collaborative tests have been completed: for suspended particulates (high volume sampler method), sulfur dioxide (a modified West-Gaeke colorimetric procedure) and carbon monoxide (use of NDIR analyzers). This EPA testing program was active before the ASTM project Threshold was conceived. Our collaborative testing is directed toward evaluation of those analytical procedures associated with the air quality and emission standards issued in the Federal Register.
A. P. Altshuller National Environmental Research Center Environmental Protection Agency Research Triangle Park, N.C. 2771 I
W h a t role for the states?
DEARSIR: The editorial in the August 1971 issue by Dr. Bowen could be titled “The States-Odd Men Out,” and I’m sure will prompt other replies. In the 1965 Water Quality Act, and in all subsequent revisions, the primary responsibility for water pollu-
tion control is left with the states and, for better or worse, this policy has carried over into the Corps of Engineers permit program. No action may be taken on an application until the state has certified that the discharge meets (or will meet) all applicable water quality standards. In Missouri, we have a permit program under the state law passed in 1957 which requires that all discharges to “waters of the state” receive a permit from the Water Pollution Board. There are no exceptions. Thus, the Corps permit program becomes a duplicate effort. This was pointed out to all of Missouri’s Senators and Representatives by letter which in turn was forwarded to Senator Muskie’s subcommittee on air and water pollution. It is our position that the permit program should be left to the states as was the development of water quality standards. Also, since the Environmental Protection Agency has now publicly admitted that nationwide industrial waste effluent guidelines could not be established, how could nationwide effluent standards be set? Each discharge and stream must be evaluated as separate cases with the
existing water quality standards as the control. These standards must be met in all cases. The last paragraph of the editorial indicates that Dr. Bowen, at least, has fallen prey to the misconception that pollution can be legislated out of existence. First, why don’t we try better funding of existing pollution control agencies so that existing laws can be enforced and better surveillance established? One final comment. The federal government has, for many years, helped fund construction of municipal waste treatment plants. Only recently has it begun to consider the importance of operation. Of all the requirements that must be met to receive a federal grant, passage of a state mandatory operator’s certification law is not one of them. In fact, only 31 states have such laws. It’s a hard fact, but you can’t solve pollution without good operation. James P. Odendahl Missouri Water Pollution Board Department of Public Health and Welfare Jefferson City, M o . 65101
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