Unnecessary and Harmful Levels of Domestic Sewage Chlorination Should Be Stopped

Published by the Government Accountability Office on 1977-08-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                        REPORT                       TO THE CONGRESS

     a\+     ‘7 -1 i>

                        BY THE COMPTROLLER GENERAL
           cOL          OF THE UNITED STATES

                        Unnecessary And Harmful
                        Levels Of Domestic
                        Sewage Chlorination
                        Should Be Stopped
                        Environmental               Protection       Agency

                        Chlorine    is frequently     used to disinfect do-
                        mestic sewage, and it is also used in industry
                        and is discharged in various industrial wastes.
                        Chlorinated      discharges have been shown to be
                        harmful to the aquatic environment,           but they
                        are still largely uncontrolled.        In many situa-
                        tions the use of chlorine is not needed. Ex-
                        cept in areas of shellfish-harvesting        or of un-
                        restricted    irrigation,  disinfection    of treated
                        wastes usually is not needed to protect

                               --swimmable      waters   in   cold   weather

                              --waters rarely used for swimming,       or

                              --drinking   water.

                        When sewage disinfection      is needed, present
                        sewage chlorination   practices generally result
                        in excessive amounts of chlorine        being dis-
                        charged into waterways. More should be done
                        to limit residuals and to promote the efficient
                        use of chlorine in sewage disinfection.

                        CED-77-108                                                AUGUST 30, 1977
                    COMPTROLLER     GENERAL     OF      THE   UNITED   STATES
                                  WASHINGTON,    D.C.     20548


To the President of the Senate and the
Speaker of the House of Representatives
      This report    discusses the use of chlorine        to disinfect
domestic   sewage at municipal    waste treatment     plants     constructed
under grants    awarded by the Environmental      Protection      Agency.
         Chlorine      is frequently         used to disinfect        domestic    sewage.
It is also used in industry                  and is discharged        in various    in-
dustrial        wastes.      Chlorinated        discharges     have been shown to
be harmful        to the aquatic          environment,      but such discharges         are
still     largely      uncontrolled.           We made this     review   to determine
whether      unnecessary        chlorination         has been stopped and whether,
when disinfection            is needed, municipalities             and industries
have prevented           harmful     levels     of chlorine     from being dis-
charged       into waterways.
     We made our review pursuant                          to the Budget and Accounting
Act, 1921 (31 U.S.C. 53) and the                          Accounting  and Auditing  Act
of 1950 (31 U.S.C.  67).
        We are sending     copies  of this    report  to the Director,
Office     of Management and Budget;       the Chairman,    Council    on
Environmental     Quality;     and the Administrator,      Environmental
Protection     Agency.

                                                of the            United        States
                                          SHOULD BE STOPPED
                                          Environmental Protection  Agency
              Chlorine    discharges     by municipal         sewage treat-
              ment plants      in the United       States     sometimes    ex-
              ceed levels      safe for the aquatic          environment.
              Fish kills     and water-life       deterioration        have
              resulted.      Chlorine    discharges,       even at low-
              levels --roughly      equivalent      to a quart of laun-
              dry bleach     in 2 million      gallons     of water--
              have been shown to harm fish and other water
              life.     (See pp. 3 through         5.)
              Municipal       sewage treatment          plant    operators
              disinfect       wastewater       because it has been gen-
              erally     thought      to protect      the public      health
              from diseases         transmitted       through     water.      GAO
              found that the practice              is widespread,          With
              the possible        exception      of chlorine       needed to
              protect      areas of shellfish           harvesting      or of
              unrestricted        irrigation       with sewage, the pub-
              lic health       benefits      from chlorinating           sewage
              are minimal.
              The widespread   practice     of sewage chlorina-
              tion is questionable      for a number of reasons:
              --The relatively           few incidents      of disease
                 transmitted        through     water in the United
                 States generally           are not serious      and are al-
                 most always transmitted             through   inadequately
                 treated     drinking
                             ------         water.
              --Sewage disinfection         is not practiced      exten-
                 sively  in other     industrialized     countries
                 with public   health     experiences     similar    to
                 those in the United        States.
              --Widespread       sewage disinfection         is a rela-
                 tively   recent    phenomenon in the United
                 States,    with little       accompanying      improve-
                 ment in public       health.       The Center for
                 Disease Control        has taken the official
                 position     that disinfection        of sewage pro-
                 vides little      public     health   benefit.

