Regional Solutions to Regional Problems A Symposium on Implementing Regional Wastewater Management Plans and the Technical Response to PL 92-500 PROCEEDINGS September 9 and 10, 1976 Portland, Oregon Sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- REGIONAL SOLUTIONS TO REGIONAL PROBLEMS A Symposium on Implementing Regional Wastewater Management Plans and the Technical Response to PL 92-500 Formation of the Unified Sewerage Agency of Washington County: A Brief Overview, by Joel Wesselman, General Manager, Unified Sewerage Agency of Washington County, Oregon The National Perspective on Regional Water Quality Management Efforts, by Joe G. Moore, Jr., Head of the Graduate Program in Environmental Science, University of Texas—Dallas; Former Program Director of the National Commission on Water Quality Political and Institutional Variables Found in the Formation of Twin Cities Regional Water Pollution Control System, by Richard J. Dougherty, Chief Administrator, Metropolitan Waste Control Commission/Twin Cities Area, Saint Paul, Minnesota Political/Institutional Variables, Summary of Discussion Sessions Moderated by Fred A. Harper, General Manager, County Sanitation Districts of Orange County, California Implementing Regional Wastewater Management Plans: The Financial Considerations, by John A. Lambie, Chief Engineer and General Manager, Ventura Regional County Sanitation District, California Financial Considerations, Summary of Discussion Sessions Moderated by Jack H. McMinn, Vice President, Bartle Wells Associates, Project Manager for the 1970 Financial Plan for the Unified Sewerage Agency of Washington County, Oregon The People Problem: Management and Operations, by Robert J. Borchardt, Chief Engineer and General Manager, Metropolitan Sewerage District of the County of Milwaukee, Wisconsin Management/Operations: The People Problem, Summary of Discussion Sessions Moderated by Penelope A. Wilson, Special Assistant to the Executive Director, Municipality of Metropolitan Seattle Implementing Water Quality Management on a Regional Scale: The Capital Facilities, by Marvin W. Runyan, President, Stevens, Thompson & Runyan, Inc. Capital Facilities, Summary of Discussion Sessions Moderated by Cowles Mallory, City Engineer, City of Portland, Oregon Regional Solutions to Regional Problems, by the Honorable Neil Goldschmidt, Mayor, City of Portland, Oregon The Resource Question: What are the Trade-Offs?, by Jerome B. Gilbert, President, J. B. Gilbert & Associates, Former General Manager and Chief Engineer, North Marin County Water District, California and Executive Officer, State of California Water Resources Control Board Overview of Land Treatment of Wastewater, by Noel W. Urban, Chief Engineering Management and Urban Studies Section, Engineering Division, Office of the Chief of Engineers, United States Army Corps of Engineers, Washington, D.C. and Mark Moser, Staff Agriculture Engineer fiHMKi RX00000b334 ------- Land Utilization/Disposal of Municipal Wastewater Sludge, by Bart T. Lynam, General Superin- tendent, Metropolitan Sanitary District of Greater Chicago; Raymond R. Rimkus, Chief Maintenance and Operations; and James L. Halderson, Agricultural Engineer When is Advanced Wastewater Treatment the Answer?, by William A. Whittington, Acting Deputy Director, Municipal Construction Division, Environmental Protection Agency, Washington, D.C. Washington County Citizens Committed to Clean Water, by J. Allan Paterson, Board of Commis- sioners, Unified Sewerage Agency of Washington County Advanced Technology Helps Solve a County's Water Pollution Problems: The Durham Facilities, by James A. Crom, Senior Vice President and General Manager, Environmental Engineering Division, Stevens, Thompson & Runyan, Inc. Dedication of the Durham Facilities: A Success Story, by Donald Dubois, Administrator, Region X, Environmental Protection Agency DISCLAIMER These proceedings have been reviewed by Region X, U.S. Environmental Protection Agency, and approved for distribution. Approval does not signify that the contents necessarily reflect the views and policies of the U.S. Environmental Protection Agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use. ------- ; gm os2?> "Regional Solutions to Regional Problems" — public officials all over the country are concerned about efficient, effective solutions to prob- lems in their areas. Are area-wide solutions the answer? Wastewater management officials attending this national Symposium on Implement- ing Regional Wastewater Management Plans and the technical response to PL 92-500 explored a number of issues and alternatives through formal presentations and intensive discussion sessions. Speakers included Marvin W. Runyan, President of Stevens, Thompson & Runyan, Inc.; Robert J. Borchardt, General Manager of the Milwaukee Sewerage Commission; and Richard J. Dougherty, Chief Administrator of the Metropolitan Waste Control Commission for the Twin Cities area in Minnesota. The political and institutional variables involved in imple- menting a regional plan was a topic of major concern throughout the Symposium. Fred Harper, General Manager of the County Sanitation Districts of Orange County, California, led the group discussion sessions on this sensitive problem. ------- 9 Financial considerations are a central part of any effort to implement an area-wide wastewater management plan. John A. Lambie, General Mana- ger of the Ventura Regional County Sanitation District in California, presented a paper on the financial aspects of regionalization and assisted Jack A. McMinn, Vice President of Bartle Wells Associates in moderating the discussion sessions on the subject. Dedication of the Unified Sewerage Agency's Durham Advanced Waste- water Treatment Facilities was the occasion for the Symposium. Donald J. Dubois, Region X Administrator for the Environmental Protection Agency, delivered the dedication address for the new facilities. L ------- Following the presentation of papers on advanced wastewater treatment technology and land treatment alternatives, Symposium participants attended the dedication ceremonies at the Unified Sewerage Agency's new Durham Advanced Wastewater Treatment Facilities. After the cere- monies around the fountain at the plant's administration building, guided tours of the new facilities introduced visitors to the complexities of a modern 20 million gallon per day plant. For those interested in land treatment, a tour was also available to the Unified Sewerage Agency's Sherwood site for a demonstration of land disposal of effluent and sludge. ft* IMtiwO ------- Formation of the Unified Sewerage Agency of Washington County: A Brief Overview by Joel Wesselman General Manager Unified Sewerage Agency of Washington County, Oregon presented September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- FORMATION OF THE UNIFIED SEWERAGE AGENCY OF WASHINGTON COUNTY: A BRIEF OVERVIEW Joel Wesselman, General Manager, Unified Sewerage Agency of Washington County, Oregon On behalf of the Environmental Protection Agency, Stevens, Thompson & Runyan and the Unified Sewerage Agency, we welcome you to the conference and hope you find the two-day sessions very helpful to you. We are looking for a large degree of participation from all of you. What I would like to do this morning is provide some perspective and dimension for what we are trying to accomplish. I am hoping we can look forward to the panel discussions this morning merely as thought starters. I want you all to be thinking as we hear the panel presentations of some key topics for the discussion sessions this afternoon. As you probably already concluded, our format and strategy for the sessions today are to hear these presentations this morning and then break out into discussion ses- sions which are outlined in your program. KEY WORD IS IMPLEMENTATION If anything, I want to overemphasize that our discussions here relate to the implementation of area-wide wastewater management plans and that would be opposed to our ongoing considerations for the preparation and development of the 208 wastewater plans themselves. Implementation is the key word here. I am fairly closely involved with the Columbia Region Association of Government's 208 Plan in the Portland metropolitan area and, as a number of us have, we've been getting letters from EPA, asking for "hard output." What they are saying is that they want to see some implementation of certain program elements prior to the time the plan is complete, and I'm not sure that when I say implementation relative to this conference that I'm talking about implementation prior to comp- letion of the study. At any rate, one of the advantages of getting people together like this intersectionally is to compare notes and see how EPA is administering its program from region to region. The next thing I would like to do is briefly review what the Unified Sewerage Agency is and offer some comments in that regard. The agency was created in 1970 in what you might term a pressure cooker with three major ingredients. First, we had an obvious and visible water pollution problem. ------- We were also going through a series of sewer connection moratoriums in the Washington County area which obviously has a gross economic impact on any urbanizing area. Finally, an obvious irrational organization of wastewater management existed in the Washington County area. The formation of the Unified Sewerage Agency combined the management of 28 separate agencies, 9 of them being cities and it provided for these ser- vices by various methods and included service to areas outside of Wash- ington County by intergovernmental contract. The USA is probably a reas- onably good example of what we might do and how we might structure a wastewater management agency. It does address very clearly some of the basic criteria that we look for such as cost-effectiveness, the ability to meet water quality standards and, of course, our age-old need to provide the necessary level of political and managerial accountability. The agency financing plan, which strikes a balance between connection fees, sewerage service charges and ad valorem taxation, has been a very good vehicle for us, both in terms of equitability and providing us the ability to give service to the various governmental agencies within the agency — service on the basis of what they desire, either wholesale or retail basis. CAPITAL IMPROVEMENTS NEARLY COMPLETE The agency is 100 square miles in total area and encompasses some 200,000 persons. Relative to the Portland metropolitan area, the agency encom- passes about one-third of the area within the Framework Plan of the Colum- bia Regional Association of Governments (CRAG), which is the outline of the Portland metropolitan area. The agency has spent its first 6 1/2 years of existence in a rather furious capital improvements plan and construction. We have been upgrading old plants that are going to be abandoned as near downstream as one year and spending our time in building facilities, such as the Durham Advanced Wastewater Treatment Plant, which we will be dedicating tomorrow. We're also under construction with our Rock Creek Facility, a facility that is almost the same size as Durham. We expect that to come on line in about a year from now. The Rock Creek plant, along with the Durham Advanced Wastewater Treatment Plant, involved the abandonment of 22 obsolete sewerage facilities, scattered upstream in the Rock Creek and Fanno Creek basins. The last thing I want to do today is to leave an impression that this conference is a case study on the Unified Sewerage Agency. It is certainly not that. I would point out, however, that Marvin Runyan, President of Stevens, Thompson & Runyan, is here. Marv was project manager for the 1969 Master Plan, which set up the capital improvements plans for the agency. Also here is Jack McMinn. Jack is Vice President of Bartle Wells & Associates and worked on the financing plan, which became the basis for the financial merger of the system operations that the agency encompasses. This plan also became the basis for presentation of our capital improvements plan bond authorization of $36 million back in 1970 which was ultimately approved by the voters. So these two people are here if we can be of assistance. Again, I emphasize, that I am not trying to project this as a case study on the Unified Sewerage Agency but if you can benefit from our experiences and mistakes, you're certainly welcome ------- Before we begin the panel presentations, we do have a key noter here this morning. I am sure you are all indirectly or directly familiar with the work of Joe Moore and the National Commission on Water Quality. The commission was headed by Nelson Rockefeller and the commissioner was charged "to make a full and complete investigation and study of all the technological aspects of achieving and all aspects of the total economic, social and environmental factors of achieving or not achieving the effluent limitations and goals set forth for 1983 in PL 92-500." The title of Joe's presentation this morning is "The National Perspective on Regional Water Quality Management Efforts." If you relate that title to the charge of the national commission, I think you'll find it obvious why Joe Moore is here today. We asked Joe to speak and lay some ground rules relative to the term "regionalization" itself and try to define that term. He will also talk about the rationale for "Regional Solutions to Wastewater Management Problems" and discuss the thrust and the result- ing thrusts of PL 92-500 with respect to regionalization and area-wide wastewater management. ------- The National Perspective on Regional Water Quality Management Efforts by Joe G. Moore, Jr. Head of the Graduate Program in Environmental Science University of Texas — Dallas Former Program Director of the National Commission on Water Quality presented September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- THE NATIONAL PERSPECTIVE ON REGIONAL WATER QUALITY MANAGEMENT EFFORTS Joe G. Moore, Jr., Head of the Graduate Program in Environmental Science University of Texas at Dallas, Former Program Director of the National Commission on Water Quality With regard to regionalization in the wastewater field, this is not some- thing that is new. There are old regional agencies and some interstate agencies that have long histories in water pollution control. Admittedly, most of these have grown out of some crisis situation, as for example, Seattle Metro really did; also ORSANCO, one of the oldest, an interstate commission on the Ohio River, began because of a particular problem. The Delaware River Basin Commission, a peculiar kind of interstate com- mission with joint federal participation, originated because of a par- ticular concern, in that case probably more water supply than water pol- lution. There are others that are represented here on your program or in your audience: Chicago's Metropolitan Sewerage District; the Nashville, Tennessee, approach to regional government, one that has been examined extensively across the country, particularly because it is more multi- purpose rather than single purpose; the Los Angeles County Sanitation District's organization that pulled together a multiplicity of local political subdivisions into a single-purpose district; Dade County, Florida, and some others that you can call from memory — St. Louis, Milwaukee, Minneapolis-St. Paul, etc. It is important to remember that these are single purpose, for the most part and grew out of some particular local concern. Some of those who point to Public Law 92-500 as a radical departure in the water pollution control statutory field overlook the fact that the Water Quality Act of 1965 had a provision intended to generate or encourage regional wastewater collection and treatment — the so-called 3C Section of that act — under which grants were made to regional agencies across the country to try to develop at least models for regionalization if not comprehensive regional plans. Those planning efforts were directed at wastewater collection and treatment rather than the general land use focus of Section 208. Frankly, I think 208 is a "sleeper" provision in PL 92-500 in the sense that I'm not sure it received a great deal of discussion during the course of the passage of that act. I think the lack of initial implementation reflects that EPA did not attach a great deal of significance to that provision in terms of its priorities for implementing the new law. ------- The real critical question in Section 208 is, "Who will be the recipient of the construction grant money once the planning process is completed"? Some states were concerned about this issue long before the implementation of that section was initiated. In the State of Texas, the governor early concluded that he would resist the identification of any Section 208 agency in the state. I'm going to come back to the Texas situation in a moment because some things that have been done there bear on the whole question of regionalization for water pollution control. Frankly, however, the major limitation of most existing regional agencies, whether they were created historically for some particular problem, or created in recent years under the impetus of the federal legislation, is that they lack a very critical element or authority and that is the power to enforce their own decisions. For example, the Delaware River Basin Commission recently wished to change the allocations — the waste load allocations — for that particular river and revise the allocation that was available to the State of Delaware, the downstream state on the river. All other states were agreeable, but not the Governor of Delaware. What do you suppose was the impact of his refusal to accept the change in his own state's wasteload allocation? This question we consistently raised when regional agencies wanted to enforce the water quality standards under the Water Quality Act of 1965. Do you, as a regional agency, have the capability to carry out the decisions you may make as a regional agency? I think the fundamental question remains. Can an existing regional agency, yours or one structured like yours, or one you might design — can an existing agency implement a regional plan for wastewater treatment? Also, how does a regional agency function with other single or multipurpose regional agencies, because after all, there are other concerns besides wastewater treatment for which political subdivisions are being established in metropolitan or thickly-populated areas simply to get the broadest possible geographic coverage for the resolution of a particular problem. So regionalization is not necessarily new and we tend to focus on single purpose units of government to achieve these kinds of things. In that process, we multiply the number of governmental jurisdictions with which the citizens have to deal. Admittedly, the simplest thing would be to design a system that would meet today's needs before there were any people within the area and thereby avoid the conflict with any existing vested interests. Then if you allowed the people to come in and fit into that structure, your management would be much simpler. I think the whole question of regionalization will eventually be resolved upon the basis of whether or not you can generate enough pure political acceptance of a regional agency in order to create it. Must there be an overriding crisis before you can achieve true regionalization? With "20-20 hindsight," some of us involved in water pollution control during past years have perhaps pushed regionalization in the wrong direc- tion. I was one of those who argued that in metropolitan areas, wherever possible, construction grant funds should be used to encourage regionali- zation. I'm sure we can all cite examples of two wastewater treatment plants perhaps even across the street from one another, separated by jurisdictional boundaries; an accident of political development produced ------- such an anomaly. There were those in New England who thought it was a tragedy to build two plants of relatively equal size just across the street from one another, simply because a political boundary was there. When I was Commissioner of FWPCA, we got into a major controversy with the City of Warren, Michigan, as to whether or not Warren sewage could be mixed with Detroit's sewage and treated in a regional plant. In fact, I had indicated that I would support the State of Michigan in awarding the construction grant to Detroit and would not give the City of Warren a construction grant because their wastewater should go into the Detroit metropolitan system. Historically, Jerry Remus had refused to take the sewage from Warren and the city felt this past slight should entitle them to their own plant. They also argued they could build an advanced waste treatment plant much quicker than the Detroit metropolitan plant could ever be built and that, therefore, in the long run, they would change the quality of the water earlier than the City of Detroit could. At any rate, we indicated that we would support regionalization, in that case by refusing to approve the construction grant. What do you suppose the City of Warren did? They sent a delegation to see their congressman in Washington and their congressman called the commissioner of the Federal Water Pollution Control Administration and asked for an audience. Those audiences are granted when requested and the whole delegation came down. I had to sit there and tell them "No, we will not approve a construction grant to you. The State of Michigan has refused it and the Federal Water Pollution Control Administration will refuse it." I then made what was perhaps a facetious observation, but it is one that to some degree still holds. I asked the delegation from the City of Warren, "Where do you get your water supply"? They said, "We buy it from the City of Detroit." I said, "Don't you think it is a little bit odd that you can argue that you are perfectly willing to draw your water supply from the same source, but you want to segregate your sewage? Though it's all right to drink water from the same container, you can't flush your toilets into the same sewer." They didn't think much of that response and, incidentally, I'm not sure how the case finally came out. I, fortunately perhaps, was relieved of the opportunity to see the situation through to conclusion by the change in administrations in 1969, but that is the kind of question that often causes a problem in regionalization. Another mistake I think we make is to convey the idea that, for a regional system, all the wastewater must be collected and put through one wastewater treatment plant. In the State of Texas, wastewater from a major part of the Dallas metropolitan area is now going into a treatment facility that is a classic in terms of examining technologies for wastewater treatment. The original Imhoff tanks are still on the site being used as primary sedimentation basins; then there are a series of regular trickling filters, then a series of rapid-rate trickling filters and now they are just com- pleting an activated sludge treatment plant followed by sand filters. The present plant is a whole string of the technologies for wastewater treatment. The problem is that the 125 million gallon a day volume through the wastewater treatment plant is discharged into a substantially dry water course; thus the entire flow is primarily sewage. The City of Houston happens to be further downstream and it has for a reservoir on the Trinity River, a reservoir which is, of course, accumulating the Dallas-Fort Worth treated sewage. Dallas' present permit requirements ------- are a BOD of 10 and a suspended solids of 10. They are constructing a facility to produce 5-5 instead of 10-10, but they still have a massive discharge of 125 million gallons a day. A legitimate question is, "Might it not have been better to have scattered some of the waste treatment investment over a wider area so that there would not be such a massive discharge in a single spot"? Regionalization should not necessarily mean consolidation, with all due respect to what is going on here in Portland, of all wastewater in a single place to be treated and discharged into a water course. (I will admit that in this part of Oregon they have a little bit more water than they might have in some parts in Texas.) With regard to where we stand on regionalization from the federal view- point, I happen to believe that, in most cases, what regionalization we are likely to see occur from this point forward will arise as a result primarily of the federal legislation. That may be unfair. I'll comment in a moment about a different kind of issue, but for the most part, I think PL 92-500, if Section 208 proceeds in the direction it appears to be going, will produce a major thrust to achieve regionalization through the implementation of the plans developed under Section 208. In this process, however, we have another case of "the cart before the horse", because, while EPA did not implement Section 208 early, neither did they allocate the total authorization for publicly-owned treatment works con- struction grants. Now we find a situation in which those in the construc- tion grants program of the Environmental Protection Agency are rushing to obligate all of the remaining $18 billion by October 1, 1977, if at all possible. This means that the publicly-owned treatment works con- structed with that $18 billion will already be sited and substantially fixed before the 208 planning process is completed. So far as 208 having an impact in terms of designing an optimum system, even with all the ob- stacles that may exist, the system is not likely to be optimum when the 208 planning process is concluded, because the publicly-owned treatment plants will already be in place. To some degree, the same thing is true of industrial treatment facilities. The pressure has been for industry to comply with the 1977 requirements of Public Law 92-500. The testimony of industry to the National Commission on Water Quality was largely to the effect that they will achieve substantial compliance with the require- ments for "best practicable control technology currently available" by the July 1, 1911 deadline. They generally stated that at least 90 percent of the industries would achieve that requirement, in terms of numbers of plants rather than in terms of volume of wastewater. Nevertheless, substantial industrial waste treatment facilities will have been designed and constructed, or will be under construction, while this 208 planning process is underway. What is left? There remain the questions of nonpoint sources of pollution, agricultural or urban runoff and perhaps some atten- tion to the question of growth, which inevitably arises in the regional planning. If you want to tamper with a difficult regionalization question suppose you have a composite of individual political subdivisions as ' opposed to a unified agency, such as for example, the Los Angeles County Sanitation Districts, and you must design for growth. Who bears the cost for the growth? Some will argue that there is not going to be any growth in their particular area, that the growth is going to occur either in undeveloped areas within other political subdivisions or on the periphery of the geographic jurisdiction. ------- I think one of the peculiar impacts of the 1972 act on regionalization has been the conclusion, largely as a result of the NRDC suit against the Environmental Protection Agency, that 100 percent of every state's geography must be covered by a Section 208 plan. This means that there could logically come a time when the question is, "What is the implemen- tation vehicle outside the specifically-designated Section 208 planning agencies"? Who is going to handle the broader geography and to what extent will the state's role be altered in terms of construction grants for the area outside the designated 208 areas? One of the questions regional agencies will have to address is: what attention is being given, if any, to unincorporated areas, since they are likely to become incor- porated or become parts of existing subdivisions? I am going to use a phrase, I suppose that it is not standard, but the councils of government approach to planning, particularly with regard to Section 208, is probably the one that is most common across the country. If you are part of a planning agency as opposed to an operating one, or if you are an agency that has both planning and operations functions, you know the problems that are likely to arise between plans and implemen- tation if the plans are the responsibility of one jurisdiction and the implementation must be done by somebody else. Early on, Texas became interested in the COGS and because of a planning unit in the Governor's office — long before Public Law 92-500 was enacted — the state's geo- graphy had become completely covered by COGs. Texas had at that time about 22 Standard Metropolitan Statistical areas, so those 22 statistical areas became COGs. The Governor's office actually generated the creation of Councils of Government that would cover the entire geography. There may be some small areas not yet within these units in Texas, but 95 to 99 percent of the geography was included in COGs before the planning provisions of Section 208 became law. These COGs are able to exist at the sufferance of the operating political subdivisions. The question is, who is going to get the operational authority after the COG has developed the plan? If you want to think of the complications, the Dallas- Fort Worth metropolitan area has had a history of disagreement between the cities of Dallas and Fort Worth, while all the small cities are afraid that they are going to be overwhelmed by Dallas and Fort Worth. Dallas has traditionally been the water supplier for the small cities. Now the small cities are in heated litigation with the City of Dallas over whether or not they are being overcharged for their water supply. (I never will forget, there was a small bedroom community completely encom- passed within the City of Fort Worth and we were doing population pro- jections one time — the name of the city escapes me at the moment, but let me call it Richardson, which is another city in the general area — and so in our tables where we were displaying populations of the cities, we put Fort Worth and marked it with an asterisk and down at the bottom in the footnote we indicated "includes the City of Richardson." When we were holding hearings on this particular report in which that table appeared, the City of Richardson made a plea that our display was unfair to the City of Richardson. They suggested what we should have done is, put Richardson in the table with an asterisk and down at the bottom (raying "includes the population of Fort Worth" — simply because they had gotten swallowed up in the statistical presentation.) Can a COG, or should a COG, or is a COG a vehicle, is a regional planning agency a vehicle, that ------- should, through some kind of metamorphosis, become an operational agency? Some will want to do that and some existing operational agencies will obviously resist, but can you make a valid argument as to why planning should be done in one political arrangement and implementation somehow has to be done in another political arrangement? When I was in the Gover- nor's ofice, while I wasn't involved in those activities, at a staff meeting one time, 1 said, "Why don't we just face the question openly and in a very straightforward kind of way and say that we regard these COGs as just interim steps toward regional government"? I thought the staff man in charge of that particular responsibility was going to collapse right there. He said, "You can't even say that out loud because of the fear by the cities and counties that these COGs are going to somehow take away a part of their jurisdiction." It's still a good question — why should planning and operation be separate, or if they shouldn't be separated, how are the two activities to be coordinated? By the way, Section 208 in its implementation is likely to be concerned about much more than the question of whether or not there's going to be a comprehensive wastewater collection and treatment system, and this is a significant difference. It is conceivable that Section 208 is in- tended to become some kind of local, governmental decision focus for questions of growth, the direction of growth and the utilization of land within the political subdivision. You may as well face the fact that all these issues will become involved at some point in the planning pro- cess. At the same time, I have to be honest and say that I think most local agencies involved in the construction of publicly-owned treatment works regard the requirements of Section 208 as just another hurdle to securing construction grant money; it's just one more procedural step, paper work requirement of EPA. I'm not sure that construction agencies have taken the implementation provisions of 208 all that seriously and obviously if you can get your commitment for construction grant funds and get the publicly-owned treatment works constructed, you may not be confronted with the question. Even though they've gotten the cart before the horse, "existence is 9/10's of the law" and when the time comes, the operating agency can influence the implementing procedure. With regard to the continuous planning process that is presumably to be initiated, through Sections 208 and 303(e) and 106, etc., the provisions of Public Law 92-500 that deal with the planning question, one of the fundamental misunderstandings on the part of the federal level — and, by the way, this is not necessarily limited to, I'm not restricting