DRAFT
FINAL REPORT
An Analysis of Planning
for
Advanced Wastewater Treatment (AWT)
By
Jerome Horowitz
Larry Bazel
Prepared for:
Headquarters
U. S. Environmental Protection Agency
Office of Planning and Evaluation
In response to:
EPA Contract 68-01-4338
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ABSTRACT
Federal grants for Advanced Wastewater Treatment (AWT) should
be stopped until two fundamental defects have been corrected:
(1) The planning is often technically unsound, and the
technical analysis specified in section 303(d) of
P.L. 92-500 is ignored, oversimplified, or falsified.
(2) The apparent need for AWT facilities varies greatly
from State to State, and there is no uniform National
policy to prevent some States from getting many large
AWT grants while others do not qualify for any at all.
The great differences in AWT planning among the States do not relate to
great differences in water quality or to pollution problems; rather, the
differences must be traced to enormous disparities in water-quality stan-
dards, implementation plans, State laws and regulations, and perceived
needs for treatment works.
Until these two defects have been worked out, the Federal grant
program may be legitimately charged with hidden favoritism, unfairness,
noncompliance with P.L. 92-500, and scientific incompetence. Meanwhile,
Federal funds can be put to good use by building more secondary plants,
correcting problems in sewer systems, and (in some instances) treating
urban stormwater.
We therefore recommend that EPA should ask Congress to delete
sections 303 and 510 from P.L. 92-500. Section 303, which covers water-
quality standards and wasteload' allocations, does not produce technically
credible planning. Section 510 empowers the States to set arbitrarily
severe treatment requirements requirements leading to very expensive
treatment plants that may have little effect on water quality.
These conclusions and recommendations were derived from six
detailed case studies, selected in cooperation with EPA Regional Offices
and State pollution-control agencies as outstanding examples of AWT plan-
ning. Nearly every other example of AWT planning in the U.S. is probably
at least as poor as these six.
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"Ye shall know them by their fruits. Do men gather
grapes of thorns or figs of thistles? Even so, every
good tree bringeth forth good fruit.... Wherefore by
their fruits ye shall know them." Matthew 7:16-20
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ACKNOWLEDGEMENTS
We could not have written this report without the help of many
conscientious workers in Federal, State, regional, and local agencies.
Our debts are large and varied. Many people helped us locate documents
and track down leads. Nearly everyone we asked lent us material or allowed
us to photocopy what we needed. Nearly everyone we dealt with was helpful
and cooperative; they did more than they had to, and they did it willingly.
It is a privilege to thank them by name, but we are so indebted to so many
people, we can do little more than list their names. There were many
others whose names we don't even know, and we are grateful to all of them
too.
As usual, we are indebted most of all to our incomparable friend
and teacher, Howard L. Cook (consultant, Washington, D. C.). He helped us
at every step, at all hours of day and night. He reviewed large portions
of this report in draft and helped us make the issues clearer. His un-
failing good sense, sage technical advice (especially on matters pertaining
to hydraulics and water policy), and Olympian perspective sustained us
through many difficulties. Without his generous help, our report would
have been much poorer.
lil
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Our Project Officer at EPA Headquarters, Truman P. Price,
extended every courtesy to us. He participated in selecting the case
studies and helped us sort out the many candidates that had been sug-
gested. He was unfailingly helpful and understanding, and he ensured
that anything we might need from EPA Headquarters was made available.
When we left Washington, D. C., to gather material in the
field, our debts to agencies and individuals rapidly multiplied. We
organize them here in large blocs, one case study at a time, with apolo-
gies for being so impersonal.
Largo, Florida
U.S. EPA, Region IV: Mary Veale, Gene McNeil, George J. Collins,
Robert J. Freeman, Gary Lubin, J. William Gunter, Raymond D. Cozart,
Robert Harnley, and Joseph R. Franzmathes. We are especially grateful to
Mr. Freeman.
Florida Department of Environmental Regulation: G.J. Thabaraj,
Wayne Stevens, John Jackson, Banks Vest, Tim S. Stuart, Katherine C. Caleen,
R.L. Caleen, Jim Santarone, Gene Nowak, Karl Starzinger, Howard Rhodes,
Ted Mikalsen, Richard Wieckowicz, George J. Horvath, Troy Mullis, and
Howard Curren. We are especially grateful to Dr. Thabaraj and to Mr. &
Mrs. Caleen.
Tampa Bay Regional Planning Council: Ron N. Armstrong.
Largo STP: Richard L. Bragg, Eric Blankman, Bob Finch.
Quentin L. Hampton Associates, Inc.: Art Argerenon.
Wallkill Valley. New Jersey
U.S. EPA, Region II: Peter F. Cerenzio, Thomas D. Morris,
Charles N. Durfor, James P. Rooney, Kenneth S. Stoller, and William
H. De Pouli, Jr. We are especially grateful to Mr. Morris.
N.J. Department of Environmental Protection: S.T. Giallella,
Steven Pacenka, Robert H. Soldwedel, Paul Schorr, and Dong Whang. We
are especially grateful to Mr. Giallella.
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Sussex County Municipal Utilities Authority: Alexis A. Lundstrom.
Lee T. Purcell Associates: Lee T. Purcell, Jr.
Springfield, Missouri
U.S. EPA, Region VII: Donald E. Sandifer, W.L. Banks, Mike
Thomas, Len Harrington, Robert J. Steiert, Donald C. Draper, Ted Geppert,
William J. Keffer, and Dale B. Parke. We are especially grateful to Mr.
Banks and Mr. Sandifer.
Missouri Department of Natural Resources: Charles A. Stiefermann,
Paul E. Decker, Rich MacMillan, and V. Ramiah. We are especially grateful
to Mr. Stiefermann and Mr. Ramiah.
Missouri Conservation Commission: James R. Whiteley.
Missouri Geological Survey: James Hadley Williams.
City of Springfield: Charlene Chandler, Joyce Reese, William
C. Hayes, Jr., Ron Martin, and Robert R. Schaefer. We are especially
grateful to Mrs. Chandler and Mr. Schaefer.
Hood-Rich Architects and Consulting Engineers: Paul T. Hickman.
Consoer, Townsend & Associates: Cody H. Russell, Walter G. Shifrin.
De Pere, Wisconsin
U.S. EPA, Region V: Steve Dudas, Kent Fuller, Howard Zar, Walter
L. Redmon, Shirley A. Mitchell, and Jon-Eric T. Stenson.
Wisconsin Department of Natural Resources: Jerome R. McKersie,
Dale J. Patterson, Duane Schuettpelz, and John Cain. We are especially
grateful to Mr. McKersie.
Fox Valley Water Quality Planning Agency: John Laumer, Tom
Windau.
U.S. Army Corps of Engineers, Kaukauna: Ross Plains.
City of De Pere: J.J. Smits, David E. Benner, Andrew S.
Radetski.
Robert E. Lee & Associates: James M. Jakubovsky.
University of Wisconsin @ Green Bay: James H. Wiersma.
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San Jose/Santa Clara. California
U.S. EPA, Region IX: Donald A. Anderson, Richard A. Coddington,
George Teramoto, and Philip C. Woods. We are especially grateful to Mr.
Anderson.
California Regional Water Quality Control Board, San Francisco
Bay Region: R. Robert Scholar, Harold J. Singer, Valentine J. Miller,
Lawrence P. Kolb, M. Hossain Kazerai, Griffith L. Johnston, Robert J. Roche,
Alice M. De Castro, and Mirra A. Morrison. We are especially grateful to
Mr. Scholar.
California State Water Resources Control Board: Lyndel Melton.
Bechtel Corporation: Carol M. Harper.
San Jose/Santa Clara STP: Frank M. Belick and Edward R. Becker.
Mr. Belick is, without any doubt, the most thoughtful and helpful soul we
have had the pleasure of meeting in years. It's worth going to San Jose
just to meet him.
Spokane, Washington
U.S. EPA, Region X: William B. Schmidt, Ron Kreizenbeck, John
Yearsley, Robert Rulifson, George Abel, Kenton L. Lauzen, Jack E. Sceva,
and Esther Ulrich. Although all the EPA Regional Offices we worked with
were helpful, Region X was easily the most helpful, and we are greatly
indebted to them for their exceptional kindness.
Washington State Department of Ecology: Jeanne Rensel, Rhys
A. Sterling, Phil H. Williams
Pacific Environmental Consultants: Thomas G. Haggarty.
Washington State University: William H. Funk.
City of Spokane: Ingrid Haynes, Roger James, and Glade Wilson.
Robert M. Kennedy and William A. Anderson of Kennedy Engineers
were, as usual, cooperative and imaginative colleagues.
Gladys Hayes and Cindy Robey worked long hours to get this
report typed.
Our families and friends put up with our long absences from
home while we did our field work, and put up with more long absences
vi
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while we wrote this report. Their forebearance has been a mystery
and something of a miracle.
J.H.
L.B.
McLean, Virginia
July 1977
vii
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Alice laughed. "There's no use trying," she
said: "one can't believe impossible things."
"I daresay you haven't had much practice,"
said the Queen. "When I was your age, I always
did it for half-an-hour a day. Why, sometimes
I've believed as many as six impossible things
before breakfast." Lewis Carroll, Through the
Looking Glass
viii
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CONTENTS
Section Page
ABSTRACT . i
ACKNOWLEDGEMENTS ill
1 THE REPORT IN BRIEF 1
Inequities Inherent in P.L. 92-500 1
Planning Is Incompetent and Differs from State to State 1
r
An Inseparable Cluster of Related Issues 2
Six Detailed Case Studies 3
A Word to the Reader 3
2 CONCLUSIONS 5
3 RECOMMENDATIONS 23
Scientific 23
Administrative 29
Legislative 34
4 LARGO, FLORIDA 39
4.1 The Issues in Brief 39
4.2 The Setting 42
4.3 The Largo STP 43
4.4 The Success Story 44
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Section Page
4.5 The Confusion 44
4.6 Technical and Bureaucratic Definitions of AWT 46
4.7 Chronology of Events at Largo 47
4.8 Florida's Pollution-Control Agencies: DPC and DER 53
4.9 The Wilson-Grizzle Act and Florida's Pollution-
Control Agencies 53
4.10 -The Definition of AWT and Largo's NPDES Permit 56
4.11 An Alternative to AWT 58
4.12 Plans for the Largo STP .61
4.13 The Plans and the Cross Bayou Canal 64
4.14 AWT Planning and the Pollution-Control Agencies 65
4.15 U.S. EPA and the Plans 66
4.16 The Tampa Bay Regional Planning Council 68
4.17 The Planning Requirements of P.L. 92-500 69
4.18 Section 201(g)(3): Infiltration and Inflow
Into the Sewers 69
4.19 Section 208: Planning for Areawide Management 73
4.20 Section 303(c): Revising Water-Quality
Standards (WQS) 74
<>
4.21 Section 303(d)(l): Segmentation and Maximum
Daily Load 83
4.22 The "Wilson-Grizzle Limits" Method 85
4.23 The Mathematical-Modeling Method 88
4.24 The "No-Discharge" Method 90
4.25 Methods and Realities 90
4.26 Phosphorus: Where Does It Come From? 90
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Section Page
4.27 The Dubious Rationale for Phosphorus Removal 100
4.28 The Dubious Rationale for Nitrogen Removal 104
4.29 Real Water-Quality Problems: Red Tides and
Algal Rot . 108
4.30 Red Tides 109
4.31 Algal Rot 112
4.32 Bibliography 119
5 THE WALLKILL RIVER VALLEY, NEW JERSEY 133
5.1 The Issues In Brief 133
5.2 Case History 137
5.3 Bibliography 145
6 SPRINGFIELD, MISSOURI 159
6.1 The Issues In Brief 159
6.2 Case History 163
6.3 Bibliography 199
7 DE PERE, WISCONSIN 219
7.1 The Issues In Brief 219
7.2 Case History 225
7.3 Bibliography 239
8 SAN JOSE/SANTA CLARA, CALIFORNIA 251
8.1 The Issues In Brief 251
8.2 Case History 255
8.3 Bibliography 287
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Section Page
9 SPOKANE, WASHINGTON 311
9.1 The Issues In Brief 311
9.2 Case History 317
9.3 Bibliography 387
10 EPILOGUE: AN ADVENTURE 419
APPENDIX A: BENEFIT-COST EVALUATION OF AWT PLANTS:
FIVE CASE STUDIES
APPENDIX B: AREA MAPS FOR THE SIX CASE STUDIES
APPENDIX C: ABBREVIATIONS USED IN THIS REPORT
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AN ANALYSIS OF PLANNING FOR ADVANCED WASTEWATER TREATMENT (AWT)
Case Studies In
Largo, Florida
The Wallkill River Valley, Sussex County, New Jersey
Springfield, Missouri
De Pere, Wisconsin
San Jose/Santa Clara, California
Spokane, Washington
U.S. Environmental Protection Agency
Waterside Mall
401 M Street, S.W.
Washington, D. C. 20460
EPA Contract No. 68-01-4338
July 1977
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This report is being reviewed by the Environmental
Protection Agency. The opinions, findings, conclusions
and recommendations expressed are those of the authors
and do not necessarily reflect the views of the Agency.
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1. THE REPORT IN BRIEF
Inequities Inherent in P.L. 92-500
A fundamental inequity is written into sections 301(b)(l)(C)
and 510 of the Federal Water Pollution Control Act. These sections
empower the States to adopt pollution-control measures that are more
stringent than those set by the U.S. EPA. Some States (e.g. Texas) re-
quire AWT everywhere; others (e.g. Kansas) never require it. There is
no uniform National policy to prevent this inequity, which provides
large Federal subsidies to States that may be setting unrealistically
demanding requirements for pollution control requirements leading to
very expensive treatment plants that may have little effect on water
quality.
Planning Is Inadequate and Differs from State to State
The planning sequence leading to AWT is complex, and all the
principal structures in the sequence vary greatly among the States:
WATER-QUALITY STANDARDS are extremely variable and rarely make
sense, despite public participation and EPA review. They
are commonly filled with vagueness, paradox, internal con-
tradiction, hedging, and simplistic notions of causation.
WATER-QUALITY SURVEYS are generally suspect on technical grounds,
beset with irregularities in sampling and analysis, and
naive in matters pertaining to hydraulics, sediments, and
water chemistry.
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MATHEMATICAL MODELS are oversimplified and filled with elaborate
guesswork. They are intricate, abstruse fictions. They
rarely account for even the principal features of the
waterway they claim to represent, and they are usually
built from inadequate data on hydrodynamics and water quality.
WASTELOAD ALLOCATIONS are the basis for discharge permits. They
are principally derived from mathematical models, and share
all their weaknesses. Section 303(d) of P.L. 92-500 re-
quires wasteload allocations as the technical basis for <
AWT discharge permits, but this requirement is universally
ignored, over-simplified, or falsified.
DISCHARGE PERMITS embody AWT requirements. They are commonly
filled with confusions between wastewater effluents and
the quality of the receiving water. Sometimes there are
uniform effluent limits for an entire State, with no
adjustment for local conditions or probable improvements
in water quality; uniform effluent limits do not recognize
any difference between an ocean and a puddle. In common
with water-quality standards, discharge permits are rich
in vagueness and internal inconsistency.
An Inseparable Cluster of Related Issues
AWT cannot be meaningfully addressed apart from a cluster of
interdependent issues. Degree of treatment (AWT versus secondary) must
be evaluated in a context of related questions:
WHAT IS TO BE TREATED? How many homes? How many industries?
What kinds of industries? How much industrial pretreat- ,
ment? How big will the sewer-service area be? How much .
stormwater will be treated? How much growth should be
planned for?
HOW WILL WASTEWATERS BE CONVEYED? How many sewers? What kinds
of sewers? How large? Where emplaced? How will peak
flows be handled? Will storm sewers be entirely separate?
How much leakage in the sewer system is tolerable? How
should the budget for the sewer system be allocated among
sanitary sewers, storm sewers, lift stations, pumping
stations, interceptors, siphons, and river crossings?
HOW MUCH CENTRALIZATION SHOULD THERE BE? Will one treatment
plant be enough, or should there be several? How much of
the existing facilities can be salvaged? Where should the
treatment plants be built?
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WHERE SHOULD THE EFFLUENTS BE DISCHARGED? Into which watercourse?
At how many points? Should the discharge be diffused and
submerged? Should the wastewaters be disposed of on land,
with no discharge to any waterway? Will groundwaters be
contaminated?
Six Detailed Case Studies
We sought the cooperation of EPA Regional Offices and State
pollution-control agencies in selecting six outstanding cases of AWT
planning for detailed analysis. Even in these six exemplary cases, many
of the AWT-related issues were not given the attention they merit; the
planning suffered from large stretches of technical incompetence; and the
inequities inherent in P.L. 92-500 were evident everywhere we looked.
A Word to the Reader
The six case studies occupy most of this report. They are not
easy reading because the material is often very technical and our treat-
ment of it is concentrated. We rarely pause for long explanations and
recapitulations. Only in our first case study (Largo, Florida) do we go
into lavish detail. In all the other case studies we cover a great deal
t
of material, and we cover it quickly. At the beginning of each case,
however, we summarize the most important issues and comment on their
significance. You may find it helpful to refer to these summaries from
time to time; it is easy to lose sight of the major issues as you slog
through the detailed histories.
Except for Largo, all the case studies are organized into three
sections: (1) The Issues in Brief, (2) History, and (3) Bibliography.
The historical analyses are given in chronological order. As the history
unfolds, the cast of characters swells and the planning issues grow
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increasingly complex. We have studiously tried to avoid over-simplifying,
but we have done our best to be clear. The histories are not light read-
ing because the AWT planning did not unfold in simple chronological order.
However, the strict chronological order lets you follow the issues as they
developed. We have given cross-references wherever we thought they might
help.
We have tried to be frank and candid. We may have been wrong
on occasion (though we strived for accuracy and fairness), but we resisted
the temptation to be vague, to hedge our bets, to cover our tracks.
Costs and benefits of AWT in these case studies are separately
treated in Appendix A, prepared by Kennedy Engineers, Inc., of San
Francisco. The Kennedy team compared AWT with secondary treatment (using
EPA's definition of secondary treatment). Their analysis shows what a
comparable secondary plant would have cost; it also shows the difference
between AWT and secondary effluents in each of the five cases they
evaluated. They explicitly identify their assumptions and their sources
of information.
The bibliographies are long and detailed. We hope that they
are thorough. They include all the material we used in our analyses
we went through a lot of material. We had to, and if time had permitted,
we would have gone through even more. If we have been successful, the
histories will show you how the planning developed; the bibliographies
will give you complete references to the material we used so that you
can get more detail for yourself and explore many important issues we
scarcely touched. Maps are in Appendix B; abbreviations are explained
in Appendix C.
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2. CONCLUSIONS
1. Our six case studies were not hastily selected. They were
carefully chosen from lists of outstanding candidates prepared by EPA and
State agencies. We tried hard to find the best the country had to offer.
It saddens us to report that none of the six can be held up as a model of
successful planning. It is probably safe to assume that nearly every
other example of AWT planning in the U.S. is at least as poor as these six.
2. Although AWT plans were repeatedly reviewed by many agencies,
massive faults were rarely identified. The review process was grossly
inadequate in all six cases.
3. The Federal Water Pollution Control Act (P.L. 92-500) offers
two principal justifications for AWT:
Section 303(d) justifies AWT through water-quality
standards (WQS), mathematical models, and wasteload
allocations.
Sections 301(b)(l)(C) and 510 empower the States to
require AWT (or any other pollution-control requirement)
at their discretion, so long as their requirements are
more demanding than Federal requirements.
In our six cases, both justifications were bungled.
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4. The justification based on WQS and mathematical models
came to grief because (a) the WQS were a tissue of ambiguity and paradox,
and (b) the mathematical models even at their best were filled with
unverified assumptions, elaborate guesswork, and egregious oversimplifications.
5. The justification based on State requirements fell apart
because the requirements were not accurately applied. Here is a light-
hearted analogy. Suppose that State law requires all canaries to be
housed in gilded cages. In enforcing the law, the State misidentified
canaries as robins (and therefore did not require gilding where the law
specified it) or mistook falcons for canaries (thereby requiring falconers
to gild cages the law never mentioned). We found both kinds of errors in
our six case studies. Springfield, Missouri, was a "robin"; Largo, Florida,
was a "falcon."
6. When P.L. 92-500 was debated in Congress, proponents of the
bill contended that it would do away with great inequities among the States
by establishing uniform, nationwide standards for wastewater treatment.
Our six cases show nothing of the kind. By permitting enormous variations
among the States variations in WQS, mathematical models, wasteload
allocations, pollution-control requirements the law perpetuates these
inequities.
7. The various planning programs usually lead separate lives:
setting WQS, surveying water quality and wastewater discharges, developing
mathematical models and techniques for wasteload allocations, preparing
basin plans, areawide plans, facility plans, discharge permits, and analyses
of "environmental impact." The unresolved discrepancies among these planning
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activities induce a kind of organizational schizophrenia. A concluded
that B implied C, but B assumed that D tentatively meant C, and that C was
being evaluated by E; but E's technical committee was instructed that C
must be coordinated with F, and F couldn't be funded until B had reviewed
A .... Consequently, everybody spent a lot of time going to meetings and
reviewing position papers.
8. We are not the first .to observe that planning is mired in
paper, scattered, and poorly coordinated. Far too much of the planning
we reviewed was paper-shuffling, a bureaucratic exercise rather than, a
concerted attempt to find out the facts and devise meaningful cures for
long-standing pollution problems.
9. Pollution-control agencies are bigger and richer than ever.
There is plenty of talent in the agencies and in their retinues of consul-
tants. However, these resources are not being effectively mobilized. The
busy business of planning consumes time and talent. It eats up budgets.
It blurs issues where sharp focus is indispensable. It values quantity
over quality. It diverts skills from meaningful work to facile elaborations
on paper. Massive planning documents are thrown together in haste, without
adequate attention to establishing the facts, without due regard for truth,
with speed and size displacing such virtues as accuracy and fairness. It
is not an edifying spectacle. AWT planning under P.L. 92-500 did not
initiate this misapplication of resources, which has been common for gen-
erations, but it has exacerbated the problem.
10. AWT isn't cheap. Its voluminous planning consumes resources,
beginning with time, paper, and manpower. An AWT plant always costs more
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than a comparably sized secondary plant, and the Federal Treasury sub-
sidizes most of the construction costs. AWT plants always cost more to
run than secondary plants they consume more energy and more chemicals.
Local sanitary districts must absorb all the running costs. The districts
might be happy to bear the additional cost if they could be sure that they
were getting something, for their money, that AWT would make a substantial
difference to water quality^ that it would convert a polluted river into
a valuable resource, an asset to the community. There is no assurance in
our six case studies. AWT was not adequately justified in any of them.
11. There must be a profound revulsion to wet feet, a distaste
for long hours on the open water, a dislike of careful scientific measure-
ment. How else can one explain the extreme reluctance of pollution-control
agencies to study water? The talk of water-quality improvement, aquatic
ecology, non-degradation, and environmental integrity is mostly talk.
Little time or money is actually spent on learning how a body of water
behaves, how it responds to pollution, how it changes with the seasons,
how it is modified by resource development, how it responds to unusual
weather or hydraulic conditions. Surprisingly little is known about water
quality or the factors that influence it.
Costly pollution-control projects are commonly built with almost
no real knowledge of the waters that are to be protected by the generous
investment in treatment facilities. The investment in public works far
outstrips the investment in positive knowledge. The poverty of knowledge,
the slender basis for massive investments in AWT facilities, the doubtful
validity of many of the arguments advanced for AWT our six case studies
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return to these points over and over again. There is no escaping them.
The meager sources of data (usually of doubtful validity) have been
stretched over a framework of assumptions and oversimplifications, then
plastered under a heavy facade of paper. The paper does not strengthen the
planning structure.
The planning is so far removed from reality, one must combat the
illusion that it is a desperate fantasy world, something that Franz Kafka
might have imagined. And indeed he did:
"Poseidon sat at his desk and calculated. The administra-
tion of all water gave him endless work. He could have
had helpers, as many as he wanted, and he did have many;
but since he took his job in earnest, he always recalcu-
lated everything himself, so his helpers didn't help much.
It can't be said that he liked his work....
"What most irritated him and this, largely explains why
he disliked his job was to hear the idea people had of
him: how he was forever gallivanting through the waves,
trident in hand. But all the while he sat here in the
ocean depths, calculating constantly. Every now and then
a trip to Jupiter would break the monotony, but he returned
more furious than ever. So he had scarcely seen the sea,
only glimpses on quick trips to Olympus, and had never
really gotten to know it." Franz Kafka, Parables and
Paradoxes (trans, by J.H.)
12. In each of our case studies, there was little relation
between the WQS and the substances that AWT will remove. Phosphorus is
rarely mentioned in WQS anywhere, though phosphorus removal is one of the
most common types of AWT. Ammonia fares somewhat better, but not much.
Suspended solids are almost never included in WQS, though facilities for
removing unusual quantities of suspended solids are extremely common in
AWT plants. Why are these substances so dangerous that they must be
removed from wastewaters, but not important enough for inclusion in the
WQS? This discrepancy is always difficult to make sense of, but it is
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particularly baffling when AWT is a planning issue. After all, P.L. 92-500
requires AWT when ordinary secondary treatment cannot ensure compliance
with WQS. In theory, the relation between WQS and pollutant removal
should be especially close when AWT is involved; in fact, it isn't.
One can readily understand why WQS are used so little. They are
usually vague, hedged, non-numerical, internally contradictory, paradoxical,
statistically ambiguous, and given to simplistic notions of causation.
They commonly fail to distinguish between water quality and wastewater
quality. These failings are analyzed at length in our case histories.
When the WQS are filled with ambiguity and contradiction, they
cannot be meaningfully used in pollution-control planning. For meaning-
ful compliance with section 303(d) of P.L. 92-500, the WQS must be clear
and unambiguous. Until the WQS are greatly improved, one should not
expect much of the planning required by section 303(d) the only section
of P.L. 92-500 that provides a scientific basis for AWT planning.
13. The assumptions and oversimplifications in mathematical
models necessarily weaken the case for AWT,. One of our cases, San Jose/
Santa Clara (SJ/SC), offers an exceptional example of the trouble that
models can cause. The models used in SJ/SC were unusually elaborate and
well documented. San Francisco Bay has been studied by several genera-
tions of scientists, and it has been modeled repeatedly. The AWT decision
for SJ/SC was largely justified by one of these models. However, a later
model, a refined version of the earlier one, showed that AWT would not
indeed, could not cure the water-quality problems in south San Fran-
cisco Bay and its tidal tributaries. Planners are new in a quandary. They
have built some of the facilities recommended by the earlier model, but
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cannot decide whether to proceed with the rest. They now question the
assumptions and oversimplifications that the modelers had freely admitted
to all along.
The new model for SJ/SC shows that the extensive marshes around
the south bay are responsible for large quantities of deoxygenating matter.
This conclusion has not been supported by measurements of the marshes,
and State planners now insist that the model should not be believed until
actual measurements have established the importance of the marshes (and
several other phenomena) beyond any reasonable doubt. This conclusion is
rather belated, since the earlier models contained even more assumptions
and oversimplifications than the controversial new one, but better late
than never.
Even after the marsh loads have been studied, the model will
still have serious shortcomings. It will still be unable to simulate the
powerful tides that surge through the south bay and its tributaries. The
tides change the water level by about nine feet during the course of a
day. As the water level is raised and lowered, the salt marshes are
covered and uncovered, alternately drowned and drained. The tides also
control the movement of water, but not nearly enough is known about the
hydrodynamics of the south bay and its tributaries to deal with them
meaningfully in any model. In its current version, the model can simu-
late only the average oxygen concentration in the water, but the WQS for
these waters set limits on both the minimum oxygen concentration and the
lower tenth percentile. In .short, the marsh studies will certainly
improve the model, but many more improvements will have to be made before
the model can claim to represent these complicated waters.
11
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The mathematical model of the Wallkill River (our case study in
New Jersey) also assumes that marshes are responsible for many of the
water-quality problems in the river. The model predicts that the large
marshes below the proposed STP outfall will seriously affect the dissolved
oxygen (DO) during severe summer droughts. No one has ever studied DO in
marshy reaches of the Wallkill during hard summer droughts, and there is
no evidence of a DO problem in the river. Everything depends on the
accuracy of the model's predictions. If the marshes should consume a
little more DO than the modelers have assumed, AWT will not cure the DO
problem because the marshes will cause the river to fall below its,DO
standard anyway. Without accurate measurements of the marsh loads, the
model is little more than an elaborate guess.
The Wallkill model guesses and oversimplifies in other ways as
well. Anyone can see that the shallow Wallkill is carpeted with rooted
aquatic weeds, but the weeds have been neglected in accounting for the
oxygen regime of the river. The rooted weeds are nourished both by
the mud in the riverbed and by the water in the river. They are un-
likely to be greatly affected by AWT, but they are certain to have a
profound effect on the oxygen regime of the river. (By draining the
marshes and removing the sediments that support the growth of these aquatic
weeds, the Wallkill would have much higher concentrations of DO and more
capacity for assimilating the urban wastes from Sussex County; however,
it is extremely unlikely that marsh drainage or sediment removal would
be approved by environmentalists and planners.) The model ignores the
weeds, guesses at the marshes, and guesses at the oxygen regime of the
river during summer droughts.
12
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Unlike California, the planners in New Jersey have not yet
insisted that the Wallkill model should not be believed until its assump-
tions about the marshes have been verified by accurate measurements.
Perhaps that is yet to come.
In both SJ/SC and the Wallkill, the modelers argued that decay-
ing organic matter from the marshes uses up much of the assimilative
capacity of the receiving waters, leaving very little capacity to assimi-
late wastes from STP discharges. The modelers may be right the
hypothesis is plausible. But they cannot yet prove they are right, and
until they can, AWT in these areas amounts to a costly conclusion from
an unproven premise.
We must emphasize that the models used in SJ/SC and the Wallkill
were unusually good vastly superior to the usual "canned" models.
They were far superior to the other models we reviewed in these case
studies. SJ/SC was easily the most sophisticated of the lot. It is no
accident that the most sophisticated model is now the most controversial.
With growing sophistication elsewhere, one should expect that the results
of earlier modeling efforts will be doubted more and more. As the models
are cast into doubt, the conclusions derived from them will become
doubtful too, and AWT is a common conclusion.
14. AWT is not likely to cure the water-quality problems that
were identified in any of our case studies.
j* The Tampa Bay Complex in Florida will not be affected by the
new facilities in Largo, which is too small to make much difference to
the bay complex. Most of the phosphorus that enters the bay complex
comes from the extraordinary phosphate deposits and the enormous
13
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concentration of phosphate industries in this part of Florida, which
produces most of the phosphorus in the U.S. and about a third of all the
phosphorus in the entire world. Red tides and algal rot the two most
serious problems in the bay complex are not caused by urban wastewater
or by phosphorus; they are caused by floods and on-shore winds.
AWT facilities for the Wallkill River Valley in New Jersey have
been designed to cure a DO problem. There is no evidence of a DO problem
in the river. The problem exists only as the prediction of an oversimpli-
fied, inadequately verified mathematical model. If the marshes and the
aquatic flora consume a little less DO than the modelers have assumed,
AWT will be wasteful because there will be no DO problem in marshy reaches
of the river. The Wallkill marshes are important in another way as well.
Although there is'no evidence of a DO problem in the Wallkill, nearly every
sample ever taken from the river is loaded with bacteria. However, it is
not clear how much of the bacterial pollution should be attributed to
sewage and how much to saprophytic bacteria flourishing in the marshes.
The outstanding problem in Springfield, Missouri, is persistent
fishkills in the James River. The fishkills are known to occur only in
wet weather, when a storm drenches Springfield before it hits the rest of
the area. There is no question that stormwater is somehow (no one knows
precisely how) the necessary agent for killing fish. The new AWT facili-
ties will do almost nothing about the stormwater, and the problem of fish-
kills is expected to grow worse after the AWT facilities begin opejrating.
The estuary of the Fox River, Wisconsin, is one of the most
polluted waters in the State. The little city of De Pere, at the head
of the estuary, is too small to have much effect on this river, which
i
14
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receives the wastes from a large complex of industries (especially paper-
mills), from several larger cities upriver, and from the city of Green
Bay. De Pere is the only wastewater source in the estuary required to
provide AWT. A very large proportion of the wasteload in De Pere comes
from two industries (a meat-packer and a dairy), which send their waste-
waters to De Pere's STP for treatment. By severely curtailing these two
industrial wasteloads, either by pretreatment measures or by making the
industries build their own facilities for treatment and separate discharge,
many of the problems at De Pere's STP would vanish.
South San Francisco Bay and its tidal tributaries will, accor-
ding to the most recent planning documents, continue to have serious
water-quality problems no matter what SJ/SC is required to do. Keeping
the discharge where it is and upgrading waste treatment will not cure
these problems, and moving the discharge far out into the bay won't cure
them either. Twenty-five years of planning have ended in this blind
alley, and no one knows a way out. Like De Pere, SJ/SC treats large
quantities of waste from the food-processing industry, and these wastes
stress nearly every process and facility at the STP. Paradoxically, AWT
was largely justified by the need to remove ammoniacal nitrogen, but
cannery wastes (the largest sources of industrial waste in the area) are
virtually ammonia-free.
Over unusually strenuous objections from the city, Spokane has
been required to build facilities for phosphorus removal, on the unproven
theory that phosphorus from Spokane controls the growth of algae in Long
Lake, a hydropower reservoir just downriver. It has not been shown that
phosphorus from any source causes the algal blooms, and there are several
15
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other large sources in the drainage basin, including the sediments them-
selves. It has not even been shown that algae cause the deoxygenation in
Long Lake during the summer. There are two other likely causes: (1) sedi-
ment oxygen demand, and (2) entrapment of dispersed matter having long-term
oxygen demand matter carried into the reservoir by Spring floods and
trapped there during the summer. Neither of these explanations has been
looked into.
I
15. Faulty sewers can cause problems when problems are least wel-
come. Section 201(g)(3) of P.L. 92-500 forbids grants for treatment works
"unless the applicant shows to the satisfaction of the Administrator that
each sewer collection system discharging into such treatment works is not
subject to excessive infiltration." The words "satisfaction" and "excessive"
must be elastic: Two of our case studies have serious problems with infil-
tration and inflow (Springfield and Spokane). Section 201(g)(3) mentions
only infiltration, but EPA also requires analyses of inflow, and for good
reason. But tight or leaky, separate or combined, sewers cause problems,
and there is no uniform National policy for dealing with them.
Our case studies demonstrate how non-uniform these policies are.
San Jose/Santa Clara (SJ/SC) has fairly tight, fully separated sewers.
Springfield has serious infiltration and wet-weather overloading. Spokane
has severe inflow and bypassing from combined sewers. Yet all three were
awarded AWT grants, presumably because the Administrator was satisfied that
their sewer systems were "not subject to excessive infiltration." Whatever
else this may show, it does not show even-handed administration of the law.
SJ/SC has plenty of hydraulic capacity for wet-weather flows be-
cause its design was dictated by the canneries, which are active only in dry
16
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weather. Besides, discharges from the storm drains never get to the STP.
However, the County Health Department has complained for years about fishkills
associated with discharges from the storm drains. Shouldn't toxic stormwater
be treated? SJ/SC is in the middle of a National Wildlife Refuge.
The persistent fishkills below Springfield have been traced to
stormwater. The city, State, and EPA Region VII have agreed that special
facilities should be built to accommodate wet-weather flows, but EPA Head-
quarters has ignored their requests. Everyone agrees that the fishkills will
persist until the stormwater problem has been cured. Why hasn't it been?
For more than a decade, the State has ordered Spokane to fix the
bypasses and overflows in its sewers, but these problems have been deflated
while pressures for phosphorus removal at the STP have built up. Spokane is
building facilities for partially treating the bypasses and overflows, but
not for removing phosphorus from them, and not for giving them secondary
treatment, as required by P.L. 92-500. Why has phosphorus removal a rela-
tively recent issue been attended to before the sewers?
SJ/SC must give complete treatment to all wastewater from all do-
mestic, commercial, and industrial sources, and must do it all the time.
Neither Springfield nor Spokane can. give complete treatment to wastewaters
from these three sources all the time because their sewers and STPs cannot
accommodate wet-weather flows; in both cities, wastewater is mixed with in-
filtration water and stormwater in the sewers, and this happenstance exempts
them from providing the complete treatment that is required of SJ/SC. SJ/SC
treats none of the stormwater in the area; Spokane and Springfield treat part
of it. Is this equal justice under law? Or is it one more of the inequities
sanctioned under P.L. 92-500? A uniform, even-handed National policy on
sewers is long overdue.
17
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16. Owing to lack of coordination between AWT planning and
the preparation of NPDES discharge permits, three of the six AWT plants
we studied will violate their permit conditions.
Largo cannot meet its effluent limits for nitrogen
and phosphorus because it has no facilities for
nutrient removal.
There is no NPDES permit for the Wallkill River Valley.
The NPDES permit for Springfield neglects the special
facilities that were built to accommodate the high
flows in wet weather. Through neglect of these
facilities, the NPDES permit guarantees that the new
STP cannot meet its limits for flow, biochemical
oxygen demand, suspended solids, and ammoniacal nitrogen.
There is no discrepancy between the NPDES permit and
the facilities in De Pere.
SJ/SC will certainly violate two conditions of its dis-
charge permit, and it may violate two other conditions.
It will violate the provision that forbids any waste-
water discharge south of Dumbarton Bridge; the STP
discharges into Artesian Slough, which is twelve miles
south of the bridge. It will violate the receiving-
water limitation for dissolved oxygen. It may violate
the receiving-water limit for undissociated ammonium
hydroxide, and it may violate the effluent limit for
toxicity. The violations of the receiving-water limits
can be cured by excising these limits from the permit.
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Receiving-water limits are out of place in a dis-
charge permit, and are a common source of trouble
there. The prohibition against wastewater discharges
south of Dumbarton Bridge will be violated until the
costly outfall project is built; however, it is not
yet clear whether the outfall project will ever be
approved.
There is no discrepancy between the NPDES permit and
the facilities in Spokane.
Which is right, the AWT planning or the NPDES permits? Either
the planning was right and the permits are wrong, or the permits are
right and the planning was wrong. Better coordination between the plans
and the permits would stop the shame of permit violations by brand-new,
EPA-subsidized STPs.
17. AWT adds substantially to the costs of wastewater treat-
ment. AWT costs more to build (higher capital costs) and more to run
(higher costs of operation and maintenance). AWT facilities do little
to improve removal of biochemical oxygen demand (BOD) and suspended solids
(SS), but they may remove substantial amounts of other pollutants,
especially ammoniacal nitrogen and phosphorus. In short, AWT adds greatly
to the costs, but does not remove much more of the most common pollutants.
Kennedy Engineers has analyzed the benefits and costs of AWT
in five of our six cases. Largo was excluded because it is not an AWT
plant. The benefit-cost analysis is given in Appendix A of this report.
In this analysis, AWT is compared with EPA's definition of secondary
treatment, viz. an effluent containing 30 mg/1 of BOD and 30 mg/1 of SS.
19
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The Wallkill STP, evaluated at an assumed design flow of 5
million gallons a day (5 mgd), will remove 10% more BOD, 7.5% more SS,
61% more ammoniacal nitrogen, and 68% more phosphorus than an equivalent
secondary STP. Facilities for secondary treatment account for 66.7% of
the capital cost and 52.1% of the annual cost of operation and mainten-
ance (O&M). AWT accounts for 33.4% of the capital cost and 47.9% of the
O&M. The grant-eligible capital cost is $11 million; the annual O&M is
$1 million.
The Springfield STP, evaluated at a design flow of 30 mgd
(which excludes the high flows during wet weather), will remove 7% more
BOD, 13% more SS, and 63.4% more ammoniacal nitrogen than an equivalent
secondary STP. AWT accounts for 41.8% of the capital cost and 37.4% of
the O&M. The grant-eligible capital cost is $41.5 million; the annual
O&M is $2.2 million.
The De Pere STP, evaluated at a design flow of 14.2 mgd, will
remove 5.7% more BOD, 8% more SS, and 64% more phosphorus than an equivalent
secondary STP. AWT accounts for 49.9% of the capital cost and 54.9% of
the O&M. The grant-eligible capital cost is $17.9 million; the annual
O&M is $1.5 million.
The STP at San Jose/Santa Clara was evaluated at a design flow
of 143 mgd, which corresponds to the peak of the canning season. It will
remove 3.8% more BOD, 5.2% more SS, and 67.5% more ammoniacal nitrogen
than an equivalent secondary STP. AWT accounts for about two-thirds of
the capital cost of the most recent AWT grant to SJ/SC, and about one-third
of the O&M. These costs exclude the value of the secondary plant dedicated
in June 1974.
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The Spokane STP, evaluated at a design flow of 40 mgd (which
excludes the high flow in wet weather) will remove 54% more phosphorus
than an equivalent secondary STP; its BOD and SS removal are identical to
secondary. AWT accounts for 11% of the capital cost and 33.2% of the
O&M. The grant-eligible capital cost is $41.9 million; the annual O&M
is $3.5 million.
18. The heavy expense of operating AWT facilities leads one to
look for ways to save money. There may be substantial savings from opera-
ting AWT facilities only when they are needed: There are times of year
when AWT can have little effect on the receiving waters. For example,
AWT need not be operated year-round in the Wallkill. AWT in the Wallkill
is required to prevent oxygen problems during extreme summer droughts.
In winter and in wet weather, oxygen problems in the Wallkill are ex-
tremely unlikely; consequently, AWT can make little difference to the
river then. In Spokane, phosphorus removal was justified by the need to
prevent algal blooms in Long Lake during the summer; consequently, there
is little to be gained by removing phosphorus during the winter. None
of the discharge permits we reviewed allows the STPs to modify their
operations to account for seasonal variations; this inflexibility forces
the STPs to miss an important opportunity to save money, with little
risk to the receiving waters.
19. We conclude, in short, that AWT planning is a mess that
needs cleaning up.
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He spent several days as if he were bewitched, softly
repeating to himself a string of fearful conjectures
without giving credit to his own understanding....
The children would remember for the rest of their
lives the august solemnity with which their father,
devastated by his prolonged vigil and by the wrath of
his imagination, revealed his discovery to them:
"The earth is round, like an orange."
Ursula lost her patience. "If you have to go crazy,
please go crazy all by yourself!" she shouted. "But
don't try to put your gypsy ideas into the heads of
the children." Gabriel Garcia Marquez (1967), One
Hundred Years of Solitude (trans, by Gregory Rabassa)
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3. RECOMMENDATIONS
Clearly, there is ample room for improvement so much room,
one hardly knows where to begin or where to stop. To make our presentation
a little tidier, we shall group our recommendations into three broad
classes: scientific, administrative, and legislative.
Scientific
Ignorance is the heart of the matter. AWT planning is filled
*
with assumptions, guesswork, and oversimplifications because planners
don't know nearly enough about water and the way it responds to wasteloads.
Section 303(d)(l)(C) of P.L. 92-500 acknowledges the existence of ignor-
ance, and then prescribes Draconian measures to ensure compliance with WQS:
"Each State shall establish ... the total maximum daily
load, for those pollutants which the Administrator iden-
tifies ... as suitable for such calculation. Such load
shall be established at a level necessary to implement
the applicable water quality standards with seasonal
variations and a margin of safety which takes into account
any lack of knowledge concerning the relationship between
effluent limitations and water quality."
Our case studies show that there is plenty of ignorance and that compliance
with WQS has not been ensured by AWT. If total maximum daily loads had to
be adjusted downwards to compensate for "any lack of knowledge" in the
"margin of safety", discharges would have to be flatly forbidden in vast
23
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areas of the country. In four of our case studies Largo, De Pere,
Spokane, and San Jose/Santa Clara WQS would be violated even if the
cities were wiped off the map. We cannot believe that there is much to
be gained by proceeding along this course.
Happily, ignorance is curable. Although we may never know
enough to specify the precise relationship between wasteloads and water
quality, we can certainly do a lot better than we're doing now. In a
recent report, the U.S. General Accounting Office concluded that AWT
facilities
"may not be the most effective or efficient means for
achieving water quality goals. The [U.S. Environmental
Protection] Agency and the States need to obtain better
water quality information and consider all water pollu-
tion control alternatives so that treatment methods
selected will improve water quality and will result in
more effective and efficient use of Federal funds."*
We agree entirely with tnis conclusion, and particularly endorse one of
GAO's excellent observations:
"Water quality data needed to support river basin and
areawide planning are generally inadequate, and it is
unlikely that adequate water quality data for determining
the best course of action at least cost to solve water
pollution problems will be included in the plans once they
are completed.... GAO believes that there will be no
improvement to the continuing problem of a lack of compre-
hensive plans until adequate data on the causes and effects
of water pollution is obtained. It is only on the basis
of such data that rational decisions can be made on treat-
ment and other pollution abatement measures." (p. iii)
*U.S. COMPTROLLER GENERAL (21 December 1976). Report to the
Congress. Better Data Collection and Planning Is Needed To Justify
Advanced Waste Treatment Construction. Report No. CED-77-12. Washington,
D.C.: U.S. General Accounting Office. 70 pp.
24
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The scientific basis of AWT planning badly needs shoring up.
It is impossible to plan well without knowing in considerable detail what
ails the water. Inadequately treated wastewaters are unquestionably among
the principal factors that affect water quality, but they are not the
only factors, and they are often far from the most important. Floods and
droughts affect water quality. Severe weather affects water quality.
Land management affects water quality. Water development affects water
quality. The interaction among these factors is never trivial, and it is
foolish to think that wastewater management can be fairly evaluated apart
from detailed knowledge of these (and other) related factors.
Causation, like truth itself, is never pure and rarely simple.
Without knowing a great deal about the causes of deficient water quality,
one risks misidentifying them and misallocating a fortune to mistaken
causes. A modest investment in scientific knowledge may pay handsome
dividends in pollution-control strategies.
As our case studies show, one must not confuse the appearance of
scientific truth with its substance. We recommend that EPA should be much
more careful about this distinction. In .the canons -of science as in the
canons of Catholicism, a devil's advocate is an instrument for establishing
the truth. EPA would do well to acquire such instruments and use them
whenever AWT is a planning issue. The few weeks required to assess the
arguments for AWT will not cost much, and they may save the taxpayer
millions of dollars.
EPA already has an elaborate apparatus for review. However,
this apparatus is manifestly unequal to the tasks before it. The prin-
cipal weakness in this apparatus is its dedication to procedural and
25
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bureaucratic issues; it must be redirected to scientific and technical
issues as well.
Much more time, attention, and care must be devoted to studying
water itself. Too much effort is already spent on studying paper, which
is rarely an undistorted mirror of reality. Too much money is spent on
routine water-quality monitoring samples (usually grab samples) taken
a few times a month. Even if the sampling and the laboratory analyses
were above suspicion (and they seldom are), routine monitoring data could
not supply the information needed for AWT planning.
AWT planning requires masses of data on hydrodynamics, waste-
water discharges, water quality, sediments, and aquatic biology; these
data must come from intensive surveys conducted when water quality is
likely to be under severe stress. As we write this report, vast areas
>
are suffering under extreme drought. In the Far West, the drought is of
historic proportions. Now is the time for intensive surveys to accumulate
the evidence that EPA must have for accurately assessing the need for AWT.
Last winter, most of the Nation was gripped by exceptional cold. Lakes
and rivers that rarely freeze were ice-covered, and ice floes damned
several of the largest rivers on this continent. By impeding the free
flow of water and by cutting off the water surface from air and light,
the ice must have affected water quality. Yet studies of water quality
under ice are rarities; when they have been done (e.g in the lower Fox
River and Green Bay, Wisconsin*) they have shown unusual patterns of
*Dale J. PATTERSON et al. (June 1975). Water Pollution Inves-
tigation: Lower Green Bay and Lower Fox River. Wisconsin Department of
Natural Resources, under contract to EPA-Region V. Chicago: EPA.
Report No. EPA-905/9-74-017. 371 pp.
26
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water-quality impairment as one might expect, patterns quite different
from those of a summer drought, but no less severe. In missing these
opportunities to study water quality when it is most likely to be in
trouble, EPA leaves planners no alternative to substituting guesswork and
assumption for hard facts.
EPA had plenty of advance notice for the western drought: It
has been with us since early 1976. There was plenty of time to plan
intensive surveys, to take advantage of this unusual opportunity for
documenting water quality when it is certain to be severely stressed.
Despite the ample time to prepare, there will be virtually no intensive
surveys this summer. Clearly, something is amiss when planners fail to
plan fact-finding missions when they are needed most. We recommend that
EPA should put its house in order, rearrange its priorities, and develop
the flexibility to mobilize its resources for fact-finding. Without
facts, planning is a farce. This recommendation applies equally to all
State and Federal .agencies responsible for water and water quality.
Pollution-control planning usually centers on one set of
hydrological conditions: severe summer droughts. As an absolute minimum,
EPA must insist on intensive surveys whenever AWT facilities are planned
to alleviate water-quality problems during summer droughts. Greater
attention to the "seasonal variations" mentioned in section 303(d)(l)(C)
of P.L. 92-500 would do no harm. Simmer droughts are not alone in stres-
sing water quality. Ice cover stresses water quality. Certain wind
patterns stress estuaries by stagnating them in effect, converting the
estuary into a detention lagoon and giving pollutants a chance to accumu-
late and express themselves. Sudden storms stress water quality by
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washing pollutants from the land and by scouring up pollutants that have
been stored in the surficial sediments of the streambed. Depending on
the specifics of the situation, several kinds of "seasonal" and climatic
variations may stress water quality.
It is an oversimplification to concentrate solely on summer
droughts. It is also misleading, as several of our case studies show.
Red tides and algal rot in the Tampa Bay Complex of Florida are linked
to floods and on-shore winds, not to summer droughts. The persistent
fishkills below Springfield, Missouri, are caused by stormwater, not by
summer droughts. Severe stagnation and deoxygenation in the lacustrine
estuary of the Fox River, Wisconsin, are caused by ice cover and by wind
setup in Lake Michigan; the drought flow of the Fox River has nothing to
do with the quantity or the motion of water in the Fox River Estuary.
We recommend that EPA should pay much more attention to the specifics of
stressful situations. We recommend that EPA should concentrate on summer-
F
time droughts only when they are critical to water quality. We recommend
that EPA should insist on documented evidence compiled by intensive surveys
during the stressful conditions, be they droughts, freezes, floods, storms,
or wind conditions.
Rarely can data be taken at face value. Over and over again in
our case studies, we found data on water and wastewater that could not be
believed. It does no good to publish data that are known to be dubious
(or wrong!); plans derived from suspect data are suspect themselves.
Accurate sampling and analysis are essential to any sound planning program.
We recommend that EPA should step up measures to improve the quality and
credibility of the data used in AWT planning. It doesn't cost any more
28
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to perform an analysis accurately than to do it wrong. Quality control
in sampling and analysis merits much more attention and action; both are
long overdue.
There are, no doubt, many possible improvements in the insti-
tutional, administrative, and legal arrangements for controlling water
pollution. None of them, however, can replace knowledge of water and
wastewater. Procedural and legal reform will do little to improve matters
unless the planners know why the water behaves as it does. Procedural
reform alone cannot cure ignorance or do away with the assumptions., guess-
work, and oversimplifications that weaken AWT planning today. Without
meaningful, credible data on water and wastewater, planning is a sham.
Any procedural or legislative reform that ignores the inadequate data
base for AWT planning will be an empty reform.
*
Administrative
AWT planning generates masses of information, scattered among
Federal, State, and local agencies. A glance at the bibliographies
attached to our case studies will give an idea of its quantity and dis-
persion. Because AWT cannot be meaningfully addressed in isolation, one
must also go into the material on inseparably related issues: State laws
and regulations, Federal regulations, surveys of water quality and
wastewater quality, WQS, NPDES permits, engineering plans, cost analyses,
environmental impact statements, mathematical models, wasteload allocations,
grant files, project files, priority lists, official correspondence
the list could be extended for several pages.
29
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Project reviews could be greatly simplified by making better
use of the information that is now available. Certain fairly simple and
obvious improvements could make a great difference to AWT planning.
In our case studies, we found two examples of AWT grants that
were conditioned, in part, on tentative regulations. The AWT grant to
Springfield, Missouri, was justified by a temporary set of effluent guide-
lines drawn up by the State. Missouri pointed out that these were only
guidelines not final effluent regulations. Nevertheless, when a city
is applying for a construction grant, it cannot (as a matter of expedience
and practical wisdom) formulate plans that do not agree with the State's
official suggestions. Why court trouble? It is hard enough to clear all
the bureaucratic hurdles with the backing of the State's pollution-control
agency; any disagreement with the State's policies (be they ever so
tentative) cannot expedite the flow of approval and money. After Sp'ring-
field got its AWT grant, the State issued final effluent regulations; these
less stringent regulations superseded the guidelines that drove Springfield
to AWT. The AWT grant to De Pere, Wisconsin, was justified in part by a
proposed Federal regulation on treatment requirements for the 1983 deadline
specified.in P.L. 92-500. This proposal was not long-lived, but it was
used to justify AWT in De Pere. Its brief life coincided with a critical
phase in De Pere's planning, when its design engineers were pressing State
and Federal officials to decide whether they would fund anything less
than AWT.
EPA should think twice before awarding an AWT grant based on
anything less than a final regulation. When the officials who prepare
effluent regulations aren't sure what should ,be required, the officials
30
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who award construction grants shouldn't be sure that the requirements
won't change. The difference between an AWT grant and a grant for secon-
dary treatment may amount to tens of millions of dollars in construction
costs alone. AWT commonly doubles the costs of construction and opera-
tion. We recommend that EPA should not approve AWT grants that are
conditioned on anything less than final regulations. In considering
applications for AWT grants, EPA should insist that all justifications
based on tentative rules should be clearly identified and brought to the
attention of the evaluation team.
We have oversimplified matters by referring to "AWT grants."
Construction grants usually include a good deal more than AWT facilities.
They may contain funds for enlarging the sewer system, repairing sewers
and interceptors, adding pumping stations and force mains, improving
»
sludge management, correcting combined-sewer overflows, and expanding the
hydraulic capacity of the STP. AWT facilities may be only a small part of
the construction grant. Paradoxically, the grant documents often fail
to specify what the grant money will be spent on: They do not always
define the facilities by category and pro-rate the costs among categories.
EPA would have an easier time evaluating the merits of construction grants
if both project reports and grant documents subtotaled the costs accor-
ding to categories of facilities, e.g. the categories used in the National
Needs Surveys:
Secondary treatment
More stringent treatment (AWT)
Sewer rehabilitation
Collectors and interceptors
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Correction of combined-sewer overflows
Control of stormwater
Kennedy Engineers has devised a useful method for summarizing
the costs and benefits of AWT (see Appendix A of this report). This kind
of summary compresses into a few pages most of the relevant material that
engineers need to assess a grant application. We recommend that EPA
should require project summaries short summaries to accompany all
grant applications. These summaries should include:
performance of the existing STP and sewer system
effluent requirements (State and Federal, tentative
and final), e.g. effluent limitations from NPDES permits.
i
basis of design (assumptions and estimates of wasteflows,
concentrations, loadings, seasonal variations, peak-to-
average flow ratios, and effluent quality)
inventory of facilities, by subcategory
expected performance of the new facilities, both during
the first years of operation and under the conditions
assumed as the basis of design
benefits of AWT (effluent quality and removal efficiency
of AWT contrasted with secondary effluent)
costs of AWT (specifying costs by category and component,
clearly identifying which components are for AWT and
which are for secondary treatment)
A short summary it need never be more than a few dozen pages, at most -
may clarify planning issues by focusing attention on what is at stake.
It must, assemble essential material that is now dispersed through stacks
32
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of planning documents, thereby simplifying and expediting review. A word
of warning: Anything more than a short summary will be self-defeating.
There is already far too much paper in circulation. The diffusion of
knowledge among mankind is all to the good; the diffusion of engineering
data through yet another multi-volume report is not. The summary must be
short and to the point.
In our case studies, we used simple chronological summaries to
trace the evolution of AWT planning. Our method was neither .original nor
time-consuming. Even complicated cases (e.g. San Jose/Santa Clara, Cali-
fornia) could be compressed into a few dozen pages. The data gathering
can be done in less than a month, the analysis and writing in a few
weeks. Through brevity, compression, and sticking to the point,, it is
possible to focus attention on the most important steps leading to AWT.
The chronological summaries must expose what went into the AWT decision,
and when. We recommend that EPA should require chronological summaries
of AWT planning, and make these summaries available to project evaluators
before grants are awarded. The summaries must concentrate on the legal
and technical basis for AWT; both must be made explicit. Again, these
summaries must be short. They will lose most of their value if they
ramble on and lose focus.
Both the engineering summaries and the chronological summaries
will gain clarity and focus by being written with a devil's advocate in
mind. Both are places for critical acuity and robust doubt. Whenever
massive Federal subsidies are being considered, it is a good idea to have
a ready reserve of clear-headedness and astringency.
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Several themes recur throughout our case studies. Most of them
i
relate to fundamental inadequacies in WQS, mathematical models, and
effluent regulations. Without changing Federal law in any way, many of
these inadequacies can be dealt with. Nothing in P.L. 92-500 requires
EPA to approve WQS that are filled with vagueness, hedging, paradox, internal
inconsistency, statistical ambiguity, simplistic notions of causation,
confusions between water quality and wastewater quality, meaningless appeals
to natural background or natural conditions, and non-numerical criteria
for assessing water quality. Nothing in the law requires EPA to approve
wasteload allocations derived from mathematical models filled with assump-
tions, guesswork, and oversimplifications. Nothing requires EPA to issue
NPDES permits that are inconsistent with facilities planning and construc-
tion grants, whose monitoring requirements bear little relation to the
effluent limitations, and whose effluent limitations are inconsistent
with AWT engineering and with State regulations. In the absence of any
legal impediment, we recommend that EPA should use its powers of review
to raise the level of AWT planning. All these deficiencies should be
promptly attended to. All of them have weakened AWT planning.
Legislative
Changes in the Federal Water Pollution Control Act can accom-
plish just so much. With a stroke of the legislator's pen, Congress
cannot summon forth the scientific excellence that has been conspicuously
scarce in water-quality planning for so many years; that will take time
generations, perhaps. Congress can legislate money, power, and authority.
It cannot legislate discernment and critical intelligence. Legislation
in itself cannot recognize the difference between good planning and poor
34
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planning, between data that make sense and data that don't, between useful
regulations and busywork forms.
«
P.L. 92-500 is a complicated piece of legislation. It sets a
variety of complex planning requirements and a breakneck schedule for
building STFs and related facilities. It establishes a universal minimum
level of treatment, but makes provision for more advanced levels of
treatment that may be necessitated by WQS or local law. It offers massive
Federal subsidies for pollution-control facilities, but it also sets up
an imposing array of reviews and checks on the formal planning documents
that qualify municipalities for these subsidies. The planning require-
ments are exceedingly complex and they must be rapidly fulfilled. The
Act claims that "the discharge of pollutants into the navigable waters
[should] be eliminated by 1985." It also sets somewhat less ambitious goals
for 1977 and 1983. The complex planning requirements conflict with the
lofty goals, and there is a great deal of irreducible tension between
them. Short of amending the Act, nothing can be done to remove the
tension;
In plain words, the Act requires the Nation to plan like mad
and build like crazy. And that, we fear, is exactly what has happened.
Planners and designers have tried to make the best of an impossible
schedule by hastily doing what they can with inadequate data. In con-
sequence, the planning documents are often less ennobled by scientific
truth and engineering excellence than by practical expedience, and the
planning process is degraded into a bureaucratic exercise undertaken in
a race against the clock to comply with Federal requirements and to
qualify for Federal subsidies.
35
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We recommend that EPA should look Into ways to reduce the
tension between the planning requirements and the construction require-
ments of P.L. 92-500. One or the other will have to be relaxed perhaps
both. The Act requires the States to set effluent limitations in time
to meet the 1977 and 1983 goals. All the planning must be collapsed into
a few years, even though pollution problems are usually too complex to be
solved by this generation of scientists. With time at a premium, there
is also a billion-dollar premium on persuasive guesswork, and there are
penalties for failing to join in the charade. To our knowledge, few
States and cities have managed to comply with P.L. 92-500 without com-
promising themselves in a guessing game over the "lack of knowledge
concerning the relationship between effluent limitations and water quality."
There are problems enough in planning adequately for secondary
treatment: assessing the sewer system, infiltration and inflow problems,
the size of the sewer-service area, growth patterns, centralization of
treatment facilities, points of discharge, sludge management, industrial
wasteloads and pretreatment requirements, financing schemes, and the like.
To this formidable list of problems to be overcome (and overcome rapidly
at that), AWT adds the problem of determining the relation between
effluent limitations and water quality.
It is difficult to be favorably impressed with what is known
about this relation, and even more difficult to be favorably impressed
with the mathematical models that supposedly define it. As a temporary
measure, there is much to be said for doing away with all planning
derived from WQS. EPA should consider asking Congress to strike section
303 of P.L. 92-500. The WQS we have seen are not a helpful adjunct to
36
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'planning, and the wasteload allocations derived from them cannot withstand
scientific scrutiny. What is to be gained by persisting in a costly,
time-consuming method of planning that does not produce credible results?
There is much to be said for concentrating on the business of building
secondary-treatment plants, correcting deficiencies in sewer systems, and
dealing with the problems that stormwater often causes. There will be
time enough to attend to AWT when the moire immediate problems have been
solved.
EPA should also ponder the inequities deriving from sections
.510 and 301(b)(l)(C) of P.L. 92-500. These sections empower the States
to adopt tougher pollution-control measures than those set by EPA. Some
States require AWT nearly everywhere; others never require it at all.
There is no uniform National policy to prevent this inequity, which
provides large Federal subsidies to States that may be setting unrealis-
tically demanding requirements for pollution control requirements
leading to very expensive treatment plants that may have little effect
on water quality. These provisions of the Act undermine one of the most
powerful and persuasive arguments advanced by its proponents, viz. the
establishment of uniform, nationwide levels of wastewater treatment. There
is no reason for the Federal Government to interfere with the States'
requiring AWT wherever and whenever they see fit, but there is no.reason
for the Federal Treasury to subsidize these requirements. We recommend
that construction-grant funds should be applied only to those facilities
required for secondary treatment; all other facilities required by State
law should be paid for by the States and municipalities themselves. EPA
37
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should carefully consider amendments to sections 301(b)(l)(C) and 510
of P.L. 92-500 amendments designed to remove this blatant inequity
from Federal law.
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4. LARGO, FLORIDA
4.1 The Issues In Brief
Largo is a small suburb of St. Petersburg and Tampa. It is
included in our case studies because EPA Region IV insisted that Largo is
the outstanding example of AWT in the region. But Largo's new 9-mgd
facility is a secondary plant it does not give AWT and was not designed
for AWT. Region IV probably failed to keep up with changing plans at
Largo. At one' time Largo planned to build AWT facilities for removing
phosphorus and nitrogen from its discharge to the Cross Bayou Canal;
these plans were developed in response to Florida's Wilson-Grizzle Act,
which requires AWT of nearly all municipal dischargers in the Tampa Bay
Complex. However, for technical reasons having to do with the wording
of the Act, these requirements do not apply to the Cross Bayou Canal or
to Largo a fact that has escaped the U.S. EPA and been a stumbling
block to Florida's pollution-control agency.
Largo's design engineers successfully argued that on-land
disposal would be much cheaper than AWT; they were certainly right. But
on-land disposal is not necessarily AWT. Largo's secondary effluent is
being piped to nearby golfcourses, where it will be used for irrigation.
\
No one has even attempted to show that these golfcourses will effectively
remove nutrients from Largo's effluent.
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The prospects aren't bright. The golfcourses are built on
loose., sandy soil and on material that was dredged out of the Tampa Bay
Complex. The water table is very high (at the surface in wet weather).
Old Tampa Bay is scarcely a mile away. In the absence of scientific
studies proving otherwise, one must argue that the sandy soils may not
retain the effluent long enough for effective nutrient removal. For all
we know, the effluent may quickly drain past the root zone, seep through
the underlying sand to the water table, and move out with underflow to
Old Tampa Bay. Nutrient removal requires more than a favorable physical
setting. It also requires that the grass on the golfcourses must be
managed (through seed selection, cultivation, and cropping practices) to
maintain effective nutrient removal year round. In the absence of
scientific studies on the soils, grasses, and grass-management practices
at the golfcourses, there is no reason to think that the prospects for
nutrient removal should be bright.
Florida's definition of AWT is very demanding; it requires
extreme degrees of treatment to remove BOD, SS, nitrogen (N), and
phosphorus (P). These requirements apply only to STPs, not to industries.
It is not easy to justify any of them, especially P removal, for the
following reasons.
Neither of the two principal problems in the Tampa Bay
Complex (viz. red tides and rotting saltwater algae)
is directly caused by N, P, BOD, or SS. Both problems
are triggered by high flows in the rivers of the area
and by on-shore winds.
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All the waters of the bay complex are heavily enriched
with phosphorus. This part of Florida has one of the
world's richest deposits of phosphate rock. For many
years, this deposit has produced over 75% of the phos-
phorus used in the U.S., and about a third of all the
commercial phosphorus in the world. The rivers that
drain this extraordinary deposit are laden with phos-
phorus, and one of the most important of these rivers,
the Alafia, drains into the Tampa Bay Complex.
The gigantic phosphate industry around Tampa is not
required to provide AWT. Even though the industrial
discharges of phosphorus dwarf the municipal discharges ,
only the cities are required to provide AWT. Bills
have been introduced into the Florida Legislature re-
quiring AWT of industries, but they have never passed.
Consequently, the two major sources of phosphorus
(river runoff and industrial wastewater) are exempted
from AWT, but the cities (a relatively minor source)
must carry the costly burden of AWT.
Florida's water-quality standards (WQS) do not mention
N, P, or SS, and the BOD standard is hopelessly vague.
Why are these substances so dangerous that they must
be removed from municipal wastewaters, but not impor-
tant enough for inclusion in the WQS, which embody the
State's goals for environmental improvement?
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The wasteload allocation for Largo has been consis-
tently falsified, and the intent of section 303(d)
of P.L. 92-500 has been perverted by intentional
confusions between wastewater quality and water
quality. Had there been any rational basis for AWT
at Largo, the wasteload allocation would have been
the ideal place for making a convincing case.
4.2 The Setting*
Largo is a small suburb of Tampa and St. Petersburg in Pinellas
County, a peninsula separating the Tampa Bay Complex from the Gulf of
Mexico. The county is flat and poorly drained. All about there are bays,
bayous, canals, sounds, lakes, and islands. The Tampa Bay Complex is
roughly shaped like an elongated heart. The upper lobes are Hillsborough
Bay and Old Tampa Bay; the long bay beneath them is Tampa Bay proper.
Largo has been growing rapidly. Its population has nearly quintupled
since 1960, though it is still a small city (its 1970 population was
22,000). Because the county is so flat, gravity sewers are not practical
on a large scale. Furthermore, the poor drainage and generally high water
table do not favor large sewer systems, which are susceptible to infiltra-
tion. Consequently, this part of Florida has planned to cope with the
wastewater problems from urban sprawl by building many small STPs (serving
fairly small sewer districts) rather than one or two large regional plants.
The STP at Largo is one of these small regional plants.
*Area maps for all the case studies are in Appendix B.
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4.3 The Largo STP
The first STP at this site was -a trickling-filter plant built
in 1961. In 1969 it was modified to contact stabilization (a routine form
of biological secondary treatment) and enlarged to 3 mgd. In 1970 another
3-mgd contact-stabilization module was added, which gave the STP a capacity
of 6 mgd. The STP discharges into the northeastern end of the Cross Bayou
Canal, which cuts a diagonal through the county from Old Tampa Bay (at the
northeastern end) to Boca Ciega Bay and the Intracoastal Waterway (at the
southwestern end). The point of discharge (approximately 150th Ave. North
and Bolesta Road) is very near the St. Petersburg-Clearwater International
Airport. The service area of the STP has greatly expanded in recent years,
and there are plans for further expansion. *, . .
The STP is being enlarged to 9 mgd by adding yet another 3-mgd
contact-stabilization module. The enlargement is nearly complete, and so
are other improvements:
Upflow filters (upside-down trickling filters) are being
added to each of the three contact-stabilization modules;
these filters will further improve the quality of the
effluent, and may eventually be used in conjunction
with methanol for nitrogen removal.
Sludge-drying beds are being replaced with pelletizing
equipment and related accessories to convert Largo's
sludge into a hard, pelletized soil conditioner, which
is being commercially marketed under the brand name
"Largrow".
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Pumps and pipelines are being installed to transport
the secondary effluent to two nearby golfcourses,
where it will be used to water the grass; the discharge
into the Cross Bayou Canal will stop.
The enlargement and improvements were supported with a grant from the U.S.
EPA; this grant is the focus of our case study.
4.4 The Success Story
In a very real sense, Largo has been a paragon of successful
pollution control. Few cities or industries can rival its achievements.
The sewers are new. The STP has few operational problems, it is efficiently
run, and it has reliabJy produced a secondary effluent of excellent quality.
Moreover, Largo has found paying customers for both its sludge and its
liquid effluent it has managed to convert its wastes into useful, prof-
itable products. How much more successful can pollution control be?
We take no issue with these remarkable achievements. They deserve
to be held up as a model of success, and we are delighted to join in the
applause. However, Largo's success was achieved despite (not because of)
the elaborate planning required by State and Federal agencies.
4.5 The Confusion
The purpose of our study was to document successful examples of
AWT planning. And therein lies the difficulty. In the technical sense,
Largo's STP is a secondary plant, not an AWT plant. The principal process
at the STP is contact stabilization, a fairly common form of biological
secondary treatment. Upflow filtration is the only unusual adjunct to
44
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this standard process of biological treatment. The STP has no.special
"facilities for ammonia removal, phosphorus removal, denitrification, virus
inactivation, or advanced removal of BOD and SS. By selling its liquid
effluent to golfcourses, Largo is practicing on-land disposal. However,
on-land disposal is not necessarily equivalent to AWT. If the grass on
the golfcourses does remove significant amounts of nutrients (principally
N and P), and if the underlying soil does remove large quantities of BOD
and SS, then Largo is unquestionably providing AWT. Unfortunately, no one
has studied the golfcourses to determine whether they can remove pollutants
before the effluent seeps into the groundwater and moves with the underflow
to Old Tampa Bay. With this fundamental question unanswered, no one can
argue that Largo is an outstanding example of AWT planning. If nothing
else, AWT planning for on-land disposal must conclusively demonstrate that
the wastewater is receiving the equivalent of AWT by being applied to the
land. No one has attempted to demonstrate anything of the kind at Largo.
At one time Largo did plan to build AWT facilities, including
special units for denitrification and phosphorus removal. Largo was
chosen as one of our case studies on the enthusiastic recommendation of
EPA Region IV (Atlanta). Evidently, Region IV failed to keep up with
Largo's changing plans. Officials there knew that Largo had arranged to
sell its effluent to the golfcourses, but they mistakenly thought that the
STP was building standby AWT facilities, which would'be used when the
water table at the golfcourses was too high for spray irrigation. We
were repeatedly told that Largo could operate both in an "on-land mode"
(with effluent disposal on the golfcourses) and in an "AWT mode" (with an
outfall into the Cross Bayou Canal). In plain fact, however, there is no
-------
"AWT mode" at Largo. Moreover, the contract* between Largo and the con-
sulting engineers who designed the plant a contract that EPA Region IV
must have seen makes no mention of an AWT mode or its appurtenances
(e.g. equipment for storing and injecting methanol, alum, iron salts,
lime, polymers, or other chemicals used in AWT processes). Having heard
so much about Largo's "AWT mode", we were astonished when we came to Largo
and discovered a straightforward secondary STP.
4.6 Technical and Bureaucratic Definitions of AWT
Although Largo has no "AWT mode", and although it is a secondary
STP in the technical sense, it is an AWT plant according to EPA's defini-
tion. To a technical man, an AWT plant has special units or processes for
removing unusually large amounts of pollutants; Largo has none of these.
To EPA, however, secondary treatment means an effluent that contains
30 mg/1 of 20°-BOD5 and 30 mg/1 of SS; in bureaucratic shorthand, secondary
effluents are "30/30", as a monthly average. Anything more dilute is AWT.
By this definition, Largo is an AWT plant, and it has been one for a long
time. In 1976 Largo reported that its effluent contained about 10 mg/1
of 8005 and 7 mg/1 of SS; for years its effluent has been cleaner than
"20/20." Largo's reports on its effluent may not be too reliable, since
its laboratory is fairly rudimentary. However, it is by no means unusual
for well-designed secondary plants to produce a "20/20" effluent, or even
better. When modern secondary plants are well designed and efficiently
run, they can generally exceed EPA's "30/30" requirement especially
when there are no food-processing industries (canneries, dairies, .
*Quentin L. Hampton Associates, Inc. (February 1975). Contract
Documents for Sanitary Sewer System Improvements, Sewage Treatment Plant
Expansion, City of Largo, Pinellas County, Florida. Daytona Beach, Florida:
Hampton Assoc.
46 .
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meatpackers) or leaky sewers in the STP's service area. Largo meets all
of these conditions. . .'.
By Florida's definition, however, Largo is not an AWT plant.
The State has defined an AWT effluent as one that contains less than 5 mg/1
of BOD5, 5 mg/1 of SS, 1 mg/1 of P, and 3 mg/1 of N. Largo's effluent
contains far too much N and P (in particular) to comply with Florida's
definition. Florida's definition is much more demanding than EPA's. One
.of the great inequities in Federal water-pollution law is in sections 510
and 301(b)(l)(C). of P.L. 92-500, which explicitly allow the States to set
more stringent effluent requirements than the Federal EPA does. Florida's
definition is one.of the most severe we have seen.
Depending on how you look at it, Largo has AWT or it doesn't.
Everything depends on the definition of AWT, and there are several to
choose from.
This confusion over definitions sets the stage for our detailed
analysis of AWT planning at Largo. There is a large cast of characters
drawn from local government, State government, the U.S. EPA, and consul-
tants to these agencies. There are State requirements and Federal require-
ments, which are often dramatically different. As the agencies interacted,
there were many points of confusion and many differences to be settled.
4.7 Chronology of Events at Largo
Because the plot is complex and the cast of characters if large,
we will briefly summarize the principal events in chronological order.
We will return to the most important events for lengthy analysis after
presenting this chronological introduction to AWT planning for Largo.
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December 1969
The U.S. Federal Water Pollution Control Administration pub-
lishes Problems and Management of Water Quality in Hillsborough Bay.
FWPCA recommends "an overall removal of ninety percent total nitrogen
and ninety-nine percent total phosphorus" from the largest industrial
and municipal discharges of wastewater to the bay.
15 March 1972
The Wilson-Grizzle bill is enacted. It requires AWT for sanitary-
sewage discharges into Old Tampa Bay (Among others) and "any bay, bayou,
or sound tributary thereto". The act says nothing about industrial dis-
charges, freshwater tributaries, or canals (the Cross Bayou Canal in
particular is not mentioned).
10 April 1972
Letter from Harold Leadbetter of the Pinellas County Health
Department to Ralph H. Baker of the Florida Department of Pollution Control
(DPC). Mr. Leadbetter recommends nutrient removal for the Largo STP.
3
January 1973 .
Feasibility Report: Project for Extention of Sanitary Sewer
Service in Largo Sewer Service Area by Quentin L. Hampton Associates,
consultants to the Town of Largo. Hampton proposes expanding the Largo
STP to 9 mgd and upgrading treatment to remove nitrogen and phosphorus.
15 May 1973
EPA receives Application for Federal Assistance for Largo.
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July 1973 .
Water Quality Management Plan for the Tampa Bay Basin by the
Tampa Bay Regional Planning Council (TBRPC). The Council recommends AWT
for the Largo STP.
30 November 1973
Geo-Marine, Inc. publishes results of hydraulic and water-
quality surveys of Cross Bayou Canal. Geo-Marine is unable to determine
the rate of exchange between Old Tampa Bay and Boca Ciega Bay through the
canal. The south end of the canal is grossly polluted owing to STP dis-
charges, but water quality is much better nearer the Largo STP (at the
north end).
January 1974
Hampton submits Sewer System Evaluation, Town of Largo, Florida
to EPA. He concludes that infiltration and inflow to Largo sewers are
minimal. EPA approves Hampton's report on 13 February 1974, as required
by P.L. 92-500, Section 201(g)(3).
11 February 1974
Letter from Joseph R. Franzmathes (Director, Water Programs
Office, EPA Region IV) to Peter P. Baljet (Executive Director of DPC).
Both agencies agree that AWT discharges must meet the following limits.
BOD5 (mg/1)
SS (mg/1)
total N (mg/1)
total P (mg/1)
Yearly Average
Limits
5
5
3
1
Monthly Average
Limits
8
8
5
2
Weekly Average
Limits
12
12
7
3
49
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Note that this definition ofAWT is different from the one in the Florida
Administrative Code (December 1974), Section 17-3.04(2)(b), which defines
AWT as "that treatment which will provide an effluent containing not more
than the following concentrations:"
BOD5 (mg/1) 5
SS (mg/1) 5
total N (mg/1) 3
total P (mg/1) 1
April 1974
Two golfcourses near the Largo STP (Bullard's Bay and Airco)
offer to buy the STP effluent to supplement their supply of freshwater
for lawn watering.
7 May 1974
Town of Largo becomes City of Largo.
21 June 1974 ,
DPC submits State Water Pollution Control Work Plan, Fiscal
Year 1975 to EPA. DPC subverts the intent of Section 303(d)(l)(C) of
P.L. 92-500, which requires each State to determine the assimilative
capacity ("total maximum daily load") of each segment. DPC did not
determine the assimilative capacity of the Cross Bayou Canal near Largo.
DPC added hypothetical STP discharges and called the sum the "assimilative
capacity." DPC's "assimilative capacity" is patently not the real assimi-
lative capacity.
50
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12 August 1974
Largo's NPDES permit is signed. The STP is required to meet the
following limits after 1 August 1975:
BOD5 (mg/1)
SS (mg/1)
total N (mg/1)
total P (mg/1)
Monthly Average
Limits
7.5
7.5
4.5
1.5
Weekly Average
Limits
11.5
11.5
6.8
2.3
Note that the permit does not specify yearly average effluent limits; EPA
eliminated the strictest effluent limits, the effluent limits specified in
the Florida Administrative Code.
October 1974
Hampton and EPA exchange letters comparing the costs of nutrient
removal and spray irrigation at the two golfcourses. Spray irrigation is
much less expensive.
4 December 1974 .
EPA completes Environmental Impact Appraisal of Largo's STP
improvements; EPA notes that spray irrigation was chosen over nutrient
removal.
18 December 1974
EPA decides that an Environmental Impact Statement (EIS) is
unnecessary.
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31 December 1974
EPA grants Largo $2,000,000 for STP improvements.
24 April 1975
DPC interprets "bay, bayou, or sound" of the Wilson-Grizzle Act
to include any "tributary rivers and streams" up to the "normal" location
of the 1500 mg/1 chloride line. The Cross Bayou Canal at the Largo STP
discharge probably contains more than 1500 mg/1 chloride, and therefore
may be subject to the Wilson-Grizzle Act. However, we have not been able
to find any measurements of chloride, conductivity, or TDS in the Cross
Bayou Canal near Largo's STP discharge. Without these measurements, it
is impossible to demonstrate that the canal must meet the Wilson-Grizzle
limits. Furthermore, the canal is not a tributary river or stream. Con-
sequently, even if it could be shown that the canal had a "normal"
chloride concentration of 1,500 mg/1 at Largo's point of discharge, the
Wilson-Grizzle Act would still not apply because the canal is not a river
or stream.
26 June 1975
The EPA grant to Largo is increased to $2,343,540 to cover the
Federal share of the low bid, which was higher than expected.
1 July 1975
DPC becomes DER (Department of Environmental Regulation).
March 1976
DER publishes a preliminary draft of the 303(e) basin plan.
DER persists in its illegitimate methods of calculating assimilative
capacity.
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Spring 1976
Preliminary "208" reports are published by consultants to TBRPC.
July 1976
Wasteload Allocation for Tampa Bay Tributaries is published by
Yousef A. Yousef et al. (consultants to DER). The first allocation for
Largo's STP is "no discharge".
9 November 1976
The new STP is dedicated, though there is still some construction
going on. Everything will be finished in a few weeks.
4.8 Florida's Pollution-Control Agencies; DPC and DER
Until 1 July 1975, Florida's Department of Pollution Control
(DPC) was responsible for water-pollution planning. With the passage of
the Environmental Reorganization Act of 1975 , DPC was abolished and all
its functions were transferred to the new Department of Environmental
Regulation (DER).
4.9 The Wilson-Grizzle Act and Florida's Pollution-Control Agencies
Because Largo has for many years been a good STP, what reasons
can there have been for requiring Largo to provide AWT or to move its
point of discharge? Both the U.S. EPA and Florida's DER told us that the
Wilson-Grizzle Act was responsible. Though the act may have provided
the impetus, it did not provide the authority. Here is the act in its
entirety.
*Laws of Florida, Chapter 75-22, effective 1 July 1975.
**Laws of Florida, Chapter 72-58; Florida Statutes Annotated,
Section 403.086(1)(b). Enacted 15 March 1972.
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"No facilities for sanitary sewage disposal constructed
after the effective date of this act shall dispose of
any wastes into Old Tampa Bay, Tampa Bay, Hillsborough
Bay, Boca Ciega Bay, St. Joseph Sound, Clearwater Bay,
Sarasota Bay, Little Sarasota Bay, Roberts Bay, Lemon
Bay and Punta Gorda Bay or any bay, bayou or sound
tributary thereto without providing advanced waste treat-
ment approved by the department of pollution control."
The act does not define AWT that technical detail is left to
DPC. However, the act painstakingly enumerates the waterways it covers.
It applies only to these bodies of water and to "any bay, bayou or sound
tributary thereto". It does not apply to rivers, canals, or any other
body of water. In particular, it does not apply to the Cross Bayou Canal.
Therefore, it does not require AWT at Largo, which discharges into the
Cross Bayou Canal. DPC ignored this simple fact and proceeded to transform
the act by administrative action.
Although the Wilson-Grizzle Act does not apply to Largo, DPC was
legally empowered to require AWT at Largo (or anywhere else, for that
matter) by the preceding paragraph of the Florida Statutes Annotated,
Section 403.086(1)(a):
"Neither the Department of Health and Rehabilitative
Services nor any other state agency, county, special
district, or municipality shall approve construction
of any facilities for sanitary sewage disposal which
do not provide for secondary waste treatment and, in
addition thereto, advanced waste treatment as deemed
necessary and ordered by the Department of Environ-
mental Regulation."
In Largo, DPC deemed AWT necessary. This broad, elastic grant of discre-
tionary power enabled DPC and DER to require AWT at Largo without any
54 '
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reference to the Wilson-Grizzle Act. The Wilson-Grizzle Act never had to
be invoked to justify AWT at Largo. The State had the power all along.*
On 24 April 1975 several months after EPA had awarded an AWT
grant to Largo the Executive Director of DPC instructed his staff to
broaden the application of the Wilson-Grizzle Act to include brackish
portions of rivers and streams that flow into those bodies of water named
in the act.
"[The Wilson-Grizzle Act] does not include rivers and
streams which empty into the named waters or adjoining
bays, bayous, or sounds. For the purpose of defining
at what point the above named water bodies are to be
distinguished from tributary rivers and streams, refer-
ence is made to Chapter 17-3.05(3)(c)(v) FAC [scil. of
the Florida Administrative Code] whereby 'Fresh waters
shall be all waters of the State which are contained in
lakes and ponds, or are in flowing streams above the
zone in which tidal actions influence the salinity of
the water and where the concentration of chloride ions
is normally less than 1500 mg/1. Treatment levels in
the rivers and streams tributary to the above named
bodies of water shall be that degree necessary to main-
tain water quality in accordance with the water quality
criteria defined in Chapter 17.3, FAC."**
This memorandum broadens the application of the act to include brackish
portions of such rivers as the Alafia and the Hillsborough. However, it
does not apply to the Cross Bayou Canal because the canal is not a river
or a stream. Moreover, no one knows whether the canal contains more than
*Broad grants of discretionary power to State pollution-control
agencies are neither recent nor unique to Florida. For example, in 1945
Washington State empowered i'ts Pollution Control Commission to "require
the use of all known available and reasonable methods by industries and
others to prevent and control the pollution of the waters of the State of
Washington." Session Laws of the State of Washington, 29th Session, chap.