Tear Sheet.  Upon removal,   the report        i                            CED-77-108
cover date should be noted   hereon.
--Epidemiological        studies  attempting    to relate
   bacterial      levels   in swimming waters with
   levels    of illness     have been inconclusive.
In particular,            disinfection         of treated          wastes
is usually        not needed to protect                waters that
are ultimately            used for drinking            because these
waters are purified               in water treatment               plants.
Nor is disinfection               usually      required        to pro-
tect waters rarely               used for swimming;              nor is
it needed to protect                 swimmable waters            in cold
weather.         Disinfection           should not be required
unless      it can be reasonably               demonstrated           that
the public        will      benefit.         In addition,          the
Environmental            Protection       Agency's       rationale
for disinfecting              swimmable waters has no
strong      scientific         basis.        The States        feel
that the Agency has not supplied                       sufficient
guidance       to them as to when disinfection                        is
not required.             According        to the Agency, the
decision       to chlorinate           should be predicated
on whether        or not chlorination              will      protect
the public        health.         Any decision         to limit
chlorination           of wastewaters          should be made
on a case-by-case              basis with consideration
being given to drinking                  water source protec-
tion,     recreational           water use, shellfish               grow-
ing, and other public                 health     aspects.          (See
PP. 7 through           13.)
Although     the Agency could do more to prevent
the unnecessary          use of chlorine,        it has taken
steps to reduce the uncontrolled                 and excessive
use of chlorine          for wastewater      disinfection.
Since July 26, 1976, Agency regulations                      no
longer    require      that all discharges           from pub-
licly   owned treatment           works provide        a minimum
level   of disinfection.             Because of the change,
States    now do not have to disinfect                 waste
treatment      plants'      effluent    unless     it is
needed to meet the States'              water quality
The change, which allows               States    to determine
the conditions        under which they will              use
chlorine      for disinfection,          will    not fully
solve the problem.            Officials       of 25 of the
States     GAO contacted        (50 percent)        stated
that they do not plan to reduce their                     chlo-
rination      requirements.          Many cold weather
States,     including      Alaska,      Michigan,      and Minne-
sota,    require     continuous        year-round      sewage
                      chlorination,          with no reductions          permitted
                      during      cold weather months.              In addition,     the
                      Agency's        water quality       bacterial      criteria    for
                      swimmable waters may be interpreted                     by the
                      States      to mean that year-round             use of chlorine
                      is required.           Since the criteria          are not suffi-
                      ciently       flexible      to allow for less disinfection
                      because of seasonal            variations       or a lack of
                      use of the waters by swimmers,                  the States may
                      still     disinfect       regardless      of how low the ex-
                      posure risk          to people might be.           (See pp. 18
                      through       20.)
                      Many sewage treatment       plants      use too much
                      chlorine     and have high chlorine         residuals
                      because of ine.fficient       chlorination        systems.
                      Even in designing      new plants,       State and Fed-
                      eral emphasis on improving          chlorination        effi-
                      ciency    has been inadequate.          Chlorine     produc-
                      tion    is energy intensive      and a substantial
                      reduction     in its use would save a significant
                      amount of energy.        (See pp. 28 through           35.)
                      The Administrator,           Environmental          Protection
                      Agency,  should:
                      --Revise     the     Agency's       water quality          criteria
                         regarding       the bacteria         standard       for swimmable
                         waters    to    recognize        seasonal     variations          and
                         he should       specifically         delineate        those cir-
                         cumstances        in which       sewage chlorination              is
                         or is not       needed to        protect     public       health.
                      --Include        chlorine      residual     limitations       in all
                          National       Pollutant      Discharge      Elimination
                          System permits,           when disinfection         is judged
l    ”
                          necessary       for the protection           of the public
                          health,      for sewage treatment            plants    and for
                          all    industrial       dischargers       of chlorinated
                      --Lower  the limitation        on chlorine             residuals
                         in powerplant    effluents.
                      --Require  regional          offices     or the States,
                         where appropriate,            to tailor    permits   to

