PRETREATMENT ISSUES AND
  THE PUBLICS RESPONSE
AN ANALYSIS OF PUBLIC HEARING TESTIMONY
   AND COMMENTS RECEIVED BY EPA ON
  A PROPOSED REVISION TO THE GENERAL
  PRETREATMENT REGULATION (40 CFR 403)
             ^ PRO^°
    U.S. ENVIRONMENTAL PROTECTION AGENCY
  OFFICE OF WATER PLANNING AND STANDARDS
        WASHINGTON, D.C 20460

           SEPTEMBER 1977

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         PRETREATMENT ISSUES

      AND THE PUBLIC'S RESPONSE
      An Analysis of the Public
      Hearing Testimony and Com-
      ments Received by EPA on a
      Proposed Revision to the
      General Pretreatment Regu-
      lation  (40 CFR 403)
          September 1977
U. S. Environmental Protection Agency
Office of Water Planning and Standards
  Office of Analysis and Evaluation
      Washington, D.C.  20460

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This document was prepared for
the U.S. Environmental Protection
Agency by a private contractor and
does not necessarily reflect the
views of the Agency. The document
does not imply endorsement of any
opinions expressed by the public
nor does it indicate any predis-
position by the Agency toward any
of the four pretreatment strategy
options proposed to the public as
40 CFR 403.

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                               TABLE OF CONTENTS


    INTRODUCTION	1

    MAJOR PRETREATMENT ISSUES	5

       I.     Degree of Federal Involvement	5

      II.     Adaptability of the Pretreatment Program	25

     III.     Basis for Pretreatment Standards 	  35

      IV.     Extent of Industry and Pollutant Coverage	53

       V.     Sludge Disposal and Treatment Considerations  	  71

      VI.     Meeting Statutory Compliance Deadlines 	  83

     VII.     Duplication with Existing Pretreatment or
              Industrial Source Control Programs 	  95

    VIII.     Economic Impact of Pretreatment Programs  	105



LOG OF LETTERS	125
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         PRETREATMENT PROGRAM ISSUES AND THE PUBLIC'S RESPONSE



          Introduction.  The Environmental  Protection Agency (|EPAj,  in



the February 2, 1977 Federal Register, proposed four alternative pre-



treatment strategies for the control of industrial  wastes discharged to



municipal sewer systems.  These options attempt to  achieve the statutory



objectives of preventing interference and pass-through.\  They differ



primarily in terms of 1) the basis on which pretreatment  standards  would



be developed; 2) the degree to which EPA, the States, and local  governments



would have responsibility for enforcement of the program; 3) the number



and type of pollutants and sources that would be covered  by national



standards; and 4) the number of sources of each pollutant within an



industry that would be regulated by national technology-based standards.



         1 To encourage public participation in the  rule-making process,



EPA held public hearings\during the month of April, in the cities of San



Francisco, Boston, Washington, D.C. and Chicago.  In addition, the



public was invited to submit written comment for consideration by EPA by



the (extended) May 18, 1977 deadline.   EPA noted that the publication



of the four strategy options did not preclude interested  parties from



offering a modification of one option or a combination of two or more



options for consideration.



         iThe following analysis of public comment  is based on the



transcripts of the four public hearings and the 374 letters received to



dateA A log of these letters is attached.

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                                  -2-
Major Pretreatment_Pjrograni Ijssu_es.
          In developing the analysis,  the above documents were carefully
studied, and the comments were categorized into eight major issues.  Key
elements were identified which highlighted each of the major issues. The
eight major issues are briefly summarized below:
          Degree of Federal Involvement.  Essentially two approaches
exist for implementation of enforcement programs, (a) maximum (i.e., direct
Federal) involvement, and (b) minimum  (i.e., indirect) Federal involvement.
          Adaptability of the Pretreatment Program.  In developing the
pretreatment program, it was deemed necessary to include variance provisions
to compensate for the extreme variability exhibited by POTW's in the removal
of industrial pollutants to avoid the  construction of redundant facilities
by industry, and the problems resulting from such an approach.
          Basis for Pretreatment Standards.   This issue focuses on the
flexibility of pretreatment standards  to adjust to local variations.  Two
types of standards have been proposed, (a) national technology-based stan-
dards; and (b) water quality-based standards.
          The type of unit in which the standards would be expressed—mass-
based limits  or concentration-based limits—was also a matter of consid-
eration.
          The Extent of Industrial and Pollutant Coverage.  This issue
is inextricably related to the other pretreatment issues, i.e., degree
of Federal  involvement, type of standards, variances, duplication, and
also involves the fulfillment, by EPA, of the Consent Decree signed
in June, 1976 by the Agency, the Natural Resources Defense Council (NRDC),
the Environmental Defense Fund (EOF),  and the Citizens for a Better
Environment.   Six factors have been identified that directly relate  to
the expressed viewpoints on industrial and pollutant coverage:

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          a)   the demand for broad industry and pollutant coverage;
          b)   the demand for limited industry and pollutant coverage;
          c)   compliance with the requirements of the Consent Decree;
          d)   the form of coverage:   uniform standards or guidelines;
          e)   technical feasibility of industry achieving standards;
               and
          f)   categorization of pollutants and industry for regulatory
               purposes.
          Sludge Disposal and Treatment Considerations.  The type and
quantity of industrial discharges and the degree to which industrial
pretreatment is practiced will directly influence the character of a
POTW's sludge.   Where industrial pretreatment is not practiced, or where
a POTW is issued a variance, toxic pollutants will be absorbed into, and
contaminate the POTW's sludge, thereby limiting the POTW's sludge disposal
alternatives.
          The resolution of the sludge disposal issue is also contingent
on how the recently enacted Resource Conservation and Recovery Act of
1976 will eventually relate to the finalized pretreatment regulations
and the ultimate requirements for sludge disposal.
          Meeting Statutory Compliance Deadlines.  This issue centers  on
the problems of attaining compliance with the proposed pretreatment pro-
gram and how the as-yet unpromulgated standards will cause delay in the
attainment of the July 1, 1977 and July, 1983, water quality goals and
technology control requirements.
          Duplication With Existing Pretreatment or Industrial Source
Control Programs.  A major concern expressed in the comment received is
that the proposed regulations would cause duplication of facilities

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and conflict with the efforts of existing pretreatment and industrial  source
control  programs.  Also recommended for consideration by EPA in determining
pretreatment requirements were regulatory and  enforcement conflicts,  dis-
regard of industrial  POTW's,  and the additional  financial  burdens to  be
imposed.
          Economic Impact of  Pretreatment Programs.   Concern was expressed
by municipalities required to design and implement pretreatment programs,
and by the industrial dischargers who must absorb pretreatment costs,  that
EPA had not adequately assessed the economic or  energy impacts of the proposed
pretreatment program.
          A detailed  analysis of the major issues is  contained on the
following pages.

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                                  -5-
l-    DEGREE OF FEDERAL INVOLVEMENT
               Under the statutory mandate of PL 92-500,  the Federal
     government must assume through the ministrations of  the U.S.  Envi-
     ronmental Protection Agency (EPA), the overall  responsibility for
     compliance with pretreatment requirements through an enforcement
     program.  The degree to which this Federal  involvement should be
     exercised has received considerable attention at the four pre-
     treatment public hearings and in the written comments received by
     EPA on this issue.
               Essentially, there exist two approaches for implementing
     enforcement programs.  The Act enables direct Federal enforcement,
     but also strongly encourages State and local efforts that minimize
     Federal involvement.  Thus, the two choices for enforcement programs
     are:
               1)   maximum (i.e., direct) Federal involvement and
               2)   maximum State/local (i.e., indirect Federal) involve-
                    ment
     Under a direct Federal enforcement program, EPA and  NPDES States
     would continuously enforce directly against industry (notify in-
     direct dischargers, perform compliance reviews and monitoring,
     enforce significant violations, etc.).  Under an indirect enforce-
     ment program, the major responsibility for achieving compliance
     would be placed on local  and other State authorities.  In this case

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                                -6-
the local/State authorities would notify all  indirect discharges,
perform compliance reviews and monitoring,  and enforce the stan-
dards.   EPA and the NPDES States would back-up local  enforcement
efforts only where requested or needed.
          Comments supportive of both the direct Federal  enforce-
ment program and the State/local enforcement  programs are docu-
mented on the following pages:

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                              -7-
A.   Comments Supporting Maximum Federal Involvement and Enforcement

     1 .    The Federal government is the strongest enforcing authority for
          obtaining industrial compliance with the pretreatment program
          due to the capability of its varied technical  staff and eco-
          nomic resources.

          Dr. Gaytha A. Langlois, Clean Air Committee, Ecology Action
          for Rhode Island, statement at Boston Public Hearing:

                    "...it should be noted that local  enforcement,  or
               even State enforcement procedures in some cases are  often
               inadequate, either through deliberate negligence,  or
               because of insufficient personnel or by particular
               administrative decision patterns."

          John G.  Costello, Executive Director, Bergen County Sewer
          Authority, NJ, Statement at Boston Public Hearing:

                    "Without strong Federal  backup available, most
               local agencies could simply not afford  the financial
               impact of an effective pretreatment program.   Partici-
               pation by EPA and NPDES States in enforcement  actions
               should be more prominent than those of  local authority in
               order to increase the deterrence value  of the  actions  and
               to  precipitate rapid and uniform resolutions of legal
               issues of national  environmental  importance."

          William  E. Muno, U.S.  EPA Enforcement Division,  Washington,
          D.C.:

                    "One reservation with local  enforcement is that
               those closest to  a  problem are usually  the  most reluctant
               to  take enforcement actions."

          Roger  Sinclair,  Director of Public  Works,  Cottage Grove,
          OR,Statement at San Francisco Public Hearing:

                    "The enforcement has to  be on a  Federal-State level.
              We  have had local  level  control  for years,  and this  is
              why the East River  used to  burn.   And it  just  can't  be
              done.   It can't be  done in  our State.   I  know  that."

          Frank  Dryden,  Head Technical  Services Department, Sanitation
          District of Los  Angeles  County,  Whittier,  CA,  Statement at  San
          Francisco Public Hearing:

                    "...there is obviously a  concern that  the EPA would
              be  considered remiss if it  does not oversee every  step
              that a  local  agency takes in  establishing  and  carrying
              out a pretreatment  program."

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                                  -8-

          I.M.  Rice,  Association  of Metropolitan  Sewerage Agencies,
          Dallas,  TX,  Statement at Washington, D.C.  Public  Hearing:

                    "While  we  recommend  a  high degree of local  control,
               we  realize that the Federal  government must  have undis-
               puted  authority to impose nationally  uniform standards on
               some  substances, whose  effects are especially destruc-
               tive,  and so our proposal is based on three  observations."

          Thomas R.  Glenn,  Director and  Chief Engineer,  Interstate
          Sanitation  Commission,  CN, Statement at Washington,  D.C.
          Public Hearing:

                    "The strategy for  pretreatment source control should
               put the regulatory authority and implementation at the
               State or the Federal and  state level.  Public Law 92-500
               mandates that there are to  be Federal standards.  That is
               from  Section 307.

                    "In general,  it contemplates  that regulation and
               enforcement  pursuant to such standards be either Federal
               or  State, with  Federal  action held in reserve.   The
               latter approach is preferable because it  is  possible to
               utilize State and  interstate agency resources more effec-
               tively, and  because it  makes more  practicable some treat-
               ment  of variation  in the  programs  to  meet differences  in
               regional conditions."

          Roy E. Martin, National Fisheries Insitute, Inc.,
          Washington,  D.C.:

                    "The other options (I,  II, III)  leave too much to
               the control  of  local enforcement and  management.  These
               local  situations are subject to too many  variables, i.e.:
               budgets, personnel, local politics, etc.  Our resources
               have  been subjected to  this  later  scheme  of  management
               and reasoning for  too  long  with resultant disastrous
               consequences for seafood."

2.   Federal  enforcement eliminates "pressures" that could  be exerted
     against  a municipality by an industry to establish  a local
     compliance program or  to  ease enforcement of a standard.

          Dr. Gaytha A. Langlois, Clean  Air Committee,  Ecology Action
          for Rhode  Island, statement  at Boston Public  Hearing:

                    "...these  (local)  governments are particularly
               vulnerable to economic  and  political  pressures, and often
               show  little  continuity  of personnel over  time."

          H.  Clay  Kellogg,  Jr., General  Manager,  Kellogg Supply, Inc.,
          California:

                    "...(local governments) do not need  local  pressures
               from  self-interest groups always trying  to get special
               favors. Keep the  authority at the federal or state
               level."

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                           -9-
Robert H. Kelly, Forest Preserve District of DuPage County,
Lombard, IL:

          "Other options apparently leave too much to
     local control- and local  indecision, confusion, instability,
     and so on.  Even the state can easily back down from
     pressures."

Roger Sinclair, Director of Public Works, Cottage Grove, OR,
Statement at San Francisco Public hearing:

          "Local agencies are very, extremely vulnerable to
     political and social pressures from the local industries.
     We have local industries, and I feel that pressure.  And
     even states, if they are not backed by EPA, they are
     subject to regional industrial organizations, and even
     the legislatures sometimes lean on the state agencies."

John Saucier, Director, Tennessee, Div. of Water Quality
Control, Nashville, TN, Statement at Washington, D.C. Public
Hearing:

          "...one of the problems that we see with the pretreat-
     ment standards is that in some particular small towns,
     industry has enough local clout, that they can get whatever
     ordinance they want passed.  And this is where the state
     and federal government has got to insist that strong
     enough ordinances are passed that they will protect the
     POTW, as well as the effluent standards."

Larry E. Crane, Executive Director, Iowa Dept. of Environmental
Quality, Des Moines, IA:

          "...Many cities may not wish to have the responsibility
     for setting standards due to unreasonable pressures from
     local industry.  Basically cities prefer to have state or
     federal requirements to follow when dealing with local
     industry.  This is especially true of smaller cities that
     may not have large technical, legal, or administrative
     staffs. Many small cities have an industry that provides
     such a large part of local  employment that it is unreasonable
     to expect the city to take firm enforcement action."

Ethyle R. Blcok, Co-Chairman,  Clean Water Committee, Fort
Wayne Chap., Izaak Walton League of America, Inc., Ft. Wayne,
IN:

          "Local enforcement program as supplementary.  This
     is important as they know their community's industries
     and functions.  However,  local government is often lax
     about "hurting" industry for fear of the industries
     moving out of town, and as a result the public often gets
     "stuck" with paying part of industry's bill.  Municipalities
     can not play favorites if this is a nationwide requirement."

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          S.W.  Kitzazaki,  General  Manager,  Oconomowoc  Electroplating
          Co.,  Inc.,  Ashippun,  WI:

                    "To allow local  programs  to  establish  pretreatment
               standards would  not be  as  effective  or  uniform.   We must
               remember that POTW's have  a  vested  interest in  the  commu-
               nity they serve  and may bias or delay pretreatment  stand-
               ards."

          Richard W.  Klippel, Chairman, Industrial  Waste Committee, New
          York Water Pollution  Control  Assoc.:

                    "The entire pretreatment  program including  all  of
               the steps and/or priorities  can only be accomplished if
               it is accompanied by fair  and  efficient enforcement.  In
               the past, efforts,  at enforcement at the local  level have
               met with mixed success.  Lack  of  enforcement has most
               often occurred in localities which  are  economically
               dependent on a small  number  of primary  industries.   In
               such localities, the economic  pressure  executed  by  the
               few primary industries  has often  delayed and in  some
               cases totally defeated  any and all  efforts  of an enforcement
               nature."

          J. Taylor Banks, et.  al.,  Natural Resources  Defense  Council,
          Inc., Washington, D.C.:

                    "...EPA states that variances  from national  pretreat-
               ment standards based on POTW removal  capability  may be
               more or less stringent  than  the national levels.  The
               impetus to seek  variances  which would relax pretreatment
               standards is obvious: indirect dischargers  will  put
               tremendous pressure on  local authorities to obtain  such
               variances."
3.        State and local  enforcement agencies may not possess the neces-
          sary legal  authority and/or enabling legislation  to implement and
          enforce a pretreatment program (e.g., only 28 states have
          assumed NPDES responsibilities).   The existing enabling  legis-
          lation also may not extend  regional  enforcement authority to
          those municipalities that accept  industrial  wastes from  outside
          their political  jurisdiction as a part of a  regional  treatment
          system.

          John G. Costello,  Executive Director, Bergen Co.  Sewer Authority,
          NJ, Statement at Boston Public Hearing:

                    "It must also be  recognized that many regional  sewer
               agencies will  require  state  enabling legislation by all
               the member municipalities to obtain the legal  power
               necessary for direct enforcement of pretreatment regula-
               tions."

          Marwan Sadat, Program Director, Office of Sludge  Management
          and Industrial  Pretreatment, New  Jersey Department of Environmental
          Protection, Trenton, NJ, Statement at Boston Public Hearing:

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                          -11-
          "In general, the local  authorities lack the technical
     status and the regulatory experience to make the proper
     technical decisions in setting up standards in these
     sophisticated problem areas."

John Saucier, Director, Tennessee, Div.  of Water Quality
Control, Nashville, TN, Washington, D.C.  Public Hearing:

          "It is further stated that before any municipality,
     authority, or treatment and collection agency can control
     the waste being discharged into its system, it must first
     have the power of authority to enforce such a regulation.
     Contractual agreements were used in Buffalo and this
     approach is a portion of the procedures recommended by
     the State of Tennessee.  Additionally, the Tennessee
     Division of Water Quality Control believes that indirect
     dishcarge permits with State and/or Federal enforcement
     back up is essential to insure proper enforcement of any
     pretreatment regulation."

Herbert C. McKee, Ass't. Director for Pollution Control, Health
Dept., Houston, TX, Statement at Chicago Public Hearing:

          "While it appears that local governments can best
     develop and implement pretreatment programs, some jurisdict-
     ional problems are inevitable because of the multiplicity of
     local governments in a given metropolitan area.  State and
     Federal programs can perform a useful function in obtaining
     the necessary coordination and cooperation between different
     units of government at the local level.

          "In Harris County, approximatley (sic) two-thirds of the
     people live in the City of Houston and their domestic sewage
     is treated in a city-owned system.   The other one-third are
     served by sewer systems operated by smaller cities, or by
     systems that serve suburban and rural housing in unincorporated
     areas.  No figures are available, but the suburban and rural
     areas do not contain large concentrations of industry; it
     would appear that the Houston permit system probably covers
     between 75 and 90% of the industrial dishcarges to sewers
     that should be covered by pretreatment discharges to sewers
     that should be covered by pretreatment requirements.  Never-
     theless, as the entire area grow, pretreatment of some of the
     discharges outside the City of Houston may be desirable.
     The Texas Constitution denies legislative or ordinance-
     making power to County governments, so a comprehensive pre-
     treatment program developed and implemented by the Harris
     County government would be difficult to achieve.  State and
     Federal programs could be of considerable assistance here
     in devising ways whereby sewer discharges outside the City
     of Houston could be covered by reasonable pretreatment stand-
     ards at some future time."

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4.   Limited economic resources, narrow technical  and administrative
     capabilities, and small  staffs are likely to  preclude the successful
     implementation, monitoring and enforcement of pretreatment regu-
     lations in municipalities, unless extensive assistance and support
     through guidance documents is provided by EPA,  especially in
     smaller municipalities.

     The Metropolitan District, Hartford,  CN, Statement at Boston
     Public Hearing:

               "To establish  the organization needed with the type
          of properly trained employees desirable  would impose a
          serious hardship on a small  town.  And to  suggest it be
          repeated for every  town which has treatment plants seem
          folly when considering the duplication of  effort and
          administration needed to accomplish this.   Even if the
          review were done by private engineers or the review and
          inspection done this way the public organization needed
          to handle these programs at the  local  level  seem still  to
          be unjustified."

     William A. Healy, Executive Director,  Water Supply and Pollution
     Control Commission, Prescott Park, Concord, NH:

               "The proposed  regulations would seem  to be more
          appropriate to large communities  which are more likely to
          have the resources  necessary to  implement  the type of
          pretreatment program contemplated by EPA.   Once again,
          this is clearly an  attempt to apply national standards in
          an area which has numerous variables and would more
          properly be dealt with on a case-by-case basis within the
          broad framework of  generalized Federal-State guidelines."

     Walter A. Lyon, Director, Bureau of Water Quality Management,
     Department of Environmental Resources, Harrisburg, PA:
               "...There needs to be some  guidance for munici-
          palities to allow them to establish pretreatment limits
          on a case by case basis.   This guidance  would not be in
          terms of a nationwide industrial  standard  of pretreatment
          but rather a description of the  treatment  processes
          available for the various industries and the degree of
          pollutant removal various treatment processes can achieve.
          For example, the pretreatment guidelines could for each
          of the industries of interest define the treatment system
          necessary to remove 50% of the pollutants, 75% of the
          pollutants, 90% of  the pollutants, and 100% of the pollu-
          tants.  Then, based on the individual  situation at the
          publicly owned treatment works,  the necessary degree of
          treatment could be  established and effluent requirements
          be set for each industrial discharger to the treatment
          works.  This would  give the treatment plant operator the
          flexibility to develop a pretreatment program to fit its
          specific needs.  The difficulty  is that  most small  muni-
          cipalities do not have the technical capability nor the
          money to obtain the capability to develop  the pretreat-
          ment guidelines. The EPA could  develop  these guidelines
          and make them available to publicly owned  treatment
          works."

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John Saucier, Director, Tennessee, Div. of Water Quality
Control, Nashville, TN, Statement at Washington, D.C. Public
Hearing:

          "All options, with the exception of four, emphasize
     the primacy of local enforcement programs.  Based on our
     experience and observation in the State, we are opposed
     to this concept for enforcement.  For the most part, it
     is believed that these industries contributing signifi-
     cant amounts of incompatible pollutants will  have to be
     forced to pretreat, in that local agencies will not be
     able to cope with the monitoring and enforcement require-
     ments, in addition to the legal, technical type request
     for variances and exclusions...

          "I think technical assistance is needed at all
     levels, but much greater with the small municipality.   A
     number of the large municipalities have technical staff
     that are capable of doing that, although we have worked
     even with the large municipalities in our State, and
     provided them technical assistance, as well as the Region
     4 EPA has worked with them.  And so, yes, technical
     assistance is needed in developing their guidelines, the
     ordinances or whatever they control the pretreatment
     with."

Robert O'Dette, Environmental Engineer, Nashville, TN, State-
ment at Washington, D.C. Public Hearing:

          "Well, I think for most of the large municipalities,
     they are capable of doing this.  I think when it gets to
     a smaller community, like metropolitan Nashville, cer-
     tainly it is capable of handling its own system.  Smaller
     systems, like Portland, Athens (Tennessee), they may be
     able to handle some of the problems, the monitoring and
     this type of thing, but I think the guidance, the help
     with ordinance evaluation, variance requests and evalu-
     ating all the data that they could be bombarded with, is
     going to have to go through the State, and with guidance
     coming to the States from the Federal government."

Peter A.A. Berle, Commissioner, New York State Dept. of Envir-
onmental Conservation, Albany, NY:

          "Discussions with municipal representatives throughout
     the State indicate that many of the smaller local systems
     have neither the desire nor resources to cope with a pre-
     treatment program to the extent envisioned in the proposed
     regulations.  In these situations a local pretreatment
     program will not achieve its objective and will be wasteful
     in terms of financial and manpower resources.  The use of
     State/EPA personnel conversant with the program will more
     effectively utilize limited technical resources in these
     situations.  The incapability or lack of desire of small,
     local government units to implement a pretreatment program,

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                                   -14-

               however,  must be  accepted  as  real  and  should  not  be  used
               as a  reason  for denying  certain  incentives  or variances
               proposed  in  the regulations.  Aspects  of  the  program
               dealing with local  communities must  be simplified, clearly
               presented, yet be flexible enough  to allow  local  partici-
               pation where desired.  Small  communities  can  least assume
               the impact of possible industry  dislocation.   Possible
               loss  of variances,  based on an administrative decision
               triggered by the  inability to cope with a pretreatment
               program,  places a double burden  on small  communities."

          Glen H. Fuller, Washington State Dept.  of Ecology, Water
          Quality Division, Olympia, WA:

                    "We  believe  the major hurdle  to the  pretreatment
               program will be to  convince those  medium-sized cities
               with  significant  industry  to  undertake the  program.   This
               problem  should be kept uppermost in  mind  as deliberations
               continue.  In Washington,  we  have  two  cities  in the  100-
               200,000 range which we believe should  have  such a program,
               but the remaining cities are  smaller and  at most  have
               only  a  handful  of industrial  dischargers.   We believe
               that  the  majority of these smaller cities do  not  have
               the resources,  nor  capability, to  do a proper job, and
               the present  situation wherein our  state agency issues
               permits to the indirect  dischargers  is the  best solution.

                    "We  would hope a proper  mix of  incentives will  be
               available to insure that the  medium-sized cities  (100,000-
               200,000)  do  opt for the  program, whereas, at  the  same
               time, the smaller cities are  not penalized  for not doing
               the program, a role they are  not well  equipped to do."

B.    Comments Supporting Maximum State/Local Government  Involvement and
     Enforcement.

     1.    State/local governments  have  the most flexibility  and  sensitivity
          in dealing with local  problems, and are the most familiar with
          local  water quality conditions.

          Stephen M. Schwartz, Manager  of Environmental  Engineering for
          Keystone Consolidated  Industries,  Inc.:

                    "Unquestionably, the  local  agency knows  of its  own
               problems  on  a day to day basis regarding  sewer system
               problems, treatment plant  operational  difficulties,
               quality of the receiving stream, weather  consideration,
               etc...Being  in relatively  close  physical  proximity to the
               POTW, meetings and  conferences can be  scheduled with a
               minimum of inconvenience and  loss  of time.  If industry,
               discharging  to a  POTW, were to be  administered by Federal
               or even State agencies,  this  would significantly  increase
               the existing work load of  those  agencies  or require
               additional funding, or both.  Local  agencies  are  already
               equipped  to  deal  with their contributing  industries.   If
               they  are  not so equipped,  State  agencies  would still  find

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                      -15-
     it much simpler to upgrade a local  POTW's enforcement
     system, than to upgrade a myriad of industrial  discharges."

Alvin G. Keene, Superintendent of The Scarborough Sanitary
District, ME:

          "...local enforcement of those (Federal) standards
     wherever a local enforcement program is approved, backed
     up by Federal or State enforcement when necessary, but
     with a provision allowing publicly-owned sewage treatment
     plants to develop and enforce locally-derived pretreat-
     ment limits in place of the Federal standards,  in cases
     where the receiving waterway already meets in-stream
     water quality standards."

          "They feel this will provide needed Federal  involve-
     ment in standards development, but will preserve the
     local communities' role in administering rules and regu-
     lations as well as providing an opportunity for local
     standards when deemed advisable by special conditions or
     needs."

Richard Wooley of the Metal Finishing Association of Southern
California, Statement at San Francisco Public Hearing:

          "Local authorities should have the primary respon-
     sibility for ensuring compliance with local and federal
     standards,as provided in Options I through III.  Local
     authorities are most knowledgeable concerning the prob-
     lems in their areas and have the most immediate stake in
     the success of the pretreatment program.  This is consis-
     tent with the policy of the Act to preserve the primary
     responsibilities of State and local authorities to
     regulate water pollution."

Robert Ruddock, Director of Metropolitan Affairs, Great Boston
Chamber of Commerce, Statement at Boston Public Hearing:

          "But, we believe that the local control option
     provides the greatest degree of flexibility, avoid unfair
     and inequitable treatment for overly broad regulations
     and enforcement actions."

Gordon Nelson, Massachusettes Public Interest Research Group,
Statement at Boston Public Hearing:

          "Since the aim of the pretreatment standards is to
     protect the integrity of our municipal treatment faci-
     lities, it is reasonable to assume that the municipa-
     lities themselves are more intrinsically concerned with
     the enforcement of these standards.  It is the local
     municipality that has to deal with the detriment that
     water pollution causes to our local waterways.  Let's
     give them the power to control it at its source.

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                               -16-


2.   State/local  governments have established a more intimate working
     relationship with industry which allows the greatest intercommuni-
     cation in solving problems.

          Don E.  Salzman,  Office of the City Clerk,  The City of Melrose,
          MM:

                    "With  this option (Option II with part of Option III)
               you would be putting the enforcement  on a local  level.
               It is the local  people who  deal  directly with each indus-
               try on a day-to-day basis.   I feel  that the industries
               being dealt with would feel  that they have some say so in
               helping control  their waste discharges."

                    "The industries in our particular municipality have
               been very cooperative.   We  have  gone  in explained what we
               would like  to do and then worked together with them to
               achieve our goals.   It has  been  very  effective for us."

                    "The way things are now, most of the industries
               are dealt with on  a Federal  level.  They receive a letter
               stating what should be done,  but then they never see a
               Federal representative.   Some of the  time they really
               don't understand what is expected of  them.   If this
               situation would be dealt with on a local  level  they would
               have someone right there to help them and answer ques-
               tions about the requirements."

          Stephen M. Schwartz,  Manager of  Environmental  Engineering for
          Keystone Consolidated Industries,  Inc.:

                    "Unquestionably,  the local  agency knows of  its own
               problems on a day-to-day basis regarding sewer system
               problems, treatment plant operational  difficulties,
               quality of  the receiving stream,  weather consideration,
               etc...Being in a relatively close physical  proximity to
               the POTW, meetings and  conferences can be scheduled with
               a  minimum of inconvenience  and loss of time."

          Rohn and Haas Tennessee Incorporated,  Knoxville,  TN:

                    "Our greatest concern  is that many plants within
               each industry group may ultimately be required to pre-
               treat for the sake of  meeting a  nationally  developed
               effluent standard  rather than meet local  conditions
               necessary to protect publicly owned treatment  works.
               Rational  standards which balance effluent limitation with
               requirements of  the receiving facility must  be established."

                    "We cannot  stress  too  strongly that we  feel  useful
               limits  can  be determined most efficiently and  effectively
               by administration  at the local and  state level.   It  is
               virtually impossible for EPA  regional  offices  to  be
               familiar with and  properly  evaluate prevailing conditions
               at thousands of  locations across  the  country.  Establish-
               ment  of a working  relationship between  the people  actu-
               ally  involved offers the best hope  of  accomplishing  the
               desired goals in the shortest possible  time.  Local  and

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                     -17-
          "The local  ordinances developed in accordance
     with a Federally approved compliance program, would allot
     the necessary enforcement capabilities to concerned local
     officials.  Thus, there need not be any loss in effec-
     tiveness from local  enforcement, yet it holds promise of
     an increase in efficiency."

C.J. Buschkill, Manufacturing Engineer, George Koch and Sons,
Inc., Evansville, IN:

          "I would wholly support the major responsibility of
     achieving compliance by authority at the local level.
     Bureaucracy, when put to the test, can't respond to the
     flexibility required in this realm."

          "A very small plater or other business requiring
     waste water treatment might be able to survive if it were
     allowed to pay a surcharge to the local treatment faci-
     lity to correct its deficiencies.  This procedure, placed
     within the judgment of a local governing body, could
     respond to individual probabilities.  The State and
     certainly the Federal level could never be adaptable to
     the flexibility required for this possible approach."

Robert Canham, Executive Secretary, Water Pollution Control
Federation, Statement at Washington, D.C. Public Hearing:

          "A major limitation of all Federal programs in the
     water pollution control area centers around the remote-
     ness of the control  and the inherent reliance upon
     written directive from Washington.

          "To a large degree, the avoidance of local control
     relates to concern for competence and trust-worthiness
     but, regardless to what extent this concern has been
     justified in the past, local support and initiative
     remain critical  to effective water pollution control."

William H. Busch, Manager, Permit Section, Div. of Water
Pollution Control, Illinois Environmental Protection Agency,
Springfield, IL:

          "Implementation of the pretreatment control program
     must be at the publicly owned treatment works operating
     agency level.  It is unrealistic to expect the Federal or
     State NPDES Agencies to ever have adequate resources to
     directly regulate industrial dischargers into public
     sewer systems as well as manage a Direct Discharger NPDES
     Program. Federal and State NPDES Agencies are too far
     removed from local sewer system control problems to be
     able to regulate and ,work with each and every toxic and
     incompatible waste discharger into a public system."

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                      -18-
     State authorities are best able to provide this "talking"
     relationship, and Federal function should be limited to
     providing this "talking" relationship, and Federal
     function should be limited to providing backing as needed."

Marwan Sadat, Program Director, Office of Sludge Management
and Industrial Pretreatment,  New Jersey Department of Environ-
mental Protection, NJ, Statement at Boston Public Hearing:

          "Local  governments and authorities are much more
     knowledgeable of the local conditions and of the indus-
     tries which discharge into their systems.  Sewerage
     treatment plant personnel have developed lines of com-
     munication with industrial dishcargers and are aware of
     their peculiarities, characteristics and seasonal variation.

          "We feel that any pretreatment strategy must include
     the local authority.  Their exclusion would almost auto-
     matically insure the failure of an industrial pretreat-
     ment program."

Howard Verges, Vice President-Engineering, Banquet Foods
Corporation, St.  Louis, MO:

          "We believe that the standards, if there must be
     standards, should be established by the EPA and enforced
     by local authorities.  The results would be more thorough
     research, more reasonable standards, and certainly more
     consistency in the program throughout the country.   Local
     control over standards would subject industry to the
     whims and fantasies of changing administrations and the
     lack of consistency under which multi-plant industries
     could establish corporate-wide programs for treating
     wastes."

E.L. Powers, Mobay Chemical Corp., Pittsburgh, PA:

          "It has been our general experience that local agencies
     working directly with small  manufacturing or production fa-
     cilities has resulted in relatively beneficial  and  mutual
     success."

James B.  Bewley,  Superintendent-Water Quality Control, South
Bayside System Authority, San Carlos, CA:

          "...any federal program compatible with the necessary
     and  possibly ongoing local programs.  Cordial dialogue be-
     tween industry and local regulatory agencies is difficult
     to establish and must not be jeopardized by conflicting
     requirements or duplicated administrative loads.  Local
     enforcement  of federal and local requirements would lessen
     the  likelihood of disrupting progress that is now being
     made."

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                    -19-
Kenneth A. Fenner, Counsel, Masonite Corp., Chicago, IL:

          "We recommend the Agency propose a program that is
     predicated on local development of requirements to meet
     local conditions as reflected in the POTW's NPDES permit
     as the logical and most equitable way to implement a
     pretreatment program.  Such a program would allow indus-
     trial dischargers and municipal or regional authorities
     to initiate negotiation of necessary agreements now.
     These agreements must be made eventually; therefore, such
     a program should be preferable to one that holds this off
     until after extensive rulemaking is completed,

          "Secondly, we feel that a program rigorously committed
     to local initiative will be more effective than one
     directed by agencies located away from affected areas.
     The FWPCA by virtue of its delegations to local state and
     regional authorities recognizes the folly of attempting
     to treat the entire nation as a homogeneous unit.  The
     NPDES permit program and implementing regulations have
     practically demonstrated this by attempting for example,
     to impose standards totally unsuited to the various
     climates and geographic regions of the country..."

Herbert C. McKee, Ass't. Director for Pollution Control,
Health Dept., Houston, TX, Statement at Chicago Public Hearing:

          "The results of the Houston program suggest that
     local governments should have the dominant role, both in
     establishing pretreatment requirements and in implementing
     a control'-program.  Perhaps some provincialism is evident
     in'jthia statement, as well as some degree of pride in
     past accomplishments.  Nevertheless, many options were
     considered before the Houston program was initiated,
     including the option of sitting back and waiting for
     state or federal action to solve the problem.  However,
     it is difficult to imagine a federal agency with headquarters
     in Washington, D.C.  trying to understand and control a
     back yard machine shop, a local research laboratory that
     is the only one of its kind in the world, or a small
     four-man shop that repairs automobile radiators.  The
     state agency with headquarters in the state capitol is
     also far removed from these local operations. However,
     the city government contacts these people frequently to
     repair their stopped-up sewer, to stop them from burning
     trash in their back yard, to patch their streets, or to
     provide other services essential to any urban community.
     Extension of these activities to cover pretreatment and
     control of wastewater discharges into the City sewer is
     natural and logical."

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                               -20-


3.        The development of local  enforcement and administrative staff through
          training programs would facilitate the decentralization of bureaucratic
          inefficiencies and reduce implementation complexities.

          Richard A. O'Hare, Manager,  Environmental  Conservation, Shell
          Oil Company, Carson, CA:

                    "...we think the whole pretreatment program can be
               most effectively and efficiently carried out by maxi-
               mizing local control  and regulation."

                    "...with regard to local  control,  we discharge some
               five million gallons a day into the LA  County Sanitation
               District system.  And I think, you will  recognize that we,
               as dischargers or the regulated, know best the qualifi-
               cations of the regulator.

               We observed that they have an experienced competent
               technical administrative staff and are  best equipped to
               handle the control of those people who  discharge to their
               system.  If the pretreatment program fails to fully
               utilize the talent that they have by not providing for
               maximum local control and  regulation, it's certainly a
               waste of a very valuable and useful resource."

          Robert H. Brindley, Division Engineer, the Metropolitan District,
          Hartford County, CN:

                    "Very, very briefly,  the State of  Connecticut has
               accepted under the existing water quality programs the
               complete responsibility for all of this review of - all
               of this installation, overviews as well as the policing
               program once the pretreatment works have been installed
               in industry.  It has reduced considerably our efforts at
               the municipal level.   And, this is really the way we feel
               it should be operated...The State is doing all this work
               with a single large organization at much less cost than
               to try to accomplish the same program at every local
               level."

          H.A. Golle, Vice-President Operations, General Foods Cor-
          poration, White Plains, NY:

                    "As we interpret Option III, we believe it stresses
               a comprehensive local program and places the prime respon-
               sibility for pretreatment  development,  control and enforce-
               ment at the local  level.  We contend that this strategy
               would allow for protection of the publicly-owned treat-
               ment works facilities,  the receiving waterways, and be
               the most cost effective alternative for the following
               reasons:

                         It minimizes redundancies in  waste water treat-
                         ment

                         It would tend to minimize over-regulation or
                         pretreatment practices without due conside-
                         ration of cost vs. benefit.

