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 ------- 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. ------- "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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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. ------- 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? ------- 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 ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- '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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "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 ' ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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) ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "The total project cost (of the new AWT plant] is estimated as $41,600,000. In spite of such enormous expenditures, the plant is considered overloaded even in the planning stage. In the seven day period starting from February 22, 1975 the plant records show a total flow through the plant of 402 million gallons and even if the plant were operated at 42 mgd for the seven day period and storing another 40 million gallons in the equalization basin, approximately 68 million gallons will have to be bypassed. Similarly for an eleven day period starting from November 3, 1974 the flow totalled about 600 million gallons which would have resulted in the bypassing of 98 million gallons or approximately 9 mgd. In addition operating the plant at the maximum capacity for such extended periods of time would further reduce the effi- ciency of treatment. Therefore, the key to the success of protecting James River is to reduce the infiltration/inflow and the evaluation that is underway should be comprehensive enough to estimate the actual treatment needs accurately. (p. 45) "The collection system sufferes[sic] from enormous infiltra- tion/inflow problem [sic] and the wet weather flow as high as 80 mgd which is ten times as much as dry weather flow, have [sic] been recorded. It should be noted that the re- corded data are not actually the Indication of total extraneous flow as the sewer capacity is limited to approximately 80 mgd and any flow in excess, estimated as approximately 10 to 20 mgd surcharges from the manholes during heavy rain. An infiltration/inflow analysis report was submitted in June 1974 based on the data collected in 1973. According to this report the average daily flow during the longest dry period in the summer of 1973 was about 14 mgd of which the domestic and industrial sources contributed 9 mgd and the remaining 5 mgd by extraneous flow. Most of the dry weather extraneous flow is caused by infiltration into sewers located along drainage- ways as the water table is near the ground level in these areas most of the time. The direct inflow during thunder- storms produces only temporary flow increases and it is estimated that about six million gallons enter the system for every inch of rainfall. However, direct inflow during thunderstorms is less significant than infiltration and indirect inflow caused by large and repeated rainfalls. For statistical comparison the flow through the plant during a five day period following a general1 rainstorm of the type that occurred on March 30 & 31, 1973 was as follows: base flow - 45 million gallons, direct inflow - 7 million gallons and infiltration and indirect inflow - 190 million gallons. However, as far as evaluation study is concerned, the city has initiated a year long monitoring program of the collection system and the study is expected to be completed by April 1976. Based upon this evaluation, [a] sewer rehabilitation program will be undertaken by the city. However, the city will have to seek state and federal grants for the rehabilitation program." (p. 44) 194 ------- DNR predicts that fishkills will be worse after the AWT plant begins operating because there will be more fish to kill: "It should be recognized that the new Southwest plant solves only part of the pollution problem. It reduces the pollution from the sewage plant considerably, whereby the aquatic life including fish populations would undoubtedly increase con- siderably in James River below Wilson Creek. However, by unfortunate coincidence, if the urban runoff were to instigate a fish kill, the visible impact of such an incident by way of the number of fish killed, [sic] would be considerably more than in the past." (p. 49) The inadequate hydraulic design of the new AWT plant and the severity of fishkills are interrelated; the problems will intensify with time: "Two problems, however, are associated with heavy rain in the Wilson Creek drainage. In the first place the potential for its devastating impact which resulted in many fish kills in the past is statistically as probable in the future as it was in the past ten years. As a result, [sic] of the improvements to the sewage plant effluent, the James River below Wilson Creek is likely to accommodate a much larger fish population than at present. Therefore a fish kill in the future is likely to be more devastating than in the past. Secondly, the excess infiltration/inflow in the sewer system renders the plant hydraulically overloaded for a long period of time as a result of which the effluent is not likely to meet the designed effluent quality during wet weather flow along with inevitable bypasses [sic] . In fact, it is estimated that even if the new plant was to be in operation in 1975 [sic] the excess flow would have necessitated the bypassing of the entire plant of at least 10 mgd for a six-day period and operating the plant at the maximum load of 42 mgd during those six days. If that was the situation in 1975 it can be expected to be more severe in 1978. Its impact, however, on the receiving stream would be one of retarding the recovery, although quantitatively it is anybody's guess." (p. 11) 195 ------- DNR also expects that phosphorus from Springfield will cause algal blooms in the James River: "Although considerable improvements are anticipated in associa- tion with the reduced BOD and ammonia load from the sewage plant, as far as phosphorus is concerned the existing level of discharge is likely to continue for a [sic] forseeable future as the new plant does not have phosphorus removal. It is estimated that the sewage plant would continue to discharge approximately 250 tons of phosphorus as P per year to Wilson Creek [,] thence to James River and to the James River arm of Table Rock Lake. As discussed earlier there are indications of excess algal productivity at present in James River below Wilson Creek and with the improved effluent quality the tur- bidity is expected to be very low. As a result the James River is expected to be clearer in the future and with high phosphorus it is unlikely that algal productivity would not become a problem." (p. 11) DNR recommends that a "208" study of the Springfield area shoulc "quantitatively evaluate the contribution of phosphorus from various sources and analyze the benefits of phosphorus removal for the southwest plant from stream water quality point of view." (p. 48) The report contains a very serious internal discrepancy. Wilson Creek is identified as a "known losing stream" (p. 255) from its headwaters to the Christian County Line (about five miles below the STP). The Effluent Regulations of May 1974 and 11 April 1975 disfavor discharges into losing streams; in such discharges, the BOD5 must be "equal to or less than 5 mg/1". The NPDES permit (20 December 1974) allows Springfield's discharge to con- tain a daily average of 10 mg/1; a daily average of 10 mg/1 is much higher than an absolute maximum or 5 mg/1. Here is the discrepancy. On page nine, DNR calls Wilson Creek "an unclassified stream": "As far as Wilson Creek is concerned it is an unclassified stream and only the general criteria of the standards [scil. the WQS] ... are applicable." 