse, prompt the adoption
of higher recirculation rates to
optimize costs and reduce liability
for plant discharges. With current
technologyf the average recircular-
tion rates for the manufacturing
sector could reach 8 to 10 times by
the year 2000.
122
-------
Table 3. Projected manufacturing water requirements
in the conterminous United States
Gross
Recirculation ratio
Withdrawal
Discharge
Consumption
1965
90.0
2.25
40.0
37.4
2.6
1968
97.7
2.31
42.3
39.0
3.3
1980
164.3
3.0
54.8
50. 2
4.6
2000
349
4.4
80
70
10
Source: National Commission on Materials Policy Report,
June 1973
RENEWABLE RESOURCES AND WATER QUALITY
The acquisition of a renewable
resource can also cause unique
impacts on water quality. The
impacts associated with improper
applications of forest practices
include:
1. Quantity and timing of water
runoff
2. Soil disturbance
3. Changes in stream temperature
4. Changes in chemical water
quality
5. Pesticide and fertilizer
effluents
Quantity and Timing of Water Runoff
Timber cutting increases water
yields because evapotranspirative
losses are reduced when trees are
cut down. Silvicultural practices
that lead to even-aged management
and that include a period of com-
plete stand removal have a greater
influence on short-term water yield
than do practices that involve
uneven-aged management and only par-
tial cutting. Reforestation usually
decreases water yield, and convert-
ing vegetation from one species to
another also causes significant
changes in flow.
Flood runoff is also increased
by deforestation. A stream channel
is approximately filled by the mean
annual flood. If the mean annual
flood is increased following clear-
cutting, the increased discharge is
accommodated by increased size of
the channel. Most of the accommo-
dation is made by increasing the
channel width, implying extensive
bank erosion, and possibly undercut-
ting of sideslopes, roads, or other
structures.
Soil Disturbance
Various forest manipulations
may induce substantial movement of
soil and associated nutrients which
can eventually enter the waterways.
The stripping of forest cover and
the burning of vegetative soil, with
attendant accelerated erosion and
increased transport of sediment in
streams, occur as a consequence of
natural disturbance such as fire,
windrow, disease and insect attacks
as well as timber harvesting. Clear-
cutting substantially accelerates
these processes. The amount of accel-
eration is partly a function of topo-
graphic, soil, and precipitation con-
ditions , and partly a function of
the total extent of initial distur-
bance, whether by tree cutting
itself or by construction of timber
extraction roads.
Impact of Forest Practices on Stream
Temperature
Some forest manipulations bring
about temporary changes in the tern-
perature of the water in streams,
lakes and estuaries. This environ-
mental impact can result in changes
in the biota for which these bodies
of water provide a natural habitat.
For example, increased water tem-
perature in breeding areas is one
of several ways in which pressure
has been put on the salmon of the
Northwest. Salmon, like other sport
fish, have limited tolerance to
123
-------
variation in the temperature of
their stream habitat. These limits
have been exceeded in substantial
bodies of water in the past.
Impact of Forest Practices on
Chemical Water Quality
Most plant nutrients are stored
in the soil in various degrees of
availability to plants. The remain-
ing nutrients are in the organic
compounds of the forest vegetation
and forest floor debris and are con-
stantly being exchanged and recy-
cled with the nutrient pool of soil.
Under undisturbed conditions, the
export of nutrients from a forest
ecosystem often is low with respect
to total turnover rates.
Harvesting practices upset this
nutrient cycling process in several
ways. First, they tax the conser-
vation capacity of the soil by the
sudden nutrient release from decom-
posing logging debris which results
in a first-year fluctuation larger
than the normal seasonal fluctua-
tions in stream ecology. Second,
burning of slash returns nitrogen
and other volatiles to the atmo-
sphere, and leaves a residue of
nutrients in a highly mobile state
in the ash. Leaching and erosion
of the structureless ash occurs
readily, contributing to the chemi-
cal content of runoff. Third, the
export of logs and bark results in
a nutrient loss from the production
site, and generates a disposal prob-
lem at the processing site which
contributes to water pollution.
Pesticide and Fertilizer Effluent in
Water Courses
Herbicides are used in forest
manipulations to control brush and
to modify species mixes in favor of
commercially desirable species. They
are also used to control weed and
brush growth along forest road
rights-of-way. Residues from such
herbicide applications can enter
water courses, lakes and estuaries.
Forest fertilization is a rapid-
ly developing technology used to
increase the growth potential of
forest land. In the application of
fertilizers, some fraction of the
chemical ends up off target. Aerial
applications result in deposit
across critical boundaries. Such
introduction of nutrient additives
into water courses can improve water
habitat for aquatic organisms where
streams are very low in nutrient
content, or overenrich aquatic habi-
tats and downstream receiving waters
with possible subsequent increase in
the rate of eutrophication.
Insecticide and pesticide resi-
dues can cross critical boundaries—
a serious consideration since they
are not selective with respect to
nontarget species. They can there-
fore bring changes or death to water
fauna or nontarget populations such
as fish and insects.
RESOURCE TRENDS
Having demonstrated that water
quality is indeed affected by some
of the resource acquisition activi-
ties, it is important to evaluate
the past and future patterns of the
materials supplies and demands in
general. The future effect on water
quality will greatly depend upon the
amounts of materials that flow
through the materials cycle.
As shown in Figure 1, the United
States has evolved from a basic
agricultural and manufacturing eoon~
omy in the early decades of thi°
century to a more mature service-
oriented economy in recent decades.
Requirements and supplies of mineral
materials kept pace with population
growth despite wars and recessions.
The faster rise of gross national
product since 194-0 reflects the
increase in services and the ameni-
ties of life in the United States.
During 1972 the United States
required about 4.14- billion tons of
new basic mineral and non-food
organic materials (Figure 2). This
is equivalent to about 42,500 Ib.
(per person. The sizes of the rec-
tangles within the square indicate
the proportionate weight of each
type of material required per capita
124
-------
POPULATION IN MILLIONS OF PEOPLE
MATERIALS IN BILLIONS OF CONSTANT
1967 DOLLARS
GROSS NATIONAL PRODUCT IN CONSTANT
1967 DOLLARS
900
800
700
240
220
200
UJ
O.
U.
180 °
05
O
160 3
i
140
120
100
80
60
40
20
1900 1910 1920 1930 1940 1950 1960 1970 1980
Figure 1. Raw Materials in the U. S. Economy: 1900-1969
Source: National Commission on Materials Policy Report, June 1973
PHYSICAL STRUCTURE MATERIALS
GROSS NATIONAL PRODUCT/
PHYSICAL
STRUCTURE
MATERIALS
O
t/i
Note that nonmetallic materials_and
mineral fuels predominate by weight.
Per Figure 3 it is noted that
• World consumption of raw steel,
aluminum, copper, and zinc_
increased more rapidly during
1972 than consumption during
the 1950-1970 period.
• The strong lead which the U. S.
had over other industrialized
nations of the world in the
early '50s has diminished.
The position of the U. S. as
predominant producer of metals,
minerals, and fuels declined
considerably from 1950-1970.
The U. S. mine production of
major metals, nonmetals, and
mineral fuels did not rise sig-
nificantly from 1950-1970, and
was certainly not proportionate
to U. S. consumption or world
consumption.
125
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NONMETALLIC MATERIALS
MINERAL FUELS
METALS ORGANICS
NATURAL RUBBER (10)
NATURAL FIBERS AND OILS (50)
90
80
70
2
S
_i 60
8
6 50
a:
^ 40
O
z
0 30
(T
a.
20
10
ALL OTHER NONMETALS (1200): :
i r v i •+' 'lA'sfii • • -e " 1 1 1
,. CLAYS (600 ,
'"' :CEMENT(806):
^ ;
STONE
(85001
^.
V
>
SAND AND GRAVEL
(90001
-
I t i i
5,000 10,000 15,000 >
20,550
OTHER METALS (35) —
ZINC (15) -^
LEAD (15)/
COPPER (25)
ALUMINUM (50) '
NATURAL GAS
(5000)
COAL
(5000)
PETROLEUM
(7800)
1 1 I
25,000 30,000 35,000 r
17,800
%
*;
I
UJ
1-
:n
:^
Z
O
S:
:;:v
S?
1
1
,*
~
I
(N _
to
O -
O
CC
a.
en
LU ~
O
-
1
o'
Figure 2. Weight of New Basic Raw Materials Required by Average
U. S. Citizen During 1972
Source: National Commission on Materials Policy Report, June 1973
Fibrous materials consumed in
the manufacture of paper and board
is projected to total more than 150
million tons annually by the year
2000 (Figure 4). The U. S. demand
for metals from now until the year
2000 will be great, with U. S. mine
production not being able to meet the
the demand (Figure 5). Consequently,
the demand will be met by imported
ores and concentrates, new and old
scrap, and metal imports. However,
it must be noted that the world
demand for minerals and metals will
increase more than that of the U. S.
Competition to obtain resources in
the foreign marketplaces will be
high -- greater than the U. S. has
ever faced.
Given the above resource trends
and the present level of technology,
population trends, and consumptive
habits, it is reasonable to expect
that more materials will pass
through the U. S. materials cycle in
the next decade. Consequently, the
environmental stress per unit^of
production on water quality will
increase as (1) the quality of ores
and other natural resources declines,
(2) the readily available resources
are exhausted, and (3) the use of
energy per unit of output increases
to maintain the intensity of mater-
ials throughput.
In summary, since the environ-
ment is both the source of materials
and the sink for the waste or bypro-
ducts of production and use,
materials and environment interact
continually. The continuing yield
of materials and quality of water
will depend on how materials are
extracted, how materials are re-
126
-------
600
1950
1955
1960
3.12
2
1.61
REFINED COPPER
(Million metric ton)
contained copper)
APPARENT CONSUMPTION
WORLD TOTAL-
REST OF WORLD
UNITED STATES :
W/////M/////,
ALUMINUM INGOTS
(Million metric tonil
APPARENT CONSUMPTION
1955 1960 1965 1970
REFINED ZINC
(Million metric tons contained zinc)
APPARENT CONSUMPTION
/^/UNITED STATES
y///////////,
I960
1966
1960
1960
1965
Figure 3. World Metal Requirements Compared with U. S. Needs
Source: Second NCMP Interim Report, April 1972
stored to the environment, 'how water
is used, how much is consumed, and
how it is treated. No stage of the
materials flow system can be treated
without regard for the others;
actions at one point of th'e system
always affect many others. The
challenge to those who frame poli-
cies is to acquire an understanding
of the basic interactions in the
materials and water systems suffi-
cient to obtain the desired outcome
and avoid unwanted effects.
127
-------
^uu
50
TOTAL F
£=S==
IBROUSM/*
WOOD PU
^^
^^
^^-
TERIALS,-'
LPSxl .-'
/WASTE
PAPER
..--•"
.-•'
>•
OTHER!
1920 1940 1960 1980 20<
Figure 4. Fibrous Materials Consumption in the U. S.. to the
Year 2000.
Source: NCMP Report, "Timber - The Renewable Material," 1973
U S. IRON DEMAND AND SUPPLY
(Ml LLION SHORT TONS CONTAINED IRON)
TOTAL DEMAND
NET STEEL IMPORTS^. \
PRIMARY DEMAND
^.--"'SECONDARY ..--""
NET ORE IMPORTS
20 YEAR TREND
1950 1955 1960 '965 1970 1975 1980 1985 1990 1995 2000
U.S. ALUMINUM DEMAND AND SUPPLY 26.4 AT YEAR 2000
(MILLION SHORT TONS ALUMINUM CONTENT)
INDUSTRIAL DEMAND //
/•' PRIMARY DEMAND
<«&•"'""
«^""
TTTTTTTTTrrrtrr.
,._. MINE PRODUCTION
\ 20 YEAR TREND
77/A/////^//^//^////yA/////A/////A/////iV////,
1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000
U.S. COPPER DEMAND AND SUPPLY
(MILLION SHORT TONS COPPER CONTENT]
1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000
U.S ZINC DEMAND AND SUPPLY
(MILLION SHORT TONS ZINC CONTENT) OLD SCRAP-
INDUSTRIAL DEMAND
0
1951 1955 .1960 1965 1970 1975 1980 1985 1990 1995 2000
Figure 5. Demand and Supply of Major Metals in the U. S. to the
Year 2000
Source: National Commission on Materials Policy Report, June 1973
128
-------
Bibliography
1. Material Needs and the Environ-
ment Today and Tomorrow^Final
Report of the National Commis-
sion on Materials Policy,
Washington, D.C., June 1973.
2. Man, Materials, and Environment,
National Academy of Sciences/
National Academy of Engineering,
Washington, B.C., March 1973.
3. Towards a National Materials
Policy - Basic Data and Issues,
Interim Report of the National
Commission on Materials Policy,
Washington, B.C., April 1972.
Towards a National Materials
Policy - World Perspective"
Second Interim Report of the
National Commission on Materials
Policy, Washington, B.C.,
Timber: The Renewable Material,
prepared for the National Com-
mission on Materials Policy, by
Edward P. Cliff, Washington,
B.C., August 1973.
National Materials Policy,
Hearings before the subcommittee
on minerals, materials, and
fuels, Ninety-Third Congress,
October 30 and 31 and November 1,
1973, Washington, B.C.
129
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THE IMPACT OF ENERGY SELF-SUFFICIENCY ON POLLUTION CONTROL
Kurt E. Yeager
Environmental Protection Agency
Office of Research and Development
401 M Street, S. W.
Washington, D. C. 20460
ABSTRACT
?
This presentation will initially describe the general role of environmtui_al
research and specifically that of the EPA in the achievement of energy self-
sufficiency. This role is based on the Federal position that the development
and implementation of energy technology and policy must be sensitive to effects
on health and the environment. If this sensitivity is rationally incorporated
into the energy development process, self-sufficiency can be achieved in harmony
with the environment. The fundamental goals of the Federal energy-related research
program are therefore to: (1) fundamentally improve understanding of the
environmental impact of energy self-sufficiency; (2) determine the relationship
between source control and impact reduction on social, economic and environmental
terms; and (3) translate these research efforts in a manner which permits the
public and its representatives to make policy decisions based on knowledge of
the total costs and benefits of various approaches to energy self-sufficiency.
The second portion of the presentation will summarize the major environmental
problems in the achievement of energy self-sufficiency and the corresponding
Federal environmental research objectives designed to solve these problems.
These objectives and associated resource allocations, based on a $191 million
increase in the FY '75 research appropriation, will be described in terms
of seven major environmental research program areas.
INTRODUCTION
Public concern for the health,
environmental, societal and welfare impacts
of energy-related activities has become
the single most important issue limiting
the growth of domestic energy production.
These public concerns are directed at
observable as well as suspected deleter-
ious aspects of the discovery, extraction,
transport and processing of fuels as well
as their conversion to produce synthetic
fuels.
These concerns are ligitimate,
urgent, and unavoidable. They dictate
that health and environmental considera-
tions be integrated with the large-scale
technological developments associated
with the achievement of energy self-
sufficiency. They demand that a broadly
based vigorous and effective program be
conducted in parallel with and closely
coupled to the technology R§D to
guarantee minimal effects on man and his
environment.
Our growing environmental concerns
and most recently the energy crisis have
combined with gathering force to make us
understand that we do not have unlimited
room or resources. We are starting to
s ee that our energy and environmental
ills stem, essentially, from the same
source: from patterns of growth and
development that waste our energy re-
sources just as liberally as they lay
130
-------
waste our natural environment. We no
longer live in a time when we were few
and the land was wide and waiting for us.
We have reached the point where we can
no longer insulate ourselves from the
punishment and pollution we visit upon the
earth and the atmosphere, and where the
natural resources we once regarded as so
endlessly available and expendable are
becoming increasingly hard to get.
The energy crisis is part and parcel
of our overall environmental problem --
a classic symptom of the strains that
occur when an organism begins to exceed
the carrying capacity of its habitat. It
warns us that we had better begin to face
up to the fact that modern man every-
where is pressing the limits of the
resources and resilience of the earth.
This environmental research agenda
is designed, therefore, as an integral
part of the energy R£D program in order
to improve understanding of 1) the impact
of energy self-sufficiency on human health
welfare and ecological systems and 2)
the relationship between source control
and impact reduction. This understanding
must be gained and applied in concert
with the achievement of energy self-
sufficiency if this policy is to be
protective of human health and the en-
vironment. Further, this understanding
must span all phases of the energy
cycle from extraction through con-
version to end utilization as well as
the environmental relationships existing
between these phases.
The scope and objective of this
research program consider the activities
necessary to define in timely and cost
efficient manner the environmental
control requirements which will com-
plement the future production of energy.
The difficulties in energy related
decision making are nowhere more evident
than those relating to the environment.
Explicit consideration of the environ-
mental imperative is a new, often a
first glance, constraining concept in
the development of energy and associated
RSD policy. In addition, the basic
information upon which to base these
energy decisions is very often either
non-existent or of a qualitative and
emotional nature intended to support
adversary positions rather than
resolve apparent conflicts between
energy and the environment.
As shown in Figure 1, energy policy
formulation on the Federal, regional
or state level appears to take the
obvious benefit goals of providing
adequate supplies, minimum cost and
maximum use of domestic resources
and adds the apparent conflicting
goals of minimum environmental impact.
However, if the environmental goal
can be considered integral with energy
policy formulation and supported
on a sound technology and policy base,
it may cease to become an apparent
conflict issue.
It is basic to the practical
achievement of an energy policy,
praticularly one of energy self-
sufficiency, that data limitations
relating to the environment be
removed and an environmental/energy
policy relationship such as that
shown in Figure 2 established. This
relationship will allow the adequate
consideration of environmental protec-
tion costs and benefits in the for-
mulation of energy policy.
At the present time the environmental
data base is effectively limited to char-
acterization of an aggregated subset of
fossil and nuclear energy residuals and
definition of the health effect thresholds
associated with a few major energy related
air pollutants within this subse of
residuals. A number of additional energy
residuals whose environmental impacts
have not yet been quantitatively examined
can be expected to have as great an addi-
tional effect on the development, imple-
mentation, siting and control of energy
systems as that already, for example,
caused by sulfur oxides. These include
fine particulate and associated trace
metals; sulfate aerosols; Krypton-85,
Strontium-89, tritium; waste heat; solid
wastes and associated water pollutants
from mining, processing, conversion and
control as well as destructive land use.
The objectives of this environmental
research agenda are directed to obtaining
the priority impact and transport data
concurrent with the development of
energy self-sufficiency. In this funda-
mental objective, control requirements
c an be defined as an integral part of the
basic energy development program rather
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Figure 1. Energy Policy Formulation
MEASUREMENT MONITORING
PHYSICAL
CHEMICAL
BIOLOGICAL
EMISSION
CHARACTER-
IZATION
ENVIRONMENTAL
POLICY
FORMULATION
Fipure 2. Environmental Data Flow
132
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than later retrofitted at much greater
economic cost, industrial resistance and
reduced environmental and operational
e fficiency.
In order to achieve energy self-
sufficiency at known and acceptable envi-
ronmental and economic cost, there is,
therefore, a pressing immediate need to
clearly understand the health, welfare
and ecosystem dose-response relationships
for all established and potentially hazard-
ous energy residuals. Supporting this
goal must be comprehensive capabilities
to identify, measure and monitor each
of these residuals, both at the source and
in the ambient environment and to under-
stand the transport processes by which
these residuals transform and move through
the media and biota to their ultimate fate
or receptor so that source control require-
ments can be rationally defined for public
and industrial understanding and accept-
ance.
Another immediate factor magnifying
the environmental data and assessment
methodology necessary to guide the develop-
ment and implementation of new energy
sources and technologies is the demands
o f Environmental Impact Statements
directed by NEPA and recent court decisions
directing clarification of the environmental
regulatory process and the threshold
concept of standard setting. These include
definition of "significant" environmental
quality degradation at levels well below
current environmental standards. This
definition will have a particularly
fundamental impact on the developing and
siting of new coal based energy technologies.
These new data requirements are the first
steps in what clearly will be the long-
term mission of enviornmental research.
This long-term mission will move from
the purely Federal regulartory response
to idenfitied problems and will shift
toward a strategy of prevention based
on better understanding of local environ-
mental-effects relative to the costs of
reducing these effects and a firmer
insight into the impact of broad social
goals and energy policies on environ-
mental quality. The public must be
provided the capability to make the
decisions as to whether or not to pay
these "costs". The accomplishment of
these long-term goals will, ththerefore,
require that local governments and
industries establish the capability to
examine realistically the possible
alternative energy strategies available
to them. The responsibility of the
Federal Government in this context is to
1) support the development of the data
base, tools and methodologies that make
such examinations possible and 2) provide
broad assessments that consider the total
energy cycle and thus provide the frame-
work and basis for rational decisions
1 eading to the local prevention of
environmental degradation. These local
decisions, when aggregared, will best
approach an optimal rational environ-
mental control strategy for energy.
In summary, two basic conclusions
have been drawn with respect to this
challenge: first, development and
implementation of energy systems for
achieving and maintaining energy self-
sufficiency clearly must be sensitive
to the effects that the systems will
have on health, welfare and ecosystems.
Second, if this sensitivity is rationally
incorporated into the development and
implementation of energy processes domestic
resources can be broadly utilized harmony
with the environment.
The achievement of this second point
is the fundamental goal to which this
environmental research agenda is directed.
This agenda consists of five subprogram
constructed by projecting presently
known and anticipated concerns for the
impacts of existing and developmental
energy systems on the environment and
the prevention or control of these
impacts. These subprograms are directed
at research in the areas of 1) Effects
(Health, Ecological and Welfare), 2)
Instrumentation and Monitoring, 3) Environ-
mental Processes, 4) Control Technology
and 5) Implementation.
Goals and Objectives to be Achieved
During the Next Five Years
Pollutant Characterization, Measurement
and Monitoring - Goals:
To identify and define the chemical
and physical characteristics of the by-
products associated with each phase of
existing and developing energy systems
from extraction through utilization of
the energy and to achieve a capability
to accurately measure and maintain an
accounting of the total impact of these
133
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pollutants on existing and developing
energy systems on heuman health, welfare,
society, and ecological systems.