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                          -21-
               It deals at the lowest level  with those pro-
               viding service.  Hopefully, it minimizes the
               proliferation of paperwork.

               It provides extensive local flexibility in that
               it would more effectively deal with the varia-
               bilities of publicly-owned treatment works on a
               case by case basis.

               It provides a more flexible atmosphere for
               working out treatment problems before going
               into enforcement action, and  brings control
               closer to the source.

Robert Miles, Director of Environmental Control  UniRoyal, and
Rubber Manufacturers Association, Statement  at Washington,
D.C. Public Hearing:

          "Local  enforcement also minimizes  the burden of
     paperwork.  Periodic reports would only be necessary from
     the industries significantly impacting  the operations of
     the POTW's and causing them to be in non-compliance with
     their NPDES permits."

Walter Lyons, Director, Bureau of Water Quality, State of
Pennsylvania, Statement at Washington, D.C.  Public Hearing:

          "Guidance to the municipalities, in the form of case
     history technology transfers,  seminars, training is
     really very urgently needed.  We need model ordinances.
     We need POTW capabilities, in  regards to industrial waste
     removals; some papers, of course, have  been published on
     this subject."

               It optimizes energy utilization.

          "We believe that this strategy is  most consistent
     with the intent of the Clean Water Act  Amendments of
     1972."

Glen Fitzgerald,  President, Alco Cad-Nickel  Plating Corpo-
ration, Los Angeles, CA, Statement  at San Francisco Public
Hearing:

          "As an independent small  business  corporation in
     the metal finishing industry,  I am very much concerned
     with the potential economic impact of the proposed gene-
     ral pretreatment standard.  It seems in the United States
     we are constantly proposing less regulation and bureau-
     cratic involvement with free enterprise, but at every
     opportunity the Federal government is enacting regu-
     lations to impose more layers  of bureaucratic control."

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                    -22-
          11 We do not need another layer of bureaucracy to
     create more confusion,  duplication, extraneous paperwork,
     extra costs, excessive  regulations and more government
     involvement."

E.F. Young, Jr., Director Environmental Affairs, American Iron
and Steel  Institute, Washington,  D.C.:

          "Any type of enforcement program to be truly effec-
     tive must involve the municipal  agency staff, because
     they live with the situation, the  treatment facility and
     its operation, every day.   The logical program is local
     control backed up by the State and Federal  EPA.  Such a
     system gives maximum coverage.  To accomplish this con-
     trol  with either State  of Federal  EPA directly would
     require placing staff from the State or EPA in each
     community on a full  time basis."

Frank Dryden, Head, Technical Services  Department, Sanitation
District of Los Angeles County, CA:

          "...there is obviously a concern that the EPA would
     be considered remiss if it does not oversee every step
     that a local agency takes in establishing and carrying
     out a pretreatment program.   The answer to this dilemma
     may lie in establishing a working  relationship between
     EPA and local agencies  similar to  that involved in dele-
     gation of program responsibility to a state.

          After a local agency has demonstrated that it has
     the legal and technical capability to establish and
     enforce a viable pretreatment program, the EPA should
     delegate or deputize that local  agency to administer in
     its behalf a pretreatment program  that accomplishes the
     objectives contained in PL 92-500."

Theodore Garrett, Counsel, National Association of Metal
Finishers, Statement at Washington, D.C. Public Hearing:

          "The alternative (to local  programs) is to arbi-
     trarily impose a burden on industry without knowing
     whether or not it is going to be necessary to achieve
     water quality standards, just to impose this huge cost,
     impose this huge administrative framework, to require
     treatment for its own sake,  even where it is not necessary."

Glen J. Hopkins, Deputy City Manager, Knasas City, MO:

          "Municipalities cannot escape compliance with estab-
     lished standards for their 'end of the pipe1 discharges.
     We consider consider complex Federal pretreatment standards
     an unnecessary and costly duplication of governmental
     effort when a community has the confidence and necessary
     resources to run its own program.   We would strongly urge
     a strong effort to minimize the Federal bureaucracy
     wherever possible."

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                     -23-
Ralph D. Grotelueschen, Manager-Environmental Control, Deere &
Co., Moline, IL, Statement at Chicago Public Hearing:

          "We recommend the decentralization of authority to
     municipalities.  This is really an organizational manage-
     ment approach.  And decentralization as experienced in
     operating our own personal control system with the factories
     is the only one that allows use of human resources effect-
     ively, as well as capital resources.

          "To make this effective, we believe EPA will have to
     provide leadership in training and education for the
     municipalities so they understand how to implement these
     programs as well as they are going to have to determine
     the total amount of pollution control equipment available
     in this country* or manufacturing equipment available in
     this country so that the proposed guidelines are within
     the constraints of capability to comply."

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                                    -25-
II.   ADAPTABILITY OF THE PRETREATMENT PROGRAM.
               While PL 92-500 does not specifically provide for variations
     from the promulgated pretreatment standards, it is consistent with
     the Act to include variance provisions to compensate for the extreme
     variability exhibited by POTW's in the removal  of industrial pollu-
     tants.  Variability between POTW's results from the vast number of
     indirect dischargers, the numerous combinations of municipal/
     industrial waste treatment facilities, and the differing removal
     efficiencies experienced by any given type of POTW (or even those
     within given types).
               The  issue that variance provisions should be adaptable to
     a wide variety of unique local conditions (e.g., removal capabili-
     ties, types of POTWs, ambient water quality) is complicated by
     problems resulting from such a flexible approach (e.g., documenta-
     tion and equity problems).
               Comments supportive to including variances to adapt to
     local conditions and to the problems resulting from such an approach
     are documented on the following pages:
     A.  , Comments  Supporting Adaptability of the Pretreatment Program
          1.   The  consideration of both design and incidental removal
               of pollutants by a municipal POTW will result in  the
               least duplication of pretreatment efforts and/or  pre-
               treatment facilities by both government and industry.
               Alan C. Van DeBoe, Superintendent of Sanitation,  Quincy,
               IL:
                         "Because Federal standards must be on a national
               level, certain assumptions must be made, such as  removal
               percentages for a typical secondary treatment facility.
               The  City of Quincy suggests that there are no typical
               secondary treatment plants, only many secondary treatment

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                         -26-
     systems, some with high removals of pollutants and some
     with low, but in the aggregate,  by averaging,  comprise a
     typical  secondary treatment system.  Each treatment
     system possesses an influent with a different
     ratio of domestic waste to industrial  waste.   Further-
     more, even the industrial  waste  portion is different for
     each treatment facility because  it's industrial  community
     is composed of a great variety of industries  each with
     its own  particular type of waste.  Since removal  efficien-
     cies do  vary from plant to plant, the Federal  standards
     would, undoubtedly, be based on  the lower removals and
     therefore treatment facilities with higher removal effi-
     ciencies would be adversely affected.   Since  the Federal
     government cannot develop  an individual standard for each
     facility, it would appear  again  that the municipalities
     would be in the best position to consider all  local
     conditions when developing pretreatment standards. The
     U.S. EPA recognized that there are differences in removal
     efficiencies from one plant to another and have proposed
     a variance system.  However, the variance procedure is so
     complex  that so much time, effort, and money  would be
     incurred in gaining approval of  the variance  that many
     municipalities would not pursue  this approach."

Richard R. Van Sicler, Rohm and Haas  Tennessee Inc., Knoxville,
TN:

          "Our greatest concern is that many plants within
     each industry group may ultimately be required to pretreat
     for the  sake of meeting a  nationally developed effluent
     standard rather than meet  local  conditions necessary to
     protect  publicly-owned treatment works."

Albert C,!<€lark, Manufacturing  Chemists Assoc., Washington,
D.C.:

          "Variance provisions  are must items for  any option
     adopted. Industrial contractual  relationships, POTW
     characteristics, unique capabilities,  and fundamental
     differences, as well as water quality needs,  are impor-
     tant factors which ought to be considered individually.
     Congressional intent to encourage a vital industrial-POTW
     partnership contemplated that the system's individuality
     would have a prevalent role in the actual standards set
     in each  case."

Joseph G. Zainea, City Manager, City  of Grand Rapids, MI:

          "However, uniform enforcement of standards nationwide
     within each category does not allow for variations between
     localities.  Uniformly applied standards could require
     higher levels of pretreatment than is necessary to meet
     local environmental goals, resulting in unnecessary
     monetary expenditures or hesitation by local  officials to
     allocate any additional resources."

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                             -27-
Richard J. Wooley, President, Spence Electro Plating Co.,
Metal Finishing Association of S. Calif., Burbank, CA, State-
ment at San Francisco Public Hearing:

          "The regulations should take into account
     relevant factors, such as the removal capabilities of
     well-designed POTW's achieving secondary treatment, the
     size of the POTW, and the volume of the industrial dis-
     charge.  The latter factors are variable and thus approp-
     riate subcategories will be necessary.  Since particular
     POTW's will achieve higher levels of removal, a variance
     provision is essential to assure that pretreatment require-
     ments more stringent than necessary are not imposed where
     the POTW effluent meets its NPDES permit limits."

Richard O'Hare, Manager, Environmental Conservation, Shell Oil
Co., Carson, CA, Statement at San Francisco Public Hearing:

          "First of all, the pretreatment program should
     take into account differences in removal efficiency of
     different POTW's.  However, I notice frequently mentioned
     the requirement that the POTW be fundamentally different.
     I see that term used frequently, and it concerns me that
     that would -- that that is intended to require some
     fundamental -- some fundamental difference that we think
     is important is the difference in actual removal efficiency,
     be it caused by operating conditions, the volume loading
     in the plant, the nature of the waste received, or in
     many cases the design or whatever it might be."

          "Another program -- Another problem that's
     associated with a variance or credits or however you want
     to handle allowances for differences in plant is that, as
     I think everybody's aware, many POTW's are not going to
     meet the statutory time limits or time requirements on
     achieving the secondary treatment requirements.  We
     believe that the pretreatment standards should be based
     upon an optimistic evaluation of what the POTW will
     ultimately achieve by the time it does come into com-
     pliance with the statutory requirements."

          "And it's possible to establish those.  The LA County
     Sanitation District has provided us with estimates based
     on pilot plant studies of what those removal efficiencies
     will be.  So it can be done.  To do otherwise would result
     in industry and ourselves installing facilities which, in
     a few years or so, would not be required.  I think this  is
     obviously an example of poor cost effectiveness."

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                    -28-
Frank Dryden, Head,  Technical  Services Dept.,  Sanitation
District of Los Angeles, Co.,  CA,  Statement at San Francisco
Public Hearing:

          "The proper approach may be different for different
     municipal situations.   If national standards are adopted
     for these materials, then some type of local variation
     should be allowed for to  account for these differences."

S. Norman Keston, ASARCO, Inc., NY, NY:

          "Each POTW is different  in many respects, including
     operating characteristics, from each other plant and no
     two plants have the same  mix  of wastes discharged to
     them, with the  result that the ease or difficulty of
     plant operation and the characteristics of plant wastes
     vary widely.  Consequently, it is essential  that each
     POTW operator have the maximum flexibility to determine
     the quantity and characteristics of the wastes that are
     compatible with that plant."

Gordon Nelson, Massachusetts Public Interest Research Group,
Statement at Boston  Public Hearing:

          "However 'incidental  removal1 in biological treatment
     systems must also be taken into consideration.  Redundancies
     in treatment must be avoided  to make the pretreatment
     scheme as cost-effective  as possible."

Marsha Gordon, Southeastern Regional Planning Economic Develop-
ment District, Marion, MA,  Statement at Boston Public Hearing:

          "We would  certainly  hope that you would add variances
     that would fit.  We do not believe that New England is
     uniform.  We do not believe that Massachusetts is uniform.
     We believe that water standards should play a role just
     as all the industrial  inputs  are not uniform, all material
     costs are different in New England as they are in other
     areas.  So are  energy costs.   So, we don't believe that
     growth is uniform.  We would  like the variances."

John Saucier, Director, Tennessee, Div. of Water Quality
Control, Nashville,  TN, Statement  at Washington, D.C. Public
Hearing:

          "Additionally, the unit  operations of the POTW must
     be considered.   The development of Federal  pretreatment
     standards for industrial  subcategories does not take
     either one of these aspects into proper consideration.

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                                  -29-


                    "Furthermore, regardless of what national technology
               based standards are developed and/or adopted, the unit
               operations and effluent standards at the POTW will have
               to be considered if the intent of the Act is to be upheld."

B.        Comments Noting Problems with an "Adaptable Program" Approach

          1.   Excessive documentation may be required of municipali-
               ties in justifying variances to EPA and in complying
               with monitoring-reporting procedures. As yet, the
               degree of comprehensiveness of this requisite documen-
               tation has not been addressed by EPA.

               Frank Dryden, Head, Technical Services Department, Sani-
               tation District of Los Angeles Co., Whittier, CA, Statement
               at San Francisco Public Hearing:

                         "Any option which incorporates complicated
                    review and approval procedures to obtain variances
                    for specific constituents is doomed, in my opinion,
                    to founder in an administrative quagmire."

               Art Vondrick, Water and Sewers Dept., Phoenix, AZ:

                         "Each and every needed modification of the
                    Federal requirements would have to be justified to
                    EPA.  From past experience, this justification would
                    entail the submission of voluminous and comprehensive
                    reports, and long delays in obtaining approvals."

               Carmen F. Guarino, Commissioner, Water Dept., Philadelphia,
               PA:

                         "Too much of the burden of proof for the water
                    quality aspects is solely on the municipality.
                    There would be too much pressure for the EPA to
                    simply state that the municipality did not present
                    sufficient proof and, therefore, no variance would
                    be granted.  Also, there would be too much potential
                    variation between Regions regarding what is sufficient
                    evidence for a variance. Likewise, there is too much
                    potential for suits and hearings regarding the
                    granting or the not granting of variances."

               Timothy L. Morris, Texas Water Quality Board, Austin, TX:

                         "Program requirements so onerous as to make it
                    very difficult for the local government to gain
                    program approval will defeat the purpose of the
                    entire program. We feel quite strongly that the
                    administrative requirements of the regulations must
                    be minimized.  In particular, provisions that would
                    require measurable levels of local resources to
                    report local  program activity or to justify local
                    program features to Federal reviewers ought to be

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                         -30-
               omitted.  Accordingly,  we recommend that
               to justify local  program features to Federal  re-
               viewers ought to  be omitted.   Accordingly,  we recommend
               that the following paragraphs in the proposed rules
               ought to be omitted:   403.10(B). 403.10(C), 403.11(B)
               through 403.11(N) with appropriate modifications to
               403.11(0), and  403.12."

          Seymour Lubetkin,  Chief Engineer,  Passaic Valley Sewerage
          Commissioners, Newark, NJ, Statement at Washington, D.C.
          Public Hearing:

                    "The big problem we saw  in this option (III)
               was the records,  red  tape and reports."

          John A. Tiepel, Chairman,  Environmental Services Task
          Force, Public Technology Inc., Washington, D.C.:

                    "The most  common concern expressed by the M.S.
               cities is that  the program may become unduly burdensome
               and costly due  to extensive analytical  and  reporting
               requirements.  Many cities already find themselves
               heavily burdened  by paperwork and are reluctant to
               assume more responsibilities  for federally enacted
               laws; this reasoning  was cited by the communities
               which opted for Option IV."

          Gene B. Welsh, Chief-Water Protection Branch, State of
          Georgia Dept. of Natural  Resources, Atlanta, GA:

                    "In general, the procedures required to obtain
               variances are far too complicated and time consuming
               and should be greatly simplified.  In addition, the
               requirements  proposed for municipalities to receive
               authority to  administer the pretreatment program are
               so complex and  tied up With typical EPA red tape
               that we anticipate no more than ten of the 450
               municipal authorities operating wastewater  treatment."

          Bill B. Dendy, Executive Officer,  State of California,
          Water Resources Control Board, Sacramento, CA:

                    "The volume  of paper that would be generated
               through implementation of the proposed regulations
               is staggering.  We suggest an annual summary of all
               indirect dischargers to be submitted by the POTW
               operator."


2.        Lack of "Adaptable Variance" provisions or excess documenta-
          tion to qualify for  variances^would discourage municipalities
          from implementing  local compliance programs.

          Richard 0.  Wooley,  President, Spencer Electro Plating
          Co., Metal Finishing Assoc.  of S.  Calif., Burbank,  CA,
          Statement at San Francisco Public  Hearing:

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                         -31-
          "Now, the problem that I have with variances is I
     read and reread that Federal  Register,  and I  just wonder
     with the what seems to me to be a very complicated
     variance procedure, how many variances would  be granted,
     if it might not be so time consuming and require so much
     money to go through the variance procedure that very few,
     in fact, would be applied for, and maybe even fewer
     granted, and that this might seriously affect areas
     where, in fact, a variance was warranted and  justified
     under water quality standards."

Carmen P. Guarino, Water Commissioner, Philadelphia, PA:

          "Also, there is no real  incentive for local  agencies,
     except pride and professionalism, to take responsibility
     for local programs.  75 percent of planning and start-up
     costs are not really an incentive since 25 percent of
     these expenses plus the on-going expenses would have to
     be borne by the local agencies.  In addition, applying
     and accounting for the 75 percent grant may cost almost
     as much in paper work expenses.  In fact, option I is
     really a masochist's dream - work like 'heck1 to get
     approval for a program to enforce Federal Regulations and
     then, based upon experience in other matters, receive 308
     letters at any time and have reports "rubber-stamped' as
     being incomplete."

J.F. Cormack, Supervisor - Water Programs, Crown Zellerbach
Environmental Services, Camas, WA:

          "It is essential to have the regulation  administered
     on a local basis.  The proposed regulations are complex
     and difficult to understand and I feel  that many local
     authorities will not be interested in the job if the
     rules remain in their present form.  The procedures for
     variances and for developing local standards  must be
     simplified and the EPA must be very sure to provide
     adequate assistance and guidelines for the necessary
     local standard setting.  The focus on close regulation of
     only those industries and compounds of real importance is
     encouraging and should help in simplifying the administration
     of the regulation."

Robert Canham, Executive Secretary, Water Pollution Control
Federation, Statement at Washington, D.C. Public Hearing:

          "However, owing to manpower and priority constraints,
     it is possible that the POTW may not submit such a detailed
     variance request, and I would submit that because of the
     program -- it is complicated, it is going to  be difficult,
     that you will that cities, maybe below 100,000 or 50,000
     in population are not going to be very interested and active

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                                  -32-
          in picking up this program.   And as a result of that,  the
          POTW's that are located in those municipalities could  be
          put at a disadvantage,  through no fault of their own."

     Gene B. Welsh, Chief, Water  Protection Branch,  Georgia State
     Dept.  of Natural Resources,  Atlanta,  GA:

               "We certainly prefer that the major responsibility
          for industrial  pretreatment lie with local  governments;
          however, your proposed  regulations appear  to serve as  a
          deterrent. Practically  speaking, the State of Georgia  and
          probably most other states in the country  would be faced
          with administering the  vast majority of the compliance
          programs under any of the four strategy alternatives
          proposed, since relatively few municipalities will  have
          the capability and the  desire to administer the program
          themselves."

3.   An "adaptable program" approach could cause equity problems
     by allowing certain municipalities to offer easier standards
     than others.

     Albert C. Clark, Manufacturing Chemists Assoc.,  Washington,
     DC:

               "In reviewing submittals of compliance programs by
          POTW,  care should be taken to reflect on overconservative
          limitations, e.g., heavy-handed or one sided modes of
          application of local  authority.   Some POTW may view the
          burden of this program  as resolvable only  be "getting
          rid" of industrial contributors.  That would serve neither
          Congress1 intention under section 208 of the Federal
          Water Pollution Control  Act nor the  Agency's purposes;
          ultimately it would work against inequities in compliance
          program design."

     David DiGuiseppi, Assoc. Regional  Planner, Central  Mass.
     Regional Planning Commission, Worcester,  MA:

               "Regarding the issue of local  credit  for incidental
          removal  of pollutants in secondary biological  treatment
          facilities and wabased  standards; this agency expresses
          reservation.  Non-uniform pretreatment standards will  tend
          to concentrate.industries in those areas where relaxed
          standards are available, leading to  a further degradation
          of water quality.   Varying pretreatment standards within
          an industry represents  an inequitable situation, where
          those industries will be at a financial  disadvantage if
          they discharge to a POTW with no local  credit, or where
          their receiving water's quality results in stringent
          water  quality based standards.   Further, varying stand-
          ards within an industry will  pose a  disadvantage to those
          communities where no relaxed standards can be granted.

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                     -33-
     Such communities will  suffer by being somewhat less
     attractive to wet industries, which those municipalities
     may want to attract."

Albert J. Slap,National Water Committee, Sierra Club, Statement
at Washington, D.C. Public  Hearing:

          "Water quality-based pretreatment standards is a
     good idea, if they are more stringent than the ever,
     industries will relocate on rivers and will  relocate on
     rivers and streams where water quality standards are
     weak, and in towns where public officials are compliant."

Larry E. Crane, Executive Director, Iowa Dept. of Environmental
Quality, Des Moines, IA:

          "Few Iowa municipalities have thand fiscal
     resources to develop local  standards.  Development of
     standards on a local basis would not encourage development
     of uniform state or national standards.  Municipalities
     would be put in a position of competing with each other
     to attract industry by lowering local standards.  Much
     the same problem would also occur in local enforcement
     programs.  Industry would shun those cities with tough
     enforcement and standards in favor of cities with lax
     enforcement or standards..."

Richard Woods, Counsel, Ocean County Sewerage Authority, Toms
River, N.J.:

          "While the Authority feels there will be no signi-
     ficant difference in either Options I or II, we favor the
     implementation of Option I because we believe it would be
     easier to develop technology-based standards for the
     various pollutants in  lieu of water quality standards for
     the various pollutants in lieu of water quality criteria-
     based standards; and Option II could conceivable provide
     an economic advantage for locating industries in certain
     parts of the country or states which are industrialized
     and thus where the water quality criteria could be less
     stringent than in other parts of the country or states."

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                                    -35-
m-   BASIS  FOR PREIRE&1MEM STANDARDS
               The issue of pretreatment standards  focuses  on  the  flexi-
     bility of such standards to adjust to local  conditions.   However,
     the statutory mandates of PL 92-500 did not  specify the mechanism
     to accomplish this task and as a result different types of stan-
     dards have been proposed:
                    1)  National technology-based standards,
                    2)  Standards based on water  quality considerations.
               National technology-based standards  would be determined
     by the degree of effluent reduction attainable through the appli-
     cation of the best effluent control technologies.  Water  quality
     based standards entail establishing specific numeric limits for
     pollutants that would be incorporated into a POTW's effluent  per-
     mit.
               In addition, PL 92-500 did not specify the units in which
     the national standards would be expressed.  The two proposed  approaches
     to this problem are:
                    1)  concentration-based limits,
                    2)  mass-based limits.
               Both approaches have distinct advantages and disadvan-
     tages. Concentration-based limits are easiest to enforce, but
     dilution could be a problem with some pollutants or where water
     supplies are scarce, e.g. in the drought situation presently being
     experienced in the western half of the U.S.   Mass-based limits,
     though more difficult to enforce, encourage  water conservation by
     industries.

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                               -36-
          Both of these major issues regarding pretreatment stan-
dards were addressed at the four public hearings and in the written
comment received by EPA.   Documented comments  addressing these key
issues are presented in this section.

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                                   -37-
A.   Comments Supporting Water Quality-based Standards.

     1.    Water quality-based standards provide the most flexibility to
          adapt to local conditions, and are the most cost-effective
          approach to pretreatment.

          John A. Lambie, Chief Engineer-General Manager, Ventura
          Regional County Sanitation District, CA:

               "Pretreatment standards should be nationally established
               based on water quality concentration of substances which
               are environmentally and "public health" wise safe."

          Timothy L. Morris, Texas Water Quality Board, Austin, TX:

                    "...Water quality-based standards, and by that I
               mean standards that are derived from water quality
               considerations and not just standards derived from
               existing water quality standards, provide an opportunity
               to greatly reduce the number of monitoring points, but at
               the same time to effectively regulate the pollutant
               emission to the environment."

          Charles A. Geisler, Sanitation Engineer, Department of Public
          Works, Omaha, NB:

               "The arbitrary adoption of pretreatment effluent stan-
               dards does not take into consideration  local conditions
               or water quality standards of the area."

          Alan C. Van De Boe, Superintendent of Sanitation, Quincy, IL:

                    "The City of Quincy feels that the Federal and/or
               State Environmental Protection Agencies should be con-
               cerned only with the quality of the discharge from
               municipal wastewater treatment facilities into the
               receiving stream and should not become  involved in the
               individual discharges that make up the  influent to the
               treatment plant.  After all, it is the  municipal dis-
               charge and not the individual discharges that directly
               effect the environment of the receiving stream...

                    "Any pretreatment standard based on strict numeric
               limits cannot address itself to local conditions and the
               type and quantity of flow associated with a certain
               concentration of pollutants.  As an example, if numeric
               limits are established, a particular industrial discharge
               may be in violation even if it had a very low flow rate
               and a concentration above the numeric limits."

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                            -38-
          Such industry would then be required to construct
     and install  an expensive pretreatment system to remove a
     very small quantity of pollutant simply to comply with a
     numeric limit even though the concentration prior to
     pretreatment is not detrimental  to the municipal treat-
     ment facilities.  An expensive pretreatment system would
     pose a hardship on most industrial dischargers.  There-
     fore, any standards developed should not be based on
     numeric limits, but rather on water quality."

Andrew Aiken, Environmental Engineer, Narragansett Electric
Company, Providence, RI, Statement at Boston Public Hearing:

          "Strict national  standards  would be inflexible,
     would fail to take into consideration the needs and
     capabilities of the local POTW and, in many cases, would
     result in treatment for treatment's sake."

Marwan Sadat, Program Director, Office of Sludge Management
and Industrial Pretreatment, New Jersey Department of Environ-
mental Protection, Trenton, NJ, Statement at Boston Public
Hearing:

          "These options (I and III)  would rely on the local
     authorities to determine some of the industrial pre-
     treatment standards.  This presupposes that existing
     water quality standards include  limitation on industrial
     pollutants, heavy metals and toxics.  This, in fact, is
     not the case.  Many water quality standards today have no
     limitations on these materials.   Furthermore, the develop-
     ment of water quality standards  to include such substances
     would require the solution of technical problems which
     are, as yet, unresolved.

          "In some cases, for example, the analytical tech-
     niques necessary to determine the concentration levels
     have not been fully evaluated.  We see considerable
     difficulty in the feasibility of allowing local authori-
     ties to determine their own standards."

Charles J. Henry, Director, Water Pollution Control, Metro-
politan Seattle, WA:

          "Pretreatment standards should be established on the
     basis of cost effectiveness.  Although such analyses are
     recognized in the regulations, there has been an historic
     tendency to establish treatment requirements on the
     technical basis of capability rather than needs.  Full
     consideration of energy and other resource consumption,
     water quality needs and economic impacts should be
     strongly stressed to prevent unnecessarily restrictive
     standards and treatment requirements."

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                          -39-
John Saucier, Director, Tennessee, Div. of Water Quality
Control, Nashville, TN, Statement at Washington, D.C. Public
Hearing:

          "The State of Tennessee has always considered water
     quality of the receiving stream when evaluating and/or
     establishing discharge standards, and strongly believes
     that the same basic philosophy should be followed through
     in establishing pretreatment standards.

          "It is important to note that the Tennessee Division
     of Water Quality Control believes that water quality
     standards and/or criteria are the foundation of water
     pollution control.  Without these standards and criteria,
     there is nothing upon which to aggressively control water
     pollution."

L.A. Grosmaire, Chairman, Tennessee Manufacturers Assoc.,
Nashville, TN:

          "Technology based standards are least to be pre-
     ferred over water quality based standards.  A technology
     based standard equally assigned for compliance to the
     industry categories completely ignores the needs of the
     receiving stream, the POTW and the effluent being sub-
     jected to treatment.  These standards based upon best
     available technology (BAT) require in-depth technical
     studies with supporting data, something which has not
     been without problems in the past.  Such technology would
     be subject to very rapid change (Section 307 (b) 2) as
     new developments were brought into the program providing
     no stability for practical treatment facilities."

Ward H. Nay, Vice President for Engineering, Upjohn Co., Kala-
mazoo, MI:

          "Certainly the goal of the many years of the nation's
     water pollution control efforts is to maintain the appli-
     cable water quality standards in each locality.  Thus, we
     believe that pretreatment requirements should be set only
     as necessary to maintain water quality standards.  For
     this reason, we encourage that local agencies be given
     the option of deriving and enforcing pretreatment standards
     in order to meet the limitations of their discharge per-
     mits.  EPA, or an approved state, should administer pre-
     treatment standards only when the local agency chooses
     not to do so or when the discharge permit is violated.
     Pollutants not inhibiting the operation of the treatment
     plant, or otherwise causing violation of water quality
     standards, should not be regulated by pretreatment standards
     at all."

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                                   -40-
B.    Comments Supporting  Technology-based  Standards.

     1.    Technology-based  standards  provide  an overall framework and
          guidance to municipalities  that  can best achieve the goals of
          PL 92-500.

          Gordon Nelson,  Massachusetts  Public  Interest Research Group,
          Statement at Boston  Public  Hearing:

                    "Water  quality based standards are not coherent with
               the technology  based standards of  the  direct  dischargers.
               They do not  encourage  uniform  effluent requirements for
               treatment  works discharging into different bodies of
               water.  And, most importantly, water quality  based
               standards  do not make  for maximum  progress toward the
               goal of eliminating the discharge  of pollutants into
               navigable  waters, the  basic goal of the Act."

          Wayne A. Schmidt, Staff Ecologist,  Michigan United Conser-
          vation Clubs, Lansing, MI:

                    "MUCC supports strong  waste water pretreatment
               standards.   We  do not  believe  that the public shouTd
               subsidize  removal of industrial  toxic  pollutants, such as
               heavy metals and halogenated hydrocarbons, at publicly-
               owned treatment works (POTW).   Most municipal treatment
               plants in  Michigan are not  designed to remove such toxi-
               cants and  the introduction  of  such chemicals  creates
               serious problems affecting  public  resources."

          Timothy L.  Morris, Texas Water Quality  Board, Austin, TX:

                    "It would  be our recommendation that  technology-
               based standards be developed and applied for  the ex-
               tremely hazardous pollutants about which there is limited
               technology.   These pollutants  would  include  pesticides,
               herbicides,  and the various carcinogenic pollutants."

          Richard W.  Klippel,  Chairman,  Industrial Wastes Committee,
          New York Water  Pollution Control Assoc.:'

                    "Since  many of the  incompatible pollutants are con-
               servative  in nature and  not subject to degredation  (sic)
               in the receiving waters,  the use of a  technology standard
               has some merit, from the  standpoint of protecting the
               downstream user from cumulative concentrations of incom-
               patible and/or  cumulative pollutants.

                    "The  use of a water  quality variance  would have meaning
               in such a  case  only if the water quality of the downstream
               waters were  fully evaluated to assess  the  total effect of the
               accumulation of pollutant concentrations from all  direct
               discharges as well as the non-point discharges.

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                          -41-
          "Many of the conservative pollutants such as heavy
     metals concentrate in the bottom sediments of the receiving
     waters and are not visible by direct water quality measure-
     ments.  However, they still  affect the aquatic environment.
     Other conservative pollutants such as Mirex,  PCB's, Kepone
     and Mercury are cumulative in nature and are  concentrated
     in the food chain.  Thus the effect of these  pollutants
     would not necessarily be reflected in measurement of re-
     ceiving water quality.

          "In light of these facts, it is doubtful if water quality
     can be successfully utilized as a basis to factually determine
     the level of treatment required in the immediate future.

          "It is therefore recommended that technology based.
     standards be utilized for conservative pollutants from in-
     direct discharges, and that technology variances be granted
     for municipal systems which can document removals higher than
     those assumed in the regulations.

          "However, since it is recognized that such complexities
     preclude the use of a water quality basis for establishing
     pretreatment requirements, any such regulation should a-t
     the same time, preclude a state or local authority from
     justifying levels of treatment higher than the technology
     level on the basis of water quality for a given period of
     time, i.e., 5 - 10 years, except in extreme cases where the
     state or local government can offer overwhelming justification.

          "In other words, each affected industry will design
     treatment facilities to meet the known technology standard.
     Each industry will have a stationary target to reach and
     some assurance that the target level will remain stationary
     for a fixed period of time.

          "With a known treatment requirement, accompanied by the
     assurance that the sludges and concentrates can be efficiently
     and economically disposed of, we feel that industry would be
     in a position to implement the requirement pretreatment facili-
     ties within a rather short time span.  To put it in other
     words: 'with the uncertainties removed, progress can be accel-
     erated. "'

A.B. Early, Environmental  Action, Washington, D.C.:

          "It is well known that one of the major departures of the
     1972 amendments to the FWPCA from the previous law was to es-
     tablish technology based standards instead of water quality
     based standards, except where the latter were found to be more
     stringent.  The .Congress found that the data needed to estab-
     lish water quality standards and to establish the relationship

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                          -42-
     between such standards and individual discharges was too
     complex to provide a predictable means of water pollution
     control.  It would be wholly inconsistent for the Congress
     to have established a technology based system of control
     for direct dischargers under section 301  and 304, and auth-
     orize a water quality based system of control for indirect
     dischargers under Section 307(b)."

Peter A.A. Berle, Commissioner, New York State Dept. of Environ-
mental Conservation, Albany, NY:

          "The State of New York favors a State/EPA technology
     based program with strong positive (non-punitive) incentives
     and permissive mechanisms allowing capable local governmental
     units to assume administration of a pretreatment program.

          "The State of New York concurs with the proposed method-
     ology for the development of national standards.  The national
     standards must maintain environmental equity through applica-
     tion of appropriate pretreatment technology (APT).  APT should
     maintain a minimum overall (industry & POTW) treatment removal
     equivalent to the BPCTCA limitations of an individual industry
     discharge, and in the case of toxic substances, approaches or
     is equivalent to BATEA.  During the development of APT, con-
     sideration should be given for regional  and size categorization.
     Significant impacts due to the implementation of the standards
     may be masked by technical and economic assessments averaged
     on a national scale."

Louis J. Breimhurst, Director-Div. of Water Quality, Minnesota
Pollution Control  Agency, Roseville, MN:

          "Pretreatment standards based on water quality may not
     sufficiently take into consideration inhibitory/interference
     effects of a pollutant on the operation of a POTW.  The con-
     ditions of granting a water quality variance did not address
     this major concern.

          "Water quality standards are difficult to develop and more
     difficult to enforce."

Glen H.  Fuller, Washington State Dept. of Ecology, Water Quality
Div., Olympia,  WA:

          "The most important thrust of option two is that it pro-
     vides for variances to allow cities to enforce limits on in-
     direct dischargers based on the sewage treatment plant's ability
     to  meet the receiving water quality standards rather than
     technology based effluent standards.   We  recommend against
     this  approach.   If it were to be used, we foreseee long  delays,
     as  studies are undertaken to ascertain whether water quality
     standards  are indeed violated for the many toxic pollutants.
     The extremely low concentrations in question  could  very  likely
     result in  uncertain conclusions."

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                                   -43-

          J.  Taylor Banks,  et.al.,  Natural  Resources Defense Council,
          Inc.,  Washington, D.C.:

                    "The Settlement Agreement specifically provides  that
               the pretreatment standards shall  be technology based...
               FWPCA does not authorize municipalities to  grant  water
               quality based variances from national pretreatment standards
               as proposed. ..Sections 307(b)  and (c) require that indirect
               dischargers meet uniform standards designed to prevent
               the discharge into  POTWs of incompatible pollutants.   In
               compatibility must  be determined  with reference to design
               assumptions regarding POTW removal  capability and interference
               or upset considerations, and cannot be dependent  upon
               receiving water quality in individual stream segments...

                    "Congress chose to require the development and imple-
               mentation of effluent limitations and standards (including
               national pretreatment standards)  independent of the water
               quality based restrictions contained in Section 303 of
               the FWPCA precisely because it had been demonstrated
               during years of experience prior  to 1972 that dependence
               upon a water quality approach would not achieve the
               needed water cleanup.  The immense practical  problems
               associated with relating effluent levels to receiving
               water quality dictated that a technology-forcing  approach
               be taken.  Long periods of costly and detailed infor-
               mation gathering and analysis, including development and
               implementation of water body modelling data, are  necessary
               for effective application of a water quality program."

2.   Uniform Technology-based standards would provide equity between
     municipalities.

          Joint Municipal Authority of Wyomissing Valley,  West Reading,
          PA:

                    "Uniform standards equally applied are imperative.
               Otherwise, industries will be subjected to  stringent
               regulations in one  vicinity, while their competition may
               be generating large profits due to their being located  in
               a vicinity where enforcement is lax.  If enforcement is
               not uniform, industries could be  driven out of business
               or forced to immigrate to areas of lax enforcement."

          Carmen F. Guarino, Commissioner, Water Department, Philadelphia,
          PA:

                    "...Strict standards regardless of sludge disposal
               and effluent discharge needs...provide a degree of uni-
               formity regarding competitive economics within industrial
               grouping."

          Eugene Booth, President,  John Inglis Frozen Food, Modesto, CA:

                    "It seems to me that it is most important in the
               food business that  we have uniform standards throughout
               the country on waste pretreatment since the industry is
               extremely competitive and it would be unfair for any one
               segment to gain advantage over another segment by this
               means."

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                                    -44-
C.   Comments Supporting the use of mass-based  limits .for  the  expression
     of pretreatment standards.

          Albert C.  Clark,  Manufacturing  Chemists Association, Washington,
          D.C.:

                    "Influent loadings be based on mass flow,  not concen^
               tration;  natural  dilution  from infiltration,  surface
               washings, etc.,  should  be  recognized as fnitigating
               against shocks possible from 'slug1  flow's."