196 ------- Throughout the report, DNR refers to the karst topography of the Springfield area and to the importance of the underground drainage system (e.g. pp. 10 and 49). Yet DNR does not seem to notice that the AWT dis- charge (a daily average BOD,- discharge of 10 mg/1) violates the effluent standard for discharges into losing streams. In short, DNR has not noticed that the new AWT discharge will violate Missouri's effluent regulations both in wet weather and in dry weather. DNR has recognized that the new AWT plant has inadequate hydrau- lic design, but has not yet recognized that the AWT discharge will always violate the effluent regulations, owing to inadequate BOD removal. 197 ------- "Most people in distress know the cure for what ails them. And the world around them, it too knows the cure. And yet, from all this knowledge, nothing comes forth for their relief." Henry de Montherlant (1933/34), Les Cglibataires [trans, by J.H.] 198 ------- 6.3 BIBLIOGRAPHY ANON. (20 September 1966). Untitled, 3-page memorandum on a meeting of State, Federal, and local officials to discuss the causes of fishkills in the James River and to plan research on them. Obtained from the file marked "James River fish kill", Spring- field Division of Sanitary Services. ANON. (26 March 1975). A brief history of Springfield's wastewater treat- ment facilities. Distributed at the groundbreaking ceremonies for additions to the Southwest STP. 4 pp. Obtained from Springfield's Division of Sanitary Services. Bruce R. BARRETT & Ralph E. AUSTIN (19 July 1971). James River fish kill investigation, Springfield MO. This 5-page report was prepared for Carl Walter, EPA Region VII, Kansas City. Barrett & Austin are with EPA's Robert S. Kerr Water Research Center in Ada OK. Obtained from the file marked "James River fish kill, July 1971", Springfield Division of Sanitary Services. 199 ------- James A. BURRIS (6 June 1974). Report on investigation of the southwest sewage treatment plant, Springfield MO. Jefferson City: Missouri Clean Water Commission. 4 pp. The report describes gross deficiencies in the plant effluent, hydraulic overloading in wet weather, and pollution in Wilson Creek. Obtained from the "1.200 File" on Springfield, Missouri Div. of Environmental Quality, Jefferson City. CONSOER, TOWNSEND & ASSOCIATES (November 1967). Report to the City of Springfield MO on condition and operation of the sanitary sewerage system. Chicago: Consoer, Townsend. 18 pp. Idem (September 1969). Comprehensive report on the expansion of sanitary wastewater facilities for the greater Springfield area. Chicago: Consoer, Townsend. 96 pp. Idem (1972). Basic design data report: additions to southwest wastewater treatment plant, City of Springfield MO. Chicago: Consoer, Townsend. 36 pp. Idem (January 1973). Supplemental report to comprehensive report on the expansion of sanitary wastewatar facilities for the greater Springfield area, Springfield HO. St Louis MO: Consoer, Townsend 20 pp. Idem (February 1973). Supplemental report to comprehensive report on the expansion of sanitary wastewater facilities for the greater Springfield area, Springfield MO. Sc. Louis MO: Consoer, Townsend. 25 pp. 200 ------- Idem (1973, revised January 1974). Basic design data report: additions to southwest wastewater treatment plant, City of Springfield MO. Chicago and St. Louis: Consoer, Townsend. 43 pp. plus 1 app. Idem (1974). Final plans: wastewater treatment plant additions, southwest plant, City of Springfield MO. Chicago and St. Louis: Consoer, Townsend. Over 100 figures. Idem (June 1974). Infiltration/inflow analysis, southwest wastewater collection and treatment system, City of Springfield MO. Chicago and St. Louis: Consoer, Townsend. 33 pp. plus 6 apps. CONSOER, TOWNSEND & ASSOCIATES & HYDROSCIENCE, INC. (January 1975). Waste load allocation study: James River - Wilson Creek [and] Little Sac River - South Dry Sac Creek. Prepared for the Missouri Department of Natural Resources, Clean Water Commission. St. Louis MO and Westwood NJ: Consoer, Townsend & Assoc. & Hydroscience. 86 pp. plus 48 tables & figures plus 4 apps. Charles H. CRISWELL (11 September 1973). Letter to Wayne E. Sanders, Missouri Clean Water Commission, listing 15 discharges in the Springfield area that were not on Sanders' list of NPDES applicants. Criswell is Associate Sanitary Engineer, Spring- field Division of Sanitary Services. Obtained from the "1.000 File" on Springfield, Missouri Div. of Environmental Quality, Jefferson City. 201 ------- Idem (4 March 1976). Memorandum to Robert R. Schaefer, Springfield's Superintendent of Sanitary Services. He describes efforts to trace the cause of a fishkill in the James River in late Feb- ruary or early March 1976. Criswell is Associate Sanitary Engineer, Springfield Division of Sanitary Services. Obtained from the file marked "James River fish kills various", Springfield Division of Sanitary Services. Charles S. DECKER (21 May 1973). Letter to Don G. Busch, City Manager, Springfield. The letter describes the poor condition of the polishing lagoon at the Southwest STP and makes four recommen- dations for improving it. Decker is Acting Regional Engineer, Springfield Regional Office, Missouri Clean Water Commission. 1 p. Obtained from the "1.000 File" on Springfield, Missouri Div. of Environmental Quality, Jefferson City. Richard M. DUCHROW (19 March 1976). Memorandum to James R. Whitley on a fishkill in the James River in early March. The cause is un- certain. Both Duchrow and Whitley are staff members of the Missouri Dept. of Conservation. Obtained from the file on "FY 76 Municipal Spills", Missouri Div. of Environmental Quality, Jefferson City. Everett FUCHS & John GODDARD (21 July 1971). Memorandum to James R. Whitley on "Fish kill investigation - James River". Fuchs & Goddard are with the Missouri Dept. of Conservation. 8 pp. Obtained from the file marked "James River fish kill July 1971", Springfield Division of Sanitary Services. 202 ------- 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 ------- W.W. JOHNSON & L.E. MEADOR (28 November 1967). Request of City of Springfield MO, for pollution alleviation of Wilson's [sic] Creek by flow augmentation through Wilson's [sic] Creek Battle- field National Park. This request is addressed in the form of a letter, bound as a report (bearing the cover date December 1967), to Col. Frank P. Bane, Chairman, White River Basin Coordinating Committee. Johnson & Meador are co-chairmen of the Mayor's Water Resources Committee. 13 pp. Obtained from Robert R. Schaefer, Springfield's Superintendent of Sanitary Services. William Q. KEHR (10 January 1975). Letter to Consoer, Townsend & Associates containing a review of the draft waste load allocation study for James River-Wilson Creek and Little Sac and South Dry Sac Rivers. Kehr is Engineering Consultant to the Water Quality Program of the Missouri Clean Water Commission. 2 pp. Obtained from the "1.000 File" on Springfield, Missouri Div. of Environmental Quality, Jefferson City. Peggy J. KEILHOLZ (21 January 1972). Report of investigation, Springfield MO. 4 pp. Keilholz is Water Pollution Control Technician, Missouri Water Pollution Board. Obtained from the file marked "SW plant additions", Springfield Division of Sanitary Services. Ed L1GHTFOOT (17 October 1975). Memorandum to Chas. Stiefermann, suggesting that the Southwest STP should extend its outfall pipe below the "losing point (100* approximately)." James H. Williams' report on the extent of the losing reach in Wilson Creek (14 February 1972) 204 ------- is attached to Lightfoot's memorandum. Obtained from the "1.000 File" on Springfield, Missouri Div. of Environmental Quality, Jefferson City. MISSOURI (28 August 1970?). Missouri water pollution law and regulations. Jefferson City: Missouri Water Pollution Board. 32 pp. Idem (12 April 1972). Missouri clean water law. Senate bill no. 321, 77th General Assembly, approved by the governor on 12 April 1972. MISSOURI CLEAN WATER COMMISSION (May 1973), Continuing planning process, State of Missouri. Jefferson City MO: The Commission. 