AMERICAN IRON AND STEEL INSTITUTE AMERICAN IRON AND STEEL INSTITUTE, Mr. BARRY M. MEYER, Chief Counsel, Committee on Public Works, Washington, D.C. DEAR MR. MEYER: My associates and I wish to express our appreciation for the time you, Mr. Billings, and others on the staff spent with us on Thursday afternoon to review some of our suggestions on pending water pollution control legislation. As promised, we are enclosing our comments on the draft document. Some of these reiterate our oral comments of Thursday, but in more detail, and others are additional comments on points we did not cover during our discussion. In addition, we are including two attachments, one an industry statement on waste water discharge monitoring and the other a proposal for a Water Quality and Effluent Standards Review Board. We make reference to these attachments in the enclosed draft. I trust these comments will be of assistance. Again, please accept my thanks on behalf of the industry for a most courteous reception. Sincerely, Enclosures. REYNOLD C. MACDONALD. WATER QUALITY AND EFFLUENT STANDARDS REVIEW BOARD (1) There shall be created within sixty days from the date of enactment of this Act a Water Quality and Effluent Standards Review Board, which shall be composed of a chairman and eight members who shall be appointed by and serve at the pleasure of the President. (2) All members of the Board shall by education, training and experience be qualified to assess and evaluate the adequacy of water criteria, water use, water quality standards, and implementation plans. (3) Three members of the Board shall be the Surgeon General of the United States, the Director of the Bureau of Standards, and the President of The National Academy of Sciences. One member shall be a representative of the industrial manufacturing community, one member shall be a representative of the agricultural community, and four members shall be selected regionally from the state governments of the Nation. (4) It shall be the duty and responsibility of the Board to promulgate (i) all national minimum water quality standards required by Section 302, (ii) all national uniform standards of performance for new sources required by Section 306, and (iii) all toxic and pretreatment effluent standards required by Section 307. The Board shall make appropriate and timely review of all such standards to determine their adequacy and the extent of their economic impact upon the total environment and the Nation's economy. (5) Within ten days following any decision by the Administrator relating to any national minimum water quality standard required by Section 302. Any national uniform standard of performance required for new sources required by Section 306, and any pretreatment effluent standard required by Section 307. he shall notify the chairman of the Board in writing of such decision and shall transmit to the Board such proposed standards and all documents, correspondence, evidence and testimony relating thereto. The chairman of the Board shall within ten days after receipt of the Administrator's decision fix a time and place for a hearing by the Board to determine the adequacy of such standards and the extent of their economic impact upon the total environment and the Nation's economy. Such hearing shall be held not more than sixty days from the receipt of the Administrator's decision and the chairman shall publish notice of such hearing in the Federal Register not less than thirty days prior thereto inviting all interested parties to appear and offer evidence and testimony pertaining to the proposed standards. Within sixty days following the conclusion of any such hearing, the Board shall promulgate appropriate standards as required by Section 302 (e) (4). (6) The Board shall, without regard to civil service laws or requirements, appoint and prescribe the duties of a secretary of the Board and such legal counsel as it deems necessary. Subject to the laws of the civil service, the Board shall appoint such other employees as it deems necessary to exercise and fulfill its powers and responsibilities. The compensation of all employees appointed by the Board shall be fixed in accordance with Chapter 51 and Subchapter III of Chapter 53 of Title 5. (7) The members of the Board who are not officers or employees of the United States, while attending conferences or meetings of the Board or while otherwise serving at the request of the Chairman, shall be entitled to receive compensation at a rate to be fixed by the Chairman, but not exceeding $100 per diem, including travel time, and while away from their homes or regular places of business they may be allowed travel expenses, including per diem in lieu of subsistence, as authorized by law (Sections 5703(b)-(d) and 5707 of Title 5) for persons in the Government service employed intermittently. (8) Five members of the Board shall constitute a quorum, and official actions of the Board shall be taken only on the affirmative vote of at least five members; but a special panel composed of one or more members upon order of the Board, shall conduct any hearing provided for in Section 302 (e) (5) of this Act and submit the transcript of such hearing to the entire Board for its action thereon. (9) The Board is authorized to make such rules as are necessary for the orderly transaction of its proceedings which shall include requirements for adequate notice of hearings to all parties. (10) Any member of the Board may sign and issue a subpoena for the attendance and testimony of witnesses and the production of relevant papers, books and documents and administer oaths. Witnesses summoned before the Board shall be paid the same fees and mileage that are paid witnesses in the courts of the United States. (11) In the case of a refusal to obey a subpoena served upon any person under this section, the Federal district court for any district in which such person is found or resides or transacts business upon application by the United States and after notice to such person and hearing, shall have jurisdiction to issue an order requiring such person to appear and give testimony before the Board or to appear and produce documents before the Board, or both; and any failure to obey such order of the court may be punished by such court as a contempt thereof. (12) Any final order issued by the Board under Section 302 (e) (5) shall be subject to judicial review by the United States Court of Appeals for the circuit where the promulgated standards are applicable. ATTACHMENT A WASTE WATER DISCHARGE MONITORING SAMPLING METHODS A stream can be tested for concentrations of physical and chemical constituents either by continuous monitoring instruments or by periodically collecting samples, which are then analyzed in the laboratory. 1. Continuous Monitors These instruments are available for only a relatively few parameters including temperature, electrolytic conductivity (an indicator of dissolved salts), dissolved oxygen, pH, turbidity, and oxidation-reduction potential. There are also instruments available for specific ions such as chloride, sulfate, nitrate, phosphate, calcium, magnesium, sodium, cyanide, and others, but these instruments are very expensive and have not been developed to a point of high reliability, particularly with respect to interferences by other elements. 