216, section 1 (S.B. 294), enacted 16 March 1945.
**Memorandum from Peter P. Baljet (Executive Director, DPC) to
Deputy Executive Director et al. (24 April 1975). Subject: Water -
Legal - Rules - Interpretation of the Wilson-Grizzle Act. Copy obtained
from Dr. George J. Horvath, DER, Tallahassee.
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1,500 mg/1 of chloride at Largo's outfall; we were unable to find any
measurements of chloride (or even of closely related properties, such as
conductivity and IDS) anywhere near Largo's outfall. Consequently, this
expanded interpretation of the Wilson-Grizzle Act does not apply to Largo
any more than the act itself does.
Florida's pollution-control officials at all levels have insisted
that the Wilson-Grizzle Act and its expanded interpretation of 24 April
1975 necessitated AWT at Largo. Upon carefully examining' these regulatory
materials, however, we conclude that neither the act nor its expanded
interpretation can be legitimately applied to Largo or to the Cross Bayou
Canal. In short, we conclude that the officials have been consistently
mistaken in their reading of these regulations, and that AWT was not re-
quired by the regulations they cited. However, the State did nothing
illegal in Largo because State agencies are empowered (by the sweeping
language of section 403.086(1)(a) of the Florida Statutes Annotated) to
require AWT wherever they please.
4.10 The Definition of AWT and Largo's NPDES Permit
DPC formally defined AWT in Chapter 17-3.04(2)(b)l of the
Florida Administrative Code (Supp. No. 25, December 1974), as follows:
"Advanced waste treatment is that treatment which will provide
an effluent containing not more than the following concentra-
tions:
a. Biochemical Oxygen Demand (8005) 5 mg/1
b. Suspended Solids 5 mg/1
c. Total Phosphorous [sic], expressed as P 1 mg/1
d. Total Nitrogen, expressed as N 3 ing/l"
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Nevertheless, these limits (the so-called 5-5-3-1 limits) are
not the limits used by DER and EPA in the NPDES permits. EPA and the
State finally agreed on effluent limits in February 1974, nearly two years
after the Wilson-Grizzle Act. They agreed to interpret the 5-5-3-1 limits
as yearly averages, and set limits on monthly and weekly averages as follows:*
Monthly Average Weekly Average
Limits Limits .
BOD5 (mg/1) , 8 12
SS (mg/1) 8 12
total N (mg/1) 5 7
total P (mg/1) 2 3
Although Largo's NPDES permit was signed on 12 August 1974
six months after the EPA-DPC agreement the effluent limits in Largo's
NPDES permit differ from the limits that EPA and DPC agreed to on
11 February 1974. Here are the AWT limits (which went into effect on
1 August 1975) in Largo's permit:**
Monthly Average Weekly Average
Limits Limits
BOD5 (mg/1) 7.5 11.5
SS (mg/1) 7.5 11.5
total N (mg/1) 4.5 6.8
total P (mg/1) 1.5 2.3
*Joseph R. Franzmathes (11 February 1974). Letter to Peter P.
Baljet, Executive Director of the Florida Dept. of Pollution Control,
Tallahassee, giving EPA's interpretation of the 5-5-3-1 criteria for AWT
and asking for clarification of the application of the "Wilson-Grizzle
Bill" [sic] to "stream tributaries". Mr. Franzmathes is Director of the
Water Programs Office, EPA Region IV, Atlanta. Copy obtained courtesy of
Dr. G. J. Thabaraj, Florida DER, Tallahassee.
**U.S. EPA (12 August 1974). NPDES permit to Town [sic] of
Largo. Permit No. FL0026603. Effective date: 27 September 1974; expires
30 June 1979. Obtained from the files of the Enforcement Division, U. S.
EPA, Region IV, Atlanta. An identical copy is on file with the Florida
DER, Tallahassee. Amended by letter from Donald J. Guinyard (EPA Region
IV, Enforcement Division) on 31 August 1976, as follows: "Your new date
for attainment of operational level is January 1, 1977."
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There are no yearly-average limits. The Largo STP does not have to meet
the 5-5-3-1 limits set forth in the Florida Administrative Code. Note
that during 1976 the Largo STP came close to meeting the BOD^ and SS
limits, although it gave only secondary treatment. It did not meet the
nitrogen and phosphorus limits.
4.11 An Alternative to AWT
The Florida Administrative Code provides an alternative to AWT,
and DPC allowed Largo to choose the alternative:
"Alternate effluent disposal is a minimum of secondary
treatment (90 percent) followed by an effluent disposal
system approved by the Department which will prevent any
effluent from being discharged to the surface waters of
the State. Such disposal may include land disposal, deep
injection wells, or combinations thereof, or other methods
approved by the Department."*
Largo chose spray irrigation over AWT because it is less expensive. Two
golfcourses close to Largo need freshwater for lawn watering and are
willing to buy the STP effluent for that purpose.
Notice the vagueness in this definition of secondary treatment,
i.e. "90 percent". It is probably fair to assume that this cryptic phrase
means 90% removal, but we are not told whether it applies to BOD, SS,
bacteria, COD, UOD, or something else. We are hot told whether it is to
be interpreted as an absolute minimum, a daily minimum, a weekly minimum,
a weekly average, a monthly average, a seasonal median, or an annual mode.
The statistical vagueness is characteristic, and is a common source of
trouble in interpreting pollution-control regulations.
*Florida Administrative Code (Supp. 24, repeated in Supp. 69),
chapter 17-3.04(2)(b)3.
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Notice too the vagueness in the phrase "an effluent disposal
system ... which will prevent any effluent from being discharged to the
surface waters of the State [emphasis supplied]." Deep-injection wells
can probably prevent any effluent from reaching surface waters; but land
disposal of effluent is no guarantee. The effluent may seep through the
land to the groundwater, whence it may freely rejoin surface waters.
Everything depends on the definition of "discharge". It is customary to
speak of the discharge of groundwater into surface channels, but we have
no way of determining whether Florida agrees with this custom. Effluent
from Largo will surely seep through the golfcourses into the groundwater
that is tributary to Old Tampa Bay; the seepage will be especially severe
in wet weather. Depending on the State's definition of "discharge", the
groundwater under the golfcourses may be said to constitute a discharge
of Largo's effluent to Old Tampa Bay. Vague regulations of this sort are
another obstacle to clarity in what should be straightforward pollution
control.
The groundwater beneath one of the golfcourses (Feather Sound
formerly Bullard's Bay) was monitored in December 1975 and January 1976.*
These are the only analyses on file, and they were conducted before Largo
began spray irrigation of its effluent. These analyses show that the
groundwater was of variable, but generally very poor, quality. Concentra-
tions of total nitrogen reached 21.4 mg/1, total phosphorus was up to
24.9 mg/1, ammoniacal nitrogen hit 15.5 mg/1. Chloride concentrations
*The analyses were performed by the Raines Testing Laboratory, Inc.,
of Clearwater FL, for Quentin L. Hampton Associates, Inc. (design engineers
for the Largo STP). Mr. Hampton submitted these reports to DER on 19 December
1975 and 6 February 1976. Mr. Hampton reported that -"The monitoring wells
extend to a depth from 15 to 20 feet below the surface so as to allow sampling
of the ground water just above the aquaclude." Our copies were obtained from
the Largo file in the Office of Water Programs, EPA, Atlanta.
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ranged from 44 to 79,000 mg/1. In short, the groundwater was impure and
sometimes contained extremely toxic concentrations of ammoniacal nitrogen.
Although these analyses were on file with State and Federal pollution-
control agencies, the agencies failed to consider groundwater quality in
the planning. In some respects (e.g. ammoniacal nitrogen and total phos-
phorus) Largo's effluent is cleaner than the worst of the groundwaters.
When Largo starts applying its effluent to the golfcourses, the irrigation
will necessarily increase the slope of the piezometric surface, which will
in turn promote the flow of these contaminated groundwaters into Old Tampa
Bay. On-land disposal is not always the wisest solution to a pollution
problem. The poor quality of the groundwater cannot be .traced to leaky
sewers or poor septic tanks; it must rather be attributed to the scattered
horizons of tidal swamp and sedimentary muck that lie buried beneath the
grass.*
Apart from the two sets of analyses cited above, we could not
find any studies of the groundwater. No one knows how the groundwater
moves, how it is affected by the tides in Old Tampa Bay, or how rapidly
it moves. No one knows how spray irrigation will alter the motion of the
groundwater. No one knows how storing Largo's effluent in the little
lakes on the golfcourses will affect the piezometric surface. In short,
all the fundamental questions related to on-land disposal have been
ignored.
*Earl S. Vanatta, Jr. et'al. (September 1972). Soil Survey of
Pinellas County, Florida. Prepared by the Soil Conservation Service of
the U.S. Department of Agriculture in cooperation with the University of
Florida Agricultural Experiment Stations. Washington, D. C.: USGPO.
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There is an odd symmetry in Largo's plans for effluent disposal.
For years, Largo's effluent was discharged into the Cross Bayou Ganal,
which appears to be much dirtier than Largo's effluent. Now Largo's
effluent will seep into generally dirty groundwater. Once again, the
effluent will in some ways be cleaner than the receiving, water (e.g. less
salt, less phosphorus, less total and ammoniacal nitrogen). The north-
eastern end of the Cross Bayou Canal may become more stagnant and impure
when Largo's outfall is abandoned. It is possible that the discharge
into the Cross Bayou Canal does more to improve water quality (both in the
canal and in Old Tampa Bay) than on-land disposal at the golfcourses. No
one knows. Someone should.
4.12 Plans for the Largo STP
Largo changed its STP plans several times. Before the Wilson-
Grizzle Act, Largo intended to enlarge the STP to 9 mgd but to maintain
the level of secondary treatment and the o.utfall into the Cross Bayou
Canal. On 10 April 1972, a month after the act, Harold Leadbetter
(Director of the Division of Sanitary Engineering of the Pinellas County
Health Department) asked DPC to revise these plans to include nutrient
removal and better sludge-handling facilities.* We were not able to find
these early plans. The first set of plans we could find in State or
Federal files is dated January 1973; these plans include nitrogen and
*Harold Leadbetter (10 April' 1972). Letter to Ralph H. Baker,
Jr., Administrator of the Waste Water Section, Bureau of Sanitary
Engineering, Florida Department of Pollution Control. Obtained from
the Largo file of the Florida DER, St. Petersburg.
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phosphorus removal.* Largo applied to EPA for a construction grant on
15 May 1973 and received the grant nearly eighteen months later on
31 December 1974.
After the grant application was filed, Largo changed its plans
from AWT (with an outfall into the Cross Bayou Canal) to secondary treat-
ment (with on-land disposal at the golfcourses). In April 1974 two golf-
courses near the STP ~ Bullard's Bay (now called Feather Sound) and Airco
offered to buy the STP effluent to supplement their freshwater supply for
watering the grass. Quentin L. Hampton, the designer of Largo's STP,
immediately wrote to the Town Manager and described the advantages of this
offer from the golfcourses:
"I am reporting to you the discussion I had earlier ...
with Mr. Fred Bullard and Mr. Jack Russell, principals
of the Bullard's Bay and Airco Golf Course Facilities,
relative to these golf courses making use of treated
effluent from the Largo sewage treatment plant. At the
meeting with these gentlemen, I was informed that they
desire to acquire and pay for Largo sewer plant effluent
for the purpose of irrigating their golf courses. As you
know, Airco has been in existance [sic] for quite a few
years and needs more fresh water than their present
supply will yield. The Bullard's Bay Golf Course is
under construction and completed to the point where
they will begin planting grass soon. Ground water at
the Bullard's Bay Course will not yield a dependable, -
long-term supply sufficient to meet requirements of
this golf course turf.
"We now have between four and five million gallons of
treated effluent being discharged to Cross Bayou, and
it is my feeling that if this water can be pumped to
the extensive lake systems within the Airco and Bullard's
Bay Golf Courses, it will not only be a more satisfac-
tory point of final disposal of this waste, but it can
also be very useful to the golf course people at a
reasonable cost wherein the Town [of Largo] would suf-
fer no expense for obtaining the more desirable method
of final disposal of its sewage.
*Quentin L. Hampton Associates, Inc. (January 1973). Feasibility
Report: Project for Extension of Sanitary Sewer Service in Largo Sewer Service
Area. Daytona Beach FL.: Hampton Assoc.
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"We have determined that we can economically pump the
Largo plant effluent to these golf courses through a
pressure pipeline system with the proper pumping facili-
ties at a total project cost of $225,000. If this amount
is appropriated by either the Town or the golf course
owners, it can be amortized over a ten year period at
8 percent interest at an annual cost of $36,400.00 per
year. Operating cost of such a system at present and
immediate future flows are [sic] estimated to be
$14,000.00 a year, including electric power and operation
and maintenance expenses. These figures indicate that
all of the Largo sewage plant effluent can be disposed
of in a very acceptable manner' as far as State and
Federal Pollution Control agencies are concerned at a
total annual cost of approximately $50,000.00 per year.
"I was advised by Messrs. Bullard and Russell that they
will expect to use between five hundred thousand and one
million gallons per day for each of the two golf courses
on an annual average basis. The remainder of the effluent
would be sufficient to maintain their lake system level
elevations somewhat above sea level so as to assure the
lakes being salt-free water at all times."*
Selling the STP effluent made economic sense to Largo, especially if the
sale would allow Largo to forego the expense of AWT. It costs much more
to run an AWT plant than a secondary plant. Reducing the degree of
treatment also reduces the operating costs (which Largo must pay all of);
pumping facilities would add modestly to the capital costs (which EPA
pays 75% of).
Note that the State of Florida did not subsidize Largo's STP.
EPA put up 75% of the eligible costs and Largo put up the rest.**
*Quentin L. Hampton (19 April 1974). Letter to Donald D. Herman,
Town Manager of Largo, in re "Sewage Treatment Plant Effluent Disposal to
Golf Course Irrigation Systems".
**U.S. Environmental Protection Agency (31 December 1974). Grant
//C120493010 to the City of Largo for $2,000,000 to enlarge and upgrade the
Largo STP. Signed by Jack E. Ravan, Regional Administrator, EPA-Atlanta.
See p. 52 for further details on EPA funding.
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4.13 The Plans and the Cross Bayou Canal
We made a cursory examination of the Cross Bayou Canal at Largo's
point of discharge on 11 November 1976. The canal was narrow, winding,
swampy, and densely bordered with trees; it smelled of lush decay. The
water was turbid, its surface blotched with floating scum. The STP effluent
in contrast, was much clearer and did not smell. There were several dozen
Muscovy ducks and various other waterfowl swimming in and walking about
the STP's polishing pond, but we saw no waterfowl in the canal.
Despite the poor water quality, there are fish in the canal.
Geo-Marine reported finding many fish and noted that the canal was full
of small young fish in the 1950's.* Most of Geo-Marine's observations
were made at the southwest end of the canal, where water quality, is worse
than it is at Largo's outfall. At the southwestern end, DO in the canal
r
approached zero.** Although the canal cannot meet Florida's WQS, it is
apparently hospitable to fish.
At no point in the planning for Largo did anyone try to 'determine
what would be best for the fishlife or the water quality at the northeastern
end of the canal. Moving Largo's discharge may reduce flushing in the
canal. Maybe the move will degrade water quality; maybe it won't. No one
knows how the change will affect fish in the canal. The pollution-control
agencies do not know how Largo's effluent affects the canal now. They do
not know whether the new spray-irrigation scheme will improve the canal or
*Geo-Marine, Inc. (30 November 1973). A Field Study of Selected
Ecological Properties of Upper Boca Ciega Bay, Cross Bayou Canal, and
Adjacent Areas. Conducted for the Board of County Commissioners, Pinellas
County, Florida. St. Petersburg FL.: Geo-Marine. Passim, especially
p. 132.
**Idem, p. 98.
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degrade it. Considering how much no one knows, we can only wonder why EPA
chose Largo as an outstanding example of pollution-control planning.
4.14 AWT Planning and the Pollution-Control Agencies
Planning for pollution control in the Tampa Bay Compex is a
bureaucratic process, not a scientific one. There has been no intensive
water-quality study of the Tampa Bay Complex since 1968, and that study
confined itself to an odor problem in Hillsborough Bay. The Hillsborough
County Environmental Protection Commission and other agencies do routine
monitoring, but these data have provided only the crudest knowledge and
have led to spurious conclusions. In some places (such as the Cross Bayou
Canal near Largo's outfall) we have been unable to find any data, and must
assume that almost nothing is known. Without sound knowledge of pollution
problems and their causes, the pollution-control agencies can only specu-
late about degrees of treatment, points of discharge, and probable improve-
ment in water quality after the plans have been put into effect.
The plans change often, partly because the planners do not know
the effects of their plans. The agencies are often unable to keep up with
the changes; consequently, there are errors and oversights.
There are few checks on the pollution-control agencies. We
found little evidence of debate either within or among the agencies and
the municipalities. It is surprising that the municipalities did not
object to DPC's requirements, particularly the requirement for phosphorus
removal. The existence of the phosphate deposits, the phosphate mines,
and the gigantic phosphate-fertilizer industry is common knowledge.
Someone must have .realized that removing phosphorus from the discharges
of small STPs would have little effect on the Tampa Bay Complex.
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One of the rare debates among the agencies concerned DPC's
definition of AWT. EPA prevailed upon DPC to interpret the "5-5-3-1" limits
(for BOD, SS, N, and P) as annual averages rather than as monthly averages
or instantaneous maxima. However, EPA did not question the arbitrariness
of these limits. EPA did not ask whether these stringent effluent limits
would solve any of the persistent water-quality problems in the bay com-
plex (e.g. red tides and rotting benthic algae). No one asked whether
these effluent standards are necessary for the bay complex to meet any of
Florida's WQS, and no one asked whether Florida's AWT requirements will
be sufficient. Although procedural questions were common, fundamental
questions were never asked.
4.15 U.S. EPA and the Plans
EPA has not challenged DPC or DER on important issues; it has
restricted itself to procedural and bureaucratic questions. EPA approved
Florida's WQS, which are so flawed that they can hardly be used (and in
fact were never used) for pollution control in the bay complex. EPA
accepted DPC's definition of AWT with only one reservation, i.e. the
statistical interpretation of the "5-5-3-1" limits. EPA accepted the -
requirement for phosphorus removal, even though the Atlanta office knew
about the phosphate deposits and the phosphate industry. EPA required
AWT for Largo (in the NPDES permit) without questioning whether the
Wilson-Grizzle Act applied to the Cross Bayou Canal. EPA apparently
accepted DPC's illegitimate version of assimilative capacity in the Cross
Bayou Canal (see our comments on pp. 83-90). In short, EPA has attended
to paperwork and has neglected the substantive problems of improving
water quality in the bay complex.
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Even in procedural matters, EPA has not been prompt. For
example, Largo's STP violated its NPDES permit for a year without correc-
tive action by EPA. The NPDES permit required Largo to begin N and P
removal by 1 August 1975. It was not until 19 August 1976 that Quentin
L. Hampton (Largo's STP designer) applied for an extension of the interim
discharge limitations (which did not require N and P removal) and a delay
in the requirement for N and P removal. EPA granted the extension on
31 August 1976, after a year of non-compliance at Largo.
EPA's Atlanta office did not know that the new STP at Largo
does not have facilities for N and P removal. We suppose that EPA failed
to keep up with changing plans at Largo. The "Environmental Impact
Appraisal" that EPA prepared for the Largo project shows EPA's misunder-
standing of the changed plans:
"The proposed project includes the expansion and upgrading
of the existing 6.0 MGD contact stabilization plant to a
9.0 MGD modified advanced waste treatment facility includ-
ing nitrification and breakpoint chlorination. The project
will provide highly treated effluent which will be spray
irrigated at two golf courses and the St. Petersburg-
Clearwater International Airport, a total of 1,300 acres,
in the immediate proximity [sic] of the treatment plant.
The treatment facility is designed so that it will be
able to render advanced waste treatment in compliance
with Wilson-Grizzle Bill [sic] requirements and discharge
to Cross Bayou Canal to Tampa Bay during any situations
when the effluent could not be spray irrigated, such as
during periods of rainfall....
"Since the Largo facility is located in the area covered
by the Wilson-Grizzle Bill [sic], advanced waste treat-
ment or alternate means of effluent disposal was required.
The alternates considered were:
(1) Provide complete, on-site AWT consisting of
biological secondary treatment, nitrification,
denitrigication [sic], phosphorus removal, and
breakpoint chlorination with a surface discharge
to Cross Bayou Canal.
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(2) Provide secondary treatment with deep well injec-
tion of the effluent.
(3) Provide modified advanced waste treatment with
filtration and breakpoint .chlorination and
utilizing the effluent for spray irrigation with
no discharge to surface waters.
"The latter [i.e. third] alternate was chosen for two primary
reasons.... This project will enhance the long-term pro-
ductivity [sic.1] by essentially eliminating the oxygen
demand and nutrient loads to Tampa Bay."*
4.16 The Tampa Bay Regional Planning Council
The Tampa Bay Regional Planning Council was funded under P.L.
89-753 to prepare a comprehensive basin plan .and to make recommendations
on pollution abatement. The council is now the "designated 208 agency",
and is preparing another basin plan.
In its 1973 plan, the council recommended AWT for Largo; this
recommendation was inspired by the customary misinterpretation of
the Wilson-Grizzle Act. The council had considered secondary treatment
with spray irrigation, but was wary:
"There are those who believe that secondary effluent spray
irrigation is a panacea ... but in practice, there are
significant unknowns."**
*This appraisal was attached to a memo (dated 4 December 1974)
from George Collins (Project Manager, Florida State Section, EPA-Atlanta)
to "EIS and Legal", through H.K. Lucius (Deputy Director, Office of Water
Programs, EPA-Atlanta). Our copy was obtained from the Largo file in the
Office of Water Programs, EPA-Atlanta.
**Tampa Bay Regional Planning Council (July 1973). Water Quality
Management Plan for the Tampa Bay Basin. St. Petersburg: The Council.
N.B. On the inside front cover and on the bibliographic data sheet, the
report is dated June 1973. Report No. TBR-73-11-WQ. 424 pp. plus plates.
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The council sent Largo a letter certifying that AWT for the
Largo STP "fully conforms to the Tampa Bay Regional Council's long-range
plans, goals, and objectives."* Perhaps the Council derived its powers
of certification from a State law; under P.L. 89-753, it was empowered
only to make recommendations. EPA made sure that Largo's AWT plans fit
the council's basin plan, but EPA never asked the council's opinion of
secondary treatment plus spray irrigation.
The council's 1973 report was filled with plans and models, but
it contained almost no data on water quality. The only data in the report
*were derived from one set of grab samples, collected by volunteers on one
occasion.
4.17 The Planning Requirements of P.L. 92-500
The planning requirements of P.L. 92-500 have led to more paper-
work, not to more knowledge or a better understanding of the Tampa Bay
Complex. We will comment on parts of sections 201, 208, and 303.
4.18 Section 201(g)(3): Infiltration and Inflow Into the Sewers
Section 201(g)(3) requires applicants for construction grants
to show that there is not excessive infiltration and inflow into the
sewer system. To comply with this requirement, Quentin L. Hampton sub-
mitted an evaluation of Largo's sewers to EPA.** He concluded that
infiltration and inflow into Largo's sewers were minimal. However, he
offered only indirect evidence.
*Scott D. Wilson (2 July 1973). Letter to Carl G. Ecklund, Town
Manager of Largo. Mr. Wilson was Assistant Director of the Council. Our
copy was obtained from EPA-Atlanta.
**Quentin L. Hampton Associates, Inc. (January 1974). Sewer
System Evaluation, Town of Largo, Florida. Period of Study September
1972 - August 1973. Stamped "Approved" by EPA, 13 February 1974. Daytona
Beach FL.: Hampton Associates.
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It should be easy to check for gross inflow into the sewer
system by examining STP records on flow and influent BOD. Gross inflow
is marked by great hydraulic fluctuations and by low BOD concentrations
when the inflow rate is high (e.g. after a storm, or after high tide).
Infiltration is a little .harder to detect because the changes are slower
and less dramatic. Largo's sewers are below the water table. Because
they are underwater, they are more subject to steady infiltration than to
dramatic inflow. Steady infiltration is difficult to measure, and no one
has tried to measure in Largo. However, infiltration is not very hard to
detect, because the concentration of influent BOD should be about 150-200
mg/1 in normal domestic/commercial sewage. When the concentrations of
influent BOD are variable, often much lower than 150 mg/1, or both, one'
must choose between two unattractive hypotheses: (1) an untrustworthy
analytical laboratory at the STP, and (2) infiltration and inflow into
the sewer system.
Hampton reported that the flow rate" in Largo increased somewhat
(up to 20%) after heavy rain, but he attributed the increase to direct
inflow through manholes. He argued that infiltration and inflow are mini-
mal because the sewers were carefully laid, tested before use, and because
the per-capita rate of wastewater flow is less than per-capita water
/
sales: 94 gals/day versus 102 gals/day.* However, USGS has reported
that per-capita water use in Largo is 61 gals/day, not 94 gals/day.**
The USGS figure implies that the Largo STP treats more water than Largo
uses. Infiltration may be one-third of the influent.
*Idem, p. 14.
**Henry G. Healy (1972). Public Water Supplies of Selected Munici-
palities in Florida, 1970. Florida Bureau of Geology, Information Circular
No. 81. Prepared by the U.S. Geological Survey. Tallahassee: The Bureau.
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We cannot judge either figure. EPA accepted arid approved
Hampton's report without checking, and the subject of infiltration into
Largo's sewers has not come up again.
Both Hampton and EPA neglected to check the records maintained
by Largo's STP. It is difficult to believe these records, because they
show enormous variations in the influent BOD variations that are not
accompanied by proportionate variations in flow. When the influent BOD is
unusually low, the flow rate should be unusually high; and conversely,
when the influent BOD is unusually high, the flow rate should be unusually
low. At Largo, the STP records show nothing of the kind. The flow measure-
ments are probably reliable. The BOD analyses, however, are probably
invalid. The STP laboratory is fairly rudimentary, and there is no regular
program of quality control. Consequently, all the data from this STP
should be used with extreme caution.
If the BOD analyses were credible and we emphasize again that
they are not they would suggest that there is some infiltration into
Largo's sewers. . Here are summaries for the first nine months in 1976.
Flow Rate (mgd) Influent BODs (mg/1)
Month Average Maximum Minimum Average Maximum Minimum
January
February
March
April
May
June
July
August
September
5.9
5.8
5.9
5.8
6.1
6.3
6.17
7.17
6.78
6.1
6.0
6.3
6.2
7.0
7.0
6.8
8.2
8.2
5.5
5.5
5.5
5.5
5.5
5.7
5.8
6.2
5.1
193
214
209
186
142
140
132.5
122.4
125
257
326
257
285
180
310
242
205
200
120
133
155
140
80
80
73
73
97
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The monthly averages seem to make sense. The highest BODs occur in the
months with the lowest average flow, and the lowest BODs occur in the
months with the highest average flow. The maximima and minima, however,
tell another story.
Influent BODs well below 100 mg/1 are difficult to explain in
an STP that does not have a serious problem with infiltration or inflow.
If the changes are sudden, the culprit is probably inflow; if the changes
are gradual, the culprit is probably infiltration. In Largo, however, the
changes in BOD are not accompanied by changes in flow. The BODs bounce
around wildly, while the flow rate stays fairly steady. Here are data for
two exceptionally inexplicable intervals:
Date . Total Flow (mgd) Influent BODs (m8/!)
1 February 1976 5.8 . 195
2 February 1976 6.0 326
3 February 1976 5.8 185
4 February 1976 5.8 260
5 February 1976 5.8 210
6 February 1976 5.7 175
11 June 1976 7.0 80
12 June 1976 6.8 . 113
13 June 1976 6.4 153
14 June 1976 6.6 '143
15 June 1976 6.4 . 310
16 June 1976 6.3 185
17 June 1976 6.3 112
The February sequence shows a steady flow rate and a BOD range
of 151 mg/1 (a high of 326 and a low of 175) within less than a week.
It is difficult to conceive how the BOD could have been so variable or so
high; the BOD analysis (especially on 2 February) must be spurious.
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The June sequence shows BODs even more variable, with a range
of 230 mg/1 (a high of 310 and a low of 80) in less than a week. The
flow rate was slowly decreasing, but the BODs jumped every which way.
One cannot escape the conclusion that the BOD data are invalid.
EPA accepted Hampton's assessment of infiltration and inflow
without checking to see if it squared with the STP's records. Florida's
pollution-control agencies have accepted Largo's STP data for years, even
though these data make no apparent sense. Had any of these agencies
examined these data, they might have instituted corrective action
checks on quality control in the STP laboratory and a general improvement
in the analytical work. Had the data made sense, Hampton could have used
them to furnish direct evidence on infiltration and inflow. We do not
know why Hampton did not use the STP data, and it is just as well that he
didn't. His indirect evidence, however, is not conclusive, and one of
his principal arguments (per-capita water use) is contradicted by USGS.
Neither EPA nor the State noticed the contradiction and neither insisted
on direct evidence. This performance is«one more proof that planning
at EPA is a bureaucratic process rather Chan a scientific one. It is
paperwork, not a serious attempt to deal with reality.
4.19 Section 208; Planning for Areawide Management
Section 208(a)(2) requires the governor of each State to desig-
nate a planning organization for each area within 270 days of 18 October
1972, but permits him to designate new areas and agencies later.
The Tampa Bay Regional Planning Council became the designated "208" agency
in May 1975. It has not yet prepared a plan, although'it has received
some preliminary studies from its contractors'.
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Section.,208(d) requires that all grants for the .construction of
municipal STPs must conform with the areawide plan, and section 208(e) ,
requires that all NPDES permits must conform with the areawide plan.
Since there is no plan yet, these requirements have not been applied to
Largo.
4.20 Section 303(c); Revising Water-Quality Standards (WQS)
Section 303(c) requires each State to review its WQS at regular
intervals, and to revise them as it sees fit. Florida's latest revision
is contained in Chapter 17-3 of the Florida Administrative Code, Supp.
Nos. 34, 35, 68, and 69 (1976).* Florida's WQS contain the characteristic
faults we have found in the WQS of other States: vagueness, statistical
confusion, wording that cannot possibly mean what it says, confusions
between water quality and wastewater quality, simplistic notions of causa-
tion, and unwarranted appeals to undefined background conditions. We have
written about these'problems many times before.** We refer the interested
reader to these earlier reports for lengthy, detailed analyses. We shall
restrict ourselves here to the most egregious aspects of Florida's WQS.
*Undated, but published between June and November 1976.
**There are lengthy analyses of WQS in two of our recent reports
for the National Science Foundation and the U.S. Office of Management and
Budget.
Jerome Horowitz & Larry Bazel (July 1976). Phase I Final Report on Greater
Boston: Water-Quality Issues in Planning for Pollution Control. NSF Order
No. 76-SP-0931.
Jerome Horowitz &,Larry Bazel (December 1975). An Assessment of Planning
for Water-Pollution Control in Sacramento, California. NSF Contract
No. C-1046. '
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In section 17.3.02, Florida has included the so-called "four
freedoms" in its WQS as
"minimum conditions [which] are applicable to all waters,
at all places and at all times. Within the territorial
limits of this state all such waters shall be free from:
(1) Settleable Substances substances attributable
to municipal, industrial, agricultural, or other discharges
that will settle to form putrescent or otherwise objectionable
sludge deposits.
(2) Floating Substances floating debris, oil, scum,
and other floating materials attributable to municipal,
industrial, agricultural, or other discharge in amounts
sufficient to be unsightly or deleterious.
(3) Deleterious Substances materials attributable
to municipal, industrial, agricultural or other discharges
producing color, odor, or other conditions in such degree
as to create a nuisance.
(4) Toxic Substances -- substances attributable to
municipal, industrial, agricultural, or other discharges
in concentrations or combinations which are toxic or
harmful to humans, animal, plant, or aquatic life."
This general language has two characteristic deficiencies: (1) It is
so vague as to be useless, and (2) it concerns itself exclusively with
water-quality problems that can be attributed to "discharges" (and not
necessarily wastewater discharges) from cities, industries, and farms.
Consider, for example, the problems inherent in the WQS for
settleable substances. The standard does not say that there shall be
no "putrescent or otherwise objectionable sludge deposits" in the State;
it says only that such deposits shall not be attributable to discharges
from cities, industries, and farms. This is a characteristic confusion
between wastewater quality and water quality. If sludge deposits are bad,
they are bad regardless of what causes them. Consider too one of the
largest deposits of settleable substances in the Tampa Bay Complex, viz.
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the deposit of fluorite near the outfall of Gardinier, Inc. (formerly
U.S. Phosphoric), one of the largest of the phosphate industries in the
area:
"Two canals are used for discharging Gardinier's phosphate
processing wastes into the Bay [Hillsborough Bay]. At the
mouth of the southernmost canal there is a deltaic deposit
of fluorite that, to the best of our knowledge, is the only
known deposit of sedimentary fluorite in the world. In
cross-section, the deposit is approximately three inches
thick at the point of initial discharge and thins rapidly
to translucent flakes at the outer edges of the deposit
approximately 1,000 feet into the Bay. The fluorite deposit
is composed of alternating layers of fluorite and loose
grains except where sticks, limbs and roots of trees have
provided a site, free of detrital grains, for fluorite to
precipitate."*
This deltaic deposit of fluorite certainly comes from an industrial dis-
charge, but the deposit is not putrescent. Is it objectionable? Does the
general language of the WQS apply to it? One assumes that the standard
does not apply to the sunken sticks, limbs, and roots of trees (which may
be a hazard to navigation, and which may undergo putrescent decomposition),
because these objects cannot be readily attributed to municipal, industrial,
and agricultural discharges. Whatever else this standard may be, it is not
a useful adjunct to pollution control. It is too vague and not nearly
specific enough to help one decide whether a non-putrescent sedimentary
deposit is permissible or forbidden. If it cannot be clearly applied to
one of the largest industrial discharges in the State, what good is it?
The standard that regulates floating substances may or may not
apply to oil spills from the large tankers that supply Tampa and St.
Petersburg. In what sense is an oil spill from a tanker accident an
industrial discharge?
*William H. Taft & Dean F. Martin (1974). Sedimentary fluorite
in Tampa Bay, Florida. Environmental Letters 6^(3): 167-174.
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The regulation governing toxic substances seems to forbid the
discharge of freshwater into the bay complex. Freshwater is toxic to many
kinds of marine life, which usually cannot tolerate water that is not
salty. The freshwater discharges from all the STPs and industries around
the bay complex are harmful to the marine life at least to the marine
life that comes into contact with the freshwater discharges. Do these
discharges violate this general standard or don't they? If they do, why
doesn't the State forbid these discharges in NPDES permits?
The relation between effluent limitations (or NPDES permits)
and WQS bears close scrutiny in Florida. The WQS for the Tampa Bay Complex
include criteria for DO, BOD (a non-numerical limit), TDS, conductance,
radioactive substances, cyanides and cyanates,* Cu, Zn, Cr, "phenolic-type
compounds", Pb, Fe, As, oils and greases, pH, detergents, Hg, temperature,
turbidity, bacteria, "toxic substances", "deleterious" substances, and
odor. Please note that there are no WQS for phosphorus, nitrogen (not
even for un-ionized ammoniacal nitrogen, which is deadly to fish), and SS.
The BOD standard is hopelessly vague:
"BOD shall not be altered to exceed values which
would cause dissolved oxygen to be depressed below the
limit [established elsewhere in the WQS] ... and in no
case shall it be great enough to produce nuisance
conditions.
There is no simple relation between DO and BOD, certainly not in waters
as hydraulically complex as those around Tampa Bay. Nor can one readily
conceive of BOD concentrations that would, in and of themselves, produce
nuisance conditions. For example, honey and sugar syrup have astronomical
*The yoking of cyanides and cyanates is curious. Cyanide is
extremely poisonous, but cyanate is not much more toxic than common table
salt. Furthermore, cyanates are unstable in the presence of water; they
rapidly decompose into carbon dioxide and ammonia.
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BOD concentrations, but they are not usually thought of as nuisances.
Notice too that the list is far from complete. For example, the
sulfide ion, which is about as poisonous as the cyanide ion, is not men-
tioned. The nickel ion, which is extremely toxic to plants, is overlooked
too. What rationale can there possibly be for excluding very common toxic
substances (such as sulfide, nickel, and. un-ionized ammonia), while includ-
ing such comparative rarities as arsenic?
Most of the substances and properties mentioned in the WQS are
not mentioned in the NPDES permits, and most of the substances and proper-
ties mentioned in the NPDES permits are not mentioned in the WQS. One
would think that the WQS and the NPDES permits would have some overlap,
especially since Florida often weaves language concerning "municipal,
industrial, and agricultural discharges" into its WQS. That the NPDES
permits and the WQS have so little in common is a sure sign of trouble.
Whenever the NPDES permits and the WQS are disjoint, one must conclude
that there is little relation between a State's program of pollution
abatement and its explicit goals for water-quality improvement.
Consider the confusion between effluent limitations and WQS.
Throughout Chapter 17-3 of Florida's Administrative Code (which is prin-
cipally devoted to WQS), Florida repeats a non-specific treatment require-
ment in the midst of provisions that set criteria for ambient water
quality:
*
"Sewage, Industrial Wastes, or Other Wastes any industrial
wastes or other wastes shall be effectively treated by the
latest modern technological advances as approved by the
regulatory agency." -- Sections 17-3.07(1), 17-3.08(2),
17-3.09(1); nearly identical language appears in section
17-3.04(1). Florida Administrative Code, Supplements
No. 69, 68, and 35.
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This requirement is vague and elastic. It has nothing to do with criteria
for ambient water quality. It suggests that treatment plants will have to
be rebuilt every year as technology advances. Moreover, it is inconsistent
with other effluent limitations set forth in the same chapter of the
Administrative Code:
Section 17-3.04(1) specifies that "All discharges from munici-
pal and privately owned domestic waste plants will comply with
the Water Quality Standards of the State of Florida with 90%
treatment [undefined] or better as expeditiously as possible,
but not later than January 1, 1973, except that those plants
discharging sanitary sewage through ocean outfalls or disposal
wells must provide for at least 90% treatment or better as
deemed necessary by the Department [DFC] not later than January
3, 1974."
Section 17-3.04(2) requires industries to adopt treatment
levels in accordance with Federal definitions of "BPT" and
"BAT"; this provision contradicts section 17-3.07(1), which
requires "the latest modern technological advances".
Section 17-3.04(2)(a)(4)(b)(2)(a) specifies that "no wastes
shall be discharged into waters of the state which will vio-
late applicable state water quality standards or reduce the
quality of the receiving waters below the criteria established
for its respective [sic] classification..." This require-
ment does not agree with either of the requirements quoted
above. Furthermore, there is no necessary or readily
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demonstrable connection between waste discharges and
violation of WQS. Causation is rarely simple.
Section 17-3.04(3) requires dischargers of "sanitary waste"
in many parts of the State to adopt AWT or "alternate effluent
disposal", which is defined as "a minimum of secondary treat-
ment (90 percent) followed by an effluent disposal system
approved by the Department [DER] which will prevent any ef-
fluent from being discharged to the surface waters of the
State." This provision puts a heavy burden on municipal
STPs but not on industrial dischargers. Is this equal justice
under the law? Florida State Senator Warren S. Henderson
(representing the 25th District) introduced a bill (SB 984)
in the last session of the legislature to require industries
to adopt AWT. This bill would have put municipalities and
industries on an equal footing, but the bill died in the
Senate Committee on Natural Resources and never reached the
* floor for a vote.
It is difficult to make sense of any effluent limitation incorporated
into a regulation that supposedly sets WQS, and it is especially difficult to
make sense of the matter when there are so many effluent limitations,
nearly all of them inadequately defined.
The WQS themselves are internally inconsistent. Consider, for
example, the standards governing chlorides, dissolved solids, and specific
conductance. These three properties are closely related, especially in
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brackish or salty water. We shall first quote the standards in full,
then comment on the internal inconsistencies and other flaws.
"Chlorides chlorides shall not exceed two hundred fifty
-(250) mg/1 in streams considered to be fresh water streams;
in other waters of brackish or saline nature the chloride
content shall not be increased more than ten per cent (10%)
above normal background chloride content."
"Dissolved Solids not to exceed five hundred (500) rag.
per liter as a monthly average or exceed one thousand
(1,000) mg. per liter at any time."
"Specific Conductance shall not be increased more than
one hundred per cent (100%) above background levels or to
a maximum level of 500 micromhos per centimeter (cm) for
streams considered to be fresh water streams."
The standard for- dissolved solids must be violated all the time
in the Tampa Bay Complex, since these waters are salty and usually contain
about 30,000 mg/1 of dissolved solids. Although the standards for
chlorides and conductance make special provision for waters that are not
fresh, the dissolved-solids standard does not. The dissolved-solids
standard is defined in terms of a monthly average, but we are not told
how many samples are to be collected, where they are to be collected, and
how they are to be averaged. For example, if we take 1,000 samples in
the non-estuarine portion of the Hillsborough River and 1 sample in the
middle of Tampa Bay, the average will show that the water contains few
dissolved solids. On the other hand, if we take 1,000 samples in the
middle of Tampa Bay and 1 sample in the non-estuarine portion of the
Hillsborough River, the average will be very high far above 1,000 mg/1.
The standard does not contain any provisions to prevent this kind of
statistical nonsense.
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Chlorides may not "be increased more than ten per cent (10%)
above normal background chloride content", but conductance may not "be
increased more than one hundred per cent (100%) above background levels".
In the waters of the Tampa Bay Complex, there must be a strong correlation
between chlorides and conductance. Why, then, may chlorides be increased
by 10%, while conductance may be increased by 100%? Here is a paradox
indeed. The standard for dissolved solids must be continually violated
in the bay complex; the standard for chlorides may easily be violated when
the standard for conductance is not. Why should three closely related
properties of water receive such differential treatment at the hands of
the standards-setters? All three standards were supposedly devised to
protect the same beneficial uses.
Notice too that "normal background chloride content" and
"background levels" of conductance are not defined. Just what is the
"normal background"? How does it differ from the "background level"?
Where is it to be measured? May it be measured after a storm? Is it to
be measured only at the water surface, or is it to be measured throughout
the water column? Will the conductance and chloride standards be violated
when reverse flow in Hillsborough Bay pushes a tongue of saltwater up the
Hillsborough and Alafia Rivers? Are saltwater intrusions into estuaries
"normal background"? Does the answer change when the saltwater intrusion
is occasioned by a wind tide rather than an astronomic tide? One suspects
that the standards-setters had very simple bodies of water in mind when
they wrote these vague, simplistic standards. There is much to be said
for drafting WQS specially designed for the complicated waters of the
Tampa Bay Complex.
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One wonders too about the talk of increases in chlorides and
conductance. Aquatic life may be just as sensitive to sudden decreases
as to sudden increases. One suspects that the standards-setters talked
only of increases because they had wastewater discharges in mind; they
probably wished to avoid discharges of very salty water into freshwater
channels. If this supposition is so, the talk of "increases" is another
example of the cryptic confusion between wastewater quality and water
quality. One supposes that the standards-setters failed to consider the
damage to marine life that can be caused by freshwater discharges into
marine waters. It works both ways: Salty discharges into freshwater
may upset freshwater forms of life, but freshwater discharges into salt-
water may upset marine life. The standards-setters evidently failed to
consider this basic ecological fact.
When Florida reviews its WQS, and when EPA comments on the
proposed revisions, we hope that they will do something about the vagueness,
the statistical ambiguities, the confusions between wastewater quality
and water quality, the oversimplifications, the paradoxes, and the internal
inconsistencies that now afflict these standards.
4.21 Section 303(d)(l); Segmentation and Maximum Daily Load
Section 303(d)(l)(A) requires each State to identify its Water-
Quality Limited (WQL) waters and rank them according to the severity of
pollution and the uses to be made of the water. Water-Quality Limited
waters are those that would violate WQS if all the municipal discharges
gave secondary treatment and all the industries gave best practicable
treatment (BPT). The process of dividing and identifying the waters is
known as segmentation. Section 303(d)(l)(C) requires each State to
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determine the assimilative capacity of its.WQL waters for each pollutant
that the Administrator identifies. Section 304(a)(2) requires the Adminis-
trator to identify those pollutants by November 1973, but the Administrator
has not yet identified any.
Florida ranked its segments by faking assimilative capacities.
No one knows enough about the Tampa Bay Complex to determine an assimila-
tive capacity for any pollutant. To get around this deficiency DER (and
DPC before it) used several methods to produce numbers that are called the
assimilative capacity, but that are patently not the assimilative capacity.
In 1974 DPC explained its method as follows:
"The assimilative capacities of Tampa Bay and the
segments tributary thereto were based on the efflu-
ents established by the Grizzle-Wilson bill....
That is, the assimilative capacity was computed by
determining the total UOD of the existing flows
within the segment if AWT standards were being met."*
By 1976 DER had added two methods - simplified mathematical modeling and
the following curiosity:
"In segments where no discharge is permitted, the
calculated assimilative capacity was based on a
minimum UOD discharge of 117 Ibs/capita/day."**
*Florida Department of Pollution Control (21 June 1974). State
Water Pollution Control Work Plan, Fiscal Year 1975. Submitted to EPA-
Atlanta in accordance with PL 92-500, Section 106. Tallahassee, Fla.:
The Department. Appendix, Section 2, p. A2-3.
**Florida Department of Environmental Regulation (March 1976).
Tampa Bay Area Water Quality Management Plan, submitted in accordance with
the 1972 Federal Water Pollution Control Amendments (Public Law 92-500,
section 303). The cover is marked "preliminary draft for public hearing";
it is the only form of this report (as of November 1976) available in
Atlanta, Tallahassee, or St. Petersburg. Tallahassee, Fla.: The Depart-
ment. The last page is a letter from Loring Lovell, Chief, Bureau of
Water Quality, Florida Department of Environmental Regulation. The letter,
dated 29 June 1976, certified that the planning in this report "is in accord
with state plans, projects, and objectives." This certification is in
compliance OMB circular A-95 and Florida statutes, p. 11-45.
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Neither of these methods can produce a legitimate version of an assimila-
tive capacity. We will review them separately.
4.22 The "Wilson-Grizzle Limits" Method
At first DPC tried to compute assimilative capacity from the
"5-5-3-1" limits. It calculated UOD (Ultimate Oxygen Demand) from 5 mg/1
of BOD_ and 3 mg/1 of nitrogen by assuming that all the nitrogen was TKN.
5
It then multiplied the UOD concentration by the sum of all the STP flows
to get an effluent-UOD flux for each segment, which is called the assimi-
lative capacity. An assumed effluent flux is not an assimilative capacity.
The justification that DPC gave for using this method reveals
fundamental misunderstandings of both assimilative capacity and pollution
control. Here is part of DPC's justification:
"ranking the segments required a qualitative [sic] method
for determining the'severity of the pollution problem. The
parameter of ultimate oxygen demand (UOD)...represents a
common indicator of pollution. UOD is readily converted
for [sic] BOD5, a standard sampling parameter, and can be
equated with dissolved oxygen levels in surface waters."
"The assimilative capacity of the segment is the sum of the
assimilative capacities of all the receiving waters to which
loads are being discharged."*
These two short passages are thick with errors. UOD cannot be
equated to dissolved oxygen (DO), nor can it be readily calculated from
BODg alone. A concentrated solution of ammonium hydroxide may have no
DO; its BOD- will be zero because microbes cannot live in it; but its UOD
will be astronomically large. There is simply no necessary relation among
UOD, BOD^, and DO. A complete growth medium laced with antibiotics and
*Florida Department of Pollution Control (21 June 1974).
Op. cit., Appendix, Section 2, pp. A2-1 to A2-2.
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heavy-metal ions cannot support microbial growth; consequently, its
must be zero, even though the UOD of the medium may be high and even
though all essential nutrients are present. There is much more to pollu-
tion than UOD (e.g. contamination of water supplies by pathogenic microbes
or poisons), and UOD is not the only factor that affects DO (other impor-
tant factors are reaeration, temperature, photosynthesis by aquatic flora,
sediment oxygen demand). UOD alone doesn't explain much, nor does it
correlate with most of the conditions that anyone in his right mind would
call pollution.
It is deceptive to claim that the assimilative capacity of a
segment is the sum of the assimilative capacities of all the receiving
waters into which loads are being discharged. Everything is inside-out.
To the best of our knowledge, a segment must be smaller than a body of
receiving water; there may be many segments in one such body, but there
had better not be several bodies in one segment. Yet this is exactly
what DPC has done. Assimilative capacity can be meaningfully calculated
only on a point-by-point basis. The hydraulic connections among these
points must be clear and simple; if they aren't, there is no hope of
calculating an assimilative capacity. When a competent modeler speaks of
a segment, he has in mind a rather small, uniform volume of water; and if
he knows what he is doing, he has a good idea of the hydrodynamic exchanges
among adjacent segments. Largo is in a segment (24.4EA) that encompasses
bayous, passes, harbors, a sound, creeks, lakes, impoundments, a canal,
parts of three bays, and part of a gulf. To call this hodge-podge of waters
a segment is playing fast and loose with language. No one knows how the
various receiving waters are interrelated in Segment 24.4EA. For that
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matter, the fundamental hydrodynamic relationship between the Cross Bayou
Canal and Old Tampa Bay has yet to be explored, much less sufficiently
understood for a calculation of assimilative capacity. In short, DPC's
claim is quackery.
The segmentation of the Tampa Bay Complex is particularly poor.
Each of the bays is split into two or more segments, and the segments may
contain parts of two or more bays. The line between two segments (24.4EA
and 24.4DA) has never been formally drawn through Old Tampa Bay. Each
person we asked in DER pencilled in a different line and gave us a dif-
ferent story. Apparently the segment lines come from the USGS delineation
of drainage basins.* Until recently, USGS did not take routine measure-
ments in the Tampa Bay Complex. It therefore had no need to number the
bays, and did not. It drew lines to divide one river basin from another
(e.g. the Hillsborough from the Alafia) but the lines stopped or became
dashed as they reached a bay. DPC apparently connected the dashes.
Despite the problems of determining assimilative capacity,
Florida used its ranking methods to prepare many lists. In DPC's 1975
work plan, Segment 24.4EA (Largo's segment) scored 960.7 and ranked 25th
among the segments of the State. In DER's 1976 basin plan, 24.4EA again
scored 960.7 but ranked 26th. The assimilative capacity of the segment
was not published in either of these documents, but we located the orig-
inal worksheet in Tallahassee. 24.4EA was ranked thirtieth; its score
on the sheet had been changed from 815.8 to 49,306.8. The "assimilative
capacity" of the segment had also been changed, from 10,517 Ibs/day to
*See United States Geological Survey (1974). Water Resources
Data for Florida, Water Year 1973, Part 2: Water Quality Records.
Washington, D. C.: U. S. Government Printing Office, p. 3.
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174 Ibs/day. We were told that the numbers had been changed when the
first STP in the segment was required to cease direct discharge to the
surface waters of the State. When that happens, DPC treats the segment
as a "no discharge" segment, and the assimilative capacity of the segment
is assumed to be 174 Ibs/day.
Why 174 Ibs/day? DPC and DER use this number as a denominator
in the ranking calculation; the denominator must not be zero. 174 Ibs/day
is the calculated UOD flux of 1 mgd carrying 5 mg/1 BOD5 and 3 mg/1 TKN.
It has nothing to do with assimilative capacity. It is a cacoethes
calculandi.
4.23 The Mathematical-Modeling Method
DER claims that it used "simplified or, if available, more
complex" mathematical models to determine the assimilative capacity of
its segments in the Tampa Bay basin.* Although the Tampa Bay Regional
Planning Council and the University of South Florida have developed models
of the Tampa Bay Complex, the models are unverified and have not been used
to compute an assimilative capacity. DER hired a consultant (Yousef) to
model Tampa Bay tributaries, but his report was published after the basin
plan.** Yousef used simple models and programmed them with assumptions.
For the Largo STP he assumed the flow of the Cross Bayou Canal, the reaera-
tion rate, the background DO deficit, and the sediment oxygen demand; he
*Florida Department of Environmental Regulation (March 1976).
Tampa Bay Area Water Quality Management Plan. p. 11-45.
**Yousef A. Yousef et al. (July 1976). Waste Load Allocation
for Tampa Bay Tributaries. Florida Technological University, Environmental
Systems Engineering Institute, prepared for the Florida Department of En-
vironmental Regulation. Technical Report //ESEI-5. Orlando, Fla.: The
University.
88
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ignored photosynthesis and glycolysis. However, Yousef decided to forbid
a discharge from the Largo STP without using a model. Here is his logic:
"Water quality data are not available in the immediate
area."
"Since the Western Part of the Canal has low dissolved
oxygen readings, the Eastern part must be similar."
"Since the background dissolved oxygen levels are very
low, a no discharge policy appears to be the conclusion
without any quantification using the simplified mathe-
matical modeling techniques."*
Yousef's logic is faulty. The field study of the Cross Bayou
was done by Geo-Marine, Inc.** In the northeastern half of the canal,
Geo-Marine never found a DO lower than the minimum WQS of 4 mg/1; in the
southwestern half of the canal, however, Geo-Marine found that the DO
approached zero. Yousef is wrong when he concludes that the two halves
are similar. The DO readings nearest the Largo STP were much higher than
the readings in the western part of the canalJ Quite aside from logic,
we note that Yousef's allocation came long after Largo had decided to spray-
irrigate its STP effluent.
Apparently Yousef has not seen Largo's discharge into the canal.
He seems to have assumed that the discharge degrades the naturally clean
waters of the canal. As anyone can plainly see, the STP effluent certainly
looks cleaner than the water in the canal. For all we know, relocating the
STP discharge may degrade the canal, not improve it.
*Yousef A. Yousef et al. (July 1976). Waste Load Allocation
for Tampa Bay Tributaries. Florida Technological University, Environmental
Systems Engineering Institute, preapred for the Florida Department of En-
vironmental Regulation. Technical Report //ESEI-5. Orlando, Fla.: The
University, pp. 105-106.
** Geo-Marine, Inc. (30 November 1973). Op. cit.
89
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Yousef's work is better than DER's, but it is not nearly good
enough to produce legitimate assimilative capacities.
4.24 The "No-Discharge" Method
DER claims that it calculated assimilative capacities "based
on a minimum UOD discharge of 117 Ibs/capita/day." What nonsense!
Although we have no idea how DER chose that rate, it sounds suspiciously
like the rate DER chose for the assimilative capacity of Segment 24.4EA,
viz. 174 Ibs/day. It is embarrassing to point out that 117 Ibs/capita/day
of anything is illogically high, particularly for people who weigh less
than 117 pounds. In the real world, people have a hard time generating
more than a pound of UOD in their daily wastes. To generate 117 Ibs/day,
they would have to take turns throwing themselves into the sewers.
4.25 ' Methods and Realities
Despite all the methods for determining assimilative capacities,
no one in DER or EPA knows whether Largo's STP discharge causes violations
of WQS in the Cross Bayou Canal and adjacent waters. Wouldn't it be better
to abandon the paperwork and the unrealistic assumptions long enough to per-
form a sensible, empirical study of the canal? To detect DO problems (or
the absence of DO problems), one needs no more than a couple of technicians
and a simple DO probe.
4.26 Phosphorus: Where Does it Come From?
Phosphorus from STPs enters the Tampa Bay Complex; but this source
c
of phosphorus is dwarfed by the phosphorus-laden rivers of the area, parti-
cularly the Alafia. The riverine phosphorus is derived from the gigantic
phosphate deposits just east of the bay complex. It is impossible to
\
90'
-------
determine how much of the phosphorus comes from erosional processes and
how much comes from the enormous phosphate industry in this part of Florida.
It is no secret that Florida is one of the leading phosphate
producers in the world:
"Florida, for the 80th consecutive year, ranks as the
leading state in the production of phosphate with over
75% of the total domestic and 30% of the world market
being met by production in Hamilton, Polk, Marion,
Gilchrist, and Citrus Counties.... The land pebble phos-
phate deposits occur in two widely separated areas, one
centered in Hamilton County [about 75 miles east of
Tallahassee] and the other in Polk County [about 30 miles
east of Tampa], and they account for more than 98% of the
total production.*
"Florida has been the leading producing State for many
years and is currently furnishing 74% or more of domestic
production, 90% of which comes from the land-pebble field
of central Florida [just east of Tampa]."**
In processing the phosphate rock, large quantities of phosphate
slimes are created:
"The Florida phosphate rock washing operations, because
of the nature of the material, produces large quantities
of a slurry of very fine clay and phosphate minerals
called slimes. This is a waste product and must be con-
tained in slime ponds that cover large areas. . .. [0]Id
slime ponds are now being reclaimed for recreational,
agricultural, and other uses. Some of the phosphate
mining is done in swamplands, and after reclamation, the
area is better suited for other uses than it was before
the mining took place. The greatest problems of this
nature exist in Central Florida....
*J. William Yon & W. R. Oglesby (1975). Florida Mineral
Industry, pp. 498-506 in Allen Morris [compiler], The Florida Handbook,
1975-1976, 15th edition. Tallahassee: Peninsular Publishing Co.
Mr. Yon is "Geologist, Bureau of Geology, [Florida] Department of
Natural Resources."
**Richard W. Lewis (1970). Phosphorus, pp. 1139-1155 in
U. S. Bureau of Mines, Mineral Facts and Problems, 1970. Washington,
D. C.: USGPO.
91
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"Perhaps the biggest problem of the phosphorus industry
is in connection with exploiting the Florida land pebble
deposits. About 30% of the mined ore matrix is slime
material that is removed in the washing plant and dis-
carded into ponds. The slimes occupy approximately 50%
more volume than the original phosphate matrix mined.
Even though a mined-out pit is generally used for their
storage, one-third more volume [sic] is required and
must be provided for by the construction of expensive
earthen dikes or dams. After preliminary settling some
water is recovered for reuse but many years of settling
are required before the area can be reclaimed. In addi-
tion, the slimes contain nearly the same phosphate values
as the original matrix, therefore, there is about a 33%
loss of phosphorus^ resource. This problem has been
magnified in the last couple of decades by the advancing
population. Residential areas are closing in on the
phosphate operations and so what was a minor problem a
generation ago is becoming more of a. major one."*
It has been known for a long time that the rivers dra'lning this
phosphate-rich area are themselves loaded with phosphorus. For example,
Prof. Howard T. Odum published a seminal paper in 1953 dealing with phos-
phorus in Florida's waters.** Here is an extract of Odum's data:
*Idem..
**Howard T. Odum (9 January 1953). Dissolved phosphorus in
Florida waters: A report to the Florida Geological Survey. Reports of
Investigations No. 9, "Miscellaneous Studies", part 1, pp. 1-42.
Tallahassee: The Survey. N. B. The title is deceptive. Odum measured
both particulate and dissolved phosphate, and made no attempt to dis-
tinguish between them.
92
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Sampling Site Total P (ppm)
Alafia River System, 19 June 1952
Alafia estuary
Fishawk Creek
Alafia R. above Lithia Springs
Alafia R. @ Lithia Springs
Alafia R. @ Riverview
So. Branch of Alafia R. @ Pinecrest
Alafia R. @ Bloomingdale-Lithia Rd.
Sampling Site
Tampa Bay Series, 27 September 1952
On Ballast Point pier, 300 yds out
McDill Field, east coast
East end of longer bridge of
Courtney-Campbell Causeway
West end of Gandy Bridge
St. Petersburg, south of Papys
Bayou near 54th Street
End of St. Petersburg pier
50 yds. out from Bee Line Ferry
Dock
Buoy 5 off Pinellas Point (pH 8.3)
Buoy 1
Buoy can 3B
Buoy 3A
"Buoy 2A
Buoy 14
Buoy 13
Buoy 11 @ Harbor mouth
Just outside harbor in
Egremont Channel
Depth (ft)
0
0
0
0
0
0
0
0
10
0
10
20
0
10
20
30
0
0
0
0
10
20
30
0
10
20
30
Salinity (ppt)
25.2
25.6
27.3
27.7
28.4
28.9
30.0
30.6
30.6
29.1
30.0
32.8
29.4
29.9
32.0
33.0
33.2
33.0
34.2
34.4
34.0
34.2
34.2
34.0
0.660
0.390
1.81
2.37
1.36
>3.33
1.25
Total P (ppm)
0.74
0.84
0.274
0.250
0.33
0.285
0.290
0.256
0.33
0.148
0.284
«__
0.136
0.295
0.163
0.154
0.130
__
0.073
0.126
0.096
Prof. Odum was not explicit about his sampling methods or his
analytical techniques. It is probably safe to assume that he entirely
93
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overlooked the bedload (i.e. the sediments that move along the riverbed);
from what is known about the vast quantities of phosphate slimes created
by the beneficiation of phosphate ores, it is likely that many of the
waters in the phosphate-producing districts ride on a thick blanket of
phosphate-rich ooze. Consequently, Odum's figures are probably much too
low. Nevertheless, he certainly demonstrated that the waters he sampled
were loaded with phosphorus, and all subsequent studies have confirmed
this observation. It is worth pondering a few of Odum's observations and
conclusions:
"It will be noticed that streams are high and in fact
enormously laden with phosphorus in the phosphate districts...
Estuarine waters contain more phosphorus than open water...
but somewhat less than the streams from which the phosphate
is derived, [pp. 12-13] t
"Since Florida has such large resources of phosphate rock,
it is reasonable to expect Florida's waters to contain on
the average higher phosphorus concentrations than most other
regions of the world.... Of those [other regions of the
world] analyzed only the salt lakes in arid parts of the
world show higher phosphate contents than those of the
phosphate districts of Florida, [p. 18]
"The phosphate industry particularly in the Peace and
Alafia river systems is discharging phosphate slimes....
A high original phosphorus concentration is indicated by
the streams in the Peace and Alafia river area which do
not receive industrial wastes but have very high values
although not so great as the Peace and Alafia proper. It
seems likely that the pollution somewhat accentuates the
addition of phosphorus. [p. 25]
"The dissolved phosphorus content of Florida's fresh water
is correlated with the underlying phosphatic rock formations
of the drainage area. [p. 28]
"The dissolved phosphorus content of Florida's estuarine
waters is determined by the proximity of the rivers and
the phosphorus content of these rivers, [p. 28]
"The dissolved phosphorus and thus the potential fertility
in Florida waters especially in the phosphatic districts is
considerably higher than in waters' in most other humid regions
of the world yet studied." [p. 28]
94
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Odum wrote this report nearly two decades before the Wilson-.
Grizzle Act and P.L. 92-500. His commentary seems to have been overlooked
in the recent wave of pollution-control legislation.
In 1967-68 the U.S. Federal Water Pollution Control Administra-
tion (FWPCA) also found very high concentrations of phosphorus in the
Alafia River and in Hillsborough Bay (part of the Tampa Bay Complex; the
Alafia flows into Hillsborough Bay). Unlike Odum, FWPCA stressed the
magnitude of industrial wasteloads of phosphorus:
"Comparisons of filtered and unfiltered phosphate deter-
minations indicated that greater than 95% of the concen-
tration was in a soluble form. All concentrations in the
subsequent discussion refer to total phosphate. However,
for all practical purposes, these figures can be assumed
to represent soluble phosphate as well. [Like Odum, FWPCA
neglected the bedload.]
"Phosphate distribution based on the mean concentration
for the period of study [several months during the summer
of 1967 and the winter of 1967-68] is shown in Figure 9.8.
[Figure 9.8 shows that the mean phosphorus concentration
(as P) in surface samples varied from a low of 3.0 mg/1 in
the northwest corner of Hillsborough Bay to a high of
9.0 mg/1 in the lower Alafia River.] A mean survey value of
9.65 mg/1 was observed at Station Al (U.S. Highway 41
Bridge) on the Alafia River. As previously noted approx-
imately 43,470 pounds/day of phosphates (as P) are discharged
from the Alafia River and another 8,810 pounds per day are
discharged from U.S. Phosphoric Products [a division of
Gardinier, Inc.; this plant is at the mouth of the Alafia].
Together these two sources account for 93.8% of the total
phosphorus input into Hillsborough Bay from waste sources.
[This sentence implies that one river plus one factory
equals two waste sources.] The phosphate gradient is pro-
nounced around these two sources, approximately 1 mg/1 per
mile. The lowest values are found in the northwestern
portion of the Bay near Bayshore Boulevard (2.85 mg/1) and
in [upper] Tampa Bay (2.34 mg/1), with phosphate concen-
trations slightly lower in winter than in summer. [The
rainiest months are June - September; higher concentrations
during wet weather suggest area sources, probably from the
bedload and the slime ponds.] This is the result of lower
flows in the Alafia River and consequently lower mass
input [scil. outflow] of phosphate during the winter. The
pattern of distribution does not change. The minimum total
phosphate concentration observed occurred at station B24
95
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[in the northwestern corner of Hillsborough Bay, over six
miles from the mouth of the Alafia] on August 23, 1967 and
was 0.165 mg/1 as P. Examination of phosphate concentra-
tions at three and four hour intervals during August and
September of 1967 reveal [sic] no variation in concentra-
tion attributable to tidal action."*
FWPCA reported that 78% of the phosphorus introduced into Hills-
borough Bay came from the Alafia River; 1.1% came from the Hillsborough
River, 4.8% from the Tampa STP at Hookers Point (a primary plant), and
15.8% from U. S. Phosphoric Products.** Clearly, most of the phosphorus
did not come from STPs (and the Tampa STP is the only large one on Hills-
borough Bay). The phosphorus came from the Alafia River and from U. S.
Phosphoric (now Gardinier, Inc.), and the Alafia was far more important:
"The Alafia River was considered a point source of fresh
water flow and pollution. Processes and waste disposal
practices of the individual industries and municipalities
within the Alafia River basin were outside the scope of
this project. However, the results of these practices in
terms of the effect on Hillsborough Bay were of major con-
cern. There are 14 phosphate processing plants located in
the Alafia River basin. Their combined effect resulted in
a discharge of approximately 43,470 pounds per day of
total phosphate measured at the Alafia River gaging station
at Lithia, Florida. This makes the Alafia the most signi-
ficant source of phosphate wastes discharged into Hills-
borough Bay."***
*U. S. Federal Water Pollution Control Administration,
Technical Programs, Southeast Region, Hillsborough Bay Technical
Assistance Project (December 1969). Problems and Management of Water
Quality in Hillsborough Bay, Florida. Tampa: The Administration,
pp. 23-24.
**Ibid., Table A.6, pp. 58-60.
***Ibid., p. 16. CAVEAT; FWPCA confuses "phosphate" and
"phosphorus" throughout this report. It is rarely clear whether "phosphate"
is expressed as P or as PO^, and there are contradictory instructions in
the text. Phosphate weighs about three times as much as phosphorus.
43,470 pounds of phosphate contains only 14,178 pounds of phosphorus. We
assume that the occasional mention of "phosphorous", i.e. PO-j, is bad
spelling, a "typo" for "phosphorus", rather than bad chemistry.
96
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We are not at ease with the facile attribution of all phosphorus
in the Alafia to industrial waste. As Odum pointed out years before, there
is plenty of phosphorus in the Alafia that has nothing to do with industry;
after all, the Alafia basin includes one of the richest phosphate deposits
on earth. FWFCA made no attempt to distinguish between industrial and
erosional phosphate in the Alafia. No doubt, industries account for a lot
of the Alafia's phosphorus, but there must have been plenty of phosphorus
in the Alafia long before the industries were established. How much is
anybody's guess, but it is preposterous to allege that all the phosphorus
in the Alafia comes from wastewater.
FWFCA admitted that there was phosphorus in the Hillsborough
River, and they did not attribute this phosphorus to wastewater. Their
handling of the Hillsborough River leaves much to be desired: It is
incomplete and misleading. They did not report phosphorus data for the
Hillsborough River; but at Station Bl (Hillsborough Bay just below the
mouth of the river) they reported that the phosphate concentration was
2.54 mg/1 in summer and 2.84 mg/1 in winter.* They claimed that the
Hillsborough River (measured just above Tampa's water-supply reservoir)
carried 630 Ib/day of total phosphate.** In Table A.6 they explain that
this conclusion was "based on weekly samples .from June 1967 through April
1968." They do not explain that 630 Ib/day must be exceptionally low
because the Hillsborough River was in extreme drought during these eleven
*Ibid., Table 9.3, p. 24.
**Ibid., p. 17/18.
97
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months. During droughts, rivers have much less carrying capacity than
in normal flow.
In Table A.2 they give hydrological data for the Hillsborough
River. One immediately sees that the flow was below normal in ten of
the eleven months. In six of these months it was more than 90% below
normal, and in four months it was more than 95% below normal. For these
eleven months as a whole, the actual flow was only 36% of the normal flow.
The Alafia River, by way of contrast, had nearly normal flow.*
For these eleven months as a whole, its flow was 12% above normal.
Consequently, the Hillsborough River (which is normally the
largest tributary to Hillsborough Bay - over 50% larger than the Alafia)
carried less water than the Alafia in all but two months. FWPCA carefully
reported the hydrology, but then failed to warn the unsuspecting reader
that the hydrological differences greatly bias the data on phosphorus
loads. It is worth repeating that rivers in drought have much less
I
carrying capacity than they do in normal flow. It is misleading to com-
pare a river in extreme drought with a river in normal flow - and FWPCA
t,
never alerts the reader to this deceptive comparison. In more normal years,
the Alafia would carry a little less phosphate (and the Hillsborough River
would carry far more) into the Tampa Bay Complex.
FWPCA did report that there was enough phosphate in the Hills-
borough River to support a massive bloom of water hyacinth (Eichhornia
crassipes) in Tampa's water-supply reservoir:
*Ibid., Table A.3, p. 52..
98
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"The Tampa Water Supply Reservoir located ten miles above
the mouth of the river has a severe water hyacinth
(Elchhornia [sic] crassipes) problem. These plants float
on the water surface with an unattached root system exten-
ding 12 to 18 inches beneath the surface. In the presence
of warm temperatures and relatively high nutrient quanti-
ties, these plants multiply until they cover the surface
of the reservoir. During June and July 1967, the entire
surface area of the Hillsborough River reservoir was
covered to such an extent that no water could be seen.
It is the present practice to treat these hyacinths with
a chemical herbicide, 2-4-D [sic], and allow them to sink
to the bottom of the reservoir. However, during the summer
of 1967, several thousand acres of hyacinths were released
from the reservoir to be deposited in Hillsborough Bay.
It has been reported by the Florida State Board of Health
that hyacinths contribute 200 pounds of nitrogen and 16
pounds of phosphate per acre. During the summer of 1967,
an estimated 400,000 pounds of nitrogen and 32,000 pounds
of phosphates were released to Hillsborough Bay in this
manner. If the practice of flushing these hyacinths
from the reservoir should become routine, these hyacinths
would become a significant source of nutrient material
and would contribute to the deposition of organic bottom
sediments in the Bay."*
Even in extreme drought, the Hillsborough River carried plenty of phos-
phorus. FWPCA does not attribute this phosphorus to wastewaters, but
neglects to mention where it might have come from.
FWPCA attributes most of the phosphorus to industry. Odum
attributes most of it to erosion. Neither of them contended that STPs
contribute more than a small portion of the phosphorus that is found
in the bay complex. And to the best of our knowledge, neither has
anyone else.
If the STPs are relatively trivial in the phosphorus budget of
the bay complex, what is to be gained by having the STPs go to the expense
of phosphorus removal? Everyone seems to agree that most of the phosphorus
in the bay complex has nothing to do with the STPs. Recall that Florida's
*Ibid., p. 17/18.
99
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AWT requirements apply only to STPs: They do not apply to industries
and they do not apply to fluvial erosion. In short, Florida's AWT require-
ment is aimed at the wrong target, and it would seem beyond rational
dispute that phosphorus removal makes little sense for the STPs in the
Tampa Bay Complex.
4.27 The Dubious Rationale for Phosphorus Removal
The Tampa Bay Complex is not Lake Superior. It is warm, salty,
and rich in plant nutrients. It was surrounded by lush tidal swamps,
which suggest nutrient enrichment, long before the region was developed.
In short, it is a productive body of water, and it has produced masses of
aquatic flora for a very long time.
There is no evidence that phosphorus is the growth-limiting
element for aquatic plants in the bay complex, and there is overwhelming
evidence that phosphorus levels in these waters would be high whether or
not STPs provided AWT.
Perhaps the great emphasis on phosphorus removal may be traced
to the rather general verbiage on phosphorus as a pollutant in the 1972
"Blue Book:"*
"Phosphorus as phosphate is one of the major nutrients
required for algal nutrition. In this form it is not
normally toxic to aquatic organisms or to man [indeed,
the phosphate fizz, which is nothing more than a flavored
solution of supersaturated phosphoric acid, was for sev-
eral generations a standard item at American soda fountains].
Phosphate in large quantities in natural waters, particularly
in fresh waters, can lead to nuisance growths and to eutro-
phication. This is particularly true if there is a
*Environmental Studies Board, U. S. National Academy of Sciences
and National Academy of Engineering (1972). Water Quality Criteria 1972:
A Report of the Committee on Water Quality Criteria. Requested and funded
by the U. S. EPA. Washington, D. C.: USGPO. The cover and spine are
marked EPA-R3-73-033-March 1973. USGPO Stock No. 5501-00520.
100
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sufficient amount of nitrate or other nitrogen compounds
to supplement the phosphate. Thus, there is a need for
control of phosphate input into marine waters." [pp. 253-254]
"In the marine environment, growth of phytoplankton is
commonly limited by the availability of essential nutrients,
the most important of which are phosphorus and nitrogen in
available forms. In some cases, shortages of silicate can
inhibit the growth of the diatoms and encourage growth of
other species. In certain limited areas, other elements
such as iron and manganese have been reported as limiting
the growth of algae, and the presence or absence of other
growth stimulating substances, such as vitamin B-12, can
influence both the amount and the character of plant species
capable of growing. It should be noted that in the marine
environment, several elements essential for plant growth
such as potassium, magnesium, and sulfur, are present in
great excess.
"[F]rom an addition of phosphorus and available nitrogen
to final concentrations of 50 and 362.5 micrograms per
liter respectively in the receiving water, enough organic
material could be produced to remove 6.9 milligrams of
oxygen per liter. Data in Table IV-9 indicate that sea water
with a salinity of 30 o/oo and a temperature of 25C will
contain, at saturation, 6.8 milligrams of oxygen per liter.
This concentration of nutrients would thus permit the sys-
tem to become anoxic and would violate the requirement that
oxygen not be changed beyond levels expressed in the section
on Dissolved Oxygen....
"The example used might be considered to set an upper limit
on the amount of these nutrients added to water. The actual
situation is, of course, much more complicated. It is clear
from the data in Table IV-9 [which gives DO as functions
of temperature and salinity] that simmer conditions place
the most stringent restrictions on nutrient additions to
the aquatic environment. Furthermore, the normal content
of nutrients in the natural environment has to be consi-
dered . If these were already high, the amount of nutrients
that could be added would have to be reduced. [Emphasis
supplied]
"Recommendations
Neither organic matter nor fertilizers should be added
that will induce the production of organic matter by
normal biota to an extent causing an increase in the size
of any natural anoxic zone in the deeper waters of an estuary.
The natural ratios of available nitrogen to total phos-
phorus should be evaluated under each condition, and the
101
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element actually limiting plant production should be
determined. Control of the amount of the limiting
element added to the water will generally control
enrichment.
If the maximum amounts of available nitrogen and
phosphorus in domestic waste increase the concentration
in receiving waters to levels of 50 micrograms per
liter of phosphorus and 360 micrograms per liter of
nitrogen, enough organic matter would be produced to
exhaust the oxygen of the water, at the warmest time
of the year under conditions of poor circulation, to
levels below those recommended (see p. 275). These con-
centrations of nutrients are clearly excessive."*
The "Blue Book" is silent on algal blooms in waters where
nutrient levels are naturally higher than 50 ug/1 of P and 360 ug/1 of N.
The "Blue Book" directs attention to domestic waste, and says nothing
about phosphorus from industries or from phosphate deposits. What will
phosphorus removal at STFs accomplish in waters whose phosphorus is prin-
cipally derived from massive phosphate deposits and from the phosphate t
industry? Phosphorus removal at STPs will have little effect on the
phenomenal phosphate concentrations in the bay complex. Recall that
Odum never found less than 73 ug/1 of P anywhere in the complex, and
usually found well over 100 ug/1. FWPCA never found less than 254 ug/1
of P, as a seasonal average. If all the cities in the bay complex were
to be wiped off the map, these waters would still contain plenty of
phosphorus.
Phosphate concentrations in the bay complex are phenomenally
high - much too high to limit plant growth. Very little of the phosphorus
comes from STPs. Both these facts are so well known, we cannot imagine
how EPA and DPC could have decided to require phosphorus removal at STPs
in this region.
*Idem, pp. 275-278, passim.
102
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If phosphorus is not a growth-limiting element in the bay com-
plex, nothing will be changed when the STPs start to remove it. To the
best of our knowledge, no serious study of the bay complex has ever
concluded that phosphorus is a growth-limiting element in these waters.
FWFCA's report on Hillsborough Bay concluded that phosphorus was not
limiting, but nonetheless recommended phosphorus removal:
"The excessive growths of phytoplankton in the Bay are
primarily the result of the extremely high concentrations
of phosphate and higher than desirable concentrations of
total nitrogen in the Bay. The cause of these concentra-
tions is the effluents from the phosphate processing plants
on the Alafia River, the Tampa sewage treatment plant,
U. S. Phosphoric Products Company, the Nitram Chemical
Company [a large producer of nitrogen fertilizers] and
water hyacinth control practices. Because of the mas-
sively excessive phosphate concentrations, it is concluded
that the biological plant system is limited by available
nitrogen. A high percentage reduction of available nitrogen
as well as phosphorous [sic] will limit the growth of
aquatic vegetation."*
FWPCA seems to want it both ways. They argue that phosphorus
is "massively excessive" and that nitrogen (not phosphorus) is the growth-
limiting element. But they also call for "high percentage reduction" of
*
both nitrogen and phosphorus. If nitrogen is the growth-limiting element,
phosphorus removal will accomplish nothing. Phosphorus removal makes
sense only when it has been conclusively shown that phosphorus is the
growth-limiting element.
Perhaps FWPCA was led astray by the example of the Waccasassa
Estuary, which is reported as follows:
"Studies by the University of Florida on the unpolluted
waters of the Waccasassa Estuary show phosphate concen-
trations of 0.03 mg/1 [i.e. 30 ug/1]. That study [sic]
concluded that the Waccasassa Estuary is nutrient limited
*FWCA, op. cit., p. 5.
103
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in that it does not presently exhibit maximum photo-
synthesis. However, nitrogen rather than phosphorus
was concluded to be the limiting nutrient. Further, it
was concluded that the Waccasassa Estuary was a balanced
ecological system. Thus, it can be hypothesized that,
in this area, a phosphate concentration of 0.03 mg/1 is
sufficient to maintain a diversified ecology without
limiting primary productivity. Concentrations of phosphate
observed in Hillsborough Bay are approximately 100 times
higher than the level reported in the Waccasassa Estuary,"*
The Waccasassa Estuary is nearly 100 miles north of the Tampa Bay Complex,
and is isolated from the large phosphate deposits centered in Hamilton
and Polk Counties. Of course the Waccasassa contains less phosphorus than
waters affected by rich phosphate deposits and an enormous phosphate in-
dustry! Yet even the Waccasassa was limited by nitrogen, not by phosphorus.
FWPCA seems to attach some importance to the fact that Hillsborough Bay may
contain 100 times as much phosphorus as the Waccasassa Estuary. In plain
fact, however, it makes.no difference because neither body of water is
growth-limited by phosphorus.
In brief:, phosphorus removal at STPs has no justification in
scientific fact. All the available evidence shows that phosphorus is not
growth-limiting in these waters and that very little of the phosphorus
comes from STPs. Phosphorus removal at STPs is a waste of money.
4.28 The Dubious Rationale for Nitrogen Removal
The case for nitrogen removal has never been clear. The avail-
able evidence (which is scanty) suggests that nitrogen is not in short
supply either, not even during the worst algal blooms. If there is plenty
of nitrogen for further growth even during the largest algal blooms, nitro-
gen cannot be the growth-limiting element.
*Ibid., p. 24.
104
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FWPCA claimed that nitrogen was the growth-limiting element in
Hillsborough Bay, but did not support the claim or even argue it:
"Nitrogen is the growth-limiting primary nutrient in
Hillsborough Bay. Any reduction in available nitrogen
could be expected to produce corresponding reductions in
growth."*
"The excessive growths of phytoplankton in the Bay are
primarily the result of the extremely high concentrations
of phosphate and higher than desirable concentrations of
total nitrogen in the Bay.... Because of the massively
excessive phosphate concentrations, it is concluded that
the biological plant system is limited by available
nitrogen."**
FWPCA's data on the bay show that nitrogen was not the limiting
element. Two of the least polluted stations in their survey, stations
B3 and'BS, showed total N concentrations well above 500 ug/1 throughout
the year; once the total N concentration at station B3 approached 3,000
t ug/1 as a monthly average.*** Despite the evidence that nitrogen in suit-
able forms was well in excess of the 360 ug/1 recommended in the "Blue
Book", FWPCA concluded that:
"This system is limited by available nitrate, [therefore]
further reduction of available nitrate and ammonia might
be expected to further limit the growth of aquatic
vegetation."****
FWPCA has misinterpreted its own data, which show that total
nitrogen was well above 360 mg/1. Although nitrate N was generally lower
*Ibid., p. 42.
**Ibid., p. 5.
***Ibid., Figures 9.10 and 9.11. These are the only stations
FWPCA gives data for. We assume that the stations nearer Nitram and
the Tampa STP had even higher concentrations of total nitrogen, but
there is no way of knowing from FWPCA's report.
****Ibid., p. 25/26 [sic].
105
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than 100 ug/1 at stations B3 and B8 (the only stations FWPCA published
data for), total nitrogen was much higher. Aquatic plants are not limited
by nitrate, ammonia, or both. They are limited by total available nitrogen,
which is a very different thing. Fish extract is a common plant food; so
is dried beef blood. Both are relatively low in ammonia and nitrate, but
high in total available nitrogen. Soluble nitrogen in nearly any form is
an excellent plant food; the form need not be (and often is not) nitrate
or ammonia.
Perhaps FWPCA thought that only nitrate, ammonia, or phosphate
could limit algal growth; we cannot say. Although FWPCA's claim lacked
evidence, and although the claim referred only to Hillsborough Bay,
FWPCA's report undoubtedly affected local attitudes and led to the AWT
requirement for discharges into all the bays.
Hillsborough County's Environmental Protection Commission (EPC),
which collects most of the water-quality data on the Tampa Bay Complex,
also claimed that nitrogen was the growth-limiting nutrient, in Hills-
borough Bay:
"Nitrogen continued to be the limiting nutrient to the
growth of aquatic vegetation in Hillsborough Bay."*
EPC has misinterpreted its own data and has confused correlation with .
cause.
EPC ran multiple-linear-regression analyses on its data. It
concluded that in Hillsborough Bay
"....there existed significant evidence of correlation
between Nitrate and Chlorophyll A.... 48% of the
*A. J. Shaw [ed.] (1973?). 1972 Water Quality, Hillsborough
County, Florida. Tampa: EPC. First page of unpaginated summary.
106
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variation in Chlorophyll A could be attributed to
Nitrate." [Idem, p. 4-9]
This correlation does not show that nitrogen is limiting. Indeed, it
shows that nitrogen could not have been limiting. "Nitrogen-limited"
means that plants stop growing because they have used up all the nitrogen;
their growth is limited by the absence of nitrogen, and when more nitrogen
comes their way they resume growing. A positive (or direct) correlation
between chlorophyll and nitrate shows that nitrate was not in short supply;
it shows that there was plenty of nitrogen available for further growth,
especially when plants were most numerous. A negative (or inverse) cor-
relation between chlorophyll and nitrate would have suggested that nitrate
was growth-limiting; it would have shown that further growth may have been
limited by nitrate or by something that correlated strongly with nitrate.
EPC found a positive correlation, and this finding kills the argument for
nitrogen as a growth-limiting nutrient.