The starting point for any environmental
evaluation of energy systems is charac-
terization of the physical and chemical
properties of energy system residuals
which result in all phases from extrac-
t ion through conversion and transmission
to end utilization. This characteriza-
tion must also consider the technologies
used to control pollutants and the
residuals which result from the control
processes. The importance of this
knowledge of the material balances of
each ;energy system is the guidance it
provided to both the effects and
control R§D. Instrumentation and analy-
tical techniques must be made available
to perform this characterization through-
out the development of new and improved
energy systems as well as to maintain
an accurate accounting of these residuals
and associated control performance after
commercial implementation. Finally,
monitoring systems must be developed
and implemented on a national and even
international scale to provide the
capability to accurately measure the
impact of all energy-related pollutants
on human health, welfare, society and
localized ecological systems. This
measurement capability is fundamental to
the development of national environmental
standards and incentives. These systems
must further be capable of maintaining
an accounting for their impacts to
insure that they are maintained below
tthe defined tolerance levels.
The projects included in this
program are those in which funding
is imperative to meet the near term require-
ments of the 1972 Noise Control Act,
the Clean Air Act and the Federal Water
Quality Act (1972) as they bear on energy
s ystems.
The primary objectives of the research
in the FY 75-79 period are as follows:
Characterization
Develop and apply all methods
necessary to chemically and physically
quantify the residuals associated with
existing and developmental total energy
systems and technologies.
Monitoring and Measurement
Insure precision and accuracy of
ambient and source measurement methods
and procedures for criteria and radio-
logical pollutants.
-Develop verified ambient and source
measurement methods and procedures for
pollutants for which no standard has
been established (e.g., fine particulates,
sulfate, nitrate).
-Develop quality assurance procedures
and training programs for monitoring
environmental degradation.
-Develop and demonstrate advanced
monitoring techniques, i.e., remote/
in situ sensors.
-Develop and implement data acquisition,
retrieval, and assessment procedures
permitting maximum Federal, regional and
local application of monitoring informa-
tion.
-Develop physical standards for cali-
bration of instrumentation used to measure
pollutant concentrations.
Environmental Transport Processes - Goals:
To determine the relationship exist-
ing between energy system byproduct
emission burdens and ambient environmental
c oncentrations as well as trace the path-
ways from energy system emitter to ulti-
mate fate.
The second step in the sequence of environ-
mental data development is understanding
and being able to predict the relationship
between energy system emissions and the
ambient concentrations affecting the
environment. Decisions on the best
approaches for allowing energy growth
while balancing existing and potential
environmental quality conditions are to a
large extent perplexing because of our
inadequate knowledge of the transport,
interactions and fates of pollutants.
In order to satisfy this requirement, the
capability must be developed to trace the
pathways and transformation of energy
system emissions through all media and
biota to their ultimate fate or receptor.
Transport processes encompass two classes
of phenomena: physical transport and
chemical transformation.
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Transport processes are important in three
regions: immediate neighborhood of the
source; regional; and global. Chemical
transformations of pollutants occur both
in the atmosphere and water. In these
cases relatively innocuous compounds may
b e converted into more toxic and more
damaging species.
Specific priority research objectives to
be pursued in the FY 75-79 time period
include:
1. Atmosphere
a. Cooling System Plume Behavior.
b. Atmospheric interactions in
both Dry and Wet-scrubbed plumes from
Fossil Energy Systems (especially respira-
ble sulfate particle formation, S02 oxida-
tion rate, and interactions with urban
pollutants).
c. Dispersion of Plumes in
Rough Terrain.
d. Low-level Dispersion pathways
and ultimate fates of Radionuclides from
Nuclear Plant Building Releases, especially
at low wind speeds and including building
wake effects.
2. Freshwater
a. Thermal and pollutant dispersion
pathways and ultimate fates in streams,
lakes, and groundwaters.
b. Physical and chemical transfor-
mation of pollutants in streams and lakes.
3. Marine
a. Thermal and pollutant diffusion
in characteristic coastal waters.
b. Physical and chemical transfor-
mation of pollution in coastal waters.
4. Intermedia
a. Transfer of atmospheric sulfur
to soils and economic crops.
b. Impact of moisture and heat
release on local climate.
c. Model for precipitation
scavenging of sulfur.
d. Dry deposition of atmospheric
pollutants.
Effects: Health, Ecological, Welfare and
Social - Goals:
To define the health, welfare and
social and ecological effects of existing
energy systems, to obtain adequate infor-
mation on the parameters of social and
economic changes resulting from environ-
mental modifications associated with energy
systems and to develop sufficient informa-
tion on the damage functions associated
with developing energy systems to confi-
dently permit assessment and control.
Health Effects
It is clear that while existing data are
adequate to define a risk to health and
hence indicate the need for control, an
adequate appreciation of the true health
impact for energy system related pollutants
does not exist. Sufficient effort has not
been made to determine the nature of the
dose response relationship with respect
to numerous important end points. For
example, although existing data are
sufficient to define the need for a total
suspended particulate standard, they are
not adequate to evaluate the impact of
particle size or chemical composition of
these particles upon health. Likewise,
in the case of carbon monoxide, data do
not exist to define the effect of CO upon
the very young, especially premature
infants and little information is availa-
ble to determine the effect of high alti-
tude upon response to carbon monoxide.
The standard for N02 is based, perhaps,
upon the least sufficient information of
all existing standards. While minimally
adequate toxicologic data indicate that
N02 is a problem, epidemiologic and
clinical studies do not exist to adequately
define important dose-response relation-
ships. These deficiencies are compounded
by measurement method problems which have
unduly confounded even existing studies.
This problem will provide limited but
urgently needed information on health
effects required for safe utilization of
energy systems. Information will be
obtained from clinical and epidemiologic
studies on human populations and limited
experimental studies on animals and lower
organisms. It will be possible to
initiate minimal but less than adequate
studies on short and long term effects of
acute, chronic and intermittent exposure
to energy-related pollutants on which
135
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criteria for standards must be based
ultimately. On late effects studies, end
points of particular concern will be
obtained on carcinogenesis, mutagenesis,
teratogenesis, and physiologic and metabol-
ic effects. Again, with minimal funding,
studies of the complex problems of poten-
tial synergistic effects of simultaneous
exposure to more than one pollutant cannot
be conducted. Minimal efforts will be
directed to the combating of adverse
effects of pollutants in man. Studies
will include investigations on those
pollutants for which standards are re-
quired by law, studies of some of the
other known pollutants, and identification
and evaluation of other possible toxic
materials resulting from energy systems.
As indicated, the level of activity will
be lower than desired in all areas in the
"Orderly" program, and work on all but
the primary and secondary pollutants will
be drastically reduced.
Specific priority health effect objectives
supporting energy self-sufficiency which
must be addressed in the FY 75-79 time
period are:
-Strengthening of scientific bases
for existing primary ambient air quality
standards. Although these standards
were formulated upon the best available
information at the time of their promul-
gation, there is a pressing need for the
Agency to place these standards on as
firm a scientific basis as possible before
they are implemented. Gaps in knowledge
are particularly evident with respect to
nitrogen dioxide.
-Evaluation of health effects associa-
ted with exposures to air pollutants for
which ambient air quality standards do
not presently exist. These include
effects of fine particulates and suspended
sulfates, as well as known or suspended
carcinogenic hydrocarbons (PPOM).
-Health effects associated with
exposures to trace metals and persistent
chemicals. Although these are in reality
multi-media problems, airborne exposures
can be important. Current strategies
for long term control of lead mobile
source emissions and for control of lead
and cadmium stationary source emissions
are dependent upon availability of addi-
tional health effects information.
-Evaluation of health consequences
resulting from the impact of fuels and
fuel additives upon regulated as well as
non-regulated pollutants. Work includes
safety assessment of catalysts to be used
in emission control systems for automobiles
as well as protocol development for
safety assurance testing.
-Definition of effects of simultaneous
exposure to a number of air pollutants.
This includes assessment of non-pulmonary
effects due to air pollution such as
decreased resistance to infection, and
impact upon health of future generations
via teratogenic or mutagenic effects.
-Detection of long term, low level
effects of pollutants (including radiation)
-Development of means of combating
adverse effects of pollutants.
-Provision of information on health
effects essential to cost-benefit-risk
decisions in the choice of energy systems
when diverse, competing technologies
exist.
Ecological Effects
The general objectives of ecological
effects research are: (a) to assess
the effects on ecosystems of various steps
in the fuel cycle; (b) to provide feedback
information to the technologies so that
appropriate controls may be instituted;
(c) to develop information complete
enough for cost-risk-benefit comparisons
of alternate energy technologies, and
for the development of new environmental
management techniques to minimize eco-
system impact including the impact of
habitat obliteration and secondary develop-
ment in estuarine and wet-lands habitats
brought about by energy-related installa-
tions.
In the ecological effects area the base
of fundamental knowledge in the structure
and function of ecosystems is too inade-
quate to predict and interpret the impact
of introduced insults. The limited
resources available to energy effects
research has necessarily required that
first priority be placed on the human
health aspects of energy residuals. As
a result energy technologies intended to
produce synthetic oil and gas from coal
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are being considered as "clean" only in
terms of their ability to minimize the
air pollution potential associated with
coal combustion. While this consideration
for the primary health impact of coal in
urban areas is a necessary factor in
energy system design, it is by no means
sufficient to ensure the environmental
harmony of energy self-sufficiency. Major
ecological and obvious degradation of
land as well as surface and groundwaters.
These concerns have been largely limited
by available data to the subjective. Little
or no effort has been made to understand
the ecological impact of these operations,
both immediate as well as the more subtle
changes that ultimately could seriously
affect the natural ecological balance
thus limiting man's ability to survive on
this planet.
It must be clearly understood, for example,
that the inherent inefficiency of coal
conversion technology coupled with the
use of chemical additives to remove air
pollution increases, in a quantitative
sense, destructive land use by at least
30 percent and solid waste and the re-
sulting water pollution potential by more
than 70 percent relative to direct coal
combustion systems. Further, the demands
of energy self-sufficiency mean that U.S.
coal production will triple from 600
million tons per year in 1973 to more than
1,800 tons by 1990. In a qualitative sense
the introduction of new chemical species
for air pollution control increases the
damage potential of these residuals by an
unknown degree. The immediate goal of the
ecological effects research program is
therefore to understand these impacts so
that the distribution and control of
rapidly increasing coal related energy
residuals associated with energy self-
sufficiency can be accomplished in (1) a
manner which minimizes their ecological
impact to a level consistent with local
tolerances and (2) without jeopardizing
the health effects control capability of
these emerging energy technologies.
Development of new coal technology must
be done in a manner minimizing environ-
mental and ecosystem damage. This
research program will insure that energy
self-sufficiency can be attained by
1985 with known and controllable environ-
mental impact. Ecological impact and
ecosystem data on oil shale and geothermal
technology will not be initiated under
this level of effort until 1978-79.
Specific objectives to be addressed in the
FY 75-79 time period are:
1. Assess the environmental
effects and impacts of coal, oil, oil
shale, uranium, and geothermal extraction
techniques and predict ecosystem effects
permitting enhancement of benefit-cost
ratios by suitable land management policy.
2. Determine the environmental
effects of radionuclides, hydrocarbons
and other fuel transport and storage.
This will include determining the
accumulation ratios and transfer rates of
secondary pollutant dispersal through the
food chains and other pathways, and
development of strategies for concentra-
tion and/or decontamination in order to
minimize residual long term ecosystem
effects, including those impinging on
3. Determine pollutant pathways and
toxicities so as to guide routine and
non-routine releases from energy conversion
and reprocessing plants. Both geochemical
and ecosystem studies will be conducted
to provide guidelines and criteria for
siting of facilities and disposal of
both liquid and solid wastes generated by
both nuclear and non-nuclear plants.
A. Determine the ecosystem costs of
thermal shocks from power plant waste heat
release, from entrainment and impingement
in the cooling systems and from cooling
tower blow-down as well as the impact of
anti-fouling additives. Additionally,
the ecosystem impacts and synergistic
effects of effluents such as radioactive
materi'als, trace metals, noxious gases,
organic compounds and other substances
produced during energy generation will
be evaluated and management strategies
instituted for minimizing these impacts.
5. Develop biological indices
(species diversity, fecundity, natality,
mortality, etc.) for ecosystem impact
evaluation. A systems approach encom-
passing laboratory, greenhouse, microcosm,
and large scale field experimentation
will be used to address the problem. This
systems approach requires a model that is
structured in such a way that those sub-
systems most affected by pollution can be
sensed. A more detailed analysis of these
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components will then be made with a view to
assessing the site, time, and mechanism
of the pollution effects.
6. Conduct large scale ecosystem
studies on dedicated, controlled-access
parcels of land and water, such as
environmental research parks, and through
the biome studies developed under the
International Biological Program.
7. Produce a number of relatively
simple, reliable estimators of ecological
impact and estimated extent and duration
of observed effects using the above
capabilities and data base.
Social and Welfare Effects
Social effect studies will quantify
both tangible and intangible costs of
selected energy projects. Economic
methods and protocols will emphasize not
only the direct costs to energy consumers,
but also indirect or hidden dollar costs;
e.g., to taxpayers. Sociological methods
will develop a standard protocol for
estimating non-dollar costs as well. With
minimal funding particular case studies
can be started, including land use changes,
documented with a social segment in the
regional data base; regional modeling for
predicting social changes can be started
only very slowly.
Welfare effects, in a special sense defined
by the Clean Air Act, includes damage of
pollutants to materials from fossil fuel
systems; indirect effects (savings) in
this area and others should arise from
nuclear systems and unconventional alter-
natives .
The minimal program would establish a
capability for the evaluation of the
effects of atmospheric pollutants (acid
rain) on national memorials, public
buildings, works of art, and irreplaceable
structures.
Effects of extraction processes on land
for any fuel cycle have aspects of public
welfare which need research as an input
to Assessment and Policy Formulation.
Specific objectives to be addressed in
the FY 75-79 time period are:
-Assessment of material deterioration
problems in field at present.
-Factors effecting erosion of stone -
characterization and parametric evaluation.
-Study of pigment degradation in
artistic and other works.
-Assessment of contruction metals
and their uses in construction, art and
transportation.
-Develop a reasonable standard proto-
col for societal assessment techniques
to be used by different energy R&D groups
(opinion surveys, handbooks, etc.).
-Develop and test models of value
changes in impact assessments. Compare
results of system analyses used by all
groups.
-Implementation and dissemination
of results (in lay terms) to government
policy-making bodies, etc.
Environmental Assessment and Policy
Formulation - Goals:
To provide mechanisms for rationally
integrating environmental considerations
into the energy policy decision making
process. These mechanisms must include
(1) evaluation of the institutional,
economic, sociological, and technical
implications of environmental impacts
and controls, (2) development of infor-
mation synthesis methodologies for
determining cost/benefit and other
relationships; and (3) analyses of
alternative energy systems using these
tools with development of recommenda-
tions for optimal energy policies
compatible with environmental and public
health goals.
Energy issues are inextricably inter-
woven with all aspects of the modern
society from economics, and environment
to its very life style. Any major
change affecting the terms and
conditions under which energy is produced,
distributed or consumed impacts in many,
varied and often unpredictable ways
throughout all segments of the society
affecting the way people work, live, and
spend their leisure time. Furthermore,
the effect is often non-uniform with
respect to regions of the country and
with the population. For example, an
attempt to produce "clean" energy for
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urban areas can adversely impact already
"clean" rural areas by disrupting the
land, air and water environment previously
used for agriculture. This impact can
in turn impact the population in urban
areas through higher food costs.
Energy issues also affect international
politics, national security, and
international balance of trade. It is
probably fair to say that no other single
sector of the economy has such pervasive
efforts on all aspects of life.
The Implementation Research objectives
are directed at providing the basic
knowledge to define the constraints
imposed on energy systems when applying
appropriate environmental impacts; and
means for preventing, controlling or
avoiding environmental insults. While
all of these areas are essential for
developing and implementing a sound
national energy policy, they are not
sufficient to identify and achieve an
energy program that attempts to optimize
all the societal costs, where both costs
and benefits are viewed to include the
full range of environmental, institutional,
social and economic factors.
It would appear that the credits and
debits of an energy system cannot be
totaled on an accounting balance sheet.
However, it would appear that an attempt
should be made to provide the energy
policy decision-makers, be it at the
Federal, state, local or plant level, with
better tools to weight the various insti-
tutional, economic, social and technolo-
gical factors. In essence this is the
purpose of implementation research.
Priority research objectives in the FY75-
79 time period are:
-Determine the ability of existing
and proposed institutional structures for
energy decision-making to accurately
represent the environmental concerns of
all segments of the population.
-Development of methodologies for
intercomparing the environmental risks
and benefits of highly disparate energy
systems.
-Research leading to improved
quantification of both environmental
costs and benefits to society and develop-
ment of techniques by which the cost of
pollution control can be more effectively
internalized.
-Development of methodologies for
synthesizing information produced by the
environmental research programs.
-Analysis of alternative implementa-
tion techniques for reducing environmental
impact (e.g., Environmental Impact
Statements, Environmental Standards,
economic incentives).
Control Technology Research
The objective of the control
technology research agenda is to define
the requirement for technology needed to
reduce or inhibit environmental degrada-
tion associated with or potential to state-
of-the-art or new energy system technologies
The environmental control research agenda
is directed toward the development and
demonstration of the technology necessary
to achieve material energy self-sufficiency
at a cost which is both environmentally
and economically acceptable.
This is a particularly challenging objective
because of the inherent environmental
"dirtiness" of the domestic energy resources
which are sufficient to meet our expanding
energy needs in the near-term, specifically
coal and shale oil.
The means for meeting this challenge
include control process technology, fuel
changing or modification, improved dis-
persion of residuals, land use planning
to minimize environmental impact, basic
energy process modification, and con-
servation to reduce energy demand.
The primary environmental control
development requirements may be
summarized as follows:
-Fine particle control for metals,
sulfate and condensed organics.
-Improved sulfur oxide and nitrogen
oxide control through fuel pretreatment
as well as combustion modification and
flue gas cleaning.
-Capability of "zero" discharge for
water pollutants at all phases of the
energy cycle.
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-Waste heat use and dispersion.
-Land reclamation and subsidence
control.
High Temperature Gas Turbine
High Temperature Turbine - Low BTU
coal gasification, integrated with a
high temperature turbine offers the
potential for improved thermal efficiency
in electrical generation. Aside from the
need for essentially total particulate
removal prior to the turbine, as dis-
cussed under Low BTU gasification,
control of increased NOX emissions
caused by high temperature nitrogen
fixation must also be addressed. Dry
control methods for NOX are needed if
excessive water pollution and usage as
well as turbiee efficiency degradation
is to be avoided. The proposed control
R&D program would address control of
combustion reactions through combustor
design followed by verification testing
and demonstration as an integral part
of the high temperature turbine develop-
ment. This control technology will
also have application to advanced auto-
motive turbine development.
Advanced Cycles, Fuel Cells, and Other
Concepts
Magnethohydrodynamics - Emissions
of both sulfur oxides and nitrogen oxides
will have to be controlled for both open-
and closed- cycle processes operating
with fossil fuels. In the open-cycle,
demonstration of total ash and metallic
seed material must be achieved. The
most pressing control R&D requirements
will be in the control of NOx at the very
high temperatures and the application of
fine particulate control developed for
conventional combustion applications to
the specific requirements of open-cycle
MHD.
Use of Wastes as Fuels - Effort must
be directed to the development and
demonstration of pyrolysis techniques
for producing solid, liquid and gaseous
fuels from municipal solid wastes
without the concurrent release of
dangerous byproduct. Direct and mixed
burning technology must be demonstrated
on the range of industrial and utility
combustion systems with specific gaseous
and particulate air pollution control
systems.
Advanced Auto Rail, Ship and Air
Propulsion
Air pollution control R&D is required
to (1) assess the emission characteristic
of new engine system and alternative
fuels and (2) develop design modifications
and operating procedures to achieve emission
control requirements.
Energy and Fuel Transmission Distribution
and Storage
Control requirements focus primarily
on the understanding and control of high
voltage (HV) transmission system effects;
zone noise and non-energy electromagnetic
radiation. A second area of development
is in improved leak detection add control
devices for pipeline systems. The
critical importance of this capability
to the environmentally sound development
of the Alaskan Pipeline make Federal
involvement important to insure both time-
liness and operational adequacy.
Increased Production of Oil and Gas
Of particular concern during oil and
gas exploration are the accidental
spillages and releases of brines and
hydrocarbons that may occur from test
drilling, both onshore and offshore. Efforts
should also be directed to demonstrate the
practical application of existing control
techniques and to determine the operational
adequacy of these techniques. Of particu-
lar need, as more emphasis is placed on
offshore drilling, is improved techniques
for flowout prevention as well as develop-
ment and demonstration of baseline
protection and nectoration methods for
oil spills. Once the technology is
developed it should be included as a
requirement in offshore petroleum
operations. A second major environmental
need associated with both nuclear and
non-nuclear stimulation and in situ
oil shale retorting is the ability to
predict, monitor, and control seismic and
subsidence effects. A third control R&D
need is the development and/or adaptation
of technology for the removal of contami-
nants at the well head. These include:
(1) nitrogen which is the major con-
taminant in much low-grade gas and
(2) wasted natural gas at combined-oil
and gas wells. This program is especially
needed to demonstrate efficient and
economical contaminant removal systems
140
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permitting recovery of natural gas from
small individual wells.
In oil shale processing a program is
required to characterize the environ-
mental burdens associated with the
various industry developed processing
techniques and to develop and demonstrate
the necessary environmental controls.
Pollutants which will need to be considered
include sulfur, nitrogen, particulates
and hazardous trace metal air and water
emissions, and the large solid waste
emissions represented by the retorted
shale.
Surface Mining - The thrust of the
control technology research and develop-
ment for surface mining of coal is to
develop and demonstrate suitable methods
for control of acid mine drainage and
reclamation of the ground water system and
land disturbed by mining operations.
