United States
Environmental Protection
Agency
Washington, D.C. 20460
April 1977
Clean Water
and the
Beet Sugar
Processing
Industry

-------
   T'his booklet is about the beet sugar  processing industry and  water
     pollution.  It  is  intended  to  help -you understand  how this
industry—and all other industries in the United States—are affected by a
law passed by Congress to reduce and eliminate water pollution.
  There  are  52 beet  sugar processing plants  in the  United States,
employing approximately 13,000 men and women. In addition to beet
sugar, some of these plants produce pulp and molasses for animal feeds,
and Steffen filtrate for use in monosodium glutamate production.
  But they also produce about 30 million pounds of  wastes each day.
Those  wastes  include  6 million  pounds of  oxygen-consuming
decomposing organic matter, and 24 million pounds a day of suspended
solids.
  While 5 of these plants discharge waste waters directly to municipal
treatment plants, where the pollutants are treated along with wastes from
nomes and other industries, and 11 are already achieving zero discharge
of wastes to navigable waters, 36 others discharge  directly into water
bodies.
  This booklet describes in non-technical language what those 36 beet
sugar processing plants must do to keep their wastes from polluting the
Nation's waters.

This booklet explains that:

• The  technology  exists  to reduce  water pollution from beet  sugar
processing plants to safe levels.

• Applying that technology costs money—but most beet sugar processing
plants can afford to make the necessary investments to control pollution.

• Such pollution control investments would have only slight impact on the
financial condition of the plants, and on the price consumers pay for beet
sugar, and pulp and molasses by-products.

  This booklet also describes why a few beet sugar processing plants may
not be able to comply with pollution control standards and, unfortunately,
will have to shut down withifthe subsequent loss of jobs.
  In brief, this booklet discusses the facts of life of water pollution—how it
affects all of us, why it must be controlled, and what the law requires the
beet sugar processing industry to do as its part of the national program to
clean up our Nation's waterways.

-------
SWIMMING
   mriK POLLVJW
NO tiff &m on a

-------
The Problem

You and millions ot other
Americans have probably seen the
warning signs. They say "no
swimming" or "no fishing" or "no
boating" or "beach closed"  or
"danger, do not drink the water."
  The signs are there because the
water is polluted: with raw or poorly
treated human wastes, with  runoff
from city streets, farmlands, animal
feedlots, and mines; with leaks and
spills from ships. And with wastes
from industries — including the beet
sugar processing industry.
  Each year, some 402 million tons
of pollutants resulting from human
activities enter the Nation's  waters.
That's almost two tons for every
man, woman, and child in the
United States. The pollutants
include bacteria, viruses, organic
materials,  animal fats, oil, acids,
metals, pesticides, a myriad  of other
chemicals, and hot water from
power plants and industrial  boilers.
  The pollutants make our waters
unsightly. They can  make the water
unfit for drinking, for irrigation, and
for  industrial use, without expensive
purification. Some pollutants rob
water of the oxygen required to
sustain fish and other aquatic life.
Some pollutants contaminate fish
and shellfish, making them
unpalatable or actually unsafe to
eat. Some pollutants speed  the
growth of algae that clog
waterways, disintegrate, and give
off  noxious odors. Some pollutants
endanger  health. Some pollutants
endanger  reproduction; they can
cause deformities and even death
in various  life forms.
  It is impossible to put a precise
pricetag on the cost of water
pollution. But there is no doubt that

-------
water pollution exacts a heavy toll.
It's estimated that dirty water costs
the American people at least $13
billion a year—in water purification
bills, in damage to fishery
resources, in lost recreation.
  Water pollution, in short, is a
major national problem.
  How did this come to pass? How
did so many of our waterways
become open sewers?
   For many years we thought our
waterways could handle the waste
products of human activities.  The
wastes would decompose and
disappear harmlessly, we thought.
But we learned otherwise. We
learned that we had overburdened
the capacity of water to cleanse
itself. We learned that our streams,
rivers, and  lakes  could no longer
assimilate the sewage discharges
from increasing numbers of people
and the increasing waste
discharged from  industry,
agriculture, and mining. We learned
that some pollutants can never be
assimilated; they persist and
accumulate in nature, posing a
continuing danger to public and
ecological health.
  And after more than two decades
of generally ineffective attempts to
control water pollution, we realized
that a completely new approach
was needed.
To Solve the Problem