33 pp. Idem (June 1973). Missouri water quality standards. Jefferson City: The Commission. 81 pp. Idem (May 1974). Effluent regulations. Approved by the Commission on 24 April [sic] 1974. Jefferson City: The Commission. 9 pp., including 2 appendices. Idem (16 June 1974). Definition regulation. Jefferson City: The Com- mission. 5 pp. An identical version, found in the complete minutes of the Missouri Clean Water Commission, is dated May 1974. The Commission approved this regulation on 24 April 1974. Idem (16 June 1974). Regulation for the submission of applications for discharge permits and letters of approval, Jefferson City: The Commission. 11 pp. 205 ------- 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 ------- MISSOURI DEPARTMENT OF CONSERVATION (20 July 1966). Untitled, one- paragraph report on the fishkill in the James River, 16 July 1966. Obtained from the file marked "James River fish kill, July '66", Springfield Division of Sanitary Services. MISSOURI DEPARTMENT OF NATURAL RESOURCES, DIVISION OF ENVIRONMENTAL QUALITY (20 December 1974). NPDES permit for the Southwest STP, Springfield. Expires on 19 December 1979. 3 pp. Obtained from the NPDES files of EPA Region VII, Kansas City. -MISSOURI DEPARTMENT OF NATURAL RESOURCES, DIVISION OF ENVIRONMENTAL QUALITY, WATER QUALITY PROGRAM (June 1976). Water quality management basin plan for White River Basin in accordance with section 303(e) of P.L. 92-500. Jefferson City MO: The Depart- ment. 259 pp. plus 2 apps. MISSOURI GEOLOGICAL SURVEY AND WATER RESOURCES et al. (1965). Water quality of James, Spring and Elk River Basins. Appendix D: water quality data. Jefferson City: Missouri Water Pollution Board. 7 pp. Obtained from the library of the Missouri Divi- sion of Environmental Quality, Jefferson City. Idem (January 1974). Water quality of James, Elk and Spring River Basins, 1964-65. Jefferson City: Missouri Clean Water Commission. 107 pp. Obtained from the library of the Missouri Div. of Environmental Quality, Jefferson City. 207 ------- Idem (January 1974). Water quality of James, Elk, and Spring River Basins. Appendix C: biological data. Jefferson City: Missouri Clean Water Commission. All the data are from 1964-65. 85 pp. Obtained from the library of the Missouri Div. of Environmental Quality, Jefferson City. MISSOURI WATER POLLUTION BOARD (September 1966). A water quality study of Wilson Creek and James River below Springfield, Greene County MO. Jefferson City: The Board. 10 pp. Obtained from the file marked "James River fish kill", Springfield Division of Sanitary Services. Idem (June 1968). Water quality standards: White, North Fork, Spring, Eleven Point, Current, and Black Rivers and tributaries. Jefferson City: The Board. 9 chapters + 3 appendices. Idem (November 1971). Missouri effluent guidelines. Jefferson City: The Board. Obtained from the Missouri Division of Environmen- tal Quality, Jefferson City. 10 pp. Idem (February 1972). Transcript of proceedings of a public hearing 1 before the Missouri Water Pollution Board at Howard Johnson's Motor Lodge, Springfield MO, 23 February 1972. Transcribed by Charles R. Neff, Branson MO. Original typewritten copy obtained from the archives of the Missouri Department of Natural Resources. 117 pp. 208 ------- 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 ------- Ronald R. RITTER (5 July 1972). Memorandum to Director, Division of Grants Management, [EPA-HQ], "Request for eligibility deter- mination - City of Springfield, Missouri." Ritter (Chief of Grants Administration, EPA Region VII) asks EPA-HQ to decide whether stormwater control in Wilson Creek is eligible for a Federal grant. 1 p. plus 6 enclosures, including Springfield's conceptual plan for stormwatercontrol facilities and the Clean Water Commission's endorsement of the plan. Obtained from Donald Eugene Sandifer, EPA Region VII, Kansas City MO. W.E. SANDERS (7 September 1973). Letter to Mr. Greg Cole (city of Spring- field), giving the NPDES applications "for your area." W.E. Sanders is with the Missouri Clean Water Commission. 15 appli- « > cants are listed, 12 of them in the James River basin. .Obtained from the "1.000 File" on Springfield, .Missouri Div. of Environmental Quality, Jefferson City. Robert R. SCHAEFER (15 May 1974). Letter to Jack K. Smith, Executive Secretary, Missouri Clean Water Commission. The letter trans- mits a memorandum outlining a discussion between the City of Springfield and Springfield City Utilities concerning the use of effluent from the Southwest STP for cooling water at the Southwest Powerplant. Schaefer is Springfield's Superintendent of Sanitary Services. Obtained from the "1.000 File" on Springfield, Missouri Div. of Environmental Quality, Jefferson City. 210 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Idem (January 1974). Report on analysis of infiltration and inflow on the wastewater collection system for the City of De Pere, Wisconsin, wastewater treatment project. Green Bay, WI: Lee, and Wilmette, IL: Weston. 31 pp. + appendixes and maps. Idem (March 1974). Addendum to the infiltration/inflow analysis for the . City of De Pere, Wisconsin wastewater treatment plant project. Green Bay, WI: Lee, and Wilmette, IL: Weston. 24 pp. + map. Idem (June 1975). Phase I, II and III grant application, City of De Pere, Wisconsin, EPA project //C-550706. Green Bay, WI: Lee, and Wilmette, IL: Weston. Approx. 50 pp. Dale J. PATTERSON (March 1973). Results of a mathematical water quality model of the lower Fox River, Wisconsin. Wisconsin Department « of Natural Resources, Bureau of Standards and Surveys, Water Quality Evaluation Section. Madison, WI: The Department. 45 pp.. Dale J. PATTERSON et al. (June 1975). Water pollution investigation: lower Green Bay and lower Fox River. Prepared by the Wisconsin Department of Natural Resources, Division of Environmental Standards, for the U.S. Environmental Protection Agency, Gceat Lakes Initiative Contract Program, Chicago. Report //EPA-905/9- 74-017. Chicago: The Agency. 371 pp. Paul E. SAGER & James H. WIERSMA (1972). Nutrient discharges to Gr^en Bay, Lake Michigan from the lower Fox River. In: Proceedings, 15th Conference on Great Lakes Research, 1972: 132-148. 244 ------- Idem (March 1975). Phosphorus sources for lower Green Bay, Lake Michigan. In: Journal of the Water Pollution Control Federation 47(3):504-514. F.H. SCHRAUFNAGEL et al. (4 January 1968, revised 18 January 1968). Report on an investigation of the pollution in the lower Fox River and Green Bay made during 1966 and 1967. The Wisconsin Department of Natural Resources, Division of Resource Develop- ment. Madison, WI: The Department. 78 pp. R.J. SCHNEIDER (18 October 1973). Letter to Robert M. Krill (Chief, Municipal Wastewater Section, Wisconsin Department of Natural Resources). Schneider (Director, Air and Water Programs Divis- ion, U.S. Environmental Protection Agency, Chicago) writes that "the City of De Pere should be designing for secondary treatment, if funded with FY '74 funds, or BPWTT, if funded with FY '75 funds." Obtained from DNR, Madison, WI. Ralph H. SCOTT et al. (21 March 1957). Drainage Area 11 A stream pollution, lower Fox River. Wisconsin Committee on Water Pollution. Madison, WI: The Committee. Obtained from the Wisconsin Department of Natural Resources, Madison. 47 pp. Richard W. SMITH (14 November 1973). Memo to the file. Smith summarizes a meeting (on 8 November 1973) requested by Jakubovsky to settle De Pere's degree-of-treatment requirements. EPA tentatively endorsed Jakubovskyfs proposal for an AWT plant with nitrifica- tion facilities. 245 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "Cria cuervos y te sacaron los ojos." Tomas de Iriarte (1781), Fabulas literarias. 254 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Idem (February 1958). Staff report on a survey of water conditions .in San Francisco Bay south of Dumbarton Highway Bridge, on September 18 & 19, 1957. No publication details. 