Research in soil stabilization is required
to prevent erosion by water and wind.
Further, the restoration of natural surface
drainage and aquifers are necessary to
minimize long term ground water effects.
Underground Mining - Control research in
subsidence and acid mine drainage is vital
if the vast underground deposits of coal
are to be used in an environmentally accept-
able manner. Annually, some 500 billion
gallons of mine drainage containing
millions of tons of acids, acid salts
and alkali salts degrade over 10,000
miles of surface streams and more than
15,000 acres of impounded water. Further,
subsidence problems and fires in abandoned
mines and tailing piles create hazardous
conditions which must be controlled.
Oil Shale Mining - With the expansion
in use of oil shale, the land require-
ments and potential environmental burden
caused by mining and spent shale disposal
will be significant. Some of the
potential environmental problems to which
the control technology is addressed are:
-Lowering of water tables in the
vicinity of the mine.
-Erosion and leaching of spent shale
deposits.
-Worsening of water quality with time
as mine depth are increased.
-Long term ecological system dis-
ruption resulting from inadequate land
reclamation techniques.
Specific emphasis should be placed on the
development of methods to minimize
water utilization.
Direct Combustion
The first control technology which
should be developed under this area is
fluidized bed combustion of coal in
the presence of limestone. The
envisioned fluidized-bed boiler should
permit combustion of high-sulfur U.S.
coals for electric power generation with
simultaneous control of SOx and NOX. Data
indicate that, in comparison with uncon-
trolled conventional boilers, fluidized-bed
boilers offer potential for 90 percent
reduction in SOx and major reduction in
NOX. Since even the dirtiest fuels can
be handled, control can be effected
without change in fuel type, quality or
origin.
Ongoing development and demonstration
of combustion modification techniques
for the control of NOx emission from
conventional combustion sources should
also be continued to ensure long-term
maintenance of the NOX ambient air quality
standards.
Efforts have shown that (1) flue gas
recirculation is the most effective com-
bustion control technique for NOX emission
from nitrogen fixation and (2) staged
combustion is the most effective control
method for NOx emissions from fuel nitrogen
conversion. The application of this
technology has controlled the NOx emission
from gas and oil fired utility boilers to
a level of 150-250 ppm. In short-term
testing, combustion modifications have
also resulted in NOX reductions of up to
50 percent in commercial coal-fired utility
boilers. In addition, burner and furnace
design variables have been shown to cause
widely varying NOX emission levels in all
boiler categories. Future R&D efforts
will apply the results of this research
to the pilot and commercial scale demon-
stration of combustion control technology
for existing and new combustion sources
in all size categories.
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Synthetic Fuels
Although much of the control required
for each sub-task may be developed with
funding in Task 3D1, specific problems
will be identified here with each
technology.
1. High BTU Gasification - Control
activities contained in this section
should be directed at demonstration of the
air, water, and solid waste control
technology when applied to the specific
conditions associated with the Hi-Gas, C0£
Acceptor, Synthane and Bi-Gas.
2. Coal Liquification - Control
technology requirements for this process
center around the development and
demonstration of appropriate fine particu-
late controls and the storage and disposal
of slag (ash) and the elemental sulfur
produced as a byproduct of SRC processes,
H-coal, advanced, and multiple.
3, Low-BTU Gasification - The
development of advanced coal gasification
processes will require two major R&D
efforts: (1) high temperature/high pressure
gas cleaning to remove gaseous pollutants
as well as fine particulate which can
cause both erosion of system components
and environmental degradation and (2)
isolation and disposal of solid waste
streams to control ecological damage.
Large quantities of solid wastes are
generated from the ash content of the coal
and the chemical processing to remove
sulfur. The effort should perform a
comparative evaluation of the molten
salt and dolomite high temperature clean-
up systems at the pilot scale leading to
selection of the best for demonstration.
Pilot and demonstration should be inte-
grated with the basic gasifier systems to
which they are to be applied.
4. Synthetic Fuels Pioneer
Program - A major concern rests with
synthetic Fuels Pioneer Program. The
objectives of the program as defined
are valid and should be achieved.
However, the plans for incorporating
environment controls into this program
are not evident. While it is not
recommended that this vital demonstra-
tion program be delayed, it is
recommended that work begin immediately
on defining the control technology
requirements and that the best available
controls for air, water and solid waste
handling be commercially demonstrated
in conjunction with the two selected
synthetic fuel processes.
Environmental Control Technology
The objective of this program should
be to develop the environmental controls,
in conjunction with the various coal combus-
tion processes to insure minimal environ-
ment insult in all media resulting from
the implementation of these processes.
The technology required for these controls
are:
-Pre-combustion - Development of
physical and chemical coal desulfurization
technology will allow the continued use
of coal in facilities not suitable for
post-combustion conversion. In concert
with the development of this technology
must be the development of controls for
the liquid and solid waste byproducts
generated. This technology will permit
the essentially complete removal of sulfur
as well as particulate and associated
trace metal impurities in coal. This may
be the best approach to the control of
sulfate formation resulting from coal
combustion.
-Post-combustion - The cleaning of
flue gas emitted after combustion offers
a near-term solution for meeting existing
SOX ambient air quality standards. Addi-
tional research and development, however,
is necessary to adequately demonstrate
reliable and efficient performance and
to control environmental side effects of
this technology. A major problem exists
in the collection of fine particulates
( 2 micron) emitted after combustion.
Conventional control equipment is highly
inefficient in collection of this most
offensive particulate size fraction.
Candidate control approaches include
condensation scrubbing, electrostatic
augmentation and agglomeration,
Safety-Reactors and Fuel Handling
Control technology to assure that
radioactivity from fission fuel cycles
does not become a significant environ-
mental pollutant must be developed if
the currently projected growth rate of
the nuclear power industry is to be
achieved. The characteristics of radio-
activity are such that two types of
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potential problems must be dealt with.
The first stems from those radionuclides
such as 1-131 with short half-lives which,
if released in sufficient magnitude could
result in an immediate threat to the
environment or public health; this type
of release is considered in depth during
the sitting, design, and operation of
radioactive effluents from nuclear facili-
ties have been made in the past few years
for systems related to the uranium fuel
cycle. While final demonstration of the
adequacy of this new technology remains to
be verified utilizing environmental
monitoring and surveillance programs on
the large LWRs currently beginning
operation, it does not appear that major
Federal R&D funding for further develop-
ment of such control technology is
required. Development of control
technology for advanced systems (e.g.,
LMFBRs, advanced converters using the
thorium - U-233 .fuel cycle) cannot be
precisely defined at this time, but will
be required at a pace dictated by the
progress of development of such systems.
At this juncture, it appears that radio-
nuclide control technology being
developed for the uranium fuel cycle
in LWRs will largely suffice for the
other fission-fuel cycles.
The second potential problem stems
from radionuclides with long half lives
(e.g., 1-129, the actinides, and, to
a lesser extent, Kr-85 and tritium);
the longevity of such radionuclides
dictates that special consideration be
given to assure that accumulation of
releases from all nuclear facilities
(present and future) will not ulti-
mately result in an environmentally
unacceptable situation for a given
ecosystem.
The projected increase in the number
of LWRs and the onset of large through-
puts of spent fuel in the reprocessing
plants requires that technology be
developed over the next few years for
collection and storage of krypton-85
and tritium. Much of the basic research
in this area has been completed. A more
crucial near-term problem is the lack of
available criteria, guides, and environ-
mental standards for the long-term alpha
emitters (e.g., actinides) because of
the current production of plutonium in
LWRs, as well as its potential use as
fuel in LWRs and LMFBRs. Lack of
guidance in this area is beginning to
impact adversely fuel reprocessing and
waste handling practices. Unfortunately,
there are major uncertainties on the
transport of these very toxic materials
in the environment. The problem is
further complicated in that current
technology results in mixtures of the
long-lived actinide waste with high-
level radioactive waste which would
otherwise require isolation for only a
few hundred years. Some effort to develop
efficient (99.9%) separation of the
actinides from other high-level waste
components is underway. Success in this
area would facilitate subsequent "ulti-
mate" removal of this material if
subsequent concepts (e.g., space disposal
or transmutation) can be made practicable.
With regard to radioactive waste storage
and disposal, extensive efforts for
handling high-level wastes are already
underway, with major emphasis on storage
in a retrievable surface storage facility
and disposal in a bedded salt geologic
formation. Some preliminary information
also exists on other geologic formations
and the technology of using space is
disposal sites. High level waste solid-
ification methods exist in this country
and abroad, and solidification methods
which would ease subsequent waste storage
and disposal problems are currently under
development. Current efforts for reducing
the volume of solid, low-level alpha wastes
are also underway, but storage or dis-
posal of such wastes requires improvement.
Significant information and methods already
exist for spent-fuel shipping methods
(e.g., casks); however, this technology
base will likely have to be improved in
view of the major increases in spent-fuel
shipping which are anticipated. Methods
of adequately and economically decommission-
ing nuclear facilities at the end of their
useful life do not currently exist.
An additional major near-term problem is
the long time period required to select
and judge the adequacy of sites for major
industrial endeavors in general and nuclear
facilities in particular. Nuclear facility
siting is particularly difficult because
of the environmental and public health
risks associated with potential accidents,
as well as the "normal" environmental
impacts resulting from plant effluents
(waste heat and radionuclides), use of
large quantities of water for cooling,
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land use for the s-ite and transmission
lines, etc. The need for additional efforts
in the nuclear facility siting area is
particularly important in the near-term
since nuclear plants for generating
electricity are a current viable alterna-
tive to the use of fossil fuels which can
be utilized to higher advantage in other
endeavors (e.g., transportation). With
a projected need for several hundred new
sites for nuclear facilities by the year
2000, increasingly severe difficulties
will be encountered over the very near term
in obtaining sites that will adequately
meet all necessary siting requirements.
Many potential sites are likely to involve
complex siting problems. Continued
improvements in siting technology are
needed to assure that siting needs can be
met.
In addition to restraints related to site
selection methods, a major constraint to
siting flexibility is a lack of large
supplies of cooling water at otherwise
acceptable -ower plant sites. This
restraint could be significantly eased
with the development of air cooling
methods, i.e., dry cooling tower
technology. Without the option of dry
cooling, power plant siting will become
extremely difficult in many regions of
the Nation by the early 1980's. There is
a considerable foundation of existing
experience (including foreign experience)
upon which to build, but this experience
derives principally from applications
where lifetime and reliability require-
ments have been much less demanding and
critical than for large scale power plant
use. There is some existing foreign
experience with a small number of dry
cooled power plants up to about 300 MWe in
size. In the United States, however, the
largest dry cooled power plant operated
to date is a 20 MWe fossil unit of the
Black Hills Power and Light Company
located at Wyodak, Wyoming. A major
effort to demonstrate dry cooling tower
technology on a large scale has recently
been initiated utilizing a joint
Government-industry arrangement.
Another area which requires additional
R&D to increase nuclear facility siting
flexibility involves the development of
adequate radiological emergency pre-
paredness capabilities. Current
technology in this area has concentrated
on preparedness for relatively low-level
releases, and utilizing guidance originally
developed for nuclear weapons fallout. In
the past year, a concerted effort on the
part of several Federal agencies (AEC,
DCPA, EPA, HUD-FDAA, and HEW) has been
undertaken in the area of radiological
emergency preparedness which should be
of value in the event of incidents or
accidents in nuclear facilities. Basic
guidance is being developed for state and
local officials who would have to act in
such emergencies. While extensive
emergency monitoring capability appear
available for small releases to the
environment and for monitoring of food-
studd, adequate rapid emergency monitoring
systems which could aid in reaching
decisions concerning the need for rapid
action (e.g., evacuation do not currently
exist) .
In general the recommended program included
the following:
-Development and demonstration for
collection and storage for krypton and
tritium effluents from nuclear facilities.
-Development and demonstration of
facilities for reducing the volume and
subsequent storage/disposal of low-level
alpha-contaminated solids.
-Development and demonstration of
methods to separate 99.9% of the transu-
ranic from high-level wastes.
-Long-term development of methods of
removing actinides (space disposal,
transmutation).
-Construction of the Retrievable
Surface Storage Facility for high-level
waste.
-Development of a high-level waste
disposal facility utilizing the bedded
salt geologic formation concept.
-Development of improved spent fuel
shipping methods.
-Development of adequate economical
methods for nuclear facility decommissioning,
Fusion
Controlled thermonuclear technology
is in an early stage of development, and
its environmental impact is not quantifi-
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able at this time. Identifiable control
considerations, however, include the
following: Appropriate clean-up techniques
will be required for possible coolant
systems under consideration (helium,
flourine-beryllium, or lithium).
Tritium leakage and inventory in fusion
systems must be kept at a minimum, and
tritium separation methods may be
required on a longer time scale to reduce
both on-site and off-site radiation
exposures. The investigation of improved
structural materials to replace long-
lived niobium (e.g., vanadium alloys,
containing titanium and chromium) may
be desirable for reducing long-term
radioactive waste storage requirements.
Solar
The use of solar energy appears
promising from an environmental stand-
point. This is particularly true for
the decentralized applications to direct
heating and cooling of buildings. In
the centralized approaches, however,
potential environmental impacts unique
to each approach must be evaluated and
the resulting control requirements
integrated into its development. In
the case of Solar Thermal Conversion
Systems, large areas of land are
required (10-20 square miles per
1,000 MWe). This can create an exten-
sive ecological impact and will probably
require carefully developed siting and
construction criteria. These impacts
will be accentuated by the local
change in albedo created by the solar
collectors. In the case of Ocean Thermal
Conversion, effluent treatment systems
must be incorproated for control of
biocides and corrosion inhibitors will
be required to meet discharge require-
ments.
Bioconversion to fuels will require
liquid and solid waste disposal systems
tailored to meet zero discharge require-
ments. This can be particularly challen-
ging in the case of fermentation plants for
animal feedlots wastes. In the case of
Photovoltaic Electric Power toxic metal
films will be used in large conversion
arrays. These must be controlled
throughout the manufacturing, fabrica-
tion and operational phases to avoid danger-
ous atmospheric and groundwater emissions.
Geothermal
Geothermal energy sources can create
serious environmental impacts through
emissions of gaseous pollutants and
highly mineralized brines, as well as land
subsidence, induced seismic activity,
noise, and destructive land use. The
cost-effective disposal of such pollutants,
preferably by conversion to practically
recoverable substances or reinsertion into
the lithosphere without interference with
the energy extraction process is the
primary goal of the environmental control
program. In addition, the very low thermal
efficiency of geothermal systems (5-20
percent) can create a heat load which may
require new disposal mechanisms. Although
many potential environmental problems have
not yet been quantified because of the
early development problems state of all
but dry steam systems, it appears that much
of the pressing air and water pollution
control needs can be addressed by the
application of technology developed for
fossil fuel pollution control. What is
specifically needed in the near term is
the adaptation and performance evaluation
of these control systems concurrent with
the development of each type of geothermal
source.
PROGRAM DEVELOPMENT
The translation of the goals and
objectives defined in the preceding section
into a task level research program has
been performed by an Energy R&D Planning
Task Force established within EPA. The
principle objective of the Task Force,
composed of representation from each of
the technical disciplines within the Office
of Research and Development has been to
develop a comprehensive environmental
science and control technology R&D agenda
which is maximally responsive to the
environmental needs of lead energy agency
development and policy activities.
In order to consider the energy-related
environmental R&D agenda in a problem
oriented rather than disciplinary basis
the Task Forcfe was organized in a matrix
fashion according to five major activity
areas in energy development. These were:
• Energy Conservation
• Fossil Fuel Extraction
• Fossil Fuel Combustion and
Conversion
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• Nuclear Energy Systems
• Advanced Energy Systems
(Solar, Geothermal)
The steps followed by the Task Force in
achieving this objective may be summarized
as follows:
1. Energy R&D and Policy Timeline Definition
The first step in R&D program development by
the Task Force was the identification of the
energy development and policy decision mile-
stones, and the associated schedules which
the environmental R&D program is intended to
support. These timelines, defined through
communication with the Federal Agency
responsible for each technical or policy
development, represent a summary picture of
Project Independence both in content and
schedule. This timeline picture has been
published and is available from EPA.
2. Environmental Factors
In order to provide a basis for establishing
research priorities as well as scoping "the
required EPA disciplinary research outputs,
the Task Force developed an initial qualita-
tive and where possible, quantitative assess-
ment of the pollutants, by-products, and
resource requirements associated with each
development or policy timeline.
3. Major Environmental Products Definition
This activity involved an identification by
the Task Force of the major environmental
products which will be needed to provide an
integrated environmental recommendation
supporting a specific energy development or
policy milestone.
4. Program Output Development
Based on the preceding steps the Task
Force identified specific achievable
outputs which would be required from each
disciplinary Program Element in order to
develop the integrated environmental re-
commendations bearing on energy technology
and policy.
5. Program Implementation
The definition of program output
requirements completed the formal efforts
of the Task Force. These requirements
have, in turn been translated into a
research plan specifying objectives,
priorities, and resources by each of the
disciplinary program areas within the EPA
Office of Research and Development.
Table 1 summarizes the results of this
planning in terms of proposed resources
associated with each disciplinary program
area as a function of activity area in
energy development. The implementation
and translation of research results into
EPA recommendations bearing on the energy
decision-making process will involve the
following organizational activities:
(a) Each ORD disciplinary program
area will manage its energy
related environmental research
program according to the pro-
gram output requirements de-
fined by the Energy R&D Task Force.
These requirements focus, both in
technical content and time, on
the key decision milestones in the
technology and policy develop-
ments associated with achieving
energy self-sufficiency.
(b) Integrated assessments of the
program area research products
will be performed in order to
relate the damage potential
associated with developmental
energy technologies or policies
to the costs of alleviating these
damages in environmental, econo-
mic, and social terms. These
efforts will be performed
according to schedules which
permit the research results to
be effectively applied to
specific energy R&D or policy
decision points. These integrated
assessments will be performed by
a new analytical group being
established .in the EPA Washington
Environmental Research Center
(WERC).
(c) The Energy R&D Planning and
Coordination Group within
the EPA Office of Research
and Development will act as
the focal point within ORD
for the translation of the
integrated assessments either
into recommendations bearing
on technologies under develop-
ment by the energy research
community or into support for
Agency policy. The responsi-
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bilities of this office will
also include; (1) Maintaining
accurate definition of the
national energy technology
developments together with
their associated schedules
(2) Developing and coordina-
ting the environmental re-
search strategies associated
with these technologies and
(3) Insuring that EPA enrgy
related environmental R&D
programs are conducted in a
manner responsive to these
strategies and the associated
environmental goals.
CONTRIBUTION TO THE ENERGY SYSTEM
Implementation of the environmental
research program discribed will make a
vital contribution to the national energy
system in three critical areas (1) cost
(2) usability of domestic energy sources
and (3) timelines in implementing energy
system initiatives.
With respect to costs, at least $90
b illion will be spent by the energy
industries in the period 1971-1980 alone,
to meet established environmental require-
ments for the limits set on air and water
pollutants. This amount of pollution
c ontrol expenditure will add about 15 per-
cent to the wholesale delivered national
cost of fuel over the same time period.
By providing the technical and scientific
environmental knowledge to be gained
from this research and development
program it will be possible to develop
and demonstrate environmental controls in
conjunction with developing energy tech-
nology rather than having to rely on the
costly retrofit programs exemplified by
the current SOX control program. It
is estimated that the environmental cost
to achieve the broad environmental
objectives could in this manner be reduced
to less than 10 percent of the wholesale
delivered national cost of fuel.
The technologic development and imple-
mentation of coal-based energy systems
f or near-term energy self-sufficiency must
be sensitive to the effects that re-
siduals from the system will have on
health, welfare, and the ecological system.
I f this sensitivity is incorportated into
the development and implementation
process these domestic resources can be
broadly utilized in harmony with the
environment. These effects act as a
constraint on the technical requirements
for control, the siting of the system
and the value of the system as a producer
of energy. Further, knowledge of the
effects of the system before it is im-
plemented will avoid the enormous costs
a ssociated with the need to retrofit
c ontrols on an operational system,
or to "clean up" the wastes once they
have the technical basis for understanding
these environmental consequences and
b alancing the environmental and energy
system costs in an equitable manner to
the society.
While, in theory, the environmental
r esearch program does not add one BTU
to the energy balance, in practice the
energy supply forecasts made by each
technology panel are dependent on
demonstrating to A concerned and increasing
sophisticated public that environment
impacts are understood and controllable to
an acceptable level. Recent history has
demonstrated that delays can occur due
t o lack of a sound understanding of energy
related environmental questions. Examples
o f these ddelays which have affected energy
supplies have been the Alaska Pipeline
and delays in nuclear liscensing. Delays
also affected implementation of environ-
ment controls as exemplified by litigation
of ulitities against installation and
operation of SO flue gas clean techno-
logy. The environmental research program
would also provide the basic understanding
necessary to evaluate and measure
environmental impacts, determine their
effects and to develop and implement
timely and minimum cost environmental
controls.
Successful implementation of this
environmental research program will
affect all aspects of the energy
program and could be the definitive
determinant of optimal energy source
use and of the feasibility of specific
technology aapproaches. Disruption
o f the energy program can be prevented
by anticipating potential problems
related to each technology and by
d etermining as rapidly as possible
the effects on health, ecosystems and
society. Perhaps the largest barrier
t o be faced is the need to convince
energy-related technologists and
planners that this seemingly
distractive commitment must be made
at the outset to prevent very major
disruptions in energy production.
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c
Moderator:
G. Strasser
Strasser Associates, Inc.