          Charles J. Henry, Director,  Water Pollution Control, Metro-
          politan Seattle,  WA:

                    "Primarily,  emphasis  on use of a concentration
               standard  with a  secondary  emphasis on mass  limits is not
               the most  ideal  approach in control  of hazardous materials
               discharge.   While the single numeric standard is easier
               to enforce,  it does not recognize that, in  many instances,
               the water quality or sludge quality may be  better, more
               cost effectively protected with  a mass limitation sup-
               ported by a  more liberal concentration standard."

          Marwan Sadat,  Program Director, Office of Sludge Management
          and Industrial Pretreatment, New Jersey Department of Environ-
          mental Protection, Trenton,  NJ, statement at Boston  Public
          Hearing:

                    "We  would further  suggest that Option  I  as modified
               should impose not only  numericals of concentration
               limitation  but should also provide equivalent mass units
               which would  be determined  by the local  authorities during
               the development  of industrial  pretreatment  programs and
               would be  subject to approval  by  EPA and State regulatory
               agencies. This  is necessary to  control  unregulated
               expansion of pretreatment  facilities in those cases where
               the surface  water quality  is critical."

          James  McQuean, Regional  Manager,  National  Council  of the Paper
          Industry for Air  and  Stream  Improvement,  Medford,  MA, state-
          ment at Boston Public  Hearing:

                    "I'd like to make  this one  single comment  that
               industry  is  used  to dealing  in mass units.  And, muni-
              cipal  treatment  systems are used to dealing in  concen-
              tration,  of  materials and  their  influents or  effluents.

                    "In  general,  when, at some  point,  when limits are
              set for one  reason or another whether it be pretreatment
              of final  effluent,  they sit down and decide how much  flow
              each  has, all  right,  and what concentration might result
              to make it easy  for the analysts to  determine how many

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                         -45-
     milligrams per liter or whatever it is in the final
     effluent and he can make his test and everything  is
     satisfactory.  And, everything is fine for a very short
     period of time.  Because,  what happens after that con-
     centration is agreed upon, something changes, a year or
     two down the road.  The flow changes in the plant.   The
     amount of materials coming from one side of town  in-
     creases.  The amount of materials coming from the other
     side of town stays the same.  And, we're left with the
     same concentration type limits if that's all  there is in
     the standards.  So, I would implore the agency to con-
     sider both mass and concentration.  If there are  certain
     things that make it easy for the analysts, fine,  but I
     would like to have recourse on those to go back to the
     mass basis."

John Saucier, Director, Tennessee, Div. of Water Quality
Control, Nashville, TN, Statement at Washington, D.C.  Public
Hearing:

          "The mass basis on the other hand is certainly
     compatible with the philosophy of water conservation.   If
     the development documents  concept is continued then  the
     question boils down to one of concentration versus mass
     limits."

Richard O'Hare, Manager, Environmental Conservation, Shell  Oil
Company, Carson, CA, statement  at San Francisco Public Hearing:

          "I think fundamentally we believe that mass  limi-
     tations are the more desirable and more fundamentally
     correct, provided they take into account the variables
     involved in the quantities generated in the process  that
     generates pollutants, and  also they take into account the
     factors involved in the treatment involved.

          "We certainly recognize, however, that there are
     some enforcement problems  and control problems involved
     with the mass emission concept, and we would suggest that
     the local  agency be permitted to use a concentration
     limitation which is ultimately derived from some  basic
     mass limitation and that that be adaptable, then, to
     changes, should there be methods of saving water  that
     might result in concentration increases."

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                          -46-
John D. Thomas, Chief of Industrial  Wastes, Orange County
Sanitation District, Fountain Valley, CA, Statement at San
Francisco Public Hearing:

          "I have a few other comments.   The districts have
     been into a source control  program since July of 1976.
     In that program, we are using mass emission rates.  My
     understanding, it's probably one of the few agencies in
     the country that are doing  that.  At this point in time,
     I'm very pleased with the results we are seeing on that,
     especially right now with the drought the way it is.

          "For instance, we have a couple of companies that
     had had -- Well, we have had one company that discharged
     about 30,000 gallons a day prior to our program.  They
     are down to 3,000 gallons a day.  Granted, their con-
     centrations are roughly tenfold what they were prior to
     the program, but they are meeting our mass emission rates
     for that particular facility."

Glen Fitzgerald, President, Alco Cad-Nickel Plating Corporation,
Los Angeles, CA, statement at San Francisco Public Hearing:

          "I think it's also true, that eventually this concen-
     tration basis will have to  be interpolated in a mass
     emission factor because as we go into installing treat-
     ment facilities, water reduction is a primary requisite.

          "And, of course, with the concentration, the minute
     we start to reduce our water, our concentration levels go
     up...from a strictly enforcement standpoint...concen-
     tration basis...has to be the tool  or the measuring
     device that they (POTW's) go by. But it will have to be
     interpreted or derived from a mass emission standard."

Gilbert W. Bassett, Exec.  Director, Environmental Conservation
Board of the Graphic Communications Industries, Inc., Pittsburgh,
PA:

          "We further suggest that, whatever standards are de-
     veloped of  discharges into municipal systems, they should
     be stated in terms of quantities, rather than concentrations,
     in order to encourage conservation of water and' to reduce
     the flow to the publicly-owned treatment works, thereby
     minimizing the need for costly expansion of the treatment
     plant.  Concentration limits tend to be unduly restrictive
     insofar as they do not recognize fully the large amount of
     dilution which occurs within the municipal sewer system nor
     the ability of the municipal system to assimilate without
     difficulty small volume discharges of relatively highly
     concentrated pollutants."

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                          -47-
T.C. Payne, Vice President-Environmental Quality, International
Paper Co., Mobile, AL:

          "We understand that the Agency intends to express
     pretreatment limits primarily in terms of concentration,
     although mass limits also may be provided where possible.
     We recognize that concentration limits are preferred
     because they facilitate compliance monitoring and enforcement.
     In our view, however, both concentration and mass limits
     should be provided in every case as alternative limitations.
     We believe the industrial facility should be allowed an
     opportunity to choose between compliance with concentration
     or mass limits, as long as the POTW and the facility
     agree.

          "To fail to provide for mass limits discourages
     efforts to conserve water use.  Water conservation programs
     are encouraged by the use of mass limitations (or reference
     to base water consumption to pro-rate the allowed concentration
     upward as water conservation programs reduce volume)."

H. Neal Troy, Manager-Environmental Control, Owens-Illinois,
Toledo, OH:

          "Pretreatment limits expressed solely in concentration
     limits, although facilitating compliance monitoring an
     enforcement do not encourage water conservation, which
     should be an important consideration to any water program.
     Concentration limits, along with mass limits or some
     other mechanism to prorate allowed concentrations upwards
     as water usage decreases, should be incorporated into the
     standards to encourage water conservation programs.  Such
     programs not only save water but extend the POTW's capacities,
     and useful life, thereby, ultimately saving public funds."

Ralph D. Grotelueschen, Manager-Environmental Control, Deere
Co., Moline, IL:
          "Establish mass discharge requirements as the basic unit
     of control whenever possible rather than concentration
     units. Three advantages that will acrrue from this concept
     are:

     a.   Less water will be used by industry thereby conserving
          water and raw materials.

     b.   We usually find this to be in the interest of energy
          conservation.

     c.   This definitely will encourage the development of
          inherently less polluting manufacturing processes."

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                          -48-
Glover, R.C., Manager-Waste Water and Solid Waste, Proctor &
Gamble Co., Cincinnati, OH:

          "In general, for simplicity in enforcement, there
     has been a strong tendency to write effluent limits in
     terms of concentration rather than mass.  This is unfortunate
     because it is the total  amount of pollutants, not their
     concentration in a stream of otherwise pure water, which
     is important.  Concentration limits encourage wasteful
     use of water and discourage proactive programs to reduce
     water uses. Many POTW's which are otherwise adequate, are
     hydraulically overloaded.  The flow reductions which are
     discouraged by concentration limits could save the taxpayers
     of this country a great deal of money.  Even more important
     is the fact that water supplies rapidly are becoming the
     critical determinant of the economic strength and growth
     potential for major geographic areas, such as the West
     Coast.  It is critical that the agency not foster regulations
     which discourage the conservation of our critical water
     resources."
Thomas J. Dufficy, National  Assoc.  of Photographic Manufacturer's,
Inc., Harrison, NY:

          "NAPM realizes that limits based on concentration
     are easy to monitor.  However, as more and more industries
     adopt water conservation measures, numeric concentration
     limits will progressively become more difficult to meet.
     Average daily effluent concentrations will increase
     although the pollutant loading (Ib/day) remains constant.
     One easy way to calculate such a daily loading (Ib/day)
     is to multiply the concentration of a composite sample
     (mg/1) by the daily flow (gal/day) and a conversion
     factor."

Allen R. Frisckorn, Jr., Counsel, G & E Service Corp., Washington,
DC:

          " A number of areas of the United States are currently
     experiencing droughts and other water shortages.   In this
     regard EPA should note that plants which must conserve
     water might encounter problems in meeting concentration
     derived discharge limits.  EPA should take this fact into
     account to ensure that such plants are not unfairly
     penalized for circumstances beyond their control."

K.S. Watson, Director of Environmental Control, Kraft, Inc.,
Glenview, IL:

          "We agree that EPA should issue detailed guidance (not
     specifications)  for the use of the states and local  communi-
     ties in implementing their programs.   Such guidance  should

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                         -49-
     address both water quality based and technology based stand-
     ards.   We agree that mass limits and concentrations should
     both be specified but mass limits should have the higher
     priority.  This is consistent with EPA's work to date on
     guidelines for stream discharge.

          "Today, with the need for sound water usage assuming  a
     position of greater importance, the adopting of mass limits
     supports this thesis.  Concentration limits, on the other  hand,
     do not thrust toward the need to soundly manage the use of
     water.

          "The use of concentration limits only for each type of
     production operation will cause difficult and costly sampling
     and analyses problems for complex multiproduct plants.   On
     the other hand, mass limits would require the use of only  a
     single sampling station on the combined  discharge of the
     total  production facility."

W.J. Coppoc, Vice President-Environmental Protection, Texaco Inc.,
Beacon, NY:

          "Technology standards must be developed on a mass  discharge
     basis to provide equity with an industry to account for water
     reuse and effluent reduction practices.   Concentration  limits
     (derived from mass standards and actual  flow) should contain
     provisions to allow adjustment for future effluent flow re-
     duction.  Artificial dilution to meet concentration limits
     is well recognized to be prohibited."

J. Taylor Banks, et.al., Natural Resources Defense Council,  Inc.,
Washington, DC:

          "Finally, EPA recognizes that ue of "concentration limi-
     tations" could cause "dilution" problems.  42 Fed. Reg. 6481.
     Unfortunately, recognition is all that EPA's proposed options
     will do about this problem.  EPA offers  two reasons in sup-
     port of its reliance on concentration limits.  The first is
     ease of enforcement.  It makes no sense  to adopt weak stand-
     ards than can be easily enforced when the result will be
     substantially diminished water quality.   Moreover, because
     the water quality benefits of the pretreatment program would
     be reduced by use of effluent limits expressed as concnetrations
     of pollutants, EPA has established a basis for reducing its
     enforcement effort, thereby subverting the explicit reason
     that EPA offered in support of relying on concentration
     limits.  The second reason EPA offers ...is the  'agency's
     desire to implement the pretreatment program as quickly as
     possible.'  Again, it makes no sense to  develop a pretreatment
     program quickly if program quality must  be sacrificed in the
     process....

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                                    -50-
                    "It is critical  that  total mass  limitation  be  placed
               on incompatible  pollutants.   Such  pollutants are not only
               toxic to aquatic life in significant  concentrations-, but
               often are bioaccumulative  and persistent.  Thus, while
               discharges of small concentrations may avoid acute  toxicity
               problems, the total mass of  pollutants may build up in
               stream sediments over time and lead to sever health and
               other environmental problems.   We  recommend that mass
               limits be established, and that local authorities be
               required to enforce such standards."


D.   Comments Supporting the use of  concentration-based  limits  for the
     expression of pretreatment.standards.

          Jack Barren,  Department of Public Works, City  of San  Francisco,
          CA, Statement at San  Francisco  Public Hearing:

                    "So concentration is  far better  for  us on an enforce-
               ment problem with industry.   Mass  emission is very, very
               difficult to monitor."

          Newton A. Brokaw, Executive Director, Columbus Industrial Assoc.,
          Columbus, OH:

                    "We reccomend that POTWs be allowed  to establish uniform
               concentration limitations  as local pretreatment  standards
               across industry  categories,  recognizing that eventual impact
               upon reciving waters  if the  prime  cdncen  of a POTW  and that
               a pollutant will  have the  -same impact on  a POTW  and its re-
               ceiving  water regardless of  source of origin."

          John A.  Lambie,  Chief Engineer-General  Manager, Ventura
          Regional  County Sanitation District, CA:

               "The Pretreatment Standards  should be issued on  a con-
               centration  limit basis rather than a  mass emission  limit.
               The problem of increased water usage  by industry for
               dilution  of concentrated wastes must  be dealt with  on a
               local  basis rather than through a  federal limit.  Water
               consumption surcharges and local ordinances against the
               use of water for dilution  are more easily administered
               and effective than trying  to federally modify a  Pre-
               treatment limit  to serve water conservation purposes.
               The Pretreatment limits are  more easily monitored and
               enforced  on a concentration  limit.  The mass emission
               limit  would require tht all  discharges being monitored
               have accurate flow measurements as well as concentration
               analysis.   To attempt to enforce through  litigation or
               other  legal  means a limit  based on two less than accurate
               technologies would only serve to compound the problem."

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                           -51-
James B. Bewley, Superintendent-Water Quality Control,  South
Bayside System Authority, San Carlos, CA:

          "The problem of "how" to enforce standards also deserve
     some discussion.  It is generally agreed that mass emission
     rates, rather than concentration, would provide the most
     equitable standards within a particular industrial  category.
     That is, if: a) accurate production data is quickly available,
     b) accurate daily flow data is available, c) a direct corre-
     lation between production and pollutant loading has been
     established, and d) a quick, relatively straightforward means-
     of computing this information is available.  It'has been
     found working with individual industries, especially electro-
     platers, that none of the above are normally available.  The
     only workable method for routine enforcement of discharge
     standards is the use of concentration based standards.   It
     is essential that the time from collecting a sample to
     reporting the compliance or non-compliance be kept as short
     as possible.  If mass emission standards via production
     rates were used, weeks and possibly months could pass before
     the status of compliance were known."

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                                   -53-
IV.   THE EXTENT OF INDUSTRY AND POLLUTANT COVERAGE.
               The EPA is presently in the initial  phases of implementation
     of a new regulatory strategy in fulfillment of the requirements of
     a Consent Decree signed in June, 1976, by the  Agency, Natural
     Resources Defense Council  (NRDC), Environmental  Defense Fund (EOF),
     and Citizens for a Better Environment.  The Consent Decree among
     other requirements stipulates the promulgation of pretreatment
     standards controlling for 65 toxic pollutants  as discharged by 21
     major industrial categories.
               The proposed pretreatment regulations focus on these 65
     toxic pollutants and 21 industries and vary in their degree of
     coverage for each category.  Several approaches call for broad
     coverage of industry and pollutants.  In two approaches (Options I
     and II) technology-based standards would be established for these
     21 Industries focusing on the 65 toxic pollutants.  Another approach
     (Option IV) would cover 34 to 39 industries and ore than 65 toxic
     pollutants.  Under yet another approach (Option III) coverage would
     be narrower, limiting itself to only 13 industries and less than
     the 65 toxic pollutants.
               Preferences for these two categories of coverage - broad
     versus limited - have been expressed at public hearings and in
     written comment submitted to EPA.  In addition, participants have
     expressed other viewpoints and raised other issues which would
     influence the extent, form, and degree of industry and pollutant
     coverage to be incorporated into the final pretreatment regulations
     selected for implementation.
               Six issues  (factors) have been identified that directly
     relate to expressed viewpoints on industry and pollutant coverage:
               A)   The demand for broad industry and pollutant coverage;
               B)   The demand for limited industry and pollutant coverage;

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                               -54-
         C)   Compliance with the requirements of the Consent Decree;

         D)   The form of coverage: uniform/fixed numerical standards

              versus Federally-derived guidelines used on a case-by-

              case  basis;

         E)   Technical feasibility of industry achieving standards; and,

         F)   The categorization of pollutants and  industries for

              regulatory purposes.

         Analysis of comments relating to  industry  and pollutant

coverage revealed its inextricable  relationship with other pretreatment

issues - i.e., degree of Federal  involvement,  type of  standards, vari-

ances, duplication,  et.c -  examined  in different sections of this

evaluation.   Consequently,  discussion of  those issues  indirectly

touch upon  industry  and pollutant coverage.   In turn,  viewpoints

expressed in this section will,  indirectly,  have an  influence  on

the other pretreatment  issues.   However,  every effort  was undertaken

to make a distinction between the issues,  so that  the  documented

comments on the following  pages  could avoid needless redundancy and

focus on the direct  issue of pollutant and industry  coverage.

A.   Comments Supporting Broad Coverage

     1.   Broad coverage would best protect the public health  and
          the environment,  and is consistent with  the  objectives
          of the Act.

          Gordon Nelson, Massachusetts  Public Interest Research  Group:

               "National technology based standards  must be formulated
               for all  of the sixty-five toxic pollutants noted  in the
               proposals.   It would not be in accordance with the goals
               of the Act if the national standards  covered only the
               most hazardous pollutants, as is suggested in Option
               III.   Leaving all other incompatible  pollutants to be
               controlled by local  authorities invites unwanted  non-
               uniformity in the standard setting process."

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                                  -55-
          Jean Anderson, Chairman, Environmental  Quality Committee,  League
          of Women Voters of the U.S., Washington,  DC:

                    "The League opposes limiting  federal  standards to only
               the most hazardous pollutants from the most significant
               dischargers for a number of reasons, not the least of which
               is that such a procedure would disobey the mandate of Section
               307(b).  That section directs the  Agency to promulgate pre-
               treatment standards "to prevent the  discharge of any  pollutant
               through treatment works..., which  pollutant interferes with,
               passes through or otherwise is incompatible with such works."

          Marwan M. Sadat, Program Director, Office of Sludge Management
          and Industrial Pretreatment Division of Water Resources, New
          Jersey Department of Environmental Protection,  Trenton, NJ:

                    "We recommend that Option 1 (modified) expand the
               list of the 21 industries which will be covered by
               pretreatment standards.  An important omission, which we
               feel should be corrected is the development of pretreatment
               standards for major medical centers, biological labor-
               atories and research institutes involved in research  with
               carcinogens, viruses and toxic pollutants.  The need  to
               regulate this kind of discharge is obvious. The release
               of dangerous pathogenic organisms  and cancer-causing
               substances used in experimental research not only poses
               danger to the human life but may result in the deposition
               of carcinogens in bottom sediments."

2.        In order to provide adequate health and environmental pro-
          tection a uniform regulatory program with broad authority is
          necessary.

          Edward Larrabee, Superintendent, Wastewater Treatment Facilities,
          Sanger, California:

                    "I feel that this option (option III) is no good.
               In my opinion a standard of quality  pretreatment should
               be maintained throughout the state and/or nation."

          Joseph G. Zainea, City Manager, City of Grand Rapids, Michigan:

                    "All wastewater pretreatment  needs are not covered
               by this Option, as standards for only the more hazardous
               pollutants are involved.  Leaving  the development and
               enforcement of standards for non-included pollutants  to
               local authorities poses two primary  problems.  First,
               many local authorities do not have the experience or
               expertise available to enable them to be aware of all
               pollutants which should be controlled.  Secondly, locali-
               ties may be reluctant to allocate  resources necessary to
               control pollutants for which there is no specific mandate
               by law.  In short, this Option provides only partial
               coverage of pollutants and would not enhance consistency
               of impact of standards upon localities across the nation."

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                          -56-
Dr. Gaytha A. Langlois, Co-Chairperson, Clean Water Committee,
Ecology Action for Rhode Island:

          "In Option III, it is noted that less than 21
     industrial and less than 65 toxic pollutants would  be
     covered.  This would also appear to be inadequate in
     meeting federal guidelines, based on the definition of
     the 65 toxic pollutants.  Furthermore, permitting local
     authorities to amend national  standards would seem  to be
     unnecessarily lenient and would encourage evasion of the
     standards ... since industry discharges into POTW's are
     numerous and highly variable,, it is important to establish
     pretreatment regulations for as many industries as  possible.
     The small size of a given industrial units should not
     solely determine the impact of its toxic substances --
     the significance of an industry to the national  economy
     cannot always be correlated with its impact on the  environment,
     e.g., the electroplating industry."

Bill B. Dendy, Executive Officer, California State Water Resources
Control Board, Sacramento, CA:

          "If...EPA is only going tu establish pretreatment standards
     for a limited number of industries, instead of covering the
     entire spectrum, we strenously object.  Such a procedure may
     be cost effective from the standpoint of EPA's budget, but
     to transfer responsibility for developing.the balance of the
     needed technology based standards to the states or  to local
     agencies is not cost effective from the standpoint  of overall
     expenditure of tax dollars.  Further, we cannot understand
     why the electroplating industry is even being considered for
     less attention than others on  the list of 21.  Were we to
     prioritize the list, the electroplating industry would be
     close to the top of the list as needing regulation."

Howard J. Naftzger, Kensington, CA:

          "All of the materials in  the list of 65 are undesirable
     in the environment.  (As EPA's Mr. Beck said at the San Fran-
     cisco hearings, "You wouldn't  want any of them on your corn-
     flakes.")  Where reasonable cost-effective technology exists
     to substantially remove and isolate these materials, I
     believe it should be used.  Once removed from the waste
     stream, many of these pollutants can be either recovered
     and recycled or destroyed.  For those hazardous substances
     which must be disposed of as such, I think it .is generally
     preferable that they be in concentrated form to minimize
     volume."

Robert C. Niles, Director-Environmental Control, UniRoyal,
Middlebury, CN:

          "We subscribe to the principle that "prohibited dis-
     charge" standards similar to Section 128.131  should be es-
     tablished.  The 65 toxic pollutants contained in the NRDC/
     EOF consent degree also need to be controlled by national
     standards, regardless of source.  Mechanisms need to be

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                                    -57-


               incorporated in the regulations that allow for additions
               to the toxic list as substances are proven to significantly
               be hazardous under prescribed concentrations and circum-
               stances."

          Stanley Dohmus, Deputy Assistant Secretary of the Interior,
          Washington, DC:

                    "Option IV would best serve fish and wildlife resource
               protection."

          T.H. Goodgame, American Institute of Chemical  Engineers,
          Benton Harbor, MI:

                    "...the discharge of toxic substances into the
               environment,must be controlled.  But, both regulations  and
               legislation must take into account the fact that the mere
               removal of a toxic substance from the water does not
               protect the environment, for the substance may be discharged
               into the air, or onto the land.  The overall control of
               toxic substances should minimize the effect on the total
               environment, not merely that in one medium.  Regulations
               for the control of toxic substances should be based upon
               a systems approach.  Quite simply, if the required level
               of control of a toxic substance causes other more damaging
               substances to be emitted into the environment, then the
               level of control must be adjusted to minimize the overall
               environmental effects, or to maximize environmental
               quality.  And, this should consider toxic conditions,
               aesthetic qualities, economic effects and energy intensiveness."

B.    Comments Supporting Limited Coverage

     1.    National numerical standards are appropriate for only
          the more toxic and hazardous pollutants.  The remaining
          pollutants are better controlled at the local  level where
          the local water quality situation and the individual removal
          capabilities of the POTW can be taken into consideration.

          Jon S. Legallet, Legallet Tanning Company, San Francisco, CA:

                    "We have reviewed the alternate strategy options for
               pretreatment standards and believe option III is the
               best.  This position is based on our belief that if the
               most serious pollutants are controlled Federally, sufficient
               and better regulation of the remaining pollutants can be
               developed and enforced by the State Municipalities."

                    "It is most important for the Federal regulation to
               cover only the most serious pollutants and leave the
               balance of regulations to the determination of local and
               state authorities."

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                    -58-
Timothy L. Morris, Texas Water Quality Board, Austin, TX:

          "It would be our recommendation that technology-
     based standards be developed and applied for the
     extremely hazardous pollutants about which there is
     limited technology.  These pollutants would include
     pesticides, herbicides, and the various carcinogenic
     pollutants.  On the other hand, water quality-based
     standards would be appropriate for pollutants that
     are subject to wet-chemistry techniques that are
     readily available in most of the affected publicly-
     owned treatment works'  laboratories such as chromium,
     zinc, lead, and phenols."

Francis W. Kutchta, Director, Department of Public Works,
Baltimore, MD:

          "We therefore request the EPA to adopt the AMSA
     Pretreatment Policy as  the National  Standard and
     that the record show that it is the official stand
     of the City of Baltimore made at the public hearing
     April 21, 1977 in Washington, D.C.

          "AMSA Policy:  EPA shall issue nationally
     uniform, technology-based standards for only the
     most hazardous and toxic pollutants of all  those
     regulated under a national  pretreatment program."

David R.  Small, Executive Vice President, H. Swoboda and
Son, Division of Trans-Continental Leathers, Inc., Phila-
delphia,  PA:

          "It is our strongly held position and that of
      many others, both in our own and other industries
     with whom this has been discussed, that, of the four
     suggested possibilities, only Option III should be
     considered.  The need for standards to control  dis-
     charge of selected, highly toxic, pollutants is ob-
     vious.

          "Beyond that need, what the Federal Government
     should regulate is the  effluent of the POTW's.
     Based on their long experience and technical competence,
     the  local  POTW organizations know best what their
     facilities can and cannot accept from their discharging
     customers, to allow their facilities to meet treat-
     ment standards.   It should be left for those POTW's
     with their intricate knowledge of local conditions
     and  the  capacities of their systems to impose safe
     and  practical  standards and charges on their customers.
     Interposition of the Federal  Regulatory presence
     between  these two principals is wrong and unnecessary
     interference, certainly beyond the intent of the
     original  legislation."

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                    -59-
J.F. Cormack, Supervisor, Water Programs Environmental
Service, Crown Zellerbach, Camas, WA:

          "Option III is the most preferable option since
     it seeks to regulate most stringently those compounds
     and sources that are most likely to cause problems.
     While this option is the most preferred one, there
     are certain problems.  It is essential  to have the
     regulation administered on a local  basis.  The pro-
     posed regulations are complex and difficult to un-
     derstand and I feel that many local authorities will
     not be interested in the job if the rules remain in
     their present form.  The procedures for variances
     and for developing local standards must be simpli-
     fied and the EPA must be very sure to provide adequate
     assistance and guidelines for the necessary local
     standard setting.  The focus on close regulation of
     only those industries and compounds of real importance
     is encouraging and should help in simplifying the
     administration of the regulation."

W.G. Turney, Bureau Chief, Michigan Department of Natural
Resources," Lansing, MI:

          "The concept of local program development with
     good guidance is consistent with both historic approaches
     and the present climate of implementability.  Strict
     control of hazardous materials is the area for
     strongest current emphasis and Option III offers the
     best blend of these approaches."

Peter D. Hughes, Wastewater Treatment Facilities Commission,
Fitchburg, MA:

          "Of the four proposals, only one seems to have
any practicality to it.  That scheme involves the establish-
ment by federal authorities of maximum limits for only
the very few most toxic substances to biological treatment
or human life.  All other substances would be controlled
by local authorities based on local treatment system
conditions and capabilities.  This would give the necessary
backing to a municipality concerning the potentially most
toxic substances and allow the municipality to determine
the impact of other materials on their treatment facility,
while considering other impacts including economic.  With
this approach, problem discharges could be addressed as
they occur without an immediate large commitment of
manpower looking at every potential problem prior to
state or federal acceptance of a given municipality's
program."

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                     -60-
Larry G. Lawson, Virginia State Water Control  Board:

          "...technology-based standards should only be
     promulgated for toxic and hazardous materials and
     should be universally applicable.

          "We believe that the national  pretreatment
     standards for the most toxic and hazardous pollu-
     tants should be promulgated with uniform concentra-
     tions, regardless of the industrial category.

          "In addition to these numeric  limits, the stand-
     ards should also identify the types of industries
     which these are associated and are  expected to origin-
     ate."

Bruce S. Crutcher, Greater Cincinnati Chamber of Commerce,
OH:

          "Given the variety of treatment processes and the
     different plant configurations in existence, the
     associated variation in efficiencies and treatability,
     and the varying characteristics of  receiving streams,
     both qualitative and quantitative,  the promulgation
     of national uniform numeric pretreatment standards
     is deemed inadvisable except for the more significant
     dischargers of more toxic pollutants.  In other
     words, national standards should be provided only
     for the most environmentally significant toxic
     pollutants and for the major sources of those pollutants.
     For these "most important" -toxics,  federal or state
     control over variances from a national standard is
     appropriate where requests for variance has been
     initiated and justified by a community or its industries.
     All other pretreatment regulations  should remain
     within the province of local regulation.  National
     control of non-toxic pollutants can best be achieved
     by the inclusion of effluent limitations in NPDES
     permits. Next best is to al'low local regulations to
     prevail so long as receiving water  quality standards
     are met."

Mr. Rice, Association of Metropolitan Sewerage Agencies,
Dallas, TX:

          "The coverage of pollutants.  EPA issue nationally
     uniform technology-based standards  for only the most
     hazardous and most toxic pollutants of all those
     regulated under the program	Coverage of industries.
     EPA issue guidance, under section 304(f) of the
     Public Law 92-500, regarding the industrial  categories
     most closely related to potential discharge of each
     pollutant that is covered by technology-based standards."

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                          -61-
     Seymour A. Lubetkin, Chief Engineer, Passaic Valley
     Sewerage Commissioners, Newark, NO:

               "EPA would issue regulations and standards on
          the most toxic and hazardous materials, such as
          kepone, etc., where even the smallest trace amount
          of the item is detrimental to our ecology and cannot
          be tolerated. It would be EPA's judgment as to what
          materials and industries effected would be included
          in this list. Of course, if an individual  industry
          disagreed with a particular material, it has its
          remedies through the appeal process.   These would be
          controlled by EPA directly."

     Robert Niles, Director of Environmental  Control, Uniroyal,
     representing the Rubber Manufacturers Association, Statement
     at Washington, D.C. Public Hearing:

               "...federal technology-based standards for
          only the most toxic pollutants, less than 65 pollutants,
          should be promulgated for all dischargers...incompatible
          pollutants for a POTW should be very carefully
          weighed before promulgation of a national  standard."

     Theodore Garrett, Counsel, National  Association of Metal
     Finishers:

               "The pretreatment standards, themselves, should
          be no more stringent than the 1977 BPT standards,
          should regulate only the most significant sources of
          toxic pollutants, and should be based principally on
          the municipal treatment and removal  capabilities and
          the inhibition-interference considerations in the
          statute."

2.   Limited coverage would be more cost-effective and treatment-
     effective avoiding the situation of treatment-for-treatment's
     sake which would occur in many cases in a broad coverage program.

     Earle F. Young, Jr., Director, Environmental Affairs
     American Iron and Steel Institute, Washington, D.C.:

               "Because of the wide range of treatment provided
          by municipalities and the resultant variation in the
          impact industrial discharges have on treatment
          works, ranging from little or no effect of incompatible
          or toxic pollutants in large plants to significant
          effects in small plants, to set numeric limits to
          cover such a broad range of needed treatment would
          result in many cases in needless treatment and
          increased energy use to protect for the most critical
          situation.  The best program would be one that
          protects the environment with the least number of
          pollutants having absolute or numeric limits.
          Option III provides this type of control."

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                          -62-
Milton E. Abraham, Chairman,  Niagara Falls Industrial  Liaison
Committee for the City of Niagara Falls Wastewater Treatment
Plant, NY:

          "We suggest a minimum EPA effort (as in Option III)
     in development of numerical  pretreatment limitations with
     a concentrated effort in guidance and approval  of sound
     local programs.

          "...we strongly oppose such a strategy (Option IV).
     Such an approach would be extremely inefficient,  cost
     ineffective (even if EPA resources were available), and
     would discourage industrial  use of POTW's under the
     regionalization concept.  We see no need for this level
     of federal  involvement in pretreatment regulations."

H.J. Campbell, Jr., Engineering Service Division, E.I. DuPont
De Nemours and Company, Wilmington, Delaware:

          "We believe that the taxpayers'  money can be more
     wisely spent through incentive programs for development
    , of technically adequate local  pretreatment programs.  We
     suggest a minimum EPA effort.(as in Option III) in develop-
     ment of numerical pretreatment limitations with a concentrated
     effort in guidance and approval of sound local  programs."

Raymond Kudukis, President, Cleveland Regional Sewer District,
Board of Trustees, Cleveland, OH, Statement at Washington, D.C.
Public Hearing:

          "To end up with a virtually endless list of toxics only
     ensures that virtually none will be controlled because of
     the endless litigation and extensive manpower requirements.
     This would be unfortunate, since some extremely toxic
     materials could go virtually unregulated in this process.

          "We propose that EPA draft national.pretreatment
     source standards for only the most hazardous and toxic
     pollutants.  For the remaining pollutants, US-EPA should
     draft technology-based standards, structured around the
     POTW and its effluent.  For these materials, credit
     should be given for dilution and removal in the POTW as
     defined in Public Law 92-500."

A.P. Kowalik, Manager, Union Oil  Company of California, Los
Angeles, CA:

          "We also believe it is appropriate that Federal
      pretreatment standards should be established for only
     the most significant contributors of hazardous or toxic
     pollutants as described in Option III of the proposed
     rules.  Developing Federal pretreatment standards for all
     of the 21 industries and all of the 65 toxic pollutants
     seems to be an unreasonable burden."

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                                    -63-
          W.  James Wells, Bell, Galyardt and Wells, Inc., Omaha,  NB:

                    "Minimizing the total  number of industrial  plants
               regulated will  minimize the amount of surveillance,  samp-
               ling and testing as well as the amount of paperwork  required
               by the local authorities, NPDES States and EPA.   Concur-
               rently, this will serve to focus attention on the major
               potential sources of hazardous pollutants.  Similarly, re-
               gulating only the most hazardous pollutants focuses  attention
               on the most significant sources of pollution while reducing
               the time and expense required to monitor and control  pollu-
               tants of lesser significance."

     3.   Limited coverage is more appropriate at this early stage  of
          the pretreatment program's development.

          John G. Costello, Executive Director,.Bergen County Sewer
          Authority, NJ, Statement at Boston Public Hearing:

                    "Furthermore, we feel  the focus of federal  efforts
               under Option III on the regulation of the most hazardous
               and toxic pollutants and the more significant sources
               would be the appropriate direction toward the maximization
               of environmental gains at this, early stage of the program
               and would establish a firm foundation upon which to  build
               a strong, highly respected national pretreatment program."

          W.A. White, Vice President National Agricultural Chemical  Assoc.,
          Washington, D.C.:

                    "As to the number of industries to be covered over the
               three-year period proposed:  It is always goood to have a
               goal, but to make it a fixed objective within a limited period
               of time can be foolhardy when the resources are limited and
               the full extent of the endeavor is unkown, which seems to
               be the case here.  EPA has faced fixed objectives in the
               past under similar circumstances and some of the results
               have not been satisfactory.  We support the Option III goal
               of 10-13 industries in three years as an objective suggest-
               ing that time and resources be taken as needed to complete
               each project in a good manner, recognizing that the  goal
               may not be reached or, optimistically, may even be exceeded.
               We hope that EPA will not require more than it can accomplish
               in a good manner with the available resources."

C.        Comments on the issue of strict compliance with the terms
          of the Consent Decree.

     1.   The EPA need not be overly concerned with complying with
          the terms of the Consent Decree.

          Albert C. Clark, Vice President and Technical Director, Manu-
          facturing Chemists Association, Washington, O.C.:-

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                          -64-
          "We also believe EPA. should not be overly preoccupied
     with the Natural  Resources Defense Council,  Inc.  settlement
     agreement of June 6, 1976 in promulgating these standards.
     The current list of 123 toxic pollutants (65 pollutant
     families) is not sacred; certain copounds may be added
     appropriately, while others may be deleted.   The goal  of
     the Agency must be to work toward the goals  of the Act
     without unreasonable risk to health and with equity
     toward POTW and their manifold users."

S. Norman Kesten, Assistant to the Vice President, Environ-
mental Affairs, ASARCO Incorporated, New York, NY:

          "...Consequently, it is essential that  each POTW
     operator have the maximum flexibility to determine the
     quantity and characteristics of the wastes that are
     compatible with that plant.  It is recognized, of course,
     that guidelines for some pollutants from some industries
     are mandatory under a court-ordered agreement between EPA
     and certain plaintiffs but the court order need not be
     permitted to interfere with the necessary flexibility."

Raymond Kudukis, President, Cleveland Regional Sewer District,
Board of Trustees:

          "We recognize that statutory revisions  may be required
     and that some of our proposals may be counter to the
     NRDC/EDF consent decree.  While we know that those who
     brought this action against EPA had every worthwhile
     intent, the impracticality of what is proposed could bog
     the entire program down in a complex web of  further law-
     suits, requiring many years to resolves."

John Saucier, Director, Div. of Water Quality Control, Nashville,
TN, Statement at Washington, D.C. Public Hearing:

          "The time, money and expenditure of resources required
      regardless of which option is selected, make it imperative
     that other alternatives be evaluated.- This  will  require
     amending the consent decrees that exist today with EPA.
     Nevertheless, the State of Tennessee is of the opinion
     that this could be done."

