115 



Dr. Pearson, That is perfectly correct, Senator, and that is the 

 point I want to make in j^oint 2, about uniform or blanket disposal 

 requirements. My remarks relate to coastal regions, and where you 

 have the open ocean suited for this type of disposal. 



Regulations regarding waste management must consider local con- 

 ditions, uses, and requirements rather than follow what becomes easy 

 to administer, an approach which requires the same thing of every- 

 body, regardless of the situation. Let us consider the blanket approach 

 of requiring secondary treatment for all waste discharges. Secondary 

 treatment as defined by EPA simply means 85-percent removal of the 

 biochemical oxygen demand (BOD) and suspended solids or a con- 

 centration of BOD or suspended solids less than 30 parts per million, 

 whichever is the more restrictive. 



This is to be applied uniformly for all discharges, whether a city 

 is located at the head of the estuary on Podunk Creek or on the open 

 ocean. This is a very ineffective approach to waste management, and 

 it should be reassessed if it is really going to be implemented. Let me 

 make a couple of specific points. First, there has been no study to show 

 that for well-designed sea disposal systems that BOD or suspended 

 solids are at all a problem. They are in fact not. 



Secondly, the imposition of uniform requirements of secondary 

 treatment for the waste treatment-disposal systems like we have in 

 southern California, which are primarily, mechanical, with biologi- 

 cal digestion of the sludges, secondary treatment will cost twice as 

 much as present practice. This will mean expenditures to provide 

 secondary treatment of about three-quarters of a billion dollars. If we 

 are going to spend money on waste management, it seems to me it 

 ought to be directed toward the specific problems that ought to be 

 identified, not just follow traditional and expensive approaches. 



Two additional points can be made. A blanket treatment approach 

 requiring 85 percent removal, or 30 parts per million in the effluent 

 of BOD, suspended solids or anything considers the same value or 

 significance to a small flow of 20,000 gallons per day as compared 

 to one that is 100 million gallons a day. 



There is inequity of requiring sophisticated treatment, particularly 

 for the smaller systems. Too often the assumption is made that these 

 treatment systems are functionally designed to perfection, and that 

 operators and equipment never fail or falter. The more reliance we 

 place on sophisticated treatment processes, we must also be sure that 

 we have adequate safeguards for their continued high level of opera- 

 tion. This is particularly true where adequate dilution is not available 

 to reduce the concentrations of the residual wastes to insure the protec- 

 tion of the environment. 



One of the big advantages of the large wastewater disDersion sys- 

 tems in southern California is that they do effectively dilute, more 

 than a hundred to 1, the treated wastewater with the seawater. Thus 

 with respect to the waste constituents that are not present in seawnter 

 at significant concentrations, these dispersion systems affect 

 removal than any designed treatment process to date. In other 

 iwords, a dilution of 100 to 1 is equivalent to 99 percent re- 

 moval with respect to the pollutant concentrations in the receiving 

 water. Don't misunderstand me, I am not advocating that "dilution is 

 the solution to pollution." Nonetheless the degree of safeguard or back- 

 up or sophisticated treatment processes must consider the terminal dilu- 