         Tear Sheet                                 iii
   assure the use of chlorine           testing      and
   operating     equipment    which would signifi-
   cantly    improve chlorination         efficiency
   at individual      treatment    plants.
--Incorporate          key factors    of efficient
    chlorination,        such as rapid,      thorough
    initial      mixing   and flow-proportional
    dosage adjustment,          into construction
    review criteria         for all new plant       con-
    struction.         (See pp. 20, 35, and 36.)
To reduce unnecessary           chlorination       of sewage,
the Congress should amend the Federal                   Water
Pollution       Control   Act Amendments of 1972 to
permit      exceptions     from the national        goal of
swimmable waters         to recognize        those situa-
tions     in which waters are determined              to be
unswimmable        because of other factors,            such
as heavy barge traffic,            cold seasons of
year,     and general      appearance.         (See p. 20.)
GAO requested    written    Agency comments in a
letter  dated January      11, 1977.       Although      sev-
eral meetings    were subsequently         held with
Agency officials      to discuss      GAO's findings        and
recommendations,      the Agency has not submitted
written  comments.       To avoid further        delay,
GAO is issuing    the report       without     an official
Agency expression       of position.


DIGEST                                                                   i
   1      INTRODUCTION                                                   1
              Chlorinated   sewage and other           chlorinated
                discharges                                               1
              Scope of review                                            2
              Agency comments not furnished                              2
              Chlorinated   discharges     are toxic to the
                aquatic   environment                                    3
              Only a small amount of suspected       carcin-
                ogLns in drinking      water are a result
                of sewage chlorination                                   5
   3      UNNECESSARY SEWAGE CHLORINATION                                7
              Value of widespread        sewage chlorination
                for disease      control   is questionable               8
              Chlorination     of sewage is not needed to
                protect    swimmers during      cold weather
                months                                                  13
              Chlorination     is not needed for sewage
                discharges     into waters rarely        used for
                swimming                                                14
              Chlorination     of treated     wastewater     is
                usually    not needed as a backup to
                drinking    water disinfection                          16
              EPA could do more to discourage            unnec-
                essary chlorination                                     18
              Conclusions                                               20
              Recommendations       to the Administrator        of
                EPA                                                     20
              Recommendation      to the Congress                       20
            EFFLUENTS                                                   21
              Sewage chlorination            may be needed to
                protect     shellfish-harvesting               areas
                and when sewage is used for unre-
                stricted     irrigation                                 22
              Chlorine    residuals         in many locations
                are too high for safe discharge                         23
              Though a toxic         pollutant,        chlorine
                residuals      are largely          uncontrolled        25
              Most toxic     chlorine         residuals       can be
                removed                                                 27
CHAPTER                                                                                     Page
                      Improving    plant   effectiveness                  and
                        efficiency     permits     lower              chlorine
                        residuals                                                            28
                      Conclusions                                                            35
                      Recommendations                                                        35

          I   Review of epidemiological   studies   of disease
                transmission  by swimming in polluted     waters                             37

     II       Alternatives              to chlorine          for   sewage disinfec-
                 tion-                                                                       40

 III          List         of suggested            references                                42

     IV       Principal          EPA officials      responsible              for   activ-
                 ities        discussed      in this report                                  48

EPA           Environmental                  Protection      Agency
GAO           General         Accounting            Office
NPDES         National            Pollutant         Discharge      Elimination