In response to widespread public
concern about the sad condition of
the Nation's waterways, Congress
enacted the Federal Water Pollution
Control Act Amendments of 1972.
The 1972 Act built upon the
experiences of earlier water
pollution control laws. It brought
dramatic changes.
  What the 1972 law says, in
essence, is that nobody—no city or
town, no industry, no government
agency, no individual—has a right
to pollute our water. What was
acceptable in the past—the free
use of our waterways as a dumping
ground for our wastes—is no longer
permitted.  From now on, under the
1972 law, we must safeguard our
waterways even if it means
fundamental changes in the way we
manufacture products, produce
farm crops, and carry on the
economic life of our communities.
  Congress declared that the
objective of the 1972 law is "to
restore and maintain the chemical,
physical, and biological integrity of
the Nation's waters."
  Congress established two goals
in the 1972 law: First, wherever
possible by July 1983, achieve
water quality that's clean enough
for swimming and other
recreational use, and clean enough
to protect fish, shellfish, and wildlife.
Second, by 1985, no more
discharges of pollutants into our
waters.
  How do we get from the dirty
water of today to the clean water
envisioned for the future? The law
set in motion a new national  system
of uniform controls on the
discharge of pollutants.
  How this system applies to the
beet sugar processing industry is
discussed later. First, consider how
the national system works, as
mandated by Congress and  carried
out by the U.S. Environmental
Protection Agency (EPA) in
cooperation with State and local
governments:

• The law requires EPA to establish

-------
national "effluent limitations" for
industrial plants—including beet
sugar processing plants. An
"affluent limitation" is simply the
maximum amount of a pollutant that
anyone may discharge into a water
body.

• By July 1,1977, the law requires
existing industries to reduce their
pollutant discharges to the level
attainable by using the "best
practicable" water pollution  control
technology (BPT). BPT is
determined by averaging the
pollution control effectiveness
achieved by the best plants  in the
industry.

• By July 1,1983, the law requires
existing industries to reduce their
pollutant discharges still more—to
the level attainable by using the
"best available" pollution control
technology (BAT). BAT is based on
the best practicable control
procedures economically
achievable. If it is technologically
and economically feasible to do so,
industries must completely
eliminate pollutant discharges by
July 1,1983.

• The law requires new industrial
plants to limit pollutant discharges
to the level attainable by meeting
national "standards of
performance" established by EPA
for new plants. A new plant must
meet these standards immediately,
without waiting for 1977 or 1983.
These new plant standards  may
require greater reduction of
pollutant discharges than the 1977
and 1983 standards for existing
plants. Where applicable, zero
discharge of pollutants can  be
required.
• The law requires industrial
facilities that send their wastes to
municipal treatment plants—as
some beet sugar processing plants
do—to make sure the wastes can
be adequately treated by the
municipal plant and will not damage
it. In some industries, discharges to
municipal plants may thus have  to
be "pretreated." That is, the portion
of the industrial waste that would
not be adequately treated or would
damage the municipal plant must
be removed from the waste before it
enters the municipal system.


• The law does not tell any industry
what technology it  must use. The
law only requires industries to limit
pollutant discharges to  levels
prescribed by law.

• The law also says that if meeting
the 1977 and 1983 requirements is
not good enough to achieve water
quality standards, even tougher
controls may be imposed on
dischargers.


• And while the law requires
industries to meet the national
discharge standards set for 1977,
1983, and for new plants, the law
also allows a State or community to
impose stricter requirements if it
wishes. The national standards are
thus minimum requirements that all
industries must meet.


