3
REPORT TO
a*- BY THE COMPTROLLER GENERAL
Vv , 1/ of UNITED S TA TES
Better Data Collection And Planning
Is Needed To Justify Advanced
Waste Treatment Construction
Environmental Protection Agency
Costs for advanced waste treatment are higher
than costs for secondary treatment. The
Environmental Protection Agency is financing
some advanced waste treatment facilities
without sufficient water quality data and
planning.
In many instances, these facilities may not be
the most effective or efficient means for
achieving water quality goals. The Agency and
the States need to obtain better water quality
information and consider all water pollution
control alternatives so that treatment meth-
ods selected will improve water quality and
will result in more effective and efficient use
of Federal funds.
C ED-77- 12
DEC.21.197G
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COMPTROLLER GENERAL OF THE UNITED STATES
WASHINGTON. D.C, 20345
3-166506
To the President pf the Senate and the
Speaker of the House of Representatives
This report discusses the need for the Environmental
Protection Agency to require better water quality data col-
lection and planning to justify the construction of advanced
waste treatment facilities funded under the Federal Water
Pollution Control Act Amendments of 1972.
Because large amounts of Federal funds are needed to
construct advanced waste treatment facilities, a review was
made to determine whether such facilities are the most effec-
tive or efficient means for improvinq water cruality. We made
our review pursuant to the Budget and Accounting Act, 1921
(31 U.S.C. 53), and the Accountinq and Auditing Act of 1950
(31 U.S.C. 67) .
Vve are sending copies of this report to the Director.
Office of Management and Budget; the Chairman of the Council
on Environmental Quality; and the Administrator. Environmental
Protection Agency.
2L
Comptroller General
of the United States
US, EPA LIBRARY REGION 10 MATERIALS
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Contents
Page
DIGEST
CHAPTER
INTRODUCTION 1
Planning for water pollution abatement 2
Planning is important for controlling
costs and achieving water quality
goals 4
Scope of review 5
NEED TO IMPROVE WATER QUALITY
PLANNING AND DATA COLLECTION 6
Lack of comprehensive planning continues
to be a problem 7
Low priority placed on planning 8
Problems encountered in developing area-
wide plans 9
Delays in developing river basin plans 11
Need to improve water quality data
collection programs 13
States' water quality data collection
programs 15
Conclusion 17
Recommendations 18
CONSTRUCTION OF MUNICIPAL ADVANCED WASTE
TREATMENT FACILITIES NOT ADEQUATELY JUSTIFIED 19
Primary, secondary, and advanced waste
treatment 20
Additional information needed to justify
construction of advanced waste treat-
ment facilities 22
Water quality benefits of nutrient re-
moval facilities are unknown 27
High capital cost of advanced waste treat-
ment facilities may not be justified 29
High operation and maintenance costs
of advanced waste treatment facilities 32
Obtaining sufficient numbers of trained
operators for advanced waste treatment
facilities may be a problem 34
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Page
CHAPTER
Conclusion 35
Recommendation 35
Matter for consideration by the Congress 36
THE WILLAMETTE STUDY—AN EXAMPLE OF THE
BENEFITS OF USING GOOD DATA FOR PLANNING 37
Cleaning up the Willamette River 37
A description of the Willamette study 38
Results of the Willamette study 40
Conclusion 43
AGENCY AND STATE COMMENTS AND OUR EVALUATIONS 44
APPENDIX
I Fact sheets for the District of Columbia,
Idaho, Maryland, Oregon, Virginia, and
Washington 47
II Letter dated September 29, 1976, from the
Assistant Administrator for Planning and
Management, Environmental Protection Agency 55
III Letter dated August 26, 1976, from the Secre-
tary of Health and Mental Hygiene, State of
Maryland 58
IV Letter dated September 21, 1976, from the
Administrator Water Quality Division, State
of Oregon 60
V Letter dated August 30, 1976, from the Deputy
Executive Secretary, Virginia State Water
Control Board 63
VI Letter dated September 21, 1976, from the
Supervisor, Water Quality Management Divi-
sion, State of Washington 68
VII Principal Environmental Protection Agency
officials responsible for activities dis-
cussed in this report 70
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ABBREVIATIONS
AWT advanced waste treatment
BOD biochemical oxygen demand
CBOD carbonaceous BOD
EPA Environmental Protection Agency
GAO General Accounting Office
mgd million gallons per day
NBOD nitrogenous BOD
USGS United States Geological Survey
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Glossary
Advanced waste
treatment (AWT
Algal blooms
Processes which remove additional
pollutants from wastewater beyond
those eliminated by primary and
secondary treatment. The most common
AWT processes include (1) nitrifica-
tion (removal of nitrogenous biochemi-
cal oxygen demand (NBOD)), (2) aenitri-
fication (removal of nitrogen), and
(3} phosphorus removal.
Prolific growths of algae which can be
caused by an abundance of phosphorus
and nitrogen in water. When decaying,
algae can cause severe decreases in
the oxygen of the water; certain
species cause taste and odor problems.
The AWT processes of denitrification
and phosphorus removal are designed to
prevent algal blooms in waste-receiving
waters.
Biochemical oxygen A measure of the oxygen consumed in
demand (BOD) the biological processes that break
down organic matter in water and
wastewater. Carbonaceous BOD (CBOD)
is the readily oxidizable organic
matter which is primarily removed by
secondary treatment, and nitrogenous
BOD (an organic matter difficult to
oxidize) is removed by the AWT process
of nitrification.
Cause and effect Cause data describes how pollution is
data occurring and by whom as well as the
amount of pollution from each source.
Effect data describes to what degree
water quality would be improved after
one or more of the causes of pollution
were eliminated.
Dissolved oxygen
The oxygen dissolved in water. Dissol-
ved oxygen is necessary for the life of
fish and other aquatic organisms and
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for the prevention of offensive odors.
Dissolved oxygen is consumed by CBOD
and NBOD. Secondary treatment and the
AWT process of nitrification are de-
signed to protect dissolved oxygen in
waste-receiving waters.
Effluent The wastewater discharged by an in-
dustry or municipality.
Effluent limitations Restrictions established by a State
or EPA on quantities, rates, and
concentrations of chemical, physical,
biological, and other constituents
discharged from point sources.
A segment of a river whose water
quality criteria can be met through
secondary treatment of waste dis-
charges .
Nonpoint sources Sources of pollution that are diffi-
cult to pinpoint and measure. Common
examples include runoff from agricul-
ture and forest lands, runoff from
mining and construction, and storm
runoff from urban areas.
Effluent-limited
segment
Nutrients Elements or compounds essential as
raw materials for organism growth and
development. In this report, nutrients
usually imply nitrogen and phosphorus.
Point sources Specific sources of pollution that can
be readily identified, such as factories
and sewage treatment plants.
Treatment usually involving screening
and sedimentation for the removal of
the larger solids in wastewater. The
CBOD removal from domestic sewage by
this process is about 30 percent.
Treatment using biological processes
to accelerate the decomposition of
sewage and thereby reduce CBOD by 80
to 90 percent.
Primary waste treat-
ment
Secondary waste
treatment
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Sludge
Water quality-
criteria
The solid matter removed from waste-
water through treatment. Sludge
handling involves the processes that
remove solids and make them ready for
disposal. Disposal may involve in-
cineration, dumping in oceans, or
land application.
Specific concentrations of water pollu-
tants which, if not exceeded, are ex-
pected to allow a body of water to be
suitable for its designated use.
Water-guality-
limited segment
A segment of a river whose water
quality criteria can not be met through
secondary treatment and can only be met
through advanced treatment of waste
discharges.
Water quality-
standard
Water quali
elements:
recreation,
and wildlif
for a body
tect those
(for needed
programs),
ty standards contain four
the designated use (such as
drinking water, and fish
e propagation) to be made
of water, criteria to pro-
uses, implementation plans
water quality improvement
and an enforcement plan.
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COMPTROLLER GENERAL'S
REPORT TO THE CONGRESS
BETTER DATA COLLECTION AND
PLANNING IS NEEDED TO JUSTIFY
ADVANCED WASTE TREATMENT
CONSTRUCTION
Environmental Protection Agen
DIGEST
The 1972 amendments to the Federal Water
Pollution Control Act authorized $18 billion
for the construction of publicly owned waste
treatment facilities. As of March 31, 1976.
about §8.9 billion had been obligated for
constructing publicly owned waste treatment
facilities.
To this end, the Environmental Protection
Agency and the States have placed a high
priority on constructing such facilities and
on issuing discharge permits. In many cases,
these facilities will provide advanced waste
treatment that is expensive as compared to
facilities providing secondary treatment.
Because the 1972 amendments require munici-
palities to provide secondary treatment by
July 1, 1977, extensive planning and data
gathering was not of major importance in
deciding to build secondary treatment facil-
ities, since the minimum treatment levels
were stipulated by law.
As a result, low priority was placed on
gathering data on types, extent, and sources
of pollution and on preparing comprehensive
pollution abatement plans for river basins
and local areas. Without reliable data and
sound plans, however, the multimillion dollar
advanced waste treatment facilities being
constructed may not be the most effective
and efficient means for achieving water qual-
ity goals.
GAO recommends that the Environmental.Protection
Agency:
—Publish final regulations on data collec-
tion which indicate specifically how
States are to obtain information on ade-
quate water quality.
CED-77-12
Tear Sheet. Upon removal, the report
cover date should be noted hereon.
i
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—Reassess its existing priorities to deter-
mine whether comprehensive water quality-
planning and data collection programs
should be given additional emphasis.
—Determine whether existing resources at the
State level are adequate to implement effec-
tive comprehensive water quality planning
and data collection programs, and if not,
request additional resources from the Con-
gress .
--Before approving grants for the construc-
tion of expensive advanced waste treatment
facilities, make sure that all water pollu-
tion control alternatives have been consid-
ered and that adeauate information has been
obtained on expected water quality improve-
ments, high initial capital costs and an-
nual operation and maintenance expense,
sludge disposal problems that may result,
and the existence of trained personnel to
properly operate and maintain the facility.
If the Congress wishes to maintain closer
scrutiny over the Agency's funding of ad-
vanced treatment facilities, the Congress
may want to consider having the Administrator,
Environmental Protection Agency, report to
the Congress annually on the (1) costs and
potential water quality improvements of new
advanced treatment facilities and (2) prob-
lems and accomplishments of completed ad-
vanced treatment facilities in meeting
their water quality objectives.
NEED TO IMPROVE WATER QUALITY
PLANNING AND DATA COLLECTION
Comprehensive information on water quality
conditions and trends is essential in plan-
ning abatement actions needed to improve
water quality. The Congress recognized the
need for this when it enacted the Federal
Water Pollution Control Act Amendments of
1972. These amendments require that compre-
hensive areawide and basin plans be prepared
for determining the best course of action to
follow for improving water quality.
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Water quality data needed to support river
basin and areawide planning are generally in-
adequate, and it is unlikely that adequate
water quality data for determining the best
course of action at the least cost to solve
water pollution problems will be included
in the plans once they are completed. One
reason planning by the States is not compre-
hensive enough to identify the specific
causes of water quality problems is that the
Agency did not provide the States with de-
tailed regulations for developing data col-
lection programs which would produce the
water quality information necessary to sup-
port the olanning function. (See po. 13 to
17. )
GAO believes there will be no improvement
to the continuing problem of a lack of
comprehensive plans until adequate data on
the causes and effects of water pollution is
obtained. It is only on the basis of such
data that rational decisions can be made on
treatment and other pollution abatement
measures.
CONSTRUCTING MUNICIPAL ADVANCED
WASTE TREATMENT FACILITIES NOT
ADEQUATELY JUSTIFIED
Many expensive municipal advanced waste treat-
ment facilities are being constructed even
though they may not be the most effective or
efficient means for achieving water quality
goals.
In the States GAO visited, municipalities are
constructing or planning to construct 26 ex-
pensive advanced waste treatment facilities,
involving about $882 million in Federal funds,
to remove higher percentages of pollutants
and nutrients. However, adequate water qual-
ity information on the major causes of pollu-
tion was not available.
Without more information on the sources of
pollution and their effects on water quality,
a thorough analysis of all alternative means
of reaching water quality goals, and addi-
tional experimentation with advanced proc-
esses, the justification for several of these
Tear Sheet
iii
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advanced waste treatment facilities is Ques-
tionable. Possible alternatives to advanced
waste treatment include low flow a ugmen'c,-:) i; i vi,
control of nonpoint sources of: po 11 -,i;; i on , ^n-1
a variety of other pollution abatement actions.
Justifications for advanced waste treatment
facilities should consider the high initial
capital costs and annual operation and main-
tenance expenses of the proposed facilities
as well as the resulting sludge disposal
problems and the need for trained personnel
to operate and maintain the facilities prop-
erly. (See pp. 22 to 35.)
In the Washington, D.C., area, the Blue
Plains, Alexandria, and Arlington advanced
treatment facilities are being built at an
estimated Federal cost of $459 million.
There is considerable uncertainty as to the
expected improvements these facilities will
have on the water quality of the Potomac
River. Operation and maintenance costs for
these plants will total about $90 million a
year. (See pp. 28 to 34.)
In Maryland, advanced waste treatment facil-
ities, costing an estimated $69 million in
Federal funds, were planned for the Patuxent
River Basin. These facilities were to remove
nitrogen. GAO's review of the information
used to justify constructing these facilities
indicated that a less expensive program—such
as phosphorus removal—might also be as fea-
sible in improving water quality in the
Patuxent.
As a result of GAO's questions, Maryland re-
evaluated the need for removing nitrogen at
four facilities and decided to defer construc-
ting the nitrogen removal process, thereby sav-
ing $13.5 million in Federal funds. Maryland
officials believe that greater benefits can
be achieved by using the funds for other pur-
poses, such as upgrading primary treatment
facilities to secondary treatment. (See
pp. 23 to 25.)
An example of the benefits of using good
water quality data in planning is the U.S.
Geological Survey study of the Willamette
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River in Oregon. The U.S. Geological Survey
thorough study of the waste receiving waters
and careful analysis of alternative pollution
control measures appear to have successfully
identified more effective and efficient
methods of achieving Oregon's water quality
standards than originally planned. The
study and analysis may save several million
dollars in Federal and State construction
funding.
This case study illustrates the potential
benefits that can be obtained if additional
emphasis is placed on collecting scientifi-
cally sound water quality data and using it to
carefully analyze management alternatives for
water pollution control. In complex river
basins such studies will require considerable
time and money, but the Willamette example
shows the great potential benefits that can
result if this additional time and money is
spent. (See ch. 4 . )
In commenting on this report, the Agency
agreed with its main theme that costly treat-
ment facilities providing treatment levels
beyond the secondary level generally should
not be approved until intensive water quality
studies have been completed. The Agency
agreed also with the recommendations made.
However, both the Agency and the States
commenting on the report questioned some of
the issues raised. (See app. II through VI.)
Chapter 5 is an evaluation of agency and State
comments.