2. Periodic Sampling This can be done by "grab" sampling or by composite sampling over a time period, such as 8 or 24 hours, which is considered to be representative of plant operations. Composite sampling is preferable to grab sampling. COSTS The analysis of water samples is costly due to the manpower required for timeconsuming wet chemistry. The more frequent the sampling, the more costly. For example, an estimate has been that to analyze a daily sample for all of the parameters specified for steel industry outfalls in the application form for the Corps of Engineers permits would cost the industry, which has an estimated 1500 outfalls, about $450,000 per day. Comments on monitoring In general, steel operations that generate waste discharge water are continuous and involve water flow rates and contaminant loads that remain relatively uniform as long as the production process is not changed significantly. A blast furnace, for example, is operated with a constant input of raw materials, so the output of contaminants in the waste gas scrubbing water should not vary widely. Continuous waste water surveillance should therefore not be necessary for continuous processes. Batch discharges of pollutants that might require continuous surveillance are uncommon in the iron and steel industry. With regard to the parameters that should be tested and reported, these will be different for every outfall even for one specific industry such as steel. In each individual case we should analyze only for those elements that are known to be of concern. A given outfall might be analyzed once, during normal plant operations, for all of the elements of concern to EPA (such as those in the SIC listing in the Corps of Engineers permit application instructions), and thereafter only analyze regularly those found to be of significance. It is senseless and extremely costly to an already low profit industry to analyze frequently for items that are not of significance to the ecology of a particular waterway. It is justifiable to analyze frequently, even daily, for something such as bacteria that can have an immediate health effect on the public, but steel industry contaminants do not generally have a potential health effect. A program of reporting analysis of a discharge stream should be intended to represent the discharge characteristics of the stream in terms of the most likely concentration over a long term. There will be peaks and valleys in the discharge concentrations but these will be smoothed out by dilution in the receiving waterway so there is no point to extremely frequent sampling or even instantaneous readings by a continuous monitoring instrument. Any high pollutant discharge incidents, such as by accidental spills or control equipment breakdowns, usually happen too fast to be prevented through any frequency or monitoring. When there is a breakdown of control equipment, this is detected and acted upon by operating personnel as soon as possible and dependence on frequent monitoring is not needed. We have made a statistical study of data from a steel industry outfall to determine the relationship of the results obtained with various frequencies of sampling. The information that was used for this study consisted of data obtained over a period of one year from the effluent of a waste water treatment facility at a steelmaking complex. Composite samples of the effluent were obtained throughout the day and analyzed for chemical contaminants every day. The data from this study are summarized in the attached tables for three of the chemicals that showed the most variation, iron, chromium, and alkalinity. The data in Table I summarizes the yearly average values of the concentrations of the three chemicals for daily, random weekly, and random monthly sampling frequencies. The data show that the sampling frequency makes very little differences as far as a yearly average is concerned, so random monthly samples are just as good as daily samples for this purpose. Of even greater importance, however, is the summary of statistical analysis of the data, which is shown in Table II. For each of the three sampling frequencies (daily, random weekly, and random monthly), effluent concentration values were determined for the "median," or the point below which 50% of the values lie, and concentration values were also determined for the point below which 90% of the values lie. There is close agreement of these values for each of the three sampling frequencies. For example, for iron the median concentration for the entire year, based on daily testing, was 0.6 parts per million. If a sample had been obtained on random days once per week instead of every day, the median concentration would have been 0.5 parts per million. Further, if a sample had been obtained randomly once per month, the median concentration would have been 1 part per million, which is considered close agreement for these low concentration levels. All of the chemicals tested showed a similar or even closer agreement of concentration values. In addition to analyzing the averages and medians of the data, we also estimated the variability of the yearly data. For example, for iron, the standard deviation, or spread in values of the data (1.3 parts per million) was used to derive the curve of the attached Figure 1. This curve shows a mathematically derived relationship between the number of samples obtained per year and the precision of the iron concentration as calculated from the number of samples. This curve, which would be typical for other chemicals as well as iron, shows that very little additional information can be gained from samples obtained at a frequency greater than 26 per year, or bi-weekly. CONCLUSION Based on this statistical study of a steel industry discharge stream, it is concluded that sampling and analysis conducted once per week or even once per 1 month would yield data on the characteristics of the stream that is nearly as representative as daily or "continuous monitoring" data. In consideration of all $ factors, including stream pollution control, the general type of discharge from I steel industry operations, and the cost of monitoring, we strongly feel that a = practical program of implementation of stream quality criteria should not and need not include a requirement of continuous or very frequent monitoring. We propose, from a practical standpoint, that if reporting of effluent concentrations is required, then this should be done by means of 8-hour composite samples obtained no more often than bi-weekly. The parameters to be analyzed and reported should only be those that are known to be of significance in the particular processes that contribute to the discharge stream. Before any Federal legislation is adopted concerning waste water monitoring, a cooperative effort between EPA and the industry involved should be held to set up mutually agreeable ground rules on the frequency and type of sampling. TABLE 1.-YEARLY AVERAGE VALUES OF DATA FOR VARIOUS SAMPLING FREQUENCIES Sampling frequency Jaily... Random weekly. TABLE II.-SUMMARY OF STATISTICAL ANALYSIS OF EFFLUENT DATA 59-068 0-71-pt. 4 |