  Setting limits on  industrial
discharges is only the first step in
controlling water pollution, of
course. The next step is to make
sure those limits are met. And the
law provides the mechanism to do
that.

-------
6
          Permits

          The key to applying the effluent
          limits to industries—including the
          beet sugar processing industry—is
          the national permit system created
          by the 1972 law. (The technical
          name is the "National Pollutant
          Discharge Elimination System," or
          NPDES).
            Under the 1972 law, it is illegal for
          any industry to discharge any
          pollutant into the Nation's waters
          without a permit from EPA or from a
          State that has an EPA-approved
          permit program. Every industrial
          plant that discharges pollutants to a
          waterway must, therefore, apply for
          a permit. Essentially all have done
          so.
            When issued, the permit
          regulates what may be discharged,
          and the amount of each identified
          pollutant. It sets specific limits on
          the effluent from each  plant. It
          commits the discharger to comply
          with all applicable national effluent
          limits and with any State or local
          requirements that may be imposed.
          If the industrial plant cannot comply
          immediately, the permit contains a
          compliance schedule—firm target
          dates by which pollutant discharges
          will be reduced  or eliminated as
          required. The permit also  requires
          dischargers to monitor their wastes
          and to report the amount and nature
          of wastes put into waterways.
            The permit, in essence, is a
          contract between a company and,
          the government.
            This combination of  national
          effluent standards and limits,
          applied to specific sources of water
          pollution by individual permits, with
          substantial penalties for failure to
          comply, constitutes the first
          effective nationwide system of
water pollution control.
  Now, what does all this mean to
the beet sugar processing industry?
That's next.
The Beet Sugar Processing
Industry's Pollution Problems

The first step in applying the 1972
law to the beet sugar processing
industry was to identify the
industry's water pollution problems
and to find out what can be done to
solve those problems.
  To do that, the Environmental
Protection Agency assembled all
available information on the beet
sugar processing industry. This was
done through an extensive study of
the industry by EPA, through
published literature, with the help of.
a voluntary questionnaire survey of
the industry conducted by the U.S.
Beet Sugar Association, and by on-
site visits  and interviews at various
beet sugar processing plants
throughout the United States. In
addition, a contractor's study was
prepared under EPA supervision to
provide a  basis for evaluating the
potential economic impact of
effluent limitations  guidelines and
standards of performance
established by EPA.
  Raw waste characteristics were
identified  and quantified, including
analyses  of the source and volume
of water used in the process
employed, and the sources of
waste and waste waters in various
plants. The constituents of waste
waters which should be subject to
the effluent limitations guidelines
were identified. Existing control and
treatment technologies were
identified,-as well as the problems,
limitations, and reliability of each

-------

-------
8
treatment and control technology
and the time required to implement
them.

From this extensive study the
following facts emerged:

• If discharged without treatment,
the waste waters from a beet sugar
processing plant of average size
would be equivalent to the sewage
load from a population of about
823,000 people in terms of organic
polluting  effect.

• Together, the 52 beet sugar
processing plants in the United
States discharge approximately 30
million pounds-of wastes each day.

• That waste water contains about
6 million  pounds of oxygen-robbing
organic materials and about 24
million pounds of suspended solids
per day.

• A major pollutant in waste
discharges from beet sugar
.processing plants is organic
material.  The measurement of
these oxygen-consuming pollutants
in water is called "biochemical
oxygen demand," or BOD. (This is
usually expressed in terms of the
amount of biochemical oxygen
demand in five days, or BOD5.)
When dumped untreated into a
stream or river, the organic material
is decomposed  by micro-
organisms, which consume oxygen
in the water. This depletion of the
oxygen content can have a
catastrophic impact on life in the
water body, since fish and other
aquatic animals and plants must
have dissolved oxygen to survive.  A
total lack of dissolved oxygen due
to high BOD can produce a "dead"
water body in which aquatic
survival is impossible. Also, even
when all the oxygen in a body of
water has been used, the decay of
organic matter continues, which
produces noxious gases, such as
hydrogen sulfide and methane.