Tear Sheet
V
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CHAPTER 1
INTRODUCTION
The objective of the Federal Water Pollution Control
Act Amendments of 1972 (Public Law 92-500) (33 U.S.C. 1251 et.
seq.) is to restore and maintain the chemical, physical, and
biological integrity of the Nation's waters. To achieve
this objective, the amendments established two goals:
(1) eliminate the discharge of pollutants into navigable
waters of the United States by 1985 and (2) an interim goal
to obtain water quality sufficient for the protection and
propagation of fish, shellfish, and wildlife and for rec-
reation by July 1-, 1983.
To reach these goals, the amendments require that by
July 1, 1977, as a minimum, secondary treatment is to be
used by publicly owned waste treatment facilities and that
by July 1, 1983, publicly owned waste treatment facilities
are to use a level of treatment which the Environmental
Protection Agency (EPA) determines will achieve the goals of
the amendments. If the minimum required levels do not enable
the waters to meet water quality standards established by the
States, the States can require higher levels of treatment so
that the water quality standards can be met.
The States have the primary responsibility for abating
and eliminating water pollution. Under the amendments,
the States and interstate agencies receive grants for carry-
ing out programs for preventing, reducing, and eliminating
pollution. The Federal allotment of funds to the States
or interstate agencies is based on the extent of the pollu-
tion problems in each of the States. These funds are to
help the States and interstate agencies fund their programs
in such areas as planning, monitoring, and various other
water pollution abatement activities.
The Federal role is one of supporting research and pro-
viding technical and financial assistance to States, inter-
state agencies, and municipalities. Where States do not
accept or fulfill their responsibilities, EPA has the
authority to carry out abatement activities.
Under the 19 72 amendments, EPA's Administrator has
authority to make grants to municipalities for 75 percent
of the eligible costs to construct publicly owned waste
treatment facilities. The 1972 amendments authorized EPA
to allocate $18 billion to the States—$5 billion, $6 bil-
lion, and $7 billion for fiscal years 1973, 1974, and 1975,
respectively. The waste treatment construction grant pro-
gram has become the Nation's largest single public works
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program. As of March 31, 1976, EPA had obligated about
$8.9 billion for construction of publicly owned waste treat-
ment facilities. The remaining $9.1 billion must be obli-
gated by September 30, 1977, or be reallocated to those
States which have used their full allocation.
PLANNING FOR WATER POLLUTION ABATEMENT
Sections 208 and 303(e) of the 1972 amendments require
two major levels of water quality management planning:
(1) areawide waste treatment management plans to be devel-
oped by either local agencies in specifically designated
local areas or States in all areas not covered by a local
areawide planning agency and (2) river basinl/ water quality
management plans to be developed by the States.
Areawide (section 208) plans are to address difficult
urban-industrial and nonpoint source water quality problems.
River basin (section 303(e)) plans are to identify water
quality problems and set forth effective remedial programs
so that river basin water quality can be improved. Area-
wide and basin plans are to be used in decisionmaking and,
therefore, must have sufficient detail to facilitate the
necessary analysis for decisions.
EPA regulations require that basin planning include a
monitoring program to (1) collect the data needed to deter-
mine the relationships between water quality and individual
polluters, (2) identify nonpoint sources of pollution, and
(3) gather data necessary to set and review water quality
standards and determine total allowable maximum daily amounts
of pollution.
Whereas the river basin plan is concerned with evaluating
the extent to which each river basin is polluted, the area-
wide plan is concerned, in most cases, with only a particular
part of a river basin identified as having substantial water
quality control problems as a result of urban-industrial
concentrations. (See diagram on p. 3.) Areawide planning,
as EPA initially implemented it under section 208 of the
197 2 amendments, was performed exclusively by local agencies
in specifically designated local areas. As the result of a
June 1975 court decision, however, EPA has recently imple-
mented section 208(a)(6) of the 1972 amendments which requires
each State to act as the planning agency for all areas not
covered by a local areawide planning agency. EPA will
require such planning only where a need exists, such as
river basin planning.
i/The area drained by a river and its tributaries.
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RELATIONSHIP BETWEEN
AREAWIDE AND RIVER BASIN PLANNING
AS DISCUSSED IN THIS REPORT
1 Areawide waste treatment management plan (section 208)
River basin plan (section 303?)
A Sewage treatment plant
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As a result of the June 1975 court decision, EPA revised
its water quality planning requirements and promulgated
final regulations on November 28, 1975. In February 1976
EPA issued "Draft Guidelines for State and Areawide
Water Quality Management Program Development." The initial
basin plans developed by the States and areawide plans
developed by the local agencies will be incorporated into
the statewide water quality management plans along with
any additional State areawide planning deemed necessary.
This report refers primarily to EPA's areawide and basin
planning before the promulgation of the November 28, 1975,
planning regulations.
PLANNING IS IMPORTANT FOR CONTROLLING COSTS
AND ACHIEVING WATER QUALITY GOALS
In a February 1975 report to the Congress, States and
EPA estimated that it would cost $107 billion to control
pollution from municipal sources, excluding storm water
runoff, to meet the 1983 goal of the amendments. The
magnitude of the estimated dollars required to construct
municipal waste treatment facilities calls for cost controls
to insure that Federal funds are being effectively used.
Even small percentage reductions in the costs of waste
treatment facilities would result in important dollar
savings and would permit more effective use of Federal con-
struction grant funds.
Planning serves as the basis of control over construc-
tion of treatment facilities and other actions to abate
water pollution. Critical parts of water quality manage-
ment planning include a thorough analysis of the water,
a careful consideration of alternative ways of cleaning up
the water, and the establishment of specific timetables for
required actions. Careful planning is needed to insure
that construction grant funds are used most effectively to
improve and protect the quality of the Nation's waters.
The 1972 amendments state that treatment facility con-
struction must be in conformity with any applicable basin
plan and included in any applicable areawide plan. Develop-
ing adequate water quality management plans , especially where
advanced waste treatment is needed but also for effluent-
limited segments where only secondary treatment is needed,
requires (1) collecting water quality data to define the
causes of pollution, (2) knowing the effects on water
quality if various pollutants are eliminated, (3) identify-
ing all viable management alternatives, and (4) deciding
which alternative would be the best to use.
A 1974 evaluation of State water quality standards by
an EPA contractor stated that, without knowing the full
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extent of water quality problems and their causes, a fortune
may be spent on a cleanup program only to find that the
the water is still far below standard.
SCOPE OF REVIEW
Because of the magnitude of Federal funds being spent
for constructing waste treatment facilities, we made a
review to (1) ascertain whether the States had adequate
data to develop water quality management plans, particularly
for water-quality-limited receiving waters where advanced
wastewater treatment may be needed, and to determine alter-
native methods of pollution control, (2) find out whether
the States had completed basin and areawide plans to direct
their water quality activities, and (3) determine the effect
of present planning, or the lack thereof, on decisions to
build advanced waste treatment facilities to provide a
level of treatment higher than the minimum required by the
19 72 amendments.
We made our review at EPA headquarters, Washington, D.C.;
EPA regional offices in Seattle (region X) and Philadelphia
(region III); and State agencies administering activities
under the act in five States—Idaho, Maryland, Oregon,
Virginia, and Washington. We also obtained information on
the construction of the Blue Plains treatment plant in the
District of Columbia. During the review, we were assisted
by Dr. Donald t. Lauria, Associate Professor of Water
Resources Engineering at the University of North Carolina.
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CHAPTER 2
NEED TO IMPROVE WATER QUALITY
PLANNING AND DATA COLLECTION
Comprehensive information about water quality conditions
and trends is essential in planning abatement actions needed
to improve water quality. The Congress recognized the need
for collecting coordinated and comprehensive water quality
data and for effective water quality planning when it
enacted the Federal Water Pollution Control Act Amendments
of 1972. These amendments require that comprehensive area-
wide (section 208) and basin (section 303(e)) plans be pre-
pared for determining the best course of action to follow
for improving water quality. While such planning is impor-
tant for all waste-receiving waters, it is particularly so
for water-quality-limited segments where advanced waste-
water treatment may be needed.
However, comprehensive areawide and basin plans will
not be completed in a timely manner because the Environ-
mental Protection Agency and the States have not given the
planning process a high priority. Funding and manpower for
planning has been assigned a lower priority compared to
other pollution control activities, such as awarding waste
treatment facility construction grants and issuing industrial
and municipal discharge permits. In addition, EPA did not
promptly issue planning regulations for use by State agencies
nor did it approve most of the funding for areawide planning
agencies until June 1975, the deadline for 100 percent
funding of these agencies under the 1972 amendments.
Comprehensive planning has also been delayed because of
problems encountered by local planning agencies. Basin
plans will be delayed because of the time-consuming process
of dealing with the comments and opposing views of public
interest groups. The areawide planning process may not
be entirely successful because of the short time frame
(2 years) mandated for completing plans and the uncertainty
of continued funding of areawide planning agencies.
Further, water quality data needed to support river
basin and areawide planning is generally inadequate, and it
is unlikely that such plans when completed will be adequate
for determining the best course of action at the least cost
to solve water pollution problems. This is especially crit-
ical for constructing municipal advanced waste treatment
facilities as discussed in chapter 3.
The U.S. Geological Survey was successful in gathering
adequate water quality data on the Willamette River in
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Oregon and, as a result, was able to identify more effec-
tive and efficient methods for achieving Oregon's water
quality standards than through treatment, as originally
planned. The potential benefits which may be realized from
gathering good water quality data may result in savings of
several millions of dollars in Federal, State, and local
construction funds. This study, which is discussed in
chapter 4, is an excellent example of the work and benefits
associated with sound water quality planning.
LACK OF COMPREHENSIVE PLANNING
CONTINUES TO BE A PROBLEM
The lack of comprehensive water quality management plans
to direct waste treatment facilities' construction has been
a problem for many years. Our review of the development of
basin and areawide plans by the 5 States we visited showed
that, as of July 1, 1976, only 23 basin plans of an expected
76 had been completed and approved and that no areawide
plans had been completed. Not all the initial basin water
quality plans ana the areawide plans will be completed until
the end of 1976 and mid-1977, respectively.
Consequently, it will be some time before comprehensive
water quality plans will have an impact on waste treatment
facilities' construction. Large amounts of Federal funds,
however, have already been obligated to States for treat-
ment facilities' construction. As of March 31, 1976, a
total of about $8.9 billion had been obligated by EPA
nationwide under the 1972 act, and $927 million had been
obligated in the five states and the District of Columbia
that we visited.
As early as 1967, the Commissioner of the Federal Water
Pollution Control Administration, the predecessor to EPA,
stated that decisions to construct treatment facilities
were not based on comprehensive plans. These plans were
first required by the Federal Water Pollution Control Act of
1956, which was enacted 16 years before passage of the 1972
amendments.
In our November 3, 1969, report to the Congress entitled
"Examination Into the Effectiveness of the Construction
Grant Program For Abating, Controlling, and Preventing Water
Pollution" (B-166506), we pointed out the need for compre-
hensive water quality planning. We noted that before 1968
Federal comprehensive planning for construction grant deci-
sions was inadequate, and we recommended that systematic
planning relate the construction of waste treatment facili-
ties to improvements in water quality.
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Regulations issued in 1970 by the Federal Water Quality
Administration (successor to the Federal Water Pollution
Control Administration) emphasized the need for planning by
requiring that construction grants be approved only for
projects included in current comprehensive plans for pollu-
tion abatement. EPA and State officials said that few of
these plans were completed upon passage of the 1972 amend-
ments which required States and local agencies to prepare
basin and areawide plans for use as a basis for EPA funding
waste treatment facilities' construction.
LOW PRIORITY PLACED ON PLANNING
EPA issues annually a Water Quality Strategy Paper to
provide guidance to States and EPA regional offices on
priority program areas and resource allocations for the
coming year. The first strategy paper was issued for
fiscal year 1974. EPA's strategy papers for fiscal years
1974 and 1975 gave higher priority to awarding waste treat-
ment construction grants and issuing discharge permits.
In the five States we visited, the lower priority placed
by EPA on planning was reflected in the States' own water
pollution control planning. EPA and State officials in-
formed us that funding and manpower at the State level were
channeled into the construction grant and permit programs
during fiscal year 1975 rather than into planning. EPA and
State officials said that, during this period, several
States reassigned planners to the permit program to try to
meet the statutory deadline for issuing discharge permits.
The lower emphasis on planning is evident in that EPA
did not promptly issue basin and areawide regulations, and
approval of grant funding for areawide agencies was largely
delayed until June 1975, the deadline for 100 percent fund-
ing of these agencies under the 1972 amendments. Of the 17
areawide agencies in the States we visited, 13 received
funding in June 1975.
EPA regulations originally required that the States sub-
mit basin plans by July 1, 1975. In some instances, however,
EPA regional administrators extended this date. EPA issued
interim basin planning regulations in March 197 3. Final
EPA regulations on basin plans were published on June 3,
1974, almost 2 years after enactment of the 1972 amendments.
8
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PROBLEMS ENCOUNTERED IN DEVELOPING
AREAWIDE PLANS
The areawide plan is designed for areas with substantial
water quality control problems due to urban-industrial con-
centrations or other factors and is supposed to bring about
improved environmental quality on the Nation's waterways by
1983. The plan is to tie together the various Federal water
pollution abatement requirements, including municipal, in-
dustrial, residual waste, runoff, and groundwater pollution
abatement. Regional and local agencies are responsible for
planning and implementing these provisions. Areawide agen-
cies have 2 years from receipt of a planning grant to com-
plete their areawide plan and obtain approval from the
State and EPA.
The 197 2 amendments provide a timetable for local agen-
cies to develop areawide plans. According to this original
timetable, such areawide plans would be certified by the
Governor and submitted to EPA no later than mid-1976. EPA
did not promulgate regulations for designating areawide
agencies--which were required by the 1972 amendments to be
issued by January 16, 1973—until September 14, 1973. Also
interim regulations detailing the roles and responsibilities
of designated areawide agencies were published in May 1974
and were not finalized until November 28, 1975.
According to the 197 2 amendments, areawide grants to
designated agencies should have been awarded within 1 year
after the area and the planning agency had been designated.
In the States we visited, 9 of the 17 areawide agencies
received funding after this 1-year period.
Nationally, as of June 30, 1975, a total of 149 local
planning agencies had been designated as areawide agencies
and had been awarded grants for areawide planning. As of
July 1, 1976, there were no completed and approved areawide
plans. Although areawide planning is to bring about en-
vironmental quality improvement on the Nation's waterways
by 1983, a number of problems might preclude the areawide
planning process from achieving this goal.
A July 1975 report by an EPA contractor entitled
"National Profile of Section 208 Areawide Management Plan-
ning Agencies" made the following observations after a
review of the areawide planning process.
—The 2 years required by law to accomplish all the
analysis, planning, evaluation, and approval required
for the areawide plan is too short a time frame.
Requirements for public participation, local review,
9
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and approval are very time consuming and cut signifi-
cantly into the planning period.
—Most areawide agencies have serious doubts about their
ability to finance the planning process on their own
after the 2-year period expires. Local governments
do not consider themselves bound to pay for areawide
planning after the termination of the grant and are
not showing financial commitment to the continuing
planning process.
—It is unclear what the areawide planning management
system will look like, how it will be created, and
what powers it should exercise. The general insist-
ence on "local autonomy" by jurisdictions within the
areas will be a serious constraint on innovative re-
gional management alternatives.