this just to the Environmental Protection Agency — is to get something started and then say that our intent is that state and local communities will later assume the costs. Now put the question honestly to your situation in your state. If the federal money were not available for planning, would your state or some local unit of government provide an amount of money equivalent to that the Environmental Protection Agency has made available for regional planning? I think if you are really honest the chances are that in 9 cases out of 10 the answer would be "no". The states will not necessarily pick up the planning function after EPA gets it started and this is a crucial question for long-range results. What is likely to be the cost-sharing between federal funds, state funds and local funds and what bearing is the proposition likely to have on the regional activities? ------- There is another development that will have to be dealt with in due course and that's to what degree do the requirements for public participation under Public Law 92-500 cause some problems in the Section 208 plan or the implementation of that plan? At the risk of boring you with something with which you are already familiar, I am going to read some excerpts from the EPA's rules and regulations that bear on this question of imple- mentation. First, this is from the "Policies and Procedures for Continuing Planning Process," issued November 28, 1975 after the litigation that resolved the question of whether or not each state had to have planning agencies covering the entire state's geography. In the introduction, describing what follows in the rules and regulations, EPA says, "The broad goals of the continuing planning process are to assure that the necessary institutional arrangements and management programs are estab- lished to make and implement coordinated decisions designed to achieve water quality goals and standards; to develop a state-wide (state- and area-wide) water quality assessments; to establish water quality goals and state water quality standards which take into account overall state and local policies and programs, including those for management of land and other natural resources; and to develop the strategic guidance for preparing the annual state program plan required under Section 106 of the act." One of the issues yet to be resolved and one which all operating agencies and Section 208 planners will confront is, "how do you enforce the plan once you have gotten it approved"? The enforcement device for which pressure is developing is construction grants. If there is not an imple- mentation program for the Section 208 plan, then construction grants can be withheld, or state grant funds can be withheld. I want to elaborate on that in just a moment. The major concern relating to provision of legal sanctions — that is, withholding of construction grants or permits in the absence of complete planning — was resolved prior to the proposed regulations as a result of an EPA legal opinion. Still, in the introduc- tion to the regulations, "Thus the final regulations do not incorporate sanctions for noncompliance, but provide that once a plan has been approved by the regional administrator no permits shall be issued or construction grants approved which are in conflict with the plan. (Sounds like a fairly effective control device.) Recognizing that other determinations outside the planning process by EPA and/or the states could lead to inconsis- tencies with approved plans, the final regulations clarify how such deter- minations are to be dealt with in revising the plans." There follows some discussion and in describing the management agencies, there are enumerated a series of things that the management agency is supposed to be able to do: "(0) Management agencies. (1) The identification of those agencies recommended for designation by the Governor pursuant to regulation 130.15 of this Chapter to carry out each of the provisions of the water quality management plan. The identification shall include those agencies necessary to construct, operate and maintain all treatment works identified in the plan, and so on." There follow some nine speci- fications for what the management agencies are supposed to perform. In 3une of this year, the Natural Resources Defense Council wrote the administrator of EPA on this point, saying, "We believe that one of the best methods of ensuring meaningful implementation of Section 208 is to ------- utilize the Section 208 grant program itself as well as the related funding programs under Sections 106 and 201/204. in each of these three programs, the EPA administrator has the authority, indeed the responsibility, to condition the federal grant to require the development and implementation of an adequate 208 plan." This letter goes on to spell out the legal basis for litigation against the Environmental Protection Agency to assure that the other provisions of the law are used in such a way as to assure that the developed plan can be implemented. I think this is where the implementation issue is eventually going to focus, i.e., whether or not you can withhold funds provided elsewhere in Public Law 92-500 for failure to implement. Just let me quickly review the Texas experience and I'll quit with some suggestions about where I think we'll likely go. Fortunately, states that have had water problems are likely to have tried various kinds or organizations much more than in other places; that is, in Texas, fortu- nately, constitutional provision provides an umbrella under which agencies to deal with water problems can be created. In some cases, we have en- tirely too many created, but nevertheless, there was a means for creating something to manage the problem. Long before Public Law 92-500 — in fact, in 1966 — water districts and river authorities in Texas were authorized to become regional waste treatment plant owners and operators. The Brazos River Authority actually bought the Waco waste treatment faci- lity and started operating it. Then the Guadalupe Blanco Authority bought the Victoria wastewater treatment facility. You might say, "What in the world is the advantage to that"? Well, in Texas the river authorities were originally conceived to manage water resources in terms of quantity. When quality problems arose, the river authority also became the vehicle for managing the quality considerations. The Trinity River Authority fills in the service gaps between the Dallas-Fort Worth city waste collec- tion and treatment systems. As a general rule, before any small city in the Dallas-Fort Worth metropolitan area is granted a permit for a waste treatment facility, the Trinity River Authority is asked whether or not it can serve that city in one of its regional facilities. They are now in the process of constructing and updating some of their facili- ties. We also tried something else, modeled after the European experience in the Emscher River; the state legislature created the Gulf Coast Waste Disposal Authority in the Houston metropolitan area. Its jurisdiction was limited because of political considerations, but nevertheless, that agency is in the process of consolidating many municipal and industrial waste treatment facilities. Some issues have arisen; for example, should the Gulf Coast Waste Disposal Authority own property that's exempt from the property tax, if they buy an industrial facility and start operating it as a governmental facility. . That question has caused them some difficulty. Texas has an agency called the Texas Advisory Commission on Intergovern- mental Relations; it's supposed to help solve some of the institutional problems among multiple jurisdictions. It did a study of the area-wide water quality planning and management provisions of PL 92-500 and suggested a geographic distribution of what the 208 agencies might look like in that state.* Then as a result — and these are drafts at the moment — * Area-wide Water Quality Planning and Management: A Proposal for Texas, Texas Advisory Commission on Intergovernmental Relations, January 1974 ------- as a result of these new EPA regulations, the State of Texas developed a continuous planning process and specified the regulations that go with it to assure that they comply with that particular provision.* For the National Commission on Water Quality, one of its contractors provided a report on planning, available through the National Technical Informa- tion Service of the Department of Commerce;** it has some interesting things to say about the problems that can arise or are likely to arise under 208. Let me just mention the incentives for regionalization. I mentioned the Waco and the Victoria experience; in these cases, the cities were able to transfer the debt for capital expenditure from the city to a regional authority which provided additional debt capacity where there is a limitation on local debt. Second, there are economies of scale, both for the capital investment and for the maintenance and operation expenses, plus the fact that in some cases, plants that might not otherwise be adequately operated can be operated if they are part of the regional system. Third, the selection of control or treatment sites can be devel- oped on a regional basis to minimize possible adverse impact such as the case of Dallas I was talking about a moment ago where there is a massive discharge to some particular point. Systems operation of the regional facilities is possible to provide the optimum flexibility — which is to say you might get more mileage out of a connected regional system than you would get out of a large number of disconnected, uncoor- dinated individual plants. There can be a consolidation of the technical and financial resources for problem solving — that is, the regional authority can provide an R and D program of its own. There is a likelihood that the growth and development of the area will be more orderly than it otherwise might have been. Finally, there is the possibility of achiev- ing economies through the use of tax exempt municipal bonds; this procedure is under attack and may not survive, but at least for the time being, it does offer an opportunity for saving. I'm going to conclude by giving a series of things that I characterize, "If I were running a zoo . . . what would I do? If I were EPA, I would examine the institutional structures for all SMSA's in each of the 10 or 15 most populated states or, I would let each EPA regional administrator examine those institutional structures in each of those SMSA's and for those regions that don't have one of the 10 or 15 most populated states, let each one pick the most populated state in his region and examine the SMSA's there and see whether or not there is an adequate regional management entity. Is there one there? Or are there several that could be models or that could be improved upon to be the management agencies? If one does not exist, then begin now in each 208 area to explore alter- natives to develop a regional management agency. * The State of Texas Continuing Planning Process, and Appendices> Texas Water Quality Board ** Water Pollution Control Act of 1972. Institutional Assessment, Planning, Harold F. Wise & Associates, 1975, NTIS, Dept. of Commerce, PB-244907 ------- If I were a state, I would do the same thing, because the states will confront the same question — where are the management agencies when the planning is completed? I happen to believe that the necessary study and analysis must be done by persons capable of professional institutional analysis, which is to say they have to be social scientists, in my view, or political scientists and not engineers or lawyers, because the question is a political one. Can you get enough people together to sell the creation of a regional authority? The local and state governmental and civic leaders must be invited to participate; there will have to be some general public participation. It should be actively sought, because you'll never get one created if you don't do that. If you are serious about regionali- zation, then let's just approach it head-on and say what we want to do is try to create an entity that will serve the purposes of the law. I think we should not ignore the possibility that we should decide whether or not to create a multipurpose regional unit of government different from either cities or counties or the single purpose political subdivisions we now have. Political scientists in this country have failed in that we do not have, or have not made enough effort to see if we can't create multipurpose, regional entities to replace some of those limited local governments we do have. In conclusion, I think this is a political question and if you don't ap- proach it in terms of political realities, I'm not sure that Section 208 will ever really be implemented by management agencies — and it may not be. Section 208 management requirements may, in the long run, be so controversial and the political context in which the issues are likely to be resolved so complex, that the management question becomes the major one confronting the new planning units. Thank you very much. ------- Political and Institutional Variables Found in the Formation of the Twin Cities Regional Water Pollution Control System by Richard J. Dougherty Chief Administrator Metropolitan Waste Control Commission/Twin Cities Area Saint Paul, Minnesota presented September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- POLITICAL AND INSTITUTIONAL VARIABLES FOUND IN THE FORMATION OF THE TWIN CITIES' REGIONAL WATER POLLUTION CONTROL SYSTEM Richard J. Dougherty, Chief Administrator, Metropolitan Waste Control Commission/Twin Cities Area, Saint Paul, Minnesota THE PKOBLEMS A genuine environmental and political problem existed in the Twin Cities metropolitan area during the decades of the 50's and 60's. There are 3 major rivers flowing through the area (the Mississippi, Min- nesota and St. Croix), about 200 lakes scattered throughout the region, numerous streams and wetlands and an immense groundwater recharge area that provides the 7-county region with much of its water supply. Many of these irreplaceable natural resources were being polluted in one way or another. Water pollution was caused by thousands of on-lot disposal systems. Existing treatment plants, mostly inefficient and overloaded, discharged into lakes and rivers. Landlocked communities experienced restricted growth, inequitable service charges or no service at all. The political and physical fragmentation also caused a proliferation of poorly-operated treatment works. Commercial and industrial site locations and discharge points were uncontrolled. And preferential rate structures were prevalent for industry. To compound the problem, there were nearly 300 highly-independent political jurisdictions in the 3,000 square mile metropolitan area and a population approaching 2 million people. These governmental units included 7 counties, 75 school districts, 59 townships, 108 villages, 27 cities, 21 special districts and even 1 borough. In addition, a total of 125 major industries existed in the region. Over a period of years, a beginning had been made in the alleviation of water pollution through the formation of 6 semi-autonomous sanitary sewer districts throughout the area. Inter-community sewerage agreements had also been put into effect between a number of area communities. Most such agreements were ineffective and became self-serving with respect to other units of government due to a lack of specific legislative control of budgetary processes, cost allocation, personnel codes and so on. ------- It became apparent to governmental and civic leaders that further positive steps were required to bring the increasing water pollution problem to a halt. As a result, after working on the problem in 4 biennial sessions, the Minnesota legislature established the Metropolitan Council in 1967 as the area-wide coordinating and development agency of government. Working not as a "super government", but rather as a "broad brush" planning and review agency, the council was created to provide solutions to region- wide problems which local governments could not handle alone. The metro- politan council's first legislative charge was fulfilled when it proposed and brought to fruition the regional sewerage system concept for water pollution control. The regional system was made possible through active support from state legislators, public officials and citizen groups. The result of the work of the council and key legislators was the enactment, by the 1969 Minnesota legislature, of the Metropolitan Sewer Act. The act directed the council to establish the Metropolitan Sewer Board as an operating agency to implement legislative policy for the abatement of water pollution in the 7-county Twin Cities area. The sewer board lives on today with a different name . . . the Metropoli- tan Waste Control Commission. The commission presently operates a highly- successful regional water pollution control system of 20 wastewater treat- ment plants which provide at least secondary treatment to all locations and advanced treatment at a number of other locations. Because of this regional organizational set-up, the Twin Cities region has an enviable track record in all phases of water pollution control. Quantitative and qualitative analysis of 7 years of commission performance brings out some interesting points. 1. Only one of the original 33 treatment plants acquired met existing effluent standards in 1969. Today, these facilities have been con- solidated into 20 plants which all meet NPDES permit standards. Many installations have been upgraded and 3 totally new plants have been built. 2. A totally integrated river quality monitoring system expanded and operated by the commission disclosed that the water quality of all 3 major rivers has never been better, even during this summer of 1976 when the lowest recorded flows have been experienced. 3. The commission has been a major recipient of federal and state grants for 140 projects totalling nearly $250 million and has placed under construction and/or completed better than $150 million of construction for treatment works, interceptors and appurtenant facilities. 4. Large-scale research and development programs, only possible through the regional capability.of the commission, include physical-chemical treatment, modified tertiary treatment by phosphate removal and ef- fluent filtration, sludge-solid waste pyrolyzation disposal, varinip press processes for dewatering and energy conservation, and radio satellite transmission of river monitoring data. ------- 5. Establishment of a highly technical, nonpolitical staff of system managers has resulted in a merit system for encouraging high per- formance levels. Management by objective budgeting has resulted in cost-effective service to local units of government and area citizens. A series of important lessons relative to political and institutional variables have been learned through the Twin Cities experience. I believe, many of them are applicable to regional water pollution control systems in any part of the nation. In order to give you as many of these exper- iences as possible in a limited time, I am going to discuss a few of the specific components of our regional legislation that are essentials to any regional concept. THE LEGISLATION Given the fact that 8 to 12 years were spent in the Twin Cities region trying to decide on an overall regional organizational structure for water pollution control, we can safely state that the real, effective answer lies in strong, positive action by the state legislature. Joint powers agreements between 2 or more local municipalities did not work. A series of semi-independent sanitary districts could not do the job. The only viable alternative, in the face of today's tough federal and state environ- mental regulation, was a specific and direct piece of organizational legis- lation. This is, however, a regional set-up with a difference: In the Twin Cities, only those functions that can most efficiently be performed at the regional level are performed at the regional level. The introduction to the Metropolitan Sewer Act, therefore, bears reading. Metropolitan Sewer Act - Purpose and Responsibility "473C.01 LEGISLATIVE PURPOSE AND POLICY. The legislature determines that in the metropolitan area there are serious problems of water pollution and disposal of sewage, which cannot be effectively or economically dealt with by existing local government units in the area under existing laws. The legislature, therefore, declares that for the protection of the public health, safety and welfare of the area, for the preservation and best use of waters and other natural resources of the state in the area, for the prevention, control and abatement of water pollution in the area and for the efficient and economic collection, treatment and disposal of sewage it is necessary to assign to the Metropolitan Council the responsibility of carrying on a continuous, long-range program of planning with respect thereto and to establish a sewer service board, which together with the council, can take over, acquire, construct, operate and maintain all inter- ceptors and treatment works necessary for the collection, treatment and disposal of sewage in the metropolitan area." THE POLITICAL ORGANIZATION We firmly believe the organizational set-up of our Twin Cities opera- tion is now, not only the most acceptable politically, but also the most ------- effective - politically and otherwise. The council-commission relationship provides the checks and balances system to ensure legislative charges and policies are properly carried out. Political orientation or domination is virtually impossible. One hundred urbanized and developing municipali- ties are provided direct, physical service by the regional interceptor sewer and wastewater treatment plant system operated by the commission. These local units of government and the 7 counties they are located in are highly independent and quite rightfully, go to great lengths to pre- serve their local autonomy. The political organization of the waste con- trol commission complements local autonomy by not infringing upon it. At the same time, however, the following specific powers are held by the commission to enable us to do our job properly. 1. The chairman is appointed by the governor and must be a resident of the metropolitan area. 2. Eight commissioners are appointed by the inetro council on the basis of equal population state senatorial districts - the 1-man, 1-vote principle. 3. The chairman and commissioners are all voting members. The chair- man may be full- or part-time, commissioners are part-time. Com- pensation of the chairman is made by the commission. Commissioners are reimbursed on a per diem basis. 4. A chief administrator is selected by the chairman subject to approval of the full commission - chosen solely on basis of training, experience and other qualifications and serving at the pleasure of the commission. The administrator has no voting powers, but appoints and removes, sub- ject to the personnel code, upon the basis of merit and fitness all other officers and employees who carry out all duties, policies and functions of the commission. 5. The commission and metropolitan council established service areas generally, but not exclusively, along watershed lines or treatment service area lines. For each service area an advisory board is ap- pointed to advise and review plans and programs with the commissioner representing that area. POLITICAL ACCEPTABILITY ENCOURAGED BY CLEAR LEGISLATION The political acceptability of the commission and its establishment of the Metropolitan Disposal System was in large measure a result of the legislative provisions that set forth a series of specific requirements. 1. Acquisition of all treatment facilities and the method of acquisition including existing debts. 2. The dissolution of all existing sanitary districts and joint powers agreements by a specific date. ------- 3. Commission ownership of any acquired facility entitled the previous owner to receive credit with interest against amounts to be allocated to it for current costs. 4. The Metropolitan Council set up a policy plan for the commission which is subject to comprehensive review and/or amendment every few. years. Any revisions are subject to the full public hearing process. 5. The commission prepares a development program which covers all detailed technical planning, engineering, financing and scheduling undertaken by the commission to carry out the policy of the council. Any local unit of government may request a public hearing upon the program which shall be submitted to the council for review and approval. 6. The commission submits the capital improvements (development program) budget to the council for approval each year. The commission's annual operating budget may be reviewed and commented upon by the council. The commission's annual budget must be in the program budgeting format subject to approval of the council. All budgets are subject to the public hearing process. 7. Each local government shall submit a comprehensive local sewer plan subject to review and approval of the commission. All local sewer extensions must conform to the approved comprehensive sewer plan which may be amended at any time subject to approval of the commission. 8. Connections to the Metropolitan Disposal System may be required by the commission. 9. Cost allocations to each unit of government must cover all current costs which are defined as the cost of operation, maintenance and debt service paid each year by the commission, including costs of acquisition and betterment of the system. 10. Costs for current use are allocated to each unit of government in proportion to its use of the total interceptors and treatment works based upon volume. In addition, each unit of government is allocated costs for reserve capacity assigned to it based on the cost of acquisi- tion, betterment and debt service only after having been first reduced by service availability charges received by the commission. 11. The commission may request the Metropolitan Council to sell bonds to finance the local share of development program projects. If the council approves, they sell bonds for the commission, including emer- gency certificates of indebtedness, if needed. TWO INGREDIENTS REQUIRED FOR SUCCESS IN REGIONAL PROGRAM It has been my experience that 2 basic ingredients are essential to suc- cessfully implementing a regional system on a timely schedule. I identify these ingredients as community and personal relations. ------- The first, community relations, starts with the very concept of a regional system. It is imperative that the recjional body view itself as a manager, not the owner of the regional system. The regional body must be capable of dealing fairly, openly and equally with each unit of government involved in the system. The axiom that . . . "what you do for one you must be prepared to do for all ..." must be adhered to. The Twin Cities' regional legislation supplies a perfect example: The legislature provided a single formula for the acquisition of all existing facilities. Called the "Current Value Credit," the formula provided for all facilities required for the Metropolitan Disposal System to be acquired at the precise current value of the facility. The current value in all instances was determined by taking the original cost including construction, engineering, legal and other administrative costs; less any part of the facility paid from federal or state funds; less the principal amount of any outstanding bonds issued to finance its construction. The original cost, as established, was multiplied by a factor equal to a current cost index divided by the same cost index at the time of construction to determine replacement cost. The cost indexes used were from the Engineering News-Record and U. 5. Public Health Service for sewer and treatment plant construction. The current value of the facility was then adjusted by the cost of depre- ciation of 2.5 and 1.25 percent per annum for treatment plants and sewers respectively to yield the actual replacement costs. This process sounds complicated; however, it was the essence of a mutual trust and bond between the regional management and local units of government and thus, a political relationship in its pure definition of the term "political" or community relations. The second essential characteristic, personal relations, is that arrangement between the appointed chairman and commissioners and the operating staff. The duties of the commissioners must be clearly defined. Even more impor- tantly, the commission membership should have a broad spectrum of back- grounds including business, financial, engineering, legal, labor, government and personnel. A Rotarian or Kiwanian cross section is a must. This provides the broadest policy analysis and guidance to the operating staff. Commissioners must be or should be persons of established accomplishment in their own fields who have the desire and time to dedicate themselves to public service. A balance membership as described is the key to a viable regional system. In terms of the associated personal relations, the operating staff must understand that it is subordinate to the commissioners and they are the managers only for the local units of government. Staff operating within this framework will seldom find itself at odds with the commission and local governments; it will also find majority support when tough decisions are required. ------- SUMMARY By going the route of performing only necessary Operating functions at the regional level and then clearly defining all necessary functions and relationships as in some of the examples I have- just given, the Minne- sota legislature and the supporters of the regional water pollution control concept ensured support from most of the local governments and officials in the Twin Cities region. As noted, however, it took better than 8 years to find the proper set of political and institutional variables to gain enough support to actually establish the regional system. It is obvious that the political structure is essential to an effective regional water pollution control system. It is my opinion that certain regional or political forms are more accept- able than others. The Twin Cities' format, I think is a median type between a totally independent utility (public or private), a contract format between the local governments, industries, etc. and the authority such as Pittsburgh's Alcosan and local government officials serving as commissioners and the elected commissioner form. After my working exper- ience with the Twin Cities and Pittsburgh forms and observations of others, the Twin Cities political form best melds the political and institutional variables. There are a number of objections to regional concepts that stand out in my experience, most of which are emotional rather than quantitative or qualitative. Some of these are: 1. Private interest can do it better. 2. Local government is more responsive to people. 3. Regional dynasties are created. 4. Only elected officials should be permitted to authorize bond sale rate structures, etc. 5. Deep concern over purchase price or value of existing facilities to be paid by the regional body to the local government or owner. 6. Equitability of service charges; usually an argument between the older communities versus the growing communities or suburbs. 7. Reserve capacity charges. These are the most common in my experience. The Minnesota legislature dealt effectively with these problems and the commission implemented the policies openly, fairly and effectively. I do not believe EPA or PCA orders affect the political structure normally. I presume, however, political strategy can be used by both political organizations and persons and/or business and industries. With respect to the appointed versus the elected political format, I have reached a firm conclusion, which I may state is shared by my past ------- chairman, who for many years was an elected official, but appointed as chairman of the commission and the speaker. My conclusion is that if you provide a commission with a membership of dedicated, well-qualified members with sufficient professional backgrounds, you will have a highly viable and successful region. Members who do their homework without political orientation will serve best. I firmly believe, as I mentioned earlier, that much of the Twin Cities' experience in regional political organization can be applied to the benefit of nearly any part of the nation. ------- Political/Institutional Variables SUMMARY OF DISCUSSION SESSIONS Moderated by Fred A. Harper General Manager County Sanitation Districts of Orange County, California on September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- POLITICAL/INSTITUTIONAL VARIABLES Summary of Discussion Sessions Moderated by Fred A. Harper, General Manager, County Sanitation Districts of Orange County, California Of the four major topics of discussion at the Symposium on Implementing Regional Wastewater Management Plans, the problem of the political and institutional variables generated the most interest and concern. Through- out the conference, the importance of addressing the political side of the issues was constantly repeated. Following the opening remarks at each of the two discussion sessions devoted to the political and institutional variables involved in implement- ing regional wastewater management plans, participants were asked to identify their agency affiliation and the primary points they were seeking to have covered in the workshop. The more significant of these points provided a topical guideline for discussion purposes. Because of the broad array of issues raised and the relatively short duration of the workshop, it was not possible to develop specific answers to many of the questions. Following are the more definitive positions on, or answers to, questions that were developed during the course of the sessions. 