ppb           parts         per    billion
ml            milliliter

Anaerobic                 Refers      to life   or processes         that   occur
                          in the      absence   of oxygen.
Baffle                    Any deflective      device used to change the
                          direction     of flow or the velocity   of sew-
Carcinogen                A cancer-producing            substance.
Chlorine       contact    A chamber in a waste treatment         plant   in
chamber                   which effluent   is disinfected      by chlorine
                          before  it is discharged      to receiving
Coliform                  A ‘group     of bacteria       recognized      as an in-
organisms                 dication      of possible        fecal  pollution.
Dechlorination            The partial      or complete    reduction of re-
                          sidual   chlorine      in water by any chemical
                          or physical      treatment.
Dissolved        oxygen   The oxygen dissolved      in water.    Dissolved
                          oxygen is necessary     for the life     of fish
                          and other aquatic    organisms     and for the
                          prevention of offensive      odors.
Effluent                  The wastewater        discharged       by an industry
                          or municipality.
Effluent                  Restrictions       established        by a State or
limitations               EPA on quantities,          rates,      and concentra-
                          tions     of chemical,      physical,       biological,
                          and other constituents             discharged       from
                          point     sources.
Epidemiology              The study       of diseases      as they     affect
Fecal      coliform       A group of organisms        common to the in-
                          testinal   tracts   of man and animals.         The
                          presence   of fecal   coliform    bacteria    in
                          water is an indicator        of possible   fecal
Nonpoint       sources    Sources     of pollution       that are difficult
                          to pinpoint      and measure.        Common exam-
                          ples include       runoff    from agriculture     and
                          forest    lands,      runoff   from mining    and con-
                          struction     activities,        and storm runoff
                          from urban areas.
Nutrients             Elements or compounds essential       as raw
                      materials  for organism    growth and de-
                      velopment;   e.g., carbon,    oxygen,  nitro-
                      gen, and phosphorus.
Pathogenic            Causing   or capable     of causing     disease.
Primary   waste       Treatment     using filtering   and sedimenta-
treatment             tion techniques      to remove about 30 per-
                      cent of oxygen-demanding       wastes.      Sub-
                      stantially     all floating   or settleable
                      solids     are removed.
Secondary    waste    Treatment   using biological    processes   to
treatment             accelerate   the decomposition     of sewage
                      and thereby    reduce oxygen-demanding
                      wastes by 80 to 90 percent.
Suspended    solids   Small particles     of solid pollutants    which
                      are present     in sewage and which resist
                      separation    from the water by conventional
Water quality         Specific  concentrations      of water pollut-
criteria              ants which,   if not exceeded,     are expected
                      to allow a body of water to be suitable
                      for its designated       use.
Water quality         Water quality          standards     contain   four ele-
standards             ments:     the designated           use (such as rec-
                      reation,      drinking       water,   fish and wildlife
                      propagation)         to be made for a body of
                      water;    criteria        to protect     those uses; im-
                      plementation         plans    (for needed water qual-
                      ity improvement           programs);     and a plan of
                                        CHAPTER 1
        The Federal         Water Pollution          Control    Act Amendments of
1972, Public           Law 92-500,      clearly     establishes      the responsibil-
ity of the Environmental                Protection       Agency (EPA) for reducing
and controlling           the pollution         of navigable       waters.    The act
establishes          an interim      national      goal that,      wherever   attain-
able,      water quality         should provide        for the protection        of fish,
shellfish,         and wildlife       and for recreation           in and on the wa-
ter by July 1, 1983.               It also establishes           as national     policy
that the discharge             of toxic     pollutants       be limited     or prohib-
ited and requires            that effluent         standards     be established       for
toxic      pollutants.
        In carrying       out its responsibilities,                 EPA in 1973 in-
cluded a bacterial           limitation      in its definition             of secondary
treatment       of sewage.         EPA had set a limit             on bacterial       dis-
charge because it believed              that discharges             below the limita-
tion would minimize            the spread of disease.                 The attainment
of this limitation,            however,    virtually         required      the use of
chlorine      in most sewage treatment              facilities.          In July 1976
EPA removed the limitation              because of the toxic               effect     of
chlorinated       discharges        on aquatic      life,       its concern       about the
public     health    effects      of chlorinated          organics,      the cost of
chlorine,       and the energy needed to produce                    it.
       Chlorination    of sewage is aimed primarily            at preventing
the transmission     of waterborne      diseases     through    destruction  of
the disease-causing       bacteria    and viruses.       The need for sew-
age chlorination     is not universally         agreed upon by public
health    officials,     Unnecessary    chlorination       wastes energy and
is also expensive.        We estimate     that the cost of the 200,000
tons of chlorine     used for sewage disinfection            in 1976 was
$40 million.
        Chlorine      is also found in industrial                 discharges.          It has
achieved      major importance             as an antifoulant         in electric         power-
plants.       Powerplants         are estimated        to add about 100,000 tons
of chlorine       chemicals        to cooling      water each year to control
slime films.          Such chlorinated           waters are generally             dis-
charged     intermittently.             A variety     of food processing             indus-
tries    also use chlorination               for equipment        cleanup     (slime      con-
trol),    product       wash, and can cooling.               Breweries,       pulp and
paper mills,        and plants        producing      chlorine       may also dis-
charge chlorinated            effluents,        as do industries          using chlo-
rine for cyanide           removal       (for example,       electroplating          plants).

