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
                          ii

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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.
                                    iv

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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
                                    ix

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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
                                    xi

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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
                                    xii

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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






                                    10

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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.
                                    18

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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.
                                      20

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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.
                                   21

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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)
                          22

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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
                                    27

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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
                                    31

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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.
                                    33

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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.
                                    38

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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.


                                    39

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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.
                                   40

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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?
                          41

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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.
                                    42

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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".
                                    43

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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   .

-------
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.
                                    47

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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.


                                    48

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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.







                                    51

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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.





                                    52

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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.
                                    53

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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.

                                    55

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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"
                                   56

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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."
                                    57

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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.
                                    58

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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.
                                    59

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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.
                                    60

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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.
                                    61

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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.

                                    62

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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.

                                   63

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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.


                                    64

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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.






                                    65

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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.






                                    66

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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.
                                    67

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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.
                                    68

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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.


                                     69

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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.

                                   70

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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
                                    71

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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.
                                    72

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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'.






                                    73

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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.                                         '
                                    74

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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.
                                    75

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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.

                                    76

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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.


                                    77

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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.
                                    78

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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
                                    79

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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
                                    80

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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.
                                   81

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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.
                                  82

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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






                                    83

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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.

                                     84

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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.
                                    85

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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
                                    86

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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.
                                    87

-------
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

-------
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

-------
          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

-------
          [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.





                                    108

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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




          system, Pinellas County, Florida.  Gainesville, Fla.:  Black




          Crow, & Eidsness.






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.






                                    119

-------
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

          Conservation, Division of Geology.



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.

          Tampa, Fla.:  Tampa Electric Company.



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

          Bay Regional Planning Council.  Gainesville, Fla.:  ES&E.



FLORIDA ADMINISTRATIVE CODE (December 1974).  Rules of the Department of

          Pollution Control.  Chap. 17-3, Pollution of Waters.  Supp.

          No. 25.  18 pp.  Source:  U. S. EPA Headquarters, Washington,

          D. C.  A supplemental title page bears the following information:

          Water use classifications and water quality criteria for the

          State of Florida.  Florida Pollution Control Board (&) U. S.

          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.
                                   120

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FLORIDA CHAMBER OF COMMERCE (1976).  1976 directory of Florida industries.




          Tallahassee:  The Chamber.






FLORIDA DEPARTMENT OF COMMERCE, DIVISION OF ECONOMIC DEVELOPMENT (1973).




          Florida ports and waterways directory.  Tallahassee, Fla.:




          The Division.






FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION (1 March 1976).  Report




          on implementation of the Florida Environmental Reorganization




          Act of 1975.  66 pp.  Tallahassee:  The Department.  The intro-




          duction (p. 1) states that "this is the final report on imple-




          mentation of the ... Act ... as required by Section 20 of the




          Act."






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




          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:  The Department.




          513 pp.  The last page is a letter from Loring Lovell, Chief,




          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

-------
Idem (24 September 1976).  A proposed rule on land application of




          domestic wastewaters, second draft.  Tallahassee:  DER,




          Division of Environmental Programs, Bureau of Drinking




          Water & Special Programs, Treatment Process and Technology  .




          Section.  Courtesy of Dr. G. J. Thabaraj, Administrator,




          Division of Environmental Programs.






FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION, BUREAU OF WATER QUALITY




          (16 August 1976).  Monitoring program, fiscal year 1977.




          56 pp., photocopy.  Tallahassee:  The Department.






FLORIDA DEPARTMENT OF POLLUTION CONTROL (submitted 21 June 1974).  State




          watervpollution control work plan, fiscal year 1975.  Submit-




          ted to EPA in accordance with PL 92-500, Section 106.  Talla-




          hassee, Fla.:  The Department.






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.




          Laws of Florida. Chap.  75-22.  Filed as "Committee Substitute




          for Committee Substitute to Senate Bill No. 123"; approved by




          the Governor 22 May 1975, effective date 1 July 1975.  "An act
                                   122

-------
          relating to environmental reorganization ... creating the




          Department of Environmental Regulation ..."






FLORIDA LEGISLATURE (1976).  Senate Bill 984, "a bill to be entitled



          An act relating to sewage disposal facilities; amending s.




          403.086, Florida Statutes; providing that certain wastes or




          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

-------
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.
                                   135

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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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
          "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	
                                   173

-------
"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

-------
          "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,
                                    175

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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.
                                   176

-------
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 ."
                                    178

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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]."

                                    179

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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
                                    180

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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.
                                    181

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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
                                    182

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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
                                    183

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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
                                    184

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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".
                          185

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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.
                                    188

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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

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          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

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          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

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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

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"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

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                            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

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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

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          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

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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 stormwater—control 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

-------
          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

-------
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

-------
          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

-------
          "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

-------
          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

-------
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

-------
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

-------
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

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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.
                                   250

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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.
                                   253

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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:
                                    261

-------
          "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).
                                   265

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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







                                    270

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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).
                                    272

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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.           '
                                   273

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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.
                                    274

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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.
                                    275

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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.
                                   276

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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

-------
          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....
                                    280

-------
          "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

-------
$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

-------
                           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 +




          appendices A-E.






                                   287

-------
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

-------
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

-------
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

-------
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

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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

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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

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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

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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.
                                    310

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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).




                                    311

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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.

                                    314

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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.
                                    315

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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.
                                    317

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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."
                                     318

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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).


                                    319

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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.
                                    323

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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.
                                     325

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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."
                                     327

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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
                                    328

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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."





                                     329

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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
                                   330

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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."


                                    341

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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
                                    342

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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
                                    344

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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
                                     346

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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."
                                    347

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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.
                                    348

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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.
                                   349

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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."
                                    350

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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.
                                    351

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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.
                                    354

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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)
                                    355

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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.
                                   357

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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
                                   358

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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
                                    359

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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
                                    360

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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).
                                    361

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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
                                     362

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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
                                    363

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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
                                    364

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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.
                                    365

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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

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          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

-------
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

-------
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

-------
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

-------
          •  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

-------
          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

-------
                            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

-------
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

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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

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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

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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

-------
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

-------
          "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

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                               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

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          (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  ,

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          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

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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

-------
     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

-------
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

-------
     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

-------
               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

-------
 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

-------
          (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

-------
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

-------
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

-------
 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

-------
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

-------
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

-------
          (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

-------
          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

-------
           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

-------
          (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

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  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

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                                     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

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                     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

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        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.

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                    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

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                               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

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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

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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

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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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