1. The creation of a regional agency is a difficult and painful process. Existing jurisdictions relinquish responsibilities very reluctantly and will often maintain bitterness over lost responsibilities for a long period of time. A new regional agency inherits all of the political animosities of its constituencies, many of whom have old bones to pick over issues which are not even relevant to the objectives of the regional agency. Because of the difficulties of creating a regional agency, successful regionalization must be predicated on the following: a. The regional agency must fill a clearly defined and recognized need. b. There must be a strong personal commitment to attain regionali- zation on the part of the elected officials and key members of institutions that are involved in the regionalization. ------- 2. There are two major concepts of regionalization. The first concept is one where the regional agency acts as a wholesaler of services to existing jurisdictions. These jurisdictions then continue to interface with the public on a "retail" level while acquiring their actual major capability from the regional agency. The second concept is a complete consolidation, wherein the regional agency provides the service and the interface with the customer. The proper political and institutional framework for each of these concepts is quite dif- ferent, as the method of operation and agency objectives are quite different. 3. The participants defined five general institutional forms which are available for regionalization: a. Elected Commissions or Boards b. Appointed Commissions or Boards c. A Contractual Arrangement to Provide Services d. A Governmental Body e. A Federation of Elected Officials There was no consensus on which of these institutional forms is the most politically acceptable. It is apparent that there is no univer- sally correct structure, but rather that the specific form selected for any regionalization activity is a function of the particular circumstances surrounding that regionalization. There did seem to be a strong feeling that intergovernmental agreements are not a satis- factory solution to regionalization. This is particularly true if the number of governmental jurisdictions is large. Interest was also expressed concerning the compatibility of institu- tional forms that are most politically acceptable and those that may work the best from a management standpoint. 4. In creating a wholesale/retail concept of regionalization, one of the more difficult aspects is a determination of what resources belong to the regional agency and what resources belong to the surviving local jurisdictions. One concept proposed is that interceptors (or any other resource) serving two or more communities belong to the regional agency. Another concept suggested was that any pipe larger than a certain diameter belongs to the regional agency while any pipe smaller than that diameter belongs to a local jurisdiction. These definitions must necessarily be worked out prior to the creation of a regional agency. 5. Probably the most substantive issue raised and one which was the subject of much discussion, was the issue of properly structuring the board of a regional agency. If the agency has taxing authority, or can be construed as having taxing authority, then the issue of equal representation under the law becomes a constitutional question. The constitution provides for the concept of "one-man, one-vote" and a regional board must be structured to be responsive to that requirement. This can be a particularly difficult problem in region- alization encompassing numerous political jurisdictions. If the sma lest jurisdiction is provided with one vote, then the laraer ------- jurisdictions must have a proportionately larger vote, and the resul- tant board then becomes very, very large. References were made to boards with 40 to 70 directors. Boards of this size become particu- larly unwieldy to deal with on a day-to-day basis. The best solution suggested to respond to the "one-man, one-vote" requirement is to constitute a board on the basis of legislative districts as opposed to political jurisdictions. Assuming that legislative districts are reapportioned on a timely basis, this automatically responds to the "one-man, one-vote" issue. It has the additional advantage of providing representation for an area, as apposed to a political jurisdiction and thereby eliminates certain petty bickering which can occur over jurisdictional prerogatives. ------- Implementing Regional Wastewater Management Plans: The Financial Considerations by John A. Lambie Chief Engineer and General Manager Ventura Regional County Sanitation District, California presented September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- IMPLEMENTING REGIONAL WASTEWATER MANAGEMENT PLANS: THE FINANCIAL CONSIDERATIONS John A. Lambie, Chief Engineer and General Manager, Ventura Regional County Sanitation District, California The financial considerations that lead to the regionalization decision by individual agencies are: 1. What is the current financial status of each agency and how will it be benefited by the regional service? 2. How will it be improved and can the agencies go it alone? 3. What is our equity in the existing facilities and what is on the books minus the grant? 4. How will each be reimbursed for our present treatment plant improvements? 5. What will the immediate and long-range effects be? In discussing the regional district with funding agencies, such as the EPA and the state, and with both the entire region and the prospective individual agencies in Ventura County, the response has been excellent. Regionalization can solve some of their problems while resolving ours. The state and federal agencies are tired of receiving applications for grants from neighboring cities or agencies which conflict with each other. This causes adverse comments and political problems. The recent response to our case, where we represent 26 agencies who have agreed to and sub- scribe to a regional plan, has been refreshing. The funding agencies have confidence that project approval can be accomplished without gaining as many enemies as friends. Federal (75 percent) and state (12 1/2 percent) grants, without a question, have assisted the progress of regionalization. In my opinion, decisions are accelerated because grants are available and the regional plans are being realized. FINANCIAL CONSIDERATIONS One of the probems of producing a satisfactory financial plan for consoli- dation of sewerage agencies is the rapdly-rising construction costs. It is ------- most difficult to present a financial plan to a council or board which includes the inflation rate of 7 1/2 or 8 percent. Often, they will compare alternate financial plans which ignore inflation completely, use a different figure, or say, "We base everything on 1976 dollars". The same is true of rapidly rising operating costs. In the Ventura Regional County Sanitation District financial plan, the indebtedness is to be paid by the use of the connection fee. The plan is for the regional agency to assume the debt by the use of contracts of 20 years duration at a nominal interest rate of 5 percent. The in- debtedness of current bonds of each city or district is assumed and the regional district will make these payments when due from the funds received from the connection fees. The abandonment of capital facilities is a very difficult matter to address, especially to councils that are proud of their treatment plants. However, you must start somewhere and we started by developing a fine Regional Master Plan of Sewerage Facilities which is consistent with the State 201 Facilities Plan for Basin 4B. Now with the state and EPA funding plans consistent with the regional plans, new capital facilities were scheduled. A construction program was established for new facilities. This is constantly kept in sequence with the state and federal capital project funding program under Public Law 92-500. Naturally, there had to be certain facilities abandoned if the true economy of a regional system was to be realized. To repeat, old capital facilities are planned for abandonment as the new facilities are constructed. I'll now answer some of the questions that were submitted to me by the conference chairman. Do You Have a Regional Financing Authority? None has been created until the present time. However, a regional financing authority is planned. Small subregional financing authorities may also be the answer to local problems. In this manner, the broad base of the regional district's assessed valuation of nearly $2 billion could be used to provide greater assistance to small agencies. What Experience Have You Had in the Assumption of Debt in a Regional Agency? None in Ventura County. However, my previous experience in Los Angeles County held numerous examples where the debt was assumed by a regional water works district or sewer maintenance district, or the reverse situa- tion where there was a transfer of facilities from the county to a city. What Experience Have You Had in Transferring Capital Investments Between Agencies? None in Ventura County. However, nearly 1/2 of our agencies (26) have indicated a desire to enter into the regional system. ------- Have You Used an Equalization Formula? Yes. In our presentations to each of the city councils and agencies, we use an equalization formula. I have also used a similar formula prior to working in Ventura County. How Are Decisions Made By Your Agency on Consolidating Facilities? The consolidation of facilities must be consistent with the master plan which has been adopted and is consistent with the state and federal plans and guidelines. Have You Been Able to Meet Increasingly Strict Requirements? No. This is one of the most difficult matters that we have to work with. The cities, county and districts have just finished an update of their sewerage treatment plants. Even before completion, all were given notices to upgrade their treatment plants. These changes in the requirements will require considerable capital improvements for compliance. SUMMARY The Ventura Regional County Sanitation District, which was formed in 1970 and activated in 1971 for the purpose of consolidation of local sewerage facilities into a regional system, is progressing slowly but satisfactorily. Although the district was formed after over 5 years of public meetings and hearings throughout the county and with less than 5 protests out of nearly 1/2 million people, it is most difficult to fulfill the tasks for which it was created. Its purpose is simple. It is to develop a regional system for the handling of solid and liquid wastes and provide sewage treatment and disposal only. There are no collector systems in the district. Hence, whether through sewage treatment or liquid and solid waste disposal, we are truly regional in character, wholesale only. With the retention of local collector systems, there has not been a loss of home rule. Each city, district or agency makes its local decisions as to who shall use the facilities and each agency is represented in the regional district. At first, we considered the size of the board to be unwieldy, too large, of uneven voting strength and a violation of the 1-man, 1-vote principle. The advantages of each agency being represented and being a part of the decision-making process is, we believe, swinging the unequal voting strength proponents to our favor. Our relationships with each member agency are by contract and there is the secret to equality of treatment. A contract is an equalizer. Further, the regional district board operates with 5 committees to promote member participation and involvement. They are: finance, personnel, advance planning, engineering and construction and operations. The opera- tions committee is composed of the chairman of each committee mentioned plus the chairman and vice chairman of the regional district board. The committees usually meet the week or a few days prior to the regular board meeting. The board members then make the committee comments and the chief engineer-general manager's recommendations to the board. If ------- a matter requires consideration of more than one committee resulting in an impasse, the operations committee will meet. Monthly meetings are held in the evening on the third Thursday of each month to conduct the affairs of the regional district. In our 5 years of being, we have developed first an interim and then the Master Plan for Sewerage Facilities; an interim and then the Master Plan for Solid Waste Management; a Financing Plan for the Consolidation of Sewerage Facilities; taken a complete inventory of all wastes generated within the district; and are currently operating 3 treatment plants, with several more being considered under contract. We have also been designated as the Area-Wide Waste Treatment Management Planning Agency by the Governor and EPA under Section 208 and are currently involved in development of the Regional Land Use Plan, Air Quality Maintenance Plan and Area-Wide Waste Treatment Management Plan for Ventura County. ------- Financial Considerations SUMMARY OF DISCUSSION SESSIONS Moderated by Jack H. McMinn Vice President Bartle Weils Associates Project Manager for the 1970 Financial Plan for the Unified Sewerage Agency of Washington County, Oregon on September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- FINANCIAL CONSIDERATIONS Summary of Discussion Sessions Moderated by Jack H. McMinn, Vice President, Bartle Wells Associates Financing is always a critical element in the implementation of a regional wastewater management plan. As the moderator pointed out in the Symposium's discussion session on financial considerations, five critical financial questions need to be resolved: 1. Who is going to do the financing? 2. What are they going to finance? 3. What is the amount to be financed? 4. How is it to be financed? 5. When will it be financed? The procedure selected must insure sound management programs, sound financing programs and the ability to implement the project. The participants generally were concerned about the equitability of exist- ing entities' rates where facilities exist which are to be utilized and/or abandoned. Considerable discussion involving solutions to regionalization of entities with these situations was held. It was agreed that no two projects would solve these problems in exactly similar ways, since polit- ically different methods may be desired. It was interesting to note that very similar solutions to regional systems were financed in many different ways. The agency for financing the facilities may be a single entity, either a joint powers agency or a regional or subregional agency of some type put toqether from a number of individual agencies. What is to be financed is a function of the needs and desires of the public and the amount to be financed must include cost of the design, cost of construction, cost related to legal affairs and financing arrangements and, if a bond issue is involved, a reserve fund or financing of interest during construction if the facility is financed by future revenue. A project can be financed a number of ways. In the wastewater field numerous grants are available: federal and in some states, state grants; loan programs such as the Wastewater Cleanwater Loan Program in the State ------- of Oregon; cash reserves of the agency; and debt financing. Usually financing works out to be some combination of these methods. The question of when to finance relates to the cash flow requirement. Generally bonds are used if it is debt financing. Bonds are sold very early at about the same time or even preceding the actual construction of the facilities to provide some cash flow. A secondary consideration usually is minimizing competition with other agencies who are seeking capital with relation to bonds. Capital financing requires the borrowing of money through the sale of bonds or some other financing vehicle, general obligation bonds, revenue bonds, special assessment bonds and in some cases, waste- water facility public authority bonds and nonprofit corporation bonds. These are forms of long-term debt financing. With respect to short-term, there may be tax anticipation notes and medium-term financing or a promis- sory note that might go out for five years or more. There are other grant and loan programs that are less significant than the Public Law 92-500 program. Money is available from the Farmers Home Administration in certain cases, and from HUD's Community Development Block grants. More recently the Economic Development Administration public works program for encouraging employment may make funds available for people who are in a position to immediately implement a construction program. Discussion was also held and questions asked about annual revenue sources and service charges. Most agencies have the ability to levy service charges, connection charges, standby charges, interest income and miscel- laneous income and property taxes. Another important element in most of the financing plans for regionalization is Equalization Compensation. In terms of public involvement, this factor becomes a part of the sales program to demonstrate that everyone is being treated fairly and also to justify the sharing of revenues and expenses and a uniform system of rates and charges throughout the service area. This program, in turn, assures that nobody benefits unfairly as a result of their geographic location with respect to treatment facilities. Also, the money that is generated from growth wherever it occurs is used as one source of revenue to help pay off the equalization program. ------- The People Problem: Management and Operations by Robert J. Borchardt Chief Engineer and General Manager Metropolitan Sewerage District of the County of Milwaukee, Wisconsin presented September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency I ------- THE PEOPLE PROBLEM: MANAGEMENT AND OPERATIONS Robert J. Borchardt, Chief Engineer and General Manager, Metropolitan Sewerage District of the County of Milwaukee, Wisconsin The title of this discussion, "The People Problem: Management and Opera- tions," could very well have a subtitle, "The Public Entity and Dealing with the Public." I would like to forewarn you that I'll be editorializing quite extensively, so the caution is that "what might work for us, might not for you." However, if you can utilize in any one of your jurisdic- tional areas just one of the ideas that I present, then I will be com- pletely satisfied. COMMUNICATIONS CRITICAL ELEMENT We are all aware that communications today is a vital tool to use in drawing attention to a problem and in offering solutions to that problem. It is a wise administrator that develops these lines of communication, up, down and laterally, both within and outside the organization. When dealing outside the organization, I prefer to call communications publicity, public involvement as opposed to public relations. In govern- mental operations, the public is somewhat wary of public relations efforts, the hard sell, the image improvement. With all deference to anyone's political affiliation, I call this the "Watergate Syndrome." It seems that when something detracting happens in the highest echelons of govern- ment, that all areas of government are swept up in the backwash. Credibil- ity is further strained and it causes an extended effort on the part of the agency to re-establish credibility in operation and administration. Certainly a gap in communications does not spell success in creating public awareness of problems or solutions, nor does it spell success in achieving credibility. Therefore, it then becomes a question of how to correct this situation. It would seem highly desirable to resort to tried and proven methods, but there is no "cookbook" recipe, nor has chapter and verse been written. One must then develop innovative thinking and progressive methods to carry the activity through to a successful completion. ------- Not too long ago, I was conversing with an engineer-type colleague on the way to a meeting and as a variety of subjects are prone to being discussed, we talked about the Middle East situation, desegregation, school bussing and so on. My comment to my companion was, "This whole society seems to be full of ignorance and apathy! What do you think, George"? After a few moments, he stated, "Well, I don't know, Bob, and I don't think I give a damn"! Needless to say, I was somewhat taken aback, in spite of the humor. So it would appear then that we've got our work cut out for us. Shortly after being appointed chief engineer and general manager, I had to somehow demonstrate that we were moving beyond "the business as usual" concept. I felt that there was a need to develop a public awareness of our operation, because future solutions to the environmental problems of the metropolitan area would cost a considerable amount. You can call it what you like, "psyching out," or whatever, but the bottom line is public involvement. We formed a technical coordination committee, composed of selected profes- sionals and technicians from within the district, to serve as a sounding board for our proposed developments. Just recently, we started to work with a Metropolitan Sewerage District Development Task Force, a group of selected governmental representatives from the area. These groups cover both the professional arena and the political arena. Decision making in our area of operation involves both arenas; any decisions, be they professional or political, have to be made separately, before being brought to the other area for acceptance. Professional decisions have to contain a cost-effective analysis ingred- ient, and have to present a final recommendation based on research of alternative solutions. Decisions made in the political arena include financial practicability, feasibility in timing and level of state or federal aid. The district's responsibility in utilizing these advisory groups is to lend constant motivation to the decision-making process, narrow the issues and move the programs forward. Taxpayer groups, regu- latory agencies, financial development groups, labor organizations and environmentalists must be brought together in the same forum to discuss the problems and analyze the solutions. I previously mentioned public relations and public involvement. We have had some success recently, in one of our major projects, the Combined Sewer Overflow Pollution Abatement Program, being studied by our district, with the able assistance of the consulting firm of Stevens, Thompson & Runyan, and the methodology in involving the public. I do not imply that we are involving the general public in the decision-making process, something that the agency alone is responsible for, but rather, in public awareness through an extensive district-sponsored publicity campaign with displays, meetings, talks, editorial conferences and so on. We have been able to shed quite a bit of light on this major environmental problem. The media, needless to say, both the electronic and the written are strongly encouraged to become part of the picture, to fulfill their responsibility to the community. This allows the agency to tell its ------- story, highlighting the problem and ensuring that the solution to it will be thoroughly investigated to justify the expense that the taxpayer ultimately will have to support. In our particular area of operation, the foregoing is innovative. We are a special interest governmental entity operating within, and cooperating with, other separate municipal corporations characteristic of major metro- politan areas. The tendency existed heretofore that we became somewhat arbitrary in our thinking because of our highly specialized area of opera- tion. The sophisticated procedures and methods utilized in addressing environmental problems and the complex nature of the operation itself, do not allow a readily understandable scrutiny by the general public. Therefore, we felt it necessary to engage in an educational campaign in matters related to pollution abatement, in addition to justifying expenditures. HOW THE SEWERAGE COMMISSION WORKS IN MILWAUKEE To serve as some background in this discussion, a brief scenario as to the formation and operation of our 2 commissions would be in order. The metropolitan area of Milwaukee is divided into 3 drainage areas, the Milwaukee, the Menomenee and the Kinnickinnic rivers, which flow through the area from the north, the west and the south, respectively, and unite at a point near their combined outlet into Lake Michigan. Before 1925, when the treatment plant at Jones Island was put into opera- tion, the sewage and industrial waste from the city and its suburbs were discharged through combined sewers directly into the 3 rivers. This discharge would then flow into Lake Michigan. Predictably, the pollution carried by the rivers through the heart of the city created a significant health hazard, to say nothing of the odor nuisance. The first attempt to remedy the pollution of the rivers and lake caused by the untreated sewage was the construction of flushing tunnels to pump large volumes of lake water into the river outlet. While the flushing did dilute the pollution and reduce the odor nuisance, the more serious problem of water supply pollution and the consequent health hazard remained. Following state enabling legislation in 1913, the City of Milwaukee estab- lished a sewerage commission empowered to construct and develop a sewerage system and treatment facility within its borders. Proposals were soon made that the plant and intercepting system handle the sewage from all communities in the immediate tri-river drainage area because upstream pollution by the suburbs could perpetuate the very problem that the proposed facilities were intended to eliminate. The initiative for a metropolitan system came from the suburbs, a number of which were faced with large expenditures for sewerage facilities that exceeded their legal debt limits. The city was receptive to the idea because the con- struction of the sewer system was also proving more than its own financial resources could bear. With support from both sources, Metropolitan Sewer- age Commission was created by state law in 1921, for the purpose of con- struction of sewer line mains, outside the central city, to connect the ------- various suburban districts to Milwaukee's intercepting sewer system and its disposal facilities. The law provided that the city would be reim- bursed over a period of years for the suburban areas' proportionate share of the costs of constructing the disposal plant and the intercepting system. The metropolitan district was enlarged in 1959 to include all of Milwaukee County. Its jurisdiction was further expanded the next year, when the 2 commissions authorized contracts with municipalities outside Milwaukee County for the transmission and treatment of sewage from territory within the drainage area of the district. The City Sewerage Commission consists of 5 members appointed by the Mayor, with Common Council approval, for terms of 5 years. The Metropolitan Sewerage Commission has 3 members appointed by the Governor for 6-year terms. Although the 2 agencies are organizationally separate, they operate administratively as one unit. At the time that the Metropolitan Commission was created, it was provided that the City Sewerage Commission remain in existence with jurisdiction over all facilities within Milwaukee city limits. It was also provided that the City Commission's staff and work force become the operating agent for the larger district. Both bodies are served by the same chief engineer and general manager, the same secre- tary and the same organizational personnel. Moreover, it has been common practice to have one member serve on both commissions, so as to provide an additional means of coordination and liaison between the 2 bodies. This dual arrangement has prevailed up to the present day despite numerous attempts to consolidate the 2 agencies, or transfer the total sewerage function to the county government. EXPANSION OF THE DISTRICT SYSTEM Our procedure during the district expansion, in eliminating other opera- tional plants, followed these lines. If the plant that was to be eliminated through system expansion was a municipal operation, through their public works department, the management and staff of that plant was ultimately assimilated by the municipality involved. As we were not prepared to immediately serve the area taken over through expansion, we reimbursed the municipality for its actual cost of operating and maintaining the plant until it, in fact, was elimi- nated. The plant property, of course, remained in the ownership of the municipality. In a situation where the district absorbed a smaller district through expansion, we placed the staff of the smaller district on our own payroll during the interim period before plant elimination. After the point of plan abandonment, we absorbed the remaining staff in our organization placing them in related positions. This transfer, of course, had to ' be negotiated with the bargaining unit responsible for plant operators However, the solution was worked out to the satisfaction of all parties concerned; the seniority used for the absorbed employees was the date of the legal assumption of jurisdiction over the smaller district. ------- In this case, the board members of the smaller district, who served without remuneration, upon takeover by the district, no longer played an active role in matters related to the smaller district, except to advise our board members during the interim transition period. COLLECTIVE BARGAINING IN PUBLIC AGENCIES Just a few brief comments on the collective bargaining unit in public agencies. In 1965, municipal corporation employees in the State of Wisconsin were given the right to bargain with their employers. I must say that a mini- mum of municipal employers were ready for this program. It brought an entirely different philosophy into the spectrum of agency operations that previously did not exist. Pursuant to this injection of municipalities into the collective bargain- ing field, the 5 major taxing units of the metropolitan area formed a group from the administrators of each of the agencies, to establish common denominators in benchmark position salaries, pensions and fringe benefits. It was at this time and still is, imperative that the 5 taxing units present a common front in negotiations. If one of the parties breaks the settlement pattern, the others then have to suffer the consequences of "whipsawing," or giving that little bit more to effectuate a settlement. In addition, the negotiation exercise, on the part of the employer, must be placed in the hands of the experts, who can utilize all of the avenues of research, investigation and comparison that are available. The art of negotiations is best left in the hands of seasoned veterans, who are adept and knowledgeable, more so than the uninitiated. To ward off any problems with personnel who are not represented by a bargaining unit, the major taxing units have felt it necessary to award the same settlement to these people as was negotiated with the major bargaining unit. With multiple unions, we have attempted to standardize fringe benefits and any increases therein, including pensions. Negotiations with the major union, on fringes, are applied across the board. We attempt to maintain a standard percentage wage increase throughout. Of course, the cents/hour figure will be different based on the average hourly rate of the unit. More and more, operational agencies in our metropolitan area, including our own district, are looking toward cost savings developments, either through automation, instrumentation, or central control. With rapidly escalating costs in operation and maintenance and the fact that labor's total package cost represents over 60 percent of operating and maintenance expenses, I feel that the charge to trim costs is entirely valid. These developments toward larger and more complex facilities cause the agency to search for more sophisticated operating and maintenance personnel. ------- Training programs have to be initiated for in-house personnel. There is more dependency also, on retaining outside staff augmentation on a temporary, as needed, basis. Due to the complex nature of our line of business, I don't feel that there could be a one source, manpower pool to adequately serve the needs of our agency. On the other hand, there could be a specialized reserve of manpower maintained by an agency, devoted to 1 or 2 facets running through all agencies, who could augment staff during times of need. The cost-effectiveness of staff augmentation, as opposed to permanent staff enlargement, should be a determining factor in the agency's decision- making process. SUMMARY In summary, there is much more need for the manager in a governmental agency today to attune himself to the needs of the community, through communication. The general public must be made aware that the agency is making all attempts to address and solve the environmental problems with realism and respect for the community's ability to pay. We, in operational agencies, must establish effective dialogue with the regulatory and funding agencies. I have to say that I have only been able to scratch the surface on a variety of items. Perhaps, during