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ENVIRONMENTAL QUALITY IMPROVEMENT THROUGH SYSTEMATIC
IMPLEMENTATION OF POLLUTION CONTROLS
* *
N. Dee, H. Reiquam, P. Choi
Battelle-Columbus Laboratories, Columbus, Ohio 43201
El Paso Natural Gas Company, El Paso, Texas 79999
ABSTRACT
The Clean Air Act of 1970 and the comprehensive Federal Water Pollution Control Act
Amendments of 1972 require achievement of national ambient air quality standards on the
one hand and specific water effluent standards for individual facilities on the other. In
the process of improving the air and water quality individually, these limitations on
pollutant discharge often have important secondary impacts. The control technologies
which are aimed at achieving the discharge limits often generate new waste streams which
in turn require controls. Without a systematic assessment of these impacts, there is
substantial risk that pollution control strategies for controlling pollution in one medium
will exacerbate problems in another medium. This paper describes and discusses the
elements necessary for this assessment. The assessment methodology consists essentially
of developing an index for each control strategy and comparing it with a corresponding
index for the uncontrolled case. The index is a function of three elements: (1) the rate
of production of pollutants; (2) the behavior of those pollutants in the environment;
(3) the relative importance of each pollutant. Application of these three elements yields
an expression of strategy effectiveness in terms of the net effect of a particular
strategy upon the environment. A case study of an integrated iron and steel production
facility was used to verify the methodology. In addition to the strategy effectiveness
index, the costs associated with each strategy in terms of energy consumption, capital
costs, and operating costs, were also developed.
INTRODUCTION
In the United States, the maintenance
of a high physical quality environment for
all is being addressed in a piecemeal
fashion. Instead of viewing the
environment as a complex system having
many interrelationships, it is viewed
simply as having three independent media;
land, water, and air. Further, it is
assumed that by maintaining quality in
each of these media, a high quality can be
maintained for the entire environment.
Following this philosophy of
environmental quality management, quality
standards are established for each medium.
These standards are used to regulate the
pollutants discharged into the media, and
thus maintain the desired environmental
quality. Examples of standards that are
currently being used to regulate pollutant
discharges are the Clean Air Act of 1970
and the Federal Water Pollution Control
Act Amendments of 1972.
Unfortunately, this philosophy fails
to consider the interaction or cross media
impact that exists between media during
the implementation of standards. Such
interaction may cause the implementation of
a standard on a single medium to improve
that medium but to decrease the net quality
of the three media.
Effluent standards are a means of
maintaining a high quality environment.
These standards are implemented through the
use of controls on the waste discharges
into the three media. Cross media impacts
are created from the new waste streams
generated by the controls. Without
150
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systematic assessment of all waste streams,
those generated by processes and those
generated by processes and those generated
by controls, there is risk that the
pollution controls will not provide the
desired high quality environment.
This paper describes and discusses the
elements necessary for a systematic
assessment of pollution control strategies.
It compares the relative effects of trading
impacts in one medium for impacts in
another medium. The methodology is used to
develop a Strategy Effectiveness Index for
the selection of the controls necessary to
maintain a high quality environment.
METHODOLOGY
Traditionally, pollution control
strategies have been selected almost
entirely on their efficiency in reducing,
modifying, or eliminating pollution in one
selected medium: air, water, or land. As
controls become more stringent, however,
experience indicates that cross-media
impacts associated with control strategies
often can be serious. A systematic
analytical approach is required to examine
strategies within a total environment
framework. This paper describes a
methodology that can be used to
differentiate between alternative pollution
control strategies based on their control
effectiveness in all three media.
Industrial processes generate waste
streams which are either discharged
directly to the environment or modified by
a control process, and then discharged to
the environment. The control process in
turn generates its own waste stream which
is also discharged to the environment.
Both of these waste streams are normally
defined by various physical/chemical
pollutants. In general, each of these
pollutants affects the environment to a
different degree, and the significance of
the effect on the total environment is
different.
To use this pollutant information for
comparing control strategies or for
selecting the "best" strategy, it is
desirable to express the information in a
single index. This index requires that
trade-offs between pollutants be explicitly
stated and provide a simple means for
differentiating between strategies. The
Strategy Effectiveness Index (SEI) is
designed to satisfy these needs.
The SEI is obtained by subtracting the
impact resulting from a particular control
strategy from the impact resulting from no
control. This impact is defined by an
Environmental Degradation Index (EDI).
Therefore, the effectiveness of any
strategy can be expressed in terms of SEI
by using the relationship:
SEI = EDI, - EDI
s (uncontrolled) s
The EDI is a function of three
elements:
(1) The rate of production of
pollutants
(2) The environmental damages created
by each pollutant
(3) The relative importance of each
pollutant.
Rate of Production of Pollutants
Waste streams from industrial
processes and control strategies can be
defined by their physical/chemical
parameters. Parameters for air, such as
sulfur oxides, lead, and particulates; for
water, such as alkalinity, sulfates,
chlorides, and dissolved solids; and for
land, such as organic refuse and glass,
might be used to describe the waste
streams.
The pollutants included in this
element are generated in the production and
the control process. They are measured by
performing a materials balance on both of
these processes. To aid in developing a
comprehensive list of pollutants, a
three-step structure is used:
STEP 1. Identify expected pollutants
for a specific industry by
using the industrial
classification developed by
EPA.
*Reiquam, H., Dee, N., and Choi, P., "Development of a Cross-Media Evaluation
Methodology", Final Report to Council on Environmental Quality and Environmental
Protection Agency, by Battelle-Columbus Laboratories, January, 1974.
151
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STEP 2. Identify the pollutants
associated with each defined
control strategy.
STEP 3. Categorize each pollutant in
a two-level hierarchy
consisting of the medium at
the first level and the
pollutant at the second.
Environmental Damage Created by Pollutants
The environmental damage associated
with each control strategy is a function
of the waste generated and its behavior in
the environment. The potential damage of
waste production is first measured by using
damage functions. This potential is then
adjusted by the pollutants' behavior in the
environment.
Development of Damage Functions
The potential impact resulting from
the discharge of a pollutant into a medium
is measured by a "damage function". This
function transforms the total production
of a pollutant discharged, industrial and
control, into a corresponding index of
potential environmental damage. The index
is a number between 0 and 1, where 0
denotes no potential environmental damage
and 1 extremely high potential
environmental damage.
The functional form relating the total
production of a pollutant discharged to
potential environmental damage can be
described as a general S-shaped curve as
shown in Figure 1.
1.0
Magnitude
of Potential
Environmental
Damage
(d )
0
u-a
The exact mathematical relationship of the
damage function is described by the
cumulative density function of a normally
distributed random variable, where d_ is
the index of potential environmental
damage for discharging pollutant p, x is a
possible rate of pollutant discharge, y
and a are mean and standard deviation
respectively, and Z is the actual amount of
pollutant discharged. The measurement of a
pollutant goes from 0 to some maximum value
Total Pollutant Production Rate
Figure 1. Form of damage function.
Z -1/2 I- ^) dx
/ ' "
o
Behavior of Waste in the Environment
Various pollutants have different
environmental impacts depending upon their
behavior after they are discharged.
Indeed, some wastes are not discharged in
the usual sense of the word, in that they
remain under the control of man. It is
clear that their ultimate potential for
damage probably is much less than that
associated with a pollutant which, once
discharged, can eventually pervade the
entire environment.
The damage functions described above
are based solely upon the maximum
production of each pollutant within each
industrial plant class. Modifiers of each
damage function then are required in order
to take into account these behavioral
differences. These modifiers are based
upon the natural dispersion of the
pollutants, their persistence in the
environment, and their capability of being
transferred by deposition, precipitation,
or leaching, from one medium to another.
In view of the fact that the interest here
is in the impact of one pollutant as
compared with another, the relative values
of these modifiers are most important;
modifiers for each pollutant damage
function must be obtained in a consistent
and straightforward way.
The equation used in calculating the
modifier is
C = x + t + e
where x, t, and e refer to the dispersal
range, persistance, and media exchange
capability, respectively.
152
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Values used in the computation of C
are given in Table 1. Once the value for
C has been obtained, the modifier, M, is
determined by multiplying C by 0.1. This
transformation allows the damage to remain
between 0 and 1.
TABLE 1. EQUATION VALUES
Dispersal local
Range (x)
Time (t) days
Exchange
(e)
no
transfer
regional
weeks
transfer
global
years
Procedure for Calculating Environmental
Damage
As indicated earlier, the magnitude of
environmental damage associated with each
control strategy under consideration is a
function of the production of waste
materials produced and the behavior of
those wastes in the environment. That
magnitude is obtained in three steps.
First, enter the appropriate damage
function with the mass of pollutant p
produced by the strategy; second, read dp;
third, multiply dp by the appropriate
damage function modifier M. The damage due
to production of each pollutant thus
depends upon specific consideration of an
industry, and upon general consideration of
the behavior of that pollutant once
released to the environment.
Relative Importance of Pollutants
Besides measuring the magnitude of the
damage caused by a pollutant discharge, it
is also necessary to measure the
significance of the damage to the
environment. Some pollutants affect many
elements of the natural and man-made
environment, while others affect only a
few. In addition, some pollutants cause
acute environmental damages while others
cause only chronic damages. The
differentiation between pollutant
discharges and their resulting damage is
obtained by relatively weighting all
pollutants. This weighting explicitly
indicates the significance of an
environmental damage caused by each
pollutant.
In assigning relative weights,
consideration must be given to the
different environmental conditions that
occur throughout the United States.
Regional differences occur because of the
different assimulative capacities of the
environment as well as the different
perceived importance attributed to
environmental damages by the population.
It is therefore desirable to obtain weights
for the three media and associated
pollutants for each of the many regions
throughout the United States.
There are many procedures available
for assigning relative weights. Two of the
most common are the use of judgment of
knowledgeable individuals, experts, and the
use of estimates of "social" costs or
damages. Both methods are discussed in
this paper.
Types of Weights
The three media used for disposal of
wastes are constant for all industrial
categories and pollution control
strategies, but vary in importance
throughout the United States depending on
physical, economic, and social
characteristics of the area. The
pollutants used to describe each medium, on
the other hand, only vary among industry
categories and control strategies. For
these reasons a hierarchical arrangement of
weights was developed consisting of two
levels:
Level 1:
Level 2:
Expert Judgment
Media weights
Pollutant weights.
Delphi Technique. Determination of
weights for the three media and associated
pollutants based on expert judgment is an
important and difficult task. Historically
weights were implicitly assigned using
"intuition". As the decisions became more
complex, it became necessary to develop a
technique for using expert judgment to
determine weights explicitly. It was
necessary for the technique to be
consistent, systematic, and explicit, and
to use inputs from several decision makers.
The technique used in this study to
obtain expert judgment is basically a
structured procedure for gaining consensus.
153
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In this technique individuals focus on and
debate issues anonymously, thus allowing
systematic determination of consensus or
dissensus. The technique helps illuminate
basic differences in values and beliefs,
and clarifies and removes communication
difficulties. The technique is conducted
through several rounds, with the results
of each round being given to the
participants prior to the next round. The
results of each round inform the
participants on the aggregate attitude of
the participants, and allow them to modify
or accept the aggregate results.
National Weights. This Delphi
procedure was used to obtain both levels of
relative weights; media and pollutant. The
first level, media, weights were obtained
by using opinions of individuals from the
Environmental Protection Agency located in
regional offices throughout the United
States. The second level, pollutant,
weights were obtained by using opinions of
experts at Battelle-Columbus Laboratories.
To obtain the media weights, members
of the Battelle research team visited all
ten regional offices of EPA. With the
cooperation of the director of each office,
appropriate staff were selected to
participate in the weighting exercise.
Each staff member first participated
in the delineation of an inclusive set of
subregions. Then they were individually
asked to express for each subregion their
opinion of the "level of concern about
each medium as a depository of wastes".
Their stated opinion was not EPA's position
on waste disposal, but a composite opinion
of the population, industry, and government
in the subregion. Basically, the EPA
personnel were sensors of the subregion's
position on waste disposal.
The information from these weightings
were used as input into a model that
estimates the media weights given only
physical, economic, and social data of the
subregion. This model eliminates the
necessity of performing a media weighting
every time a different pollution control
strategy is evaluated. It also provides
the sensitivity and flexibility of working
at various spatial levels.
The model is given below
where
i = medium index
J
k
MWik =
M =
characteristic index
subregion
medium weight for subregion k,
i = 1, 3
physical characteristics for
subregion k, j = 1, M
economic characteristics for
subregion k, j = 1, P
social characteristics for
subregion k, j = 1, N
total number of physical
characteristics
P = total number of economic
characteristics
N = total number of social
characteristics.
The model was estimated using a
statistical technique called Automatic
Interaction Detector (AID). The program
collapses measurements or estimates of
several characteristics into a single
medium weight. The AID program is a
multivariate technique for determining what
characteristics and levels of these
characteristics are statistically the most
reliable predictors of the weight.
After appropriate coefficients were
determined for this model a national
average of all 48 subregions was obtained.
These relative estimates which appear in
Table 2 are based on a total of 1000
points.
TABLE 2. ESTIMATES OF MEDIA WEIGHTS:
EXPERT JUDGMENT
Media
Air
Water
Land
Total
Weight
290
390
320
1000
154
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Economic Indicators
All costs of production and
consumption are not accounted for under our
present market institutions. While the
price of a product roughly corresponds to
the cost of the various inputs, the cost or
damage of side effects is seldom included.
Monetary approximation of these "social
costs" of production and consumption
provides a method of weighting the
importance or significance of the
respective damages to the environment
defined by the water, air, and land media.
Water Medium. The social costs of
discharging waste into the water medium are
given in Table 3. They are identified by
their impact areas which are not mutually
exclusive. Unfortunately, data were not
available to further delineate these costs
by the specific pollutant types.
TABLE 3. NATIONAL SOCIAL COSTS: WATER
MEDIUM, 1970 ($ billion)
Effects
(Loss Category)
Industrial
Municipal/Domestic
Recreation
Ecology (Change in
Total
Social
Costs
.5
1.75
2.4
.8
Source
1
2
1
3
Property Value)
Aesthetic
Total (Using 80%
Aesthetic Damages)
(60-100%
of
Total)
9.8
SOURCES:
1. Tihansky, Dennis P., Economic Benefits
of Water Pollution Control in the
United States, Environmental Protection
Agency, Washington, D. C., 1973.
2. Tihansky, Dennis P., Economic Damages
to Household Items from Water Supply
Use in the United States, Environmental
Protection Agency, June, 1973.
3. David Dornbush and Company, Inc.,
Benefit of Water Pollution Control on
Property Values, Prepared for
Environmental Protection Agency, 1973.
4. Ralph Stone and Company, Inc., Socio
Economic Study of Mutual Use of Water
Supply Reservoirs, Prepared for Office
of Water Resources Research, 1971.
Air Medium. The social costs of
discharging waste into the air medium are
given in Table 4. They are identified by
their impact area as well as by the
specific pollutants. The 1968 costs given
in the source study have been inflated to
1970 values using the consumer price index.
TABLE 4. NATIONAL COSTS OF AIR POLLUTION
DAMAGE BY POLLUTANTS, 1970
$ billion)*
Effects
(Loss
Category)
Residential
Property
Materials
Health
Vegetation
Total
SOx
3
2
3
0
9
.14
.47
.66
.01
.28
Partic-
ulate
2.
0.
3.
0.
6.
68
77
12
01
58
Oxidant
—
1.26
—
0.07
1.33
NOx
—
0.82
—
0.04
0.86
Total
5
5
6
0
18
.82
.32
.78
.13
.05
*Source—Barrett, Larry B., and Waddell,
Thomas E., Cost of Air Pollution Damage;
A Status Report, Environmental Protection
Agency, National Environmental Research
Center, Research Triangle Park, North
Carolina, 1973.
Land Medium. The social costs of
disposing waste on or in the land is the
least studied of the three media. Effects
that can be measured in terms of marketable
goods and services are usually the result
of airborne or waterborne pollutants, and
are determined elsewhere. Damages because
of aesthetic degradation are location
specific, while destruction of land form
or wildlife habitat from waste disposal has
not been measured adequately. As a
consequence, only the cost of waste
disposal is available.
The disposal cost is estimated to be
$5.7 billion dollars. It is based on
annual operating, maintenance, and
depreciation costs. The costs include the
collection and disposal of residential,
commercial, institutional, and industrial
waste. This cost figure is a significant
underestimation of the true social cost,
and hence this should be recognized when a
comparison of other media is made. The
155
-------
estimate is taken from the Council on
Environmental Quality Report of 1971.
Comparison of Alternative Weighting
Procedures
The two methods of determining the
relative importance of various pollutants,
expert judgment and economic indicators,
both have substantial merit. The common
scale underlying economic indicators has
obvious appeal; it has clear meaning to
everyone. The essentially qualitative
relative importance obtained from expert
judgment, on the other hand, is easily
rejected by people without technical
knowledge of the specific problem areas in
question. Yet, precisely because those
judgments are elicited from experts, they
will in general reflect the importance of
impacts for which no cost data are
available.
Three criteria were used to select
between the two weighting procedures;
consistency, comprehensiveness, and
flexibility. The expert judgment procedure
was judged more consistent than the
economic procedure. All expert judgments
were obtained under similar control
conditions while the economic data had wide
variation of sources and assumptions. The
same procedure was also judged to be more
comprehensive. Weights were available by
region and by pollutant. This was not true
for the economic procedure. Finally,
expert judgment was also considered more
flexible. It was felt that expert judgment
was easily adaptable to different industry
types and to different data availability.
Therefore, for the purpose of
comparing the effectiveness of competing
pollution control strategies, it is
concluded that the relative weights to be
assigned individual pollutants should be
derived from expert judgment rather than
from presently available economic
indicators.
Although expert opinion is suggested
the procedure that should be followed for
obtaining weights, a comparison of the
national results of the expert opinion and
economic analysis is given below. The
economic data were normalized and expressed
in the same format as the expert opinion,
1000 points.
Air
Water
Land
Total
Expert Opinion
290
390
320
Social Costs
540
290
170
1000
1000
It is felt that the relatively high
social cost weight given the air medium is
a function of both the significant research
directed at determining the social costs of
air pollution and the failure to account
for the large percent of the United States
that is not urban. If the expert opinion
were grouped by an urban, nonurban
dicotomy, the air medium would have a
higher value for urban than nonurban. The
primary reason for the low social cost
value for land is the lack of data upon
which to measure the social costs.
Calculation of a Strategy Effectiveness
Index
The specific procedure that should be
followed to compute a SEI for a control
consists of seven steps.
STEP 1. Identify Pollutants. Waste
streams from the industrial
processes and control
strategies are defined by
physical/chemical pollutants.
These pollutants and their
production are identified and
then tabulated according to
their controlled and
uncontrolled states.
STEP 2. Determine Potential
Environmental Damage. For
each of the pollutants
identified in Step 1,
determine the potential
damage created by the
discharge of the wastes. The
damage (d_) is obtained from
the damage function by
entering the function with
*Council on Environmental Quality, Environmental Quality—The Second Annual Report,
Government Printing Office, Washington, D. C., 1971.
156
-------
the total mass of pollutant
p, and then reading the
value, d .
STEP 3. Determine Damage Modifiers.
The damage computed in Step
2 must be adjusted to account
for the behavior of the
pollutant in the environment.
STEP 4. Determine Importance of
Media. The significance of
the damage created by the
discharge of pollutants into
the environment is expressed
by a relative weighting of
the media. If national
weights for the media are
used, they appear in Table 2.
If, on the other hand,
regional weights are desired,
the model developed using an
AID analysis is applied.
STEP 5. Determine Importance of
Pollutants. After the media
weights have been assigned,
they can be proportioned to
the individual pollutants.
A pollutant weight is
expressed as percent of the
medium weight under which it
is grouped.
STEP 6. Compute Environmental
Degradation Index. The
Environmental Degradation
Index (EDI) can now be
calculated for both the
controlled and the
uncontrolled state.
EDI = y (M x d x )
s L p p,sw
P P
where
s = strategy index
p = pollutant index
d = damage for pollutant p when
"' strategy s is applied
w = national weight of pollutant p
M = pollutant damage function
" modifier.
STEP 7. Compute the Strategy
Effectiveness Index. After
computing the EDI for both
the controlled and
uncontrolled states, it is
possible to compute the
Strategy Effectiveness Index
(SEI).
SEI = EDI, nl ,. - EDI .
s (uncontrolled) s
CASE STUDY
To assure that the methodology is
usable, it has been applied on the
Integrated Iron and Steel Industry. The
steel industry was selected as one which
has undergone substantial cleanup. Many of
the techniques employed to abate air
pollution have led to increased production
of water pollutants which in turn have been
abated.
The seven steps described earlier are
used in this example. In Table 5 the
pollutants are identified along with their
rate of production. Also in Step 1, the
control systems are identified and are
listed in Table 6.
TABLE 5. STEP 1. IDENTIFY POLLUTANTS
(uncontrolled)
Air
Oxides of Nitrogen
Sulfur Dioxide
Carbon Monoxide
Particulates
Total Organic Material
Ammonia Products
Chlorides
Calcium Fluoride
Phenols
Cyanides
Water
Suspended Solids
Ammonia Nitrogen
Phenols
Cyanides
Cyanates
Chlorides
Oil
Hydrochloric Acid
Land
Dry Dust
Sludge
15 Ib/hr
1,932 Ib/hr
507,830 Ib/hr
39,420 Ib/hr
1,599 Ib/hr
65 Ib/hr
542 Ib/hr
71 Ib/hr
6 Ib/hr
90 Ib/hr
6,880 Ib/hr
226 Ib/hr
87 Ib/hr
1.2 Ib/hr
35 Ib/hr
11,880 Ib/hr
1,594 Ib/hr
138 Ib/hr
0 Ib/hr
0 Ib/hr
157
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TABLE 5 (Continued)
TABLE 8. STEPS 3-5. DAMAGE FUNCTION
MODIFIER AND POLLUTANT WEIGHTS
Byproducts
Metallic Dust
Metallic Sludge
Oil
Acid
Iron Oxide
0 Ib/hr
0 Ib/hr
0 Ib/hr
0 Ib/hr
0 Ib/hr
The magnitude of the environmental
damage is given in Table 7 and the damage
function modifier and the pollutant
weights, Steps 3-5, are given in Table 8.
The final strategy effectiveness index for
the two controls is given in Table 9, along
with energy demands and cost
considerations.
