Water Pollution Control — Stream Standards vs. Effluent Standards

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by W. Β. Ηart, Pantech, Inc.

Water Pollution Control — Stream Standards vs. Effluent Standards Industry will go along much more quickly with stream standards than with effluent requirements

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words have been used in discussion of this controversial subject but no general policy appli­ cable in all the country seems to have become acceptable. This situation causes a great deal of difficulty for those engaged in the abatement of water pollution. T h e opinion has been growing that there is use for both stream standards and effluent standards. T h e stream standard should be given the greatest consideration and should take precedence over effluent stand­ ards in general practice. T h e efflu­ ent standards should be reserved for application where there is re­ calcitrance to be overcome. Also, effluent standards may be neces­ sary where there is high density of industrial activity. Here it is de­ sirable to be able to trace particular pollutional substances to their source and to maintain the necessary al­ lowable discharge that will prevent the pollution these substances could create. Any opinion expressed con­ cerning controversial matters is sub­ ject to examination to ascertain its soundness and the conditions which contribute to its development. Therefore, it is proper to examine the opinion that stream standards should be the basis by which pollu­ tion abatement properly should be measured. This examination can take any of several forms.

pollution of its waterways. Few, if any of these laws, however, pre­ sent any suggestion as to technical procedures for preventing pollution or any definite statement on the quantities of pollutional substance that may be discharged into a public body of water. There is a good reason for this situation. For one thing, assuredlv successful methods for the treatment of numerous types of industrial wastes are not always known. If they were known the rapid advance in many technologies of manufac­ ture would soon make such laws or regulations obsolete or would re­ quire continual changes in the pro­

cedures or restrictions as to quan­ tity acceptable for discharge which they would establish. Further, in densely populated industrial areas such laws could not effectively pro­ vide for the interaction of wastes after discharge. T h e chemistry and biology of such interaction is not as yet even nearly well enough known to make such interactions predict­ able. A second phase of the situation is that of responsibility. Assume that a raw waste when discharged into a stream causes continuous "fish kills," or creates a hazard in the treatment of the water for potable use. T h e establishment discharging

From the legal aspect it would be supported by the fact that practically every law or regulation in this field, state or federal, has for its purpose the prevention and abatement of VOL. 48, NO. 9 ·

SEPTEMBER 1956

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the waste is advised of the condition the waste creates and also directed to a process by which, presumably, the waste can be treated to make it innocuous. T h e establishment accepts the use of the procedure and spends thousands of dollars to install the treatment. But as a result of some step in its manufacturing processes or for other reasons, there is little or no improvement in the pollutional effects although examination of the effluent shows that the limitations set forth in the law or regulation are being met. T h e n the authorities must go back to the organization a n d say that they have not gone far enough, they must investigate further, install more treatment, spend more money. T h e industrial establishment responds that they have met the law or regulation requirement both as to process and limitation of pollutional substances in their effluent. T h e authorities reply that they are charged with the responsibility of preventing the pollution regardless of the working of the law or regulation. A grand fight has begun; by doing just what was required of it the industrial establishment has p u t the responsibility right back in the hands of the authority and the authority does not want it. This is why such forms of law or regulation are avoided on the books. Authorities, both state and federal, have been asked many times by industrial people how their industrial wastes should be treated. "Just what do you want us to do, how much acid, alkali, phenol, or cyanide can be discharged?" they say. T h e authorities promptly answer that they cannot a n d will not answer such questions. They cannot accept a situation in which they are taking a scientific responsibility of that nature. Their job is only to prevent or abate pollution, not to prescribe methods for doing it. But prevent or abate pollution of what? Simply of the stream or other public water into which waste is being discharged. It is the stream in which they are interested and for which they carry responsibility and authority for its protection. Should the industrial organization choose to treat its wastes in some manner diametrically opposed to the recommendation of a state au66 A

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thority, or to the requirement of a law or regulation should such law or regulation exist, and eliminated the pollution there is little chance that the courts, public opinion, or any other other medium of pressure, would condemn the method of treatment or the organization that applied it. O n e of the strongest arguments in favor of stream standards is the ease and extent with which they can be applied. Recently there has been great pressure for the enactment of federal legislation that would cover the entire United States with a uniform antipollution law. Uniform legislation of any nature is highly desirable when it can be applied to uniform conditions. But where the legislation is uniform and the conditions it is to govern are not uniform, it probably presents more difficult problems than when the reverse is true. It is highly improbable that any other than very general uniform legislation to control water pollution over the entire country is practicable, because the conditions in various parts of the country are so different. It would be highly helpful to the manufacturing areas of the two coasts if they could discharge wastes with dissolved solids concentrations that would well fit the highly alkaline areas of the Southwest and the great basin regions, and not have to worry about osmotic effects, and it should be remembered that dissolved solids often create serious problems when acid neutralization and similar processing are involved in waste treatment procedures? Similarly, why should the industrialists and farmers of the Southwest and great basin regions have to worry about phenols in wastes when the waters receiving the wastes cannot be used for potable purposes or stock watering because they are too alkaline for consumption? Stream standards would avoid any such complications for they would be established by local conditions, and the cleanliness of the waterways would be easy to check.

watercourse that answers this general condition of cleanliness a stream that may be under suspicion readily can be rather definitely determined to be clean or polluted. Thus, each area of the country will establish its own standard of cleanliness and the quality of all the waters in the area can be brought to approximately the same level of cleanliness without involved discussions as to what can or cannot be discharged in a waste. T h e stream will soon reveal any serious breakdown in this acceptable degree of cleanliness. Use of the term, "acceptable degree of cleanliness," calls attention to another argument in favor of stream standards. T h e construction and operation of waste treatment plants are expensive. Industrial people, unaccustomed to spending money without knowing before they do so that the expenditure is going to bring about a profit, have been slow in pollution abatement activities because only infrequently does an expenditure for waste treatment bring about a return. Industry has now come to realize that we must protect what clean waters we have, and try to recover the cleanliness of polluted waters. Industry can see much more common sense in such protection than in trying to meet some specification for its wastes prior to discharge, a specification for which perhaps only a few in the industrial organization can understand the need. Industry will go along much more willingly with stream condition requirements than with effluent requirements. These latter are only a device that is hoped will bring about proper stream conditions. There are other reasons that could be cited for giving stream standards preference over effluent standards. However, effluent standards also should be considered, and their proper application discussed where there is the possibility of gain in pollution abatement or elimination to be obtained. These will be the subject of the discussion for November.

In practically every section of the country there are public waters which are not polluted. Such waters will establish the general characteristics of all the waters of the region. By comparison with any

Correspondence concerning this column will be forwarded if addressed to the author,

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