--Areawide planning budgets are generally inconsistent
in format or incomplete due to a lack of staff and
expertise in price and cost analysis. Because the
makeup of the budgeted items varies among areawide
agencies, it will be very difficult to either analyze
the direction or evaluate the progress of the area-
wide planning process on a national basis.
--There is a serious need for EPA to provide more tech-
nical guidance to local areawide planning agencies.
The greatest demand was for guidance on nonpoint
source analysis, point and nonpoint sources of pollu-
tion monitoring, and urban storm water and combined
sewer analysis.
An EPA study team report dated February 19, 1976, con-
cerning EPA management of the areawide planning program
stated that agency policy and guidance for the program has
been inadequate, EPA's administration of the program has
been weak, and most currently funded planning agencies will
be unable to complete all the complex tasks within the time
frame mandated by the 1972 amendments. To improve the
management of the program, the report suggested that EPA:
—Provide more adequate and timely guidance to areawide
planning agencies on such matters as (1) defining
more explicitly State responsibilities in the program
and (2) clarifying and defining the relationship be-
tween areawide planning and other EPA pollution con-
trol programs.
--Improve the formal planning and reporting system to
permit continuous monitoring of program performance.
10
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--Give greater attention to the review and analysis of
subcontracts entered into by areawide agencies.
An EPA Planning Division official acknowledged that
there are problems associated with areawide planning. To
help rectify the problems set forth in the "National Profile
of Section 2 08 Areawide Management Planning Agencies" and
the EPA study team's report, EPA issued a "Strategy for the
Water Quality Management Process" in January 1976.
The strategy instructs areawide planning agencies to
rank the planning issues that they must address and con-
sider first the most important issues so that they will have
something worthwhile to show for their efforts after 2 years.
The strategy also instructs the areawide planning agencies
to direct their efforts towards solving pollution problems
not being addressed by other ongoing planning. The purpose
of this is to avoid duplicating effort. In addition, EPA,
in conjunction with the States, has developed a program to
monitor and evaluate the progress of areawide planning to
insure that the areawide planning agencies are provided with
the assistance they need and that they will achieve program
goals.
DELAYS IN DEVELOPING RIVER BASIN PLANS
The river basin plan is designed to coordinate and
direct water quality management for a river basin by:
--Identifying problems: determining existing water
quality, applicable water quality standards, and
point and nonpoint sources of pollution.
--Determining priorities: assessing water quality and
abatement needs to establish priorities for awarding
construction grants, processing permits, and taking
other needed steps to achieve water quality goals.
—Scheduling actions: setting forth compliance schedules
or target abatement dates and indicating necessary
State and local activities.
—Coordinating planning: identifying needs and priori-
ties for treatment facility plans and areawide plans
within the basin.
Although EPA has made studies to evaluate the areawide
planning process, it has not made studies of basin planning.
During our review, however, we did note instances where
some States were hindered by several factors during the
basin plans' development. Idaho, for instance, had expected
11
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to submit its six basin plans to EPA by December 1975.
State officials informed us that their basin planning was
delayed significantly because of active opposition by
agricultural interest groups to an initial draft of a
basin plan which was the subject of a public meeting held
in November 1973. An EPA official stated that initial
opposition from these interest groups centered on a poten-
tial threat to water-drawing rights. Later, opposition
to the plan's proposed requirements for changes in agricul-
tural practices became the primary problem delaying the
basin plans' development in Idaho. The EPA officials
stated that the planning process will take more time to
insure that agricultural problems like these have been
fully considered.
To speed up completion of the basin plans, all six
plans were consolidated into one plan. On July 23, 1976,
EPA approved the consolidated plan.
Although Oregon1s basin plans have been drafted since
mid-1974, only one draft plan has been submitted to EPA for
its approval. An EPA official said that a major reason
that completion of the basin plans had been delayed was
because the draft basin plans had yet to be reconciled with
land use plans.
As of May 1975, Maryland had the only basin plan com-
pleted and approved in the five States we visited. Mary-
land's remaining 17 basin plans are scheduled to be sub-
mitted by October 1976 for EPA's approval. Maryland
officials stated that--by July 1975--public advisory
groups had become active in the development of all 18 river
basin planning areas. The State officials informed us that
one factor delaying the completion of the plans was the
additional time required by the public advisory groups to
review and comment on the plans submitted to them by the
State.
We also looked at whether States were calculating total
maximum daily loads and waste load allocations for river
segments. EPA regulations require that basin plans include,
for water-quality-limited segments, a determination of the
maximum daily discharge limit for each specific pollutant.
This is to be done by first calculating from mathematical
models the total maximum allowable daily waste loads which
can be safely discharged to river segments without violating
water quality standards and then allocating these allowable
loads among polluters discharging into receiving waters.
In the States we visited, it was noted that few of the
initial basin plans were to contain total allowable maximum
12
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daily loads or waste load allocations. Waste load alloca-
tions in the river basin plans are either incomplete or
inadequate because they are based on insufficient data. In
Maryland, for example, 24 of the State's 206 river segments
are considered high-priority, water—quality-limited seg-
ments for which waste load allocations are required. A
Maryland official said that, as of May 21, 1975, the State
had waste load allocations for only 8 of the 24 river seg-
# The State official said that sufficient data was
not available to make the waste load allocations for the
remaining 16 segments.
In Washington about 60 percent of the stream segments
^j-0 classified as water quality limited. A State official
Informed us, however, that none of the initial basin plans
will include total allowable maximum daily loads or any
waste load allocations since the parameter in question is
generally bacteria or the waste is from a nonpoint source.
More research is needed before maximum daily loads and
waste load allocations can be determined on these types of
wastes.
In three of the five States visited, 69 percent of the
stream segments were classified as not capable of meeting
water quality standards primarily because of nonpoint
sources of water pollution. State and EPA officials
affirmed the lack of available data on nonpoint source
discharges and possible pollution control alternatives.
It will probably be a number of years before the basin
and. areawide planning process will have an impact on deter-
mining the best approach to solving water quality problems.
The usefulness of the plans will depend primarily on the
planning agencies' ability to obtain meaningful data on all
the factors affecting water pollution control problems.
NEED TO IMPROVE WATER QUALITY DATA
COLLECTION PROGRAMS
The data collection programs of the five States we
visited were generally inadequate for identifying specific
causes of water quality problems. Although the 1972 amend-
ments became effective in October 1972, EPA still has not
issued final regulations detailing specific information on
how or when to collect water quality data. Further, EPA
and the States have placed a low priority on data collection.
Without such information, it is unlikely that the area-
wide and basin plans will be adequate for determining the
best course of action to take for constructing advanced
waste treatment facilities.
13
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Unless EPA increases emphasis on collecting needed water
quality data in its national strategy paper, strengthens its
data collection regulations, and improves its review of
State data collection programs to insure that reliable data
is obtained, areawide and river basin plans the States
submit will continue to lack adequate data necessary to
solve water pollution problems.
In commenting on the impact of the Federal water pollu-
tion control effort, the National Commission on Water
Quality—in its March 18, 1976, report—stated that:
"We also find that there is still a major lack of
adequate information. We simply do not know enough.
There are not sufficient data to tell us exactly how
bad the water was, or how much better it is getting.
The measuring and analytical techniques and predic-
tive methodologies are not good enough in many in-
stances to tell us the scope and value of incremental
water quality improvements. If billions of dollars
are to be invested wisely, we must have more and
better data collected over an adequate term of years."
EPA's Water Quality Strategy Paper for fiscal years 1974
and 1975 emphasized issuing discharge permits and awarding
waste treatment construction grants because EPA believed this
would result in the most immediate improvements in water
quality. EPA's fiscal year 1976 national strategy paper
still gives highest priority to issuing construction grants
but shifts the emphasis from permit issuing to permit enforc-
ing. State officials told us that insufficient State
resources—both manpower and funding — have been allocated
to data collection and analysis because both the 1972 amend-
ments and EPA guidance heavily emphasized controlling point
sources of pollution by issuing permits and awarding con-
struction grants.
State officials informed us that the lack of detailed
monitoring regulations from EPA has also contributed to the
States' inability to develop adequate data collection and
analysis programs. The 1972 amendments require that—to
be eligible for a pollution control program grant—the
States must have a water quality monitoring program. In
June 1973 EPA issued interim monitoring regulations to
implement this requirement, but the regulations were very
general and did not contain specific information on how or
when to collect water quality data.
In August 1974, about 2 years after the 1972 amendments
were passed, EPA issued proposed regulations to clarify data
collection required by States. According to EPA officials,
14
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the proposed regulations were based on a model data collec-
tion program. An EPA official said that State officials
complained that they could not comply with the program in
the proposed regulations because they lacked funding and
qualified manpower. The EPA official stated that, as a
result of the State comments, the regulations were going
to be revised to a "bare bones program" so that State pro-
grams would be in compliance.
On April 27, 1976, EPA issued general regulations on the
components of State water quality monitoring programs.
Rather than publishing the technical details of monitoring
programs as regulations, the EPA Administrator stated that
EPA will issue guidance documents in the future which will
detail recommended monitoring practices.
We believe that, without specific regulations on the
need for adequate data collection programs, States will
continue their current efforts with little emphasis on the
use of intensive surveys to obtain necessary water quality
data. An EPA region X official stated that without more
detailed data collection regulations, EPA lacked the clout
needed to force improvements in State data collection and
analysis programs.
STATES' WATER QUALITY DATA
COLLECTION PROGRAMS
The States we visited were mainly oriented to fixed-
station network monitoring. This monitoring is a base-
line for determining existing water quality conditions and
in particular for identifying the existence of water quality
problems. It is not particularly concerned, however, with
determining the specific causes of water quality problems,
and it is the identification of such causes that is the
starting point for developing comprehensive water quality
plans with viable solutions.
Once a potential water quality problem is identified, an
intensive surveying program 2/ is needed to quantify the
— Fixed-station network monitoring is the repeated sampling
and measurement of water quality conditions at fixed
points.
2/
An intensive survey concentrates on collecting the data
needed to understand the cause and effect relationship
between sources of pollution and instream water quality.
Information on pollution sources, streamflow, and instream
water quality should be obtained at the same time.
15
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problem, identify the causes, examine the alternatives, and
decide on a course of action for achieving water quality
standards. Data from a fixed-station network is normally
inadequate for serving these functions, in part because it
does not enable development of the relationship between
water quality and pollutional loads. Intensive surveys
produce data suitable for determining the amount of pollu-
tants to be removed and other actions needed to achieve
water quality standards.
The five States we visited had performed intensive sur-
veys on only a few river segments. Washington had not made
intensive surveys even though 96--or about 60 percent—of
the river segments were classified as water quality limited.
State officials told us that, because the 1972 amendments
placed a heavy workload on the States, they needed additional
time to reorganize their traditional monitoring to provide
the information required.
Oregon made few intensive surveys. Although all river
segments in the State were classified as water quality
limited, intensive surveys, according to an Oregon State
official, were not generally made because of inadequate re-
sources to collect all the data required by EPA.
In Idaho 16--or about 17 percent—of the water-quality-
limited segments were intensively surveyed, some of which
were done in cooperation with Federal agencies. State
officials recognized that an improved State monitoring
program was needed, but they were reluctant to make major
changes until EPA published more detailed monitoring regu-
lations .
EPA region X officials are developing a data collection
program for use in their region which emphasizes the cause
and effect relationship between sources of pollution and
instream water quality. The central theme of this program
is on defining cause and effect relationships as a basis
for problem solving. Data obtained from limited fixed-
station monitoring at key locations identifies problems.
Intensive surveys are then made only where major water
quality problems are noted.
In Maryland 9—or about 4 percent—of the 206 segments
were intensively surveyed. These intensive surveys were
made to help predict the effect water pollution control
actions would have on water quality. Intensive surveys and
modeling were underway for 35 more segments. As of May
1975, Maryland was still in the process of determining how
many of its 206 river segments should be classified as
water quality limited.
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Virginia officials informed us that stream surveys were
initiated in 20 of 75 water-quality-limited segments; how-
ever, not all of the 20 surveys were intensive. Some of the
surveys were not sufficiently intensive to obtain necessary
water quality data on the causes and effects of pollutants.
State officials indicated that the data collection program
was not adequately funded or staffed to obtain the needed
data on all pollution sources.
CONCLUSION
Comprehensive planning is a key element in State water
pollution control programs and should have a major impact
on decisions to build expensive advanced waste treatment
facilities. In the States we visited, the initial basin
and areawide plans will be delayed primarily because EPA
and the States have not given planning a high priority.
As a result, these plans will not have a major impact on
current decisions to construct advanced waste treatment
facilities. Meanwhile, millions of dollars in Federal funds
are being spent in these States to build such facilities.
It appears that because of limited funding and manpower
at the State level as well as the lack of detailed data col-
lection regulations, the initial basin plans, when completed,
generally will be based on inadequate data, will not in-
clude a determination of allowable maximum daily loads, and
will contain little consideration of nonpoint sources of
pollution. Without such information, it is questionable as
to how effective the plans will be towards improving water
quality where advanced waste treatment facilities are to be
constructed.
Water quality information States use for planning pur-
poses generally is based on fixed-station network monitoring
and is not comprehensive enough to identify the specific
causes of water quality problems although such information
is critical in developing adequate plans. Accordingly, we
believe that there will be no improvement to the continuing
problem of a lack of comprehensive plans until adequate data
on the causes and effects of water pollution is obtained.
Although areawide (section 208) and river basin (section
303(e)) planning and data collection are not especially criti-
cal in cases where secondary treatment plants are required
on effluent-limited segments, such planning becomes ex-
tremely important to reasonably predict cause and effect
relationships for improving water quality where advanced
waste treatment facility contruction is being considered.
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The National Commission on Water Quality in its March 18,
197 6, report recommended to the Congress that an ongoing
national assessment of the quality of the Nation's waters be
undertaken to determine progress toward water guality goals
and objectives and that the progress be periodically re-
ported to the Congress. The Commission also said that there
must be renewed commitment to a data collection and analysis
program encompassing an adequate range of parameters, a
network of collection points providing satisfactory national
geographic coverage, and a timespan during which changes in
water quality and biological response are likely to be
reflected.
We concur in the Commission's concern over the need for
better water quality data collection.
RECOMMENDATIONS
We recommend that the Administrator, EPA:
—Publish final data collection regulations which will
specifically state how the States are to obtain ade-
quate water quality information through the use of
intensive surveys and require that such surveys be
made in those instances when the expenditure of large
amounts of funds are contemplated.
—Reassess existing priorities within EPA to determine
whether comprehensive water quality planning and data
collection programs should be given additional empha-
sis .
—Determine whether existing resources at the State
level are adequate to implement effective comprehen-
sive water quality planning and data collection pro-
grams. If existing resources are inadequate, addi-
tional resources should be requested from the Congress.