Nitrogen was not the only element that EPC correlated with
chlorophyll a_. In Old Tampa Bay and in Tampa Bay proper, EPC found the
following correlations:
Old Tampa Bay: "there existed significant evidence
of inverse correlation between Salinity and Chlorophyll
A.... 75% of the variation in Chlorophyll A could be
attributed to Salinity."
lower Tampa Bay: "only Phosphate indicated significant
correlation with Chlorophyll A.... 62% of the variation
in Chlorophyll A could be attributed to Phosphate."
upper Tampa Bay: "there was not sufficient evidence to
indicate that any of the parameters (Temperature, Salinity,
107
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Nitrate, or Phosphate) had any significant linear t
correlation with Chlorophyll A."*
EPC did not use these correlations to show that salinity inhibi-
ted plant growth in Old Tampa Bay, or that phosphate limited plant growth
in lower Tampa Bay. EPC focused its misunderstanding of correlation on
nitrogen in Hillsborough Bay.
Since there is no clear evidence that either phosphorus or
nitrogen limits the growth of aquatic plants in the Tampa Bay Complex,
what justification can be offered for the requirement that municipal
sewage plants must go to the expense of AWT? The Wilson-Grizzle Act
offers the only justification we can find, and this justification, so
far as we can tell, has no scientific merit.
4.29 Real Water-Quality Problems: Red Tides and Algal Rot
There are two major problems associated with algal blooms in
the Tampa Bay Complex: red tides and offensive odors from rotting salt-
water algae. Neither problem is directly related to nitrogen or phosphorus.
Both are triggered by floods and by on-shore winds.
Red tides refer to discolored patches of seawater, usually
accompanied by fishkills. Red tides in Florida are blooms of two dino-
flagellates, Gonyaulax monilata and Gymnodinium breve, which kill fish by
producing a neurotoxin. Shellfish can accumulate both the dinoflagellates
and the neurotoxin, so shellfish beds are closed during red tides.
Tourists stay away and the local economy suffers. The first outbreak of
red tides in western Florida was recorded in 1844; there have been 24
outbreaks since then, most recently in 1971.
*Ibid.
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Stench from algal rot in the bay complex was first reported in
1928; the problem has occurred intermittently since then. The rot has .
been attributed to the death en masse of saltwater algae, especially
Gracilaria spp. Gracilaria must live in saltwater. When floods flush
large quantities of freshwater into these normally saline bays, the
Gracilaria die of osmotic shock. The freshwater kills them. As the
moribund algae wash ashore, their decay gives off a powerful stench
spiced with sulfide (the smell of rotten eggs).
Both problems are real and important. In the following sections
we summarize important research on them.
4.30 Red Tides
The evidence on red tides in western Florida was summarized in
a 1973 review paper by Karen A. Steidinger (Research Biologist, Florida
Department of Natural Resources, Marine Research Laboratory, St. Peters-
burg, Florida). Here are several extracts from her review:*
"Red tides are fairly common throughout the world and
are associated with areas of upwelling or heavy land
runoff. In the Gulf of Mexico red tides refer to dis-
colored patches of seawatar usually accompanied by
fish kills. The planktonic organisms causing these natural
phenomena are dinoflagellates which produce a neurotoxin
that, when in high concentrations, is capable of paraly-
zing and killing a variety of fishes, but relatively few
invertebrates.... The effects on larval vertebrates is
[sic] relatively unknown. There are at least four toxic
species (Gonyaulax monilata, G. polyedra, G. tamarensis
*Karen A. Steidinger (March 1973). Phytoplankton, pp. IIIE-1
through IIIE-17 in James I. Jones et al. [eds.], A Summary of Knowledge
of the Eastern Gulf of Mexico 1973. Coordinated by the State University
System of Florida, Institute of Oceanography, St. Petersburg, in coopera-
tion with the Florida Coastal Coordinating Council of the Florida Depart-
ment of Natural Resources et al. This report was supported by grants
from the American Petroleum Institute through its "Subcommittee on Fish,
Wildlife, and Conservation of the Environmental Task Force [sic]."
109
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var. excavata, Gymnodinium breve) in Gulf of Mexico
waters, yet only two have been associated with mass
mortalities - Gonyaulax monilata and Gymnodinium
breve. Gonyaulax monilata is primarily an estuarine
species while Gymnodinium breve is essentially coastal
in origin. Williams and Ingle (1972) recently docu-
mented the distribution and known outbreaks of Gony-
aulax in Gulf waters such outbreaks are of short
duration and rare in the eastern Gulf of Mexico.
Contrarily, Gymnodinium breve blooms (>250,000 cells/
liter is considered lethal to fishes) cause extensive
widespread mortalities and are associated with the
appearance of toxic shellfish. Gymnodinium breve
blooms have been reported from Florida's northwest
and west coasts, Texas east coast, Campeche area of
Mexico, and Trinidad.
"The first written account of discolored water and marine
mortalities off Florida's west coast was 1844. Since
then there have been 24 outbreaks, the last being sum-
mer of 1971 in the Tampa Bay-Boca Grande area. Most
major red tides last only two to four months; however,
the outbreak of 1946-1947 continued for 11 months and
caused considerable stress to residents and the State
of Florida. Prior to 1946 little was known about such
phenomena, yet in the past 25 years researchers have
identified the causative organism, studied its basic
physiology and ecology, delimited parameters favoring
G_. breve blooms and even proposed methods of predication.
"Initial monitoring of Florida coastal waters revealed
that normally £. breve exists in concentrations of less
than 1000 cells/liter, but during times of calm weather
and seas, gentle onshore winds, high levels of trace
elements and growth factors and appropriate temperature
(16-30°C) and salinity (27-37 o/oo), £. breve popula-
tions have the potential to increase and accumulate in
inshore waters. The sudden development of G_. breve
blooms (e.g., 1-75 million cells/liter) cannot be accoun-
ted for through increased reproduction (up to 1 division/
day) [;] rather it is believed that when water and
weather conditions are optimal and can support moderate
population increases, G^ breve cells are physically con-
centrated by winds, currents, tidal action and density
gradients. Steidinger and Ingle (1972) suggested that
(5. breve exists as a resident cyst (spore) population
in coastal sediments and that initial increases are due
to excystment. This speculation is further supported by
culture studies (Wilson, 1966) and observations by J. H.
Finucane (unpublished) as well as recent data demonstra-
ting this type of life cycle to be common to certain
coastal and estuarine dinoflagellates, particularly
110
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bloom species (Wall and Dale, 1968; Prakash et al.,
1971; Wall, 1971). Steidinger and Ingle also pointed
out that minor short-lived G_. breve blooms are pro-
bably an annual event in various parts of the Gulf,
but if all conditions are not simultaneously favor-
able, the bloom will dissipate.
"At one time it was thought that phosphorus or vitamins
were the triggering factors or at least 'limiting'
factors; however research showed these factors to be
at nonlimiting levels (Steidinger and Ingle, 1972).
Further, laboratory data (Wilson, 1966) indicated that
chelated iron greatly enhanced (5. breve growth. Sub-
sequently, statistical analyses of 25 years data
revealed that if and when the iron concentration in
the Peace River reached 235,000 Ibs over a three month
period, a major red tide occurred in the coastal
waters off Charlotte Harbor (Ingle and Martin, 1971).
[CAVEAT: Total iron in the Peace River must not be
confused with chelated iron, which Steidinger suggests
as a triggering substance.] Therefore, this has pro-
vided a method of predicting Florida red tides in that
particular area. Iron, per se, has not been pinpointed
as 'the' triggering factor, yet it appears to be a
suitable index and possibly coincides with other trace
elements or chelators discharged via land runoff after
heavy rains (Martin, Doig, and Pierce, 1971).
"....The basic known ecology of red tides is outlined
and suggests that Gymnodinium breve, the causative
organism, blooms annually in selected parts of coastal
Gulf waters, but that many interrelated parameters must
be optimal for the bloom to be supported and develop
into a major red tide outbreak.
"Nutrients, particularly chelated trace metals, have
been implicated with the initiation of red tides in
Florida waters following heavy rainfall and land runoff.
Using iron as an index, researchers suggest that moni-
toring of certain river discharges can be used to predict
major red tides.
"Red tides appear to have their severest effects on local
and state economy in the form of reduced tourism and the
expense of dead fish removal. Commerical fisheries are
reportedly not affected while isolated sports fisheries,
i.e., reef fishing, are affected in a red tide area.
"Controlling Gymnodinium breve red tides after they have
developed is considered unfeasible at the present time
for reasons outlined in the text, e.g., vast area and
volume of saltwater to be treated as well as the prospect
111
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of recruitment of other G_. breve populations by
physical forces from surrounding areas. Gymnodinium
breve blooms are not a surface phenomenon and the
organism can be found throughout the euphotic zone."
In short, neither nutrients (phosphorus especially) nor waste-
waters have been implicated as causative factors in outbreaks of the
red tide in western Florida. It is known that phosphorus is not a growth-
limiting element for red-tide organisms. Red tides are caused by the
joint occurrence of several factors, which include high riverflows, onshore
winds, and warm weather. Consequently, one must conclude that the program
of wastewater management in Greater Tampa will do nothing to reduce the
prevalence or severity of red tides in the Tampa Bay Complex. In particular,
the new STP at Largo will do nothing to reduce red tides.
4.31 Algal Rot
FWPCA investigated odor complaints in Hillsborough Bay, at the
request of the City of Tampa.* FWPCA attributed the odors to massive
accumulations of rotting benthic algae (Gracilaria spp.). The death and
the rot were attributed to floods in the Hillsborough River. When flood-
waters poured into the salty bay, they killed the resident Gracilaria,
which cannot tolerate freshwater.
FWPCA insisted that wastewater does not directly cause the odor
problem; they pointed out that Gracilaria is tolerant of degraded water
quality. However, they argued that the massive populations of Gracilaria
could not exist in Hillsborough Bay were it not for the "waste effluents
and excessive nutrient concentrations." We have already analyzed FWPCA's
*0p. cit.
112
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arguments about nutrients and algal blooms in sections 4.27 and 4.28
(above). The core of their argument is this:
"Waste discharges from point sources do not produce the
odor problem directly. In fact, Gracilaria is tolerant
to degraded water quality. However, waste effluents and
excessive nutrient concentrations create the water quality
conditions whereby Gracilaria can flourish at the expense
of a number of other plant species that would produce a
healthy diversified ecosystem if water quality were im-
proved. Therefore, the contribution of. nutrients and
organic wastes to Hillsborough Bay is the ultimate cause
of the obnoxious odors along the western shore of Hills-
borough Bay." [p. 5]
We agree that nutrient enrichment supports the massive popula-
tions of Gracilaria. We can find no evidence, however, for FWPCA's claim
that a "healthy and diversified ecosystem" would replace the Gracilaria
populations if water quality were improved. This claim may be true, but
nothing in the report justifies it. Furthermore, even if Gracilaria
could be replaced by a more diversified population of aquatic flora, the
diverse population would necessarily be one that was adapted to saltwater.
Freshwater floods would presumably kill a diversified population of salt-
water flora just as effectively as they kill a homogeneous population of
Gracilaria. The offensive stench is largely due to sulfide, which is
produced when the sulfate in saltwater organisms is anaerobically decom-
posed by saprophytes. The sulfate in these organisms comes from the
saltwater itself. Marine waters are loaded with sulfate; the high sulfate
concentrations have nothing to do with wastewater management. There is
plenty of sulfate in all marine water. A diversified population of salt-
water flora would contain sulfate too, and would liberate sulfide when
they were killed by freshwater. We do not think that FWPCA's ecological
arguments are sound.
113
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FWPCA failed to show that the total biomass of saltwater flora
could be controlled by nutrient removal in wastewaters. Phosphorus
removal will certainly accomplish nothing, and there is no evidence
that nitrogen removal would make any difference either. FWPCA claimed
that Old Tampa Bay supported a more diversified population of algae than
Hillsborough Bay; unfortunately for their argument, the total biomass in
Old Tampa Bay was greater than in Hillsborough Bay:
"Based on chlorophyll determinations, Hillsborough Bay
supports a phytoplankton population about four times
greater than Tampa Bay primarily due to the excessive
concentrations of total nitrogen and phosphorus in Hills-
borough Bay. Gracilaria is the benthic algae [sic]
which proliferates along the western shore of the Bay.
In Hillsborough Bay, Gracilaria makes up 98% of the
attached algal crop while in Old Tampa Bay it accounts
for only 2%. Old Tampa Bay exhibits a diversified
population of plant species which is indicative of a
healthy ecosystem. Hillsborough Bay does not support
a diversified population of plants. Field and labora-
tory evaluations have shown that Gracilaria is tolerant
to turbid water and degraded water quality." [pp. 3-4]
"Standing crops of benthic plants were determined in both
bays [Hillsborough and Old Tampa] during June 1968.
Eleven transects perpendicular to shore, with stations
at 50-yard intervals, were selected for Petersen dredge
sampling in Hillsborough Bay. Twenty-one transects were
used in Old Tampa Bay.... Transects were at approximately
1 1/2 mile intervals along the shore and extended to the
six foot contour when possible. Three grab samples were
made at each station.
"The mean standing crop in Hillsborough Bay was 512 pounds/
acre compared to 532 in Old Tampa Bay. These values, along
with numbers of species in each bay, indicate that higher
levels of enrichment have the effect of decreasing benthic
plant diversity rather than increasing standing crop." [p. 30]
Having admitted that the relatively clean waters of Old Tampa
Bay supported a larger biomass of benthic algae than the heavily polluted
waters of Hillsborough Bay, FWPCA has destroyed its most important argument,
Yet FWPCA ignored its own evidence when it claimed that species diversity
114
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will stop the odor of algal rot in Hillsborough Bay. The diversified
population of saltwater algae in Old Tampa Bay would produce just as
much sulfide as the homogeneous population in Hillsborough Bay. Indeed,
they might produce even more, since there is a greater biomass in Old
Tampa Bay (532 pounds/acre) than in Hillsborough Bay (512 pounds/acre).
The critical difference between Hillsborough Bay and Old Tampa Bay has
nothing to do with nutrient enrichment or algal standing crop.
The critical difference is freshwater tributaries. Hillsborough
Bay has three of them: the Hillsborough River, the Alafia River, and the
Palm River (Sixmile Creek). Old Tampa Bay has no freshwater tributaries
of importance; its largest tributaries are Sweetwater Creek, Rocky Creek,
and Allen Creek. The freshwater flow into Hillsborough Bay is roughly
ten times greater than the freshwater flow into Old Tampa Bay. The
freshwater floods kill the algae that fill the air with gagging rot.
It is difficult to agree with FWPCA's contention that Old Tampa
Bay is a model of species diversity. Large quantities of sea lettuce
(Ulva lactuca L.) have been reported in Old Tampa Bay; there was a heavy
bloom in the spring of 1972.* Had there been a flood in Old Tampa Bay
during the sea-lettuce bloom, there would probably have been a serious
odor problem too, especially if onshore winds had blown the lettuce into
shallow water near shore.
We agree with FWPCA's identification of floods as the cause of
algal death. We do not agree with FWPCA's ecological arguments, which
are contradicted by their own evidence. We do not agree with FWPCA's
*Howard J. Humm (March 1973). Benthic algae of the Eastern
Gulf of Mexico, pp. IIIB-1 through IIIB-15 in James I. Jones et al., op. cit,
115
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recommendations for Improved waste treatment, because they are not sup-
ported by evidence or compelling argument:
"An overall removal of ninety percent total nitrogen and
ninety-nine percent total phosphorus presently being dis-
charged to Hillsborough Bay and its tributaries from the
Tampa sewage treatment plant, U. S. Phosphoric Products
Company, Nitram Chemical Company and phosphate processing
plants on the Alafia River should be accomplished.
"Secondary sewage treatment to remove at least ninety
percent of the carbonaceous waste material and effective
year round disinfection should be provided at the Tampa
sewage treatment plant and the MacDill Air Force Base
sewage treatment plant." [p. 6]
We are not sure what to make of FWPCA's recommendations on
flood control and sewer improvements, but they merit serious consideration:
"Fresh water discharge from the Hillsborough River should
not exceed 2000 cubic feet per second (cfs). Adequate
facilities to meet this requirement should be provided by
the Southwest Florida Management District and the U. S.
Army Corps of Engineers in the Hillsborough River phase of
the Four Rivers Basin Project.
"Storm sewers along the western shore should be extended
by the city of Tampa to the 3 1/2 foot depth (mean low
water) to reduce the effects of this localized source of
fresh water.
I
"These measures will maintain chloride concentrations along
the western shore greater than the level below which
Gracilaria are killed and odors are subsequently produced."
[p. 6]
We do not know whether the Hillsborough River offers enough dam
sites to afford comprehensive protection against flood flows into Hills-
borough Bay. If there are available dam sites, there is good reason to
think that flood control will alleviate two of the major water-quality
problems in the bay complex: red tides and algal rot. Steidinger has
argued that red tides in western Florida routinely follow floods in the
rivers of that region, and there is convincing evidence that Gracilaria
spp. are killed by floods.
116
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From the evidence we have evaluated, we conclude that dams
and flood control would do more to improve the Tampa Bay Complex than
any degree of investment in AWT or on-land disposal of STP effluent.
117
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4.32 BIBLIOGRAPHY
Peter P. BALJET (30 January 1974). Letter to Joseph [R.] Franzmathes,
Director, Water Programs Office, U. S. EPA Region IV, Atlanta.
This letter sets forth Florida's interpretation of the "5-5-3-1"
criteria and the scope of the AWT requirements in the "Wilson-
Grizzle bill" [sic]. Mr. Baljet was Executive Director of the
Florida Dept. of Pollution Control, Tallahassee.
Idem (24 April 1975). Memorandum to Deputy Executive Director et al. on
"Water - legal - rules - interpretation of the Wilson-Grizzle
Act." Unpublished. Copy obtained courtesy of Dr. George J.
Horvath, Florida DER, Tallahassee.
BLACK, CROW, & EIDSNESS, INC. (October 1970). Engineering report:
water resources investigations for the Pinellas County water
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BRILEY, WILD, & ASSOC., INC. (1969). Master plan for sanitary sewage in
Pinellas County, Florida. Prepared for the Pinellas County
Board of County Commissioners. Clearwater, Fla.: Briley, Wild,
& Assoc.
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R. N. CHERRY (July 1966). Chloride content of ground water in Pinellas
County, Florida, in 1950 and 1963. U. S. Geological Survey
Map Series No. 20. Tallahassee, Fla.: Florida Board of
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CONSERVATION CONSULTANTS INC. (17 September 1972). Tenth quarterly
report to Tampa Electric Company. Ecological surveys of the
Big Bend area. Palmetto, Fla.: Conservation Consultants.
In: TAMPA ELECTRIC COMPANY (December 1972). Application for
permit to construct Unit #3 Big Bend Station, volume II.
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ENVIRONMENTAL SCIENCE AND ENGINEERING, INC. (undated, but known to be
1976). 208 areawide waste treatment management planning pro-
gram. Two heavy volumes, unpaginated. Prepared for the Tampa
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Pollution Control. Chap. 17-3, Pollution of Waters. Supp.
No. 25. 18 pp. Source: U. S. EPA Headquarters, Washington,
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Water use classifications and water quality criteria for the
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EPA, Region IV, Atlanta, Ga.
Idem (1976). Rules of the Department of Environment [sic] Regulation.
Chap. 17-3, Pollution of Waters. Supp. No. 69, 11 pp.
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FLORIDA CHAMBER OF COMMERCE (1976). 1976 directory of Florida industries.
Tallahassee: The Chamber.
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Florida ports and waterways directory. Tallahassee, Fla.:
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on implementation of the Florida Environmental Reorganization
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duction (p. 1) states that "this is the final report on imple-
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Idem (March 1976). Tampa Bay area water quality management plan, submit-
ted in accordance with the 1972 Federal Water Pollution Control Act
Amendments (Public Law 92-500, section 303). The cover is
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Tallahassee, or St. Petersburg. Tallahassee: The Department.
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Bureau of Intergovernmental Relations, Florida Division of
State Planning, to Dr. Tim Stuart, Chief, Bureau of Water
Quality, Florida Department of Environmental Regulation. The
letter, dated 29 June 1976, certified that the planning in
this report "is in accord with state plans, projects, and
objectives." This certification is in compliance with OMB
Circular A-95 and Florida statutes.
121
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Idem (24 September 1976). A proposed rule on land application of
domestic wastewaters, second draft. Tallahassee: DER,
Division of Environmental Programs, Bureau of Drinking
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(16 August 1976). Monitoring program, fiscal year 1977.
56 pp., photocopy. Tallahassee: The Department.
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FLORIDA, LAWS OF (15 March 1972). The "Wilson-Grizzle Act", Laws of
Florida, Chap. 72-58, pp. 216-217. House Bill No. 3220,
approved by the Governor 15 March 1972. "An Act relating to
sewage disposal, amending Section 403.086(1), Florida Statutes
... by adding a new paragraph to provide that advanced waste
treatment shall be required for sanitary sewage treatment
facilities in the Tampa Bay area...."
Idem (22 May 1975). Florida Environmental Reorganization Act of 1975.
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for Committee Substitute to Senate Bill No. 123"; approved by
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relating to environmental reorganization ... creating the
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FLORIDA LEGISLATURE (1976). Senate Bill 984, "a bill to be entitled
An act relating to sewage disposal facilities; amending s.
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industrial discharges shall not be disposed of into certain
streams ... unless advanced treatment, approved by the Depart-
ment of Environmental Regulation, is provided..." Introduced
by Senator Warren S. Henderson; died in the Natural Resources
Committee.
FLORIDA POLLUTION CONTROL BOARD (17 September 1974). Resolution No.
74-83 (adopted 13 October 1974), exempting industrial waste-
water discharges from the provisions of the Wilson-Grizzle Act.
FLORIDA STATE UNIVERSITY SYSTEM, INSTITUTE OF OCEANOGRAPHY [coordinator]
(March 1973). A summary of knowledge of the eastern Gulf of
Mexico, 1973. James I. Jones et al. [eds.]. "Preparation of
this report was supported by a grant from the American Petro-
leum Institute through its Subcommittee on Fish, Wildlife,
and Conservation of the Environmental Task Force, Committee '
on Exploration." 607 pp. St. Petersburg, Fla.: The Institute.
FLORIDA STATUTES ANNOTATED (1976-77 Supplement to Book 14B). Chapter
403, Environmental Control.
123
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Joseph R. FRANZMATHES (11 February 1974). Letter to Peter P. Baljet,
Executive Director of the Florida Dept. of Pollution Control,
Tallahassee, giving EPA's Interpretation of the 5-5-3-1 criteria
for AWT and asking for clarification of the application of the
"Wilson-Grizzle Bill" [sic] to "stream tributaries." Mr. Franz-
mathes is Director of the Water Programs Office, EPA Region IV,
Atlanta. Copy obtained courtesy of Dr. G. J. Thabaraj, Florida
DER, Tallahassee.
GEO-MARINE, INC. (30 November 1973). A field study of selected ecological
properties of Upper Boca Ciega Bay, Cross Bayou Canal, and
adjacent areas. Conducted for the Board of County Commissioners,
Pinellas County, Fla. St. Petersburg, Fla.: Geo-Marine.
QUENTIN L. HAMPTON ASSOCIATES, INC. (11 July 1972). Site plan, Town of
Largo, Pinellas County, Florida, sewage treatment plant.
Daytona Beach, Fla.: Hampton Associates.
Idem (January 1973). Feasibility report: project for extension of
sanitary sewer service in Largo sewer service area. Daytona;
Beach, Fla.: Hampton Associates.
Idem (January 1974). Sewer system evaluation, Town of Largo, Florida,
period of study September 1972-August 1973. Approved by EPA
13 February 1974. Daytona Beach, Fla.: Hampton Associates.
16 pp. +4 appendices.
124
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Idem (19 April 1974). Letter to Donald D. Herman, Town Manager, Town of
Largo, entitled: Sewage treatment plant effluent disposal to
golf course irrigation systems. Mr. Hampton relates the offer
of Dullard's Bay and Airco golf courses to buy the Largo STP
effluent. Mr. Hampton designed the Largo STP.
Idem (February 1975). Contract documents for sanitary sewer system
improvements, sewage treatment plant expansion, City of Largo,
Pinellas County, Florida. Daytona Beach, Fla.: Hampton
Associates.
Henry 6. HEALY (1972). Public water supplies of selected municipalities
in Florida, 1970. Florida Bureau of Geology Information Cir-
cular No. 81, prepared by the U. S. Geological Survey. Talla-
hassee, Fla.: The Bureau.
Matthew I. KAUFMAN (August 1969). Generalized distribution and concen-
tration of orthophosphate in Florida streams. U. S. Geological
Survey Map Series No. 33. Tallahassee, Fla.: Florida Depart-
ment of Natural Resources, Bureau of Geology.
Howard T. ODDM (9 January 1953). Dissolved phosphorus in Florida waters:
a report to the Florida Geological Survey. Report of investi-
gations no. 9, "Miscellaneous studies," part I, pp. 1-42.
Tallahassee: The Survey. N. B. The title is deceptive.
Odum measured both particulate and dissolved phosphate, and
made no attempt to distinguish between them.
125
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Allen R. OVERMAN et al. [eds.] (2-3 May 1973). Proceedings of the 1973
workshop on landspreading municipal effluent and sludge in
Florida, Winter Park (Fla.). Sponsored by the Institute of
Food and Agricultural Sciences of the University of Florida
and the Cooperative Extension Service of the Agricultural
Experiment Stations. Copies available from A. R. Overman,
Agricultural Engineering Department, University of Florida,
Gainesville, Florida 32611.
PINELLAS COUNTY DEPARTMENT OF PLANNING (February 1968, reprinted Septem-
ber 1969). Natural resource study of Pinellas County, Florida.
Technical Report No. 4, Comprehensive Plan Series. Prepared
for Pinellas County Board of County Commissioners and Pinellas
County Planning Council. No publication data are offered in
the text. 50 pp.
PINELLAS COUNTY DEPARTMENT OF PLANNING, ENVIRONMENTAL STUDY TASK FORCE
(1974). Surface water quality assessment, Pinellas County,
Florida. Clearwater, Fla.: The Department.
R. W. PRIDE (1973). Estimated water use in Florida. Prepared by the
U. S. Geological Survey in cooperation with the Florida Depart-
ment of Natural Resources, Bureau of Geology. Information
Circular No. 83. Tallahassee: The Bureau.
A. J. SHAW [ed.] (1973?). 1972 Water quality, Hillsborough County,
Florida. Hillsborough County Environmental Protection Com-
mission. Tampa, Fla.: The Commission.
126
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William H. TAF.T & Dean F. MARTIN (1974). Sedimentary fluorite in Tampa
Bay, Florida. Environmental Letters 6(3):167-174.
TAMPA BAY REGIONAL PLANNING COUNCIL (October 1972). A modeling study of
water quality in Old Tampa Bay. Dr. Bernard E. Ross and Dr.
Melvin W. Anderson are named as consultants on the title page,
and are credited with "manuscript preparation" on the inside
back cover. 74 pp. St. Petersburg, Fla.: The Council.
Idem (July 1973). Water quality management plan for the Tampa Bay Basin.
St. Petersburg: The Council. N. B. On the inside front cover
and on the bibliographic data sheet, the report is dated June
1973. Report No. TBR-73-11-WQ. 424 pp. plus plates. "The
preparation of this report was financially aided through a
federal grant from the Environmental Protection Agency, Office
of Water Quality, Under Section 3(c) of the Water Pollution
Control Act (P.L. 84-660), as amended."
TAMPA BAY REGIONAL PLANNING COUNCIL & SOUTHWEST FLORIDA WATER MANAGEMENT
DISTRICT (June 1974). Comprehensive plan for areawide water
systems in the Tampa Bay Region. St. Petersburg, Fla.: The
Council. "The preparation of this report was financially aided
through a federal grant from the Department of Housing and
Urban Development under the Urban Planning Assistance Program
authorized by Section 701 of the Housing Act of 1954, as
amended."
127
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TAMPA BAY REGIONAL PLANNING COUNCIL (March 1976). The 1973 water quality
management plan for the Tampa Bay region: a success story in
planning. N.B. On the outside cover, the title is given as:
Water quality management planning in the Tampa Bay region, a
1 success story! 24 pp. St. Petersburg, Fla.: The Council.
G. J, THABARAJ (26 October 1976). Memorandum to Ralph H. Baker, Jr.,
Chief, Bureau of Drinking Water and Special Programs. Dr.
Thabaraj is Environmental Administrator, Division of Environ-
mental Programs, Florida DER. The memo describes the Largo
STP the week before it was formally dedicated (9 November 1976).
Obtained through the kindness of Dr. Thabaraj.
U.S. EPA (19 June 1974). NPDES permit to Nitram, Inc., Tampa. Permit
No. PL 0001643, Application No. FL 074 OYL 2 000239. Obtained
from the files of the Enforcement Division, U.S. EPA Region IV,
Atlanta; an identical copy is on file with the Florida DER,
Tallahassee. 10 pp.
Idem (12 August 1974). NPDES permit to Town [sic] of Largo. Permit
No. FL0026603. Effective date: 27 September 1974; expires
30 June 1979. Obtained from the files of the Enforcement
Division, U.S. EPA, Region IV, Atlanta. An identical copy is
on file with the Florida DER, Tallahassee. Amended by letter
from Donald J. Guinyard (EPA Region IV, Enforcement Division)
on 31 August 1976, as follows: "Your new date for attainment
of operational level is January 1, 1977."
128
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Idem (23 August 1974). NPDES permit to Kaiser Agricultural Chemicals
Division, Tampa Nitrogen Plant, Tampa. Permit No. FL 0000647;
Application # FL 074 OYL 2 000092. Obtained from the files
of the Enforcement Division, U.S. EPA Region IV, Atlanta; an
identical copy is on file with the Florida DER, Tallahassee.
Appended to the permit is a notification, also dated and signed
23 August 1974, which states that "the permit shall expire...
not later than July 1, 1977." The permit, on p. 1, states
that the effective date of the permit is 23 September 1974,
and that the expiration date is 23 September 1979. 11 pp.
Idem (24 September 1974). NPDES permit to Gardinier, Inc., U.S. Phosphoric
Products, Tampa. Permit No. FL0000761; Application No.
FL0740YL2000124. Effective date: 24 September 1974; expires
24 October 1979. Obtained from the files of the Enforcement
Division, U.S. EPA, Region IV, Atlanta. An identical copy is
on file with the Florida DER, Tallahassee. 14 pp.
Idem (30 December 1974). NPDES permit to City of St. Petersburg for the
SW plant. Permit No. FL0021385. Effective date: 13 February
1975; expires 30 June 1979. Obtained from the files of the
Florida DER, Tallahassee, NPDES Section. An identical copy is
on file with the Enforcement Division, U.S. EPA Region IV,
Atlanta. 13 pp.
129
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Idem (30 December 1974). NPDES permit to the City of Tampa. Permit
No. FL0020940. Effective date: 13 February 1975; expires
30 June 1979. 10 pp. Obtained from the files of the NPDES
Section of the Florida DER, Tallahassee. An identical copy
is on file with EPA Region IV, Atlanta.
Idem (31 December 1974). Grant //C120493010 to the City of Largo for
$2,000,000 to enlarge and upgrade the Largo STP. Signed by
Jack E. Ravan, Regional Administrator, Atlanta.
Idem (13 August 1976). NPDES permit to Tropicana Products, Inc.,
Bradenton, Fla. Permit No. FL0000043, Application No.
FL 074 OYL 2 000008. Effective date: 13 September 1974;
expires 13 September 1979. Obtained from the files of the
Enforcement Division, EPA Region IV, Atlanta; an identical
copy is on file with the Florida DER in Tallahassee. 11 pp.
U.S. FEDERAL WATER POLLUTION CONTROL ADMINISTRATION, TECHNICAL PROGRAMS,
SOUTHEAST REGION, HILLSBOROUGH BAY TECHNICAL ASSISTANCE PROJECT
(December 1969). Problems and management of water quality in
Hillsborough Bay, Florida. 88 pp. Tampa: The Administration.
U.S. GEOLOGICAL SURVEY, WATER RESOURCES DIVISION, FLORIDA DISTRICT
(October 1968, July 1969, July 1970, November 1971, January
1973, September 1974, October 1975). Summary statements for
water resources investigations. Annual series. Tallahassee,
Fla.: The District.
I it)
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U.S. GEOLOGICAL SURVEY (1974). Water resources data for Florida,
water year 1973. Part 2: water quality records. Washington,
D.C.: U.S. Government Printing Office.
Idem (1975). Water resources data for Florida, water year 1974. Part 2:
water quality records. Washington, D.C.: U.S. Government
Printing Office. .
Idem (1976). Water resources data for Florida, water year 1975. Vol-
ume 3: west central Florida; surface water, ground water,
quality of water. Washington, D.C.: U.S. Government Printing
Office.
.Earl S. VANATTA, Jr. et al. (September 1972). Soil survey of Pinellas
County, Florida. Prepared by the Soil Conservation Service
(U.S. Dept. of Agriculture) in cooperation with the University
of Florida Agricultural Experiment Stations. Washington, D.C.:
USGPO.
Scott D. WILSON (2 July 1973). Letter to Carl G. Ecklund, Town Manager,
Town of Largo, Florida, certifying that Largo's plan (for the
Largo STP to provide AWT treatment, most likely) "conforms to
the Tampa Bay Regional Planning Council's long-range plans,
goals, and objectives." Mr. Wilson was Assistant Director of
the council, St. Petersburg, Florida. Obtained from the files
of EPA, Atlanta.
131
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J. William YON & W.R. OGLESBY (1975). Florida mineral industry, pp.
489-506 in ALLEN MORRIS [comp] (1975). The Florida Handbook,
1975-1976, 15th edition. Tallahassee: Peninsular Publishing
Co. Mr. Yon is "Geologist, Bureau of Geology, [Florida]
Department of Natural Resources.'
Yousef A. YOUSEF et al. (July 1976). Waste load allocation for Tampa
Bay tributaries. Florida Technological University, Environ-
mental Systems Engineering Institute, prepared for the Florida
Department of Environmental Regulation. Technical Report
#ESEI-5. Orlando, Fla.: The University.
132
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5. THE WALLKILL RIVER VALLEY, NEW JERSEY
5.1 THE ISSUES IN BRIEF
The Wallkill River originates in Sussex County, in northwestern
New Jersey, and flows north through marshes and swamps to join the Hudson
in New York. The small communities along the upper Wallkill have a total
population of about 30,000. Nearly the entire area is served by septic
tanks; there are virtually no sewers or wastewater-treatment plants.
During long dry spells, most of the water in the river comes from septic
tanks. Evidently the septic tanks don't work well, because nearly every
sample taken from the river is loaded with coliform bacteria. However,
the available data (which are skimpy) show almost no other pollution
problem. In particular, the river always contains plenty of dissolved
oxygen (DO).
The preliminary ("Step 1") facilities plans have been completed.
They call for collector sewers, interceptors, pumping stations, force
mains, and a 5-mgd AWT plant. AWT is being required to prevent violations
of the DO 'standard, although there are no known DO violations. DO problems
have been predicted by mathematical models, which have been constructed
with inadequate data and many unsubstantiated assumptions. The modelers
insist that DO problems will be caused by algae, and that algae will
133
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flourish unless the AWT plant removes both nitrogen and phosphorus.
New Jersey officials argue that nitrification (an AWT process much less
costly than complete nitrogen removal) will suffice. A compromise has
been reached: The Wallkill Valley AWT Plant will provide nitrification
and phosphorus removal, but not nitrogen removal. However and this is
a serious flaw the compromise solution has never been evaluated by the
mathematical modelers.
Although the mathematical models have been central to the plan-
ning, they are deficient in the following respects:
1. The modelers assume that the principal determinants of DO
are oxygen-demanding materials in sediments and marsh runoff,
algal photosynthesis and respiration, and surface reaeration.
None of these determinants have been directly measured in the
Wallkill.
2. The modelers claim that algally induced variations in the
diurnal 00 profile will cause DO violations. However, there
have been no adequate diurnal studies of DO, and DO has never
been measured between midnight and dawn, when extremely low
values are most likely.
3. The modelers attribute an undue proportion of the diurnal
DO variation to algae. As anyone can plainly see, the shallow
Wallkill is carpeted with rooted aquatic weeds. These weeds
derive their nourishment from the mud in the riverbed, not from
the water. AWT will not check the weeds because it can have
little effect on the mud they live in. No one knows how much
134
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of the diurnal DO variation should be attributed to the weeds,
and how much to the algae. But the modelers have based all
their estimates of photosynthetic rates on the concentration
of chlorophyll in the water; this method of estimation completely
ignores the rooted aquatic weeds.
4. The model has not been adequately verified. The predicted
DO minima (especially in Hamburg Pond) are much lower than
actual DO measurements in the verification data. Yet the prin-
cipal function of the model is to predict DO minima accurately.
The field data used for verification are suspect on several
grounds: absence of nighttime measurements, failure to report
quality-control procedures in the laboratory, and unexplained
increases in BOD values among the three sets of field data.
Although the model is being used to predict nighttime DO minima
during hot weather and severe droughts, the verification data
were collected during daylight hours in September and October,
when the weather was not very hot and the Wallkill was flowing
at five to nine times its drought rate.
%
, Nitrification and phosphorus removal have no basis in the WQS
for the Wallkill. There are no WQS for phosphorus or nitrogen. As in
Largo, an AWT plant is being planned to remove substances that are not
mentioned in the State's explicit goals for environmental quality.
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5.2 CASE HISTORY
October 1967
Lee T. Purcell Associates proposes a 15-mile interceptor and a
system of collector sewers for the unsewered Wallkill River Valley in
Sussex County. He proposes a secondary STP at RM 15.8; its initial
capacity is to be 3 mgd. This study was prepared for the Sussex County
Board of Chosen Freeholders.
18 September 1972
The Sussex County Municipal Utilities Authority (SCA) directs
Purcell to suspend design work because the N.J. Department of Environmental
Protection (DEP) has decided to wait for an environmental assessment and
a mathematical model. The letter is from Louise Childs (Secretary of SCA).
January 1973
Purcell compares the capital costs of the interceptor route he
proposed (which will require one pumping station) with two routes proposed
by the Environmental Assessment Council, Inc. (EAC) which will ultimately
require either 32 or 19 pumping stations. Purcell's proposed route is much
less expensive. EAC had proposed the two routes to minimize the amount of
construction in the river.
137
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November 1973
Hydroscience publishes its mathematical model of the Wallkill
River. It concludes that the Wallkill marshes are responsible for most
of.the dissolved-oxygen (DO) loss in the river and that the STP would have
to provide extreme treatment, including nitrogen and phosphorus removal,
to prevent violations of water-quality standards (WQS) for DO. Hydroscience
recommends that some of the STP effluent should be pumped upstream from the
STP at. RM 15.8 to a second outfall at RM 10.7 and perhaps to a third at
RM 0.0. This model was not used to evaluate an STP discharge of 5 mgd at
RM 10.7. N.B. Lake Mohawk Dam, near Sparta, is RM zero.
December 1973
Purcell compares sixteen regional schemes and recommends a
7.9-mgd STP with two outfalls at RM 15.8 and 10.7. Following the Hydro-
science report, he recommends nitrification, denitrification, and phosphorus
removal.
12 December 1973
EAC publishes its environmental assessment. It concludes that
parts of the Wallkill Valley need sewering because of increasing popula-
tion and inadequate soil for septic tanks. EAC concurs with the degree
of treatment recommended by Hydroscience.
2 December 1974
New WQS become effective. The new WQS maintain the DO minima
i
for the Wallkill River: 5.0 mg/1 above the Route 23 bridge (RM 12), and
4.0 mg/1 below.
138
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7 January 1975
SCA yields to DEP's suggestion for a shorter interceptor and a
smaller STP (5 mgd) with only one outfall at RM 10.7. The letter is from
Alexis A. Lundstrom, Chairman of SCA.
13 January 1975
SCA accepts a Step 1 grant from EPA. The original grant amount
of $203,720 was increased to $206,570 on 1 April 1976. EPA grant no.
C340406-01-0.
29 January 1975
EAC estimates that more than 2/3 of the 7Q10 (the lowest river-
flow that is likely to occur for one week in a decade) of the upper
Wallkill River comes from septic-tank outflow. When the area is sewered,
the river may be dry above the STP outfall.
11 September 1975
DEP's staff objects to Hydroscience's conclusions on nitrogen
removal. Dong Whang (mathematical modeler at DEP) contends that too
little is known about the role of the marshes to justify nutrient removal;
he also notes that New Jersey does not have any WQS for nutrients in the
Wallkill River downstream of the proposed STP outfall.
22 October 1975
DEP informs SCA that it cannot justify nitrogen and phosphorus
removal. The letter is from S.T. Giallella (Acting Chief Engineer, Public
Wastewater Facilities Element).
139
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November 1975 (revised June 1976)
DEP completes its 303(e) basin plan for the Wallkill River, but
does not release it publicly. In this plan, DEF sets aside 25% of the
river's assimilative capacity as a margin of safety. The assimilative
capacity is derived from the Hydroscience model. The wasteload allocation
of BOD5 for the Wallkill STP (i.e. the STP's share of the assimilative
^
capacity) is about half of the allocation recommended by Hydroscience,
yet DEP does not require SCA to prepare new plans for better treatment.
Nor does DEP bring the allocation into line with the existing plans. DEP
sets the stage as follows: by 1980, the average flow at the STP will be
2.5 mgd, its BOD5 allocation is 210 Ib/day, its outfall will be near
4
Hamburg (RM 10.7), and it will have nitrification facilities for ammonia
removal. DEP is unclear about phosphorus removal, but plainly does not
require nitrogen removal. DEP's logic will not withstand close scrutiny.
DEP used the Hydroscience model for its BODj allocation, but did not
follow Hydroscience's assumptions about nutrient removal (Hydroscience
insisted that nitrogen removal was essential, but DEP did not require it).
In fact, DEP did not recommend nutrient removal of any kind neither
nitrogen nor phosphorus:
"Recommendations
* *
"(1) Sussex County MUA [synonymous with the Wallkill STP]:
Under the present model developed by Hydroscience, the SCMUA
will be allowed no more than 210 Ibs BOD/day, with a maximum
flow of 2.5 mgd." (page VII-12)
140
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2 December 1975
George J. Kehrberger (Hydroscience) responds to Giallella's
letter of 22 October 1975. Kehrberger insists that nitrogen and phosphorus
removal are essential. He argues that even with nutrient removal, the STP
effluent will consume nearly 100% of the assimilative capacity. The model
predicts that the DO standard will be violated if neither nutrient is re-
moved, but will not be violated if both are removed. Kehrberger did not
model the river with phosphorus removal but without nitrogen removal at
the STP. Assuming a 5-mgd STP discharging at RM 10.7, with nitrogen and
phosphorus removal, Kehrberger calculates a BODe limit of 420 Ib/day for
the STP.
14 January 1976
EPA-N.Y. concludes that phosphorus removal (without nitrogen
removal) will prevent algal blooms in the Wallkill River. In a memo from
Charles N. Durfor (Chief of the Water Branch, EPA-N.Y.), drafted by
W. De Pouli, the EPA Water Branch recommends funding facilities for
phosphorus removal but not for denitrification.
23 January 1976
DEP rejects Hydroscience's claims. In a letter to Gordon Merck
(Executive Director, SCA), DEP's Giallella tells SCA that DEP and EPA
discussed nutrient removal in December. DEP and EPA agreed that phosphorus
removal was justified but nitrogen removal was not. Hence, nitrogen-
removal facilities will not be eligible for grants.
141
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9 February 1976
SCA responds to DEP's 303(e) basin plan (see entry under Novem-
ber 1975). SCA contends that DEP has miscalculated, that the Wallkill
River can assimilate the planned SIP effluent with approximately 25%
of the assimilative capacity to spare. Using DEP's assumptions, SCA
calculates the BOD5 allocation for the STP as 405 Ib/day. SCA derived
its conclusions from a DEP table that was in turn derived from the
Hydroscience model. Note that Hydroscience's Dr. Kehrberger had written
about assimilative capacity just two months before (see entry under
2 December 1975). He said, in effect, that the river's ability to assimi-
late BODj depends on the amount of algae in the river; the algae, in turn,
depend on the quantity of nitrogen in the STP effluent. Therefore, he
argued, without nitrogen removal, the BOD5 in the effluent would exceed
the entire assimilative capacity of the river. The SCA letter is from
Alexis A. Lundstrom (Chairman).
21 July 1976
Purcell sends EPA-N.Y. a thick volume that contains all his
planning work since December 1973. It does not contain a description
or even a diagram of the STP that will be built as a result of all
the planning.
28 September 1976
DEP approves the facility plan for the Wallkill STP and endorses
the project. The approval is conveyed in a letter from Anthony R. Ricigliano
(Assistant Director, Public Wastewater Facilities Element, DEP) to Kenneth S.
Stoller (Chief, N.J. Construction Grants Branch, EPA-N.Y.).
142
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7 October 1976
EPA-N.Y. approves the plan for a 5-mgd STP with facilities for
nitrification (ammonia removal) and phosphorus removal. The approval is
conveyed in a letter from Gerald M. Hansler (Regional Administrator, EPA
Region II) to Gordon Merck (Executive Director, SCA).
7 December 1976
The Wallkill STP is priority #78 on DEP's project priority list,
submitted to EPA-N.Y. by Rocco D. Ricci (Deputy Commissioner, DEP). DEP
estimates that the STP, interceptor, force mains, and pumping stations
will cost $30,000,000.
4 March 1977
EPA-N.Y. concedes the inability of mathematical models to pre-
dict "diurinal [sic] DO variability". However, EPA insists that the
decision to require AWT at the Wallkill STP is sound. The memo is from
Charles N. Durfor (Chief, Water Branch) to Kenneth S. Stoller (Chief of
the N.J. Construction Grants Branch).
143
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5.3 BIBLIOGRAPHY
Peter F. CERENZIO (20 February 1976). Memo to Robert Raab (Acting Chief,
New Jersey & Puerto Rico Section, Environmental Impacts Branch,
U.S. Environmental Protection Agency, New York). Cerenzio
(Chief, Atlantic/Delaware Construction Grants Section, EPA,
New York) explains that the Wallkill sewage-treatment plant
will not accept septage because the extra waste might cause the
STP to exceed its wasteload allocation, and that dechlorination
at the STP will be accomplished by post aeration. Drafted by
Thomas D. Morris. Obtained from the files of the Agency, New
York.
Louise CHILDS (18 September 1972). Letter to Lee T. Purcell, Jr. v
(Lee T. Purcell Associates, Paterson, NJ). Childs (Secretary,
Sussex County Municipal Utilities Authority) directs Purcell to
suspend design work on the sewage-treatment plant. Obtained
from the files of the New Jersey Department of Environmental
Protection, Trenton.
145
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Charles N. DURFOR (14 January 1976). Memo to Kenneth S. Stoller (Chief,
New Jersey Construction Grants Branch, U.S. Environmental Pro-
tection Agency, New York). Durfor (Chief, Water Branch, EPA,
New York) recommends that EPA fund phosphorus-removal but
not nitrogen-removal facilities for the Wallkill sewage-
treatment plant. Drafted by W. De Pouli. Obtained from the
files of the Agency, New York.
Idem (4 March 1977). Memo to Stoller. Durfor concedes the inability of
mathematical models to predict "diurinal [sic] DO variability,"
yet insists that the decision to require AWT at the Wallkill STP
is sound. Obtained from the Agency, New York.
ENVIRONMENTAL ASSESSMENT COMMITTEE (8 August 1972). Preliminary environ-
mental assessment outline, Sussex County Municipal Utilities
Authority. Submitted to the U.S. Environmental Protection
Agency, Construction Grants Program. New Brunswick, NJ: The
Committee. 13 pp.
ENVIRONMENTAL ASSESSMENT COUNCIL, INC. (2 October 1972). Preliminary
environmental assessment, plant sites and interceptor lines of
the Sussex County Municipal Utilities Authority. New Brunswick,
NJ: The Council. 42 pp. + foldout map.
i
Idem (12 December 1973). Environmental assessment of a wastewater manage-
ment scheme for the Wallkill River watershed. New Brunswick,
NJ: The Council. 273 pp. + 2 appendixes. Appendix A is the .
Hydroscience (November 1973) report.
146
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Idem (22 August 1974). Addendum report to the environmental assessment of
a wastewater management scheme for the Wallkill River watershed.
New Brunswick, NJ: The Council. 49 pp. + 1 foldout map.
Idem (17 October 1974). Public comment on the proposed wastewater manage-
ment facilities of the Sussex County Municipal Utilities Authority.
New Brunswick, NJ: The Council. 87 pp.
Idem (29 January 1975). Wallkill environmental assessment statement
addendum, report B. New Brunswick, NJ: The Council. 15 pp.
Idem (3 December 1975). Environmental assessment of the proposed waste-
water facilities plan for the Borough of Hamburg, Sussex County,
New Jersey. New Brunswick, NJ: The Council. 106 pp. +
appendixes.
Idem (12 December 1975). Environmental assessment of the proposed waste-
water facilities plan for the Borough of Ogdensburg, New Jersey.
New Brunswick, NJ: The Council. 101 pp. + 6 appendixes + many
foldout maps.
Idem (14 January 1976). Environmental assessment of the proposed waste-
water facilities plan for the Borough of Franklin, Sussex County,
New Jersey. New Brunswick, NJ: The Council. 107 pp. + 6
appendixes. ' '
Idem (16 February 1976). Stage I archaeological survey, Borough of
Franklin, Sussex .County, N.J. New Brunswick, NJ: The Council.
6 pp. +70 photographs + 1 foldout map.
147
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Idem (16 February 1976). Stage I archaeological study: Borough of
Hamburg, Sussex County, N.J. New Brunswick, NJ: The Council.
7 pp. + photographs + maps.
Idem (16 February 1976). Stage I archaeological study, Borough of
Ogdensburg, Sussex County, N.J. New Brunswick, NJ: The
Council. 6 pp. +47 photographs + 1 foldout map.
Idem (24 February 1976). Environmental assessment of the proposed waste-
water facilities for the Landing - Short Hills area of Roxbury
Township, State Highway No. 10, Succasunna, N.J. New Brunswick,
NJ: The Council. 91 pp. +4 appendixes + many foldout maps.
Idem (3 March 1976). Public comment: environmental assessment of the
proposed facilities plan for the Borough of Franklin, N.J.
New Brunswick, NJ: The Council. 24 pp.
Idem (21 March 1976). Public comment: environmental assessment of the
proposed wastewater facilities plan for the Borough of
Ogdensburg, Sussex County, N.J. New Brunswick, NJ: The Council.
28 pp.
Idem (5 May 1976). Public comment: environmental assessment of the
proposed wastewater facilities plan for the Borough of Hamburg,
Sussex County, N.J. New Brunswick, NJ: The Council. 28 pp.
148
-------
Idem (5 October 1976). Addendum: stage I archaeological.survey, Hamburg,
New Jersey. New Brunswick, NJ: The Council. A A pp + appen-
dixes. Appendix B is a complete reproduction of the Council's
"Stage I archaeological-Study", dated 16 February 1976.
ENVIRONMENTAL ASSESSMENT COUNCIL; INC. & LEE T. PURCELL ASSOCIATES
(December 1975). 201 facilities plan, sanitary sewage collec-
tion system, Borough of Franklin, Sussex County, New Jersey.
New Brunswick, NJ: The Council, and Paterson and Franklin, NJ:
.Purcell Associates. A3 pp. + 17 appendixes.
Idem (December 1975). 201 facilities plan, sanitary sewage collection
system, Borough of Ogdensburg, Sussex County, New Jersey.
New Brunswick, NJ: The Council, and Paterson and Franklin, NJ:
Purcell Associates. Al pp. + 18 appendixes.
S.T. GIALLELLA (23 January 1976). Letter to Gordon Merck (Executive
Director, Sussex County Municipal Utilities Authority).
Giallella (Acting Chief Engineer, Public Wastewater Facilities
Element, New Jersey Department of Environmental Protection)
informs Merck that DEP and the U.S. Environmental Protection
Agency have discus.sed the need for nutrient removal at the
Wallkill STP,, and decided that phosphorus removal was justified
but nitrogen -removal was not. Obtained from the .files of the
Department, Trenton.
1A9
-------
Gerald M. HANSLER (7 October 1976). Letter to Gordon Merck (Executive
Director, Sussex County Municipal Utilities Authority). Hansler
(Regional Administrator, U.S. Environmental Protection Agency,
New York) approves the plan for a 5-mgd sewage-treatment plant
with nitrification and phosphorus-removal facilities. Obtained
from the files of the Agency, New York.
Dirk HOFFMAN (30 November 1973). Memo to S.T. Giallella (New Jersey
Department of Environmental Protection) entitled: Borough of
Hamburg, stream encroachment application no. 5796, channel
improvements. Hoffman writes about septage overflows in
Hamburg: "The problem is so critical that raw sewage actually
flows down the gutters in this area." Obtained from the Hamburg
file of the Department, Trenton.
HYDROSCIENCE, INC. (November 1973). Water quality analysis for the
Wallkill River, Sussex County, New Jersey. Westwood, NJ:
Hydroscience. 81 pp. + tables + figures.
George J. KEHRBERGER (9 July 1974). Letter to Alexis Lundstrom (Chairman,
Sussex County Municipal Utilities Authority). Kehrberger
(Hydroscience) writes that"the Wallkill River could assimilate
at least 4 mgd of AWT effluent at RM 15.8. Contained in the
Sussex County Municipal Utilities Authority (August 1974)
report.
150
-------
Idem (2 December 1975). Letter to Gordon Merck (Executive Director,
9
Sussex County Municipal Utilities Authority). Kehrberger
insists that nitrogen and phosphorus removal are essential.
Obtained from the files of the U.S. Environmental Protection
Agency, New York.
Alexis A. LUNDSTROM (27 September 1972). Letter to Sidney L. Willis (State
Review Coordinator, Division of.State & Regional Planning,
New Jersey Department of Community Affairs). Lundstrom
(Chairman, Sussex County Municipal Utilities Authority) writes
that the Authority has stopped design work on the proposed
sewage-treatment plant, as the State had requested. Obtained
from the files of the New Jersey Department of Environmental
Protection, Trenton.
Idem (7 January 1975). Letter to Anthony R. Ricigliano (Program Manager
Wastewater Facilities, Division of Water Resources, New Jersey
Department of Environmental Protection). The Sussex County
Municipal Utilities Authority yields to the DEP's suggestion
for a shorter interceptor and a smaller sewage-treatment plant
with only one outfall. Obtained from the files of the Depart-
ment, Trenton.
t
Idem (9 February 1976). Letter to Ernest R. Segesser (Assistant Director,
Water Resources Planning and Management .Element, Division of
Water Resources, Department of Environmental Protection). The
Sussex County Municipal Utilities Authority responds to the DEP
Wallkill River basin plan. Obtained from the files of the
Department, Trenton. '
151
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Gordon MERCK (17 September 1976). Letter to Bob Patel (Department of
Environmental Protection). Merck (Executive Director, Sussex
County Municipal Utilities Authority) estimates the cost of the
Wallkill sewage-treatment plant at $8,000,000, and the cost of
the interceptor, force mains, and pumping stations at $24,000,000.
Obtained from the files of the U.S. Environmental Protection
Agency, New York
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION, DIVISION OF FISH, GAME,
AND SHELLFISHERIES (1976). List of waters stocked by the division.
Trenton, NJ: The Division. 6 pp.
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION, DIVISION OF WATER
RESOURCES (effective 2 December 1974). Surface water quality
standards, docket no. DEP 012-74-11, N.J.A.C. 7:9-4 et seq.
Trenton, NJ: The Division. 66 pp.
Idem (November 1975, revised June 1976). Sec. 303(e) water quality manage-
ment plan (phase I), Wallkill River basin. Trenton: The Division.
Unpublished, unapproved (10 January 1977). Reviewed in draft in
Trenton. Unpaginated, 148 pp. + 6 blueprints in pocket.
LEE T. PURCELL ASSOCIATES (October 1967). Sewerage feasibility study for
Sussex County, New Jersey, report no. 1: regional sewerage
facilities for the Wallkill River drainage basin. Paterson, NJ:
Purcell Associates. 27 pp. + 18 plates.
Idem (February 1968). Sewerage feasibility study for Sussex County,
New Jersey. Prepared for the Sussex County Board of Chosen
Freeholders. Contains the October 1967 report. Paterson, NJ:
< Purcell Associates.
152
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Idem (May 1968, revised February 1969). Comprehensive water plan for
Sussex County, New Jersey. Prepared for the Sussex County
Board of Chosen Freeholders. Paterson, NJ: Purcell Associates.
60 pp. 4-4 appendixes.
Idem (March 1969). Preliminary engineering report for Proposed Wallkill
Valley regional water pollution control plant for Sussex County.
Paterson, NJ: Purcell Associates. 13 pp. + appendix.
Idem (December 1969). Preliminary engineering report for the proposed
Wallkill regional interceptor sewer for Sussex County.
Paterson, NJ: Purcell Associates. 5 pp. + appendix.
Idem (April 1970). Preliminary project report: Sussex County, New Jersey,
Vernon Valley, regional sewerage system and pollution control
facilities. Paterson, NJ: Purcell Associates. 30 pp + appendix.
Idem (June 1970). Project report: Sussex County, New Jersey. Vernon
Valley regional sewerage system and pollution control facilities.
Paterson, NJ: Purcell Associates. 33 pp. + appendix.
Idem (January 1973). Engineering analysis of the various alternative
routes of the Wallkill Valley interceptor sewer as proposed by
the Environmental Assessment Council. Prepared for the Sussex
County Municipal Utilities Authority. Paterson, NJ: Purcell
Associates. 27 pp. + plates, photographs, and overlays.
153
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Idem (December 1973). Engineering evaluation of alternatives for a water
pollution control management plan for the Wallkill River basin
in Sussex County, New Jersey. Paterson, NJ: Purcell Associ-
ates. 18 pp. + figures + the January 1973 Purcell report.
Idem (March 1974). Engineering report of the accepted revised alignment
for the Wallkill interceptor sewer. Prepared for the Sussex
County Municipal Utilities Authority. Paterson, NJ: Purcell
Associates. 5 pp.
Idem (March 1974, revised August 1974). Compiled area plans showing
accepted revised alignment, Sussex County Municipal Utilities
Authority, Wallkill Valley interceptor sewer. Paterson and
Franklin, NJ: Purcell Associates. Marked: Enclosure //I.
18 plates.
Idem (August 1974). Addendum to engineering report entitled: engineering
evaluation of alternatives for a water pollution control manage-
ment plan for the Wallkill River basin in Sussex County, New
Jersey. Paterson and Franklin, NJ:' Purcell Associates. 10 pp.
+ enclosures.
Idem (undated, 1975?). Preliminary: draft master water plan for the
Wallkill drainage basin. Paterson and Franklin, NJ: Purcell
Associates. 41 pp.
154
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Idem (February 1975). Solids handling facilities for alternate 13,
Wallkill Valley regional water pollution control facilities.
Prepared for the Sussex County Municipal Utilities Authority.
Paterson and Franklin, NJ: Purcell Associates. 19 pp.
Idem (February 1975). Update report on evaluation of potential sites for
the construction of the Wallkill Valley wastewater disposal
plant, alternative 13. Prepared for the Sussex County Municipal
Utilities Authority. Paterson and Franklin, NJ: Purcell
Associates.
Idem (September 1975). Surface water study for potable water supplies in
the Wallkill River drainage basin. Prepared for the Sussex
County Municipal Utilities Authority. Paterson and Franklin,
NJ: Purcell Associates. 107 pp. + 2 appendixes + maps in
pocket.
Idem (July 1976). Preliminary design drawings, four sewage pumping sta-
tions, Wallkill Valley sewerage system. Paterson and Franklin,
NJ: Purcell Associates. Folio of 18 blueprints (drawing no.
3621) + site map.
Idem (21 July 1976). Facilities plan data for alternate 13, Wallkill
Valley sewerage system. Paterson and Franklin, NJ: Purcell
Associates. Consists of a thick compendium of miscellaneous
reports, memoranda, and data. Submitted to Thomas Morris (U.S.
Environmental Protection Agency, New York) by Jerome Watman
(Purcell Associates). Contains all of Purcell'1 .s planning work
after December 1973.
155
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LEE T. PURCELL ASSOCIATES & ENVIRONMENTAL ASSESSMENT COUNCIL
(December 1975). Facilities plan step I, municipal wastewater
collection system, Borough of Hamburg, Sussex County. 73 pp.
+ 5 appendixes. Paterson and Franklin, NJ: Purcell Associates,
and New Brunswick, NJ: The Council.
Rocco D. RICCI (7 December 1976). Letter to Gerald M. Hansler (Regional
Administrator, U.S. Environmental Protection Agency, New York).
Ricci (Deputy Commissioner, New Jersey Department of Environ-
mental Protection) submits the Fiscal Year 1977 Priority List
to EPA. DEP ranks the Wallkill River project 78th, and esti-
mates that it will cost $30,000,000.
Anthony R. RICIGLIANO (28 September 1976). Letter to Kenneth Stoller
(Chief, New Jersey Construction Grants Branch, U.S. Environ-
mental Protection Agency, New York). Ricigliano (Assistant
Director, Public Wastewater Facilities Element, Division of
Water Resources, New Jersey Department of Environmental Pro-
tection) approves the facility plan for the Wallkill sewage-
treatment plant and endorses the project. Obtained from the
files of the Agency, New York.
SPARTA TOWNSHIP COUNCIL, SEWER STUDY COMMITTEE (20 June 1968). Second
sewer study report. Unpublished: Obtained from the files of
the New Jersey Department of Environmental Protection,
Trenton. 8 pp.
156
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SUSSEX COUNTY BOARD OF CHOSEN FREEHOLDERS et al. (September 1974).
Sussex-Warren resource conservation and development project.
Somerset, NJ: U.S. Department of Agriculture, Soil Conservation
Service. Prepared under authority of the Food and Agriculture
Act of 1962 (PL 87-703). 125 pp.
SUSSEX COUNTY MUNICIPAL UTILITIES AUTHORITY (1 December 1973). Summary
report on a proposal for a water pollution control management
plan for the Wallkill River basin in Sussex County, N.J.
Newton, NJ: The Authority. 15 pp. +4 figures.
Idem (August 1974). Addendum, summary report on proposal for a water
pollution control management plan for the Wallkill River basin
in Sussex County, N.J. Newton, NJ: The Authority. 9 pp.
Idem (1975). Public hearing, re: Walkill [sic] facilities plan, Newton,
N.J., 10 April 1975. Transcribed by Knarr-Richards, Associates,
Morristown and Newton, NJ. 49 pp. There are many obvious
errors in the transcript; the document cannot be trusted.
U.S. ARMY CORPS OF ENGINEERS, NEW YORK DISTRICT (January 1973, revised
January 1974). Interim survey report for flood control, black
dirt area, Wallkill River, N.Y. and N.J. New York City:
The Corps. 39 pp. +9 appendixes. Covers only the New York
part of the Wallkill basin.
157
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Dong S. WHANG (11 September 1975). Memo to Sam Giallella. Whang (Water
t
Quality Management Planning, Division of Water Resources,
New Jersey Department of Environmental Protection) objects to
Hydroscience1s conclusions on nitrogen removal. He contends
that too little is known about the role of the marshes to
justify nutrient removal. Obtained from the files of the
Department, Trenton.
158
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6. SPRINGFIELD, MISSOURI
6.1 THE ISSUES IN BRIEF
Springfield's sanitary sewers are leaky, its storm sewers are
grossly inadequate, its treatment plant is overloaded, and its wastes
are discharged into tiny streams that have almost no dilution capacity.
Fishkills in the nearby James River have been traced to filthy stormwater
from Springfield. The city is now completing a sophisticated AWT plant,
built in compliance with preliminary effluent guidelines issued in 1971
by the Missouri Water Pollution Board. These Statewide guidelines
severely restricted BOD and ammonia in discharges to small streams. On
the basis of these guidelines, Springfield successfully applied for a
Federal AWT grant in 1972. However, in 1974 Missouri published its final
effluent regulations; these regulations .lifted the restrictive limits on
BOD and ammonia the very limits that drove Springfield to AWT. Had
the final regulations been in effect when Springfield was preparing its
grant application, Springfield would not have requested (or been awarded)
money for AWT. A secondary plant of adequate hydraulic capacity would
have sufficed. Ironically, the new AWT plant will not treat the storm-
water that kills fish.. In short, Springfield has gotten grants to cure
temporary legal problems (preliminary effluent guidelines), but could not
get a grant to end the persistent stormwater problems that kill fish.
159
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Springfield sits on a divide. Most of the city lies south of
the divide, where several brooks merge to form Wilson Creek, a tributary
of the James River. The larger of Springfield's sewage-treatment plants
(STPs), the Southwest plant, discharges into Wilson Creek. This plant,
which provides inadequate secondary treatment using the Kraus process, is
seriously overloaded in wet weather. It is now being expanded to 30 mgd
and upgraded to AWT with facilities for pure-oxygen activated sludge,
nitrification, multimedia filtration, and ozone disinfection; flow-
equalization facilities are also under construction.
Above the STF discharge, Wilson Creek is intermittent, though
its flow is always derived from the streets and sewers of Springfield.
In wet weather it is swollen with runoff from industrial areas, urban
landwash, and overflowing sewers. Below the STP outfall its rocks are
i
blackened with sulfide, its bed is blanketed with sludge and slime, its
surface is often heaped with suds. This filthy water then flows through
rural countryside and a national park before entering the James River,
some seven miles below the STP.
Springfield has improved its STPs again and again: in 1913,
1922, 1936, and 1938-40. The present Kraus-process plant began operating
in 1959; it too has been improved several times. Upper aeration was
added in 1964, a polishing pond was built in 1968-70, then fitted with
mechanical aerators in 1973. Bypasses of raw sewage have been halted
since December 1971, but there are still large and frequent bypasses of
incompletely treated wastes, especially in wet weather. The sludge and
slime in Wilson Creek must owe something to the STP bypasses. The new
AWT plant, which has a larger hydraulic capacity, will not bypass any
160
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raw waste at all; and neither would a secondary plant of adequate hydraulic
capacity. However, the new plant cannot give AWT to the high wasteflows
that occur in wet weather.
There are no fishkills in Wilson Creek because no fish inhabit
these squalid waters, but there are massive fishkills in the James. -They
occur after dry spells, when Springfield gets heavy rain before the rest
of the area. As the flood crest rushes down Wilson Creek, it quickly
loses all its oxygen; and when this great mass of anoxic water pours into
the James, whose flow is insufficient to dilute the flushing of Wilson
Creek, fish are asphyxiated en masse. Heavy rain may also flush the com-
plex underground drainage system associated with Wilson Creek. Most of
southern Missouri is underlain with cavernous limestone, and there are
many sinkholes and resurgences near Springfield. Stagnant groundwater,
ammonia released by storms' scouring the sludge deposits, and toxic
materials from urban landwash have all been implicated in the fishkills.
Stormwater kills the fish, and all the planners in Springfield
know it. Complaints of fishkills in the James have been reported since
the 1920's, and there have been several formal investigations of fishkills
since 1954. The most recent kill was in 1976; serious kills were investi-
gated by the State and the Federal Government in 1960, 1966, and 1971.
Despite all the improvements in Springfield's STPs, the fishkills have
persisted. So far as one can tell, the slaughter will continue until the
stormwater problem has been solved. Local planners in Springfield have
devised a solution. In 1972 they bought land for a detention lagoon that
would catch the stormflows in Wilson Creek, and they proposed to treat the
stormwater at the lagoon or to convey the lagooned waters gradually to the
161
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SIP. Springfield won Missouri's approval, but has been unable to win an
EPA grant for this sensible project. Acting under the direction of
Missouri's Clean Water Commission, Springfield submitted'a preliminary
proposal for stormwater treatment to EPA Region VII; and Region VII sent
the proposal to EPA Headquarters (on 5 July 1972) for a determination of
its grant eligibility. Headquarters has never replied to Region VII, and
nothing further has been done.
The stormwater problem is poorly understood. In all the years
of monitoring and special investigations of Wilson Creek, no one has
learned why the stormwater is so quickly deoxygenated. Some scientists
suspect the sludge deposits, but no one has ever measured their five-hour
(rather than five-day) oxygen demand - an obvious measurement, and one
that might explain how millions of gallons of stormwater could lose all
their oxygen in a few hours. The mathematical model that was used to set
effluent limits for Springfield's discharge permit completely ignores both
stormwater and sludge deposits. Storms, sludge deposits, SIP operations,
and fishkills are all thought to be interrelated, but to this day no one
knows the fundamental nature or extent of the interrelation.
However, the connection between stormwater in Wilson Creek and
fishkills in the James has been an undisputed fact for many years. Para-
doxically, it has been slighted by the scientists who have investigated
Wilson Creek and disregarded by the Federal officials who award grants
for pollution control.
162
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6.2 CASE HISTORY
April 1954
A large fishkill is reported in the James River below Wilson
Creek.
May 1954
The Missouri Conservation Commission et al. investigate the
April fishkill. They report that industrial waste kills everything in
Wilson Creek above the STP and that sludge carpets the creek below the
STP. They speculate that a storm might have scoured the sludge deposits;
the sludge, with the help of raw sewage bypassed by the STP, might have
deoxygenated Wilson Creek. An anoxic Wilson Creek could have deoxygenated
the James River and asphyxiated the fish.
1959
A new, 12-mgd Southwest STP begins operating. It is a Kraus-
process activated-sludge plant designed by Consoer, Townsend & Associates
(CTA). The old STP (a trickling-filter plant) is abandoned.
18 July 1960
A large fishkill is reported in the James River below Wilson
Creek.
163
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4 August 1960
Another large fishkill is reported in the James River below
Wilson Creek.
September 1960
The Missouri Conservation Commission et al. conclude that
anoxia caused the July and August fishkills, but cannot identify the
cause of the anoxia.
1964
Springfield increases the organic capacity of the Southwest STP
by adding more aeration equipment.
1964-1965
The Missouri Geological Survey et al. investigate water quality
in the James River basin. They conclude that the Southwest STP pollutes
both Wilson Creek and the James River. They contend that Springfield's
effluent lowers the DO for more than 21 miles downstream, and that nutri-
ents in the effluent cause algal blooms 36-48 miles downstream.
15-16 July 1966
A large fishkill is reported in the James River below Wilson
Creek.
20 July 1966
The Missouri Department of Conservation (DOC) reports that the
James River did not contain toxic concentrations of pesticides or organic
chemicals during the fishkill. DOC concludes that the fish were killed
by anoxia caused by organic wastes from Springfield.
164
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July 1966
The Missouri Water Pollution Board (WPB) claims that Springfield's
street runoff caused the anoxia; the raw-sewage bypasses at the STP had
little effect.
September 1966
WPB concludes that temperature shock and perhaps anoxia caused
the fishkills, but admits that it does not know what causes the anoxia.
The suspects are:
landwash from Springfield
STP bypasses
scoured sludge from Wilson Creek
underground pools of anoxic water that are flushed into
Wilson Creek by high surface flows.
9
WPB claims that
"every major fish kill has occurred after several
weeks of no rain, with temperatures 95 to 100°F
or above, and a local thunder storm occurs in the
Wilson Creek Watershed within the Metropolitan
area of Springfield with little or no rain in the
James River Basin above Wilson Creek."
However, WPB surveyed water quality during dry weather, not during a
local thunderstorm. Consequently, the survey is irrelevant to fishkills
and the conclusions derived from the survey are suspect.
WPB opposes reservoirs for augmenting the droughtflow of Wilson
Creek. WPB fears that reservoirs might create more pollution. The
impounded water might lose DO, seep into underground channels, and be
flushed to the surface.
165
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December 1967
Springfield asks the White River Basin Coordinating Committee
for money to control stormwater. Springfield wants to dam Wilson Creek
just above the STP. A dam would trap landwash during storms, and would
also augment flow during dry weather.
1968
Harvey and Skelton (U.S. Geological Survey) publish a study of
groundwater in the Springfield area. They found that Wilson Creek loses
flow to underground channels at many places. There are two major sink-
holes below the STP outfall: (1) just below the STP outfall, and (2) at
Rader resurgence-sink, over a mile downstream. When the water table is
low, Wilson Creek loses flow to both these sinks; water emerges again at
Rader Spring, just downstream of Rader resurgence-sink. When the water
table is high, Rader resurgence-sink acts as a spring arid contributes to
the flow of Wilson Creek.
June 1968
WPB publishes specific water-quality standards (WQS) for the
James River and general WQS for Wilson Creek. Neither effluents nor
landwash may lower the DO of the James River (at its confluence with
Wilson Creek) below 4 mg/1. Effluents must not change the average cross-
sectional temperature more than 5°F or raise the temperature above 90 F.
Wilson Creek (and all waters of the State) must be free from sludgebanks,
floatables, nuisances, and harmful substances from municipalities,
industries, agriculture, and mining. Wilson Creek violates each of these
WQS.
166
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June 1969
The U.S. Federal Water Pollution Control Administration (FWPCA)
publishes a study of fishkills and water-pollution problems near Springfield.
FWPCA concludes that the James River is "mildly degraded" by Wilson Creek
except when storms suddenly flush the creek, which may then overwhelm the
river. FWPCA attributes the fishkills to slugs of deoxygenated water
slugs that also contain high concentrations of ammonia and SS and that
may suddenly change the temperature, pH, and conductivity of the James
River. The stormwater is filthy, FWPCA asserts, because it washes the
streets of Springfield and scours the sludgebeds in Wilson Creek.
FWPCA recommends flow augmentation for both Wilson Creek and the
James River. It also recommends retarding the flush of stormwater down
Wilson Creek. To reduce groundwater pollution, it suggests moving the STP
discharge (to avoid the sinkholes at the STP) and damming Rader resurgence-
sink.
FWPCA1s conclusions were tied to an extensive body of field data
on Wilson Creek and the 'James River. However, these data are irrelevant
to many of the principal conclusions. For example, there was heavy rain
on one of the twelve days FWPCA did intensive sampling in Wilson Creek
(20-31 July 1968), but FWPCA missed the leading edge of the stormcrest as
it advanced down the creek:
"a critical time period of 1 hour and 20 minutes
was permitted to elapse between samples, during
which time the leading edge of runoff passed by
and any slug of low DO water which might have
passed by was not recorded." (vol. 1, p. 54)
167
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Despite the importance of the sludgebeds, FWPCA failed to do any work on
sediment chemistry. And despite the rapid deoxygenation of Wilson Creek
during storms, FWPCA failed to measure short-term oxygen demand (which
might have explained the rapid deoxygenation). FWPCA1s measurements of
oxygen demand were limited to the 5-day BOD and the COD, even though the
stormcrest is deoxygenated in a few hours at most.
September 1969
CTA publishes "Comprehensive Report on the Expansion of Sanitary
Wastewater Facilities for the Greater Springfield area." This report
calls for enlargement of the existing Southwest STP, but does not call
for AWT facilities.
29 September 1969
Carl R. Noren (Director, DOC) challenges FWPCA's conclusions.
Speaking for the DOC, he argues that FWPCA1s data show that Wilson Creek
severely pollutes (not mildly degrades) the James River even during
dry weather. He uses FWPCA's own data to show that there are not sudden
changes in temperature, pH, and conductivity. He criticizes FWPCA for
failing to identify the source of the enormous sludge deposits in Wilson
Creek.,
DOC alleges that giving AWT to Springfield's sewage would be
better than sealing sinkholes or augmenting flow. DOC opposes augmenting
the flow of the James River for the following reasons:
it could not supply clean dilution water rapidly enough to
prevent fishkills
it might increase undesirable vegetation
it might promote undesirable fish at the expense of sport
fish.
168
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September 1970
The STP starts operating a new polishing lagoon. The lagoon
receives both raw sewage that would have been bypassed and most of the
secondary effluent.
20 June 1971
Springfield retains CTA to design improvements on the Southwest
STP.
10 July 1971
A large fishkill is reported in the James River below Wilson
Creek.
July 1971
C.M. Walter et al. (EPA) report that a slug of low-DO water
from Wilson Creek killed approximately 50,000 fish on 10 July 1971. They
claimed that the new polishing lagoon has reduced sludge deposits in
Wilson Creek and that storm runoff from Springfield's streets is the main
cause of low DO.
20 July 1971
Anthony Homyk (Districk Chief, U.S. Geological Survey) releases
data recorded during the fishkill of 10 July 1971. The flow of Wilson
Creek jumped from 20 cfs to 380 cfs in one hour. An automatic monitor
in Wilson Creek recorded that the DO suddenly plunged to zero. However,
Homyk warns that the DO data may not be accurate because the probes were
fouled with slime. The probes were fouled so badly, Homyk refused to
print most of the DO data.
169
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21 July 1971
Everett Fuchs and John Goddard (DOC) reported that low DO and
high ammonia killed approximately 70,000 fish on 10 July 1971. They
attributed the fishkill to the STP, sludge banks, and streetwash.
November 1971
WPB publishes effluent guidelines (not final standards). These
guidelines prohibited discharges into losing streams (i.e. "a stream
which distributes a major part of its flow through natural processes,
that is permeable subsoil and/or cavernous bedrock, into groundwater
aguifers"[sic]), except where moving the discharge is "impractical".
Discharges into other streams must contain less than 20 mg/1 BOD and
must not cause the ammonia concentration in the stream to exceed "0.10
of the toxic level at the prevailing pH value, or 2.0 mg/1 whichever is
least [sic]."
20 January 1972
Walter G. Shifrin (CTA) writes to Paul T. Hickman (Springfield's
Superintendent of Sanitary Services) about the changes in STP design that
have been brought about by Missouri's effluent guidelines (November 1971).
Shifrin reports that the new ammonia limit will entail nitrification
facilities, in his interpretation:
"As you know, these Guidelines state that the allowable
concentration of ammonia which may be present in the
receiving stream after mixing shall not exceed 0.10 of
the toxic level at the prevailing pH value or 2.0 mg/1,
which ever [sic] is least. Since Wilson's Creek
has no flow in the summer months, we interpret the
effluent criteria to indicate that the above referenced
concentration of ammonia may not be exceeded in the
plant effluent.
170
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"In order to meet these standards, facilities over and
beyond those proposed in our 1969 report will be re-
quired at the Southwest l^lant.... Therefore, we are
proposing that the Southwest Plant expansion include
biological treatment utilizing pure oxygen for removal
of the carbonaceous BOD, followed by nitrification of
the effluent in the existing aeration tanks.... [W]e
are [also] proposing that the effluent be disinfected by
chlorination prior to discharge to the Creek in order to
assure that the coliform levels in the James River as
required by the Water Quality Standards of the State
will be met."
Shifrin also recommends that the city should retain Union
Carbide Corporation to perform treatability studies with pure oxygen. He
further recommends that the city should begin bench-scale testing on
phosphorus removal
"even though the present Effluent Guidelines do not
require its removal. ...[W]e believe that phosphorous
[sic] removal will undoubtedly be a future requirement.
Secondly, the removal of phosphorous [sic] will have an
effect upon the other processes proposed and therefore
should be evaluated."
Shifrin did not comment on the guideline that recommends complete
removal of discharges from losing streams, even though Harvey and Skelton
(USGS) reported in 1968 that Wilson Creek is a losing stream, and FWPCA
(June 1969) recommended damming Rader resurgence-sink.
This is the first written mention of AWT by the design engineers,
and it is explicitly attributed to the effluent guidelines that were
adopted by Missouri in November 1971. Shifrin first discussed the need
for nitrification on 11 January 1972, in a meeting with Hickman.
171
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21 January 1972
Peggy J. Keilholz (WPB) reports that "Wilson Creek is an
extension of the sewage treatment process of the Southwest Plant." The
creek bottom is covered with solids at the STP; downstream it is full of
sludgeworms, Sphaerotilus, and fungi. Foam may cover the surface of the
creek at the STP and persist for more than a half mile downstream. She
found evidence of raw-sewage bypasses.
14 February 1972
James H. Williams (Missouri Geological Survey) contends that
Wilson Creek is a losing stream from Springfield to Rader Spring. He
recommends that Springfield's effluents should not be discharged above
Rader Spring.
18 February 1972
CTA submits its "Basic Design Data Report: Additions to Southwest
Wastewater Treatment Plant, City of Springfield, Missouri". This report
formalizes the AWT design.
May 1972
The Linde Division of Union Carbide Corporation publishes its
"Evaluation of Treatability Study for Springfield, Missouri", prepared
for CTA. Its principal conclusion is:
"The results of this study indicate that the Springfield,
Missouri [,] wastewater is amenable to nitrification using
either air or high purity oxygen. Nitrification at temper-
atures lower than those of this study [scil. 20-25° C] will
require a somewhat longer sludge age [scil. 10 days for
acclimation for one-stage nitrification, and 20 days of
acclimation for two-stage nitrification]. A full-scale
air system would require an even longer sludge age at D.O.
levels less than 6 mg/1." (p.7)
172
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11 May 1972
The Missouri Clean Water Commission (CWC formerly the WPB)
requires Springfield to submit plans for a stormwater-control project and
to install aerators in the lagoon. The decision was relayed by Jack K.
Smith (Executive Secretary, CWC).
31 May 1972
The CWC approves CTA's design (18 February 1972) of AWT
facilities for the Southwest STP.
20 June 1972
Walter G. Shifrin (CTA) writes to Don G. Busch (Springfield's
City Manager). He explains in detail how the ntiw effluent guidelines
have necessitated an AWT design, and how Union Carbide's treatability
study led to choosing pure oxygen (rather than air) for secondary
oxidation:
"These Guidelines ... require a higher degree of treatment
than previously was thought to be necessary. In addition
the recently adopted Federal Guidelines prohibit the by-
passing of untreated wastewater to a receiving stream.
"In addition the wastewater flows and strength design
bases of the Southwest Plant were increased from 23 mgd
with a BOD, of 300 mg/1 (57,500 Ib/day) and a suspended
solids concentration of 200 mg/1 (38,400 Ib/day) to 24
mgd with a 8005 of 400 mg/1 (80,000 Ib/day) and a sus-
pended solids of 200 mg/1 (40,000 Ib/day)
"These three items have substantially increased the con-
struction requirements at both the Southwest and the
Northwest Wastewater Treatment Plants. Whereas the
estimated project costs in 1969 to meet the requirements
at that time were $4,150,000 and $230,000 for the South-
west and Northwest Plants, respectively, these projects
are currently estimated at $16,100,000 and $1,500,000
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"At the Southwest Plant the principal requirements necessi-
tating estimated construction costs nearly $9,500,00 greater
than previously estimated are an ammonia concentration in
the receiving stream of 2.0 mg/1 or less and a fecal coliform
level not greater than 2,000/100 ml. In addition the BODs
in the plant effluent is not to exceed 20 rag/1 and by-passing
of raw wastewater is prohibited.
"The ammonia requirement may be met by biological nitrifica-
tion of the wastewater. This process is provided in a second
stage of biological treatment. Since the capacity of the
existing system appears to be compatable [sic] with the
nitrification system with the exception of the final settling
tanks, the decision to use these facilities for nitrification
and provide new secondary treatment facilities was made.
Following the treatability tests performed for the City by
Union Carbide Corporation, the use of pure oxygen in lieu of
air in the secondary process was deemed to be favorable. The
capital savings accruing to the City are estimated to be on
the order of $1,000,000. However, where the additional
aeration tanks, air supply and final settling tanks were
previously estimated to cost $1,740,000, the facilities now
required; [sic] that is, secondary settling tanks, and final
settling tanks; [,sic] have an estimated construction cost of
$5,550,000. In addition the treatability tests indicated
that when nitrifying the wasfewater, finely divided floe
particles are produced. Many of these do not settle and
therefore will be present in the effluent as both suspended
solids and BODs. Therefore, in order to meet the effluent
BODj requirements, it is proposed that mixed media polishing
filters be installed. These filters have an estimated con-
struction cost of $1,800,000 and were not included in the
previous estimates.
"The fecal coliform requirements necessitate the construction
and operation of disinfection facilities. Chlorine has
commonly been used for this purpose; however, in recent years
considerable interest in the use of ozone has been demonstrated.
Union Carbide Corporation is presently completing laboratory
studies on disinfecting treated Springfield wastewater with
ozone. Although the first cost and probably the operating
costs of ozone are greater than chlorine, it may be in the
best interest of the City to utilize ozone in order to
possibly reduce potential downstream taste and odor problems
and to achieve additional reductions in COD and BOD,-. Until
the above referenced studies are completed and the results
obtained, a final decision can not be made on this point.