B.H. Bruba'ker, Special Assistant to the Director  of Safety and
Environmental Engineering, Diamond Shamrock, Cleveland, OH:

          "...Diamond Shamrock Corporation supports the concept
     of requiring pretreatment of; (1) highly toxic pollutants
     that pass through a POTW, after secondary treatment opera-
     tions are functional at such POTW's and (2)  those wastes
     demonstrably interfering with the operation  of the POTW
     and traceable to industrial sources.  We realize that such

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                                  -6b-
              an approach will,  iri all  liklihood,  require modification
              of the consent agreement.   To this end,  we refer you  to
              the letter of May 26, 1976 by Judge Thomas A.  Flannery
              (expressly filed with the  opinion in NRDC'v. Train,  supra)
              indicating that such motions to modify may be  entertained.
              In order for our position  to prevail,  Diamond  Shamrock
              Corporation supports such  a position as  the most reasonable
              and equitable solution of  the issue."

         P.M.  Charles, Corporate Director-Environmental  Affairs,  Union
         Carbide Corp., New York, NY:

                   "The regulation scope and schedule  established  in the
              NRDC/EDF consent decree'accepted by the  Agency are  too
              ambitious to be consistent with early implementation.  All
              parties to the agreement should reassess their priorities
              in light of the practical  level of effort available  to
              carry out the project, and the accomplishments that  would
              best serve the needs of the nation."

         Eugene L. Kilik, President, Tanner's Council  of America,  Inc.,
         New York, NY:

                   "Finally, the consent decree in Natural Resources
              Defense Council, Inc. v.  Train, 8 ERC 2120 (D.D.C.1976)
              does not preclude the adoption of Option III.   EPA  cannot
              bargain away its duty to implement the Federal  Water  Pol-
              lution Control Act in accordance with the intent of  Congress.
              A bargain struck with a few interest groups cannot  override
              the Agency's duty to the public."

         Thomas E. Roberts, Supervisor of Environmental  Control,  Celanese
         Polymer Specialties Co., Louisville, KY:

                   !!Jl^DC_J^on^ejit_J)ecree_   It is entirely satisfactory
              that EPA should have to modify the NRDC/EDF Consent Decree
              in order to implement Option III.  Neither the States, the
              POTW's, nor industry had any input to the formulation of
              that consent agreement and it thus ignored many of  our
              concerns.  In fact, the chemical industry was  specifically
              denied the right to intervene in that decree."

2.        Coverage must be consistent with that stipulated in the
         Consent Decree.

         Wayne A. Schmidt, Staff•Ecologist, Michigan United  Conser-
         vation Clubs, Lansing,  MI:

                   "We reject Option III out-of-hand as inconsistent
              with the NRDC/EDF Consent  decree."

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                                   -66-
         Meyer Scolnick, Director-Enforcement Div., USEPA Region II,
         New York NY:

                    "Option  II is also unacceptable and may be unlawful.
              First of all, this option  is inconsistent with the Section
              307(b) mandate which requires the promulgation of national
              standards for the introduction of incompatible pollutants
              into  a municipal facility.  Secondly, the NRDC, EOF
              Consent Decree requires that national standards be established
              for 65 pollutants and 21 industries.  Therefore, Option
              III is not even a legally  practical alternative until the
              Court Order  is modified."

         J. Taylor  Banks,  et.al., Natural Resources Defense Council,
         Washington, D.C.:

                    "Pollutant coverage under Option III would call for
              federal standards applicable only to known hazardous
              pollutants,  and local standards.  Sections 307(b) and (c)
              as well as the Settlement  Agreement contain no authority
              for limiting  national pretreatment standards in this
              manner.  Pretreatment standards must be developed for all
              pollutants that interfere  with, pass through, or otherwise
              are incompatible with publicly owned treatment works...

                    "The coverage of point sources under Option III is,
              as noted by  EPA in the preamble, flatly inconsistent with
              th6 Settlement Agreement.  The criteria proposed by EPA
              for exclusion of industrial pollutant sources under
              Option  III bear no resemblance to the criteria which
              under the Settlement Agreement EPA has agreed to utilize.
              Use of  these criteria would result in a substantially
              smaller pretreatment program than is required by the
              Agreement  (e.g. 13 rather


D.        Comments supporting the development of Federal guidelines
         rather  than  standards.

         William A. Healy,  P.E., Executive Director, Water Supply and
         Pollution  Control  Commission, Concord, New NH:

                    "The  proposed regulations would seem to be more
              appropriate  to large communities which are more likely to
              have  the resources necessary to  implement the type of
              pretreatment program contemplated by EPA.  Once again,
              this  is clearly an attempt to apply national standards in
              an area which has numerous variables and would more
              properly be  dealt with on  a case-by-case basis within the
              broad framework of generalizedstate guidelines."

         Walter  A.  Lyon, Director, Bureau of Water Quality Management,
         Pennsylvania Department of Environmental Resources, Harrisburg,
         PA:

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                         -67-
          "There needs to be some guidance for municipalities
     to allow them to establish pretreatment limits on a case
     by case basis.  This guidance would not be in terms of a
     nationwide industrial  standard of pretreatment but rather
     a description of the treatment processes available for
     the various industries and the degree .of pollutant removal
     various treatment processes can achieve.  Then, based on
     the individual situation at the publicly owned treatment
     works, the necessary degree of treatment could be established
     and effluent requirements be set for each industrial
     discharger to the treatment works.   This would give the
     treatment plant operator the flexibility to develop a
     pretreatment program to .fit its specific needs."

Albert C. Clark, Vice President and Technical Director,
Manufacturing Chemists Association, Washington, D.C.:

          "Tailoring meaningful standards to individual POTW
     should be the Agency's prime concern.  Too many assumptions
     or generalizations in the standard setting process will
     defeat an otherwise nobl«e endeavor.  We urge EPA to apply
     seasoned judgement in establishing criteria in an effort
     to make the program optimum with regard to both treatment
     effectiveness and cost effectiveness. Section 304(f)
     guidelines can best serve as a basis for judgement rather
     than rigid-number limitations."

J.F. Lagnese, Duncan, Lagnese and Associates, Inc., Pittsburgh,
PA:

          "...specific pretreatment standards by EPA would not
     be required.  Certainly, it would be appropriate and
     probably necessary to satisfy the statutory requirements
     on pretreatment, that EPA would develop general standards
     to protect the POTW from damage or interference of the
     industrial discharge.   I believe these could be universal
     type standards applicable to all industries.  The detail
     implementation of regulations for this type of control
     and protection would remain the responsibility of each
     POTW subject to EPA review and approval similar to the
     procedure now used for user charge compliance, etc."

W.P- Anderson, Assistant Director, Environmental, and Regulatory
Affairs, Tenneco Chemicals, Saddle Brook, NJ:

          "We believe the POTW operators should be allowed the
     broadest possible freedom to establish pretreatment
     regulations for their systems.  These must take into
     account their specific NPDES permit limits and the
     capacity and capability of their own particular systems.

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          "Federal  Guidelines based  on  reasonably  available
     technology will  undoubtedly be  useful  to  the  POTW.   These
     guidelines,  however,  must not be allowed  to evolve  into
     rigid "not to  exceed" limits as did  the effluent  guidelines
     under the NPDES  program.  These national  guidelines must
     be drawn with  due consideration to the very great differences
     in size, characteristics, treatment  capability and  discharge
     requirements of  the various POTWS.  For example,  some of
     our plants discharge into systems  with daily  flows  in the
     hundreds of millions of gallons which  in  turn discharge
     directly into  the open ocean.   On  the  other extreme, one
     plant discharges into a small system,  which treats  between
     one and 1.5 million gallons per day  and discharges  into  a
     stream which is  used for drinking  water supplies."

Bill  B. Dendy, Executive Officer, California State Water
Control Board, Sacramento, CA:

          "We suggest, as another alternative,  a pretreatment
     program that is  workable and relatively simple while
     expending resources only on the areas  of  greatest need.
     The heart of this program consists of  placing discharge
     limitations on the individual municipalities  to ensure
     adequate control on the discharge  of toxic substances.
     The municipality would be required to  institute those
     controls necessary to prevent any  plant upset or  effluent
     discharge in violation of their discharge permit.  To
     assist the municipality in accomplishing  this task, under
     Section 304(f),  the Agency could publish  true guidelines
     illustrating available pretreatment  technology and  performance
     for various industrial categories  and  could outline the
     procedural aspects of an adequate  pretreatment program."

Paul  C. Hittle, General Supervisor of Environmental  Activities,
Consumers Power Co.,  Jackson, MI:

          "The Company, however, does not favor unguided local
     establishment  of pretreatment standards for nonhazardous
     pollutants. The Company believes  that many municipalities
     would not have the available resources to establish such
     standards based  on meaningful criteria and that the
     unguided setting of standards by municipal agencies could
     produce widely differing and inconsistent standards
     throughout a state. Moreover, the  task of establishing
     meaningful criteria upon which  to  base such pretreatment
     standards might  well  discourage many local agencies from
     actively participating in the pretreatment program.  The
     Company, therefore, recommends  that  EPA or NPDES issuing
     states provide flexible guidelines for municipal  agencies
     to follow in establishing pretreatment standards for
     nonhazardous pollutants."

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                                    -69-
          J.L.  Rodgers,  Jr.,  Division Manager,  Amer.  Water Works Service
          Co.,  Inc.,  East Dedham, MA:

                    "We also  feel that Option III will  permit both the EPA
               and state agencies to provide general  guidelines to be used
               by local  agencies in developing  proper programs for pretreat-
               ment and enforcement of these.  Also,  EPA and state agencies
               will be able to act as recommending agencies performing re-
               search for practical application in the  field.  Further,
               Option III will permit the quickest regulation of the most
               hazardous pollutants which are known to  adversely affect
               aquatic environments, fish and/or drinking water."

          T.H.  Goodgame, American Institute of  Chemical  Engineers, Benton
          Harbor, MI:

                    "It is also strongly recommended that 'the national
               requirements be put forth in the form of guidance rather
               than standards.  By this means,  the agency with the local
               authority and  responsibility for determination of limitations
               has the flexibility required of  the local situation - that is,
               overriding local conditions can  be fully taken into consid-
               eration, whether they are based  upon technology, stream limi-
               tations or economics."

E.         Comments supporting the position that the degree to which
          an industry is regulated must take into consideration the
          standard's technical attainability.

          H.J.  Campbell, Jr., Engineering Service Division, •£.I. DuPont
          DeNemours and Company, Wilmington, DE:

                    "As with  effluent guidelines for direct dischargers,
               any pretreatment guidelines should be based upon tech-
               nology applicable to each given  industrial  category
               rather than transfer technology.  Furthermore, guideline
               levels should  also reflect reliable, long-term performance
               of technology that can be consistently attained by full-
               scale field equipment on a day-to-day basis.  All too
               often transfer technology and short-term technology per-
               formance have  been misused and relied upon in past guide-
               line promulgation attempts.  As  we all  have experienced,
               such inadequate technical bases  have led to, and, if used
               in the future, will continue to  lead to  needless and in-
               effective legal recourses."

          J.F.  Cormack, Supervisor, Water Programs, Environmental Services,
          Crown Zellerbach, Camas, WA:

                    "The eventual establishment of a uniform limit for
               all categories for a given pollutant will be troublesome.
               It would presumably be on a concentration basis.  This
               will inevitably result in discouraging desirable water
               conservation programs.  Also, great care must be taken to
               ensure that the limits are technically achievable by all
               affected industries."

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                          -70-
Pj?J™rnts jjJjpporting the position that regulated pollutants
and industries should be categorized.

Marwan M. Sada-t, New Jersey Office of Sludge'Management and
Industrial Pretreatment, Department of Environmental Protection,
Trenton, NJ, Statement at Boston Public Hearing:

          "Recognizing the economic impact of industrial pre-
     .treatment standards on small  industries,  we would sup-
     port, after-the implementation of water quality standards
     and careful consideration, future levels of concentration
     less stringent than the APT standards for the small
     dischargers.   It is apparent that MCI's (Major Contributing
     Industries) benefit from-the economy of scale resulting
     from the construction of large pretreatment facilities.
     In setting the APT standards, we feel that EPA should
     assign different levels of concentration  for varying size
     pretreatment facilities.  Large installations would have
     to meet more stringent requirements.   Small discharge APT
     standards would impose higher concentration limits."

W.C. Trefz, Chief Engineer, Allegheny County Sanitary Authority,
Pittsburgh, PA:

          "The 65 toxic pollutants should  be categorized into
     groups to establish priorities with :emphasis on removing
     at an early date those most objectionable and for which
     proper techniques have been developed."

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                                    -71-
V.   SLUDGE DISPOSAL AND TREATMENT CONSIDERATIONS




               The type and quantity of industrial  discharges and the degree



     to which industrial pretreatment is practiced  will  directly influence



     the characteristics of a POTW's sludge.  Where industrial  pretreat-



     ment is not practiced, toxic pollutants will be absorbed into and contam-



     inate the POTW's sludge.  The presence of these pollutants limits the



     sludge disposal alternatives - as composting and land spreading  -



     available to the POTW and thus increases the cost of adequate sludge



     disposal.  Consideration of this issue is incorporated into the  four



     options in that the toxic contamination of municipal  sludges and the



     ability of pretreatment standards to reduce contamination  is a factor



     in the promulgation of national standards.



               Under all four options, the granting of a variance or  modi-



     fication is contingent upon a showing by the POTW of adequate sludge



     disposal and/or utilization capabilities.  Case-by-case modifications



     could result in further sludge contamination problems and, hence, ad-



     ditional constraints or. feasible disposal alternatives.  Therefore,



     variances are conditional  on the availability  of environmentally-sound



     disposal methods.  In addition, it becomes readily discernible that the



     primary responsibility for the management of these toxic sludges will



     be placed on either the POTW or the industrial generator depending on:



     (1) the extent and degree of stringency of pretreatment standards; and,



     (2) the provision of variances.



               Another aspect to this issue is the  recently enacted Resource



     Conservation and Recovery Act.  Under Subpart  C of this Act, standards



     for the management of hazardous and toxic wastes will be established



     with enforcement authority through a permit system.

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                                -72-
          After a review of opinions expressed  at public hearings

and in written comment,  four issues have been identified that have

a direct bearing on the  question of sludge disposal  and treatment:

          A.    Whether sludge disposal  considerations are rightfully

a part of a pretreatment program or should be dealt  with under the

Resource Conservation and Recovery Act?

          B.    Responsibility for the management of  toxic sludges.

          C.    The demand for broad industry and pollutant coverage

to avoid sludge contamination problems.

          D.    The impact of case-by-case modifications on a  POTW's

sludge.

A.        Sludge disposal considerations should be addressed  by the
          Resource Conservation and Recovery Act of'1976 instead of
          being made a condition for variance approval.

          Albert C. Clark, Manufacturing Chemists Association,
          Washington, D.C.:

                    "It  is recognized that pass-through may affect
               the characteristics of the sludge and thus limit the
               disposal  options for it.  Because sludge disposal is
               addressed in the Resource Conservation and Recovery
               Act and because of the multi-media aspects of sludge
               disposal, we urge that regulatory considerations
               under 40CFR403 be concentrated on the quality and
               quantity of the influent to the POTW.   If that is
               done in the context of the POTW design and operating
               characteristics, the sludge problem should be simplified."

          Richard J. Wooley, President, Spence Electro Plating
          Company, Metal Finishers of Southern California, Burbank,
          CA:

                    "This variance should in no way  be conditioned
               upon tihe  adequacy of the POTW sludge  disposal  methods.
               EPA has no authority for such requirements under
               Section 307(b) of the Act.  Such matters can be
               dealt with as appropriate under other programs, such
               as the Resource Conservation and Recovery Act of
               1976."

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                          -73-
Bruce S. Crutcher, Greater Cincinnati Chamber of Commerce,
Cincinatti, OH:

          "Questions related to sludge disposal  methods should
     be severed from those related to pretreatment regulations,
     even those applicable to toxic substances.   The Agency
     has authority under the Resource Conservation and Recovery
     Act of 1976 (PL 94-580) to insure proper sludge disposal
     and, as the Agency itself stated, the choice of a sludge
     disposal method should be a local decision  based upon the
     alternatives available in that specific area."

E.E. Ross, Manager, Water Pollution Control  Department, East
Bay Municipal Utility District, Oakland, CA:

          "While we believe that there may be definable relationships
     between direct industrial discharger quality and municipal
     sewage sludge quality, the extent to which  sludge quality
     can be controlled by the application of pretreatment to
     conform with yet to be developed hazardous  waste disposal
     guidelines or regulations pursuant to the Resource Con-
     servation Recovery Act of 1976(PL 94-590) will depend
     upon local conditions.

          "Compliance with PL 94-580 provisions  may or may not
     be consistent with measures required to achieve the
     objectives stated in the first paragraph of this section.
     Therefore, we feel that the inclusion of sludge disposal
     considerations in the pretreatment program  objectives for
     PL 92-500 is not appropriate at this time."

Theodore Garrett, Counsel, National Association  of Metal Fin-
ishers, Washington, D.C.:

          "The pretreatment regulations should provide for a
     relaxation of the federal standards where the municipal
     treatment works achieve treatment levels better than
     those assumed by EPA in developing the standards.  This
     variance should in now way be conditioned upon the adequacy
     of the municipality's sludge disposal methods, as to
     which Section 307(b) of the Act provides EPA with no
     authority, and which is better handled under other statutes,
     such as RCRA."

Elaine Fielding, Legal Dept., Clark Oil Refining Corp., Blue
Island, IL:

          "Second, sludge disposal concerns are not properly  the
     concern of pretreatment standards.  To the extent that in-
     dustrial discharges can, as asserted,  'contribute signifi-
     cantly to sludge disposal problems of POTWs"   (Information
     For Proposed General Pretreatment Regulations, at p.2),  no

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                          -74-
     good reasons are adduced for adopting pretreatment stand-
     ards that would merely pass the problem back to the dis-
     charger.  The environmental problem would be the same.
     Moreover, incorporating sludge disposal considerations
     into the pretreatment program is an extra-legal and
     unauthorized assertion of authority by EPA.   Nowhere does
     the Act warrant such an assumption of authority by EPA.
     No one would deny that proper waste disposal is a serious
     national issue.  However, it deserves to be  treated in  an
     integrated fashion under the Resource Recovery and
     Conservation Act, not in the fragmented, back-door approach
     contemplated by the proposed regulations. We recommend
     that all references to sludge disposal  be deleted from
     the regulations.

Guy Weismantel, Western Editor Chemical  Engineering, Los
Angeles, CA:

          "Also, prior to making rulings on joing treatment,
     EPA should get its own house in order.   The  present legis-
     lation is public law 94-580, the Resource Conservation
     and Recovery Act, October 21, 1976.  Under subtitle C
     there is a section on hazardous wastes—and  this section
     on hazardous wastes—and this section would  naturally
     effect any joint treatment legislation.  Under 94-580
     Jack Lehman and his group have to define what is a hazardous
     waste. This will be done, with input from those who are
     interested, and it will  probably be about an 18 month
     process.  I do not honestly know how you can set guidelines
     on joint treatment until these definitions have been
     presented and published."

Peter A.A. Berle, Commissioner, New York State Dept. of Environ-
mental  Conservation, Albany,  NY:

          "...large metropolitan sewer districts  also have the
     most severe problem of adequate disposal of  large volumes
     of contaminated municipal sludge.  Many reasonable methods
     of sludge disposal  such as incineration or land disposal
     are precluded because of resultant air or groundwater
     pollution. In the immediate future, and until  a pretreatment
     program becomes effective, extremely difficult decisions
     regarding adequate disposal of sludge will be facing us.
     It is for this reason that contingencies in  the proposed
     regulations that relate to satisfying The Resource Conservation
     and Recovery Act (PL 94-580) may be inconsistent with the
     least environmentally adverse means of sludge disposal.
     Therefore, these contingencies must be flexible and allow
     significant State input and modification."

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                                    -75-
B.        The primary responsibility for the management of toxic sludges
          should be with the POTW rather than numerous individual in-
          dustrial plants.

          Andrew Aiken, Narragansett Electric Company, Providence, Rhode
          RI, Statement at Boston Public Hearing:

                    "There are also the issues of treatment system
               operation and sludge disposal to contend with.  A single
               POTW, where it can adequately treat industrial wastewater,
               can be more effectively monitored and controlled by the
               appropriate agencies than can a series of pretreatment
               systems owned and operated by individual industries.
               Also, each pretreatment system will produce a solid waste
               product, much of which will  be deemed a hazardous waste
               material under the Resource  Conservation and Recovery Act
               of 1976.  Such material will be difficult to dispose of
               and the temptation for illicit disposal may be compel-
               ling. With a single POTW and a limited number of pretreatment
               plants, the sludge disposal  problem can be better controlled
               by solid waste management authorities."

          Timothy L. Morris, Texas Water Quality Board, Austin, TX:

                    "You are proposing to go from that to a situation
               where you not only have the  12,000 publicly-owned treatment
               words with their concomitant sludge disposal problems,
               but also 55,000 industries with pretreatment facilities
               and comcomitant sludge disposal problems.  With the
               advent of such an increase in the number of sludge sources,
               you will begin to encounter  every violative sludge disposal
               technique imaginable.  The regulatory resources of the
               Federal, State, and local governments will be exceeded
               accordingly.  We feel quite  strongly that in order to
               minimize the sludge disposal problem the sludge disposal
               capabilities of the publicly-owned treatment works ought
               to be optimized."

          Joint Comment of the Buffalo Sewer Authority and the Buffalo
          Area Advisory Council on Industrial Wastewater, Buffalo, NY:

                    "In support of our proposal, we feel that these
               recommendations have the best potential for improving the
               environment without excessive unnecessary economic  impact
               on industrial users.  A POTW with the responsibility  for
               meeting water quality-related effluent  limit guidelines
               for its own discharge, together with the responsibilities
               for the protection of the  biolgoical, mechanical  and
               hydraulic  integrity of the plant, and for the environ-
               mentally safe disposal of  its sludge,  is ideally  qualified
               to establish pretreatment  standards to  control the  character
               of its  influent."

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                         -76-
W.R. Johnson, Director-Plant Environment, General  Motors Corp.,
Warren, MI:

          "The law of conservation of mass dictates that very
     stringent pretreatment standards for preserving or upgrad-
     ing the POTW's sludge quality would exchange the POTW's
     sludge disposal  problem for an industrial  sludge disposal
     problem.  In either case,  environmentally acceptable dis-
     posal problem.  In either  case, environmentally acceptable
     disposal methods must be used.  However,  the decision on
     where this burden should lie should clearly be left to
     the individual POTWs and not indirectly made for them by
     the U.S. EPA through the adoption of unnecessarily strin-
     gent national pretreatment standards.

John F- Hall, National  Forest Products Assoc.,  Washington, D.C.:

          "Stringent  pretreatment requirements will in turn
     create large accumulations of sludge; POTW's are more
     experienced and  are in a superior position technologically
     to handle large  amounts of sludge.  Numeric limits incor-
     porated into municipal permits for incompatible pollutants
     should be considered when  technology-based, standards are
     being developed."

Kenneth A. Fenner, Counsel •, Masonite Corp., Chicago,. I.L:

          "An additional problem that arises under the preterat-
     ment scheme is that the number of locations at which sludges
     will be generated will expand enormously.   The Agency's
     responsibility to police disposal will be multiplied tre-
     mendously, and perhaps far beyond the Agency's capabilities.
     The POTW on the  other hand, as a central  gathering point,
     will minimize the number of locations.  Furthermore, the
     POTW will  generally have a greater and more sophisticated
     sludge handling  and disposal capability.   These capabilities
     can be further augmented by the Agency's  construction
     grants program and enforced by standard provisions found
     in Part B of all NPDES permits.  The expenses, of course,
     can be passed on to the sources through the user charge
     system."

C.R. Calkins, Vice-President-Environmental Affairs, American Paper
Institute, Washington,  D.C.:

          "Sludge disposal considerations in setting pretreatment
     standards may force industrial facilities to handle a variety
     of sludges in many separate locations.  We submit that, in
     many cases, it may be better to have a municipality deal
     with sludge disposal rather than each individual  industrial
     facility.   This  would be a particularly burdensome respon-
     sibility for small plants  with limited technical  staff

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                                    -77-

               and/or land area to handle solid waste.   We also believe
               that to require pretreatment which would produce a sludge
               from the POTW acceptable for land application at a location
               which disposes of sludge in an alternative manner (i.e.,
               incineration) would not be cost-effective.  We suggest,
               further, that sludge disposal  considerations be limited
               to those highly toxic materials which are likely to
               concentrate in sludges."

C.        Industry and pollutant coverage must be broad to avoid sludge
          contamination problems.

          H. Clay Kellogg, Jr., General Manager, Kellog Supply Inc.,
          Carson, CA:

                    "This is the 52nd year which our company, Kellogg
               Supply, Inc., has been marketing sewage sludge.  We
               currently sell approximately 40,000 dry tons per year  and
               the material is on allocation by us to our customers
               because of lack of supply from the Sanitation District.
               Over 80% of our business is done with the retail nurseries
               and garden shops.  In most areas of the United States
               there has not been an effort to market sewage sludge.
               Now that more and more of it is being collected, it could
               become a plague rather than the natural  resource which it
               is if unfair restrictions are put upon its use  ... To
               allow some industry to pollute one of our greatest natural
               resources, which  sewage sludge is, would be a disgrace.
               Next thing you know, sewage would be called a hazardous
               waste or the Board of Health would put so many restrict-
               ions on its use that everyone would be afraid to use it."

          Albert S. Matlack, The Society of Natural History of Delaware,
          Hockessin, DE:

                    "Paper after paper bemoans the fact that toxic
               heavy metals limit the use of sewage sludge on  land.
               Methods such as ion exhange, electrolysis, solvent ex-
               traction, precipitation, etc. exist for the recovery of
               Cr, Ni, Cd, Zn, Pb, Hg, Cu, etc. at the metal finishing
               on other source.  The reason they are not used  is that  it
               is cheaper to throw away the Rhodesian Cr, or Canadian
               Ni, even though the supply at the source  is limited.
               With these metals removed, the sludge can be used on land
               as a source of N, P, and organic material."

          Wayne A. Schmidt, Staff Ecologist, Michigan United Conservation
          Clubs, Lansing, MI:

                    "MUCC supports strong wastewater pretreatment  standards.
               We do not believe that  the public should  subsidize  removal
               of industrial toxic pollutants,  such as heavy metals and
               halogenated  hydrocarbons, at publicly-owned treatment
               works  (POTW).  Most municipal treatment plants  in Michigan

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                          -78-
     are not designed to remove such toxicants and the introduction
     of such chemicals creates serious problems affecting
     public resources -- air pollution from incomplete incineration
     of sludge; water pollution from inadequate treatment of
     wastewater discharge; increased costs of operation from
     incompatible chemicals interfering with normal  treatment;
     and prevention of land treatment practices because of
     potential groundwater contaamination and public health
     hazards from treatment of agricultural lands ...  One of
     the reasons only '25' percent of the POTW sludge  is
     utilized on land for animal  and human food crops' is the
     absence of stringent pretreatment standards today.
     Current wasteful disposal practices (i.e., landfill ing or
     incineration)  should not be  justification for pretreatment
     standards which do not assume future land disposal.

               "Further measures  should also be mandated
     regarding reduction of toxic substances at their  source,
     and recycling  and recovery of useful  industrial materials...
     Problems of sewage treatment, and, particularly,  sludge
     disposal are acute in our state, especially in  the greater
     Detroit area.   Disposal  of sludge via land treatment is
     inevitable; the sooner stringent pretreatment standards
     are applied, the sooner we will  have a chance to  solve
     these problems of disposal."

Thomas Glenn, Director and Chief  Engineer, Interstate  .Sani-
tation Commission,  Greater New York Metropolitan Area, CN:

          "But we are coming to realize that sludges containing
     more than acceptable amounts of heavy metals, and possibly
     other substances, originating in industrial wastes cannot
     be safely spread on the land.

          "If these detrimental substances cannot be largely
     removed from sewage by practical and economic treatment
     methods, the only way to keep them from unreasonably
     intensifying the sludge problem is to insist on pretreatment
     and source control."
A.B. Early, Environmental  Action,  Washington,  D.C.:

          "Landspreading of sludge on croplands may  require the
     removal  of pollutants at greater rates than is  required to
     meet the national  standards.   Either the  national  standards
     should be based on the use of the sludge  disposal  alternative
     demanding the greatest amount of removal  (presumably land-
     spreading on croplands), or a mechanism must be established

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                                   -79-
               enables the POTW to lower the standard because it is
               "incompatible" with the disposal  alternative being used.
               The failure of the proposed regulations to  address this  prob-
               lem presumably leaves the establishment of  a more stringent
               standard as a local requirement.   Section 307(b)(l) of the
               FWPCA (33USC1317 (b) (1)) requires the issuance of pretreat-
               ment standards for introduction of pollutants into publicly
               owned treatment works as defined  in Section 212 "which would-
               interfere with the operation of such treatment works."
               (emphasis supplied)  Section 212(2)(A) of the Act (33  USC
               1292(2)(A)) clearly contemplates  sludge disposal  as included
               in the definition of treatment works.   Environmental Action
               takes the position that EPA should therefore assume the
               use of a sludge disposal method that requires the greatest
               amount of pollutant removal from  the sludge disposal method
               that requires the greatest amount of pollutant removal from
               the sludge to prevent water or other environmental  degra-
               dation."

D.         Case-by-case modifications of the promulgated 'standards could
          result in additional incompatible pollutants in  POTW's sludge
          restricting disposal possibilities.

          Charles J. Henry, Director, Water Pollution Control, Municipality
          of Metropolitan Seattle, WA:

                    "Some problems could develop from the  requirement that
               acceptable sludge disposal program are a prerequisite  to
               granting local variances.  Since  most large municipalities
               are faced with a sludge disposal  problem, an 'interim policy
               may have to be established to prevent undue hardships  on
               local industry tributary to such  systems.   If an industry
               is not contributing to the situation which  is snagging the
               approval of an acceptable sludge  disposal program, it  should not
               be required to suffer the loss of an otherwise permissible
               variance."

          W.G. Turney, Bureau Chief, Environmental Protection Bureau,
          Dept. of Natural Resources, State of Michigan, Lansing, MI:

                    "Sludge considerations:  In  the development and approval
               of local pretreatment programs, a very clear analysis  of
               the sludge disposal or use question should  be provided.
               The options available for sludge  management may be more
               critically affected by pretreatment decisions than are
               the biological treatment process  options which could  be
               affected.  A clear review of the  sludge question should
               be required with respect to capital, energy, and other
               environmental impacts before local programs are approved."

          Kenneth S. Kamlet, Counsel, National Wildlife Federation,
          Washington, D.C.:

                    "First, the issue of removal versus treatment, as
               the basis for a variance -- none of the options adequately
               addresses what EPA itself recognizes to be  one of the  funda-
               mental problems pretreatment standards should be designed

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                        -80-
     to remedy;  namely,  reduction of contaminant levels in
     sewage sludge.

          "As noted  by the preamble to the proposed regulations
     many industrial  pollutants can contribute significantly to
     the sludge  disposal  problems of POTW's.   Industrial  pollu-
     tants, particularly metals and other toxic pollutants can
     limit the sludge disposal  alternatives available to the POTW,
     and thus, increase the cost of adequate sludge disposal
     facilities, and in some cases, improper handling of metals
     and/or other toxic contaminated sludges can result in uptake
     of metals by crops in the  human food chain, or leaching
     of these pollutants into ground water, as well  as surface
     waters.  And that was a quote from the preamble of the pro-
     posed regs.

          "So, the contaminant  content of sewage sludge,  the end-
     product of  POTW contaminant removal  processes,  is a  matter
     of considerable environmental  significance.  Unfortantely,
     the variance procedures proposed by EPA for all four of its
     pretreatment options, fail to give sludge the consideration
     it requires."

Albert J. Slap,  Sierra Club's National  Water Quality Committee,
Philadelphia, PA:

          "The idea  of local credits for sewage treatment plants
     that remove substantial quantities of industrial pollu-
     tants is plainly wrong. Even though there is a removal
     from the liquid to solid phase, and consequently no pass-
     through EPA's responsibility over pollution is now 'from
     cradel to grave."  That is, EPA has not discharged its
     responsibility and,  hence, cannot relieve the industrial
     discharger  of its duty, by pointing to a percentage
     removal at  the  publicly owned treatment works.

          "The sludge in the municipal  plant would,  in a
     variance situation, contain more industrial waste and
     probably be unfit for land application.   EPA cannot leave
     the solution of this type  of problem solely to the local
     government."

Marwan M. Sadat, New Jersey Office of Sludge Management and
Industrial Pretreatment,  Department of Environmental Protection,
Trenton, NJ, Statement at Boston Public Hearing:

          "National  pretreatment regulations should preclude the
     qualifications of the national pretreatment standards and
     and should  not allow for any variances from those standards.
     When variances are granted on the basis of a high degree
     of removal  by a POTW, the  net result of such a variance
     is to concentrate in the sludge the pollutants which
     the pretreatment program is supposed to remove.  Under
     Option 1, municipalities would be required to demonstrate

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                          -81-


     that adequate sludge disposal  facilities  could  handle  the
     additional  contaminants in the sludge.  This  would  only
     increase the complexity of the sludge disposal  problem.
     It is important to keep in mind that the  main objective
     of any industrial  pretreatment program is to  minimize  the
     impact of pollutants on the environment.   When  toxic
     substances, heavy metals and contaminants are concen-
     trated in the sludge they invariably affect another
     sector of our environment and  may even,  in extreme  cases,
     return to the surface waters we are trying to protect.
     For this reason, we feel that  whatever option EPA finally
     decides to implement, no variance for toxics  and  heavy
     metals should be granted to local  authorities."

Louis J. Breimhurst, Director-Div.  of Water guality, Minnnesota
Pollution Control Agency, Roseville, MM:

          "Any variance increases the potential  for  problems
     developing from sludge disposal.  Approval  of local credit
     allowances alone will adversely affect sludge quality.   In
     addition, if industries are allowed to discharge  a  pollutant
     at a given concentration, as opposed to mass  limits, POTW's
     receiving a given pollutant from several  industries may
     still have a sludge quality problem.  A water quality  vari-
     ance would only add to this problem.  None of these options
     really dealt with this to assure good sludge  quality for
     acceptable disposal.  Since this aspect of wastewater  treat-
     ment can constitute up to one-half of wastewater  treatment
     costs, it is of major concern."

Dr. Dana Davoli, Director of Toxic  Substances  Research,  Citizens
for a Better Environment, Chicago,  IL:

          "In granting a variance,  EPA also states that  it  must
     be assured that the sludge will be disposed of  in an environ-
     mentally safe manner.  Such variances granted by  EPA would
     necessarily involve an increase in the amounts  of toxic  pol
     lutants in the POTW's sludge.   This would include increases
     not only in the levels of heavy metals such as  lead, mercury
     and cadmium, but also increases in organic substances  such
     as chloroform, benzene, and pesticides.   Such increases  in
     toxic substances would limit the number and types of disposal
     options available to the treatment plant  and  therefore increase
     the costs of sludge utilization or disposal.   In  addition,
     there are large gaps in our knowledge as  to what  constitutes
     a "safe" disposal  method.  Incineration of sludge may  result
     in hazardous air emissions and water pollution  both by fallout
     of these air emissions to the  water and by improper disposal
     of the ash.  Landfilling may result in pollution  of ground
     waters and ocean dumping may have toxic  effects on  aquatic
     life.  In some areas, sludge is used solely for agricultural
     landspreading.  Even with proper land management, problems
     can still arise with this type of disposal  due  to our  lack

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                    -82-
of knowledge about the environmental  fate and biological
uptake and effects of such heavy metals as cadmium and
selenium in agricultural  use.   Our level  of knowledge
is even more limited when dealing with organic compounds
such as pesticides, polynuclear aromatic  hydrocarbons and
others listed on the settlement agreement.  In addition
to the problems associated with heavy metals (environmental
fate, biological uptake), volatilization  of organics from
sludge can result in increased air pollution and increased
human exposure.  Due to this  lack of  information on safe
disposal of sludge, CBE feels  that every  effort should
be made to prevent contamination of municipal  sludge with
toxic materials.  Stringent pretreatment  standards are a
step in the right direction.   Granting variances to second-
ary treatment works is not.  While we realize that stringent
pretreatment standards may cause a sludge disposal  problem
for industry, the sludge  produced in  this case represents
a much smaller volume and,  therefore,  could be more adequately
handled by sanitary landfills."

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                                    -83-
VI-   MEETING STATUTORY COMPLIANCE DEADLINES

               Considerable discussion concerning POTW and industrial

     compliance with statutory dealines, as set forth in PL 92-500, has

     been generated by the proposed pretreatment regulations.   At the

     heart of the compliance issue lies the unanswered question of

     whether or not the, as-yet, unpromulgated pretreatment standards

     will cause delay in the attainment of the July 1, 1977, and July,

     1983, water quality goals and technology control requirements.

               The crucial factors which have raised this interest

     center on the following key relationships:

                    a)   the lack of enabling legislation for some
                         States and localities;

                    b)   the time required to train and staff local
                         agencies; to establish model ordinances;

                    c)   the "gearing-up" period that will be necessary
                         to effect efficacious program implementation
                         and administration;

                    d)   the uncertainties confronting both local con-
                         trol agencies and industries in municipal sewer
                         systems where secondary treatment facilities
                         are not yet operational; and,

                    e)   the unaddressed questions of due process,
                         judicial review, and legal challenge.

               The amalgam of comments presented in this section collec-

     tively address the compliance issue.

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                                  -84-
A.        The lack of enabling legislation and model  ordinances for some
          States and localities would delay meeting compliance dates.

          John G.  Costello,  Executive Director, Bergen County Sewer
          Authority, NJ,  Statement at Boston Public Hearing:

                    "It must also be recognized that  many regional
               sewer agencies will  require state-enabling legislation  by
               all  the member municipalities to obtain the legal  power
               necessary  for direct enforcement of  pretreatment regu-
               lations.   The Bergen County Sewer Authority,  for example,
               is  comprised  of 44 autonomous member municipalities  with
               the result that legal  enforcement problems can be  exces-
               sively complex.  Any time  limitations  or penalties for
               delayed local  enforcement  must consider the time required
               for the local  authority to obtain state-enabling legis-
               lation and for action  by all  the member municipalities.
               We  would estimate that it  would require at least 3 to 5
               years to develop an  adequate pretreatment program  for
               regional sewerage agencies that now  lack the  proper
               enabling legislation."