Application of air pollution control
systems alone leads to a very large
increase in the production of suspended
solids and cyanides as water pollutants,
and of dry dust as solid waste. Thus,
although there are markedly smaller
emissions of air pollutants, the cross-
media impact is substantial and the net
gain, or Strategy Effectiveness, is not
great. Application of water pollution
systems alone does not have a comparable
TABLE 6. STEP 1. IDENTIFY POLLUTANT CONTROLS
Air Control Only
Pollutant, p Weight W
Oxides of nitrogen
Sulfur dioxide
Carbon monoxide
Particulates
Total organics
(to air)
Ammonia products
Chlorides (to air)
Calcium fluoride
Phenols (to air)
Cyanides (to air)
Suspended solids
Ammonia nitrogen
Phenols (to water)
Cyanides (to water)
Cyanates
Chlorides (to water)
Oil
Hydrochloric acid
Dry dust
Sludge
22
43
26
56
30
47
47
43
56
60
71
52
84
75
56
33
71
28
42
58
Modifier M
0.5
0.7
0.3
0.8
0.5
0.5
0.4
0.4
0.4
0.4
0.6
0.6
0.5
0.5
0.5
0.6
0.5
0.4
0.5
0.6
Plants
Coke Oven
Sinter
Blast Furnaces
Basic Oxygen Furnaces
TOTAL
Plants
Coke Oven
Hot Rolling Mill
Acid Pickling
TOTAL
Control System
High Energy Wet
Scrubber
Electrostatic
Precipitator
High Energy Wet
Scrubber
Electrostatic
Precipitator
Water Control Only
Control System
Biological System
Primary Clarifier and
Filter Systems
Regeneration System
Capital
Cost, $
10,500,000
1,500,000
5,100,000
10,000,000
27,100,000
Capital
Cost, $
2,150,000
18,140,000
1,278,000
21,568,000
Annual Operating
Cost, $
2,262,000
501,500
413,000
1,059,000
4,235,500
Annual Operating
Cost, $
1,181,000
1,576,000
115,000
2,872,000
158
-------
great. Application of water pollution
systems alone does not have a comparable
deleterious effect on air, so although
it increases the production of solid
wastes it results in a substantial net
gain.
Combined air and water pollution
control results in a higher Strategy
Effectiveness than a simple sum of the
two more basic strategies because it
yields nearly all of the individual gains
of both, without producing the negative
impacts on water which stem from air
pollution controls alone.
CONCLUSIONS
A methodology has been developed in
this paper for assessing the effectiveness
of control strategies applied to a single
medium in terms of their impact on all
environmental media. It appears that the
approach developed is sufficiently general
to allow for a more systematic assessment
of the cross-media impacts of proposed
pollution control standards. It should
hopefully prove useful as one of the tools
for making decisions as to which control
techniques are most appropriate for meeting
standards in a way to provide a net
improvement in environmental quality.
TABLE 7. STEP 2. DETERMINE MAGNITUDE OF ENVIRONMENTAL DAMAGE
1.0
0)
00
eo
O
o
n
-H
0.5
NOX, Ib/hr
S02, Ib/hr
CO, Ib/hr
Particulates, Ib/hr
Total organics, Ib/hr
Ammonia products, Ib/hr
Chlorides, Ib/hr
Calcium Fluoride, Ib/hr
Phenols, Ib/hr
Cyanides, Ib/hr
Suspended Solids, Ib/hr
Ammonia nitrogen, Ib/hr
Phenols, Ib/hr
Cyanides, Ib/hr
Cyanates, Ib/hr
Chlorides, Ib/hr
Oil, Ib/hr
Hydrochloric acid
Dry dust, Ib/hr
Sludge, Ib/hr
p-a
23
493
126,958
9,855
400
16
136
18
2
22
5,098
56
23
23
9
3,085
398
34
3,918
434
P
46
986
253,915
19,710
800
32
272
36
3
45
10,195
113
46
46
18
6,170
797
69
7,835
868
p+a
68
1,479
380,872
29,566
1,200
49
406
53
4
68
15,292
170
70
68
26
9,255
1,196
104
11,752
1,303
max
91
1,972
507,830
39,421
1,599
65
542
71
6
90
20,390
226
93
91
35
12,340
1,594
138
15,670
1,737
159
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TABLE 9. STEPS 6-7. STRATEGY EFFECTIVENESS INDEX
Costs „_ _
Strategy
Operating, Effectiveness
Strategy Energy, kw Capital, $ $/year Index
3 x 106 tons/year Integrated Steel Mill
Air Pollution Control only 10,134 27.1 x 106 4.24 x 10
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HEALTH ASSESSMENT OF FULL UTILIZATION OF
WATER POLLUTION CONTROL TECHNOLOGY
Dr. L. A. Plumlee
Environmental Protection Agency
401 M St., S.W.
Room 625 West Tower (RD-675)
Washington, D. C. 20460
ABSTRACT
In the development and utilization of technology to protect the public health and the
environment from water pollution, we must carry out research to ensure that the new
technologies themselves do not create unacceptable public health or ecological problems.
In order to set reasonable goals for water pollution control technology, additional
research must be carried out to expand the water quality criteria relating to health. To
protect the public health, additional criteria are necessary for drinking water, fish and
shellfish, irrigation water, and water drunk by livestock. Those areas addressed by the
EPA research program are described. The advantages and limitations of epidemiology,
animal studies, and clinical research in providing these criteria are discussed. Health
aspects of EPA's wastewater reuse policy are summarized. It is recommended that water
criteria indicate the relationships between pollutant levels in water and health risk, so
that officials may choose standards which are appropriate to local social and economic
conditions. The wise expenditure of billions of dollars on water pollution control
technology requires a substantially increased effort to quantitate the benefits and risks
of control.
The purpose of water pollution control
technology is to prevent damage to the
health of man and other living creatures,
and to materials. The stringency of con-
trol which is feasible is a function of the
risk of adverse effects at various levels
of control, the availability and cost of
control technology, and the period of time
for applying the technology. It is inter-
esting to compare progress in water
pollution control with progress in air
pollution control. Water pollution control
has gradually gained momentum over many
years. The activity now appears to be
rapidly accellerating. To the degree that
high costs are necessary to meet standards
within a short period of time, a reexami-
nation of the data upon which standards
are based, in an attempt to lower costs
without concomitant embarrassing health
effects, will be made. For example, auto-
motive emission standards were specified
in the Clean Air Act amendments in December
1970. The high cost of meeting these
emission standards in the short time avail-
able led to the development of control
technology, specifically catalytic con-
verters, which would substantially reduce
the pollutants specified in the Clean Air
Act, but at high costs and with control
technology which promised to substitute
for the harmful pollutants named in the
Clean Air Act potentially harmful amounts
of pollutants such as sulfuric acid mists.
Because of the speed with which the law
required emission standards to be met, the
potentially adverse effects of the proposed
control technology were found out just in
time to prevent both government and
industry from permanently locking into a
technology which had not been completely
assessed for its own health effects.
When the Energy Crisis became in-
creasingly apparent, the Senate Committee
on Public Works called upon the National
Academy of Sciences to examine the health
basis for the Air Quality Standards. It
is interesting that they did not request
any evaluation of the standards that were
based on damage to wildlife and materials.
In general, the air standards to protect
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wildlife and materials were more stringent
than those to protect health, but in a
crunch, it was concluded that wildlife and
materials must suffer before man, and
many considered retrenchment to lower
standards at the second line of defense --
that essential to protect human health.
Some experts, such as Dr. Bertram Dinman,
told the National Academy of Sciences that
society might reduce the costs of air
pollution control by considering paying
for the relocation of those individuals
who are especially susceptible to adverse
health effects from air pollution into
areas which are less polluted.
Let us compare this situation with
problems in water pollution control. It
may well be that analagous problems are
just a little way down the pipe. Perhaps
we can use our hindsight from air pollution
control to avoid making the same mistakes
in the water area. The Federal Water
Pollution Control Act Amendments of 1972
came just about two years after the Clean
Air Act Amendments.
Under the water amendments, it is
clear that Congress was eager to get water
pollution control activities underway
regardless of whether or not scientists
could agree on what levels were necessary
to protect the health of man and beast.
Nevertheless, Congress recognized that
certain toxic pollutants required stand-
ards for effluents into water regardless
of the state of advancement of control
technology. EPA is now in the midst of
trying to set such toxic pollutant efflu-
ent standards. In this task, the water
quality criteria recently revised by the
National Academy of Sciences and by EPA
provide the best source of data. In
numerous instances, the levels at which
the chemicals have adverse effects on fish
are enumerated. But what if society
decides that the cost is too great to bear
to protect fish in certain areas for a
while. Perhaps society would then decide
as was discussed in the case of air pol-
lution above, to set interim standards at
levels which might not be fully protective
of the fish, but would safeguard man from
adverse effects from eating fish produced
in certain areas. Or perhaps our concern
would be to protect man from chemicals
which would necessarily enter water
supplies for a time and for which no
drinking water treatment technology was
available. Or perhaps society would
choose to control to the point of accept-
able risk for swimming, but not to be
fully protective of fish or other organisms
in the water. Well, I think we would be
in trouble then. Such human health cri-
teria are sparse or absent for all three
alternatives.
And what about the adverse effects
of fully utilizing 'modern water pollution
control technology? Have we studied
illnesses in individuals living downwind
from activated sludge sewage treatment
plants? Have we studied the impact on
air quality of incinerating sludges con-
taining chemicals such as lead from street
surface runoff? Have we determined the
degree to which vegetation takes chemicals
from sludges disposed on land and concen-
trates them to levels which might be
adverse to man or livestock or both? Have
we followed populations of swimmers in
various types of water with controls to
determine the health impact of various
recreational water qualities? Have we set
food standards or goals for chemicals in
fish, shellfish, plants, or livestock and
thus derived water quality goals to pro-
tect man? Have we studied the environ-
mental degradation of the toxic chemicals
which industries and municipalities put
into the water, and the ability of existing
drinking water treatment technology to
remove such chemicals from the raw water?
Hardly at all. Well, what will happen?
Will the decision makers rely on the
existing data describing toxic effects on
fish production, or will these decision
makers, including the courts, hold that
there is insufficient evidence to require
controls? Probably a mixture of both from
time to time, depending upon the individuals
involved in the decision. In the abs.ence
of data, decision makers must fall back on
their personal philosophies. Some will
prefer to err on the side of safety, others
on the side of preventing possibly unnec-
essary costs.
What can we do? Well, engineers and
administrators can learn to accept the
need for evaluating the potential adverse
health and environmental impacts of new
technologies. What disciplines and
capabilities are available to us should
we choose to fill these gaps? I think it
is clear that we must first decide what is
a desirable level of chemicals or micro-
organisms in the media which come into
contact with man. With respect to water
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pollution, these media include our
drinking water, the water we swim in, fish
and shellfish grown in water, plants
irrigated by water, and livestock, which
drink water. In every instance, except
perhaps for swimming, setting the maximum
desirable level requires knowledge of
human consumption patterns. We must deter-
mine how much water people drink and how
much of various food stuffs people eat.
Since these patterns are highly variable,
administrators at this step must consider
what percentage of the population they are
going to protect. Does the person on the
tuna Weight Watcher's diet require the
same degree of protection as the person
who has precisely average food consumption
patterns? In order to set standards for
chemicals in water or foods grown with or
in water, we utilize market surveys in
conjunction with data from epidemiology,
animal exposure studies, and intentional
and accidental human exposure studies.
Epidemiology permits us to study
populations in real life settings. Since
individuals are already exposed to some
chemicals and microorganisms at levels of
concern, we have a social responsibility
to do epidemiology. Epidemiology also
permits us to study the effects of chronic
exposure of humans, to look at variability
in the pollutant burden among many indi-
viduals, and to assess any health benefits
before and after controls are instituted.
With epidemiology, we can look in humans
for effects that we suspect might be there
based on animal studies, we can study the
interaction of disease with pollution
exposure, and we can study outbreaks.
Then why is so little epidemiology done?
It's expensive, there is an incredible
shortage of epidemiologists, and among
present ones, there's often a lack of
interest. If you must publish or perish,
you may shun work which requires intensive
efforts but produces few publications.
A cheaper way of getting information
on desirable levels of chemicals in food
and water is through controlled animal
exposure studies. They permit controlled
dose-response studies at all desirable
points on the response curve, sacrifice of
the animal before his natural death in
order to look for tumors or fetal deform-
ities, as well as the option for life-time
chronic studies under controlled exposure.
They also permit controlled studies of
several pollutants simultaneously. But
most important, with animal studies, we
can assess a problem before human popu-
lation exposures ever occur. Unfortunately,
we still have considerable difficulty in
extrapolation of animal toxicity results
to man.
A third technique available for
determining desirable levels of environ-
mental agents in food and water from the
perspective of human health is clinical
research. Volunteers may be exposed to
some chemicals, where adverse effects are
not anticipated, and human absorption,
metabolism, and excretion of the pollu-
tants studied. In addition, clinical
investigations may secure valuable infor-
mation by studying those accidentally
exposed. Clinical research enables us to
study the effects of experimental exposure
on the course of disease, to do some dose-
response studies, to intensively study a
few naturally exposed subjects and perhaps
thereby identify new response indicators,
and to verify results of toxicologic and
epidemiologic studies, thus strengthening
an existing data base. Well why don't we
do more clinical research? Well, these
studies are expensive too, and it is
apparent that investigators must be
exceedingly thoughtful and discreet.
Furthermore, absolutely necessary checks
and balances to protect the rights of
subjects are time consuming and sometimes
abrasive to the investigator.
In the case of drinking water, once
we have determined a desirable level of a
chemical or other pollutant in water, we
can set about utilizing or developing the
technology to achieve this goal. But in
the case of foods grown in or with water,
the matter is much more complicated. For
example, in order to set an effluent
standard for a chemical into water, we
must consider the degree to which the
effluent chemical will be diluted, its
environmental degradability or persistence,
its direct concentration from the water
into the organism which man consumes, and
its concentration through a chain of
organisms ultimately reaching man. Unfor-
tunately, agencies directly concerned with
food regulations have not acquired immense
expertise in the latter areas, and agencies
concerned with environmental water in our
rivers and streams have not developed
enough expertise at determining desirable
levels of chemicals in food and then
extrapolating from such ,/oals in order to
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set standards for chemicals in or into
water. The result of these oversights
could very well lead to harmful human
exposures occurring at the same time that
insufficient evidence were available to
prove that the exposures were harmful. It
is not at all inconceivable that the
courts may find a chemical innocent of any
wrong doing merely because the judge or
jury examining the situation felt that the
evidence presented left a reasonable doubt
that the agent was responsible for harm.
What is the Environmental Protection
Agency doing to increase the data base for
assessing the health benefits of water
pollution control technology, and the
health risks of such technology, if any?
The first table illustrates EPA's ongoing
program in water health effects research.
After each program the amount being spent
in thousands of dollars and the number of
man-years of effort on each program are
enumerated.
When considering that none of these efforts
are funded at more than half a million
dollars per year, it is interesting to
recall that our society is spending
several billions of dollars per year to
apply technology to the solution of
problems elucidated in major part by this
very modest program. Are the American
people getting their moneysworth from
water pollution control technology? This
is the kind of work that enables us to
answer that question. Table II on the
following page shows a small addition to
the preceeding list describing a new
program to assess possible adverse health
effects from waste water and sludge treat-
ment and disposal.
I.
TABLE I. EPA WATER HEALTH EFFECTS RESEARCH (FY 74)
Occurrence & effects of organic contaminants in drinking water
-- isolation, identification, assessment of the acute
toxicity of organic chemicals in tap water
$398K/9MY
II. Occurrence & effects of inorganic contaminants in drinking water $350K/13MY
-- identify inorganic contaminants & determine significance of occurrence
-- toxicological studies for lead, cadmium, barium & asbestos
-- epidemiologic surveys (silicate, nitrate)
-- carcinogenic/mutagenic potential of raw versus finished water
III. Biological contaminants of water supplies $300K/13MY
-- review & determine the cause of water borne disease outbreaks
-- survey of water supplies for virus, bacteria, and higher
parasitic forms
IV. Health effects of waste water reuse $120K/OMY
-- isolate & identify organic compounds and trace metals in
treated wastewater
V. Recreational water quality criteria $400K/11MY
-- correlate recreational water quality to various indices
of microbial pollutants
-- conduct epidemiologic-microbiological studies at 2 N. Y. City
beaches (one relatively clean, one barely acceptable) to correlate
water quality & incidence of diseases among swimmers
-- occurrence of the pathogenic amoeba naegleria,incidence of
meningo-encephalitis
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TABLE II. RESEARCH ON HEALTH EFFECTS OF
WASTEWATER AND SLUDGE TREATMENT AND DIS-
POSAL ($200K/OMY)
-- Monitor air, soil and water surrounding
a wastewater treatment plant for micro-
biologic and chemical agents
-- Conduct epidemiologic studies to assess
possible adverse health effects
resulting from the operation of a
wastewater treatment plant
The third table compares the water health
effects expenditures for this fiscal year
ending next month with those proposed for
the new fiscal year beginning in July 1974.
TABLE III. EPA WATER HEALTH EFFECTS
RESOURCES
FY-74
Organics
Inorganics
Microbiological
Water reuse
Scientific summaries
Marine recreation
Freshwater recreation
Wastewaters & sludges
Totals
$K
395
350
300
120
0
250
150
230
1795
MY
9
13
13
0
0
8
3
1
47
FY-75
$K
700
1150
600
400
160
350
150
600
4110
MY
9
13
13
0
0
8
3
1
47
I believe you can see that EPA is beginning
to spend more money on water health effects
research. In fact, the projected total
expenditure is $4,110,000, or an increase
of 130%. This is about one seventh of
EPA's total health effects research budget
not including the monies which EPA may
receive for health effects research and
development relating to energy problems.
The budget does not include any research
directed toward the health impact of
sewage sludge incineration, or for directly
assessing the impact of water pollution on
humans who eat fish, shellfish, irrigated
vegetables, or livestock which have drunk
water or eaten irrigated foods. However,
there are efforts planned which relate to
some aspects of these problems.
Full utilization of water pollution
control technology would include making
the best possible uses of the treated
water. EPA recognizes and supports the
potential for waste water reuse including
agricultural industrial, municipal,
recreational, and ground water recharge
applications. EPA believes that the
potable use of renovated waste waters,
blended with other acceptable supplies in
resevoirs, may be employed once research
and demonstration have shown that it can
be done without hazard to health. But EPA
does not support the direct interconnection
of waste reclamation plants with municipal
water treatment plants. This is, in part,
because accidental spills or sabotage
present an acute threat which cannot be
disregarded, since anyone can flush large
quantities of any chemical he likes down
a toilet. Thus, even if other health
problems relating to direct recycling of
water are solved, such as viruses, bacte-
rial buildup, chemical buildup, and
reliability of operation, the problems of
accidential spills or sabotage may mean
that some system of holding and dilution
resevoirs may inevitably need to be pro-
vided between the reclamation plant and
the potable water intake, together with
biological and chemical monitoring. But
this problem is a relatively minor
stumbling block compared to the multiple
feasible potential uses for treated
municipal sewage waters.
Earlier in my talk, I referred to the
need for us to determine desirable levels
of chemicals in water and in food grown
in or by using water other than rain water.
Before I finish, I would like to discuss
how desirable levels are determined. There
is an increasing belief throughout our
society that standard setting is not the
responsibility of scientists alone, but
requires, in addition, the weighing of non-
scientific factors. It appears that an
administrator trying to decide, for example,
a toxic pollutant effluent standard,
should have before him several potential
standards, the severity and scale of risks
of disease or ecological consequences
associated with each potential standard,
the costs associated with these risks, and
the costs of achieving the level of control
associated with each potential standard.
Only with all these data can an adminis-
trator expect to make the most beneficial
decision. Public acceptance of a concept
of socially acceptable risk and public
participation in the standard setting
process are highly desirable goals. Such
public participation may well be necessary,
since highly localized conditions
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determine what is socially acceptable.
Thus, one EPA researcher has recommended
that instead of using a numerical criterion
such as 200 fecal coliforms per hundred
milliliters for all recreational waters,
instead a criterion should be used which
is a mathematical expression of the
relationship of water quality indicators
to the probability of illness as well as
the social and economic impact of such
illness. Such a criterion would be con-
stant, but the acceptable risk might be
different depending on the conditions
peculiar to the area using the criterion.
The standard derived from such a criterion
could be expected to become more restric-
tive as the cost of treatment facilities
decreased, or if there were an improvement
in the competitive posture of advanced
waste treatment facilities for available
funding and manpower resources. In some
areas, the demand for recreation and the
lack of lower risk alternatives might
justify a slightly increased risk of
illness from swimming. Indeed, the
literature demonstrates an increased
infectious illness rate among swimmers
even in very clean water, when compared
to non-swimmers. Thus, the mere fact that
we allow swimming at all is because we
recognize that the pleasure derived from
swimming is worth taking some health risks.
To make the matter even more complex,
we must consider the impact of chlorination
of sewage waters not only on the swimmers
downstream, but on the fish. As we
chlorinate to reduce the swimmers' hazard
from viruses and bacteria, we increase the
hazard of chloramine toxicity to fish.
Large fish kills have been attributed to
this source. The solution is the develop-
ment and assessment of additional techno-
logical solutions.
Thank you for the invitation to
discuss the health assessment of full
utilization of water pollution control
technology. I hope that these reflections
will assist those who develop the technol-
ogy, and I personally look forward to
learning more about the technology as we
continue together the never completed task
of protecting the public health.
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COST-BENEFIT ANALYSIS OF WATER POLLUTION CONTROL
D. P. Tihansky
Washington Environmental Research Center
U. S. Environmental Protection Agency
Washington, D. C. 20460
ABSTRACT
Cost-benefit analysis should be part of the decisionmaking process involving the
establishment and subsequent enforcement of water quality standards. An assessment of the
economic tradeoffs realized by pollution control provides insight on those standards most
beneficial to society. This study begins with a justification for cost-benefit research,
and then presents a conceptual outline of basic components in the analysis. The role of
technological progress is discussed as it improves the economic welfare of water users.