14 pp. + 2 plates + 7 tables. . . : Idem (June 1958). Report on pollution and nuisance conditions in San Francisco Bay south of Dumbarton Highway Bridge, September 1957. No publication details. 13 pp. + 3 plates. Idem (19 November 1959). Resolution no. 316. The Board revises its effluent and receiving-water requirements for the San Jose/ Santa Clara STP. Obtained from the Board, Oakland CA. Idem (December 1959). Staff report to Regional Water Pollution Control Board, San Francisco Bay Region, relative to sewage and indus- trial waste disposal problems of the City of San Jose. No publication details. 32 pp. + appendices A-H. Idem (17 December 1959). Resolution no. 318. The Board orders San Jose to cease and desist from violating its requirements and to comply with the requirements of Resolution no. 316. Obtained from the Board, Oakland CA. Idem (16 March 1961). Resolution no. 354. The Board revises the schedule for pollution abatement contained in Resolution no. 318. Obtained from the Board, Oakland CA. Idem (18 July 1963). Resolution no. 484. The Board grants San Jose a time extension. Obtained from the Board, Oakland CA. 301 ------- Idem (December 1964). Staff report on a survey of water conditions in San Francisco Bay south of Dumbarton Highway Bridge on July 17, August 14, September 11 and October 23, 1964. 11 pp. + appen- dices A-C. Idem (15 April 1965). Resolution no. 661. The Board orders new improve- ments to the SJ/SC SIP and more controls on the industrial hookups. Obtained from the Board, Oakland CA. SAN FRANCISCO BAY REGIONAL WATER QUALITY CONTROL BOARD (November 1966). Staff report on a survey of water conditions in San Francisco Bay south of Dumbarton Highway Bridge, May 31, 1966 through October 7, 1966. No publication details. 13 pp. + appendices A-C. Idem (1967). Water quality control policy for tidal waters inland from the Golden Gate within the San Francisco Bay Region. Oakland: The Board. The main report is in 6 chapters; appendices A-G are separately bound in 3 volumes; 2 attachments are bound in a separate volume. (5 volumes, all included). Idem (1967). Staff report on waste loading and water quality conditions in south San Francisco Bay, south of Dumbarton Bridge. 12 pp. V. Idem (July 1967). Self-monitoring program and schedule for sampling, analyses and observations for the City of San Jose and other . agencies tributary to the San Jose sewerage system, Santa Clara County. Obtained from file #2189.8014, folder #19 of the Board, Oakland CA. 10 pp. 302 ------- Idem (21 March 1968). Resolution no. 68-11. The Board sets stricter requirements for SJ/SC. Obtained from the Board, Oakland CA. Idem (16 July 1968). Waste loading and water quality condition in south San Francisco Bay, south of Dumbarton Bridge: 1967. Oakland CA: The Board. 12 pp. +3 figures + appendix. Idem (3 April 1969). City of San Jose's water pollution activities. Obtained from the desk file of R.R. Scholar of the Board, Oak- land CA. 2 pp. Idem (24 June 1969). Resolution no. 69-26. The Board orders SJ/SC to cease and desist from violating Resolution no. 68-11. Obtained from the Board, Oakland CA. Idem (23 July 1970). Resolution no. 70-57. The Board orders SJ/SC to cease and desist from violating Resolution no. 68-11 according to a schedule. Obtained from the Board, Oakland CA. Idem (24 November 1970). Resolution no. 70-91. The Board sets new and stricter requirements for SJ/SC. Obtained from the Board, Oakland CA. Idem (June 1971). Interim water quality control plan for the San Fran- cisco Bay Basin. Oakland CA: The Board. 72 pp. Idem (24 June 1971). Order no. 71-36. The Board gives SJ/SC a time extension. Obtained from the Board, Oakland CA. 303 ------- Idem (23 November 1971). Order no. 71-78. The Board orders SJ/SC to cease and desist from violating Resolution no. 70-91. Obtained from the Board, Oakland CA. Idem (22 August 1972). Order no. 72-62. The Board orders San Jose and other cities on the south bay to proceed with their plans for regionalization. Obtained from the Board, Oakland CA. Idem (20 November 1972). 1973-1974 municipal project list. Obtained from the desk file of Edward R. Becker, SJ/SC STP, San Jose CA. 9 PP. Idem (1 August 1974). Documentation of modification of recommendation, City of San Jose. Submitted by M.H. Kazemi. Obtained from the Board, file #2189.8014, folder #18, Oakland CA. Idem (19 November 1974). Draft NPDES permit for SJ/SC. Obtained from the Board, file #2189.8014, folder #19, Oakland CA. 9 pp. Idem (6 December 1974). Order no. 74-168, NPDES no. CA0037842. A final discharge permit for SJ/SC. Obtained from the Board, Oakland CA. 15 pp. Idem (April 1975). Water quality control plan report, San Francisco Bay basin. In 2 parts, separately bound. Part 1 includes chapters 1-7 + a special appendix; part 2 includes chapters 8-17. Idem (13 May 1975). Routine compliance monitoring report, City of San Jose. Dave Block (Field Engineer) inspects and reports on SJ/SC. Obtained from the Board, file #2189.8014, folder #19, Oakland CA. 304 ------- Idem (15 March 1977). Executive officer summary report. Dierker submits Valentine Miller's report (7 February 1977) to the Board. Ob- tained from R.R. Scholar, the Board, Oakland CA. CITY OF SAN JOSE (1960). San Jose: design for tomorrow. San Jose CA: The City. 58 pp. Idem (1966). The general plan: 1966-2010. San Jose CA: The City. One oversized sheet folded into a booklet. Idem (effective November 1971). Industrial Waste Ordinance for that area tributary to San Jose - Santa Clara water pollution control plant. San Jose CA: The City. 16 pp. Idem (1974). Industrial waste ordinance for that area tributary to San Jose - Santa Clara water pollution control plant. San Jose CA: The City. 16 pp. SAN JOSE DEPARTMENT OF PUBLIC WORKS (5 February 1975). Sewer system i evaluation and preventive maintenance program, program descrip- tion. Obtained from the San Francisco Bay Regional Water Quality Control Board, file #2189.8014, folder #19, Oakland CA. 3 pp. CITIES OF SAN JOSE & SANTA CLARA (undated, 1965 or later). San Jose/Santa Clara water pollution control plant. San Jose and Santa Clara CA: The cities. 24 pp. 305 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "Pensiamo perche non sappiamo." [Italian proverb: "We think because we don't know." Trans, by J.H.] 316 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "'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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- "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 ------- 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 ------- the concentration of phosphorus in a sample inoculated with Selenastrum must correspond to the maximum yield of Selenastrum in that sample. The first two correspondences are unproven and far-fetched. How could the standing crop of algae correspond to the concentration of dissolved phosphorus two weeks later? Both are constantly changing, owing to variations in the flow and quality of the Spokane River, varia- tions in the mixing patterns of Long Lake, climatic changes, the succession of species, the phosphorus input from Spokane, and the release of phos- phorus from the lake's sediments. The last two correspondences were disproved by their own data. More to the point, how could stratification (or the lack of it) cause a two-week time shift in a relationship between the standing crop of algae in Long Lake and the yield of Selenastrum capricornutum Printz in.a laboratory? January 1976 The U.S. Army Corps of Engineers publishes Water Resources Study, Metropolitan Spokane Region. This 13-volume work, prepared by Kennedy-Tudor Engineers, is by far the largest study ever published on pollution-control planning in Spokane. For all its weight, it is not fundamentally different from its thinner predecessors. It too is filled with guesswork, oversimplifications, assumptions, and preconceived con- * elusions. It too fails to derive pollution-control measures in Spokane from adequate