          Frank Dryden, Head,  Technical Services Department,  Sanitation
          District of Los Angeles,  Mhittier,  CA:

                    "First,  I  think that  you  have to  recognize  that
               communities which do not now have the  technical  capability
               or  manpower to  set up  and  run  a pretreatment program
               suitable to their system are going to  require  some time.
               It  takes time  to  train and  develop this  capability.

                         "In our own  case,  we  started,  you  know,  in
               '70,  and we still  aren't up as  far along  as we would like
               to  be.   There  are still  parts  of the permit program --
                You  know,  we  have gotten  the major  things all under
               control, but there are still  —  of our  7,000,  there are
               still  some  that we have  not  been  able  to  get to  and
               check.   It  takes  time  to write  and adopt  ordinances. And
               if you  don't allow a couple  years  to three years for that
               type  of process,  you are kidding  yourself.  And  if you
               try to  do  it by fiat in  a  short  period  of  time,  I  think
               you tend to create chaos rather  than help  the  situation
               along.

                         "You must  have a  training program that recog-
               nizes  it's  going  to  take time to  develop  this capability.
               But it  is entirely capable of being developed  in every
               community that  needs it."

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                          -85-
Bruce S. Crutcher, Greater Cincinnati Chamber of Commerce,
Cincinnati, OH, Statement submitted at Washington,  D.C.  public
hearing:

          "Differently situated are many small  POTW's serving
     smaller communities which include one or a few large
     indirect dischargers.  Few of such managing authorities
     have adequate pretreatment and enforcement programs, and
     the posture of many may be such that the probability of
     being over-reached in negotiations with a large indirect
     discharger which may also exert a major influence on the
     economic health of the local  community, may be signifi-
     cant.  In this situation, we believe compliance with the
     intent of the Act would be unnecessarily delayed if the
     local authority is required to establish a program of
     pretreatment and enforcement which, when its inadequacies
     became apparent, would be superseded by State  and Federal
     action."

Richard Woods, Counsel, Ocean County Sewerage Authority, Toms
River, NJ:

          "...the OCSA is created by virtue of the  implement-
     ing legislation known as the Sewerage Authorities'  Law,
     N.J.S.A. 40:14A-1, et seq.  The powers of the  sewerage
     authority are set forth in N.J.S.A.40:14A-7.  This section
     of the Sewerage Authorities'  Law is the powers of a
     sewerage authority.  Although these powers are broad to
     enable a sewerage authority to exercise public and essential
     governmental functions to provide for the public health
     and welfare, they are not broad enough to enable an
     authority to impose, for instance, criminal sanctions  for
     failure to comply with pretreatment regulations.

               "Under the laws of the State of New  Jersey,  the
          police power is ultimately vested in the  State
          Legislature. In certain instances, the police power
          has been delegated to municipalities which may, by
          ordinance, impose certain penal sanctions for actions
          which harm the public health, safety and  welfare.
          Finally, in certain instances affecting public
          health, local boards of health are given  the power
          to impose penal sanctions.

          "A sewerage authority, however, does not  have the
   type of police power which is vestedin the State Legislature,
   municipalities and boards of health.  It can act only within
   the parameters of its enabling legislation.  Section 403.9
   far exceeds, in our opinion, the powers which a  sewerage
   authority in the State of New Jersey can exercise.  It is
   the OCSA, or any other sewerage authority, to establish
   the programs as set forth in Section 403.9"

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                         -86-
The "gearing-up" period required for POTW design and construction
as well as the administrative arid procedural  complexities will cause
postponement of compliance deadlines.

Albert C. Clark, Vice President and Technical  Director,
Manufacturing Chemists Association, Washington, D.C.:

          "We commend the Agency's recognition of the time
     factor conflict between July 1, 1977 and the installation
     time faced by those who must meet yet-unpromulgated
     standards.  We recommend that the Agency stipulate, in
     the promulgation, that the three-year period for compliance
     by all affected industries begins with the date of promulgation.
     For many, design, installation and start-up will indeed
     be a three year undertaking."

John Lambie, Chief Engineer-General Manager,  Ventura Regional
County Sanitation District, Ventura, CA:

          "The procedures as outlined for making an  appli-
     cation for a variance in the pretreatment standards are
     complicated to the point that processing of a variance
     might require extensive manpower and time commitments."

Charles A. Geisler, Sanitation Engineer,  City of Omaha, NB:

          "Requiring an industry to sample and report o.n
     its status every six months does not guarantee  meeting
     compliance. This will require a major police action."

Jack Barron, Division Engineer, Industrial Waste Division,
Department of Public Works, San Francisco, CA, Response to
Question at San Francisco Public Hearing:

          "...Basically, we began our efforts in '73, and
     this is the gearing up process and problems that you
     have.

          "Our first emphasis was on getting  a surcharge
     program in operation, and we found we had to do it all at
     one time because we were being taken to  court if we
     attempted it on a piecemeal basis.  So  we had  to expend
     the first year in getting this program underway since our
     SPDES permit was granted in '74.  So we  didn't  precisely
     know what we would have to control.

          "So since '73, these ensuing years, we have been con-
     centrating on our pH problems, which we  now have under
     control, and then on our heavy metals.

          "Now, we will be getting into controlling  those things
     that may have any adverse effect on our  secondary treatment
     plants in our next phase..."

          "And I would like to reemphasize...that it takes con-
     siderable time to gear up to do these things because industry
     can't overnight, and neither can we overnight,  arrive at
     solutions that will resolve the issues."

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                        -87-

Frank Dryden, Head, Technical Services Department, Sanitation
District of Los Angeles, Whittier, CA:

          "I would like to point out that the options appear
     to be quite complicated administratively and that there
     is a great need to simplify some of the concepts and some
     of the administrative procedures, and that failure to
     simplify them will probably result in their demise because
     it will almost become an excuse for adopting what would
     be administratively simplistic but I think not the best
     or most reasonable approach, and that of decreeing uniform
     national standards without the variances.  So I'm very
     concerned that, as you proceed to selecting and adopting
     a final option that you work for a simplification of the
     procedures, for which I have some suggestions this morn-
     ing."

Roger R. Patocka, Banner Associates, Inc., Consulting Engineer
and Architects, Brookings, SD:

          "It is felt that any of the four options presented
     will require a great amount of effort to implement.
     Laboratory capability will be needed as well as the
     expertise necessary to perform the analyses.  It is
     questionable if the proposed timetables can be met."

James B. Bewley, Superintendent, Water Pollution Control,
South Bayside System Authority, San Carlos, CA, Response to
question at San Francisco Public Hearing:

          "...My only hedge would be what you determine to
     be a reasonably short period of time to get the program
     going and started.

          "I'm sure you recognize it takes some time.  You
     have the ordinance problem and the budgetary problems and
     finding the people.  The time, though, up -- the time
     constraints up until now have not been on the local
     agency.  We have been anxiously awaiting federal guidance
     since 1972 on this.

          "So I do think that it would be reasonable that --
     I will stay with California because my only experience is
     here -- that the State Board through the regional boards
     could establish a procedure for determining whether a
     local agency was capable of handling it.  I think in the
     absence of such procedure, yes, that the -- the technology-
     based standards would be all that you have to work with."

Robert Cruess, Permit and Surveillance Division, State of New
Hampshire, Concord, NH, Statement at Washington, D.C. public
hearing:

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                          -88-
          "...I think the standards should be written before
     we have the procedures to implement them.   But then, the
     second issue is that with these standards,  I  think you
     will  find that it will take you ten years before you have
     a handful of communities running a pretreatment program.
     I think it would be better to have a more simplified
     program and make it concentrated only where we have large
     major industrial concentrations.  In New Hampshire,
     that's probably two communities.

William B. Dendy, Executive Officer, California  State Water
Resources Control Board, Sacramento, CA:

          "Subsection (3) indicates that EPA expects local
     agencies to be able to develop technology based limits on
     an interim basis pending promulgation of national  standards.
     Considering the difficulties EPA encountered  in establishing
     the BPT standards,  this is a curious statement.  We don't
     understand how local agencies can be expected to accomplish
     such a task in this time frame.  The most that we would
     expect is for those few agencies already having some pre-
     treatment requirements to continue and for  some of the
     largest POTW operators not yet having any pretreatment
     requirements to adopt some requirements...It  is also
     important that any requirement for pretreatment be consistent
     with the timing of municipal treatment facilities construction.
     Industries will, in accordance with applicable revenue
     recovery programs,  be paying for these facilities and  as
     such they should be entitled to obtain any  benefits in
     terms of reduced pretreatment which result  from the use
     of the municipal facilities."

W.R. Johnson, Director-Plant Environment, General  Motors
Corp., Warren, MI:

          "During our contacts with POTWs, large or small,
     each has one or more persons responsible for  implementing
     an industrial  wastewater control program under a local
     ordinance. Programs of some large POTWs, such as Chicago
     Metropolitan. Sanitary District and Los Angeles County
     Sanitary District,  were developed and implemented success-
     fully even before the promulgation of any federal  pretreat-
     ment standards. Further, many POTWs have not  fully developed
     the capability to enforce pretreatment programs because
     of the uncertain nature of federal regulations.  The full
     development of local enforcement capability may take
     several years for some POTWs.  However, again, the development
     of an equivalent capability at the federal  level may take
     even longer."

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                                   -89-
C.        Due process, judicial review, and other legal considerations will
          delay compliance with established statutory deadlines.

          Kenneth S. Kamlet, National Wildlife Federation, Washington,
          D.C., addressing question regarding the level of adequacy for
          due process in granting variances, Washington, D.C. public
          hearing:

               [Comments in regard to due process for industrial variances]

                    "Just off the top of my head, one thought occurs to
               me, as a means of preventing such variance proceedings
               from dragging on indefinitely while the discharges
               continue, might be an approach similar to one layed out
               by Congress in the Water Act, the Air Act and various
               other statutes, whereby industry, those that are subject
               to the regulation, are given 60 days or 90 days or some
               set period of time in which to complain, and if they
               don't avail themselves of that opportunity within that
               period of time, then they are foreclosed from complaining
               thereafter.

                    "Once they register their complaint, the request for
               a variance, they will have an opportunity to have a
               hearing and so forth, administratively and whatever.  I
               am not suggesting that they not have the opportunity to
               make their case and have the decision made on the basis
               of the evidence they present.

                    "It seems to me that a balance has to be struck, as
               you pointed out, and one way of doing that would be to
               establish some reasonable cut-off for objecting to what
               has been adopted."

               [Comments in fegard to due process for POTW variances]

                    "1.  First, we reiterate our strong view that variances
               should be made available only in rare cases, only where the
               "fundamentally different" nature of a POTW results in a
               degree of treatment (not merely "removal") in excess of
               that upon which the national standard was based, and only
               where the grant of a variance will cause no decline in the
               quality of either the resultant effluent or the resultant
               sewage sludge.

                    "2.  Second, we believe different approaches are appro-
               priate and necessary for new as opposed to existing POTW's.
               Since existing POTW's presumably have an operational experience
               upon which to draw, it is fitting that such plants should
               be given less time than new sources in which to challenge
               or seek variances from pretreatment requirements.

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                         -90-
          "3.   Third,  inasmuch as the national  (and other)
     pretreatment standards for industries and  pollutants will
     generally, if not always, have effective dates delayed by
     as much as three  years from the date of their final
     promulgation, variance requests, variance  proceedings,
     and the disposition of such requests should be made,
     conducted, and completed within the phase-in period.
     Moreover, variance decisions should be made sufficiently
     early in the phase-in period to permit affected industries
     to complete any necessary process or facility modifications
     within this period, without delaying the effective date
     of the standards.

          "4.   Fourth,  for existing POTW's, the operating auth-
     ority should have no more than 60 days from the date of
     promulgation of the final pretreatment standards within
     which to request  a variance.  EPA (or the  NPDES state)
     should be required to hold a complete variance proceedings,
     along with a final disposition of the variance request,
     within a maximum  of 180 days from the date of the request.

          "5.   Fifth,  for new POTW's, the operating authority
     should have no more than 60 days from the  date of promul-
     gation of a final  pretreatment standard within which to
     request a variance, unless: (a) EPA determines within  15
     days of the request that probable cause exists to anticipate
     ultimate approval  of the request, (b) the  operating
     authority demonstrates that, by virtue of  the "newness"
     of the POTW, it was not reasonably possible to accumulate
     the data necessary to evaluate the need for a variance
     within the time limits applicable to an existing POTW,
     and (c) the operating authority exercised  its best good
     faith efforts to  expeditiously assemble all  necessary
     data and otherwise to comply with the time limits appli-
     cable to existing POTW's.

          "6.   Sixth,  where a new POTW qualifies (as in 5,
     above) for an extension in the time limit  for requesting
     such extension should in no case exceed 60 days from the
     earlies date on which the operating authority could
     reasonably have had available the data necessary to
     determine the need for a variance.  Again, the decision
     on the requested  variance should be forthcoming within a
     maximum of 180 days from the date of the request.

          "7.   Seventh, if it is necessary to stay the effective-
     ness of a pretreatment standard pending a  determination
     on a request for  a variance, the stay should be as narrowly
     drawn and of as limited a duration as possible.  Variance
     requests for which decisions have not been made within
     the allotted 180-day period should be deemed denied."

C.J.  Buschkill, Manufacturing Engineer, George  Koch Sons,
Inc., Evansville, IN:

          "The present BPT requirement by July  1, 1977, and

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                         -91-
     BPT by July, 1983, are undefinable, indefinite,  and
     unrealistic.  The interpretation, as I  have attempted
     to secure from federal, state and local  levels,  is so
     broad that litigation could easily continue for  the
     next decade."

Seymour A. Lubetkin, Chief Engineer, Passaic  Valley Sewerage
Commissioners, Clifton, NJ, Statement at Washington,  D.C.
public hearing:

          "Generally speaking, some of the time tables indicated
     in the Federal Register, are out of date with reality,
     particularly on some very large, complex projects.  And,
     although I realize there are dates within the law that,
     at present, are unalterable, I request  that when the
     final regulations are drawn, consideration be given to
     the problems of many urban areas, whereby primary treat-
     ment plants are being upgraded to secondary plants after
     dates, which prohibit such a plant from  administering a
     pretreatment program.

          "In our particular case, for instance, due  to the
     siz.e and complexity of the problem, the  first phase of
     construction will not be completed until the end of 1980,
     whereby we will have a secondary treatment plant, but
     without primary clarifiers.  Thus, not  up to the removals
     required by law.

          "The second phase will not be completed until the
     end of 1983, and it is only at that time, with a 93
     percent removal, will we meet the standards necessary for
     our discharge.

          "The PVSC is working as fast as possible and all the
     dates set in the law cannot make construction go any
     faster.  It would be unconscionable, because of  such a
     long and complex construction program,  for the industries
     within our area to be unnecessarily penalized and bur-
     dened twice; first, by having to install pretreatment
     equipment because we cannot meet a construction  date for
     our discharge as set in the regulations, particularly
     since the delay is causing no problems  in our area, and
     then, secondly, by paying through the industrial cost
     recovery system for our expensive upgrading, which makes
     unnecessary part of their pretreatment."

Robert G. O'Dette, Environmental Engineer, statement  at
Washington, D.C. Public Hearing:

          "The disregard for many economic considerations,
     from an engineering and consumer point  of view is most
     distressing.  The only costs mentioned  in the Register
     were $15 to $85 million for reporting requirements, and
     less than $1 million for compliance.  The following
     conservative estimate will show that actually this cost
     may well exceed $300 million for compliance alone.

          "If this is the case, EPA will have violated Exec-
     utive Order 11821, as extended, OMB Circular A-107, and

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                          -92-
     their own guidelines on  economic  impact analysis,  which
     requires an analysis if  incremental  amortized costs of
     compliance, including capital  charges,  exceeds $100
     mill ion.

          "Without this analysis,  it is virtually impossible
     for people who must bear the  burden  of  the costs of the
     program and increased consumer costs,  to make any in-
     formed decision to support or reject the proposed  regu-
     lation."

J.R. Thorpe, Manager of Environmental  Affairs, GPU Service
Corporation, Parsippany, NJ:

          "Under Section 403.8, a  Regional Administrator may
     withdraw a previously granted "variance for removal  of
     pollutants" (local credit) after  notice to the POTW and
     all indirect dischargers,  and publication of the reasons
     for the withdrawal.  The proposed regulations, however,
     do not provide for a hearing  prior to  the withdrawal  of
     the variance.  In view of the severe impact on the
     operations of both the POTW and its  industrial dischar-
     gers of a withdrawal  of  the local  credit variance, EPA
     must provide an opportunity for a hearing prior to the
     withdrawal of the variance by the Regional Administrator.

Robert C.  Miles, Director-Environmental Controls, UniRoyal,
MIddlebury, CN:

          "Paragraph 403.6 (b), Pg. 6497  -  An industrial  dis-
     charger who is called a  requester may  ask for a variance
     90 days following the promulgation of  a pretreatment standard.
     In the rubber industry there  are  1,189  fabricated  rubber
     products plants which generally discharge to POTW's and are
     privately owned.   The small ness of these operations tend
     to preclude knowledge of EPA's activities in this  area and,
     therefore, timely response does not  occur.  EPA seldom
     surveys this type of operation so that, statistically, an
     element of fundamental difference from  national pretreatment
     standards may occur.   This vexing problem requires special
     consideration."

Paul C. Hittle, General Supervisor of Environmental Affairs,
Consumers Power Co., Jackson, MI:

          "In a state which has an approved  NPDES program, this
     section would establish  a three-level  approval process for
     industrial variances. Approval of a variance would be re-
     quired by the State Director, the EPA  Regional Administrator,
     and the EPA National  Administrator.   Because of the possi-
     bility of delay in securing all three  approvals, the Company
     recommends the inclusion of a 60-day time limit within which
     the State Director and EPA Administrators must either approve
     or disapprove complete variance requests.  It is also recom-
     mended that provisions be added to allow delegation of this

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                     -93-
     "The Company also recommends that the time period
for the submission of supporting evidence for a variance
request be extended to at least 180 days, and that the
Regional Administrator or State Director be given the
authority to extend this period even further, when
individual circumstances justify such an extension.
Although a variance request could be made within the
90-day proposed period, adequate supporting evidence for
a variance request be extended to at least 180 days,
and that the Regional Administrator or State Director
be given the authority to extend this period even fur-
ther, when individual circumstances justify such an
extension.  Although a variance request could be made
within the 90-day proposed period, adequate supporting
evidence for the request might in some cases not be
obtainable within the 90-day period.  For example, the
acquisition of reliable supporting evidence could require
the purchase and installation of sampling and analytical
equipment and contracting of outside laboratory sources.
These activities could easily take 90 days to complete;
even if they required a lesser period there would be
little time to complete the necessary monitoring.  In
many cases, however, a brief period would not adequately
cover the full range of a discharger's production acti-
vities, particularly if the period coincided with the
discharger's seasonably high or low production period."

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                                   -95-
VII. DUPLICATION WITH EXISTING PRETREATMENT OR INDUSTRIAL SOURCE
     CONTROL PROGRAMS.""

               As stated in the February 2, 1977, Federal Register

     (Part II), a secondary objective of developing a national pre-

     treatment strategy "...is to begin to reconcile existing pretreat-

     ment programs in many cities with the approach called for by the

     Federal legislation."  However, the proposed pretreatment standards

     only stated the issue and addressed none of the complexities that

     might be occasioned by their promulgation.  Statements at the four

     public hearings and in written comment submitted to EPA, support

     this contention.  The major concern expressed was that the proposed

     regulations would cause duplication of facilities and in treatment

     efforts of existing pretreatment and industrial source control

     programs.  Regulatory and enforcement conflicts, lack of mention of

     industrial POTWs, additional financial burdens, and no discussion

     of any EPA consideration of existing pretreatment efforts in

     determining new pretreatment requirements were also highlighted as

     problem areas.  Discussion of these duplication issues are con-

     tained on the following pages.

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                                    -96-


A.         The Pretreatment program does not account for anj^^onf]j_ct__wi_tjl
          presently established local/state source control programs that may
          or may not be more stringent.

          Jack Barren, Department of Public Works, City of San Francisco,
          CA:

                    "So no matter what you do, we are still going
               to have a source control program.  We can't avoid it.

                    "So in other words, we appear to have some dup-
               lication. ..

                    "The other thing is that you look at it from indus-
               try's point of view.  We are working now with industry,
               have them under permits, under orders to do certain
               things for pretreatment.

                    "Now,  it is possible that EPA will  come along with
               pretreatment standards and require — and we will have to
               require industry to take a second run at this pretreatment
               problem.  And if they would have known originally how
               much pretreatment they would have to install, they may
               have addressed the issue in a very different manner.
               They may have gone to an entirely different method of
               manufacturing rather than attempt to eliminate some of
               the constituents in the current method of manufacturing."

          James B. Bewley, Superintendent, South Bayside System Auth-
          ority, San Carlos, CA:

                    "...you must recognize that most local agencies that
               have industrial  problems have already begun a source
               control program and in whichever of the choices you pick,
               you want to make sure that you do not jeopardize any of
               the progress that we have made."

          Don T. Howell, Director of Utilities, Board of Light and-Water
          Commissioners, Concord, NC:

                    "Pretreatment requirements as proposed represented
               still another roadblock (to a Regional treatment plant).
               As the development of the Concord Regional Plan matured,
               using EPA's ever changing guidelines, primary clarifiers
               with chemical precipitation were approved in the initial
               grant application.  After final plans and specifications
               were prepared and approved, the primary clarifiers were
               declared ineligible for grant participation.  Local and

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                         -97-
     industrial funds were secured to construct the primary
     clarifiers to be used exclusively to remove industrial
     pollutants.  This entire cost is to be paid by the
     affected industries.  It is realized that additional
     sludge is to be expected from facilities of this nature,
     but at the same time dewatering and incineration faci-
     lities are under construction to dispose of this sludge
     in an environmentally acceptable manner.  If facilities
     such as these are to be duplicated at every industrial
     plant, it will be impossible to be cost effective."

J.F. Cormack, Supervisor, Water Programs, Environmental
Services, Crown Zellerbach, Camas, WA:

          "There is one important situation that is not
     addressed in any of the options.  This is the case where
     a large industry has a combined treatment plant with a
     small community.  The nature of the final effluent
     approaches that from the industry.  These plants were
     specifically constructed to achieve economy of operation
     and to avoid duplicate facilities.  The imposition of
     pretreatment requirements is inappropriate in such
     situations."

E. Ray Farley, Superintendent, Water and Sewer Department,
Lewisburg, TN:

          "Why should incompatible wastes be handled differ-
     ently from compatible wastes—where, through ordinance,
     local POTW's require pretreatment when the POTW's efflu-
     ent standard is endangered?  The basic goal of PL 92-500
     is unpolluted water.  The only dischargers affecting
     receiving waters are direct dischargers—point source and
     POTW's	We lose sight of the real goal at times.   It
     would appear that EPA regulation of indirect dischargers
     is regulation for the sake of_ regulation."

James W. Scanlan, Assistant Chief, Facilities, Bureau of Water
Quality Control, Arizona Department of Health Services, Phoenix,
AZ:

          "Secondary Objective	is to reconcile existing
     pretreatment programs in many cities.  This should not be
     a Federal objective.  It seems that the local authorities
     should be able to develop what programs they want.  Some
     programs may be very restrictive because they don't want
     a lot of water-using industries, others might be very
     liberal so they can attract those industries.  Therefore,
     the primary objective is very important; the secondary
     objective stated above seems to  infringe on our compe-
     titive systems."

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                                  -98-
          Karol  M.  Enferadi,  Chairwoman,  Industrial  Wastewater Sub-
          committee,  California  Water Pollution  Control  Association,
          Pasadena, CA:

                    "Existing source  control  programs currently are
               being  developed and  enforced within  the represented
               region under the  NPDES permit  system.   There  permits also
               require enforcement  of EPA Standards  when promulgated.
               It appears to  date that none of EPA's standards are more
               restrictive than  all of the represented local  agencies
               enforced standards.

                    "An approved local  source control  program is the
               most efficient way of  meeting  water  quality standards.
               Option II is,  therefore, most  compatible with the exis-
               ting structure."

          Nicholas  J. Lardieri,  Director-Environmental  Resources,  Scott
          Paper Co.,  Philadelphia,  PA:

                    "We believe  that  EPA  should  take no action in  the
               pretreatment area which would  unduly  jeopardize existing
               joint  municipal-industrial  treatment  or inhibit further
               development of such  systems.   The desirability of joint
               treatment is a clearly stated  policy  of PL 92-500 which
               we strongly endorse.   Joint treatment facilities result
               in economies of scale, elimination of multiple treatment
               sites  and minimize required regulatory surveillance.
               Pretreatment regulations should be desiqned to preserve
               these  advantages  by  encouraqinq local  enforcement fo the
               least  possible number  of Federal  pretreatment standards."

B.        The Pretreatment Regulation fail to recognize the  difference  between
          a "municipal"  POTW designed to  treat normal  domestic sewage,  and  an
          "industrial" POTW designed  specifically to treat industrial wastes.

          Joe P. Teller, Deputy  General Manager, Gulf Coast  Waste  Dis-
          posal  Authority, Houston, TX:

                    "The proposed Pretreatment Standards regulation
               assumes that all  Publicy Owned Treatment Works (POTW's)
               are  conventional  biological treatment facilities, and,
               even further,  frequently refers to them as "municipal."
               For  example:  "These standards known  as prohibited
               discharge standards,  are designed to  prevent  inhibition
               or interference with the municipal treatment  works...."
               (Fed.  Reg. Vol. 42,  No.  22, p. 6478); "The Agency will
               consider the effects of industrial wastes on  the muni-
               cipal  sewer system	" (Fed.  Reg. Vol. 42, No. 22,
               p. 6478); and  "To be more  specific regarding  this as-
               sumption EPA would assume  that the POTW is one of a
               group  or family of biologic treatment processes which are
               commonly used  in  the treatment of normal  municipal
               sewage	" (Fed. Reg. Vol. 42, No.  22, p. 6480).

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                          -99-
          "This ^assumption, Which is apparent throughout the
     proposed regulations, is not valid in all  instances.
     Existing facilities, specifically designed to treat
     industrial wastes and owned by public entities,  are in
     operation now and have been for some time....

          "There is clearly a distinct difference between a
     municipal POTW and an industrial POTW, yet no distinction
     is found in the proposed regulations.  To overlook these
     differences would be a direct disservice to water quality
     management, and would pose a totally unnecessary finan-
     cial and technical burden on those parties involved."

J.F. Cormack, Supervisor, Crown Zellerbach Environmental
Services, Camas, WA:

          "There is one important situation that is not
     addressed in any of the options.  This is the case where
     a large industry has a combined treatment plant  with a
     small community.  The nature of the final  effluent
     approaches that from the industry. There plants  were
     specifically constructed to achieve economy of operation
     and to avoid duplicate facilities.  The imposition of
     pretreatment requirements is inappropriate in such
     situations. Such plants should have the option of being
     regulated under the appropriate industry limits  or by
     these regulations."

Timothy L. Morris, Texas Water Quality Board, Austin, TX:

          "We also recommend that the regulations be  drafted
     to exempt publicly-owned treatment works that are speci-
     fically designed, constructed, and operated to provide
     regional treatment of industrial waste such as the plants
     operated by the Gulf Cost Waste Disposal Authority and
     the Lower Neches Valley Authority in Texas.  Major
     reductions in the pollutant loads on the Houston Ship
     Channel and the Lower Neches River have been realized by
     these systems.  It is our belief that the pretreatment
     rules as they have been proposed will jeopardize the
     future of these systems like them if they are affected by
     the regulations just as any other publicly-owned treat-
     ment works would be."

Frank J. Krasofski, Vice President, James River Fitchburg,
Inc., Fitchburg, Inc., Fitchburg, MA:

          "No distinction is made between a municipal treat-
     ment facility designed primarily for domestic wastes and
     a facility primarily designed as a joint municipal-
     industrial system capable of processing industrial wastes,

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                                     -100-
                     "The city of Fitchburg  operates two waste treatment
                plants; the West plant was designed to accept and process
                all  industrial  wastes from the various paper companies in
                the area, including James River-Fitchburg.   The plant was
                designed in conjunction with the paper companies, and
                funded by these companies, along with the city of Fitchburg.

                     "Because the plant has  already been designed for
                industrial  wastes, pretreatment regulations for industry
                feeding wastes to the plant  would be an unwarranted and
                unjustified cost burden of duplicated effort."

           Elaine Fielding, Legal Dept., Clark Oil  & Refining Corp., Blue
           Island, IL:

                     "First, there seems to  be an unarticulated and over-
                generalized hostility to POTWs serving the  function of a
                central mechanism for the treatment of industrial waste-
                water.  There may be some basis for this in a locality
                where the POTW is geared exclusively or primarily to
                treat residential and commercial wastes, and not the more
                esoteric industrial wastes.   However, we strongly believe,
                as discussed more fully below, that explicit recognition
                should be given to those highly industrialized areas in
                which the POTW is not only equipped to, but is desirous
                of treating industrial wastes, if it can demonstrate that
                it will do so in an environmentally sound manner.  This
                is obviously the situation in the Chicago area where the
                MSDGC treats the wastes of 6000 industrial  facilities,
                and we imagine the same is true in many other areas of
                the nation too."

           Robert C.  Miles, Director-Environmental  Control, UniRoyal,
           Middlebury, CN:

                     "Furthermore each POTW  represents an engineering
                design for] the community it  serves, including the indus-
                trial  customer.  Many POTW's are designed to handle
                industrial  process wastes and therefore pretreatment
                regulations could be counterproductive.  At one of our
                facilities we discharge high levels of phosphorous which
                helps the POTW meet the P/BOD ratio with a  minimum of
                nutrient addition.  Some industrial discharges have
                abnormal pH values in their  discharges but  mixing in the
                collection works results in  a neutral pH at the treatment
                works.''

C.         Experience  with existing industrial source control or pretreatment
           programs forms a basis for determining the necessity or desirability
           of new or  duplicative pretreatment requirements.

           Jack Barron, Division Engineer, Industrial Waste Division,
           Department of Public Works, San Francisco, CA, Response to
           question at San Francisco Public  Hearing:

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                         -101-
          "I can't answer as to what the smaller communities
     can or cannot do.  I think it would have to be based on
     each individual  community.  But I think we could carry
     out this program that you are mentioning in a reasonable
     time and probably carry it out as quick or quicker and
     more efficiently than we could if we had to rely on EPA
     pretreatment standards, which will  also have to probably
     be included with our source control program, because --
     I'm second-guessing you here.  Maybe I'm not doing this
     correctly -- but I think that you are going to put those
     same controls for those same contaminants in our NPDES
     permit, and if you do, then we face the problem that you
     are mentioning, whether or not you  issue the pretreatment
     standards."

N.L. Martin, James River-Massachusetts,  Inc., Fitchburg, MA;

          "In 1972, the paper mills committed themselves to
     capital and fixed operating costs (for a treatment plant
     designed specifically to treat paper mill effluents as
     discharged) for ten years after startup plus all of the
     operating and maintenance costs based upon Solids, Flow,
     and BOD of water treated.

          "The paper mill's commitments for ten years through
     1985 was made expressly to allow us to discharge untreated
     waters to a municipal plant and achieve the required
     degree of treatment.  A pretreatment provision in the
     commitment required the mills to bear full costs for
     pretreatment facilities required.

          "We are, therefore, opposed to the imposition of
     further pretreatment requirements on mills which dis-
     charge into municipal plants when the required degree of
     treatment is achieved."

Larry G. Lawson, Virginia State Water Control Board, Richmond,
VA, Statement at Washington, D.C., Public Hearing:

          "We recognize that all the on-going pretreatment
     programs (nationally) are not the same nor are they at
     the same level of development and we have only presented
     Virginia's program as one example,  however, we believe
     that before significant mandatory modifications to
     40 CFR 128 are made serious consideration must be given
     to existing pretreatment programs."

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                         -102-
T.O. Andrews, Manager, Environmental  Protection, Hammermill
Paper Company, Erie, PA:

          "We believe that there are specific instances where
     water quality standards can be maintained without the
     requirement of pretreatment by specific industries
     through locally derived water quality based pretreatment
     limits.  We do not believe the selection of options
     should be so rigid so as to preclude sensible courses of
     action such as the above.

          "In any selection of a pretreatment scheme care
     should be exercised to prevent a confrontation between
     industry and the operators of publicly owned treatment
     works.  The benefits of toxic substance control could be
     lost."

Edward E. Phillips, Director of Public Works, City of Hayward,
CA:

          "We feel  that Option II allows the greatest possible
     flexibility with respect to source control  programs.
     Specifically,  it would permit Municipal sanitation agencies
     currently operating under NPDES permit with approved
     source control programs, to continue the orderly admini-
     stration of these programs without having to impose
     federal technology-based standards on their industrial
     dischargers.  In many cases, the imposition of these
     technology-based standards would only result in duplicity
     of efforts, added cost to industry, and no significant
     improvement in the quality of the receiving waters.  As
     in our case, any NPDES approved local source control
     program should and would contain wastewater discharge
     standards designed and tailored to protect the operation
     of the specific publicly owned treatment works and insure
     compliance with NPDES permit conditions and limits
     established for the particular discharge."

E.D. Blum, Coordinator, Environmental Programs, Union Oil
Company of California, Los Angeles, CA:

          "Union Oil and its subsidiaries operate a refinery,
     a fertilizer complex and other smaller facilities in the
     Los Angeles area. These facilities all discharge their
     wastewaters to the various local Sanitation Districts
     (i.e., Joint Sanitation Districts of Los Angeles County,
     Los Angeles City Sanitation District, Orange County
     Sanitation District).

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                         -103-
          "These districts all have pretreatment programs in
     existence with stringent but achievable pretreatment
     standards.  We understand that some of the pretreatment
     requirements imposed on our facilities are necessary to
     protect operation of the treatment plants while others
     are water quality based limits necessary to meet the
     requirements of the California Ocean Plan.

          "We recognize the likelihood that all local  districts
     throughout the country may not have the capabilities of
     the districts in the Los Angeles area.  In these cases,
     the Federal pretreatment standards mandated by the Water
     Pollution Control Act appear to be appropriate.  Any such
     Federal pretreatment standards should be based on a
     combination of pretreatment technology reasonably available
     to the indirect discharger plus removal capabilities of
     publicly owned treatment works.  It is essential  that
     such pretreatment standards be carefully designed to
     prevent duplication of treatment facilities between the
     indirect discharger and the publicly owned treatment
     works."

Mark A. Pisano, Executive Director, Southern California Assoc.
of Governments, Los Angeles, CA:

          "As you know, the larger sanitation agencies in Southern
     California, wich serve major industries such as the electro-
     plating ndustry, have done a capable job overall  in design-
     ing and implementing local pretreatment programs.  The local
     programs consist of ordinances controlling discharges to
     municipal sewers, discharge permits which specify discharge
     limitations, user charges, inspection and monitoring pro-
     visions, and fees for noncompliance with permit conditions.
     These local pretreatment programs involve "good housekeeping"
     techniques by industrial dischargers and, where necessary,
     pretreatment equipment.  The local pretreatment programs
     are making significant progress in allowing sanitation agen-
     cies to meet NPDES limitations based on current EPA and
     State requirements on toxic pollutant discharges.

          "In light of the demonstrated pretreatment capabilities
     of the major sanitation districts in Southern California,
     SCAG supports local development and enforcement of pretreat-
     ment standards, with nationally-developed, uniformly applied
     pretreatment standards applied only if EPA judges local
     pretreatment programs to be adequate.  SCAG supports water
     quality-based variances, on a jurisdictional rather than
     pollutant-by-pollutant basis, with national pretreatment
     standards for the most serious industries and toxic pollu-
     tants being developed as in Option 3 and applied unless
     a water quality variance is granted."

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                         -104-
C.R. Calkins, Vice President-Environment Affairs,  American
Paper Institute,  Inc.,  Washington,  D.C.

          "A number of local  authorities already have imple-
     mented fully adequate and effective pretreatment programs.
     A national  pretreatment  program will  be more  easily and
     effectively begun if these local  programs are allowed
     to continue without an excessive "over-lay" of new federal
     standards and requirements."

Nicholas J. Melas, President, The Metropolitan Sanitary District
of Greater Chicago, Chicago,  IL:

          "Presently, there are numerous local  agencies with
     effective industrial  waste control  programs which account
     for a significant percentage of the nation's  industrial
     dischargers.   As an example, the Metropolitan Sanitary
     District of Greater Chicago  (MSDGC) which serves approxi-
     mately 12% of the total  number of industrial  dischargers
     in the nation has had an active industrial  waste control
     program since 1969.  The efforts of the local  agencies
     should not be delayed or negated by Federal regulations
     but instead should be assisted in continuing  their efforts.
     The objective should be  the  expansion of local  programs
     and not the development  of a whole new set of programs."

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                                      -105-





VIII. ECONOMIC IMPACT OF PRETREATMENT PROGRAMS -







                 Analysis of the public hearing transcripts and written



       materials ubmitted to EPA indicated widespread concern exists,



       among the municipalities required to design and implement pretreat-



       ment programs and the industrial discharges who must absorb pre-



       treatment costs, that promulgation of pretreatment requirements



       will engender significant economic impacts for both sectors.



                 Economic areas of concern to local  governments stem from



       their responsibility for designing and administering pretreatment



       programs.  A  municipality :must enforce whatever pretreatment



       standards are necessary to meet the requirements, prevent violations,



       minimum sludge disposal costs, protect their systems from industrial



       waste damage, etc.  Consequently, there are two fundamental economic



       elements to municipal pretreatment programs:  1) the cost of surveying,



       monitoring and analyzing industrial wastes discharged into the



       local sewer system, and 2) the cost of administering and regulating



       the program.