        Although      chlorinated     discharges      have been found to be
extremely       toxic    to fish and other water life,          they occur
widely     throughout        the country    in disinfected     sewage and
other effluents.             In view of the reported       concern over
chlorinated        discharges,      we reviewed     the adverse effects     of
chlorination         and EPA's efforts        to reduce the discharge      of
chlorinated        wastes.
        We made our review at EPA headquarters,                          Washington,      D.C.;
EPA regional        offices        in Seattle,        Washington;        Philadelphia,
Pennsylvania;        and Boston,          Massachusetts;            and at State agencies
responsible       for water quality               in Washington,         Oregon, Maryland,
Pennsylvania,        and California.                We also examined construction
review guidelines             from all EPA regions.                 We sent question-
naires     to the State agencies                responsible         for water quality         in
all 50 States.            In addition,          we sent questionnaires              to about
400 sewage treatment              plants      randomly        selected     from lists     pro-
vided by five geographically                   diverse        EPA regions--Philadel-
phia; Atlanta,          Georgia;       Chicago,       Illinois;        Denver,    Colorado;
and Seattle.         The      response      rate     was    approximately       85   percent.
We interviewed          officials        at the Center for Disease Control,
U.S. Public      Health         Service,      and various         EPA laboratories        as
well as academic and professional                        experts      on sewage chlorina-
tion.      We also obtained            information          on the sewage disinfec-
tion practices          of seven foreign             countries.         During the re-
view, we were assisted                by Dr. Murray Grant,              GAO Medical      Con-
sultant;     Dr. Frank D. Schaumburg,                    Head, Civil       Engineering      De-
partment,     Oregon State University;                     and Dr. Donald T. Lauria,
Associate     Professor          of Water Resources              Engineering      at the
University      of North Carolina.
         On January     11, 1977, we forwarded       a draft     of this report
to EPA and requested          the Agency's   written    comments within        30
days.      Although    we subsequently     met several       times with Agency
officials       to discuss    our findings   and recommendations,         the
Agency has not submitted           written  comments.       To avoid further
delay,     we are issuing       the report  without    an official      Agency
expression       of position.
        Chlorinated       discharges       are extremely      harmful     to creatures
which live       in the water.           Major fish   kills      and significant
water-life       deterioration         have resulted      from chlorinated          dis-
charges.       Such discharges,           even at extremely        low levels,
have been shown to harm fish and other water organisms                            in
various     stages of their         life     cycle.  Sewage chlorination
creates     compounds which are potentially                 carcinogenic,        but
only a small amount of these compounds are found in drinking
-------------------        ---
        Many scientific        studies     have demonstrated            the toxic
effects     of chlorinated        discharges.         Significant         fish   kills
have been caused by such discharges.                     Although       fish gener-
ally    try to avoid chlorinated            discharges,        major fish        kills
have been directly          traced     to chlorinated         sewage, and chlorine
residuals       may have been a principal             factor      in other     fish
kills     ascribed    to sewage effluent.             Fish kills        have also
been caused by chlorine             discharges      from powerplants.             Very
low levels       of chlorine      in sewage discharges              harm fish      repro-
duction      and growth.
        Chlorinated     discharges       have played          a major     role   in the
deterioration        of aquatic     life    in various          bodies    of water in
the United       States   as illustrated       by the         following      examples:
       --Major      fish kills         occurred      in the lower James River in
          Virginia       in 1973 and 1974.               The Virginia     Institute        of
          Marine Science           investigated          the kills     and attributed
          them to chlorine             residuals       from sewage treatment
          plants.        Overall,        5 to 10 million          fish probably       died
          over a 3-week period                in 1973.        The species    affected
          included       bluefish,        striped      bass, weakfish,       and
          menhaden.          Following        a reduction       in the levels       of re-
          sidual      chlorine       in the sewage effluent,             dead fish
          counts dropped           from thousands           to tens within       2 days.
          A similar        experience         occurred      the following       year.      In
          addition,        when the chlorine             was cut back, the oyster
          season was unusually                successful       while other estuaries
          entering       the Chesapeake Bay were no more productive
          than usual.
        --A major fish   kill   due to chlorine   residuals     from sew-
           age treatment  plants     was noted by the California       Fish
           and Game Department     in 1972 in the Sacramento       River