• Another major pollutant from beet
sugar processing plants is
suspended solids, both organic and
inorganic. Among the inorganic are
silt, sand, and clay.  The organic
components include such things as
beet tops, grass, and boiler ash.
These pollutants are collectively
called "total suspended solids," or
TSS. Suspended solids discolor and
cloud water,  impairing
photosynthesis in aquatic plants. If
pollutants containing organic
matter settle on the bottom, they
become sludge beds that further
deplete the water's  oxygen content,
as well as creating  gases toxic to
aquatic life. In addition to their
esthetic and ecological
considerations, suspended solids in
water from streams used by
industry can interfere with maYiy
industrial processes. They can
cause foaming in boilers, damage
equipment, and impose high
purification costs on industries that
need water to make their products.

  There are two key points to
remember: Raw wastes from beet
sugar processing plants contain
unacceptable amounts of organic
materials and suspended solids.
The wastes thus have to be treated
before they can be  discharged into
a water body.-and...
These two major beet sugar
processing industry water
pollutants can be treated
successfully.

-------
• Other identified pollutants in beet
sugar processing plants include
coliform bacteria and heat.

• Another consideration is the acid
or alkali content of liquid wastes.
This is called the "pH" of the
mixture. (Pure distilled water has a
pH of about 7, a strong acid solution
has a pH of 1, and a strong alkali
solution has a pH of 14.) Extremes
of pH or rapid pH changes can
exert stress conditions on aquatic
life, or kill it outright. Dead fish,
associated algae blooms, and foul
stenches are esthetic liabilities in
any waterway. Even moderate
changes from "acceptable1: criteria
limits of pH are deleterious .to some
species. In general, however, the
pH of wastes from sugar beet
processing plants can be easily
adjusted where necessary.

• The proper handling of sugar
beets before reaching the plant, the
design of beet flume systems to
facilitate dry-handling techniques,
dry methods for handling  lime mud
cake, conversion of Steffen filtrate to
usable end-products, process water
reuse, and the reuse and recovery of
various flows in the processing
plant—all in-plant control
measures—are extremely important
in efforts to control pollution from
beet sugar processing.

• Finally, the EPA study revealed
that the process waste waters from
the beet sugar processing industry
also contain pollutants that will not
interfere with publicly owned
treatment  works.

   In sum, the beet sugar processing
industry's  water pollution  problems
were identified, and it was
determined that water pollution from
the industry can be controlled by
use of machinery  and methods
already in use. In  other words, the
technology to do the job already
exists.
The Law and the Industry

Having assembled these facts,
EPA's next step was to prepare
standards for beet sugar processing
plants under the 1972 law. Many
factors were considered:
Differences in raw material used, the
product produced, the
manufacturing process employed,
raw waste characteristics, existing
control and treatment technologies
with their attendant problems,
limitations and reliability of each,
and  environmental impact of such
technologies on other pollution
problems such as air,  solid waste,
noise, and  radiation. The energy
requirements and costs of each
control and treatment technology
were also identified.
  The proposed regulations were
issued July 19,1973. They were
sent to the industry and other
interested organizations for review
and comment. Comments were
received from sugar processing
companies, beet sugar processing
organizations, and by Federal and
State agencies. EPA then carefully
analyzed the comments and made
appropriate changes in the
standards.
  On January 31,1974, EPA issued
the final standards for the beet sugar
processing industry to follow in
order to meet the requirements of
the 1972 law.
  The standards are contained in an
official government regulation
9

-------
10        published in the "Federal Register."
          This regulation is supported by a
          detailed technical document called
          the "Development Document for
          Effluent Limitations Guidelines and
          Standards of Performance for New.
          Sources for the Beet Sugar
          Processing Subcategory of the
          Sugar Processing Point Source
          Category."

