NTA detergents as presently available perform poorly on wash-and-wear, permanent-press type fabrics which often compose over half of the modern laundry mix. They also perform poorly in hard water, and for heavily soiled laundry. Since performance is considerably lowered with such products, the consumer will be tempted to use mort of the substitute compounds in hope of achieving the excellent results formerly obtained from phosphate compounds. The effects of pouring billions of pounds of table salt, washing soda, or similar chemicals into our lakes and streams may well be a much greater threat to our environment than continued use of phosphates. Trading the better known effects of a chemical that could be easily removed from sewage, such as phosphate, for the unknown effects of hard-to-remove chemicals may be a bad bargain, ecologilogically and economically. The problem to be solved then is how can we provide consumers with effective, low-cost laundry compounds which either we can be certain do not need to be removed from waste water, or can be economically removed at sewage treatment plants. Several solutions present themselves. First, based upon present environmental knowledge, the only way we can be certain that laundry products would not further contribute to water pollution or fertilization would be to stop using all detergents, including soaps, water softeners, "non-phosphate" products, bleaches everything. If we were to stop pouring any chemical mixture down our drains and were to use only clear water for washing and cleaning, we would obviously make an improvement. If. however, we used only clear water for washing and cleaning, America would still not have clean lakes and streams. Soaps and detergents are estimated to contribute less than 17% of the total phosphate which enters our waters. A large amount is also contributed by crop fertilizer, animal manure, dirt, bacteria and other nutrient run off from farmlands, feed lots, and gardens. Also, industrial and human wastes which are not properly removed by sewage treatment because most sewage plants are inadequate, contribute not only phosphate but many other undesirable chemicals and bacteria. And of course washing clothes in clear water would still result in millions of pounds of dirt and bacteria from the clothes going into the drain and ultimately to streams and likes, if not removed at a treatment plant. Clear water would of course only do a very poor job of washing, and such a solution would be neither workable nor acceptable. Secondly, we can re-formulate laundry products, eliminating the phosphates. This method is being strongly promoted by public pressure today. However, it is highly questionable whether reformulation will even partially solve problems of nutrient-rich waters. As long as any chemicals continue to enter streams and lakes in such great quantity, there is a strong possibility that the new phosphate-substitute formulas may be even more ecologically difficult to control than the old phosphate products, which at least we know we can remove at sewage plants. We must also consider that such new formulas create many new and complex problems such as increased corrosion of washing machines, and inefficient performance on synthetic, and wash-and-wear fabrics. We will also have to contend with lower performance in hard water (even when the new formulas are used in considerably greater quantities than present phosphate detergents), higher consumer costs, plus limited use in automatic machines, etc. In view of these facts it then becomes apparent that the value of substitute chemicals is serisously limited as a real solution to “the phosphate problem" (or more correctly, “the total eutrophication problem"). But we already have available to us a for more comprehensive and effective and economical solution to the problem of detergent chemicals entering streams and lakes. Although we know very little about lake eutrophication and the effect of complex mixtures of various chemicals drained into our waterways, we do know a great deal, right now, about how to remove various chemicals in water solution from sewage water. The technology for removing chemicals from water is well developed and very advanced, although the use of this technology with regard to sewage treatment unfortunately has been limited by the taxpayers' indifference and reluctance to pay for proper sewage treatment. Therefore, a logical solution, both reasonable and workable, is to have a Federal agency specify which chemicals may be used not only in detergents and soaps but in any product that may find its way into sewage drains, and allow the use of only those chemicals that can be easily removed from waste water. It should be also mandatory for municipal and industrial sewage treatment plants to install equipment capable of removing these chemicals. In this way the Federal and municipal governments together with the industrial and public sector will be coordinated on a total plan to restore the quality of our waters. Not all chemicals can be removed easily and economically or with the same type of equipment. But processes are available today that are reliable and economical for removing a number of commonly used detergent chemicals from sewage water at municipal sewage plants. For instance, phosphates can be removed by an inexpensive process with an operational cost of less than $2. per person per year at a municipal plant, (even in primary stage plants) and the process will not only remove detergent phosphates but sewage phosphates as well, for about the same cost. Since at least half of the phosphate entering streams and lakes comes from sewage, it would make eminently more sense to remove phosphate from all sources at the city sewage plant than to eliminate only part of it from detergents at the point of manufacture. And since detergent re-formulation with phosphate substitutes might introduce chemicals much more difficult to remove than phosphate, and potentially more harmful to the environment, it would make good sense to go no further down the reformulation path until we are sure of all the results. Laundry detergent manufacturers do not use phosphates because they have no regard for the environment. They have been accused of resisting change; of being able to produce products without phosphate, but unwilling to change because it would hurt their profits, and of being environmentally unconcerned. Such accusations are not based on fact. If the expense of phosphate substitutes necessitated increased costs to