   of California.       Estimated    losses of eggs, larvae,           and
   fingerlings     were in the millions       for salmon,     and in
   the billions     for striped    bass and shad.        Sturgeon      and
   catfish     were also killed.       The California     Fish and
   Game Department      reported   that the fish lost        would
   have been a significant        portion   of the State's       fish-
   ery resources.       For king salmon alone,        the Fish and
   Game Department      estimated    the loss at $1,123,200.
--In      studies       of San Francisco         Bay published            in 1972 and
    1974 (made because of periodic                     fish     kills     and deteri-
    oration       of the fisheries          there),        sanitary       engineering
    researchers          at the University          of California            at Berkeley
    suggested         that chlorine       in wastewaters              may be the
    largest       single    source of toxicity              entering        San Francisco
    Bay.       The researchers         concluded         that chlorinated            sew-
    age, even after           secondary       treatment,          is harmful       to
    aquatic       life.     The tests       demonstrated            impairment       to
    oysters       exposed near plant            outfalls;        and in laboratory
    studies,         baby clams and oysters              experienced         50-percent
   mortality          at chlorine      residuals         less than 5 parts per
    billion        (ppb).     Chlorine      discharges         above 1,000 ppb
    are frequently          found in sewage discharges.
--In     some years pollution               from municipal         waste was the
    leading    cause of fish            kills     in the United        States.
    Five fish kills           in 1974-75 were specifically                  ascribed
    to chlorine        in domestic          sewage.      However, many reports
    of fish    kills      from municipal            operations       have indicated
    that suffocation            from low dissolved             oxygen caused by
    sewage was the immediate                  cause of death.           Studies    of
    research     literature         done by an Assistant              Director     of
    EPA's Duluth,         Minnesota,          Environmental        Research Lab-
    oratory    cited      two studies          published       in 1975 which
    suggested       that,     because chlorine            interferes       with a
    fish"s    ability       to respire,         many fish may have died
    from residual         chlorine        or the combined effects              of sew-
    age and residual            chlorine.
--A 1974 progress          report    prepared   by fisheries        research-
   ers at Oregon State University             reported     that coho
   salmon exposed to only 20 ppb of residual                   chlorine     had
   significantly         impaired    growth.    The illustration         on
   page 6 demonstrates            the effects   of various       levels    of
   residual      chlorine     on the growth of continuously             ex-
   posed coho salmon.
--Chlorine    has been found to affect        the environment          in
   very subtle   ways.     Several   studies,     including     four
   done by Michigan     Department    of Natural       Resources     re-
   searchers   in 1971, reported       long river      reaches down-
   stream rendered     uninhabitable      to many fish due to

           chlorine     residuals      in sewage effluents.            Aquatic
           organisms      in the food chain other than fish may be
           killed     or harmed.       Tests have shown that the high-
           est total      residual     chlorine     concentration         having no
           measurable       chronic    adverse    effect      on an important
           fish    food organism       was 2 to 4 ppb.           A level     of 6 ppb
           is roughly       equivalent       to a quart of laundry           bleach
           in 2 million        gallons     of water.      Chlorine      also in-
           terferes     with the anaerobic          conditions       essential      to
           the normal processes            in a tidal      salt marsh, or swamp,
           and with the reproduction             of some aquatic          animals.
           Chlorinated       organics      may interfere        with chemical       com-
           munications       systems     (for   example,      in the sensing
           which some fish species             use for homing to breeding
----m------.-L-    IN DRINKING       WATER
                                        --- ARE
------          OF SEWAGE
                      -a----- CHLORINATION
       Sewage chlorination          results   in a large number of chlo-
r inated   organics.       In a March 1976 task force            report,     EPA
reported     that some of these organics             are suspected       causes
of cancer.       One such organic--chloroform--was               banned in
foods and in medicinal          and cosmetic       products    in July 1976 by
the Food and Drug Administration.                In a July 1975 report          to
the Congress,       EPA reported       that chloroform      has been found
widely    dispersed     in U.S. drinking        waters.     A study l/ pre-
pared   for EPA reported         that almost all of the chloroform
found in drinking         water appears to have been formed during
the process      of drinking       water chlorination,       rather      than dur-
ing the process       of sewage chlorination.
        Many organics       formed     in sewage chlorination           have not
yet been identified,            and the effects       of most of those which
have been identified            are unknown.        Some scientists       are con-
cerned     with the unknown effects            of these organics         considered
either     individually       or collectively.          Although    sewage chlo-
rination      is a source       of chlorinated       organics     in streams,
fish,    and shellfish,         the major source is industrial              dis-
charges,      especially      from pulp and paper plants.               Runoff of
agricultural        chemicals      (for example,      pesticides      and herbi-
cides)     may also be a source           of chlorinated       organics.

