JACK SCHAEFFER1

A REVIEW OF EPA'S ANALYSIS OF THE MUSKEGON SYSTEM

1. LAND REQUIREMENTS

'A agrees that the Muskegon System will work and estimates that, on a nal basis, it would require nearly eight million acres of land. This amounts is than 1% of the acreage presently classified as farm land.

rthermore, it should be noted that

(a) Only 60% of the land utilized in the Muskegon System is used for wastewater disposal.

(b) of the remaining 40%, half is available for the disposal of solid wastes and sludge and the remaining 20% is used as storage basins which could be used for cooling ponds for nuclear power plants.

ice EPA's calculations are based upon a national program of 70 billion ns per day (BGD), a straight line projection of Muskegon land requires indicates that 16 million acres would be required in lieu of the 7.8 million ated by EPA. However, conditions (a) and (b) above, along with the that most of the nation has a longer irrigation season than Muskegon by by reducing the number of acreage needed, suggest that the amount of required for the Muskegon System would be between eight to ten million , which, as was true of EPA's 7.7 million acre estimate, is still less than of total farm land.

2. THE COST OF A NATIONAL PROGRAM

A's document indicates that if the Muskegon System were implemented nally, it would cost some $25 billion more than advanced waste treatment esses which would achieve comparable results. This difference comes as a t of EPA's using, on page 3 of their document, an estimate of 40¢ per gallon city for advanced waste treatment systems. Also, implicit in their analysis igure of 93¢ per gallon of capacity for the Muskegon System.

ither of these figures is supported by the very recent testimony of Mr. am Cawley of the Environmental Protection Agency before the State of igan and the Circuit Court for the County of Muskegon on May 6, 1971. chment A to this document is a copy of a portion of Mr. Cawley's statement. ould be noted that on page 668. Mr. Cawley was asked whether he believed the costs provided in Exhibit 13, attached hereto as Attachment B and red by Bauer Engineering, were accurate. Mr. Cawley's reply was that Bauer had underestimated the cost of advanced waste treatment systems. sed upon the data prepared by Dr. Bauer and considered to be underated by Mr. Cawley, we note that the cost of an advanced waste treatment m proposed along the lines of the one set forth in EPA's document, would least 81¢ per gallon of capacity in lieu of the 40¢ per gallon used in EPA's lation.

sed upon the information and views of Bauer and Cawley, the costs for a nal program are as follows:

The 40¢ per gallon figure for the conventional advanced waste appears to be exceptionally low in light of—

(a) Mr. Crawley's opinion that 81¢ was low.

(b) 68¢ per gallon paid (see Attachment C) for only a primary treatment plant-i.e., excluding secondary and advanced treatment-by EPA and the State of Pennsylvania.

(c) A statement by Mr. Russell Culp, Manager of the South Lake Tahoe Advanced Waste Treatment Plant quoted in the June 1971 issue of Readers Digest (Attachment D), in which he states: "That tertiary treatment costs about double the price of the usual primary and secondary treatment systems."

Based upon this information, along with that in (b) above, the cost of advanced waste treatment could conservatively be in excess of $1.00 per gallon of capacity.

Furthermore, it should be noted that the cost of a Muskegon-type system includes storage lagoons and facilities needed to treat storm water and thus the incremental cost of $25 billion for the treatment of storm water projected by EPA, while applicable to advanced waste treatment systems, is overestimated for land disposal systems.

3. OPERATING COSTS

EPA's document, while adressing first costs, did not address operating costs. When one considers average annual costs (debt retirement plus O&M costs) a savings of from $2.3 billion a year could be realized if aerated treatment-spray irrigation technology was applied nationally. Details are presented in the following table.

With respect to power requirements, the detailed calculations show a power savings of $500 million per year for the spray irrigation system. In addition to its greater power cost, the conventional advanced waste treatment systems requires $43 per MGD of influent. For a 70 BGD flow this would require 32% of the total market value of natural gas used in 1969.

4. CONCLUSION

In conclusion, if the nation were to embark upon a dramatic shift in technology from conventional-advanced waste treatment water disposal to aerated treatment-spray irrigation land disposal the following impacts would result:

(1) Less than 1% of present farm land is needed.