                 The nature of the pretreatment cost impacts on industrial



       dischargers focuses on several factors: the costs of the pretreatment



       (or self-treatment) facility; the particular industries and pollutants



       requiring regulation; individual plant size, age and operating efficiency;



       production process; capital structure and profitability; and financing



       mechanisms.  The interrelationships between these economic factors



       are extremely complex, especially when one considers that there are



       substantial economies of scale to most pollution abatement processes



       (particularly when end-of-pipe treatment is employed).  Hence, the



       average abatement cost for larger firms is much  lower than that for



       smaller firms.  Additionally, larger firms often have better access

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                                   -106-
to tax exempt financing, which provides an important subsidy for pollution

abatement investments.



          Comments directly addressing the institutional  and industrial

economic impacts of the proposed pretreatment regulations are documented

on the following pages.


A.        The cost effectiveness of the pretreatment standards should
          be the prime substantive factor in formulating  the final
          regulations.

          Charles J. Henry, Director,  Water Pollution Control, Muni-
          cipality of Metropolitan Seattle, Seattle, WA:

                    "Pretreatment standards should be established on the
               basis of cost effectiveness.  Although such analyses are
               recognized in the regulations, there has been an historic
               tendency to establish treatment requirements on the
               technical basis of capability rather than  need. Full
               consideration of energy and other resource consumption,
               water quality needs and economic impacts should be strongly
               stressed to prevent unnecessarily restrictive standards
               and treatment requirements.

                    "Option three represents the most practical approach
               in this respect since it recognizes primary need to con-
               centrate on the major dischargers and most hazardous
               pollutants."

          Joe P. Teller, Deputy General Manager, Gulf Coast Waste Disposal
          Authority, Houston, TX:

                    "This assumption,  which is apparent throughout the
               proposed regulations,  is not valid in all  instances.
               Existing facilities, specifically designed to treat
               industrial wastes and owned by public entities, are in
               operation now and have been for some time.  Should recognition
               not be given to those industrial POTW's, serious economic
               and technical disadvantages would be immediately forthcoming.
               For example, Section 403.4(f) of the proposed regulation
               (Fed. Reg. Vol. 42, No. 22, p. 6497) would prohibit
               influent to a POTW in excess of 40° C (104°F).  An
               industrial POTW, designed in accordance with sound engineering
               practices, would provide facilities to cool these wastes
               in order to provide efficient treatment in the plant.  An
               existing facility which had provided the cooling phase
               would find itself with a capital expenditure item not
               needed,  and the industry discharging the waste would be
               required to construct a cooling phase.  This is clearly a
               waste of capital.  Other examples are known to exist,
               such as the planned commingling of wastes  with extreme

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                          -107-
     variations in pH, giving a resultant mix of the optimum
     pH without the addition of neutralizing chemicals.

          "There is clearly a distinct difference between a
     municipal POTW and an industrial  POTW, yet no distinction
     is found in the proposed regulations.  To overlook  these
     differences would be a direct disservice to water quality
     management, and would pose a totally unnecessary financial
     and technical burden on those parties involved."

Charles A. Geisler, Sanitation Engineer, City of Omaha,
NB:

          "Consider all the pretreatment program standards and
     the situation where a company can jump from one area to
     another based on Industrial  Cost Recovery charges.  This
     in turn could cause overloading of existing facilities
     and NPDES limits or losing a paying customer.

          "Is each violation a separate offense and punishable
     or can they (industry) just dump it all if they're  going
     to pay a $1,000 fine anyway.  Must a company shutdown and
     close immediately if one of the EPA limits is violated?
     If it is to be enforced by ordinance, it must state
     clearly when this is to be the case.  The statement "when
     it endangers health" is too general and not definable.

          "If the POTW has only primary treatment facilities,
     does this mean the pretreatment standards imposed on
     industry would be those of a new point source not dumping
     into a POTW?  If this is true, would there be a need for
     ICR charges?"

John G. Costello, Executive Director,  Bergen County Sewer
Authority, NJ, Statement at Boston Public Hearing:

          "...The Sewer Authority feels that local agencies
     should be responsible for enforcement of pretreatment
     regulations because they are closer to the problem  and
     are familiar with local conditions and would thus be
     better able to implement this program.  However, because
     the potential exists for many legal challenges by industry
     and the legal fees resulting from extensive litigation
     could be prohibitive, the Authority feels that it is
     essential that Federal agencies provide strong backup,
     upon request by the Authority, at such time that we are
     faced with recalcitrant violators. This topic is one of
     our greatest concerns and cannot be emphasized enough.
     Without strong Federal backup available, most local
     agencies could simply not afford the financial impact of
     an effective pretreatment program."

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                                   -108-

B.         The cost to local  government for administering a POTW's pretreatment
          program will  be exceedingly expensive.

          Timothy L.  Morris, Texas Water Quality  Board,  Austin,  TX,
          Statement at Chicago Public Hearing:

                    "The day-to-day administration  of the programs
               envisioned by your proposed rules  will  be extremely
               expensive.   For instance,  our  experience  with  compliance
               monitoring which is comparable to  that being proposed  in
               these  rules indicates that an  average  environmental
               technician working for about $14,000 a year can effectively
               keep up with about 30 industries a year.   If you  take
               that salary figure and apply a 30% factor for  salary cost
               and a  2.25 factor for overhead and support cost,  you will
               find that your pretreatment program  costs about $1,365
               per industry per year.   Considering  that  there are 55,000
               such industries nationally, that means that the cost to
               the local  government for administering the program you
               have proposed will  run about $75 million  annually nationwide.
               That is an expensive water pollution control program.  It
               is particularly expensive  when you realize that the
               average cost  to the industry begin regulated exceeds $100
               each month."

          Frank Dryden,  Head,  Technical Services  Department,  Sanitation
          District of Los Angeles County,  Whittier, CA,  Response to
          Question at San  Francisco Public Hearing:

                    "I  would say in our own case, in  1970 while  we
               were running  the rather  cursory type protective system
               programs that have been  historic,  we had  a very small
               staff  devoted to source  control, approximately five
               inspectors  and  two  engineers.  We  now  have 13 or  14
               inspectors,  plus the availability  of the  county engineers,
               inspectors, and  we  have  a  staff of about  40, most  of whom
               are engineers,  involved  in  our industrial  waste program.

                   "The  cost  is half a million to  a million dollars  a
               year type  program.   That covers everything  we do  now.
               It's not  --  It's not an  expensive  program.  It is, and
               properly  should  be,  covered  by the charges  to  industries
               that cover  our  system.   Because it is  not  an inexpensive
               program, we really  don't like  having to do  anything more
               than we can show needs to  be done."

          Don T.  Howell, Director  of Utilities, Board of  Light and Water
          Commissioners of the  City of Concord, Concord,  NC:

                   "We in the  City of Concord, North Carolina have
               been working  for more than  five years attempting  to

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                         -109-
     produce and construct a regional treatment
     plant.   Exhaustive efforts have gone into d^/eloping a
     program that  wiTl  benefit all  sections of our county
     (Cabarrus).   With the enactment of PL 92-500 everyone had
     the feeling  that the battle had been won and we were at
     last on the  way to cleaning up the environment.  Great
     strides have been made,  but roadblock after roadblock has
     caused  delays and increases in projected costs.

          "Pretreatment requirements as proposed represented
     still  another roadblock.   As the development of the
     Concord regional plan matured, using EPA's ever changing
     guidelines,  primary clarifiers with chemical precipita-
     tion were approved in the initial  grant application.
     After final  plans and specifications were prepared and
     approved, the primary clarifiers were declared ineligible
     for grant participation.   Local and industrial funds were
     secured to construct the primary clarifiers to be used
     exclusively to remove industrial pollutants.  This entire
     cost is to be paid by the affected industries.  It is
     realized that additional  sludge is to be expected from
     facilities of this nature, but at the same time dewatering
     and incineration facilities are under construction to
     dispose of this sludge in an environmentally acceptable
     manner.  If facilities such as these are to be duplicated
     at every industrial plant, it will be impossible to be
     cost effective."

Robert R. Matthews, Manager,  Water and Sewer Commission, City
of Freeport, IL:

          "We are a certified municipal laboratory and POTW
     that are presently running an extensive monitoring program,
     sometimes successfully,  and sometimes not.  Industry in our
     city is responsive to our requirements and we are probably
     an excellent candidate for a local compliance program,
     whichever option you may choose.  I do not take exception
     to the proposed regulations but I do raise the question
     of how to pay for the local government participation.

          "Sections 201 and 208 are not enough.  Construction
     grants are necessary when facilities are built, but by
     and large the thrust of these regulations will be on
     municipalities with already built facilities.  Indeed
     in strict interpretation a local compliance program would
     require this.  Therefore, E.P.A. should consider some
     sort of remuneration to the municipality that is opera-
     ting a  certified monitoring and laboratory program in
     the form of an operating grant.  The administration
     could be simply tied to the local  compliance program
     application and approval.  In my opinion, the success
     of the proposed regulations depends on this provision."

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                              -no-
Robert G. O'Dette Environmental  Engineer, Statement at Washington,
D.C. Public Hearing:

          "The disregard for many economic considerations,
     from an engineering and consumer point of view is most
     distressing.  The only costs mentioned in the Register
     were $15 to  $85 million for reporting requirements, and
     less than $1 million for compliance.  The following
     conservative estimate will  show that actually this cost
     may well exceed  $300 million for compliance alone ...

          "Under the  new regulation, pretreatment will be
     required regardless of flow, and with very little consideration
     for economic impact.  Although it is difficult *to generalize
     a cost for the physical-chemical pretreatment works, an
     engineering estimate of amortized capital costs,  operation,
     and maintenance, chemical  and power costs would be about
     $50,000 per year for ten years.

          "There are  over 400 POTW's in the State of Tennessee
     alone.  If only half these municipalities had only one
     industry, similar to the one described that would be
     affected by the  change in regulations, the cost in Tennessee
     alone would be $10 million.   Considered over the  50
     states, the cost could exceed $300 million, and this is a
     very, very conservative estimate, I believe.

          "EPA further states that an economic impact  analysis
     will be performed for each pretreatment regulation when
     it is prepared and promulgated.  I contend that economic
     evaluation at this time is too late.  It is conceivable
     that the economic impact of any one subcategory regulation
     may not exceed the $100 million; however, a total economic
     impact of the overall program could be devastating."

W.C. Trefz, Chief Engineer, Allegheny County Sanitary  Authority,
Pittsburgh, PA:

          "All options will require considerable local monitoring
     and testing.  All costs of local monitoring required for
     this program should be reimbursed by EPA.  This would
     include cost of  the system monitoring, sampling and lab
     analysis.  Our best estimate of the Alcosan (Allegheny
     County Sanitary  Authority)  costs of the new regulations
     for our system would be as follows:

     One time initial expense for purchase of equipment    $565,000.00

     Estimated annual increased operating costs          " $245,000.00"

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                          -111-
Gene B. Welsh, Chief-Water Protection Branch, Georgia
State Dept. of Natural Resources, Atlanta, GA:

          "The application and enforcement of a pretreatment
     program under any of the options would be similar to
     the NPDES program which we now administer with direct
     industrial dischargers.  However, the new program would
     require an expenditure of resources at least equal
     to and perhaps exceeding that of the industrial  NPDES
     workload  in the State and therefore would require some
     8 to 10 additional staff members in this agency to
     administer it.  We also believe that the programs out-
     lined are so ambitious that EPA may have to double its
     NPDES staff in order to administer the program.   It is
     folly to  believe that the states or EPA could handle
     these additional responsibilities without substantial
     increase  in staffs."

Gary F- Levy, Director, Jefferson County Dept. of Environmental
Quality, Louisville, KY:

          "All of these functions create an additional cost to
     the local authority because of the increase in manpower
     requirements, the need for additional equipment, an increase
     in support services such as laboratory analysis, the uti-
     lization of legal counsel for enforcement activities, and
     the increase in administrative services.  Federal funds
     apply only to the cost of initial program development.
     The long term cost of operation and maintenance are to be
     funded by the system users."

Mark S. Davis, Secretary, Technical Advisory Committee,  India-
napolis Chamber of Commerce, Indianapolis, IN:

          "It appears that the City of Indianapolis will be
     required to expend approximately $600,000 in first year
     start-up costs for an adequate industrial pre-treatment
     program.  This rough estimate indicates a substantial
     need for additional federal assistance in the form of
     a grant.  I strongly suggest that these types of start-up
     expenses are not an appropriate item for industrial cost
     recovery, but rather should be funded solely by a first
     year federal grant."

Peter A.A. Berle, Commissioner, New York State Dept.  of Environ-
mental Conservation, Albany, NY:

          "We estimate that there are 6,000 industries in the
     State that have process wastewater discharges into POTW's
     with a total combined flow also of 1 BGD.  In summary
     the pr.etreatment program in New York State will  involve
     approximately four (4) times the number of industries

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                         -112-
     as the NPDES permit program with approximately the same
     amount of flow as industrial  facilities  subject to NPDES
     permits.

          "To  further assess the impact of the proposed regu-
     lations,  it is estimated that of the 6,000 industries  dis-
     charging  to POTW's, we will  have significant  involvement
     with approximately 3,000 because of the  presence of incom-
     patible pollutants.  This general, but realistic,  estimate
     of the numbers of POTW's and industries  involved,  has  led
     us to conclude that financial  aid and manpower resources
     in excess of four (4) times that presently committed by
     New York  State to the implementation of  the POTW and
     industrial waste portion of the NPDES permit  program
     will be required.  This estiamte does not include  the
     commitment of resources on the local  level.

          "This significant program implication requires that
     New York  State insist that sufficient funds be made available
     for the establishment, implementation and continuation of
     a pretreatment program."

Nicholas J. Melas, President, The Metropolitan Sanitary District
of Greater Chicago, IL:

          "A direct enforcement program by either  the EPA or
     the NPDES states would require an inordinate  expenditure
     of manpower and monies, and in many cases duplicate some
     of the efforts of existing local  industrial waste  control
     programs; e.g. sampling, compliance reviews.   Even with
     Federal enforcement programs the local authorities would
     still have to carry out programs of their own to prevent
     interference from non-regulated industries or pollutants
     with the  POTW's operation.

          "As  an example of the magnitude of  proper enforcement
     of a local industrial waste control  (a pretreatment) program,
     the MSDGC's program currently requires a staff of  100
     full-time professional, technical and clerical  employees
     at an annual cost of about $2.5 million.  This is  to keep
     account of approximately 6,000 concerns  which discharge
     liquid industrial wastes to the sewer system  for treatment
     in the MSDGC treatment plants."

Randy Laks, Jefferson County Sewer District,  Louisville, KY,
Statement at Chicago Public Hearing:

          "We  have dorie some estimating. We are in this process,
     going about this right now.  So, we have some idea of  what
     it costs.  We are projecting out that it's going to take
     us about  a year and a half to get around to 210 quote,
     unquote,  "major contributing industries."  And the esti-
     mated cost of this program, just going around and  building
     the data  base, first time around the labor cost is some-

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                         -113-
     where in the neighborhood of $600,000.   We also need
     some additional  equipment, especially when you are
     getting into the organic contents.   The cost associated
     with some of the additional  equipment above of what we
     already have would be about $220,000."

James Brannan, City of Ft. Smith, AK, Statement at Chicago
Public Hearing:

          "Development of a local pretreatment program in
     the equipment for and except in monitoring and enforcement
     program will cost an estimated $80,000.  This is the
     initial cost.  The estimated cost of a  continuing program
     of monitoring and enforcement is $30,000 per year."

Gene Jensen, Kansas State Bureau of Water Quality, Topeka, KA,
Statement at Chicago Public Hearing:

          "Our estimate for Kansas is that if the State admin-
     isters the program totally, or if some  combination of
     State and local  government were to administer the program,
     it would cost approximately $500,000 per year.

          "We estimate that the cost of industry in Kansas,
     and there are some 4,400 industries that would be regulated,
     might amount to another two to 20 million dollars per
     year.

          "This sort of suggestion, nationally that the cost
     might be in the nature of a quarter of a million dollars
     and it might go four or five times that."

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                                     -114-
C.        The cost of pretreatment programs to industry could force,
          plant relocations, unemployment, plant closings, dispropor-
          tionate payments by certain industries of user charges and
          and industrial  cost recovery funds,  etc.

          Alan C. Van De  Boe, Superintendent of Sanitation, City of
          Quincy Sanitation Committee, Quincy, IL:

                    "A major concern involves  the cost of providing pre-
               treatment.  If the pretreatment standards are too restrictive
               causing an industry to construct and operate an expensive
               pretreatment facility, it may be less expensive for that
               industry to totally separate itself from the municipal
               system, rather than pay for not only the pretreatment
               facilities, but also the User charges and Industrial Cost
               Recovery Charges mandated by Federal  law.  If an industry
               were to separate from the municipal  system, the User
               charges paid by other industries and by residential  users
               would increase, perhaps causing other industries to reach
               the point  where it is cheaper to go  it alone.  From the
               standpoint of financing the operation of a municipal
               treatment  facility, it is absolutely essential that as
               many users as possible are served by the system.  Restrictive
               pretreatment standards encourage separation of industrial
               users from municipal systems and are contrary to this
               philosophy.

                    "One  aspect of the proposed regulations would be of
               great benefit namely, the use of part of the Industrial
               Cost Recovery (ICR) funds to finance the development
               and enforcement of locally-derived pretreatment
               limits. One argument against local enforcement is
               the general lack of funding at  the local  level for
               such a program. Under the current regulations, 50%
               of the amount of ICR funds collected is to be sent
               to U.S. EPA, 40% is to be retained and placed into a
               restricted account while the final 105 can be used
               at the discretion of the municipality.  The concept
               of restricting some of the ICR  funds for use only
               for expansion or reconstruction of the municipal
               treatment  facilities is beneficial and should remain
               at 40%.  It is suggested that the amount of discretionary
               funds be increased from 10% to  25% of the amount of
               ICR funds  collected.  Since the ICR  monies do come
               from industrial users, they should be used to finance
               the programs intended to regulate those same industrial
               users.   The 25% figure should generate sufficient
               funds to effectively carry out  a pretreatment program."

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                        -115-
C.J. Buschkill, Manufacturing Engineer, George Koch Sons,
Inc., Evansville, IN:

          "A very small plater or other business, requiring
     waste water treatment might be able to survive if it were
     allowed to pay a surcharge to the local  treatment fa-
     cility to correct its deficiencies.  This procedure,
     placed within the judgement of a local governing body,
     could respond to individual probabilities.   The state and
     certainly the federal level could never be adaptable to
     the flexibility required for this possible approach."

Richard Wooley, Metal Finishing of Southern California,
Burbank, CA, Response to question at San Francisco Public
Hearing:

          "...there was an area that was indicated on Page
     6485 that no variance would be allowed unless the POTW
     had complete secondary treatment.

          "Now, as we discussed, there is a --there is a
     timing problem there because of funding, engineering
     considerations.  A number of POTW's will not have secon-
     dary treatment in force for several years.   And if this
     statement were followed exactly, it would mean that no
     variance could be applied for until such secondary
     treatment was, in fact, in full operation.

          "This might require real capital  expenditure by
     industry for a matter of one, two or three years, and
     then would no longer be necessary, and that would be an
     unduly harsh economic impact."

Pearce Klazer, Division of Water Supply and Pollution Control,
Rhode Island Department of Health, Statement at Boston Public
Hearing:

          "...There are several serious concerns inherent in
     the proposed pretreatment rules that in our opinion may
     have the potential of reversing, rather than augmenting,
     recent efforts to improve the quality of our nation's
     waterways. For example, now with hefty industrial cost
     recovery charges mandated by PL 92-500, municipal sewer
     user charges and fees, now to be combined with pretreatment
     requirements and costs, which may approach those of BAT,
     there leaves little inducement for those industreies to
     consider using or even remaining in municipal sewage
     systems when instead they can obtain a NPDES permit and
     treat their own wastes, and in doing so, be eligible for
     an IRS write-off, SBA loans, a variety of state economic
     development aid, as well as state sales tax and property
     tax exemptions."

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                    -116-
Theodore Garrett, Counsel, National  Association of Metal
Finishers, statement at Washington,  D.C.  Public Hearing:

     "The National Association of Metal  Finishers repre-
spectrum of the electroplating and metal  finishing industry.
Members of this industry, typically, are small  firms in
urban areas, which of necessity discharge into municipal
treatment plants, and which have neither the physical
space nor the financial resources to install expensive
pretreatment technology.

     "The Association justifiably fears that the promulgation
of pretreatment standards which are more stringent than
necessary, may sound a death knell for a large portion of
this industry."

Marvin Rivland, Counsel, Compliance Operations, City of
New York, New York, response to questions at Washington,
Public Hearing:

     "Now, with respect to pretreatment standards, virtually
the only industry in New York which will  be affected by
pretreatment standards will be the electroplating industry...
There are about 200 electroplaters.   There were several
years ago.  I have no reason to believe that that figure
has changed.

     "Now, if strict standards are imposed, and thinking
in terms of the substantial background levels,  if strict
standards are imposed upon this industry, we figure that
80 percent of them -- 80 percent -- will  either have to
close up or move.

     "The reason is not only financing,  which is horrendous,
but also room, and you mentioned this in the discussion
of your February 2nd publication.  There  of these job
plating shops to install the kind of precipitation equipment,
if that is the best practical  technology, and at present
I think it is.  I have no reason to believe that reverse
osmosis, ion exchange has come into its own.

     "It is chemical precipitation.   There is no room
for the installation of this type of technology, the
equipment that goes with it.  The industry would certainly
have to move, or members of the industry would have to
move.

     "They would move to places where they could have
more land for the installation of the equipment. That
means to New York City a loss of 1,000 to 1,500 jobs."

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                         -117-
L.K. Duncan, Plant Manager, Davison Chemical  Division,  W.R.
Grace & Co., Chattanooga, TN:

          "National technology-based pretreatment standards
     are not mandated by PL 92-500, and would lead in many
     instances to "pretreatment for treatment's sake",  regardless
     of POTW operations and effluent quality.  The national
     economic result of such measures would be of sufficient
     magnitude to mandate national  and regional Economic
     Impact Analyses by the EPA.  The adverse effect on national
     energy resources would be enormous.  A secondary ultimate
     consequence would be withdrawal of many industries from
     POTW systems in favor of direct stream discharge,  thus
     imposing severe future economic burdens on POTW's."

John J. Burnett, Director of Utilities, City of Niagara Falls,
NY:

          "Please be advised that the city of Niagara Falls,
     New York wishes to take a strong stand for pretreatment
     standards similar to Option 3.  The publicly owned treatment
     works is in initial stages of the largest industrial
     users.  These 24 have contractural obligations to  the
     city for their proportionate shares of both capital
     funding and operation and maintenance monies, since 1971
     they have recognized their obligations for pretreatment
     in order to conform to the local sewer ordinance,  the
     city is unalterably opposed to any opinion that may force
     these industrial users to discontinue participation in
     the local program for economic reasons."

Bruce D. Miller, Assistant Plant Manager, Kidde Chestnut
Operating Co., Reading, PA:

          "Specifically we are a city based industry without
     space to add pretreatment equipment, but our local P.O.T.W.
     can and does handle our effluent properly on a surcharge
     basis.

          "We are satisfied, they are satisfied, and the
     effluent leaving the P.O.T.W.  is satisfactory.

          "Pretreatment regulations would unnecessarily cause
     jobs to be lost where a problem does not exist."

W.P. Anderson, Assistant Director, Environmental and Regula-
tory Affairs, Tenneco Chemicals, Saddle Brook, NJ:

          "Development of the Federal Guidelines must also
     consider that the typical plant discharging to a POTW  is
     an older and smaller plant located in a congested urban
     area. Because of its location,  it may not have the option
     of discharging directly to public waters.  Many such
     plants have very limited space available for the construction
     of extensive pretreatment facilities.  Because of their
     age and size, such plants are frequently marginal  economic-

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                         -118-

     ally, and,  therefore,  the  addition of any cost burden
     will  be a very serious concern to them.   Individual  plant
     economics,  of course,  cannot be allowed  to rule out
     treatment to the extent required, but should be weighed
     very carefully in determining just what  is required in
     order to meet the objectives stated earlier. Treatment to
     the extent possible within the limits of technology (for
     the sake of treating to that extent)  should not be required
     unless it is necessary to  achieve the objectives."

Marwan Sadat, Program Director, Office of  Sludge Management
and Industrial Pretreatment, New Jersey Department of Environment,
Statement at Boston Public  Hearing:

          "Option II and III place heavily industrialized
     states in a difficult  position.  These options would
     encourage shopping by industries wishing to relocate.
     Many surface waters in these states are  water quality
     limited. And, therefore, would result in much more strin-
     gent industrial water  pretreatment standards.  The
     implications of the situation are quite  obvious.

          "Our problem in New Jersey, in the  Northeast is
     especially complex.  Some  authorities in New Jersey have
     industrial  discharges  into municipal  systems which number
     in the hundreds.  And, in  one specific case upwards of
     2,000 industries discharge into a single municipal system.
     We estimate there are, in   New Jersey, approximately
     12,000 indirect dischargers while 900 industries discharge
     directly in our streams.  We must, therefore, carefully
     consider which of these options could be easily developed
     within our own legislative framework  and which would be
     most effective in achieving our water quality goals."

Allen R. Frischkorn, Jr., Attorney,  GTE Service Corp., Washington,
D.C.:

          "GTE is concerned that the imposition of mandatory
     pretreatment standards on  small concerns will cause such
     concerns to go out of  business.  In accordance with
     corporate policy, the  GTE  manufacturing  companies attempt
     to utilize small and emerging sources of supply wherever
     practical.   It is essential in our view  that the agency
     must not adopt pretreatment regulations  which would be
     burdensome to these small  sources and for whom costs of
     compliance would be prohibitive.  In  this same regard, we
     note that plants which utilize a POTW incur substantial
     costs through user charges, industrial cost recovery,  ad
     valorem taxation, property assessments,  etc., none of
     which are borne by direct  dischargers."

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                         -119-
Thomas E. Roberts, Supervisor of Environmental  Control,
Celanese Polymer Specialties Co., Louisville, KY:

          "Economic Impact - The economic impact of a general
     regulation that establishes ground rules and  procedures
     to be used to develop a national  pretreatment program is
     going to be significant.  This new national pretreatment
     program could easily cost CPSC $3 million to  $4 million in
     capital outlays and $0.5 to 1.0 million in annual  operating
     expenses, over what we would have to spend to comply with
     existing POTW ordinances; and CPSC is just one small  company.
     An option, like IV, that requires redundant treatment
     facilities could cost significantly more.  We believe these
     general regulations, no matter which option is selected,
     definitely have a economic impact greater than $100 million
     per year."

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                                   -120-
D.        The energy implications of implementing  the  pretreatment
          program have not been  investigated  or  quantified

          E.F.  Young,  Director,  Environmental  Affairs,  American  Iron  and
          Steel  Institute, Washington,  D.C.

                    "The energy  situation  is  another reason  for  flexibility.
               The energy crunch has developed since enactment of Public
               Law 92-500; while this in no way  changes this law, energy
               considerations must be given increased  emphasis along
               with the environmental  considerations to achieve  the
               maximum social  good.   Providing flexibility to take into
               account variations in POTW  removals to  meet water quality
               standards, and getting standards  for only the most significant
               toxics, gives the greatest  possible energy savings, as
               there is not treatment for  treatment's  sake or just cause
               we know how to treat--treatment is  required only  to
               protect the POTW  and  maintain  water quality.  Management
               of discharges and management of operation of  POTW's
               keyed to protecting the  environment will  give the best
               return  of investment  and save  the most  energy, while
               encouraging the treatment of industrial  wastes in POTW's."

          Timothy::!. Morris,  Texas Water Quality Board,  Austin,  TX,
          Statement at Chicago Public Hearing:

                    "Realizing that  the resources  of the regulatory
               agencies are limited,  that  pretreatment  systems will
               place high demands on energy and  other  natural resources,
               and considering what  these  programs will  do to product
               cost and other inflationary pressures,  we believe very
               strongly that prior to implementation of the  program,  its
               cost must be very critically appraised  in light of the
               benefits to be derived."

          Jack  M.  Betz,  Director,  Bureau of Sanitation,  Los  Angeles,
          CA:

                    "To require  the  Best Practicable Control Technology
               Currently Available (BPTCTCA)  when  NPDES  requirements
               were already met  would  involve  heavy expenditures of
               energy  which would  be wasteful  of resources and would  add
               further pollutants  to the air,  water and  land environ-
               ments.

                    "Cost effectiveness in terms of environmental improve-
               ment involves balancing fund availability with needs in
               terms of the control  of possible  pollutants to the air,
               land or water.  If  NPDES requirements for POTW discharges
               to  the  waters  can be  met with  the changes outlined above,
               it  would not be a cost effective  solution to  require
               BPCTCA.   Estimates  for the  City of  Los Angeles indicate
               that satisfactory results can  be  obtained at  about 25% of
               the cost of BPTCTCA."

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                         -121-
Raymond Kudukis, President of the Board of Trustees,  Cleve-
land, Regional Sewer District, Cleveland, OH, Statement
at Washington, D.C. Public Hearing:

          "While in theory uniform nationwide technology-
     based standards for each class and type of industry
     may appear to be desirable, in reality, the nation at
     this point in overally environmental benefits to be
     achieved by this objective may not outweigh the  total
     costs.

          "We, in the Mid-West, having faired the worst
     winter on record, and having suffered severe energy
     curtailments, are particularly sensitive and conscious
     of energy problems.  Therefore, we believe that  energy
     must be utilized in the most cost-effective manner,
     and can find little justification for treatment  for
     the sake of treatment.

          "I would like to see an energy impact statement,
     in terms of any one of these projects."

Bill B. Dendy, Executive Officer, California State Water Re-
sources Control Board, Sacramento, CA:

          "To require the equivalent effluent quality for dis-
     charges to all water bodies, in our opinion, can represent
     a substantial waste of the energy and other resources in
     many cases.  Regardless of its impact on the individual
     industrial discharger, this is the sort of waste of resour-
     ces that this country simply cannot afford."

Henry B. King, President, United Brewers Association, Inc.,
Washington, D.C.:

          "The USBA believes that an Economic Impact  Analysis
     should be prepared prior to the issuance of final pre-
     treatment regulations.  Both the economic and energy
     usage impacts of the proposed regulations need to be
     fully explored and discussed.  By the Agency's own ad-
     mission the proposed national pretreatment program
     dwarfs the NPDES Program.  Although the proposed
     40 CFR 403 alone may not result in economic and  energy
     impacts of sufficient magnitude to trigger an Economic
     Impact Analysis Statement, it is the keystone of a
     national pretreatment strategy which is actually being
     established.  While the numerous regulations governing
     pretreatment for individual industry subcategories may
     not justify an extensive analysis, certainly the program
     as a whole does."

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                                    -122-

E.         What is the feasibility of implementing  Industrial  Cost
          programs in small  municipalities when  its  economic  benefits
          In liarge municipalities iare suspect?


          Jack Barren, Division Engineer,  Industrial  Waste Division,
          Department of Public Works, San  Francisco,  CA,  Response to
          question at San Francisco  Public Hearing:

                    "I would like also to  address  the comments that you
               solicited on  the industrial  cost  recovery  program.  In
               the case of San Francisco,  our program for water pollution
               is about $1.5 billion total  at this time.  And  when you
               look at the possible  amount that  can  be recovered on an
               industrial cost recovery basis,  it's  very  negligible,  and
               I believe and I think very  difficult  to collect administratively
               because, when you start to  separate out domestic waste,
               sanitary waste, etc., it would be very, very cumbersome.

                    "A large part of our program is  for wet weather
               handling because we have a  combined system. On that
               basis, I don't believe -- And  I  have  no facts  to back
               this up at this time  -- but it would  seem  that industry
               may not be required to contribute very much under the
               industrial cost recovery program  be eliminated."

          John G. Costello,  Executive Director,  Bergen County Sewer
          Authority, NJ, Statement at Boston  Public  Hearing:

                    "An additional  compliance incentive suggested is
               to increase the present allocation  of 10 percent of re-
               covered industrial  cost recovery  payment which may be
               used as the grantees  sees fit  that's  40 CFR 35.928-2 (B).
               Upon completion of its current plant  expansion from 50
               million gallons to 75 million  gallons the  Bergen County
               Sewer Authority, under its  ICR Program, will recover
               approximately $180,000 per  year  for 30 years.   This would
               result in an  allocation of  $18,000  per year to be used at
               its discretion.  However, the  cost  to  operate  the ICR
               Program is estimated  at $100,000  annually  and  the annual
               cost of enforcing a  pretreatment  program is expected to
               be at least $100,000.  Therefore, we  suggest that 100
               percent of ICR payments be  made available  to local authorities
               to use as they see fit.   These funds  would most likely be
               applied to the combined cost of financing  the  ICR and
               pretreatment  programs.  It  must  be  recognized, however,
               that any change in allocation  of  ICR  payments  may require
               modification  of Section 204(B) (3)  and possibly other
               sections of Public Law 92-500."

          Raymond Kudukis, Presdient of the Board  of Trustees, Cleveland
          Regional Sewer District,  Cleveland, OH,  Statement at Washington
          D.C., Public Hearing:

                    "As a positive incentive  to  those willing to accept
               the burden of regulating industry within their system,

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                         -123-
     and agreeing to maintain their POTW effluent within
     EPA's limits, Public 92-500 should be changed to
     permit them to retain 100 percent of all  industrial
     cost recovery monies collected, and to utilize these
     monies for any wastewater related purposes.   While
     many may debate the merits of ICR, as long as it re-
     mains a requirement, all monies collected should be
     retained by the local agency."

Seymour A. Lubetkin, Chief Engineer, Passaic Valley Sewerage
Commissioners, NJ, Statement at Washington, D.C.  Public
Hearing:

          "This type of program will simplify things for the
     federal government, but will add cost to the local
     agency's administration.  We, at PVSC, will  undoubtedly
     increase our staff by approximately 40 people on this
     industrial control item alone, and we feel we should be
     reimbursed by having 100 percent of the industrial cost
     recovery monies being returned to us, to finance our
     monitoring program, as I am not implying that monitoring
     would be eliminated."

Karol Mi' Enferadi, Chairwoman, Industrial Wastewater Subcommittee,
California Water Pollution Control Association, Pasadena,
CAi

          "Regarding the question of a possible increase in
     the percentage of industrial cost recovery charges
     collected that a grantee might be permitted to use for
     any purpose, Subcommittee consensus is that publicly
     owned treatment works be permitted to use, for any purpose,
     100 percent of the funds collected.  The local agency
     could keep all recovered funds and channel monies back
     into the local pretreatment program, thereby reducing
     everyone's costs.  Some represented agencies report that
     the amount of monies under consideration is negligible
     and that administrative costs often outweigh the value of
     the current ten percent.  Therefore, this Subcommittee
     recommends that the Industrial Cost Recovery Program be
     eliminated."

Roger E. Krempel, et. al., Water Utilities Director, Fort
Collins, CO:

          "ICR funds is well intended, but the present ten
     percent is not sufficient to finance existing ICR operating and
     accounting expenses.  To comment on an estimated  increase
     in retained funds to finance a proposed program, the
     extent and demands of which are totally unknown,  is
     purely a guessing game.  The fact that local municipali-
     ties need a higher percentage of these ICR funds, with or
     without this proposed pretreatment program, is a foregone
     conclusion."

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                          -124-
William E. Korbitz, Manager, Metropolitan Denver Sewage
Disposal District No.  1, Denver, CO:

          "In connection with industrial  cost recovery, it
     is suggested that the industrial  cost recovery provisions
     be eliminated from the Act.  If this cannot be done,
     a minimum of 50 percent of the recovered moneys should
     be retained by the local agency to help cover the admin-
     istrative costs of the ICR program."

L.A. Grosmaire, Chairman, Tennessee Manufacturers Association,
Nashville, TN:

          "It is not readily understood how the Environmental
     Protection Agency could say that the application of BAT
     to the removal of the metals and other toxics concerned
     in these regulations would be accomplished nationwide
     for less than $100 million.  In Tennessee alone, these
     technology based standards would result in untold millions
     of new capital dollars as estimated  by the Tennessee
     Department of Economic and Community Development.  This
     estimate extrapolated nationwide could result in billions
     of dollars of unproductive capital added to industry costs.
     We therefore urge the EPA to determine these economic costs
     first in order to better evaluate a  direction to proceed.
     Since the separation processes required in pretreatment
     have a significant energy need,  this critical category
     should also be evaluated prior to selection and promul-
     gation of pretreatment requirements."