the manufacturer, the cost would be passed on to the consumer as is true in any manufactured product. Profit structure would not be affected. Detergent manufacturers buy phosphates from chemical suppliers as they do other chemicals, and they have no vested interest in promoting phosphates. Laundry detergent manufacturers, however, know a great deal more about the chemistry of soaps and detergents and other cleaning products than do most of their critics, no matter how sincerely motivated such critics may be. They are aware that a hasty change in direction at this time may literally, and ecologically, be "jumping from the frying pan into the fire." Therefore, although the detergent industry can produce phosphate substitute products immediately if public pressure demands (although such products are markedly inferior in performance), conscientious manufacturers are very aware that until a great deal more is known about the entire situation, it may be far wiser not to take any premature action or make any radical changes which could expose our environment to the possibility of what are presently unknown hazards. Phosphate is well known and understood and is economically manageable. New directionsnew chemicals-new chemical mixtures-are unknowns. Another possible danger of great magnitude could be legislation at local levels which has not been coordinated with a Federal master plan structured upon knowledge and assessment of all of the options. Some state and local governments have been bowing to public pressure and threatening to pass hasty laws requiring detergents to be formulated without phosphates or with lower phosphate content. Such local legislation, if it should proliferate, will only add to confusion. It may bring greater ecological damage as well as result in higher costs to the consumer. A far more sensible approach is to set a reasonable top limit on phosphate usage in products at the Federal level now. The 20% P2Os (8.7% P) level used in Canada is practical. This would buy some time for scientists to engage in relevant research. A Federal law, as previously mentioned, should require certification of all chemicals to be used in detergents to the effect that they are considered removable at sewage plants, or considered not harmful to streams or lakes even if not removed. Following these guidelines, the manufacturers would be able to formulate from this certified list of chemicals the different products needed for various purposes-heavy duty laundry-hard water laundry-soft water laundry-bleaching-stain removal-with full consideration for environmental concerns. Such a scientific and logical approach, properly coordinated at the Federal level only, would provide the greatest possibility of bringing all of us to the ultimate goal of clean water. The emotional tactics of hurling invective, printing outdated, confusing and inaccurate phosphate percentage lists, and trying to reformulate detergents in local legislative halls are not effective methods. In fact it is quite possible that a certified list of government approved chemicals, evaluated under conditions of cool scientific testing instead of hot emotional hearsay would list controllable phosphate as one of the safest of all the chemicals we could use. With due consideration for alternative solutions, it appears at this time that use of such certified, approved chemicals, coupled with adequate sewage treatment plants, would eliminate the threat of salted streams or soda lakes or algae blooms and bring us instead to our goal-the re-establishment of clean, pure water supplies to serve the needs of North America! RESEARCH PUBLICATIONS Chemical and Engineering News, 1155 Sixteenth St., N.W., Washington, D.C. 20036. Chemical Engineering, 330 W. 42nd St., New York, N.Y. 10036. Chemical Processing, 111 E. Delaware Pl., Chicago, Ill. 60611. Detergent Age, 41 E. 42nd St., New York, N.Y. 10017. Modern Packaging, 1301 Ave. of the Americas, New York, New York 10019 Soap & Chem. Specialties, 254 W. 31st St., New York, N.Y. 10001. Aerosol News, P.O. Box 31, Caldwell, N.J. 07006. Analytical Chemistry, 1155 16th Street N.W., Washington, D.C. 20036 STATEMENT OF HON. JAMES M. BEGGS, UNDER SECRETARY OF THE DEPARTMENT OF TRANSPORTATION [BEFORE THE SENATE COMMITTEE ON COMMERCE, SUBCOMMITTEE ON OCEANS AND ATMOSPHERE, REGARDING S. 1238 AND RELATED BILLS, WEDNESDAY, APRIL 21, 1971] Mr. chairman and members of the committee, I appreciate the opportunity to testify today on S. 1238 and related bills, all of which are directed at the serious problem of the contamination of our oceans. I would like to introduce Rear Admiral Robert E. Hammond, Chief of the Office of Operations of the Coast Guard, who is on my right. Secretary Volpe has said often that at the Department of Transportation environmental quality is a goal, not a constraint. I am pleased to be here today to explore with the Subcommittee how the Department, through the Coast Guard, can play a positive and effective role in regulating ocean dumping. I graduated from the Naval Academy in 1947. At that time, no one questioned the capacity of the oceans to absorb our waste. We now realize, however, the peril of ocean dumping on a major scale. We now understand that we cannot continue to poison our oceans merely because they seem large enough to dilute the poison. Administrator Ruckelhaus of the Environmental Protection Agency and Chairman Train of the Council on Environmental Quality will testify during this hearing. Both of these gentlemen will address themselves to the environmental concerns involved. I need not reiterate their statement of the problem or their commitment to solving it. I would like, however, to assure this Subcommittee that my Department, through the Coast Guard, stands ready to cooperate immediately with the Environmental Protection Agency to carry out those portions of the program which they choose to delegate to us. I can also assure the Subcommittee that the Coast Guard can today fulfill its responsibilities for enforcement under section 8 (c) of S. 1238. In this regard, let me review for you the capabilities of the Coast Guard to carry out this proposed legislation. I have attached to my statement, as Appendix A, a more thorough analysis of what is available in the way of support personnel, materials, and technical expertise to fulfill this mission. The Coast Guard is already active in the area of ocean dumping as an adjunct to its Marine Environmental Protection Program. On a day-to-day basis. they receive information on planned dumping