Document BRB40GVD9NM3pKX94gR4MZq34

FOR POLLUTION CONTROL FEDERAL, STATE AND MUNICIPAL j/jp Cud) by Arnold R. Smith Nebolsine, Toth, McPhee Associates Norwood, New Jersey POLLUTION CONTROL SYMPOSIUM AMERICAN SOCIETY OF LUBRICATION ENGINEERS ALLENTOWN, PENNSYLVANIA April 13, 1972 00b^38^ TOWOLDMONOQ55888 LAWS AND REGULATIONS FEDERAL, STATE AND MUNICIPAL BY Arnold R. Smith Nebolsine, Toth, McPhee, Associates Norwood, New Jersey Laws relating to water pollution control are ephemeral at best, at least at the present time. You are probably aware that the Federal Government is considering proposals for "zero pollut ion", whatever that means, and that other bodies keep changing the rules. While I am sure we'd all like to see water pollution limited, it is rather difficult to chart a course in the shifting shoals of legislation. MUNICIPAL REGULATIONS Sewers To start at the lowest level of responsibility, most municipal governments have ordinances regulating discharges into the municipal sewer system. If there is no sewer system and wastewaters are dis charged into a water course or body of water, then the State usually has jurisdiction, except of course if the discharge causes such a nuisance that residents raise a howl, then the issue may remain local. In any event, municipal ordinances follow pretty much a stan dard format. The regulations are directed to two items: 1. Protection of the sewer system from material that will ^ affect carrying capacity and the integrity of the I structures, and will pose hazardous conditions to sewer workers. 1 0065384 2. Elimination of substances that will affect the sewage treatment processes. THE SEWER SYSTEM The specific prohibitions with relation to the sewage collec tion system usually include the following: 1. pH range between 6.5 and 9.5. 2. No explosive or flammable substances. 3. Temperature maximum of 150 degrees F. 4. Limited quantities of grease and oil. 5. Gases or vapors in toxic concentrations. 6. Limited sulfides 7. Rubbish, ashes, cinders, etc. 8. General clause prohibiting anything that is harmful. This is by no means a complete listing but it is representa tive of the material found in most municipal ordinances. The more complete regulations will permit BOD, suspended solids, and chlorine demand values in excess of those normally found in dom estic sewage, but the discharger will usually have to pay a surcharge. This compensates the municipality for the increased cost of operation because of the stronger wastes. Excess suspended solids result in increased sludge production and consequent higher costs for sludge handling and disposal; BOD increases the expense of biological pro cesses while chlorine demand, of course, increases the cost of chlorine. There are several different methods of charging for these extra costs, some with the intent of "socking it" to industry and others on an equitable basis. 0065385 2 TOWOLDMONOQ55890 Municipal ordinances contain some bombshells for the unwary. For example, "no explosive or inflammable material may be discharged into the sewers" is a statement open to many interpretations. One of our clients, a research laboratory, used heptane, MEK and acetone to wash laboratory glassware. All may be considered flammable and ex plosive under the proper conditions. The laboratory collected the solvents and washings in barrels for ultimate disposal and discharged only rinse water to the sewers. Very small quantities of solvent were diluted with large quantities of water in the washing process and the danger of explosions seemed infinitisimal. They were denied a discharge permit. The Town Council was advised that every bar in town was technically in violation of the ordinance because unfinished alcoholic beverages were discharged into the sewer system. The an swer was, "Did you ever drink in this Town? We don't throw anything away". But the denial stood and the company could do little about it. The Treatment Plant Most municipal secondary treatment plants use a biological treatment process in which bacteria utilize the waste material for cell growth and for maintenance. In essence, they convert colloidal and soluble material to insoluble cell material which can be separated from the carrying water. Unfortunately, the bacteria are rather sensitive to their environment and diet,and they must be treated carefully or they perish - and there goes the treatment process. The sections of the ordinance directed toward preserving the sewage treatment process usually include the following; TOWOLDMONOQ55891 1. Limited Chlorine demand. 2. Limited BOD (250-350 mg/1). 3. Limited phenols, r--' '--------------------------------- ' 4. Limited heavy metals. 5. Elimination of materials interfering with the biological process. 