data (adequately understood) on Long Lake. As usual, the problem is the "lack of knowledge concerning the relationship between effluent limitations and water quality." [P.L. 92-500, sec. 303(d)(1)(C)] 372 ------- As usual, too, Kennedy-Tudor relied on a mathematical model instead of careful measurement and painstaking analysis. The model sought to explain the deoxygenation of Long Lake. As we have shown, there are at least three ways to account for the anoxia: oxygen-demanding sediments long-term BOD, dispersed or dissolved, trapped in the lake at the end of the Spring flush algal rain, which decomposes as it falls from the surface through the hypolimnion. No one has measured sediment-oxygen demand, no one has measured long-term BOD from hypolimnetic samples collected in late Spring, no one has measured the settling rate or the deoxygenation rate of the algal rain in fact, no one is quite sure whether to measure the algae as biomass, cell volume, or chlorophyll concentration, and the measures often fail to agree. How can anyone purport to explain the anoxia without having adequately measured any of the relevant factors? No doubt the explanation will not be simple: Many factors may interact in complex ways. The reports of Soltero et al. have already shown that Long Lake is not a simple pool of water. By all accounts, it is an exceptionally complex reservoir, with unusual hydrodynamics and mixing patterns. In the absence of measurements and real understanding, there is no alternative to guessing. What the model will "predict" depends on these guesses. In short, guesswork in, guesswork out. If the modelers should believe that sediment oxygen demand is the principal determinant of anoxia, and if they set the reaction rates in the model accordingly, 373 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- SHANNON & WILSON, INC., GEOTECHNICAL ENGINEERS (October 1973). Preliminary draft: geology, soils and groundwater in the urbanizing area of the Spokane River basin. Submitted to Kennedy-Tudor Consulting Engineers, Seattle. Part of the Metropolitan Spokane region water resources study sponsored by the U.S. Army Corps of Engineers, Seattle District. 85 pp. s Tamotsu SHIROYAMA et al. (June 1975). Effect of nitrogen and phosphorus on the growth of Selenastrum capricornutum. Pp. 132-142 in U.S. EPA, Office of Research and Development, National Environmental Research Center, Corvallis, Oregon, "Proceedings: Biostimulation - nutrient assessment workshop," 16-17 October 1973, Corvallis OR. Report no. EPA 660/3-75-034, program element 1BA031. Springfield VA: U.S. National Technical Information Service. / Idem (26-27 March 1976). Growth response of Anabaena flos-aquae (Lyngb.) De JBreblssprv & waters collected from Long Lake Reservoir, Washington. .In,; Proceedings of the symposium on terrestrial and aquatic ecological studies of the Northwest. Cheney WA: . Eastern Washington State College Press. W.O. SIMONS et al. (1953). Spokane - Coeur d'Alene River basin, Washington- Idaho. Chapter 10 (pp. 164-185) in .U.S. House of Representatives Interior & Insular Affairs Committee. "The physical & economic foundation of natural resources: IV, subsurface facilities of water management and patterns of supply - type are# studies." Washington DC: USGPO. W.O. Simons et al. were with USGS. 406 ------- Raymond A. SOLTERO et al. (1 July 1973). An investigation of the cause and effect of eutrophication in Long Lake, Washington. Eastern Washington State College, Department of Biology; prepared for the U.S. Department of the Interior, Office of Water Resources Research. 86 pp. Cheney WA: The Department of Biology. Idem (1 July 1974). Further investigation as to the cause and effect of eutrophication in Long Lake, Washington. Eastern Washington State College, Department of Biology; prepared for the Wash- ington Department of Ecology. 85 pp. incl. figures and tables.j Cheney WA: The Department. Idem (1 June 1975). Response of the Spokane River periphyton community to primary sewage effluent arid continued investigation of Long Lake. Performed under contract to Washington State Dept. of Ecology, project no. 74-144. plympia WA: Washington State Dept. of Ecology. 117 pp. Idem (1 June 1976). Continued investigation of eutrophication in Long Lake: verification data for the Long Lake model. Performed under contract to the Washington State Dept. of Ecology, con- tract no. WF-6-75-081. Olympia WA: Washington.Dept. of Ecology. 64 pp. Idem (5 January 1977). Affidavit, Superior Court, State of Washington, County of Spokane; Leonard J. and Lovetta Miotke, et ux, et al.fsic] vs. City of Spokane, et al. No. 228268. Obtained from the files of EPA-Seattle. 407 ------- SPOKANE CITY COUNCIL (13 July 1970). Resolution. The Council resolves that it intends to construct "advanced sewage treatment" (undefined) as rapidly as possible. Obtained from the city's "Wastewater study" file at City Hall, Spokane WA. SPOKANE DEPARTMENT OF PUBLIC WORKS (March 1970). Sewer study invitation prospectus for the City of Spokane, Washington. Spokane WA: The City. 9 pp. SPOKANE DEPARTMENT OF PUBLIC WORKS AND UTILITIES et al. (1 September 1965). Public service facilities, part 5: Sewerage facilities plan, report no. 15, city plan series 1. Spokane WA: The City. 44 pp, SPOKANE PUBLIC WORKS DEPARTMENT (1976). Draft: Facilities planning report for project area 1, Erie Street drainage basin. Spokane WA: The Department. 2 vols. marked Text and Exhibits. Idem (1976). Draft: Facilities planning report for project area 2, Assembly-Shadle basin and North Central basin. Spokane WA: The Department. 2 vols. marked Text and Exhibits. Carl Ted STUDE (1971). An analysis of water quality in the Spokane River. A thesis submitted in partial fulfillment of the requirements for the degree of Master of Science in Civil Engineering, Univer- sity of Washington. Obtained from Rhys Sterling, Washington State Department of Ecology, Spokane. 92 pp. 408 ------- SYSTEMS CONTROL, INC. (18 May 1973). Data report for the Spokane River basin model project. Prepared for the U.S. Environmental Protection Agency, Washington DC. 20 pp. plus approx. 150 pp. of tables, figures, etc. Palo Alto CA: Systems Control. Idem (August 1973). Preliminary draft: Spokane River basin model project, volume VI: User's manual for stratified reservoir model. Prepared for the U.S. Environmental Protection Agency. Palo Alto CA: Systems Control. 13 sections. Dick TODHUNTER & Dick CUNNINGHAM (August 1972). Water quality report, Spokane and Little Spokane Rivers: July 1971 - September 1971. Olympia WA: Washington State Dept. of Ecology. 28 pp. Idem (November 1972). Water quality report, Spokane and Little Spokane Rivers: April 1971 - June 1971. Olympia WA: Washington State Dept. of Ecology. 37 pp. U.S. ARMY CORPS OF ENGINEERS, SEATTLE DISTRICT (12 January 1976). Public brochure, metropolitan Spokane region, water resources study. Seattle: The Corps. 29 pp. Idem (May 1976). Metropolitan Spokane water resources study. Except for the summary, the report was prepared by Kennedy-Tudor Consulting Engineers. Seattle WA: The Corps. 13 vols. 409 ------- U.S. BUREAU OF RECLAMATION (1973). Land application of wastewater. Author and date are-handwritten. Stamped preliminary. Unpub- lished: obtained from the files of Kenton L. Lauzen, EPA Region X liaison engineer on assignment to Washington State Department of Ecology, Olympia WA. U.S. BUREAU OF RECLAMATION, REGION 1 (June 1954). Rathdrum Prairie pro- ject, prairie division, Idaho: Report of the regional director and substantiating materials. Boise: U.S. Bureau of Reclamation. 122 pp. + appendix + several unnumbered foldout maps. Idem (April 1961). Reappraisal, Spokane Valley project, Washington. Boise: U.S. Bureau of Reclamation. 70 pp. U.S. ENVIRONMENTAL PROTECTION AGENCY, NATIONAL ENVIRONMENTAL RESEARCH CENTER, CORVALLIS (undated). Spokane River algal survey. Stamped "preliminary" and marked "for discussion only". 