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where dilution of the waste is minimal, to the open ocean where high dilutions 

 are possible? With blanket treatment requirements there is no economic incentive 

 for a city to transport its waste to areas of high dilution nor to join with other 

 municipalities to accomplish the same objective. Instead the incentive is on 

 "going it alone." applying secondary treatment at all locations where wastes 

 are generated. There will be little if any effort devoted to the transport of 

 wastes out of estuaries or areas of low dilution capabilities. Instead, we will 

 overload and possibly destroy our estuaries before this error is realized or 

 admitted. Historically, most of our severe water quality problems have occurred 

 in estuaries rather than in the open ocean associated with well-engineered out- 

 falls. Yet we seem to be committing ourselves to a policy that will destroy our 

 estuaries before we seriously consider the real advantages of engineered treat- 

 ment and ocean dispersion systems uith accompanying high waste dilutions. 



Another possible approach to increase the incentive for the development of 

 regional systems in estuarine-coastal waste management is as follows. If sec- 

 ondary treatment is to be required for open coastal waste disposal systems with 

 high dlutions (i.e., >100 :1), then treatment markedly higher than secondary 

 should be required for estuarine dischargers where physical dilutions are mini- 

 mal — often in the range of 10 to 30 :1. But what should that treatment be? Will 

 the increase of BOD and SS removals from 85 to 95+% solve the problem? But 

 what if BOD and SS are not the critical estuarine problems? Moreover, it appears 

 that BOD and SS are not the major problem in many estuaries, such as in San 

 Francisco Bay today where BOD and Suspended Solids concentrations are of 

 little consequence. Instead, toxicity and floatables appear to be major problems, 

 and treatment requirements and the required funds should be directed to solving 

 specific water quality problems — not just adding more and more classical treat- 

 ment processes to increase removal of BOD and SS. Logically then, if secondary 

 treatment is to be required for open ocean waste disposal systems, a higher level 

 of treatment (and likely twice the cost of conventional secondary treatment) 

 should be required for estuarine discharges. Are the costs of adding more and 

 more sophisticated treatment processes for BOD and SS removal justified and 

 are the benefits tangible? Based upon present information, this trend, though 

 supported by some designers and equipment suppliers, may not improve signifi- 

 cantly environmental quality, and its cost/effectiveness is very high. And signifi- 

 cant improvement in environmental quality will not occur until .such time as 

 waste treatment policies, regulations, and designs are directed to specific water 

 quality problems rather than by a "lumper" treatment method approach. It is 

 recognized that the "lumper" approach of specifying traditional treatment method 

 requirements "across the board" may appear to be equitable and easy to enforce. 

 However, will it solve the real pollution problem? I fear that we will run out 

 of funds for environmental improvement following this approach long before we 

 re.solve our important water quality problems. 



Two additional points should be made regarding the uniform treatment method 

 requirement approach. 



Does it make much sense to require 85 percent removal of the BOD or what- 

 ever, from a 10,000 gallon per day flow — a few pounds per day at a cost per unit 

 of flow, or per capita, several times that required for 85 percent removal from 

 a 100,000,000 gallon per day flow? In the latter instance the removal is measured 

 in tens of tons per day. 



Increasing reliance on sophisticated treatment processes without concern for 

 terminal dilution for the treated waste stream in the environment places real 

 protection of the environment in a precarious position. I have observed few, if 

 any, treatment process systems that performed uniformly and continiiously as 

 predicted in design or that did not on occasion either fail or require shutdown 

 for maintenance or other reasons. Without adequate terminal dilution for these 

 periods of upset or decreased performance, what happens to the pollutant con- 

 centrations in the receiving waters? They increase markedly and of course addi- 

 tional stress is placed on the environment. With high terminal dilutions such as 

 experienced with present day ocean disposal systems in California, this stress is 

 markedly reduced. 



Senator Tuxxey. Our final witness is Mr. Lawrence Hargrove, 

 director of studies, American Society of International Law. 