some of our further discussions at this symposium, I can be more specific in areas that you might choose. ------- Management/Operations: The People Problem SUMMARY OF DISCUSSION SESSIONS Moderated by Penelope A. Wilson Special Assistant to the Executive Director Municipality of Metropolitan Seattle on September 9,1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- MANAGEMENT/OPERATIONS: THE PEOPLE PROBLEM Summary of Discussion Sessions Moderated by Penelope A. Wilson, Special Assistant to the Executive Director, Municipality of Metropolitan Seattle Problems of dealing with employees, managers and board members who formerly were associated with local service districts or cities which were brought into a regional plan were discussed at the management and operations sessions at the Symposium on Implementing Regional Wastewater Management Plans. Although participants acknowledged the need for public awareness and concern in the successful implementation of a regionalized wastewater management plan, the thrust of this discussion dealt with people who were individually affected in their day-to-day livelihoods or community responsibilities by an implemented plan. Questions and the ensuing discussions presented to the group were as f ollows: WHAT ARE THE MAJOR PEOPLE PROBLEMS IN REGIONALIZING? Preserving the identity of workers, managers and public board members who represent agencies that are affected by regionalized plans is a major concern for the management of the regional institution. People who are brought into a consolidated operation many times have felt that they have lost their identity in their local community and sometimes feel that this lost identity is reflected by a lessening of the community pride in them and the work they do for the community. Regionalized agen- cies, where consolidation has occurred, find that they must deal with operations, management and policy-making people who have different levels of experience and training. New training in many instances has to be implemented and standardized classifications for employees need to be established. It has been found that job enrichment has developed into a problem in dealing with workmen who formerly had general duties, but after consolidation find that they are becoming specialized. The common report was that such personnel begin to find their daily tasks quite boring and without variety. Sometimes the result of this is dissatis- faction by the workman to the point where he takes other employment. ------- HOW DO YOU DEAL WITH MANAGERS, STAFF AND BOARD MEMBERS WHEN DISTRICTS MERGE? In many instances the board members, managers and staff remained the same and kept many of the same duties unless their institution was absorbed into original agencies through the vehicle of consolidation. When this is not the case, many states have legislation which requires that the regionalizing agency take all former employees of local districts into the regional agency's payroll. Where employed staff is consolidated, it is nevertheless not unusual to see that district board members remain on their boards with only an office staff remaining. District managers have remained in their positions with the same responsi- bility and salary, but sometimes the operations of the district are dimin- ished, as when treatment plant responsibility is taken over by a regional agency. In many cases the regional agency does not deal with the individual customers in a direct way; rather it acts as a wholesaler of some kind of service to local agencies, who in turn maintain local contact. HOW DO YOU DECIDE ON WHICH STAFF TO KEEP? Legislation required that in some states all the employed staff become employees of the new agency. This has resulted in the new agency having an excess of staff, but this matter eventually takes care of itself through good management practices. For instance, the staff members who the agency really wanted to keep are the kind of people who would grow with the agency, while the indifferent to substandard performing employees have either left the agency eventually or stay on at the original entry level. It was agreed that it would be inevitable that there would be personnel inefficiency in a newly-formed, consolidated regional agency. Attrition eventually seems to level off the overstaffing problem, while in other cases the excess staff has been absorbed as the agency expands in its operations. There was some agreement that some kind of payroll inefficiency might have to be accepted for a period of three to five years. WHAT ABOUT UNEQUAL SALARY LEVELS, PENSION PLANS AND BENEFITS? The experience of some of the seminar participants suggests that it takes about three years for unequal salary levels to even out and for a good salary plan to be fully in operation. This, of course, depends on the size of the agency and the initial qualifications of its staff. It was pointed out that in some instances the requirement for certification of treatment plant operators, when made after the agency has formed, has made it easier for the agency to fit its personnel into more appro- priate positions of responsibility and salary. As for pension plans, one agency reported that the consolidated staff was given the choice of either staying with its former plan or going with a new pension plan to be established by the agency. It was found that benefits under the two plans were similar and in some instances the agency's plan was better. The consensus was that if employees consolidated into a regional plan had been enjoying a pension prior to consolidation, then they should be pro- vided with similar benefits after consolidation. ------- HOW DO YOU DEAL WITH MULTIPLE UNIONS? This seems to be a growing problem as more public employees become union- ized. Not all regional agencies deal with multiple unions and in fact at least one agency reported that it dealt with only one. The need to have good labor law attorneys involved with union problems and negotiations was stressed. DO PEOPLE OR MANAGEMENT THEORY DICTATE THE ORGANIZATION STRUCTURE OF A NEW REGIONAL AGENCY? The general consensus was that both theories dictated the organizational structure. The stress depends on the primary concern of the agency as it evolves over the years. For instance, one agency reported that in its early years its operation was primarily concerned with construction. This reguired a large proportion of the staff to be engineers, planners and construction specialists. After the agency's facility was constructed, then the emphasis shifted to management and operations and this was re- flected in a shifting of the percentages of kinds of jobs to be done. HOW IS THE BILLING PROBLEM HANDLED? There wasn't a general rule that seemed to be evident from the discussions. Some agencies charge a local district by customer connection fee, which the local agency in turn passes on to the customer. Other agencies deal directly with the customer. Another method of collecting funds was an annual rate charged to a local district that is assessed at the time property taxes are due and the method of payment was either a direct payment to the agency or by means of arrangement through monthly mortgage payments. HOW DO YOU TREAT SEWER DISTRICTS AROUND A REGIONALIZED AGENCY? Although this subject was not on the agenda, it was brought up by several attendees who have not yet been thoroughly involved with regionalization. It was suggested that an agency could sell space in its system, where the local agency collects wastewater. Other methods of charges, such as volume, strength, connection fee, etc., were discussed. In some cases it was pointed out that the regional agency might take over an entire sewer district, including the collection system, plant and other facilities and in this case it might charge a fee directly to the customer. SUMMARY It was evident that the seminar attendees felt that there were two kinds of people problems: 1. Dealing with the general public, generating initial support and concern for a regional wastewater management plant implementation. ------- 2. Dealing with the personnel who have formerly been involved with the operation and maintenance of" existing systems. This problem is more direct and generally appears after reqionalization has occurred. There was general agreement that it is necessary to accept a local dis- trict's staff as they are, retrain them as necessary, extend to them benefits equal to those they had formerly enjoyed and to expect that a good personnel policy would take several years to implement before payroll efficiencies could be realized. Dealing with local districts that are involved with regional agencies that do not provide consolidation of facilities and reduction of treatment plants is such a variable problem that no one specific solution seems to fit every case. ------- Implementing Water Quality Management on a Regional Scale: The Capital Facilities by Marvin W. Runyan President Stevens, Thompson & Runyan, Inc. presented September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- IMPLEMENTING WATER QUALITY MANAGEMENT ON A REGIONAL SCALE: THE CAPITAL FACILITIES Marvin W. Runyan, President, Stevens, Thompson & Runyan, Inc. Twenty years ago, it certainly would not have required 20 plus minutes to describe how the decisions were made on capital facilities. Basically, I could say that the engineer developed the facilities plan based on accepted engineering logic and then someone else figured out how to raise the money to pay for it. Everyone understands what engineering logic is so I could finish my talk in a minute and sit down. Frankly, today things are quite a bit more complicated. To begin with, our metropolitan areas have substantially more complicated urban forms. The central city is surrounded by a number of autonomous governmental agencies, many of which have developed their own infrastructure. The number of people involved in decisions has escalated rapidly, both because of the increase in number of governmental units and because of the layering of units from federal through regional to local. Also, engineering logic is only one of many factors which goes into public works decisions now as demonstrated by the fact that I am fourth on a program discussing how regional decisions are made. And very importantly, the public is increasingly aware of the public works planning and implementation process and is actively involving itself in these decisions. In 1968 when the master plan was completed for the Tualatin basin there were 11 cities, 23 sanitary and service districts and 9 private sewerage systems serving an estimated population of 99,000 out of a total population of approximately 150,000. In addition to many miles of sewer, there had been constructed 29 sewage treatment plants discharging effluent to small streams in the basin. The plants varied in size from 10,000 gpd to the largest which was 2.5 mgd. This will give some indication of the magnitude of the problem to determine disposition of existing capital facilities when considering regionalization. The thrust of my remarks today will be to discuss how the capital facili- ties decisions are made in establishing a regional wastewater program. Our firm has been involved in the implementation of a number of regional wastewater programs and if we have learned one thing from that experience, it is that there is no formula which can be applied uniformly. Rather, ------- I will talk about some techniques that we have used and discuss some of the questions which must be answered in any regionalization program and then illustrate my remarks with examples from our own experience with emphasis on the Unified Sewerage Agency. Our experience has shown that for a program to be successful, the capital facilities consultant must be dedicated to devising a program which can be implemented. It is this goal orientation on the part of the primary consultant that provides the driving force for the whole program. In other words, it is our job to find a solution to the problem while meeting as many of the often-conflicting goals of the people involved as possible. NEW APPROACH REQUIRED There are several techniques which we have used for making decisions on capital facilities. The traditional approach, which was used extensively a few years ago and is still being utilized on smaller projects, basically consists of establishing the most feasible program from an engineering and cost-effectiveness view. In this process, the engineer essentially internalizes all the political, environmental, social and other factors in his own decision process. The system approach, which was developed by the aerospace industry in the 1960's, consists of establishing goals and then obtaining a consensus agreement on objectives. Once these are determined, the solution (in this case the desired capital facilities) can be determined in a very straightforward, almost mathematical manner. Neither the traditional approach nor the systems approach has proven to be valid in modern society. The traditional approach did not account for the dynamics of public decision-making processes and the large number of people and considerations which enter into any decision. The systems approach, which was highly successful for putting a man on the moon, has been much more difficult to apply to people problems. People are either unable or unwilling to articulate their objectives at the outset of a project and then sit back and watch the results come out without having further input. Another technique which I believe has merit is one which I will call the "practical approach" in that it recognizes reality and results in a program which can be implemented. In the practical approach the facilities consultant continuously maintains the goal of developing an implementable program. He is not passive, but aggressively pursues this objective. In order to achieve this goal, he weaves his way through the objectives of the many interested parties, satisfying as many of these as possible as he proceeds. This technique recognizes that peoples' objectives will not emerge until specific pro- posals are put forward and until they can see the consequences of these proposals. The consultant s progress in reaching his goal appears to be rather halting as he is taking 2 steps forward, reviewing and revising, one step backward and then 2 steps ahead. ------- Enough discussion about the theoretical decision-making process. Now let's talk about what specific factors and considerations are included in developing the capital facilities program. COST-EFFECTIVENESS Cost-effectiveness is the key to facilities decisions in regional waste- water systems. The system must be responsive to the protection of public health and the maintenance of water quality. It must be politically acceptable to those participating. It must be legally implementable. And, it must be economically efficient. A cost-effective regional system must optimize all of these aspects, not just initial dollar costs or life cycle dollar costs, in order to produce the maximum benefit. Cost estimates must be further broken down to see who will bear the burden of the various costs and this is particularly important when you are considering a voluntary association of local agencies into a new regional program. When we developed the regionalization program here in Washington County, we had several fundamentally different concepts that could be utilized. The 3 basic plans that were considered were: 1. Transport the sewage outside the Tualatin basin for treatment and disposal to the Willamette River. 2. Continue building and expanding existing sewage treatment plants on the small tributaries of the Tualatin River within the basin. 3. Remove plants from the tributaries and concentrate treatment at several key locations at the lower end of major subdrainage basins with treatment and discharge to the Tualatin River. Based on an analysis of the original capital cost, operation and mainten- ance, and projected future costs, evaluation of the plans presented was made and essentially the plan of moving treatment from the tributaries to locations at the lower end of the major subdrainage was adopted as most cost-effective. SERVICE BOUNDARIES The boundary of a regional sewerage system and the size and configuration of the system are often very difficult questions to resolve. Neither drainage basins, political boundaries nor geographic boundaries can be used by themselves. The decision is ultimately based on a combination of cost factors, urban growth boundaries, development trends and political considerations. Again, no magic formula can be established for determin- ing these boundaries, but rather through discussion and agreement. In Washington County we started with the county boundaries which, fortun- ately, closely paralleled the Tualatin River drainage basin, and then dealt with specific problem areas. First, there was the rural western ------- portion of the county which was outside the urban growth area. Secondly, there was a city in the county which chose not to join the regional pro- gram. And lastly, there was a portion of Clackamas County which was in the Tualatin River drainage basin. SIZING FACILITIES The traditional engineering practice of establishing facility sizes to serve ultimate development is no longer automatically applied. Current EPA regulations discourage sewerage development as a means of encouraging urban growth, and considerably more attention is being placed on phased development of these facilities. If a land use and zoning plan exists, the engineer can conduct a cost analysis to determine the proper phasing of facilities to meet expected development. If properly done, this will facilitate orderly growth through sewer construction as well as provide the most economic system overall. REGIONAL FACILITIES Which facilities are considered regional and which local when putting together a regional wastewater program? Certainly no pat answer such as all treatment plants plus sewers over a certain diameter will suffice for this question. A number of factors must be brought into consideration including the primary function of the facility, the responsiveness of the agency, economics, financing ability, etc. In the process of estab- lishing a regional system, the decisions on which facilities are regional is probably the critical one in gaining local acceptance. If the local agencies can maintain their desired measure of local control, then they will support the establishment of a regional program for functions which are clearly outside their own ability to provide. It is very seldom that the engineer has the option of providing a new regional system in an area with no existing facilities or where all exist- ing facilities are obsolete and should be abandoned. In fact, the usual situation involves facilities ranging from those that are fairly new through those that are fully amortized. The only criteria which we have found which can be successfully used in the abandonment or retention decision is the one of usefulness to the regional program. A detailed cost analysis should be prepared for every abandonment or retention deci- sion, but typically other factors prevail in this consideration. It may be necessary to make exception to the rule that only reused facilities will be purchased by the regional agency in the case of fairly new facili- ties which could continue to be used if it were not for regional considera- tions. Sometimes it may be possible to utilize these facilities during the phased development of the regional program. Throughout the service area of the Unified Sewerage Agency, we had a number of sewage treatment plants and pumping stations that had been in service for a number of years and had used up much of their service life, while others had been constructed quite recently. Still other areas had no facilities whatsoever. ------- After the district was formed and a financing plan developed, as a part of the program of dealing with the previous entities of the Unified Sewerage Agency, a reimbursement program was developed for those facilities which were retained and incorporated into the area-wide system. The total reimbursement for facilities was approximately $3 million. The formula used in arriving at the reimbursement was the initial cost of the facility less any federal grants which had been received, plus a 5 percent annual increase from the time of construction to compensate for inflation. Three sewage treatment plants were recognized, the Forest Grove plant which was the largest of the plants and was already located with discharge to the Tualatin River, and 2 small plants at Banks and Gaston which were quite isolated from the rest of the developed area. Reimbursement for sewers was limited to those 24 inches or larger in diameter. OPERATIONAL CONCERNS While not strictly a facilities consideration, the problems of training, providing spare parts and the operation and maintenance of a regional system made up of merged smaller systems is obviously of concern. It is very difficult to quantify the cost of these problems or in fact to deal with them other than in a subjective way in regional decisions. Adequate staffing of the regional agency must be provided early in the implementation phase for both operation and administration. In the case of the Unified Sewerage Agency, employees of the previous districts became employees of the new agency. COST ESCALATION The cost of inflation cannot be overemphasized in establishing the implemen- tation schedule for a regional program. Consideration must be given to construction management and fast-track techniques which can more effec- tively be utilized by a large regional agency than by a smaller local agency. Also, the regional agency may be more able to raise the capital necessary within the time frame required for rapid construction. Importance of speed of implementation to overcome the effects of inflation can be demonstrated by reviewing the cost estimates prepared in 1968 for the Tualatin Basin master plan construction and today's costs. The 1968 construction costs plus 25 percent allowance for administration, legal, rights-of-way, engineering and contingencies resulted in a total estimated cost for the system of $70 million. At that time the Engineering News-Record Construction Index was 1200, today 8 years later it is 2445. Using this as a basis of updating previous estimates, the construction would be more than double in 8 years. Based on trends prior to 1968, it was estimated that the construction cost would double in 15 years. When you look at the facilities decision process in the way I have just discussed it, it becomes obvious that you are not just talking about treatment plants, pumping stations and sewer lines. In fact, we find that the decisions on what will be built are really based on financial, institutional and people considerations as well as what makes engineering sense. And this is the way it should be! ------- Capital Facilities SUMMARY OF DISCUSSION SESSIONS Moderated by Cowles Mallory City Engineer City of Portland, Oregon on September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- CAPITAL FACILITIES Summary of Discussion Sessions Moderated by Cowles Mallory, City Engineer, City of Portland, Oregon The development and implementation of the Regional Capital Facilities Plan is a very complex process. Public awareness is vital to the formu- lation and success of the plan. Coordination and cooperation between the engineer, the client and numerous public groups and agencies are of fundamental importance, agreed the participants in the two discussion sessions on capital facilities at the Symposium on Implementing Regional Wastewater Management Plans. Discussion on this element of area-wide plans ranged across many fields. The following is a summary of the major topics: development of the regional plan, financing and legislation. DEVELOPMENT OF THE REGIONAL PLAN The major topics discussed relative to the development of the regional plan were evaluation of existing facilities, establishing priorities for phased construction, determination of the design period and deter- mination of the need and type of new facilities. Participants expressed concern that the value of existing facilities be properly determined and the appropriate credit be given the owner. As an example, sewage treatment plants of the same age and size but having a history of poor maintenance versus proper maintenance would have very different present worths. It was stated that credit for existing facili- ties such as sewers, which are incorporated into a regional facility, could be given through outright purchase. Although the same method could be used for treatment plants, it would be less applicable. Criteria used to evaluate the existing worth of treatment plants include physical condition, plant performance and capacity, effluent criteria, and operation and maintenance cost. It was suggested that abandoned plants are a liabil- ity; however, it is possible that a future use such as a training facility could be found. The initial prioritization of sewerage projects should be based on a logical progression of events as they are currently projected to occur. Available resources such as city and area-wide land use plans, zoning ------- ordinances and population projections should be used to the maximum extent possible in order to set initial priorities. Once priorities have been established, many participants in these discussions pointed out that it is crucial that a group or agency be delegated responsibility to monitor growth and to determine the current validity of the priority list. Flexi- bility to alter the priority list as needs change must be retained within the review system. At such times that changes in zoning or land use are made, timely coordination of all appropriate changes in all agency goals, guidelines and requirements is necessary. The design period is selected by the consideration of several factors and is largely a matter of judgment. Among the factors to be considered are the following: 1. Economies of scale which may be substantial, such as adding three inches in diameter to a sewer or five feet in diameter to a clarifier. 2. The type of facility, such as sewers which are difficult to ex- pand, and treatment plants which require only the duplication of existing facilities. 3. The location and timing of future development, which may necessi- tate and also hinder the expansion of existing facilities. 4. The useful life of facilities, which may range from 10 years to 50 years. 5. The development of new technology which may be superior to that currently available. 6. Financial considerations are important. In those instances where federal grants are available, extension of the design period becomes attractive. The need and type of new facilities is a function of such factors as population distribution, industrial loads and effluent requirements. Regionalization of facilities, which is considered by EPA to be an area-wide wastewater management approach to facility ownership, operation and maintenance, may be feasible in areas with large population concen- trations. The regional facilities may be comprised of one or more treat- ment facilities. The capacity in the regional facilities can be allocated, using some predetermined formula, to the entities involved or it may be utilized on an "as needed" basis. The inclusion of capacity for indus- trial wastes should be considered, as it may be beneficial to both the public and the industry. The wastewater characteristics and the effluent requirements will influence the type of processes employed.. FINANCING A very large portion, currently 75 percent minimum, of the cost of capital facilities is paid for by state and federal governments through grants paid for by the taxpayers. While participants agreed that grants play ------- an important role in the construction of wastewater treatment plants, the nature of the role is not clearly defined. EPA originally viewed the grants as a vehicle which could he used to solve existing water pol- lution problems. In contrast, some municipalities view grants as a source of funds for financing construction of facilities to curb water pollution while paying for future growth and thus decreasing the financial burden on the community through local taxation. Some people believe that this policy on the part of cities promotes growth; others suggested that sewers do not affect growth or birth rates. The grant issue does not stop here, however. In an effort to cut down on capital costs, EPA has adopted at least two approaches: 1. Fund only those projects which are most "cost-effective" toward solving the immediate water pollution problems. The term "cost- effective" was not defined. 