WWEMA Window: Step One In Regulating Pollutants: Assess Whether It Is Technologically Achievable
By Thacher Worthen, President, Schreiber LLC
Nutrient pollution represents one of the major impairments to waterways in the United States and elsewhere in the world. To date, regulations and the adoption and enforcement of regulations vary across the country. Each state is on its own with regard to nutrient standards, and even within each state, localities are developing their own standards. The permit writers at a given office can have differing interpretations of the permit guidelines and how to write them based off the technology they have been presented. This leads to a very fragmented and diverse spectrum of standards, from the unachievable to the immeasurable.
A reasonable level for total nitrogen is 6 ppm, though 3 ppm is achievable, as we have seen in the Chesapeake Bay. Considering that 0.5 to 1.5 ppm of total nitrogen in typical municipal wastewater cannot be removed with the best available technologies, achieving a limit below 2 ppm is considered unfeasible.
Achieving a phosphorous limit of 0.5 mg/L is achievable and reasonable. A limit of 0.1 mg/L is questionable even at double the price, but requirements that are appearing in local waterways of .05 mg/L are irresponsible given the technology on the market today, and will only further delay implementation.
Using technology-based limits can allow a much more affordable implementation of standards given the numerous technologies that can achieve excellent results. In areas where tighter water quality-based limits are required, such as the Chesapeake or in certain Florida watersheds, there would be a balance between technology-based and water quality-based limits derived on practical technological practices. The question has to be asked: Which is more beneficial: a 0.2-0.5 mg/L phosphorous level in the majority of the country at affordable prices or a 0.05 mg/L level at unaffordable prices, across a state or region, with very little implementation and years of debate?
These are the questions faced by every state, county, and local utility planning for its future. How can a municipality project a multi-year capital plan with the grey area of “recommended” regulations hanging over them? It’s unrealistic and silly to expect broad-scale implementation of nutrient standards that will cost hundreds of billions of dollars. Sounds like a fast way to bankruptcy. Technology, removal, and broad-scale costs all need to be part of any future discussions for regulations.
Given the change in spending associated with municipalities and the adaptation of the “more with less” approach, it makes sense for the EPA, states, manufacturers, and consulting engineers to come together and decide what is achievable and what are the costs to get there. Such a gathering occurred in Denver on June 10 at the American Water Works Association’s national conference. WWEMA participated in this "Overcoming Challenges to Innovation in the Water Industry" technical session along with 70 professionals from all areas of the water and wastewater treatment industry.
The nutrient issues are not going away anytime soon, so getting all constituents together is a first step and a great conversation starter, but it will take much more to “stem the tide,” as they say. Thanks to WWEMA and AWWA for taking the initiative in addressing this matter. We look forward to the continued discussion and momentum going forward. As manufacturers, we thrive on progress through innovation! For more info on this technical session, go to the WWEMA website (www.WWEMA.org) to learn more.