Historically, there has been far greater emphasis on cost than benefit evaluations. As
standards become more stringent, however, it is necessary to show that the rising cost
burden is worthwhile by increasing net benefits, whether they be quantified in monetary or
other units. A survey of the economics literature reveals that national damages from
water pollution exceed $12 billion per year. Recreationists, commercial fisheries, water
supply users, property owners, and the navigation sector are seriously impacted by
degraded water. Although the national estimate excludes important categories, such as
aesthetics, ecological preservation, sub-clinical health effects, and nonuser preferences
for recreation, its magnitude is great enough to encourage the enhancement and
conservation of water resources.
INTRODUCTION
From the viewpoint of national
priorities, water pollution control is one
of the most important programs for social
well-being. More than five years ago when
environmental issues began to receive
emphasis, the Senate Select Committee on
National Water Resources estimated that
investments in wastewater treatment would
cost about $100 billion by the year 2000.
Current annual costs— including annualized
capital, operating and maintenance— of
municipal and industrial waste control are
estimated at $5 billion plus.
Because of these seemingly high
costs, the question arises as to the worth
of such programs. Only in recent times has
this question been seriously recognized and
Federal funds earmarked for research. The
economic test of abatement expenditures is
the magnitude of benefits or reduced
damages realized by water users. If the
marginal benefits of improving water
quality are greater than associated costs,
then the program adds to net social welfare
and is thus worthwhile.
Technology assessment should thus
depend not only on the cost of treatment,
but also on the effectiveness of this
investment to enhance societal welfare.
Criteria other than cost-benefit analysis
have been proposed and often used for
determining the optimal level of control.
They include minimizing water use, reducing
pollution discharges, and applying economic
incentives, such as effluent taxes. But
these approaches may not provide the
greatest benefits to society. Only by
conducting a cost-benefit analysis can
these considerations be integrated and the
optimal level of control be evaluated.
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MOTIVATION
The allocation of funds for
wastewater treatment should be designed to
elicit maximal welfare gains to society.
Since about 70% of all wastewater
originates from industrial sources,
environmental policies must be formulated
to generate these optimal responses chiefly
from privately owned orgainzations: heavy
and light water-using industries, electric
power plants, and combined industrial and
municipal sewerage systems. Because many
pollution damages are external to the waste
generating firm and thus are excluded from
that firm's production costs, a regulatory
agency, such as the U.S. Environmental
Protection Agency, is needed to internalize
the damages to the firm, by setting
effluent standards or applying other
methods of control.
There is no reason, based on actual
experience or economic theory, to expect a
private organization to engage in socially
optimal treatment. In the absence of water
quality standards or economic incentives,
such as fines and payments or the threat of
legislative penalties for inaction, a firm
will optimize its profits by transferring
input resources from abatement into more
profitable manufacturing operations.
Market forces are not strong enough to
stimulate technological development in
order to maximize net welfare impacts of
pollution control. If government
enforcement proceeds without adequate
rationale, then industry and other
polluters are likely to win court battles
on their right to degrade the environment
irresponsibly.
The need for a carefully conducted,
comprehensive economic analysis becomes
more acute as the level of effluent
requirements changes from best practicable
technology (BPT) currently available
(implemented to 1977) to best available
technology (BAT) economically achievable
(implemented in 1983). The need to prove
economic achievability is directly
dependent on a cost-benefit analysis of
alternative control strategies. As a
result, the level of control must be
evaluated in terms of its potential to
enhance man's use of water. This will
necessitate the stimulation of
technological innovation and a more precise
assessment of costs and benefits.
Perhaps the most important reason for
cost-benefit analyses is a Congressional
mandate to do so. Prior to the
establishment of any effluent regulation,
Section 302(b)(2) of the Federal Water
Pollution Control Act Amendments of 1972,
require the determination of "the
relationship of the economic and social
costs of achieving any such limitation or
limitations, including any economic or
social dislocation in the affected
community or communities, to the social and
economic benefits to be obtained." Such
information can provide guidance for the
maximization of net social welfare within
technologically feasible ranges of control.
But even prior to the 1972 Amendments,
there was interest in cost-benefit studies,
although to a lesser degree because of
insufficient Federal funding and support.
The initiative for this research originated
in the mid-nineteenth century with a
classic discussion (1) on the utility of
public works. By 1946, the Federal
Inter-Agency River Basin Committee was
given the task of "formulating mutually
acceptable principles and procedures for
determining benefits and costs for water
resources projects." The end product of
this venture was the publication of the
famous "Green Book" (2), the first
economics guideline on project evaluation.
In the past several years, empirical
techniques have improved considerably as a
result of strong public pressures and
Federal concern for effective environmental
management.
THEORETICAL FRAMEWORK
To achieve maximal benefits relative
to costs, one conducts a cost-benefit
analysis of alternative control levels.
The accuracy and completeness of this
analysis rests on the level of effort and
quality of resources devoted to the
assessment. Of principal concern to
legislators are two issues: the usefulness
of the analysis in a dynamic context and
the economic feasibility of zero discharge,
which is the idealized goal of Public Law
92-500.
The first issue addresses the role of
technological development in a dynamic
context of pollution control. Such
advancement shifts the total cost of the
control curve in Figure 1 to the right from
K- to K . The optimal control level can be
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important because they guide policy on
overall government funding tradeoffs among
competing societal needs, such as pollution
Figure 1.
Effluent Concentration
Increasing social benefits
by improved controls.
shown from ordinary calculus to be the
point where the slopes of the total cost
and benefit curves are identical. Assuming
that greater unit cost savings occur with
new technology, this impact produces a
curve below K... . Thus the economically
feasible effluent concentration changes
from GO to GI closer to zero discharge.
That is, technological progress on control
equipment increases the net benefits (total
benefits less costs of pollution control).
The second issue concerns the economic
evaluation of zero discharge. This
ultimate standard could become the optimal
strategy only after substantial
technological advance, decreased water
procurement costs (through recycling),
product recovery, and byproduct sale. At
the present time, however, zero discharge
is not economically attractive for most
industries. Based on a recent study (3),
the costs of zero discharge from industrial
and electrical power plants would be
approximately 3.3 times as much as the
present costs of attaining ambient water
quality standards. Substantial reductions
in control costs will thus be required
before total abatement can be justified.
MACRO-ANALYSIS
A macro-analysis of benefits and costs
pertains to regional or national impacts,
and hence differs from a specific plant, or
micro-, analysis. Regional estimates are
control ,
programs .
pollutant ,
indicate
research
fruitful
health care,
Their relatives
by region,
priorities on
and educational
magnitudes (by
etc.) can also
technological
as well as point toward potential
areas of future research and
development . Because large R&D
expenditures can often be supported at the
macro-level (e.g., at Federal government
research centers), the results of these
efforts can benefit research on
micro-analyses, which at the local level
cannot be supported so generously.
The estimation of regional economic
impacts of future control technologies
requires the aggregation of all benefits
and costs incurred within that area. The
relative size of the region can
significantly affect the scope of benefit
estimation. In small lake and estuary
studies, recreation benefits from abatement
are likely to compete with those in
neighboring areas. But these substitution
effects are seldom assessed in the
literature. Larger regional, e.g., major
river basin, studies are less inclined to
ignore these effects. Yet even these
estimates may inadequately reflect national
impacts .
While benefits are a function of
ambient quality, cost curves are derived on
the basis of source control. There is thus
a basic incompatibility on the scope of
variables required to assess these impacts.
Benefits are more directly measureable for
a region, while costs must be measured at
the micro- or firm level and then
aggregated into regional totals.
To assess specific effluent impacts
requires the disaggregation of benefit
estimates by their source, e.g.,
agricultural, municipal, or industrial
effluent discharges. For most regions,
this task is very challenging, if not
impossible (4) . If a sufficiently long
time series of water quality data exists ,
or if there are very few point sources of a
specific waste discharge, the
identification problem becomes easier. But
many benefits are a function of a number of
pollutants, so that the separation of
pollution effects is practically
impossible. To relate benefit changes from
ambient quality to variations in emissions
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requires a reliable water quality model.
Such models are available for special
pollutants and small regions, but they are
not yet developed with sufficient
predictive accuracy for more encompassing
analyses.
MICRO-ANALYSIS
At the level of the individual firm,
costs can be estimated for a range of
control levels. But benefits are generally
realized in the surrounding environment
which receives and assimilates the firm's
discharges. In the immediate vicinity of
the source, it may, or may not, be possible
to attribute damages to specific
discharges, since other regional activities
can also affect ambient quality, even very
close to the source. In general, cost
components (for end-of-line treatment) are
fairly well-defined, compared to benefits
whose evaluations are so often debated in
the literature. But over the past two
years, Federal support for improved benefit
studies has been very encouraging. Both
the U.S. Environmental Protection Agency
and the National Commission on Water
Quality are operating under Congressional
mandates to derive empirical estimates of
water quality impacts.
COST COMPONENTS
Costs are typically defined and
measured to include effluent control and
water procurement costs less byproduct
recovery revenues. In ordinary usage,
then, cost usually means the monetary
expenditure allocated to purchase and to
operate control facilities. For municipal
treatment plants this definition may
suffice, but for most industries it is
incomplete. There are also costs
associated with production changes, which
could either include the costs of
substituting more expensive inputs, or a'
decline in profits due to a drop in the
sales of certain products. Still
unresolved is the problem of allocating
costs of process change between abatement
and increased productivity. If the change
is motivated by the latter goal, even
though it may reduce the total pollution
load, this decision should be recognized
and weighed accordingly. Failure to do so
will result in ai upwardly biased charge to
abatement of the appropriate share of
depreciation and overhead expenses from
process modification. There is also the
related point that today's pollutants may
be tomorrow's commercially sold, secondary
products. Thus, the cost analyst must be
wary of overestimating the costs associated
with controls involving such products.
Standard engineering practice in most
firms is to presume that a net cost in the
range of 2-4% of manufacturing costs is a
reasonable range for end-of-the-pipe
treatment. Choice within this range is
highly arbitrary, however, without
knowledge of the specific control
technology being utilized and the operating
and maintenance requirements thereof.
This engineering approach involves the
extrapolation of plant costs from detailed
engineering and design specifications of
individual treatment processes. The major
difficulty is that design engineering costs
usually do not correspond to actual
installation costs (4).
Another method of cost estimation
relies on accounting records. Cost
accounts of plants with pollution control
activities list capital, maintenance, and
operation expenditures. A drawback to this
approach is that many companies do not
record expenditures in sufficient detail to
permit cost determination. Another problem
is that for national policy purposes, one
is interested in predicting costs of
technologies and systems not yet in
operation.
BENEFIT COMPONENTS
Benefits are comprised of a monetary
evaluation of improvements in health
(morbidity and mortality) and welfare as
stream quality is improved. Clear water
yields a variety of benefits to society,
but their value is not always obvious nor
can they be easily quantified. Since many
water pollutant damages relate to
subjective feelings and anxieties, there
are no market prices to adequately reflect
their values. Nonetheless, the benefits of
clean water are real, not imagined, and the
protection and improvement of water quality
contribute to the social well-being.
The basic frame of reference for
benefit quantification is a geographic
region, a specific recipient or water use,
a water quality constituent, or any
combination thereof. The most common
objective is to predict total regional
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benefits of all water-related impacts. In
addition to the total estimates, it might
also be useful to analyze the distribution
of these impacts by population sub-group.
Within this macro-setting, water
quality criteria are designed to protect
major water users. Streams are classified
in many states according to their function
in serving the interest of patrons. The
sensitivity of the water uses to water
quality specifications is reflected in the
magnitude of benefits. The complementarity
or perhaps incompatibility of activities,
e.g., commercial fishing and navigation,
underscores interdependencies among benefit
recipients. Although water uses are
generally responsive to many pollutants
simultaneously, standards must pertain to
individual water constituents.
Consequently, there is a need for benefit
studies relating to a single parameter.
Table I depicts a conceptual outline
of basic components in an empirical benefit
assessment. Each matrix element links the
economic damage potential to a water use
(column heading) caused by an ambient level
of the constituent (row heading). The row
and column titles are selected from water
quality criteria guidelines.
The weighted pollution index in the
bottom row is summed over standard
parameters, such as dissolved oxyten, pH,
total dissolved solids, iron and manganese,
temperature, and total nitrogen. Among all
pollution variables the impacts of BOD
levels on water use have been assessed most
frequently. BOD is usually assumed as a
surrogate, or indicator, of the general
level of water quality. On the other hand,
other pollutants in the table can be
identified more uniquely with water use
responses.
Consistent definitions of each water
use are needed to assess damages. The water
supply category includes treatment cost
increases resulting from polluted water
intake. Navigation is a catch-all term for
damages to bridges, piers, and ships, as
well as boat accidents and water route
closures. Human health can be affected by
ingestion of drinking water or by bodily
contact with beach water. Other categories
are, for the most part, self-explanatory.
It is obvious that some water use
categories overlap, such as recreation and
aesthetics. Mutual dependencies of water
uses preclude a complete partitioning of
benefit categories. Nevertheless, for
purposes of estimation, they are usually
considered distinct.
Based on pollutant—water use
relationships (5), most of the matrix
elements can be documented in terms of
physical, chemical, or biological effects.
On the other hand, few of these effects
have been translated into economic
equivalents. The sparseness of economic
estimates in the matrix suggests either the
non-existence of certain benefits or else
the current infeasibility of quantifying
the impacts. Economic values have yet to
be derived for some benefits in the
aesthetic and ecological realm. In
evaluating any economic impact, there is
quite frequently the problem of segregating
multi-pollutant effects. Most benefits are
the joint product of a number of water
quality parameters and hence cannot easily
be apportioned among causative agents.
EMPIRICAL ESTIMATES
Published benefit estimates of water
quality improvement are relatively scarce.
Most refer to specific regions and cover
only the major benefit categories, such as
recreation and municipal water supply
demand. Furthermore, it is difficult to
segregate damages associated with specific
pollutants. Most estimates relate to a
general index of water quality, rather than
to a single constituent.
A survey (5) Of the literature reveals
that most benefits estimates lack
credibility. Many are based on invalid
theoretical notions and are not
conceptually grounded in welfare economics.
There is also a paucity of empirically
derived damage functions. Practically all
recreation studies, for example, use
hypothetical attendance loss curves.
In addition, most empirical findings
are region-specific and cannot be easily
generalized to other areas. The number of
water use categories evaluated is usually
small for want of data. Few studies
provide explicit formulae or damage
equations for general application to other
regions. While this deficiency does not
negate the theoretical validity of benefit
estimates, it narrows the usefulness of the
results.
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TABLE I. STATE-OF-THE-ART MATRIX ON POLLUTION DAMAGE ESTIMATES
Symbols
= economic estimates. ® = physical damages documented.
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Even if benefits could be measured
accurately, difficulties arise in using
them to justify water quality standards.
Since a poor person is generally less
willing to pay for water-related services
than his wealthier counterpart, should his
benefits also count less? Water management
programs can be designed to increase total
benefits and/or to redistribute impacts by
emphasizing water uses associated with
special income groups. For the latter
objective, it is important to measure the
distribution of benefits (and costs) among
the population and also among geographic
areas.
Table II summarizes annual estimates,
as of mid-1974, for damages to human
health, materials, outdoor recreation,
production costs, and property value. The
best estimates of water quality benefits
were compiled and aggregated, wherever
possible, into national values. In some
instances, only regional or case study
values could be ascertained. Empirical
results are not yet available for aesthetic
and psychic benefits.
Human Health
The protection of human health has
traditionally been the primary objective of
water quality enhancement. In spite of a
long historical period of concern for
drinking water standards, the extent to
which most pollutants are harmful via the
water routes is unknown.
Liu (6) estimated the impact of
enteric viruses on acute clinical
illnesses, such as infectious hepatitis,
acute gastroentiritis, and congenital heart
anomalies. The author admitted that these
estimates are crude, but at least they were
preceded by an extensive literature search
on outbreaks and sporadic cases of
water-related illnesses.
In the prevention of tooth decay,
fluoridation is beneficial to man's health.
Conservatively, a savings of $30 per year
is realized by fluoridation for a typical
child. For the nation, such savings are
translated into total benefits exceeding
$1.1 billion, given data on fluoride levels
of public water supplies (7). On the other
hand, excessive fluoridation can lead to
fluorosis, which is quite expensive to
treat.
TABLE II. ECONOMIC DAMAGES FROM WATER
POLLUTION IN U.S., 1970
Type of Damage
Estimate
(Millions)
Human Health
Viral-related, clinical $ 374
Tooth decay l,100a
Preventable illness 300
Materials Damage
Ohio River Basin 2
Sediment depositions 260C
Household damage 600 - 3,450
Navigation damages 20
Outdoor recreation
Fishing 2,240
Boating 1,620
Swimming 3,760
Waterfowl hunting 30 - 90
Commercial fishing 12 - 65
Industrial water supply 430 - 620
Appalachia 1.2
Illinois 24
Ohio River Basin 56
Municipal water supply
Ohio River Basin 25
Illinois 4
Agricultural water supply ,
Colorado River Basin 16
United States 800e
Property Values 33 - 175
Not necessarily caused by water
, pollution.
Acid mine damage.
Flood plain damages, storage losses in
reservoirs, navigation channel closure,
, commercial fishery losses.
Irrigation water constituents, salts.
Plant nutrient losses from erosion and
sediment.
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Another study (8) anticipated monetary
impacts of drinking water contaminants on
preventable illnesses. Economic values are
based on typical costs of medical treatment
and time lost from work. These illnesses
differed somewhat from the above by
including low-level gastroentiritis and
non-viral related incidents. However, the
illness rates were based on a questionable
extrapolation of reported cases, to account
for unreported outbreaks.
These estimates, based on medical
costs and worker absenteeism, are likely to
be conservative since they exclude work
days below full productivity and
efficiency. There are also low-level
illnesses, such as the common cold or
influenza, whose economic impact per
individual may indeed be small but in the
aggregate could easily run into millions of
cases annually. Psychic costs of suffering
and anxiety are perhaps even more difficult
to quantify. Besides direct ingestion of
water, there are dangers from recreation in
contaminated water. Unfortunately, the few
empirical studies published on this topic
are contradictory.
Materials Damage
From an economic perspective,
corrosive and abrasive pollutants have
significantly damaged materials in direct
contact with water. Materials damages can
be distinguished according to their
original point of occurrence. With respect
to instream activities, polluted water
bodies are responsible for accelerated
depreciation of bridges, wharfs, and piers;
blockage of navigation routes; and
increased repair of ships and other
floating vessels. With water withdrawal
activities, damages occur to appliances and
plumbing facilities in households as well
as intake water distribution facilities in
municipal and industrial plants.
One of the earliest benefit reports
C9), in 1943, estimated the economic losses
of corrosion from acid mine drainage in the
upper Ohio River Basin. Annual damages
totalled more than $2,000,000 to domestic
and industrial water suppliers, steamboats
and barges, power plants, and river and
harbor structures. At that time,
recreational and aesthetic damages were
considered unmeasurable, although their
values were surmised to be at least as
large as those measured.
Damages caused by floating debris are
a continuing problem in major shipping
areas. Typical costs to owners of boats
colliding with debris are rarely mentioned
in the literature. But the Corps of
Engineers, as part of its harbor
maintenance program, estimated losses to
the twenty largest U.S. ports at almost
$20 million (10). These costs pertain to
repair and maintenance of damaged ships,
both commercial and recreational, but they
exclude the value of time delays from
accidents and health costs from human
injuries or, in a few cases, fatalities.
They also neglect damages in smaller ports,
public recreational areas, and private
marinas.
National estimates of damages from
sedimentation and erosion are available,
but they are highly suspect because of the
intuitive nature of the data. Sediment
loads are usually from non-point sources,
and hence their diffusion and transport in
water cannot be accurately monitored. The
source of sediment discharges cannot be
accurately traced, although a large
fraction of total loads is due to natural
processes of erosion or originates from
land developed for agriculture and lumber
production. To identify that portion due
to human activities is currently
infeasible. The value of plant nutrients
removed by soil erosion in this country is
estimated at $800 million annually (11).
Sediment particles are responsible for an
additional $260 million, of which $50
million is flood plain damages; $16
million, irrigation ditch obstructions; and
$11 million, damages to hydro-turbines and
commercial fisheries. Because these are
crude estimates, they must be interpreted
with caution.
Household appliances and personal
items in daily contact with water supply
are subject to damages from chemical and
other constituents in the water. These
damages were translated (12) into economic
losses for a typical household, and then
aggregated at the national and individual
state levels. In the United States, total
1970 damages to household items were in the
range of $0.65 - $3.45 billion, with a mean
of $1.75 billion. Those states with the
highest mean estimate of damages include
California at $230 million and Illinois at
$164 million. Per capita damages are
highest for Arizona, $22.53, and New
Mexico, $18.58. The most damaging
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pollutants are hardness and total dissolved
solids. Water quality data by supply
source were obtained from state water
resources experts, whose personal
assessments may introduce biases into the
calculations.
Outdoor Recrpa1-inn
Recreation benefits have often been
cited as the most important objective of
water quality legislation, aside from the
protection of human health. Economic
theory and consumer behavior suggest that
there are at least five distinct types of
recreational benefits: (1) a potential
reduction in price (travel cost) to current
users, primarily fishermen, boaters and
non-pool swimmers; (2) an expansion of
water-based activities from this lower
price, both on the part of existing and new
users; (3) a shift in the quality of the
recreation experience; (4) a preservation
value that a large group of nonusers attach
to the conservation of waterways in their
natural state, even though these
individuals have no intention of ever using
them for recreational sports; and (5)
option value that nonusers attach to the
increased likelihood that they will be able
to recreate in natural waterways, should
they decide to do so in the future.
A recent survey (13) of the recreation
literature concluded that past studies have
understated economic benefits because they
developed empirical estimates for only one
or at most two of these five types of
impacts. Empirical findings indicate that,
on a national scale, recreation benefits
from water quality enhancement exceed the
combined gains to commercial fisheries,
property value, materials corrosion, and
water supply to the housing, industrial,
and agricultural sectors. But whether they
are greater than human health losses
including sub-clinical cases remains to be
proven.