18
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CHAPTER 3
CONSTRUCTION OF MUNICIPAL ADVANCED
WASTE TREATMENT FACILITIES NOT ADEQUATELY JUSTIFIED
Many expensive municipal advanced waste treatment
facilities are being constructed even though they may not be
the most effective or efficient means for achieving water
quality goals. In the States we visited, municipalities are
constructing or planning to construct 26 expensive advanced
waste treatment facilities, involving about $882 million in
Federal funds, to remove higher percentages of pollutants
and nutrients. However, adequate information for planning
these facilities was not available. Without such informa-
tion, decisions to build advanced waste treatment facilities
were being made without carefully considering whether other
less costly methods were available to control water pollu-
tion. Possible alternatives to advanced waste treatment
facilities include low-flow augmentation, instream aeration,
control of nonpoint sources of pollution, and a variety of
other pollution abatement actions.
The most common advanced waste treatment processes being
planned or constructed in the States we visited included
nitrogen and phosphorus removal. By removing these nutrients,
the States hope to control the algal growth thereby improving
water quality. Exact scientific knowledge is usually lacking,
however, on the amount of each nutrient to be removed and
the effect of such removal on the growth of algae in waste-
receiving waters.
With few exceptions, constructing advanced waste
treatment facilities is extremely expensive. The capital
cost of waste treatment facilities increases dramatically
with levels of treatment beyond secondary. in 1972 data
from EPA indicated that it would cost at least five times
as much to remove the last 15 percent of the pollutants
as to remove the first 85 percent.
Not only are initial capital costs of advanced treatment
facilities enormous, but also annual operation and mainte-
nance costs are high. For example, after expanding the
capacity of the Blue Plains plant that serves most of the
Washington D.C., area by 29 percent and adding advanced waste
treatment, the annual operating costs are expected to rise
from $13 million to $76 million—a sixfold increase—due
primarily to the addition of advanced waste treatment.
Other problems associated with advanced waste treatment
include the disposal of large amounts of sludge which result
19
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from higher degrees of treatment and development of a
sufficient number of adequately trained personnel to properly
operate and maintain such facilities.
As a result of questions raised during our review,
Maryland reevaluated the need for removing nitrogen at four
advanced waste treatment facilities it is planning to
construct. State officials decided to defer construction
of the nitrogen removal processes, thereby saving $13.5
million in Federal construction grant funds, because they
felt greater benefits could be obtained by using the funds
for other purposes, such as upgrading primary treatment
facilities to secondary treatment. In addition, the State
is continuing to review the adequacy of the justifications
for nutrient (phosphorus and/or nitrogen) removal planned
for 17 or 18 other proposed advanced waste treatment facili-
ties.
PRIMARY, SECONDARY, AND
ADVANCED WASTE TREATMENT
Conventional waste treatment generally includes two
processes—primary and secondary treatment. In primary
treatment, essentially all settleable solids are removed by
plain sedimentation. In secondary treatment, biological
processes are used to accelerate the decomposition of sewage
and thereby reduce the oxygen demand of the waste. Secondary
treatment, in coordination with primary treatment, increases
biochemical oxygen demand (BOD) removal from 30 to about 80
or 90 percent.
Advanced waste treatment involves processes which are
for removals beyond secondary treatment. Nitrification
satisfies the oxygen demand of nitrogenous compounds and
thereby reduces the BOD of wastes. Like secondary treatment,
it is designed to protect the oxygen resources of waste-
receiving waters. Denitrification and phosphorus removal
are processes for eliminating nutrients to prevent the
production of algal blooms in receiving waters. Denitrifica-
tion is a biological process with high costs and operating
expenses and careful operation by well-trained personnel is
required. Phosphorus removal has a lower capital cost but
has higher operating costs. This process can be easily
started and stopped but results, however, in large quantities
of sludge. Other advanced waste treatment processes are
intended to remove minute concentrations of pollutants to
obtain effluents of extremely high quality.
A diagram of a primary, secondary, and advanced waste
treatment process is shown on page 21.
20
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DIAGRAM OF A SEWAGE TREATMENT PLANT INCLUDING
ADVANCED WASTE TREATMENT
K>
PHOSPHORUS
REMOVAL
DENITRIFI CATION
SEDIMENTATION SUPPORT
GRAVEL
MULTIMEDIA
FILTRATION
ACTIVATED CARBON
ADSORPTION
CHLORINATION
DISCHARGE
TO STREAM
WASTE TREATMENT
SEWER
GRIT REMOVAL
PRIMARY
AERATION
SECONDARY
NITROGEN AND
BIOLOGICAL CARBON DIOXIDE
NITRIFICATION V RELEASE
SECONDARY NITRIFICATION
SEDIMENTATION SEDIMENTATION BIOLOGICAL
DENITRIFICATION
ADVANCED
-------
ADDITIONAL rirPRMATION NEEDED
TO JUSTIFY" CONSTRUCTION OF
ADVANCED WASTE TREATMENT FACILITIES
The States included in our review are requiring the
construction of expensive advanced waste treatment facilities
on the basis of special studies. Many of the studies, how-
ever, were not based on adequate water quality information
on the major causes of pollution. Without such information,
decisions to build advanced waste treatment facilities were
being made without adequately considering whether other less
costly methods were available to control water pollution.
Dr. Clarence Velz, a national authority on pollution
control, emphasized the need for considering alternatives
in the following manner:
"In considering strategies it is recognized that
wastewater treatment of point sources has always been,
and will continue to be, a major line of defense. But
the question is, what degree of treatment of point
sources is required and what proportion of limited
public funds should be devoted to treatment and what
proportion to other lines of defense and offense?
There can be no arbitrary answer to this, and only by
a scientific evaluation of effectiveness of alternatives
applicable to each specific river basin can rational
decisions be made."l/
There are several alternatives for improving water
quality. The most conventional is treating wastewaters
from industries and municipalities. Industries can also
change their production practices for more efficient use of
water so that less treatment of wastewater is needed, wastes
can be evaporated or burned, cities can zone areas of planned
growth to minimize pollution, agricultural and lumber
practices can be improved to reduce erosion and fertilizer
runoff, and better environmental controls can be implemented
to reduce problems resulting from urban storm water runoff.
In some cases instream aeration can be practiced by
placing a barrier across a stream much like a low dam.
Water in the stream is aerated as it flows over the barrier,
l/j?rom a paper entitled "Public Law 92-500 or Oregon's
Rational Approach: The Willamette River Study," prepared
for presentation at the June 30-July 2, 1975, meeting of
the American Water Resources Association.
22
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raising its dissolved oxygen level. Mechanical aerators
can be placed in lakes to agitate the water or even pump air
into the water to raise the lake's dissolved oxygen level and
slow eutrophication.^/
In many situations, water can also be stored in
reservoirs for release during periods of low streamflow to
greatly dilute pollutants. If the water saved during rainy
months is released during the low streamflow times of the
summer, the Quality of the water can be improved because the
natural cleansing capability of the water is increased. In
some river basins, low streamflows during the summer are
only a fraction of the high streamflows in the spring. The
use of water storage must depend on the condition in each
river basin, however, because the storage of water in a
reservoir may decrease water quality by entrapment of
nutrients, causing nuisance aigal growth.
The following examples noted during our review
demonstrate the need for the States to consider alternatives
to advanced waste treatment facilities for solving their
water quality problems.
Patuxent River Basin
Four advanced waste treatment plants, costing an
estimated $69 million in Federal funds, were planned for
the Patuxent River Basin in Maryland. The Patuxent River
is the largest intrastate river in Maryland. From its
headwaters, the Patuxent River flows through the State for
110 miles to the Chesapeake Bay. To control excessive
algal growth in the Patuxent River Basin, the State planned
to construct advanced waste treatment facilities at Parkway,
Western Branch, Central Patuxent, and Savage to reduce the
level of nitrogen in the river. The decision to use a
nitrogen reduction program to control algal growth was based
on a State analysis of data collected in 1970.
Our review of the 197 0 data indicated that a less
expensive program—such as phosphorus removal—might also
be as feasible in reducing the algal growth in the Patuxent.
The cost of the equipment needed to remove phosphorus would
be considerably cheaper than that needed to remove nitrogen.
i/Eutrophication is the normally slow aging process during
which a lake becomes so rich in nutrients, especially
nitrogen and phosphorus, that algae and other microscopic
plant life become superabundant thereby "choking" the lake
and causing it to eventually dry up.
23
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Our consultant also reviewed our analysis of the data
Maryland used to justify the nitrogen reduction program and
agreed that a phosphorus removal program would probably
limit the growth of algae in the Patuxent. He concluded
also that the algae problem in the Patuxent River Basin was
more complex than shown by the State's information since
there does not seem to be any clear evidence that either
phosphorus or nitrogen is the cause of algal growth. Our
consultant stated that the decision on which nutrient to
remove must be evaluated in terms of anticipated costs and
benefits. He stated that a phosphorus reduction program
could be more readily justified since it is a chemical-
physical process that is flexible and can be turned on and
off as needed, while the nitrogen reduction program planned
for the Patuxent River Basin is a biological process that
is not so easily controlled.
Because of the complexity of the algae problem in the
Patuxent River Basin, our consultant recommended that, before
spending the funds required to build the expensive nitrogen
reduction plants, the State should research the extent of
the algae problem and alternative solutions to it. In this
regard, he recommended that, before deciding on a particular
type of treatment, the State should:
--Identify the relationship of the location and
magnitude of peak algal growth to streamflow to
determine the frequency with which excessive algal
growths occur.
--Determine those streamflows which produce the critical
nutrient concentration that is necessary to promote
noticeable algal growth. This should be done for both
existing and assumed future users of the waste treat-
ment system. Such analysis will hopefully indicate
whether nutrient removal is needed for all or only
part of the year. If the analysis shows that
nutrient removal is needed part of the time, then a
flexible process should be the preferred treatment.
Our observations on the lack of justification for the
construction of nitrogen removal facilities at the treatment
plants proposed for the Patuxent River were discussed with
Maryland officials during our review. On the basis of our
observations, Maryland reevaluated the need for a nitrogen
removal program and decided to defer construction of the
facilities but design them so that nutrient removal facili-
ties can be added in the future. The nitrogen removal
program has been deferred because Maryland officials now
believe that greater benefits can be achieved by using the
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funds for other purposes, such as upgrading primary treatment
facilities to secondary treatment.
At the time of our review, Maryland officials had not
developed the total cost savings resulting from deferring
nitrogen removal at the four facilities on the Patuxent
River. Later, cost figures were developed for the Savage
facility that indicate that capital cost savings of $3.6
million would be realized and that total savings over the
useful life of the facility would be $16.3 million, including
operation and maintenance, interest, and amortization. We
estimate that, by using the cost figures developed for the
Savage facility and applying them to the other three facili-
ties, Maryland's decision to defer nitrogen removal at all
four facilities on the Patuxent River would save $13.5
million in Federal funds and $2.2 million in State funds.
In addition, the State is continuing to review the
adequacy of the justifications for nutrient (phosphorus and/
or nitrogen) removal at the other 17 or 18 proposed advanced
waste treatment facilities.
Tualatin River Basin
An advanced waste treatment facility, providing
phosphorus removal and high levels of filtration, is being
built in the Tualatin River Basin in Oregon at a total
Federal cost of about $19 million. The study justifying
this facility's construction stated that water quality
standards in this basin could not be attained without
river flow augmentation and control of runoff from
agricultural lands.
Although Oregon is requiring advanced treatment for all
point sources in the Tualatin River Basin, it appears that
this action alone will be insufficient because the river's
flow and runoff from agricultural lands will not be
controlled. In addition, the State has not determined the
most effective or efficient actions needed in the river
basin to achieve water quality standards.
One consideration in determining which water pollution
control alternative to implement is whether the alternative
is eligible for Federal funding. For instance, although
EPA provides funds for construction of waste treatment
facilities, an Oregon Department of Environmental Quality
official stated that no EPA funds are available for
construction of reservoirs for low-flow augmentation.
25
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Concerning river flow augmentation we noted that, in a
1975 paper prepared for the American Water Resources Associa-
tion, Dr. Clarence Velz reported:
"To allow flood waters to escape to the sea and expose
men to the risks of severe droughts with dependence upon
the least flow is certainly not intelligent nor wise
conservation. Many of our water shortages and quality
problems are not for lack of water, but stem from our
failure to * * * make fuller use of the total annual
flow available."
*****
"Surely it becomes questionable to increase expendi-
tures three-to five-fold on elaborate treatment works
and do nothing to control the ravages of drought steam-
flow. If the current 'treatment only' philosophy
continues, there is grave danger of spending billions
of dollars on what may prove to be regarded as elaborate
expensive 'monuments' along the banks of shrunken
rivers, rivers which remain inadequate in both quantity
and quality for man's needs."
Roanoke River Basin
The Roanoke water pollution control plant is located
on the Roanoke River near its confluence with Tinker Creek
in Roanoke, Virginia. An estimated $24 million in Federal
funds was needed to expand and upgrade the present secondary
facility to an advanced waste treatment facility which will
remove phosphorus. Construction of the facility was begun
in fiscal year 197 2 and scheduled for completion in fiscal
year 1976. As of July 1976, it was 99 percent complete.
This advanced treatment facility was justified on the
basis of a 1970 study which showed that Roanoke River
drainage into a lake had a high level of nutrients because
of waste loadings in the Roanoke urban area. The study
recommended reducing nutrient input to the lowest possible
level to limit the growth of nuisance algal blooms in the
lake. However, no specific consideration was given to
alternative methods of reducing nutrients, and the degree
of reduction that should be required for each point and
nonpoint source was not specified.
Although advanced waste treatment is being required for
the Roanoke facility, a State official thought that the facil-
ity would only slow further degredation of the lake rather than
improve water quality to any great extent. We believe that
before decisions are made to build advanced treatment
26
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facilities, extensive information should be obtained on non-
point sources of nutrients to determine whether treatment
will effect the desired improvement. In addition, alterna-
tive abatement measures need to be investigated to determine
the most efficient plan for achieving improved levels of
water quality.
Designing facilities for future addition of
advanced waste treatment processes
While advanced waste treatment facilities are being
planned for the Patuxent, Tualatin, and Roanoke River Basins
without adequately considering all major factors affecting
water quality, Idaho is not going to construct advanced
treatment facilities in the Snake River Basin to remove
nutrients until it obtains adequate information that clearly
justifies constructing such facilities. Without information
on the major factors affecting water quality, Idaho is
taking a careful approach to constructing expensive treatment
facilities.
Idaho is having serious algae problems in reservoirs
on the Snake River downstream from Twin Falls. The State is
requiring that a new secondary treatment facility at Twin
Falls be designed so that phosphorus removal equipment can
be added in the future. The additional cost of modifications
to provide for the future addition of phosphorus removal
equipment is estimated at $2,000, considerably less than
1 percent of the total Federal cost of about $5 million to
construct the secondary treatment facility. The Idaho State
Grants Coordinator stated that it would be foolish to require
advanced waste treatment now because the water quality could
not be improved unless the nonpoint source pollution problems
are also corrected.