2. Prevent the engineer from writing specifications which are so restrictive that many equipment suppliers are prevented from bidding. The only discussion on the first policy pertained to who makes the de- termination of what is most cost-effective; it was concluded that the community should make the decision, but that EPA must concur in order for the project to proceed in a timely manner. Numerous questions rele- vant to the latter policy were raised. It was generally felt that not restricting equipment suppliers from bidding would indeed lead to a sub- stantial savings in capital; however, it would only be at the expense of operation and maintenance costs which are borne in their entirety by the community, due to the substitution of cheaper equipment with in- ferior quality. This in turn would encourage the community to inadequately operate and maintain their systems and therefore decrease, at least par- tially, water quality. The raising of funds to cover the local match share is a complex process which demands public education and awareness, pointed out many of those attending the session. Since wastewater systems include capacity not only for the existing population, but also future populations, the cost recovery system must be equitable to all those to be served by the faci- lities. The fund raising scheme must consider debt service, operation and maintenance costs. Allowance must be made for escalation of costs, although the method of doing so tends to be nebulous. Legislation Existing legislation plays a key role in the development and financing of wastewater treatment facilities. Doubt was expressed that pollution abatement can be effectively realized through legislation. Current legis- lation prescribes uniform levels of treatment throughout the nation without giving attention to local needs and conditions. While this approach tends to make the economic burden uniform, it does not encourage the greatest pollution abatement for the dollars spent. Improvement of the benefit to cost ratio could be realized by adopting strict standards only in those areas that currently have water quality problems and relaxing them in areas with relatively good water quality; this approach would require a constant review of the standards to ensure high water quality. ------- Regional Solutions to Regional Problems by The Honorable Neil Goldschmidt Mayor City of Portland, Oregon presented September 9, 1976 at the Symposium on Implementing Regional Wastewater Management Plans sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- REGIONAL SOLUTIONS TO REGIONAL PROBLEMS The Honorable Neil Goldschmidt, Mayor, City of Portland, Oregon Most of the time, regionalism is defended as an environmentalist's tool, or a tool to protect the environment. This is because we are now correctly observing that a large number of environmental concerns do not respect the artificial boundaries of cities/counties and as such, must be attacked regionally: air shed; water and sewer; solid waste; and land use and transportation. These problems are focused on largely because they are critical elements in the ecosystem, basic to our life-support system. As such, they clearly fall into the category of regional problems in need of regional solutions. In assessing the case for regionalism, I would argue that the environmental perspective is too narrow; in fact, the most compelling arguments on be- half of regionalism may be economic and political rather than environmental. To explain why, you have to look at 2 phenomena that have guite possibly become the 2 most significant developments during this decade: growth management in an era of diminishing natural resources; and government decision-making in an era of diminishing public confidence. These 2 threads weave together to form the compelling argument for making regional- ism work. Here's how! GROWTH MANAGEMENT IN AN ERA OF DIMINISHING NATURAL RESOURCES By now, it is something of a cliche to acknowledge the fact that we have entered an era of shrinking resources. At the same time, Oregonians recognize the phenomenal growth pressure upon our state. Oregon population grew by 9.4 percent between 1970 and 1975, much in excess of the national growth rate of 5 percent. Here again, the question of growth management is often perceived as an environmental or ecological problem. How do we direct growth without upsetting the ecology? What is often misperceived or not perceived at all is the fundamental economic question. How do we direct economic ------- development to provide the level of jobs, goals and services that is desired? How do we meet the housing needs that we face over the next 4 years or 2 decades? I am suggesting that a regional perspective in economic development is the key to our management of growth as we con- front the limits that are imposed by dwindling natural resources. It is true for the Portland metropolitan region, and for the other regional communities in Oregon as well, that the economic well-being of our region depends upon our maintaining and improving the economic balance that exists between the urban-suburban and rural communities in the region. Make no mistake about it, we are economically interdependent. And the sooner we recognize those interdependencies and the harder we work at strengthening them, the better we will be able, as a region, to manage the growth ahead. EXAMPLES OF ECONOMIC INTERDEPENDENCIES A Diverse Economic Base A key to the economic strength of our region is its diversity. The Port- land SMSA is a West Coast leader in manufacturing diversity and is a principal center for industrial development, warehousing and distribution in the Pacific Northwest. Our regional economy is spread fairly evenly over a broad base: electronics, food processing, lumber and timber indus- tries, ship building and repair, sportswear, sports equipment and apparel, trucks and trailers and light manufacturing. Considering the following: . The forest products industry accounts for 12,200 jobs in our region and a $143 million annual payroll. . Agriculture was a $4.6 million industry in 1975. . Wholesaling employs 40,000 workers with a $7.2 billion annual volume, third on the West Coast. . Retailing employs 75,000 workers with a total retail trade of $2.3 billion. . The Portland harbor ranks third on the West Coast in total tonnage of domestic and foreign marine cargo moved; PIA handles 60,000 tons of cargo and 3 million passengers per year. . A full 50 percent of the entire Oregon work force lives in the tri- county area. The 10 full service banks with upwards of $6 billion in assets and 12 savings and loans make the Portland region a finance center. ------- Keeping those elements of our economy in place is a regional undertaking. The urban center is needed to attract the capital, provide the warehousing, distribution, shipping and receiving. The surrounding suburbs account for much of the production, the labor forces, the investment and the purchasing power. The Entire Region Operates as a Single Marketplace We are seen that way from the outside; we share in the economic benefits; we need to see ourselves that way from the inside. Moreover, our market- place will not be healthy without our efforts to fortify it. A growing skilled labor force needs housing — and the production of that housing can help the timber industry. Supporting the agricultural industry means a review of our tax provision, to make sure we don't tax land out of production. Our retailing and wholesaling markets rely on employed, well-paid consumers to purchase the goods. It all works together. Regional Capital Investment Maintaining our economic base calls for coordinated regional capital investment. The make-up of our economy — from timber to agriculture to wholesaling and retailing to tourism to port-related activities — relies upon a cooperative approach to building and maintaining the regional infrastructure that allows that activity to flourish. That largely means public expenditures. Transportation Networks Much of our transportation network came originally from old assumptions, not only about travel, but about local and state governments' ability to finance road construction and maintenance. We have in place a high- guality road system to carry merchandise to and from the market and workers to their jobs. But in our region, some of the counties and cities still project massive new road projects, far in excess of need or financial ability. Today, the state says it needs an additional one-cent gas tax just for maintenance of our existing system. The answer must be 2-fold: A rethinking of our assumptions regarding construction need and an increased reliance on transit for work trips. It's the only answer we can afford. And to arrive at it will take regional cooperation, regional planning and regional sharing. The Port Drydock Another example is the proposed port drydock facility. We already know the role the port marine operations play in the economy of the tri-county area. In 1975, value-added community economic impact of the marine opera- tions totaled nearly $1/2 billion; marine operations resulted in almost 21,000 jobs and a payroll of just under $300 million, spread throughout the tri-county area. Now the region, as a region faces an economic decision point. As Mayor of Portland, I am supporting the drydock bond measure, not only because ------- of what it will mean for my community, but for what it will mean for the economic vitality of the entire region. Tourist Facilities, Such As the Zoo In the May election, tri-county voters approved an important measure to turn what was the city zoo into a regionally-financed regional facility. I believe it was a sign of regional awakening to the fact that we are a region, that facilities such as the zoo ought not be the sole responsi- bility of one jurisdiction, particularly where the economic and cultural benefit is felt region-wide. It showed, I believe, that tri-county voters are aware of the economic interrelationships that do exist and want to approach decisions regarding economic growth and development with a regional perspective. GOVERNMENT DECISION-MAKING IN AN ERA OF DIMINISHING PUBLIC CONFIDENCE If economics is the first argument in favor of regionalism, then politics is the second. Just as our economic growth is under pressure from dimin- ishing natural resources, so the diminishing confidence of the public in their institutions of government places additional pressure on all who participate in the decision-making process. Regionalism, rather than being "another level of government", represents a chance for govern- mental efficiencies and more credible decision-making. According to a recent poll in a national news magazine, politicians are now at the bottom of the public's list; the public finally trusts politi- cians less than used car salesmen. The important thing is not how high or low in the public esteem politicians are held. What is interesting is that all politicians are regarded as the same, all levels of government as the same. To much of the public, it doesn't matter whether it's state, federal, city or county: it's just the government. And, in fact, that's the way in which much of government has proceeded. Treating artificial boundary lines as if they were stone walls, government has acted unilaterally in the past, often with little or no regard for spin-off effects on neighboring jurisdictions. Special purpose govern- ment has pursued its limited purposes within the boundaries of general purpose government and not considered the transferred costs or unintended impacts of their programs. The result is accurately perceived by the public as inefficiency, uncoordinated regulation, ineffective decision- making . As a case in point, during my first 3 years in the Mayor's office, I spent a great deal of time simply trying to prevent the programs and policies of other units of government from destroying my chance to set programs and policies for my unit of government. I found myself and my city bureaus engaged in a defensive strategy, spending so much time protecting ourselves from others that there was inadequate time to promote a positive strategy to enhance our city. The Port, the State Department of Transportation, Tri-Met, each was pursuing its own agenda. And, if ------- the tangle of governmental cross-purposes left the city gasping for relief, imagine how an individual citizen must feel. Our response, the only possible one I believe, was to invest more time in regional matters, not less. Only we tried to use a formal regional structure, in our case CRAG, to provide the forum to untangle governments, to establish a common regional agenda, to demonstrate to the public the capacity government does have for rational, cooperative, coordinated, efficient decision-making, not to improve ourselves by making our neighbor's lot more difficult. As important as the actual decisions are, the public perception of those decisions is more important. That's why CRAG's value as a regional deci- sion-making body is partly substance and partly style. If the political leaders in the region can begin to think about problems and solutions in a regional context, and to demonstrate by their actions the underlying benefits of regionalism, then the public will as well appreciate the value of the concept. The simple symbolic message of the CRAG meetings where the leaders of the tri-county area get together to work together cannot be missed. The message is clearly one of government looking to increase its effectiveness and efficiency to the public by working together. Harry Truman said, "There is enough in the world for everyone to have plenty to live on happily and be at peace with his neighbors". That is much of what regionalism is all about. We are only now at the beginning of our efforts to work toward regional solutions for regional problems. But it is an effort we cannot choose not to make. ------- The Resource Question: What are the Trade Offs by Jerome B. Gilbert President J.B. Gilbert & Associates Former General Manager and Chief Engineer North Marin County Water District, California and Executive Officer State of California Water Resources Control Board presented September 10,1976 at the Symposium on the Technical Response to PL 92-500 sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- THE RESOURCE QUESTION: WHAT ARE THE TRADE-OFFS? Jerome B. Gilbert, President, J. B. Gilbert & Associates, Former General Manager and Chief Engineer, North Marin County Water District, California, and Executive Officer, State of California Water Resources Control Board Every organized society continually makes decisions that balance short- term and long-term interests. However, long-term interests tend not to be weighed objectively when there is great urgency in resolving an immediate problem. This tendency exists in our society's present approach to environmental problems and the long-term resource implications are serious. Our environmental problems are national in scope and have evolved from both real and assumed needs. In the modern world, the magnitude of a nation's environmental problems is proportional to a nation's material affluence. A poorly-fed and ill-housed society has little time to con- template the future and its environmental goals are limited to those essential to survival. In 1976, our affluent and environmentally-aware society has very high environmental goals tending towards the maintenance of a natural state of quality. Some argue that the only solution is to reverse our obsession with material trappings and corresponding industrial growth and return to an abstract concept of the simple life, including of course such com- plexities as electric lights, reliable water service, full employment and finally pollution control. In short, society's desires for environ- mental quality control are tempered with other public needs and the degree of investment in long-term goals beyond the elimination of famine and epidemics depends entirely on our wealth and our sense of priorities. In our haste to solve environmental problems, we must not lose sight of our overall objective of making life on this planet healthier and happier. We must continue to remind ourselves to search out the long-term effects of actions taken now to assure that they do not precipitate con- flicts with our higher objective. I welcome this opportunity to share with you some of my thoughts on the resource aspects of our national water pollution control program. ------- WATER POLLUTION - A NATIONAL PROBLEM Early in this century, water pollution problems began to transcend state boundaries and gain national significance; but it was not officially recognized as a national problem until 1965 with the formation of the Federal Water Pollution Control Administration. By 1965, the problem had increased to crisis proportions in many areas. Out of these crises there grew a public desire that went beyond the elimination of pollution to the restoration of an unaffected or natural environment. This view led to the passage of California's Porter-Cologne Act in 1969 and subse- quently to the variety of other state acts and Public Law 92-500. PUBLIC LAW 92-500 — FOUNDATION FOR A NATIONAL SOLUTION At the outset, the federal water pollution control program and its objec- tive of cleanup of the nation's waters seemed straightforward enough. The need for a cleanup effort was never significantly disputed. Unlike other state and federal programs, this program was not founded on contro- versy, difference of opinion, split legislative votes and divided public opinion. It is, at the national, state and local level, a program based on the 99th percentile of public approval and near unanimous legislative vote in the Congress and many state legislatures. The need for a degree of national uniformity of effort was apparent if pollution problems were not to be simply transplanted from states and locales having pollution control objectives which are high relative to those of others. The social and economic impacts of industrial reloca- tions, for example, played an important part in the general acceptance of the concept of national pollution control standards. Although the dollar cost of a major pollution control effort was grossly underestimated, it was acknowledged that federal funding would be essential to its ac- complishment. It is well known that federal funds are never provided without accompanying federal regulation which has, to say the least, become abundant. Recall if you will that these deliberations were carried out in the eco- nomic and political climate of an outwardly healthy economy and an environ- mental awareness which was peaked by a long history of environmental insult and abuse. The national program that evolved in this setting was ambitious in every sense. In a single legislative stroke, it sought to remedy past evils and thrust water pollution control squarely into the 21st century. This was to be accomplished in the now familiar 3 steps: 1. 2. Provision by 1977 of secondary treatment for all discharges to surface waters. 3 Application by 1983 of the best practicable treatment technology to all discharges to surface waters with the goal of renderino these waters fishable anrl swimmaMo 3. Elimination of pollutant discharges to the nation's waters by ------- The attainment of the first plateau has proved to be a major undertaking which will exhaust the appropriated funding and likely not be achieved until well into the 1980's. In retrospect, the whole regulatory effort might well have been directed at this objective which is readily trans- latable to physical facilities under current technology, will correct 95 percent of the waste discharge related environmental problems and is 30 to 40 years overdue. The experience of the past 4 years has confirmed our early suspicion that superimposing of the ill-defined second and third plateaus only serves to confuse the issue and diffuse the effort. The extremely short time frame specified for achievement of these plateaus will almost cer- tainly result in some costly judgments as to what constitutes "best prac- ticable treatment" and how this relates to the elimination of pollutant discharges. A TIME FOR REFLECTION Collectively, we can justly take considerable pride in the water pollution control advances of the past 10 years. The atmosphere has been heady and we have responded well to the crisis. While many of our treatment systems are still on the drawing boards, the accomplishment of our na- tional secondary treatment objective is in sight. As we begin serious consideration of the best practicable treatment and pollutant elimination objectives which lie ahead, we must do so with clear heads and a full understanding of the importance of the decisions yet to come. The time has come to reflect on the results of our most recent efforts and the degree to which our basic goal has been accomplished. Lest we forget, the basic goal of the program is the restoration and protection of the reasonable beneficial uses of the nation's waters. The nearly unanimous public consensus which favors this goal and fostered the water pollution control program is not likely to support a single- minded commitment to pollution control for its own sake which results in the waste or unwise commitment of other resources. Public perception that this is occurring will kill the program even though legitimate work remains undone. Our reflection must include the following: With the exception of the nagging problem of ocean disposal, secondary treatment is a reasonable national standard. With rare exceptions, with or without the national funding program, it can be implemented without undue financial burdens. The national funding program just makes the job easier. It is in the increase of treatment beyond the secondary level that the serious resource trade-off issues begin to arise. The recuperation of the nation'8 waters in those cases where gross pollutant discharges have been eliminated suggests very strongly that extreme measures of pollutant reduction may not be warranted in many instances. A careful case-by-case evaluation of advanced treatment can be made during the period after ------- achievement of secondary treatment which is a necessary intermediate step in most advanced wastewater treatment processes. An essential element of our present secondary treatment planning and design must be a built-in flexibility to add tertiary treatment process trains as future needs dictate. In many cases, the receiving water quality benefits of advanced waste- water treatment levels are difficult to quantify because they are above the threshold of demonstrable damage. The resource costs of advanced wastewater treatment are becoming increasingly well known. When measured only in terms of the direct resource impacts, these costs are remarkably high. The Sacramento Case Studies conducted for the regional program at Sacramento, California, included an evaluation of the direct costs of conforming to future regu- latory standards demanding advanced levels of treatment. To provide some background on the Sacramento problem, there are currently 13 waste- water treatment plants discharging to the Sacramento River and tributary streams within the community. Although many of these plants are secondary treatment plants, most are nearing capacity; several discharge to heavily used recreational waters; and two are located in residential areas and are the source of numerous odor complaints. The combination of regulatory prohibitions of future discharges from several of these plants and the economics of meeting secondary treatment requirements led to a decision to construct a single regional plant. This plant, which will begin opera- tion in 1981, will discharge to the Sacramento River 50 miles upstream fron San Francisco Bay. The average daily discharge rate in 1981 will be about 120 mgd (million gallons per day) increasing to about 200 mgd by year 2020. The estimated program cost is $400 million, but the average total cost per residence will be only $7 per month. The Sacramento River is of excellent water quality and is an important migratory route for anadromousfish including salmon, steelhead and stur- the source of bitter controversy. and dissolved .inerals to ------- At Sacramento, the receiving waters are of very high quality and this interpretation of the goal could preclude discharge to surface waters. The dollar cost of compliance with the literal interpretation of the goal would range from 2.5 to 4 times the cost of secondary treatment or from $300 to $600 per acre-foot at 1980 cost levels. The primary energy requirements to comply with this interpretation of the goal through advanced treatment are equally impressive. Direct energy consumption would increase from about 450 kwh per acre-foot for secondary treatment to about 3200 kwh per acre-foot for advanced treatment. Case 2. A less restrictive interpretation of the goal is that it would be implemented through the specification of effluent standards requiring the use of advanced levels of treatment for major reduction of organics, nutrients, toxicity, bacteria and viruses. At Sacramento, such standards could well include the following: Monthly Avg. Parameter Units Concentration Ultimate Oxygen Demand mg/1 50 Fecal Coliform Bacteria number/100 ml 200 Toxicity toxic units 0.6 Nitrogen mg/1 1.0 Phosphorus mg/1 0.1 Although there is now no basis for prediction of standards on viruses and stable organics (loosely defined as organic substances not removed in biological secondary treatment processes), conformance with reason- able standards on viruses and stable organics would be possible using the advanced treatment processes of chemical coagulation, mixed media filtration and carbon adsorption. The dollar cost of this treatment would be about $300 per acre-foot. In this case, direct energy consumption would rise from the 450 kwh per acre-foot secondary treatment requirement to about 1300 kwh per acre-foot. In an effort to make an objective assessment of the Sacramento program, the Office of Management and Budget with the aid of several consulting firms, evaluated the Sacramento program. In essence, they found that a refurbishing of the existing systems could be done for 30 to 40 percent less, but that the standards could only marginally be met. However, the operation and maintenance costs would be higher. We have yet to feel the effect of PL 92-500 decision-making on the balance between capital and operation and maintenance costs. With the continual escala- tion of energy sensitive treatment inputs including chemicals, electricity, ------- transportation and maintenance materials, the incentive to go to high capital, low maintenance facilities remains very strong. The penalty for high operation and maintenance selection falls particularly heavily on wet industry. The largest wet industry in Sacramento contributes a peak seasonal canning load equal to a community of 400,000 people. Its costs per acre-foot of waste treated has recently been estimated at $800 compared to the average cost for domestic flows in the same system of $150. This is in large part due to the federal requirement for indus- trial repayment and California's additional requirement that local costs be allocated on the same formula. Sacramento has another problem that is facing many communities — the desire to institute lifeline sewer rates. Recent indications are that the state will permit such categories within the subdivision of residential users providing the entire group pays its fair share. Although these are Sacramento figures, it is reasonable to assume that the cost and energy relationships of secondary to advanced treatment are similar in other areas of the nation. It is also reasonable to assume that there are many other situations where the benefits of such expenditures are equally questionable. The need clearly exists to distin- guish between these situations and the lesser number of cases where benefits of advanced treatment can be shown. This distinction must be made in both the law and regulations. Laws and regulations cannot and should not cover all of the details of such a complex problem. The ultimate responsibility to make these case-by-case evaluations and decisions there- fore must rest jointly with: (1) engineers and scientists who make careful and comprehensive factual showings as to the costs and water quality benefits in each case, (2) regulators who weigh each case independently and intelligently, understanding that decisions in precedent cases are relevant only under circumstances of identical conditions which will seldom exist, and (3) decision-makers at the local, state and national levels who must be cognizant of priorities both within the water pollution control program and outside it. It must be clear to all involved that the mere identification of a water quality benefit of additional waste- water treatment will not necessarily warrant the resource expenditures to achieve that benefit. Ideally, national or regional sets of priorities would be established under which resource trade-offs could be evaluated. Trade-offs which might be considered include: . Foregoing the total enhancement of fisheries and other biological resources of certain waters in favor of providing increased protection to these same resources in other waters where it is more cost-effective to do so. . Use of public funds to provide advanced treatment to municipal water supplies in those cases where protection of public health from trace organics and other substances is the concern and supply treatment is more cost-effective than wastewater treatment. Energy trade-offs in the use of chemicals and energy dependinq on local or regional cost factors. The extreme energy requirements for ------- advanced wastewater treatment create demands on energy resources which are themselves subject to increasingly restrictive environmental regulation. . Costs of water pollution versus expenditures for education, health and other social programs. . Cost-effective wastewater treatment systems, regardless of treatment level, are larger scale systems which are designed to be expanded to accommodate long-term community growth. Community growth has come to be regarded by many as undesirable because it connotates urban sprawl, increased air pollution potential and increased demands on resources to house, transport, educate, shelter, feed and provide necessary community services to expanded populations. This appropriate- ness of limiting water pollution control facilities as a means of controlling growth and its adverse economic and environmental impacts has been the subject of a great deal of debate. Those of us in the water pollution control business have already seen attempts to limit the capacity of secondary treatment facilities. We have defended our projects on the basis that such limitations would not be effective in solving other environmental problems and would result in greater long-term costs for solution of our water pollution problems. As the dollar costs of water pollution control increase due to the neces- sity for advanced treatment, we may well find that we have a direct economic interest in growth limitation. Obviously, the biggest problem with this approach is the development of a satisfactory national or regional needs formula under which priorities would be evolved and funding distributed. Clearly, regional or national funding will be necessary both because of the high costs involved and because under a priority approach, expenditures in certain geographical areas would be increased to compensate for lesser expenditures in other areas where solution may not be as cost-effective. The environmental awareness that gave impetus to the water pollution control effort has spread to other areas of environmental concern, some of which directly affect the water pollution program. Prime examples of this spillover are: . Increased restrictions on thermal power development due to air quality, cooling water disposal and nuclear hazard concerns. These restrictions have contributed to the untimely arrival of the energy crisis which has a very direct effect on pollution control system operational costs. . Increased restrictions on pollution-free hydro power development due to concerns with the protection of wilderness areas and wild and scenic rivers. . Increased restrictions on pollutant emissions from industries which supply materials, equipment and chemicals for water pollution control system construction and operation. These restrictions incur increases in product costs which are reflected in higher system construction and operation costs. ------- Increased restrictions on development of surface water resources for water supply. The corresponding increases in water development costs and reductions in ultimate availability of fresh water encourage water conservation and reclamation. WASTEWATER RECLAMATION The relationship between secondary and advanced waste treatment has a direct impact on the potential for additional water uses. If the uses are of environmental character and it is difficult to conclusively demon- strate the value of a step up from secondary to tertiary level (as illus- trated by nitrification, filtration, or nutrient removal), it is unlikely that such facilities will be built, particularly in the absence of grants. The costs are just too high and most local agencies still demand some sort of justification other than the general community sentiment which remains strongly in favor of pollution control. In the community of Irvine, California, the Irvine Ranch Water District recently developed a total reuse program which will control total dissolved solids to the level of 750 through blending with imported water from northern California (a good part of which is Sacramento wastewater). This program will result in reduced imported water demands and elimination of discharge to the ocean at an average cost of something less than $130 per acre-foot which is the value of reclaimed wastewater when compared with imported water. But in the adjacent community to the north, central Orange County, there is a large groundwater basin where average wastewater quality will be in the range of 1,200 parts per million of TDS; demineralization is neces- sary and costs range from between $350 and $400 per acre-foot compared to the marginal costs of new water of between $100 and $200 per acre-foot. I must emphasize one point. When you consider water supply, and the re- claimed wastewater represents a small fraction of the total supply, very high incremental costs can be incurred without big increases in water rates. Where higher treatment levels lead to or create a situation in which water that would otherwise be wasted to the sea can be used, there are direct resource benefits that accrue. Such instances may well be the only situations in which advanced treatment is warranted. In summary, we will increasingly see, whether paid for at the national or local level, water resource recovery projects in arid areas where water costs are high. However, the future for marginal levels of waste treatment including management of surface waters does not appear bright. THE CONTINUING BALANCE SHIFT Before I get too pessimistic, because I along with most of you would advocate advanced waste treatment or land confinement in many if not ------- most local situations in the West, it is important to look at the ever shifting balance of society's priorities. In California, a recent proposal to build petrochemical facilities, of which there are many in Texas, Louisiana and in the Midwest, in running into stiff opposition from envi- ronmentalists who are now confronted by labor and other economic interests. If the project is stopped, the resulting implications in terms of society's standards for environmental protection will have a significant impact on development in California generally. The issue remains in doubt. A similar type of test recently occurred on our coastal zone legislation where, after some weakening of initial proposals, the legislature approved by a strong majority the continued operation of coastal zone controls despite opposition of key economic groups in the state. However, pollution control still has a lot going for it. The construction jobs and environ- mental benefits it offers are not yet offset by the economic impact of reduced job opportunities and productivity. SUMMARY We have all learned in this environmental era that the environmental process can be an end in itself. The struggle continues between the constructors and the questioners, between those who desire to solve or correct problems and between those who frequently enjoy analyzing the problem for the sake of analysis. Nevertheless, the environmental approach with all of its weaknesses and the adversary relationship, has contributed a very important element to the planning process: the development of noneconomic benefit analysis. When it comes to advanced waste treatment, expenditures on water pollution control, elimination of pollutants whether through source control or pretreatment, the basic concepts of engineering economy as modified by the new environmental science must be the foundation for case-by-case analysis. Uniform national standards of secondary treatment are a costly but necessary goal. The next steps are more complicated but the following should be considered. . A new set of national resource management goals to be supplemented by goals reflecting regional characteristics and economic conditions. . A grant program designed — however politically unpalatable this may be — to satisfy needs which do exist in varying degrees and varying areas. . The establishment of regional environmental (resource management) goals and evaluation procedures that reflect regional priorities, growth standards and alternative investment strategies. . Standards necessary to protect public health or assure reliability should be based on numerical values that develop from ongoing research. However, the use of enforceable numerical standards to define marginal degrees of environmental protection should be decreased to provide adequate flexibility to achieve resource trade-offs. ------- . Continued emphasis of case-by-case evaluation of water quality im- provement projects only in the framework of regional urban analysis that gives equal consideration to economics of the water system, energy and resource allocation and regional growth policies. Traditional concepts of engineering economy still have great value. We can reestablish them after we have achieved the first plateau of water pollution abatement, !jut inevitably within a new context that reflects national resource