Benefit numbers listed in the table
were based on documented assumptions
concerning: (1) the amount of polluted
waterway to be restored for recreational
activities; (2) changes in the recreation
behavior of consumers as water quality
changes; and (3) the price or
willingness-to-pay for water-based outdoor
recreation activities. Among the major
sport activities, beach swimming gained the
largest share, almost half, of all the
benefits. Fishing gains were realized in
fresh water (almost 80 percent of total
benefits) as well as salt water, especially
in polluted estuaries (20 percent).
These estimates, it must be noted,
pertain only to the first three types of
welfare impacts, namely, the reduction in
travel cost to more accessible water
bodies, increased demand from participants,
and enhanced value of the recreation
experience. These respective categories
accounted for 54%, 12%, and 34% of all
benefits. Of course, these values are
preliminary and will be revised as more
data are published.
Production Benefits
Commercial Fishing
Roughly one-fifth of marine
shellfishing areas in the United States are
closed because of pollutants, primarily
high fecal coliform or BOD levels, although
toxic metals have also affected the
industry. Most published estimates of
commercial fishery losses are for localized
problems, although three national estimates
have been made. Two (14, 15) of these
estimates are based on decreases in
potential catch, as the landing price
remains constant; the third (16) assumes
that price responds to supply changes and
then estimates the total change in
willingness-to-pay by consumers of fish
products. The lowest estimate considers
only clams and oysters as being harmed by
pollution, while the upper one also
includes lobsters, shrimp, and crabs.
Industrial Water Supply
Treatment costs of water intake by
industry are well documented in the
literature, but they generally depend on
water quantity rather than quality.
Nevertheless, there are a few regional
estimates of the costs of chemical
additives as water quality changes, holding
other factors constant. There are no
national damage estimates because of
difficulties in extrapolating local
estimates, based on a particular industry
-mix and water pollution problems.
In Appalachia, a ninety percent
reduction of acid mine drainage at the mine
source would imply a savings of $1.2
million in lime neutralization (17) . At
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least two regional studies (17, 18)
concluded that the elimination of all
natural pollutants in water would yield
benefits in the tens of million dollars.
Assuming that less chlorine and other
chemicals would be required, an estimate
for the state of Illinois is $24 million.
Another study (19), of the Ohio River
Basin, arrives at a total of $56 million as
a result of less filtration, softening,
clarification, and demineralization. But
these estimates are based on simplistic
assumptions, such as fixed unit costs of
treatment processes and the use of certain
treatment technologies. Extrapolating
these figures to the national level yields
a range of $430 - $620 million in damages.
Municipal Water Supply
Treatment costs of municipal water
supply have been shown to increase as the
quality of intake water worsens. There are
few regional estimates of economic losses
from water treatment. Those available show
wide ranges of values on a per capita
basis, due primarily to differences in
assumptions on the number and types of
treatment processes necessary to control
pollution.
In the Ohio River Basin, added annual
costs of water treatment attributable to
water quality factors were estimated (19)
at almost $25 million or $1.25 per
individual, on the average. These costs
exclude treatment of ground water, which
was thought to be primarily natural in
origin. The latter opinion is strongly
refuted by most hydrogeologists. In a
state report (18) for Illinois, cost
savings of water quality control were
estimated at $4 million annually, or $0.35
per capita. But this estimate excluded
treatment of Lake Michigan water supply,
which seems incorrect in view of the lake's
partial contamination by man-made
activities.
Another empirical study (20), in the
Chicago metropolitan area, found damages
from dredging to be very minor at less than
$10,000 per year for the entire urban
population. This estimate is much smaller
than the above because it is concerned with
a minor pollutant, dredge spoils, compared
to a myriad of pollutants normally treated
in a municipal plant.
Agricultural Water Supply
In farming activities, economic
damages are identified primarily with
dissolved salts and bacterial content of
irrigation water. Deleterious effects of
salts on plant growth can result from
osmotic effects or prevention of water
intake, or from chemical effects upon plant
metabolism. Coliform bacteria can
contaminate food crops, although they
seldom cause serious problems in the United
States.
Economic damages are usually measured
as the revenue or farm income lost from
reduced crop yields and increased operating
costs. At high salinity levels, only
certain crops can tolerate the chemical
effects of irrigated water.
In the Colorado River Basin, 1970
annual economic losses from salinity were
estimated at $16 million (21). By 1980,
this estimate is supposed to increase to
$28 million, unless corrective actions are
taken. But the method of estimating these
damages has been criticized for assumptions
adopted about crop response to salinity and
about options available to farmers to
handle salinity problems.
Another study (19) concluded that
damages in the Ohio River Basin are
negligible because the total annual value
(cost to farmers) of irrigation water
subject to pollution impacts is below
$60,000. But this conclusion is based on
the cost of water rather than crop damages
that it causes.
Property Values
It has been clearly demonstrated that
as water quality improves over time, people
are willing to pay more for property near
the water. An estimate (22) of national
benefits to property owners showed that
improved water quality increases property
values an average of 8 - 25 percent. In
aggregating from case studies to the
national level, estimates were obtained for
metropolitan (18 percent) , town (17
percent), and rural areas (65 percent).
Sale prices and tax assessments were used
to measure the property values before and
over a time interval of ten years.
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Other studies (23, 24) also reached
the general conclusion that water quality
affects property values. Benefits ranged
from 5% to 15% of original property value,
but were no more important than other
determinants in affecting values along
man-made lakes.
CONCLUSION
This paper has addressed some of the
theoretical issues underlying cost-benefit
assessments of water pollution control, and
has related them to the impact of
technological progress. Because far less
attention in the literature has been
devoted to benefit than cost analysis, the
former topic is emphasized.
In the past, cost analysis has
received far more attention than the
benefit issues. But even published cost
data narrowly focus on end-of-the-pipe
treatment, to the exclusion of process
change impacts, social costs of
unemployment, and secondary cost impacts to
the regional economy. Benefit studies have
appeared more frequently in the last two or
three years, but the state-of-the-art on
estimation varies considerably with respect
to each water use category.
Quantifying the benefits of
water-based recreation has been the subject
of considerable effort over the past
decade. While progress is notable,
particularly on the theoretical side, many
benefit values, such an nonuser demand,
remain to be examined. Aesthetic and
ecological benefits, frequently ranked with
high priority in water resource
developments, remain elusive of economic
evaluation.
Health effects have been monetized for
certain illnesses, but these estimates are
conjectural at best. There is considerable
disagreement among economists about the
value of human life and the costs
associated with pain, suffering, and
anxiety.
Property value estimates are usually
based on reasonable statistical techniques,
and empirical findings are quite consistent
among the best-known studies. For the
analysis of production benefits, e.g., with
commercial fishing and water supply users,
the methodological framework is fairly
standard and data bases can often be
obtained. Yet empirical work is severely
limited to a few references.
Despite these deficiencies, national
damages have been estimated here for
important water uses. Preliminary results
indicate that these impacts exceed $12
billion annually, excluding nonuser
benefits from recreation and intangibles,
such as aesthetics, ecological stability,
and wildlife support. Many public opinion
surveys have underscored ' the social
importance of preserving or enhancing these
values. It is thus apparent from a cursory
analysis that water quality control is
indeed worthwhile to national welfare, and
it should therefore be pursued vigorously
so that society can realize these
potentially large benefits.
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GUIDING TECHKDL06ICAL AND SOCIAL CHANGE
Sven Lundstedt
The Ohio State University
Schoel of Public Administration
College of Administrative Science
1775 South College Road
Columbus, Ohio 43210
ABSTRACT
This paper examines concepts which contribute to a deeper understanding of how to
guide technological and social change. Technology assessment requires social assessment
utilizing knowledge of how social systems change. Social indicators are one important
method of obtaining information about social change. Methods of guiding change and manag-
ing conflict are also reviewed. Contributions from the social and behavioral sciences sug-
gest that a "socio-technical" systems analysis will be more useful in technology assessment
in the future.
Measuring the impact of pollution con-
trol technology is a form of technology
assessment and guidance of social change.
Technological changes can be social inter-
ventions. Consequently, a new technology
may require analysis of its present and fu-
ture effects upon physical and biological
environments, and upon human social commu-
nities and individuals. This perspective
requires not only the physical and biologi-
cal sciences, and engineering, but also the
social and behavioral sciences.
TECHNOLOGY ASSESSMENT
According to one view (from "Technology
Assessment for the Congress" prepared by a
subcommittee of the Committee on Rules and
Administration, United States Senate, GPO,
1972), "Three key questions arise in the
technology assessment process: Where do we
want to go? (goals); where are we most
likely going? (forecasting); and where are
we now and how are we doing? (social, eco-
nomic, environmental, and other indicators)
. . . . The purpose behind all these for-
ward looking activities is to direct plan-
ning efforts toward creating desirable situ-
ations without the undesirable effects. . . .
Sociology, anthropology, psychology, mathe-
matics, engineering, ecology, and the policy
sciences demonstrate man's new power to un-
derstand, forecast and sometimes manipulate
those forces which influence his social and
physical environment."
One example of technology assessment
methodology developed by the Mitre Corpora-
tion for the Office of Science and Tech-
nology identifies seven steps:
1. Define the assessment task.
2. Describe relevant technologies.
3. Develop state-of-society
assumptions.
4. Identify impact areas.
5. Make preliminary impact analysis.
6. Identify possible action options.
7. Complete impact analysis.
SOCIAL AND BEHAVIORAL SCIENCE METHODOLOGY
The social and behavioral sciences en-
large the "state of society assumptions"
in the third step. The methods presently
available for social system analysis, atti-
tude measurement, and analysis of the so-
cial "ecology" of communities comprise al-
ternative forms of analysis. Social indi-
cators used to monitor over time the social
impact of a technological innovation are
especially useful. Social indicators
179
-------
promise to become a forecasting methodol-
ogy to determine how changes in human com-
munities are affected by proposed technol-
ogy. According to Parke and Sheldon (1972,
p. 100), such an indicator is ". . . (a)
statistical time series that measure
changes in significant aspects of society.
. . .a prerequisite to the advancement of
social indicators, however defined, is the
scientific measurement of social change."
An important part of technology assessment
is, consequently, measuring technological
impact on social change.
Prediction of the multiple effects of
complex technology upon a social system
using social indicators may have to go be-
yond empirical studies. A social system
theory is also necessary if a social indi-
cator is to be used effectively. Social
indicators reflect an underlying social
structure said to be undergoing change in a
community. The elements of such a social
structure are not easy to determine because
there is apparently no uniform opinion about
how to characterize it. Sheldon and Freeman
(1970, pp. 102-103) argue that "There is no
social theory, even of a tentative nature,
which defines the variables of a social sys-
tem and the relationships between them. It
is difficult to locate partial theories or
so-called middle-range ones covering any
single aspect of society which have convinc-
ing explanatory potential. Yet, without
the guidance of theoretical formulations
concerning significant variables and their
linkages, one can hardly suggest that there
exists, even potentially, a set of measures
that parallel the economic variables."
While technical problems such as scale con-
struction, experimental design and the like
are important, theory development is an
urgent overriding need. Sheldon and Free-
man (1970, p. 104) recommend that "With more
knowledge on what to measure and better op-
erational measures, work on understanding
the past and predicting the future would be
made more effective."
If analysis of social systems can pro-
ceed forward in a complimentary way with
increased methodological sophistication,
then social indicators may "contribute (.1)
to improved descriptive reporting; (2) to
the analysis of social change; and (3) to
the prediction of future social events and
social life" (Sheldon and Freeman, 1970,
p. 103). The three levels of analysis all
seem to be relevant in technological impact
analysis.
IMPORTANCE OF AN ECOSYSTEM VIEW
A comprehensive ecological theory of
social system change is necessary in tech-
nological impact studies. Some elementary(
forms of social change in complex human co^n-
munities, for example, are like those among
lower organisms in their ecosystems. The
concept of the "food web" of feeding inter-
relations has a counterpart in complex human
communities in the "resource web" or "re-
source network" in which a resource commod-
ity may be simple ingestible food or forms
of usable energy such as gasoline, fuel oil,
natural gas, electricity and atomic fuels.
The fuel shortage is a recent example of the
dramatic effects on social behavior of major
reductions in portions of the United States
resource network.
Another example is "convergence" (or
maturation) illustrated clearly in edaphic
series which range from so-called pioneer
to climax ecosystems. Programs of pollu-
tion control suggest optimistically that a
technology intensive aging process in an
ecosystem can be reversed. If this is
true, then should we not be able to find
that some forms of social reversal of aging
may occur in related human social systems
at the same time? Cleaning up lakes and
streams may initiate public demand for rec-
reation which in turn may set in motion re-
newed social interaction and economic ac-
tivity with second and third order social
benefits.
Synecological effects (i.e., interre-
lations of natural grouping of populations
and communities) also may be quite far
reaching as efforts are made to reverse the
aging process of human societies which are
a result of wear and tear on society
caused by technology.
Social and technological stratifica-
tion is still another consideration. Much
more could be known about the forms of pol-
lution control efforts upon the vertical
series, or social strata, of human commu-
nities. Benefits to one social group, for
example, cannot be assumed to occur across
the board. Questions of social and legal
equity and questions of social and polit-
ical organization are raised. The social
goal of "the greatest good for the greatest
number" poses logical and value problems
associated with distributive justice which
are hard to resolve and which need reinter-
pretation in the light of present values.
180
-------
Tradeoffs in resource allocation from con-
trol programs to reduce social costs of
technology to some groups and organizations
may not be successfully applied in all
cases. Pollution control programs may
spread this social cost too narrowly among
some social groups or too widely among
others. The issues this problem raises are
philosophical and ethical as well as social-
psychological .
Social changes arising as a consequence
of "resource web" disruptions may seriously
affect the economic survival of individuals
in the "intergrading" areas which comprise
ecotones or marginal zones in an ecosystem.
For example, independent automobile service
stations were the first to disappear when
the gas shortage struck. Poorer people who
live in lower socio-economic areas in the
vertical series in the ecosystem usually
are hurt first by the price increases cre-
ated by the disruption in the resource web.
Such people will not be able to pay for,
and obtain, gasoline should it reach one
dollar per gallon.
Moreover, studies of the formal, admin-
istrative, nonpsychological structures of
a social system are often misplaced analy-
ses. Changes in human behavior often go
unnoticed. Synomorphic analysis of the be-
havioral space of a human community yields
quite a different order of information
about important social relationships (see
the work of Barker, 1968). It is not sur-
prising to find that a change in a physical
environment by control of a pollutant will
not at all affect the formal structure of,
say, a family or larger social organization,
but may change dramatically the type and
intensity of informal day-to-day behavior.
We are all familiar with the fact that a
classical organization chart may contribute
very little to understanding actual work
behavior of people in an organization.
Finally, comparative analysis of the
ecolpgical equivalence, or differences be-
tween communities, may help us to under-
stand positive or negative changes in so-
cial behavior occurring after changes in
the physical environment. Often we do not
know ahead of time which technological
changes result in beneficial social effects
because we do not understand the principle
of ecological equivalence. The people of a
given socio-economic level in one community
may or may not share the needs and problems
of the same socio-economic level in another
ecosystem. The assumption that they do may
be wrong. All poor people do not have the
same needs nor do all wealthy people, all
other things being equal. They may vary in
the periodicity of their needs which are
invariably correlated with changes in such
resources as food and energy. The question
of the effects of such change upon resource
use would seem to be an important one to
ask.
These considerations can affect the
kinds of social indicators which may be de-
veloped to improve social reporting, analyze
social change, and predict future social
events and social life as it is affected
by technological change.
THE RANGE OF SOCIAL INDICATORS
Land suggests that one can view social
indicators as "output descriptive" which
measure the end products of social proces-
ses, "other descriptive indicators" which
are general measures of social conditions
and changes, and "analytic indicators"
which are components of models of social
processes resulting in the values of output
indicators (see also Sheldon and Land, 1972,
p. 139). The last one illustrates the
problems of theory development discussed
above.
Sheldon and Land (1972, p. 146) also
list social indicator content areas which
has some bearing upon the range of social
events which we may wish to view in rela-
tion to a given technological assessment.
The list is obviously not exhaustive for
our purposes and its eclectic form misses
the theoretical mark. Under "socio-econom-
ic welfare" they mention population (com-
position, growth and distribution), labor
force and employment, income, education,
health, leisure, public safety and legal
justice, housing, transportation, physical
environment, social mobility and stratifi-
cation, and knowledge and technology. Un-
der "social participation and alienation"
are included family, religion, politics,
voluntary associations, alienation, use of
time, consumption behavior and aspirations,
satisfaction, acceptance, morale, etc.
Land remarks that "While there is nothing
inherently wrong with such a procedure, es-
pecially at this stage in social indicators
research, it fails to provide a rule for
the systematic refinement and augmentation
of the list, and it certainly provides
little in the way of guidelines for the
analysis of social change."
181
-------
Social indicators, therefore, should
be encouraged in technology assessment be-
cause they will increase knowledge of the
effects of technology on social life and
are useful in planning and monitoring
change. Limits of space preclude further
discussion of a variety of technical issues,
such as attitude measurement (e.g., Maloney
and Ward, 1973, discuss an interesting ob-
jective scale for measuring ecological at-
titudes and knowledge), data collection
methods, and experimental or study design
which will have special relevance in socio-
technical systems analysis. There are also
a number of related problems of policy im-
pact analysis including the value of using
rigorous experimental designs to guide so-
cial experiments in technology assessment.
Volumes and papers by Rossi and Williams
(1972), Campbell (1971), Seashore (1973),
and Webb, Campbell, Schwartz, and Sechrest
(1973) serve as examples.
GUIDING TECHNOLOGICAL CHANGE
Guidance of change requires rational
planning and wider citizen participation,
and knowledge of the limitations of such
planning and participation. One thing seems
to be clear. Guiding change is sufficiently
complex to require attention in and of it-
self. I favor the term guidance of change
rather than management because in this com-
plex work tasks are often highly consulta-
tive and communications intensive rather
than directive and controlling in the older,
classical, management sense. Very often
control over procedures and effects is a
consequence of a mixture of problem solving
behaviors, rather than a single kind of
directive administrative or legal action.
Jurisdictional and legal boundaries and con-
straints, moreover, require flexible utili-
zation of methods which cut across diverse
social organizations and groups. Thomas
and Bennis (1972, p. 11) warn that one often
"cannot afford the illusion of total mastery
over change which many technocratic ap-
proaches seem to imply; nor can (one) afford
that brand of fatalism which can cause us to
give up attempting to implement the planning
for change ethos necessary. ..." One
interesting paradox offered by Eric Trist
called the "planners dilemma" urges us to
reconsider the methodological issues manage-
ment of change raises. Trist says that
". . .the greater the degree of change, the
greater the need for planning—otherwise
precedents of the past could guide the fu-
ture; but the greater the degree of uncer-
tainty, the greater the likelihood that
plans right today will be wrong tomorrow"
(quoted in Schmidt, 1970, p. 29).
At the heart of guidance of change are
three fundamental elements: adequate infor-
mation and knowledge; viable communication
or information systems requiring an appro-
priate degree of citizen participation; and
flexible decision rules comprising a strat-
egy for utilizing these elements. I should
like to illustrate some decision rules which
contribute to guidance of change. Some are
sequential requiring, as does the critical
path analysis, a deliberate sequence of
acts to be performed. I have paraphrased
one view of change guidance which recom-
mends five initial steps (Mann and Neff,
1961). Those who have an historical inter-
est may recall that a significant amount of
prior conceptual work has been done includ-
ing earlier pioneering efforts by Kurt
Lewin (1958) and William Fielding Ogborn
(see his selected papers, 1964), and work
in social psychology and sociology.
The state of a community or social eco-
system before technological change.
Thi-s amounts to a social system analy-
sis which may involve a partial or
complete study of some morphological
and functional aspects of life styles.
I have referred above to the term
social ecosystem which is a preferred
unit of analysis for reasons given
earlier. The focus of a given analy-
sis is determined by the character of
the technological change'to be intro-
duced. In some cases, use of social
indicators may suffice, in others more
comprehensive analyses may be required.
Recognizing a need for change. Psy-
chological readiness for change is im-
portant to determine. One must assure
that individual motivation is reason-
ably high to search for innovative sol-
utions to a problem and that a problem
is recognized initially.
Planning for change. Setting objec-
tives, clarifying the problem and de-
fining it, developing alternative
courses of action, strategy and tactics,
identifying and developing needed
skills, obtaining information and
knowledge, and designing information
systems which determine the required
degree of citizen participation. In
this connection see the volume Planning
182
-------
for Innovation (Havelock, 1971) which
discusses a variety of methods.
Taking action steps to make the change.
Action is taken to execute the change
plan through appropriate degree of in-
volvement of the public and others,
creating methods for monitoring the
change by utilizing appropriate social
indicators, replanning where necessary,
and formation of new action steps.
Stabilizing change. It is important
to act to consolidate and to reinforce
patterns of behavior and fulfill public
expectations required under a new sys-
tem. This is no less important than
the other four conditions since there
never are built-in guarantees in any
new program that it will not seriously
be affected by changes in the ecosys-
tem in the future, especially those
which are political and economic.
This approach recognizes the vital im-
portance of citizen participation in the
actual process of change. Without emotion-
al and intellectual commitment to new ideas
it engenders there can be no long-term com-
mitment to the change. An atmosphere of
trust and openness in communication and mu-
tual planning and action is a key to sus-
tained public support for programs of tech-
nological change. It is important to re-
affirm that methods of change are as impor-
tant for success as is the object of change.
Ends do not justify means because the means
will affect the ends in far-reaching unan-
ticipated ways.