39 pp., containing tables & chemical analyses not published elsewhere. Available from Kenton L. Lauzen (U.S. EPA Region X liaison engineer on assignment to the Washington State Dept. of Ecology, Olympia WA). . U.S. ENVIRONMENTAL PROTECTION AGENCY, NATIONAL ENVIRONMENTAL RESEARCH CENTER, OFFICE OF RESEARCH AND DEVELOPMENT (June 1975). Proceed- ings: Biostimulation - nutrient assessment workshop, 16-17 October 1973, Corvallis, Oregon. Sponsored by the Eutrophication and Lake Restoration Branch, Pacific Northwest Environmental Research Laboratory, National Environmental Research Center, Corvallis OR. 319 pp. Washington DC: U.S. Gov. Printing Office. 410 ------- U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X (24 August 1972). Appendix A. (EPA justifies its position on phosphorus removal for Spokane.) Appended to a letter from Robert S. Burd to F.S. Fulwiler dated 5 September 1972. Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to the Washington State Department of Ecology, Olympia WA. 6 pp. Idem (April 1973). Priority basin accomplishment plan, Spokane. Seattle: U.S. EPA. Unpaginated, no table of contents. 2 pp. of text, 2 full-page maps, and numerous tables. Idem (1974?). Ground-water monitoring, FY 1974, Spokane Valley, Washington. Seattle WA: U.S. Environmental Protection Agency. 54 pp. (un- paginated) of computer printout + 1 page of text + 1 figure. Idem (29 July 1974). Grant agreement, grant no. C-53 0580 01 0. EPA offers $2,124,375 to Spokane. Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to the Department of Ecology, Olympia WA. Idem (29 July 1974). Grant amendment, grant no. C-53 0580 02 0. EPA offers Spokane $973,125; Spokane accepts 8 August 1974. Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to the Department of Ecology, Olympia WA. 411 ------- Idem (23 October 1974). Grant amendment, grant no. C-530580021, amend- ment no. 1. EPA adds a special condition to its grant offer: that Spokane commit itself to completing the "entire treatment works project." Spokane agrees 31 October 1974. Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to the Depart- ment of Ecology, Olympia WA. Idem (10 February 1975). Grant amendment, grant no. C-530580-02-2, amendment no. 2. EPA increases Spokane's grant to $1,209,375; Spokane accepts 20 February 1975. Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to the Department of Ecology, Olympia WA. Idem (24 March 1975). Grant amendment, grant no. C-530580-02-3, amendment no. 3. EPA increases Spokane's grant to $34,965,375; Spokane accepts 2 April 1975. Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to the Department of Ecology, Olympia WA. Idem (7 May 1975). Grant amendment, grant no. C-530580-02-4, amendment no. 4. EPA decreases 'Spokane's grant to $31,405,477; Spokane accepts 6 June 1975. Obtained from Kenton L. Lauzen, EPA Region X liaison engineer to the Department of Ecology, Olympia WA. [U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X ?] (4 May 1971). Draft: Resume of pollution problems in the Spokane River basin. 12 pp. Obtained from EPA Region X, Seattle WA.- 412 ------- Idem (1974?). Present waste loads. A report on waste discharges and Spokane River quality. Obtained from Rhys Sterling, Washington Department of Ecology, Spokane. 16 pp. U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X, AIR AND WATER PROGRAMS DIVISION, WATER PROGRAMS BRANCH, MUNICIPAL SECTION, OPERATION AND MAINTENANCE UNIT (1 October 1973). Operation and maintenance survey, Spokane River basin. 20 pp. plus tables. Seattle WA: The Agency. U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION X, SURVEILLANCE AND ANALYSIS DIVISION (June 1973). Spokane area. Approx. 100 pp. incl. 3 apps. Seattle WA: The Agency. Idem (1975). Spokane River basin profile; river basin water quality status. 225 pp. incl. numerous figures. Unpublished: obtained from the Agency, Seattle WA. This report also exists in an apparently identical version under the title "River basin water quality status report, Spokane River basin." Idem (undated). Spokane River basin, "305 A" report. Unpublished; reviewed in manuscript at U.S. EPA, Seattle WA. U.S. GEOLOGICAL SURVEY, WATER RESOURCES DIVISION (1960-1975). Water resources data for Washington. An annual series in two parts: Part 1, surface water records; part 2, water quality records. Prepared in cooperation with the State of Washington and with other agencies. Tacoma WA: USGS. 413 ------- 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 ------- 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 ------- 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 ------- APPENDIX A Benefit-Cost Evaluation of AWT Plants: Five Case Studies .by Kennedy Engineers, Inc. 657 Howard Street San Francisco, California 94105 (415) 362-6065 ------- CONTENTS 1. INTRODUCTION A-l 1.1 Procedure A-l 1.2 Benefits A-2 1.3 Costs A-3 Capital Costs A-3 Costs of Operation and Maintenance (O&M) A-5 1.4 Case Studies A~6 2. DE PERE, WISCONSIN A-7 2.1 Existing Plant Performance A-8 2.2 Requirements A-9 2.3 Basis of Design A-ll 2.4 AWT Facilities A-12 2.5 Future Performance A-13 2.6 Benefits of AWT A-14 2.7 Costs A-14 2.8 Discharge Location A-17 3. SPRINGFIELD, MISSOURI A-18 3.1 Existing Plant Performance A-18 3.2 Requirements A-20 3.3 Basis of Design A-20 3.4 AWT Facilities A-21 3.5 Future Performance A-22 3.6 Benefits of AWT A-23 3.7 Costs A-23 3.8 Springfield Stormwater Problem A-26 ------- 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 ------- APPENDIX A Benefit-Cost Evaluation of AWT Hants 1. INTRODUCTION We have analyzed five advanced waste treatment (AWT) plants. In each case we compared the costs and benefits with those of secondary treatment. This report has been prepared for The Vertex Corporation as a supplement to their report under EPA Contract No. 68-01-4338. Advanced waste treatment (AWT) is defined as treatment beyond "secondary treatment." Since 7 June 1973, 40 CFR 133 has always defined "secondary treatment" as (1) 85% removal of BOD and suspended solids, or (2) reduction of these constituents to 30 mg/1 each, whichever is more restrictive. Until 26 July 1976, 40 CFR also restricted fecal coliform bacteria to 200 colonies per 100 ml; but that restriction was lifted 26 July 1976. In the cases we evaluated, we used the definition of secondary treatment that was in force when the grant offer was made. 1.1 Procedure For each project we reviewed data on influent loadings, per- formance, mass emissions, requirements, facilities plans, grant documents, and costs gathered and furnished to us by Vertex. We have evaluated the information to determine: A-l ------- (a) Influent loadings before and after AWT (b) Effluent emissions from secondary treatment (c) Effluent emissions from AWT (d) Costs, both capital expenditures and annual expenses for operating and maintaining AWT facilities The performance of existing plants was determined from self- monitoring reports. We found that several of the proposed facilities either did not meet or greatly exceeded the requirements of subsequent NPDES permits. Because of conflicting data, we sometimes had to assume a basis for design that complied with permit requirements. * Calculated values of wastewater flows, concentrations, and mass amounts of pollutants have been rounded and may not be accurate beyond three significant digits. Estimated costs were usually rounded to the nearest thousand dollars. 