priorities and regional environmental and growth policies. ------- Overview of Land Treatment of Wastewater by Noel W. Urban Chief, Engineering Management and Urban Studies Section Engineering Division, Office of the Chief of Engineers U.S. Army Corps of Engineers, Washington, D.C. and Mark A. Moser Staff Agriculture Engineer presented September 10,1976 at the Symposium on the Technical Response to PL 92-500 sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- OVERVIEW OF LAND TREATMENT OF WASTEWATER Noel W. Urban, Chief, Engineering Management and Urban Studies Section, Office of the Chief of Engineers, U.S. Army Corps of Engineers, Washington, D.C. and Mark A. Moser, Staff Agriculture Engineer Why Should A Municipality Or Regional Wastewater Management Authority Consider Land Treatment Of Wastewater? There are many reasons to consider using land treatment to remove unwanted and undesirable materials from wastewater. The Federal Water Pollution Control Act Amendments of 1972 (PL 92-500) set a goal of the elimination of the discharge of pollutants to waterways by 1985 and encouraged the evaluation of land treatment as an alternative. Other legal arguments include the prohibition of materials discharge to navigable waters under the Refuse Act of 1899 and the national goal of a clean environment as stated in the National Environmental Policy Act of 1970 (NEPA). These regulations form a common ground for seeking cost-effective techniques to protect the nation's waterways. The technical rationale for the use of land treatment follows closely the goals outlined in PL 92-500. There is no discharge of pollutants to surface waters. Fertilizer, food, drinking water and irrigation water are resources that can be recovered by land treatment. Resources in the form of energy, concrete, steel and other construction materials may be recovered by construction of land treatment systems. Flexibility in handling flow and waste strength variations is another important advan- tage afforded by land treatment systems. The economics of land treatment tend to make it an attractive alternative. Variable state regulations affect the design, operation and economics of a system. Land treatment can be less expensive than tertiary treatment (removal of pollutants in the wastewater to a level in excess of secondary treatment) and in some cases, competitively priced compared to conventional secondary treatment (stabilization of oxygen-demanding materials). The recharge of groundwater aquifers can be an economic benefit to an area and the recovery and sale of the water can generate revenue. Addi- tionally, recovery of operating expenses is possible when salable crops are harvested from the site. Table 1 summarizes the legal, technical and economic considerations. ------- Land treatment is not a panacea and may not be usable in all situations. It must be recognized that proper design and operation are important factors in the success of a system. There are a large number of land treatment facilities currently treating wastewater in the United States. A survey by the American Public Works Association (1) identified 155 municipal and 38 industrial sites in 1973. The use of land for treatment or disposal of wastewater is not a new technology, as many people seem to believe. Ancient China and Athens, in the time of Pericles, used human waste in farming practices. (2) "Sewage farms" were the European and American forms of land treatment in the 1800's and early 1900's. Many of the early sewage farms became unpopular as sewage volumes exceeded the capacity of the sites to accept raw sewage. The sites could not be expanded due to urban growth. Result- ing odors, cropping problems and the advent of "modern" sewage treatment led to the discontinuance of most of these systems. However, the water- short southwestern United States recognized the potential in both water and fertilizer value of municipal waste flows. Consequently, land treat- ment has been used continuously and successfully for many years at a multitude of sites in the southwest, including the cities of Fresno, California (1891) and San Antonio, Texas (1895). Currently, crops are grown, golf courses supplied with water and nutrients and landscaping is irrigated as the wastewater is treated. Foreign experiences with land treatment have also given positive results. The present-day sewage associations of Wolfsburg and Braunsweig, West Germany; Paris, France* the Board of Works farm of Melbourne, Australia and the Mexico City irri- gation project represent large scale successful land treatment systems. It is notable that most of the foreign systems still apply undisinfected, raw sewage. ' WHAT IS LAND TREATMENT? Land treatment is the use of the soil community with its microbial, plant and water relationships to extract unwanted pollutants from wastewater. By applying wastewater to land, advantage is taken of the physical, chem- ical and biological phenomena in the soil ecosystem to perform the pollu- tant removal functions of a sewage treatment plant. The technique is used as a secondary level treatment process or in addition to an existing secondary level system to attain tertiary levels of pollutant removal. A high degree of water purity is obtained by either use. As the applied wastewater filters through the soil, large particles are physically strained from the solution. Compounds and elements in solution may be removed by adsorption to soil particles or organic matter surfaces as water is passed over these surfaces. Heavy metals (Cu, Zn, Ni, Pb, Cd, etc.) and phosphorus are preferentially bound to soil surfaces in most types of soil. Bacteria and viruses may be strained from solution or sorbed to particle surfaces. Depending upon their combined chemical state, plant nutrients such as nitrogen or phosphorus can be retained in the soil or remain mobile in the soil solution. Within the soil regime, the degradable organic portion of the waste will be decomposed by soil microorganisms with the uptake of the nutrients ------- necesary for growth. Nutrients not adsorbed by soil or soil micro- organisms, that are in solution in the zone of plant root influence, are available to satisfy the nutrient needs of growing plants. The plants will absorb a portion of the available nutrients. Those nutrients remain- ing may move with the soil solution down the soil profile to join the groundwater. The land treatment system functions as an interwoven network of cyclic processes. Material added to the network may be transformed, taken up, leached, volatilized, absorbed or adsorbed. Figure 1 summarizes the cycles associated with the major constituents applied in wastewater. The design and operation of a land treatment facility will depend directly upon these environmental factors. There are three primary classes of land treatment? Infiltration—Perco- lation, Slow Infiltration and Overland Flow. These classifications are based on the ability of a soil to accept water and allow it to move through the profile. Infiltration-percolation sites take advantage of coarse soils (i.e., sand and gravel) to pass large amounts of water into the soil, but may achieve a lesser degree of treatment than other classes of land treatment. Filtration is relied upon to initially remove pollutants as sand or gravel are poor adsorbants (Figure 2). Intermittent drying promotes aeration at the soil surface and speeds microbial destruction of accumulated matter. Rapid infiltration sites are most often not cropped. Slow infiltration is a class of land treatment that includes many modes of operation. Ridge and furrow irrigation, broad irrigation, flood irri- gation, drip irrigation and all techniques of sprinkler irrigation (solid set, movable line, center pivot and water cannon) are application modes associated with slow infiltration. Slow infiltration sites are operated to maximize pollutant removal by continual plant, soil and microbial action upon waste. This class of land treatment is designed to have little or no runoff. Overland Flow treatment allows the use of soils of low permeability for a land treatment system. The wastewater is applied to an overland flow plot at the head of a slope and allowed to flow over the vegetated soil surface to the foot of the slope where it is collected (Figure 3). As there is little water loss by infiltration or evapotranspiration (about 25 Dercent) the system is designed to have a discharge. The water is purified by contact with the soil and plant surfaces and with the micro- organisms growing there. The process can be compared to a trickling filter with attached microbial growth that removes and assimilates undo- sirablf» suhqtances The vegetation on the plot acts to increase the travel time of the'water down the slope, remove nutrients by absorption, as a site of microbial attachment and as a potential source of monetary return Table 2 (after Pound and Crites (3)) summarizes the comparative characteristics of the three classes of land treatment. The expected t^en^e^r!" for each type of system ref ects the operating characteristics of existing systems with good management. ------- The ultimate applicability of land treatment systems, their design and operation depend on a number of factors including legal, technical, economic, physical and social considerations. The legal and technical considerations have been mentioned. Economic concerns have been discussed in part and will be further amplified by example. The physical factors most prominently affecting the design of a system are wastewater characteristics, climate, site characteristics and site management. A short summary of each follows: Wastewater Characteristics - The concentration of the rapidly degradable organic fraction of the waste is a factor to be examined. Any treatment site can assimilate large amounts of organic carbon depending on the presence of microorganisms, the availability of nutrients, soil temperature and the availability of oxygen in the soil pore spaces. Exceeding the capacity of a site for aerobic decomposition leads to the anaerobic putre- faction process and odor generation will result. A "high" concentration of heavy metals in the wastewater would necessitate a lesser application of wastewater. These elements accumulate in soil and may accumulate to the point of affecting plant and animal growth; however, wastewaters seldom contain concentrations of heavy metals to make them a limiting factor in design. Presence of substances injurious or toxic to plants and animals may pre- clude land treatment as it has been defined. The wastewater application rate must be controlled so as not to exceed the capacity of the plants, soil and microorganisms to remove nutrients from the water and to avoid washout of excessive amounts of nutrients. The nutrient balance of the wastewater may have to be altered to maximize plant utilization. Climate - The frost-free growing season limits the period during which the slow infiltration and land treatment system modes can be used. Waste- water should not be applied to frozen ground. Storage will be required equal to the nonoperating period of the land treatment system. Precipitation during the growing season limits the application of waste- water. Water application rates must consider crop needs and precipitation to minimize runoff, to insure adequate soil residence time for assimilation of waste and to avoid creating waterlogged, anaerobic conditions in the soil. Spray irrigation must be curtailed during excessive wind, to preclude off-site movement of aerosols. Border plantings can mitigate the effect of wind or another form of irrigation can be used during these periods. Site - The on-site application rate is dictated by the climate, soil infiltration and percolation rates. The percent of clay and type of clay will alter the application rate. Clay and organic matter adsorb heavy metals, nutrients and pathogens. The higher the clay content of a soil, the greater is its potential for adsorbing these materials- how- ever, increasing clay content decreases water in i ! materials, how- Shallo* bedrock, Intrusive rock for.aUo!^ ' rC", lfij.it percolation must be considered in the design. ------- Excessive slopes, presence of flowing surface water, drinking water wells and residences must be identified and dealt with in finalizing the system design. A high water table may lead to short circuiting of the treatment process and contamination of the groundwater. The direction of flow, rate of flow and location of areas of groundwater recovery affect the rate of spread of possible contamination and hence the system design. Vegetation - The choice of vegetation for a site will be made with several goals in mind. Plants such as reed canary grass will take up large amounts of nutrients and water. Other crops may be grown to provide a monetary return. Corn will remove fewer nutrients than reed canary grass but is a more marketable product. Forested areas benefit from the added nutrients in wastewater. Forest soils normally do not freeze in the winter and may be usable for treatment all year; however, forest soils and forest areas are not as efficient in removing the undesirable materials from water. A mix of crops having a seasonal range of peak water and nutrient demands will permit a longer application season and insure against system failure due to a monoculture crop failure. The wastewater, site, climate and vegetation characteristics all have an interactive effect on the final design of the land treatment system. In the interplay of factors, the most restrictive factor will become the minimum basis for design. Nitrogen is often cited as the limiting factor in design; therefore, the whole system may be designed so as to limit the nitrogen application to the maximum amount that the site can accept. Table 3 depicts the general physical characteristics to be con- sidered in land treatment system design. Management - In any engineered system, the final product is only as good as the system management. When sanitary engineers design a biological sewage treatment unit, the continuing success or failure of the unit is dependent upon the competency of the operator. Land treatment must be viewed in the same light. To achieve water treatment goals, the land treatment system manager must understand his objectives and how to achieve them. Excessive water or pollutant application may result in less than optimal renovation of wastewaters. Use of crops for pollutant removal requires an understanding of crop growth so as to maximize pollutant removal and water quality renovation. Some of the more pressing considerations of land treatment are the legal, social and regulatory atmospheres. Unfamiliarity with the land treatment process at all government levels affects the potential for use of land treatment. Regulations and guidelines for design and construction of land treatment systems are varied in the 24 states that have regulations or guidance on land treatment. The lack of familiarity with land treatment has often put it within the jurisdiction of a multitude of agencies. There is no uniform approach or advancement of national policy regarding ------- the return of wastewater to land. Water supply agencies are concerned with the potential pollution of groundwater under land treatment sites. Public health agencies are concerned with the potential health hazards of returning wastewater to land, especially via spray irrigation. Agri- cultural bureaus are hesitant to apply heavy metals or exotic organic substances to land for fear of accumulation of these substances in the soil and subsequent contamination and removal of arable land from produc- tion. Local governments are concerned about becoming property owners and farm managers and about the removal of land from the local tax base. Environmental protection agencies are concerned in part with all the above as well as the lack of expertise in the area. Similarly, engineering firms may express various concerns as they lack familiarity with the land treatment method and may have no person versed in the design and operation of land treatment systems. The most valid concerns are those regarding groundwater pollution and public health protection. Avoiding groundwater contamination is a matter of system design and operation. Proper system design will include an application rate and schedule that minimizes the passage of contaminants into the groundwater. The public health risk is an unsettled issue. Some researchers feel that land treatment will be an unnecessary risk to public health by concentrating disease organisms, thus becoming a source for the spread of disease. Other equally qualified researchers contend that the potential for disease spread is minimal. Examination of existing systems and the chronicles of now defunct systems revealed no incidence of illness that could be attributed to those systems. Several outbreaks of typhoid fever have been attributed to the consumption of uncooked salad vegetables that had been "grossly contaminated" with raw sewage (6). The spectre of aerosol spread of disease from waste spraying has been down played as more research is completed (4). Disease outbreak is a dose dependent phenomena. Off the land treatment site, the chance for an infective dose appears to be very low. Adequate separation of the public from the site by fences or ditches reduces the risk of contami- nation by direct contact with the site. The regulations for land treatment in California were developed from experience over the years and contain reasonable provisions for minimizing the health risk (Table 4). The most real concerns are those of the public. The potential for odor or health hazard may provoke a negative public reaction. Lack of rebuttal by governmental decision makers, as well as lack of interest, enhance summary rejection of the potential value of land treatment. One of the more attractive aspects of land treatment is the potential cost savings of this system over others. A cost comparison is made here based upon References 3 and 7 as modified by conclusions from References 8, 9 and 10. The costs presented are cost estimates for total systems to achieve the specified levels of treatment. They have been updated to January 1976 cost levels using the EPA Sewage Treatment Cost Index. The cost comparison has been further substantiated with the Corps of Engineers CAPDET Model (Computer-Assisted Procedure for the Design and Evaluation of Wastewater Treatment Systems). The costs on an annual basis for hypothetical 1, 3, 5, 10, 50 and 100 mgd municipal wastewater plants for several treatment alternatives are presented in Table 5. Land treat- ment costs increase in a more linear manner while the activated sludge ------- enjoys more pronounced economies of scale. This is true because the unit price of land is a constant, whereas construction materials are less expensive in large amounts. Future costs for energy and materials may significantly affect activated sludge and advanced waste treatment pro- cesses. The land treatment system, having much lower operation and main- tenance costs, will be less affected by post-construction supply cost changes. Though the costs are estimates, they are based on the best information available to the Corps of Engineers through EPA and the private sector and reflect the relationships between the system costs. Spray irrigation is cost-effective at low flow rates, while the complete-mix activated sludge is more cost-effective at higher flow rates. The need for treatment in excess of biological stabilization will make land treatment a compara- tively less expensive alternative, as can be seen in Table 5. Tertiary levels of treatment are now necessary in some areas and may be necessary to reach the goal of fishable-swimmable waters as set in PL 92-500. A word of caution. Costs for treatment systems are quite site dependent. We have discussed the general case. Local conditions may modify these conclusions. The largest existing land treatment system in the United States, Muskegon County, Michigan, will show a good return on its crops this year. The system is built on a formerly unproductive sandy soil area in Muskegon County, about 11 miles from the City of Muskegon. It handles 28 million gallons per day, applying approximately 2.5 inches of water per week to 6,000 acres of corn. The wastewater is pretreated in aeration basins, ponded, disinfected and then spray-irrigated. The system is wholly owned by Muskegon, but managed by a private management corporation. The land treatment system at Midland, Texas, relies on a private farmer whom the city has contracted to irrigate his land with the municipal wastewater. A similar, successful arrangement exists at Bakersfield, California. The city owns 2,400 acres of land. The land is leased to a private farmer who uses the wastewater to irrigate the multicropped area. The wastewater has allowed the reclamation of formerly unproductive land and the city is compensated, in part, for the treatment. In addition to municipalities that employ various management schemes to achieve land treatment, industries successfully use land treatment to reduce or eliminate the discharge of wastewater. Campbell Soup Company's Paris, Texas, plant is unusual in that it has used overland flow treatment since 1964. Hay is cropped and removed from the site. A multitude of fruit and vegetable processors, paper and paper products manufacturers and other industrial operations utilize land treatment. At least a dozen military facilities use some form of land treatment. The U.S. Army Corps of Engineers is exploring the use of land treatment with the idea of applying the technology more widely at its own instal- lations. The land treatment method is flexible and very adaptable to the Corps' recreational areas that experience extreme daily and seasonal flow fluctuations. The Corps has three demonstration projects in progress, including two spray irrigation sites, Deer Creek, Ohio, and Arkabutla, Mississippi, and ------- an overland flow project at Utica, Mississippi. The Corps is also at- tempting to determine design parameters through research on overland flow treatment at the Waterways Experiment Station (WES). The Cold Regions Research and Engineering Lab (CRREL) at Hanover, New Hampshire, is involved in research to develop more information on components of the land treatment system. Greenhouse studies and test plots are being used to quantify plant and soil capacities for wastewater renovation. Year-round applica- tion of waste is being explored at CRREL. At the University of Washington, forest ecosystems are being studied under the direction of the Corps. Similarly, cropping practices are being studied at the University of Minnesota. The Army Surgeon General's office, the Corps and the United States Environmental Protection Agency (EPA), alone and jointly are spon- soring work on the potential health risks associated with land treatment. The Corps of Engineers and EPA are jointly undertaking the development of a manual for the design of land treatment systems to facilitate the wider application of the technology. In addition to the above, there is a large amount of research in progress all over the United States. EPA, the Corps of Engineers, the Department of Agriculture, the Department of the Interior, various federal and state bureaus and agencies are conducting or sponsoring research in all aspects of land application of wastewater, sludges and animal manures. The poten- tial resource recovery from these sources is too large to ignore. High levels of wastewater treatment attained at minimal cost warrant further inquiry and exploration into the use of land as a wastewater treatment unit process. SUMMARY Land application of wastes is an old technique, but one that can be de- signed and managed as a high performance wastewater treatment system. The cyclic processes in the soil-plant-water system result in a high degree of water purification. The most limiting factor (climate, soil properties, heavy metal accumulation, nutrient concentrations, vegetation, or others) will control the application rate and hence the area necessary for application. Land treatment is a flexible system that, for the cases we have evaluated, appears most applicable to small and medium waste flows. It is in systems that have smaller flows that the technology is currently being most widely applied. A large research effort is ongoing to quantify the physical, biological and chemical processes involved in land treatment. Results of this work will provide the expertise necessary to utilize land more fully. The use of land treatment has several advantages including: 1. Elimination of pollutant discharge to waterways. 2. Cost-effectiveness. 3. Resource recovery. 4. Energy and cost savings. ------- The lack of familiarity with land treatment is one of its most obvious disadvantages. Other disadvantages to be noted are: 1. Potential for groundwater pollution. 2. Potential health hazards. 3. Pre-emptive land use restriction. 4. Need for skilled management (though this is not unique to land treatment). Trends toward regionalization of sewage treatment may favor the use of land treatment, in that land for a system will be found mostly in inter- urban areas. The nutrients and water from the city and rural sources can be beneficial to these areas while solving sewage disposal problems at the same time. ------- BIBLIOGRAPHY 1. American Public Works Association Survey of Facilities Using Land Application of Wastewater Office of Water Programs Operations U. S. Environmental Protection Agency Washington, D. C. 20460 July 1973 EPA - 430/9-73-006 2. Hartman, Willis 3., Or. An Evaluation of Land Treatment of Municipal Wastewater and Physical Siting of Facilities Master's thesis Pennsylvania State University May 1975 3. Pound, Charles E., Ronald W. Crites and Douglas A. Griffes Costs of Wastewater Treatment by Land Application Office of Water Program Operations U. S. Environmental Protection Agency June 1975 EPA - 430/9-75-003 4. Sorber, Charles A. "Viruses in Aerosolized Wastewater" Presented at Symposium on Virus Aspects of Applying Municipal Waste to Land Gainesville, Florida June 29, 1976 5. Morris, Carol E. and William J. Jewell "Regulations and Guidelines for Land Application of Wastes A 50 State Overview" Presented at 8th Annual Cornell University Agricultural Waste Management Conference Rochester, New York April 30, 1976 6. Sepp, Endel "The Use of Sewage for Irrigation, A Literature Review" Bureau of Sanitary Engineering State of California 1971 ------- 7. Cost-Effective Comparison of Land Application and Advanced Wastewater Treatment November 1975 EPA - 430/9-75-016 8. Culp, Gordon "Evaluation of Land Treatment Markets and Experiences in the Marketplace" Presented at: Marketing Workshop for OR&D Managers, Office of Technology Transfer, USEPA, Cincinnati, OH, Aug 10-11, 1976 9. Wastewater Sludge Utilization and Disposal Costs September 1975 EPA - 430/9-75-015 10. Christensen, L. A., et al An Economic Analysis of the Utilization of Municipal Wastewater for Crop Production Ag. Econ. Report No. 292 Economic Research Service November 1975 ------- I INFILTRATION- PERCOLATION Zone of Acr.ihon and Pollutant Removal Water Mounding r\ Under System 1/ Ground Water Water Loss to Evaporation Water Ponded Water Percolation (Unsaturated Flow) , < Original Level Application Evaporation Water Recovery n—" /^(To Outlet) f- > . . I Percolation (Not Significant) Overland Flow ------- Table 1 LEGAL, TECHNICAL AND ECONOMIC ARGUMENTS FOR CONSIDERATION OF LAND TREATMENT Legal 1. Federal Water Pollution Control Act Amendments require consideration of land treatment. 2. Rivers and Harbors Act (Refuse Act 1899) prohibits discharge of materials to navigable waters. 3. National Environmental Policy Act (1970) established a national goal of clean environment. Technical 1. Almost zero discharge of pollutants to waterway. 2. Drinking quality water returned to groundwater. 3. System flexible to shock loading. 4. Conservation of resources - concrete, steel, energy. 5. Recovery of resources - fertilizer value, water. Economic 1. Cost-effective (based on less restrictive regulations ex. - California). 2. Additional monetary recovery possible through sale of crops. 3. Potential for recovery of drinking quality water. 4. Regionalization more attractive as site most often between wastewater sources. ------- Table 2 COMPARATIVE CHARACTERISTICS OF SLOW INFILTRATION, INFILTRATION-PERCOLATION AND OVERLAND FLOW SYSTEMS FOR MUNICIPAL WASTEWATER (After Pound and Crites (3)) Slow Infiltration Factor Low-Rate High-Rate Infiltration-Percolation Overland Flow Liquid Loading Rate, in./wk, Avg. 0.5 to 1.5 4 to 120 2 to 9 Application Techniques Spray or surface Usually surface Usually spray Vegetation Yes Yes No Yes Crop Production Potential Excellent Good/fair Soils Moderately permeable soils with good produc- tivity when irrigated Climate Constraints Storage often needed Wastewater Lost To: Evaporation and percolation Expected Treatment Performance B-EOD and SS Removal Nitrogen Removal Phosphorus Removal 98+% 85+% * 80 to 99% Poor/none Fair/poor Rapid permeable soils, such as sands, loamy sands and sandy loams Reduce loadings in freezing weather Slowly permeable soils, such as clay loams and clays Storage often needed Percolation Surface runoff and evaporation with some percolation 85 to 99% 0 to 50% 60 to 95% 92+% 70 to 90% 40 to 80% * Dependent on crop uptake. Metric conversion: in. x 2.54 = cm ft. x 0.305 = m acre x 0.405 = ha ------- Table 3 GENERAL DESIGN CONSIDERATIONS Site Wastewater Climate Vegetation Management Soils Geohydrology Topoqraphy Volume Precipi- tation Type Groundwater Slope Water Tolerance Crop Type Nitrogen Growing Season Depth Seasonal Depth Erosion Potential Nutrient Uptake Application Technique Phosphorus Freezing Season Percent and Type of Clay Direction of Flow Cropping Toxicity Tolerance Frequency Heavy Metals Wind Infiltration Rate of Flow Marketability Treatment Goal Organic Component Velocity Permeability Bedrock Toxic Substances Duration Cation Exchange Capacity Organic Hatter Water Retention Depth Type Permeability Note: This is a general list and not necessarily all inclusive. ------- Table 4 CALIFORNIA REGULATIONS FOR THE APPLICATION OF WASTEWATER TO LAND - AFTER MORRIS (1) Water Quality Requirement Ultimate Use Equivalent to Primary-Treated Disinfected, Oxidized Disinfected, Oxidized, Coagulated, Clarified, Filtered 1. Surface irrigation of orchards, vineyards. 2. Food crops which are to be processed. 3. Surface or spray irrigation of fodder, fiber and seed crops. 1. Surface irrigation of food crops. 2. Irrigation of pasture for dairy animals. 3. Restricted recreational impoundment (noncontacted water sports). 4. Landscape impoundments. 1. Spray irrigation of food crops. 2. Nonrestricted recreational im- poundments (contact water sports). 1. Requires permission from Department of Health. 2. Requires median of 2.2 coliform organisms per 100 ml. 3. Requires median of 23 coliform organisms per 100 ml. 4. Requires median of 2.2 coliform organisms per 100 ml; no more than 23 coliform organisms per 100 ml in any 30-day period. 5. California definitions of treatment processes. a. Primary Treatment: Less than 0.5 ml settleable solids per liter. b. Disinfected: Destruction of pathogens. c. Oxidized: Stabilized, nonputrescible, aerobic. d. Filtered: Two turbidity units not to be exceeded 5% of the time. ------- Table 5 COST COMPARISON OF TREATMENT SYSTEMS - AVERAGE ANNUAL COST (CAPITAL AND O&M) $ (THOUSANDS) REF (3, 7, 8, 9, 10) System Land Activated Nitrification Nitrif ication- Lime Coagulation Treatment Sludge Denitrification Selective Ion Exchange + + + Treatment BOD, SS, N, BOD, SS NH, Removal N Removal P, SS Removal P, Heavy j Metals Flow 1 259 286 344 400 463 3 506 532 633 742 891 5 726 714 846 1,002 1,223 10 1,240 1,133 1,308 1,593 1,970 50 5,140 4,000 4,672 5,694 6,570 100 8,990 7,242 8,292 10,395 11,680 Assumptions Activated Sludge: Complete system costs including; sludge thickening, digestion, vacuum filtration and trucking to landfill sites. Land Treatment System: a. Aerated lagoon pretreatment with chlorination. b. 2.5 mile transmission (Q < 10 mgd). c. 2 inches per week application rate. d. 10-week storage. e. Center pivot application. f. Underdrained on 150-foot spacing of tile. g. $1,000 per acre. h. Crop return - 15.7 cents per thousand gallons treated (approximately $300 per acre). Advanced Waste Treatment: Costs reflect integrated system construction. ------- Land Utilization/Disposal of Municipal Wastewater Sludge by Bart T. Lynam General Superintendent Metropolitan Sanitary District of Greater Chicago and Raymond R. Rimkus Chief, Maintenance and Operations and James L. Halderson Agricultural Engineer presented September 10, 1976 at the Symposium on the Technical Response to PL 92-500 sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- LAND UTILIZATION/DISPOSAL OF MUNICIPAL WASTEWATER SLUDGE Bart T. Lynam, General Superintendent, Metropolitan Sanitary District of Greater Chicago and Raymond R. Rimkus, Chief, Maintenance and Operations and James L. Halderson, Agricultural Engineer The Metropolitan Sanitary District of Greater Chicago (district or MSD) serves the City of Chicago and approximately 120 adjacent suburban com- munities covering an area of about 900 square miles. The district was originally organized under an act of the General Assembly of the State of Illinois in 1889. The district's sewered population of 5.5 million people represents about 70 percent of the Illinois total sewered popula- tion. The population equivalent of 5.5 million for all other inputs (commercial, industrial and inflows) brings the total population equivalent served by the district to 11.0 million people. From this residential and industrial complex, the district collects and treats 1.4 billion gallons of sewage every day. For the past several years, solids produced from the treatment of the district's sewage for ultimate disposal amounts to approximately 600 dry tons/day. This amount in recent years has been reduced significantly by the enactment of the Industrial Waste Surcharge and Sewage and Waste Control Ordinances (1969). Both of these industrial waste ordinances have been vigorously carried out in the district's service area. Prior to 1971, processed sewage solids were either stored in lagoons in liquid form, were heat-dried and sold in bulk as a dry fertilizer for agricultural use, or were air-dried (Imhoff digested sludges only) and stored on district property. It is not difficult to understand that in a large urbanized center such as Chicago, that space for storage lagoons was limited. Indeed, additional storage lagoon space is no longer avail- able in or around Chicago. For the three disposal modes mentioned, the problems were multiple and include: for lagooning - a small reduction in volume, no more available land and occasional complaints of nuisances; for air drying - very little volume reduction and no more available land; for heat drying - freeze on natural gas allocation and an almost exponen- tial cost increase for air pollution control and for natural gas. To say that the district was confronted with a solids dispoaal problem would be an understatement. ------- Faced with this virtually insurmountable and ever increasing problem, the governing board of the district in 1967 assigned to the staff the task of developing recommendations for a long-term sludge disposal scheme which would ideally incorporate the following criteria: 1. Eliminate air and water pollution problems caused by other methods of disposal. 