The cost of chlorination facilities has been included in the
estimates and is currently estimated to be $160,000.
174
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"The 'no by-passing1 requirement may be met by the construction
of flow equalization facilities. The existing third stage pond
will be utilized along with new facilities to hold flows reach-
ing the plant greater than 36 mgd. When the inflow subsides to
a rate less than 36 mgd, the wastewater in the pond will be re-
turned to the plant for treatment. These facilities are esti-
mated to cost $450,000.
"The additional treatment plus the return of by-passed flow
will require pumping of the wastewater not previously contem-
plated. Three pumping stations are envisioned and are esti-
mated to cost $375,000.
"At this time plans have become firmer as to the needs for
additional space for administrative offices, laboratories,
maintenance facilities and employee facilities. These improve-
ments have an estimated construction value of $430,000.
"At the same time it has been determined that it would be more
advantageous to install thickeners for the waste activated
sludge than additional primary settling tanks. This decision
will require an estimated construction cost of $200,000 in
lieu of $280,000 previously estimated for settling tanks.
"Since the estimates were prepared for the additions to both
plants in 1969, there have been significant increases in
construction prices. The earlier estimates were based on a
1970 Engineering News Record Construction Cost Index in
Kansas City of 1300. As of June, 1972 this index had risen
to 1871 or a 44 per cent increase in costs."
In short, one thing led to another. The ammonia limit brought
on nitrification. Nitrification created an abundance of fine particles,
which would have violated the BOD guideline. Hence, mixed-media filtra-
tion was required to remove the fine particles created by nitrification.
Treatability studies showed that pure oxygen would be cheaper and more
effective than plain air in removing BOD. With so much pure oxygen on
hand, it seemed sensible to convert oxygen to ozone, which could then be
used for disinfection. The prohibition against bypassing led to the
design of large storage tanks (flow-equalization facilities), which will
store raw wastewater in excess of the STP's hydraulic capacity; however,
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Mr. Shifrin must have known that the STP will still have to bypass in wet
weather. Altogether, the new improvements to the STP will cost about
$10,000,000 more than CTA had previously estimated.
5 July 1972
Springfield buys 160 acres for its stormwater-control project.
It plans to build a basin in Wilson Creek that will catch the first 55
million gallons of street wash. The basin will either treat the street-
wash (by aeration or filtration), or pump it to the STP. Springfield
estimates that the facilities will cost $3,130,000.
5 July 1972
Ronald R. Ritter (EPA-Kansas City) asks EPA Headquarters whether
Springfield's proposed stormwater-control basin is eligible for a Federal
grant. Headquarters never responds.
29 December 1972
EPA offers Springfield $11,215,753 to enlarge the Southwest STP
from 12 mgd to 24 mgd and to upgrade it to AWT. Springfield accepts on
6 February 1973.
1973
Springfield installs aerators in the lagoon.
January 1973
CTA publishes its "Supplemental Report to Comprehensive Report
on the Expansion of Sanitary Wastewater Facilities for the Greater Spring-
field Area". This report formalizes the AWT design that Shifrin described
to Busch on 20 June 1972, and includes ozone facilities for effluent disin-
fection.
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February 1973
CTA publishes another supplemental report on AWT design for
Springfield. This report was revised in January 1974 under the new title
"Basic Design Data Report: Additions to Southwest Wastewater Treatment
Plant, City of Springfield, Missouri."
17 June 1973
New WQS go into effect, and they are quite different from the
1968 WQS. There are new numerical standards for the James River. The DO
standard has been raised from 4 to 5 mg/1, and for the first time there
is a standard for ammoniacal nitrogen:
"Undissociated ammonium hydroxide as nitrogen shall not
exceed 0.1 mg/1"
The DO standard continues to confuse effluent regulations with WQS; the
confusing phrase is "due to effluents". Here are the 1968 anti 1973 DO
standards in their entirety:
"The dissolved oxygen in the James River (Zone 2) shall not
be less than 4 mg/1 at any time due to effluents or surface
runoff." (1968)
"The dissolved oxygen shall not be less than 5 mg/1 at any
time due to effluents." (1973)
The curious exclusion for surface runoff was eliminated in 1973, perhaps
because Missouri recognized that rivers largely consist of surface runoff.
Perhaps Missouri will one day recognize that causation is no simple matter,
and that it is virtually impossible to prove that DO problems are solely
"due to effluents". There are always other complicating factors (photo-
synthesis, sediment demand, temperature, insolation, impoundments, chan-
nel improvements, groundwater inflow), and it is no easy job to show an
exclusive, direct connection between effluent quality and river quality.
177
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The new ammonia standard is also different from the ammonia
limit that was included in the 1971 Effluent Guidelines:
"Ammonia - (Measured as nitrogen) Concentration in the River
after mixing shall not exceed 0.10 of the toxic level at the
prevailing pH value, or 2.0 mg/1 whichever is least [sic] ."(1971)
This 1.971 effluent guideline is a backhanded sort of WQS because it
limits ammonia "in the River after mixing"; it does not limit ammonia in
effluents.
The confusion between WQS (i.e. standards of water quality) and
effluent limits (i.e. standards of wastewater quality) appears frequently
throughout the 1973 WQS. For example, on page one of the WQS the CWC
announces that it will
"require conformance with a schedule which will effect com-
pletion of secondary treatment facilities by December 31,
1975."
These connections between effluent regulations and WQS are out of place.
They belong in load allocations and basin plans, not in the WQS and the
effluent regulations, where they make both the WQS and the regulations
impossible to interpret.
13 July 1973
Jerome H. Svore (Administrator, EPA Region VII) approves the
new WQS. He encourages Missouri to persist in confusing WQS with
effluent regulations:
"Missouri is to be commended for retaining the December 31,
1975, date for compliance with the secondary treatment re-
quirement ."
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May 1974
The CWC promulgates effluent regulations, which are quite dif-
ferent from the effluent guidelines (November 1971) that drove Springfield
to AWT. Once again, the State neglects to specify whether Wilson Creek is
a losing stream. This is serious neglect because the effluent regulations
governing discharges into losing streams are f^r more stringent than those
governing other streams. These regulations prohibit discharges into losing
streams, except when moving the discharge is demonstrably "not feasible":
"Releases [from publicly owned STPs] ... shall not be per-
mitted to those waters of the State designated [as losing
streams].... However where an engineer has studied the
problem and presented data to the agency which clearly
shows that effluent removal is not feasible, and if the
agency determines that such removal is not feasible, and
that such releases are in the public interest, releases
with the following effluent limitations may be permitted.
* BOD5 equal to or less than 5 mg/1
** Suspended Solids equal to or less than 10 mg/1
*** Fecal Coliform equal to or less than 200 colonies
per 100 ml"
The definition of "losing stream" has been changed too:
"A losing stream under these regulations is a stream which
distributes 30% or more of its flow t irough natural pro-
cesses, such as through permeable subsoil and/or cavernous
bedrock, into groundwater. Effluents shall be considered
as being released to a losing stream if such loss of flow
of the stream to groundwater occurs within one (1) day's
flow time below the point of release during the seven (7)
day QIQ stream flow."
STP discharges into other streams require much less treatment:
"* BODs equal to or less than 30 mg/1
** Suspended Solids equal to or less than 30 mg/1
*** Fecal Coliform equal to or less than 200 colonies
per 100 ml"
STP discharges into all lakes and streams (including losing streams)
except the Missouri River and the Mississ .ppi
"shall provide a minimum level .if Dissolved Oxygen of 80%
of saturation or 6.0 mg/1, whichever is least [sic]."
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There are several Important peculiarities in these regulations.
First, the ammonia limit (which helped drive Springfield to AWT) has been
lifted. Second, the BOD and SS limits are worded as maxima; perhaps
through inadvertance the CWC failed to specify that these limits are to be
interpreted as monthly averages. A maximum BOD of 30 mg/1 is quite
different from a monthly average BOD of 30 mg/1. And third, one does not
know whether the CWC intends to classify Wilson Creek as a losing stream.
Harvey and Skelton (1968) found that Wilson Creek sometimes lost
more than 30% of its flow to the sinkholes near the STP, and sometimes
lost another 30% at Rader resurgence-sink. However, they took few measure-
ments, and their conclusions on the subsurface distribution of seepage
from Wilson Creek were contested by FWPCA (June 1969). But even FWPCA
recommended that Rader resurgence-sink should be sealed off. The Missouri
Geological Survey (14 February 1972) contended that Wilson Creek was a
losing stream between Springfield and Rader Spring. However, these con-
clusions were derived from one set of measurements (2 November 1971) by
Anthony Homyk (USGS). Homyk's gaging stations were (1) 2,500 ft below the
STP outfall, and (2) 3,000 ft below Rader Spring. He concluded that Wilson
Creek was a gaining stream below Rader Spring, but took no measurements
between the STP outfall and Rader resurgence-sink the segment of Wilson
Creek that Harvey and Skelton reported as a losing stream. Consequently,
the Missouri Geological Survey had no new data to support their conclusion
that Wilson Creek is losing between Springfield and Rader Spring.
With the problem of losing streams unsettled, it is unclear
whether the Southwest STP must produce a 30/30 effluent or a 5/10 effluent.
This problem will surface again in the NPDES permit (20 December 1974) and
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in the "303" Basin Plan (June 1976); and when it resurfaces in the "303"
plan, it will mark the undoing of all the AWT planning.
June 1974
CTA publishes an analysis of infiltration and inflow into
Springfield's sewer system. CTA concludes that more than half the STP
effluent is derived from infiltration and inflow. CTA reports that many
of the larger sewers are below the perennial water table and may be sub-
ject to continuous infiltration. In wet weather, the overloaded sewers
force open some manholes and raw sewage spurts out; CTA estimates that
10-20% of the sewage escapes.
CTA claim's that it would be less costly to eliminate some of
the infiltration and to increase the hydraulic capacity of the STP than
it would be to eliminate most of the infiltration. CTA recommends that
the STP should be expanded (42 mgd of peak capacity, 30 mgd average flow)
and should be provided with holding ponds for another 38 million gallons
of influent. When the holding ponds are full, any additional flow to the
STP will be routed through a settling pond (4-raillion-gallon capacity) which
will remove 20% of the BOD^, 40% of the SS, and none of the ammonia.
30 September 1974
EPA increases Springfield's grant to $19,270,950; the increase
was caused by the new plans to increase the average hydraulic capacity of
the STP to 30 mgd. Springfield accepts on 17 October 1974.
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20 December 1974
The Missouri Department of Natural Resources (DNR) issues an
NPDES permit to Springfield's Southwest STP (permit number MO-0049522).
Beginning 1 July 1977, the following effluent limitations and monitoring
requirements will apply:
Effluent
Characteristic
Flow
BOD5
SS
Fecal coliform
pH (not to be
averaged)
Ammonia nitrogen
(as N)
DO
Temperature
Final Limitations
(Daily Average)
30 mgd
10 mg/1
,2,500 Ib/day
10 mg/1
2,500 Ib/day
200 organisms/ 100 ml
6.0 - 9.0
2 mg/1
500 Ib/day
6 mg/1 or 80% of
saturation, which-
ever is less
N/A
Measurement
Frequency
once/daily
once /week
once /week
once/week
once /week
once /week
once /week
once/week
Sample
Type
2 4 -hour
composite
24-hour
composite
grab
grab
grab
grab
grab
The monitoring requirements bear little relation to the effluent
limitations. An average daily flow cannot be meaningfully monitored by
one measurement a day; a daily average requires at least two measurements
a day. The STP was designed for 42 mgd of peak hydraulic capacity; con-
sequently there will be days when the average flow will greatly exceed
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4
30 mgd, and there may be weeks or entire months when the average flow
will exceed 30 mgd. Perhaps DNR meant to limit the annual average flow
to 30 mgd, but that is not what the permit says.
Similarly, BOD and SS are limited to a daily average of 10 mg/1.
However, there will certainly be days when the average BOD and SS will
greatly exceed 10 mg/1. For example, when the settling pond is in use.
during wet weather, the average BOD in the SIP discharge is sure to exceed
10 mg/1 because the settling pond was designed to remove only 20% of the
BOD. Plainly, the permit cannot mean what it says. Perhaps DNR meant to
r
limit the annual average of BOD and SS, but the permit limits only the
daily average. The monitoring requirements (one composite sample a week)
bear no relation to the effluent limits (a daily average, which implies
at least two samples a day).
The ammonia limitation is more egregious still. "Ammonia nitro-
gen" was probably meant to include both the dissociated and undissociated
forms of ammoniacal nitrogen (i.e. both the ammonium ion and undissociated
ammonium hydroxide or ammonia). However, the permit says that only
ammonia (the undissociated form) is limited. Elsewhere (e.g. the WQS of
17 June 1973), Missouri was careful to distinguish between these two forms,
and the distinction is important. Ammonia (the undissociated or non-ionic
form) is extremely toxic to fish; but ammonium (the ionic or dissociated
form) is relatively harmless. In our analysis of this limitation, we
shall assume that DNR meant the term "ammonia nitrogen" to mean "total
ammoniacal nitrogen". Most authorities recommend that the concentration
of ammonia (the non-ionic form) should be limited to an absolute maximum of
0.02 mg/1. The NPDES permit limits the daily average concentration of
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i!
"ammonia" nitrogen to 2 mg/1, i.e. over 100 times the recommended limit.
But even the limit of 2 mg/1 of total amraoniacal nitrogen is sure to be
violated during wet weather, because the settling pond (which is used to
treat high flows during wet weather) was designed to remove no ammoniacal
nitrogen at all. Perhaps Missouri meant to limit the annual average
ammoniacal nitrogen, but that is not what the permit says. But even if
the State meant to limit the annual average to 2 mg/1, it will be disap-
pointed in its expectations. During long wet spells, the STP cannot
produce an effluent containing only 2 mg/1 of ammoniacal nitrogen, nor was
it designed for this ammoniacal limit in wet weather . By neglecting the
special facilities (which it had approved!) that were designed for high
flows in wet weather, DNR has guaranteed that the effluent limitations in
this permit cannot be met by the new AWT plant.
At this point, it may help to review the most important of the
WQS and effluent limitations that have been applied to Springfield. There
are five sets of regulations: (1) the WQS of 1968, (2) the Effluent
Guidelines of November 1971, (3) the WQS of June 1973, (4) the Effluent
Regulations of May 1974, and (5) the NPDES permit of 20 December 1974.
DO There has never been a DO standard for Wilson Creek.
The WQS of 1968 set a minimum DO of 4 mg/1 for the James
River; DO readings below this minimum must not be "due
to effluents or surface runoff."
The WQS of 1973 set a new DO standard: "not less than
5 mg/1 at any time due to effluents."
The Effluent Guidelines of 1971 made no mention of DO.
The Effluent Regulations of May 1974 required STP
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releases "to provide a minimum'level of Dissolved
Oxygen of 80% of saturation or 6.0 mg/1, whichever is
least."
The NPDES permit of December 1974 requires the AWT
effluent to maintain a daily average DO of "6.0 mg/1,
or 80% of saturation whichever is less."
BOD -- Missouri has never incorporated BOD into its WQS.
The Effluent Guidelines of 1971 limited "the maximum
concentration which may be present in the effluent
being discharged" to 20 mg/1.
The Effluent Regulations of 1974 set a limit on effluent
BOD5 "equal to or less than 30 mg/1". However, for
discharges into losing streams, the limit is "equal
to or less than 5 mg/1". Although the Missouri
Geological Survey and the U.S. Geological Survey call
Wilson Creek a losing stream, Missouri's pollution-
control agencies take little notice.
The NPDES permit of 1974 limits BODs to a "daily average"
of 10 mg/1 and 2,500 Ib/day. ,
S£ Missouri has never incorporated SS into its WQS.
The Effluent Guidelines of 1971 do not include SS.
The Effluent Regulations of 1974 set a limit on effluent
SS "equal to or less than 30 mg/1". However, for
discharges into losing streams, the limit is "equal
to or less than 10 mg/1".
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The NPDES permit of 1974 limits SS to a daily average of
10 mg/1 and 2,500 Ib/day.
Fecal Coliform Bacteria There have never been WQS for
bacteria in Wilson Creek.
The WQS of 1968 established a standard for coliform
bacteria in the James River: "The fecal coliform ...
shall not exceed 2,000/100 ml. (either MPN or MF
count) except in specified mixing zones adjacent to
or downstream from waste outfalls. The above criteria
shall not be applicable when the stream is affected by
storm water runoff." The mixing zone for the confluence
of Wilson Creek and the James River has never been
specified. Furthermore, the State has never clarified
the meaning of "affected by storm water runoff". How
long does it last? Does rain on Tuesday void the stan-
dard until Wednesday? Thursday? Friday? How far does
it extend? Does rain in Springfield void the standard
for 10 miles? 20 miles? 50 miles? Does a steady
drizzle for two days count as a storm?
The WQS of 1973 retain the language of 1968. Mixing
zones will be "determined on a case-by-case basis";
there are no specifics on the confluence of Wilson
Creek and the James River.
The Effluent Guidelines of 1971 did not include bacteria.
186
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The Effluent Regulations of 1974 set a limit on fecal
coliforms "equal to or less than 200 colonies per
100 ml". This limitation is apparently an absolute
maximum.
The NPDES permit of 1974 limited fecal coliform organisms
to a "daily average" of 200 per 100 ml. Note that
a "daily average" of 200 is not identical to an
absolute maximum of 200.
Ammoniacal Nitrogen There have never been WQS for
ammoniacal nitrogen in Wilson Creek.
The WQS of 1968 did not include ammoniacal nitrogen.
The Effluent Guidelines of 1971 set a standard for the
concentration of ammonia (measured as nitrogen) for
all discharges: "Concentration in the River after
mixing shall not exceed 0.10 of the toxic level at
the prevailing pH value, or 2.0 mg/1 whichever is
least." Note that the State has not answered the
obvious question toxic to what? Ammonia is toxic
to fish, but there are no fish in Wilson Creek.
Ammonia is not toxic to algae, and there are plenty
of algae in Wilson Creek. Also note that this
"effluent guideline" does not limit ammonia in
effluents: Rather, it limits the concentration of
ammonia in waterways after the effluent has been
mixed with the receiving water. Furthermore, this
guideline does not define mixing zones.
187
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The WQS of 1973 set a limit for "undissociated ammonium
hydroxide as nitrogen" in the James River; the
concentration shall not exceed 0.1 mg/1.
The Effluent Regulations of 1974 made no mention of
ammoniacal nitrogen.
The NPDES permit of 1974 limits "Ammonia-Nitrogen (as N)"
to a daily average of 2 mg/1.
This is quite a list, and it is by no means all-inclusive. It
is shot through with inconsistencies and changes, many of them apparently
unintentional (e.g. the confusion between daily averages and absolute
maxima). The temporary Effluent Guidelines of 1971 drove Springfield to
AWT by setting very demanding limits on BOD and ammoniacal nitrogen. The
Effluent Regulations of 1974 relaxed these demanding limits, but added new
limits on fecal coliform bacteria and effluent DO.
The NPDES permit requires far more of the AWT plant than the
Effluent Regulations do. However, the AWT plant was not designed to
comply with the NPDES permit, and this obvious fact seems to have escaped
everyone's notice.
Specific WQS for DO, ammoniacal nitrogen, and fecal coliform
bacteria have never been promulgated for Wilson Creek. There are specific
WQS for the James River, and they are violated. The most severe violations
are caused by stormwater from Springfield, but stormwater is noc mentioned
in the Effluent Regulations or in Springfield's NPDES permit.
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State and Federal hydrologists have classified Wilson Creek as
a losing stream since 1968. From 1968 to 1974, Missouri's pollution-
control authorities set very strict limitations on effluents discharged
into losing streams. However, State and Federal officials approved plans
for an AWT discharge into Wilson Creek, and this discharge does not meet
the strict limits for losing streams.
Whatever else this might be an example of, it is not an example
of tidy planning.
January 1975
CTA and Hydroscience publish a mathematical model of Wilson
Creek and the James River in their "Waste Load Allocation Study". They
recommend seasonal effluent limits for ammoniacal nitrogen (1 mg/1 from
May to October, 2 mg/1 from November to April). They mention phosphorus
removal but stop short of recommending it. They do not even mention SS.
Their recommended effluent limits for ammoniacal nitrogen
which are stricter than those in the NPDES permit are not justified by
the model, which predicts than an effluent containing 2.3 mg/1 of ammonia
would not cause violations of WQS.
The model is far removed from reality. It was calibrated with
data collected by FWPCA in 1968, when Wilson Creek was carpeted with
sludge. Yet the model ignores sludge deposits. It was designed to predict
mean DO, but the WQS require minimum DO levels. CTA and Hydroscience
calibrated the model for dry weather, but the worst water quality, the
most severe pollution, and the fishkills occur in wet weather. Conse-
quently, the model is irrelevant to meaningful pollution-control planning.
189
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The model does not comply with section 303(d) of P.L. 92-500,
which requires the calculation of maximum dally loads (i.e. assimilative
capacity). Rather than calculating the assimilative capacity of the
James River, the model only assessed the effects of the proposed AWT
effluent.
In short, the model is both procedurally inadequate and scien-
tifically invalid.
10 January 1975
William Q. Kehr (a consultant to CWC) reviews the model. He
concludes that it "is well written and clearly explains technical water
quality considerations".
6 March 1975
EPA increases Springfield's grant to $31,101,750, owing to high
bids for constructing the AWT plant. Springfield accepts on 21 March.
11 April 1975
The CWC's "Effluent Regulation As Amended" goes into effect.
This new "Effluent Regulation" is virtually identical to the "Effluent
Regulations" of May 1974. The definition of losing stream remains
unchanged, and so do the BOD and SS limits for discharges into losing
streams. It is still not clear whether the CWC considers Wilson Creek a
losing stream.
17 October 1975
Ed Lightfoot (DNR) misunderstands the memo by James Hadley
Williams (14 February 1972) about the losing reach in Wilson Creek.
L90
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Referring to Williams' memo, Lightfoot writes that Wilson Creek loses
flow for about 100 feet below one of the STP. outfalls. He suggests that
the STP should move its outfall 100 feet downstream i.e. below what he
takes to be the losing reach. However, Williams wrote that Wilson Creek
loses flow from Springfield to Rader Spring, which is about 1.5 miles
(not 100 feet) below the STP outfall. There are indeed sinkholes near
the STP, and Lightfoot recognized the folly of an STP outfall situated so
as to pour into a sinkhole. However, Lightfoot overlooked Rader resurgence-
sink (nearly opposite Rader Spring), which it; one of the principal losing
points in Wilson Creek.
23 October 1975
James P. Odendahl (Staff Director at CWC) tells Springfield that
a discharge to the losing reach of Wilson Creek is "unacceptable". Like
Lightfoot, he too overlooks Rader resurgence-sink.
"We take this opportunity to remind you that Wilson
Creek loses flow to the groundwater for approximately
100 feet downstream of this secondary plant outfall.
Effluent discharge within this reach of stream is
unacceptable.
"It is recommended that the City construct a temporary
outfall extension to carry the secondary plant effluent
to a point approximately 100 feet downstream where
Wilson Creek becomes a gaining stream. It is further
recommended, [sic] that until such time as the tempo-
rary outfall extension is completed, discharges from
the secondary outfall cease."
Odendahl recommends a "temporary outfall extension" because the new AWT
plant will discharge below the sinkholes near the STP; however, the AWT
outfall will be more than a mile above Rader resurgence-sink.
191
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10 December 1975
James L. Wilson (Director, DNR) tells Springfield that DNR erred
on Springfield's NPDES permit. The interim limits should set the BOD at
50 mg/1 and the SS at 70 mg/1, not vice versa.
16 December 1975
John T. Rhett (Deputy Assistant Administrator, EPA Headquarters)
issues Program Guidance Memorandum - 61, which describes EPA's policy on
grants for stormwatar control. EPA will not-give grants to control pol-
luted stormvater from storm sewers "except under unusual conditions".
Springfield apparently meets these unusual conditions, but Headquarters
still fails to take action on Springfield's proposal of 5 July 1972, which
set forth a plan for controlling the polluted stormwater that causes fish-
kills.
1976
In response to CWC's letter (23 October 1975), Springfield builds
a temporary 100-ft outfall extension.
February 1976
Approximately 5,000 fish die in the James River below Wilson
Creek.
4 March 1976
Charles H. Criswell (Sanitary Engineer, City of Springfield)
attributes the fishkill to a slug of anoxic water from Wilson Creek.
Criswell thinks that the fishkill occurred on 21 February, but was not
reported until 2 March. A continuous monitor on Wilson Creek (which USGS
192
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had calibrated two days before) recorded zero DO for 20-30 minutes on
21 February.
5 March 1976
EPA Region VII publishes an investigation of the Southwest STP
that was conducted on 23 September and 4-10 November 1975. EPA concluded
that "the facility was within the effluent discharge limitations set by
the NPDES permit", but EPA quoted the wrong limits (see 10 December 1975).
EPA's investigators made the mistake of using the interim BOD limits given
in the NPDES permit; they neglected the correction to the permit (10
December 1975), which rectified the confusion between BOD and SS limits.
EPA reports that the mean (6 samples) BODg on 4 November 1975 was 54.5
mg/1; however, the corrected permit requires the daily average 8005 to be
50 mg/1. Consequently, the STP was in fact violating its BOD limit,
according to EPA's own measurements.
19 March 1976
Richard M. Duchrow (DOC) concludes that STP effluent caused the
low DO that killed about 5,000 fish in February. He thinks that the kill
occurred during 27-29 February.
June 1976
DNR publishes its 303(e) basin plan. DNR concludes that the
AWT plant will be overloaded immediately because it must bypass incom-
pletely treated sewage in wet weather:
193
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"The total project cost (of the new AWT plant] is estimated
as $41,600,000. In spite of such enormous expenditures,
the plant is considered overloaded even in the planning
stage. In the seven day period starting from February 22,
1975 the plant records show a total flow through the plant
of 402 million gallons and even if the plant were operated
at 42 mgd for the seven day period and storing another 40
million gallons in the equalization basin, approximately 68
million gallons will have to be bypassed. Similarly for an
eleven day period starting from November 3, 1974 the flow
totalled about 600 million gallons which would have resulted
in the bypassing of 98 million gallons or approximately 9 mgd.
In addition operating the plant at the maximum capacity for
such extended periods of time would further reduce the effi-
ciency of treatment. Therefore, the key to the success of
protecting James River is to reduce the infiltration/inflow
and the evaluation that is underway should be comprehensive
enough to estimate the actual treatment needs accurately.
(p. 45)
"The collection system sufferes[sic] from enormous infiltra-
tion/inflow problem [sic] and the wet weather flow as high
as 80 mgd which is ten times as much as dry weather flow,
have [sic] been recorded. It should be noted that the re-
corded data are not actually the Indication of total extraneous
flow as the sewer capacity is limited to approximately 80 mgd
and any flow in excess, estimated as approximately 10 to 20
mgd surcharges from the manholes during heavy rain. An
infiltration/inflow analysis report was submitted in June 1974
based on the data collected in 1973. According to this report
the average daily flow during the longest dry period in the
summer of 1973 was about 14 mgd of which the domestic and
industrial sources contributed 9 mgd and the remaining 5 mgd
by extraneous flow. Most of the dry weather extraneous flow
is caused by infiltration into sewers located along drainage-
ways as the water table is near the ground level in these
areas most of the time. The direct inflow during thunder-
storms produces only temporary flow increases and it is
estimated that about six million gallons enter the system
for every inch of rainfall. However, direct inflow during
thunderstorms is less significant than infiltration and
indirect inflow caused by large and repeated rainfalls. For
statistical comparison the flow through the plant during a
five day period following a general1 rainstorm of the type that
occurred on March 30 & 31, 1973 was as follows: base flow -
45 million gallons, direct inflow - 7 million gallons and
infiltration and indirect inflow - 190 million gallons. However,
as far as evaluation study is concerned, the city has initiated
a year long monitoring program of the collection system and the
study is expected to be completed by April 1976. Based upon this
evaluation, [a] sewer rehabilitation program will be undertaken
by the city. However, the city will have to seek state and
federal grants for the rehabilitation program." (p. 44)
194
-------
DNR predicts that fishkills will be worse after the AWT plant
begins operating because there will be more fish to kill:
"It should be recognized that the new Southwest plant solves
only part of the pollution problem. It reduces the pollution
from the sewage plant considerably, whereby the aquatic life
including fish populations would undoubtedly increase con-
siderably in James River below Wilson Creek. However, by
unfortunate coincidence, if the urban runoff were to instigate
a fish kill, the visible impact of such an incident by way of
the number of fish killed, [sic] would be considerably more
than in the past." (p. 49)
The inadequate hydraulic design of the new AWT plant and the
severity of fishkills are interrelated; the problems will intensify with
time:
"Two problems, however, are associated with heavy rain in the
Wilson Creek drainage. In the first place the potential for
its devastating impact which resulted in many fish kills in
the past is statistically as probable in the future as it was
in the past ten years. As a result, [sic] of the improvements
to the sewage plant effluent, the James River below Wilson
Creek is likely to accommodate a much larger fish population
than at present. Therefore a fish kill in the future is
likely to be more devastating than in the past. Secondly,
the excess infiltration/inflow in the sewer system renders
the plant hydraulically overloaded for a long period of time
as a result of which the effluent is not likely to meet the
designed effluent quality during wet weather flow along with
inevitable bypasses [sic] . In fact, it is estimated that
even if the new plant was to be in operation in 1975 [sic]
the excess flow would have necessitated the bypassing of the
entire plant of at least 10 mgd for a six-day period and
operating the plant at the maximum load of 42 mgd during
those six days. If that was the situation in 1975 it can be
expected to be more severe in 1978. Its impact, however, on
the receiving stream would be one of retarding the recovery,
although quantitatively it is anybody's guess." (p. 11)
195
-------
DNR also expects that phosphorus from Springfield will cause
algal blooms in the James River:
"Although considerable improvements are anticipated in associa-
tion with the reduced BOD and ammonia load from the sewage
plant, as far as phosphorus is concerned the existing level of
discharge is likely to continue for a [sic] forseeable future
as the new plant does not have phosphorus removal. It is
estimated that the sewage plant would continue to discharge
approximately 250 tons of phosphorus as P per year to Wilson
Creek [,] thence to James River and to the James River arm of
Table Rock Lake. As discussed earlier there are indications
of excess algal productivity at present in James River below
Wilson Creek and with the improved effluent quality the tur-
bidity is expected to be very low. As a result the James River
is expected to be clearer in the future and with high phosphorus
it is unlikely that algal productivity would not become a
problem." (p. 11)
DNR recommends that a "208" study of the Springfield area shoulc
"quantitatively evaluate the contribution of phosphorus from
various sources and analyze the benefits of phosphorus removal
for the southwest plant from stream water quality point of
view." (p. 48)
The report contains a very serious internal discrepancy. Wilson
Creek is identified as a "known losing stream" (p. 255) from its headwaters
to the Christian County Line (about five miles below the STP). The Effluent
Regulations of May 1974 and 11 April 1975 disfavor discharges into losing
streams; in such discharges, the BOD5 must be "equal to or less than 5 mg/1".
The NPDES permit (20 December 1974) allows Springfield's discharge to con-
tain a daily average of 10 mg/1; a daily average of 10 mg/1 is much higher
than an absolute maximum or 5 mg/1. Here is the discrepancy. On page nine,
DNR calls Wilson Creek "an unclassified stream":
"As far as Wilson Creek is concerned it is an unclassified
stream and only the general criteria of the standards [scil.
the WQS] ... are applicable."
196
-------
Throughout the report, DNR refers to the karst topography of the
Springfield area and to the importance of the underground drainage system
(e.g. pp. 10 and 49). Yet DNR does not seem to notice that the AWT dis-
charge (a daily average BOD,- discharge of 10 mg/1) violates the effluent
standard for discharges into losing streams.
In short, DNR has not noticed that the new AWT discharge will
violate Missouri's effluent regulations both in wet weather and in dry
weather. DNR has recognized that the new AWT plant has inadequate hydrau-
lic design, but has not yet recognized that the AWT discharge will always
violate the effluent regulations, owing to inadequate BOD removal.
197
-------
"Most people in distress know the cure for what ails
them. And the world around them, it too knows the
cure. And yet, from all this knowledge, nothing
comes forth for their relief." Henry de Montherlant
(1933/34), Les Cglibataires [trans, by J.H.]
198
-------
6.3 BIBLIOGRAPHY
ANON. (20 September 1966). Untitled, 3-page memorandum on a meeting of
State, Federal, and local officials to discuss the causes of
fishkills in the James River and to plan research on them.
Obtained from the file marked "James River fish kill", Spring-
field Division of Sanitary Services.
ANON. (26 March 1975). A brief history of Springfield's wastewater treat-
ment facilities. Distributed at the groundbreaking ceremonies
for additions to the Southwest STP. 4 pp. Obtained from
Springfield's Division of Sanitary Services.
Bruce R. BARRETT & Ralph E. AUSTIN (19 July 1971). James River fish kill
investigation, Springfield MO. This 5-page report was prepared
for Carl Walter, EPA Region VII, Kansas City. Barrett & Austin
are with EPA's Robert S. Kerr Water Research Center in Ada OK.
Obtained from the file marked "James River fish kill, July 1971",
Springfield Division of Sanitary Services.
199
-------
James A. BURRIS (6 June 1974). Report on investigation of the southwest
sewage treatment plant, Springfield MO. Jefferson City:
Missouri Clean Water Commission. 4 pp. The report describes
gross deficiencies in the plant effluent, hydraulic overloading
in wet weather, and pollution in Wilson Creek. Obtained from
the "1.200 File" on Springfield, Missouri Div. of Environmental
Quality, Jefferson City.
CONSOER, TOWNSEND & ASSOCIATES (November 1967). Report to the City of
Springfield MO on condition and operation of the sanitary
sewerage system. Chicago: Consoer, Townsend. 18 pp.
Idem (September 1969). Comprehensive report on the expansion of sanitary
wastewater facilities for the greater Springfield area. Chicago:
Consoer, Townsend. 96 pp.
Idem (1972). Basic design data report: additions to southwest wastewater
treatment plant, City of Springfield MO. Chicago: Consoer,
Townsend. 36 pp.
Idem (January 1973). Supplemental report to comprehensive report on the
expansion of sanitary wastewatar facilities for the greater
Springfield area, Springfield HO. St Louis MO: Consoer,
Townsend 20 pp.
Idem (February 1973). Supplemental report to comprehensive report on the
expansion of sanitary wastewater facilities for the greater
Springfield area, Springfield MO. Sc. Louis MO: Consoer,
Townsend. 25 pp.
200
-------
Idem (1973, revised January 1974). Basic design data report: additions
to southwest wastewater treatment plant, City of Springfield MO.
Chicago and St. Louis: Consoer, Townsend. 43 pp. plus 1 app.
Idem (1974). Final plans: wastewater treatment plant additions, southwest
plant, City of Springfield MO. Chicago and St. Louis: Consoer,
Townsend. Over 100 figures.
Idem (June 1974). Infiltration/inflow analysis, southwest wastewater
collection and treatment system, City of Springfield MO.
Chicago and St. Louis: Consoer, Townsend. 33 pp. plus 6 apps.
CONSOER, TOWNSEND & ASSOCIATES & HYDROSCIENCE, INC. (January 1975). Waste
load allocation study: James River - Wilson Creek [and] Little
Sac River - South Dry Sac Creek. Prepared for the Missouri
Department of Natural Resources, Clean Water Commission.
St. Louis MO and Westwood NJ: Consoer, Townsend & Assoc. &
Hydroscience. 86 pp. plus 48 tables & figures plus 4 apps.
Charles H. CRISWELL (11 September 1973). Letter to Wayne E. Sanders,
Missouri Clean Water Commission, listing 15 discharges in the
Springfield area that were not on Sanders' list of NPDES
applicants. Criswell is Associate Sanitary Engineer, Spring-
field Division of Sanitary Services. Obtained from the "1.000
File" on Springfield, Missouri Div. of Environmental Quality,
Jefferson City.
201
-------
Idem (4 March 1976). Memorandum to Robert R. Schaefer, Springfield's
Superintendent of Sanitary Services. He describes efforts to
trace the cause of a fishkill in the James River in late Feb-
ruary or early March 1976. Criswell is Associate Sanitary
Engineer, Springfield Division of Sanitary Services. Obtained
from the file marked "James River fish kills various",
Springfield Division of Sanitary Services.
Charles S. DECKER (21 May 1973). Letter to Don G. Busch, City Manager,
Springfield. The letter describes the poor condition of the
polishing lagoon at the Southwest STP and makes four recommen-
dations for improving it. Decker is Acting Regional Engineer,
Springfield Regional Office, Missouri Clean Water Commission.
1 p. Obtained from the "1.000 File" on Springfield, Missouri
Div. of Environmental Quality, Jefferson City.
Richard M. DUCHROW (19 March 1976). Memorandum to James R. Whitley on a
fishkill in the James River in early March. The cause is un-
certain. Both Duchrow and Whitley are staff members of the
Missouri Dept. of Conservation. Obtained from the file on
"FY 76 Municipal Spills", Missouri Div. of Environmental
Quality, Jefferson City.
Everett FUCHS & John GODDARD (21 July 1971). Memorandum to James R.
Whitley on "Fish kill investigation - James River". Fuchs &
Goddard are with the Missouri Dept. of Conservation. 8 pp.
Obtained from the file marked "James River fish kill July 1971",
Springfield Division of Sanitary Services.
202
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E,J. HARVEY (30 June 1967). Letter to Paul Hickman (Springfield Sanitary
Services Dept.)> on the reversible flow in Rader resurgence-
spring and its possible connection to sinkholes near the South-
west STP. 2 pp. plus 2 diagrams. Harvey is Assistant District
Chief, USGS, Rolla MO. Obtained from the file marked "James
River & Wilson Creek pollution and sink hole study", Springfield
Division of Sanitary Services.
Idem (5 October 1967). Memorandum to C.J. Robinove, Office of Remote
Sensing Water Resources, USGS, Washington DC, on remote sensing
in Springfield MO area. Harvey is Assistant District Chief,
Missouri Water Resources Division, USGS. The memorandum dis-
cusses the relation between sewage, grpundwater, and Wilson
Creek. The enclosures describe gaging studies and dye studies
of the groundwater. Obtained from file marked "James River &
Wilson Creek pollution & sink hole study", Springfield Division
of Sanitary Services.
«
E.J. HARVEY & John SKELTON (1968). Hydrologlc study of a waste-disposal
problem in a karst area at Springfield MO. U.S. Geological
Survey Professional Paper 600-C, pp. C217-C220.
Anthony HOHYK (20 July 1971). Letter to Paul T. Hickman (Chief, Sanitary
Services, Springfield), giving data from the USGS automatic
monitor on Wilson Creek during 8-12 July 1971. 2 pp. Homyk is
District Chief, USGS, Water Resources Division, Rolla MO.
Obtained from the file marked "James River fish kill 1971",
Springfield Division of Sanitary Services.
203
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W.W. JOHNSON & L.E. MEADOR (28 November 1967). Request of City of
Springfield MO, for pollution alleviation of Wilson's [sic]
Creek by flow augmentation through Wilson's [sic] Creek Battle-
field National Park. This request is addressed in the form of
a letter, bound as a report (bearing the cover date December
1967), to Col. Frank P. Bane, Chairman, White River Basin
Coordinating Committee. Johnson & Meador are co-chairmen of the
Mayor's Water Resources Committee. 13 pp. Obtained from Robert
R. Schaefer, Springfield's Superintendent of Sanitary Services.
William Q. KEHR (10 January 1975). Letter to Consoer, Townsend & Associates
containing a review of the draft waste load allocation study for
James River-Wilson Creek and Little Sac and South Dry Sac Rivers.
Kehr is Engineering Consultant to the Water Quality Program of
the Missouri Clean Water Commission. 2 pp. Obtained from the
"1.000 File" on Springfield, Missouri Div. of Environmental
Quality, Jefferson City.
Peggy J. KEILHOLZ (21 January 1972). Report of investigation, Springfield
MO. 4 pp. Keilholz is Water Pollution Control Technician,
Missouri Water Pollution Board. Obtained from the file marked
"SW plant additions", Springfield Division of Sanitary Services.
Ed L1GHTFOOT (17 October 1975). Memorandum to Chas. Stiefermann, suggesting
that the Southwest STP should extend its outfall pipe below the
"losing point (100* approximately)." James H. Williams' report on
the extent of the losing reach in Wilson Creek (14 February 1972)
204
-------
is attached to Lightfoot's memorandum. Obtained from the
"1.000 File" on Springfield, Missouri Div. of Environmental
Quality, Jefferson City.
MISSOURI (28 August 1970?). Missouri water pollution law and regulations.
Jefferson City: Missouri Water Pollution Board. 32 pp.
Idem (12 April 1972). Missouri clean water law. Senate bill no. 321,
77th General Assembly, approved by the governor on 12 April 1972.
MISSOURI CLEAN WATER COMMISSION (May 1973), Continuing planning process,
State of Missouri. Jefferson City MO: The Commission. 33 pp.
Idem (June 1973). Missouri water quality standards. Jefferson City:
The Commission. 81 pp.
Idem (May 1974). Effluent regulations. Approved by the Commission on
24 April [sic] 1974. Jefferson City: The Commission. 9 pp.,
including 2 appendices.
Idem (16 June 1974). Definition regulation. Jefferson City: The Com-
mission. 5 pp. An identical version, found in the complete
minutes of the Missouri Clean Water Commission, is dated May 1974.
The Commission approved this regulation on 24 April 1974.
Idem (16 June 1974). Regulation for the submission of applications for
discharge permits and letters of approval, Jefferson City:
The Commission. 11 pp.
205
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Idem (29 June 1974). Regulations for public participation and permit
processing and issuance. Jefferson City: The Commission.
10 pp.
Idem (11 April 1975). Effluent regulation as amended. Jefferson City:
The Commission. 10 pp.
MISSOURI CLEAN WATER COMMISSION et al. (January 1974). Water quality
of James, Elk and Spring River Basins. Jefferson City: The
Commission. 119 pp. + 2 separately bound appendices (C and D).
MISSOURI CLEAN WATER COMMISSION, EXECUTIVE SECRETARY & STAFF (26 April
1972). Summary of hearing at Springfield MO, February 23, 1972
concerning the water quality of Wilson Creek and James River.
3-page memorandum to the Missouri Clean Water Commission members.
Obtained from the "1.000 File" on Springfield/Missouri Div. of
Environmental Quality, Jefferson City.
MISSOURI CONSERVATION COMMMISSION et al. (1954). Report of field inves-
tigation of Wilson Creek near Springfield MO with reference to
conditions promoting fish kill in the James River. Cited by
U.S. FWPCA (June 1969), summarized on p. 16 of vol. 1.
Idem (September 1960). A study of pollution effects upon water quality,
life, and stream conditions in Wilson Creek and the James River,
Greene and Christian Counties, MO. Cited by U.S. FWPCA (June
1969), summarized on p. 17 of vol. 1.
206
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MISSOURI DEPARTMENT OF CONSERVATION (20 July 1966). Untitled, one-
paragraph report on the fishkill in the James River, 16 July
1966. Obtained from the file marked "James River fish kill,
July '66", Springfield Division of Sanitary Services.
MISSOURI DEPARTMENT OF NATURAL RESOURCES, DIVISION OF ENVIRONMENTAL
QUALITY (20 December 1974). NPDES permit for the Southwest
STP, Springfield. Expires on 19 December 1979. 3 pp. Obtained
from the NPDES files of EPA Region VII, Kansas City.
-MISSOURI DEPARTMENT OF NATURAL RESOURCES, DIVISION OF ENVIRONMENTAL
QUALITY, WATER QUALITY PROGRAM (June 1976). Water quality
management basin plan for White River Basin in accordance with
section 303(e) of P.L. 92-500. Jefferson City MO: The Depart-
ment. 259 pp. plus 2 apps.
MISSOURI GEOLOGICAL SURVEY AND WATER RESOURCES et al. (1965). Water
quality of James, Spring and Elk River Basins. Appendix D:
water quality data. Jefferson City: Missouri Water Pollution
Board. 7 pp. Obtained from the library of the Missouri Divi-
sion of Environmental Quality, Jefferson City.
Idem (January 1974). Water quality of James, Elk and Spring River Basins,
1964-65. Jefferson City: Missouri Clean Water Commission.
107 pp. Obtained from the library of the Missouri Div. of
Environmental Quality, Jefferson City.
207
-------
Idem (January 1974). Water quality of James, Elk, and Spring River Basins.
Appendix C: biological data. Jefferson City: Missouri Clean
Water Commission. All the data are from 1964-65. 85 pp.
Obtained from the library of the Missouri Div. of Environmental
Quality, Jefferson City.
MISSOURI WATER POLLUTION BOARD (September 1966). A water quality study
of Wilson Creek and James River below Springfield, Greene
County MO. Jefferson City: The Board. 10 pp. Obtained from
the file marked "James River fish kill", Springfield Division
of Sanitary Services.
Idem (June 1968). Water quality standards: White, North Fork, Spring,
Eleven Point, Current, and Black Rivers and tributaries.
Jefferson City: The Board. 9 chapters + 3 appendices.
Idem (November 1971). Missouri effluent guidelines. Jefferson City:
The Board. Obtained from the Missouri Division of Environmen-
tal Quality, Jefferson City. 10 pp.
Idem (February 1972). Transcript of proceedings of a public hearing
1 before the Missouri Water Pollution Board at Howard Johnson's
Motor Lodge, Springfield MO, 23 February 1972. Transcribed
by Charles R. Neff, Branson MO. Original typewritten copy
obtained from the archives of the Missouri Department of Natural
Resources. 117 pp.
208
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Carl R. NOREN (29 September 1969). Letter to William G. Galegar, Regional
Director, U.S. FWPCA, Dallas, analyzing deficiencies in FWPCA's
study of the James River and Wilson Creek. Noren is Director
of the Missouri Dept. of Conservation. 4 pp. Obtained from
file marked "James River & Wilson Creek pollution & sink hole
study", Springfield Division of Sanitary Services.
James P. ODENDAHL (23 October 1975). Letter to David G. Snider, Spring-
field's Director of Public Works. Odendahl recommends that
Springfield should build a temporary outfall extension to carry
effluent from the Southwest STP below the losing points in
Wilson Creek, "approximately 100 feet downstream of this
secondary plant outfall." Odendahl is Director of Staff,
Missouri Clean Water Cpnmission. Obtained from the "1.000 File"
on Springfield, Missouri Div. of Environmental Quality, Jefferson
City. 1 p.
John T. RHETT (16 December 1975). Program guidance memorandum - 61:
Grants for treatment and control of combined sewer overflows
and stormwater discharges. 3 pp. This memorandum is now
issued under access number PRM 75-34. Obtained from Alan Hals,
Chief, Municipal Technology Branch, U.S. EPA-HQ, Washington DC.
209
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Ronald R. RITTER (5 July 1972). Memorandum to Director, Division of
Grants Management, [EPA-HQ], "Request for eligibility deter-
mination - City of Springfield, Missouri." Ritter (Chief of
Grants Administration, EPA Region VII) asks EPA-HQ to decide
whether stormwater control in Wilson Creek is eligible for a
Federal grant. 1 p. plus 6 enclosures, including Springfield's
conceptual plan for stormwatercontrol facilities and the Clean
Water Commission's endorsement of the plan. Obtained from
Donald Eugene Sandifer, EPA Region VII, Kansas City MO.
W.E. SANDERS (7 September 1973). Letter to Mr. Greg Cole (city of Spring-
field), giving the NPDES applications "for your area." W.E.
Sanders is with the Missouri Clean Water Commission. 15 appli-
«
>
cants are listed, 12 of them in the James River basin. .Obtained
from the "1.000 File" on Springfield, .Missouri Div. of Environmental
Quality, Jefferson City.
Robert R. SCHAEFER (15 May 1974). Letter to Jack K. Smith, Executive
Secretary, Missouri Clean Water Commission. The letter trans-
mits a memorandum outlining a discussion between the City of
Springfield and Springfield City Utilities concerning the use
of effluent from the Southwest STP for cooling water at the
Southwest Powerplant. Schaefer is Springfield's Superintendent
of Sanitary Services. Obtained from the "1.000 File" on
Springfield, Missouri Div. of Environmental Quality, Jefferson
City.
210
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Idem (5 June 1974). Letter to Jack K, Smith, Executive Secretary of
the Missouri Clean Water Commission. Summarizes data and
problems at the Southwest SIP during the spring of 1974.
Schaefer is Springfield's Superintendent of Sanitary Services.
Obtained from the "1.000 File" on Springfield, Missouri Div. of
Environmental Quality, Jefferson City.
Idem (27 May 1975). Letter to V. Ramiah (Missouri Div. of Environmental
Quality). He objects to the wasteload allocation study, which
should be delayed until the STP improvements are completed. He
admits to Springfield's stormwater problems; however, "the City
has no funds available for stormwater collection and treatment
and, therefore, planning at this time will serve no useful
purpose." Schaefer is Superintendent of Sanitary Services,
Springfield. Obtained from the file marked "SW plant additions,
dossier #3", Springfield Division of Sanitary Services.
Idem (19 September 1975). Letter to Ken Karch, Director, Environmental
Quality, Missouri Dept. of Natural Resources. Schaefer recom-
mends continued support for three USGS monitoring stations below
the outfall of the Southwest STP.' Schaefer is Springfield's
Superintendent of Sanitary Services. Obtained from the "1.000
i
Pile" on Springfield, Missouri Div. of Environmental Quality,
Jefferson City.
211
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Walter G. SHIFRIN (20 January 1972). Letter to Paul T. Hickman (Super-
intendent, Sanitary Services, Springfield). This letter
summarizes the effect of Missouri's effluent guidelines (Nov-
ember 1971) on the design of the Southwest STP. It contains the
first mention of AWT by the design engineers. Shifrin is the
principal engineer at Consoer, Townsend & Assocs. responsible
for Springfield's STPs. 3 pp. Obtained from the file marked
"SW Plant Additions", Springfield Division of Sanitary Services.
Idem (20 June 1972). Letter to Don G. Busch, City Manager, Springfield.
The letter explains the reasons for the substantial increases
in construction requirements at the STPs. Shifrin is the prin-
cipal engineer at Consoer, Townsend & Associates responsible for
Springfield's STPs. 4 pp. Obtained from the file marked "SW
Plant Additions", Springfield Division of Sanitary Services.
Idem (8 August 1974). Letter to David G. Snider, Springfield's Director
of Public Works, describing modifications to the lagoon at the
Southwest STP. Shifrin is the principal engineer at Consoer,
Townsend & Associates responsible for Springfield's STPs.
Obtained from the file marked "SW Plant Additions", Springfield
Division of Sanitary Services.
Jack K. SMITH (11 May 1972). Letter to Don G. Busch, City Manager, Spring-
field. The letter sets forth a compliance schedule for Springfield's
Southwest STP. Smith is Executive Secretary, Missouri Clean
Water Commission. 2 pp. Obtained from the "1.000 File" on
Springfield, Missouri Div. of Environmental Quality, Jefferson City.
212
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SPRINGFIELD DEPARTMENT OF PUBLIC WORKS (July 1968). Report on addition of
tertiary bypass treatment facility. The report is signed by
V.W. Whitfield (Director of Public Works and City Engineer) and
Paul T. Hickman (Superintendent of Sanitary Services) on p. 8.
11 pp. Obtained from Robert R. Schaefer, Springfield's Super-
intendent of Sanitary Services.
Idem (March 1971). Addendum I: addendum to interim report on the expan-
sion of sanitary wastewater facilities for the greater Springfield
area. Springfield MO: The Department. 19 pp. plus monthly STP
reports, April 1970 - March 1971.
Idem (March 1971). Interim report on the expansion of sanitary wastewater
facilities for the greater Springfield area. Springfield MO:
The Department. 50 pp. plus area map in pocket.
SPRINGFIELD ZONING AND PLANNING COMMISSION (March 1968). 1968-1974
Capital improvement program. Springfield MO: The Commission.
186 pp.
Charles A. STIEFERMANN (20 February 1976). Memorandum to James P. Odendahl,
proposing revisions to the effluent regulations on disinfection
policy and dissolved-oxygen requirements. He recommends deleting
the DO requirement entirely; instead, design engineers should be
required to evaluate the DO sag in the receiving stream. "The
D.O. requirement in the Water Quality Standards shall not be vio-
lated due to the effluent discharge." Stiefermann is Chief of the
Municipal Waste Section, Missouri Div. of Environmental Quality.
213
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Obtained from the complete minutes of the Missouri Clean Water
Commission, Jefferson City.
Jerome H. SVORE (13 July 1973). Letter to Governor Christopher Bond,
transmitting EFA's approval of Missouri's WQS and commending
the State "for retaining the December 31, 1975, date for com-
pliance with the secondary treatment requirement." Svore is
Regional Administrator, U.S. EPA, Region VII. Obtained from
the WQS files of EPA Region VII, Kansas City. 2 pp.
C.T. TAYLOR (1964). Chemical quality of Missouri surface water. Jeffer-
son City [?]: Missouri Water Pollution Board. Prepared in
cooperation with USGS. C.T. Taylor is with USGS. 28 pp.,
including 8 foldout tables.
UNION CARBIDE CORPORATION, LINDE DIVISION (May 1972). Evaluation of
treatability study for Springfield MO. Kansas City KS (?):
The Division. 7 pp. plus 39 tables.
Idem (10 November 1972). Ozonation study for Springfield MO. Kansas
City KS (?): The Division. 9 pp. plus tables and figures.
U.S. ENVIRONMENTAL PROTECTION AGENCY (29 December 1972). Offer and
acceptance of Federal grant for sewage treatment works, project
no. C290564. EPA offers. $11.2 million; the total eligible cost
is $14.95 million.
214
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Idem (30 September 1974). Notification of grant award action, grant no.
C290564 01 2. Increase's grant amount to $19.27 million; total
eligible cost is $25.69 million.
Idem (6 March 1975). Notification of grant award action, grant no.
C290564 01 3. Increases grant amount to $31.1 million; total
eligible cost is $41.47 million.
U.S. ENVIRONMENTAL PROTECTION AGENCY, SURVEILLANCE AND ANALYSIS DIVISION
(5 March 1976). Report of investigation: Springfield MO
southwest wastewater treatment facility, NPDES permit,number
MO-0049522. Kansas City KS: The Division. 3 pp. plus 19 pp.
of tables.
U.S. FEDERAL WATER POLLUTION CONTROL ADMINISTRATION, SOUTH CENTRAL REGION,
TECHNICAL SERVICES PROGRAM, ROBERT S. KERR WATER RESEARCH CENTER
(June 1969). James River-Wilson Creek study, Springfield tfO.
Ada OK: The Center. 2 vols., including many figures, tables
and maps.
C.M. WALTER et al. (July 1971). A report on the investigation of a fish
kill in James River MO. 4 pp. plus tables and enclosures. The
report covers the fishkill on 10-11 July 1971. Walter et al.
are employed by the U.S. EPA in Kansas City MO and Ada OK.
Obtained from the file marked "James River fish kill, 1971",
Springfield Division of Sanitary Services.
215
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WHITE RIVER BASIN COORDINATING COMMITTEE (June 1968). Comprehensive
«
basin study: White River Basin, Arkansas and Missouri. Little
Rock: The Committee. 6 volumes, comprising a main report and
appendices A-F. The committee consisted of 6 Federal agencies
and the 2 states. Col. Charles L. Steel (Dept. of the Army)
was chairman.
V.W. WHITFIELD (7 September 1966). Letter to Jack K. Smith, Executive
Secretary, Missouri Water Pollution Board, outlining the rela-
tion between conditions in Wilson Creek and a fishkill in the
James River on 15 July 1966. Whitfield is Springfield's Direc-
tor of Public Works and City Engineer. 3 pp. Obtained from
the .file marked "James River fish kill, July 1966", Springfield
Division of Sanitary Services.
James R. WHITLEY (23 February 1972). Statement by the Missouri Dept. of
Conservation on pollution of J.imes River and Wilson Creek, pre-
sented at a public hearing in 'Springfield on 23 February 1972.
This statement summarizes the department's understanding of the
relation between fishkills in the James and pollution in Wilson
Creek. Dr. Whitley is Supervisor, Water Quality Branch, Division
of Fisheries, Missouri Dept. of Conservation. 5 pp. Obtained
from the hearing file, Wilson Creek & James River, Missouri Div.
of Environmental Quality, Jefferson City.
216
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James H. WILLIAMS (14 February 1972). Engineering geologic report on
Wilson Creek, Greene County; subject: extent of losing stream
reach of Wilson Creek. Williams is Geologist and Chief, Engin-
eering Geology Section, Missouri Geological Survey. Obtained
from the "1.000 File" on Springfield Missouri Div. of Environ-
mental Quality, Jefferson City. 1 p.
James L. WILSON (10 December 1975). Letter to Springfield's Dept. of
Public Works, correcting a confusion in the NPDES permit to the
Southwest STP. The confusion involved an inadvertent switch
between the BOD and SS limits. This letter officially modifies
the NPDES permit of 20 December 1974. Wilson is Director of
the Dept. of Natural Resources. Obtained from the "1.100 File"
on Springfield, Missouri Div. of Envir. Quality, Jefferson City.
Oilman WOMMACK (21 June 1973). Letter to Jim Payne (Mayor of Springfield)
describing an analysis of the effluent from the lagoon at the
Southwest STP. The effluent contained 76 mg/1 of BOD, 122 mg/1
of COD, 16 mg/1 of ammoniacal nitrogen, and 8.32 mg/1 of o-PO^
(as P). Wommack is Water Pollution Control Technician, Missouri
Clean Water Commission. Obtained from the "1.000 File" on
Springfield, Missouri Div. of Envir. Quality, Jefferson City.
217
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Idem (7 October 1974). Letter to Don G. Busch (Springfield's City
Manager), describing an analysis of the effluent from the
Southwest STP's lagoon. It contained 4.93 mg/1 of O-P04 (as P),
15.4 mg/1 of ammoniacal nitrogen, 55 mg/1 of BOD, and 140 mg/1
of COD. The fecal coliform count was 2.1 million per 100 ml.
Wommack is Director, Section of Laboratory Services, Missouri
Clean Water Commission. Obtained from the "1.000 File" on
Springfield, Missouri Div. of Environmental Quality, Jefferson
City.
218
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7. DE PERE, WISCONSIN
7.1 THE ISSUES IN BRIEF
The little city of De Pere (13,000 population in 1970) sits at
the head of the Fox River estuary. A few miles downriver are the city of
Green Bay and Green Bay itself, a massive embayment of Lake Michigan.
Upriver there are other sizable towns (Fond du Lac, Oshkosh, Neenah,
Menasha, Appleton, Kaukauna), Lake Winnebago, and many dams, most of them
providing water and power to the gigantic complex of papermills whose
wastes spice the air and water throughout this region. Meatpackers,
dairies, cheese factories, canneries, and metal industries are common
too. Below De Pere the estuary is lined with mills and smokestacks.
The Fox River and Green Bay have been notoriously polluted for decades,
and the pollution has been studied repeatedly by Wisconsin's Department
of Natural Resources (DNR).
Of all the cities in the lower Fox Valley, only De Pere's dis-
charge permit has effluent limits on BOD and SS more stringent than
30 mg/1, even though De Pere is far from the largest city in the region,
and even though the industries are responsible for most of the BOD and SS
(sometimes in the form of direct discharges, sometimes as major waste
sources in municipal sewerage districts, as in De Pere). Of all places,
why was De Pere singled out?
219
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The answer is not simple or straightforward. De Pere's STP has
been overloaded almost from the moment that secondary-treatment facilities
were built in 1964. In 1970, DNR ordered De Pere to provide 90% removal
of BOD. and SS and 85% removal of phosphorus (the phosphorus requirement
came from the Federal Enforcement Conference on the Great Lakes, which
ordered phosphorus removal throughout the Great Lakes drainage basin).
If De Pere's raw wastewaters contained no more than 300 rag/1 of BOD and
SS, 90% removal would produce a "30/30" effluent at the STP. But owing
to a meatpacker and a dairy in its service area, De Pere's raw wastewaters
usually contain much more than 300 mg/1 each of BOD and SS. Consequently,
90% removal will not produce the 30/30 effluent required by Federal regu-
lations. However, Federal regulations (40 CFR 133.103(b)) give special
consideration to cities with heavy industrial wasteloads: They allow the
30/30 limits in such cities to be adjusted upwards. Until November 1973,
De Pere wasn't sure whether to design its new (and badly needed) STP for
90% removal (which would not have required AWT) or for a 30/30 effluent .
(which would have). On 8 November 1973 EPA Region V finally decided
against relaxing the 30/30 limits for De Pere in spite of the indus-
trial wasteload and the die was cast.
Region V was not being capricious. A month before it disallowed
a variance of the 30/30 standard, EPA Headquarters had proposed a new
regulation (40 CFR 137) that would have severely limited discharges of
Ultimate Oxygen Demand (UOD) in all STPs funded after June 1974. The
proposed limits on UOD would have driven De Pere to AWT in any event.
The UOD proposal was not long-lived: It died early in 1974, after a few
months of interagency review. There was stili time to relax the AWT
requirement.
220
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But it was never relaxed. Not until June 1975 did a mathemati-
cal model of the lower Fox first recommend more than 30/30 effluent
quality from the STPs. The models published-in 1973 by DNR and EPA had
both recommended 90% BOD removal at municipal STPs. On 8 May 1975, EPA-
Chicago asked De Pere's design engineer to rejustify the need for AWT.
His justification was based on three reasons: (1) 90% removal would not
reliably produce a 30/30 effluent at De Pere; (2) without AWT, the new STP
could not comply with EPA's BPWTT requirements (i.e. the UOD effluent
standard); and (3) "due to De Pere's location on a water quality limited
segment of the Fox River ..., it was apparent that nitrification was an
eminent [sic] treatment requirement in the immediate future."
Even while De Pere was actively planning for AWT in late 1973
and 1974, its discharge permit (issued by DNR on 27 August 1974) called
for a 30/30 effluent. Clearly, the discharge permit was not coordinated
with the facilities planning.
DNR did promote AWT, however, in the Spring of 1975. De Pere's
STP outfall is right on the riverbank, where there are extensive shallows.
DNR feared that 30 mg/1 of SS in De Pere's discharge might cause sludge
banks to accumulate in the riparian shallows, though they offered no
evidence for their fears. They gave De Pere a choice:
"either the outfall must be extended onto the bed of
the Lower Fox River, approximately 200 feet from shore"
or
"the discharge of suspended solids by the City must be
limited to 10 milligrams per liter on a monthly average
basis and 20 milligrams per liter on a weekly average."
De Pere accepted the limit of 10 mg/1, and thus became the only city in
the lower Fox Valley to have such severe effluent limits.
221
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Why did De Pere accept? After all, a 200-ft outfall line would
have cost about $200,000, whereas the additional waste treatment will run
into the millions. The explanation seems to involve a mixture of fatigue
and prudence fatigue, because the planning had been creeping for years
through an obstacle course of shifting rules and regulations, and prudence,
because De Pere's City Fathers had good reason to believe that AWT might
soon be required anyway. The lower Fox River is a "water-quality-limited
segment", and a heavily polluted one at that. In such segments, DNR may
require extreme degrees of treatment. When the current "208" study of
the Fox River is completed in 1978, DNR may very well require drastic
improvements in municipal waste treatment throughout the Fox Valley. The
City Fathers evidently were anxious to get Federal subsidies for AWT
while the opportunity was available; they were willing to risk the pos-
sibility that AWT might never be a general requirement for the region.
Who can blame them? They knew that De Pere was contributing to the pol-
lution of the Fox estuary and they wanted to avoid a repeat performance
of 1964, when the new STP was overloaded almost before the cement was
dry. Better too much than too little. This was a multimillion-dollar
risk worth taking.
EPA approved the AWT discharge permit and the facility plans;
in August 1975 they offered De Pere $19.5 million for the new AWT planf
and associated facilities (the grant amount was lowered to $17.6 million
in 1976). The latest cost estimate for the AWT plant and the sewer
improvements is over $25.4 million.
222
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An equivalent STP designed to produce a 30/30 (rather than a
10/10) effluent would have cost about half that. The AWT plant will
remove about 6% more BODc and about 8% more SS than a 30/30 plant would
have. The costs of running the AWT plant will be roughly twice those of
an equivalent 30/30 plant.
Is this relatively trivial difference in performance worth the
great difference in cost? After all, De Pere is one of the smallest waste
sources on the Fox River, and a large proportion of De Pere's wastes come
from a meatpacker and a dairy. By the simple expedient of requiring
higher pretreatment of these two industrial wastewaters, De Pere could
have built a conventional secondary STP that would produce a 30/30 effluent
cheaply and reliably.
223
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7.2 CASE HISTORY
18 January 1968
Wisconsin's Department of Natural Resources (DNR) publishes its
revised Report on an Investigation of the Pollution in the Lower Fox
River and Green Bay Made During 1966 and 1967. DNR finds that De Pere's
STP, which had just been fitted with activated-sludge facilities for
»
secondary treatment in 1964, "removed 59 per cent of the BOD from the
raw wastes. This efficiency is considerably less than expected from
this plant and further studies are necessary co determine whether more
satisfactory treatment normally occurs. Portions of the city are served
by combined sewers which results in volumetric overloading of the sewage
treatment facilities at times and occasional bypassing of raw wastes."
5 March 1970
In compliance with the Federal Enforcement Conference on the
Great Lakes, Wisconsin requires all dischargers into Lake Michigan and
Lake Superior to provide phosphorus removal. DNR orders De Pere to
provide 90% BOD removal, 90% SS removal, and 85% phosphorus removal by
30 September 1972. DNR Order No. 4B-68-lla-10A.
225
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1971?
In an undated report, De Pere's design engineers recommend
facilities to comply with the DNR Order. Roy F. Weston, Inc. & Robert E.
Lee & Associates, Summary Report: Expansion of Sewage Treatment Plant,
City of De Pere, Wisconsin.
February 1972
Lee & Weston recommend two STPs for Greater Green Bay, one of
them to be located in De Pere. Brown County Sewage and Solid Waste Plan -
1972.
30 May and 14 June 1972
Two letters from Donald J. Hanaway (Mayor of De Pere) to L. P.
Voigt (Secretary of DNR's Division of Environmental Protection). Hanaway
asks DNR to approve or reject the Brown County regional plan. Should
De Pere abandon its STP, or should the STP be enlarged and upgraded?
Hanaway announces that he has stopped all further planning until DNR
makes its decision.
March 1973
DNR publishes a simplified mathematical model of the Fox River
estuary, but cannot verify it successfully. The model predicts that
water-quality standards (WQS) for the estuary will be met if industries
discharge no BOD and municipalities provide 90% BOD removal. Dale J.
Patterson, Results of a Mathematical Water Quality Model of the Lower Fox
River, Wisconsin*.
226
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10 July 1973
In a letter to Thomas G. Frangos (Administrator, Division of
Environmental Protection, DNR), Mayor Hanaway acknowledges that DNR has
at last approved the regional plan for Brown County. He asks whether DNR
is considering new, more stringent requirements for De Pere.
22 July 1973
The Wisconsin Legislature enacts a new law requiring all effluent
limitations to "comply with and not exceed" the requirements of P.L.
92-500. Wisconsin Laws of 1973, chapter 74. Wisconsin Statutes, sec.
147.021.
August 1973
Dan Crevensten et al. of EPA publish Water Quality Model of the
Lower Fox River, Wisconsin. They illegitimately use a stream model for
the Fox estuary, and cannot make it verify. They predict much cleaner
water in the estuary than Patterson did, and with far less treatment:
BPT for industries and 90% BOD removal for municipalities. (See the
entry under March 1973).
13 August 1973
Letter from Robert M. Krill (Chief, Municipal Wastewater
Section, DNR) to James M. Jakubovsky (Vice President of Robert E. Lee &
Associates, and the principal engineer assigned to the De Pere project).
Krill advises that De Pere should plan AWT facilities because an EPA list
has De Pere marked for AWT.
227
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5 September 1973
Letter from Krill to Todd Gayer (Chief of the Construction
Grants Branch, EPA Region V). Krill asks EPA to advise him on effluent
limits for De Pere. What should the degree of treatment be?
1 October 1973
New WQS become effective. They require a minimum of 2.0 mg/1
of dissolved oxygen in the Fox River estuary.
3 October 1973
EPA Headquarters proposes BPWTT (1983) effluent limits for
Ultimate Oxygen Demand (UOD) and Ultimate Biochemical Oxygen Demand
(UBOD). These limits are much more stringent than the "30/30" definition
of secondary treatment (required by 1977). When the influent is warmer
than 20 C, the effluent UOD must not exceed 50 mg/1 (as a monthly
average); when the influent is cooler than 20° C, the effluent UBOD must
not exceed .30 mg/1 (as a monthly average). EPA Notice of Proposed Rule
Making (40 CFR 137), Information on Alternative Waste Management
Techniques and Systems to Achieve Best Practicable Waste Treatment.
15 October 1973
Letter from Frangos to Francis T. Mayo (Regional Administrator
of EPA Region V). Will EPA immediately fund an enlarged secondary plant
at De Pere, or should the project be set aside for at least one year to
allow time for a wasteload allocation?
228
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18 October 1973
Letter from R.J. Schneider (Director of Air and Water Programs,
EPA Region V) to Krill. Schneider says that "De Pere should be designing
secondary treatment, if funded with FY '74 funds, or BPWTT, if funded with
'75 funds."
14 November 1973
Memo to the file from Richard W. Smith (EPA-Chicago). Smith
summarizes a meeting held on 8 November 1973 at the request of .De Pere's
STP-design consultant, Jakubovsky. Jakubovsky wanted a final answer to
a persistent, fundamental question: Should he be designing a secondary
plant or an AWT plant? He proposed three candidate designs: two variants
of the contact-stabilization process (both of them secondary plants) and
a nitrification design based on the modified Kraus process (an AWT plant).
The two contact-stabilization designs reliably remove about 90% of the
BOD and SS. When the influent contains less than 300 mg/1 of BOD and SS,
contact stabilization will produce a "30/30" effluent. However, De Pere's
influent often contains much more than 300 mg/1 of BOD and SS; the strong
influent is explained by the major industries in the service area, prin-
cipally a meatpacker and a dairy. 40 CFR 133.103(b) gives special con-
sideration to cities with heavy industrial wasteloads; it allows the
"30/30" effluent limits to be adjusted upwards. Smith reports that EPA
refuses^to "allow a variance in the 30/30 requirement", but does not
explain why. EPA therefore rejected both the secondary-STP designs.
229
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The AWT design (nitrification using a modified Kraus process),
however, will achieve more than 95% removal of BOD^ and SS. It will also,
according to Smith, produce an effluent that will conform to the UBOD and
UOD limits proposed by EPA Headquarters on 3 October 1973:
"Inasmuch as the DePere [sic] project is likely to be funded
after June 30, 1974, this agency tentatively endorses the use
of technology which will result in an effluent ultimate oxygen
demand not to exceed 50 mg/1 ... and ... the ultimate biochemi-
cal oxygen demand not to exceed 30 mg/1 on a parallel basis.
QUALIFICATION: The above information has been presented
based upon the current understanding of Secondary Treatment
and proposed BPWTT Regulations. In the event such regulation's
are modified or additional regulations are promulgated which j
impact the interpretation of present regulations, then the
above information may be voided." (Emphasis in the original)
I
Jakubovsky had his answer, at least for the moment. He was to
forget about secondary treatment and proceed with an AWT design indeed,
a complex AWT design, which Smith calls "two stage modified Kraus Process
t
activated sludge (carbonaceous and nitrogeneous [sic] BOD removal) to
achieve 95% plus removals."
January 1974
Lee & Weston publish their report on infiltration and inflow.
They recommend new separate sewers in the few acres of town that have
combined sewers, and they recommend disconnecting all basement and roof
drains from the sanitary sewers.
29 January 1974
Letter from Gayer to Mayor Hanaway. EPA "approves-in-principle"
nitrification facilities for the De Pere STP and underscores the importance
of the proposed BPWTT regulations:
230
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"We are confirming statements made to your consulting engineers
to the effect that:
".... 2. Construction of a two stage activated sludge sewage
treatment facility in two operable 'unit' phases is an accept-
able approach to satisfying the tentative requirements of the
proposed BPWTT standards. The appropriate grant applications
would have to be prepared with this concept in mind. Both
'phases' are potentially eligible under the construction grant
program.
"3. This agency has made no decisions, nor have any been con-
templated, to the effect that EPA participation in sewage
treatment works would be limited to those facilities designed
to meet the minimum secondary treatment requirements. Such a
position would be contrary to the philosophy expressed in
Title II, Section 201, of the Federal Water Pollution Control
Act.
"4. Although the above referenced BPWTT requirements have not
been promulgated in the form of a regulation to date, thus,
establishing formal definitions of the specified processes to
be utilized, Section 201 of the Act does stipulate that the
Administrator shall not make grants from funds authorized for
any fiscal year beginning after June 30, 1974, unless the
grant applicant has satisfactorily demonstrated that the works
proposed will provide for the application of BPWTT over the
life of the works. Based upon the foregoing, we 'approve-in-
principle' of the city's approach to abating pollution providing
this approach concurrently meets the requirements of your State
agency." (Emphasis in the original)
25 February 1974
EPA Headquarters cancels the BPWTT regulations that were proposed
on 3 October 1973 (40 CFR 137). UOD and UBOD limits will not be imposed
on municipal effluents. The proposed UOD and UBOD limits were evidently
killed during interagency review:
"Prior to interagency review, it was recommended that criteria
be established (in the form of a regulation) for three major
wastewater management alternatives: treatment and discharge,
land application, and reuse. The treatment and discharge
criteria would have required an upgrading of some plants
designed to achieve secondary treatment to a higher level of
treatment at an estimated marginal cost of $1.7 to 2.9 billion.
However, upon reconsideration it is now proposed that the mini-
mum treatment requirement for publicly owned treatment works
231
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should remain at secondary treatment as defined in 40 CFR 133.
This proposal is made for budgetary reasons and in Light of
the fact that water quality standards will dictate where treat-
ment levels higher than secondary treatment are necessary.
"The originally recommended BPWTT criteria shifted the emphasis
from the five day biochemical oxygen demand (BOD) to ultimate
oxygen demand (UOD), which includes both the BOD and ammonia
oxygen demand, as the key effluent parameter. The criteria
essentially required a plant to be designed for 92 percent
removal of BOD. The percent UOD removal would have been in-
creased from only 69 percent (as required by the EPA secondary
treatment definition) up to 88 percent as required by the rec-
ommended BPWTT criteria for the critical warm periods of the
year. This level was selected so that the costs were at the
'knee' of the cost curve.
".... [The recommended approach is that Headquarters should
have the proposed BPWTT rules of 3 October 1973, and their
supporting documents,] revised by eliminating the discussion
of and reference to more stringent minimum treatment and
discharge requirements Secondary treatment, therefore
remains the minimum level of treatment."
EPA Headquarters memorandum, "Information on Alternative Waste Management
Techniques and Systems to Achieve Best Practicable Waste Treatment
ACTION MEMORANDUM", from the Acting Assistant Administrator for Air and
Water Programs to the Administrator.
March 1974
Environmental Impact Statement by Weston does not compare the
effects of AWT and secondary treatment on the Fox estuary.
10 April 1974
Summary Report; Expansion of Wastewater Treatment Plant, City
of De Pere, Wisconsin by Weston & Lee. Includes facilities for nitrifi-
cation and multimedia filtration.
232
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21 August 1974
De Pere's discharge permit (//WI-0023787) requires the STP
effluent to meet the following monthly-average limits by 1 July 1977:
BOD5 of 30 mg/1, SS of 30 mg/1, and total P of 1.0 mg/.
9
4 September 1974
EPA Region V surveys the De Pere STP and rates it as "unaccepta-
ble". EPA reports that there are daily bypasses of raw sewage at the
STP, owing to hydraulic overloading; infiltration in the sewer system;
bypasses during wet weather; organic overloading "by the industrial wastes
primarily from Armour and Company"; periodic shock loadings; and sludge
digesters stressed by high solids loadings.
"The treatment plant is severely overloaded both hydrauli-
cally and organically due to plant obsolescence and the
volume of industrial wastes. The flow through the plant
is limited by the Venturi meter which can only accept a
maximum flow of about 2,000 gpm. Even if the flow through
the plant could be increased to the design flow, it does
not appear that the additional organic loadings could be
handled by the plant. Expansion of the plant is planned
when funding becomes available."
Dale I. Bates, Report on Operation and Maintenance of Wastewater Treatment
Plant; cover letter from EPA's Clarence C. Oster is dated 25 October 1974.
4-5 September 1974
In conjunction with EPA, DNR surveys the De Pere STP. DNR finds
that the effluent contained 95 mg/1 of BOD5, 30 mg/1 of SS, and 4.3 mg/1
of total phosphorus. DNR splits samples with the De Pere STP; the results
are shocking they differ by as much as a factor of 16. James C.
Fahrbach, Results of a 24-Hour Survey at City of DePere [sic], September
4-5, 1974. approved by DNR on 31 March 1975.
233
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April-June 1975
DNR and De Pere correspond about the STP's point of discharge.
DNR wants the STP outfall extended into the river, for fear that 30 mg/1
of SS in the effluent will cause sludge banks along the shore. However,
DNR will allow the outfall to remain near shore if De Pere will agree to
an SS limit of 10 mg/1. De Pere agrees.
June 1975
Dale J. Patterson et al. of DNR (under contract to EPA Region V)
publish Water Pollution Investigation: Lower Green Bay and Lower Fox
River. DNR illegitimately uses a stream model for the Fox estuary and
cannot simulate DO minima. This model is to be used in a formal alloca-
tion of industrial wasteloads; the municipal wasteloads are handled by
assumption. The De Pere STP is assumed to discharge 10 mg/1 of 3005 and
10 mg/1 of SS.
August 1975 .
EPA offers De Pere two grants totalling $19,472,475 for an AWT
i
plant and associated facilities. Grant number C550706-01 is for
$2,050,125; the estimated project cost is $2,733,500. Grant number
C550706-02 is for $17,422,350; the estimated project cost is $23,229,800.
In both cases the Federal Government offers to pay 75% of the project cost
and the local government assumes 25% of the costs; the State offers no
financial assistance. (Grant number C550706-02 is later revised twice;
see entries under 9 March 1976 and 27 May 1976.)
234
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August 1975
DNR publishes The Fox-Wolf Water Quality Management Basin Plan.
The De Pere STP is incorrectly described as having 34.500-mgd capacity
and an effluent BOD of "000"; the complicated treatment code is not
*
explained and the disinfection code is uninterpretable.
August 1975
Robert W. Lanz (University of Wisconsin-Green Bay) publishes
A Computer Analysis of the Water Quality in the Lower Fox River and Lower
Green Bay, Wisconsin. Lanz, like all the other modelers, illegitimately
uses a stream model for the Fox estuary, and he too cannot make it verify.
28 August 1975
De Pere's discharge permit (//WI-0023787) is revised. The STP
must now meet the following effluent limits by 1 July 1978: BODc of 10 mg/1,
SS of 10 mg/1, and total P of 1.0 mg/1. Note that De Pere's BOD limit has
been reduced, although BOD has no relation to sludge banks (see entry under
April-June 1975).
15-16 October 1975
DNR surveys the De Pere STP. It finds overflows in the sewer
system, bypasses of raw sewage at the STP (during the survey 453,000
gallons of raw sewage 'were bypassed to the Fox River), shockloads of
industrial waste at the STP, and a final effluent containing 88 mg/1 of 8005,
368 mg/1 of SS, and 12.3 mg/1 of total phosphorus. DNR splits samples with the
De Pere STP laboratory; once again the results are shocking they differ
by as much as a factor of 8. Dan Uhl (& Tim Doelger), Results of a 24-Hour
Survey at City of DePere [sic]. October 15-16. 1975. approved by DNR on
4 November 1975.
235
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9 March 1976
EPA-Chicago amends Grant number C550706-02. The revised grant
amount is $15,479,550; the revised project cost estimate is $20,673,226.
De Pere accepts the revisions on 19 March 1976.
30 March 1976
EPA awards $772,000 to the Fox Valley Water Quality Planning
Agency to prepare a "208" plan. The plan will involve yet another mathe-
matical model, a variant of the QUAL III model used by DNR (see entry
under June 1975). The model continues to treat the estuary as a stream,
ignores sediment kinetics, and neglects bypassing. The principal product
of the "208" plan will be another wasteload allocation for the Fox Valley,
to be published in March 1978.
27 May 1976
EPA-Chicago amends Grant number C550706-02. The revised grant
amount is $15,479,550; the estimated cost of the project is changed to
$20,793,226. De Pere accepts the changes on 17 June 1976.
6 January 1977
DNR presents "Background Information for Wasteload Allocations"
on the Educational Television Network; the information is exclusively on
the Fox and Wisconsin Rivers, the two major papermill rivers in the State.
The 1977 daily BOD load from De Pere is given as 470 Ib/day; this figure
is inconsistent with De Pere's discharge permit, with the basin plan, and
with the design specifications of the new AWT plant. DNR announces that
it does not plan to issue "final waste discharge permits" until the end
of 1978.
236
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15 Feburary 1977
Thomas Windau of the Fox Valley "208" agency sends the Vertex
Corporation a list of dischargers in the lower Fox River; these dischargers
will be evaluated in the QUAL III model. "The loads indicated on the list
assume secondary treatment for all municipalities at a design year of
about 1995." The list gives the De Pere STP a BOD concentration of 30 mg/1
and an average BOD load of 3558 Ib/day. Yet De Pere's discharge permit
(see-entry under 28 August 1975) limits the monthly average BODj discharge
to 1184 Ib/day beginning 1 July 1978, and the average monthly concentration
i
of BOD5 in the effluent is limited to 10 mg/1.
Autumn 1977
The new AWT facilities are scheduled to begin operation.
237
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7.3 BIBLIOGRAPHY
ANON (19 July 1974). Public hearing: environmental impact statement for
City of De Pere proposed wastewater treatement plant expansion,
EPA project //C550706, 4 June 1974, City Hall, De Pere, Wisconsin.
Transcribed by Colleen Reed, Court Reporter, State of Wisconsin.
On file with the U.S. Environmental Protection Agency, Chicago.
45 pp.
Dale I. BATES (4 September 1974). Report on operation and maintenance of
wastewater treatment plant (EPA form 7500-5), De Pere wastewater
treatment plant . Obtained from the De Pere file of the
Wisconsin Department of Natural Resources, Madison. 8 pp.
BROWN COUNTY REGIONAL PLANNING COMMISSION (February 1972). Brown County
sewage and solid waste plan, 1972, supplement A. No publication
details; obtained from the files of the U.S. Environmental Pro-
tection Agency, Chicago. 10 pp.
Todd A. CAYER (29 January 1974). Letter to Donald J. Hanaway, (Mayor,
City of De Pere). Gayer (Chief, Construction Grants Branch,
U.S. Environmental Protection Agency, Chicago) "approves-in-
principle" nitrification facilities for the De Pere STP.
Obtained from the files of the Wisconsin Department of Natural
Resources, Madison.
239
-------
Dan CREVENSTEN et al. (August 1973). Water quality model of the lower Fox
River, Wisconsin. Chicago: U.S. Environmental Protection
Agency, Enforcement Division. 47 pp. + appendix.
DE PERE COMMON COUNCIL (20 November 1973). Resolution #73-86. Authorizes
De Pere's engineering consultants to design AWT facilities.
Obtained from the files of the Wisconsin Department of Natural
Resources, Madison.
DONOHUE & ASSOCIATES (1970). Report on wastewater treatment facilities
for the City of De Pere, Wisconsin. Sheboygan, WI: Donohue.
75 pp.
Earl EPSTEIN et al. (August 1974). Lower Green Bay: An evaluation of
existing and historical conditions. Prepared for the U.S.
Environmental Protection Agency, Region V, Great Lakes Initiative
Contract Program,by the Wisconsin Department of Natural Resources,
Division of Environmental Standards. Chicago: The Agency.
281 pp.
James C. FAHRBACH (approved 31 March 1975). Results of a 24-hour survey
at City of De Pere, 4-5 September 1974. Approved by Allen F.
