117 



I understand EPA has given California the right to enforce that 

 legislation on behalf of EPA. California has demonstrated to EPA 

 that their requirements are equivalent to those at EPA. In order 

 to meet the Federal requirements, California lias developed a set 

 of requirements that appear to be even more restrictive than the Fed- 

 eral requirements. In other words, the effluent requirements and receiv- 

 ing water conditions are more restrictive than specified by EPA in 

 accordance with that legislation. 



Tlie question is, how are California agencies and organizations going 

 to meet these requirements? I might say I don't know, and I don't 

 think any of them know either, but they are vigorously at work start- 

 ing to engineer candidate systems, which they must do if they are 

 going to meet the deadlines. 



What are they doing? Well, they are doing what logicallv I guess 

 what anyone would do, since they don't know liow to meet these even 

 more restrictive requirements, nor do I think they they believe in 

 them. For the most part, they are designing conventional secondary 

 treatment svstems, and the cost of increasing the degree of treat- 

 ment, is going to be about $750 million. Many of us feel that the 

 bulk of those moneys will be wasted. That is how I understand the 

 enforcement of that legislation is going to be practiced. I assume 

 it will just be limited practically to EPA's requirements of secondary 

 treatment which, to discharges on open coastal waters, in my judg- 

 ment, has very little relevancy. 



Senator Tfxney. Can you just tell us what specifically you foel the 

 Congress ouglit to do now with respect to actualizing some of the con- 

 ceptual concerns that you have outlined in your conclusions and 

 recommendations ? 



Dr. Pearsox. There are a number of things that could be done. Much 

 of it relates to having technical competence in establishing limits or 

 criteria, and having a regulatory basis which utilizes the technical 

 competence available. 



First would be to support more studies of tlie type mentioned so that 

 there is hard, reliable data upon which regulations can be proposed. 

 The arena for "blanket requirements" comes when nobody knows much 

 about anything, and that is what we need to avoid. In waste manage- 

 ment, we could save tremendous sums of money if there were more, 

 not necessarily just research, but field investigations that develop 

 pei'tinent data related to the management of the systems. 



Second, I think this committee should be sure that the Federal regu- 

 lations are not primarily of the "blanket type," eas}^ to administer 

 criteria that appear equitable, like everybody has to have secondary 

 treatment. 



If they do, if you have to have it for open sea discharge with a dilu- 

 tion of 100 or 200 to 1, what type of treatment should a city have 

 on "Podunk Creek" with essentially no dilution of its effluent? 



Also the regulations don't, since you have to apply the same degree, 

 and essentially the same costs, now, the costs go down as the size of the 

 system goes up, but essentially the same cost, there is no economic in- 

 centive for the city inland with limited dispersion or dilution capabil- 

 ities to ever get their wastes out of the area. 



A classic example is San Francisco Bay where technical studies indi- 

 cated that the solution was to provide treatment suited to deep sea 

 disposal, but the easier, political, and apparently more equitable solu- 