2. Conserve and utilize all resource materials for beneficial purposes. 3. Be economical, or at least, be no more costly than other methods. 4. Be permanent, i.e., complete the natural cycle into perpetuity. Following several years of surveys, feasibility studies, laboratory ex- perimentation and field demonstrations within Metropolitan Chicago and elsewhere in the state, the Board of Commissioners, upon the recommendation of the staff, established the policy that properly processed municipal sludge was a valuable natural resource and must be utilized. With this policy, the Prairie Plan was born and implementation began in 1970 with the initial purchase of 7,100 acres (28knr) of partly strip mined lands in Fulton County, Illinois, approximately 190 miles southwest of Chicago. At the beginning of the Prairie Plan project, it should be pointed out that no federal direction on sludge utilization existed. The State of Illinois EPA established, for the first time with this project, regulations and a permit system in 1972 which remain in effect today. The district's research was the primary basis of the regulations. LAND UTILIZATION SITE Site Selection The district selected the Fulton County site because of several advanta- geous features. The soils are deep and predominately silt and clay in composition to offer a great absorptive capacity to minimize the potential for nitrogen contamination of groundwaters. Secondly, the soil is mostly neutral in pH, contains comparatively few rocks and is usable in fairly large-sized fields. Sufficient land was available in a single tract to justify the large expenditures for capital facilities. Environmental monitoring at the site was somewhat facilitated because most of the sur- face drainage channeled into a single waterway. Site Development To date, the district has reclaimed land with the end utilization of agricultural row crop capabilities in mind. Two general systems have been utilized to date in the soil rebuilding program. In one type of work the topography is changed by grading to generally accomplish slopes of less than 5 percent, but which still provide for good surface drainage without erosion. Debris such as rock and steel cable ------- is removed to a depth of one foot or more. Berms are placed around each field so that all surface water runoff is directed to adjacent retention basins for temporary storage and analysis prior to release to the natural water course. Berms also divert water from surrounding areas to minimize the volume to be stored. Retention basins were designed to receive the 100-year frequency storm runoff, which for central Illinois amounts to a bit over 5 inches of water. Areas outside of application fields that were scarified are seeded to permanent grasses for erosion control. A later type of land development has been directed toward use of fields without general disturbance of existing pasture grasses. Minor eroded areas are improved, but facilities are not installed to control and col- lect surface runoff. Although the first of these later systems is in the late stages of installation and it is too early to speak of opera- tional experience, it is planned to harvest several cuttings of hay each year from the application area. Application for this system will be by gated pipe and it is planned to apply both supernatant and sludge solids. An experimental area of approximately 50 acres is being used for testing the concept of incorporating sludge solids into the rough corduroy land as it is initially being leveled. If successful, such a method would result in a much deeper topsoil and would also increase sludge application' per acre. Sludge Handling and Application System Sludge is transported by barge on the Illinois River from Chicago to Liverpool, Illinois, a distance of approximately 180 miles. Initially, only freshly digested anaerobic sludge was shipped with a solids content of approximately 4 percent. The last several years, sludge has been sent primarily from lagoon storage with an increase in solids of several percent. From the Liverpool dock, sludge is unloaded and piped underground year-round a distance of approximately 11 miles to on-site storage basins. A conventional dredge is used to remove sludge from storage. It has a cutter head which can reach down to the bottom of the holding basins to remove sludge with a higher average solids content than the basin input. The dredge discharges to several large tanks onshore which serve as the supply system for field distribution. Distribution pumps are of the high head open impeller type with two pumps, for series or parallel operation, per distribution line. Each distribution line serves approximately 250 acres and sometimes exceeds four miles in length. Distribution pipes are on the surface for easy access for main- tenance, but must be flushed and drained about November 1st each year for winter weather. Sludge distributed to fields is presently approximat- ing 5 to 6 percent in solids content. In the fields, sludge can be applied by several methods. Early in the operations, large traveling sprinklers were the primary application method. They have an advantage of being able to apply to a growing crop, but have the disadvantage of excessive runoff, spray drift and visual unsightliness. ------- Tillage is primarily used at the present to incorporate sludge into the soil as it is being applied. Figure 1 shows such a machine. An incor- poration unit can apply more sludge per pass than a sprinkler, leaves far less exposed for potential runoff and can apply to steeper slopes. The capital investment and operational cost is somewhat greater for incorporators. Generally, the solids content of sludge is limited to 6 percent for sprinklers and 12 percent for incorporators. An experimental center-pivot sprinkler has been installed to develop a prototype unit for application at low pressure. If such a unit is developed, it is proposed that its major advantages would be in the capability of applying to existing crops with a machine that poten- tially could be automated but without the spray drift problem of present sprinklers. A gated pipe system is presently being installed for use on approximately 1,500 acres. This system was briefly mentioned in the site development section above. Site Operation The district provides a resident supervisory staff at the site to conduct the affairs of the district. Manpower for operation of the sludge applica- tion system is obtained through a contractual bidding process. Initial site preparation and installation of distribution systems and other major items are also done under contract. FIGURE 1 An incorporation machine for applying sludges of up to 12 percent solids ------- Agricultural crops are produced annually on those fields which are not being utilized for sludge application. A rotational system of cropping and sludge application is evolving to optimize nutrient utilization and erosion control while land is being rebuilt. Crops such as corn or soy- beans are usually contracted from "bag to bin," but other crops primarily aimed at erosion control are accomplished with district facilities. Prior to being strip mined, much of this land was in row crop production by private venture The district has not established definite plans for returning land to the private sector at this time. Monitoring at the site is done for the mast part with district staff, but several outside agencies do spot sampling to corroborate district results. Site Monitoring The system was designed to operate in a fail-safe manner. Collection of all application field surface runoff is done by the retention basin, field berm system. Collected water is analyzed prior to release. If the waste should not meet state standards, it is held to correct the offending constituent(s) or is applied to adjacent fields for purification. Suspended solids most often cause difficulty. Several small streams that run through the property are monitored at points where they enter and leave the property. The U.S. Geologic Survey, state EPA and county health department also monitor some of the surface water. Numerous shallow wells have been located throughout the property for purposes of monitoring groundwater. Prior to the start of sludge appli- cation, background concentrations were established for groundwater as well as numerous other parameters. Well points surround the main sludge holding basins to detect any seepage into the groundwater. Periodic samples of soils are taken to determine organic matter increase, con- centrations of heavy metals, concentrations of plant nutrients and other items. Crops are monitored for composition. In addition to the above mentioned parameters that are being monitored, lakes on the site are periodically sampled for biological specimens ranging from fish to microorganisms. The University of Illinois School of Veteri- nary Medicine is conducting a research project aimed at determining whether parasites and heavy metals can cause problems in the cycle of using sludge to produce forage upon which livestock are fed. Both direct grazing and stored feeding are employed in the project. Numerous other research and monitoring projects are being conducted but will not be elaborated upon herein. REGULATORY ASPECTS C 1.U v „ woor npriod. the USEPA has been attempting to establish or the past th e tlon of 3iudge on land. The latest regulations regulation for utalization^of s ^g^ ^ ^ ^^ ^ ^ e«l°RegistM The public was allowed tomato comments until September 3. q TT ; v o nf aDecific points contained an the current reguUUons ™7how they affect land utilization of municipal eludges. ------- Policy Toward Land Utilization The preamble to the regulations states that EPA's current program emphasis has shifted toward improved technology for returning sludges to the environ- ment in an ecologically acceptable manner. If such is the case, then the regulations require a much more positive approach toward land utili- zation. All disposal systems have related operational problems but yet, disposal must be made somewhere in the environment. Land utilization offers several very positive aspects - such as recycle of valuable plant nutrients and returning of organic matter to beneficial use - while tending to minimize adverse environmental effects when compared to land- fill, incineration and lagooning. If EPA favors land utilization, then the regulations should be revised to reflect a more positive tone and perspective. Multiple Agency Jurisdiction In Section 2-4.2, 2-4.4, Project Review, it is noted that USDA and FDA are to be involved in project reviews. The criteria or mechanism for review by these two agencies is not noted. It would not appear to be acceptable to have three coequal agencies in- volved in review of a project. Presumably, any one of the three agencies or the state agency could reject a project even though the others might approve. Further, it would not appear acceptable to start again from the beginning with issuance of criteria, public review, etc., because too much time has already passed by without establishment of definite regulations. It is not reasonable at this time to make the necessary large capital investments in land utilization facilities when regulations remain at an impasse. History has documented that EPA has not allowed some new incinerator facilities to be operated after they were constructed. It is unclear at this point why the EPA has decided to transfer some of its regulatory and review authority to the FDA and USDA. Clearly, only the EPA has the responsibility for reviewing construction grant applications and granting awards for sewage treatment facilities. It appears wholly unwarranted to shift such authority to these agencies when the responsibility unquestionably rests with the federal EPA. Monitoring Requirements The regulations have continually alluded to more and more monitoring being necessary for practically all land utilization systems. Consid- erable information is presently available on certain aspects to reasonably preclude them from monitoring requirements at most sites. However, EPA has not changed its basic approach toward monitoring since initial drafts of regulations several years ago. It is suggested that specific concen- trated attention be given to those problem areas in order to develop valid research information at an early date. To require extensive general monitoring at most sites is to spread research monies and expert personnel so thin as to not make progress in problem areas. ------- Agriculture is an important long-term user of sludge. The suggested limitation without monitoring is 10 DT/A/yr. of liquid sludge. We believe that this amount is too low to allow municipalities to distribute their sludge products to the general public for use on farms and other agri- cultural operations. It is vital that farmers and other individuals interested in using sludge as a fertilizer be allowed to apply sludge at rates which will equal the nitrogen requirements of the crop grown. If a farmer or other user cannot apply sludge at this rate without moni- toring requirements, he simply will not avail himself of the municipal sludge. For some sludges, 10 T/A/yr. will not supply sufficient nitrogen for certain crops. If municipalities are going to have use of their sludge products by the general public, monitoring requirements must be consistent with crop nitrogen requirements. The district recommends that the monitor- ing loading rate limit be raised from 10 T/A/yr. to 15 T/A/yr. This will allow users of municipal sludge to apply it at rates consistent with crop requirements, yet avoid a costly monitoring program. Many of the present public objections associated with municipal sludge application to land could be avoided if sludge products could be distri- buted to the general public without monitoring requirements. The sludge would be disseminated to people who want the product, the product would be applied usually only once per year and there would be no Single large project where public attention would be focused. Dedicated Lands Several parts of the regulations note that greater amounts of sludge can be applied to those lands that are dedicated to sludge application or lands that are forested. More than sufficient operational information is available to show that crops such as corn, wheat and soybeans do not have a pathogenic or heavy metal problem. Therefore, it seems quite unjustifiable to consider de- grading certain tracts of land. There is not sufficient sludge available to begin correcting even a modest portion of lands that have been disturbed in the past by strip-mining, metal extraction, road building and other of man's activities. Dedicated lands is an invalid concept because there are no evident problems with sludge utilization oh land that cannot be readily handled by current technology and management. Section 2-4.2: Protection of Food Products and Agricultural Lands This section contains restrictions related to the pathogen content of sludge products. In this section it is stated that land to which sludge has been applied cannot be used for growing crops to be eaten raw until three years after sludge application ceases. The district is of the opinion that a blanket restriction on sludge application to vegetables should not be given in the guidelines. Certain sludges which have received sludge treatment to reduce or eliminate pathogens may be acceptable for such use. This should be determined on a case-by-case basis. ------- In another paragraph, it is required that "sludge should be negative for Salmonella and Ascaris ova if applied to crops normally cooked in the home before consumption, but marketed without being subjected to a process which is lethal to pathogenic microorganisms and parasites". Again such blanket requirements are unnecessary for sludge which is ex- tensively processed for pathogen reduction or elimination prior to ap- plication to soil. Also, for this requirement, it appears unnecessary to limit the presence of certain pathogens when it is known that many natural soils contain these pathogens in quantities above those found in sludge. The district since 1974 has been distributing a product called "NU EARTH" to the general public free of charge. This product is used extensively for home gardens. This product is air-dried Imhoff sludge (15 percent solids) which has been stored for many years to achieve a solids content over 35 percent and further pathogen reduction. Since 1974, the district's R&D Department has had an experimental vege- table garden where NU EARTH has been applied to various vegetables such as carrots, radishes and tomatoes. Both the 1974 and 1975 reports show that the pathogen content of the vegetables grown on NU EARTH fertilized soil was no different from those grown on chemically-fertilized soil. Clearly then, it is unreasonable to put blanket pathogen restrictions on sludge applications unless one is familiar with the sludge utilized. There are undoubtedly many other sludges besides NU EARTH which could be used for growing vegetables and other commodities in the home garden. The district suggests deletion of the requirement for cessation of sludge application three years prior to growing crops eaten raw and the require- ment that sludge be negative for Salmonella and Ascaris ova prior to application to crops not commercially processed but normally cooked prior to consumption. It is suggested that the EPA regional offices review individual projects to determine guidelines for specific projects. AMSA FIELD REPORT ON CURRENT PRACTICES AND PROBLEMS OF SLUDGE MANAGEMENT The Association of Metropolitan Sewerage Agencies (AMSA) recently compiled information from membership (54 members) on sludge management practices. AMSA represents approximately 55 million people and roughly 33 percent of the total service population of the United States. The estimated amount of sludge generated yearly is 1 million dry tons. A sample of 20 representative members was chosen to examine 3ludge manage- ment issues. Eleven sewerage agencies viewed incineration as an attractive sludge disposal alternative while eight opposed incineration. Unavailability of land was cited as the major reason in the decision. Twelve of the 20 interviewed stated land application was impractical for them because of heavy metals, unknown groundwater effects, it was uneconomical, or because land was not available. Five members gave a positive response to land application. Groundwater effects of land application reflected in uncertainty of most AMSA members. Ocean disposal was not extensively discussed because the federal policy makes it unacceptable for all but the present users. ------- Seventeen of the interviewees indicated that they were beset with political or regulatory constraints, such as inability to transport sludge across other jurisdictions, lack of industrial waste ordinance and extensive delays in approval of facility plans. Public involvement was noted as having two general effects. Complaints about nuisances caused by plant operations or by sludge management programs was one, while lengthy delay in putting facilities on-line due to public resistance was the other problem of note. AREAS NEEDING ADDITIONAL RESEARCH Plant Uptake of Heavy Metals There is data presently available from several sources which shows that some agricultural crops do not encounter heavy metal problems when grown on sludge application areas. These crops are corn, wheat and soybeans, when all are grown for grain. Analysis of grain has shown that the sludge grown crops cannot be distinguished from normally grown crops. Greenhouse pot studies with soluble salts have been used by numerous researchers for modeling sludge response in the field. However, sufficient full- scale results are available to show that such a model is not a reliable indicator of responses in the field. Additional data is needed on other crops to provide a wider selection for use when sludge is applied. Forages are especially needed because of the greater likelihood of their use as opposed to row crops. Site management requires flexibility in use of different plants for various purposes but the heavy metal uptake of forages is not sufficiently known at the present time to permit their widespread use on sludge application sites. Information is needed on the effects of a fallow period, following sludge application, on reducing the gross quantity of heavy metals utilized by plants. There is some indication that a fallow period can considerably reduce the total heavy metal uptake by plants - at least by certain plants. Mineralization Rates Utilization of sludge on land is primarily done in two distinctly different settings. In one case, organic matter is needed in large quantities per acre to rebuild soils that have been disturbed by man's activities, such as strip mining, road building, building construction and so on. In this setting, sludge is applied because of its stable organic matter content and relatively little value is placed on associated plant nutrients. In the other case, sludge is used to provide plant nutrients to various agricultural crops where the nutrient application quantity is in balance with the requirements of the particular crop. Much of the total nitrogen in the sludge occurs in the organic matter. To become available for plant use, the organic matter must be decomposed - mineralized by the soil micro- organisms. Therefore, it is necessary that reasonably accurate mineraliza- tion rates be available for various sludges and for differing soil types. Nothing will diminish agricultural usage of sludge as a nutrient source any faster than will poor crop responses due to insufficient nutrients, ------- primarily nitrogen. This item requires immediate attention because most sanitary districts have far greater acreages of agricultural land immedi ately nearby than they will have acreages of disturbed land. Pathogen Transmission The potential for recycling of viable bacterial pathogens appears to be very small sii.ee no documented evidence exists of such difficulties actually having occurred. However, sound management practices should still be employed to tend to minimize the potential. Viral transmission appears to be quite a different situation from bacterial transmission. Only recently have techniques been perfected for being able to trace introduced virus through such a system. Additional research funding and efforts are needed. Even with an aggressive national program it is likely that progress will be quite slow due to the nature of the re- search subject and the available technology. SUMMARY The district Prairie Plan has been unigue in several areas. It is the first large-scale program for utilizing municipal sludge on land in this country. Moreover, the documentation and research has been conducted to provide verification of cause and effect relationships. The Prairie Plan is a working example of sludge utilization to solve disposal problems, and it is working. Clearly the project demonstrates that sludge can be beneficially utilized on land to reclaim disturbed soils and to produce certain agricultural crops in an environmentally-sound manner. ------- When is Advanced Wastewater Treatment the Answer? by William A. Whittington Acting Deputy Director Municipal Construction Division Environmental Protection Agency, Washington D.C. presented September 10, 1976 at the Symposium on the Technical Response to PL 92-500 sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- WHEN IS ADVANCED vv ASTEWAi tK I KhATMENT THE ANSWER? William A. Whittington, Acting Deputy Director, Municipal Construction Division, Environmental Protection Agency, Washington, D.C. There have been many attempts to define the term "advanced waste treat- ment", but none of these has really caught on. As a result, whenever there are two engineers discussing advanced waste treatment in general, the odds are high that they are not talking about the same thing. For the purposes of this paper, advanced waste treatment is defined as waste- water treatment processes used by publicly-owned treatment works generally (but not always) to meet effluent limitations other than the EPA secondary treatment definition. That secondary treatment definition is 30 mg/l BOD and suspended solids on a monthly average. Thus, advanced waste treatment could be for pollutants other than BOD and suspended solids or it could be for more stringent BOD and suspended solids limitations than secondary treatment. Also, it could be an innovative or "advanced" treatment process to meet secondary treatment. Similarly, there is no clear background on where the term "advanced waste treatment" came from. Different origins are given, including the naming of the advanced waste treatment lab in Cincinnati in 1961, the unsuit- ability of the term "tertiary treatment" and the general idea that any- thing that is new and advanced must be better. In the EPA construction grants program, we have found that an accurate and all-encompassing defini- tion is not practical. Application of the term to a specific plant can be inappropriate, regardless of the definition used. Additionally, we have seen the fallacy in the concept that advanced eguals better and have tried to focus more on cost-effectiveness. The result is that our emphasis has been on describing unit processes, rather than trying to arrive at a label or all—encompassing term. The unit processes which are available now to meet the more stringent effluent limitations vary depending on the desired objectives. There are seven major categories of pollutants which need to be addressed in consideration of treatment processes. These are pathogens, BOD and sus- pended solids, phosphorus, ammonia, nitrogen, toxic metals, or organics. Table 1 shows the types of treatment processes which are available now to be used for each specific pollutant. For each category of pollutant ------- the processes are listed in descending order of use. That is, for disin- fection, chlorination/dechlorination is most commonly used, followed by ozone and so forth. In some cases there is interaction between the pollutants and the processes involved. For example, chemical addition to remove phosphorus may also remove suspended solids, BOD and heavy metals. Nationally the application of these pollutants shows some variation. Table 2 shows that about two-fifths of the major publicly-owned treatment works discharge effluent to water quality limited streams or waters (i.e., where requirements more stringent than secondary treatment apply). These treatment plants serve about two-thirds of the 160 million sewered popula- tion. The remainder of the treatment plants either dischuge to effluent limited segments (i.e., where secondary treatment applies) or, to a leaser extent, use land treatment or other reuse systems. These figures do not include disinfection which was recently removed from the secondary treatment definition. As the water quality requirements now stand, disin- fection is required when needed to protect the public health such as near water supplies where the discharge can affect shellfish beds or where the discharge is to recreational waters. It must be emphasized that in discussing a water quality segment, it is not meant to imply that all seven categories of pollutants apply to these segments. F^r example, in a particular segment only phosphorus may be a pollutant of concern beyond secondary treatment. Such a segment would still show as a water quality segment. Looked at in these terms we can discuss each of the pollutant categories in general terms of its national applicability. Phosphorus and nitrate nitrogen are usually removed because of concern about their nutrient value contributing to eutrophication in slow-moving streams, estuaries or lakes. Thus, it is not surprising that we find a concentration of the phosphorus and nitrate requirements in the Great Lakes area (Figures 1 and 2) Other locations for nutrients include isolated lakes which have been found to be sensitive, such as Lake Tahoe, or slow-moving streams in relatively warm climates such as the Potomac River Estuary. A recent trend has been to defer nitrate removal until such time as the performance of the phosphorus removal step has been evaluated. For example, at the Blue Plains plant in Washington, D.C., the decision has been made to proceed with phosphorus removal and nitrification, but to evaluate the effects of this treatment on water quality before proceeding with the more expensive and energy-intensive nitrate removal. BOD and suspended solids removal are generally pervasive throughout the country where there are critical dissolved oxygen problems. Ammonia removal, or alternatively oxidation of ammonia to nitrate, is most common in streams where the ammonia oxygen demand can be a significant source of dissolved oxygen depletion (Figure 3). Some states have also imposed ammonia requirements for the winter months on the basis that ammonia can be toxic to fish. Heavy metals and organics removals are rarely required except where water supplies are involved or particular industries are known to be present and have a significant part of the treatment plant flow. ------- A recent report by the EPA Office of Research and Development (Interior Report on the Impact of PL 92-500 on Municipal Pollution Control Technology by Lykins and Smith) summarized these requirements. The 1973 Needs Survey data indicated that 780 municipal wastewater treatment plants planned to remove phosphorus to a level of less than or equal to 1 mg/1 and the 698 intended to achieve less than or equal to 1 mg/1 of inorganic nitrogen. Conventional secondary wastewater treatment systems cannot reach this level of effluent quality, but advanced waste treatment processes can be incorporated into them to produce the required results. Effluent total phosphorus, for example, can be reduced to less than 0.05 mg/1 in a biological treatment plant where two-stage, tertiary lime addition plus filtration are provided. In the case of inorganic nitrogen, processes can achieve concentrations below 1 mg/1 for nitrate and ammonia nitrogen. It should be noted, however, that all of the total nitrogen values will exceed 1 mg/1 because present technology cannot prevent at least that amount of refractory organic nitrogen from passing through each system. Advanced waste treatment is used in the EPA Construction Grants Program when it is most cost-effective. One of our major goals in EPA is to ensure a thorough evaluation of the alternatives including, but not limited to, advanced waste treatment. It is our general finding that alternatives such as land treatment, nonpotable reuse, individual home treatment units or lagoons are not always being adequately analyzed and fairly considered in the facility planning process. Although our cost-effectiveness requirements clearly state that both operat- ing and capital costs are to be considered in making the cost-effectiveness determination, the fact is that the grants program is capital intensive. That is, federal money is available to assist with the capital portion of the project but is not available to assist with the operation and maintenance costs. As is well known, the cost of wastewater treatment increases as the effluent limits become more stringent. We recently analyzed capital costs based on bid data for secondary treatment systems. This data was then extrapolated for the higher effluent limits as shown in Table 3. Note the significantly greater capital costs for smaller plants. Because of the capital intensive nature of the grants program and for a variety of other reasons (perhaps most fundamentally, because sanitary engineers are used to treatment processes), there has been a recent unfor- tunate trend to the use of advanced waste treatment in small plant situa- tions where one of the alternatives may be