6. Limited suspended solids. Operational problems are more severe in the smaller plants where an industrial waste discharge may be a significant part of the total flow, especially so where the industrial discharges vary widely during the day, or are seasonal. A food packing waste may run only several months of the year and while the wastewater is biodegradable, high concentrations of carbohydrates may not be completely compatible with normal domestic sewage. Municipalities differ in their attitude toward industrial wastes and depending on the "human factors" involved, some degree of negotiation may be possible on the terms of what can be dis charged . STATE REGULATIONS The Department of Environmental Resources handles permits for industrial waste discharges in the Commonwealth of Pennsylvania. In general, the regulations of the Department require treat ment determined by present and future'water use. Water quality standards have been set for interstate streams and are progress ively being established for intrastate streams. The degree of treatment, except for some wastes for which definite standards 0065387 4` TOWOLDMONOQ55892 have been set, are determined by the critical low stream flow and the uses for the water. There are several standards for all waste streams, however, viz. : 1. There shall be no discharge of wastes which are acid. 2. Wastes shall have a pH of not less than 6.0 nor greater than 9.0. (Wastes discharged to acid streams may have a pH greater than 9.0.) 3. Wastes shall not contain more than 7.0 mg/1 of dissolved iron, 4. When surface waters are used in an industrial plant, the quality of the effluent need not exceed the quality of the raw water supply provided that the source of supply would normally drain to the point of effluent discharge. 5. Wastewaters shall show no more than a slight iridescence and shall at no time contain more than 30 mg/1 of oil or lesser amount as the Department may specify. 6. All phenolic bodies (phenols, tars, creosols, etc.) shall be completely eliminated from wastewaters discharged to the Ohio River or its tributaries. 7. Cyanides or cyanogen compounds shall not be discharged into any waters of the Commonwealth. Depending on the receiving body of water, the State may require primary, intermediate or secondary treatment, in which percentage removals of BOD and suspended solids are specified. This could mean different things to different plants in the same industry because of differences in operation, housekeeping, etc. 5 OOfe^88 TOWOLDMONOQ55893 So the State has started to set up standards for industries to establish "normal" raw waste characteristics. The milk processing; pulp, paper and paperboard, and oil well industries are covered to date. What the State did'was to establish the waste load from a normal, well operated plant in each industry. All plants in the same industry will be assumed to have these wastewater flows and characteristics per unit of production and the percentage reduc tions in the wastes will apply to these norms, regardless of the plants actual wastewater characteristics. The regulations apply ing to each industry are rather detailed. Presumably other in dustries will be so categorized in the future. The State also has thermal pollution standards and regula tions for underground disposal. All the regulations can be expected to change as Federal Law requires. DELAWARE RIVER BASIN COMMISSION As part of the interstate compact setting up the Delaware River Basin Commission (DRBC), this body has jurisdiction over wastewaters discharged into the River and its tributaries. After several alternate plans were prepared and many hear ings were held, one plan for reducing pollution of the River was developed. The different plans represented varying degrees of oxy gen levels to be maintained in the River and carried different price tags. The plan selected represented a sort of compromise between the ultra-clean waters desired by the conservationists and the less strin gent requirements envisioned by industry and many municipal officials. Oxygen levels were to be 3.5-4.0 mg/1. 6 OOb^89 The River was divided into six zones, with Zone 1 represent ing the headwaters and Zone 6 the section where the River joins with the Atlantic Ocean. Zones 2 to 6 are in tidal waters while Zone 1 is non-tidal. The "water uses to be protected", "stream quality objectives" and the "effluent quality objectives" vary in accordance with Zone and in general, the water quality desired is best in Zone 1 and decreases as the mouth of the River is approached. The stream quality objectives include the following para meters : 1. Dissolved oxygen 2. pH 3. Total alkalinity 4. Temperature 5. Phenols 6. Threshold odor number 7. Syndets 8. Turbidity 9. Radioactivity 10. Coliform Bacteria 11. Fecal coliform To meet the stream quality objectives the DRBC determined the assimilative capacity, with regard to carbonaceous BOD, of each Zone A number of pounds for each Zone was then allotted to each waste contributor, with a certain percentage held back for future industry First the B0D^_ of the untreated wastewater and a certain percentage 7 0065390 removal were established. The remaining BOD became the allotment. For.some industries, establishing the raw waste BOD became a problem because of interfering substances. Some metal working plants had heavy metals in their discharge which interfered with the BOD test. The problem was resolved by using very high dilutions