1.2 Benefits The difference between items (b) and (c) above represents the incremental benefits of AWT, which include: (a) BOD numerically less than either 30 mg/1 or 15% of the influent BOD, whichever is less (b) Suspended solids (SS) numerically less than either 30 mg/1 or 15% of the influent SS, whichever is less (c) pH values within more narrow limits than 6.0 and 9.0 (d) Fecal coliform bacteria less than 200 per 100 ml, when the grant was offered before 26 July 1976; any fecal coliform limit after 26 July 1976 means AWT, in our legalistic definition A-2 ------- (e) Residual chlorine, oil and grease, nitrogen, phosphorus or other nutrients, or toxicity from chlorine or un-ionized ammonia in smaller amounts than normally would be expected in secondary effluents (f) Dissolved oxygen in larger amounts than would normally be expected in secondary effluents In addition, AWT may improve the receiving waters more than secondary treatment would. We do not include this kind of improvement in our analysis of costs and benefits because all new STPs are legally required to produce effluents that will be consistent with WQS; this requirement applies to AWT and secondary plants alike. Unless otherwise noted, "BOD" means "20°-BOD5." It should be noted that in secondary effluents, the ratio of BOD to UOD may be much lower than in AWT effluents. The incremental benefits and costs of AWT are not the difference between future and present conditions. Some plants are not now attaining secondary treatment, but others are exceeding it. 1.3 Costs Capital Costs We reviewed the data on costs of grant-eligible facilities for each case study. Eligible costs were separately identified for the secondary and the AWT portions. Price levels were adjusted for the region where the facilities are located and for the date the grant was made. For each case, we give the corresponding price level from the Engineering News-Record (ENR) Construction Cost Index. The ENR Index is a weighted index of constant quantities of a hypothetical block of construction, valued at $100 in 1913 prices, and repriced weekly for twenty areas in the U.S. A-3 , ------- Secondary treatment includes pre-treatment, primary treatment, conventional secondary treatment, disinfection (in most cases), and a pro-rata share of sludge management, service buildings and sitework. AWT includes the additional components for higher treatment and a pro-rata share of the commonly needed components. The capital costs we report indicate the amount spent for secondary treatment and for AWT facilities, 75% of which comes from Clean Water Grant funds. The capital costs do not include any salvage value of existing plant components that will be reused. The project documents we reviewed do not assign a salvage value to existing facilities, whether or not they were funded by previous grants. Capital costs are the total project costs given in the grant agreements and amendments. We have attempted to adjust the grant costs to include only the amount that represented treatment facilities; we excluded portions of the grant for interceptors, pumping, and other kinds of wastewater facilities. It has not been possible to identify accurately what the grants are for because grant documents do not always define the facilities by category. Where grants were known to include other facili- ties, we pro-rated the grant amounts according to preliminary estimates in project reports. We also used this method to arrive at capital costs for individual components of treatment plants. Project reviews would be greatly simplified if both the project reports and the grant documents sub-totaled the costs according to facilities categories, such as those used in the National Needs Surveys: I Secondary Treatment II More Stringent Treatment III Sewer Rehabilitation IV Collectors and Interceptors V Correction of Combined Sewer Overflows VI Control of Stormwater A-4 ------- We believe that the reported capital costs include all the Step 3 costs for eligible construction, as well as engineering, administrative, and legal work during construction. In older projects (initiated before the three-step grant process), the construction-grant amount may include costs for facilities planning (Step 1) and design (Step 2) because the grant documents do not segregate these costs or show whether they are in- cluded. Costs of Operation and Maintenance (O&M) We have estimated annual costs to operate and maintain the secondary and the additional AWT facilities. Operation and maintenance (O&M) costs were not always available for the first year of operation of the expanded facilities; and none of the documents we reviewed projected O&M costs for the expanded plant at full design capacity. We have there- fore made both kinds of O&M projections. Our source of unit costs was the curves we developed for the "Metropolitan Spokane Region Water Resources Study," Department of the Army, Corps of Engineers, Seattle District, by Kennedy-Tudor Consulting Engineers, January 1976. O&M costs in that study represented a Pacific Northwest Region, mid-1974 price level at ENR Index 2000; we adjusted these costs to the time of the grant and to the location of the grantee by applying a ratio of the local ENR Index to the Index used in the Spokane Study. O&M costs include (1) estimates for labor, materials, chemicals, power, and supplies for the typical day-to-day operation and maintenance, and (2) the averaged cost of long-term maintenance; they do not include replacement costs. The estimated cost for ultimate disposal of sludge A-5 ------- solids or Incinerator ash is included, assuming a 20-mile truck haul to a landfill site. The method we used is valid for comparative purposes, but may not reflect the true cost of O&M because the cost of energy is increas- ing more sharply than the ENR Index. We have estimated O&M costs for the existing treatment facilities that will continue to be used, even though the value of existing facilities is not included in the reported capital costs. We contacted the grantees to determine local policy on pretreat- ment of industrial wastewater. In every case, the industries are not required to pretreat their wastewaters for "compatible substances" (e.g. BOD, SS, P, NH-j). If industries had to pretreat to remove "compatible substances," the results of this evaluation would be drastically different. 1.4 Case Studies We have evaluated the benefits and costs for the selected t projects. They are reported in the following sequence: De Pere, Wisconsin Springfield, Missouri (southwest plant) San Jose, California Sussex County Municipal Utilities Authority (SCA), New Jersey Spokane, Washington Largo, Florida. The plant is not AWT and was not evaluated. A summary of all projects is in Section 7. A-6 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- (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 ------- (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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- (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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- FUTURE PERFORMANCE Concentrations in mg/1 PLANT De Pere Springfield San Jose Sussex Co. Spokane . jj,, RAW SEWAGE INFLUENT CONCENTRATIONS BOD SS NHo-N P 350 250 - 17.0 370 200 30.9 562 485 20.0 200 200 25.0 10.0 231 174 - 7.2 c Ah SECONDARY EFFLUENT CONCENTRATIONS BOD SS NH^-N P 30 30 - 11.9 30 30 21.0 30 30 15.0 - 30 30 17.0 7.0 30 26 - 5.0 i AWT EFFLUENT CONCENTRATIONS BOD SS NH-^-N P 10 10 - 1.0 5 5 2.0 - 9.2 5 1.5 10 15 1.0 0.2 30 26 - 1.1 ------- 7.2 Benefits The benefits of AWT texpressed as the difference between AWT and secondary treatment for removal of BOD, SS, NH^-N, and P) at each project are tabulated as follows. Benefits of AWT Project De Pere, WI Springfield, MO San Jose, CA « T** Sussex, NJ Spokane, WA Flow (mgd) 14.2 30 143 5 40 Improved Removal BOD Ib/day 2,365 6,250 22,800 830 0 SS Ib/day 2,365 6,250 29,900 620 0 NH3-N Ib/day ? 4,750 16,350 640 0 P Ib/day 680 0 0 290 1,303 * The San Jose plant will also have improved removals of fecal coliform organisms and several other constituents. ** The Sussex plant will also have improved removals of coliform organisms and improved dissolved oxygen in the effluent. *** The Spokane plant effluent will also have a more nearly neutral pH. 7.3 Costs (a) Capital Cost The capital cost for grant-funded facilities and the amount of the grant that we attribute to AWT facilities are listed below. The grant-eligible amounts in the first table are at a price level corresponding to the time the grant was made and to the geographical location of the grantee. The second table gives capital costs trended to correspond to the National average (20-cities ENR Construction Cost Index of 2513) for March 1977. The accompanying graph shows (1) the construction price trends for each region studied and (2) the 20-cities average since enactment of Public Law 92-500. The graph simply shows how the price of the same unit of construction work varied through- out the country between 1973 and 1977. A-64 ------- 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 ------- -.