WATER QUALITY BENEFITS OF NUTRIENT
REMOVAL FACILITIES ARE UNKNOWN
The principal advanced waste treatment process being
planned or constructed in the States we visited was
nutrient—nitrogen and phosphorus—removal. By removing
these nutrients, the States hope to control the growth of
algae thereby improving existing water quality. Exact
scientific knowledge is lacking, however, as to the extent
algae can be prevented from growing when varying combina-
tions of the nutrients are removed. In addition, it is
difficult to predict the effects that light, suspended solids,
temperature, and other factors might have on preventing and
controlling algal growth. While scientists know that
phosphorus, nitrogen, light, temperature, and suspended
27
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solids affect the growth of algae to some degree, they cannot
determine with certainty what the effect will be on
preventing or reducing algae if one or more of these elements
is increased or decreased.
Washington, for example, has approved the construction
of an advanced waste treatment facility for phosphorus
removal to control an algae problem in the Spokane River.
The estimated Federal cost of the facility is about $34
million. Although an EPA study indicated that the river
quality may be improved if phosphorus is removed from the
facility's effluent, various scientists believe the current
state of knowledge of algal growth is such that it is
impossible to relate the frequency or severity of algal
blooms to specific phosphorus levels in the water.
The EPA region X Chief of the Water Surveillance and
Investigation Branch stated that, although EPA lab studies
indicated that phosphorus removal would control algal growth
in the Spokane River, this concept has never been success-
fully demonstrated. In addition, no experiments have
proved that phosphorus removal will control algal growth
in a complex river system.
There is also considerable uncertainty as to the effect
nutrient removal will have on preventing algal blooms on
the Potomac River in Washington, D.C. Three advanced
waste treatment facilities, the Blue Plains plant
in Washington, D.C., and the Alexandria and Arlington
facilities in Virginia, are planned to provide for nutrient
removal on the Potomac River, because the 1969 Potomac
Metropolitan Area Enforcement Conference recommended that
high levels of phosphorus and nitrogen be removed from
the effluent of Washington, D.C., metropolitan area
municipal sewage treatment facilities.
A 1969 Federal Water Pollution Control Administration
report and various studies since that time have predicted
that removal of as much BOD and oxygen-demanding nitrogen
as possible will be necessary to achieve the dissolved
oxygen standard in the Potomac River Estuary.
Although the costs of constructing these facilities are
substantial, we found no evidence to demonstrate what the
effect on algae would be if varying amounts of phosphorus
and nitrogen were either increased or decreased at these
facilities. Much of the information justifying the removal
of nutrients at these facilities indicated uncertainty as
to whether or not algae could be controlled. In addition,
a January 1975 report prepared by the Interstate Commission
on the Potomac River Basin and entitled "Non-Point Pollution
28
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in the Potomac River Basin" pointed out that the concentra-
tion of nutrients coming downstream in the Potomac River is
by itself, great enough to support nuisance levels of algae.
Therefore, even if the three facilities removed all nitrogen
and phosphorus from their effluent, remaining nutrients could
still support nuisance levels of algae.
Because of rising costs and national shortages of
energy and other resources, EPA reassessed the water quality
management programs in the Washington, D.C., area in 1974.
On the basis of this reassessment, EPA decided to defer the
removal of nitrogen at the Blue Plains treatment plant
for 2 years until the extent of water quality improvement
from phosphorus removal can be determined. In explaining
the justification for deferring nitrogen removal, EPA
indicated the imprecise nature of benefits that are being
anticipated from either phosphorus or nitrogen removal:
"* * *although scientific understanding of algae
blooms has greatly improved, the precise benefits to be
attained by nitrogen removal remain unclear. Algae
nuisances will be reduced somewhat by phosphorus removal,
without dentrification—possibly to an acceptable
level."
Our consultant stated that the benefits to be derived
from constructing advanced waste treatment facilities
cannot be accurately estimated until more scientific
knowledge has been developed about how this construction
will improve water quality. Concerning the building of
advanced treatment facilities in the absence of information
on expected outcomes, he stated that he
"* * *would generally be inclined in the absence of
knowledge to proceed slowly and cautiously, taking a
wait-and-see attitude. Set standards which will not
incur costs to society of tens or hundreds of millions
of dollars. Set them with advice to the polluter that
they may need to be tightened;* * *"
HIGH CAPITAL COST OF ADVANCED
WASTE TREATMENT FACILITIES MAY
NOT BE JUSTIFIED
With the exception of small, uncomplicated sewage
treatment facilities, advanced treatment processes are
generally expensive. The cost to remove additional oxygen-
consuming materials increases dramatically after the secondary
treatment level which removes 80 to 90 percent of the
pollutants.
29
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As a result, the incremental water quality improvements due
to advanced waste treatment are likely to be modest when
compared to the increased costs.
The following chart shows that--with present technology--
it would cost at least five times as much to remove the last
15 percent of the pollutants in wastewater as to remove the
first 85 percent.
INDEX OF CONTROL COSTS (in $) PERCENT REDUCTION
As indicated by the chart, decisions on the level of
water quality desired have an enormous impact on the total
cost of waste treatment facilities and thus on the demand for
Federal funds. For example, the Blue Plains, Alexandria,
and Arlington advanced waste treatment facilities planned
and under construction for the Metropolitan Washington, D.C.,
area exemplify the high costs of advanced treatment. All
three are located on the Potomac River and are presently
secondary treatment facilities that are being upgraded to
provide for advanced waste treatment.
30
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The construction costs for existing primary and
secondary facilities and for increased capacity including
proposed advanced treatment facilities for the three
plants, as of March 1975, are shown below.
Cost of proposed
facilities (note a)
Increased
capacity
Average
and advanced
capac ity
treatment
of proposed
Cost of
including
facilities
existing
Nutrient
nutrient
(mad )
facilities
removal
removal
(000,000
omitted)
Blue Plains
309
$150
b$33 5
b$482
Alexandria
54
4
70
104
Arlington
30
6
36
64
$160
$441
$650
facilities.
^Does not include cost of existing
$100 million of this amount has been deferred until a final
decision has been made about the need for removing nitrogen,
As shown by the above table, the cost for advanced
treatment facilities in the Metropolitan Washington, D.C.,
area is enormous. Of the $650 million total cost of
expansion and advanced treatment facilities at the three
facilities, the estimated Federal share is about $459
million. For the Blue Plains plant, nutrient removal
is estimated to cost more than two times the combined cost
for existing primary and secondary treatment.
In announcing the decision to defer the building of
the nitrogen removal process at the Blue Plains plant,
the EPA region III Administrator stated that "It is a highly
expensive process involving enormous outlays of funds for
a relatively small amount of cleanup."
The study justifying the need for nutrient removal
facilities at Blue Plains was made in 1969 shortly after
the Potomac River had experienced a serious problem with
algal growth. There has not been as serious a problem with
algal growth since that time, however. Spending large
31
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amounts of Federal tunds for nutrient removal facilities to
control a water auality problerr which has not been demon-
strated to be a serious recurrino problem does not apoear
to be justified.
HIGH OPERATION AND MAINTENANCE COSTS OF
ADVANCED WASTE TREATMENT FACILITIES
The operation and maintenance costs of advanced waste
treatment facilities are also high. The following chart
shows a comparison of the current and projected operation
and maintenance costs for the three advanced treatment
facilities in the Metropolitan Washington, D.C., area.
Current annual operation Projected annual costs
and maintenance after expansion
costs for and advanced
secondary treatment treatment is installed
(millions)
Blue Plains
$13.0
$76.0
Alexandria
1.2
10.0
Arlington
1.4
4.4
Total
$15.6
$90.4
Although the design capacity of the Blue Plains
facility is being increased by 29 percent because of
expansion and the modifications which add advanced waste
treatment, the projected operating costs will rise from
about $13 million to $76 million (a sixfold increase) due
principally to the modifications adding advanced waste
treatment. With a 25-percent increase in size, Arlington's
operation and maintenance costs will rise frora $1.4
to $4.4 million (a threefold increase). Some of the
increased operation and maintenance costs can be attributed
to the expanded capacity of the facility but a large part
of the costs are directly attributable to the advanced
treatment facilities.
A major reason for the greatly increased operation and
maintenance costs of advanced treatment is the vast amounts
of chemicals and energy which are required. For example,
if the proposed Blue Plains plant were to be completed as
originally planned, the daily quantities and projected
costs of chemicals expected to be used for the advanced
waste treatment processes would be as follows:
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Treatment
Chemical needed
Quantity
Cost
Phosphorus removal alum
114 tons
$11,600
Nitrogen removal methanol
19,600 gallons
65 tons
85 "
12 ,700
3 ,300
8 ,600
lime
alum
polymer
195 pounds
450
Sludge incineration, if used, would require 45,000
gallons of fuel oil a day at a cost of $19,800. The chemical
costs for methanol and polymer will not be needed if a final
decision is made not to build the nitrogen removal facilities
at Blue Plains.
Because of population increases and improved sewage
treatment processes, the volume of sludge generated by
treatment facilities is expected to increase significantly.
Nationwide, about 4 million tons of sludge are generated
annually. EPA estimates that the total volume of sludge
produced will reach 10 million tons by 19 85. For the Blue
Plains plant, the proposed expansion and nutrient removal
facilities are expected to increase the amount of sludge
produced from about 400 to 2,000 tons a day, a 500-percent
increase.
Some cities are experimenting with a variety of sludge
disposal methods, ranging from incineration to recycling
sludge as fertilizer. Orange County, California, for exam-
ple, plans to open a pilot plant in 197 6 to test a process
that reduces sludge to a small residue of carbon ash.
Philadelphia, Pennsylvania, is testing the wet oxidation
process which involves heating sludge in oxygen and
applying sulfuric acid to destroy the organic material.
The heating process produces gas and grease containing
certain paraffin-type compounds that can be burned as fuel.
In addition, a liquid residue contains metals that can be
extracted for recycling.
At present, Blue Plains uses land trenching as
one of its major means of sludge disposal. However, this
requires a large amount of land. The jurisdictions
surrounding Blue Plains have had difficulty in obtaining
enough land for sludge disposal because land costs are high
and many citizens do not like living near sludge disposal
sites.
For example, in the spring of 1976, Blue Plains was not
operating as efficiently as it could because it did not want
to produce more sludge than the available land in the
surrounding-jurisdictions would be able to handle. In May
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1976 EPA cited Blue Plains for violating its permit and
stated that "At all times, all facilities shall be operated
as efficiently as possible* * *"
EPA later granted Blue Plains a waiver until June 15,
1976, after concluding that Blue Plains had no place to
dispose of the sludge. Before the waiver elasped, however,
the jurisdictions surrounding Blue Plains were able to obtain
sufficient land to allow Blue Plains to resume operating at
maximum removal levels by the June 15 deadline.
The District of Columbia is cooperating with Maryland
and the U.S. Department of Agriculture to develop a sludge
disposal method called composting, which involves a process
whereby organic waste is decomposed to produce a humus-like
material, which can be used as a soil conditioner. Incinera-
tion is proposed as a backup system at Blue Plains.
However, composting, as well as other new sludge
disposal methods, is still being developed and its feasibility
for widespread use at large sewage treatment facilities—
particularly with sludges generated by advanced waste treat-
ment processes which contain large quantities of inorganic
chemicals—will have to be determined.
OBTAINING SUFFICIENT NUMBERS OF TRAINED
OPERATORS FOR ADVANCED WASTE TREATMENT
FACILITIES MAY BE A PROBLEM
A sufficient number of adequately trained personnel
to properly operate and maintain advanced waste treatment
facilities may not be available once the facilities are
constructed. EPA estimates that by 1977 the development of
the municipal plant workforce will require recruiting and
training an estimated 10,000 additional new treatment plant
operators each year in addition to increased training for an
estimated 3 8,000 operators annually. As wastewater treat-
ment facilities become more complex and sophisticated, an
even higher level of expertise will be needed to operate
them.
The Executive Secretary of the Water Pollution Control
Federation said in April 197 5, that there is presently a
shortage of trained operators to run the planned new facili-
ties. He stated that:
"If all the required secondary plants were built there
would not be enough trained operators to run all the
plants. There obviously aren't enough trained
operators to run both the needed secondary and advanced
wastewater treatment plants."
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At the Arlington, Virginia, waste treatment facility,
the operating staff is to be increased from its present
level of 60 to 95 as a result of expanding the capacity
and adding advanced waste treatment. The facility's
superintendent stated that he has had difficulty in obtaining
qualified operating personnel for the present secondary
treatment facility and expected to have continuing difficulty
recruiting operators for the advanced treatment facilities.
CONCLUSION
Controlling pollution from municipal sources will be
costly—billions of taxpayers' dollars—and the most cost-
effective use of Federal funds is essential, especially in
view of the Nation's inflation and economic problems.
Advanced waste treatment facilities are being constructed
even though some of them may not be the most effective or
efficient alternatives for achieving water quality goals.
Decisions were made to build some of these expensive treat-
ment facilities, however, even though comprehensive water
quality planning had not been done, adequate water quality
information on the causes of pollution had not been obtained,
and alternatives to advanced waste treatment had not been
adequately considered. Possible alternatives to advanced
waste treatment plants include low-flow augmentation, control
of nonpoint sources of pollution, and a variety of other
pollution abatement actions.
Some advanced waste treatment facilities are being
constructed without knowing the extent of improvements in
water quality, if any, that are to occur once the facilities
are constructed. In addition, adequate consideration is not
being given to such factors as the high capital costs and
annual operation and maintenance expenses of the proposed
facilities and the sludge disposal problems which may result
because of higher levels of treatment.
RECOMMENDATION
We recommend that, before approving grants for
constructing expensive advanced waste treatment facilities,
the Administrator of EPA determine that:
—All water pollution control alternatives have been
considered.
—Adequate information has been obtained on expected
water quality improvements, high initial capital costs
and annual operation and maintenance expense, and
sludge disposal problems that may result.
35
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MATTER_FOR_CONSIDEFATION_BY
1!1E_92NGRESS
If the Conqress wishes to maintain close scrutiny over
EPA's funding of advanced treatment facilities, the Congress
may wish to have the Administrator, EPA, annually report
to the Conqress on the (1) costs and potential water quality
improvements of new advanced waste treatment facilities and
(2) problems and accomplishments of completed advanced
waste treatment facilities in meeting their water quality
goals .
36
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CHAPTER 4
THE_WILLAMETTE_STUDY«AN_EXAMPLE_OF
^H^_?^EFITS_OF_USING_GOOD_DATA_FOF_PLANNING
Several experts we contacted in the field of water
quality analysis stated that much of the national effort to
attain desirable water quality is based on inadequate data.
Methods of obtaining the needed water quality information
are available and are starting to be implemented by some of
the States. At the same time, however, even these methods
are being continuously improved. In addition to EPA
obtaining water quality information, other Federal agencies
are assisting in developing methods for obtaining and
interpreting water quality data.
After collecting cause and effect data based on a pilot
study of the Willamette River in Oregon, a U.S. Geological
Survey (USGS) team identified alternatives for achieving
water quality standards. These alternatives may save
several million dollars in Federal and State construction
funds. Several members of the Department of the Interior's
Advisory Committee on Water Data for Public Use—which
includes national authorities on pollution control—said that
the Willamette study was excellent and should be used as an
example of how water quality studies should be done. Oregon
Department of Environmental Quality officials also stated
that the USGS study was well done and that the State is
using the results of the study to clean up its water.