          In brief, the regulation:

          • Establishes the limits to be met by
          July 1,1977 through the best
          practicable control technology
          currently available.

          • States the limits to be met by July
          1, 1983, using the best available
          technology economically
          achievable.

          • Establishes the requirement of
          zero discharge of process waste
          water pollutants to navigable waters
          for all new plants.

          • Identifies the major beet sugar
          processing industry pollutants and
          establishes maximum limitations for
          BODS,  TSS, fecal coliform, and
          temperature that  beet sugar
          processing plants can discharge
          during any one day, and on an
          average over a 30 day period.

          • Requires that the pH (acidity or
          alkalinity) of  beet sugar processing
          plant discharges be within the range
          of 6.0 to 9.0.

          • States there is nothing to preclude
          the discharge of process waters
          from  beet sugar processing to
          municipal treatment plants.

          • Allows flexibility in applying
pollution controls to meet the 1977
standard in special cases.

• Does nof tell beet sugar
processing plants what technology
to use to meet regulations. The
standards require beet sugar
processing companies to limit
pollutant discharges to levels found
attainable by using best practicable
control technology.

  What does all this mean—to beet
sugar processing companies, to
those who work  in beet sugar
processing plants, and to the
public?
Impact of the Guidelines

Let's consider some questions at
this point about the impact of
pollution control on the beet sugar
processing industry.

1. Can  beet sugar processing
plants meet the 1977 limitations?
That is, technologically can they
reduce  their discharges of
pollutants to the levels  required by
1977?
  The answer is yes. Most existing
beet sugar processing  plants can
meet the 1977 standards. In fact,
60 percent of the plants are
already meeting the 1977 standards,
While there is no one treatment
process (biological, chemical, or
physical) which is  universally
applicable  in achieving zero
discharge of  pollutant waste
waters, the technologies already
exist which can be applied to any
one single  plant in meeting the
guidelines limitations. In addition,
five plants  discharge their waste
waters to municipal treatment

-------
plants, another alternative available
to other beet sugar processing
plants.

2. Can beet sugar processing
plants meet the 1983 limitations?
That is, technologically, can they
reduce their pollutant discharges to
the  levels required by 1983?
  Again, the answer  is yes, with a
few exceptions. Presently, there are
11 plants already achieving zero
discharge of pollutants to navigable
waters. Approximately 11 to 19
plants in  various areas of the
country are anticipated to have
difficulty meeting the zero discharge
standards, 9 due to excessive land
requirements and attendant high
economic costs, and the rest due to
intrinsic economic difficulties. If
municipal systems become
available to the nine plants without
sufficient land, these plants would
no longer have difficulty meeting the
1983 requirements.

-------
12
3. Can new plants meet the new
source performance standards?
  Yes. Using the best available
demonstrated control technology,
and with proper site selection to
assure sufficient land availability,
any new beet sugar processing
plant can meet the zero discharge
requirement.

4. Can the beet sugar processing
industry afford to meet the 1977
water pollution control
requirements?
  The answer is yes. It's estimated
that meeting the 1977 standards will
cost the beet sugar processing
industry approximately $7 million.
Annual operating costs are
estimated at about $0.7 million. The
new investment in  pollution control
facilities amounts to 0.5 to 0.8
percent of the industry's present
investment in plant and equipment,
the exact  amount varying
depending on the size of the plant,
and whether it uses the straight or
Steffen system.