* 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 ------- (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 ------- 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 ------- 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 ------- APPENDIX B Area Maps for the Six Case Studies ------- Hillsboroug River x Area Map of LARGO, Florida B-l ------- RM "0" LAKE MOHAWK Area Map of the WALLKILL RIVER VALLEY, New Jersey Adapted from: HYDROSCIENCE (November 1973). Water quality analysis for the Wallkill River, Sussex County, New Jersey. Westwood NJ: Hydroscience. B-2 ------- SPRINGFIELD North Wilson Creek , -o Jordan Creek Wilson Creek Springfield STP Rader Spring Fassnight Creek South Creek Rader resurgence-sink Wilson's Creek Battlefield National Park Terrell Creek James River James River Area Map of SPRINGFIELD, Missouri Adapted from: U.S. FEDERAL WATER POLLUTION CONTROL ADMINISTRATION (June 1969). .James River - Wilson Creek Study, Springfield, Missouri. Ada OK: The Administration. B-3 ------- Area Map of DE FERE, Wisconsin Source: Robert W. LANZ (August 1975). A "computer analysis of the water quality in the lower Fox River and lower Green-Bay; Wisconsin. University of Wisconsin Sea Grant College Technical Report WIS-SG-75-228. Green Bay, Wl: The University. B-4 ------- LOS ALTOS MT view CARTESIAN SL. SAN JOSc SUNNYVALE GOLDEN GATE 8R. N Area Map of SAN JOSE, California Source: CONSOER, TOWNSEND & ASSOCIATES, CONSULTING ENGINEERS (1968). A comprehensive study of Che waste treatment requirements for the Cities of San Jose and Santa Clara and tributary agencies, phase 1, assimilative capacity of south San Francisco Bay. San Jose CA and Chicago IL: Consoer, Townsend. ------- Area Map of SPOKANE, Washington Source: COLUMBIA BASIN INTER-AGENCY COMMITTEE, HYDROLOGY SUBCOMMITTEE (April 1964). River mile index, Spokane River.. No publication details, Obtained from the library of the U.S. EPA, Seattle WA. B-6 ------- APPENDIX C Abbreviations Used In This Report ------- APPENDIX C Abbreviations Used In This Report The abbreviations are arranged in sequences: first alphabetic, then numeric. Abbreviations beginning with a letter of the alphabet are listed in alphabetical order. Those beginning with a number come afterwards, arranged in ascending numerical order. The symbol "o/oo" is saved for the end. As Arsenic. AWT Advanced wastewater treatment. There are at least two defi- nitions. (1) Bureaucratic: Treatment designed to produce an effluent containing substantially less than 30 mg/1 of BOD and 30 .mg/1 of SS, as a monthly average. (2) Engineering: An STP with special facilities and processes for removing excep- tional quantities of BOD, SS, ammoniacal nitrogen, total nitro- gen, phosphorus, etc. BOD Biochemical oxygen demand. Unless otherwise specified, it is measured for five days, in the dark, at 20° C. BOD- 5-day biochemical oxygen demand. BOD-Q 20-day biochemical oxygen demand. BODgQ 60-day biochemical oxygen demand. BODgQ 90-day biochemical oxygen demand. BAT Best available technology economically achievable. A bureau- cratic phrase derived from P.L. 92-500, section 301(b)(2) (A) and elsewhere. BAT does not apply to STPs; it applies princi- pally to industries. BPT Best practicable control technology currently available. A bureaucratic phrase derived from P.L. 92-500, section 304(b)(l)(A) and elsewhere. BPT does not apply to STPs; it applies principally to industries. BPWTT Best practicable waste treatment technology. A bureaucratic phrase derived from section 201(g)(2)(A) of P.L. 92-500. It applies to STPs, not to industries. C-l ------- 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 ------- FWPCA FY gpm Hg HQ I.C.R. I/I JTU L. lb(s) lb(s)/day Lyngb. max. MBAS MF mgd mg/1 ml ml/1 ml/l-hr. MPN N U.S. Federal Water Pollution Control Administration, one of EPA' s predecessor agencies . Fiscal year. Gallons per minute. Mercury. Headquarters . Industrial cost recovery, often in the narrow sense of sec- tion 204(b)(l) of P.L. 92-500. Infiltration and/or inflow into a sewer system. Jackson turbidity unit. Linnaeus (in taxonomy). Pound (s). Pounds per day. Lyngbya (in taxonomy)., Maximum. Methylene blue active substances; generally, detergents and related surfactants. Membrane (usually Millipore) filter, a technique of bacterial assay. Million gallons a day. Milligrams per liter. Milliliter. Milliliters per liter. Milliliters per liter-hour. Most probable number, a technique of bacterial assay. Nitrogen. Ammonia. Ammonia, expressed as nitrogen. C-3 ------- NH^OH N03 N03-N NPDES NTU O&M o-P04 P Pb P.L. P04 P04-P ppm PPt Q Res. RM SBDA SCA SERL SFB SJ/SC Sol. Ammonium. Ammonium hydroxide. Nitrate. Nitrate, expressed as nitrogen. National Pollutant Discharge Elimination System; a permit system established by section 402 of P.L. 92-500. Nephelometric turbidity unit. Operation and maintenance. Orthophosphate, often the ion. Phosphorus. Lead. Public Law. Orthophosphate. Orthophosphate, expressed as phosphorus. Parts per million. Parts per thousand. Flow rate. Residual. River mile. Customarily, the mouth of the river is RM zero; but there are exceptions, such as the Wallkill River, where RM zero is at the very top of the river. South Bay Dischargers Authority, a consortium of wastewater dischargers at the south end of San Francisco Bay, California. Sussex County (New Jersey) Municipal Utilities Authority. Sanitary Engineering Research Laboratory, University of California at Berkeley. San Francisco Bay Regional Water Pollution Control Board; later, San Francisco Bay Regional Water Quality Control Board of the California State Water Resources Control Board. San Jose/Santa Clara, California, especially the SIP they jointly own and operate. Solids. C-4 ------- spp. Species (in taxonomy). SS Suspended solids. STP Sewage-treatment plant. TAG The Technical Advisory Committee attached to the South Bay Dischargers Authority (SBDA). TBRPC Tampa Bay Regional Planning Council. IDS Total dissolved solids. TKN Total Kjeldahl nitrogen. TL Median lethal dose (or dosage). TL5Q-96 hr. The dose or dosage lethal to half the test organisms within 96 hours. TLM Median lethal dose (or dosage). trans. Translated. UBOD Ultimate biochemical oxygen demand. ug/1 Micrograms per liter. UOD Ultimate oxygen demand. USGPO U.S. Government Printing Office. USGS U.S. Geological Survey. var. Variety (in taxonomy). WAC Washington (State) Administrative Code. WPB Missouri Water Pollution Board. WPCC Washington (State) Water Pollution Control Commission. WQL Water-quality limited; a bureaucratic description of waters specified in section 303(d)(l)(A) of P.L. 92-500. WQS Water-quality standards. WWP Washington Water Power Company. Zn Zinc. C-5 ------- 5/10 An effluent containing 5 mg/1 of BOD and 10 mg/1 of SS. 7Q10 The 7-day, 10-year low flow of a river; the lowest weekly riverflow likely to occur in a decade. 20°-BOD_ Biochemical oxygen demand, measured after 5 days of incubation at 20° C. 20/20 An effluent containing 20 mg/1 of BOD and 20 mg/1 of SS. 23°-BOD Biochemical oxygen demand, measured after 20 days of incubation U . at 23° C. 30/30 An effluent containing 30 mg/1 of BOD and 30 mg/1 of SS, usually expressed as a monthly average. "208" Areawide waste treatment management, referring to section 208 of P.L. 92-500 and its planning requirements. "303" Section 303 of P.L. 92-500, which covers planning related to water-quality standards and their implementation. o/oo Parts per thousand. C-6 ------- |