CLEANING UP THE WILLAMETTE RIVER
The Willamette River Basin is located in northwestern
Oregon. Within the basin are three of the State's largest
cities, Portland, Salem, and Eugene and about 70 percent of
the State1 s population. The basin supports an important
timber, agricultural, industrial, and recreational economy
and also extensive fish and wildlife areas.
The Willamette River has been carefully studied in the
past and, on the basis of this information, extensive
cleanup has been made in Oregon by various industries, the
State, and the Federal Government. The goal of this cleanup
was to provide a water quality that satisfied the recreational
and aesthetic requirements of people and an adequate environ-
ment for fish. One of the most important measures of water
quality is dissolved oxygen. The State has set requirements
for minimum levels of dissolved oxygen necessary for fish
and other aquatic organisms and for the prevention of
offensive odors.
37
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Through several years of extensive cleanup, all the
industrial and municipal dischargers on the river finally-
achieved secondary treatment of their wastes in 1972. The
Willamette River is now the largest river in the United
States on which all known point sources of wastewaters
receive secondary treatment. As a result, the water quality
of the river has markedly improved, reaching the State
standards for dissolved oxygen in all but extremely low-flow
years.
Because of strong State interest in environmental
matters, the State Department of Environmental Quality
planned to take additional actions to make sure that the
Willamette water guality met or exceeded State standards at
all times. The State planned to require advanced wastewater
treatment for all municipal and industrial polluters to remove
additional amounts of BOD and suspended solids. This advanced
treatment requirement would have affected a large number of
municipal polluters and could have cost tens of millions of
Federal and State dollars.
The results of the U.S. Geological Survey study of the
Willamette, begun in January 197 3 and done in cooperation
with the Oregon Department of Environmental Quality,
indicated that effective and efficient management alternatives
were available which could achieve the desired water quality
standard, yet save millions of dollars.
A DESCRIPTION OF THE WILLAMETTE STUDY
The purpose of the Willamette River pilot study was to
(1) develop and test new methods for river quality analysis
and (2) use the information obtained to determine the impact
of various alternatives on water quality. As noted by the
study team:
"Achievement of desirable river quality at acceptable
cost requires that management decisions be based on
sound impact assessments, not on arbitrary assumptions.
Thus, the vital link between resource-development
plans and management decisions is scientific assessment
to predict the probable impacts of each planning
alternative."
To understand the cause and effect water quality
relationships in the Willamette Basin, the study team looked
at the basin's hydrology, chemistry, and biology. The team
stated that river basin studies have to be developed on a
case-by-case basis because each basin has different charac-
teristics that need to be considered.
38
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A large amount of river quality data had been collected
in previous studies, and much of this data was useful for
background purposes of the USGS study. Information on
pollutant loadings, flow, and water quality had not been
collected at the same time. Consequently, cause and effect
relationships could not be determined. Additionally,
in order for monitoring and surveying information to be
useful, the sampling has to be aimed at the specific needs
of the program managers. Water quality experts cannot
simply collect general data and try to use it later for a
variety of specific purposes.
The study team prepared a mathematical model of
dissolved oxygen to test alternatives concerned with variable
water flow and pollutant loadings. The study team defined
specific data needs and modified certain standard tests to
meet the changing conditions of the water. For instance,
most of the BOD tests in previous river quality studies
were given a 5-day analysis which is a standard test.
However, the basinwide implementation of secondary treatment
had removed a substantial percentage of the rapidly decaying
wastes from the water. The remaining wastes in the river
tended to degrade much more slowly. The study team thus
used a 20-day test of BOD which was more meaningful.
Because river quality planning and management decisions
in the Willamette Basin have been dictated primarily by
poor water quality conditions that occur during the summer
when low flows and high temperatures exist, the study team
aimed the tests and modeling at this critical period. The
study team believed that collecting extensive dissolved
oxygen data during the remainder of the year for assessing
management alternatives would waste both time and money.
Because only a short period of the year needed to be
studied, fieldwork could be very intensive to provide a high
degree of data reliability.
The study emphasized the importance of timeliness in
gathering information for water quality planning and manage-
ment needs. Even with this emphasis, however, the study
took 2-1/2 years to complete. In commenting on the extended
time frame, the study team stated that few, if any, rivers
have existing data that is valid and adequate enough to
permit sound river quality planning. Therefore, for complex
river systems, 2 to 3 years of intensive data collection,
verification, and analysis during critical periods is gener-
ally needed. The data can be collected during a short, low-
flow period during the summer, but it takes 2 or more years
to analyze and verify the conclusions developed from the
data.
39
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The study cost an estimated $500,000 to complete. A
large part of the money, however, was used to experiment
with new approaches, testing techniques, and methods of
analysis. The director of the study team estimated that a
similar study, using the newly developed approaches and
methods, would cost about $150,000 to $200,000 and would
require 2 years to complete.
The study did require a great deal of money, but it is
only a fraction of the tens of millions of dollars it would
have cost: to install advanced waste treatment facilities to
remove more BOD and suspended solids basinwide.
RESULTS OF THE WILLAMETTE STUDY
The study team found that the generally high quality
of the Willamette River during most of the year was the
result of two factors—basinwide implementation of secondary
treatment and low-flow augmentation. The naturally occurring
low summer flows have been augmented by a number of Corps
of Engineers reservoirs which were built for irrigation and
navigation and not for water quality enhancement. The Corps
maintains a minimum flow of 6,000 cubic feet per second
during the critical summer months. In comparison, the
naturally occurring low flow for the unusually dry summer of
1973 would have been 3,260 cubic feet per second.
The study team stated that, without flow augmentation,
State dissolved oxygen standards would have been violated
for a large segment of the river during the 1973 natural
flow. They also found that, even though secondary treatment
had a profound effect on the river, increasing BOD and
suspended solids removal by implementing advanced waste
treatment would not have appreciably increased the dissolved
oxygen levels further. One reason for this is because, of
the total remaining BOD in the river, almost one-half
represents natural sources of pollution. Thus only one-half
of the BOD is potentially amenable to removal by higher
levels of treatment at point sources.
According to the study team, the major factor affecting
dissolved oxygen levels in the only segment of the river
that did not meet State standards in the summer of 19 7 3
was the discharge of ammonia by industrial dischargers.
About 6 8 percent of the ammonia came from one industrial
discharger. When this ammonia is discharged to the Willam-
ette. it reacts with bacteria in the river to change its
chemical form. This reaction consumes dissolved oxygen.
The study results indicated that advanced waste treat-
ment construction for all municipal and industrial dischargers
40
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to remove additional amounts of BOD and suspended solids over
secondary treatment levels would not appreciably increase the
dissolved oxygen levels in the river. Instead, the study
results showed that the continued augmenting of the flow of
the river from reservoirs and controlling just the one
industrial firm's large ammonia discharge would greatly
reduce the impact of nitrogen and achieve desirable dissolved
oxygen levels throughout the Willamette River.
The effect of the dissolved oxygen level of the various
alternatives examined by the study team is shown on page 42.
The dotted line represents the State standards for dissolved
oxygen levels in the Willamette. Line B shows the actual
dissolved oxygen levels in the Willamette during the summer
of 197 3, when the flow was augmented to 6,000 cubic feet per
second. Line C shows what the dissolved oxygen levels would
have been in the summer of 1973 if the Willamette's flow had
not been augmented. As can be readily seen, if the flow
had not been augmented, the dissolved oxygen levels would
have violated the State standards for a large segment of the
river.
Line A represents the dissolved oxygen levels attainable
through the continued use of low-flow augmentation and the
reduction of ammonia from present dischargers. Under this
alternative, the State standards would be exceeded at all
times.
If all municipal and industrial dischargers were
required to go to advanced waste treatment to remove
additional amounts of BOD and suspended solids as originally
planned by the State, the study showed that the existing
dissolved oxygen levels, as shown by line B, would not change
substantially.
The USGS analysis of the Willamette was completed in
August 1975. An official of the Oregon Department of
Environmental Quality stated that, because of the new
information, the State has revised its water cleanup on the
Willamette. Efforts are now being made to reduce the
ammonia loadings from both industrial and municipal point
sources.
Concerning the need for maintaining adequate flow levels
in the river, an official of the Oregon Department of
Environmental Quality explained that the State has no control
over the water flow levels on the Willamette. Even with the
high levels of treatment at the point sources on the
Willamette, the present good quality waters would fall below
the State standard if the Corps of Engineers decreased the
flow levels because of changes in irrigation or navigation.
41
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IMPACT OF FLOW AND AMMONIA LOADING
ON WILLAMETTE RIVER DISSOLVED OXYGEN LEVELS, JULY-AUGUST 1973
100 I—
6000 CFS* (AUGMENTED FLOW WITH AMMONIA REDUCED)
SALEM, OREGON
NEWBERG, OREGON WILLAMETTE FALLS PORTLAND HARBOR
RIVER MILE FROM MOUTH
•CUBIC FEET PER SECOND - REPRESENTS THE AVERAGE FLOW AT SALEM, OREGON
42
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An April 197 5 State water quality report noted that, of the
various factors affecting water quality, the loss of stream-
flow would be the most detrimental to water quality. The
report emphasized the need for increased attention to
streamflow as follows:
"The value of a flowing stream needs public recog-
nition and support eaual to that given to the protection
of water duality through the control of waste discharges."
CONCLUSION
Because USGS used better data to develop cause and
effect relationships in evaluating the various water
pollution control alternatives, more effective, efficient,
and economical means of achieving desirable water quality
were discovered.
We believe this case study illustrates the potential
benefits that can be obtained if additional emphasis is
placed on collecting scientifically sound water quality data
and using it to carefully analyze management alternatives
for water pollution control. In complex river basins, such
studies will take a considerable amount of time and money
but the Willamette example illustrates the great potential
benefits that can result if this additional time and money
is spent.
43
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CHAPTER 5
AGENCY AND STATE COMMENTS AND OUR EVALUATION
This proposed report was submitted to the Environmental
Protection Agency, Idaho, Maryland, Oregon, Virginia,
Washington, and the District of Columbia for comments on our
review of their activities discussed in the report.
EPA advised us in a September 29, 1976, letter that it
agreed with the main thrust of our report that costly
treatment facilities providing for treatment levels beyond
the secondary level should generally not be approved until
intensive water quality cause and effect studies have been
completed. (See app. II.) EPA also concurred with our
findings that there are instances where adequate monitoring
data may not have been collected in the case of some
advanced waste treatment projects. EPA's main concern with
our proposed report, however, was that most of EPA's con-
struction grant funds are being spent on secondary treatment
facilities which are not subject to many of the criticisms
raised in the proposed report. According to EPA, significant
improvement has been made in planning for secondary treatment
facilities.
We agree with EPA that very little water quality
planning and data collection are required for construction
of secondary treatment facilities. Indeed, a major feature
of the 197 2 amendments is that secondary treatment is
generally required for all municipalities, and because of
this, little decisionmaking concerning the need for construc-
tion is really needed.
Although less planning and water quality data is
generally required for secondary than for advanced waste
treatment, we believe it is essential that EPA sufficiently
plan and collect cause and effect water quality data before
it decides that advanced waste treatment facilities are
necessary and that such treatment facilities can achieve
water quality goals in an effective and efficient manner.
EPA said that it has problems where some advanced
waste treatment facilities are required, particularly in
predicting cause and effect relationships. According to
EPA, a primary problem in determining cause and effect
relationships has been inadequate water quality data.
EPA stated that it has taken steps to evaluate its
decisionmaking process for funding advanced waste treatment
facilities and recognizes a need for improving water quality
data collection. According to EPA, an internal, independent
44
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evaluation group within EPA is currently addressing advanced
waste treatment problems through an evaluation of water
quality standards, effluent limitations, and other elements
of planning that result in advanced waste treatment require-
ments. In addition, EPA said it formed a working group,
which includes State representation, to review monitoring and
to develop program and policy revisions. Implementation of
the program is expected to substantially strengthen the data
base on which advanced waste treatment planning decisions are
made.
We concur with EPA's efforts to develop a sound basis
on which decisions to build expensive advanced waste
treatment facilities can be better justified. In the interim,
however, and until the results from EPA evaluations are
received, we believe that EPA may wish to consider limiting
State construction of expensive advanced waste treatment
facilities to a few designated experimental basins.
EPA agreed with our recommendations concerning water
quality planning and data collection and suggested two more
recommendations for improving the comprehensive planning
process.
Technical changes suggested by EPA officials were
considered and changes made to the report where appropriate.
Washington felt that the report, in general, raised
valid points regarding the problems associated with water
pollution abatement planning in the United States.
Specifically, the State felt that such problems as the need
for more comprehensive data and technical knowledge to
determine treatment levels necessary to safeguard or improve
water quality and the need for trained operators at existing
and newly constructed treatment facilities are well taken and
should be resolved for more effective water quality manage-
ment. However, the State questioned some of the other points
we raised. (See app. VI.)
Oregon believed that the general emphasis of the report
seemed to be that advanced waste treatment is not necessary
to clean up the Nation's waters. (See app. IV.) We believe
that the report does not imply that advanced waste treatment
is never needed. To the contrary, we believe there can be
times when the most effective or efficient means for
achieving water quality goals will be for advanced waste
treatment facilities to be constructed. We believe, however,
that decisions to build advanced waste treatment facilities
are justified as long as comprehensive water quality planning
has been done, adequate water quality information on the
causes of pollution has been obtained, and all water
45
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pollution control alternatives have been considered to
insure that advanced treatment processes will improve water
quality and will result in the most effective and efficient
use of Federal funds.
Virginia stated that, in the past, the States had
pressure on them to get the grant funds committed under the
philosophy of "use it or lose it." According to Virginia,
the States and EPA had insufficient manpower to always assure
that the projects funded were fully cost effective. Planning
has been behind schedule and out of phase and EPA should not
be faulted for putting construction first because it could
not do everything at once. Virginia further commented that
although current elaborate planning and cost-effectiveness
methodologies did not exist in the old days, the then
existant planning procedures were applied. (See app. V.)
Maryland did not make any specific comments regarding
the general thrust of our report but did comment on a number
of specific issues which were pertinent to their own State's
activities. (See app. III.)
Various comments made by the States which responded
were considered and changes were made to the report where
appropriate.
46
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APPENDIX I
APPENDIX I
FACT SHEETS FOR THE DISTRICT OF COLUMBIA, IDAHO,
MARYLAND, OREGON, VIRGINIA, AND WASHINGTON
DISTRICT OF COLUMBIA FACT SHEET
Funds allocated under Public Law 92-500 for construc-
tion :
Fiscal year
1973
$ 14,228,000
Fiscal year
1974
21,342,000
Fiscal year
1975
38,233 ,800
Fiscal year
1976
72,492,000
Total
$146,295,800
Number of basins and designated areas: Basins: 0
Areas: al
Number of completed and approved plans as of July 1,
1976: Basins: N/A Areawide: 0
Estimated date of completion of basin plans: N/A
Statutory completion date of areawide plan: 1977
Advanced Treatment Facilities
Planned or Under Construction as
of July 1976
Estimated
Federal Project
Project funding (note b) status
Blue Plains C$328,600,000 ^58 percent complete
The planning is being done under an areawide agency
consisting of Maryland, Virginia, and District of Columbia
officials.
k
Includes costs to upgrade and/or expand the secondary
treatment process.