Four additional points about the guid-
ance of change are noteworthy. There is
first an effect created by the psychologi-
cal, social and material rewards brought
about by the change, as well as by disap-
pointments . Motivational effects of change
are important to consider. Closely related
is the timing of the change process. Rapid
change will have adverse motivational ef-
fects which are irreversible. They may
create deep-seated resentments which will
limit future programs of technological
change. Third, social power, and its many
political forms, will play an important
part. Ignorance of the "realpolotik" of
social change is an important cause of fail-
ure of change efforts. Fourth, complex or-
ganizations are interconnected systems, some
elements of which will affect the behavior
of others. Obvious as it may first appear
to be, failure to take into account other
relevant systems which affect the one to be
changed contribute to the probability of
failure.
A summary of decision rules which apply
to the guidance of change are reproduced in
Figure 1. While the term management is
used in the text of the figure, the deci-
sion rules also apply to the concept of
guidance of change.
MANAGEMENT OF CONFLICT
In the course of guiding complex tech-
nological change, responding to dissent
through the resolution of group and indi-
vidual protest may become a critical issue.
Consequently, it may be useful at this time
to discuss some principles about the man-
agement of conflict. The following remarks
are adopted from an earlier paper (Lund-
stedt, 1970).
Kenneth Boulding (1964, pp. 138-145)
makes a useful distinction between two
elementary social acts which occur in ad-
versary relations called conflict moves
and trading moves. Successful trading re-
sults in both parties gaining something.
Conflict results in gains for at least one
party and some losses for the other. Occa-
sionally both lose. Mutual loss is a spe-
cial outcome of conflict behavior in which
neither party may have full control over a
final outcome. Conflict can have a "win-
lose" quality.
Fortunately, all conflicts are not ir-
retrievably hopeless. They are usually
changed into mutually beneficial trading by
compromises and sharing of benefits. Nego-
tiation and bargaining, strictly speaking,
is a procedure by which a particular con-
flict field is explored to find the best
available and mutually beneficial trading
moves. As soon as all available trading
moves in a particular field of conflict
are exhausted, the parties are left with an
"irreducible minimum" of conflict. If the
leftover conflicts are unimportant to the
further survival of either party, each may
lose interest in the issue at hand. If the
remaining conflicts are serious enough, the
conflict relationship between the two may
continue to evolve and may become a crisis
and deadlock. New methods of conflict man-
agement are then imperative. The "relevant
states," or value systems in the conflict
field often have to be reexamined to find
ways to break the deadlock.
183
-------
The
Individual' E
Estimate
of Impact
of Change
on Him
Figure 1
Strategies for Managing Change
Management's Estimate of Impact of Change on Individual
Estimates
as Self-
Enhancing
(compatible
with per-
sonal goals)
Don't Know
Estimates
as Self-
Destructive
(incompatible
with per-
sonal goals)
Estimates as
incompatible with
individual's per-
sonal goals
Don't know
Estimates as
compatible with
individual's per-
sonal goals
When finding
Support and
Acceptance:
Start scaling down
expectations to real-
istic basis so that
disillusionment is
not destructive
When finding
Resistance:
Begin to review
objectives and give
information about
the change to re-
duce ambiguity
When finding
Opposition:
Review change ob-
jectives
Change objectives
or
Change personnel
(Change would have
to be made in period
of power imbalance
in favor of manage-
ment)
(A) When finding (D)
Support and
Embracement:
Provide individuals
with knowledge that
course of change is
not fully predictable
.
(B) When finding (E)
Resistance:
Provide full informa-
tion about necessity
for change as seen
by management
Share control in putting
change into effect
1 ' ' ~ .,.-.-
(C) When finding (F)
Opposition:
Provide full informa-
tion
Share control in putting
change into effect
1
1
1
1
I
I
1
H.
|
i
1
1
1
1
1
1
T —
I
1
1
1
1
|
1
|
1
1
|
When finding (G)
Embracement
and Support:
No problems except
to maintain favorable
definition of change
When finding (H)
Resistance:
Increase informa-
tion about change to
reduce ambiguity
When finding (I)
Opposition:
Increase informa-
tion about change and
its implications
Recognize that climate
of trust is unfavorable
— Identify and publicize
how steps being taken
are compatible with in-
dividual goals --distin-
guishing this change
from others in the past
From: Mann, F. and Neff, F. Managing Major Change in Organizations. Ann Arbor:
Foundation for Research, on Human Behavior, March^ 1962,
-------
Social attitudes and motivation are
obviously helpful in understanding social
conflict. If we should ask why conflict
and trading occur between individuals and
groups, psychological concepts are required
to help explain the source of an action.
Conflict and trading are always motivated
behaviors and a key to understanding them
is to know the extrinsic and intrinsic mo-
tives behind the behaviors.
Conflict and trading behavior are said
to be motivated by expectations and emotions
associated with reward or punishment. Ex-
perimental research and common sense over-
whelmingly support the interpretation that
people are attracted by the promise of
pleasure and the reduction of pain. This
fundamental point is important. Pain irri-
tates, angers, and then repels or provokes
attack and is a basic source of conflict.
Conflict and trading are also "motivated"
by reasoning and reasoned choices among al-
ternatives, especially in the selection of
avenues for achieving personal or group
goals which appear rewarding.
We commonly think about social rela-
tions and conflict not only in terms of an
anticipated future, but also in terms of
immediate and past memories (both emotional
and intellectual) of earlier pleasure or
pain encountered in conflicts with others.
Conflict and trading behavior reflect the
influence of long- and short-term memories
in ways which are subtle and far-reaching.
As for plans and anticipation, it is fair
to say that most people regard the future
in terms of a subjective probability where-
in either winning or losing in a conflict
is expressed along a scale of values in
which emotionally laden long- and short-term
memories of former reward and punishment
play an important part.
Only when minimal human requirements
for survival have been met can generosity
and cooperation begin to take on extensive
concrete meaning. Paradoxically, though,
under some limited conditions people may be
able to express these sentiments even when
deep dissatisfaction and personal suffering
are evident. People will, on the average,
express humane social wants and sentiments
even under severe duress provided, of
course, that too much duress does not exist.
Providing cynicism is not too over-
whelming, generosity also leads to increased
generosity and reciprocity. George Homans
(1958, p. 597) correctly tells us that
human social exchanges are even a form of
"economic1' reciprocity.
Reward and punishment also markedly af-
fect the emotional depth of intellectual
commitment. In trading, when one is con-
sistently rewarded, thoughts about one's
adversary should tend to become favorable.
When two or more parties continue to be
mutually rewarded the relationship between
them eventually should improve. It is im-
portant also to indicate that use here of
the terms "reward" and "punishment" does
not imply any commitment to a particular
theory of behavior, such as behavior modi-
fication or the like, and is merely a use
of the terms in a generic psychological
sense.
When we think, feel, and prepare to
act toward someone or something we are
said to have an attitude toward it. These
three elements form the structure of a
single attitude, and, thus, an aspect of
our psychological posture toward something
or someone. Thought, feeling, and a
readiness to act are obviously of great
importance in understanding conflict and
trading behavior, and ultimately conflict
management. We know a great deal when we
understand the true attitudes of others,
and, accordingly, we can manage relation-
ships better by anticipating others' needs.
On this sound basis we can examine more
thoroughly common mistakes and alternative
methods of confrontation and problem solv-
ing.
Two common errors are indicated in
Figure 2.
TWO METHODS OF CONFRONTATION
Dueling
This method of confrontation has been
inherent in generalized conflict. The in-
evitable "win-lose" quality that arises in
dueling contributes to cycles of behavior
that often lead to patterns of mutual de-
struction. Since each will work only in
terms of his own self-interest to the ex-
clusion of the other, each may become ir-
revocably trapped within this blind alley
which so decidedly shapes the final outcome
of such conflict and sets narrow limits
upon opportunities available for its reso-
lution. People, groups, or organizations
can hardly be expected to bargain rationally
185
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Figizre 2
Attitudes and Conflict Management
But the octuol otti'ude of your
adversary toward you is:
Positive and
Favorable
Negative and
Hostile
||
si
ll
**
ll
a>"&
"S&
B5I 1
'II
Probable Outcomes:
Trading
Conflict resolution,
Increased Communication
and
Generally productive
relations
Type 8
Error in Decision-Making
Probable Outcomes:
Disruption in trading due
to miscommunication and
confusion of motive.
Higher probability of
hostility and conflict un-
less corrected,
Type A
Error jn Decision-Making
Probable Outcomes.-
Disruption in trading due
to miscommunication and
confusion of motive.
Higher probability of
hostility and conflict un-
less corrected.
Hostility and
Conflict
in the face of hostile attitudes/ mistrust,
and anger that are aroused by mutual punish-
ment. Indeed the dilemma has been called a
form of "conflict trap." Hostile duelers
often cannot abandon a pattern for fear of
loss of face, status, or property.
Paradoxically, variations upon this
style may represent only a slight improve-
ment so that quantitative deescalation may
not in fact equal qualitative deescalation.
The psychological limitations of this
method of social problem solving are quali-
tatively similar. Threats to survival in-
evitably force contending parties to adopt
the inexorable logic of defense and offense.
The locked-in quality of the "win-lose"
frame of mind strangles efforts to find
avenues for productive bargaining, and the
cycle of dueling and mutual destruction re-
mains essentially unchanged.
Mutual Problem-Solving
Collective bargaining attempts to re-
move a qualitative psychological barrier in
dueling behavior because it reflects a
change in attitude toward one's adversary
and in the motivational bases for action.
The requirement of negotiation in many mod-
ern conflicts has set the stage for mutual
problem-solving leading to intelligent
trading behavior. The special conditions
for such an outcome involve not only a
conscious effort to abandon open hostile
dueling, but efforts to promote the devel-
opment of mutual trust. But we may ask,
what in addition to mutual trust is the
major difference between such problem solv-
ing and the other patterns of conflict man-
agement? What can one expect to find in
this pattern and not in the others? Ini-
tially, the motivational basis of conflict
management has changed from mutual punish-
ment to mutual reward wherein the cultiva-
tion of positive attitudes toward one an-
other is seen as valuable and necessary in
its own right.
Control of threat and anxiety is an
initial qualitative difference in mutual
problem solving. Anxiety has not always
been correctly interpreted. At times it
has been called an unnatural element in be-
havior, an interpretation formed no doubt
from clinical observations of its dysfunc-
tional aspects and their effect upon person-
ality. Such a limited interpretation has
evidently narrowed its usefulness, for it
fails to acknowledge the genuinely natural
function of anxiety.
In moderate quantities, anxiety is a
very effective energizer and motivator. If
it increases too much, however, it tends to
destroy the capacity to reason efficiently
and thereafter acts to inhibit flexible,
creative thinking, replacing it with impul-
sive flight or fight behavior.
This is why excessive threat is a po-
tent negative force in conflict management,
and may limit one's capacity to use effec-
tively the bargaining strategies available.
The indiscriminate use of threat is danger-
ous at best. There are many forms of it,.
and no matter how eloquently it is ex-
pressed, one can never be sure just how
much anxiety and impulsive behavior a given
form will produce in an adversary.
The alternative to threat of any kind
is that form of behavior which succeeds in
reducing anxiety by providing evidence of
positive concern for the survival of one's
adversary.
Anxiety is a form of "noise" in human
communication. In its loudest forms it
will destroy listener and communicator ef-
fectiveness and impair social learning.
186
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Since bargaining and trading depend upon
good feedback they will be affected adverse-
ly by the loss of it caused by defenses
against anxiety. This, of course, even-
tually will leave only blind conflict and
further dueling as an alternative form of
exchange.
A second qualitative difference is a
willingness to take risks with other people,
a basic element in trust. Interpersonal
risk (Lundstedt, 1966) is a formulation
which argues that people will withhold or
give away personal influence and control
over one another (share and exchange re-
sources) only after an initial assessment
by them of the amount of personal risk in-
volved in such a relationship. The concept
of interpersonal risk may be applied to the
group or organization undertaking change.
When the capacity to take interpersonal
risks is inhibited by too much anxiety,
guidance of change is impaired if not cir-
cumvented.
A very good strategy seems to be posi-
tive face-to-face confrontation. Fruitful
negotiation apparently is impossible among
human beings by remote control. People re-
quire the constant reassurance of others'
intentions by personal contact.
Another way is to establish a policy
of improving trust by reducing threat and,
subsequently, the inevitable human respon-
ses of anxiety, frustration, hostility, and
defensive behaviors of flight or fight as-
sociated with threat and anxiety. A good
treaty is one special form. Another is to
examine freely and with candor mutual goals
and all available paths to such goals. All
parties require accurate information about
areas of mutual gain and agreement, as well
as areas of legitimate differences. Still
another is deliberate disengagement from
old patterns of language and thought. Lan-
guage and other cultural patterns can be
serious barriers to effective mutual prob-
lem solving, and to renewed learning.
The intellectual and material re-
sources of any person, group, or organiza-
tion are usually ranked in terms of their
survival value. Accordingly, as one bar-
gains with the most precious elements of
any social system, the price of a trading
exchange will naturally be higher than for
less precious elements. A price may be too
high to allow trading if the things to be
exchanged are too precious. At such a point
normal further trading may become a threat
and a conflict. To press one's advantage
may convert a free exchange into a "win-
lose" situation. An adversary will, as we
have seen, respond with defense or offense
if his capacity to survive is threatened.
Negotiation involving the core resources
of a person, group, or organization is less
likely to result in fruitful trading behav-
ior because of its threatening nature.
Should the strategy of conflict man-
agement one adopts initially begin at the
periphery of a group's valued resources?
Knowledge of human behavior suggests it
might best begin there. Where one stops in
trading and negotiation is a prgamatic mat-
ter guided by one's awareness of natural
human boundaries which eventually become
known through a process of social learning.
They have often been called "territorial
imperatives" indicating that they are func-
tional borders and frontiers which are there
to assure individual and group survival.
We may close this discussion in a
lighter vein with the following thought as
Kenneth Boulding expressed it in his
"Ballad of Ecological Awareness":
One principle that is an ecological
upsetter
Is that if anything is good, then more
of it is better
And this misunderstanding sets us very,
very wrong
For no relation in the world is linear
for very long.
REFERENCES
Barker, R. G. Ecological Psychology: Con-
cepts and Methods for Studying the Environ-
ment of Human Behavior. Stanford, Califor-
nia: Stanford University Press, 1968.
Boulding, K. "A pure theory of conflict
applied to organizations" in Kahn, R. L.
and E. Boulding (Eds.) Power and Conflict
In Organizations. New York: Basic Books,
1964, 136-145.
Campbell, D. "Methods for the experiment-
ing society." Draft of paper delivered to
the American Psychological Association.
September, 1971.
Committee on Rules and Administration, U.S.
Senate. Technology Assessment For The
187
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Congress. Washington, D.C.: GPO, November,
1972.
Deutsch, M. The Resolution of Conflict.
New Haven: Yale University Press, 1969.
Environmental Protection Agency. The
Quality of Life Concept. Washington, D.C.:
Environmental Protection Agency, 1973.
Gerba, J. and P. Boulay (Eds.) Alterna-
tive Futures and Environmental Quality.
Washington, D.C.; Environmental Protection
Agency, May, 1973.
Havelock, R. et al. Planning For Innova-
tion. Ann Arbor: Institute For Social
Research, 1971.
Homans, G. "Social behavior as exchange1'
American Journal of Sociology, 63, 1958,
597-606.
Lundstedt, S. "Interpersonal risk theory"
Journal of Psychology, 62, 1966, 3-10.
Lundstedt, S. "Conflict management: pre-
eminent challenge" Mental Hygiene, October-
November, 1970, 584-588.
Maloney, M. P. and M. P. Ward "Ecology:
Let's hear it from the people - an objec-
tive scale for the measurement of ecological
attitudes and knowledge." American Psychol-
gist. July, 1973, 583-586.
Mann, F. and F. Neff. Managing Major
Change in Organizations. Ann Arbor: Founda-
tion for Research on Human Behavior, 1961.
National Institute of Mental Health. Pollu-
tion: Its Impact on Mental Health. Wash-
ington: Department of Health, Education and
Welfare, 1972 (publication number HSM
72-9135).
(eds.) Experiences In Action Research.
London: Josslyn Press, 1973.
Sheldon, E. B. and H. Freeman. "Notes on
social indicators: promises and potential"
Policy Sciences 1, 1970, 97-111.
Sheldon, E. B. and K. C. Land. "Social
reporting for the 1970's" Policy Sciences
3, 1972, 137-151.
Thomas, J. M. and W. G. Bennis (Eds.).
Management of Change and Conflict. Har-
mondsworth: Penguin Books, 1972.
Webb, E. J., D. T. Campbell, R. D. Schwartz,
and L. Sechrest. Unobtrusive Measures:
Nonreactive Research In The Social Sciences.
Chicago: Rand McNally, 1973.
Wohlwill, J. and D. H. Carson (Eds.).
Environment and the Social Sciences. Wash-
ington, D.C.; American Psychological Asso-
ciation, 1972.
Parke, R. and E. B. Sheldon. "The Need for
Social Indicators." Proceedings, Indus-
trial Relations Research Association 25th
Annual Meeting, 1972, 99-105.
Rossi, P. H. and W. Williams. Evaluating
Social Programs. New York:. Seminar Press,
1972.
Schmidt, W. H. Organizational Frontiers
and Human Values. Wadsworth, 1970.
Seashore, S. "The design of action re-
search" In Clark, A. W. and P. M. Foster
188
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CLOSING REMARKS
F. M. Middleton
Deputy Director
National Environmental Research Center
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
We have come to the close of the Pol-
lution Control Technology Conference. You
have heard the papers and the discussions.
I will not go into a detailed summary and
reiteration, but I would like to hit a few
high spots in closing.
The Conference was off to a good start
when Mr. Strasser gave us an explanation of
Technology Assessment. It seems to be many
things to many people. I believe
Mr. Strasser considers Technology Assess-
ment to be a systematic planning and
forecasting process—one that delineates
options and costs and that encompasses
economic, environmental, and social con-
siderations , both external and internal to
the program or product in question. Bad
as well as good effects are considered.
From some industrial sector representa-
tives we heard that pollution control laws
and their administration are unrealistic,
with possible disastrous consequences for
some industries. From other industrialists,
it appeared that fruitful discussions with
enforcement bodies are possible - and that
give-and-take can resolve many knotty
problems.
We also heard from EPA lawyer Johnson
in the Enforcement Division, which grapples
with the permit system, how progress in
turning the work over to the States is being
made. The complexities of implementing a
complex law on a tight time table were
evident.
Norman Ross gave us some frank views as
to how the Administration's Domestic Council
carries out its functions and relates to
the agencies.
We had a marvelous review of the behind-the-
scenes work of the House Public Works
Committee through Counsel Gordon Wood. It
was made clear that the organizational
structure and division of duties have made
it nearly impossible to consider the en-
vironment in an integrated fashion. Changes
in the offing may improve this situation.
After these opening sessions, we went
into pollution control technology as it
relates to air, solid wastes, radiation,
hazardous wastes, and water.
It is quite obvious that nearly anything
we do toward environmental improvement
affects something else. Cleaning the air
may produce large amounts of solids that
themselves create a disposal problem. The
scrubbing water can be a water pollution
problem. Getting the water cleaner and
cleaner creates more sludge. Are we using
too much water for our needs? With water
sales an important source of revenue to
cities, should the water be conserved if the
supply is plentiful? In industry, attention
is focused on the industrial process itself
and on avoiding pollution where possible.
We do know a great deal about radiation
and the handling of wastes, but serious
gaps are evident. Nuclear energy development
will require continuing attention to safety.
We find that we are in a very early
stage of dealing with hazardous wastes. We
even have trouble knowing just what is
hazardous and how hazardous. Shall we
treat them? store them? recover valuables?
or what can we do? Here is a place to
truly focus upon how hazardous wastes come
into being in the first place.
Solid wastes are tough problems.
Mr. Bucciarelli told of good progress in
closing dumps and instituting better regula-
tions and disposal methods. The quantities
189
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of solid wastes, already staggering, are
increasing. Can the ocean be an ultimate
sink? Will we run out of land in a suit-
able location for land disposal? There are
hazards to deep well disposal. Dick
Eldredge has found that it was easier to
write regulations than to solve a client's
problem in an economical manner.
At the banquet Joe Moore explained the
work of the National Commission on Water
Quality. When speaking of trends in the
environmental area, Joe noted the tendency
to hire lawyers instead of engineers. He
believes this trend may be in the wrong
direction.
The relations of land use and planning
to water pollution came in for discussion,
as did materials and natural resources.
Dr. Clark and Ken Klitz put these more
indirect factors affecting pollution into
perspective. Energy is a key word today.
Kurt Yeager brought out clearly the inter-
relationships of the environment and energy.
He showed the early plans for dealing with
the multiple problems in seeking self-
sufficiency in energy.
In our wrap-up session on Friday,
Dr. Lee described some progress in cross
media effects and emphasized that in our
control strategy, we must consider pollu-
tants from our industrial processes. We
need to do more to develop an index of
pollution that relates to air, water, and
land.
Dr. Plumlee indicated that data on
health effects from environmental pollution
are sparse. What is the danger of living
downwind from the activated plant or an
incinerator? How do we achieve protection?
We were pleased to hear that health effects
work in EPA is increasing.
Dr. Tihansky demonstrated the very
large costs of controlling pollution. What
are the cost-benefit trade-offs of these
actions? National damages from pollution
in terms of esthetics, agriculture, fisher-
ies, health, plumbing, and navigation amount
to billions of dollars.
Our final talk by Dr. Lundstedt stressed
the importance of the effects of technology
on people. Plant siting considerations are
vital. What are the community stresses re-
sulting from development? Can you reverse
the aging of a community? What kind of
guidance can be given for management change?
What is the net result of our Conference?
I believe that we can all agree that it was
very informative. Thanks to excellent
speakers, the Conference was stimulating.
All of us should have gained in breadth as
well as depth in the several subjects
discussed. I trust, too, that audience
interactions in and out of the meeting were
useful.
The results of the Conference should not
stop at an interesting two-and-one-half
days. The practice of technology assessment
should spread back to our colleagues and
organizations. Ways of thinking about
environmental matters should be expanded as
a result of the Conference, and Conference
proceedings can extend this information to
many who could not attend.
And now, with our deepest thanks to the
planners, the speakers, and to you, the
audience, we bring this Conference to a
close.
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