and record the location, identity of materials, and persons involved in all observed ocean dumping activities. This information is furnished to interested agencies such as the Council on Environmental Quality and the Environmental Protection Agency. They have also monitored many dumping operations upon request. Based on our experience, we believe effective regulation of ocean waste disposal requires three elements: a permit issuing authority, an available surveillance and enforcement capability, and effective monitoring activity. Clearly. the agency vested with the responsibility for enforcement should have some involvement at each stage of the regulation scheme, particularly the issuance of permits. S. 1238 makes provision for this in section 8(b), and we have already begun to discuss with the Environmental Protection Agency how we can be most useful to them and to the program. It is self-evident that effective surveillance and enforcement calls for knowledge of any permits issued and the terms of those permits. The Coast Guard engages in a variety of mission areas which would support the role of the Environmental Protection Agency in the regulation of ocean dumping. They have long been established as the Federal maritime law enforcement agency. Their officers and men are trained and experienced in matters of law enforcement just as they are trained and experienced in seamanship. The Coast Guard provides a substantial Federal maritime force for enforcement of the maritime aspects of the Refuse Act and the various other oil pollution laws. They also have a long history of involvement with the marine community in such areas as the handling of dangerous cargo and the issuance of permits for various regulated marine activities. In addition, the Coast Guard has the facilities to carry out these functions, and with little augmentation, can utilize these same facilities to participate actively in a program of ocean dumping regulation. Appendix A outlines in detail the Coast Guard units available for ocean dumping regulatory activity. As you will note, they cover all waters over which the United States has jurisdiction. The Coast Guard can easily aid the Environmental Protection Agency in the issuance of permits, and I have listed in Appendix A the locations of the alreadyestablished Coast Guard Captains of the Port and Marine Inspection Offices. I wish to emphasize that these offices are well known to all members of the marine industry, both national and foreign, and are presently involved in many tasks closely related to ocean waste disposal regulation. Captains of the Port are responsible for the inspection of port structures housing hazardous materials and for the supervision of explosives loading. Marine Inspectors are responsible for the inspection and certification of merchant vessels. These two types of facilities represent an already available administrative force. We believe these offices would be able to absorb a permit issuing function with a modest personnel increase. The FY 1972 budget already contains 26 additional staff members for the Captain of the Port Offices to help handle the increased work loads caused by expanding pollution control and port security duties. Based on a projection of three to six thousand permits a year, we would estimate that an additional $285,000 for additional personnel would be needed for this function during the first year. In addition, the Coast Guard's experience and the data they have collected, in the regulation of hazardous material transport, would be readily available to assist the Environmental Protection Agency in making the necessary determinations as to whether or not particular substance should be disposed of at sea. The Coast Guard also collects oceanographic data in support of other missions which, while presently limited in scope, could be utilized in baseline determination. Captains of the Port have small boats, ranging from 31 to 44 feet, at their disposal for a variety of tasks including the supervision of loading of material to be dumped at sea and other calm water surveillance and monitoring. Eighty-two and 95 foot patrol boats are also available for the same tasks. Medium and high endurance cutters can be utilized too, and these vessels are capable of long-range operations of extended duration. Finally. Coast Guard helicopters and fixed-wing aircraft can respond in less than one hour for surveillance and other duties. We are currently assuming that surveillance will be required in each instance when toxic or radioactive dumping takes place. In other cases, spot checks will be made in approximately 5 to 10 percent of the dumpings. To specifically carry out the surveillance function, we would initially utilize the six HU 16 aircraft which the FY 1972 budget reactivates for the Marine Environmental Protection program. The Coast Guard estimates that this places an additional burden of 600 aircraft hours or $315,000 on its resources. The availability of surface vessels is somewhat more critical. The Coast Guard has estimated that surface surveillance activities will require 350 ship days at a cost of one million dollars. If the Committee would like, I would be pleased to submit for the record how we arrived at this figure. We would point out that our present fleet is fast approaching its limit of use. even based on multi-purpose missions. Exact requirements cannot be determined, but we believe additions to the fleet in the smaller cutter range will be necessary in the future in order to fully perform our surveillance function. Further personnel expenses to maintain liaison with the Environmental Protection Agency will be necessary. If requested, we could also aid the Environmental Protection Agency in oceanographic monitoring of dump sites and adjacent waters. The Coast Guard has, for several years, been a major participant in the United States oceanography program. This participation takes the form of daily observations from lightships and offshore light stations as well as from a variety of ships. Seasonal oceanographic cruises are also carried out in specially equipped vessels. Craft are therefore already available for this function and the only additional cost would be for specialized equipment. In this regard, the Coast Guard Office of Research and Development and the Office of Engineering are developing monitoring technology and instrumentation to support our present operational programs. Of particular importance will be the development of sensors specifically for pollution control |