5. Can the beet sugar processing
industry afford to meet the 1983
water pollution control
requirements?
   Yes, most of the companies can
afford to do so. It's estimated that for
the entire  industry  the incremental
investment and annual cost to meet
the 1983 standards will be $5-13
million and $430,000-1.1 million
respectively.
  Moreover, much of the additional
investment can be returned in the
form of valuable- materials
recovered by using better in-plant
controls. In fact, some beet sugar
processing plants may find that their
new cost to control water pollution
may be small. And  a few plants may
actually realize a net profit on their
pollution control .investments,
thanks to recycling—the recapture,
sale, and use of materials now being
discharged as wastes.
  So far, we've talked about beet
sugar processing plants that
can—technologically and
financially—meet the 1977 and
1983 standards.  Now a tougher
question:

6. What about beet sugar
processing plants that cannot
financially meet the 1977
standards? What will happen to
them?
  The economic analysis for this
industry indicated that from three to
five plants might have financial
difficulty in meeting the final 1977
guidelines. However, three of these
plants have indicated through
permit applications that they in fact
would  be able to meet the 1977
limitations. This reduces the
potential closures for 1977 to one to
two plants, representing about 50 to
100 full-time employees.
   For the men and women affected,
the loss will be very real. It will mean
relocating to another job in the beet
sugar  processing industry involving
a move to another community,
perhaps entering a new career, or
perhaps an early retirement. EPA is
very much aware of this problem. As
originally proposed, the 1977
standards could have affected four
to 10 plants under the guideline. By
revising the regulation (but
maintaining its integrity and
purpose),  this potential economic
impact was substantially reduced.
Any further lowering of the 1977
standard would have meant the
continuing discharge of raw
wastes—or business as usual,

-------
regardless of water pollution. And
business as usual with water
pollution is  simply no longer
environmentally tolerable and
therefore is not allowed under the
1972 law. It should be noted that the
regulation will create new jobs in
construction and maintenance of
new pollution control facilities.
  In sum, the price of restoring and
maintaining the quality of our
waterways  for the benefit of all  may
indeed be costly to those who  can
only stay in business by continuing
to pollute.

7. What about the 1983
standards? Will any more beet
sugar processing plants have to
close because of those standards?
  An EPA economic analysis
indicates, unfortunately, that  one to
two additional plants could have
financial difficulty in meeting the
1983 guidelines. These plants  are
larger than 2300 tons of beets
sliced/day and thus are not
exempt from the zero discharge
requirement. The average plant will
employ 50  people on a full-time,
year-round basis, and
approximately 200 full-time people
on a seasonal basis. Both seasonal
workers and full-time workers
would lose their jobs if the plants
close. For the seasonal workers,
work in the beet sugar processing
plant is not their primary source of
income. The full-time workers,
because of their skills, are in a
pretty good position to move into
other jobs in the same  industry.
  There is  no denying that
closures of plants wdiild seriously
affect beet growers. Each plant
processes  the entire crop of about
300 growers who would suffer loss
of sales through shutdowns of
plants. However, if the capacity
and processing of a plant that had
to close down is picked up by
another nearby plant, the loss of
income to beet growers would
probably be negligible.  In most
cases, too, growers have the
option of growing crops other than
beets.

8. How will the i 977 and 1983
standards affect consumers? What
impact will they have on the price
of beet sugar?
  The EPA economic analysis
concluded that any price increase
due to pollution control would be
minimal.  Plants representing 40 to
45 percent of the industry's annual
production are already  in
compliance with the zero
discharge level, and- plants
representing another 30 percent
require only a 0.2 percent price
increase (to maintain profitability).
The rest of the  industry might
require, at most, a 0.8 percent
price  increase.  Competition with
the cane sugar industry may
further limit any price increase that
may be required.

9. What about the productive
capacity that will be lost if some
beet sugar processing  plants do
indeed shut down?
   Based on consideration of
excess capacity in various plants,
the likely advent of new plants in
some regions, and the  availability
of imported  sugar and substitute
sweeteners, the overall supply of
sugar would probably not be
affected  in the event of actual plant
closings.
  Thus, water pollution control
requirements for the beet sugar
processing industry will have no
13

-------

-------
long-range repercussions in terms
of supplies of beet sugar and
related by-products, or industry
growth. The standards will  not
affect the  Nation's balance of trade
with other countries or exports of
beet sugar.