more appropriate. Projects of this type authorized by laws previous to PL 92-500 are now coming on-line. In some cases the user charges for local operation and maintenance of these systems are a staggering surprise to the local residents. It is our view that when the true user charges of these sophisticated systems, particularly in small towns, become more widely known, local pressure and vigilance will increase. Combined with the EPA review, this will result in more comprehensive consideration being given to alternatives to treatment and discharge. There are many case histories which dramati- cally illustrate this situation. One recent example showed an increase per household of $200 per year in sewage collection and treatment costs. ------- Advanced waste treatment has a place in the overall scheme of wastewater treatment and EPA's construction grants program. It is not a panacea, and alternatives such as land treatment and nonpotable reuse become very attractive in comparison with higher levels of advanced waste treatment (Figure 4). In smaller communities where operation and maintenance capa- bility maybe severely limited, full consideration should be given to the effect of user charges for advanced waste treatment on the individual home owner. The sludge problems associated with conventional treatment can increase by an order of magnitude when chemical addition, toxic metal or organic removal and various waste carbons are involved. EPA's goal in the grants program is to be sure that alternatives are fairly considered and the most cost-effective solution is chosen. Table 1 ADVANCED WASTE TREATMENT PROCESSES Disinfection BOD & SS NH, Chlorination/ Dechlorination Ozone Bromine Chloride Ultraviolet Biological Chemical Carbon Filtration Biological Air Stripping Ion Exchange Breakpoint — Chlorination N0- Metals Chemical Biological Reverse Osmosis Chemical Filtration Orqanics Carbon (Granular) Biological Carbon (Powdered) ------- Table 2 ESTIMATED DISTRIBUTION OF PUBLICLY-OWNED TREATMENT WORKS Water Quality Limited Effluent Li mi ted Total Major 1,676 1,373 3,049 Minor 7,242 11,012 18,254 Total 8,918 12,385 21,303 Table 3 CAPITAL COST FOR MORE STRINGENT EEfLUENT LIMITS Lb./Gallon BOD/SS P nh3 NO^ 1 mgd 10 mgd 20-30 2.15 1.40 5-19 2.55 1.65 5-19 R 2.65 1.72 5-19 R R 3.00 1.95 5-19 R R R 3.30 2.20 <5 R R R 3.90 2.55 R = Removal Required ------- I Figure 1 States with Water Quality Standards for Phosphorus ------- Figure 2 States with Water Quality Standards for Nitrate Nitrogen ------- Figure j States with Water Quality Standards for Ammonia Nitrogen ------- Advanced Technology Helps Solve a County's Water Pollution Problems The Durham Facilities by James A. Crom Senior Vice President and General Manager Environmental Engineering Division Stevens, Thompson & Runyan, Inc. presented September 10, 1976 at the Symposium on the Technical Response to PL 92-500 sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- ADVANCED TECHNOLOGY HELPS SOLVE A COUNTY'S WATER POLLUTION PROBLEMS: THE DURHAM FACILITIES James A. Crom, Senior Vice President and General Manager, Environmental Engineering Division Stevens, Thompson & Runyan, Inc. ' The Durham Advanced Wastewater Treatment Plant is the fruit of planning efforts initiated in 1969 by the citizens of Washington County, Oregon. In 1966, there were 26 service districts and 9 cities operating some 46 treatment plants which served the Washington County area; the majority of these plants discharged into the Tualatin River or one of its tribu- taries. The Tualatin River is a meandering stream with low summer flows of about 15 cfs. The low stream flow combined with runoff from agricul- tural lands, drainage from septic tanks and inadequately treated sewage from the plethora of treatment plants turned the Tualatin into little more than a sewage lagoon with high algae concentrations during the summer months. AREA-WIDE PLAN DEVELOPED In 1969, an area-wide wastewater management plan developed by Stevens Thompson & Runyan was presented to the local citizenry. The master plan recommended that all treatment plants on the tributaries of the Tualatin be abandoned and six new or expanded plants, located on the Tualatin itself, be utilized to effect complete wastewater treatment. In addition the plan called for the formation of an area-wide agency which would ' have responsibility for implementing, financing, constructing and operat- ing the proposed regional facilities. The Unified Sewerage Agency of Washington County (USA) was established in 1970 and has responsibility for area-wide wastewater management in Washington County. It is signi- ficant that a local citizens' group, the Clegn Water For Life Committee was instrumental in helping the USA promote the successful passage of ' a $36 million bond issue, which is being used to finance the capital construction program. The Durham Advanced Wastewater Treatment Plant serves the highly-pooulated Fanno Creek Basin, which drains into the eastern reach of the Tualatin River near its confluence with the Willamette River. Figure 1 shows the location and service area of the Durham plant. This plant is desioneH to serve an initial population of about 170,000 people with an initial ------- capacity of 20 mgd. The plant was designed to accommodate expansion up to 60 mgd. The $22.2 million construction cost was financed with a 75 percent grant from the Environmental Protection Agency and 25 percent matching funds from the USA. FACILITIES MEET STRINGENT STANDARDS Effluent criteria were established for the Tualatin River by the Oregon Department of Environmental Quality (DEQ). The criteria reflect critical water quality conditions occurring during the summer low flow period. The DEQ standards call for no more than 5 mg/1 each of biochemical oxygen demand (BOD) and total suspended solids (TSS), 85 percent removal of phosphorus and a dissolved oxygen (DO) level such that the effluent will not drop the DO level in the receiving stream below 6 mg/1 during the summer low flow period extending from May through October. During the high flow winter period, the DEQ standards require an effluent with no more than 20 mg/1 each of BOD and TSS. While the required effluent quality for winter periods can be produced with the conventional activated sludge system, tertiary treatment must be provided for additional removal of BOD, TSS and phosphorus during the summer season. Since the effluent criteria established by the Oregon DEQ are so restric- tive, consideration was given to discharging directly to the Willamette River, which is located approximately six miles to the east. At the time the sewerage facilities plan was developed, the effluent standards for the Willamette River required no more than 20 mg/1 each of BOD and TSS; however, the DEQ advised that the standards would be reduced to 10-10 in the near future. It was determined that it was not economically feas- ible to convey the sewage from the Durham plant to the Willamette River. In addition, the effluent discharge to the Tualatin River would be of better quality than the river itself, at least during critical summer periods, and thus would serve to improve the water quality through dilution. Figure 2 is a process schematic of the entire Durham Advanced Wastewater Treatment Plant. During the low flow season, which extends from May through October, both the secondary and tertiary systems will be in opera- tion. From November through April, the plant will be operated as a conven- tional activated sludge system. The tertiary treatment system includes two-stage phosphorus removal and mixed media filtration. In addition, a 15 mg flow equalization basin has been provided to dampen diurnal flow variations to the tertiary system. SLUDGE HANDLING DIFFICULT AND COSTLY The secondary system is of conventional design with the exception of the sludge disposal element which employs incineration. The preparation of the secondary sludge for incineration is a difficult and costly opera- tion. In order to minimize the incineration costs, it is desirable to have self-sustaining combustion, which requires a solids concentration of at least 25 percent. The primary sludge is processed through a cyclone degritter and gravity thickener prior to being introduced into the "Porteus" ------- heat treatment system. The waste biological solids are thickened by disc centrifuges prior to introduction to the heat treatment system. The primary and secondary sludges are combined after heat treatment, dewatered by solid bowl centrifugation and incinerated in a multiple-hearth furnace. The overflow from the blend tank and the centrate from the dewatering centrifuges are combined and aerated in a high-strength aeration basin prior to metering back into the regular flow system. This controlled metering of the high-strength waste has a very beneficial effect on the operation of the secondary biological system. ADVANCED TREATMENT REMOVES PHOSPHORUS The tertiary system consists of two-stage phosphorus removal and mixed media filtration. The primary mode of phosphorus removal will utilize lime addition and precipitation of phosphorus as hydroxyapetite. Provision has been made to feed both iron and aluminum salts as back-up chemicals to the lime system. Lime will normally be mixed with the secondary ef- fluent to raise the pH above 11 prior to the primary chemical reactor- clarifiers where the phosphorus is removed through chemical precipitation; some additional removal of nonsettleable solids is also realized. In order to increase the recovery of lime, the effluent from the primary chemical reactor-clarifier is recarbonated by dissolving CO2, reducing the pH to about 9.3, which is near the point of minimum solubility of calcium carbonate. The excess lime is then removed as calcium carbonate in the secondary chemical reactor-clarifier. To prevent the formation of unwanted calcium carbonate and scale formation, the pH is further reduced to about 7 in the secondary recarbonation basin. The combined sludge from the chemical clarifiers is thickened by gravity prior to separating the phosphates as hydroxyapetite from the chemical sludge in the classifying centrifuges. Following classification, the chemical sludge will be recalcined in a multiple-hearth furnace, which is similar to the organic furnace. The recovered lime is recycled to the chemical treatment system. The hydroxyapetite sludge is wasted to the organic incinerator. The chemical process was designed to operate essentially as a closed system with 15 to 25 percent lime makeup expected. To automatically convey the recalcined lime from the bottom of the furnace into a large storage silo, the plant will use a pneumatic conveying system. The system also uses a second air blower to automatically fill the two day-use tanks from the two large storage silos. The lime is automatically fed to slakers and into the chemical reactor-clarifier. As a reliability feature to back up the organic incineration process, the lime recalcining furnace can also be used to burn the organic sludge when the organic incinerator is down. Under the .incineration mode of operation, the organic ash is conveyed by the pneumatic system to a cyclone separator from which the sterile ash is transported by truck for final disposal. A dust collector is provided to prevent dust emissions during in-plant conveying operations and truck unloading of makeup lime supplies. In addition, feeder valves throughout the system are provided with motion ------- safety switches to signal an alarm to the plant control panel in the event of unscheduled stoppage. Finally, automatic and manual diverter valves are provided for automatic and standby operation of the pneumatic conveying system. In order to comply with the region's stringent air pollution standards, each incinerator has been eguipped with a Venturi scrubber to control particulate emissions and an after-burner to insure that hydrocarbon and carbonyl levels are within acceptable ranges. Particulate emissions are continuously monitored, using double-pass transmissometers. The electrical power supply and distribution system must operate with a high degree of reliability to keep the wastewater discharge within the strict environmental limits established by the DEQ and the EPA. Elec- trical reliability at the plant begins with connections into Portland General Electric's 115,000-volt looped transmission line system in the area. The electrical system brings service to the Durham plant from two different directions. Automatic switching in the Durham substation is arranged to take service from either or both 115,000-volt lines as needed. Two main transformers are provided, either of which is adequate to serve the entire plant load. Each of the various local substations throughout the plant is served by two lines from the main substation and either line has adequate capacity to serve the loads. Each local sub- station also includes two or more transformers connected through secondary circuit breakers and high-capacity bus systems so that failures can be isolated for repair. Duplicate pieces of plant machinery are connected to different local substations so that at least a minimum portion of the required process system will always be operable. As one last measure of assurance, the main Durham substation has space and connection facilities provided for connection of power company mobile transformer units if required. TRAINING ESSENTIAL TO EFFICIENT OPERATION Operation and maintenance play a major role in such a complex treatment process. In addition to the plant superintendent and the operation super- visor, the Durham plant has five plant supervisors and 29 operators, plus a maintenance supervisor and 29 maintenance personnel, a lab super- visor, two lab technicians and a secretary. Most of the personnel have transferred from the smaller existing treatment plants, which these new facilities are replacing. An extensi.ve training program for plant per- sonnel began more than a year ago when facilities were still under con- struction. In addition to preparing the operation and maintenance manual, STR worked with the plant supervisors to set up the training procedures and developed lesson plans. The supervisors have conducted three-week training sessions for groups of ten staff members. The lessons included both basic theory for effective problem solving and detailed operating instructions and testing. The staff is currently developing a set of visual aids for permanent use as reference material and in upgrading plant personnel and training new employees in the future. The Durham facilities also include a modern water quality laboratory. Staffed by four chemists, two lab assistants and a supervisor, this district ------- laboratory will serve the entire Unified Sewerage Agency's service area. In addition to monitoring the six treatment plants in the USA system the lab will primarily be responsible for testing and checking industrial waste discharges in the county. To conduct the necessary tests, the lab now has a gas chromatograph, an atomic absorption spectrophotometer a total organic carbon analyzer, a Technicon Autoanalyzer II and ' an infrared spectrophotometer. With these new instruments, the agency estimates the number of separate analyses per year will increase from 1,500 to more than 5,000. Although reliability is of primary concern in the design of the Durham plant, aesthetic considerations are also priority items. Provision has been made to utilize ozone at various locations throughout the plant to control odors. Because the plant is located in a growing residential area between the Durham Elementary School and the Tigard High School extra effort was made to make the plant compatible with its surroundinqs Trees and plantings as well as land forms are used to screen parts of the plant and to create a pleasant park-like setting for use by the general public. A free-form fountain in front, of the plant's administration building will use the treated water to demonstrate the high quality of effluent that the new facility will return to the environment. This year marks the culmination of the first phase of the master plan with the completion of the Durham Advanced Wastewater Treatment Facilities Designed by STR and constructed by Jelco, Inc., of Salt Lake City, this plant consolidates treatment in the Fanno Creek Basin in the more urbanized eastern part of the county. A second major new treatment facility, the Rock Creek Advanced Wastewater Treatment Plant, will be completed In 1977. By consolidating collection and treatment in the two most developed parts of the Tualatin Basin, the county is able to provide the advanced levels of treatment necessary to meet the stringent water quality standards set by the state, particularly during the low flow occurring through the summer months. Construction of one of the most advanced wastewater treatments in the West and a modern water quality laboratory will help provide an efficient and effective wastewater system for Washington County and .is a major part of the USA's commitment to protect public health and preserve the environment for the community. ------- PAGE NOT AVAILABLE DIGITALLY ------- Durham Advanced Wastewater Treatment Facilities Process Schematic Figure 2 ------- Washington County Citizens Committed to Clean Water by J. Allan Paterson Board of Commissioners Unified Sewerage Agency of Washington County presented September 10, 1976 at the Symposium on the Technical Response to PL 92-500 sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- WASHINGTON COUNTY CITIZENS COMMITTED TO CLEAN WATER J. Allan Paterson, Board of Commissioners, Unified Sewerage Agency of Washington County In an editorial a couple of weeks ago, the Oregon Journal was calling attention to the significance of the Durham facility completion in con- nection with what was referred to as the "war on pollution". The editorial started out by noting that an accomplishment doesn't always receive the attention that the unsolved problem did in the first place. The problems that do not exist any more do not sell many newspapers and we all under- stand that problem. It is unfortunate though that we find it so difficult to make public both the problems and the accomplishments, such as rapre- sented by the USA facility at Durham. We see here today people representing the contractors who built the plant, the engineers who designed it, USA management who will run it, the board of directors, and the advisory commission. But our basic purpose today should be to express our thanks and our pride in the citizens of Washington County for their massive commitment to the protection of our water re- sources. As elected officials and members of the professional community, we are simply the means by which the public commitment was carried forward. For a minute, let us take a look at the public determination that every citizen of Washington County should be proud of. In one stroke, the people of Washington County made a massive reorganization in pollution control which would be difficult to match anywhere. The voters consoli- dated the pollution control effort of 28 separate agencies by creating the USA and then approved a $36 million bond authorization to carry out the program. Financial commitment was the largest ever approved for any local government in the State of Oregon. When the voters launched the USA and its water pollution control program, they unleashed the largest construction project ever initiated by public or private industry at any level in Oregon. The direct and indirect economic impacts do not measure what we have all felt. Only one of the tangible results is the Durham facility, which is the subject of today's dedication. When the USA Rock Creek facility is completed next year, the two largest tertiary treatment plants in the Northwest will be serving USA's citizens. The ultimate result will be the advanced stage treatment of polluted waters at three regional sewage treatment facilities and ------- the abandonment of 22 obsolete treatment plants scattered upstream from the Durham and Rock Creek treatment facilities. Fanno Creek was famous for its reputation as an open sewer. Today, you can report that all sewage discharge into Fanno Creek has been stopped as of a couple of weeks ago. The underlying concept, which formed the basis for creation of the USA, was economic because city and county boundaries would have to be disre- garded if sewage was to be completely treated in a most efficient manner. Our USA also serves some of Portland's Multnomah County, within the Tualatin River basin, an example of a little intergovernmental cooperation. Meeting water quality requirements in the Tualatin River basin is a difficult and expensive job. Oregon DEQ has established treatment requirements in Washington County which are exceedingly critical because of the nature of the Tualatin River drainage. We could not, nor could we afford to, meet today's water quality requirements operating the way we did in the past in Washington County. The USA has spent the first six years of existence in one crash construc- tion program after another to meet the demands of sewer service by one of the fastest growing areas in Oregon. We have been building facilities like the Durham facility to complete the first phase of the construction program and to catch up work needed to meet our water quality responsi- bilities that were so neglected during the 1950's and 1960's. The com- pletion of the Durham facility really marks the change in the USA from an agency that has occupied itself with just meeting one crisis after another to one which now looks forward to leading the way in pollution control and clean water. That is our prime responsibility. It has been over six years since the Citizen's Action Committee called "Clean Water for Life" brought the message about water pollution control to the voters of Washington County. A lot of new people have moved into Washington County in that time period, and we need to keep reminding ourselves of the commitment we made and why we made it. Going back to my earlier remarks about the newspaper editorial, I hope that we can continue to keep the public aware of our accomplishments along with our trials. It is hard to sell sewer service, that is if you don't have any. I would like now to introduce a person who represents the federal level of commitment to water pollution control. The nation- wide objective which established the 1972 Water Pollution Control Act recognized the critical priority to reverse the continual degradation of our nation's water resources. Mr. Donald Dubois is the Administrator of the Environmental Protection Agency's Region X based in Seattle and is in charge of EPA programs for our area. Briefly, Mr. Dubois was for- merly Deputy Regional Administrator for Region VIII in Denver. Our guest speaker is no stranger to the Northwest, born in Spokane, Washington and a graduate of Washington State University in Pullman. Ladies and gentlemen, Donald Dubois. ------- Dedication of the Durham Facilities A Success Story by Donald Dubois Administrator, Region X Environmental Protection Agency presented September 10, 1976 at the Symposium on the Technical Response to PL 92-500 sponsored by Unified Sewerage Agency of Washington County Stevens, Thompson & Runyan, Inc. with technical and financial assistance from the Environmental Protection Agency ------- DEDICATION OF THE DURHAM FACILITIES: A SUCCESS STORY Donald Dubois, Administrator, Region X, Environmental Protection Agency At the time I started in our construction grants program in Washington, D.C., in 1957, we had a national budget of $50 million a year. Our maximum grant was 30 percent of any one project and we had a dollar limitation of $250,000 for any project, which meant we would have been able to con- tribute about one percent to the cost of a facility the size of this one at Durham. I also lived in Portland about two years in the early 1960's when water quality in the Willamette and Tualatin, like that in many of the nation's streams and lakes, certainly was not up to par. There's been a big change in that, too, both here in Oregon and nationally. So we've come a long way together, and its great that so many of you could take part during the last day and a half in this symposium, where some of the information and knowledge gained from this project can be shared. We can all learn from what has happened here, just as we can learn from what has been happening for the last several years in the environment around the United States. Our agency is undertaking a program to identify successful efforts that have taken place during these recent years so we can show what has happened to the quality of our environment, and it might interest you to know that this area is one that is often pointed to as an example of an environ- mental success story. For today, however, there are two basic points that I would like to emphasize: First of all, let's look at the elements that have made this particular area a success. Secondly, let's see where we might be going from here. This project is a demonstration of how the whole federal, state, and local governments and private citizens can work together in this country to abate water pollution and protect the environment. The Washington County experience is an example of how that complicated system is sup- posed to work. ------- The federal government, through the Congress and the Environmental Pro- tection Agency, established broad national goals, provided some of the technical input, provided some of the funding, and geneally established the basic framework for water pollution control efforts to meet these goals throughout the country. The Oregon Department of Environmental Quality recognized the need for sound water quality standards in the Willamette basin and the Tualatin, to provide for the kinds of water uses and benefits that the citizens of this area wanted. The DEQ then translated these water quality objec- tives into standards and into rather demanding effluent limitations for discharges to the waters in this area. Finally, the citizens, the local officials, and everyone involved recog- nized that the regional solution made sense in this area. The Unified Sewerage Agency, in this case, took on the very demanding job of getting itself together, of conceiving of this project, and doing the detailed planning and supervising of actual construction. I think the ultimate credit belongs to the citizens of Washington County who saw fit to create this agency and who are really footing the bill for the facilities we are dedicating. In other words, I think our system has worked, thanks to a lot of effort and a lot of cooperation at all levels of government. I would like to point out that we in the federal government have been convinced for some time of the benefits of regional izat.ion. It was proj- ects like this one in Washington County that helped to convince us, al- though I would caution that everyone should think it through and make sure that regionalization makes equally good sense in their specific case before starting from the point that we should always have regional- ization. There have been a number of things that we in the EPA have learned from this project. One is the development of a construction management system to speed up the process — this is now being applied at the Rock Creek treatment facilities. Another relates to what might be called the "red tape" problem. We in EPA bear our share of responsibility for contributing to this problem and we are trying to solve it. But it is a complicated system that we are involved in, this federal, state, and local partnership, and each of us has responsibilities to ensure that we are meeting the requirements that the public expects for prudent management of its tax monies, and for achieving our program objectives. We are mindful of the fact that we do need to keep down the paperwork to keep moving toward our goals. I understand that there has been a bit of a noise problem and that it is being addressed and hopefully solved. However, I think the bottom line is that the Durham facility is a good project and is one that all of you who had a part in should be proud of. As a matter of fact, EPA has embarked on a national program here to try to make our construction grants program work better by looking in some detail at good projects; projects that appear to have worked out well. I am going to recommend that our agency take a look in some depth at this Durham project so that what we learned here can be used throughout the Northwest and other parts of the country. ------- A LOOK AT THE FUTURE I told you I would look a bit into the future, although that's always pretty hazardous business. Most important to this project, we need to start thinking right now, as I'm sure you have, about how you're going to operate and maintain the Durham facility so that it produces the kind of economic and environmental benefits it was designed to produce. There has been some tendency in this country to think of a waste treatment facility as being finished when the plant goes into operation on the first day. We tend to forget the need for continued investment in that facility — continued management attention to its operation and to its maintenance. Concern for operation and maintenance should be a high priority for all of us to think about and we cannot just assume that it will be taken care of so we can move on to something else. In terms of the federal water pollution control program, it's a little hard to look very far in the future. We anticipate continued funding of the construction grants program at about the $5 billion national level in the fiscal year 1977 and possibly at a higher level for the next two years. In other words the Congress seems likely to provide continued federal assistance for projects like this one. By extension of the Sec- tion 208 planning grant authority, we think the Congress will provide for extending the secondary treatment deadline for municipalities. Some revision of Section 404, which deals with the permits for dredging on wetlands, looks probable. The House continues to find appeal in what is often called the Cleveland-Wright amendment, which would provide for considerable increased funding and more responsibility for state agencies to administer the construction grants program. We're in favor of that. No matter what the legislative details of the federal program are in the future, I certainly expect several things. First of all, I think we'll see continued strengthening of state and local efforts to deal with state and local problems. I think we've seen a significant evolu- tionary growth in the capability of state and local government to deal with their problems over the past several years. I also see a continuation of a trend toward a broadening view of waste treatment so that it becomes a part of an environmental management system rather than just looking at it as sewage treatment alone. This implies a more careful look at where we build our sewerage facilities and consideration of land-use impacts and the relationship between sewers and water and air quality and so on. I think we'll begin to see more careful evaluation of the real implication of waste treatment facilities, and I also expect greater focus on the earlier identification of problems and the earlier development of solutions to those problems; we should try to anticipate problems and plan for them and thereby prevent them from arising. I see also a much greater emphasis on solving the problems that have been traced to the so-called "nonpoint sources" of water pollution: silvicultural and agri- cultural runoff. The success of this particular project here in Washing- ton County demonstrates that we know how to solve the so-called "point source" problems. I'm not so sure that we're quite as smart and quite as experienced in solving the more pervasive problems of nonpoint sources. We're also going to see a continued expansion of citizen involvement and participation in the kinds of decisions that we come up with. ------- All of these elements should be addressed within the context of Section 208 activities under the water quality management planning program. Our agency is placing a very high priority on implementation of this 208 program. We're trying to ensure that 208 is not just another federal program to throw money at a problem — in the case of Oregon some $3.7 million. Rather, we are committing federal funds to enable state and local agencies to become deeply involved in identifying problems, develop- ing corrective measures, and actually implementing programs to deal with those problems. We're also pushing very hard for the 208 program participants to answer adequate participation by all interested and affected agencies, and the elected officials and citizens who make things happen, and not have these programs become another exercise to develop plans that will sit on a shelf. Our approach is to conduct 208 within the broad framework of the federal act, not to dictate the local solutions to local problems. Certain broad issues need to be examined, but we are trying very hard to avoid sitting in Seattle or in Washington saying to a Washington County official, "Here is the solution you should pick for the problem that is in your area." Rather, we want you to come up with the solution and see that it gets implemented. Many of you are already involved in the 208 program in your own communities in various ways. Those of you who are not should take a look at what's going on in your area and become involved. I am convinced that 208 programs, where properly conducted and implemented, will be the key to solving existing and future water quality problems. ------- |