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                                   -125-
              LOG OF LETTERS WITH OPTION PREFERENCE AND MAJOR
                             POSITION ON:
         PROPOSED STRATEGY OPTIONS FOR PRETREATMENT STANDARDS
                        (in alphabetical order)
Abraham, Milton E..Chairman, Industrial  Liaison Committee,  Niagara  Falls
     Area Chamber of Commerce, Niagara Falls,  NY  14303  (dated:  April  5,
     1977)

     Option Preference:  III
     Major Position:  Prefers local control

Adams, William R., Jr., Commissioner, State of Maine,  Dept.  of  Environmental
     Protection, State House, Augusta, ME  04333 (dated:  April  28,
     1977)

     Option Preference:  None
     Major Position:  Prefers Utilization of existing  NPDES system

Anderson, W.P., Assistant Director of Environmental  and  Regulatory
     Affairs, Tenneco Chemicals, Park 80 Plaza West-1, Saddle Brook,  NJ
     07662 (dated: April 29, 1977)

     Option Preference:  III
     Major Position:  Prefers local control

Anderson, Jean, Chairman, Environmental  Quality Committee,  League of
     Women Voters of the United States,  1730 M St.,  N.W., Washington,
     D.C.  20036  (dated:  May 11, 1977)

     Option Preference: I & IV Combination
     Major Position: Concerned with sludge recycling

Andrews, T.O., Manager-Environmental Protection, Hammermill  Paper Co.,
     Erie, PA  16533 (dated: April 28, 1977)

     Option Preference:  None
     Major Position:  Concerned with duplication with existing  pretreatment
                      programs

Atherton, Holt, Chairman, Greater San Antonio Chamber of Commerce,  602
     E. Commerce, P.O. Box 1628, San Antonio,  TX  78206 (dated:  April
     28, 1977)

     Option Preference:  III & II
     Major Position:  Prefers water quality variances

Baker, William C., Director of Public Works, City of Burlington, Box
     1358, Burlington, NC  27215 (dated: March 14, 1977)

     Option Preference:  II
     Major Position:  Prefers local control

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                                   -126-
Banks,  J.  Taylor,  et.  al.,  Natural  Resources Defense Council,  Inc.,
     917 15th St.,  N.W.,  Washington,  D.C.,  20005  (dated:   May 24,  1977)

     Option Preference:   IV
     Major Position:   Concerned with  inadequacy of EPA's proposed
                      regulations

Barry,  Donald R.,  Director  of Industrial  Relations, Industrial Management
     Council  of Rochester,  N.Y., Inc.,  12 Mortimer St.,  Rochester,  NY
     14604 (dated:   May 17, 1977)

     Option Preference:   None
     Major Position:   Prefers national  standards with local  enforcement

Bassett, Gilbert W.,  Executive Director,  Environmental  Conservation
     Board of the Graphic Communications  Industries, Inc., 4615 Forbes
     Ave., Pittsburgh, PA  15213  (dated:  May 10, 1977)

     Option Preference:   II
     Major Position:   Prefers water quality standards

Batchelor,  William H.,  City Manager, Rocky Mount, NC 27801  (no date)

     Option Preference:   II
     Major Position:   Prefers local control

Bennett, Frank C., Chairman, Rochester Section Inc., American  Chemical
     Society, Rochester,  N.Y. (dated:  May  3, 1977)

     Option Preference:   None
     Major Position:   Concerned with certification of monitoring personnel

Benson, T.L., Jr., Vice President,  Composite Can Div.,  130 S.  Bemiston
     Ave., Clayton, MO  63105  (dated:   May 4, 1977)

     Option Preference:   III
     Major Position:   Prefers local control

Berle, Peter A.A., Commissioner, NYS  Dept.  of Environmental  Conservation,
     50 Wolf Rd., Albany, NY  12233 (dated: March 7, 1977)

     Option Preference:  IV
     Major Position:  Prefers addition of variance for incidental removals

Best, Charles W., Sr.  Chemical Engineer,  J.H. Baxter & Co., 1700 S.  El
     Camino Real, San Mateo, CA  94402  (dated:  April  25, 1977)

     Option Preference:   II
     Major Position:   Prefers local control and water quality variances

Betts, C. Nevin, Hi rector-Environmental Activities, Sonoco Products Co.,
     Hartsville, SC  29550  (dated:  May 18, 1977)

     Option Preference:   III
     Major Position:   No rational

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                                   -127-
Betz, Jack M. Director, Dept.  of Public Works,  City of Los Angeles,
     Rm 1140, 200 N. Main St., Los Angeles,  CA   90012  (dated:  March  31,
     1977)

     Option Preference:  II
     Major Position:  Prefers local control

Beweley, James B., Superintendent-Water Quality Control,  South  Bayside
     System Authority, 666 Elm St., San Carlos, CA  94070 (dated:  May
     13, 1977)

     Option Preference:  II
     Major Position:  Prefers water quality variances

Biros, John A., Village of North Tarrytown,  Dept.  of Water and  Sewer,
     28 Beekman Avenue, N. Tarrytown, NY 10591  (dated:  April  29,  1977)

     Option Preference:  II
     Major Position:  Prefers local control

Bisco, Harry, P.E., Director of Operations,  City of Allentown,  PA, 18101
     (dated: April 29, 1977)

     Option Preference:  None
     Major Position: Prefers Federal standards  and local  control

Blabum, Carl J., Director, State of Wisconsin,  Dept. of Natural Resources,
     Box 7921, Madison, WI  53707  (dated:   May 5, 1977)

     Option Preference:  None
     Major Position:  Prefers local control

Bliss, Frederick R., Technical Manager, Strathmore Paper Co., Westfield,
     MA 01085  (dated:  May 18, 1977)

     Option Preference:  II & III Combination
     Major Position:  Prefers local control

Bloch, Ethyle R., Co-Chairman, Clean Water Committee, Izaak Walton
     League of America Inc., Ft. Wayne Chapter, IWLA, 6340 Donna  Dr.,
     Ft. Wayne IN  46819   (dated:  May 4, 1977)

     Option Preference:  IV
     Major Position:  Concern with environment  through strong pretreatment
                      program

Blum, E.D., Coordinator-Environmental Programs, Union Oil Co. of  Calif.,
     Union Oil Center, Box 7600, Los Angeles, CA  90051  (dated:   April
     29, 1977)

     Option Preference:  III & II
     Major Position:  Prefers local control  and water quality variances

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                                   -128-
Boecklin, George E.,  President,  National  Coffee Assoc.  of U.S.A.,  Inc.,
     120 Wall  Street, N.Y., N.Y.   10005  (dated:   May 13, 1977)

     Option Preference:   III
     Major Position:   Prefers local  control

Booman, Keith  A., Ph.D.,  Technical  Director,  Soap and Detergent  Assoc.,
     475 Park  Ave.  South, N.Y.,  NY  10016  (dated:   May 13,  1977)

     Option Preference:   Combination of II  and  III
     Major Position:   Prefers water quality standards

Boone, Eugene, President, John Inglis Frozen  Foods  Company,  P.O. Box
     311, Modesto,  CA  95353 (dated: April  14,  1977)

     Option Preference:  I
     Major Position:  Increase time frame

Borchardt, Robert J., Chief Engineer and  General  Manager, Metropolitan
     Sewerage  Dist. of the County of Milwaukee, P.O.  Box 2079, Milwaukee,
     MI  53201  (dated:   May 13,  1977)

     Option Preference:   None
     Major Position:   Prefers water quality standards

Boruszewski, Robert J.,  P.E., Director of Public Works,  Calhoun  County,
     County Bldg.,  Marshall, MI   49069  (dated:  May 12, 1977)Bowman,
     Robert K., Vice President-General  Manager, Consumers Packing

     Option Preference:   III
     Major Position:   Prefers local  control

Bowman, Robert K.,  Vice President-General  Manager,  Consumers Packing
     Plum & Liberty Sts., Lancaster PA  17604  (dated:   April  12,  1977)

     Option Preference:  None
     Major Position:  Prefers local  control

Brehm, Stuart  H., Jr., Executive Director,  Sewerage and Water Board of
     New Orleans, City Hall, Civic Center,  New  Orleans,  LA  70165
     (dated: April  12, 1977)

     Option Preference:   II and  IV
     Major Position:   Concerned  with costs

Breimhurst, Louis J., P.E., Director, Div.  of Water Quality, Minnesota
     Pollution Control Agency, 1935 W.  County Rd. B2, Roseville, MN
     55113 (dated:   May 17, 1977)

     Option Preference:   I or that submitted  by the State of Tennessee
     Major Position:   Does not prefer water quality standards

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                                    -129-
 Brokaw,  Newton A.,  Executive Director,  Columbus  Industrial Assoc.,
      1515 West Lane Ave.,  Columbus,  OH   43221   (dated:  May 5, 1977)

      Option Preference:   None
      Major Position:   Prefers local  control

 Brubaker, B.H., Special  Assistant to the Director  of  Safety and Environmental
      Engineering,  Diamond  Shamrock Corp.,  1100  Superior, Cleveland, OH
      44114  (dated:  May 2,1977)

      Option Preference:   III
      Major Position:   Prefers control of only the  most  toxic pollutants.

 Bruce, Thomas K.,  Director,  Division of Water Resources, City of Durham,
      Durham, NC  (dated:   May 5,  1977)

      Option Preference:   II
      Major Position:   Prefers local  control

 Bruder,  K.W., General  Manager, Fresh Meats Co.,  P.O.  Box 2568, San
      Antonio, TX  78299  (dated:  April 26,  1977)

      Option Preference:  III  & II
      Major Position:  Prefers water quality variances

 Burnett, John J.,  Director of Utilities, City of Niagara Falls, NY
      (dated: May 1, 1977)

      Option Preference:  III
      Major Position:  Concern with interference  with local treatment
                      programs

 Busch, William H.,  R.E.,  Manager-Permit Section, Div- of Water Pollution
      Control, Illinois Environmental Protection  Agency, 2200 Churchill
      Rd., Springfield, IL   62706  (dated:   May  11, 1977)

      Option Preference:   III & II
      Major Position:   Prefer water quality variances

Buschkill, C.J., Manufacturing Engineer, Geo. Koch  Sons, Inc., P.O. Box
      351, Evansville,  IN  47744  (dated: March  24, 1977)

      Option Preference:   None
      Major Position:   Prefers local  control

 Calkins, C.R., Vice President-Environmental  Affairs,  American Paper
      Institute, 1619 Massachusetts Ave., N.W.,  Washington, D.C.  20036
      (dated:  May 16,  1977)

      Option Preference:   III & II
      Major Position:   Prefers water quality variances

 Campbell, H.J., Jr.,  Engineering Service Div.,  E.I. DuPont de Nemours
      & Co., Inc.,  Wilmington, DE  19898  (dated: April  15, 1977)

      Option Preference:   III
      Major Postion: Prefers  local control

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                                  -130-
Casazza, Joseph F.,  Commissioner of Public Works,  City of Boston,  One
     City Hall  Square, Boston,  MA  02201   (dated:   April  8,  1977)

     Option Preference:   IV
     Major Position:  Concerned with.costs

Chaddock, R.E., Executive Director of Environmental  Affairs, Hercules
     Inc., Wilmington, DE  19899 (dated:  March 22, 1977)

     Option Preference:   III                   ;;
     Major Position:  Prefers local control

Chambers, John T., Jr.,  P.E., Administrator-Construction  Grants Unit,
     Louisiana Health and Human Resources Administration, Dept. of
     Health, P.O.  Box 60630, New Orleans, LA  70160 (dated:  May  9,
     1977)

     Option Preference:   None
     Major Position:  Prefers local control

Charles, F.M, Corporate Director-Environmental Affairs, Union Carbide
     Corp., 270 Park Ave., New York, NY  10017  (dated:  May 16, 1977)

     Option Preference:   II and III combination
     Major Position:  Prefers water quality standards

Chase,  Edith, Environmental Director, League of Women Voters of Ohio,
     5731 Caranor Drive, Kent,  OH  44240 (dated:  May 16,  1977)

     Option Preference:   None
     Major Position:  Supports Federally promulgated technology standards

Chu, Joseph P., and Philip E. Gerwert, Environmental Activities Staff,  GM
     Technical Center, General  Motors Corp., Warren, MI  48090  (dated:
     May 10, 1977)

     Option Preference:   None
     Major Position:  Discusses the establishment of effluent limitations
                      in pretreatment requirements

Civins, Jeffrey, Vinson and El kins, Attorneys at Law, First  City National
     Bank Bldg., Houston, TX  77002

     Option Preference:   None
     Major Position:  Concerned with POTW is designed to  treat industrial
                      wastes

Clark,  Albert C., Vice President-Technical Director, Manufacturing
     Chemists Assoc., 1825 Connecticut Ave., N.W., Washington, D.C.
     20009 (dated:  April 11, 1977)

     Option Preference:   III
     Major Position:  Prefers water quality variances

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                                   -131-
Clark, Paul F., Commissioner, City of Chattanooga,  Dept.  of Public
     Works, Chattanooga, TN  37402  (dated:   May 18,  1977)

     Option Preference:  Supports State of Tennessee
     Major Position:  Prefers strong local control

Cockrell, Lila, Mayor, City of San Antonio,  San Antonio,  TX  78205
     (dated: April 25, 1977)

     Option Preference: II & III
     Major Position:  Prefers water quality variances

Conway, W.G.,Loop Cold Storage Co., Southton and Center Rds.,  P.O.  Box
     179 San Antonio, TX  78217  (dated:   April  19, 1977)

     Option Preference:  II & III
     Major Position:  Prefers wate quality variances

Coppoc, W.J., Vice President-Environmental Control, Texaco  Inc.,  P.O.
     .Box 509, Beacon, NY  12508  (dated:   May 17, 1977)

     Option Preference:  None
     Major Position:  Prefers local control  and water quality standards

Corbeil, R.J., Manager of Environmental Affairs, Southern California  Gas
     Co., 810 S. Flower St., Los Angeles, CA  90017 (dated:  May  16,
     1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Cormack, J.F., Supervisor, Water Programs, Crown Zellerbach, Environmental
     Services, 904 N. Drake St., Camas, WA  98607  (dated:   April  14,
     1977)

     Option Preference:  III
     Major Position:  Prefers local control

Courtney, Stephen M., Technical Director, Menominee Paper Co., Inc.,
     P.O. Box 300, Menominee, MI  49858   (dated:  May 16, 1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality standards be included

Cousineau, John A., Manager, Townsend Div. of Textron Inc., 1224  E.
     Warner Ave., Box 2157, Santa Ana, CA  92707   (dated:  April  6,
     1977)

     Option Preference:  II
     Major Position:  Prefers local control

Crane, Larry E., Executive Director, Iowa Dept. of Environmental  Quality,
     3920 Deleware Ave., P.O. Box 3326, Des Moines, IA  50316  (dated:
     May 3, 1977)

     Option Preference:  IV
     Major Position:   Prefers State control

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                                  -132-
Crutcher, Bruce S., Greater Cincinnati  Chamber of Commerce,  Cincinnati,
     OH  (dated:  April  21, 1977)

     Option Preference:   Combination of II & IV
     Major Position:  Split options to  provide equity between small
                      and large municipalities

Cummings, David, Chief Chemist, Tri-Aid Sciences, Inc.,  161  Norris Dr.
     Rochester, NY  14610  (dated:   April  7, 1977)

     Option Preference:   None
     Major Position:  Concerned with certification of monitoring personnel

Curran, Robert F., Director-Environmental  Technology, CIBA-GEIGY,  Ardsley,
     NY  10502  (dated:   May 16, 1977)

     Option Preference:   III
     Major Position:  Prefers local control

Custis, Glenn W., P.E.,  Environmental  Engineer, Environmental Control  Dept.,
     Reynolds Aluminum-Reynolds Metals  Co.,  Richmond, VA,   23261  (dated:
     May 18, 1977)

     Option Preference:   None
     Major Position:  Prefers use of water quality criteria

Daleiden, Mary and Joseph,  2715 Harrison St.,  Evanston,  IL 60201 (No
     date)

     Option Preference:   IV
     Major Position:  Concerned with environment

Davis, Mark S., Secretary,  Technical  Advisory Committee,  Indianapolis  Chamber
     of Commerce, 320 N. Meridian,  St., Indianapolis, IN   46204  (dated:
     May 12, 1977)

     Option Preference:   III
     Major Position:  Prefers local control

Davoli, Dr. Dana J., Director of Toxic  Substances Research,  Citizens for
     a Better Environment,  Suite 2610,  59 E. Van Buren St.,  Chicago,
     IL  6060  (dated:  May 1977)

     Option Preference:   IV
     Major Position:  Concerned with the environment and  EPA adhering  to
                      the Consent Decree

De Gennaro, K.E., Manager-Environmental Engineering and  Control, Western
     Electric, 222 Broadway, NY, NY  10038  (dated:  May  16, 1977)

     Option Preference:   II and III combination
     Major Position:  Prefer local  control with water quality standards

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                                    -133-
Dendy, Bill B., Executive Officer, State Water Resources Control  Board
     State of California , P.O. Box 100, Sacramento,  CA  95801   (dated:
     May 3, 1977)

     Option Preference:  II
     Major Position:  Concerned with complexity of the regulations;
                      prefers water quality standards, and local  control

DiGuiseppi, David, Assoc., Regional Plnr., Central Mass Regional  Planning
     Planning Comm., 70 Elm St., Worcester, MA  01609 (No date)

     Option Preference:  Combination of I & IV
     Major Position:  Concern for participation by 208 agencies

Dohmus, Stanley D., Deputy Assistant Secretary of the Interior,  Office
     of the Secretary, Washington, D.C.  20240  (dated: April  14, 1977)

     Option Preference:  II
     Major Position: Regulations should consider effect of toxics in
                     sludge on wildlife

Domzalski, L.J. Technical Manager, Nalco Chemical  Co., 2901  Butterfield
     Road, Oak Brook, IL  60521  (dated:  May 11,  1977)

     Option Preference:  II and III combination
     Major Position:  Prefers local control

Dorman, Loren F-, President, American Wood Preservers Institute, 1651 Old
     Meadow Rd., Mclean, VA  22101  (dated:  May 18,  1977)

     Option Preference:  II and III combination
     Major Position:  Prefers strong local control

Dowden, Bobby, Ph.D., Assistant Superintendent, Treatment Div.,  Dept. of
     Public Utilities, P.O. Box 65, Shreveport, LA  71153  (dated:  April
     11, 1977)

     Option Preference:  I
     Major Position:  Concerned with possible local enforcement difficulties

Dryden, Franklin D., Head Technical Services Dept., County Sanitation
     Districts of Los Angeles Co., P.O. Box 4988, Whittier, CA  90677
     (dated: April  14, 1970)

     Option Preference:  II
     Major Position:  Prefers local control, and  supplied information
                      enforcement of water quality standards


Duensing,  Hollis G., General Attorney,  Law Dept., Assoc.  of American
     Railroads, American Railroads Bldg., Washington,  D.C.  20036
      (dated:   May  18, 1977)

     Option Preference:   II
     Major Position:   Prefers maximum  local control

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                                    -134-
Dufficy, Thomas J.,  National  Association of Photographic Manufacturers
     Inc., 600 Mamaroneck Ave.,  Harrison, NY 10528  (dated:   May 17,  1977)

     Option Preference:   III
     Major Position:   Prefers local  control  with water quality variances
                      under NPDES Permit system

Duncan, L.K., Plant  Manager,  W.R. Grace & Co.-Davison Chemical  Div.,
     4000 Hawthorne  St.,  Chattanooga,  TN  37406  (dated: April  22,  1977)

     Option Preference:   None
     Major Position:   Concerned  with duplication of efforts

Early, A.B., Environmental  Action, Suite 731,  1346 Connecticut Ave.,  N.W.,
     Washington, D.C.   20036  (dated:   May 18,  1977)

     Option Preference:   IV
     Major Position:   Concern for environment  and safe sludge disposal

Early, Jack D., President,  National  Agricultural  Chemicals Assoc.,  The
     Madison Bldg.,  1155  Fifteenth St., N.W.,  Washington, D.C.   20005
     (dated:  May 9,  1977)

     Option Preference:   None
     Major Position:   Concerned  with TSCA and  FIFRA

Eby, Donald L., Director-Process Environment,  Monsanto Co.,  800 N.  Lind-
     bergh Blvd., St.  Louis,  MO   63166  (dated:   May 16, 1977)

     Option Preference:   II & III Combination
     Major Position:   Prefers maximum local  control

Effinger, John III.,  P.E.,  Systems Engineer, Water and Sewer Utilities,
     P.O. Box 580, Ft. Collins,  CO  80522 (dated:  April  29,  1977)

     Option Preference:   III
     Major Position:   Concern with non-point sources

Eisele, Thomas D., Deputy Director,  Lake Michigan Federation, 53 W.
     Jackson Rd., Chicago,  IL 60604 (dated: April  29, 1977)

     Option Preference:   IV
     Major Position:   Concerned  with environment

Enferadi, Karol M.,  Chairwoman,  Industrial  Wastewater Subcommittee,
     California Water  Pollution  Control Assoc.,  127 N. Madison  Ave.,
     Suite 304, Pasadena, CA   91101   (dated: April  29, 1977)

     Option Preference:   II
     Major Position:   Concerned  with impact of pretreatment  program
                      on  local  source control  programs

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                                   -135-
Fairfield, George H., Director of Public Works,  City  of  Kearney,  Box
     489, Kearney, NB  68847  (dated:   May 3,  1977)

     Option Preference:   I
     Major Position:   No rational

Farley, E. Ray, Superintendent, Water  and Sewer  Dept., 505  Ellington
     Pkway, Lewisburg, TN  37091  (dated: April 27,  1977)

     Option Preference:   None
     Major Position:   Concerned with duplication of effort

Fenner, Kenneth A., Esq., Office of the General  Counsel,  Masonite Corp.,
     29 N. Wacker Dr., Chicago, IL  60606  (dated:  May  17,  1977)

     Option Preference:   None
     Major Position:   Prefers local control

Ferry, John D., Secretary-Treasurer, American  Wood-Preservers' Assoc.,
     1625 Eye St., N.W., Washington, D.C.  20006  (dated:   May 17, 1977)

     Option Preference:   II and III combination
     Major Position:   EPA should be concerned  only  with  truly
                      toxic pollutants

Fielding, Blaine, Legal  Dept., Clark Oil and Refining Corp., 131st and
     Kedzie Ave., Blue Island, IL  60406  (dated:   May 3, 1977)

     Option Preference:   None
     Major Position:   Concerned with duplication of treatment facilities

Fisher, William E., Administrator-Research Div., International Fabricare
     Institute Research Center, 12251   Tech. Rd.,  Silver Spring,  MD  20904
     (dated:   May 18, 1977)

     Option Preference:   III
     Major Position:   Concerned with exempting laundries from the Pretreat-
                      ment program

Freeman, George C., Jr., Special  Counsel to the  Utility  Water Act Group,
     1730 Pennsylvania Ave., N.W., Suite 1060, P.O. Box  19230, Washingtton,
     D.C.  20006  (dated:  May 16, 1977)

     Option Preference:   II and III combination
     Major Position:   Concerned with complexity  of variance provisions
                      and possibility  of local government not
                      implementing a local compliance program

Fuller, Glen H., Washington State Dept. of Ecology, Office  of Water  Programs,
     Water Quality Div., Olympia,  WA  98504  (dated:  May 16, 1977)

     Option Preference:   III
     Major Position:  Opposes water quality variances

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                                  -136-
 Garrett,  Theodore  L.,  Counsel, National Association of Metal Fishers,
      and  the  Copper  &  Brass  Fabricators Council, 888 Sixteenth  St.,
      N.W.,  Washington,  D.C.  20006  (dated:  May 18, 1977)

      Option Preference:   II  &  III  Combination
      Major  Position:   Concerned with  the legal technicalities of
                       technology-based standards

 Geisler,  Charles A.  ,  Sanitation Engineer, City of Omaha,  1819  Farnam
      St.  Omaha, NB  68102  (dated: March 14, 1977)

      Option Preference:   None
      Major  Position:   Prefers  local control

 Gilman,  I.H., General  Manager-Environmental Affairs, Chevron U.S.A.,Inc,
      575  Market St., San  Francisco, CA  94105  (dated:  May 10, 1977)

      Option Preference:   II  &  III
      Major  Position:   Prefer water quality variances

 Glover,  R.C.  and J.F.  Byrd,  Managers, Proctor and Gamble Co., Hillcrest
      Tower, 7162 Reading  Rd.,  Cincinnati, OH  45222

      Option Preference:   III
      Major  Position:   Prefers  local control

 Golle, H.A.,  Vice  President  -  Operations, General Foods Corp.,  250 North
      St.,  White Plains,  NY  10625 (dated: April 25, 1977)

      Option Preference:   III
      Major  Position:   Prefers  local control

 Goodgame, T.H.,  Director, American Institute of Chemical Engineers,  Environ-
      mental Div.,  Monte Rd., Benton Harbor, MI  49022  (dated:   May 16, 1977)

      Option Preference:   Combination  of all 4
      Major  Position:   Prefers  local control

 Graeser,  Henry J., Black  & Veatch  Consulting Engineers, 555 Griffin  Square,
      Suite  820,  Dallas TX 75202  (dated:  February 16, 1977)

      Option Preference:   II  &  III
      Major  Position:   Prefers  local control and water  quality standards

Grage, Larry,  Chief Operator, Village  of Bensenville, 700 W.  Irving Park
     Rd.,  Bensenville,  IL   '60106   (dated:  March 21,  1977)

     Option  Preference:  I
     Major Position:   Wants Federal backup

Grant, C.T., et.al.,  Deputy Commissioner for Environmental  Health  Services,
     Oklahoma  State Dept.  of  Health, N.E. 10th St. &  Stonewall,  P.O.  Box
     53551,  Oklahoma  City, OK  73105   (dated:  May 16,  1977)

     Option  Preference:  II & III  Combination
     Major Position:   Prefers local control

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                                   -137-
Green, James M., 208 Project Director, First Tennessee-Virginia  Development
     District, 207 N. Boone St., Johnson City,  TN  37601   (dated:   March
     17, 1977)

     Option Preference:  IV
     Major Position:  Wants industrial input

Grosmaire, L.A., Chairman, Air and Water Resources Committee,  Tennessee
     Manufacturers Assoc., 708 Fidelity Federal  Bldg.,  Nashville,  TN
     37219  (dated:  April 27, 1977)

     Option Preference:  None
     Major Position:  Prefers local control  and water quality-based standards

                Ralph D., Manager-Environmental  Control,  Deere & Co.,  John
     Deere Rd., Moline IL  61265  (dated:  May  9, 1977)

     Option Preference:  II & III
     Major Position:  Prefers local contorl  and water quality  variances

Gouck, James A., Chairman, Buffalo Area Advisory Council  on Industrial
     Waste Water, P.O. Box 1069, Buffalo, NY  14240 (dated: April  28,
     1977)

     Option Preference: II & III
     Major Position:  Prefers water quality variances

Gubrud, Arne E., Environmental Affairs Director, American Petroleum Insti-
     tute, 2101 L. St., N.W., Washington, D.C.   20037  (dated:  May 16, 1977)

     Option Preference:  III
     Major Position:  Limit major Federal involvement

Guarino, Carmen F., Water Commissioner, Water Dept.,  City of Philadelphia,
     1180 Municipal Services Bldg., Philadelphia, PA   19107  (dated:
     April 11, 1977)

     Option Preference:  III
     Major Position:  Prefers local control

Hall, Elmer E., Pacific Gas and Electric Co., 77 Beale St., San  Francisco,
     CA  94106  (dated: May 18, 1977)

     Option Preference:  II
     Major Position:  Concerned with conflict between Federal  and State
                      programs

Hall, John F., Vice President-Resource & Environment, National Forest Products
     Assoc., Forest Industries Bldg., 1619 Massachusetts Ave., M.W., Wash-
     ington, D.C.  20036  (Dated:  May 18, 1977)

     Option Preference:  II & III
     Major Position:  Supports water quality variances

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                                   -138-
Halloran, William J., Executive Secretary,  Blackstone Valley District
     Commission, P.O., Box A., Rumford,  RI   02196  (dated:   March 23,
     1977)

     Option Preference:   None
     Major Positon:   Prefers state enforcement

Hanson, Charles R.,  Plant Manager, Velsicol  Chemical  Corp.,  1199 Warford
     St., Memphis, TN  38108  (dated:   May  16, 1977)

     Option Preference:   Offers new option
     Major Position:  Monitor inlet of POTW and utilize water
                      qua!ity standards

Harper, Fred A., General  Manager,  County Sanitation Districts of Orange
     County, P.O. Box 8127, Fountain Valley, CA 92708  (dated:  April  28,
     1977)

     Option Preference:   II
     Major Position:  Prefers local  control

Harris, H.D., Vice President, Engineering,  the Gates  Rubber  Co., 999  S.
     Broadway, Denver, CO  (dated: April  19, 1977)

     Option Preference:   III
     Major Position:  Supports local  control

Hasfunther, William A.,  404 Riggs  Ave.,  Severna Park, MD.  21146 (dated:
     May 1, 1977)

     Option Preference:   None
     Major Position:  Prefers local  control  and standards

Hauck, Roland L., "Save our Nextdoor Creek."  Task Force California and
     Nevada Conservation Resources Committee-Sierra Club,  320 La Serena
     Way, Sonoma, CA  95476 (dated:   April  15, 1977)

     Option Preference:   None
     Major Position:  Concern for  the environment

Haxby, L.P., Manager-Environmental Affairs,  Shell Oil Co., One Shell
     Plaza, P.O. Box 2463, Houston,  TX  77001

     Option Preference:   II & III
     Major Position:  Prefers water quality approach

Healy, William A., P.E.,  Executive Director, Water  Supply  and Pollution
     Control Commission,  State of  New Hampshire, Prescott  Park, P.O.  Box
     95-105 Loudon Road,  Concord,  NH  03301   (dated:  April 13,  1977)

     Option Preference:   None
     Major Position:  Options ignore existing state laws and do not
                      consider small  municipalities

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                                   -139-
Heath, D.P., Coordinator-Environmental  Conservation,  Mobil  Oil  Corp.,150
     E. 42nd St., NY, NY  10017  (date:   May 17,  1977)

     Option Preference:   II & III combination
     Major Position:   Prefers water quality variances

Henry, Charles J. Director, Water Pollution Control,  Metropolitan
     Seattle, WA  98104  (dated:  March 31,  1977)

     Option Preference:   III
     Major Position:   Supports Mass limitations

Hert, Oral H., Technical Secretary, Stream  Pollution  Control  Board,
      Indiana, 1330 W. Michigan St., Indianapolis,  IN  46205  (dated:
      April 27, 1977)

     Option Preference:   II & III
     Major Position:   Prefers local control and water quality standards

Hittle, Paul C., General Supervisor of Environmental  Affairs,  Consumers
     Power Co., 212 W. Michigan Ave.,  Jackson,  MI  49201   (dated:  May
     17, 1977)

     Option Preference:   None
     Major Position:   Prefers EPA Guidelines for Water quality criteria

Hofheinz, Fred, Mayor, City of Houston,  Houston,  TX  77001   (dated:   May
     2, 1977)

     Option Preference:  II & III
     Major Position:   Prefers locally-derived water quality standards

Honberger, Roger F.,  Washington Representative, County of San Diego,
     Suite 500, 1735 New York Ave., N.W., Washington, D.C.   20006
     (dated:  May 17, 1977)

     Option Preference:   None
     Major Position:   Prefers modification  enforcement provision (section  M)

Hopkins, Glen J., Deputy City Manager, Kansas City, MO  64106  (dated:
     April 11, 1977)

     Option Preference:   AMSA Option
     Major Position:   Concerned with costs, and prefers water
                      quality standards

Houston, A.B.M., Manager-Compliance and Liaison Dept., Stationary Source
     Environmental Control, Ford Motor Co., One Parklane Blvd., Dearborn,
     MI  48126  (dated:   May 19, 1977)

     Option Preference:   II & III Combination
     Major Position:   Prefers locally-derived standards

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                                   -140-
Howell, Don T., Director of Utilities,  Board of Light and  Water Commissioners
     of the City of Concord, Lock Drawer 567,  Concord,  NC   28025  (dated:
     April 1, 1977)

     Option Preference:   III
     Major Position:  Coordinate pretreatment with other programs

Hughes, William E., Composite Can and Tube Institute, 1800 M Street,
     N.W., Washington, D.C.  20036  (dated:   April  29,  1977)

     Option Preference:   III
     Major Position:  Prefers local  control

Hyatt, Joe H., P.E., Deputy Director of Public Works, City of Jacksonville,
     220 E. Bay St., Jacksonville, FL  32202  (dated:  March 31, 1977)

     Option Preference:   IV
     Major Position:  National  Pretreatment  program will lend
                      authority to local  efforts

Johnson, David L., Jr.,  Chief Operator, Wastewater Treatment Plant,
     Vice-Chairman Genesee Valley Section -  NYSPCA, Village of Avon,
     Avon, NY  14414  (dated: April  13, 1977)

     Option Preference:   IV
     Major Position: Federal laws have  more  authority than local laws

Johnson, W.R., Director-Plant Environment, Environmental Activities Staff,
     General Motors Corp., General Motors Technical  Center, Warren, MI
     48090  (dated:  May 11, 1977)

     Option Preference:   II
     Major Position:  Prefers local  control

Jones, Jack, Director of Public Works,  City of Orem,  56 N. State St.,
     P.O. Box 247, Orem, UT  84507  (dated:  April  1,  1977)

     Option Preference:   III
     Major Position:  Not stated

Jones, Rex E., Executive Director, Indiana Heartland  Coordinating Commission,
     7212 N. Shadeland Suite 120, Indianapolis, IN  46250

     Option Preference:   II & III
     Major Position:  Prefers water quality standards

Jordan, A. Gayle, Attorney, Southern Railway System,  Law Dept., P.O.  Box
     1808, Washington, D.C.  20013  (dated:   May 17,  1977)

     Option Preference:   None
     Major Position:  New pretreatment  regulations are uneccessary

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                                   -141-
Kamlet, Kenneth, Counsel, National  Wildlife Federation,  1412  16th St.,
     N.W., Washington, D.C.   20036   (dated:   May 17,  1977)

     Option Preference:  IV
     Major Position:   Supports limited variances-views on  "due  process" issue

Kay, Arthur N., Environmental  Control  Director,  City  of  St. Charles,
     Municipal  Center, St. Charles, IL  60174  (dated:   May 11,  1977)

     Option Preference:  III
     Major Position:   Prefers local control

Keene, Albin G., Superintendent, Scarborough Sanitary District,  P.O. Box
     302, Scarborough, ME  047074

     Option Preference: III  & II
     Major Position:   Prefers local control

Kellogg, H. Clay, Jr., General Manager, Kellogg  Supply,  Inc., 2394 S.
     Figueroa St.,  Carson,  CA  90745   (dated:  April  20, 1977)

     Option Preference:  None
     Major Position:   Concerned with sludge


Kelly, Robert H., Forest Preserve District of DuPage  County,  881 W. St.
     Charles Rd., Lombard, IL  60148 (dated: April  15, 1977)

     Option Preference:  I
     Major Position:   Prefers Federal  control


Keston, S. Norman, Assistant to the Vice President-Environmental Affairs,
     ASARCO, Inc., 120 Broadway, NY, NY  10005  (dated:  April  18, 1977)

     Option Preference:  I
     Major Position:  Prefers local  control through  variances

Kilik, Eugene L., President, Tanners'  Council  of America,  Inc.,  411 Fifth
     Ave., New York,  NY  10016  (dated:  May 18, 1977)

     Option Preference:  III
     Major Position:   Consent Decree is not binding on EPA

King, Henry B., President, U.S. Brewers Assoc.,  Inc., 1750 K  St., N.W.,
     Washington, D.C.   20006  (dated:   May 9,  1977)

     Option Preference:  III
     Major Position:   Prefers local control

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                                    -142-
Kitazaki, S.W.,  General  Manager,  Oconomowoc  Electroplating  Co.,  Inc.,
     Ashippum,  WI   53003  (dated:   April  28,  1977)

     Option Preference:   I
     Major Position:   Concerned with equity  of enforcement

Klinger, Florence,  072 Green Street, Martinez, CA  94553  (dated:  April
     14, 1977)

      Option Preference:  IV
      Major Position:   Prefers local control

Klippel, Richard W.,  P.E., Chairman, Industrial  Waste  Committee,  New
     York Water Pollution Federation, NY   (dated:   May 11,  1977)

     Option Preference:   None
     Major Position:   Prefers technology-based standards

Korbitz, William E.,  P.E., Manager,  Metropolitan Denver Sewer Disposal
     District No.  1,  6450 York St.,  Denver,  CO  80229   (dated:  April  27,
     1977)

     Option Preference:   III
     Major Position:   Prefers Federal standards  with  local  control

Kovach, Gyula F.,  P.E.,  Director,  Water Pollution Control,  Kansas  City
     Dept. of Boulevards, Parks,  and Streets,  Civic Plaza,  701  N.  7th
     St., Kansas City, KA  66101   (dated:  May 17,  1977)

     Option Preference:   II
     Major Position:   Utilize toxicity tests  to  show demonstratable
                      need to regulate a  toxic

Kowalik,  A.P., Manager - Environmental Affairs, Gulf  Oil Co.,  -  U.S.,
     P.O. Box 2001, Houston, TX  77001  (dated:   May  2,  1977)

     Option Preference:   II & III
     Major Position:   Supports water quality  standards

Krasofski, Frank J.,  Vice President-General  Manger, James River  -  Fitchburg,
     Inc., Old  Princeton Rd., Fitchburg,  MA   01420   (dated:  April  11,
     1977)

     Option Preference:   None
     Major Position:   Concerned with exemption of industrial  waste
                      treatment facilities

Kuchta, Francis W., Director, Dept.  of Public  Works,  City of Baltimore,
     600 Municipal  Bldg., Baltimore, MD  21202  (dated:  April 19,  1977)

     Option Preference:   AMSA Option
     Major Position:   Prefers local  control  and  water  quality variances

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                                    -143-


Kumagi, James S., Ph.D., Deputy Director of Environmental  Programs,
     State of Hawaii, Dept.  of Health,  P.O. Box 3378,  Honolulu,  HA
     96801  (dated:  May 6,  1977)

     Option Preference:  II
     Major Position:  Prefers local  control

Lagnese, Joseph F., Duncan,  Lagnese & Assoc., Inc.,  3185  Babcock Blvd.,
     Pittsburgh, PA  15237  (dated:   March 18,  1977)

     Option Preference: II & III
     Major Position:  Wants  water quality variances

Lambie, John A., Chief Engineer-General  Manager,  Ventura  Regional County
     Sanitation District, CA  (dated: April 20, 1977)

     Option Preference:  II
     Major Position:  Prefers local  control

Langlois, Gaytha A., Ph.D.,  and Linda Silversmith,  Ph.D.,  Chairwomen,
     Clean Water Committee,  Ecology Action for  Rhode Island,  286 Thayer
     St., Providence, RI  02906  (dated:  May 1,  1977)

     Option Preference:  IV
     Major Position:  Concern for environment through strict  regulations

