Letters. Instrument Reliability - ACS Publications

Of course, it's always made good (business) sense to reclaim ... we've been in the “reclamation equipment business'' for years. With our Tumble ... ...
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Monstrous waste plle

DEARSIR: The story, “Can plastics be incinerated safely?” ( ES&T, August 1971, p 6 6 7 ) states that the U.S. production of solid waste handled by municipal authorities is more than 190 million tons per capita each year. This is more than 500,000 tons per person per day-impossible to believe! There must be some mistake.

P. R. Bolton Environmental Sciences Dept. Reynolds Elect. & Eng. Co. P.O. Box 14400 Las Vegas, Nev. 89114 Indeed there is! The words “per capita” should not have appeared. W e regret the error-Ed.

Instrument reliability

pelletize ammonia sulfate reclaim metallurgical powders incinerate volatiles of filter cake regenerate a catalyst dry (fine) materials in a recycling process Of course, it’s always made good (business) sense to reclaim valuable materials when it was economical to do so. Ecology now adds another sensible reason. With Calciners, Dryers, Coolers and Fluid Bed Processors (lab unit shown above) . . . we’ve been in the “reclamation equipment business” for years. With our Tumble Burner installations for waste disposal . . . we’re off and running in incineration, too.

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DEARSIR: The feature article in your August issue by Hochheiser, Burmann, and Morgan (“Atmospheric surveillance: The current state of air monitoring technology,” p 678) provides much useful information concerning this subject. As a scientist involved in directing a closely related program in EPA on the development, evaluation, and standardization of instrumentation and methods, I believe several supporting comments should be useful. Many of the newer instruments were developed or evaluated in EPA laboratories or by our contractors. We are very concerned, as is Mr. Levadie (in his letter published on p 978 of your October 1971 issue), with the need to develop new instruments which require less calibration, maintenance, and less downtime than do older instruments. Only by several years of routine use in monitoring networks can our progress be determined. Within our program of standardization, we not only develop reference calibration techniques in our laboratories and with NBS but have a collaborative testing activity. The methods tested come from the recommendations of the Intersociety Committee on which the American Chemical SOciety has representatives and from an EPA methods advisory group. The collaborative testing work is conducted with contractual support by Southwest Research Institute. Three (Continued on page 1073)

editorial Handout time in the nation’s capital Federal emphasis on sewage plant construction funds ignores cheaper routes to better pollution control

W

ashington is a crazy place sometimes. Well, all right, all the time, And when it comes to parceling out federal funds, the capital city is seen at its zenith of zaniness. When a new version of the Federal Water Pollution Control Act eventually emerges from Congress-if it ever does; the present act has been temporarily extended twice already-it is likely to contain authorization for billions of dollars for the construction of new sewage treatment plants, but not a bean for operation. Not that previous versions of the act ever authorized anything for operating costs, mind you, but the emphasis on capital cost to the exclusion of operating costs is one that merits examination. For the success or failure of a sewage treatment plant depends as much on operation as on design. Even a well-designed plant will not operate properly unless the people in charge of it know-and care-about what they are doing. Federal law generally recognizes this need by providing small sums of money to be used for training operating personnel. However. Congress appears otherwise strangely unaware that there is anything more to running a sewage treatment plant than building it in the first place. By emphasizing capital cost alone, it may not be allocating federal funds effectively. For instance, the E P A has recently promised that some of future appropriated capital construction funds will be used to build plants for phosphate removal. What seems to be assumed in this promise is that it is necessary to build a new plant for the purpose. As many of our readers and, indeed, E P A and CEQ know, it is entirely feasible to remove phosphate through modification of operating procedures, addition of chemicals at appropriate treatment stages, and the like. However, such operating modifications are not eligible for funds under present or contemplated federal law. There are other aspects of sewage treatment that bear examination in the same light. For

example, it is a well-known fact that combined storm and sanitary sewer systems regularly overload treatment plants during heavy rains, often necessitating bypassing of raw sewage to a waterway. What is not so well-known is that some uncombined sewer systems leak so badly during rains that infiltrating groundwater bolsters sewage flow to three to five times dry weather rates. It is the contention of firms in the business of upgrading sewer systems that they could provide more real progress, at lower cost than lump-sum grants, to build or enlarge existing plants. One could extend this critique of effectiveness of spending to most areas of pollution control. How many incinerators, for instance, have been shut down because they simply were not operated properly and consequently emitted excessive amounts of soot? We know, of course, that incineration is something of a black art, but are nevertheless impressed by the claim of one of our readers that incinerator operation could be vastly improved by the simple expedients of operator-training and small changes in supplying secondary combustion air. We do not intend to get into the argument over whether the federal government should indeed be in the business of supplying funds for municipalities, intriguing and germane though that argument may be. The fact is that the feds are in that business and are likely to continue to be. Nor, of course, do we argue that no new sewage treatment plants are needed-obviously very many are. What we are concerned over is the simplistic approach to spending money. For funding approaches that do not provide incentives for improved operation of existing facilities may backfire badly. And we all would be literally the poorer for that.

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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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