(2) The capital costs of the two systems are nearly equal.

(3) The average annual cost, including debt retirement and operation and maintenance, for advanced waste treatment is nearly twice as great as that for spray irrigation.

(4) Power requirements would be reduced by $.5 billion per year.

(5) $1 billion per year of natural gas required for advanced treatment would be saved.

(6) Sludge would be incidentally applied to the land as a soil conditioner and fertilizer.

(7) All solid wastes produced in the United States could be accommodated at the waste management sites for 150 years.

(8) Nuclear power plants could use the storage basins for cooling ponds-the Muskegon System could accommodate a 850 to 1,000 megawatt installation.

(9) A revenue of from $129 million to $1,120 million would be realized from the productive use of the nutrients and irrigation value of the wastewater. (10) 80% of wastewater is reclaimed for beneficial reuse.

(11) Urban sites on which treatment works are located will be free for urban redevelopment.

NATURAL RESOURCES DEFENSE COUNCIL

OMMENTS ON PROPOSED AMENDMENTS TO FEDERAL WATER POLLUTION CONTROL Аст

The following comments on the proposed amendments to the Federal Water llution Control Act are submitted to the Air and Water Pollution Subcomttee of the Senate Public Works Committee pursuant to invitation. The Natural sources Defense Council (NRDC) testified before the subcommittee when it d public hearings on the proposed water pollution legislation. NRDC also tified before the Subcommittee on the Environment of the Senate Commerce mmittee when that subcommittee was investigating the Refuse Act Permit Ogram.

Our comments are listed below in order of the appearance of the relevant ovisions in the proposed amendments, not in order of their importance. ggestions thought to be extremely important are marked by an asterisk.

1.

The scope of section 104(a) (5) on page 2, line 32, should be extended to include undwaters and the tributaries of navigable waters. If our suggestion that the inition of interstate and intrastate waters be enlarged to include groundters is accepted, the phrase "intrastate and interstate waters" could be subcuted for the present phrase, "navigable waters of the United States."

2.

Section 104 (o) should be amended to add the following phrase after the word " on page 4, line 5: "monitor the extent of pollution due to agricultural activi⇒, including irrigation practices, and to."

3.

Section 106(a)(2) (E) should be amended by adding the following phrase er the word "plans" on page 6, line 24: "and provides evidence of the implentation of such planning."

4.

Section 301 (f) (1) (A) should be amended by including the following phrase er the word "including" on page 16, line 33: “irrigation practices and."

5.*

Section 302(d) (2) should be amended to read as follows (new material undered):

(2) The national minimum water quality standard for surface waters shall be that level of water quality identified by the criteria published pursuant to section 301 which shall provide for the protection of indigenous shellfish, fish and wildlife and allow the full range of recreational activities in and on the water. For ground waters the national minimum water quality standard shall be such as not to allow ground water quality to be degraded below the levels necessary for public water supply and agricultural uses.”

6.*

Section 303(a)(2) should be amended to ensure that implementation plans mitted to the Administrator under section 302 as well as those submitted ler section 303 (a) (1) meet the requirements set out in 303(a)(2) (A)−(J). s might be accomplished by simply substituting the word "implementation" the word "such" in line 22, page 19.

7.*

The maximum time for attainment of minimum water quality standards should be three years from the date of approval of implementation plans. (See page 19, line 27; page 20, line 45; page 21, line 9; page 21, line 13; page 21, line 22.)

8.*

Section 303 (a)(2) (B) should be amended to ensure that all states as part of their implementation plans impose effluent limitations on the discharge of pollutants susceptible to secondary treatment. To achieve this, the following phrase should be added after the word "Act" on page 19, line 31: "and including effluent limitations for pollutants susceptible to secondary treatment."

9.*

Section 303 (a) (2) (F) should be amended by substituting the phrase "fully disclosing the" for the phrase "on the" in line 2, page 20, and by adding the phrase "including peak as well as average discharges" after the word "effluents" in line 3, page 20.

10.