Schoen (Assistant District Director, Wisconsin Department of
Natural Resources). Obtained from the files of the Department,
Madison. 8 pp.
240
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Thomas G. FRANCOS (15 October 1973). Letter to Francis T. Mayo (Regional
Administrator, U.S. Environmental Protection Agency, Region V,
Chicago). Frangos (Administrator, Division of Environmental
Protection, Wisconsin Department of Natural Resources) asks
Mayo if EPA will fund an enlarged secondary STP at De Pere
immediately, or if the project should wait at least one year
for a wasteload allocation. Obtained from the files of the
Department, Madison.
Donald J. HANAWAY (30 May 1972 and 14 June 1972). Two letters to L.P.
Voigt (Secretary, Division of Environmental Protection, Wisconsin
Department of Natural Resources). Hanaway (Mayor, City of
De Pere) requests that DNR approve or reject the Brown County
regional plan, and informs DNR that he has stopped all planning
until the decision is made. Obtained from the files of the
Department, Madison.
Idem (10 July 1973). Letter to Thomas G. Frangos (Administrator, Division
of Environmental Protection, Wisconsin Department of Natural
Resources). Hanaway acknowledges DNR's and the U.S. Environ-
mental Protection Agency's approval of the Brown County regional
plan. Obtained from the files of the Department, Madison.
David E. HEISER (17 April 1975). Letter to the City of De Pere. Reiser
(Engineer, Water Quality Evaluation Section, Wisconsin Depart-
ment of Natural Resources) suggests a 10 mg/1 suspended-solids
limit for the De Pere STP. Obtained from the files of the
Wisconsin DNR, Madison.
241
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Lee T., KERNEN (1975?). Fishery investigations on the lower Fox River and
south Green Bay in 1973-1974. Wisconsin Department of Natural
Resources. Unpublished: Obtained from the files of the Depart-
ment, Madison.
Robert M. KRILL (13 August 1973). Letter to James Jakubovsky (Vice
President, Robert E. Lee & Associates). Krill (Chief, Municipal
Wastewater Section, Wisconsin Department of Natural Resources)
advises Jakubovsky that De Pere should plan AWT facilities
because an EPA list has De Pere marked for AWT. Obtained from
the files of the Department, Madison.
Idem (5 September 1973). Letter to Todc Gayer (Chief, Construction Grants
Branch, U.S. Environmental Protection Agency, Chicago). Krill
asks EPA's advice on degree-of-treatment requirements for the
De Pere STP. Obtained from the files of the Department, Madison.
Robert W. LANZ (August 1975). A computer analysis of the water quality in
the lower Fox River and lower Green Bay, Wisconsin. University
of Wisconsin Sea Grant College Technical Report WIS-SG-75-228.
Green Bay, WI: The University. 55 pp.
ROBERT E. LEE & ASSOCIATES (November 1972). Brown County sewage and solid
waste plan, 1972, supplement B. Green Bay, WI: Lee. 15 pp.' +
tables, figures, and maps.
242
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Idem (May 1975). River crossing and northeast Fox River interceptor,
additional information for facilities plan. Obtained from the
files of the U.S. Environmental Protection Agency, Chicago.
3 vols., approx. 70 pp.
Idem (December 1975). Documentation for City of De Pere wastewater treat-
ment plant expansion, USEPA grant C-550706 (I). Obtained from
the files of the U.S. Environmental Protection Agency, Chicago.
Approx. 100 pp.
Idem (January 1976). Documentation for City of De Pere wastewater treat-
ment plant expansion, USEPA grant C-550706-2. Obtained from the
files of the U.S. Environmental Protection Agency, Chicago.
Approx. 150 pp.
Idem (August 1976). Documentation for City of De Pere wastewater treat-
ment plant expansion, EPA grant C 550706-02 [sic] contract 2F.
Obtained from the files of the U.S. Environmental Protection
Agency, Chicago. Approx. 50 pp.
ROBERT E. LEE & ASSOCIATES & ROY F. WESTON, INC. (February 1972). Brown
County sewage and solid waste plan 1972. Prepared for the
Brown County Regional Planning Commission. Green Bay, WI:
Lee, and Wilmette, IL: Weston. Approx. 150 pp. +maps.
243
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Idem (January 1974). Report on analysis of infiltration and inflow on
the wastewater collection system for the City of De Pere,
Wisconsin, wastewater treatment project. Green Bay, WI: Lee,
and Wilmette, IL: Weston. 31 pp. + appendixes and maps.
Idem (March 1974). Addendum to the infiltration/inflow analysis for the
. City of De Pere, Wisconsin wastewater treatment plant project.
Green Bay, WI: Lee, and Wilmette, IL: Weston. 24 pp. + map.
Idem (June 1975). Phase I, II and III grant application, City of De Pere,
Wisconsin, EPA project //C-550706. Green Bay, WI: Lee, and
Wilmette, IL: Weston. Approx. 50 pp.
Dale J. PATTERSON (March 1973). Results of a mathematical water quality
model of the lower Fox River, Wisconsin. Wisconsin Department
«
of Natural Resources, Bureau of Standards and Surveys, Water
Quality Evaluation Section. Madison, WI: The Department.
45 pp..
Dale J. PATTERSON et al. (June 1975). Water pollution investigation:
lower Green Bay and lower Fox River. Prepared by the Wisconsin
Department of Natural Resources, Division of Environmental
Standards, for the U.S. Environmental Protection Agency, Gceat
Lakes Initiative Contract Program, Chicago. Report //EPA-905/9-
74-017. Chicago: The Agency. 371 pp.
Paul E. SAGER & James H. WIERSMA (1972). Nutrient discharges to Gr^en Bay,
Lake Michigan from the lower Fox River. In: Proceedings, 15th
Conference on Great Lakes Research, 1972: 132-148.
244
-------
Idem (March 1975). Phosphorus sources for lower Green Bay, Lake Michigan.
In: Journal of the Water Pollution Control Federation
47(3):504-514.
F.H. SCHRAUFNAGEL et al. (4 January 1968, revised 18 January 1968).
Report on an investigation of the pollution in the lower Fox
River and Green Bay made during 1966 and 1967. The Wisconsin
Department of Natural Resources, Division of Resource Develop-
ment. Madison, WI: The Department. 78 pp.
R.J. SCHNEIDER (18 October 1973). Letter to Robert M. Krill (Chief,
Municipal Wastewater Section, Wisconsin Department of Natural
Resources). Schneider (Director, Air and Water Programs Divis-
ion, U.S. Environmental Protection Agency, Chicago) writes that
"the City of De Pere should be designing for secondary treatment,
if funded with FY '74 funds, or BPWTT, if funded with FY '75
funds." Obtained from DNR, Madison, WI.
Ralph H. SCOTT et al. (21 March 1957). Drainage Area 11 A stream
pollution, lower Fox River. Wisconsin Committee on Water
Pollution. Madison, WI: The Committee. Obtained from the
Wisconsin Department of Natural Resources, Madison. 47 pp.
Richard W. SMITH (14 November 1973). Memo to the file. Smith summarizes
a meeting (on 8 November 1973) requested by Jakubovsky to settle
De Pere's degree-of-treatment requirements. EPA tentatively
endorsed Jakubovskyfs proposal for an AWT plant with nitrifica-
tion facilities.
245
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J.J. SUITS (18 April 1975). Letter to David Heiser (Bureau of Water
Quality, Wisconsin Department of Natural Resources). Smits
(City Administrator, City of De Pere) writes that De Pere
accepts the 10 mg/1 suspended-solids limit. Obtained from
the files of the Department, Madison.
Dan UHL (approved 4 November 1975). Results of a 24-hour survey at City
of De Pere, 15-16 October 1975. Approved by Allan F. Schoen
(Assistant District Director, Wisconsin Department of Natural
Resources). Obtained from the files of the Department, Madison.
8 pp.
U.S. ARMY ENGINEER DISTRICT, CHICAGO (December 1975). Draft environmental
statement relating to the operation and maintenance of the Fox
River, Wisconsin Navigation Project. Chicago: The District.
9 chapters + 8 appendixes.
U.S. ENVIRONMENTAL PROTECTION AGENCY (undated). Environmental impact
appraisal. Obtained from the "201-De Pere, WI" planning file
in EPA, Chicago. 2 pp.
Idem (20 August 1975). Grant agreement between EPA and the City of
De Pere for $2,050,125. Obtained from the files of EPA,
Chicago.
Idem (8 October 1975). Grant agreement between EPA and the City of De Pere
for $17,422,350. Obtained from the files of EPA, Chicago.
246
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Idem (19 March 1976). Grant amendment between EPA and the City of De Pere
decreasing the grant by $1,942,800. Obtained from the files of
EPA, Chicago.
Idem (17 June 1976). Grant amendment between EPA and the City of De Pere
increasing the grant by $90,000. Obtained from the files of
EPA, Chicago.
UNIVERSITY OF WISCONSIN SEA GRANT COLLEGE PROGRAM & UNIVERSITY OF
«'
WISCONSIN-EXTENSION (undated). Abstracts: The water quality
of the lower Green Bay and its drainage basin, a technical
conference, 19 November 1974, Green Bay, Wisconsin. Obtained
from Dr. James H. Wiersma, University of Wisconsin at Green Bay.
17 pp.
ROY F. WESTON, INC., ECONENVIRONOMICS DEPARTMENT (March 1974). Environ-
mental impact statement, water pollution control facility,
De Pere, Wisconsin. Wilmette, IL: Weston. 61 pp. + appendixes;
and undated addendum stamped 21 February 1975 by the Wisconsin
Department of Natural Resources.
ROY F. WESTON, INC. & ROBERT E. LEE & ASSOCIATES (1971?). Summary report:
expansion of sewage treatment plant, City of De Pere, Wisconsin.
40 pp. +2 appendixes. Contained in: LEE & WESTON (January
1974), cited above.
247
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Idem (10 April 1974). Summary report: expansion of wastewater treatment
plant, City of De Pare, Wisconsin. Wilmette, IL: Weston, and
Green Bay, WI: Lee. 29 pp. + tables, figures, and 7 appendixes.
Thomas WINDAU (15 February 1977). Letter to Larry Bazel (Vertex Corpora-
tion). Windau (Environmental Engineer, Fox Valley Water Quality
Planning Agency) sends Vertex a list of the dischargers and the
effluent loads being used by the Planning Agency in its mathe-
matical modeling work.
WISCONSIN ADMINISTRATIVE CODE Chapters NR 102- NR 103 (effective 1 October
1973). Register, September 1973, No. 213. Water quality
standards for surface and interstate waters. Obtained from the
Wisconsin Department of Natural Resources, Madison.
WISCONSIN ADMINISTRATIVE CODE Chapter NR 104 (effective*! October 1976).
Register, September 1976, No. 249, Environmental Protection. '
Intrastate waters uses and designated standards. Obtained
from the Wisconsin Department of Natural Resources, Madison.
WISCONSIN DEPARTMENT OF NATURAL RESOURCES (14 May 1968). Order #4B-68-lla-10.
Requires De Pere to submit preliminary reports for sewer separa-
tion and STP upgrading, including 80% phosphorus removal. Obtained
from the Department, Madison.
Idem (5 March 1970). Order #4B-68-lla-10A. Requires De Pere to provide
90% BOD and SS removal and 85% phosphorus removal by 30 September
1972.
248
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Idem (27 August 1974). Wisconsin Pollutant Discharge Elimination System
(WPDES) permit //WI-0023787. Obtained from the U.S. Environmentiil
Protection Agency, Chicago. 8 pp.
Idem (15 April 1975). Annual water quality report to Congress. Madison,
WI: The Department. 6 sections + 6 appendixes. Appendix D
(Pollution caused fish kills 1960-1974) lists three fishkills
in the lower Fox River, all during 1970.
Idem (10 June 1975). Stipulation between the Department and the Cir:y of
De Pere; De Pere accepts the Department's modifications of its
WPDES permit. Obtained from the Department, Madison.
Idem (28 August 1975).- Modification of WPDES permit #WI-0023787. Obtained
from the U.S. Environmental Protection Agency, Chicago. 9 pp.
Idem (17 December 1976). Background information for wasteload allocations,
6 January 1977 on ETN. Obtained from the Department, Madison.
WISCONSIN DEPARTMENT OF NATURAL RESOURCES, ENVIRONMENTAL STANDARDS DIVISION
(August 1975). The Fox-Wolf water quality management basin plan.
Madison, WI: The Department. 170 pp.
Idem (15 April 1976). Wisconsin 1976 water quality inventory report to
Congress. Madison, WI: The Department. 107 pp. Appendix C
(Pollution caused fish kills ~ 1975) lists no fishkills in the
lower Fox River or in Green Bay.
249
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WISCONSIN LAWS OF 1973, Chapter 74 (effective 22 July 1973). 1973 Assemb.'.y
Bill 128. An act to repeal 144.555; to amend 15.34 and 165.07;
and to create chapter 147 of the statutes.
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8. SAN JOSE/SANTA CLARA, CALIFORNIA
8.1 THE ISSUES IN BRIEF
One large STP (which we call "SJ/SC") serves the cities of San
Jose and Santa Clara, several smaller towns, and over 100 industries at
the south end of San Francisco Bay. Among the industries are large
canneries, whose wastes come all at once in late summer. Water quality
at the south end of the bay and in its tidal tributaries (which are often
called "sloughs" in California) has left much to be desired. Among the
most serious problems is the lack of oxygen in these waters.
Since the early 1950*s, California has required more and more
pollution control in this area. Until 1956, all the wastewaters were
discharged into small sloughs without treatment of any kind. In round
after round of elaborate planning and costly construction, SJ/SC has been
expanded from a 36-mgd primary plant to a 160-mgd secondary plant. Each
round has been a failure, since the sloughs still violate the lowest DO
standard ever set for these waters. In 1951, the State required that the
DO in these waters must never fall below 2.0 mg'/l; but in November 1976
(well after the canning season had finished), the DO fell below 2.0,
although SJ/SC was operating at scarcely half its design capacity. At
present, the secondary plant is being upgraded to AWT, new facilities
251
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for sludge handling are being designed, and the State has ordered SJ/SC
to move its outfall from the sloughs to the deep bay. According to the
mathematical modelers, this new round of construction, like its predeces-
sors, is foredoomed to failure.
The scientists, engineers, and planners who got SJ/SC into this
predicament (with approval by local, regional, State, and Federal
authorities at every step) have included many of the brightest luminaries
in the business: Bechtel, Brown & Caldwell, Consoer Townsend, Engineering-
Science, Hydroscience, the U.S. Army Corps of Engineers, the U.S. Geological
Survey, the University of California at Berkeley, and WRE. The planning
was largely financed by government grants, which entailed more review.
On paper, at least, SJ/SC hasn't cut corners. There have been
water-quality surveys (both large and small), large programs of routine
monitoring, many mathematical models, and stacks of detailed engineering
plans. The regulatory apparatus has been voluminous. There have been
several sets of WQS since 1951, repeated wasteload allocations, basin
plans, "environmental-impact" documents, special policies for the south
bay, and discharge permits.
Despite this massive investment in planning, the State is now
in a quandary. The most recent mathematical model (which is an improve-
ment on many of the earlier versions versions that led to the require-
ment for AWT and for a new outfall deep in the bay) has shown that all the
earlier plans were fundamentally wrong. The modelers now contend chat AWT
IT '
and a new outfall in deep water will not bring the waters around San Jose
into compliance with WQS. The DO standard, in particular, will be violated
no matter what SJ/SC may do about pollution control. Even after the outfall
252
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has been moved from the sloughs to the bay, the sloughs will violate the
DO standard; and even with AWT at SJ/SC, the sloughs will violate the
standard if the discharge stays where it is. In short, damned if you do
and damned if you don't.
The new AWT facilities will cost about $64 million, the new
sludge facilities will cost another $21 million, and the new outfall
project will cost about $80 million more. The planners now confess that
these costly projects will not effect compliance with WQS; moreover, they
are at a loss to say what projects could satisfy the WQS.
The sophisticated planning has led into a blind alley, and none
of the planners knows a way out.
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"Cria cuervos y te sacaron los ojos." Tomas de
Iriarte (1781), Fabulas literarias.
254
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8.2 CASE HISTORY
15 March 1951
The San Francisco Bay Regional Water Pollution Control Board
(SFB) requires that the discharge from the future San Jose STP should not
contain floatables or too many bacteria, should not cause sludge banks or
odors, and should not lower the dissolved oxygen (DO) of Coyote Slough
below 2.0 mg/1 near the discharge. San Jose's municipal and industrial
wastes are now discharged directly from the sewers without treatment of
any kind. Resolution No. 48.
21 August 1952
The SFB makes its requirements more specific and adds more.
The discharge should not cause fishkills. Dissolved sulfide must be less
than 0.1 mg/1 in the surface water of any open channel leading to a
discharge. DO in Coyote Creek (Coyote Slough) and most of its tributaries
must not "be reduced below 2.0 ppm as a result of any waste discharge."
Resolution No. 106.
1956
The San Jose STP begins operating. It is a 36-mgd primary plant.
It discharges most of its effluent into Artesian Slough and the rest into
Coyote Creek, which connects Artesian Slough with San Francisco Bay.
e
255
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18-19 September 1957
The SFB staff et al. survey water quality in south San Francisco
Bay and test STP effluents during the canning season. The staff concludes
that the SFB's requirements are not being met and that San Jose and
Sunnyvale are responsible. Staff reports published in February and June
1958.
30 September 1957
The SFB orders San Jose to improve sewage treatment and to con-
trol odors during the canning season. The Board cites a letter from the
City Manager of Alviso that complains about the "unbearable odor nuisance".
Resolution No. 251.
1959
The City of Santa Clara buys an interest in the STP. The
San Jose/Santa Clara STP (SJ/SC) will be jointly owned and operated by
both cities.
December 1959
Brown & Caldwell Engineers compute that the assimilative capacity
of Artesian 'Slough is 49,000 Ib/day of 23°-BOD20, which is equal (the
engineers assert) to 46,000 Ib/day of 20°-BODc. They compute that the
assimilative capacity of Coyote Slough (Coyote Creek) is 97,000 Ib/day of 23°-
BOD20> or 90,000 Ib/day of 20°-BOD . Brown & Caldwell recommend enlarging
the STP to 94 mgd and upgrading it to give activated-sludge secondary
treatment. Report prepared for the City of San Jose.
256
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December 1959
The SFB concludes that the SJ/SC discharge violates the SFB's
requirements for odors and DO, and that San Jose has been tardy about
correcting the violations.
17 December 1959
The SFB orders San Jose to cease and desist from violating the
SFB's requirements. Resolution No. 318.
1960
The primary STP is enlarged to 51 mgd. San Jose and Santa Clara
hire Consoer, Townsend & Associates to design facilities that will meet
the SFB's requirements, with capacity for future growth.
31 January 1961
Harris et al. (University of California College of Engineering)
publish a pilot study on the effects of waste discharges in south San
Francisco Bay. They recommend a full-scale study. Prepared for the SFB.
June 1962
McCarty et al. (University of California College of Engineering)
publish a comprehensive survey of southern San Francisco Bay. They report
that Coyote Creek became anaerobic during the canning season and often-had
less than 2 mg/1 of DO throughout the winter, despite the massive tidal
exchange. The southernmost part of San Francisco Bay (south of Dumbarton
Bridge) loses more than two-thirds of its volume between tidal extremes.
Three laboratories split samples of STP effluents to ensure accuracy and
check quality control. They produced amazingly different results.
257
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February 1964 .
The secondary STP begins full operation. It is a 94-mgd plant
designed to accommodate increasing wasteflows and loads until 1970.
December 1964
The SFB concludes that during the canning season, the new STP
causes violations of the SFB's requirements for DO, dissolved sulfides,
and odors in Coyote Creek and its tributaries.
15 April 1965
The SFB orders new improvements to the STP and more controls on
the industrial hookups. Resolution No. 661.
1966
SJ/SC adds four final clarifiers.
November 1966
Consoer, Townsend & Associates (CTA) admit that the STP was
underdesigned. The influent SS loads in 1964 were much greater than the
design loadings for 1970; because it was overloaded, the STP could not
give full secondary treatment. Even with the extra clarifiers, the STP
discharged more BOD during the 1966 canning season than Artesian Slough
and Coyote Creek could assimilate (as computed by Brown & Caldwell in
1959); DO in the sloughs was often less than 2-mg/l. Prepared for San
Jose and Santa Clara.
258
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November 1966
The staff of the SFB (now the San Francisco Bay Regional Water
Quality Control Board) reports that the SJ/SC discharge violated the SFB's
requirements every month from June to October 1966.
13 June 1967
The SFB sets water-quality standards (UQS) for tidal waters
inland from Golden Gate. Most of the WQS applicable to the sloughs near
SJ/SC are unspecific and phrased in terms of "present natural background
levels", "natural causes", and "natural factors". Although it is not
clear what these phrases mean, it is clear that Artesian Slough and Coyote
Creek cannot meet either the general or the specific WQS. However, the
SFB hedges the WQS by allowing exceptions for "natural" conditions and for
mixing zones. The DO standard, for example, was worded as follows:
»
"Minimum of 5 mg/1; when natural factors cause lesser
concentrations, then controllable water quality factors
shall not cause further reduction in the concentration
of dissolved oxygen."
This ambiguous standard was applied to SJ/SC on 21 March 1968 and 24 Novem-
ber 1970. The WQS were formally adopted in Resolution 67-30.
1968
CTA and Hydroscience produce a mathematical model of the southern
bay and its tributary sloughs. The modelers ignore the tides and changes
in volume, although the tidal range is nine feet in Coyote Creek, and the
bay south of Dumbarton Bridge loses most of its water between high and low
tide. The model is nothing like the reality, and the verification is
fudged. The modelers manipulated the "observed" data so that they would
fit the model, and thereby obscured diurnal DO variations of as much as
14 mg/1.
259
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The modelers computed that the southern bay could assimilate
17,000 Ib/day of UOD for a discharge into Artesian Slough, but could
assimilate about 300,000 Ib/day of UOD for a discharge one mile south of
Dumbarton Bridge. UOD is defined as "approximately 2.0 times the measured
five day BOD and about 4.5 times the oxygen demand of the measured ammonia
nitrogen". CTA's proofreader missed the mistake in this definition. CTA
probably meant "...about 4.5 times the measured ammonia nitrogen."
the modelers hedged the results. To meet WQS 90% of the time,
they wrote, it might be necessary to reduce the allowable discharge by
half or more. The SFB requires that WQS must be met 100% of the time.
21 March 1968
The SFB sets stricter requirements for SJ/SC. SJ/SC must not
cause oil slicks, oil deposits, oil suspensions, unnatural color or
turbidity, waste or plant odors, nuisance deposits, unsightly plant
growths, high bacterial concentrations, foam, "macroscopic particulate
material", or pH variations beyond certain limits in the receiving waters.
SJ/SC must remove 90% of its influent 20°-BOD . 75% of the test fish
must survive a 96-hour bioassay in undiluted effluent; 90% of the test
fish must survive in three consecutive bioassays. The SFB states that
it will enforce the DO standard set in Resolution 67-30 (5 mg/1 mimimum),
and will set stricter treatment requirements if necessary. The SFB
defines mixing zones for some of its requirements, but does not specify
where the DO standard applies. Resolution No. 68-11.
260
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16 July 1968
The SFB's staff releases a report on water quality in the south
bay during 1967. The DO near SJ/SC was always less than 5 mg/1, and less
than 2 mg/1 half the time.
August 1968
Engineering-Science, Inc. produces a report on the biology of
San Francisco Bay. It concludes (among other things) that removing
nutrients from STP discharges will not improve water quality, and that
DO concentrations have increased in Coyote Creek. The report is part of
the Bay-Delta study financed by the SFB and conducted by Kaiser Engineers.
December 1968
CTA recomputes assimilative capacities to account for the
5-mg/l DO standard imposed by the SFB in Resolution 67-30. CTA concludes
that the standard will not be met unless SJ/SC gives AWT and moves its
discharge several miles. CTA suggests that the SFB should lower its DO
standard to 4 mg/1 for Coyote Creek and some tributaries rather than
having SJ/SC move its outfall. It recommends that the STP should be
immediately enlarged to 160 mgd (1985 design year), and that a 1-mgd
pilot plant should be built to test AWT.
June 1969
Kaiser Engineers et al. publish their plan for wastewater
management in the areas around San Francisco Bay and the Sacramento-San
Joaquin Delta. They intend to control biostimulation and toxicity:
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"The proposed system is recommended as the only practi-
cable means for the Bay-Delta of preventing accumulation
of toxicants and biostimulants which will result in pro-
gressively increasing bias in the biological populations
and the associated drastic impairment of water quality."
Kaiser recommends reclamation of some wastewaters and ocean dis-
charge for the res-t. According to the plan, SJ/SC must pump its effluent
to a deep part of the bay by 1980 and to the ocean by 1985. The effluent
must get secondary treatment when it is discharged to the bay, but only
advanced primary treatment when it is discharged into the ocean.
Kaiser et al. developed three hydraulic and water-quality models
for the study, but did not give their predictions. Prepared for the
California State Water Resources Control Board.
1970
The U.S. Geological Survey publishes hydraulic studies of San
Francisco Bay. It concludes that the Sacramento River system controls
flushing in southern San Francisco Bay, and thereby affects both the
salinity and the accumulation of pollutants throughout the bay.
23 July 1970
The SFB finds that SJ/SC is violating its requirements for
"macroscopic particulate material or foam" and bacteria. The SFB does
not mention DO. SJ/SC is ordered to cease and desist according to a
schedule. Resolution No. 70-57.
September 1970
Engineering-Science recommends that the STPs in the south bay
should discharge their effluents north of .Dumbarton Bridge, rather than
leaving their outfalls where they are and going to the expense of AWT.
The study was prepared for Santa Clara County.
262
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24 November 1970
The SFB sets new and stricter requirements for SJ/SC. It allows
the STP virtually no mixing zone for DO, and adds the following rule
(which is from Resolution 67-30): "When natural factors cause lesser con-
centrations [i.e. DO less than 5 mg/1], then this discharge shall not
cause further reduction in the concentration of dissolved oxygen." Taken
at face value, .the rule means that SJ/SC must be able to produce an
effluent whose deoxygenation rate is less than the reaeration rate of the
receiving waters in other words, an effluent with almost no BOD.
SJ/SC must submit a subregional study by 1 January 1972 and must be in
compliance with these DO requirements by July 1978.
The SFB lowers the toxicity limit. 70% (rather than 75%) of the
test fish must survive any bioassay. Resolution No. 70-91.
June 1971
The SFB publishes its Interim Water Quality Control Plan, which
stresses the reuse of wastewater over treatment and discharge. The
Interim Plan describes the discharge of municipal sewage as "an interim
means for disposing of reclaimable wastewater until a feasible project
for reuse is developed". The SFB intends that "wastewaters will be
managed as part of an integrated system of fresh water supplies". Although
the SFB adopted some of the recommendations that Kaiser Engineers made in
1969, it rejected the plan for vast regionalization and ocean discharge.
263
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The SFB declares that it intends to exclude from the south bay
discharges "which have not had substantially all toxicants and biostimu-
lants removed". In the meantime, however, discharges that get less than
ten-to-one dilution must always contain less than 10.0 mg/1 of 20°-BOD-
and less than 5.0 mg/1 half the time. No discharge is allowed within 200
feet of the extreme low-water line.
The DO standard is changed. There is an annual-median require-
ment (80% of saturation) as well as a minimum; both apply only to the
"main body of the tidal waters".
October 1971
Esvelt et al. (University of California) report on the toxicity
of STP effluents in the Bay Area. Nearly all the test fish survive 96
hours in unchlorinated effluent from activated-sludge STPs. However,
chlorinated effluents are very toxic. Esvelt et al. conclude that chlorin-
ated STP effluents may be the largest single source of toxicity entering
San Francisco Bay. Prepared for the State Board.
23 November 1971
The SFB orders SJ/SC to cease and desist from violating its
toxicity requirement. SJ/SC must discover and eliminate the causes of
the violation. It must also report on the feasibility of reducing its
ammonia discharge. Order No. 71-78.
February 1972
Hydroscience publishes another water-quality model. Like the
last (1968), it is far removed from reality. It ignores tides and the
immense tidal prism. It assumes away reverse flow south of Dumbarton
264
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Bridge. It depends on guesses for the major reaction rates: deoxygena-
tion, reaeration, and sediment oxygen demand.
Worst of all, the model is inappropriate. It was designed to
predict mean concentrations, but the SFB requires minimum and median DO
concentrations. Hydroscience claims that the minimum DO is usually within
0.3 mg/1 of the mean DO, but south of Dumbarton Bridge the area of
interest it usually is not, and the data published with the 1968 model
show that it is not.
Nevertheless, Hydroscience predicts that the bay could assimilate
32,000 Ib/day of UOD (undefined) during the 1980 dry season and 12,000
Ib/day during the wet season from a discharge at the confluence of Artesian
Slough and Coyote Creek. Hydroscience also predicts that the bay could
assimilate 81,000 Ib/day during the 1980 dry season and 64,000 Ib/day
during the wet season from a discharge about one mile north of Dumbarton
Bridge.
Hydroscience warns of algal blooms and mentions that SJ/SC may
someday have to remove nitrogen from its effluent.
March 1972
Consoer-Bechtel publishes a plan for regionalizing the South Bay
STPs. It recommends enlarging and improving some of the existing STPs and
pumping the effluents to a common discharge, a submerged outfall about one
mile north of Dumbarton Bridge. It recommends that SJ/SC should provide
140 mgd of AWT (nitrification and effluent filtration) by 1976. Prepared
for the South Bay Dischargers (SJ/SC, Sunnyvale, Palo Alto, Menlo Park,
Union Sanitary District, and Livermore).
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30 June 1972
P.L. 92-330 becomes law. It authorizes the Secretary of the
Interior to develop the San Francisco Bay Wildlife Refuge in the marshlands
bordering the south bay. The Secretary may acquire up to 23,000 acres; he
may spend up to $9 million for land acquisition and up to $11.3 million for
developing the refuge.
22 August 1972
The SFB orders SJ/SC, Palo Alto, Los Altos, Mountain View,
Sunnyvale, and Milpitas Sanitary District to proceed with their plans for
regionalization because they are violating a prohibition from the Interim
Plan (June 1971). They are discharging within 200 feet of the extreme
low-water line. Order No. 72-62.
October'1972
Brown and Beck complete A Study of Toxicity and Biostimulation
in San Francisco Bay - Delta Waters. They recommend that toxic units
(rather than species diversity) should be used to measure the effects of
STP discharges on the receiving water. They recommend that the regional
boards should set a receiving-water criterion of 0.04 toxic unit (approxi-
mately 97% survival in undiluted sample), and should limit the toxicity of
STP discharge accordingly. Prepared for the State Board.
20 November 1972
SJ/SC is included in the SFB's Municipal Project List as a
Group I project with an estimated eligible cost of $140 million.
266
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May 1973
Stone et al. (University of California) report that Aufwuchs
are affected by waters containing 0.05 to 0.12 toxic unit; they conclude
that 0.04 toxic unit (the criterion recommended by Brown and Beck) is a
reasonable limit. Prepared for the State Board.
December 1973
Bechtel publishes an environmental impact report for several
modifications of the Consoer-Bechtel plan. It recommends consolidating
four STPs into three and pumping the effluents to a common outfall about
one mile north of Dumbarton Bridge. The outfall project alone is estimated
at $55 million. SJ/SC should provide 143 mgd of secondary treatment and
effluent filtration, and 95 mgd of nitrification (design year 1985).
Bechtel is uncertain about the amount of nitrification because 95 mgd
might not be sufficient to meet the toxicity standard.
Bechtel is also uncertain about future requirements. The SFB's
staff are considering a chlorophyll-a_ limit of 50 ug/1 and a chronic-
toxicity limit of 40 ml/1 (0.04 toxic unit). An unnamed consultant to
the State Board (perhaps Bechtel itself) had recommended lowering the
median-DO standard, limiting un-ionized ammonia, banning discharges that
contain free chlorine, and setting specific criteria for toxicants (rather
than, a general "relative toxicity" criterion); but the State Board has
not acted on the recommendations. Bechtel reports that EPA has not pr^o-
posed 1983 BPWTT limits, but that EPA is considering effluent limits,of
50 mg/1 of COD and Ultimate Combined Oxygen Demand (1.5 times the BODj
plus 4.6 times the ammonia nitrogen minus the DO). Note that EPA had in
fact proposed BPWTT limits on 3 October 1973 for both UOD (Bechtel's
267
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Ultimate Combined Oxygen Demand) and Ultimate BOD (1.5 times the BODj
minus the DO). An STP with an influent that for thirty days is always
warmer than 20°C must discharge less than 50 mg/1 of UOD during those
days; at all other times the discharge must contain less than 30 mg/1 of
Ultimate BOD. Bechtel's plan could satisfy most of these requirements
without many changes.
Prepared for the South Bay Dischargers Authority (SJ/SC,
Sunnyvale, and Palo Alto).
17 December 1973
SJ/SC reports to the SFB on its program to control the toxicity
of industrial wastewaters. After two years, many of the industries are
still not in compliance. Letter from A.R. Turturici (Director of Public
Works, San Jose) to Fred H. Dierker (Executive Officer, SFB).
February 1974
CTA publishes the AWT-facilities plan for SJ/SC. Like Bechtel
(December 1973), CTA recommends 143 mgd of secondary treatment and effluent
filtration, but is uncertain about nitrification. 94 mgd of nitrification
would meet the effluent-UOD limit calculated by the 1972 Hydroscience
model, but might not meet the SFB's effluent.toxicity requirement. CTA
reports that bioassays run on secondary and AWT effluent have been incon-
clusive.
February 1974
CTA reports that heavy rains can cause substantial inflows into
SJ/SC sewers, but that infiltration is minimal or nonexistent. Prepared
for SJ/SC.
268
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1 March 1974
Bechtel publishes its Overview Facilities Management Plan.
Bechtel is still uncertain about the sizing of nitrification facilities
and about future requirements. Bechtel continues to report that EPA has
not proposed BPWTT limits.
However, Bechtel contends that the SFB's proposed "relative
toxicity" criterion is technically unsound. Here are some of Bechtel's
arguments:
The criterion requires measurements of acute toxicity beyond
the reliable range of the test.
Brown and Beck's (October 1972) data show that the toxicity
of municipal effluents is caused by biodegradable components
(chlorine, ammonia, and MBAS), and that there is no correla-
tion between biodegradable components and "the Benthic Animal
Species Diversity Index, which Kaiser (June 1969) assumed as
an appropriate measure of the biological health of the bay.
The 0.04 toxicity limit is unjustified. Brown and Beck's
data are inconclusive. Besides, the State Board has not
specified the test species, even though the bioassay results
must vary with the test species.
There is no mention of other sources of toxicants, such as
urban runoff.
The toxicity tests indirectly measure chlorine, ammonia,, and
MBAS, which can be measured directly and reliably.
Prepared for the South Bay Dischargers Authority.
269
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16 May 1974
The State Board approves the Water Quality Control Policy for
the Enclosed Bays and Estuaries of California, which bans discharges to
San Francisco Bay south of Dumbarton Bridge. Resolution No. 74-43.
7 June 1974
The new secondary facilities at SJ/SC are dedicated.
14 June 1974
Brown & Caldwell et al. publish a preliminary draft of several
models developed for the State Board. The water-quality model is not
calibrated to the southernmost end of the bay, and the ecologic models
are not properly calibrated, owing to a shortage of data.
16 August 1974
Jesse M. Diaz (State Board) briefs A.R. Turturici (San Jose)
about a meeting to consider consolidating the Sunnyvale STP with SJ/SC.
The decision will be made sometime in the future.
23 August 1974
Keith Kraft and Emanuel H. Pearl (Santa Clara County Health
Department) report on the recurring problem of toxic discharges from
San Jose storm sewers, which cause fishkills. They contend that the SFB
agreed to set discharge requirements for the storm sewers in 1969, but
has riot yet set them.
15 September 1974
Pearl asks the SFB to specify requirements in the SJ/SC discharge
permit for controlling storm-sewer discharges. He suggests that inadequate
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capacity or inadequate maintenance of the sanitary sewers may be responsi-
ble for the discharges.
31 October 1974
Fred H. Dierker (SFB) recommends that the State Board should
fund the SJ/SC AWT facilities, "based on provision of 137.5 mgd nitrifica-
tion capacity (10 years growth and average dry weather flow) and 176 mgd
(peak dry weather flow) for other flow'rated facilities". CTA and Bechtel
had recommended either 94 mgd or 143 mgd of nitrification, and 160 mgd.of
secondary treatment.
19 November 1974
The SFB's staff prepare a tentative permit, NPDES No. CA0037842,
for SJ/SC. The permit limits the monthly average effluent BOD to 5 mg/1,
r
the monthly average SS to 10 mg/1, and the 3-month average dry-weather
flow to 160.0 mgd. There are no effluent limits on ammonia or UOD. The
permit changes the toxicity limit set by Resolution No. 70-91 (24 November
1970). It increases SJ/SC's responsibility for the quality of the receiving
waters. It requires SJ/SC's outfall to be moved.
The BOD limit is a variant of the effluent limits set in the
Interim Plan (June 1971), which required (1) a median (not average) BOD
of 5 mg/1, and (2) a maximum BOD of 10 mg/1 for effluents that get less
than ten-to-'one dilution. The SJ/SC discharge, which must be pumped north
of Dumbarton Bridge, will get much more than ten-to-one dilution. From
the tidal volumes presented by McCarty et al. (June 1962), we calculate
that the flow past Dumbarton Bridge for the six hours between mean high
tide and mean low tide is seventeen billion gallons. At its 1985 design
-------
capacity of 143 mgd, SJ/SC's discharge would average less than 36 million
gallons in six hours. SJ/SC's discharge would get almost five-hundred-to-
one dilution. The new BOD and SS limits are therefore unjustified.
The toxicity limit is relaxed. The new limit requires "a 90
percentile value of not less than 70% survival for 10 consecutive samples",
i.e. it allows for an occasional toxic discharge. Note that the SF8 pro-
hibited these allowances in the Interim Plan: "The quality of all waters
in the Basin is to be continuously protected from the adverse effects of
controllable water quality factors" (emphasis in original).
There are new receiving-water limits, but they apply only to the
top twelve inches of the water column. SJ/SC must not cause the pH to vary
from the "natural ambient pH" by more than 0.2 units, or cause the concen-
tration of non-dissociated ammonium hydroxide to be more than 0.025 mg/1.
20 November 1974
The State Board approves the plan for AWT at SJ/SC. It certifies
that 137.5 mgd of nitrification facilities and 176 mgd of secondary and
filtration facilities are grant eligible. Letter from Larry F. Walker to
A.R. Turturici.
2 December 1974
Turturici (SJ/SC) asks the SFB to reconsider (1) its effluent-
BOD limit of 5 mg/1 (because the facilities were designed to produce a
10-mg/l effluent) and (2) its ban on discharges south of Dumbarton Bridge
(because the California Department of Fish and Game wants freshwater near
the wildlife refuges).
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3 December 1974
Hossain Kazemi (SFB) agrees that the BOD limit should be raised,
because "BOD is not a controlling factor at the north of Dumbarton Bridge".
4 December 1974
William H. Pierce (EPA) transmits EPA's comments on the SJ/SC
permit to the State Board. EPA thinks that SJ/SC should have an effluent-
ammonia limit. ,
6 December 1974
The SFB issues a final NPDES permit to SJ/SC. The BOD limit is
raised to 10 mg/1, but the SFB does not alter the effluent limits on SS
and toxicity, the receiving-water limits on pH and non-dissociated
ammonium hydroxide, and the prohibition of discharges south of Dumbarton
Bridge. The final NPDES permit does not limit effluent ammonia or UOD.
Order No. 74-168.
9 December 1974
Richard J. Hee (California Department of Health) certifies that
the final NPDES permit will adequately protect the public health. He has
reviewed it with the Santa Clara County Health Department.
10 December 1974
Dierker (SFB) asks Turturici (SJ/SC) to report on surveillance
of the storm and sanitary sewers.
1975
Dechlorination facilities are installed at SJ/SC. '
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5 February 1975
The San Jose Department of Public Works sends the San Jose City
Advisory Board of Health a report on its sewer-maintenance program. The
Department maintains approximately 1,000 miles of storm sewers and 1,400
miles of sanitary sewers. The department admits that its maps are inade-
quate, but it plans to improve them and to improve sewer surveillance.
7 March 1975
Frank M. Belick (Engineer-Manager of the SJ/SC STP) reports to
the SFB on controlling toxic substances from industrial wastewaters.
21 March 1975
Belick (SJ/SC) reports to the SFB on emergency plans for process
failures, equipment failures, collection-system failures, power outages,
earthquakes, fires, floods, employee strikes, strikes by suppliers of
chemicals, and other unscheduled difficulties.
April 1975
The California Department of Health issues criteria for reclaimed
wastewater.
April 1975
The SFB publishes its basin plan.
The WQS have again been revised. The minimum-DO standard (5 mg/1)
has been kept, but the annual-median-DO standard has been changed to a
complicated lower-tenth-percentile requirement that depends on temperature,
chlorides, and classification by the SFB. There is a new ammoniacal-
nitrogen standard: 0.025 mg/1 annual median, and 0.4 mg/1 maximum.
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A variant of the toxicity criterion proposed by Brown and Beck (October
1972) and opposed by Bechtel (1 March 1974) is included in the basin plan
1
as a planning criterion not as a WQS. The "toxicity concentration"
of the water is calculated from the "toxicity concentrations" of effluents,
which are calculated from one of several formulas, depending on bioassay
results. The SFB proposes to limit "toxicity concentrations", to 0.03-0.10
toxic units for waters that receive effluents.
The SFB modifies its discharge prohibition. It may allow dis-
charges south of Dumbarton Bridge "where it can be demonstrated that a net
environmental benefit will be derived from such a discharge."
The South Bay ranks first on the SFB's priority list, and is
classified Water-Quality Limited. To the SFB, the South Bay lies between
Coyote Creek and an Imaginary line about two miles south of San Mateo
Bridge; other agencies use "South Bay" to mean something else. Coyote
Creek and Artesian Slough, which were not ranked, are classified Effluent
Limited.
The SFB estimates that the assimilative capacity of South Bay
is 140,000 Ib/day of UOD (1.5 times the BOD5 plus 4.6 times the ammoniacal
nitrogen) for a discharge near Dumbarton Bridge. Note that Hydroscience
(February 1972) calculated 81,000 Ib/day during the dry season and 64,000
Ib/day during the wet season. The SFB used a tldally averaged model to
compute DO concentrations for various effluent loads, then estimated the
load that would maintain the DO above 6.0 mg/1 the applicable lower-
tenth-percentile standard (5.7 mg/1) plus a safety factor (0.3 mg/1).
The model, a variant of the model developed by Brown & Caldwell et al.
(June 1974), can compute only tidal averages, not lower tenth percentiles.
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Not enough is known to predict DO variations accurately within a total
cycle and over many tidal cycles. SFB's model cannot legitimately deter-
mine the assimilative capacity of the South Bay.
The SFB allocates 100,000 Ib/day of UOD for all municipal and
industrial discharges into the South Bay. The SFB also endorses the
Dischargers Authority's plan for three separate AWT plants and a joint
outfall. The STPs must nitrify at least 40% of their 1985 design flow
(150 mgd) to meet the wasteload allocation. Nitrification would probably
be unnecessary if the pipeline were extended north to the San Mateo Bridge.
The pipeline can be modified to transport effluent to markets in the south
in the future. However, the SFB will not approve a wastewater-reclamation
scheme until more is known about the health hazards of AWT effluent.
13 May 1975
Dave Block (SFB) inspects SJ/SC. He finds that it is violating
its chlorine-residual requirement and many other permit conditions. The
self-monitoring reports are inadequate. The oil-and-grease analyses are
not approved by EPA. Influent, effluent, and flow-sampling stations are
improperly located. Some grab samples should be composites, and some
composites grabs. BOD samples are refrigerated too long.
5 June 1975
EPA offers San Jose $52,732,500 for AWT facilities for SJ/SC.
San Jose accepts on 26 June 1975. Grant No. C-0947.
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26 November 1975
Representatives of EPA, SFB, the State Board, the Dischargers
Authority, the Leslie Salt Company, and Bechtel meet to consider dis-
charging wastewater from Leslie Salt through the Authority's proposed
outfall. They agree that Bechtel should include Leslie Salt in the
environmental-impact statement (EIS) on the outfall that Bechtel is pre-
paring for the Authority and EPA. Recorded by C.M. Harper (Bechtel).
December 1975
Hydroscience publishes another mathematical model. Like the
last (February 1972), it is a mosaic of oversimplification and guesswork.
Hydroscience extends this model into the tributaries of Coyote Creek and
the South Bay, and tries to estimate the water-quality effects of the
marshes surrounding the south bay. Unfortunately, the data are thin and
nearly a decade old. Hydroscience admits that the model is insufficiently
verified.
The model can predict only mean values, so Hydroscience tried
to derive both the minimum DO and the lower-tenth-percentile DO from the
predicted mean DO. These new calculations educed startling new conclu-
sions. Hydroscience now claims that the plan for AWT and discharge*north
of Dumbarton Bridge will not work. This was the plan that Hydroscience
recommended in 1972, that was adopted by the Dischargers Authority,
approved by the SFB and the State Board, and that was crowned with a
$52,732,.500 grant from EPA. Hydroscience now claims that this plan will
.1
cause violations of both the minimum and lower-tenth-percentile DO
standards. Each of the four plans Hydroscience investigated will cause
violations of both DO standards. Hydroscience attributes much of the
277
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blame to oxygen-demanding substances from the marshes, though little is
known about the marshes.
Prepared for Bechtel as part of the outfall EIS.
1975
EDAW, Inc. of San Francisco prepares a comprehensive plan
(under contract to the U.S. Department of the Interior) for developing
I
the San Francisco Bay National Wildlife Refuge at the south end of the
bay. Brochures describing this comprehensive plan are widely distributed.
1976
Galley proofs, of EPA1s preliminary Draft Environmental Impact
Statement. South Bay Dischargers Authority Treated Wastewater Disposal
Program are distributed to the planning agencies. The Draft EIS summarizes
the predictions of the Hydiroscience model and describes the planning
choices; it recommends the joint-outfall project, but does not rule out
several other choices. The outfall project alone is now estimated at
about: $80 million.
The Draft EIS dwells on the problems that will arise in the
sloughs at the south end of the bay once the outfall has been relocated
4
north of Dumbarton Bridge:
"Over the years of operation of the San Jose/Santa Clara
treatment plant outfall in Artesian Slough, a unique
freshwater floral and faunal association has developed
throughout much of its length. When the pipeline goes
into operation, the discharge of wastewater to the slough
will cease under all but emergency bypass conditions,
resulting in an increase in the salinity of the slough
system. Within a few years, the cattail and bulrush
marshes will die back and be replaced with more salt
tolerant forms. Eventually, a salt marsh should develop
along the slough banks and on the islands in the lower
portion. During this transition, the addition of dead
278
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plant material to the organic load in the sediments and
the water, combined with a marked reduction o,f flushing
action in the summer, may result in a depletion of dis-
solved oxygen, causing the sediments in the entire slough
system to become anaerobic, perhaps for months or more at
a time. This anaerobiosis, along with changes in salinity,
may result in aggravation of current problems with water-
fowl botulism in the South Bay. The change in plant
communities will not only eliminate roosting places for
herons and egrets and nesting places for freshwater marsh
birds and mammals, but may also significantly damage the
benthic community on the in-slough mudflats. Until this
ecological system can restablize, its value to wildlife
will be much reduced from its present level. The 'value1
of the expected new saline environment cannot be directly
compared to the existing system; a decrease in habitat
diversity in the wildlife refuge is the primary impact
:expected."
The Draft EIS also recapitulates the weaknesses in the Hydro-
science model.
Having admitted to .so many .problems, the Draft EIS generated a
great deal of disagreement among the reviewing agencies.
January 1976
The .Technical Advisory Committee of the Dischargers Authority
suggests that the :SFB should postpone banning discharges south of Dumbarton
Bridge for five years. During these.five years, the SFB should assess the
effects of AWT-.effluent and decide whether to maintain brackish-water
ecology in the .south bay.
10 January 1976
EPA reports that the canneries in the SJ/SC service area want
the AWT construction postponed. The canneries protest that the user
charges (which San Jose published on 6 November 1975) are unfair because
most of the AWT facilities will be used to remove ammonia, though cannery
279
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wastes contain little ammonia. The high user charges may force some of
the canneries to close. The canneries question the need for upgrading
treatment; they believe that the WQS are too strict.
26 February 1976
F. Wayne Pierson (State Board) writes to Charles Campbell
(EPA-Region IX) about Hydroscience's model (December 1975) of the south
bay. He criticizes the model for its assumptions about marsh loads,
mixing, and tidal effects; for its estimates of reaction rates; and for
its lack of specificity, its questionable calibration, and its lack of
verification:
"1. A steady state model was used to make predictions of
water quality variables in the South Bay and a stochastic
interpolation was done to provide information, about effects
of time varying influences. First, stochastic prediction,
as compared to deterministic prediction, does not take into
consideration the irreversibility of death or significant
damage to living organisms. Second, the stochastic inter-
polation done by Hydroscience assumed a linear variability
with respect to a parameter, i.e., they assumed effects were
additive. This is a very limiting assumption....
"2. An a priori assumption was made in setting up the model
for the South Bay that the Bay and sloughs were well mixed
systems. However, ,no discussion was presented by Hydro-
science to justify this assumption. It is difficult to
estimate the validity of such an assumption with no informa-
tion.
"3. [Hydroscience] ... treated toxicity as though it were
a physical variable. It was predicted using a quasi-
conservative species equation and the predictions were
presented without adequate qualifications.... At best the
toxicity results;should be used qualitatively where only
order of magnitude changes are considered as having any
significance.
"....5. It is understood that the reaction rate constants
were derived from intuitive estimations and [were] not
based on factual data....
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"6. Serious concern is felt with regard to the calibration
of the model with only one data set (June, 1967) for non-
conservative substances. A series of verification runs
(minimum of two under different hydrologic conditions)
should be made to substantiate the definitions of the
model's components....
"....8. .... [F]urther quantification of diffuse source
loadings (marshes) is required, especially since it has
been theorized that these (marsh loadings) are the sig-
nificant cause for poor water quality in the South Bay.
Stating the assumption that the marsh loadings do not
vary temporally or spatially is one which leads towards
weaknesses in simulating these regions.... Further, if
in fact it turns out that the marsh loading is not that
significant, one is lead [sic] to believe that either
an undefined or an improperly defined variable needs to
be accounted for, thus possibly negating much of the
existing work."
These objections are well taken. They could have been applied
even more forcefully to all the earlier models: Brown & Caldwell
(December 1959), CTA & Hydroscience (1968), CTA (December 1968), Kaiser
Engineers (June 1969), Hydroscience (February 1972), Brown & Caldwell
(14 June 1974), and the SFB (April 1975). Hydroscience's 1975 model was
an improvement over all these earlier attempts.
One suspects that the 1975 Hydroscience model prompted an
official reaction because.it showed that the south bay would be in viola-
tion, of WQS no matter what SJ/SC might build. When the models showed
that construction could solve a problem, they were accepted at face value.
However, when the 1975 model showed that no amount of construction would
work, State officials began to examine the model for unwarranted assump-
tions, inadequate verification, and skimpy data. This belated discovery
of weaknesses in mathematical models has been costly. In San Jose alone,
the costs will exceed $160 million: $64 million for the AWT plant,
281
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$80 million for the outfall project, and $21 million for additional sludge-
management facilities.
28 April 1976 " f
The planning agencies state their positions on the outfall pro-
ject during a meeting of the Dischargers Authority. The Authority and the
Santa Clara Public Health Department favor a delay so that the Hydroscience
model can be properly verified, the effects of AWT discharges can be
measured, and so that a reclamation project might be implemented. The SFB
and the Bay Area Sewage Services Agency support verification of the model,
but they oppose eliminating the outfall project. The State Board is con-
cerned that Federal grants might not be available in the future. The
0
California Department of Fish and Game agrees that the model must be
verified. The U.S. Bureau of Reclamation feels that wastewater reclamation
will be required by the year 2020. The Association of Bay Area Governments
(the "208" planners) defers judgment for 12-18 months until it has completed
a study.
July 1976
The State Board publishes effluent-bioassay guidelines prepared
by Fredric R. Kopperdahl .(California Department of Fish and Game).
Kopperdahl tentatively recommends rainbow trout (Salmo gairdneri) and
golden shiner (Notemigonus crysoleucas) as acceptable test species.
8 July 1976
EPA decreases the grant to $48,214,740, owing to low bids.
San Jose accepts on 20 August 1976.
282
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23 July 1976
E.L. Mitchell (President, Santa Clara County Canners Association)
contends that AWT will have little effect on water quality in the south
bay because of two uncontrolled sources of oxygen demand: the marshes
and the sediments. Furthermore, the AWT plant will use a huge amount of
power, more than all the canneries in the service area. The power demands
alone, he feels, make the project environmentally harmful.
17 August 1976
EPA offers SJ/SC a Step 1 grant (No. C-1381) to provide facili-
ties for sludge management. The target date for Step .3 is January 1979.
The total grant-eligible costifor additional sludge-handling facilities
is estimated at $21.2 million. The proportion of these facilities that
must be attributed to sludge produced by AWT facilities (nitrification
and final filtration) is not known yet, but will be determined as part of
the Step 1 work.
10 November 1976
DO in Artesian Slough and Coyote Creek falls below 2 mg/1,
according to SJ/SC analyses. Note that this low DO occurred after the
canning season, well into the autumn, when the water was not especially
warm. Despite all the planning and all the money spent to improve the
STP, SJ/SC still violates Resolution No. 48 of the SFB (15 March 1951),
which prohibits the STP from lowering the DO of Coyote Creek below 2 mg/1
near the point of discharge.
283
-------
23 February 1977
Dierker (SFB) informs SJ/SC that it is violating its permit
because its composite samples are not flow-proportional, its ovens are
not set to the correct temperatures, and it uses unapproved laboratory
methods.
15 March 1977
The SFB joins F. Wayne Pierson (26 February 1976) in criticizing
the 1975 Hydroscience model. Among the principal shortcomings of the
model, the Board notes especially the doubtful data base, the unwarranted
hydraulic simplifications, the gross assumptions on the nature and extent
of marsh loadings, and the inadequate verification. In short, "before the
conclusions of a large number of earlier studies are considered to have
been refuted, the questionable aspects of the Hydroscience model shouldfbe
clarified."
Like the State Board, the SFB uncritically accepted the results
of earlier studies, which concluded that there should be no wastewater
discharges south of Dumbarton Bridge. However, the SFB notes that
"This conclusion was based on the assumption that the treated
municipal wastewater was the main source of oxygen demand,
toxicity, pathogens, biostimulants and floatables in the
South Bay. The results of the Hydroscience modelling directly
contradict some conclusions and assumptions of the previous
studies. ...[T]he conclusions of the [Hydroscience] modelling
are that removal of the discharge from the South Bay would
cause minimal DO improvement in the main portion of the
South Bay and that removal of the discharges, with their
accompanying flushing action, from the extremities of the
sloughs where discharge now occurs would severely depress
DO levels in those areas."
284
-------
The SFB could scarcely be expected to rejoice in Hydro science's new con-
clusion, viz. all previous planning for the south bay has been fundamen-
tally wrong. For the first time, the SFB has critically examined a
mathematical model of the south bay, and it is found wanting. Had the
SFB been equally critical of the earlier models and studies, it might
never have gotten into its present fix.
1977
450 acres are now under Government control in the San Francisco
Bay National Wildlife Refuge. Final negotiations are underway with the
Leslie Salt Company to acquire another 13,000 acres around the south bay.
November 1977
The final Draft EIS on the outfall project is scheduled for
completion.
August 1978
AWT facilities at SJ/SC are scheduled to be in operation.
285
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8.3 BIBLIOGRAPHY
ANON (1970). Recommended expansion program. An extract from a longer
report (unidentifled), marked "Chapter VI, exhibit no. 2." «
The "exhibit" accompanies a letter from T.W. Fletcher (City
Manager, San Jose) to the San Francisco Bay Regional Water
Quality Control Board (Oakland). Available from R. Robert
Scholar, The Board, Oakland CA. "Chapter VI, exhibit no. 2,"
is paginated 39-58.
ASSOCIATION OF BAY AREA GOVERNMENTS (April 1976). Work program summary:
environmental management plan. Berkeley: The Association.
47 pp. +3 pocket maps.
BECHTEL INC. (December 1973). Environmental impact report, overall
program for water quality management in south San Francisco
Bay, South Bay Dischargers Authority. Draft. San Francisco CA:
Bechtel Inc. 5 parts + appendices A-D (comprising part VI).
Idem (1 March 1974). Overview facilities management plan, water pollution
control facilities in south San Francisco Bay, South Bay Dis-
chargers Authority. No publication details. 10 sections +
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287
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Frank M. BELICK (January 1959). First-year experiences at San Jose CA.
Sewage and industrial wastes .31(1): 100-104.
Idem (17 December 1973). Letter to Fred H. Dierker (Executive Officer,
San Francisco Bay Regional Water Quality Control Board), dis-
cussing SJ/SC's program to control industrial waste. The letter
includes summaries of industrial waste inspections and bioassay
results. The letter is written in compliance with Order no.
71-78. 7 pp. Obtained from the files of the Board, file no.
2189.8014, folder #18. Oakland: The Board.
Idem (22 October 1974). Letter to Fred H. Dierker (Executive Officer,
San Francisco Bay Regional Water Quality Control Board). Belick
(Engineer-Manager, SJ/SC STP) submits the STP's industrial-waste
report for September 1974. Obtained from the Board, file
#2189.8014, folder #18, Oakland CA.
Idem (30 December 1974). Letter to Fred H. Dierker. Belick submits the
STP's industrial-waste report for October 1974. Obtained from
the Board, file #2189.8014, folder #19, Oakland CA.
Idem (7 March 1975). Letter to Fred H. Dierker. Belick submits the STP's
industrial-waste report for February 1975. Obtained from the
Board, file #2189.8014, folder #19, Oakland CA.
Idem (21 March 1975). Letter to Fred H. Dierker. Belick reports on
emergency plans for the STP. Obtained from the Board, file
#2189.8014, folder #19, Oakland CA.
288
-------
Idem (31 January 1977). Letter to Fred H. Dierker. Belick submits SJ/SC's
discharge-permit application. Obtained from the Board, file
#2189.8014, folder #22, Oakland CA.
Randall L. BROWN & Louis A. BECK (October 1972). A study of toxicity and
biostimulation in San Francisco Bay-Delta waters, volume I,
summary report. California State Water Resources Control Board
publication 44. Sacramento CA: The State Board. 81 pp + 1 app.
BROWN & CALDWELL ENGINEERS (May 1958-December 1959), San Jose Sewage
Treatment Study. Prepared for the City of San Jose. San
Francisco CA: Brown & Caldwell. 150 pp. plus 7 appendices.
Idem (May 1975). San Francisco Bay area municipal wastewater solids
management study. Walnut Creek CA: Brown & Caldwell. 76 pp.
+ refs.
BROWN & CALDWELL et al. (14 June 1974). Preliminary draft: water quality
and ecologic models of the San Francisco Bay Delta [sic] system.
Prepared for the California State Water Resources Control Board.
No publication information. 6 chapters.
Arthur Grant BURTON (January 1972). Sediment sulfide concentrations in
relation to estuarine benthic macroinvertebrates of south San
Francisco Bay. Master of Arts Thesis, San Francisco State
College. 78 pp.
289
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CALIFORNIA DEPARTMENT OF WATER RESOURCES (August 1967). Evaluation of
ground water resources, south bay. Appendix A: Geology.
Bulletin no. 118-1. Sacramento CA: The Department. 153 pp.
+ 14 plates.
CALIFORNIA STATE WATER RESOURCES CONTROL BOARD (March 1969). Final report,
abridged preliminary edition: San Francisco Bay-Delta water
quality control program. Sacramento (?): The State Board.
12 chapters + foreword.
Idem (April 1971). Clean Water for San Francisco Bay. Sacramento CA:
The State Board. 17 pp.
Idem (June 1975). Annual state strategy, fiscal year 1975-76. Sacra-
mento CA: The State Board. 108 pp. , '
Charles H. CAMPBELL (10 January 1976). Meeting report: economic impact
of south bay pollution control projects on Santa Clara Co.
canners. Obtained from the San Francisco Bay Regional Water
Quality Control Board, file #2189.8014, Oakland CA. 6 pp.
T.J. CONOMOS et al. (1970). Movement of seabed drifters in the San
Francisco Bay estuary and the adjacent Pacific Ocean. In: A
preliminary study of the effects of water circulation in the
San Francisco Bay estuary. U.S. Geological Survey Circular
637-A,B. Washington DC: USGS. 8 pp.
290
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CONSOER-BECHTEL (March 1972). Water quality management plan for south
San Francisco Bay. Final report. Prepared for South Bay
Dischargers. Mo publication details. 2 volumes: vol. 1 in
13 sections, vol. 2 contains appendices A-I.
Idem (April 1972). Water quality management plan for south San Francisco
Bay. No publication details. 8 sections + area map in pocket.
CONSOER, TOWNSEND & ASSOCIATES, CONSULTING ENGINEERS (November 1966).
Report on effluent quality discharged to Artesian Slough, south
San Francisco Bay (1966 canning season), San Jose - Santa Clara
water pollution control plant. San Jose CA and Chicago IL:
Consoer, Townsend.
Idem (July 1967). Engineering report on sludge solids handling and dis-
posal for the San Jose - Santa Clara water pollution control
plant. Chicago IL and San Jose CA: Consoer, Townsend. 137 pp.
+ 1 appendix.
Idem (1968). A comprehensive study of the waste treatment requirements
for the cities of San Jose and Santa Clara and tributary agencies,
phase 1, assimilative capacity of south San Francisco Bay. San
Jose CA and Chicago IL: Consoer, Townsend. 140 pp.
Idem (1968). A comprehensive study of the waste treatment requirements
for the cities of San Jose and Santa Clara and tributary
agencies. Summary report, master plan for water pollution
control facilities. San Jose CA and Chicago IL: Consoer,
Townsend. 33 pp.
291
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Idem (December 1968). A comprehensive study of the waste treatment re-
quirements for the cities of San Jose and Santa Clara and
tributary agencies, phase II, master plan for water pollution
control facilities to the year 2000. San Jose CA and Chicago IL:
Consoer, Townsend. 83 pp.
Idem (January 1974). Draft environmental impact report for San Jose -
Santa Clara water pollution control plant advanced waste
treatment facilities. San Jose CA: Consoer, Townsend. 62 pp.
Idem (February 1974). Advanced waste treatment facilities project report
for the cities of San Jose and Santa Clara. San Jose CA:
Consoer, Townsend. 96 pp. + figures and appendix.
Idem (February 1974). Sanitary sewer infiltration/inflow analysis for
the cities of San Jose and Santa Clara and tributary agencies.
San Jose CA: Consoer, Townsend. 9 chapters + appendix.
Idem (April 1974). Engineering report on sludge solids handling and
disposal for the cities of San Jose and Santa Clara. San Jose CA:
Consoer, Townsend. 88 pp. +6 appendices.
Idem (September 1974). Environmental impact report, follow-up materials
for San Jose - Santa Clara water pollution control plant
advanced waste treatment facilities. San Jose CA: Consoer,
Townsend. Approx. 50 pp.
292
-------
Jesse M. DIAZ (16 August 1974). Letter to A.R. Turturici (Director of
Public Works, San Jose). Diaz (WQC Engineer, Division of
Water Quality Control, State Water Resources Control Board,
Sacramento CA) briefs Turturici about a meeting to consider
consolidating the Sunnyvale SIP with SJ/SC. Obtained from the
desk file of R.R. Scholar, San Francisco Bay Regional Water
Quality Control Board, Oakland CA.
Fred H. DIERKER (31 October 1974). Memo to Jesse Diaz (State Water
Resources Control Board, Sacramento CA). Dierker (Executive
s
Officer, San Francisco Bay Regional Water Quality Control Board)
recommends that the State Board should fund the SJ/SC AWT facili-
ties. Obtained from the desk file of R.R. Scholar, the Board,
Oakland CA.
Idem (10 December 1974). Letter to A.R. Turturici (Director of Public
Works, City of San Jose). Dierker asks Turturici to report on
surveillance of the storm and sanitary sewers. Obtained from
the Board, file # 2189.8014, folder #19, Oakland CA.
Idem (23 February 1977). Letter to Frank M. Belick (Engineer-Manager,-
SJ/SC STP). Dierker informs SJ/SC that it is violating its
permit. Obtained from R.R. Scholar, the Board, Oakland CA.
293
-------
ED AW, INC. (1975). San Francisco Bay National Wildlife Refuge. Unpagina-
ted brochure prepared for the U.S. Bureau of Sport Fisheries and
Wildlife. Neither author nor date is given on the brochure.
They were identified for us by Walter Stieglitz, first manager
of the wildlife refuge, now with the Division of National Wild-
life Refuges, Washington, DC. San Francisco: EDAW, Inc. Also
available from the U.S. Department of the Interior, Fish and
Wildlife Service.
ENGINEERING-SCIENCE, INC. (August 1968). Biologic - ecologic studies;
final report, task VH-lb, San Francisco Bay-Delta water quality
control program. Prepared for the California State Water Quality
Control Board. Sacramento CA: The State Board. 6 chapters +
1 appendix.
Idem (August 1968). Study of water quality parameters; final report, task
IV-3, San Francisco Bay-Delta water quality control program.
Prepared for the California State Water Quality Control Board.
Sacramento CA: The State Board. 5 chapters + 2 appendices.
Idem (September 1970). A report on south San Francisco Bay water quality
and circulation. Prepared for the Santa Clara County Planning
Policy Committee Baylands Subcommittee. No publication infor-
mation: obtained from the library of the San Jose/Santa Clara
sewage treatment plant. 7 chapters.
294
-------
Larry A. ESVELT et al. (October 1971). Toxicity removal from municipal
wastewaters. Volume 4 of a study of tbxicity and bio stimulation
in San Francisco Bay-Delta waters. Prepared for the California
State Water Resources Control Board by the Sanitary Engineering
Research Laboratory et al., University of California @ Berkeley;
SERL report no. 71-7. 224 pp.
M.E. GIUSTI & R.K. MULRINE (May 1975). Accomplishments and activities of
the industrial waste section, first quarter-1975. San Jose CA:
San Jose/Santa Clara Water Pollution Control Plant. 8 pp.
A. P. HAMANN (31 July 1968). A report to the city council [of San Jose] on
the requirements for additional sewage treatment facilities.
Mr. Hamann is City Manager, City of San Jose. San Jose/ -
City. 23 pp. + appendix. Obtained- -from the^Uiwsry of jjfee
***" ""^ "
San Jose/Santa
Carol M HARPER (26 -November 1975). Meeting notes #6, Bechtel job
10035-006, South Bay Dischargers Authority, wastewater disposal
EIS. Obtained from the San Francisco Bay Regional Water Quality
Control Board, file #2189.8014, Oakland CA. 9 pp.
Idem (28 April 1976). Meeting notes, TAG #7, Bechtel job 10035-006, South
Bay Dischargers Authority, wastewater disposal EIS. Obtained
from the Board, fit&v. #2189. 8014, Oakland CA.
295
-------
Howard S. HARRIS et al. (31 January 1961). A pilot study of physical,
chemical and biological characteristics of waters and sediments
of south San Francisco Bay (south of Dumbarton Bridge). Berkeley:
Sanitary Engineering Research Laboratory of the College of En-
gineering and the School of Public Health, University of Cali-
fornia. 257 pp.
James P.HEATH (July 1970). A report on Santa Clara County wetlands.
Prepared for the Santa Clara County Planning Policy Committee
Baylands Subcommittee. No publication information; obtained
from the library of the San Jose/Santa Clara sewage treatment
plant. 62 pp.
HYDRO-SCIENCE, INC. (December 1975). Evaluation of. discharge alternatives
for South Bay Dischargers Authority. Westwood NJ: Hydroscience.
139 pp. + 4 appendices.
KAISER ENGINEERS (June 1969). Final report to the State of California
San Francisco Bay-Delta water quality control program. Oakland
CA: Kaiser. 23 chapters + 1 appendix.
KAISER ENGINEERS et al. (15 December 1967). Determination of present
water use and waste loads, final report, task II-4, San Fran-
cisco Bay-Delta water quality control program. Prepared for
the California State Water Quality Control Board. Sacramento CA:
The State Board. 7 chapters + 7 appendices.
296
-------
Fredric R. KOPPERDAHL (1976). Guidelines for performing static acute
toxicity fish bioassays in municipal and industrial waste waters.
Prepared for the California State Water Resources Control Board
by the California Department of Fish and Game, Environmental
Services Branch, Fish and Wildlife Water Pollution Control Lab-
oratory, Sacramento CA: The State Board. 65 pp.
Keith KRAFT (11 September 1974). Letter to William Miller (Industrial
Waste Inspector, San Jose - Santa Clara Water Pollution Control
Plant). Kraft (Senior Vector Control Specialist, Santa Clara
County Health Department) requests that a storm-sewer discharge
should be stopped before it causes a fishkill. Obtained from
the files of the San Francisco Bay Regional Water Quality Con-
trol Board, Oakland CA.
Keith KRAFT & E.H. PEARL (23 August 1974). Memo to W. Elwyn Turner
(Director of Public Health, Santa Clara County Health Department).
Kraft and Pearl report on the recurring problem of toxic dis-
charges from the San Jose storm sewers, which cause fishkills.
Obtained from the San Francisco Bay Regional Water Quality Con-
trol Board, file #2189.8014, folder #18, Oakland CA. 3 pp.
W.R. MACKE (12 September 1974). General memo. Macke (San Francisco Bay
Regional Water Quality Control Board) reports and comments on
a storm-sewer discharge. Obtained from the Board, file #2189.8014,
folder #18, Oakland CA.
297
-------
MARINE BIOLOGICAL CONSULTANTS, INC. (May 1975). Bay Area Sewage Services
Agency: coordinated water monitoring for San Francisco Bay.
Costa Mesa CA and Foster City CA: Marine Biological Consultants,
Inc. 35 pp. + appendices A-D.
James C. McCARTY et al. (June 1962). An investigation of water and sedi-
ment quality and pollutional characteristics of three areas in
San Francisco Bay, 1960-61. Berkeley: Sanitary Engineering
Research Laboratory of the College of Engineering and the
School of Public Health, University of California. 571 pp.
D.S. McCULLOCH et al. (1970). Some effects of fresh-water inflow on the
flushing of south San Francisco Bay. In; A preliminary study
of the effects of water circulation in the San Francisco Bay
estuary. U.S. Geological Survey circular 637-A,B. Washington DC:
USGS. 27 pp.
Valentine J. MILLER (7 February 1977). Memo to Fred H. Dierker (Executive
Officer, San Francisco Bay Regional Water Quality Control Board).
Miller (Certifications Section, the Board) reports on the status
of the South Bay Dischargers Authority project. Obtained from
R.R. Scholar, the Board, Oakland CA.
E.L. MITCHELL (23 July 1976). Letter to John A. Nejedly (California State
Senator). Mitchell (President, Santa Clara County Canners
Association) contends that the AWT project is environmentally
harmful. Obtained from the San Francisco Bay Regional Water
Quality Control Board, file //2189.8014, Oakland CA.
298
-------
John D. PARKHURST et al. (June 1969). Report of the Board of Consultants
for the San Francisco Bay-Delta water quality control program
to the State Water Resources Control Board. Sacramento: The
State Board. 19 pp. + appendix.
Emanuel H. PEARL (15 September 1974). Letter to Fred H. Dierker (Execu-
tive Officer, San Francisco Regional Water Quality Control
Board). Pearl (Public Health Engineer, Santa Clara County
Health Department) asks the Board to specify requirements for
controlling storm-sewer discharges in the SJ/SC discharge permit.
Obtained from the Board, file 2189.8014, folder #18, Oakland CA.
Erman A. PEARSON (January 1959). Physical, chemical, and biological
characteristics of water and sediments, south San Francisco Bay
Dumbarton Bridge Area; tabular summary, first survey trip,
November 1 and 2, 1958. Lafayette CA: Original typewritten
copy. 25 pp.
Erman A. PEARSON et al. (March 1969). Final report: A comprehensive
study of San Francisco Bay. Volume 3: Waste discharges and
loadings. Berkeley: Sanitary Engineering Research Laboratory
of the College of Engineering and the School of Public Health,
University of California. SERL report no. 67-3. 98 pp.
Idem (July 1970). Final report: A comprehensive study of San Francisco
Bay. Vol. 8: Summary, conclusions and recommendations. Berkeley:
Sanitary Engineering Research Laboratory of the College of Engine-
ering and the School of Public Health, Univ. of California. SERL
299
-------
report no. 67-5. 85 pp. Also published by the California
State Water Resources Control Board in 1971 as Publication 42.
F. Wayne PIERSON (26 February 1976). Letter to Charles Campbell (U.S.
Environmental Protection Agency, San Francisco). Pierson (WQC
Engineer, Division of Water Quality, State Water Resources Con-
trol Board, Sacramento CA) criticizes Hydroscience's model. From
the San Francisco Bay Regional Water Quality Control Board,
file #2428.8056, Oakland CA.
SAN FRANCISCO BAY REGIONAL WATER POLLUTION CONTROL BOARD (15 March 1951).
Resolution no. 48. The Board sets effluent and receiving-water
standards for the future San Jose STP. Obtained from the Board,
Oakland CA.
Idem (21 August 1952). Resolution no. 106. The Board revises its effluent
and receiving-water standards for the San Jose STP. Obtained
from the Board, Oakland CA.
Idem (30 September 1957). Resolution no. 251. The Board finds that its
requirements are not being met by San Jose and Sunnyvale and
requires reports from the cities. Obtained from the Board,
Oakland CA.
300
-------
Idem (February 1958). Staff report on a survey of water conditions .in
San Francisco Bay south of Dumbarton Highway Bridge, on September
18 & 19, 1957. No publication details. 14 pp. + 2 plates +
7 tables. . . :
Idem (June 1958). Report on pollution and nuisance conditions in San
Francisco Bay south of Dumbarton Highway Bridge, September 1957.
No publication details. 13 pp. + 3 plates.
Idem (19 November 1959). Resolution no. 316. The Board revises its
effluent and receiving-water requirements for the San Jose/
Santa Clara STP. Obtained from the Board, Oakland CA.
Idem (December 1959). Staff report to Regional Water Pollution Control
Board, San Francisco Bay Region, relative to sewage and indus-
trial waste disposal problems of the City of San Jose. No
publication details. 32 pp. + appendices A-H.
Idem (17 December 1959). Resolution no. 318. The Board orders San Jose
to cease and desist from violating its requirements and to comply
with the requirements of Resolution no. 316. Obtained from the
Board, Oakland CA.
Idem (16 March 1961). Resolution no. 354. The Board revises the schedule
for pollution abatement contained in Resolution no. 318.
Obtained from the Board, Oakland CA.
Idem (18 July 1963). Resolution no. 484. The Board grants San Jose a
time extension. Obtained from the Board, Oakland CA.
301
-------
Idem (December 1964). Staff report on a survey of water conditions in
San Francisco Bay south of Dumbarton Highway Bridge on July 17,
August 14, September 11 and October 23, 1964. 11 pp. + appen-
dices A-C.
Idem (15 April 1965). Resolution no. 661. The Board orders new improve-
ments to the SJ/SC SIP and more controls on the industrial
hookups. Obtained from the Board, Oakland CA.
SAN FRANCISCO BAY REGIONAL WATER QUALITY CONTROL BOARD (November 1966).
Staff report on a survey of water conditions in San Francisco
Bay south of Dumbarton Highway Bridge, May 31, 1966 through
October 7, 1966. No publication details. 13 pp. + appendices
A-C.
Idem (1967). Water quality control policy for tidal waters inland from
the Golden Gate within the San Francisco Bay Region. Oakland:
The Board. The main report is in 6 chapters; appendices A-G
are separately bound in 3 volumes; 2 attachments are bound in
a separate volume. (5 volumes, all included).
Idem (1967). Staff report on waste loading and water quality conditions
in south San Francisco Bay, south of Dumbarton Bridge. 12 pp.
V.
Idem (July 1967). Self-monitoring program and schedule for sampling,
analyses and observations for the City of San Jose and other .
agencies tributary to the San Jose sewerage system, Santa Clara
County. Obtained from file #2189.8014, folder #19 of the
Board, Oakland CA. 10 pp.
302
-------
Idem (21 March 1968). Resolution no. 68-11. The Board sets stricter
requirements for SJ/SC. Obtained from the Board, Oakland CA.
Idem (16 July 1968). Waste loading and water quality condition in south
San Francisco Bay, south of Dumbarton Bridge: 1967. Oakland CA:
The Board. 12 pp. +3 figures + appendix.
Idem (3 April 1969). City of San Jose's water pollution activities.
Obtained from the desk file of R.R. Scholar of the Board, Oak-
land CA. 2 pp.
Idem (24 June 1969). Resolution no. 69-26. The Board orders SJ/SC to
cease and desist from violating Resolution no. 68-11. Obtained
from the Board, Oakland CA.
Idem (23 July 1970). Resolution no. 70-57. The Board orders SJ/SC to
cease and desist from violating Resolution no. 68-11 according
to a schedule. Obtained from the Board, Oakland CA.
Idem (24 November 1970). Resolution no. 70-91. The Board sets new and
stricter requirements for SJ/SC. Obtained from the Board,
Oakland CA.
Idem (June 1971). Interim water quality control plan for the San Fran-
cisco Bay Basin. Oakland CA: The Board. 72 pp.
Idem (24 June 1971). Order no. 71-36. The Board gives SJ/SC a time
extension. Obtained from the Board, Oakland CA.
303
-------
Idem (23 November 1971). Order no. 71-78. The Board orders SJ/SC to
cease and desist from violating Resolution no. 70-91. Obtained
from the Board, Oakland CA.
Idem (22 August 1972). Order no. 72-62. The Board orders San Jose and
other cities on the south bay to proceed with their plans for
regionalization. Obtained from the Board, Oakland CA.
Idem (20 November 1972). 1973-1974 municipal project list. Obtained
from the desk file of Edward R. Becker, SJ/SC STP, San Jose CA.
9 PP.
Idem (1 August 1974). Documentation of modification of recommendation,
City of San Jose. Submitted by M.H. Kazemi. Obtained from the
Board, file #2189.8014, folder #18, Oakland CA.
Idem (19 November 1974). Draft NPDES permit for SJ/SC. Obtained from the
Board, file #2189.8014, folder #19, Oakland CA. 9 pp.
Idem (6 December 1974). Order no. 74-168, NPDES no. CA0037842. A final
discharge permit for SJ/SC. Obtained from the Board, Oakland
CA. 15 pp.
Idem (April 1975). Water quality control plan report, San Francisco Bay
basin. In 2 parts, separately bound. Part 1 includes chapters
1-7 + a special appendix; part 2 includes chapters 8-17.
Idem (13 May 1975). Routine compliance monitoring report, City of San
Jose. Dave Block (Field Engineer) inspects and reports on SJ/SC.
Obtained from the Board, file #2189.8014, folder #19, Oakland CA.
304
-------
Idem (15 March 1977). Executive officer summary report. Dierker submits
Valentine Miller's report (7 February 1977) to the Board. Ob-
tained from R.R. Scholar, the Board, Oakland CA.
CITY OF SAN JOSE (1960). San Jose: design for tomorrow. San Jose CA:
The City. 58 pp.
Idem (1966). The general plan: 1966-2010. San Jose CA: The City. One
oversized sheet folded into a booklet.
Idem (effective November 1971). Industrial Waste Ordinance for that area
tributary to San Jose - Santa Clara water pollution control plant.
San Jose CA: The City. 16 pp.
Idem (1974). Industrial waste ordinance for that area tributary to San
Jose - Santa Clara water pollution control plant. San Jose CA:
The City. 16 pp.
SAN JOSE DEPARTMENT OF PUBLIC WORKS (5 February 1975). Sewer system
i
evaluation and preventive maintenance program, program descrip-
tion. Obtained from the San Francisco Bay Regional Water Quality
Control Board, file #2189.8014, folder #19, Oakland CA. 3 pp.
CITIES OF SAN JOSE & SANTA CLARA (undated, 1965 or later). San Jose/Santa
Clara water pollution control plant. San Jose and Santa Clara CA:
The cities. 24 pp.
305
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SAN JOSE/SANTA CLABA WATER POLLUTION CONTROL PLANT (April 1964). San
Jose - Santa Clara water pollution control plant; historical,
location and site information, description of plant units, design
data, project costs, tour route, fact sheet. Obtained from the
Plant, San Jose CA. 41 pp.
Idem (1965- ). Annual report. A continuing annual series. San Jose:
The Plant. Gives costs, plant performance, condition of receiv-
ing waters. No change in service area since 1965 except for
Milpitas (3.2 mgd, including I/I), which joined the service area
on 5 November 1974.
Idem (April 1970). Program for the identification of toxic waste water
dischargers and the prohibition thereof. San Jose CA: The
Plant. 11 pp.
Idem (20 April 1970). Review of past performance, recent and Immediate
improvements, effect of expansion on effluent quality, scheduling
of design and construction, appendices. San Jose CA: The Plant.
4 chapters + 5 appendices.
Idem (March 1974). Infiltration/inflow analysis, Alviso District. San
Jose: The Plant; 6 pp.
Robert E. SELLECK et al. (June 1966). Final report: a comprehensive
study of San Francisco Bay. Vol. 4: Physical and hydrological
characteristics of San Francisco Bay. Berkeley: Sanitary En-
gineering Research Laboratory of the College of Engineering and
the School of Public Health, Univ. of California. SERL report
no. 65-10. 99 pp.
306
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Idem (30 June 1966). Final report: a comprehensive study of San Fran-
cisco Bay. Vol. 7: A model of mixing and diffusion in San
Francisco Bay. Berkeley: Sanitary Engineering Research Labora-
tory of the College of Engineering and the School of Public
Health, University of California. SERL report no. 67-1. Ill pp.
SOUTH BAY DISCHARGERS AUTHORITY (14 January 1977). Accomplishments by
South Bay Dischargers Authority and the member agencies. Ob-
tained from the San Francisco Bay Regional Water Quality Control
Board, file #2428.8056, Oakland CA. 9 pp.
SOUTH BAY DISCHARGERS AUTHORITY, TECHNICAL ADVISORY COMMITTEE (January
1976). Report on recommended action to be taken by SBDA on
requirement of the Regional Water Quality Control Board for
?
construction of the joint interceptor and outfall. -Obtained
from the Board, file #2189.8014, Oakland CA.
Richard W. STONE et al. (May 1973). Long-term effects of toxicants and
biostimulants on the water of central San Francisco Bay. Pre-
pared for the California State Water Resources Control Board by
the Sanitary Engineering Research Laboratory, University of
California, Berkeley. SERL report no. 73-1. SWRCB publication
no. 51 (1974). Sacramento CA: The State Board. 112 pp.
307
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Philip N. STORKS et al. (April 1963). A comprehensive study of San Fran-
cisco Bay, 1961-62, south San Francisco Bay area, Suisun Bay-
lover San Joaquin River area, and San Pablo Bay area. Berkeley:
Sanitary Engineering Research Laboratory of the College of En-
gineering and the School of Public Health, University of California.
SERL report no. 63-3, 221 pp.
Idem (July 1966). Final report: a comprehensive study of San Francisco
Bay. Vol. 2: Biological sampling and analytical methods.
Berkeley: Sanitary Engineering Research Laboratory of the College
of Engineering and the School of Public Health, University of
California. SERL report no. 65-8. 75 pp.
Idem (December 1966). Final report: a comprehensive study of San Francisco
Bay. Vol. 5: Summary of physical, chemical, and biological
water and sediment data. Berkeley: Sanitary Engineering Research
Laboratory of the College of Engineering and the School of Public
Health, University of California. SERL report no. 67-2. 140 pp.
Idem (August 1969). Final report: a comprehensive study of San Francisco
Bay. Vol. 6: Water and sediment quality and waste discharge
relationships. Berkeley: Sanitary Engineering Research Labora-
tory of the College of Engineering and the School of Public
Health, University of California. SERL report no. 67-4. 6
sections, individually paginated.