Lardieri, Nicholas J. Director-Environmental  Resources, Scott Paper  Co.,
     Scott Plaza, Philadelphia, PA  19113  (dated:   May 16, 1977)

     Option Preference:  None
     Major Position:  Concerned with EPA interference with joint industrial-
                      municipal POTWs and programs

LaRosa, Reginald A., P.E.,Director,  Environmental  Engineering Div.,
     Agency of Environmental Conservation, State of  Vermont,  Montpelier,
     Vermont  05602  (dated:  May 2, 1977)

     Option Preference:  None
     Major Position:  Prefers NPDES State control

Lasker, Jerry, Executive Director, Indian Nations Council  of  Governments,
     630 W. 7th St., Tulsa,  OK  74127  (dated:   May 16,  1977)

     Option Preference:  I
     Major Position:  Prefers minimization of duplication through local  control

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                                    -144-
Larrabee, Edward, Superintendent,  Wastewater Treatment Facilities,  1700
     7th St.,  Sanger,  CA 93657  (dated:  March 24,  1977)

     Option Preference:   I
     Major Position:   Prefers local  control

Legallet, Jon S., Legallet Tanning Co., 1099 Quesada Ave.,  San Francisco
     CA  94124 (dated:  April  8, 1977)

     Option Preference:  III
     Major Position:   Prefers local  control  for less hazardous toxics

Levi, L., Chairman, Environmental  Impact Committee, Southern Rubber Group,
     5775 Dellwood Lane, Beaumont, TX   77706  (dated:   May  3, 1977)

     Option Preference:   III
     Major Position:   Supports position of the Manufacturing Chemists
                      Assoc., (Albert  Clark)

Levy, Gary F., Director, Dept. of Environmental  Quality,  Jefferson  County,
     618 Old Louisville Trust Bldg., Louisville, KY  (dated:  April 26, 1977)

     Option Preference:   None
     Major Position:   Prefers local  control  and utilization of the
                      NPDES Program

Lewis, Gayle, H., P.E., Chief-Planning Div., State  of Nebraska, Natural
     Resources Commission, P.O. Box 94876, Lincoln, NB  68509  (dated:
     May 4, 1977)

     Option Preference:   Combination of Options II  & III
     Major Position:   Concerned with expense of pretreatment program
                      for small industries

Lockwood, John, Deputy City Manager, City of San Diego, City Administration
     Bldg., 202 C. St., San Diego, CA  92101  (dated:   April 11, 1977)

     Option Preference:   II
     Major Position:   Not justified

Lohman, General Manager, Blackwell Burner Co., P.O. Box 37383, San
     Antonio, TX  78237  (dated:  April 15,  1977)

     Option Preference:  II & III
     Major Position:   Prefers water quality variances

Long, D.W., Attorney, Southern Pacific Transportation Co.,  Southern
     Pacific Bldg., 1 Market Plaza, San Francisco,  CA  94105  (dated:
     May 17, 1977)

     Option Preference:   III
     Major Position:   Prefers local  control

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                                    -145-
Lubetkin, StA., Chief Engineer, Passaic Valley Sewerage Commissioners,
     600 Wilson Ave., Newark, NJ  07105  (dated:   April  22,  1977)

     Option Preference:   III
     Major Position:   Modification of Option III  to include  Option  II

Lynam, Bart T., General  Superintendent, Metropolitan Sanitary District
     of Greater Chicago, 100 E. Erie St., Chicago, IL  60611   (dated:
     April  4, 1977)

     Option Preference:   None
     Major Position:   Lack of time for comment

Lyon, Walter A., Director, Bureau of Water Quality Management,  Dept. of
     Environmental Resources, Commonwealth of Pennsylvania,  P.O. Box
     2063 Harrisburg, PA  17120  (dated:  March 25, 1977)

     Option Preference:   II
     Major Position:   EPA should develop detailed guidance documents

Mannella, Raymond J., Director-Environmental Engineering,  RCA,  Cherry
     Hill, NJ  08101   (dated:  May 2, 1977)

     Option Preference:   III
     Major Position:   Prefers local control

Matlack, Albert S., The Society of Natural History of Delaware,  R.D. #1
     Box 137, Hockessin, DE  19707  (dated:  March 13, 1977)

     Option Preference:   I
     Major Position:   Prefers federal standards and local  enforcement

Mai kin, Gabriel, Mission Manager, Water Quality Task Force,  National Paint
     and Coating Assoc., 1500 Rhode Island Ave.,  N.W., Washington,  D.C.
     20005  (dated:  May 18, 1977)

     Option Preference:   III or AMSA option
     Major Position:   Prefer water quality variances be included

Martin, Roy E., Director-Science and Technology,  National  Fisheries Institute,
     Inc., 1730 Pennsylvania Ave., N.W., Washington, D.C.   20006  (dated:
     May 17, 1977)

     Option Preference:   IV
     Major Position:   Concerned with marine environment

Matthews, Robert R.,  Manager, Water & Sewer Commission, City of Freeport,
     230 Stephenson St., Freeport, IL  61032  (dated:  March 17, 1977)

     Option Preference:   None
     Major Position:   Concerned with grand awards

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                                   -146-
Maurer, R.H., Environmental  Maintenance Coordinator,  Celanese Chemical
     Co., Box 9077, Corpus Christi,  TX  78408  (dated:   May 20,  1977)

     Option Preference:  II  & III
     Major Position:  Concerned with POTW's designed  to treat industrial
                      wastes

McGarry, Robert S., General  Manager, Washington Suburban Sanitary Commission.
     4017 Hamilton St., Hyattsville, MD  20781   (dated:  May 17,  1977)

     Option Preference:  II  and III  Combination
     Major Position:  Prefers local control and water quality standards

McManus, William H., Executive Vice  President,  Envelope Manufacturer's
     Assoc., 1 Rockefeller Plaza, NY, NY  10020  (dated:  May 9,  1977)

     Option Preference: III
     Major Position:  Prefers local  control  and locally-derived  standards

McReynolds, L.A., Manager-Environment, Consumer Protection and Standards,
     Phillips Petroleum Co., Bartlesville, OK  75004   (dated: May 16,  1977)

     Option Preference:  III
     Major Position:  Prefers local  control

Mead Corporation, World Headquarters, Courthouse Plaza, N.E., Dayton, OH
     45463

     Option Preference:  II  & III
     Major Position:  Supports inclusion of water quality standards

Melas, Nicholas J., President, Metropolitan Sanitary  District of  Greater
     Chicago, 100 East Erie  St., Chicago, II 60611   (dated:   April  15,  1977)

     Option Preference:  II
     Major Position:  Concerned with pretreatment facility duplications

Mileski, Stanley E., Assistant to V.P.-Operations,  Texize Chemicals Corp.,
     P.O. Box 368, Greenville, SC 29602  (dated:  May  17, 1977)

     Option Preference:  II  & III
     Major Position:  Prefers addition of Option II variances

Miller, Bruce D., Assistant  Plant Manager, and  Satyendra M.  De,  Chief
     Chemist, Chestnut Operating Co., Second and Chestnut Sts.,  Reading,
     PA  19602  (dated:  April 27, 1977)

     Option Preference:  II  & III
     Major Position:  Prefers water  quality to  be considered

Miller, S.G., City of Boulder, Boulder, CO  80302  (dated: April  26,
     1977)

     Option Preference:  I & II
     Major Position:  Prefers local  control  with guidelines based on
                      Consent Decree

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                                    -147-
        , George W., Water Pollution Control  Director,  A & Burlington
     Sts., S.W., Cedar Rapids, IA  52404  (dated:   May  2,  1977)

     Option Preference:  III
     Major Position:  Concerned with industrial  coverage

Milligan, Thomas J., City Manager, City of Sparks,  City Hall,  431  Prater
     Way, Sparks, NV  89431  (dated:  April  26,  1977)

     Option Preference:  III
     Major Position:  Prefers local  control

Miyahira, Wallace, Director and Chief Engineer,  Honolulu,  HA  (dated:
     April 26, 1977)

     Option Preference:  AMSA Option
     Major Position:  Same as AMSA

Moeller, Alton S., Plant Engineer, Lone Star Brewing Co.,  600  Lone Star
     Blvd., San Antonio, TX  78297  (dated:  April  29,  1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Moore, Robert E., Manager, Santa Ana Watershed Project  Authority,  7150
     Brockton Ave., Suite 202, Riverside, CA  92506  (dated: April  28,
     1977)

     Option Preference:  None
     Major Position:  Prefers local  control

Morris, Timothy L., Assistant Director, Field Operations,  Texas  Water
     Quality Board, Austin, TX  (dated: April 19,  1977)

     Option Preference:  II
     Major Position: Prefers local control

Morse, Robert E., Ill, Attorney for Imperial  Sugar Co., One Shell  Plaza,
     Houston, TX  77002  (dated:  May 16, 1977)

     Option Preference:  II and III combination
     Major Position:  Concerned with POTW's designed to treat  industrial
                      wastes

Moschell, R.V., Director of Public Utilities, One Civic Center,  Middletown,
     OH  45042  (dated:  May 2, 1977)

     Option Preference:  III
     Major Position:  Prefers local  control

Muir, J.L., Superintendent, Waste Water Treatment Plant, City  of Tolleson,
     AZ   (dated: March 18, 1977)

     Option Preference:  II
     Major Position:  Wants Federal  Guidance

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                                   -148-
Muldoon, T.J., Vice President-Administration, Fibre Box Assoc., 224 S.
     Michigan Ave., Chicago, IL  60604  (dated:   May 9, 1977)

     Option Preference:   III
     Major Position:  Prefers local  control

Muno, William E., Chemical  Engineer, Enforcement Div., U.S.E.P.A.,
     Washington, D.C.  (dated: April  10, 1977)

     Option Preference:   II
     Major Position:  Reservation over local  control

Munroe, Robert E., Sr. Vice President-Manufacturing & Corporate Services,
     Great Western Sugar Co., P.O.  Box 53208, Denver, CO  80217  (dated:
     April 222, 1977)

     Option Preference:   II
     Major Position:  Prefers local  control

Murrey, Al E., P.E., Chief, Bureau of Water  Quality, Idaho State Dept.
     of Health and Welfare, Div.  of Environment, Statehouse, Boise, ID
     83720  (dated:  May 18, 1977)

     Option Preference:   II
     Major Position:  Prefers local  enforcement

Naftzger, Howard J., 133 Purdue Ave., Kensington, CA  942708  (dated:
     April 30, 1977)

     Option Preference:   I  or IV
     Major Position:  Prefers Federal control

Nay, Ward H., Vice President for Engineering, The Upjohn Co., Kalamazoo,
     MI  49001  (dated:   May 6, 1977)

     Option Preference:   II
     Major Position:  Prefers local  control  and  water quality standards

Nestro, John M., Secretary, Joint Municipal  Authority of Wyomissing
     Valley, Berks County,  Borough Hall,  West Reading, PA  (dated: April
     19, 1977)

     Option Preference:  None
     Major Position: Prefers national technology standards

Nikolich, Eli, Environmental Control Officer, Wastewater Treatment Plant,
     5607 W. Jensen Ave., Fresno, CA  93706   (dated:  April  29, 1977)

     Option Preference:   None
     Major Position:  Enclosed sewage ordinance

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                                   -149-
Niles, O'Jay, Director-Technical  Services, American Textile Manufactu-
     rers Assoc., Wachovia Center, 400 St. Tryon St.,  Charlotte,  NC
     28285  (dated:  May 18, 1977)

     Option Preference:  II & III Combination
     Major Position:  Concerned with industry being overburdened  by
                      regulations

Niles, Robert C. Director-Environmental  Control, UniRoyal,  Oxford Manage-
     ment & Research Center, Middlebury, CN  06479  (dated:   May  2,  1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Nolte, F.S., Plant Manager, the Celotex Corp., 2943 W.  Southcross, San
     Antonio, TX  78211 (dated: April 20, 1977)

     Option Preference: II & III
     Major Position: Prefers water quality variances

Notzon, Al J. Ill, Executive Director, Alamo Area Council  of Governments,
     TX   (dated:  April 27, 1977)

     Option Preference:  None
     Major Position:  Prefers local control

Odendahl, James P., P.E., Acting Director, Division of Environmental  Quality,
     Missouri Dept. of Natural  Resources, 2010 Missouri Blvd.,  Jefferson
     City, MO  65101  (dated:  May 13, 1977)

     Option Preference:  I
     Major Position:  Prefers local control

Olncy, Austin F., Director, Deleware State Dept. of Natural  Resources and
     Environmental Control, Edward Tathall Bldg., Dover, DE  19901
     (dated:  May 18, 1977)

     Option Preference:  None
     Major Position:  Concerned with additional administrative problems
                      and duplications

Olson, Jon L., District Director, Sanitary District of Rockford,  3333
     Kishwaukee St., P.O. Box 918, Rockvord, IL  611105  (dated:   May
     4, 1977)

     Option Preference:  III
     Major Position:  Concerned with interference with local programs

Olson, O.B., Vice President-Administration, Shawano Paper Mills,  P.O.
     Box  3629, Green Bay, WI  54303  (dated:  May 13,  1977)

     Option Preference:  III & II
     Major Position:  Opposed to uniform  national standards

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                                    -150-
Ott, Randy P.,  P.E., Industrial  Waste Engineer,  Onondaga Co.  Dept.  of
     Drainage and Sanitation,  125 Elwood Davis Rd.,  N.  Syracuse,  NY  13212
     (dated:   May 17, 1977)

     Option Preference:   None
     Major Position:  Prefers  local  control  and  water quality standards

Overcash, Cliff, President,  North Central  Texas  Council  of Governments,
     P.O. Drawer COG, Arlington, TX   76011   (dated:  April  28, 1977)

     Option Preference:   AMSA  option
     Major Position:  Prefers  local  control

Owen, T.C., Director, Office of Environmental  Affairs,  Union  Camp Corp.,
     P.O. Box 1391, Savannah,  GA  31402  (dated:   May 11,  1977)

     Option Preference:  II & III
     Major Position:  Supports inclusion of  water quality variances

Padar, Francis V., P.E., M.C.E., Assistant Deputy Commissioner, Nassau
     Co. Dept.  of Health, 240  Old Mineola  Rd., Mineola,  NY 11501
     (dated:   April 19,  1977)

     Option Preference:   None
     Major Position:  Prefers  local  control  with Federal  standards

Parish, W.D., Chairman PAC,  Lower Rio Grande Valley  Development Council,
     Suite 207, First National  Bank  Bldg., McAllen,TX  78501   (dated:
     April 29,  1977)

     Option Preference:   None
     Major Position:  Prefers  local  control  with water  quality variances

Patocka, Roger R., R.E., Banner Assoc., Inc.,  1024 6th  Street, P.O. Box
     298, Brookings, SD   57006 (dated:  March 1,  1977)

     Option Preference:  None
     Major Position:  Change definition of "Composite Sample"

Payne, T.C.,  Vice President-Environmental  Quality, International  Paper  Co.,
     P.O. Box 16807, Mobile, AL  36616   (dated:   May 9,  1977)

     Option Preference:   II  &  III
     Major Position:  Prefer water quality variances

Perry, Lloyd  H., Chairman, Chattanooga  Manufacturers Assoc.,  817  Broad
     St., Chattanooga, TN  37402  (May  13, 1977)

     Option Preference:   None
     Major Position:  Prefers  water  quality  standards

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                                   -151-
Phillips, Edward E., Director of Public Works,  Hayward,  CA   (dated:
     April 29, 1977)

     Option Preference:  II
     Major Position:  Concerned with interference with  local  programs

Pisano, Mark A., Executive Director, Southern California Assoc.  of Govern-
     ments, 600 S. Commonwealth Ave., Suite 1000, Los Angeles, CA  90005
     (dated:  May 13, 1977)

     Option Preference:  III
     Major Position:  Stresses competence of local  sanitation districts

Powers, E.L., Director, Environmental & Energy Control,  Mobay Chemical Corp.,
     Penn Lincoln Parkway West, Pittsburgh, PA  15205   (dated:   May  5, 1977)

     Option Preference:  III
     Major Position:  Prefers local  control

Pyle, Joe N. , P.E., et. al., Seligman and Pyle Consulting  Engineers,
     Inc., Suite 207, 419 S. Main Avenue, San. Antonio,  TX  78204 (dated:
     April 15, 1977)

     Option Preference:  II & III
     Major Position:  Prefer water quality variances

Racine, W.J., Vice President-Products Div., Atlantic Richfield Co, 515
     S. Flower St., Los Angeles, CA  90051   (dated:  May 12,  1977)

     Option Preference:  II and III combination
     Major Position:  Prefers local  control

Rathmell, Richard K., Market Manager, Waste Treatment Systems, Permutit
     Co., Inc., P.O. Box 355, Paramus, NJ  07652  (dated:   May 2, 1977)

     Option Preference:  None
     Major Position:  Not relevant

Reinfurt, Edward, Director of Government Affairs, Associated  Industries
     of New York State, Inc., 150 State St., Albany, NY  12207   (dated:
     May 17, 1977)

     Option Preference:  II & III Combination
     Major Position:  Prefers local  control

Rice, I.M., Director, Dallas Water Utilities, and Chairman  of the Assoc.
     of Metropolitan Sewerage Agencies, Suite 200,  1015 18th  St., N.W.,
     Washington, D.C., 20036  (dated:  May 17,  1977)

     Option Preference:  AMSA Option
     Major Position:  Prefers local  control for large municipalities

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                                   -152-
Riley, Jerry K., Administrative Assistant,  ABC Truck Rental  and Leasing
     Co., P.O. Box 9203,  San Antonio,  TX  (dated:  April  19,  1977)

     Option Preference:   II & III
     Major Position:   Prefers water quality variances

Roberts, Thomas E., P.E., Supervisor of Environmental  Control,  Celanese,
     Polymer Specialties  Co., One Riverfront Plaza,  Louisville, KY  40202
     (dated:  May 2,  1977)

     Option Preference:   Combination of I,  II, & III
     Major Position:   Prefers minimum regulations

Robson, C. Michael, Director of Liquid & Solid Waste Projects,  Dept.  of
     Public Works, City of Indianapolis, 2360 City-County Bldg.,  Indiana-
     polis, IN  46204  (dated:   April  15,  1977)

     Option Preference:   II
     Major Position:   Prefers local control  with water quality  standards

Rodgers, J.L., Jr., Division Manager,  American Water Works Service Co.,
     Inc., New England Div., 20 Milton St.,  P.O. Box 158, East  Dedham,
     MA  02026  (dated:  May 16, 1977)

     Option Preference:   III
     Major Position:   EPA should develop guidelines  for localities

Roegelein, W., Jr., President,  Roegelein Provision Co.,  Box  1698,  San
     Antonio TX  78296  (dated: April  15,  1977)

     Option Preference:  II & III
     Major Position:   Prefers water quality variances

Rook, J.H., Manager-Regulatory Affairs, Environmental  Protection  Dept.,
     American Cyanamid Co., Wayne, NJ  07470  (dated:   May 11,  1977)

     Option Preference:   II & III
     Major Position:   Prefers addition of water quality variances

Rose, Gordon, Vice-President, Bio-Chem Analysts, Inc., 4940 N.  Memorial
     Pkwy., Huntsville,  AL  35180  (dated:   May 13,  1977)

     Option Preference:   IV
     Major Position:   Prefers limited local  control

Rosen, Harold S., Deputy City Manager, City of San Jose, 801  North First
     St., San Jose, CA  95110  (dated:  April, 1977)

     Option Preference:   II
     Major Position:   Concerned with interference  with local  source
                      control programs

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                                   -153-
Ross, E.E., Manager, Water Pollution Control  Dept.,  East  Bay Municipal
     Utility District, 2130 Adeline St.,  Oakland,  CA  94823  (dated:
     April 25, 1977)

     Option Preference:   None
     Major Position:  Prefers local enforcement with water quality
                      considerations

Rowe, A.R., Jr., Negley and Co., Inc.,  P.O.  Box 12071,  San Antonio, TX
     (dated: April  15, 1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Rubin, Florence, President, League of Women Voters,  120 Boylston, MA  02116
     (dated:  May 15, 1977)

     Option Preference:   I
     Major Position:  Concerned with equity problems

Sadat, Marwan M., Ph.D., P.E., Program  Director, Office of Sludge Manage-
     ment and Industrial Pretreatment,  State of New  Jersey-Dept. of
     Environmental  Protection, Div. of  Water Resources, P.O. Box 2809,
     Trenton, NJ 08625  (dated: April 26, 1977)

     Option Preference:   I
     Major Position:  Concerned with protection of sludge

Salzmann, Don E., City of Melrose, Melrose,  MN  56352  (dated:  April  12,
     1977)

     Option Preference:   II & III
     Major Position:  Prefers local control

Sasse, Gary S., Assistant Chief Administrator, City  Hall, 125  N. Main
     St., Memphis,  TN  38103  (dated:  April  13, 1977)

     Option Preference:   II
     Major Position:  Lack of data to justify a pretreatment program

Saucier, John, Director, Tennessee Div. of Water Quality  Control, Dept.
     of Public Health, 621 Cordell Hill Bldg., Nashville, TN   37219
     (dated:  May 17, 1977)

     Option Preference:   II
     Major Position:  Supports water quality standards and submits
                      supporting documents

Scanlan, James W.,  P.E., Assistant Chief, Facilities, Bureau of Water
     Quality Control, Div. of Environmental  Health Services, Arizona
     Dept. of Health Services, State Health Bldg., 1740 W.  Adams St.,
     Phoenix, AZ  85007  (dated:  April 29, 1977)

     Option Preference:   II
     Major Position:  Prefers local control

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                                    -154-
Scherer, C.H., Water Reclamation Superintendent,  Wastewater Treatment,
     P.O. Box 1971, Amarillo,  TX  79186  (dated:   April  28, 1977)

     Option Preference:   III
     Major Position:  Concerned about interference with  local  programs

Schnitzius, Allen W., Mayor, Village of Cuba,  17.  E.  Main  St.,  Cuba,  NY
     NY  14727  (dated:   March 16, 1977)

     Option Preference:   II
     Major Position:  Prefers local  control

Schmidt, Wayne A., Staff Ecologist,  Michigan United Conservation Clubs,
     2101 Wood St., P.O. Box  30235, Lansing,  MI   48905   (dated: April
     21, 1977)

     Option Preference:   IV
     Major Position:  Concerned with sludge  disposal

Schuh, Joseph R., Manager-Production Developments, P.O.  Box 402427,  975
     Arthur Godfrey Rd., Miami Beach, FL 33140  (dated:  May 11, 1977)

     Option Preference:   III
     Major Position:  Concerned with laundry industry exemption

Schwartz, Stephen M., Manager-Environmental  Engineering, Keystone  Consolidated
     Industries, Inc. (no date)

     Option Preference:   II
     Major Position:  Prefers local  control

Scolnick, Meyer, Director, Region II, Enforcement Division, U.S.E.P.A.,
     Washington, D.C.'(dated:   April 29,  1977)

     Option Preference:   Combinations of Options  I and IV
     Major Position:  Concerned with enforcement  problems

Shaw, C. Russell, Director-Energy Conservation, Erving Paper Mills,
     Templeton, MA  (dated: April 27, 1977)

     Option Preference:   None
     Major Position:  Concerned with POTW designed specifically
                      for industrial wastes

Sherwood, Roger C., Sr.  Environmental Engineer, Georgia-Pacific Corp.,
     900 S.W. Fifth Ave., Portland,  OR  97204   (dated:  May 16, 1977)

     Option Preference:   III & II combination
     Major Position:  Prefers local  control

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                                    -155-

Shukle, Robert J., Industrial  Waste Consultant,  Technical  Services  and
     Grants Section, Colorado  Dept. of Health,  4210 E.  llth Ave., Denver,
     CO  80220  (dated:   May 16, 1977)

     Option Preference:   None
     Major Position: Concerned with proqam administration

Silverman, Richard H., Manager-Law Dept.,  Salt  River Project,  P.O.  Box
     1980, Phoenix, AZ  85001   (dated:  May 16,  1977)

     Option Preference:   III
     Major Position:  Prefers  local control

Sloan, Garrett, Director, Miami-Dade Water and  Sewer Authority,  P.O.  Box
     330316, Miami, FL  33133   (dated:  March 30,  1977)

     Option Preference:   III
     Major Position:  Prefers  local control

Sluizer, Mervyn, Jr., Technical Director,  Institute of  Industrial Launderers,
     1730 M. St., N.W., Suite  613, Washington,  D.C.  20036  (dated:   May
     16, 1977)

     Option Preference:   II &  III
     Major Position:  Prefer water quality variances

Small, David R., Executive Vice President, H. Swoboda & Son, Div. of
     Trans-Continental Leathers, Inc., 1027 Bodine St.,  Philadelphia, PA
     19123  (dated: March 14,  1977)

     Option Preference:  II & III
     Major Position:  Wants water quality  variances

Smith, Jack K., P.E., Chairman, Government Affairs Committee,  Missouri
     Water Pollution Assoc., Inc. (dated:   April  19, 1977)

     Option Preference:   III
     Major Position:  Prefers  local control

Solomon, Neil, M.D., Ph.D., Secretary of Health and Mental Hygiene,
     State of Maryland, 201 W. Preston St., Baltimore,  MD   21201   (dated:
     April 15, 1977)

     Option Preference:   II
     Major Position:  Prefers  water quality variances

Spence, John D., Jr., Superintendent, Western Carolina  Regional  Sewer Auth-
     ority, Maul din Rd., P.O.  Box 5242, Greenville, SC   29606   (dated:
     April 21, 1977)

     Option Preference:   None
     Major Position:  Prefers  local control

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                                         -156-
Stamps, J.C., P.E., Technical  Director,  Standard Electric  Co.,  3016
     Austin HW., P.O. Box 18127,  San Antonio,  TX  78218  (dated:  April
     25, 1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Stetler, C. Joseph, President, Pharmaceutical  Manufacturer's  Assoc.,
     1155 Fifteenth St., N.W., Washington,  D.C.   20005   (dated:   May
     17, 1977)

     Option Preference:   II and III combination
     Major Position:  Concerned with limiting  documentation

Strassner, Kenneth A., Regulator  Attorney-Washington Counsel's  Office,
     Kimberly-Clark Corp., 1730 Pennsylvania Ave., N.W.,  Suite  1100,
     Washington, D.C.  20006  (dated:  May 18, 1977)

     Option Preference:   III
     Major Position:  Prefers limiting number  of regulated pollutants

Studabaker, W.C., P.E.,  Environmental Engineer,  Eastern Lines,  Atchison,
     Topeka, & Santa Fe Railway Co., P.O.  Box  1738,  Topeka,  KA   66628
     (dated:  May 17, 1977)

     Option Preference:   III
     Major Position:  Utilize and build  on existing  pretreatment programs

Stull, E.B., President,  Stull  Chemical Co., 1006 Paulsen,  San Antonio,
     TX   78219  (dated: April 19,  1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Sullivan, Roger A., Director of Manufacturing, Sullivan Paper Co.,  Inc.,
     61 Progress Ave., P.O. Box 88, W. Springfield,  MA   01089  (dated:
     May 10, 1977)

     Option Preference:   III
     Major Position:  Prefers local control

Tanzer, Ernest K., P.E., Executive  Secretary,  Environmental  Steering
     Committee, Eastman  Kodak Co.,  1669  Lake Ave., Rochester, NY
     14650  (dated:  April 29, 1977)

     Option Preference:  Recommends  an alternate  option
     Major Position: Emphasizes local control  using  NYSPDES/NPDES Program

Taylor, James L., Process Control Engineer, Wastewater  Treatment Facilities
     Commission, 718 Main St., Fitchburg,  MA  01420   (dated:  April  5,
     1977)

     Option Preference:   III
     Major Position:  Prefers control of only  most hazardous  substances

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                                   -157-
Tiepel, Chairman, Environmental  Services Task Force,  Public  Technology
     Inc., 1140 Connecticut Ave.,  N.W., Washington, D.C.   20036   (dated:
     May 2, 1977)

     Option Preference:  Combination of II & III
     Major Position:  Presents a summary of the reactions of U.S.
                      urban communities

Teller, Joe P., Deputy General Manager, Gulf Coast Waste  Disposal  Authority,
     910 Bay Area Blvd., Houston TX  77058  (dated: March 28,  1977)

     Option Preference: II & III
     Major Position:  Prefers water quality variances

Thomas, S.H., Director of Environmental Services,  Owens-Corning  Fiberglass
     Corp., Fiberglass Tower, Toledo, OH  43659  (dated:   May 17,  1977)

     Option Preference:  II & III combination
     Major Position:  Combination is most time-effective  and equitable

Trefz, William C., Chief Engineer, Allegheny County Sewer Authority,
     3300 Preble Ave., Pittsburgh, PA  15233  (dated: April  29,  1977)

     Option Preference:  IV
     Major Position:  Concerned with jurisdictional  problems and prefers
                      quality variances

Troy, H. Neal, Manager-Environmental Control, Owens-Illinois,  P.O.  Box
     1035, Toledo, OH  43666  (dated:  May 9, 1977)

     Option Preference:  III
     Major Position:  Prefers local control

Thorpe, J.R., Manager of Environmental Affairs, GPU Service Corp., 260
     Cherry Hill Rd., Parsippany, NJ  07054  (dated:  May 2,  1977)

     Option Preference:  III
     Major Position:  Prefers locally-derived limits

Turney, W.G., Bureau Chief, Environmental Protection  Bureau, Dept. of
     Natural Resources, State of Michigan, Lansing, MI  48926  (dated:
     April 4, 1977)

     Option Preference:  III
     Major Position:  Prefers local control

Umlauf, Larry D., Vice President, Pet  Inc., 400 S. Fourth St., St. Louis,
     MO  63166   (dated:  May 3, 1977)

     Option Preference:  III
     Major Position:  Prefers local control

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                                   -158-


Van De Boe, Alan C., Superintendent of Sanitation, City of Quincy, City
     Hall Bldg., Quincy, IL  62301  (dated:   April  4, 1977)

     Option Preference:  II
     Major Position:  Prefers local control

Van Sicler, Richard R., Rohm and Haas Tennessee, Inc., P.O. Box 591, 730
     Dale Avenue, Knoxville, TN  37901  (dated:   April 11, 1977)

     Option Preference:  II
     Major Position:  Prefers local control

Voight, W.G., Chairman, Stinson Manufacturing Co., 555 Harriman, San
     Antonio, TX  78204  (dated:  April  195  1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Vondrick, Art F., Water & Sewers Director,  City of Phoenix, 215 E. McDowell
     Rd., Phoenix, AZ  85004  (dated:  March 28, 1977)

     Option Preference:  III
     Major Position:  Prefers local control

Vrana, Richard A., Plant Manager, Howell Hydrocarbons, P.O. Box 27776,
     San Antonio, TX  78299  (dated:   April  26,  1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Walker, Paul A., Environmental  Engineer, Hollingsworth & Vose Co., East
     Wai pole, MA  02032  (dated:  May 2, 1977)

     Option Preference:  II & III
     Major Position:  Prefers local control  with water quality standards

Walker, W. Jack, President, Greater Knoxville Chamber of Commerce, 301
     Church Ave., S.E., Knoxville,  TN  37902  (dated:  May 10, 1977)

     Option Preference:  None
     Major Position:  Water quality standards with maximum local control

Ward, Frank L., Superintendent, Municipal  Treatment Plants, High Point,
     NC  (dated:  April 25, 1977)

     Option Preference:  III
     Major Position:  Concerned with maintaining POTW iter-relationships
                      with industry

Ward, W.A., Vice President-General  Manager,  Aggie Chemical Industries,
     P.O. Box 8335, San Antonio, TX  78208  (dated:  April 22, 1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

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                                    -159-
Warr, James W., Chief Administrative Officer, State of Alabama Water
     Improvement Commission, Perry Hill  Office Park, 3815 Interstate
     Court, Montgomery, AL  (dated:  April  26, 1977)

     Option Preference:  None
     Major Position:  Concerned with delegation of authority to non-
                      NPDES states

Watson, K.S., Director of Environmental  Control, Kraft Inc., 801  Waukegan
     Rd., Glenview, IL  600025  (dated:   May 16, 1977)

     Option Preference:  II & III Combination
     Major Position:  Concerned with definition of "slug discharge"

Webb, David, Director of Operations, City of Bentonville, 115 West Central,,
     Bentonville, Ark., 72712  (no date)

     Option Preference:  I
     Major Position:  Prefers local control

Webb, Mitchell and Baxter Grier, Officers,  San Antonio Manufacturer's
     Assoc., Ill W. Laurel, Suite 228, San  Antonio, TX  78212  (date:
     April 27, 1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

Wegbreit, Sam, Box 5210, Brown University,  Providence, RI  02912 (no date)

     Option Preference:  Offers personally-derived option
     Major Position:  Gives detailed analysis

Weismantel, Guy, Western Editor, Chemical Engineering, 3200 Wilshire Blvd.,
     South Tower, Los Angeles, CA  (dated:   April 5, 1977)

     Option Preference:  None
     Major Position:  Concerned with the overall problems of implementing
                      a pretreatment program

Wells, W. James, Jr., P.E., Bell, Galyardt  and Wells, Inc., 5634 S.  85th St.,
     Omaha, NB  68126  (dated:  May 3, 1977)

     Option Preference:  None
     Major Position:  Prefers local control and water quality standards

Welsh, Gene B., Chief-Water Protection Branch, Dept. of Natural Resources,
     Environmental Protection Div., State of Georgia, 270 Washington St.,
     N.W., Atlanta, GA  30334  (dated:  April 29, 1977)

     Option Preference:  IV
     Major Position:  Prefers local control and  locally-derived treatment
                      1imits

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                                   -160-
Western Reserve Economic Development Agency,  522 Office Bldg., 918 Youngstown
     Rd., Niles, OH  44446  (dated:   May 16,  1977)

     Option Preference:  None
     Major Position:  EPA should schedule more briefings with local  officials

White, W.A., Vice President, National  Agricultural  Chemicals Assoc., The
     Madison Bldg., 1155 Fifteenth St.,  N.W., Washington, D.C.  20005
     (dated:  May 18, 1977)

     Option Preference:  II & III Combination
     Major Position:  Support local  government cooperation with industry

Willenbrink, R.V., Director-Environmental Control,  Ashland Oil, Inc., P.O.
     Box 391, Ashland, KY  41101  (dated:  May 16,  1977)

     Option Preference:  II & III
     Major Position:  Prefers addition of water quality variances

Woods, Richard H., Counsel, Ocean County Sewerage Authority, 10005 Hooper
     Ave., Toms River, NJ  08753  (dated:  May 17,  1977)

     Option Preference:  I
     Major Position:  Concerned with equity problems

Wright, James F., Executive Director,  Deleware River Basin Commission,
     P.O. Box 7360, West Trenton, NJ  08628  (dated:  May 9, 1977)

     Option Preference:  III
     Major Position:  Prefers local  enforcement

Young, Earle F., Jr., Director-Environmental  Affairs, American Iron and
     Steel Institute, 1000 16th St., N.iJ., Washington, D.C.  20036 (dated:
     April 19, 1977)

     Option Preference:  III
     Major Position:  Prefers local  control

Young, G.R., President, Southern Chemical and Refining Co., P.O. Box
     552, Melbourne, FL  32901  (no date)

     Option Preference:  None
     Major Position:  Not relevant


Yerges, Howard, Vice President-Engineering, Banquet Foods Corp., 100
     N. Broadway, St. Louis, MO  63102  (dated:  April 29, 1977)

     Option Preference:  None
     Major Position:  Prefers local  control

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                                  -161-
Zainea, Joseph G., City Manager, City of Grand Rapids,  MI   49502

     Option Preference:  II
     Major Position:  Prefers local  control

Zenie, Etnil, Supervisor of Industrial Waste Control,  Monroe Co. Div.
     of Pure Waters, 65 Broad St.,-Rm. 100,  Rochester,  NY   14614   (dated:
     Mya 16, 1977)

     Option Preference:  III
     Major Position:  Prefers technology-based standards applied  to  effluent
                      of POTW

Zohn, J., P.E. Director, Dept., of Public Works, Wastewater Management
     Div., 5055 Washington St., Denver, CO  90216  (dated:   April,  1977)

     Option Preference:  II & III
     Major Position:  Prefers water quality variances

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                                   -162-
                       ADDEMDUM TO LOG OF LETTERS


Bielo, Robert J., Susquehanna River Basin Commission, 5012 Lenker Street,
     Mechanicsburg, PA  17055  (Dated:  April 22, 1977)

     Option Preference:  IV
     Major Position:  Prefers Federal Standards and
                      Local Control

Bigler, Daniel E., New Jersey Water Pollution Control Association,
     318 - 76th Street, North Bergen, NJ  07047
     (Dated:  April 28, 1977)

     Option Preference:  None
     Major Position:  Prefers Local Control

Costello, John G., Bergen County Sewer Authority, Box 122,
     Little Ferry, New Jersey  07643  (Dated:  June 2, 1977)

     Option Preference:  III & II
     Major Position:  Prefers Local Control

Green, John A., U.S. EPA, Region VIII, 1860 Lincoln Street
     Denver, Colorado  80203 (Dated:  June 10, 1977)

     Option Preference:  I
     Major Position:  Recognition of Resource Implications of
                      all Options Inadequate

Nelson, Myron K., Johnson County Unified Sewer Districts,
     P. 0. Box 39, Shawnee Mission, KA  66201 (Dated:  June 2, 1977)

     Option Preference:  III
     Major Position:  Prefers State Control

Todd, S. K., United States Steel Corporation, 600 Grant Street,
     Pittsburg, PA  15230  (Dated:  May 4, 1977)

     Option Preference:  III
     Major Position:  Prefers Local Control

Van De Boe, Alan C., City of Quincy Sanitation Committee, Quincy,
     Illinois  62301  (Dated:  April 20, 1977)

     Option Preference:  None
     Major Position:  Prefers Local Control
                                    iU.S.GOVERNMENTPRINTINGOFFICE: 1977-260-880:84

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