Section 303 (a) (2) (H) should be amended to add the phrase "nor permit" after the word "for" in line 14, page 20.

11.

Section 303 (d) should be amended to read: "Copies of any implementation plan approved or promulgated under this section or section 305 shall be given to members of the public upon request for a charge not to exceed $10 per copy and shall be available to the public for inspection in an appropriate place in each state."

12.*

Section 303 (e) (1) should be amended by adding the phrase "a cumulative total of not more than one year" after the first "for" in line 1, page 21, and by striking the phrase "not more than years" in line 1, page 21. 13.

Section 306(b)(1)(A) should be amended to include at line 13, page 25, the following additional stationary sources: "electroplating, feed lots, and nuclear fuels processing."

14.*

Section 306 (b)(1)(B) should be amended to add the following sentence after the word "appropriate" on line 21, page 25: "In no case shall these initial standards of performance for stationary sources be less stringent than the best actual performance being achieved in June, 1971, by any existing facility involved in the same or similar activity."

15.*

Section 307(a) should be amended to add the following phrase after the word "discharge" on page 26, line 2: "directly to interstate or intrastate waters, the contiguous zone or the ocean or through public waste treatment systems discharging into such waters." A similar provision should be added to section 307 (c), page 26.

16.

Section 307(a) should be amended to add the phrase, “whichever has the lesser concentration," after the word "waters" in line 5, page 26.

17.

Section 307(a) should be amended to add the phrase, "any of the following or potentially toxic compounds thereof," after the word "of" in line 6, page 20.

18.

'he list of toxic substances in section 307(a) should be expanded to include following: "Persistent organochloride and organophosphorus pesicides; perent herbicides; cyanides; plutonium; strontium 90."

19.*

ection 307 (b) should be amended to add the following sentence after the d "section" in line 21, page 26: "This list shall include, but shall not be ted to, all known toxic substances found in wastewater which are persistent atural waters or the ecological food chain and which have median tolerance ts for algae, marine invertebrates and/or fish below 10 parts per million centration."

20.*

ection 307 (c) (1) should be amended by adding the following sentence after word "section" in line 32, page 26: "The initial list shall include insofar as sible all mjor pollutants which are not susceptible to conventional secondary tment and which are not prohibited pursuant to subsections (a) or (b) his section."

21.*

section 307 (c) (2), the sentence beginning "Effluent" in line 37, page 26, ld read as follows: "Effluent standards under this subsection shall specify eadline for compliance not to exceed three years, violation of which is ibited, and shall be established to ensure the greatest degree of effluent action which the Administrator determines to be achievable through applion of the latest available control technology, processes, operating methods ther alternatives, including, where practicable, a standard permitting no harge of pollutants. In no case shall these initial standards be less stringent the actual performance being achieved in June, 1971, by the best 10% xisting facilities in the same category. The Administrator shall, from time ime, as technology changes revise such standards following the procedure blished by this subsection for promulgation of such standards.

22.*

ection 307 (c) (3) should be amended to add the following sentence to the of the subsection: "He shall also designate both peak and average disge rates permitted."

23.*

O section 307 the following subsection (e) should be added: "It shall be ibited for any person to discharge any novel organic compound not geny part of industrial production processes and effluents as of June, 1971, out first presenting to the Administrator a complete and objective analysis he toxicity of such compound and receiving approval, conditional or other, from the Administrator."

24.

ction 308 (a) should be amended by adding the phrase "and sampling" after word "monitoring" in line 22, page 27; by adding the phrase "and monitor" the word "sample" in line 23, page 27; by adding the phrase, "in order rovide assurance that effluent and receiving water standards and limitations not being violated over shore or long periods of time," after the word "pree" in line 25, page 27; by adding the phrase "monitor and" before the 1 "sample" in line 36, page 27; and by adding the phrase "and monitor" : word "sample" in line 37, page 27.

25.*

ction 402(a) (1) should be amended to include the phrase, "or into any tribuof a navigable water of the United States," after the word "oceans" in 30, page 37.

section 402 (a) (1), the first proviso (lines 37-42, page 37) should be deleted.