CITY OF SUNNYVALE, CALIFORNIA (April 1972). Staff analysis, South Bay Dis-
chargers study. No publication details. 40 pp. An analysis of
the Consoer-Bechtel water quality management plan of March 1972.
308
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A.R. TURTURICI (17 December 1973). Letter to Fred H. Dierker (Executive
Officer, San Francisco Bay Regional Water Quality Control Board).
Turturici (Director of Public Works, San Jose) reports on San
Jose's program to control the toxicity of industrial wastewaters.
Drafted by Frank M. Belick (Engineer-Manager, San Jose - Santa
Clara STP). Obtained from file #2189.8014, folder #18 of the
Board, Oakland CA.
Idem (2 December 1974). Letter to Fred H. Dierker. Turturici asks the
Board to reconsider its effluent-BOD limit and its ban on dis,-
charges south of Dumbarton Bridge. Obtained from the Board,
file #2189.8014, folder #19, Oakland CA.
A.R. TURTURICI & Frank BELICK (April 1974). San Jose's treatment plant
Serves area. Published in Western City magazine. Obtained from
the Board, file #2189.8014, folder #18, Oakland CA.
U.S. ARMY ENGINEER DISTRICT, SAN FRANCISCO, CORPS OF ENGINEERS (February
1969). Preliminary plan of study of San Francisco Bay area in-
depth study. A report to the U.S. House of Representatives,
Committee on Appropriations. San Francisco CA: The Corps.
30 pp. + exhibits and 2 appendices.
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IX (5 June 1975). Grant
agreement, grant no. C 060947 01 0. EPA offers San Jose
$52,732,500. San Jose accepts 26 June 1975. Obtained from the
files of the SJ/SC STP, San Jose CA.
309
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Idem (8 July 1976). Grant amendment, grant no. C 060947 01, amendment
no. 1. EPA reduces SJ/SC's grant to $48,214,740. San Jose
accepts 20 August 1976. Obtained from the SIP files.
Idem (undated 1976). Draft environmental impact statement. San Francisco
CA: The Agency. Unpaginated galleys, approx. 100 pp. Approx.
200 pp. of appendices, separately bound.
U.S. ENVIRONMENTAL PROTECTION AGENCY, OFFICE OF WATER PROGRAMS OPERATIONS
(undated). Federal guidelines, pretreatment of discharges to
publicly owned treatment works. Washington DC: U.S. EPA.
Page D-17-13 bears an identification number from the U.S. Gov't.
Printing Office: 1973 546-308/30 1-3. 16 pp. + appendices A-D.
Larry F. WALKER (20 November 1974). Letter to A.R. Turturici (Director
of Public Works, San Jose). Walker (Division Chief, Manager -
Clean Water Grant Program, State Water Resources Control Board)
approves the plan for AWT at SJ/SC. Obtained from the desk file
of R.R. Scholar, San Francisco Bay Regional Water Quality Con-
trol Board, Oakland CA.
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9. SPOKANE, WASHINGTON
9.1 THE ISSUES IN BRIEF
In Spokane, the only AWT requirement is year-round phosphorus
removal. This requirement was not derived from solid evidence, impartially
judged. It was inspired by prejudice and justified by willful distortions
of the facts.
The Spokane River drains over 6,000 square miles of northwestern
Washington and the Idaho panhandle. Its drainage basin includes Coeur
d'Alene Lake and seven hydropower reservoirs, six of them in or below the
city of Spokane. Near the top of the drainage basin (in Kellogg, Idaho)
is the Bunker Hill industrial complex one of the most notorious examples
of air and water pollution in the U.S.' Its wastewaters contain, among
other things, large quantities of phosphorus and zinc. Some 75 miles
above its confluence with the Columbia River, the Spokane River flows
through the city of Spokane. About mid-way between the city and the Colum-
bia River is Long Lake Dam, which impounded 22 miles of river to create
Long Lake in 1915.
The Spokane STF serves a population of over 165,000. It is a
c
primary plant, built in 1958. Ten years later, the State ordered Spokane
i
to upgrade the plant to secondary and to make major improvements in the
sewers (combined sewers, with dozens of documented overflows and bypasses).
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Spokane stalled and made excuses. The State grew Impatient. In 1970,
the State first mentioned AWT (undefined). In August 1972, the State
and EPA insisted that Spokane must build facilities for phosphorus removal,
and in March 1973 the State formally required them. Spokane balked, but
finally capitulated. Beginning on 29 July 1974, Spokane was awarded
grants by EPA to upgrade the existing STP to a secondary plant with facili-
ties for year-round phosphorus removal. The STP improvements, which are
nearly complete now, will cost over $42 million. The sewer problem is
still being .worked on.
Controversy and litigation have surrounded every major decision
in Spokane's cleanup program. Ironically some of the bitterest arguments
accompanied,Spokane's preparations for Expo-'74, "The First World Ecolog-
ical Exposition." Our case study concentrates on phosphorus removal; we
pay no attention to the citizen suits and the acrimony that have' enveloped
other phases of the program.
How was it decided that Spokane must remove phosphorus? In
August 1972, when EPA and the State first insisted on it, very little was
known about Long Lake. Only three small studies had been done, and the
first serious study was just beginning. These studies had documented the
principal problems in the lake algal blooms and deoxygenation and
suggested that the two might be linked. Their suggestions were accompanied
by requests for further research into the causes of, and possible links
between, the two problems.
During the late 1960's and early 1970's, the links between
phosphorus, algae, and deoxygenation in lakes were enchanting researchers
all over the world. Lake Erie had been pronounced dead, and phosphorus
312
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removal was being practiced throughout the Great Lakes to avert ecological
doom. It was widely held that algae, growing luxuriantly in the surface
waters of a lake, could fall as a kind of algal rain into the depths,
deoxygenating the deep waters as they sank and decomposed.
If some way could be found to control the algae, the argument
runs, the deoxygenation of deep waters could be controlled too. Killing
algae by mechanical harvesting or chemical poisoning had no appeal.
Starving them did. It was generally believed that they could be most
easily starved by depriving them of phosphorus, an essential nutrient for
all forms of life, and one that is often scarce in lakes. Phosphorus was
suddenly transformed into a weapon of famishment in the war against algae.
This weapon is effective only if phosphorus is the growth-limiting nutrient.
You don't have a weapon if it doesn't work. If algal growth is limited
by something else (be it another nutrient such as nitrogen or manganese,
or a growth inhibitor such as zinc) phosphorus control will not starve
out the algae.
Much more is known about Long Lake now than was known in 1972.
But it has yet to be proved that phosphorus is the growth-limiting element,
or that phosphorus removal in Spokane (or in both Spokane and the Bunker
Hill complex) will starve the algae in Long Lake. There is another large
source of phosphorus in the drainage basin: the riverbed itself. It's
hard to starve an enemy who's sitting on a large food supply.
No one has shown that algal rain causes the deoxygenation of
Long Lake, or that algal rain is the likeliest cause. .There are at least
two other likely causes: (1) entrapment of long-term BOD (e.g. 90-day
BOO) in the reservoir, and (2) oxygen demand exerted by the sediments
313
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themselves they are known to be loaded with organic matter as well as
phosphorus. No one has ever measured the mass, settling rate, decay rate,
or deoxygenation kinetics of the algal rain. No one has ever measured
long-term BOD in the lake. No one has ever measured the oxygen demand of
the sediments.
Each of these unknowns undermines the case for phosphorus removal
in Spokane. The on-going research program in Long Lake continues to reveal
fresh complexities in its hydrodynamics and ecology. The lake is full of
surprises. Much more research will be needed before anyone can fairly
assess the complex interactions among the several possible causes of
; .
deoxygenation.
Phosphorus removal isn't cheap. Kennedy Engineers has estimated
that phosphorus-removal facilities in Spokane will cost about $4.6 million
to build and about $1.2 million a year to run. The city has argued that
even if phosphorus removal should be required during the months when algae
grow (roughly May through October), it is pointless to remove phosphorus
during cold weather, when algae do not grow. Seasonal removal will save
the city several hundred thousand dollars a year, but EPA and the State
have refused to allow this economy.
Long Lake is not well mixed during the summer. Several re-
searchers have suggested that modifying the dam itself might improve
mixing patterns in the reservoir; it has also been suggested that pumps
or aerators might improve circulation and oxygenation. Although State
law requires that these suggestions must be formally considered, none of
them have been seriously pursued they remain suggestions, though they
address the water-quality problem squarely and hold the promise of econ-
omical solutions.
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The formal planning apparatus has not been of any use. The
WQS for Long Lake are meaningless. The WQS require the State to distinguish
between the effects of dams and the effects of discharges (a distinction
it is manifestly incapable of), and to determine "natural conditions" in
Long Lake (an artificial impoundment built to generate hydropower and make
money). There is not, and never has been, a specific phosphorus standard
for the Spokane River or Long Lake; although phosphorus is not important
enough to be included in the WQS, it is thought to be so dangerous that it
must be removed from Spokane's wastewaters. The mathematical models are
elaborate fictions and not successful fictions at that. The basin plan
required by section 303(e) of P.L. 92-500 does not even mention the deoxy-
genation of Long Lake, and it fails to determine the "total maximum daily
load" of pollutants (required by section 303 (d)). The decision-making
process has been deformed by outrage over pollution from the Bunker Hill
complex and by the vogue of phosphorus removal. The process has yet to be
informed by thorough evidence and impartial judgement.
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"Pensiamo perche non sappiamo." [Italian proverb:
"We think because we don't know." Trans, by J.H.]
316
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9.2 CASE HISTORY
1915
Long Lake is created by Long Lake Dam, built across the
Spokane River by the Washington Water Power Company (WWP).
16 March 1945
The Governor signs into law a bill creating the State pollution
control agency and giving it the power to require AWT at its discretion:
"It is declared to be the public policy of the State of
Washington to maintain the highest possible standards to
insure the purity of all waters of the State...and to that
end require the use of all known available and reasonable
methods by industries and others to prevent and control
the pollution of the waters of the State of Washington."
1958
Spokane builds a primary STF.
1965
The Federal Water Quality Act of 1965 (P.L. 89-234) becomes law.
It requires the States to set water-quality standards (WQS) and to abate
effluents that cause the WQS to be violated.
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4 December 1967
The Washington State Water Pollution Control Commission (WPCC)
sets WQS. The Spokane River is classified Class A, to which the following
criteria (among others) apply:
"Dissolved Oxygen shall exceed 8.0 mg/1...."
"pH shall be within the range of 6.5 to 8.5... with an
induced variation of less than 0.25 units."
.
"Aesthetic Values shall not be impaired by the presence
of materials or tfieir effects, excluding those of
natural origin, which offend the senses of sight, smell,
touch, or taste."
There is also a special temperature criterion:
"Temperature Ho measureable Increases shall be per-
mitted within the waters designated which result in
water temperatures exceeding 68°F nor shall the cumu-
lative total of all such increases arising from non-
natural causes be permitted in excess of t-110/(T-15);
for the purposes hereof "t" represents the permissive
increase and "T" represents the resulting water
temperature."
These criteria suffer from confusions about natural origins,
simplistic notions of causation, and unwarranted severity. The Spokane
River is not natural it has been transformed by several large dams and
by industrial development and should not be treated as though it were
in its natural state. Nor is this the end of the "natural" difficulties,
especially as expressed in the "Aesthetic-Values" standard. Human excre-
ment is a product of natural origin; so are mining and food-processing
wastes. Hepatitis viruses are of natural origin; the cholera vibrio, the
causative agents of amoebic and bacillary dysentery, typhoid bacteria,
poliovirus all are waterborne pathogens of natural origin. Clearly,
the WQS should not exempt "materials...of natural origin."
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It is unclear why the WPCC set a special temperature criterion
for the Spokane River a criterion that cannot possibly be met. Long
Lake (an unnatural impoundment in the Spokane River) violates the tempera-
ture standard every summer.
Long Lake also violates the pH standard (because Long Lake is
full of algae) and the DO standard (because the depths of the lake are
not subject to reaeration and gradually lose DO). When the algae are
photosynthesizing in full sunlight, they remove carbonate from the water.
At night, when they are glycolyzing, they put carbon dioxide into the
water. By seasonally and diurnally altering the concentration of car-
*
bonate and bicarbonate, the plant life affects the buffering capacity of
the water, and hence induces variations in the pH.
When Long Lake becomes stratified each summer* a body of water
becomes trapped in its depths and remains there for several months while
the summer flow of the Spokane River passes over it to the power penstocks
in the dam. This body of trapped water (the hypolimnion) slowly loses
DO to decomposing organic matter in the hypolimnion itself and in the
sediment. Very little DO diffuses into the hypolimnion to offset the
effects of organic decomposition; consequently, the hypolimnion tends to
become anoxic. Hypolimnetic anoxia is "natural" only in stratified,
natural lakes. Long Lake is an artificial lake; furthermore, it might
violate the DO standard (and might become anoxic) even if Spokane were
wiped off the map. The DO standard (like the temperature standard and the
pH standard) is too severe for the unnatural conditions in Long Lake, and
is violated every year. What is the point of WQS like these?
*Stratification was first documented in a 1969 report (see p. 321).
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The WQS contain a special provision that is more demanding than
the specific criteria and even harder to interpret:
"Regardless of the water quality criteria as herein
established, wherever existing receiving waters of a
classified area are of a higher quality than the criteria
assigned for said area, the existing water quality shall
constitute the water quality criteria."
This provision seems to assume that water quality is constant
and well documented. In reality, water quality is poorly documented and
extremely variable. It changes with time and place. Does this provision
make the "existing water quality" during a winter the standard for the
following summer? Does it make the "existing water quality" during a wet
year the standard for a dry one? Perhaps. With such vague wording, the
provision could be interpreted endlessly. Vague, pretentious language
muddles pollution-control planning.
The 1965 Federal law did not usurp the powers granted to WPCC
by the 1945 Washington State law, but it did increase the complexity of
enforcing the law. Under the 1965 Federal law, WPCC had to classify the
waters of the State, issue WQS, calculate assimilative capacities, and
prepare wasteload allocations. Under the 1945 State law, WPCC had only
to use its judgement.
WPCC incorporated the essence of the 1945 law into the WQS by
declaring that it would forbid discharges that have not "been provided
with all known, available and reasonable methods of treatment." Too much
hinges on the word "reasonable." Primary treatment was "reasonable" until
1968; by 1972, both secondary treatment and phosphorus removal had become
"reasonable." What are treatment requirements doing in the WQS? WQS
should refer only to the waters of the State not to the wastewaters.
The confusion between water and wastewater is characteristic.
320
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December 1967
WPCC publishes its Implementation and Enforcement Plan for its
WQS. It requires dam owners to assess the environmental effects of
their dams:
"Dam impoundments and reservoirs may cause adverse changes
in the environmental characteristics of a watercourse.
These changes may affect downstream water quality as well
as the quality within the impoundment. Potential prob-
lems within the reservoir include thermal stratification,
low dissolved oxygen in the lower strata, accumulation
of nutrients and algal blooms. Downstream changes in-
clude temperature, dissolved oxygen, and algal blooms.
Studies shall be required of operating entities of dams
to assess 'environmental water quality changes in the
reservoir and downstream and provide recommendations for
improvements in operation and other measures as neces-
sary to minimize or eliminate any adverse effects of the
impoundment."
19 March 1968
»
WPCC requires Spokane to upgrade its STP to give secondary
treatment and disinfection by mid-1972. Spokane must also submit a plan
to eliminate "excessive hydraulic flows caused by storm water and/or
infiltration." WPCC claims that the improvements to Spokane's STP and
sewers will put the Spokane River into compliance with the WQS. It sets
a schedule and asks the city to respond by 15 May 1968. The requirements
are transmitted in a letter by Roy M. Harris (Director, WPCC).
1969
Cunningham and Pine (WPCC) publish a 1966 study of Long Lake.
They found that Long Lake was stratified; the epilimnion was often
supersaturated with DO, but the hypolimnion was anoxic. They attributed
the anoxia to phytoplankton that grew in the epilimnion, died, sank, and
decomposed in the hypolimnion and in the sediments:
321
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"It was determined during this study that approximately
40 percent of the total volume of Long Lake was devoid
of dissolved oxygen. The data suggested that this
anaerobic condition was linked to the decomposition of
volatile solids in the bottom sediments of the lake....
The source of the volatile solids contained in the
bottom sediments appeared to be plankton organisms
growing in the epilimnion of the lake."
Cunningham and Pine did not measure BOD in Long Lake, but they
did measure both BODj and BOD2Q in the Spokane River above the lake. They
concluded that BOD did not contribute to the anoxia because there was
more DO than BOD in the river.
However, they measured in September ~ the wrong month. The
crucial time to measure long-term BOD in Long Lake is in late spring,
just as the flood season ends. The water that lies at the bottom of the
lake during the summer arrived there at the end of the high-flow season.
There could be enough long-term BOD (e.g. 90-day BOD) at the start of
summer to deoxygenate the hypolimnion all by itself, without any help from
algae raining down from the euphotic zone in the epilimnion. Even in the
fall, Cunningham and Pine measured BOD2Q in the Spokane River as great as
16.4 mg/1 more than enough to deoxygenate water that, like the
hypolimnion of Long Lake, is not reaerated.
The phosphorus measurements are similarly misleading. Cunning-
ham and Pine found that in September 1966, nearly all the orthophosphate
in the river came from the Spokane STP. During spring high flows, however,
when the river is scouring phosphorus-laden sediment, most of the phos-
phorus in the river may come from elsewhere. How much of the phosphorus
carried into' the lake in the spring remains through the summer, recycled
through generations of algae? How much of the phosphorus available to
the algae comes from the STP, and how much comes from other sources?
322
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Cunningham and Pine cannot answer these questions because they did not
investigate the mass balance of phosphorus or draw up a phosphorus budget
for an entire season.
They also blamed the sediments for supporting algal blooms:
"The nutrients supporting the phytoplankton population
were liberated from the lake's bottom sediments and also
came from the Spokane Sewage Treatment Plant via the
Spokane River."
However, they neglected to explain how the nutrients might rise up through
the thermocline and the interflow currents to reach the euphotic zone,
where the algae grow.
They recommended another study to check the cause of anoxia.
They suggested destratifying Long Lake or requiring nutrient removal at
the Spokane STP if decomposing phytoplankton should prove to cause the
hypolimnetic anoxia. In any case, they recommended that WPCC should re-
quire more treatment at the STP, which would reduce BOD, nutrients, and
coliforms in the Spokane River above Long Lake.
1 August 1969
Tom Haggarty (WPCC) concludes that Spokane has no intention of
complying with WPCC's schedule. The city has not answered the March 1968
letter, although sixteen months have passed.
23 September 1969
WPCC issues a Notice of Violation to Spokane for not complying
with the schedule. Spokane must file a report within 30 days.
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16 October 1969
Spokane tells WPCC that it would be "Imprudent for the city
government to commit itself to specific completion dates." It argues
that sewer separation and STP construction are-very expensive, and the
voters would probably not approve funds. Instead, the city offers to
hire an engineering firm to study the problem. Spokane's response is
conveyed by its mayor, David H. Rodgers.
8 January 1970
WPCC -issues Order #69-77. Spokane must hire an engineering
firm that will plan "to provide an orderly program to eliminate overflows
of untreated sewage into the Spokane River caused by storm water and/or
infiltration." The plan must be submitted by 31 July 1972 the original
date set in the March 1968 letter. The engineers must also design facili-
ties for "advanced waste treatment....sufficient to meet the water quality
standards established for the Spokane River." "Advanced waste treatment"
is not defined, and it is not clear what it means. Nor is it clear why
AWT is needed. In the March 1968 letter, WPCC claimed that secondary
treatment would allow the Spokane River to meet WQS.
13 July 1970
The Spokane City Council resolves that it intends to construct
"advanced sewage treatment" (undefined) as rapidly as possible.
September 1970
The Washington State Department of Ecology (DOE formerly WPCC)
t
publishes a new Implementation and Enforcement Plan for revised WQS that
were adopted 8 January 1970. The revised WQS applicable to the Spokane
324
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River are identical to the 1967 WQS. The requirement that dam owners
must study the environmental effects of their dams is unchanged from the
1967 Implementation Plan.
"Advanced waste treatment" is defined, although vaguely:
"Advanced waste treatment is defined as Secondary Treat-
ment followed by further reduction of BOD, Suspended
Solids, MPN and/or nutrients to a level determined to
be adequate."
This definition merely substitutes one vague phrase for another "to a
level determined to be adequate" for "sufficient to meet the water quality
standards established for the Spokane River" (WPCC Order #69-77). DOE
does not know what is either sufficient or adequate for the Spokane River.
DOE finds that the Spokane River is not meeting WQS for coliforms,
DO, turbidity, and aesthetics, owing to a "discharge that can be corrected."
The river is not meeting its special temperature standard, owing to "a
temporary natural condition, or a combination of natural and unnatural
effects whose interrelationships have not been determined." DOE claims
that the river meets WQS for pH and for "toxic and deleterious" substances,
but they are wrong the pH standard is being violated in Long Lake. By
1972, EPA will be agitating about toxic concentrations of zinc in the
river concentrations that have been high for many years.
12 November 1970
WPCC, Spokane, and Spokane's consulting engineers (Esvelt &
Saxton/Bovay Engineers) discuss phosphorus removal. They arrive at no
formal conclusions.
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1971
Carl Ted Stude submits a thesis on water quality in the Spokane
River to the University of Washington. He reports that fishing for perch,
bass, and crappie is good in Long Lake; there have been some odors from
algal blooms, but the resort operators have not complained.
Stude believes that phosphorus aggravates the ills of Long
Lake, and that phosphorus removal could cure them:
"...the preponderance of expert opinion is that artificial
eutrophication can be most economically arrested by limi-
ting inflows of phosphorus."
Stude agrees with Cunningham and Fine that the hypolimnetic anoxia is
caused by decomposing phytoplankton raining down from the enriched surface
waters of the lake. He feels that long-term BOD is less important.
Stude calculated that decomposing algae would consume 2/3 of
the hypolimnetic DO even if Spokane were wiped off the map. However, his
formula is too simplistic and his assumptions are suspect. He assumed that
the BODgQ in the hypolimnion at the start of summer is only 1 mg/1, but
gave no rationale for his guess. If the BODgQ is higher, then Stude's
calculation will be way off. Simplistic calculations are no way to
decide on pollution-control strategies, but without a thorough understand-
ing of the body of water an understanding derived from careful and
appropriate measurements there is no rational way to decide.
Stude considered some modifications of Long Lake Dam, but not
others. He considered raising the level of the power penstocks (to pro-
vide cleaner water to the river below) but not lowering them (to induce
more mixing in the lake). He considered mixing the lake mechanically
326
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(and found it economically attractive) but admits he does not know what
the effects would be.
December 1971
Cunningham and Rothwell (DOE) publish routine-monitoring data
from the winter of 1970-1971. DOE has only five sampling stations on the
Spokane River, which stretches nearly 100 river miles from the Idaho
border to the Columbia River. There are no stations on Long Lake. Samples
are collected twice monthly and analyzed for a variety of constituents,
many of them irrelevant to pollution control (e.g. dissolved calcium,
dissolved magnesium, dissolved potassium all analyzed by the U.S.
Geological Survey).
DOE's monitoring program is inadequate for pollution-control
planning. There are too few stations, all of them improperly located
and sampled too infrequently. Because there are no stations on Long
Lake, the monitoring program misses both the algal blooms and the hypo-
limnetic anoxia of Long Lake the two principal water-quality problems.
DOE intended to use the data to discover trends in water quality,
but now admits that it cannot make sense of the results:
"...it will be noted that from year to year individual
parameter values often have fluctuated sometimes
drastically. These fluctuations, since this is a grab
sample type program, could be the result of too few
samples being collected rather than a real change from
year to year in the river's water quality.... The
average values shown for the years 1959-1969 were com-
puted using a maximum of four values (monthly sampling
frequency) and the data collected during 1970 was com-
puted using a maximum of eight values (semi-monthly
sampling frequency). Therefore, either the changes
that persisted for several years were not great enough
or the changes that were large did not persist long
enough to identify water quality trends."
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Cunningham and Rothwell found coliform violations near
Spokane and "perilously high zinc concentrations" the length of the
river. Most of the zinc in the Spokane River comes from the Bunker Hill
Mining Company's mining, milling, and smelting operations in Idaho.
DO was always high in the winter, just as one would expect.
1972
Bishop and Lee (DOE) publish a study of the Spokane River and
Long Lake conducted during 1970-1971 by DOE, the Lincoln County Health
Department, the U.S. National Park Service, the Washington State Univer-
sity, and the Washington Water Power Company. They conclude that Long
Lake is eutrophying and that it is subject to "nutrient build-up." They
do not guess at the cause of the hypolimnetic anoxia, but recommend
removing nutrients from Spokane's wastewater and studying the effects of
modifying Long Lake Dam.
Long Lake is a non-point source of pollution, they say:
"Nutrient build-up causes adverse changes in the environ-
mental characteristics of Long Lake reservoir which in
turn affects downstream water quality."
"In accordance with the provisions of the Water Quality
Improvement Act of 1970, studies shall be required of
operating entities on non-point pollution sources such
as dam impoundments to assess environmental water quality
changes in the reservoir and downstream. The studies
shall provide recommendations for improvements in opera-
tion and other methods as necessary to minimize or eliminate
any adverse effects of the impoundment."
They suggest that Long Lake would be much cleaner if it were destratified
during the summer.
Bishop and Lee, like Cunningham and Pine, documented water-
quality problems in Long Lake but were unable to identify the causes of
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these problems because their surveys were not designed to identify causes.
They did not follow long-term BOD, nutrients, and algae down the river
(from above Spokane through Long Lake) over an entire season to detect:
the timing, extent, and type of algal blooms
the amount of nutrients available for algal growth,
and the sources of those nutrients
the rate of algal death and deposition
the deoxygenation from decomposing algae
the deoxygenation from long-term BOD trapped in the
hypolimnion of Long Lake after the spring flush.
1972
Richard J. Condit (a student at Washington State University,
partially funded by a grant from DOE) publishes a study of algal growth
in the Spokane River. He found that there were many more algae in June
1971 than in August 1971, even though much more nitrogen and phosphorus
were available in August. He concluded that phosphorus was limiting algal
growth in June, but that nitrogen and perhaps manganese were limiting in
August.
Adding phosphorus to native algal cultures produced variable
results; sometimes it inhibited growth. Condit concluded that landwash
was responsible for the June bloom, but he also put part of the blame on
phosphorus from the STP. However, his data allow no simplistic theories .
of causation. At his station below the STP, adding phosphorus inhibited
the growth of native algae. When he later analyzed the effect of added
phosphorus on the exotic alga Selenastrum, he found that "at all stations
phosphorus produced a slight to pronounced inhibition to algal growth."
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Condit used native algae for his June bioassays, but he used
the non-native alga Selenastrum capricornutum Printz (a specialized
laboratory strain) for his August bioassays. Before adding Selenastrum,
he filtered the river-water sample through a 0.45-micron Millipore filter,
which removed the native plankton and prevented competition and predation.
Condit's August bioassays are artificial, far removed from the reality
of the Spokane River.
July 1972
Esvelt & Saxton / Bovay Engineers (ESB) publish a study of
Spokane's sewers and sewage treatment. ESB reports that most of Spokane
has combined sewers; about 1% of Spokane's annual sewage is discharged
raw through 45 overflows. Although the report is entitled "...action
plan for... advanced wastewater treatment", ESB recommends secondary
treatment plus stormwater treatment.
11 July 1972
Gary L. O'Neal (Director, Surveillance & Analysis Division,
EPA-Seattle) announces that EPA will increase "monitoring by objectives"
and decrease routine monitoring. A report on the Spokane River is
attached to the memo as an example.
The report contains little on monitoring, but much speculation
about water-quality problems and their causes. EPA fears that ground-
water (which, it claims, makes up most of the riverflow during the summer)
is deficient In DO. Groundwater inflows are colder than riverwater that
has been heated by the sun; consequently, EPA contends, the groundwater
has caused the river to become stratified, and has escaped detection
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because most river samples are surface grab samples. EPA admits that
there is no evidence to support its fears. DOE has measured well below
the surface but has found no unusually low DO concentrations.
The report describes a crude mathematical model developed by
EPA. The model "predicts" that DO will be far below the standard even
upriver from Spokane. It also "predicts" that the river contains several
times the "algicidal concentration" of zinc. Plainly, zinc has not wiped
out the indigenous algae. Condit (1972) reported algal blooms in the
Spokane River, and Bishop and Lee (1972) reported blooms in Long Lake.
18 July 1972
O'Neal (EPA) contends that phosphorus removal at Spokane would
remove "the majority of phosphorus from the Spokane River" only if two
conditions are met:
The phosphorus concentration above Spokane is reduced.
O'Neal thinks that phosphorus removal by the Bunker Hill
Co. will reduce the upriver concentration.
Spokane's sewers are fixed so that no raw sewage reaches
the river.
He concludes:
"If these conditions are not achieved, the effectiveness
of phosphorus removal at the STP is questionable."
O'Neal's comments are contained in a memo to Robert S. Burd (Director,
Air and Water Programs Division, EPA-Seattle.)
331
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August 1972
Todhunter and Cunningham (DOE) publish routine-monitoring data
from the summer of 1971. They found violations of the DO, temperature,
and coliform WQS the length of the river.
9 August 1972
EPA and DOE ask Spokane to remove phosphorus from its effluent.
24 August 1972
EPA explains its request. The Spokane River will not meet WQS,
it argues, unless Spokane removes phosphorus from its discharge:
"Our joint water quality objectives for the river and
adjacent waters will not be achieved without phosphorus
removal at the City of Spokane."
EPA does not attempt to prove that Spokane causes specific
ailments in the river. Instead, its arguments depend on a general belief
that phosphorus or algae are somehow not good:
"The adverse impact of high plant nutrient levels (phosphorus
and/or nitrogen) on water quality is well documented both
nationwide and specifically in the Spokane Basin."
In fact, the connection between phosphorus and water-quality problems is
not well documented (or even clear) in the Spokane River.
EPA does not identify which WQS are being violated by phosphorus.
There are no WQS for phosphorus or algae. The river's temperature and its
coliform levels (which do violate the WQS) will not be affected by phos-
phorus removal. Perhaps EPA was thinking of DO; after all, Cunningham
and Pine (1969) attributed the hypolimnetic anoxia in Long Lake to decom-
posing algae. However, EPA never mentions either DO or Long Lake.
332
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Although many researchers have recommended phosphorus removal
for Spokane, the evidence for phosphorus removal is meager. Cunningham
and Pine wanted an intensive survey to check their hypothesis that decom-
posing algae deoxygenate Long Lake, but no one has obliged them. Bishop
and Lee (1972) thought that "nutrient build-up" caused trouble in Long
Lake and in the Spokane River below, but could not prove it because their
survey was not designed to identify the cause of the trouble. Condit (1972)
found the ecology of the Spokane River more complex than earlier studies
had suggested. He found that "high runoff" sometimes caused algal blooms,
and that phosphorus sometimes inhibited algal growth. Algae were limited
sometimes by the availability of phosphorus, sometimes by nitrogen, and
sometimes by something else, perhaps manganese.
EPA supports itself with Bishop and Lee and with Condit, but
these supports are not sturdy. Bishop and Lee recommended phosphorus
removal, but offered no evidence that it would improve the river. Condit's
results were complicated, and EPA oversimplified them. Here is EPA's
version:
"Condit concluded that sufficient quantities of nutrients
were present in the Spokane River to promote algal growths
in bloom proportions. Phosphorus was determined to be the
limiting nutrient."
Here is Condit's version:
"During the spring months high runoff provided adequate
nutrients to promote algal growth in bloom proportions.
The large biomass reduced phosphorus concentrations to
limiting levels in the river. The especially high algal
production in the lover river was due in part to the added
phosphorus contributions made by the waste-water treatment
plant above the Bowl and Pitcher Bridge [viz. the Spokane
STP]. Dissolved orthophosphate levels at this station
were sufficiently high enough to cause inhibition to algal
growth rates when additional phosphorus was Introduced in
the bioassay. The August bioassay indicated that productivity
333
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was governed by factors other than limiting concentrations
of phosphorus. Nitrogen was found to be limiting in Por-
cupine Bay [RM 13], while manganese appeared to be a
limiting factor in Sullivan Road [RM 88] waters."
Condit found that the number of algae increased from Spokane to Long Lake
during the spring, but decreased in August. There were far fewer algae
and much higher concentrations of phosphorus in August (when Spokane
supplies most of the phosphorus) than in June (when Spokane's contribution
/
is a smaller part of the total flux). In short, the relationship between
Spokane's phosphorus discharge and algal blooms is still undefined.
EPA, however, was convinced that limiting phosphorus would
eliminate algal blooms:
"A large volume of research is available which indicates
that at phosphorus levels below 0.05 mg/1 noxious algal
growths will be restricted."
EPA should have read Condit more carefully. He reported greater algal
blooms during June, when the river carried less than 0.05 mg/1 of total
phosphorus, and lesser blooms during August, when the river carried more
than 0.05 mg/1 of total phosphorus. EPA's theory is flatly contradicted
by Condit's evidence.
EPA worries that algal blooms may become much worse in the near
future. The Bunker Hill Company is planning to reduce its zinc discharge,
which will lower zinc concentrations in the river. EPA fears that the
zinc is inhibiting algae, and that they will thrive without it. However,
they advance no evidence to substantiate these fears.
EPA used its crude mathematical model to devise ways of main-
taining the river's phosphorus concentration below 0.05 mg/1. The model
predicts that even after the Bunker Hill Company removes phosphorus from
its discharge, there will still be too much phosphorus in the river.
334
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Consequently, Spokane must remove phosphorus from its discharge too.
EPA cannot pin any WQS violation on phosphorus from Spokane.
EPA's decision grew out of a loose reading of the skimpy evidence, wishful
thinking, and an unproven mathematical model; it will not stand up to
scientific scrutiny.
EPA's justification was appended to a letter from Robert S. Burd
(Director, Air & Water Programs Division, EPA-Seattle) to John A. Biggs
(Director, DOE).
5 September 1972
Burd (EPA) warns Spokane that it is not complying with its
schedule and threatens "enforcement action." Burd expects zinc concen-
trations to drop in the fall of 1973 which, he thinks, will cause "critical"
algal problems in 1974, when tourists will be coming to Spokane's "Ecology
Fair," Expo-'74. EPA wants secondary treatment and phosphorus removal to
be in operation by 1 May 1974.
29 September 1972
David H. Rodgers (Mayor of Spokane) submits his schedule to EPA
and DOE. Rogers wants the new AWT plant to begin operating in November
1976, 30 months later than EPA's schedule.
10 November 1972
DOE issues a Notice of Violation (Docket No. DE 72-168) because
Spokane is not complying with Order #69-77. Spokane was ordered to have
AWT facilities (undefined) under construction by the end of 1972, but it
does not. (EPA did not award a construction grant to Spokane until 29
July 1974.) The Notice requires Spokane to provide secondary treatment
335
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plus 85% phosphate removal by October 1975 (17 months behind EPA's
proposed schedule, but 13 months ahead of Spokane's proposed schedule).
Spokane's plans to eliminate sewer overflows must "proceed on a timely
basis."
8 January 1973
Larry D. Biggs (Bovay Engineers, who were hired to design the
AWT plant) reviews the evidence for phosphorus removal and finds it
wanting:
"It is difficult to see from the data available how
phosphorous [sic] removal at Spokane's wastewater treat-
ment Plant will have any significant effect in reducing
the problem of oxygen depletion in the hypolimnium [sic]
of Long Lake. The oxygen demand of the bottom deposits
in the reservoir would probably deplete the D.O. in the
lower part of Long Lake in the absence of algae."
He thinks that phosphorus removal will be wasteful:
11...we are very much concerned that the City of Spokane
could build and operate a plant to remove phosphorous [sic]
at a cost of more than a half million dollars a year with-
out making any substantial improvement to the dissolved
oxygen problem in Long Lake beyond what could be accomplished
with normal secondary treatment."
20 February 1973
Pine (DOE), Schmidt (EPA-Seattle), Miller (EPA-Corvallis),
Soltero (Eastern Washington State College at Cheney), and Funk (Washington
State University at Pullman) testify at a large meeting at Spokane City
Hall. William B. Schmidt (Chief, Water Quality Monitoring Section, EPA-
Seattle) writes that "the data presented by each speaker appeared to
consistently point out the need for phosphorus removal from Long Lake if
there is any chance of reducing algal productivity." EPA and DOE stuck
to their positions despite Biggs' objections.
336
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20 March 1973
DOE issues an order (Docket No. DE 72-186) to Spokane. Spokane
must provide secondary treatment and 85% "phosphorous" removal by 30 June
1976 (26 months behind EPA's proposed schedule, but 4 months ahead of
Spokane's proposed schedule). DOE finds the ESB report (July 1972)
inadequate, and requires two more engineering reports one for the STP
(due 1 July 1973) and one for the sewers (due 1 October 1973).
June 1973
Bovay Engineers publish a draft environmental assessment. They
concluded that a secondary STP would improve the DO, turbidity, and bac-
terial quality of the river just downstream from the STP discharge. Their
assessment of phosphorus removal was grudging and non-commital:
"Phosphorus removal may have a beneficial effect on the water
quality of Long Lake. The amount of this effect or the
time frame in which this effect will be felt is unpredictable.
Phosphorus removal at the Spokane treatment plant will de-
crease the amount of phosphorus introduced into Long Lake
but the relative size of this reduction is unknown. Other
phosphorus sources, particularly agricultural runoff, have
not been quantified. The amount of phosphorus of muni-
cipal origin retained in Long Lake is unknown. The situa-
tion is clouded further by the recycling of nutrients in
the lake. That is, the phosphorus and other nutrients in
the lake can be used repeatedly. The algae uses [sic] the
phosphorus to grow, but when the algae dies and decomposes
[sic], the phosphorus is released in a form suitable for
further growth. The phosphorus is partially removed by
discharge from the dam. The extent of this recycling and
the extent of removal from the lake are unknown."
Bovay investigated land disposal of the STP effluent. They
concluded that it was too expensive and would delay the project.
337
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June 1973
EPA publishes a study of the Spokane River conducted during
autumn 1972. EPA's survey was similar to the older surveys; despite
O'Neal's memo (11 July 1972), it was not an example of "monitoring by
objectives." It did not identify the cause of anoxia in Long Lake, nor
was it designed to. It did not determine the causes of the algal blooms,
nor did it track the location, magnitude, type, and timing of the algal
blooms over a season. EPA did measure the sources of phosphorus during
low riverflow, but EPA admitted that low riverflow is not the proper time
to measure. The study dispelled two of EPA's earlier worries (see
11 July 1972); EPA's fear of low-DO groundwater proved groundless, and
its mathematical model which had predicted DO violations above
Spokane was wrong.
EPA reconstructed the mathematical model, despite its poor
performance. EPA could not use the model for Long Lake, however, because
this model cannot simulate an unmixed lake.
EPA persisted in recommending phosphorus removal at Spokane,
but admitted that there were no guarantees that algal blooms in Long
Lake would be altered:
"The significant question is whether reducing phosphorus
additions to Long Lake will effectively control algal
growths which by subsequent decay result in anoxic con-
ditions in the hypqlimnion during stratified conditions.
Because of the complexity of the phosphorus cycling in
lakes, it is difficult to predict the effect of reductions
in additions to the system."
EPA also suggested modifying Long Lake Dam to allow releases from several
levels. Although most researchers have suggested modifying Long Lake Dam,
the planners have never pursued the suggestion seriously.
338
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19 June 1973
DOE issues new WQS that are contradictory and uninterpretable.
"DOE revised its classifications, and for the first time includes reservoirs
under Lake Class:
"All reservoirs with a mean detention time of greater
than 15 days are classified Lake Class."
In the WQS, "mean detention time" has a peculiar meaning:
"'Mean detention time' means the time obtained by divid-
ing a reservoir's mean annual minimum total storage by
the 30-day ten-year low-flow from the reservoir."
By this definition, "mean" is very nearly "maximum." The mean detention
.time of Long Lake (as computed from DOE's formula) is much more than 15
days. Consequently, Long Lake should be assigned to Lake Class, but the
WQS mark it Class A. Which part of the WQS is one to believe? How can
one explain this contradiction?
The new WQS are more detailed but even less comprehensible
than the old. The word "natural," more than anything else, undermines
the WQS. The Spokane River is not natural: It has been hydrologically
transformed by a long series of dams. By physically altering the river,
the dams have altered its chemistry and ecology. Dams promote stagnation,
stratification, and settling of oxygen-demanding material, which in turn
promote hypolimnetic deoxygenation. Dams often cause water-quality
problems.
By defining the effects of dams as natural conditions, DOE has
forced pollution-control agencies to distinguish between the effects of
dams and the effects of discharges a distinction they are manifestly
incapable of making. Here is DOE's definition of "natural condition":
339
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"'Natural condition' means the resulting water quality
in the absence of any measurable pollutional effect due
to human activities excepting only the effects of depth,
volume, surface area or shoreline configuration resulting
from the legal physical alteration of a water body."
The ambiguity of "natural" affects all the WQS. The new WQS
hedge every criterion with this rule:
"Whenever the natural conditions are of a lower quality
than the criteria assigned, the natural conditions shall
constitute the water quality criteria."
Most of the Lake-Class criteria are hedged twice: once by the rule
quoted above, and once by the appeals to "natural conditions" quoted
below:
"Dissolved oxygen - no measurable decrease from natural
conditions."
"Temperature - no measurable change from natural conditions."
"pH - no measurable change from natural conditions."
"Turbidity shall not exceed 5 JTU over natural conditions."
"Aesthetic values shall not be impaired by the presence of
materials or their effects, excluding those of natural
origin, which offend the senses of sight, smell, touch, or
taste."
The new WQS have, in effect, suspended WQS for most of the
Spokane River. Until DOE determines "natural conditions" for Long Lake
and all the other impoundments that divide the river ~ which DOE does
not plan to do no one can know whether the river is in compliance
with WQS. No one can know whether Spokane's discharge causes WQS
violations. No one can know what is (or would be) natural if the river
weren't artificial.
340
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30 June 1973
William H. Funk at al. (Washington State University and Univer-
sity of Idaho) publish a study of the Coeur d'Alene basin and the upper
Spokane River conducted during 1971-1972. Their work was funded by the
U.S. Office of Water Resources Research, not by EPA or DOE. They contend
that algal growth in the upper Spokane is controlled by the nutrients
from Lake Coeur d'Alene. The controlling nutrient varied:
"Orthophosphate phosphorus...probably became limiting to
further phytoplankton growth in the late summer. Nitrate
nitrogen...was considered limiting during late summer and
fall."
According to their data, the nutrient Outflow from Coeur d'Alene Lake
varied dramatically from month to month. On 13 May 1972, for instance,
dissolved-orthophosphate phosphorus below the lake (but above the Spokane
.
STP) ranged from 0.01 to 0.02 mg/1; one month later, on 15 June 1972, it
ranged from 0.20 to 0.30 mg/1 a whopping increase. The increase cannot
be explained by changes in riverflow, for the riverflow was nearly iden-
tical. No one has researched or attempted to explain these variations,
although they will undoubtedly affect the success of phosphorus removal.
Funk et al. conclude that the Spokane River is "of good to
excellent quality except for metallic content":
"There is still, however, a considerable amount of Zn,
Pb, and Cu and other metals continually being supplied
through the Coeur d'Alene River - Lake system. These
metals are concentrated by the algae and other aquatic
plants in the river and passed on to aquatic insects and
fish feeding upon the plants. There appears [sic] to be
relatively large quantities of metallic elements in the
tissues of aquatic insects and fishes from the upper
Spokane River. It also appears, however, that most of
the metallic elements must be in a relatively innocuous
form since the fishes are swimming in waters containing
as much or more than that quantity necessary to injure
them under laboratory conditions."
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30 June 1973
Bovay Engineers submit on schedule one of the engineering reports
required by the DOE order (28 March 1973). They recommend a 40-mgd
activated-sludge STP with chemical addition for phosphorus removal. They
estimate that operation-and-maintenance costs'will be $1,350,000 a year,
of which $530,000 will be for phosphorus removal.
Bovay thinks that phosphorus removal alone will not cure Long
Lake and that phosphorus removal during most of the year is wasteful:
"...there is some question as to how much the dissolved
oxygen problem in Long Lake will be affected by the
required waste treatment. It is not unlikely that
reservoir mixing will be needed to further reduce the
oxygen depletion problem. It may be feasible to control
plankton production in Long Lake satisfactorily by re-
moving phosphate from Spokane's wastewater on a seasonal
basis rather than year-round, since the period of sub- *
stantial plankton production is comparatively short. By
reducing phosphorus input into the reservoir during the
principal plankton production season and keeping the
reservoir mixed, it should be possible to control pro-
ductivity without removing the phosphorus during other
times of the year."
1 July. 1973
Raymond A. Soltero et al. (Department of Biology, Eastern
Washington State College at Cheney) publish An Investigation of the Cause
and Effect of the Eutrophication in Long Lake, Washington. This study,
like Funk's, was funded by the U.S. Office of Water Resources Research,
not by EPA or DOE. Soltero et al. sampled Long Lake at five stations,
weekly in the simmer of 1972 and mbnthly in the spring and fall of 1972.
They measured DO, temperature, conductivity, phosphate, nitrate, etc. at
3-meter intervals from surface to bottom, but they did not measure any
form of oxygen demand or analyze any sediment. They composited samples
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taken at regular intervals within the euphotic zone (i.e. the waters
that received more than 1% of the light at the surface) to analyze algal
blooms. They counted each species of phytoplankton and determined the
concentrations of chlorophyll a^, the volumes of phytoplankton, and pri-
mary productivity. They also surveyed water quality above Long Lake.
Although this study is the most comprehensive so far, it does not solve
the mysteries of Long Lake. Instead, it shows that the planners' hypo-
theses are too simplistic, and that there are no simple and consistent
relationships between Spokane's phosphorus discharge and algal blooms in
the lake.
The various algal measures often contradicted each other; the
season could not be separated into blooms and die-offs. The volume of
phytoplankton (per liter of euphotic zone) was greatest in May, but the
chlorophyll ji concentration was greatest in June and the number of algae
was greatest in July. Primary productivity had two maxima, one in July
and the other in August. Sometimes one measure rose as another fell, but
sometimes they all rose and fell together.
Soltero et al. used multiple-linear-regression equations to
analyze the data, but could not explain much of the variance. They found
that they could improve the correlations among the algal and chemical
measures by ignoring the depth of the euphotic zone and plotting the data
as a function of the surface area of the lake. These plots stretch the
August and September peaks, but shrink the June peaks. It would be
difficult to justify this type of analysis (and Soltero et al. did not
try) because the algal measurements were made not on surface grab samples
but on composites of samples taken at regular intervals through the
343
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euphotic zone. The search for correlation led to puzzling results.
Most of the variance was explained by conductivity, temperature, and
ammoniacal nitrogen, not by phosphate.
Soltero et al. did not publish bivariate correlations between
phosphate and anything else; they never showed a simple correlation between
phosphate and algae. In the regression equations they did publish, phos-
phate was never the most significant term. Their work undermines EPA's
and DOE's conclusions: The relationship between phosphorus and algal
blooms is neither simple nor consistent.
This study creates a dilemma for the pollution-control agencies.
What is the best measure (or combination of measures) of an algal bloom?
Should the results be manipulated as a function of surface area? How
big must an algal bloom be to interfere with the beneficial uses of Long
Lake? Since no one has unraveled the interwoven causes of algal blooms
in Long Lake, how can the pollution-control agencies justify their orders?
These are not trivial questions: They go to the heart of pollution-control
planning.
Soltero et al. avoided these tough questions. They drew few
conclusions, particularly about the relevant issues: the causes of anoxia,
the causes of algal blooms, and the relationship between Spokane's phos-
phorus discharge and algal blooms in the lake. Because they did not
publish their raw data (only selected averages and summaries), they pre-
vented other researchers from using their data to explore issues that
they themselves had neglected.
One of the neglected issues relates to seasonal variations.
Spokane's relative contribution to the fluxes of the Spokane River is
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almost certainly lower In the spring (when riverflows are high) than In
the summer or fall. Condit (1972) concluded that there were algal blooms
above Spokane in 1971, and he blamed "runoff" for causing them. The
spring bloom in 1972 occurred before the lake was stratified, when river-
flows were very high (about 30,000 cfs), when the mean-detention time
was short (about 4 days), and when nitrate and soluble-orthophosphate
concentrations were near zero (as far as one can tell from the published
graphs). The summer and fall blooms occurred when the lake was stratified,
when riverflows were low (2,000-3,000 cfs), when the mean-detention time
was long (about 50 days), and when the lake was warmer, saltier, and more
nutrient-laden. Would there have been a spring bloom in Long Lake even
if Spokane had been wiped off the map? To what extent did the spring
bloom contribute to later blooms, and to what extent was it responsible
for the anoxia?
Soltero et al. found a "penstock current" in the lake. During
the summer, they say, the inflow from the Spokane River moved through the
lake at the depth of the power penstocks (i.e. the tubes through which
Washington Water Power Company withdraws water from the lake). During
the fall, when the river water was denser than lake water, the inflow
moved along the bottom and pushed out the stagnant, deoxygenated water.
These current patterns were not continuous, but changed from week to week.
Soltero et al. did not use dye, drogues, or meters to measure velocity and
track the currents; their conclusions were drawn from conductivity measure-
ments only.
There is an irregularity in the conductivity data. From August
to September, the bottom waters just behind Long Lake Dam became less
345
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salty, although that part of the lake was becoming saltier. This record
of desalinization must be a distortion of the reality. Either Soltero
et al. were measuring several pockets of water or their conductivity
meters were not working properly.
Soltero et al. claim that the decomposing sediments released
nitrogen and phosphorus, and that the released nutrients nourished algae:
"Another major source of nutrients supporting excessive
phytoplankton growth in the reservoir was the bottom
sediments."
However, they do not explain how the nutrients get to the euphotic zone,
where they are used by algae. The distinct conductivity strata and the
thermocline suggest that there are barriers to the vertical movement of
*
salts. Yet Soltero et al. imply that nitrates and phosphate salts
ascend freely through these barriers. Surely the reader deserves an
»
explanation.
They conclude that the Spokane STP provides most of the phos-
phorus in the Spokane River, but, once again, their conclusions overstep
the data:
"Over a period of eleven months, the orthophosphate load
in the river was determined to be 0.32 tons/day [above the
STP]...and 1.99 tons/day [below the STP]...or an enrichment
of 1.67 tons/day of orthophosphate."
They measured weekly, at best; weekly grab samples cannot account for
daily variations in an STP discharge and in the river's flux. They
reported their results as average concentrations, average fluxes, and
discharge-weighted concentrations but did not account for the seasonal
variations in their measurements. Most of their measurements were taken
during the summer, and therefore they are inherently biased. To determine
the mass balance of phosphorus one must carefully measure the upriver
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contribution which must be measured at flow peaks (when river fluxes
are greatest) as well as during the rising and falling portions of the
hydrograph. Monthly samples during the spring and fall are far from
sufficient.
In short, the study raises more questions than it answers, and
it does not provide the answers that are needed for good pollution-control
planning.
No one denies that Spokane's SIP discharges large quantities of
phosphorus, and no one denies that there are other large sources of
phosphorus in the drainage basin. However, no one has established a clear
connection between algal blooms in Long Lake and phosphorus from any
source; no one has firmly established that algal rain is largely respon-
sible for the hypolimnetic anoxia of Long Lake. Phosphorus may be the
growth-limiting element for algae in Long Lake, and the algal rain may
deoxygenate the hypolimnion; then again, they may not. These are hypotheses,
not established scientific facts. The work of Soltero et al. did not
convert these hypotheses into facts.
2 August 1973
A.J. Reisdorph (Superintendent of the Spokane STP) argues that
water quality in Long Lake is not Spokane's responsibility:
"...the water impoundment is not the result of any act
of the City but is rather Washington Water Power Co. [sic]
Thus, Long Lake is their problem as well as a source of
revenue. The City, in essence [,] will be subsidizing
WWP if we pay for Phosphate removal.... Were it [viz.
the Spokane River] not impounded, there would certainly
be no need for nutrient removal."
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Reisdorph's comments are belated but pertinent. Who is
responsible for the pollution of Long Lake? Is it a case of pollution
induced by the hydropower facility, municipal pollution, or both? If
Reisdorph is right if Long Lake Dam creates the need for phosphorus
removal -- should the power company pay all the cleanup costs?
Is DOE being unfair? DOE required dam operators to study the
environmental effects of their dams and to "provide recommendations for
improvements in operation and other measures as necessary to minimize or
eliminate any adverse effects of the impoundment" (December 1967). DOE
never enforced this provision against WWP. It took action against Spokane.
Is EPA condoning an industrial subsidy, contrary to the intent
of P.L. 92-500? EPA approved Washington's WQS, which define dams as
"natural conditions", although Long Lake Dam is patently a moneymaking
enterprise, not a natural condition. EPA has fought for phosphorus
removal, but has scarcely mentioned modifying the dam.
These are important questions, but both DOE and EPA have
neglected them.
5 September 1973
Glen A. Yake (Assistant City Manager, Spokane) suggests that
Long Lake can be destratified for $60,000 in construction costs plus
$4,000 per month in operating costs. Yake does not use Reisdorph's
arguments; he uses Bovay's (30 June 1973) that seasonal phosphorus
removal plus destratification might be more effective than year-round .
phosphorus removal.
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19 October 1973
Larry D. Biggs (Bovay Engineers) submits an analysis of infil-
tration and .inflow. He finds that dry-weather infiltration is about 1/3
of dry-weather flow (28 mgd). Enlarging the STP to accommodate infiltra-
tion is less expensive, he says, than trying to eliminate infiltration.
Owing to combined sewers, Spokane's wet-weather inflow greatly exceeds the
hydraulic capacity of the sewer system. Biggs estimates that the flow
rate during a once-in-five-years storm is 668 mgd; the intake sewer at
the STP can take only 146 mgd. The difference 522 mgd gets no
treatment. Biggs suggests that the STP should give full treatment to
part of the 146 mgd that reaches it, and partial treatment to the rest.
4 January 1974
Biggs (Bovay) asks DOE for a definition of "85% phosphorus
removal." He suggests that Spokane should have to remove 85% of its
influent phosphorus only as a 30-day average, only for flow rates less
than 57 mgd (the maximum-daily-dry-weather flow for which the STP is
designed), and only "during those portions of the year when phosphorus
loading reduction to the Spokane River is necessary."
29 January 1974
Biggs (Bovay) tells Roger James (Director of Public Utilities,
Spokane) that Kennedy-Tudor Engineers (who are conducting a study of the
Spokane River for the U.S. Corps of Engineers) are not convinced that
phosphorus removal will improve Long Lake. Biggs suggests that James
should ask the pollution control agencies to reconsider their decisions.
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20 February 1974
Daniel V. Neal (Bovay Engineers) describes a meeting with EPA,
DOE, and Spokane on 14 February 1974. James (Spokane) asked the pollu-
tion-control agencies to reconsider their decision on phosphorus removal.
Burd (EPA-Seattle) replied that the evidence for phosphorus removal is
technically conclusive.
28 February 1974
William B. Schmidt (EPA-Seattle) describes a meeting with DOE,
Kennedy-Tudor, Soltero (Eastern Washington State College) and Funk
(Washington State University) on 26 February 1974. Soltero, according
to Schmidt, said that decaying phytoplankton caused anoxia in Long Lake,
and that phosphorus from the Spokane STP caused the first seasonal algal
bloom. Both Soltero and Funk thought that phosphorus removal would
reduce the algal blooms in Long Lake. Bruce Collins (Kennedy-Tudor Engin-
eers) says that his question about the effects of phosphorus removal was
only a question, and was misinterpreted by others. Schmidt concludes:
"...there is no data available to support an alleged
contention [sic] that Long Lake would still have phyto-
plankton blooms even after phosphorus removal at the STP."
He is wrong; there are available data. Condit (1972) whose work EPA
used to justify phosphorus removal found that landwash could cause
algal blooms:
"During the spring months high runoff provided adequate
nutrients to promote algal growth in bloom proportions."
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March 1974
Bovay Engineers publishes a two-volume study on industrial cost
recovery: City of Spokane. Washington, Wastewater Treatment Plant Expansion,
Proposed System for User Charges and Industrial Cost Recovery. This
"I.C.R. Report" contains more than a system of charges for industrial
users of the SIP. It makes explicit the assumptions and data that guided
the engineers in designing the new STP; it is more explicit than earlier
reports on STP design.
6 March 1974 .
Robert S. Burd (EPA-Seattle) describes a meeting with Spokane,
DOE, and others on 4 March 1974. Burd and Jerry Bollen (DOE) told
Spokane that they must remove phosphorus.
14 March 1974
Bollen (Assistant Director, Office of Operations, DOE) formally
informs Spokane that it must remove phosphorus. Bollen is absolutely
certain about the decision:
[The technical staffs of EPA and DOE] "have concluded that
phosphorus removal is an absolute necessity to improve,
and then preserve, the water quality of Long Lake and the
Spokane River, both above and below the Lake.... Had there
been a question regarding our analysis of the problem,
and its solution, we would not have reaffirmed our position
to proceed with the Order [of 28 March 1973]."
Bollen accepts Biggs' definition (4 January 1974) of "85% phos-
phorus removal" with two changes: He reduced the period in which the
results are averaged from 30 days to 7 days, and he insisted on year-
round (rather than seasonal) phosphorus removal.
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Bollen forbids the STP to bypass raw sewage. All the influent
must be given primary treatment and must be disinfected. Bollen says
nothing about the discharge of raw wastes from overflowing sewers.
3 June 1974
DOE gives the Spokane AWT project 942 priority points on the
Master Work Sheet of its Wastewater Treatment Construction Grants Program.
1 July 1974
Soltero et al. (Eastern Washington State College) publish their
second annual study on Long Lake, which is nearly identical to the first.
However, Long Lake was much different in 1973. Much more of the lake was
anoxic and the anoxia lasted much longer. Soltero et al. blamed phyto-
plankton for the change:
"This year's heightened oxygen depletion was attributed
to the increased phytoplankton standing crops that even-
tually underwent decomposition on the reservoir's bottom.
The greatest percentage of organic matter was determined
to be in the lower end of the reservoir which coincided
with the areas of greatest phytoplankton standing crop."
Their data, however, do not entirely support this conclusion.
In 1973 (as far as one can tell from the published graphs), perhaps twice
as much of Long Lake was anoxic as in 1972, and the anoxia lasted nearly
three times as long. True, Soltero et al. did find more algae: Mean-
daily chlorophyll a_ increased from 11.45 mg/m^ in 1972 to 18.71 mg/m^ in
1973, and both the number and the volume of phytoplankton increased by
even more (as far as one can tell from the published graphs). These data
support their conclusion. However, Soltero et al. analyzed the sediments
for the first time in 1973, and found that the percentage of organic
matter in the sediments did not increase from June to December 1973.
352
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If wave after wave of algae died and "eventually underwent decomposition
on the reservoir's bottom", as Soltero et al. contend, shouldn't all
those decomposing phytoplankton have increased the percentage of organic
matter in the sediment? Actually, the percentage of organic matter
barely changed from station to station or from day to day. The mean
percentage during the first day was 9.58%, during the last day it was
9.80%, and during the entire year it was 9.19%.
Perhaps the low riverflows and the long detention times affected
the extent of anoxia in 1973. The flow of the Spokane River had not
exceeded 10,000 cfs since June 1972; it dropped below 1,000 cfs during
July-September 1973. Soltero et al. calculated that the mean-detention
time in Long Lake was 91.03 days in August 1973; in 1972 the longest
mean-detention time for any one month was only 55.30 days.
The 1973 data of Soltero et al. depict a very complicated lake.
Some of the data show the lake to be divided into three sharply defined
strata, some show it divided in two, and some show it to be incompletely
mixed but unstratified, with only gradual gradations. The conductivity
data often show two sharp breaks changes of up to 100 micromhos/cm
within a few meters which suggest that there was a penstock current.
The DO and pH data, on the other hand, consistently show the effect of
algae in the top 8 meters or so of the lake, but adhere to no particular
pattern below. The phosphorus data show the effect of algae at the sur-
face, and there were high concentrations of phosphorus at the bottom
at some stations, but not at all. The nitrate data are unlike anything
else; large nitrate peaks appear and remain at mid-depth. The temperature
data show no sudden changes with depth, just a gradual cooling. What
353
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physical or biological phenomena could account for these puzzling
measurement s?
As in their first study, Soltero et al. did not measure any
kind of oxygen demand. They found no consistent relationship among the
types of algal measurements, and published no bivariate correlations
between phosphorus and algae (or anything else, for that matter). They
hedged their conclusion about nutrients released from the sediments:
"Another source of nutrients that could support excessive
phytoplankton growth in the reservoir was the bottom
sediments."
The year before they were sure that nutrients from the sediments did
support "excessive phytoplankton growth in the reservoir."
There is an important new conclusion; it appears only in the
abstract, and is never supported in the main body of the report:
"It was concluded that the reservoir's phytoplankton
production was sufficient to substantiate phytoplankton
decomposition as the cause of the hypolimnetic anoxia."
To support this remarkable conclusion, Soltero et al. would have had to
adduce conclusive proof on at least three points:
The sediment oxygen demand at the start of the season
was insufficient to deoxygenate the hypolimnion
The long-term BOD dispersed through the hypolimnion at
the start of the season was too low to contribute signi-
ficantly to anoxia
The decomposing algal rain that drifted down exerted
enough BOD to deoxygenate the hypolimnion early in
the summer.
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Soltero et al. did not publish any evidence on any of these
points. They did not calculate the mass of the decomposing algae that
rain down into the hypolimnion. They do not know whether the algal rain
exerts enough BOD to deoxygenate the hypolimnion. They do not know
whether this supposed source of BOD acts rapidly enough to deoxygenate
the hypolimnion by the beginning of July, although they reported that
the hypolimnetic DO had already fallen to 1 mg/1 by then. They have
never measured any form of oxygen demand in the lake, and are therefore
in no position to assess its importance. They have never measured the
oxygen demand of the sediments at any time. Their measurements of organic
matter in the sediments do not relate directly to the question of oxygen
demand, but they show that sedimented organic matter did not build up
during the summer. How could decomposing algae have rained down into
the hypolimnion in sufficient quantity to deoxygenate this enormous mass
of water without accumulating in the sediments as organic detritus?
29 July 1974
EPA offers Spokane a grant of $973,125. Spokane accepts on
8 August 1974. This small seed of a grant will blossom within a year to
over $30,000,000.
At this point, it may help to review what was known about Long
Lake and its problems when the grant was offered. There had been five
major studies of the lake:
Cunningham and Pine (1969)
Bishop and Lee (1972), with algal assays by Condit (1972)
EPA (June 1973)
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Soltero et al. (1 July 1973)
Soltero et al. (1 July 1974)
These studies documented algal blooms at the surface and anoxia
in the depths of the lake, but did not establish their causes.
EPA, DOE, and Soltero believed that Spokane's phosphorus
discharge magnifies algal blooms, and that the decomposing remains of
these blooms cause the hypolimnetic anoxia. However, they were unable
to support their case with hard evidence and rigorous logic. Their case
for a causative connection between Spokane's phosphorus discharge and
algal blooms in Long Lake is weak because:
They have not established that the size of an algal
bloom depends on the amount of phosphorus in the
epilimnion
They have not determined how much of the phosphorus
that actually nourishes an algal bloom comes from
Spokane's discharge, how much from other sources
upriver, how much from the lake sediments, and how
much from previous algal blooms.
Their case for a causative connection between algal blooms on the surface
of the lake and anoxia in the depths is weak because:
They have not determined that the mass of decomposing
algae is sufficient to cause anoxia, even assuming
complete decomposition during the summer
They neglected to demonstrate that the long-term BOD
entering the lake in the Spring and remaining dispersed
356
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through the summer is insufficient to account for
the anoxia
They failed to demonstrate that the sediment oxygen
demand at the start of the algal-bloom season is
insufficient to cause anoxia.
In short, they failed to show that their hypothesis is a sufficient
explanation, and they failed to show that two other obvious hypotheses
were insufficient explanations. These twin failures are not the mark of
distinguished science.
At least one of these failures is easy to correct. BOD is an
easy measurement, and the importance of long-term BOD is easily assessed.
Spokane's STP regularly analyzes its influents and effluents for BOD; the
STP laboratory might just as easily run BODs on samples from Long Lake.
An easier, even less artificial BOD test could be used. At the end of
the Spring flush, and working at several depths in the lake (every ten
feet, for example), field crews could extract a large sample of water
at each depth. After carefully measuring the temperature and DO of each
large sample, the sample should be divided into approximately twenty
sealed containers. The sealed containers should then be put back into
the lake at the depth corresponding to the original large sample. Every
week or so, technicians should pull up one of these sealed containers
and measure its DO and temperature. The resulting DO curve will trace
the deoxygenating effect of the dispersed BOD that was washed into the
lake during the Spring flush.
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It is unprecedented in ciur experience to encounter lengthy
arguments on deoxygenation that are not accompanied by detailed measure-
ments of oxygen demand. How can one seriously account for deoxygenation
without accounting for biochemical and sediment oxygen demand? How could
this obvious omission have escaped detection? This is an amazing per-
formance; we have never seen its like.
There is some evidence that algal blooms and anoxia will persist
even after Spokane removes phosphorus from its wastewaters. Condit
found algal blooms in the Spokane River above the STP; he attributed
these blooms to "high runoff." Soltero et al. found that the percentage
of organic matter in the sediments of Long Lake did not increase from
June to December 1973. If the sediment oxygen demand parallels the per-
centage of organic matter in the sediment (and there is no direct
»
evidence that it does), then summertime algal blooms are probably irrele-
vant to hypolimnetic anoxia. We repeat the obvious question: How could
decomposing algae have rained down into the hypolimnion in sufficient
quantity to have deoxygenated this enormous mass of water without accumu-
lating in the sediments as organic detritus?
If the scientific imperative for phosphorus removal is unclear,
the bureaucratic imperative is murky. The WQS for the Spokane River and
Long Lake are rendered meaningless by their vague wording and their
impossible requirements (no deviation from "natural conditions" in an
artificially restructured river). State regulations require dam owners
to explore environmental improvements that could be achieved by modifying
the dams, but no one has seriously studied how Long Lake could be improved
by modifications of Long Lake Dam (e.g. by providing multiple-level
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release works) or by facilities for destratifying the lake (e.g. large
pumps to promote circulation and to induce mixing between the hypolimnion
and the epilimnion). Pollution-control agencies have never pressed
enforcement of these State regulations.
DOE was empowered to order phosphorus removal by a 1945 State
law, which allows it to
"require the use of all known available and reasonable
methods... to prevent and control the pollution of the
waters of the State of Washington."
But DOE has never made a compelling case for what is "reasonable."
Primary treatment was apparently "reasonable" in 1966, when Cunningham
and Pine concluded that 40% of Long Lake was anoxic. And it is by no
means clear that phosphorus removal is "reasonable" now.
9 September 1974
Roger James (Spokane) summarizes Spokane's strongest objections
to a draft NPDES permit. One of the objections pertains to phosphorus
removal:
"The permittee shall operate and maintain the secondary
plus phosphorus removal facilities at the maximum degree
of efficiency at all times."
Here is James' comment:
"The City has repeatedly, and with the strong backing from
learned authorities throughout the world, insisted that
85% phosphorous [sic] removal during periods of high water
in the river would accomplish nothing. The State and the
Federal governments have rejected the City's plea. The
City realizes that the State and Federal governments have
rejected the City's plea. The City realizes that the State
and Federal governments do not have to prove their posi-
tion, and is proceeding to incorporate phosphorous
[sic] removal on a year-round basis. The City does plan
to carry on an intensive study after the completion of the
plant in the hopes that hundreds of thousands of dollars
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per year could be saved by not operating the phosphorous
[sic] removal facilities during certain portions of the
year. The City would hate to find a provision in the
Discharge Permit which would tie its hands, even if it
were able to prove its longstanding contention."
Spokane also objects to a provision requiring it to "assist
DOE" in policing industrial pre-treatment standards. Spokane contends
that enforcement of industrial pre-treatment is the State's responsibility.
October 1974
Finnemore and Shepherd (Systems Control, Inc., under contract
to EFA-Washington, D.C.) publish crude mathematical models of Long Lake
and the Spokane River. Crude models could hardly be expected to simulate
complex bodies of water like Long Lake. The models were unsuccessful:
"...Long Lake raises some marginal question to the
appropriateness of simulating it with the Deep
Reservoir Model."
"In no case were there sufficient d'ata for an accurate
verification of any model."
The data assembled by Soltero et al. had already demonstrated that Long
Lake is too complex for any simple model. The Systems-Control models
were built without Soltero's data, and therefore can be little more than
elaborate guesses.
25 October 1974
DOE issues NPDES permit #WA-002447-3 to the City of Spokane.
The Final Effluent Limitations become effective on 1 February 1977. Once
again, the limitations cannot be met because of delays in the construction
schedule. On 19 March 1968, the WPCC ordered Spokane to have a secondary
STP in operation by mid-1972. On 28 March 1973 DOE ordered Spokane to
have in operation by 30 June 1976 a secondary STP with facilities for
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85% phosphorus removal. The new Final Effluent Limitations will be
postponed too because the new STP cannot be completed by February 1977.
The NPDES permit gives three distinct phosphorus limits for
flow rates less than 57 mgd; it does not contain a numerical phosphorus
limit when the flow rate exceeds 57 mgd. The three phosphorus limits are:
(1) a maximum of 2.1 mg/1 in the effluent
(2) a maximum of 377 Ibs/day
(3) at least 85% phosphorus removal.
The permit specifies that the most stringent of these limitations shall
prevail. Here are the relevant sections of the permit:
"For secondary treated flowrates less than or equal to
57 MGD (the design maximum daily dry weather flow), the
effluent total phosphorus shall be (1) a maximum concen-
tration of 2.1 mg/1 and a maximum weight of 377 Ibs/day,
or (2) less than or equal to 15% of the influent total
phosphorus concentration and weight, whichever limitation
is more stringent, based on the arithmetic average of all
samples taken during any 7-consecutive day period."
"During any 7-consecutive day period that the average daily
flow is greater than 57 MGD, no effluent limitation on
total phosphorus shall be in effect. The permittee, how-
ever, shall continue to treat for phosphorus removal all
wastewater flows receiving treatment from the secondary
units."
These phosphorus limits are not equivalent. The "I.C.R.
Report" of March 1974 estimates that the influent phosphorus load will
be 2,400 Ib/day. To attain an effluent concentration of 2.1 mg/1 will
require removal of 71% of the influent phosphorus (i.e. removal of
1,700 Ib/day of phosphorus). The discharge will contain 700 Ib/day of
phosphorus, i.e. 29% of the influent load.
To attain an effluent load of 377 Ib/day, the STP will have
to remove 2,023 Ib/day (i.e. 84% of the influent phosphorus).
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To attain 85% phosphorus removal, the STP will have to remove
2,040 Ib/day of phosphorus; the effluent load will be 360 Ib/day.
This is quite a spread of values. It ranges from 1,700 to
2,040 Ib/day of phosphorus removal a difference of 20%. It ranges
from 360 to 700 Ib/day of phosphorus in the effluent a difference of
94%. It ranges from 29 to 85% phosphorus removal a difference of 56%.
How can DOE justify these inconsistent (but precisely specified)
limits? DOE cannot point to a rational wasteload allocation derived from
WQS. There are no wasteload allocations for phosphorus in the Spokane
River too little is known to produce a legitimate wasteload allocation
or to set a phosphorus standard that makes scientific sense. In the
absence of an official phosphorus standard for the Spokane River, EPA
suggested a standard of 0.05 mg/1 of phosphorus, on the theory that low
phosphorus concentrations in the river would limit algal blooms in Long
Lake. However, the evidence that EPA cited to support this standard
refuted the underlying theory (see the entry under 24 August 1972).
Moreover, Spokane's effluent would make the river exceed EPA's limit
during low riverflows even if it contained 2.1 mg/1 or 377 Ib/day of
phosphorus.
These effluent limits are especially curious because they do
not apply when wasteflows are highest (i.e. when the flow rate exceeds
57 mgd). Does this exemption make any sense? When wasteflows are
highest, a great deal of Spokane's wastewater is discharged raw to the
river from overflowing sewers and is discharged from the STP after
* having undergone only partial treatment. The NPDES permit explicitly
allows discharges of raw sewage from 41 places in Spokane. According to
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the permit, 5% of Spokane's wastewater overflows from the sewers (not 1%
as Esvelt & Saxton / Bovay estimated in July 1972). The permit allows
Spokane an unlimited phosphorus discharge when the phosphorus discharge
«
is greatest when rain washes filth from the streets and gutters and
raw sewage spurts from the sewers.
DOE has never given Spokane a fair hearing on the issue of
seasonal phosphorus removal. All of the dissolved phosphorus in the
river at the height of the flood season passes through Long Lake without
o
causing algal blooms. Some of the particulate phosphorus settles, no
doubt, but no one can explain how phosphorus in the sediments could
affect algal blooms. No one knows how much of the phosphorus in the
sediment comes from Spokane. No one knows how phosphorus in the sediment
might affect algal blooms if the hypolimnion were kept oxygenated (e.g. .
by artificially mixing Long Lake or by using multiple-level release works
to alter the internal currents in the lake). At the time, no one knew how
much phosphorus was in the sediments.
18 November 1974
DOE formally revokes its Order of 28 March 1973, owing to the
new requirements of the NPDES permit.
1975
EPA publishes a River Basin Water Quality Status Report for the
Spokane River basin. It contains summaries of river data collected during
December 1972-August 1973. EPA still believes that 0.05 mg/1 of total
phosphorus is a "potential algal bloom concentration", but does not
compare phosphorus concentrations with algal blooms. EPA claims that
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the Spokane STP is the largest source of phosphorus in the river:
"Total phosphorous [sic] and dissolved ortho-phosphorous
[sic] levels exceeded the potential algal bloom concen-
tration downstream of the Spokane STP during both high
and low flow periods. The Spokane STP is the major*
source of phosphorous [sic] in the Spokane River. In
addition, Hangman Creek is a significant source of total
phosphorous [sic] during the high flow runoff."
However, EPA's graphs show that Hangman Creek (a tributary entering the
Spokane River a few miles above the STP) contributes about twice as much
phosphorus as the STP during flood season, when fluxes are highest.
t
10 February 1975
EPA increases Spokane's grant to $1,209,375. Spokane accepts
20 February 1975.
24 March 1975
EPA increases Spokane's grant to $34,965,375. Spokane accepts
2 April 1975.
7 May 1975
EPA decreases Spokane's grant to $31,405,477. Spokane accepts
6 June 1975.
June 1975
EPA publishes Proceedings: Biostimulation - Nutrient Assessment
Workshop, which contains a report on algal assays of Spokane-River water
by William E. Miller et al. Miller et al. took three samples of the
Spokane but neglected to say when they were taken. The samples were
autoclaved (to sterilize the sample), carbonated (to restore the solution
to its original pH), and filtered through a 0.45-micron filter (to remove
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particles that would interfere with an electronic particle counter). The
samples were subdivided. Metallic ions were removed from some; nitrogen,
phosphorus, or both were added to others. All were inoculated with
Selenastrum capricornutum Printz, a laboratory strain that is widely used
because it is exceptionally easy to count; its principal scientific merit
is convenience. Miller et al. compared the growth of Selenastrum among
the samples, and concluded that zinc controlled algal growth:
"Algal growth potential in the Spokane River from Post
Falls, Idaho, to Riverside State Park, Washington [just
below the Spokane STP] is regulated by the average dis-
solved zinc content of 112 ug/1."
"A 20-fold increase in orthophosphorus loading to the
Spokane River system upstream from Riverside State Park
would have little effect upon the growth of planktonic
algae unless the zinc content of these waters is reduced."
"A natural reduction of zinc from 112 ug/1 at the Spokane
STP to 20 ug/1 at Long Lake Dam, 23 kilometers downstream
from the treatment plant, enabled algal growth to in-
crease proportionately to the orthophosphorus content of
the water."
However, EPA's assays are very artificial. Spokane-River water
that has been autoclaved, carbonated, filtered, and inoculated is Spokane-
River water in name only. Furthermore, Miller et al. relied on an implicit
assumption that may be false: that Selenastrum behaves like the indigenous
algae. There is no proof that the indigenous algae are affected by the
zinc concentrations in the river. They may have adapted; the plain fact
that there are algal blooms in the Spokane River suggests that they have.
July 1975
Soltero et al. (Eastern Washington State College at Cheney)
publish another study, funded by DOE, of Long Lake and the Spokane River.
In some ways, they report, Long Lake in 1974 behaved as it did in 1972.
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The extent of anoxia, the mean detention time, and the concentration of
chlorophyll _a in the euphotic zone were similar in both years.
For the most part, Soltero et al. repeated their earlier studies
and their earlier conclusions (see the entries for 1 July 1973 and 1 July
1974). They quoted their own conclusion that decomposing algae were suf-
ficient to cause anoxia, but once again neglected to support their con-
clusion with evidence:
"Soltero e£ al. (1974) concluded that the reservoir's
phytoplankton production '...was sufficient to substan-
tiate phytoplankton decomposition as the cause of
hypolimnetic anoxia1."
They sent samples of the euphotic zone to EPA-Corvallis for
algal assays with Selenastrum capricornutum (as described in the June
1975 entry). Samples taken when the lake was stratified were unaffected
by treatment to remove metals or by additions of phosphorus; all grew
Selenastrum equally well. These results do not support Soltero's (or EPA's)
case. Although it is a leap of faith to relate the growth of Selenastrum
in a laboratory to the growth of indigenous algae in Long Lake, EPA-Corvallis'
assays suggested that phosphorus did not limit algal growth in Long Lake
during the summer. Phosphorus removal in Spokane will affect algal growth
only if it reduces phosphorus concentrations to growth-limiting levels.
How much phosphorus must Spokane remove to make phosphorus the growth-
limiting algal nutrient in Long Lake during the summer? Soltero et al.
cannot say, and indeed, do not draw any conclusion from the assays about.
the behavior of algae in Long Lake. EPA's Selenastrum assay is too arti-
ficial for pollution-control planning in the Spokane basin.
For the first time, Soltero et al. took sediment cores of Long
Lake but they misinterpreted the analytical results. The cores contained
366
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alternating light and dark varves:
"Below 20 mm the sediments were more concentrated and gave
off an odor of hydrogen sulfide upon fractionation which
suggested that the oxidized microzone may have extended
to a depth of 25 mm. The sediment below 25 mm was char-
acterized by two distinct types of layering. Beds of
pale laminae 20-40 mm thick were separated by dark laminae
5-10 mm-thick in alternating sequence. Pale laminae
varied in color from light brown to dark brown whereas
dark laminae ranged from dark brown to blue-black."
Chemical analyses of the core showed that the concentrations of phosphorus,
nitrogen> and organic matter regularly peaked and fell with depth. Soltero
et al. found that the core was largely composed of sand and illite clay,
and erroneously concluded that the surface clay would form a barrier to the
phosphorus-laden sediment below:
"Higher concentrations of nitrogen and phosphorus in the
sediment occurred below the 25 mm depth in all cores.
This indicates that mixing between sediment layers and
vertical migration of nutrients into the sediment-water
interface has been minimal. This 'unique' feature was
most obvious in the phosphorus profiles."
"Data from the Long Lake cores indicates, nevertheless,
that internal recycling of nutrients, particularly phos-
phorus, via the bottom sediments in Long Lake will not
significantly contribute to the nutrient supply once
secondary sewage treatment with phosphorus removal begins.
The sediments below the 25 mm depth appear to be effec-
tively sealed by clays which would inhibit vertical
migration and leaching of nutrients from older sediments."
The fault in the logic of Soltero et al. is that the clay "seal" contains
much more than innocent clay and sand it is full of organic matter and
it is loaded with phosphorus. It is not necessary for phosphorus to
"migrate" through the sediments because there is plenty of phosphorus at
every depth. Soltero et al. never reported less than 1,000 mg/kg of
phosphorus (0.1%) at any depth, in any core and they usually reported
much more. They never reported less than 70,000 mg/kg of organic matter (7%)
367
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To place these figures in perspective, compare them with the concentration
of phosphorus in the sediments of the Maumee River Estuary, one of the most
phosphorus-rich areas in Lake Erie's western basin: Long Lake's sediment
contains about 1000 times as much phosphorus. With so much phosphorus in
Long Lake and more moving down the Spokane River every year what
is the likelihood that removing phosphorus from Spokane's sewage will
prevent algal blooms in Long Lake?
Soltero et al.'s optimistic conclusion is unwarranted:
"The abatement of. the present nutrient loadings to the
reservoir coupled with a relatively high seasonal flush-
ing rate and preservation of sediment integrity should
facilitate a rapid recovery of Long Lake."
They cited two case studies of phosphorus removal and its effect on lakes
that should have made them more cautious. In one, phosphorus removal did
not reduce the extent of anoxia, although it did reduce the magnitude of
algal blooms. In the other, phosphorus removal had no effect on algal
blooms. How can they be so sure that removing phosphorus from Spokane's
wastewater will clean up Long Lake?
August 1975
William H. Funk et al. (Washington State University and Univer-
sity of Idaho) publish another study of the Coeur d'Alene basin and the
upper Spokane River. Their work was funded by the U.S. Office of Water
i
Research and Technology. They found that the concentration of phosphorus
in the sediments of Coeur d'Alene Lake was no different from that of
Long Lake.
368
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November 1975 -
Greene et al. (EPA-Corvallis and Eastern Washington State
College) try to prove that Selenastrum assays are relevant to pollution-
control planning. Their "proof" is fraudulent. They claim that the
amount of Selenastrum that can be grown in a composite sample of water
from the euphotic zone of Long Lake a composite that has been cooked
at 121°C for 15 minutes, filtered, and sometimes spiked with EDTA can
"predict" the standing crop of indigenous algae in Long Lake (either the
algal volume or the chlorophyll a_ concentration) two weeks before the
sample was taken (if Long Lake was stratified at that time), or on the
same day the sample was taken (if the lake was not stratified), except
for 1/6 of the samples, which must be thrown away. Sound confusing? It
is nonsensical.
r
Here is how Greene et al. state their case:
"When the September 30 and October 21 samples were rejected
as outliers (on the evidence presented previously), a
linear regression analysis of the relationship between
indigenous phytoplankton and maximum yields of £. capri-
cornutum...indicated a high degree of correlation (r-0.95).
However, some data manipulation was necessary to achieve
this high correlation.... The samples collected on June
8, September 16, November 25, and December 16 were entered
into the linear regression program with the algal assay
yields relative to the indigenous phytoplankton standing
crop at the same time the sample was collected. The samples
collected from July 9 through September 13 were entered
with the laboratory yields relative to the indigenous
phytoplankton standing crop two weeks prior to the samp-
ling dates. At first this anomaly in the data was believed
to be caused by the effect of physical conditions (tem-
perature and/or light) upon the indigenous phytoplankton.
Further investigation determined that the shift of some
data relative to indigenous phytoplankton biomass and jS_.
capricornutum maximum yields correlated when the reservoir
was chemically and thermally stratified."
369
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"The linear regression analysis of the relationship
between indigenous phytoplanktbn volume and S^. capri-
cornutum maximum yields...resulted in an equation that
can be used to predict the average indigenous phyto-
plankton standing crop in Long Lake Reservoir."
"A linear regression analysis was done on the chlorophyll
ji content of indigenous phytoplankton (mg m~3) and mg
dry weight _§_. capricornutum 1~1.... The data were
manipulated in the same manner as the analysis of indi-
genous phytoplankton volume and S^ capricornutum yields,
depending on whether Long Lake was stratified or homo-
thermal.... The linear regression analysis of the
relationship between chlorophyll a^ (mg m~3) in the
indigenous phytoplankton populations and S_. capricornutum
maximum yields (mg dry weight 1~1) resulted in an equa-
tion that can be used to predict the mean chlorophyll a^
content of Long Lake Reservoir."
Greene et al. threw away the "outliers" mentioned above to improve another
correlation:
"...the samples collected on September 30 and October 21
contain approximately one-half of the chlorophyll a_ as
found in equal volumes of phytoplankton in other samples
collected during the study. A linear regression analysis
excluding these two deviant samples resulted in a greatly
improved correlation (r=0.98)."