C$100,000,000 of this amount has been deferred until a
final decision about the need for nitrogen removal is made.
Construction of the denitrification stage of the project
has been deferred as noted in footnote c.
47
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APPENDIX I APPENDIX I
IDAHO FACT SHEET
Funds allocated under Public Law 92-500 for construc-
tion :
Fiscal year 1973 $ 4,354,000
Fiscal year 1974 6,531,000
Fiscal year 1975 7,898,400
Fiscal year 1976 19,219,100
Total $38,002,500
Number of basins and designated areas: Basins: a6
Areawide: 3
Number of completed and approved plans as of July 1,
1976: Basin: 0 Areawide: 0
Estimated date of completion of basin plans: 1976
Statutory completion date of areawide plans: 1977
Advanced Treatment Facilities
Planned or Under Construction as
of July 1976
Estimated
Project Federal Project
(note_b) funding (note c) status
West Boise $8,099,000 85 percent complete
a
In order to speed up their completion, the plans for the
six basins were consolidated into one plan.
Two additional plants are plumbed and one will be plumbed
for possible addition of phosphorus removal equipment.
Includes costs to build the secondary treatment process.
48
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APPENDIX I
APPENDIX I
MARYLAND FACT SHEET
Funds allocated under Public Law 9 2-500 for construc-
tion:
Fiscal year
1973
$ 85,164,000
Fiscal year
1974
127,746,000
Fiscal year
1975
54,128,100
Fiscal year
1976
297,705,300
Total
$564,743,400
Number of basins and designated areas: Basins: 18
Areas: 1
Number of completed and approved plans as of July 1,
1976: Basin: 1 Areawide: 0
Estimated date of completion of basin plans: 197 6
Statutory completion date of areawide plans: 19 77
Advanced Treatment Facilities
Planned or Under Construction as
of July 1976
Estimated
Project Federal Project
(note a) funding (note b) status
Parkway $ 10,361,000 (c)
Western Branch 35,132,000 (d)
Savage 22,346,000 (e)
Piscataway 43,083,000 (f)
Sod Run 375,000 (g)
Northeast 5,888,000 (g)
Central Patuxent 675,000 (g)
Dickerson 7 2,000,000 (h)
Total $189,860,000
aAbout $83.3 million of Federal funds for Maryland have been
included in the total for the Blue Plains Treatment Plant on
the District of Columbia fact sheet.
Includes costs to upgrade and/or expand the secondary
treatment process.
49
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APPENDIX I
APPENDIX I
The expansion of the primary and secondary stages are 99
percent complete. The advanced waste treatment stage is
undergoing facilities planning.
^The expansion of the primary and secondary stages are 95
percent complete. The advanced waste treatment stage is out
for construction bids.
0 • • •
Construction drawings and specifications are complete--
construction is being temporarily delayed pending further
study on the location of the plant's outfall.
^Ten percent complete—construction of the denitrification
stage has been deferred until a final decision about the need
for nitrogen removal is made.
^Facilities planning completed—ready for preparation of
construction drawings and specifications.
The construction grant application for this project was
returned to the State by EPA for reconsideration of alter-
natives to the plant.
50
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APPENDIX I
APPENDIX I
tion:
OREGON FACT SHEET
Funds allocated under Public Law 9 2-500 for construc-
Fiscal year 1973 $ 16,988,000
Fiscal year 1974 25,432,000
Fiscal year 1975
Fiscal year 1976
Total
34,136,700
77 ,582,900
$154,139,600
Number of basins and designated areas: Basins: 20
Areas: 4
Number of completed and approved plans as of July 1,
1976: Basin: 0 Areawide: 0
Estimated date of completion of basin plans: 1976
Statutory completion date of areawide plans: 1977
Advanced Treatment Facilities
Planned or Under Construction as
of July 1976
Project
Arlington
Hillsboro
North Tillamook Co.
Rock Creek United
Sewage Agency
Washington Co.
Durham
Total
Estimated
Federal
funding (note a)
$ 165,000
964,000
2,226,000
17,250,000
18^525^, 000
$39,130,000
Project
status
Completed
Completed
90 percent complete
20 percent complete
9 0 percent complete
Completed
Includes costs to upgrade and/or expand the secondary
treatment process.
51
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APPENDIX I
APPENDIX I
tion:
VIRGINIA FACT SHEET
Funds allocated under Public Law 92-500 for construc-
Fiscal year 1973 $ 58,286,000
Fiscal year 1974 87,429,000
Fiscal year 1975 98,673,400
Fiscal year 1976 251,809,000
Total $496,197,400
Number of basins and designated areas: Basins: 9
Areas: 5
Number of completed and approved plans as of July 1,
1976: Basin: 0 Areawide: 0
Estimated date of completion of basin plans: 1976
Statutory completion date of areawide plans:
1976 for 3 plans
1977 for 2 plans
Advanced Treatment Facilities
Planned or Under Construction as
Proj ect
(note a)
Alexandria
Arlington
Fairfax (lower
Potomac)
Prince William
Upper Occoquan
Aquia
Roanoke
Culpeper
Total
of July 1976
Estimated
Federal
funding (note b)
$ 73,961,000
46,753,000
47,457,000
23,250,000
56,471,000
3 ,592,000
23,647,000
5,000,000
$280,131,000
Proj ect
status
(note c)
(d)
85 percent complete
7 0 percent complete
(d)
80 percent complete
(d)
99 percent complete
(e)
An additional $5.3 million in Federal funds for Virginia
have been included in the total for the Blue Plains Treatment
Plant of the District of Columbia fact sheet.
52
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APPENDIX I
APPENDIX I
^Includes cost to upgrade and/cr expand the secondary-
treatment process.
c
The status of the advanced waste treatment part of the plant.
^Construction drawings and specifications completed. Ready
to begin construction or under construction.
0
Facilities planning completed. Construction drawings and
specifications being prepared.
53
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APPENDIX I
APPENDIX I
WASHINGTON FACT SHEET
tion:
Funds allocated under Public Law 92-500 for construe-
Fiscal year 1973 $ 17,812,000
Fiscal year 1974 26,718,000
Fiscal year 1975
Fiscal year 1976
Total
64 ,730 ,500
103 ,915,600
$213,176,100
Number of basins and designated areas: Basins:
Areas: 3
25
Number of completed and approved plans as of July 1,
1976: Basin: 22 Areawide: 0
Estimated date of completion of basin plans:
Statutory completion date of areawide plans:
Advanced Treatment Facilities
Planned or Under Construction as
1976
1977
Project
City of Spokane
Stevens Pass S.D.
Kittitas City
S.D. #1
Total
of July 1976
Estimated
Federal
funding (note a)
$33,530,000
1,900, 000
50CK000
$35,930,000
Proj ect
status
77 percent complete
15 percent complete
Planned
Includes costs to upgrade and/or expand the secondary
treatment process.
54
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APPENDIX II
APPENDIX II
•sr t
J> T-
UN1TED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
• ' 3"? 1976
OFFICF OF
PLANNING AND MANAGFMFNT
Mr. Henry Eschwege
Director
Community and Economic Development
Div ision
U.S. General Accounting Office
Washington, D.C. 20548
Dear Mr. Eschwege:
On July 21, we received copies of G.A.O.'s draft
report to Congress entitled "Planning for Water Pollution
Abatement: Not Effective in Controlling Costs and
Achieving Water Quality Goals," for review and comment.
The main thrust of the text of the report is that
costly treatment plants providing for treatment levels
beyond the secondary level should generally not be
approved until intensive water quality cause and effect
studies have been completed. We agree. We also concur
that in the case of some advanced wastewater treatment
(AWT) projects there are examples where adequate
monitoring data may not have been collected. Most
construction grant funds, however, are being spent on
secondary treatment facilities which are not subject to
many of the criticisms raised in the report.
In this regard, EPA has proposed an amendment of
P.L. 92-500 to Congress that would limit Federal funding
to constructing waste treatment projects necessary to
comply with secondary treatment standards unless it can
be demonstrated to the Administrator that a higher level
of treatment is the most cost-effective means of meeting
water quality standards.
Planning for the secondary treatment facilities is
covered by Section 201 (Step 1) grants. Within the
last two years, significant improvement has been made in
such planning, largely as a result of actions taken to
55
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APPENDIX II
APPENDIX
implement recommendations contained in F, PA's own evalua-
tion report, "Review of the Municipal Wastewater
Treatment Works Program," released in November 1974.
The improvements have been effective in both controlling
costs and helping to achieve water quality goals.
We recognize that we have problems wh ere some AW T
facilities are required, particularly in predicting
cause-effect relationships. EPA' s interna] , independent
evaluation group, the Program Evaluation Division (PED),
is currently addressing AW T problem areas through an
evaluation of water quality standards, effluent limitations
and other elements of planning that result in AWT
requirements. PED is also evaluating other "front
end" elements of the construction grants process, where
most of the major decisions affecting the nature and
cost of projects are made.
A primary problem in determining cause-effect
relationships has been inadequate water quality data.
EPA has recognized the problem and last year established
the Standing Work Group on Water Monitoring to review
monitoring activities and to develop program and policy
revisions. The group, which includes state representation,
is in the process of developing a basic monitoring
program. Implementation of the program is expected to
substantially strengthen the data base upon which AWT
planning decisions are made.
We agree with the recommendations at the end of
Chapter 2 (page 23), but suggest that the following two
be added:
— Enforce and/or expand permit requirements to
force municipalities to characterize wet
weather discharges.
— Publish guidelines which would specifically
state procedures to be followed in assessing
water quality impacts of point and nonpoint
sources and in determining levels of control
necessary to achieve water quality goals in
water quality limited waters.
56
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APPENDIX II
APPENDIX
[See 0-\"> i-O ("-?]
A number of proposed technical changes have been
submitted informally to your personnel with advance
copies of our comments.
We appreciate the opportunity to review and comment
on this report prior to its submission to Congess.
GAO note: Material has been deleted because of changes
in final report or because of reference to
material not included in our report.
Sincerely,
Alvin L. Aim
Assistant Administrator
for Planning and Management
57
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APPENDIX III
APPENDIX III
OFFICE OF THE SECRETARY
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
201 WFST PRESTON STRFFT • BALTIMORE MARYLAND 2)201 * Afeo Code 301 ¦ 383-2714.0
Neil Swiiimon. MD. PhD. Secretory
Refer to: August 26,
EH:SE:WS
Mr. Henry Eschwege
Director
U. S. General Accounting Office
Washing-ton, D. C. 20^1+8
Dear Mr. Sschwege:
The staff of the Environmental Health Administration of our Department has reviewed
the Draft Report to Congress for "Planning for Water Pollution Abatement: Not
Effective in Controlling Costs and Achieving Water Quality Goals." We would like
to comment as follows:
There is a connotation in Chapter 2 indicating a lack of comprehensive planning
on behalf of the States studied. We would like to point out that since 1967 the
State of Maryland has had an ongoing program of comprehensive water and sewer plan-
ning carried out by the counties under the auspicies of this Department, and these
plans have formed a major basis for the formulation of area-wide and river basins
planning required under subsequent Federal law.
As the State of Maryland has a large shellfish harvesting industry, a great deal
of emphasis has been placed by this Department on the assimilation and utilization
of bacteriological sampling as a very important facet of water quality control.
Towards this end this Department has worked diligently to reduce bacteriological
contamination from point sources^ with a great degree of success.
In addressing the advanced wastewater treatment requirements, particularly those
of nutrient removal, we have, in cooperation with the Water Resources Administration
of the Department of Natural Resources, attempted to provide facilities in those
areas where their studies indicated need for such facilities. However, as noted
in the preamble to the 1977 Grant Priority List, the list is set up to address
health and inadequate water problems prior to advanced wastewater treatment for
nutrient removal.
58
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APPENDIX III
APPENDIX III
Finally, Appendix I, Page 3, Maryland State Fact Sheet, under the estimated Federal
funding in Column 2, this is subject to change as the Savage Plant has been delayed
due to a relocation study for the outfall, the Northeast Plant is undergoing some
strong questioning at Environmental Protection Agency at this time, the Central
Patuxent Plant has a draft facility plan being prepared and Piscataway and Dickerson
Plants have, as has been widely reported, been subjected to considerable change
based on some imminent Environmental Protection Agency decisions.
We thank you for the opportunity to comment on this report.
Sincerely yours,
Neil Solomon, H.D., Ph.D.
Secretary of Health and
Mental Hygiene
NS:bn
cc: Dr. Benjamin D. White
59
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APPENDIX IV
APPENDIX IV
Department of Environmental Quality
1234 S W MORRISON STREET, PORTLAND OREGON 97205 Telephone (503) 229- S324
September 21, 1976
Director, Community &
Economic Development Division
U. S. GENERAL ACCOUNTING OFFICE
Room 6146
441 G Street N. W.
Washington, D. C. 20548
Attention: Mr. Oliver W. Krueger, Assistant Director
Gentlemen:
On September 13, 1976, I finally received the copy of the draft report
referred to in your September 3, 1976 letter.
The following comments are offered for your consideration:
1. The USGS Willamette study is mentioned in several places. The
USGS study is the best technical study of its type we are aware
of anywhere. The study has added new insights into the Depart-
ment of Environmental Quality's management program by confirming
many previous DEQ assumptions (particularly with reference to
ammonia load impact). We do not fully agree with USGS management
reconmendations however. The study did not consider the impact
of future population and industrial growth in the basin or the
potential for future reduced stream flows as a result of in-
creased consumptive water use for irrigation of food crops.
The DEQ had projected the need for municipal waste treatment to a
10/10 (mg/1 BOD/mg/1 suspended solids) level by 1980 in order to
accoimnodate growth without increasing point source waste loads to
the river. As a result of the USGS study results, the Department
is proposing to delete the 1930 date and instead require upgrading
when existing secondary facilities reach capacity and must be
upgraded.
In summary, DEQ has modified the timetable for upgrading Willamette
Basin treatment levels as a result of the USGS study — the
ultimate objective has otherwise not been modified however.
60
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APPENDIX IV
APPENDIX
U. S. General Accounting Office
Attention: Hr, Oliver W. Krueger
September 21, 1976
Page 2
2. The Tualatin Basin is mentioned on pages 33 and 34. DEQ has
consistently supported the need for stream flow augmentation in
the Tualatin Basin to meet beneficial uses. With the maximum
future flow augmentation realistically practicable, the stream
will still not accommodate the secondary treated effluent from a
projected 250,000 to 3S0.000 people. In addition most of the
stream flow at the lower end of the basin is legally diverted
into Lake Oswego - a recreational lake which has an algae growth
problem. The decision to require "advanced waste treatment" in
the Tualatin Basin was based on the lack of stream flow, the
reality and timing of flow augmentation and the need to reduce
phosphorous input to Lake Oswego.
Also, please note, that DEQ standards in the Tualatin tie treat-
ment levels to stream flow - a dilution ratio standard. Thus
the standards allow reduced treatment levels (from advanced to
secondary) if dilution water can be provided. So far, it has
not been economical for entities to provide significant flow
augmentation.
3. Several plants are inaccurately listed as "advanced treatment"
in your table on Page 62. Only the Durham and Hillsboro plants
have nutrient removal capability and are considered "advanced".