of the wastewater, which gave reasonable BOD readings while being suspect, however, because of the small oxygen depletion in the sample. But it was the best that could be done. The DRBC also has restrictions of temperature effects of a waste discharge, particularly as temperature affects trout. The Commiss ion also requires toxicity tests on industrial waste discharges and they are quite definite as to how these are to be run. The Commission is always trying to clarify the regulations and in Resolution 72-1, dated January 26, 1972, some limits of toxic substances 'were defined, viz.: Substance Stream Quality Limit - mq/1 Effluent Quality Limit - mg/1 Arsenic Barium Cadmium Chromium Copper Lead Mercury Selenium Silver Zinc (hexavalent) 0.05 1.0 0.01 0.05 - 0.05 0.005 0.01 0.0-5 0.1 2.0 0.02 0.10 0.20 0.10 0.01 0.0-2 0.60 - The Resolution also mentions limits on oil, temperature, suspended solids, debris, pesticides, odor and BOD. 8 0065391 It is certainly best to keep in contact with the Commission if you are working under their jurisdiction, not only to keep track of the latest regulations but to make sure you are working toward their objectives. FEDERAL REGULATIONS At present writing, both the House and Senate have passed separate bills concerning water pollution. A compromise will have to be worked out and eventually there will be a national water pollution control policy. It is hard to say just when this is going to happen. Up to now, the Federal agencies have relied on water quality standards but the trend seems to be toward effluent standards. In general, stream standards are a little easier for industry because they leave some room for negotiation on effluent quality, but, at the same time, they do not give a definite goal to shoot at. Eff luent standards tell you what you have to do but leave no room for negotiation. / It would appear that some Federal regulations are required, if only to prevent some states from setting water quality standards so low as to make it attractive for industry to move from a stricter state. Hopefully the new Federal law will eliminate some of the overchecking of plans and specifications that have plagued engineers in recent years. When the first Federal construction grant programs were put into effect, joint municipal-industrial treatment was attractive to industry, at least from a financial standpoint, because the 0069^92 9 grant money lowered industry's share of construction costs, com pared to the 100% of cost they would have to pay for their own treatment units. The new Senate bill S-2770 changes the rules so that industry must pay back that part of the construction cost allocable to the treatment of industrial wastes. This provision has caused many industries to review potential contracts with municipalities and to consider carefully which is the most econom ical route over a long period - self-treatment or joint treatment. At this time there seems to be a waiting period until a compromise bill is worked out. Unfortunately, the Federal rhetoric has not been matched by funding and many municipal and industrial officials have become disenchanted. The lack of funds and apparent change in direction from water quality standards to possible effluent standards have led to a wait-and-see attitude which is not going to clean up our rivers. From the standpoint of industry, there are several significant differences between the House and Senate bills: 1. The House calls for a two-year study to determine the impact of legislation with further Congressional action required to set pollution abatement goals. The Senate requires, by 1981, the implementation of the best available technology, where feasible, and implementation without exception by 1985. 2. For "zero discharge", it is considered a national policy by the Senate and a national goal by the House. 3. The permit system would be transferred to the states by the House, as does the Senate, but the latter authorizes a veto by EPA. 10 0653g3 House and Senate bills allot money for municipal treatment plants under different formulas. This would affect industry if joint treatment is contemplated. The differences in money and allocation will probably take the most time to resolve and will probably cause the greatest delay in the construction of municipal treatment plants. There should be something here about the future trends in pollution legislation. Anyone who pays taxes is aware of the com petition for the dollar and that there is a great need for pollution control as well as for schools, prisons, roads, etc. When one considers that most large cities have combined sewers that discharge raw sewage during storm periods, some questions may be raised about the overall effect of sewage treatment if it is only effective during dry periods. Thus there may be some blunting of the ecology question when all the facts are known and evaluated. There seems to be a general agreement that leadership will have to come from the Federal Government and future regulations will be tied into the money made available and the ultimate thrust of Federal legislation. 11 0065394