Greene et al. arrived at these egregious conclusions by blanking
out reality while in a statistical trance. The composite samples of the
euphotic zone of Long Lake were autoclaved and filtered. Autoclaving
killed the indigenous algae and filtering removed them. They were thrown
out Greene et al. worked only with the filtrate. Yet Greene et al.
claim that the point of this exercise is to "predict" the quantity of algae
that was thrown put!
Autoclaving affected the concentration of dissolved phosphate,
according to the published data, but did not affect it consistently.
Samples that were autoclaved and filtered had from 90% less phosphate to
170% more phosphate than samples that were only filtered. Greene et al.
370
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did not try to explain these discrepancies. Perhaps their phosphorus-
detection method was, not precise enough for the extremely dilute solutions
they worked with. The growth of Selenastrum presumably depends on the
supply of nutrients (and the absence of inhibitors) in the sample.
Although Greene et al. concluded that most of the samples were phosphorus-
limited, there was no clear relationship between the initial phosphorus
concentration and the resulting Selenastrum growth, whether or not EDTA
was added to remove zinc by chelation. Greene et al. started with
twelve samples, but threw away two.
A few artificial assays, in short, produced inconsistent
results. No legitimate conclusions about the indigenous algae of Long
Lake can be drawn from these data.
For their conclusions to be true, the following must be true:
when Long Lake is stratified, the standing crop of
algae in Long Lake must correspond to the concentration
of dissolved phosphorus in the euphotic zone two weeks
later
when Long Lake is not stratified, the standing crop of
algae in Long Lake must correspond to the concentration
of dissolved phosphorus in the euphotic zone that day
the true concentration of dissolved phosphorus in the
euphotic zone must correspond to the concentration of
dissolved phosphorus in a sample that has been autoclaved
and filtered, and
371
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the concentration of phosphorus in a sample inoculated
with Selenastrum must correspond to the maximum yield
of Selenastrum in that sample.
The first two correspondences are unproven and far-fetched.
How could the standing crop of algae correspond to the concentration of
dissolved phosphorus two weeks later? Both are constantly changing,
owing to variations in the flow and quality of the Spokane River, varia-
tions in the mixing patterns of Long Lake, climatic changes, the succession
of species, the phosphorus input from Spokane, and the release of phos-
phorus from the lake's sediments. The last two correspondences were
disproved by their own data. More to the point, how could stratification
(or the lack of it) cause a two-week time shift in a relationship between
the standing crop of algae in Long Lake and the yield of Selenastrum
capricornutum Printz in.a laboratory?
January 1976
The U.S. Army Corps of Engineers publishes Water Resources
Study, Metropolitan Spokane Region. This 13-volume work, prepared by
Kennedy-Tudor Engineers, is by far the largest study ever published on
pollution-control planning in Spokane. For all its weight, it is not
fundamentally different from its thinner predecessors. It too is filled
with guesswork, oversimplifications, assumptions, and preconceived con-
*
elusions. It too fails to derive pollution-control measures in Spokane
from adequate data (adequately understood) on Long Lake. As usual, the
problem is the "lack of knowledge concerning the relationship between
effluent limitations and water quality." [P.L. 92-500, sec. 303(d)(1)(C)]
372
-------
As usual, too, Kennedy-Tudor relied on a mathematical model
instead of careful measurement and painstaking analysis. The model sought
to explain the deoxygenation of Long Lake. As we have shown, there are
at least three ways to account for the anoxia:
oxygen-demanding sediments
long-term BOD, dispersed or dissolved, trapped in the
lake at the end of the Spring flush
algal rain, which decomposes as it falls from the
surface through the hypolimnion.
No one has measured sediment-oxygen demand, no one has measured long-term
BOD from hypolimnetic samples collected in late Spring, no one has measured
the settling rate or the deoxygenation rate of the algal rain in fact,
no one is quite sure whether to measure the algae as biomass, cell volume,
or chlorophyll concentration, and the measures often fail to agree. How
can anyone purport to explain the anoxia without having adequately
measured any of the relevant factors? No doubt the explanation will not
be simple: Many factors may interact in complex ways. The reports of
Soltero et al. have already shown that Long Lake is not a simple pool of
water. By all accounts, it is an exceptionally complex reservoir, with
unusual hydrodynamics and mixing patterns.
In the absence of measurements and real understanding, there
is no alternative to guessing. What the model will "predict" depends on
these guesses. In short, guesswork in, guesswork out. If the modelers
should believe that sediment oxygen demand is the principal determinant
of anoxia, and if they set the reaction rates in the model accordingly,
373
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the model will "predict" that sediment oxygen demand is indeed the most
important factor just as the modelers had assumed. Consequently, the
model will "predict" no change in hypolimnetic anoxia when Spokane removes
phosphorus from its wastewaters, and the model will "predict" that phos-
phorus removal is unnecessary. If the modelers should believe that long-
term BOD trapped in the hypolimnion is the principal factor, and if they
set the reaction rates in the model accordingly, the model will "predict"
that their beliefs are borne out: It will "predict" that phosphorus
removal does not affect anoxia. In the absence of careful measurement
and thorough understanding, the model can only confirm the preconceived
conclusions of the modelers.
Neither Kennedy-Tudor nor the mathematical modelers (Hydrocomp,
Inc.) gave a detailed description of how the model accounts for sediment
oxygen demand, long-term BOD, and algal rain. None of the reaction rates
were published. None of the calibration procedures were explained (a
cover-up if ever there was one). No one even attempted to verify the model.
The model grossly oversimplifies Long Lake by substituting
invalid assumptions for observable facts. Here are four supposititious
assumptions:
ASSUMPTION; Long Lake has complete longitudinal mixing.
It is the same throughout its length. It may be legiti-
mately modeled by treating its entire length (22 miles)
as one vertical array of three points:
"The simulation [model] sees Long Lake as a body of water
consisting of three layers: a top layer 0 to 5.5 meters
depth, a middle layer 5.5 to 13.4 meters depth, and a
bottom layer 13.4 meters depth and below. The simulated
quality for each layer is reported as the mean over the
374
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entire depth of the layer The simulation treats the
entire extent of the lake in each horizontal stratum as
a fully mixed homogeneous unit." [Appendix J, p. 606.4-18]
FACT; The data of Soltero et al. for September 1973
(when data were collected for the model) give a very dif-
ferent picture of Long Lake. Soltero et al. reported that
the upriver end of the lake was quite different from the
downriver end, especially with respect to DO and soluble
orthophosphate. r
Just behind the dam, Long Lake is about 35 meters
deep. At its upriver end, it. is about 10 meters deep.
What happens to the bottom stratum (13.4 meters and below)
at the upriver end of the lake? Clearly, longitudinal
variation cannot be neglected. The model does not even
account for longitudinal variation in depth.
ASSUMPTION: The three strata are homogeneous and fully
mixed.
FACT: The complex mixing patterns in Long Lake cannot be
simplified into three completely mixed strata. According
to the data of Soltero et al., there are rarely sharp
changes in temperature with depth. The temperature gradually
declines between the surface and the bottom; there are no
neat strata. Part of the lake may hold a dozen layers of
water having very different conductivities; at the same
time, other parts of the lake may have uniform conductivity
from top to bottom. Soltero et al. have also shown that
mixing patterns of DO, phosphate, and nitrate are different
375
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and distinct; they differ among themselves, and they
are different from the patterns shown by temperature
and conductivity. All of them are constantly changing.
How can three invariant strata begin to account for the
complex mixing patterns in Long Lake?
ASSUMPTION: The Spokane River passes through the lake
only in the highest stratum. In effect, the river
always floats through on the surface of the lake:
"It is inherent in the HSP simulation to input the
stream entering the lake entirely in the top layer
at all times." [Appendix J, p. 606.4-20]
FACT; The conductivity data published by Soltero et al.
for the summer of 1973 show that the river traveled
through the middle stratum (not the top stratum) as a
density current. In July and August of 1973, the tongue
of highly conductive riverwater was quite distinct through
most of the lake; the tongue was most clearly defined at
the level of the power penstocks in the dam (the middle
stratum). In October, the riverwater (whose conductivity
is quite distinct from the conductivity of the lake)
plunged to the bottom. So far as one can tell from Soltero's
sampling program in 1973, the river never passed through
the top stratum. Yet the model was calibrated to 1973 data.
The assumption is plainly false.
ASSUMPTION; The incomplete mixing patterns in Long Lake ,
can be accounted for by allowing some mixing between adjacent
strata.
376
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FACT: No they can't. Hydrocomp did not model three strata.
They modeled one vertical array of three points. Each
point corresponds to no more than a few quarts of water,
but the reservoir holds more than 80,000,000,000 gallons.
Three points cannot even suggest the complex mixing patterns
in Long Lake.
Although the model is obviously far removed from the reality,
Kennedy-Tudor used it to diagnose the anoxia in Long Lake. The diagnosis
is not tentative, it is not hedged or qualified in any way. Decomposing
algae raining down from the euphotic zone are singled out as the cause:
"Within Long Lake, the most serious quality deficiency
which develops as a consequence of thermal stratification
and high nutrient levels is the reduction in dissolved
oxygen below the surface layers caused by the demand of
dying organisms settling to the bottom." [Summary Report,
P. 24]
What does Spokane have to do with the algal rain? Kennedy-
Tudor concluded that hypolimnetic DO would be low even if Spokane were
wiped off the map:
"The lack of vertical circulation [in Long Lake] even with
complete removal of point source pollutional loads will
result in very low dissolved oxygen levels at depth."
[Technical Report, p. 304]
Given the failings of the model, both conclusions are no more than unsubstan-
tiated opinions.
These opinions may prove to be right hypolimnetic anoxia
may be unrelated to Spokane's discharge. The depths of Long Lake often
remain stratified (though not necessarily thermally stratified) for months.
During their long confinement, the deep waters are susceptible to deoxygen-
ation by long-term BOD and sediment oxygen demand. Soltero et al. showed
377
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that the sediments were loaded with organic matter, which suggests that
sediment oxygen demand may be high. But this explanation has nothing to
do with either algal rain or the model.
Several researchers have recommended that Long Lake should be
destratified, but these recommendations have been repeatedly slighted by
the planners. Kennedy-Tudor slighted them too. They mentioned destrati-
fying the lake, but their study was superficial and their conclusions
were speculative. They suggested that some methods of destratification>
might do more harm than good:
"The drawoff of lower level waters opens the possibility of
creating undesirable water quality effects downstream that
would not be worth the improvements upstream. It could
well be that Long Lake is at present performing an impor-
tant function in controlling eutrophic conditions in the
Spokane River arm of Franklin D. Roosevelt Lake [downstream]
by acting as a nutrient trap during the critical summer
season. Continuous release of the nutrient rich lower
layers could create downstream problems." [Technical
Report, p. 307]
There are several objections to this line of reasoning. Soltero et al.
have shown that there is often little difference between nutrient concen-
trations at mid-depth and those in the bottom waters; consequently, de-
stratification will not increase the nutrient load passed downriver from
Long Lake. Moreover, without data on the Spokane River arm of Lake F.D.R.,
the suggestion is a red herring.
Stude (1971) and Yake (5 September 1973) suggested that Long
Lake should be destratified by blowing air into the hypolimnion. Kennedy-
Tudor slighted these suggestions.
The Corps of Engineers claims that it intended to help Spokane:
"The purpose of the study is to provide planning assistance
to local government for satisfying State and Federal re-
quirements relating to Public Law 92-500." [Summary Report,
first page of the synopsis]
378
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This study did not give Spokane the kind of help it wanted help in
defending itself against the requirements of DOE and EPA. Spokane has
repeatedly objected to the requirement for year-round phosphorus removal;
the city has argued that the scientific justification for phosphorus removal
is- inadequate. If the Corps had really wanted to help, it should have
helped Spokane press its claim against DOE and EPA. The claim is not
trivial or frivolous. . Kennedy-Tudor did become skeptical about the need
for phosphorus removal (29 January 1974), but did not sway DOE or EPA.
In the final report, Kennedy-Tudor concluded that phosphorus removal during
the winter would not affect the eutrophication of Long Lake:
"In the year 2000 simulation, with no phosphorus removal
throughout April, there is no algal activity. Only after
phosphorus removal has begun on 1 May does activity start
as water temperature begin [sic] to climb above 10°C.
These results indicate that phosphorus removal between
October 15 and May 1 would not affect the eutrophic con-
dition of Long Lake." [Appendix J, p. 606.4-38]
This argument did not persuade DOE to modify Spokane's discharge permit.
Spokane is still required to remove phosphorus year-round.
In short, this massive planning effort is a tissue of conjecture
for all its weight, too frail to help Spokane press a reasonable and
well-founded claim against the agencies that administer P.L. 92-500.
24 March 1976
G. Thomas Clark (Bovay Engineers) lists the raw-sewage bypasses
at the Spokane STP from 1970 to 1975. There have been at least 79 hours
every year when the STP bypassed all its influent, and at least 280 hours
every year when the STP bypassed part of its influent.
379
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26-27 March 1976
Encouraged by the "success" of their earlier work (November 1975),
Greene et al. tried again during the summer of 1975. They concluded that
the indigenous phytoplankton were not affected by the presence of zinc,
although Selenastrum was, and that Long Lake was nitrogen-limited most of
the time. However, their short report tells little about how they inter-
preted the data, and gives none of the raw data; it often refers the reader
to their earlier work. In the light of their earlier work, the reader
should be skeptical.
26-27 March 1976
T. Shiroyama et al. (EPA-Corvallis) report that the growth of
Anabaena flos-aquae (an alga native to Long Lake, but not one of the most
abundant) is inhibited by zinc and also by something else, perhaps another
metal.
April 1976
DOE publishes its 303(e) basin plan for the Spokane River. It
is more a monitoring report than a basin plan. DOE compares water quality
in winter (1 December 1972 to 28 February 1973) with summer (1 July 1973
to 30 September 1973). DOE treated the entire Spokane River including
Long Lake as Class-A water. There were violations of the Class-A stan-
dards for temperature and DO during the simmer, and coliform violations
year-round. However, DOE claims that these violations are "natural":
"The water quality of the Spokane River during this
period [i.e. summer 1973] was fair. The two factors
which were responsible for this were both natural
conditions."
380
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According to DOE's graphs, the DO in Long Lake was not less than 6 mg/1
that summer an obvious error. Nevertheless, DOE insists that the DO
violations were natural:
"The dissolved oxygen values showed the typical inverse
relationship to the temperature, curve. Any apparent .
violations can be associated to temperature and were
probably due to natural, seasonal.conditions. This
reduction in dissolved oxygen was due to a natural in-
crease in temperature, since the percent saturation
remained virtually the same"."
The basin plan takes no notice of the deoxygenation in Long
Lake. Although it mentions phosphorus removal at Spokane, it ignores the
most famous problem of the lake. DOE divided the Spokane River into two
segments, 24-54-01 and 24-57-04, and ranked them as the two most polluted
segments in the State. EPA gave the segments special notice:
"Segments (24-54-01) and (24-57-04) have been designated
by the Administrator of the EPA as national priority
waters for water pollution abatement study and measures..."
What good is a basin plan that misses the anoxia in Long Lake the.worst
water-quality problem in the most polluted segment in the State?
DOE classifies the two segments of the Spokane River as "Water
Quality Limited - Nonpoint Sources" because of the "natural" coliform
and DO violations. Section 303(d) of P.L. 92-500 requires Washington State
to determine the "total maximum daily load" of pollutants that can be
assimilated by each segment classified as Water-Quality Limited; section
303(e)(3) (C) identifies the 303(d) determinations as an essential part of
a 303(e) plan. What good is a 303(e) plan that does not comply with an
essential provision of Federal law?
381
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April 1976
Rhys A. Sterling (District Engineer, DOE-Spokane) swears under
oath that Long Lake is Lake-Class water:
"in accordance with Washington State Water Quality Standards
(Chapter 173-201 WAG adopted June 19, 1973), reservoirs with
a mean exchange rate of greater than 15 days are classified
Lake Class. All reservoirs with a mean exchange rate of 15
days or less are classified the same as the river section in
which they are located. As such, Long Lake is classified as
Lake Class and Nine Mile Reservoir is classified Class A
(same as the Spokane River)."
Mr. Sterling's testimony is contained in a draft affidavit, which he
kindly offered us.
His interpretation of the WQS is unique, but warranted by sec-
tion 173-201-070 WAC. The WQS themselves (in section 173-201-080) classify
all of the Spokane River, "from mouth to Idaho border (river mile 91)", as
Class A; Long Lake is included in this stretch of the river. DOE's 303(e)
basin plan saya that Long Lake is Class-A. Evidently, DOE is confused by
its own WQS and cannot consistently decide which of them apply to Long Lake.
June 1976
Under contract to DOE, Soltero et al. publish another study of
Long Lake. The data will be used to verify another model of Long Lake, a
model being prepared for DOE by Battelle-Pacific Northwest Laboratories.
Without the annual studies conducted by Soltero et al., no one would know
very much about Long Lake. Yet despite these studies, no one understands
the relationship between Spokane's effluent and water quality. Long Lake
has stumped the pollution-control agencies, the consulting engineers,
and the college professors. Soltero et al. have made three cardinal
errors:
382
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they neglected many Important measurements (e.g.
hydraulics, long-term BOD, sediment oxygen demand,
and algal "rain")
they misinterpreted their own data (especially the
sediment-core data)
they drew conclusions that went beyond their data.
Soltero is a consultant. He is not legally responsible for
i
defining the relationship between effluent limitations and water quality
i
in the Spokane River; the pollution-control agencies are. Under sections
303(d)(l)(C) and 303(d)(2) of P.L. 92-500, DOE must determine "the total
may-fining daily load" of pollutants that can be safely assimilated by the
Spokane River, and EPA must approve the determination. DOE and EPA first
ordered Spokane to build phosphorus-removal facilities on 28 March 1973.
Soltero's first report on Long Lake wasn't published until July 1973.
Without Soltero's data, their understanding of Long Lake could not have
been more than primitive.
They did not fund Soltero's first study the U.S. Office of
Water Resources Research has that distinction. DOE has supported all of
Soltero's subsequent research on Long Lake research that continues to
accumulate basic data (one wishes that he would publish more of it) on
the reservoir's complex workings, research that continues to reveal fresh
complexities and unexpected patterns of behavior. Yet on 20 February
1974, when asked to justify the phosphorus-removal requirement, EPA
replied that the evidence was "technically conclusive". Soltero's continu-
ing research on Long Lake shows that very little is "technically conclusive"
: 383
-------
DOE is now funding a mathematical model. How can a model
a model that reduces Long Lake to a few points and relies on the guesses
of the modelers succeed in deciphering the intricate workings of the
lake? College professors using all their faculties are still
striving to unravel them. Until DOE invests in much more basic research,
nothing can be gained by modeling.
The latest study by Soltero et al. reports new complexities in
the workings of Long Lake. For the first time, there was less DO at mid-
depth than at the bottom, although the bottom waters had remained entrapped
for weeks, perhaps months. This phenomenon suggests that sediment oxygen
demand is less important than other causes of anoxia. Soltero et al.
neglected to comment.
They also neglected to comment on their phosphate data. In an
attempt to assess the importance of the STP, they have measured phosphate
in the river above and below the STP. Their data show that the STP has
discharged less phosphate each year. In 1975, it discharged one third
as much phosphate as it did in 1972. Shouldn't they try to explain this
trend?
What does thfe trend mean? It amounts to a 69% reduction in the
STP's discharge of phosphorus not quite an 85% reduction, but close.
The 69% reduction in the effluent load is close to 85% removal of the
influent load and this happened before Spokane built phosphorus-removal
facilities. What is the result of all this cleanup? Has the river im-
proved dramatically? Have EPA's predictions (or Soltero*s predictions,
for that matter) proved correct? Are there fewer algae? Is Long Lake less
anoxic? What does Soltero say about this trend? Nothing. What do EPA
and DOE say? Nothing.
384
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Here are several calculations of the STP's phosphate discharge.
Except for the last two, they were obtained by subtracting the phosphate
flux downstream of the SIP from the phosphate flux upstream. The last
two were obtained by direct measurement:
Author and
Date of Report
Cunningham and Pine,
1969
Soltero et al.,
1 July 1973
Soltero et al.,
1 July 1974
Soltero et al.,
July 1975
Soltero et al.,
June 1976
Spokane SIP,
unpublished STP data
U.S. Army Corps of Engineers,
January 1976
Sampling Dates
16 September 1966
6 May 1972-
15 March 1973
19 June 1973-
17 December 1973
8 June 1974-
16 December 1974
12 May 1975-
18 November 1975
Spokane STP Phosphate
Discharge (as PO/.)
4190 Ib/day
5960 Ib/day
5200 Ib/day
3550 Ib/day
1850 Ib/day
January-December 1976 3460 Ib/day
"representative" 3830 Ib/day
dry-weather STP effluent
February 1977
DOE drafts revised WQS. They are very similar to the WQS issued
on 19 June 1973. Long Lake still fits the Lake-Class category but is
listed as Class A. The artificial conditions imposed on the Spokane
River by Long Lake Dam are still considered natural conditions. The WQS
385
-------
still require DOE to distinguish between the effects of dams and the
effects of discharges (a distinction it is manifestly incapable of making);
they still require DOE to determine "natural conditions" for Long Lake
and all the other impoundments that divide the river (which DOE does not
plan to do). Until DOE makes these distinctions and determinations, no
one can know whether the river is in compliance with the WQS. No one can
know whether Spokane's discharge causes WQS violations. In short, these
WQS suspend all standards of water quality just as the last set did.
True, there are changes. The total-coliform standards are
changed to fecal-coliform standards. The temperature standards are
expressed in degrees Celsius rather than degrees Fahrenheit. The turbi-
dity standards are expressed in Nephelometric Turbidity Units rather than
Jackson Turbidity Units. DOE lived with the 1973 WQS for four years and
never got to know them. It never got past the bureaucratic trappings.
It never got to the heart of the matter.
What kind of pollution-control planning is that?
386
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9.3 BIBLIOGRAPHY
Herman R. AMBERG (27 April 1953). Report on natural purification capa-
cities, Spokane River. Corvallis OR: Oregon State College,
Engineering Experiment Station, National Council for Stream
Improvement (of the Pulp, Paper, and Paperboard Industries\
Inc. 64 pp.
ANON (December 1959). Spokane metropolitan area study: A plan of action
to help further the proper development of Spokane's suburbs both
within and bordering the City's limits. Spokane metropolitan
area study, report no. 1; report no. 8, city plan series.
Spokane WA: The City Plan Commission. 102 pp.
ANON (1974 or later). Untitled report consisting of a narrative section
(2 pp.) + 7 excerpts from earlier reports on revenues and charges
in Spokane's wastewater system. Available from Kenton L. Lauzen
(EPA Region X liaison engineer on assignment to Washington State
Dept. of Ecology, Olympia WA).
R.G. BACA et al. (revised November 1974). A generalized water quality
model for eutrophic lakes and reservoirs. Prepared by Battelle
Memorial Institute, Pacific Northwest Laboratories division, for
the U.S. Environmental Protection Agency, Office of Research
and Monitoring. Richland WA: Battelle. 140 pp.
387
-------
James P. BEHLKE (21 November 1969). Letter to Robert W. Twigg (State
Senator). Behlke (Director, Washington State Water Pollution
Control Commission) discusses the discharge of blood from the
Spokane STP, blood that must have come from one of the city's
meat-packing plants. Drafted by Thomas G. Haggarty. Obtained
from the Washington State Department of Ecology, Olympia WA.
Archive file marked "Spokane, City 1966-69".
Larry D. BIGGS (8 January 1973). Letter to Daniel V. Neal (District
Engineer, Washington State Department of Ecology, Spokane).
Biggs (Bovay Engineers) reviews the evidence for phosphorus
removal and finds it wanting. Obtained from Kenton L. Lauzen,
EPA Region X liaison engineer to the Department of Ecology,
Olympia WA.
Idem (19 October 1973). Letter to Daniel V. Neal and Richard R. Thiel
(Chief, Idaho-Washington Unit, U.S. Environmental Protection
Agency, Region X, Seattle WA). Biggs submits an analysis of
infiltration and inflow into Spokane's sewers. Obtained from
Kenton L. Lauzen, EPA Region X liaison engineer to the Department:
of Ecology, Olympia WA.
Idem (4 January 1974). Letter to Thomas G. Haggarty (Regional Manager,
Washington State Department of Ecology, Spokane). Biggs asks
for a definition of "85% phosphorus removal", and suggests one.
Obtained from Kenton L. Lauzen, EPA Region X liaison engineer
. to the Department of Ecology, Olympia WA.
388
-------
Idem (29 January 1974). Letter to Roger James (Director of Public
Utilities, Spokane). Biggs says that Kennedy-Tudor Engineers
are not convinced that phosphorus removal will improve Long
Lake. Obtained from the files of the Department of Public
Utilities, Spokane.
/
Bob BISHOP (5 August 1974). A memo addendum to the 1972 Bishop and Lee
report: "Additional phytoplankton data became available by
enumeration of additional stored samples collected in 1971."
Obtained from the Department of Ecology, Olympia WA. 6 pp.
Robert A. BISHOP and Ronald A. LEE (1972). Spokane river cooperative
water quality study. Washington State Dept. of Ecology.
Report no. 72-001. Olympia WA(?): The Dept. 72 pp.
R. Jerry BOLLEN (14 March 1974). Letter to the Mayor and members of the
City Council of Spokane. Bollen (Assistant Director, Office of
Operations, Washington State Department of Ecology, Spokane)
formally informs Spokane that it must remove phosphorus.
Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to
the Department of Ecology, Olympia WA.
Duane BLUNT and John HOGAN (November 1954). The status of the industrial
waste problem within the city limits of Spokane, 1954. Olympia (?)
Washington State Pollution Control Commission. 15 pp. +4 un-
numbered pages in appendix. Obtained from the library of the
U.S. Environmental Protection Agency, Seattle.
389
-------
BOVAY ENGINEERS, INC. (April 1973). City of Spokane, Washington, sewage
treatment plant expansion, shorelines management permit appli-
cation. Spokane WA: Bovay Engineers, Inc. Unpaginated.
Idem (June 1973). City of Spokane, Washington, report on additions and
1 modifications to the wastewater treatment plant. 2 volumes in
3 binders. Vol. 1 contains two separate binders, labeled "Text"
and "Exhibits and appendices"; vol. 2 is labeled only "Vol. 2."
The text is in 9 sections; "Exhibits and appendices" includes
appendices A through G plus bibliography. Vol. 2 reprints
chap. VI of "Text" in volume 1, but adds three new tabs, marked
"Lime", FeC^", and "Alum." Spokane WA: Bovay Engineers, Inc.
Idem (June 1973). City of Spokane, Washington, sewage treatment plant
expansion, environmental assessment - draft. Spokane WA:
Bovay Engineers, Inc. 51 pp. + 12 exhibits.
Idem (30 June 1973). City of Spokane, Washington, report on additions
and modifications to the wastewater treatment plant. 2 vols.
Spokane WA: Bovay Engineers, Inc. One volume is subtitled
"Text" (9 chapters); the other volume is subtitled "Exhibits
and appendices (appends. A-G).
Idem (July 1973). Application for financial assistance to Washington
State Department of Ecology from the City of Spokane, Washington,
[for] wastewater treatment works construction grant (66.400).
Spokane WA: Bovay Engineers, Inc.
390
-------
Idem (August 1973). City of Spokane, Washington, sewage treatment plant
expansion, environmental assessment - final. Vol. II [The
draft of June '73 is evidently vol. I]. Spokane WA: Bovay
Engineers, Inc. 3 chapters. Contains comments on the draft
and reposnses to comments.
Idem (March 1974). City of Spokane, Washington, wastewater treatment
plant expansion, proposed system for user charges and industrial
cost recovery. Spokane WA: Bovay Engineers, Inc. 2 volumes:
21 pp. in text volume; the supplemental volume ("Tables and
appendices") contains 18 tables and appendices A through E.
Idem (June 1974). City of Spokane, Washington, wastewater treatment
plant expansion, report on excessive infiltration/inflow.
Spokane WA: Bovay Engineers, Inc. 6 chapters, 11 exhibits,
6 tables.
Idem (March 1975). City of Spokane, Washington, wastewater treatment
plant additions and modifications, approval documents for con-
tract award. Spokane WA: Bovay Engineers, Inc. Contains 8
tab sections, marked 1-6; tab 3 is divided into 3A, 3B, and 3C.
Idem (January 1977). Engineering report on 1977 diversion alternatives.
Spokane WA: Bovay Engineers, Inc. In seven sections.
391
-------
Idem (undated; cover letter dated 14 Feb 77). City of Spokane, waste-
water treatment plant, preliminary operation and maintenance
manual. Spokane WA: Bovay Engineers, Inc. Unpaginated draft,
largely in manuscript. No table of contents. Several hundred
pages. Available from Kenton L. Lauzen (U.S. EPA Region X
liaison engineer on assignment to Washington State Dept. of
Ecology, Olympia).
BOVAY ENGINEERS, INC. & CAMP DRESSER & McKEE, INC. (December 1974). City
of Spokane, Washington, wastewater treatment plant additions and
modifications; specifications. 2 volumes. Spokane WA & Boston
MA: Bovay Engineers & Camp Dresser & McKee. Vol. I contains
divisions 1-11; vol. II contains divisions 12-16.
Idem (1975). City of Spokane, Washington, wastewater treatment plant,
additions and modifications. Contract no. 530580-04. Two
folios of detailed engineering of drawings, bound as volumes
I and II. A third bound set of drawings, bearing the same
title & further identified as addendum no. 2, was found in the
files of Kenton L. Lauzen (U.S. EPA Region X liaison engineer
on assignment to the Washington State Dept. of Ecology, Olympia).
Addendum no. 1 has not been found.
Idem (February 1975). City of Spokane, Washington, wastewater treatment
plant additions and modifications, addendum no. II. Spokane
WA: Bovay Engineers, Inc. Unpaginated.
392
-------
Robert S. BURD (11 August 1972). Memo to the files. Burd (Director,
Air & Water Programs Division, U.S. Environmental Protection
Agency, Region X, Seattle WA) and other EPA members met with
the Department of Ecology and the City of Spokane; both DOE
and EPA asked Spokane to remove phosphorus from its STP's
effluent. Obtained from Kenton L. Lauzen, EPA Region X liaison
engineer to the Department, Olympia WA.
Idem (5 September 1972). Letter to F.S. Fulwiler (City Manager, Spokane).
Burd warns Spokane that it is not complying with its schedule
and threatens "enforcement action." Obtained from Kenton L.
Lauzen, EPA Region X liaison engineer to the Washington State
Department of Ecology, Olympia WA.
Idem (16 October 1972). Letter to John A. Biggs (Director, Washington
State Department of Ecology). Burd reviews Spokane's proposed
STP-construction schedule and finds it unacceptable. Obtained
from Kenton L. Lauzen, EPA Region X liaison engineer to the
Washington State Department of Ecology, Olympia WA.
Idem (6 March 1974). Memo to the files. Burd describes a meeting in
which EPA and the Department of Ecology confirm their decision
that Spokane must remove phosphorus. Obtained from the "Spokane
Corps of Engineers correspondence 1974-" file of EPA-Seattle.
Richard A. BURKHALTER et al. (1970). A report on the water quality of
the Little Spokane River. Washington State Water Pollution
c>
Control Commission, technical report no. 70-1. 27 pp.
Olympia WA (?): The Commission.
393
-------
William F. CALLAHAN et al. (10 October 1974). Spokane pilot plant
compares treatment alternatives. Presented at the 47th annual
conference of the Water Pollution Control Federation in Denver
CO. Obtained from the Department of Public Utilities, Spokane WA.
G. Thomas CLARK (24 March 1976). Letter to James C. Sloane, City of
Spokane. Clark (Bovay Engineers) lists the monthly raw-sewage
bypasses at the STP from 1970 to 1975. Obtained from the "STP «
upgrading" file of the Department of Public Utilities, Spokane WA.
Denzel R. CLINE (1969). Groundwater resources and related geology, north-
central Spokane and southeastern Stevens Counties of Washington.
Washington Dept. of Water Resources, water supply bulletin no. 27.
Olympia: The Dept. of Water Resources. 195 pp. + 2 plates in
back-cover pocket. Prepared in cooperation with the U.S. Geo-
logical Survey.
COLUMBIA BASIN INTER-AGENCY COMMITTEE, HYDROLOGY SUBCOMMITTEE (April 1964).
River mile index, Spokane River. No publication details. 24 pp.
[N.B. each page is dated January 1964]. Obtained from the
library of the U.S. EPA, Seattle.
James W. CROSBY III et al. (October 1968). Migration of pollutants in a
glacial outwash environment. Water Resources Research 4/5):
1095-1114.
Idem (February 1971). Migration of pollutants in a glacial outwash environ-
ment, 2. Water Resources Research 7(1): 204-208.
394
-------
Idem (June 1971). Migration of pollutants in a glacial outwash environ-
ment, 3. Water Resources Research _7 (3): 713-720.
Idem (August 1971). Final report: Investigation of techniques to provide
advance warning of ground-water pollution hazards with special.
reference to aquifers in glacial outwash. Submitted to the
U.S. Dept. of the Interior, Office of Water Resources Research.
OWRR project no. B-005-WASH. Pullman WA: Washington State
University, College of Engineering. 148 pp. + 2 appendices.
This study is specific to the Spokane Valley.
Dick CUNNINGHAM & Gary ROTHWELL (December 1971). Water quality report:
Spokane and Little Spokane Rivers, December 1970 - March 1971.
Washington Department of Ecology, Office of 'Technical Services,
Environmental Monitoring Division, Water Monitoring Section.
28 pp. Olympia WA: The Department.
A.S. VAN DENBURGH & J.F. SANTOS (1965). Ground water in Washington, its
chemical and physical quality. Washington State Dept. of Con-
servation, Division of Water Resources, Water supply bulletin
no. 24. Prepared in cooperation with the U.S. Geological Survey
& the Washington State Pollution Control Commission. Olympia WA:
State Printing Plant. 83 pp.
395
-------
Roy L. ELLERMAN (15 February 1973). Letter to-Torn Haggerty [sic]
(Washington State Department of Ecology, Spokane). Ellerman
(Chief, Municipal Section, U.S. Environmental Protection Agency,
Seattle WA) refuses to accept certain of the conclusions of the
Esvelt & Saxton / Bovay report, "i.e. difficulty of predicting
D.O. improvements due to installation of secondary treatment;
non-resolution of cause and means for control of excessive algal
growth; phosphorous [sic] not being growth limiting below
Spokane; reduction in phosphorous [sic] input to the River not
reducing algal production; non resolution of .question of nitrogen
or phosphorous [sic] being limiting; and cause of stimulation
of algal growth not being determined." Obtained from Kenton L.
Lauzen, EPA Region X liaison engineer to the Washington State
»
Department of Ecology, Olympia WA.
Idem (8 February 1974). Memo to Sheldon Meyers (EPA-Washington, D.C.)
Ellerman requests a waiver of the requirement for an Environ-
mental Impact Statement for the Spokane AWT project. Obtained
from Kenton L. Lauzen, EPA Region X liaison engineer to the
Washington State Department of Ecology, Olympia WA.
ESVELT & SAXON (December 1964). Public health relationship of the
Minnehaha Sewer District and the greater Spokane community;
an engineering report prepared for the City of Spokane, Wash-
ington. Appendix "B", groundwater contamination and the Spokane
Aquifer. Pp. 36-41. No publication details. Obtained from
Jack E. Sceva, U.S. EPA, Region X, Seattle.
396
-------
ESVELT & SAXTON / BOVAY ENGINEERS, INC. (12 November 1970). Unsigned
memo about a meeting with the Washington State Water Pollution
Control Commission and the City of Spokane. Obtained from the
files of the Department of Public Utilities, Spokane City Hall.
e
Idem (22 February 1972). Spokane wastewater study, phase II interim report:
A summary of concept alternatives and costs. 52 pp. plus figures.
Spokane WA: E&S/B Engrs.
Idem (July 1972). Spokane, the city-the river; action plan for: better
wastewater control, advanced waste treatment, high river water
quality, better environment. Spokane: Esvelt & Saxon / Bovay
Engineers, Inc. The title is printed only on the front outside
cover of a plasticized album containing two separately bound
reports entitled "Spokane wastewater study"; the 2 reports are
subtitled "Text" (37 pp.) and "Exhibits" (marked II-l through
XIII-1).
EXPO '74 SPOKANE RIVER BASIN DEPOLLUTION POLICY COMMITTEE, TECHNICAL
COMMITTEE (1972). Plan of action, Spokane River basin. 48 pp.
plus 1 appendix. Spokane: The Policy Committee. The appendix
(October 1972) contains 259 pp.
E. John FINNEMORE & John L. SHEPHERD (October 1974). Spokane River basin
model project, volume I - final report. Prepared by Systems
Control, Inc. for the U.S. Environmental Protection Agency.
Palo Alto CA: Systems Control. 261 pp.
397
-------
Idem (October 1974). Spokane River basin model project, volume III -
verification report. Prepared by Systems Control, Inc. for
the U.S. Environmental Protection Agency. Palo Alto CA: Systems
Control. 66 pp.
»
William H. FUNK et al. (30 June 1973). The biological impact of combined
metallic and organic pollution in the Coeur d'Alene-Spokane River
\
drainage system; project completion report to the U.S. Dept. of
the Interior, Office of Water Resources Research. OWRR project
numbers: B-044 WASH & B-015 IDA; OWRR agreement numbers:
14-31-011-3664 & 14-01-001-3576. Pullman WA: Washington State
University, and Moscow ID: University of Idaho. 187 pp.
Idem (August 1975). An integrated study on the impact of metallic trace
element pollution on the Coeur d'Alene-Spokane Rivers-Lake
drainage system. Washington State University/University of
Idaho joint project completion report to the U.S. Dept. of the
Interior, Office of Water Research and Technology, OWRT agree-
ment #14-31-0001-9060, Title II project C-4145. Pullman WA.
Washington State University. 332 pp.
Joseph C. GREENE et al. (June 1975). Toxicity of zinc to the green alga
Selenastrum capricornutum as a function of phosphorus or ionic
strength. Pp. 28-43 in U.S. EPA, Office of Research and Develop-
ment, National Environmental Research Center, Corvallis OR.
"Proceedings: Biostimulation - Nutrient Assessment Workshop,"
i
16-17 October 1973, Corvallis OR. Report no. EPA-660/3-75-034,
program element 1BA031. Springfield VA: U.S. National Technical
Information Service.
398
-------
Idem (November 1975). The relationship of laboratory algal assays to
measurements of indigenous phytoplankton in Long Lake, Washington.
Pp. 93-126 in E. Joe Middlebrooks et al. [eds], Biostimulation
and nutrient assessment, proceedings of a workshop held at Utah
State University, Logan, Utah, 10-12 September 1975. Sponsored
by the Eutrophication and Lake Restoration Branch, Pacific N.W.
Environmental Research Laboratory, U.S. EPA, Corvallis OR and
the Division of Environmental Engineering and the Utah Water
Research Laboratory, Utah State University, College of Engineering,
Logan UT. Logan UT:. Utah State University, College of Engineering.
Partially supported by grant no. R-90352301 from U.S. EPA (Cor-
vallis). Cover bears serial number PRWG168-1.
Idem (26-27 March 1976). Use of algal assays to assess the effects of
municipal and smelter wastes upon phytoplankton production.
In; Proceedings of the symposium on terrestrial and aquatic
ecological studies of the Northwest. Cheney WA: Eastern
Washington State College Press.
Idem (undated). Report to Region X on the results of the Spokane River
algal assays. [U.S. Environmental Protection Agency] National
Eutrophication Research Program. 22 pp. Corvallis OR: The
Program.
399
-------
Thomas G. HAGGARTY (1 August 1969). Memo to R. Jerry Bollen (Washington
State Water Pollution Control Commission). Haggarty (WPCC,
Spokane) concludes that Spokane has no intention of complying
with the schedule that the Commission required on 19 March 1968.
Obtained from Kenton L. Lauzen, EPA Region X liaison engineer
on assignment to the Washington State Dept. of Ecology, Olympia WA.
Idem (22 October 1969). Memo to R. Jerry Bollen (Washington State Water
Pollution Control Commission). Haggarty assesses the Commission's
position with respect to Spokane's intransigence. Obtained from
Kenton L. Lauzen, EPA Region X liaison engineer to the Washington
State Department of Ecology, Olympia WA.
Idem (March 1970). Status report: Water pollution in the Spokane River.
Originally published as Technical report 69-1, Washington State
Water Pollution Control Commission. Reprinted in March 1970.
Olympia WA: The Washington State Department of Ecology. 8 pp.
N.B. Technical report 69-1 is by R.K. Cunningham & R.E. Pine.
The Haggarty report is not a reprint of Technical report 69-1.
Roy M. HARRIS (19 March 1968). Letter to the Mayor and members of the
City Council of Spokane. Harris (Director, Washington State
Water Pollution Control Commission) requires Spokane to upgrade
its STP to give secondary treatment plus disinfection by mid-1972.
Obtained from the files of the Spokane Department of Public
Utilities, Spokane WA. 3 pp.
400
-------
John D. HEM (June 1972). Chemistry & occurrence of cadmium and zinc in
surface water & groundwater. Water Resources Research ^(3):
661-679. [John Hem is with USGS, Menlo Park CA.]
Roger JAMES (9 September 1974). Letter to the Washington State Department
of Ecology, Spokane. James (Director of Public Utilities,
Spokane) summarized Spokane's strongest objections to a draft
discharge permit. Obtained from the "STPU - discharge permit -
EPA" file of the Department of Public Utilities, Spokane WA.
Roger JAMES et al. (27-29 October 1976). Spokane advanced wastewater
treatment plant design and construction. Prepared for presen-
tation at 43rd annual meeting, Pacific Northwest Pollution
Control Association, Seattle WA. Obtained from the files of the
Department of Public Utilities, Spokane WA.
William E. MILLER et al. (June 1975). The use of algal assays to determine
effects of waste discharges in the Spokane River system. Pp. 113-
131 in U.S. EPA, Office of Research and Development, National
Environmental Research Center, Corvallis, Oregon, "Proceedings:
Biostimulation - nutrient assessment workshop," 16-17 October 1973,
Corvallis OR. Report No. EPA-660/3-75-034, program element
1BA031. Springfield VA: U.S. National Technical Information
Service.
401
-------
Idem (November 1975). Application of algal assays to define the effects
of wastewater effluents upon algal growth in multiple use river
systems. Pp. 77-92 in E. Joe Middlebrooks et al. [eds],
Biostimulation and nutrient assessment, proceedings of a work-
shop held at Utah State University, Logan Utah, 10-12 September
1975. Sponsored by the Eutrop~hication and Lake Restoration
Branch, Pacific N.W. Environmental Research Laboratory, U.S. EPA,
Corvallis OR; and the Division of Environmental Engineering and
the Utah Water Research Laboratory, Utah State University, College
k
of Engineering, Logan UT. Logan UT: Utah State University,
College of Engineering. Partially supported by grant no. R-90352301
from U.S. EPA (Corvallis). Cover bears serial number PRWG 168-1.
Daniel V. NEAL (20 February 1974). Memo to the files. Neal (District
Supervisor, Washington State Department of Ecology, Spokane)
describes a meeting with EPA and Spokane on 14 February 1974,
during which Spokane asked the pollution-control agencies to
reconsider their decision on phosphorus removal. Obtained from
the "Spokane Corps of Engineers correspondence 1974-" file of
EPA-Seattle.
Gary L. O'NEAL (11 July 1972). Memo to fifteen people. O'Neal (Director,
Surveillance & Analysis Division, Environmental Protection
Agency, Region X, Seattle WA) announces that EPA will increase
i
"monitoring by objectives" and decrease routine monitoring, and
offers a report on the Spokane River as an example. Obtained
from Kenton L. Lauzen, EPA Region X liaison engineer to the
Washington State Dept. of Ecology, Olympia WA.
402
-------
Idem (18 July 1972). Memo to Bob Burd (Director, Air & Water Programs
Division, Environmental Protection Agency Region X, Seattle WA).
O'Neal contends that phosphorus removal at Spokane would remove
the majority of phosphorus from the Spokane River only if two
conditions are met. Obtained from Kenton L. Lauzen, EPA Region X
liaison engineer to the Washington State Department of Ecology,
Olympia WA.
PACIFIC NORTHWEST DRAINAGE BASINS OFFICE, DIVISION OF WATER POLLUTION
CONTROL, PUBLIC HEALTH SERVICE, U.S. FEDERAL SECURITY AGENCY
(1951). Report on water pollution control, Spokane river basin.
A cooperative State-Federal report. 137 pp. Prepared in coopera-
tion with the Idaho Dept. of Public Health & the Washington
State Pollution Control Commission. No publication details;
t
probably published by the Portland OR office of the U.S. Public
Health Service. Mimeo. Obtained from the Library of the U.S.
EPA, Seattle.
PACIFIC NORTHWEST RIVER BASINS COMMISSION (1969-1972). Columbia-North
Pacific region, comprehensive framework study of water and
related lands. 18 parts (variously dated, 1969-1971), consisting
of a main report, a summary report, and 16 appendices. Vancouver
WA: The Pacific Northwest River Basins Commission. Of special
relevance are Appendix IV, volume 1, "Land and mineral resources,"
dated June 1970, 202 pp; Appendix IX, "Irrigation," dated '
February 1971, 343 pp; and Appendix XII, "Water quality & pollu-
tion control," dated December 1971, 531 pp.
403
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Roland E. PINE & Eugene ASSELSTINE (14 September 1962). A general survey
of the Spokane River from Post Falls, Idaho, to the Washington-
Idaho state line. 8 pp. No publication details. Probably
published by the Washington State Pollution Control Commission,
Olympia WA. Available from the Technical Library, Washington
State Dept. of Ecology, Olympia WA, under accession no. D-129.
E.J. PLUHOWSKI & C.A. THOMAS (1968). A water-balance equation for the
Rathdrum Praire ground-water reservoir, near Spokane, Washington.
U.S. Geological Survey professional paper 600-D, pp. D75-D78.
A.J. REISDORPH (2 August 1973). Memo to Glen A. Yake (Assistant City
Manager, Spokane) and Roger James (Director of Public Utilities,
Spokane). Reisdorph (Superintendent of Spokane's STP) argues
that water quality in Long Lake is the responsibility of the
Washington Water Power Company, which created the lake. Obtained
from the "STP upgrading" file of the Department of Public
Utilities, Spokane WA.
David H. RODGERS (16 October 1969). Letter to the Washington State Pollu-
tion Control Commission. Rodgers (Mayor of Spokane) tells the
Commission that it would be "imprudent" for the city government
to agree to the Commission's schedule. Obtained from Kenton L.
Lauzen, EPA Region X liaison engineer to the Washington State
Department of Ecology, Olympia WA.
404
-------
Idem (29 September 1972). Letter to the Washington State Department of
Ecology and to Robert S. Burd (Director, Air & Water Programs
Division, U.S. Environmental Protection Agency Region X,
Seattle WA). Rodgers submits his STP-construction schedule.
Obtained from Kenton L. Lauzen, EPA Region X liaison engineer
to the Washington State Department of Ecology, Olympia WA.
S.R. SAGSTAD & D.R. RALSTON (April 1976). Analysis of a ground-water
flow system in Northern Idaho related to heavy metal concentra-
tions. Proceedings of the 14th annual Engineering Geology and
Soils Engineering Symposium. No publication details.. Obtained
from Jack E. Sceva, U.S. EPA, Region X, Seattle.
William B. SCHMIDT (21 February 1973). Memo to Gary L. O'Neal (Director,
Surveillance & Analysis Division, U.S. Environmental Protection
Agency, Region X, Seattle). Schmidt (Chief, Water Quality
Monitoring Section, EPA-Seattle) summarizes a meeting with Pine
(DOE), Soltero, Funk, and Miller (EPA-Corvallis). Obtained from
the files of EPA-Seattle.
Idem (28 February 1974). Memo to Gary L. O'Neal. Schmidt describes a
meeting with the Department of Ecology, Kennedy-Tudor, Soltero,
and Funk, in which the professors give their opinions about
phosphorus removal and Long Lake. Obtained from the "Spokane
Corps of Engineers correspondence 1974-" file of EPA-Seattle.
405
-------
SHANNON & WILSON, INC., GEOTECHNICAL ENGINEERS (October 1973). Preliminary
draft: geology, soils and groundwater in the urbanizing area of
the Spokane River basin. Submitted to Kennedy-Tudor Consulting
Engineers, Seattle. Part of the Metropolitan Spokane region
water resources study sponsored by the U.S. Army Corps of Engineers,
Seattle District. 85 pp.
s
Tamotsu SHIROYAMA et al. (June 1975). Effect of nitrogen and phosphorus
on the growth of Selenastrum capricornutum. Pp. 132-142 in U.S.
EPA, Office of Research and Development, National Environmental
Research Center, Corvallis, Oregon, "Proceedings: Biostimulation -
nutrient assessment workshop," 16-17 October 1973, Corvallis OR.
Report no. EPA 660/3-75-034, program element 1BA031. Springfield
VA: U.S. National Technical Information Service.
/
Idem (26-27 March 1976). Growth response of Anabaena flos-aquae (Lyngb.)
De JBreblssprv & waters collected from Long Lake Reservoir,
Washington. .In,; Proceedings of the symposium on terrestrial
and aquatic ecological studies of the Northwest. Cheney WA:
. Eastern Washington State College Press.
W.O. SIMONS et al. (1953). Spokane - Coeur d'Alene River basin, Washington-
Idaho. Chapter 10 (pp. 164-185) in .U.S. House of Representatives
Interior & Insular Affairs Committee. "The physical & economic
foundation of natural resources: IV, subsurface facilities of
water management and patterns of supply - type are# studies."
Washington DC: USGPO. W.O. Simons et al. were with USGS.
406
-------
Raymond A. SOLTERO et al. (1 July 1973). An investigation of the cause
and effect of eutrophication in Long Lake, Washington. Eastern
Washington State College, Department of Biology; prepared for
the U.S. Department of the Interior, Office of Water Resources
Research. 86 pp. Cheney WA: The Department of Biology.
Idem (1 July 1974). Further investigation as to the cause and effect of
eutrophication in Long Lake, Washington. Eastern Washington
State College, Department of Biology; prepared for the Wash-
ington Department of Ecology. 85 pp. incl. figures and tables.j
Cheney WA: The Department.
Idem (1 June 1975). Response of the Spokane River periphyton community
to primary sewage effluent arid continued investigation of Long
Lake. Performed under contract to Washington State Dept. of
Ecology, project no. 74-144. plympia WA: Washington State
Dept. of Ecology. 117 pp.
Idem (1 June 1976). Continued investigation of eutrophication in Long
Lake: verification data for the Long Lake model. Performed
under contract to the Washington State Dept. of Ecology, con-
tract no. WF-6-75-081. Olympia WA: Washington.Dept. of
Ecology. 64 pp.
Idem (5 January 1977). Affidavit, Superior Court, State of Washington,
County of Spokane; Leonard J. and Lovetta Miotke, et ux, et al.fsic]
vs. City of Spokane, et al. No. 228268. Obtained from the files
of EPA-Seattle.
407
-------
SPOKANE CITY COUNCIL (13 July 1970). Resolution. The Council resolves
that it intends to construct "advanced sewage treatment"
(undefined) as rapidly as possible. Obtained from the city's
"Wastewater study" file at City Hall, Spokane WA.
SPOKANE DEPARTMENT OF PUBLIC WORKS (March 1970). Sewer study invitation
prospectus for the City of Spokane, Washington. Spokane WA:
The City. 9 pp.
SPOKANE DEPARTMENT OF PUBLIC WORKS AND UTILITIES et al. (1 September 1965).
Public service facilities, part 5: Sewerage facilities plan,
report no. 15, city plan series 1. Spokane WA: The City. 44 pp,
SPOKANE PUBLIC WORKS DEPARTMENT (1976). Draft: Facilities planning
report for project area 1, Erie Street drainage basin.
Spokane WA: The Department. 2 vols. marked Text and Exhibits.
Idem (1976). Draft: Facilities planning report for project area 2,
Assembly-Shadle basin and North Central basin. Spokane WA:
The Department. 2 vols. marked Text and Exhibits.
Carl Ted STUDE (1971). An analysis of water quality in the Spokane River.
A thesis submitted in partial fulfillment of the requirements
for the degree of Master of Science in Civil Engineering, Univer-
sity of Washington. Obtained from Rhys Sterling, Washington
State Department of Ecology, Spokane. 92 pp.
408
-------
SYSTEMS CONTROL, INC. (18 May 1973). Data report for the Spokane River
basin model project. Prepared for the U.S. Environmental
Protection Agency, Washington DC. 20 pp. plus approx. 150 pp.
of tables, figures, etc. Palo Alto CA: Systems Control.
Idem (August 1973). Preliminary draft: Spokane River basin model project,
volume VI: User's manual for stratified reservoir model.
Prepared for the U.S. Environmental Protection Agency. Palo
Alto CA: Systems Control. 13 sections.
Dick TODHUNTER & Dick CUNNINGHAM (August 1972). Water quality report,
Spokane and Little Spokane Rivers: July 1971 - September 1971.
Olympia WA: Washington State Dept. of Ecology. 28 pp.
Idem (November 1972). Water quality report, Spokane and Little Spokane
Rivers: April 1971 - June 1971. Olympia WA: Washington State
Dept. of Ecology. 37 pp.
U.S. ARMY CORPS OF ENGINEERS, SEATTLE DISTRICT (12 January 1976). Public
brochure, metropolitan Spokane region, water resources study.
Seattle: The Corps. 29 pp.
Idem (May 1976). Metropolitan Spokane water resources study. Except for
the summary, the report was prepared by Kennedy-Tudor Consulting
Engineers. Seattle WA: The Corps. 13 vols.
409
-------
U.S. BUREAU OF RECLAMATION (1973). Land application of wastewater.
Author and date are-handwritten. Stamped preliminary. Unpub-
lished: obtained from the files of Kenton L. Lauzen, EPA
Region X liaison engineer on assignment to Washington State
Department of Ecology, Olympia WA.
U.S. BUREAU OF RECLAMATION, REGION 1 (June 1954). Rathdrum Prairie pro-
ject, prairie division, Idaho: Report of the regional director
and substantiating materials. Boise: U.S. Bureau of Reclamation.
122 pp. + appendix + several unnumbered foldout maps.
Idem (April 1961). Reappraisal, Spokane Valley project, Washington.
Boise: U.S. Bureau of Reclamation. 70 pp.
U.S. ENVIRONMENTAL PROTECTION AGENCY, NATIONAL ENVIRONMENTAL RESEARCH
CENTER, CORVALLIS (undated). Spokane River algal survey.
Stamped "preliminary" and marked "for discussion only". 39 pp.,
containing tables & chemical analyses not published elsewhere.
Available from Kenton L. Lauzen (U.S. EPA Region X liaison
engineer on assignment to the Washington State Dept. of Ecology,
Olympia WA). .
U.S. ENVIRONMENTAL PROTECTION AGENCY, NATIONAL ENVIRONMENTAL RESEARCH
CENTER, OFFICE OF RESEARCH AND DEVELOPMENT (June 1975). Proceed-
ings: Biostimulation - nutrient assessment workshop, 16-17
October 1973, Corvallis, Oregon. Sponsored by the Eutrophication
and Lake Restoration Branch, Pacific Northwest Environmental
Research Laboratory, National Environmental Research Center,
Corvallis OR. 319 pp. Washington DC: U.S. Gov. Printing Office.
410
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X (24 August 1972). Appendix A.
(EPA justifies its position on phosphorus removal for Spokane.)
Appended to a letter from Robert S. Burd to F.S. Fulwiler dated
5 September 1972. Obtained from Kenton L. Lauzen, EPA Region X
liaison engineer to the Washington State Department of Ecology,
Olympia WA. 6 pp.
Idem (April 1973). Priority basin accomplishment plan, Spokane. Seattle:
U.S. EPA. Unpaginated, no table of contents. 2 pp. of text,
2 full-page maps, and numerous tables.
Idem (1974?). Ground-water monitoring, FY 1974, Spokane Valley, Washington.
Seattle WA: U.S. Environmental Protection Agency. 54 pp. (un-
paginated) of computer printout + 1 page of text + 1 figure.
Idem (29 July 1974). Grant agreement, grant no. C-53 0580 01 0. EPA
offers $2,124,375 to Spokane. Obtained from Kenton L. Lauzen,
EPA Region X liaison engineer to the Department of Ecology,
Olympia WA.
Idem (29 July 1974). Grant amendment, grant no. C-53 0580 02 0. EPA
offers Spokane $973,125; Spokane accepts 8 August 1974.
Obtained from Kenton L. Lauzen, EPA Region X liaison engineer
to the Department of Ecology, Olympia WA.
411
-------
Idem (23 October 1974). Grant amendment, grant no. C-530580021, amend-
ment no. 1. EPA adds a special condition to its grant offer:
that Spokane commit itself to completing the "entire treatment
works project." Spokane agrees 31 October 1974. Obtained from
Kenton L. Lauzen, EPA Region X liaison engineer to the Depart-
ment of Ecology, Olympia WA.
Idem (10 February 1975). Grant amendment, grant no. C-530580-02-2,
amendment no. 2. EPA increases Spokane's grant to $1,209,375;
Spokane accepts 20 February 1975. Obtained from Kenton L.
Lauzen, EPA Region X liaison engineer to the Department of
Ecology, Olympia WA.
Idem (24 March 1975). Grant amendment, grant no. C-530580-02-3, amendment
no. 3. EPA increases Spokane's grant to $34,965,375; Spokane
accepts 2 April 1975. Obtained from Kenton L. Lauzen, EPA Region
X liaison engineer to the Department of Ecology, Olympia WA.
Idem (7 May 1975). Grant amendment, grant no. C-530580-02-4, amendment
no. 4. EPA decreases 'Spokane's grant to $31,405,477; Spokane
accepts 6 June 1975. Obtained from Kenton L. Lauzen, EPA Region
X liaison engineer to the Department of Ecology, Olympia WA.
[U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X ?] (4 May 1971). Draft:
Resume of pollution problems in the Spokane River basin. 12 pp.
Obtained from EPA Region X, Seattle WA.-
412
-------
Idem (1974?). Present waste loads. A report on waste discharges and
Spokane River quality. Obtained from Rhys Sterling, Washington
Department of Ecology, Spokane. 16 pp.
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X, AIR AND WATER PROGRAMS
DIVISION, WATER PROGRAMS BRANCH, MUNICIPAL SECTION, OPERATION
AND MAINTENANCE UNIT (1 October 1973). Operation and maintenance
survey, Spokane River basin. 20 pp. plus tables. Seattle WA:
The Agency.
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X, SURVEILLANCE AND ANALYSIS
DIVISION (June 1973). Spokane area. Approx. 100 pp. incl.
3 apps. Seattle WA: The Agency.
Idem (1975). Spokane River basin profile; river basin water quality
status. 225 pp. incl. numerous figures. Unpublished: obtained
from the Agency, Seattle WA. This report also exists in an
apparently identical version under the title "River basin water
quality status report, Spokane River basin."
Idem (undated). Spokane River basin, "305 A" report. Unpublished;
reviewed in manuscript at U.S. EPA, Seattle WA.
U.S. GEOLOGICAL SURVEY, WATER RESOURCES DIVISION (1960-1975). Water
resources data for Washington. An annual series in two parts:
Part 1, surface water records; part 2, water quality records.
Prepared in cooperation with the State of Washington and with
other agencies. Tacoma WA: USGS.
413
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SESSION LAWS OF THE STATE OF WASHINGTON, 29th SESSION (1945). Chapter 216.
An Act to create the Pollution Control Commission of the State
of Washington.
WASHINGTON STATE DEPARTMENT OF ECOLOGY (September 1970). Implementation
and enforcement plan for water quality regulations, surface
waters, State of Washington. 95 pp. + 1 foldout map. Includes
the WQS formally adopted on 4 December 1967.
Idem (10 November 1972). Notice of violation, docket no. DE 72-186,
issued to the Mayor and members of the City Council of Spokane.
Obtained from Kenton L. Lauzen, EPA Region X liaison engineer
to the Washington State Department of Ecology, Olympia WA.
Idem (28 March 1973). Order, docket no. DE 72-186, issued to the Mayor
and members of the City Council of Spokane. Obtained from
Kenton L. Lauzen, EPA Region X liaison engineer to the Department
of Ecology, Olympia WA.
Idem (19 June 1973). Water quality standards. Olympia WA: The Department
of Ecology. 17 pp. Approved 18 March 1974 in letter from
James L. Agee (Administrator, EPA Region X) to Governor Daniel
J. Evans.
Idem (3 June 1974). State of Washington wastewater treatment construction
grants program master work sheet as of 6-3-74. Obtained from
Frank Monahan, Department of Ecology, Olympia WA.
414
-------
Idem (25 October 1974). National pollutant discharge elimination.system,
waste discharge permit no. WA-002447-3, issued to the Spokane
municipal sewage treatment plant. Obtained from the Department,
Olympia WA. 14 pp.
Idem (18 November 1974). Order, docket no. DE 72-186, issued to the
Mayor and the members of the City Council of Spokane. Obtained
from Kenton L. Lauzen, EPA Region X liaison engineer to the
Department, Olympia WA.
[WASHINGTON STATE DEPARTMENT OF ECOLOGY?] (15 May 1974). Final submittal:
Washington State annual strategy for implementing P.L. 92-500
and State water quality monitoring program, FY-1975. No publi-
cation information: Obtained from the files of the Spokane
Department of Public Utilities. Unpaginated: approx. 100 pp. *
WASHINGTON STATE DEPARTMENT OF ECOLOGY, WATER QUALITY PLANNING SECTION,
303(E) [sic] STAFF (April 1976). 303(E) [sic] water quality
management plan, Spokane and Northeast basins, water resource
inventory areas 52, 54, 55, 56, 57, 58, 59, 60, 61, and 62.
280 pp. incl. 5 apps. Olympia WA: The Department.
WASHINGTON STATE DEPARTMENT OF ECOLOGY, WATER RESOURCES INFORMATION
SYSTEM (January 1973). Spokane River basin bibliography,
basin bibliography no. 4. Olympia WA: The Dept. of Ecology.
6 pp., listing 49 titles without annotation.
415
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WASHINGTON STATE POLLUTION CONTROL COMMISSION (17 November 1966). Infor-
mation bulletin: Public hearing on proposed water quality
standards for Spokane River [etc.]. . . Spokane WA: Washington
State Pollution Control Commission. 47 pp.
WASHINGTON STATE WATER POLLUTION CONTROL COMMISSION (December 1967).
Implementation and enforcement plan for interstate and coastal
waters. Olympia WA (?): The Commission. Approx. 150 pp.
Idem (4 December 1967). A regulation relating to water quality standards
for interstate and coastal waters of the State of Washington
and a plan for implementation and enforcement of such standards.
Olympia WA(?): The Commission. 23 pp.
Idem (23 September 1969). Notice of violation, docket no. 69-77, issued
to the Mayor and the members of the City Council of Spokane.
Obtained from Kenton L. Lauzen, EPA Region X liaison engineer
to the Washington State Department of Ecology, Olympia WA.
Idem (8 January 1970). Order, docket no. 69-77, issued to the Mayor and
members of the City Council of Spokane. Obtained from Kenton
L. Lauzen, EPA Region X liaison engineer to the Department of
Ecology, Olympia WA.
P.L. WEISS (undated). Geologic map of the Greenacres quadrangle, Wash-
ington and Idaho. To accompany U.S. Geological Survey map
GQ-734. Washington DC: U.S. Geological Survey. 4 pp.
416
-------
Glen A. YAKE (5 September 1973). Letter to Daniel V. Neal (District
Supervisor, Washington State Department of Ecology, Spokane).
Yake (Assistant City Manager, Spokane) suggests that Long Lake
can be destratified inexpensively. Obtained from Kehton L. Lauzen,
EPA Region X liaison engineer to the Department of Ecology,
Olympia WA.
Idem (27 August 1974). Letter to the Washington State Department of
Ecology, Spokane. Yake outlines Spokane's objections to a
draft discharge permit. Obtained from the "STPU - discharge
permit/EPA" file of the Department of Public Utilities,
Spokane WA.
Idem (January 1977). Affidavit, Superior Court, State of Washington,
County of Spokane; Leonard J. and Lovetta Miotke, et ux, et al.[sic]
vs. City of Spokane, et al. No. 228268. Obtained from Kenton
L. Lauzen, EPA Region X liaison engineer to the Department of
Ecology, Olympia WA.
417
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10. EPILOGUE: AN ADVENTURE
"The game's going on rather better now," she said, by way of
keeping up the conversation a little.
"'Tis so," said the Duchess: "and the moral of that is 'Oh,
'tis love, 'tis love, that makes the world go round!"
"Somebody said," Alice whispered, "that it's done by everybody
minding their own business!"
"Ah, well! It means much the same thing," said the Duchess,
digging her sharp little chin into Alice's shoulder as she added, "and
the moral of that is 'Take care of the sense, and the sounds will
take care of themselves.'"
"How fond she is of finding morals in things!" Alice thought
to herself.
"I daresay you're wondering why I don't put my arm round your
waist," said the Duchess after a pause: "the reason is, that I'm doubtful
about the temper of your flamingo. Shall I try the experiment?"
"He might bite," Alice cautiously replied, not feeling at all
anxious to have the experiment tried.
"Very true," said the Duchess: "flamingoes and mustard both
bite. And the moral of that is 'Birds of a feather flock together.'"
"Only mustard isn't a bird," Alice remarked.
"Right as usual," said the Duchess: "what a clear way you have
of putting things!"
"It's a mineral, I think." said Alice.
"Of course it is," said the Duchess, who seemed ready to agree
to everything that Alice said; "there's a large mustard-mine near here.
And the moral of that is "The more there is of mine, the less there is
of yours.'"
419
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"Oh, I know!" exclaimed Alice, who had not attended to this
last remark, "it's a vegetable. It doesn't look like one, but it is."
"I quite agree with you," said the Duchess, "and the moral of
that is 'Be what you would seem to be1 or, if you'd like it put
more simply 'Never imagine yourself not to be otherwise than what it
might appear to others that what you were or might have been was not
otherwise than what you had been would have appeared to them to be
otherwise.'"
"I think I should understand that better," Alice said very
politely, "if I had it written down: but I can't quite follow it as you
say it."
"That's nothing to what I could say if I chose," the Duchess
replied in a pleased tone.
"Pray don't trouble yourself to say it any longer than that,"
said Alice.
"Oh, don't talk about trouble!" said the Duchess. "I make you
a present of everything I've said as yet."
Lewis Carroll, Alice's Adventures in Wonderland
420
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APPENDIX A
Benefit-Cost Evaluation of AWT Plants:
Five Case Studies
.by
Kennedy Engineers, Inc.
657 Howard Street
San Francisco, California 94105
(415) 362-6065
-------
CONTENTS
1. INTRODUCTION A-l
1.1 Procedure A-l
1.2 Benefits A-2
1.3 Costs A-3
Capital Costs A-3
Costs of Operation and Maintenance (O&M) A-5
1.4 Case Studies A~6
2. DE PERE, WISCONSIN A-7
2.1 Existing Plant Performance A-8
2.2 Requirements A-9
2.3 Basis of Design A-ll
2.4 AWT Facilities A-12
2.5 Future Performance A-13
2.6 Benefits of AWT A-14
2.7 Costs A-14
2.8 Discharge Location A-17
3. SPRINGFIELD, MISSOURI A-18
3.1 Existing Plant Performance A-18
3.2 Requirements A-20
3.3 Basis of Design A-20
3.4 AWT Facilities A-21
3.5 Future Performance A-22
3.6 Benefits of AWT A-23
3.7 Costs A-23
3.8 Springfield Stormwater Problem A-26
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4. SAN JOSE, CALIFORNIA A-27
A.I Existing Plant Performance A-28
4.2 Requirements A-32
4.3 Basis of Design A-35
4.4 Future Performance A-38
4.5 Benefits of AWT A-39
4.6 Costs A-40
5. SUSSEX COUNTY, NEW JERSEY A-44
5.1 Present Situation A-44
5.2 Requirements A-44
5.3 Basis of Design A-45
5.4 Future Performance A-47
5.5 Benefits of AWT A-48
5.6 Costs A-48
6. SPOKANE, WASHINGTON A-51
6.1 Existing Plant Performance A-52
6.2 Requirements A-54
6.3 Basis of Design A-56
6.4 Future Performance. A-58
6.5 Benefits of AWT A-59
6.6 Costs A-59
7. SUMMARY OF BENEFITS AND COSTS A-62
7.1 Performance A-62
7.2 Benefits A-64
7.3 Costs A-64
FIGURE: Construction Cost Trends A-66
ii
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APPENDIX A
Benefit-Cost Evaluation of AWT Hants
1. INTRODUCTION
We have analyzed five advanced waste treatment (AWT) plants.
In each case we compared the costs and benefits with those of secondary
treatment.
This report has been prepared for The Vertex Corporation as a
supplement to their report under EPA Contract No. 68-01-4338.
Advanced waste treatment (AWT) is defined as treatment beyond
"secondary treatment." Since 7 June 1973, 40 CFR 133 has always defined
"secondary treatment" as (1) 85% removal of BOD and suspended solids, or
(2) reduction of these constituents to 30 mg/1 each, whichever is more
restrictive. Until 26 July 1976, 40 CFR also restricted fecal coliform
bacteria to 200 colonies per 100 ml; but that restriction was lifted
26 July 1976. In the cases we evaluated, we used the definition of
secondary treatment that was in force when the grant offer was made.
1.1 Procedure
For each project we reviewed data on influent loadings, per-
formance, mass emissions, requirements, facilities plans, grant documents,
and costs gathered and furnished to us by Vertex. We have evaluated the
information to determine:
A-l
-------
(a) Influent loadings before and after AWT
(b) Effluent emissions from secondary treatment
(c) Effluent emissions from AWT
(d) Costs, both capital expenditures and annual expenses for
operating and maintaining AWT facilities
The performance of existing plants was determined from self-
monitoring reports.
We found that several of the proposed facilities either did not
meet or greatly exceeded the requirements of subsequent NPDES permits.
Because of conflicting data, we sometimes had to assume a basis for design
that complied with permit requirements.
*
Calculated values of wastewater flows, concentrations, and mass
amounts of pollutants have been rounded and may not be accurate beyond
three significant digits. Estimated costs were usually rounded to the
nearest thousand dollars.
1.2 Benefits
The difference between items (b) and (c) above represents the
incremental benefits of AWT, which include:
(a) BOD numerically less than either 30 mg/1 or 15% of the
influent BOD, whichever is less
(b) Suspended solids (SS) numerically less than either 30 mg/1
or 15% of the influent SS, whichever is less
(c) pH values within more narrow limits than 6.0 and 9.0
(d) Fecal coliform bacteria less than 200 per 100 ml, when the
grant was offered before 26 July 1976; any fecal coliform
limit after 26 July 1976 means AWT, in our legalistic
definition
A-2
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(e) Residual chlorine, oil and grease, nitrogen, phosphorus or
other nutrients, or toxicity from chlorine or un-ionized
ammonia in smaller amounts than normally would be expected
in secondary effluents
(f) Dissolved oxygen in larger amounts than would normally be
expected in secondary effluents
In addition, AWT may improve the receiving waters more than
secondary treatment would. We do not include this kind of improvement in
our analysis of costs and benefits because all new STPs are legally
required to produce effluents that will be consistent with WQS; this
requirement applies to AWT and secondary plants alike.
Unless otherwise noted, "BOD" means "20°-BOD5." It should be
noted that in secondary effluents, the ratio of BOD to UOD may be much
lower than in AWT effluents.
The incremental benefits and costs of AWT are not the difference
between future and present conditions. Some plants are not now attaining
secondary treatment, but others are exceeding it.
1.3 Costs
Capital Costs
We reviewed the data on costs of grant-eligible facilities for
each case study. Eligible costs were separately identified for the
secondary and the AWT portions. Price levels were adjusted for the region
where the facilities are located and for the date the grant was made. For
each case, we give the corresponding price level from the Engineering
News-Record (ENR) Construction Cost Index. The ENR Index is a weighted
index of constant quantities of a hypothetical block of construction,
valued at $100 in 1913 prices, and repriced weekly for twenty areas in
the U.S.
A-3 ,
-------
Secondary treatment includes pre-treatment, primary treatment,
conventional secondary treatment, disinfection (in most cases), and a
pro-rata share of sludge management, service buildings and sitework. AWT
includes the additional components for higher treatment and a pro-rata
share of the commonly needed components.
The capital costs we report indicate the amount spent for
secondary treatment and for AWT facilities, 75% of which comes from Clean
Water Grant funds. The capital costs do not include any salvage value of
existing plant components that will be reused. The project documents we
reviewed do not assign a salvage value to existing facilities, whether or
not they were funded by previous grants.
Capital costs are the total project costs given in the grant
agreements and amendments. We have attempted to adjust the grant costs
to include only the amount that represented treatment facilities; we
excluded portions of the grant for interceptors, pumping, and other kinds
of wastewater facilities. It has not been possible to identify accurately
what the grants are for because grant documents do not always define the
facilities by category. Where grants were known to include other facili-
ties, we pro-rated the grant amounts according to preliminary estimates
in project reports. We also used this method to arrive at capital costs
for individual components of treatment plants.
Project reviews would be greatly simplified if both the project
reports and the grant documents sub-totaled the costs according to
facilities categories, such as those used in the National Needs Surveys:
I Secondary Treatment
II More Stringent Treatment
III Sewer Rehabilitation
IV Collectors and Interceptors
V Correction of Combined Sewer Overflows
VI Control of Stormwater
A-4
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We believe that the reported capital costs include all the Step 3
costs for eligible construction, as well as engineering, administrative,
and legal work during construction. In older projects (initiated before
the three-step grant process), the construction-grant amount may include
costs for facilities planning (Step 1) and design (Step 2) because the
grant documents do not segregate these costs or show whether they are in-
cluded.
Costs of Operation and Maintenance (O&M)
We have estimated annual costs to operate and maintain the
secondary and the additional AWT facilities. Operation and maintenance
(O&M) costs were not always available for the first year of operation of
the expanded facilities; and none of the documents we reviewed projected
O&M costs for the expanded plant at full design capacity. We have there-
fore made both kinds of O&M projections.
Our source of unit costs was the curves we developed for the
"Metropolitan Spokane Region Water Resources Study," Department of the
Army, Corps of Engineers, Seattle District, by Kennedy-Tudor Consulting
Engineers, January 1976. O&M costs in that study represented a Pacific
Northwest Region, mid-1974 price level at ENR Index 2000; we adjusted
these costs to the time of the grant and to the location of the grantee
by applying a ratio of the local ENR Index to the Index used in the
Spokane Study.
O&M costs include (1) estimates for labor, materials, chemicals,
power, and supplies for the typical day-to-day operation and maintenance,
and (2) the averaged cost of long-term maintenance; they do not include
replacement costs. The estimated cost for ultimate disposal of sludge
A-5
-------
solids or Incinerator ash is included, assuming a 20-mile truck haul to a
landfill site. The method we used is valid for comparative purposes, but
may not reflect the true cost of O&M because the cost of energy is increas-
ing more sharply than the ENR Index.
We have estimated O&M costs for the existing treatment facilities
that will continue to be used, even though the value of existing facilities
is not included in the reported capital costs.
We contacted the grantees to determine local policy on pretreat-
ment of industrial wastewater. In every case, the industries are not
required to pretreat their wastewaters for "compatible substances" (e.g.
BOD, SS, P, NH-j). If industries had to pretreat to remove "compatible
substances," the results of this evaluation would be drastically different.
1.4 Case Studies
We have evaluated the benefits and costs for the selected
t
projects. They are reported in the following sequence:
De Pere, Wisconsin
Springfield, Missouri (southwest plant)
San Jose, California
Sussex County Municipal Utilities Authority (SCA), New Jersey
Spokane, Washington
Largo, Florida. The plant is not AWT and was not evaluated.
A summary of all projects is in Section 7.
A-6
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2. DE PERE, WISCONSIN
De Fere's original wastewater-treatment plant is reported to
have been built in 1938. Additions were made in 1963 to provide secondary
treatment for an average flow of 3.45 million gallons per day (mgd). The
present plant was designed for an average influent BOD of 150 milligrams
per liter (mg/1), a total of 4,200 pounds of BOD a day. The plant served
4,950 acres; 56 acres were reported in 1970 as having combined sewers.
At that time, 800,000 gallons per day of untreated wastewater overflowed
from twenty points to the Fox River; another 870,000 gallons bypassed the
plant in wet weather. De Pere installed phosphorus-removal facilities in
the early 1970's. In 1974 the plant served 23,067 people.
The new plant will be a sub-regional facility serving the
southern part of the Brown County Regional Sewer Service Area. The Clean
Water Construction Grant will expand treatment capacity, upgrade existing
facilities, and provide a higher level of treatment. The principal refer-
ence on facilities planning is "Summary Report, Expansion of Wastewater
Treatment Plant, City of De Pere, Wisconsin," 10 April 1974, and revisions
thereto.
*Donohue & Associates (10 March 1970), Report on Waste Water
Treatment Facilities for the City of De Pere. Sheboyan, Wisconsin: Donohue
& Associates, p. 27. From 1964 through 1967, De Pere routinely reported
influent BODs of about 150 mg/1. But since 1968 the influent BODs have
routinely been over 300 mg/1.
A-7
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2.1 Existing Plant Performance
Twenty-three months of plant-operating records (January 1975 to
November 1976) have been reviewed. Concentrations are said to be from
24-hour composites. The following observations are made from these records.
(a) Flow
The average of the daily plant flows was 2.30 mgd, although
we are advised that there are no facilities for accurate
flow measurement! The maximum daily flow was 3.27 and the
minimum day was 1.18 mgd. The amount of overflows and
bypassed flow is not known.
(b) BOD
The average influent BOD was 392 mg/1, with a range of 60
to 1,365.
The average effluent BOD was 41 mg/1, ranging from 0 to 555.
Secondary treatment was not achieved.
The average BOD removal was 90%, but the results are mean-
-> 'ingless because so much waste never gets to the plant it
is bypassed.
(c) Suspended Solids (SS)
The average influent SS was 204 mg/1, ranging from 8 to 708.
The average daily effluent concentration of SS was 48 mg/1,
ranging from 1 to 688. Again, secondary treatment was not
achieved.
The average SS removal was 76%, but only for the flows that
reached the plant.
(d) Phosphorus
The influent had an average of 8.2 mg/1 phosphorus, expressed
as P.
The average phosphorus in the effluent was 0.78 mg/1, with a
range of 0.05 to 12.20; these removals were achieved by alum
precipitation, not normally practiced in secondary plants.
The average reduction was 90%. We would normally expect about
30% phosphorus removal in a conventional activated-sludge
plant not having special phosphorus-removal facilities.
A-8
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The average performance of the existing plant is summarized as
follows.
BOD
SS
Units
392
7,524
41
787
90
6,737
204
3,915
48
921
76
2,994
8.2
157
0.78
14
90
143
mg/1
Ib/day
mg/1
Ib/day
Percent
Ib/day
Type of Measurement
Influent concentration
Influent load
Effluent concentration
Effluent load
Removal efficiency
Removed load
These data are based on estimated flows and on BOD values lower than those
reported by the State.
The present facilities do not produce a secondary effluent
(in terms of BOD and SS), and not all flows are treated. The effluent
undoubtedly does not meet coliform requirements because there are no
facilities for disinfection. The effluent is better with respect to
phosphorus. The strength of the raw wastewater is high, owing to loadings
from industrial sources, principally a meat packer and a dairy. Because
the raw waste contains over 200 mg/1 of BOD, the removal required to
reach 30 mg/1 would have to be 92%. At present flows, and under EPA's
definition of secondary treatment, the effluent would contain 576 pounds
per day of BOD and of SS.
2.2 Requirements
The effluent limitations that are now in force were set in
Permit No. WI-0023787, 28 August 1975. The permit was last modified
sixteen months after the Summary Report was published. Limitations are
given for weekly and monthly averages of daily performance. Only the
A-9
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monthly average requirements are listed here.* The effluent limitations
are for three intervals, as follows.
(a) Until 30 June 1977
Characteris t ic
Limitation
Units
BOD
BOD
SS
SS
Fecal coliform
PH
Total phosphorus as P
Total phosphorus as F
Chlorine residual
(b) Beginning 1 July 1977
Characteristic
BOD
BOD
SS
SS
PH
Fecal coliform
Total phosphorus as P
Total phosphorus as P
75
2160
75
2160
200 (organisms) per
6 to 9
1.5
43
0.75 max.
and lasting until 30 June
Limitation
30
3553
30
3553
6 to 9
200 (organisms) per
1.0
118.4
mg/1
Ib/day
mg/1
Ib/day
100 ml
-
mg/1
Ib/day
mg/1
1978
Units
mg/1
Ib/day
mg/1
Ib/day
-
100 ml
mg/1
Ib/day
From 1 July 1977 until 30 June 1979, the effluent may not contain
more than 15% of the influent BOD and SS. Chlorine residual in the effluent
is not limited after 1 July 1977, and ammonia nitrogen is never limited.
limitations are based on flows of 3.45 mgd until 30 June 1977,
and 14.2 mgd thereafter.
A-10
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(c) Beginning 1 July 1978 and lasting until 30 June 1979
Characteristic Limitation Units
BOD 10 mg/1
BOD 1184 Ib/day
SS 10 mg/1
SS 1184 Ib/day
pH 6 to 9
Fecal coliform 200 (organisms) 100 ml
Total phosphorus as P 1.0 mg/1
Total phosphorus as P 118.4 Ib/day
2.3 Basis of Design
The Summary Report of April 1974 was based on the expectation that
by the year 2000 the plant will serve the city and four towns having an
area of 10,935 acres, a population of 54,800, and an average daily flow
of 16.3 mgd. Unidentified papers in EPA's Chicago Office show that the
plant design was based on 1995 conditions, as follows.
(a) Flow
Average daily flow of 14.2 mgd and peak capacity of 30.0 mgd.
The peak-to-average ratio is 2.11 to 1.
(b) BOD
BOD in the raw wastewater will be 350 mg/1 or 41,475 Ibs/day.
To attain 30 mg/1 in the effluent requires 91.4% removal of
BOD. The effluent would contain 3,550 Ibs/day at design
flow, which complies with secondary treatment.
However, the permit allows only 10 mg/1 BOD in the effluent.
To attain 10 mg/1 would require 97.1% removal. 1,185 Ibs/day
would remain in the discharge at design flow. The Summary
Report shows that the filtered effluent will contain 8 mg/1
of BOD.
A-ll
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(c). Suspended Solids
The suspended solids of the raw wastewater will be 250 mg/1
or 29,625 Ibs/day.
To obtain 30 mg/1 in the effluent requires 88% removal,
with 3,550 Ibs/day remaining in the discharge at design
flow.
The permit allows only 10 mg/1 in the effluent. To attain
10 mg/1 requires 96% removal, which would allow 1,185 Ibs/day
to be discharged. The Summary Report shows 5 mg/1 of SS in
the filtered effluent.
(d) Phosphorus
The phosphorus content of the raw wastewater will be
17 mg/1 or 2,015 Ibs/day.
To achieve a concentration of 1.0 mg/1 would require
removal of 94% of the influent phosphorus (or 1,895 Ibs/day
to be removed). This would leave about 120 Ibs/day of
phosphorus in the effluent, which is the basis of the design.
(d) Nitrogen
The Basis of Design shows influent ammonia-nitrogen concen-
trations of 18.8 mg/1 average and 22.2 mg/1 maximum; the
summertime effluent will contain 4 mg/1, a reduction of 79
to 90%.
2.4 AWT Facilities
The Summary Report shows the components planned for the new AWT
facility. Components specifically required for AWT are:
Chemical feeding for phosphorus removal
Second-stage aeration tanks for nitrification
Final (second-stage) clarifiers
Multimedia filters
Some of the secondary-treatment units are "extra" because of the
requirement for higher amounts of BOD and SS removal and because of recycle
streams from the second-stage and filtration processes. We estimate that
over 15% of the secondary capacity is due to AWT. In addition, a portion
of the sludge-management facilities is needed only because of AWT;
A-12
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(c) Beginning 1 July 1978 and lasting until 30 June 1979
Characteristic Limitation ' Units
BOD 10 mg/1
BOD 1184 Ib/day
SS 10 mg/1
SS 1184 Ib/day
pH 6 to 9
Fecal coliform 200 (organisms) 100 ml
Total phosphorus as P 1.0 mg/1
Total phosphorus as P 118.4 Ib/day
2.3 Basis of Design
The Summary Report of April 1974 was based on the expectation that
by the year 2000 the plant will serve the city and four towns having an
area of 10,935 acres, a population of 54,800, and an average daily flow
of 16.3 mgd. Unidentified papers in EPA's Chicago Office show that the
plant design was based on 1995 conditions, as follows.