Salem is a secondary plant (pure oxygen activated sludge) which
treats a large food processing waste load.
Arlington has a secondary treatment plant with a sand filter for
effluent suspended solids removal. (No chemical treatment
facilites exist). Discharge is to a boat basin which has
restricted mixing.
North Tillamook County Sanitary Authority is also a secondary
treatment plant with a sand filter. Discharge is to an estuary
in a shellfish growing area. The filtration is necessary to
remove suspended solids from the effluent to achieve adequate
disinfection.
DEQ does not consider secondary plants with sand filters or
"effluent polishing ponds" to be "advanced treatment".
4. On Page 16, a statement implies that EPA adoption of monitoring
regulations would aid state programs. We find it hard to
believe that any state would want more EPA regulations of any
kind. In Oregon, EPA regulations and program requirements have
distorted our monitoring program to the point where we are
unable to apply our limited resources to real data needs.
61
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APPENDIX IV
APPENDIX
U. S. General Accounting Office
Attention: Mr. Oliver W. Krueger
September 21, 1976
Page 3
5. The general emphasis of the report seems to be that advanced
waste treatment is not necessary to clean up the nation's
waters. The total emphasis is on clean up. It is disturbing
that no reference is made to accommodating future growth or
preventing pollution. PL 92-500 contains significant require-
ments regarding anti-daqradation. In our view, improved secondary
treatment and advanced treatment will be necessary down the road
to prevent degradation of water quality as population increases.
We hope these comments are of use to you.
Very truly yours,
LOREN KRAMER
Director
/
/ , ' '
Harold L. Sawyer
Administrator
Water Quality Division
HLS:AK
62
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APPENDIX V
APPENDIX V
COMMONWEALTH of VIRGINIA
Post Office Box 11143
Richmond, Virqinia 23230
(804)786 1411
Executive Secretary
sr tn: a i Ti n (:ovnu>i. no \fu>
-III IfitntilltH! S/rcc/
August 30, 1976
BOARD MEMBERS
Col. J. Leo Bourassa
Warien L. Braun
Vice-Chairma rt
Mr. Henry Eschwege, Director
George M. Cornell
Roy B. Marnn, Jr.
M
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APPENDIX V
APPENDIX V
Mr. Henry Eschwege August 30, 1976
We believe that it is apparent that the Roanoke decision was made on the basis
of the best planning available prior to 1972. Subsequently, the Board has
prepared a metropolitan-regional water quality management plan, which was
factored into the planning for the Roanoke plant improvements. While con-
struction of the improvements was proceeding, the Roanoke valley political
subdivisions, being appreciative of improvements in the science of determin-
ing eutrophication, were one of the first applicants in the nation for an
areawide wastewater management study under Section 208 of PL 92-500. This
study is also one of the first in the nation to be completed and the findings
reflect that point source removal of carbon and phosphorous was the most
economical methodology to be incorporated. In conjunction with this study,
the State, under Phase II of the 208 program is conducting a special study
on Smith Mountain Lake to establish a management tool for future non-point
source curtailment on Lake development (located just below the Roanoke metro-
politan area).
It will be possible to monitor performance of the Roanoke STP and the quality
of the Roanoke River and Smith Mountain Lake to determine if and what further
nutrient-removal facilities need to be installed. Therefore, we do not
believe that the treatment facilities now installed, or being installed, have
been installed blindly. Any facilities now in place, or under construction,
will be a usable part of future plant additions if future studies may indicate
they are necessary.
3) Pages 36-45 (Washington Metropolitan area). The original BOD and nutrient
limitations applicable in the Washington Metropolitan area were imposed by
the Potomac Enforcement Conference in 1969, convened under a predecessor act
to PL 92-500. As was the case in the Roanoke area, it was generally agreed
that, to reduce the total BOD discharge from all point sources in the Washington
Metropolitan Area sufficiently to maintain DO standards in the Potomac River,
more than secondary treatment would be required. Based on studies made by
one of EPA's predecessor agencies, nitrogen and phosphorous nutrient removal
objectives were also imposed.
Your consultants' report regarding the Washington Metropolitan Area points out
that a definite cause and effect relationship between nutrients and algae
growths in the Potomac River has not been shown. It also states that con-
struction of AWT facilities should "proceed slow and cautiously, taking a
wait-and-see attitude..." until data show the need for such facilities. As
is the case in the Roanoke area, AWT facilities now installed or under con-
struction in the Washington Metropolitan area will reduce carbon (as BOD),
which is completely justifiable based on the need for maximum possible BOD
removal to improve dissolved oxygen of the Potomac River. Any concurrent
phosphorous reduction is a bonus.
Having recognized some of the foregoing shortcomings, and the fact that great
amounts of nutrients are contributed to the Potomac estuary from upstream
point and non-point sources, coupled with the tremendous cost of installing
nitrogen removal facilities, EPA and the owners involved have taken a second
look and adopted your consultants' "wait-and-see" attitude with respect to
further expenditures for nitrogen removal. While some of the waste treatment
construction now underway may not be completely justified from a nitrogen
and phosphorous removal standpoint, those portions of the construction aimed
at maximum BOD reduction are completely justified.
64
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APPENDIX V
APPENDIX V
Mr. Henry Eschwege August 30, 1976
4) Page 46, while correct, takes no notice of substantial State/EPA efforts
to solve the problem by providing operator training opportunities and, in
Virginia, by requiring certification of those operators. Also, we believe
that your figure of 154 for the new operating staff at Arlington plant
includes maintenance men, painters, electricians, lab technicians, laborers,
etc., who may possibly work at other county facilities as well. The incre-
mental need for new operators at Arlington will be about 35, considerably
less than implied.
5) Pages 63 and 64 are correct, the latter as of March 1975. In an enclosure
we have updated page 64 to reflect July 197 6 status, and you may wish to use
this enclosure if similar updates are available throughout Appendix I.
The foregoing comments are specific to the Virginia references in your report.
We offer also the following very general remarks relative to efficiency and
cost effectiveness of the Federal-States water pollution control program.
1. Sanitary engineers have not generally been too innovative.
2. Regulatory agencies, particularly state health departments (who often
strongly advise on, even if they do not directly regulate, sewage disposal),
tend to be conservative in outlook. This posture is understandable in view
of their concern for public health, but it has tended to discourage trial of
novel and less-expensive disposal methods,
3. Low-cost alternatives have not been particularly popular and there
has been no real incentive to make them so at the technical decision-making
level. Consulting engineers' fees are often based on the dollar value of
the construction contract or estimate; in practice some of them may do
facility planning at or below their cost in hopes of winning the construction
supervision contract. This is not to imply conflict-of-interest or bad faith
but suggests that the impetus may not exist to encourage minimum-cost solu-
tions. The consultants' local-government clients, especially the smaller ones,
often lack engineering expertise to challenge the plans and to seek lower-cost
alternatives or indeed to effectively negotiate with the consultants. After
all, somebody else is providing 75 percent of the money.
4. There has undoubtedly been pressure on the States, in the past, to
get grant funds committed, under the philosophy "use it or lose it." The
States, and no doubt EPA as well, had insufficient manpower to always assure
that the projects funded were fully cost-effective. We believe that the
Congress and the people expected early progress on plant construction after
passage of P.L. 92-500. Planning has admittedly been behind schedule and
out of phase, but even EPA could not do everything at once, and we cannot
fault them for putting construction first. Please realize that, although
the current elaborate planning and cost-effectiveness methodologies did not
exist in the old days, the then-extant planning procedures were applied. It
would probably not have been possible to induce municipalities to spend any
extra money in the absence of the arguments developed in the planning phase.
5. P.L. 92-500 does not admit conceptually of any difference in treatment
criteria as between major metropolitan areas and small municipalities. The
thrust of the NPDES program is to impose minimum effluent standards on all
dischargers irrespective of the relative sizes of the discharge and the
65
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APPENDIX V
APPENDIX
Mr. Henry Eschwege
August 30, 1976
receiving stream. I am not arguing for a return to a minimum requirement
of primary treatment, but if you wished to minimize treatment facility
costs, certainly there are places in the nation where primary treatment
plus adequate disinfection would suffice with no measurable impairment of
stream quality.
6. P.L. 92-500 does not admit conceptually of natural watercourses being
used as conveyors/treaters of wastewater. To use the jargon, wastewater
treatment is not an acceptable, designated, or beneficial use of such water-
courses. Indeed, the low flow augmentation suggested in your report was
roundly condemned by Federal policymakers some years ago, as equivalent to
the canard "The solution to pollution is dilution," and the Corps of
Engineers, for example, is no longer permitted to factor low flow augmenta-
tion for purposes of pollution control into its cost-benefit calculations
for proposed projects. If the Federal government now wishes to reverse its
position, it is free to do so. In Virginia, we do in fact take credit for
low flow augmentation from in-place dams in calculating stream assimilative
capacities preparatory to determining maximum permissible discharges for
treatment plants, but we do not propose low-flow augmentation projects in
order to minimize treatment cost.
We believe that an analysis of the forces at work in the construction grants
program, of which the foregoing is a beginning, should be included in your
report. We have no magic answers on how to overcome these forces in the
interest of optimal usage of the construction funds.
Sincerely yours,
A. H. Paessler
Deputy Executive Secretary
/ap
attachment
66
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APPENDIX V
APPENDIX V
Advanced Treatment
Facilities Planned or Under
Construction as of July 1976
Proi ect ^
Estimated Federal Funding^
3
Proiect Status
Alexandria
$ 73,961,220
b
Arlington
46,752,700
85 percent complete
Fairfax (lower
Potomac)
47,457,000
70 percent complete
Prince William
23,250,000
b
Upper Occoquan
56,470,680
80 percent complete
Aquia
3,592,100
b
Roanoke
23,646,550
99 percent complete
Culpeper
5,000,000
a
Total: 280,130,250
An additional $5.3 million is Federal funds for Virginia have been included in
the total for the Blue Plains Treatment Plant of the District of Columbia fact
sheet.
2
Includes cost to upgrade and/or expand the secondary treatment process.
3
The status of the advanced waste treatment portion of the plant.
Legend:
a- Facilities planning completed. Construction drawings and specifications
being prepared.
b- Construction drawings and specifications completed. Ready to begin
construction or under construction.
67
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APPENDIX VI
APPENDIX
September 21, 1976
^ill
1 " : 1.1- :: I
Mr. Henry Eschwege, Director
Community & Economic Development
Division
Room 6146
441 G Street, N.W.
Washinqton, D.C. 20548
Dear Mr. Eschwege:
I would like to take this opportunity to thank you for providing
the Washington State Department of Ecology the opportunity to review
and comment on your draft report titled, "Planning for Water Pollu-
tion Abatement: Mot Effective in Controllino Costs and Achieving
Water Quality Goals". We apologize for the delay in responding and
are hopeful that our comments can still be considered as you prepare
the final report.
In general, we feel that your report does raise valid points regarding
the Droblems associated with water pollution abatement planning in the
United States. Specifically, we feel that such problems as the need
for more comprehensive data and technical knowledge to determine
treatment levels necessary to safeguard or improve water quality
and the need for trained operators at existing and newly constructed
treatment facilities are well taken and should be resolved for more
effective water quality management. However, at the same time, we
do question some of the other points that you raise and some of the
conclusions that you have drawn. A brief discussion of these points
follows.
We feel it should be mentioned on page 2, paragraph 4, that the
initial emphasis in the 303(e) basin plans was on the management
of point sources of pollution. This emphasis changed from point
sources to nonpoint sources in the 208 areawide program. In addi-
tion, the information contained in the last paragraph of page 6
should be brought up to date, viz., that at the present time, all
of Washinqton State's 23 303(e) plans have been submitted to EPA
and approved.
We believe you have oversimplified the problem of why basin plans
do not contain total maximum daily load and waste load allocation
information. It is not merely a lack of data as you state, but more
the difficulty of performing the task. If the parameter in question
is bacteria or if the waste is from a nonpoint source, it would be
difficult if not impossible to perform these calculations. When the
'state of the art" advances sufficiently, these determinations will
begin showing up more and more in the basin plans.
68
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APPENDIX VI
APPENDIX VI
Mr. Henry Eschwege
September 21, 1976
Page Two
We recommend that you discuss in your report the fact that research
is needed and a technological transfer required before there will
be a widespread use of maximum daily load and waste load allocation
analytical methods.
As a minimum, we urge you to revise page 14, paragraph 3. After
the first sentence, it should read, "A state official informed us,
however, that none of the initial basin plans will include total
maximum daily loads or any waste load allocations since the param-
eter in question is generally bacteria or the waste is from a
nonpoint source. More research is needed before maximum daily
loads and waste load allocations can be determined on these types
of wastes."
A significant point which we believe is misleading is the implica-
tion that a monitoring program and water quality data are important
prerequisites to construction grant awards. Also, that the state
agencies have dropped the ball and now regulations are necessary
to force the establishment of adequate monitoring programs. The
truth is EPA management has never considered the receivinq water
quality a major consideration in prioritizing or assigning grants.
If they had, the monitoring program would have grown substantially
when PL 92-500 was first passed and new construction would have
occurred primarily in areas where there was a proven need. As a
result, data would now be available showing water quality improve-
ments as a result of new facilities coming on line.
The solution then is not, as the report implies, a big monitoring
program, (big does not always mean better) but rather that EPA
management recognize that grants should be awarded primarily where
water quality data clearly shows a need. The monitoring program
will then grow according to need with little prodding through new
regulations.
We hope that our brief comments will be helpful to you in your
revision process and we are looking forward to hearing from you
again. If you have any questions regarding this review letter,
olease feel free to contact Myron Saikewicz, Department of Ecologv,
Olympia, Washington 98504, telephone (206) 753-6863.
Sincerely,
Glen H. Fiedler, Supervisor
Water Quality Management Division
1HF:jv
69
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APPENDIX VII
APPENDIX VII
EBIE£IE^l_environmental_protection_agency_officials
55§?2NSIBLE_FOR_ACTIVITIES_DISCUSSED_IN_THIS_REPORT
Tenure of office
ADMINISTRATOR:
Russel E. Train
John R. Quarles, Jr. (acting)
Robert W. Fri (acting)
William D. Ruckelshaus
ASSISTANT ADMINISTRATOR FOR WATER
AND HAZARDOUS MATERIALS:
Dr. Andrew Breidenback
James L. Agee
Roger Strelow (acting) (note a)
Robert L. Sansom (note a)
DEPUTY ASSISTANT ADMINISTRATOR FOR
WATER PROGRAM OPERATIONS:
John R. Rhett
Louis De Camp (acting)
Eugene T. Jensen
From To
Sept. 1973 Present
Aug. 1973 Sept. 1973
Apr. 197 3 Aug. 197 3
Dec. 1970 Apr. 1973
Sept. 1975 Present
Apr. 1974 Sept. 1975
Feb. 197 4 Apr. 197 4
Apr. 1972 Feb. 1974
Mar. 1973 Present
Sept. 1972 Mar. 1973
June 1971 Sept. 1972
aBefore April 22, 1974, the title of this position was
Assistant Administrator for Air and Water Programs.
70
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