  In summary, with the possible
exception of, at most,  17 plants the
beet sugar processing industry can
meet the water pollution control
requirements mandated by the
1972 law. The result will be cleaner
water for all of us to enjoy and less
waste for the beet sugar
processing industry.
The Cleanup Program

The control of industrial pollution is
not the only aim of the Federal
Water Pollution  Control Act. The
law also required municipal
treatment plants to meet certain
discharge standards by 1977 and
1983. The law increased Federal
aid to local governments to help
build sewage treatment facilities,
and established planning
procedures for State and local
governments to control water
pollution from all sources more
effectively,  in cooperation with the
Federal Government. It also
streamlined and strengthened the
enforcement provisions of the
water pollution control program.
  Some water quality control
problems are so complex that they
cannot be solved by using
technology alone. For this reason
the Act included an areawide
waste treatment management
planning process under Section
208. This areawide planning brings
together several aspects of water
pollution control, including
treatment of municipal and
industrial wastes, the issuing of
discharge  permits to industry, and
the ways of dealing with "nonpoint"
sources of pollution such as
stormwater runoff, in a
comprehensive approach.
Emphasis  is placed upon planning
by local governments.
  In sum, the 1972 law provides
formidable new tools "to restore
and maintain the chemical,
physical, and biological integrity of
the Nation's waters."
  With the cooperation, hard work,
and investment of considerable
amounts of money from industries
and all. levels of government,
progress has already been made
toward reducing—and eventually
eliminating—pollution in our rivers,
streams, lakes, and harbors. But
much still  remains to be done. Still
more  money and effort will have to
be invested  if the clean water
program is to be successful—if we
are to have  water that is safe and
healthful for drinking, for use by
industry and agriculture, for
swimming and boating, for fish and
wildlife.
  To  help pay for this cleanup,
Congress  set up a construction
grants program in which the
Federal Government will pay up to
75 percent of construction costs
for treatment plants. The funding
for this program is expected to rival
the Federal  highway program in
magnitude. In fact, costs of
treatment  plants, interceptor
services, and combined sewer
overflow control facilities from the
beginning of the program through
1982  are expected to total
approximately $50 billion. That's an
average of around $5 billion per
15

-------
16        year, compared to the $13 billion a
          year that water pollution now costs
          the American people. Congress felt
          that expenditures under the
          construction grants program were
          essential to deal with a significant
          and pressing environmental
          problem.
              Some Suggestions on How
              to Improve Pollution
              Control in Plants
                There are several  in-plant
              control measures which indi-
              vidual plants can  use to  re-
              duce pollutants in  beet sugar
              processing waste waters.
                While not strictly part of in-
              plant operations, the  method
              of handling beets in the fields
              can make a big difference in
              the  amount  of solid  wastes
              and  tare  which  enter the
              flume system. Care should be
              taken to remove leaves, trash,
              and as much soil as possible
              at the time the  beets are
              harvested.
                Deterioration   of  stored
              beets can  be minimized by
              proper storage conditions and
              the shortest storage time pos-
              sible.  Improvements  in sys-
tem  design  can reduce  the
amount of wastes introduced
into the beet flume system.
  One plant in California  has
solved the  lime mud  slurry
problem  by  recovering  the
lime mud cake from  the hold-
ing pond, and  recalcining  it
for reuse.
  There are several ways in
which waste waters from  ba-
rometric condensers may be
reused. Waste waters can be
used in the raw water supply,
in lime mud  slurrying,  gas
washing, in the flume recircu-
lation system, and for diffuser
makeup water.
  Not  only will improved in-
plant methods reduce  pollu-
tion,  but  experience   has
shown  that  such  improve-
ments in design, construction,
operation, and plant manage-
ment are  important  contribu-
tors  to overall efficiency  and
economics of plant operation.
         For additional copies of this
         booklet, write: Public Information
         Center (PM-215), EPA,
         Washington, D.C. 20460.

-------