(a) Flow
Average daily flow of 14.2 mgd and peak capacity of 30.0 mgd.
The peak-to-average ratio is 2.11 to 1.
(b) BOD
BOD in the raw wastewater will be 350 mg/1 or 41,475 Ibs/day.
To attain 30 mg/1 in the effluent requires 91.4% removal of
BOD. The effluent would contain 3,550 Ibs/day at design
flow, which complies with secondary treatment.
However, the permit allows only 10 mg/1 BOD in the effluent.
To attain 10 mg/1 would require 97.1% removal. 1,185 Ibs/day
would remain in the discharge at design flow. The Summary
Report shows that the filtered effluent will contain 8 mg/1
of BOD.
A-ll
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(c). Suspended Solids
The suspended solids of the raw wastewater will be 250 mg/1
or 29,625 Ibs/day.
To obtain 30 mg/1 in the effluent requires 88% removal,
with 3,550 Ibs/day remaining in the discharge at design
flow.
The permit allows only 10 mg/1 in the effluent. To attain
10 mg/1 requires 96% removal, which would allow 1,185 Ibs/day
to be discharged. The Summary Report shows 5 mg/1 of SS in
the filtered effluent.
(d) Phosphorus
The phosphorus content of the raw wastewater will be
17 mg/1 or 2,015 Ibs/day.
To achieve a concentration of 1.0 mg/1 would require
removal of 94% of the influent phosphorus (or 1,895 Ibs/day
to be removed). This would leave about 120 Ibs/day of
phosphorus in the effluent, which is the basis of the design.
(H) Nitrogen
The Basis of Design shows influent ammonia-nitrogen concen-
trations of 18.8 mg/1 average and 22.2 mg/1 maximum; the
summertime effluent will contain 4 mg/1, a reduction of 79
to 90%.
2.4 AWT Facilities
The Summary Report shows the components planned for the new AWT
facility. Components specifically required for AWT are:
Chemical feeding for phosphorus removal
Second-stage aeration tanks for nitrification
Final (second-stage) clarifiers
Multimedia filters
Some of the secondary-treatment units are "extra" because of the
requirement for higher amounts of BOD and SS removal and because of recycle
streams from the second-stage and filtration processes. We estimate that
over 15% of the secondary capacity is due to AWT. In addition, a portion
of the sludge-management facilities is needed only because of AWT;
A-12
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we have used 28% as the amount due to AWT, based on solids generated by
the various processes, including solids added for phosphorus removal. We
assume that the disinfection facilities will meet (and not exceed) second-
ary requirements.
2.5
Future Performance
The expected performance of the plant under 1995 design conditions
is tabulated below. Influent concentrations and loadings are shown. The
table also shows effluent concentrations and mass emissions for secondary
effluent, for AWT effluent, and for the difference.
Type of Measurement BOD SS
1. Influent concentration
2. Influent load
3. Secondary-effluent concentration
4. Secondary-effluent load
5. Percent removal by secondary
6. AWT-effluent concentration
7. AWT-effluent load
8. Percent removal by AWT
9. Difference, secondary minus AWT
10. Difference, secondary minus AWT
11. Percent difference, AWT minus 5.7 8.0
secondary (row 8 minus row 5)
Units
350
41,475
30
3,555
91.4
10
1,185
97.1
20
2,365
250
29,625
30
3,550
88.0
10
1,185
96.0
20
2,365
17
2,015
11.3
1,410
30.0
1.0
120
94.0
10.3
1,290
mg/1
Ib/day
mg/1
Ib/day
%
mg/1
Ib/day
%
mg/1
Ib/day
64.0 %
A-13
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2.6 Benefits of AWT
As can be seen from the preceding table, the benefits of AWT at
De Pere, as compared with secondary treatment under future permit condi-
tions, include:
(a) BOD
The AWT facilities will remove an additional 5.7% of the
BOD, which is equivalent to 2,365 Ibs/day.
(b) Suspended Solids
An additional 8% of suspended solids, or 2,364 Ibs/day,
will be removed by AWT.
(c) Phosphorus
We would normally expect a conventional activated-sludge
plant of this size to discharge about 70% of the influent
phosphorus (or 1,410 Ibs/day). The existing plant, with
alum precipitation, is actually discharging much less
phosphorus because of permit requirements, not because of
EPA's secondary-treatment requirement.* The AWT plant
will be limited to 1.0 mg/1, which is 120 Ibs/day. The
benefit of AWT is removal of 1,290 Ibs/day.
In addition, the planning documents show that nitrification
units will be available to oxidize the ammonia nitrogen, but we do not
know if they will be operated since ammonia removal is not required.
2.7 Costs
Construction grant No. C-550-706 was made in the third quarter
of 1975. The amended eligible project cost was $20,759,400. The grant
covered interceptors, a river crossing, a pump station, modifications to
the existing plant to increase its capacity, and additions for AWT.
*All discharges into the Great Lakes must be treated for
phosphorus removal. This requirement emerged from the joint State-Federal
Enforcement Conference on the Great Lakes nearly a decade ago.
A-14
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Existing units are being reused in the AWT process, and some new units for
the primary and secondary processes were funded. The capacity will be
increased from 3.45 to 14.2 mgd.
The price level for that region of the country at the time of
the grant agreement corresponds to an Engineering News-Record (ENR)
Construction Cost Index of 2300.
(a) Capital Cost
The capital cost of new STP facilities is $17,850,000.
The capital cost of the facilities for secondary treatment
(not including any salvage value for the existing plant)
is estimated to be $8,948,000, or 50.1% of the grant-eligible
cost of the STP project.
The capital cost of additional facilities to provide AWT
is estimated to be $8,902,000, or 49.9% of the grant-eligible
cost of the STP project.
(b) Operation and Maintenance Cost
Actual cost of O&M of the existing plant was reported as
$333,193 for 1975. The "Summary Report" projects $491,500
for the first year of operation of the new facilities.
We estimate that the annual O&M cost will be $1,500,000
when the new STP is operating at full future capacity, but
our estimate is based on a 1975 price level and excludes
pumping and conveyance costs. Of that amount, $677,000,
or 45.1%, are estimated to be for secondary-treatment facili-
ties; $823,000, or 54.9%, are estimated to be for extra AWT
facilities. The basis of O&M costs is explained in
Section 1.3.
Costs for each component are tabulated as follows.
A-15
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Component
Preliminary Treatment
Contact Basin
Intermediate Clarifier
Nitrification Basin
Final Clarifiers
Effluent Filters
Modify Existing Plant &
Add Chlorination Facilities
Chemical Feed
Sludge Handling
Filter Presses
Incinerator & Ash Disposal
Service Building
Site Work & Miscellaneous
TOTAL
%
Capital Cost ($1,000)
Secondary
549
2,383
685
*
-
308
-
538
636
1,568
290
1,991
8,948
50.1
AWT
-
421
121
1,143
1,128
1,026
132
440
209
247
611
435
2,984
8,902
49.9
Annual O&M ($1,000)
Secondary
121
il72
^
-
37
-
68
145
134
*
*
677
45.1
AWT
!»
>164
.190
-
305
26
57
51
*
*
823
54.9
*Annual cost included in other components
A-16
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2.8 Discharge Location
The effluent is discharged at the edge of the Fox River. Vertex
asked us to estimate the cost of extending the outfall 200 feet into water
thirty feet deep.
We have analyzed this special problem, using the following
assumptions:
Material, 36-inch ductile iron pipe
Nominal current, no storm waves
Pipe buried under 5 feet of cover
Trench would stand at 2:1 side slope
Excavated material would be
side cast and reused, not
removed to shore
Mobilization, installation, and
move-off time would be 2 weeks
(a) Capital Cost
We estimate a project cost of $200,000.
(b) Operation and Maintenance Cost
We estimate that an annual cost of $1,000 is reasonable
for O&M costs.
A-17
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3. SPRINGFIELD, MISSOURI
Springfield's Southwest Wastewater Treatment Plant is of the
activated-sludge type; it employs the Kraus Nitrification Interchange
Process. The plant also uses a deep lagoon for effluent polishing and
for receiving excess flows during wet weather.
The plant was built about 1959 and serves the southern portion
of the city. The effluent is discharged into Wilson Creek, a tributary
of the James River.
The existing plant has rated capacity of 12 mgd average daily
flow, according to the "Basic Design Data Report" (revised January 1974).
The plant receives very high peak flows, some of which bypass the STP
directly to the lagoons.
The STP is being expanded to serve additional areas of Greater
Springfield in Greene County outside the city. The work under the Clean
Water Construction Grant Program will expand the capacity, upgrade the
existing facilities, and increase the degree of treatment. The plant will
serve several industries that discharge large amounts of soluble BOD. The
plant will also have variable amounts of stormwater in the influent.
The principal references we used in this case study were the
February 1973 "Supplemental Report to the Comprehensive Report" and the
"Basic Design Data Report", revised in January 1974.
3.1 Existing Plant Performance
We have reviewed STP data from monthly operating reports. The
following observations are noted for calendar year 1976.
A-18
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(a) Flow
The average daily flow was 17.12 mgd. 1,715 million gallons
of raw sewage bypassed the plant to the lagoon, 10 million
gallons of primary effluent were bypassed to the lagoon,
2,689 million gallons of secondary effluent bypassed the
lagoon and were discharged directly to Wilson Creek. Flows
are not metered. Notice that about 40% of the wastewater
that reached the plant did not get complete treatment.
(b) BOD
The average influent BOD was 227 mg/1 or 32,500 Ib/day.
The average effluent BOD was 44.25 mg/1 or 6,320 Ib/day.
The average BOD removal was 81% or 26,180 Ib/day.
(c) Suspended Solids
The average influent SS was 179 mg/1 or 25,430 Ib/day.
The average effluent SS was 55.5 mg/1 or 7,930 Ib/day.
The average SS removal was 70% or 17,500 Ib/day.
(d) Dissolved Oxygen
The final effluent had an average DO of 4.8 mg/1. The
range of monthly, average values was 2.7 to 6.9,mg/1.
Average operating performance of the Springfield Southwest Plant
for the twelve months of 1976, as shown in the monthly plant operating
reports, is summarized as follows.
Type of Measurement BOD J5S. Units
Influent concentration 227 179 mg/1
Influent load 32,500 25,430 Ib/day
Effluent concentration 44 55 mg/1
Effluent load 6,320 7,930 Ib/day
Removal efficiency 81 70 Percent
Removed load 26,180 17,500 Ib/day
The present facilities are overloaded and are not producing a
"30/30" effluent. Data on nitrogen and phosphorus levels are scanty.
A-19
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3.2 Requirements
NPDES permit No. MO-0049522 was issued on 20 December 1974 by
the Missouri Department of Natural Resources to the City of Springfield
for the Southwest Plant; it expires 19 December 1979. The permit contains
effluent limitations for two time intervals, as follows.
Characteristic
Flow
BOD
BOD
SS
SS
Fecal coliform
PH
Ammonia nitrogen as N
Ammonia nitrogen as N
Dissolved oxygen
Before 7/1/77 After 6/30/77
Units
40
50
16,700
70
23,400
No limit
6 to 9
No limit
No limit
No limit
30
10
2,500
10
2,500
200 organisms
6 to 9
2
500
*
mgd
mg/1
Ib/day
mg/1
Ib/day
per 100 ml
pH units
mg/1
Ib/day.
*6.0 mg/1 or
of saturation, whichever is less.
No receiving-water quality is mentioned. Percentage removals
are not mentioned in the requirements.
3.3 Basis of Design
Criteria in the January 1974 "Basic Design Data Report" show
that the plant is being designed to serve a year 2000 population of 226,000.
(a) Flow
Average daily wastewater flow will be 30 mgd.
(b) BOD
Raw wastewater BOD will be 370 mg/1, or 92,600 Ib/day.
To attain 30 mg/1 in the effluent would require 85,100 Ib/day
removal, or 92%. The discharge would contain 7,500 Ib/day
. of BOD at design flow.
A-20
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According to the Basic Design Data Report, the plant design
is based upon 5 mg/1 of BOD in the effluent. This requires
91,350 Ib/day removal, or 98.6%. The discharge will contain
1,250 Ib/day of BOD. The NPDES permit actually issued
authorizes the effluent to contain twice this amount.
A COD design value of 80 mg/1 is also given.
(c) Suspended Solids
Raw wastewater was assumed to contain 200 mg/1 of SS, or
50,000 Ib/day. Volatile suspended solids were estimated at
37,500 Ib/day.
To attain 30 mg/1 in the effluent would require removal of
42,500 Ib/day, which is 85%. The effluent would contain
7,500 Ib/day.
The plant is designed to attain 5 mg/1 of SS in the effluent.
This requires 48,750 Ib/day removal, or 97.5%. The discharge
would contain 1,250 Ib/day of SS. The NPDES permit authorizes
twice this amount.
(d) Ammonia Nitrogen
The concentration of ammonia nitrogen (NHo-N) in plant influ-
ent is assumed to be 30 mg/1. This is equivalent to 7,500
Ib/day.
We would expect that normal secondary treatment would remove
about 30%. This would leave about 5,250 Ib/day in the
effluent. It should be noted that there are no established
requirements for ammonia-nitrogen content in secondary
effluents. The AWT plant is being designed to produce an
effluent containing 2.0 mg/1 of ammoniacal nitrogen. This
design requires the STP to remove 7,000 Ib/day of ammoniacal
nitrogen (94% of the influent ammoniacal nitrogen). Under
design conditions, the effluent will contain 500 Ib/day,
which is identical to the amount authorized by the NPDES
permit.
3.4 AWT Facilities
AWT facilities provided to attain more stringent effluent limita-
tions are:
Second-stage aeration tanks
Oxygen-generating equipment
Final settling tanks
Second-stage sludge pumps
Tertiary lift pumps
Polishing filters
Effluent pond
A-21
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The secondary facilities are approximately 10% larger, owing
to AWT. The sludge-management and disposal facilities are about 14% larger,
owing to the extra solids produced by AWT.
We assume that disinfection levels will meet secondary-treatment
requirements.
3.5
Future Performance
The expected performance of the AWT plant when it is operating
at the full design capacity of 30 mgd (year 2000) is summarized in the
following table for BOD, SS, and ammonia. The table gives the character
of the influent, together with effluents of secondary and AWT quality,
and the differences between AWT and secondary effluents.
Type of Measurement
1. Influent concentration
2. Influent load
3. Secondary-effluent concentration
4. Secondary-effluent load
5. Percent removal by secondary
6. AWT-effluent concentration
7. AWT-effluent load
8. Percent removal by AWT
9. Difference, secondary minus AWT
10. Difference, secondary minus AWT
11. Percent difference, AWT minus
secondary (row 8 minus row 5)
BOD
SS
NH-j-N
13
Units
370
92,600
30
7,500
92.0
5
1,250
98.6
25
6,250
200
50,000
30
7,500
85.0
5
1,250
97.5
25
6,250
30
7,500
21
5,250
30.0
2
500
93.4
19
4,750
mg/1
Ib/day
mg/1
Ib/day
%
mg/1
Ib/day
%
mg/1
Ib/day
63.4 %
A-22
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3.6 Benefits of AWT -,
The benefits of AWT at Springfield, as compared with secondary
treatment, are summarized from the preceding table as follows.
(a) BOD
The AWT facilities will remove an additional 7% of BOD
(6,250 Ib/day). The effluent BOD will be 5 mg/1 rather
than 30 mg/1.
(b) Suspended Solids
An additional 13% (6,250 Ib/day) of SS will be removed.
The effluent will be 5 mg/1 rather than 30 mg/1.
(c) Ammonia Nitrogen
An additional 63% (4,750 Ib/day) of ammonia nitrogen will
be removed. The effluent will contain 2 mg/1, as compared
to approximately 21 mg/1 expected in secondary effluent.
(d) Chlorine Residual
Because this plant is designed to use ozone for disinfection,
no chlorine residual will be present in the effluent.
Although there is no requirement to limit chlorine toxicity,
oxone disinfection has this additional benefit.
(e) Flow Equalization
The flow-equalization basins can be used to reduce the
peak-to-average ratio of the discharge from the plant, and
can minimize the instantaneous rate of mass emissions into
Wilson Creek.
3.7 Costs
Springfield was awarded Grant No. C-290564 for expansion and
improvements of the existing Southwest Plant. The 1972 estimated total
project cost was $14,994,000 for a plant rated at 24 mgd. In 1974 the
grant was amended to be for a 30-mgd plant having a total project cost
of $25,735,000. In March 1975, after bids were received, the grant was
amended for a total project cost of $41,469,000. Of that amount, $37,539,183
A-23
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are for construction; the remaining $4 million are for technical and other
services.
The price level for that region of the country at the time of
the grant corresponds to an ENR Construction Cost Index of 2340.
(a) Capital Cost
The total project cost of $41,649,000 is for treatment
facilities. We estimate that the capital cost of facilities
for secondary treatment (excluding the value of the existing
plant) is $24,148,000, or 58.2% of the grant.
The capital cost of additional facilities to provide AWT is
estimated to be $17,321,000, or 41.8% of the grant.
(b) Operation and Maintenance
We estimate the annual O&M cost during operation at full
design capacity (year 2000) as $2,157,000 at 1975 price
levels.
The cost of operating the primary and secondary facilities
,is estimated as $1,350,000, or 62.6% of the total.
The cost of operating the extra AWT facilities is estimated
as $807,000, or 37.4% of the total.
A-24
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Costs for each component are tabulated below,
Component
Preliminary Treatment
Primary Treatment (Existing)
Oxygenation
Secondary Settling Tank
Nitrification Pumps
Nitrification Tanks
Final Settling Tanks
Filter Pumps
Polishing Filter
Ozonation
Ponds
Digestion (Existing)
Sludge Thickeners
Sludge Vacuum Filters
Modification to Buildings
TOTAL
%
Capital Cost ($1,000)
Secondary
906
101
8,968
2,605
-
~
-
-
3,139
911
5
4,205
3,030
278
24,148
58.2
AWT
-.
996
289
1,125
4,907
2,202
1,125
3,781
'
911
1
668
481
835
17,321
41.8
Annual O&M
Secondary
J433
J327
-
._
-
-
99
35
121
22
313
Incl . above
1,350
62.6
($1,000)
AWT
-
}*
21
j.293
22
328
-
35
19
3
50
Incl above
807
37.4
A-25
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3.8 Springfield Stormwater Problem
We are advised by Vertex Corporation that Wilson Creek is inter-
mittently devoid of oxygen and lethal to fish life, owing to urban storm-
water and runoff discharging separately from the STP effluent. Springfield
has based its preliminary plans for stormwater management on the assumption
that runoff from a storm event could be captured in a 55-million-gallon
basin. If the basin could be pumped out and released over a period of a
week before the next storm event, the average daily flow (8 mgd) would be
one-fourth to one-third the capacity of the expanded Southwest STP (30 mgd).
Management of this stormwater separate from the Southwest STP and with a
separate discharge to Wilson Creek might be accomplished by another project
consisting of a flow-equalization basin, pumping and treatment facilities,
together with piping, sitework, and accessories. The treatment process
would have to hfi one that could be operated intermittently.
We roughly estimate the costs of such a project as follows:
(a) Capital Costs: $6 million.
(b) Operation and Maintenance: $500,000 a year.
A-26
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4. SAN JOSE, CALIFORNIA
The City of San Jose built a primary STP in 1956 with a capacity
of 36 mgd. It was enlarged to 51 mgd in 1960 and upgraded in 1964 to pro-
vide 94 mgd of secondary treatment. Subsequent enlargements through 1973
raised the capacity to average daily flows of 160 mgd and peak flows of
340 mgd. Dechlorination facilities were added in 1975. The total cost
of all existing facilities (including land) is about $72 million, of which
$25 million have come from 13 USPHS or EPA grants.
The plant serves the cities of San Jose, Santa Clara, and (by con-
tract with numerous County Sanitation and Sanitary Districts) Campbell, Los
Gatos, Monte Sereno, Saratoga, Cupertino, Milpitas, and unincorporated areas
of Santa Clara County. Industrial connections include large food-processing
plants, which operate seasonally (canneries, wineries), and manufacturers of
electronic equipment (semiconductors, circuit boards, computers).
The plant discharges into a dredged outfall channel, thence into
Artesian Slough, a tributary to Coyote Creek, which flows into the south
end of San Francisco Bay. The STP outfall is about twelve miles by water
southeast of Dumbarton Bridge.
The existing plant uses a modified activated-sludge process, the
Kraus Nitrification Interchange Process. The present secondary plant was
sized to serve a future population of about 1.2 million in approximately
the year 1993. The "Project Report" (dated February 1974) claims that- the
present plant, when loaded to full capacity during the canning season, will
produce an effluent containing 49 mg/1 of BOD and 55 mg/1 of SS. The
existing plant, at full future loading, cannot produce a 30/30 effluent.
Up to 143 mgd will now receive AWT. The principal reference on
facilities planning is "Advanced Waste Treatment Facilities Project Report
for the Cities of San Jose and Santa Clara," February 1974.
A-27
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4.1 Existing Plant Performance
We have reviewed operating data from the STP's monthly reports
for the year 1976. The following observations summarize the performance
of the plant.
(a) Flow
The average daily flow in 1976 was 89 mgd; monthly average
flows ranged from 80.6 to 106.5 mgd; daily average flows
ranged from 63.4 to 119.7 mgd; and instantaneous extremes
of flow ranged from 30 to 160 mgd. The average flow in
August and September (the food-canning months) was nearly
20% higher than the rest of the year. The STP has been
designed under two basic sets of criteria, one applicable
only during the canning season.
Average flow in 1976 was slightly less than it was in 1975.
The daily average flow in 1976 (89 mgd) was 56% of the rated
design capacity of the existing plant (160 mgd). The city
reports that, despite continued population growth, the 1977
flows are significantly less than they were in 1976, owing
to water conservation during the current drought.
(b) BOD
The average concentration of BOD in the influent was 383
mg/1, or 284,900 Ibs/day; the maximum daily concentration
was 1,247 mg/1. During the months of August and September
the influent BOD averaged 500 mg/1.
The average daily concentration of BOD in the effluent was
21 mg/1 (15,600 Ib/day).
An average annual BOD removal of 94.5% BOD was achieved.
This is equivalent to 269,300 Ib/day. During the canning
season, 94.7% was removed and the effluent contained less
than 30 mg/1 of BOD.
(c) Suspended Solids
The average concentration of SS in the influent was 370
mg/1 or 275,000 Ib/day. The maximum concentration for one
day during the year was 1,190 mg/1. During the months of
August and September the SS averaged 424 mg/1.
The average SS concentration in.the effluent was 24.2 mg/1
or 18,000 Ib/day.
The average annual SS removal achieved by the plant was
257,000 Ib/day or 93.5%. During the canning season the
effluent contained 35.5 mg/1 of SS, representing 91.6%
removal. During the remaining ten months of the year, the
average in the effluent was 22 mg/1.
A-28
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(d) Fecal Coliform
The annual average value of 30-day geometric means of fecal
coliforms in the effluent was 8 MPN per 100 ml. The range
of these values was 2 to 29.
(e) pH
The values reported for pH were generally in the range of
7.4 to 7.8 pH units. On one day the minimum value was 6.2.
(f) Settleable Solids "
Settleable solids were reported as zero each day of the year.
(g) Temperature
The annual average temperature was 23 degrees C (73.4 .degrees
F), with a monthly range of 20 to 27 degrees C.
(h) Dissolved Oxygen
The annual average DO was 6.1 mg/1, with a range of monthly
average values of 5.9 to 6.2.
(i) Turbidity
The annual average turbidity was 16 JTU, with monthly averages
ranging from 11 to 25 units.
(j) Color
The average of the monthly values of Apparent Color of the
effluent was 34 color units, ranging from 30 to 36.
(k) Sulfides
Effluent total sulfides were reported as zero each day of
the year.
(1) Oil and Grease
Average annual oil and grease in the influent was 67 mg/1,
with monthly averages ranging from 50 to 83. ,
Average annual oil and grease in the effluent was 3.1 mg/1
or 2,300 Ib/day, with monthly averages ranging from 1.9 to
4.6.
Average annual removal of oil and grease was 96% or 47,600
Ib/day.
A-29
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(m) Ammonia Nitrogen
The annual average of the monthly influent ammonia nitrogen
was 24.7 mg/1, equivalent to 18,380 Ib/day; the monthly means
ranged from 20 to 41 mg/1, and the daily values ranged from
12.6 to 55 mg/1.
The effluent contained an average of 11.2 mg/1 or 8,330 Ib/day
of ammonia nitrogen.
Average ammonia nitrogen removal was 55% or 10,050 Ib/day.
There is virtually no ammonia in canning wastes; the ammonia
concentration (both in influent and effluent) during the
canning season is less than during the rest of the year.
(n) Total Phosphate (as
The average annual total phosphate in the influent was 22.4
mg/1 or 16,670 Ib/day. The range of monthly averages was
9 to 26 mg/1.
The average annual total phosphafe in the effluent was 7.1
mg/1 or 5,280 Ib/day. The range was 5 to 10 mg/1.
Phosphate removal averaged 68% or 11,390 Ib/day.
(o) Aesthetic Characteristics
Floating matter, suspended matter, and odors were reported
as "none" throughout the year.
(p) Chlorine Residual
An average chlorine dosage of 10.33 mg/1 was applied. This
is equivalent to 7,700 pounds of chlorine per day. The
chlorine in th'e effluent is reduced with sulfur dioxide.
The average chlorine residual of the effluent was 0.03 mg/1
or 22 Ib/day.
99.7% of the applied chlorine was consumed or reduced before
discharge, on an average annual basis.
(q) Toxicity
Effluent toxicity averaged 98% in the 96-hour TLM test
(98% concentration of effluent in which 50% of the fish
survived for 96 hours).
A-30
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The average performance of the San Jose Plant for the year 1976
is tabulated below.
Measurement
Average flow
Maximum day
BOD
BOD
SS
SS
Fecal coliform
PH
Settleable Sol.
Temperature
DO
Turbidity
Color
Sulfides
Oil & Grease
Ammonia Nitrogen
Phosphate (as PO^
Chlorine
Toxic ity
Influent Effluent
89.15
119.7
284,900 15,600
21
275,000 18,000
24
8
7.4-7.8
0
23
6.1
16
34
0
49,900 2,300
18,380 8,330
16,670 5,280
22
98
Units Removal
mgd
mgd
Ib/day 94.7%
mg/1
Ib/day 93.5%
mg/1
MPN/100 ml
-
-
°C
mg/1
JTU
-
Ib/day 96%
Ib/day 55%
Ib/day 68%
Ib/day
% TL50-96 hr. -
A-31
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The 117 major industries connected to the tributary sewer system
are not required to pre-treat to reduce the influent loadings of BOD and
SS to the San Jose plant.
The effluent produced by this plant is better than secondary-
treatment quality, on an annual basis. On a monthly basis, the effluent
was also better than secondary-treatment quality except for two months
during the canning season, when the monthly average SS was 39 and 32 mg/1,
and the months of February and November, when the average BOD was 31 mg/1.
At the 1976 average flow rate (89 mgd), and under EPA's defini-
tion of secondary treatment, the discharge could contain daily mass J
emissions of 22,300 pounds of BOD and of SS (or about 8% of these con-
stituents in the influent).
4.2 Requirements
NPDES Permit No. CA0037842 was issued 6 December 1974 to the
Cities of San Jose and Santa Clara by the California Regional Water Quality
Control Board, San Francisco Region. The permit will expire on 1 July
1977; it requires the discharger to apply for a new permit before
1 January 1977.
The present permit contains effluent limits requiring AWT and a
compliance schedule extending through 15 December 1978. The permit also
contains interim effluent limitations, which applied before 1 August 1975
(maximum chlorine residual 0.2 mg/1), and other interim limitations, which
apply before 1 July 1977. In addition, the permit contains receiving-
water limitations, land-disposal requirements for sludge, discharge pro-
hibitions, and other special provisions on nuisances, contingencies, source
control, pre-treatment, bypasses, and overflows.
A-32
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(a) Location
One of the prohibitions forbids the discharge of waste to
waters of San Francisco Bay south of Dumbarton Bridge or
tributaries thereto.
(b) The discharge of an effluent containing constituents in
excess of the following limits is prohibited after
1 July 1977.
Instantaneous
Maximum
Constituent
BOD
BOD
SS
SS
Oil & Grease
Oil & Grease
Unit
mg/1
Ib/day
mg/1
Ib/day
mg/1
Ib/day
30-day
Average
10
17,140
10
17,140
5
8,570
Maximum
Day
20
34,250
20
34,300
10
17,140
Chlorine Res.
Settleable
Matter
Turbidity
mg/1
ml/l-hr
JTU
0.1
0.0
0.2
10.0
(c) Other constituents are limited as follows.
pH - between 6.5 and 8.5.
Toxicity - survival of test organisms in 96-hour bioassays
shall achieve a median of 90% survival for three consecutive
samples and a 90 percentile value of not less than 70%
survival for 10 consecutive samples.
There are limits on concentrations of eleven (11) metals
and other toxic constituents; these limits must be achieved
through a combination of secondary treatment, source control,
and pretreatment.
Total identifiable chlorinated hydrocarbons (the sum of DDE,
ODD, BHC, DDT and others) are limited to 0.002 mg/1.
BOD and SS in the effluent are also limited to 15% of the
BOD and SS in the influent.
A-33
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The median MPN of (total) coliform organisms at some point
in the treatment process is limited to 2.2/100 ml for seven
consecutive days.
(d) Receiving-water limitations, in addition to several non-
quantifiable conditions, forbid the discharge to violate
the following conditions within one foot of the water
surface.
Dissolved oxygen - 5.0 mg/1 minimum, annual median of 80%
saturation
Dissolved sulfide - 0.1 mg/1 maximum
pH - variations by more than 0.2 pH units from "natural
ambient pH"
Non-dissociated ammonium hydroxide (NltyOH) as N - 0.025 mg/1
maximum
(e) Flow ' ,
We find no numerical limit in the NPDES permit on effluent
flow rate. The permit mentions that when the application
was submitted in October 1973, che annual average flow rate
was about 82.6 mgd.
The effluent limits imply an average daily flow of 205 mgd,
which corresponds to the peak wet-weather flow for the year
1985. The peak wet-weather flow in 1985 (205 mgd) is much
larger than the annual average flow in 1977 (89 mgd).
(f) interim effluent limitations. The following interim limita-
tions apply before 1 July 1977.'
Constituent
BOD
BOD
SS ;
ss
Oil & Grease
Oil & Grease
Fecal Coliform
Organisms
Settleable Matter
Unit
mg/1
Ib/day
mg/1
Ib/day
mg/1
Ib/day
MPN/ 100 ml
ml/ 1-hr.
30-day
Maximum
60
80,100
120
160,000
15
20,016
200
_
Maximum
Day
160,000
320,000
40,000
i
10,000
1.0
A-34
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4.3 Basis of Design
Criteria from the Project Report (February 1974) show that the
additional AWT facilities were sized for flows in the year 1985. There
are apparent conflicts over the exact degree of treatment to be provided
by the new facilities now under construction.
Facilities proposed in the Project Report (which was prepared in
1973) will produce an effluent containing 10 mg/1 of BOD, 5 mg/1 of SS,
1.5 mg/1 of ammoniacal nitrogen, and a limited amount of Ultimate
Oxygen Demand (UOD). The agreement between the city and the design engineer
contains design criteria confirming the AWT loadings and BOD removals given
in the Project Report. Subsequently, in December 1974, the NPDES permit
was issued. The permit authorizes discharge of an effluent containing 10
mg/1 of BOD and .SS and places no limit on ammonia or UOD.
A 1977 effluent-reuse study prepared by San Jose, found in the
files of the Regional Water Quality Control Board, shows the projected
quality of the future AWT effluent as follows.
Constituent Value Unit
BOD 5 to 10 mg/1
SS 5 to 10 mg/1
NHj as N 0 to 2 mg/1
Organic N 0 to 1 mg/1
Nitrate N 10 to 15 mg/1
Phosphate (as PO^) 10 to 15 mg/1
Oil & Grease 0-2 mg/1
Coliform less than 2.2 organisms MPN/100 ml
DO 6 to 6.5 mg/1
Turbidity less than 10 JTU
Chlorine Residual 0 -
Bicarbonate 200-300 mg/1
A-35
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Other effluent constituents (minerals, phenolics,, total ..identifiable chlor-
inated hydrocarbons, and heavy metals) were assumed to remain unchanged
from 1976.
Design criteria for significant wastewater constituents are given
in the Project Report and the design contract; these criteria are summarized
below.
(a) Flow
Sewage and non-seasonal industrial wastes: 112-mgd average,
210-mgd peak rate.
Over and above the 112-mgd average, seasonal wasteflows from
the canneries add another 31 mgd (average cannery wasteflow
for the six busiest days each year).
Total capacity: 143-mgd average, 255-mgd peak hydraulic
rate.
The average design capacity of the AWT facilities (143 mgd)
is considerably less than that of the present treatment
plant (160 mgd). It is also much less than the amount
indicated in the NPDES permit (205 mgd). These discrepancies
derive from limitations on.the grant-eligible size of facili-
ties, and were imposed on California municipalities in
critical air basins, such as San Jose. In this case, the
size was based upon a conservative growth rate (reflecting
a low birthrate and no net immigration) and on a planning
period of only ten years (1975 to 1985). Previously con-
structed facilities were designed to have capacity for a
higher growth rate and a much longer planning period.
The seasonal load from the canneries that was used as a
basis for design (maximum 6-day flow of 31 mgd) was taken
from the STP's operating reports, and is unchanged for the
future.
(b) BOD ...
The BOD loading to the AWT facilities (from the secondary
facilities) is analyzed as follows.
Sewage and non-seasonal wastes: 52,000 Ib/day. In 112 mgd,
this is a concentration of 55.6 mg/1.
A-36
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Sewage and all Industrial wastes: 64,000 Ib/day for six
days per year. In 143 mgd, this is a concentration of
53.6 mg/1.
BOD removal of not less than 53,000 Ib/day is planned during
the canning season. This is equivalent to 83% removal of
the BOD in the effluent of the existing STP. The discharge
would contain 11,000 Ib/day of BOD; the concentration would
be 9.2 mg/1.
In the Project Report, influent BOD was shown as 286 mg/1
from domestic, commercial and non-seasonal industry, and
1,560 from seasonal industry. This amounts to 670,000
Ib/day during the canning season, which is considerably
higher than in 1976 (about 440,000 Ib/day). Secondary
treatment to 30 mg/1 would require removal of 634,300 Ib/day
(or 94.6% removal of the BOD). AWT will remove 98.4% of
influent BOD (or 659,000 Ib/day overall removal during the
canning season).
If the raw waste in the future is the same strength as it
was during the 1976 canning season (500 mg/1), 143 mg/1 of
influent would contain 596,700 Ib/day. Secondary treatment
to 30 mg/1 would require removal of 560,900 Ib/day (or 94%
of the influent BOD). Additional removal by AWT to 11,000
Ib/day remaining in the effluent would result in a concen-
tration of 9.2 mg/1 of BOD and would require 98.2% removal
of influent BOD (or 585,700 Ib/day overall removal).
(c) Suspended Solids
Influent SS in sewage and non-seasonal industrial wastes
averages 362 mg/1 for 112 mgd (or 339,000 Ib/day).
SS influent load during the canning season averages 485
mg/1 for 143 mgd (or 579,000 Ib/day). The basis of design
is for an increase of 240,000 Ib/day during the maximum six
days of the canning season.
To attain 30 mg/1 during the canning season would require
removal of 543,000 Ib/day (or 93.8% of the influent). To
attain 30 mg/1 during the remainder of the year would
require removal of 311,000 Ib/day (or 91.7% of the influent),
which is less than one-half the SS that must be removed
during the canning season.
A-37
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The basis of design, however, allows .the "secondary treat-
ment" effluent to contain 75 and 80 mg/1 of SS during
non-canning and canning seasons. This is the basis upon
which the AWT processes are planned, and it is about twice
the SS in the existing effluent. The basis for design
gives 5 mg/1 SS in an AWT effluent. This discharge would
contain about 5,900 Ib/day (or one percent of the influent
loading).
(d) Ammonia
The ammonia loading and nitrification capacity are as
follows.
Sewage and non-cannery wastes: The influent load of ammoni-
acal nitrogen is 23,500 Ib/day. In 112 mgd of influent, this
is equivalent to 25 mg/1.
j
During each of six days of maximum seasonal industry, the
AWT load will remain at 23,500 Ib/day of ammoniacal nitrogen.
In 143 mgd of wasteflow, this is equivalent to 20 mg/1.
The nitrification facilities are designed to lower ammoniacal
nitrogen to 1.5 mg/1 in the effluent year round. This
requires additional removal by AWT of 21,850 Ib/day (or 93%
of the influent ammonia)during the canning season. During
the rest of the year, 22,100 Ib/day must 8e removed by AWT,
or 94.0% of the ammonia in the influent. Therefore, the
non-canning season governs the design of the nitrification
facilities. Furthermore, all ammonia removal will be by AWT
except during the canning season, when 25% will be removed
by secondary-treatment processes and 75% will be removed by
AWT.
The secondary process was not designed to remove ammonia
during the non-canning season. During the canning season
only, the secondary effluent (and AWT influent) contains
15 mg/1, or 18,000 Ib/day of ammonia.
4.4 Future Performance
The expected performance of the STP under future design conditions
is tabulated below. The predicted character of the influent, together with
the character of secondary and AWT effluents, is shown in the table. The
data are applicable during the six days of the canning season when the flow
A-38
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is 143 mgd. Note that the values for secondary treatment are taken from
EPA's definition of secondary treatment, not from what the San Jose plant
actually produces.
Type of Measurement
1. Influent concentration
2. Influent load
3. Secondary-effluent concentration
4. Secondary-effluent load
5. Percent removal by secondary
6. AWT-effluent concentration
7. AWT-effluent load
8. Percent removal by AWT
9. Difference, secondary minus AWT
10. Difference, secondary minus AWT
11. Percent difference, AWT minus
secondary (row 8 minus row 5)
BOD
_SS_ NH3-N
Units
562
670,000
30
35,800
94.6
9.2
11,000
98.4
20.8
22,800
485
579,000
30
35,800
93.8
5.0
5,900
99.0
25.0.
29,900
20
23,500
15
18,000
25
1.5
1,650
94.0
13.5
16,350
mg/1
Ib/day
mg/1
Ib/day
%
mg/1
mg/1
%
mg/1
Ib/day
3.8
5.2
67.5 %
4.5
Benefits of AWT
The benefits of AWT at San Jose under future design conditions,
contrasted with normal secondary treatment, include:
(a) Flow
The AWT plant will treat an average daily flow of 112 mgd,
excluding seasonal industry; it will treat 143 mgd 6 days
per year, which includes 31 mgd of seasonal industry. Peak
hydraulic capacity is 210 mgd.
Rated capacities of AWT facilities (143 mgd) are lower, than
those of secondary facilities (160 mgd).
(b) BOD l .
The AWT facilities will remove an extra 3.8% of BOD, or
22,800 Ib/day during the canning season; these figures are
based on an effluent concentration of 9.2 rather than 30
mg/1. '
A-39
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(c) Suspended Solids
The AWT facilities will remove an extra 5.2% of SS, or
29,900 Ib/day during the canning season; these figures
are based on an effluent concentration of 5.0 rather
than 30 mg/1.
(d) Ammonia Nitrogen
The AWT facilities will remove an additional 67.5%
(or 16,350 Ib/day), expressed as N, during the canning
season. The effluent concentration will be 1.5 rather
than 15 mg/1.
(e) Coliform Organisms
When EPA offered San Jose an AWT grant, secondary-treatment
regulations required that fecal coliform bacteria must not
exceed 200 organisms per 100 ml. The AWT effluent is
expected to contain less than 2.2 total coliform organisms
per 100 ml. Although there is no necessary correlation
between total and fecal coliform organisms, it is safe to
say that removals of fecal coliform will be at least 99%
more than under secondary-treatment regulations.
(f) Other Parameters
San Jose's AWT effluent will be superior to secondary
effluent for the following parameters:
Less organic nitrogen, but more nitrates
Less phosphate
Less oil and grease
More dissolved oxygen
Less turbidity
Less (no) chlorine residual
Less bicarbonate
4.6 Costs
Grant No. C-0947 was made on 5 June 1975 for the Step 3 work.
After bidding, the eligible project cost was revised to $64,286,328.
This grant is primarily for nitrification and filtration; it does not '
include any facilities for sludge handling and disposal. The grant
covers two separate construction projects. Project A is for nitrification
facilities, including nitrifying-type activated-sludge aeration tanks, a
A-40
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blower building, tertiary sedimentation tanks, and appurtenances; these
costs are 58% of the grant-eligible cost of the STP project. Project B
is for tertiary filtration and some modifications to existing facilities,
e.g. additions to the administration and maintenance buildings necessitated
by the new AWT facilities, chlorine contact tanks, and modifications to
chlorination and dechlorination systems; these costs are 42% of the grant-
eligible cost of the STP project. (More than $2 million in construction
costs were ineligible for grants; these costs have been excluded from this
evaluation.)
We estimate that the AWT facilities that will be constructed
under Grant No. C-0947 include the following items.
Paint Shop: 33%
Sludge-Control Building and Modifications to Existing
Facilities: 80%
All Other Components: 100% (See pp. ^^ and A_69 for further
details.)
The construction cost of the two projects, including seven change
orders and excluding the ineligible items, is (as of 22 April 1977) slightly
less than the estimated eligible project cost shown in the grant agreement.
The eligible costs include a grant-processing fee of 0.5% as well as adminis-
tration and engineering expenses. The engineering fees include preparation
of the project report, the environmental-impact report, and plans and speci-
fications; the fees also include Step 3 services during construction and
start-up.
Sludge-solids handling and disposal are not included in Grant No.
C-0947. The Priority List shows another grant, No. C-1381, to provide
facilities for sludge-solids management. The Step 1 offer under Grant No.
C-1381 was made on 17 August 1976. The Project Report and EIR are not yet
completed. The Step 2 target date is April 1978. The Step 3 target date
A-41
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is January 1979. The total eligible cost for additional sludge-solids
facilities at the San Jose plant is estimated at $21,185,000. The State.'s
project evaluator confesses that the amount of the sludge project attrib-
utable to nitrification and filtration is not now known, but will be
determined as a part of the Step 1 work.
When the AWT grant was offered, the cost level at San Jose
corresponded to an ENR Construction Cost Index of approximately 2650.
Cost are summarized below.
(a) Capital Costs
The capital cost of grant-eligible facilities is $64,286,000
under Grant No. C-0947.
Of this amount, we estimate 1.1% ($719,000) is for secondary
treatment (plus the value of the secondary portion of the
existing plant).
We estimate that 98.9% ($63,567,000) is for AWT (plus the
value of the AWT portion of the existing plant).
The capital cost of additional sludge facilities is shown
on the State Priority List as $21,185,000. We estimate
that 70% may be attributed to secondary treatment and 30%
($6,356,000) to AWT.
The total grant-eligible costs for AWT at San Jose is
estimated at $69,923,000, plus the value of existing AWT
facilities.
(b) Operation and Maintenance
The STP's Annual Report for 1975 shows that the O&M costs
for the present secondary plant were $4,553,398, of which
41% were for personal services. O&M is expected to increase
by 30% to about $6 million in 1979.
A recent study by the city has projected the additional
first-year O&M costs (for AWT facilities only) as $3,000,000
in 1979. This projection reflects the recent large increase
in the cost of electricity. O&M costs for additional sludge-
solids management may be about $1,000,000 more.
A-42
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During the first year of operation (1978) the flow will be
at about 70% of capacity. Projecting to full capacity, the
O&M costs would be about $14,000,000 per year, at an ENR
Index of approximately 3500. Of this amount, 60% is for
operating the secondary processes and 40% ($5.6 million)
is for AWT.
Reducing the costs to grant-price levels of 1975 (ENR Index
of 2650), the O&M at full capacity is estimated to be
$6,000,000 for primary and secondary treatment, and $4,000,000
for AWT.
The following table gives a breakdown of costs by component.
Components
Ammonia-Nitrification Tanks
Tertiary-Settling Tanks
Tertiary-Blower Buildings
r
Tertiary Filters
Addition to Computer
Additions to Sludge-Control
Building
Sitework
Paint Shop
Modifications to Existing
Facilities
Total Grant No. C-0947
Percent of Total
Sludge Handling & Disposal
(Grant No. C-1381)
Capital Cost ($1,000)
Secondary
-
-
_
-
62
_. .
387
270
719
1.1
14,829
AWT
11,912
13,526
9,615
16,570
154
248
10,273
191
1,078
63,567
98.9
6,356
Annual O&M ($1,000)
Secondary
-
_
-
-
-
-
6,000
6,000
60.0
Unknown
AWT
970
1,030
-
-
-
-
2,000
4,000
40.0
Unknown
A-43
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5. SUSSEX COUNTY, NEW JERSEY
The Sussex County Municipal Utilities Authority (SCA) will pro-
vide pollution-control facilities for certain unsewered communities in the
Wallkill drainage basin of New Jersey. SCA's planning work has been
supported by a Step 1 grant from EPA (Grant No. 340406). Several boroughs
and townships where septic tanks are now used are planning to provide
collection sewers. SCA is planning to provide interceptor sewers, pump
stations, force mains, and an STP. Most of the service area is residential.
About 10% of SCA's wastewater will come from commercial establishments;
almost none will come from industries.
The source of data on the proposed plant is a schematic drawing
and four pages of design criteria (dated November 1975), modified by more
recent unwritten information obtained in New Jersey by Vertex Corporation.
5.1 Present Situation
There are virtually no wastewater facilities in this study area
other than septic tanks.
5.2 Requirements
An NPDES permit for the proposed discharge has not been issued.
Design criteria for SCA do not contain projections of influent
wastewater quality. We have made assumptions for a typical residential
community that would be required to meet minimum National standards.
A-44
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We would expect the quality of the SCA wastewater from a secondary treat-
ment plant to be:
Type of Measurement BOD SS_ Unit
Influent concentration 200 200 mg/1
Influent load 8,350 8,350 Ibs/day
Effluent concentration 30 30 mg/1
Effluent load 1,250 1,250 Ibs/day
Removal efficiency 85 85 %
Removal concentration 170 170 mg/1
Removed load 7,000 7,000 Ibs/day
A normal domestic sewage of this type may contain about 10 mg/1
of phosphorus. About 7 mg/1 (300 Ib/day) would be discharged in the
secondary effluent.
A normal domestic sewage may contain about 25 mg/1 of ammoniacal
nitrogen. About 17 mg/1 (700 Ib/day) would be discharged in the secondary
effluent.
Current Federal Regulations do not limit coliforms in STP
effluents. However, current Federal Regulations allow an NPDES permit to
set coliform limits.
5.3 Basis of Design
Facilities-planning criteria (dated November 1975) show that the
proposed plant will need capacity for an average daily flow of 5 mgd in
the year 1990 and 10 mgd in the year 2010. Vertex Corporation advises
that the grant will be for a 5-mgd plant (Letter 13 April 1977). The plant
0
will use multiple modular units, numbered from 1 to.10, for the various
components of the treatment plant. The initial phase will apparently be
constructed to serve through the year 1990; the initial 5-mgd plant may
A-45
-------
eventually be expanded to 10 mgd, although certain portions of the initial
plant appear to have 10-mgd capacity. The design criteria provide for
10-mgd capacity in the year 2010. We assume that under the pending grant
half the modular units will be built. All the sludge-management facilities
are shown as three units for 10 mgd; we assume that two will be built.
Design criteria for the future plant are:
(a) Flow
Average daily flow of 5 mgd, expandable to 10 mgd. Peak
hydraulic capacity is not given.
(b). BOD
The BOD of the raw wastewater is not given. We assume ..
200 mg/1. According to the design criteria, the plant
will produce an effluent having 10 mg/1 of BOD (420 Ib/day),
which would require removal of 7,930 Ib/day (95%) of the
assumed influent BOD.
(c) Suspended Solids
No data on SS are included in the design criteria. Under
Federal Regulations, the STP must attain at least 85% removal,
or no more than 30 mg/1 of SS in the effluent. 1,250 Ib/day
of SS may be discharged.
Pressure filters will be provided. They have a rather high
loading rate and probably are primarily for phosphorus
removal. They will further reduce the SS, perhaps to 15 mg/1.
(d) Ammonia Nitrogen
The concentration of ammonia expected in the raw wastewater
is not stated. We will assume 25 mg/1 (1,050 Ib/day) of
ammoniacal nitrogen in the STP influent. The design criteria
state that the effluent will contain 1.0 mg/1 (40 Ib/day).
Required removal will be 96% (more than 1,000 Ib/day). A
secondary effluent might contain about 700 Ib/day.
(e) Nitrate Nitrogen
0
The design criteria allow 0.5 mg/1 of N03~N in the effluent.
Nitrate is produced by ammonia oxidation and is uncommon in
the raw influent. To reduce the nitrates to this level,
however, would require denitrification. We were advised
that the methane! nitrate reactors and denitrification
A-46
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5.4
clarifiers shown in the design criteria are not grant-
eligible.
(f) Phosphorus
The concentration of phosphorus expected in the raw waste-
water is not given. We will assume 10 mg/1 (420 Ib/day).
According to the design criteria, the effluent will contain
0.1 to 0.3 mg/1 (about 10 Ib/day). Required removal will
be 98% of the assumed influent phosphorus (more than 400
Ib/day). A secondary effluent might contain about 300 Ib/day.
(g) Dissolved Oxygen
The design criteria,set the effluent DO at 6.0 mg/1; post-
aeration will be provided. Without post-aeration, not over
2 mg/1 of DO would be expected.
(h) Disinfection
The design criteria do not cover coliform organisms. However,
chlorination and chlorine-contact chambers are listed in the
facilities to be furnished.
Future Performance
The following table gives the expected performance when the STP
is operating at full loading at an average daily flow of 5 mgd. We have
assumed the influent loadings. Predicted quality of secondary and AWT
effluents and the difference between them is also listed.
Type of Measurement
1. Influent concentration
2. Influent load
3. Secondary-effluent concentration
4. Secondary-effluent load
5. Percent removal by secondary
6. AWT-effluent concentration
7. AWT-effluent load
8. Percent removal by AWT
9. Difference, secondary minus AWT
10. Difference, secondary minus AWT
11. Percent difference, AWT minus
secondary (row 8 minus row 5)
BOD
200
8,350
30
1,250
85
10
420
95
20
830
SS.
200
8,350
30
1,250
95
15
630
92.5
15
620
NH3-N
25
1,050
17
700
30
1.0
40
96
16
640
10
420
7
300
30
Unit
mg/1
Ib/day
mg/1
Ib/day
10
7.5
61
0.2 mg/1
10 Ib/day
.98 %
6.8 mg/1
290 Ib/day
68 %
A-47
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5.5 Benefits of AWT
Granting our assumptions the benefits of AWT at the proposed
5-mgd STP will include:
(a) BOD
AWT will remove an additional 830 Ib/day of BOD (10% of the
influent).
(b) Suspended Solids
AWT will remove an additional 620 Ib/day of SS (7.5% of the
influent).
(c) Ammonia Nitrogen
AWT will remove an additional 640 Ib/day (61%) of the
ammonia nitrogen.
(d) Phosphorus
AWT will remove an additional 290 Ib/day of phosphorus (68%
of the influent).
(e) Dissolved Oxygen
Post-aeration facilities, not necessary for secondary treat-
ment, will produce an additional 4 mg/1 (170 Ib/day) of DO
in the effluent.
(f) Coliform Organisms
The processes proposed are expected to reduce coliform
organisms to less than one (1) percent of the organisms
expected in a secondary effluent under present requirements.
5.6 Costs
Grant No. 340406 to the SCA is expected to include interceptors,
pump stations, force mains, and a treatment plant. Five other grants are
shown in the Priority List for collector sewers in the tributary communities.
The total cost of all projects in the Wallkill Valley is about $50,000,000.
This evaluation is limited to the grant-eligible portion of the SCA project
(Grant No. 340406) that applies to the planned STP.
A-48
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The eligible construction cost of the STP project alone was estimated'by
the SCA's design engineer at $8,328,000. The total cost of the STP will
be about $11,000,000, including engineering, administration, and other
related services. This price level corresponds to a spring 1977 ENR Con-
struction Cost Index of 2970.
(a) Capital Cost
The portion of the project grant for the STP is assumed
as $11,000,000.
We estimate the capital cost of the portion of the plant
necessary to provide secondary treatment as $7,333,000
(66.7% of the total cost of the plant).
We estimate the capital cost of the additional facilities
to provide AWT to be $3,667,000 (33.4% of the total cost
of the plant).
(b) Operation and Maintenance Cost
We estimate the annual O&M cost at present cost levels, but
at full 5-mgd design capacity (year 1990), as $1,000,000.
The cost of operating facilities to produce a secondary
effluent is estimated as $521,000 (52.1% of the total).
The cost of operating the extra AWT facilities is estimated
as $479,000 (47.9% of the total).
No breakdown of capital costs was available for the components of
the future SCA Plant. In this case,, we have developed capital costs from
the same source of unit-price data we used for O&M costs. Our estimated
costs for each component of the plant are tabulated below.
A-49
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Component
Primary Treatment
Secondary Treatment
& Nitrification
Chemical Feed for
Phosphorus Removal
Pressure Filters
Chlorination
Post-Aeration
Flotation Thickeners
Gravity Thickeners
Vacuum Filtration
Incinerators
Service Building &
Sitework
Total
%
Capital Cost C$1,000)
Secondary
2,925
975
-
-
176
-
71
731
1,054
1,401
*
7,333
66.7
AWT
-
975
196
976
-
254
27
284
410
545
*
3,667
33.4
Annual O&M ($1,000)
Secondary
141
83
-
-
22
-
5
11
181
78
*
521
52.1
AWT
-
-
133
126
-
30
2
/ *
71
30
*
479
47.9
*Included above
A-50
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6. SPOKANE, WASHINGTON
The Spokane STP was constructed in 1958 and modified in 1962.
It is a primary plant with chlorination; it serves the dry-weather flow
from the city, which is collected mostly in combined sewers. The sewerage
system has over forty documented overflows from the interceptors, unmetered
bypasses, and an overflow of raw sewage from the STP influent. The existing
plant is bypassed when there are high flows resulting from rainfall or
snowmelt. The effluent is discharged into the Spokane River at river mile
67.2.
In 1975, the sewer-service area included 19,380 acres and 167,000
persons. Approximately 82% of the area had combined sewers, and all the
sanitary sewers are tributary to combined sewers. Excessive infiltration
and localized flooding of streets and basements are persistent problems in
Spokane's wastewater system. The STP is being upgraded to provide secondary
treatment plus phosphorus removal to serve a population of 211,000.
The principal sources of data for Spokane are "Report on Additions
and Modifications to the Wastewater Treatment Plant," 30 June 1973 (in two
volumes), and "Proposed System for User Charges and Industrial Cost
Recovery," March 1974 (in two volumes). "Metropolitan Spokane Region Water
Resources Study," January 1976, was used as a source of recent data for the
evaluation of existing facilities.
A separate construction project is being planned to provide
primary treatment for stormwater overflows.
A-51
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6.1 Existing Plant Performance
Operating data for the years 1973, 1974, and 1975 were used as
the basis of this summary of performance before upgrading of the plant.
(a) Flow
The plant received an average dry-weather flow of approxi-
mately 28 mgd. In the summer the average daily flow was
about 20% more than during the rest of the year. The
amount of inflow treated ranges from zero to between 50
and 60 mgd. Few data are available on the overflows and
bypasses, but about 700 million gallons per year has been
estimated.
(b) BOD
Annual average influent BOD is reported as 221 mg/1
(51,600 Ib/day).
Annual average BOD of the treated effluent is 130 mg/1
(30,400 Ib/day).
21,200 Ib/day of BOD are removed (41% of the influent).
(c) Suspended Solids
Average influent is 165 mg/1 (38,600 Ib/day).
Average effluent is 65 mg/1 (15,200 Ib/day).
Removal of SS is 23,400 Ib/day (61%).
(d) Total Phosphorus
Total phosphorus, expressed as P, averages 8.8 mg/1
(2,060 Ib/day) in the influent. Filterable phosphorus
is about one-half that amount.
Total phosphorus in the effluent is 5.42 mg/1 (1,200 Ib/day)
The apparent removal is 840 Ib/day (41% of the phosphorus
in the influent).
(e) Total Coliform
Total coliform bacteria (on an average annual basis) range
from 20,000 to over 60,000 organisms per 100 ml of
effluent.
A-52
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(f) Dissolved Oxygen
Average annual DO has been reported as 4.1 mg/1.
The facilities-planning documents do not give the treatment
capacity of the existing plant on the basis of average daily flow. The
peak hydraulic capacity is rated at 50 to 60 mgd.
The performance of the existing primary plant during average
dry-weather flow is summarized below.
Measurement
BOD
SS
Unit
Influent concentration
Influent load
Effluent concentration
Effluent load
Removed concentration
Removed load
Removal efficiency
221
51,600
130
30,400
91
21,200
41
165
38,600
65
15,200
100
23,400
61
8.8
2,060
5.4
1,260
3.4
800
39
mg/1 v
Ib/day
mg/1
Ib/day
mg/1
Ib/day
percent
The effluent BOD is over four times that of secondary effluent,
and the effluent SS is more than double that of secondary effluent.
Emissions of phosphorus are more than triple the permit allowance. Emis-
sions of the untreated discharges are not known.
If the present dry-weather flow through the plant (28 mgd) were to be
treated to the secondary level, 86% of the BOD and 85% of the SS would have
to be removed. This would result in a discharge containing only 7,000
pounds of BOD and SS per day.
The existing plant does not meet coliform requirements. An
additional 99% reduction of coliform organisms is required because the
Step 3 grant was made before 26 July 1976.
A-53
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6.2 Requirements
NPDES Permit No. WA-002447-3 was issued to Spokane by the
Washington Department of Ecology on 25 October 1974; it expires on
25 October 1979. The permit gives interim effluent regulations and
final effluent regulations for the discharge from the STP. It also
authorizes untreated discharges from bypasses and overflows.
(a) Effluent Discharge
Effluent from the plant to the Spokane River is designated
"Discharge 005". Beginning 1 February 1977, the effluent is limited as
follows.
Parameter
Quantity
BOD
BOD
SS
SS
Fecal coliform
pH
Monthly
Average
40
30
10,008
30
10,008
200
6.5-8.5
Weekly
Average
(See Below)
45
15,012
45
15,012
400
_
Unit
mgd
mg/1
Ib/day
mg/1
Ib/day
organisms/ 100 ml
units
Total phosphorus
(See Below)
BOD and SS are limited to 15% of the influent when influent
concentrations are less than 200 mg/1; this limit may govern treatment
facilities for SS.
A-54
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For secondary-treated flows of 57 mgd or less, the effluent
total phosphorus shall be:
(1) A maximum of 2.1 mg/1 and
377 Ib/day, or
(2) Not more than 15%
of the influent,
whichever limitation is more stringent, during any consecutive seven days,
Furthermore:
"When the average daily flow is greater than
57 mgd during any 7-consecutive day period,
no effluent limitation on total phosphorus
shall be in effect. The permittee, however,
shall continue to treat for phosphorus removal
all flows receiving treatment from the secondary
units."
The pH limitation is more stringent than the 6 to 9 required
by EPA's definition of secondary treatment.
r
(b) Bypasses and Overflows at the STP
By 1 February 1977, bypasses through discharge 004 must be
eliminated and overflows must be treated. The permit requires construc-
tion of facilities at the STP site to store and treat (separately) the
flows in excess of secondary capacity. Treatment (of combined sewage)
is defined by the permit to consist of:
"at a minimum, primary clarification
and chlorination."
Chlorination is defined as total available chlorine residual
of 1-2 mg/1 just after initial mixing, followed by at least 20 minutes
of contact through a baffled structure. Overflow facilities are to be
constructed along with the units for secondary treatment and phosphorus
removal (no later than 1 February 1977).
A-55
-------
(c) Other Overflows
Facilities plans must be submitted between June 1976 and
September 1979 to provide for reducing, treating, or eliminating overflows
from the sewer system, three of which are noted as active during dry
weather.
v '
6.3 Basis of Design
According to the Project Report, the plant is designed to serve '
205,000 persons. An STP of this size would adequately serve the city j
!
until the year 2000, unless continguous areas are annexed, in which case '
it would serve until the year 1990. ,
i
The design is based on the following parameters, according to *'
the March 1974 I.C.R. Report.
(a) Flow
Projected average daily flow is given as 40 tngd, maximum
day 57 mgd, and peak 77 mgd.
(b) BOD
The estimated influent BOD load is given as 77,000 Ib/day.
This is equivalent to 230.68 mg/1.
To attain secondary treatment requires removal of 67,000
Ib/day (87%). The discharge would contain 30 mg/1 (10,000
Ib/day).
We assume that the plant is designed to meet secondary
treatment, as the NPDES permit requires.
(c) Suspended Solids
The estimated influent SS load is given as 58,000 Ib/day.
This is equivalent to 173.76 mg/1.
This wastewater is low in SS; 147.7 mg/1 (49,300 Ib/day)
must be removed. The discharge would contain 26.06 mg/1
(8,700 Ib/day), which is 15% of the influent SS.
A-56
-------
We assume that the plant is designed for this degree of SS
removal, even though the discharge would contain less SS
than one derived from an influent of normal strength.
(d) Phosphorus
The influent phosphorus load is estimated at 2,400 Ib/day.
This is equivalent to 7.19 mg/1.
To attain an effluent concentration of 2.1 mg/1 requires
that 71% (1,700 Ib/day) must be removed. The discharge
would contain 700 Ib/day, or 29% of the influent.
To attain an effluent with only 377 Ib/day requires removal
of 2,023 Ib/day (84%). This discharge would have a concen-
tration of 1.13 mg/1. We assume the plant is designed to
meet this more stringent condition of the permit.
We estimate that secondary treatment would have removed
30% (720 Ib/day).
(e) Coliform
We assume that the plant is designed to meet the fecal
coliform limit of the permit.
(f) PH
We assume the discharge will be within the pH range of the
permit.
(g) Overflows and Bypasses
0
Bovay Engineers, Inc. (design engineers for the Spokane
STP), advised us on 9 May 1977 that facilities have been
designed for wet-weather flow capacity as follows.
The headworks capacity is 146 mgd. 77 mgd will be given
secondary treatment and 89 mgd will go to a separate
stormwater-treatment system. The separate system will
provide primary clarification, chlorination, and chlorine
contact. For purposes of estimating the O&M costs, we
have assumed this facility will receive flows 25 times
a year.
The 1973 Report shows that the existing primary plant will be
i
expanded to 40 mgd (average daily flow) and that secondary treatment and
phosphorus removal will be added. No new primary clarifiers are included
for treatment of dry-weather flow.
A-57
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We were advised on 9 May 1977 by Bovay Engineers that the project
includes four trucks for hauling sludge cake,in lieu of other sludge-
disposal facilities shown in the Project Report.
Proposed new secondary facilities are:
Headworks
Primary-sludge pump station
Aeration tanks
Final clarifiers
Chlorination facilities
Stormwater-treatment facilities
A portion of the solids-processing facilities, site work,
and administration building due to secondary require-
ments
Proposed new AWT facilities are:
Chemical feed for phosphorus removal
A portion of solids-processing, disposal facilities, and
miscellaneous facilities due to AWT
6.4
Future Performance
The expected performance of the STP when it is operating at an
average daily flow of 40 mgd is shown in the following table. The projected
influent loadings are from the I.C.R. Report, dated March 1974. The efflu-
ent emissions are from the NPDES permit.
Type of Measurement BOD
SS
1. Influent concentration
2. Influent load
3. Secondary-effluent concentration
4. Secondary-effluent load
5. Percent removal by secondary
6. AWT-effluent concentration
7. AWT-effluent load
8. Percent Removal by AWT
9. Difference, secondary minus AWT
10. Difference, secondary minus AWT
11. Percent difference, AWT minus
secondary (row 8 minus row 5)
54
Unit
231
77,000
i 30
10,000
87
30
10,000
87'
0
, 0
174
58,000
26
8,700
85
26
8,700
85
0
0
7.19
2,400
5.03
1,680
30
1.13
377
84
3.9
1,303
mg/1
Ib/day
mg/1
Ib/day
%
mg/1
Ib/day
%
mg/1
Ib/day
A-58
-------
This table applies only to wastewater that is given secondary
treatment. It does not include the stormwaters, which are given primary
treatment.
6.5 Benefits of AWT
The benefits of AWT at Spokane are estimated as an additional
removal of 1,303 Ib/day of phosphorus, i.e. 54% of the influent phosphorus.
The effluent is predicted to contain 1.13 mg/1 (377 Ib/day) of phosphorus,
i.e. 16% of the influent. The amount of phosphorus in the future
effluent will be 47% of the amount being discharged by the existing plant.
6.6 Costs
Grant No. C-53 0580 was made on 29 .July 1974 to the City of
Spokane. The grant amount was revised on 6 June 1975 to $31,405,477 for
a grant-eligible project cost of $41,873,969. We assume that this project
cost includes the wet-weather treatment facility and sludge-disposal
trucks.
We have prorated the project cost given in the amended grant
agreement among the components believed to be included. We estimate the
extra capital costs of facilities due to AWT as follows.
Aeration basins and final
clarifiers: 5%
Chemical feeding for phosphorus
removal: 100%
Sludge-management
facilities: 20%
Administration building and
sitework: 12%
A-59
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(a) Capital Cost '
Total project cost: $41,874,000.
We estimate that 89% of the grant-eligible costs of the
STP project $37,268,000 (plus the value of the existing
plant) is for secondary and wet-weather facilities.
We estimate that 11% or $4,606,000 is due to AWT facilities.
(b) O&M Cost
We estimate that the annual O&M cost at future design
capacity and with intermittent wet-weather flow will be
$3,538,000.
We estimate that 66.8% ($2,362,000) will be for operating
the secondary and wet-weather facilities.
We estimate that 33.2% ($1,176,000) will be operating the
AWT facilities.
No breakdown of costs was available for Spokane. We have pro-
rated the cost as follows.
A-60
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Components
Headworks
Modify Existing Primary
Aeration Basins
Final Clarifiers
Phosphorus Removal By
Chemical Feed
Chlorination Facilities
Sludge Thickeners
Digesters (New & Modifications
to Existing Units)
Vacuum Filters
Sludge Disposal
Administration Building
Sitework
Wet-Weather Facility
'Total
%
Capital Cost C$1,000)
Secondary
2,015
155
6,920
2,209
-
465
992
3,595
4,835
1,116
1,364
2,754
10,848 '
37,268
89.0
AWT
-
364
116
930
-
248
899
1,209
- 279
186
375
-
4,606
11.0 .
Annual O&M ($1,000)
Secondary
>523
V428
-
79
27
216
809
180
*
*
100
2,352
66.8
AWT
\23
844
-
7
54
203
45
*
*
-
1,176
33.2
*Included in above
A-61
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7. SUMMARY OF BENEFITS AND COSTS
Our analysis of the case studies is summarized in this section.
The performance, benefits, and costs are based upon evaluation of available
data or assumptions noted earlier.
7.1 Performance
Future performance at each plant, when operating at full capacity,
is summarized in the following table.
Concentrations in the raw sewage influent were abstracted from
the Project Reports or were assumed. Concentrations noted as secondary
emissions and AWT influent loads are what would be required to comply with
EPA13 definition of secondary treatment; they are not necessarily what the
existing or future secondary portions of the STPs will produce. AWT
emissions are the expected quality of the future discharges after AWT.
The differences between secondary and AWT emissions are the benefits of
AWT.
A-62
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FUTURE PERFORMANCE
Concentrations in mg/1
PLANT
De Pere
Springfield
San Jose
Sussex Co.
Spokane
. jj,,
RAW SEWAGE INFLUENT
CONCENTRATIONS
BOD SS NHo-N P
350 250 - 17.0
370 200 30.9
562 485 20.0
200 200 25.0 10.0
231 174 - 7.2
c Ah
SECONDARY EFFLUENT
CONCENTRATIONS
BOD SS NH^-N P
30 30 - 11.9
30 30 21.0
30 30 15.0 -
30 30 17.0 7.0
30 26 - 5.0
i
AWT EFFLUENT
CONCENTRATIONS
BOD SS NH-^-N P
10 10 - 1.0
5 5 2.0 -
9.2 5 1.5
10 15 1.0 0.2
30 26 - 1.1
-------
7.2
Benefits
The benefits of AWT texpressed as the difference between AWT and
secondary treatment for removal of BOD, SS, NH^-N, and P) at each project are
tabulated as follows.
Benefits of AWT
Project
De Pere, WI
Springfield, MO
San Jose, CA
« T**
Sussex, NJ
Spokane, WA
Flow
(mgd)
14.2
30
143
5
40
Improved Removal
BOD
Ib/day
2,365
6,250
22,800
830
0
SS
Ib/day
2,365
6,250
29,900
620
0
NH3-N
Ib/day
?
4,750
16,350
640
0
P
Ib/day
680
0
0
290
1,303
* The San Jose plant will also have improved removals of fecal coliform
organisms and several other constituents.
** The Sussex plant will also have improved removals of coliform organisms
and improved dissolved oxygen in the effluent.
*** The Spokane plant effluent will also have a more nearly neutral pH.
7.3 Costs
(a) Capital Cost
The capital cost for grant-funded facilities and the amount
of the grant that we attribute to AWT facilities are listed
below.
The grant-eligible amounts in the first table are at a price
level corresponding to the time the grant was made and to the
geographical location of the grantee.
The second table gives capital costs trended to correspond
to the National average (20-cities ENR Construction Cost
Index of 2513) for March 1977.
The accompanying graph shows (1) the construction price trends
for each region studied and (2) the 20-cities average since
enactment of Public Law 92-500. The graph simply shows how
the price of the same unit of construction work varied through-
out the country between 1973 and 1977.
A-64
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GRANT PROJECT CAPITAL COSTS
Project
De Pere, WI
Springfield, MO
San Jose, CA
Sussex, NJ
Spokane , WA
ENR
Level of
Grant
2,300
2,340
2,650
2,970
2,250
Grant Eligi-
ble Amount
($1,000)
17,850
41,469
64,286
11,000
41,874
%
AWT
49.9
41.8
98.9
33.4
11.0
Amount
AWT
($1.000)
8,902
17,321
63,567
3,667
4,606
GRANT PROJECT CAPITAL COSTS AT AVERAGE ENR (2513)
Pro j ect.
De Pere, WI
Springfield, MO
San Jose, CA
Sussex, NJ
Spokane, WA
Trend
Factor
1.0926
1.0739
0.9483
0.8461
1.1169
Grant Eligible
Amount at.
Average ENR
($1,000) .
19,503
44,534
60,962
9,307
46,769
Amount Attribu-
table to AWT at
Average ENR
($1.000)
9,732
18,615
60,292
3,109
5,145
A-65
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-.*
CONSTRUCTION COST TRENDS
3500
3000
x
LU
G
g 2500
o
z
o
§
Z
o
u
G
OC
O
2000
1500
m
Z
a
z
£
LU
Z
o
z
LU
1000
500
100
Jose
Sussex Co.
Springfield
Spokane
DePere
20 Cities Avg.
Largo
LOCATION
Da Pare
Springfield
San Jose
Sussex
Spokane
Present 20-Cities Average
ENR CCI
2300
2340
2650
2970
2250
2513
- (Year 1913)
1973
1974 1975 1976
MARCH OF YEAR NOTED
1977
A-66
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(b) Operation and Maintenance Costs
We estimated the annual O&M costs for treating the grant-
funded capacity of wastewater at each plant. Costs were
developed separately for the portion needed to meet
secondary-treatment requirements and the portion due to
AWT. The percentage of the costs of secondary treatment
due to AWT is also shown.
TREATMENT PLANT O&M COSTS
Project
De Pere, WI
Springfield, MO
San Jose, CA
Sussex, NJ
Spokane, WA
Annual O&M ($1,000)
Secondary
677
1,350
6,000
521
2,362
AWT
823
807
4,000
479
1,176
Percent
AWT/ Secondary
122
60
67
92
50
A-67
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KennedyEngineers
13 January 1978
MEMORANDUM
To : Jerome Horowitz, Vertex
From : W. A. Anderson
Subject: EPA - AWT Study
File : KE 6124
1. Filtration at SJ/SC is called AWT on nearly every page of the booklet
published by the City of SJ (Attached). In several other documents
Mr. Belick refers to it as AWT also. Filtration at SJ/SC should:
a. Improve BOD removal; effluent concentration to be either
9.2 or 10 mg/1 depending on source of data available.
Data available during the study showed actual effluent
BOD was 21 mg/1 in 1976, certainly meeting the definition
of secondary treatment, in which case filtration is 100%
AWT. We assumed the secondary treatment facilities would
produce 30 mg/1, however, as stated on Page A-39. In '
October, Larry sent us a page from the 1974 Bechtel report
which we did not know about earlier. That report says the
old plant will produce an effluent with a BOD of only 55
mgd during the non-canning season and 60 during the can-
ning season. Therefore, if there is no source control and
no pretreatment, one could conclude that the filters are
providing BOD removal of (60-30) or 30 mg/1 toward second-
ary treatment and (30-10) or 20 mg/1 toward AWT. The
result is 20/(20 -f30)or 40% of the filtration attributable
to AWT on the basis of BOD during canning season. If
operated during the non-canning season it would be 44.4%
AWT. It should be noted, however, that we qualified our
answer at the top of Page A-39. If we were to continue
the exercise further (to the bottom of Page A-39), we
would find that the benefits of AWT would be greater.
b. Filtration should also improve SS removal. The same
reasoning applies except that using Bechtel data, second-
ary SS would be (80-30) or 50 mg/1 while AWT SS would be
(30-5) or 25 mgd, resulting in 25/50 + 25 or 33-1/3% AWT
on a SS basis.
c. Filtration will also improve removals of floatables,
coliforms, turbidity, color, and oil and grease, all
of which are 100% AWT requirements according to our
definition.
A-68
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KennedyEngineers
Memorandum (Continued)
13 January 1978
d. Furthermore, filtration should reduce the chlorine
demand resulting in less chlorine residual to be
sulfonated and less tpxicity, both 100% AWT accord-
ing to our definition.
e. Conclusion: on the basis of the information in
Bechtel's report which we had not seen in our studies,
the secondary plant will not meet secondary treatment
requirements at all times, and if filtration is chosen
rather than source control, pretreatment, or improved
conventional secondary treatment facilities, filtra-
tion as a part of the secondary process is required
as follows:
BASIS % SECONDARY % AWT
BOD 60 40
SS 66-2/3 33-1/3
OTHERS 0 100
A-69
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APPENDIX B
Area Maps for the Six Case Studies
-------
Hillsboroug
River x
Area Map of LARGO, Florida
B-l
-------
RM "0"
LAKE MOHAWK
Area Map of the WALLKILL RIVER VALLEY, New Jersey
Adapted from: HYDROSCIENCE (November 1973). Water quality analysis for
the Wallkill River, Sussex County, New Jersey. Westwood NJ: Hydroscience.
B-2
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SPRINGFIELD
North Wilson Creek
, -o
Jordan Creek
Wilson Creek
Springfield STP
Rader Spring
Fassnight Creek
South Creek
Rader resurgence-sink
Wilson's Creek Battlefield
National Park
Terrell Creek
James River
James River
Area Map of SPRINGFIELD, Missouri
Adapted from: U.S. FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
(June 1969). .James River - Wilson Creek Study, Springfield, Missouri.
Ada OK: The Administration.
B-3
-------
Area Map of DE FERE, Wisconsin
Source: Robert W. LANZ (August 1975). A "computer analysis of the water
quality in the lower Fox River and lower Green-Bay; Wisconsin. University
of Wisconsin Sea Grant College Technical Report WIS-SG-75-228. Green Bay, Wl:
The University.
B-4
-------
LOS ALTOS
MT view
CARTESIAN SL.
SAN JOSc
SUNNYVALE
GOLDEN
GATE 8R.
N
Area Map of SAN JOSE, California
Source: CONSOER, TOWNSEND & ASSOCIATES, CONSULTING ENGINEERS (1968). A
comprehensive study of Che waste treatment requirements for the Cities of
San Jose and Santa Clara and tributary agencies, phase 1, assimilative
capacity of south San Francisco Bay. San Jose CA and Chicago IL:
Consoer, Townsend.
-------
Area Map of SPOKANE, Washington
Source: COLUMBIA BASIN INTER-AGENCY COMMITTEE, HYDROLOGY SUBCOMMITTEE
(April 1964). River mile index, Spokane River.. No publication details,
Obtained from the library of the U.S. EPA, Seattle WA.
B-6
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APPENDIX C
Abbreviations Used In This Report
-------
APPENDIX C
Abbreviations Used In This Report
The abbreviations are arranged in sequences: first alphabetic,
then numeric. Abbreviations beginning with a letter of the alphabet are
listed in alphabetical order. Those beginning with a number come afterwards,
arranged in ascending numerical order. The symbol "o/oo" is saved for the end.
As Arsenic.
AWT Advanced wastewater treatment. There are at least two defi-
nitions. (1) Bureaucratic: Treatment designed to produce an
effluent containing substantially less than 30 mg/1 of BOD
and 30 .mg/1 of SS, as a monthly average. (2) Engineering: An
STP with special facilities and processes for removing excep-
tional quantities of BOD, SS, ammoniacal nitrogen, total nitro-
gen, phosphorus, etc.
BOD Biochemical oxygen demand. Unless otherwise specified, it is
measured for five days, in the dark, at 20° C.
BOD- 5-day biochemical oxygen demand.
BOD-Q 20-day biochemical oxygen demand.
BODgQ 60-day biochemical oxygen demand.
BODgQ 90-day biochemical oxygen demand.
BAT Best available technology economically achievable. A bureau-
cratic phrase derived from P.L. 92-500, section 301(b)(2) (A)
and elsewhere. BAT does not apply to STPs; it applies princi-
pally to industries.
BPT Best practicable control technology currently available. A
bureaucratic phrase derived from P.L. 92-500, section 304(b)(l)(A)
and elsewhere. BPT does not apply to STPs; it applies principally
to industries.
BPWTT Best practicable waste treatment technology. A bureaucratic
phrase derived from section 201(g)(2)(A) of P.L. 92-500. It
applies to STPs, not to industries.
C-l
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CCI Construction cost index.
CFR Code of Federal Regulations.
cfs Cubic feet per second
COD Chemical oxygen demand.
Cr Chromium.
CTA Consoer, Townsend & Associates, Consulting Engineers.
Cu Copper.
CWC Missouri Clean Water Commission.
DEP New Jersey Department of Environmental Protection.
DER Florida Department of Environmental Regulation.
DNR Missouri or Wisconsin Department of Natural Resources.
DO Dissolved oxygen.
DOC Missouri Department of Conservation.
DOE Washington State Department of Ecology.
DPC Florida Department of Pollution Control.
EAC Environmental Assessment Committee; later, Environmental
Assessment Council, Inc., a consulting firm in New Brunswick,
New Jersey.
EIS Environmental impact statement; required by the National
Environmental Policy Act of 1969 (P.L. 91-190).
EL Effluent-limited; a bureaucratic description of waters that
are not specified by section 303(d)(l)(A) of P.L. 92-500.
ENR Engineering News-Record.
EPC Environmental Protection Commission (Hillsborough County,
Florida).
ESB Esvelt & Saxton / Bovay Engineers, an engineering consortium
in Spokane, Washington.
FAC Florida Administrative Code.
Fe Iron.
C-2
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FWPCA
FY
gpm
Hg
HQ
I.C.R.
I/I
JTU
L.
lb(s)
lb(s)/day
Lyngb.
max.
MBAS
MF
mgd
mg/1
ml
ml/1
ml/l-hr.
MPN
N
U.S. Federal Water Pollution Control Administration, one of
EPA' s predecessor agencies .
Fiscal year.
Gallons per minute.
Mercury.
Headquarters .
Industrial cost recovery, often in the narrow sense of sec-
tion 204(b)(l) of P.L. 92-500.
Infiltration and/or inflow into a sewer system.
Jackson turbidity unit.
Linnaeus (in taxonomy).
Pound (s).
Pounds per day.
Lyngbya (in taxonomy).,
Maximum.
Methylene blue active substances; generally, detergents and
related surfactants.
Membrane (usually Millipore) filter, a technique of bacterial
assay.
Million gallons a day.
Milligrams per liter.
Milliliter.
Milliliters per liter.
Milliliters per liter-hour.
Most probable number, a technique of bacterial assay.
Nitrogen.
Ammonia.
Ammonia, expressed as nitrogen.
C-3
-------
NH^OH
N03
N03-N
NPDES
NTU
O&M
o-P04
P
Pb
P.L.
P04
P04-P
ppm
PPt
Q
Res.
RM
SBDA
SCA
SERL
SFB
SJ/SC
Sol.
Ammonium.
Ammonium hydroxide.
Nitrate.
Nitrate, expressed as nitrogen.
National Pollutant Discharge Elimination System; a permit
system established by section 402 of P.L. 92-500.
Nephelometric turbidity unit.
Operation and maintenance.
Orthophosphate, often the ion.
Phosphorus.
Lead.
Public Law.
Orthophosphate.
Orthophosphate, expressed as phosphorus.
Parts per million.
Parts per thousand.
Flow rate.
Residual.
River mile. Customarily, the mouth of the river is RM zero;
but there are exceptions, such as the Wallkill River, where
RM zero is at the very top of the river.
South Bay Dischargers Authority, a consortium of wastewater
dischargers at the south end of San Francisco Bay, California.
Sussex County (New Jersey) Municipal Utilities Authority.
Sanitary Engineering Research Laboratory, University of
California at Berkeley.
San Francisco Bay Regional Water Pollution Control Board;
later, San Francisco Bay Regional Water Quality Control
Board of the California State Water Resources Control Board.
San Jose/Santa Clara, California, especially the SIP they
jointly own and operate.
Solids.
C-4
-------
spp. Species (in taxonomy).
SS Suspended solids.
STP Sewage-treatment plant.
TAG The Technical Advisory Committee attached to the South Bay
Dischargers Authority (SBDA).
TBRPC Tampa Bay Regional Planning Council.
IDS Total dissolved solids.
TKN Total Kjeldahl nitrogen.
TL Median lethal dose (or dosage).
TL5Q-96 hr. The dose or dosage lethal to half the test organisms within
96 hours.
TLM Median lethal dose (or dosage).
trans. Translated.
UBOD Ultimate biochemical oxygen demand.
ug/1 Micrograms per liter.
UOD Ultimate oxygen demand.
USGPO U.S. Government Printing Office.
USGS U.S. Geological Survey.
var. Variety (in taxonomy).
WAC Washington (State) Administrative Code.
WPB Missouri Water Pollution Board.
WPCC Washington (State) Water Pollution Control Commission.
WQL Water-quality limited; a bureaucratic description of waters
specified in section 303(d)(l)(A) of P.L. 92-500.
WQS Water-quality standards.
WWP Washington Water Power Company.
Zn Zinc.
C-5
-------
5/10 An effluent containing 5 mg/1 of BOD and 10 mg/1 of SS.
7Q10 The 7-day, 10-year low flow of a river; the lowest weekly
riverflow likely to occur in a decade.
20°-BOD_ Biochemical oxygen demand, measured after 5 days of incubation
at 20° C.
20/20 An effluent containing 20 mg/1 of BOD and 20 mg/1 of SS.
23°-BOD Biochemical oxygen demand, measured after 20 days of incubation
U . at 23° C.
30/30 An effluent containing 30 mg/1 of BOD and 30 mg/1 of SS,
usually expressed as a monthly average.
"208" Areawide waste treatment management, referring to section
208 of P.L. 92-500 and its planning requirements.
"303" Section 303 of P.L. 92-500, which covers planning related to
water-quality standards and their implementation.
o/oo Parts per thousand.
C-6
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