L/"Formation    of Halogenated     Organics    by Chlorination      of Water
   Supplies,"   prepared    by Harvard University       and distributed
   by the National     Technical   Information    Service     of the U.S.
   Department   of Commerce.

                       EFFECT OF RESIDUAL CHLORINE
                       ON GROWTH OF COHO SALMON

COURTESY:        OAK         CREEK        LABORATORY        OF    BIOLOGY.          DEPARTMENT
                                       CHAPTER 3
     The value         of widespread         sewage chlorination           appears     to
be questionable         because:
       --The few       incidents    of disease     transmitted     through
          water in       the United    States   are generally      not serious
          and are      generally    transmitted      through   inadequately
          treated      drinking    water.
       --The effectiveness             of sewage chlorination       varies,           de-
          pending on the           specific  waterborne     disease    agent          in-
       --Sewage disinfection             is not extensively   practiced               in
          other    industrialized          countries with public    health              ex-
          periences      similar       to those in the United    States.
       --Widespread   sewage disinfection                  is a recent      phenomenon
          in this country,  with little                 accompanying       improvement
          in public health.
       --Epidemiological      studies attempting   to relate    bacterial
          levels    in swimming waters with levels    of illness      have
          been inconclusive.
      Specifically,            sewage disinfection           is usually     not    needed
to protect
       --swimmable        waters     in cold       weather    periods,
       --waters       rarely      used for     swimming,      or
       --drinking        water.
        In addition,         chlorine       production         is energy intensive
and a substantial            reduction         in its use would save a signif-
icant     amount of energy.              EPA could do more to discourage                  un-
necessary       sewage chlorination.                  Its virtual      mandating      of
universal       sewage disinfection               in 1973 established           year-round
universal       chlorination          of sewage as a norm of water quality
protection       and, in many instances,                  resulted     in chlorination
of sewage which state officials                      believe      was not necessary.
Although      EPA removed the year-round                    universal    need for sewage
chlorination,          this action         will     probably      not significantly
reduce unnecessary             chlorination          since many States          plan to
continue      year-round         chlorination.            In addition,       EPA water
quality      bacterial       criteria       for swimming waters may effec-
tively     reinstate       universal,          year-round        sewage chlorination

when compliance         with   the   1983 interim      goal    of   swimmable     waters
is required.
        Diseases       with known causes,          for which the Center for
Disease Control,            U.S. Public      Health Service,      has reported
waterborne        incidents,       include    salmonellosis,      shigellosis,
typhoid,      cholera,       hepatitis-A,      amoebic dysentery,         and
giardiasis.          The most common of these diseases,               salmonellosis
and shigellosis,            are both characterized           by abdominal      pain,
diarrhea,       nausea,      and vomiting.        Two other bacterial          dis-
eases, cholera          and typhoid,       are more serious,       but the United
States      averages      less than 430 cases and 8 deaths per year.
from typhoid         fever     (1965-73)    and has had only 1 indigenous
case of cholera           in the last      65 years.
          Most water borne illnesses           are directly   traced  to inade-
quately       disinfected   drinking     water,    not sewage water,    al-
though      the contamination       frequently     originates    from sewage.
        In addition      to inadequately     treated    drinking      water,   in-
gestion    of raw or partially         cooked shellfish        (presumably     from
contaminated       waters)    may play a significant         role in trans-
mission    of viral     hepatitis.       Due to the paucity         of evidence.,
the role of swimming in sewage-polluted               water in the trans-
mission    of illness      has not been conclusively           defined.
       The effectiveness         of sewage chlorination          against   var-
ious organisms       that cause waterborne          diseases    varies,   de-
pending   on the disease         organism    involved.       Sewage chlorina-
tion   is aimed particularly           at bacteria     and has been thought
to be generally        effective     in this regard.         Levels of bac-
teria,   however,      may actually      establish     their   original    numbers
through   regrowth.       L/
        Viruses     are generally    more resistant           than bacteria         to
chlorination,        and they require       a much heavier           dosage and
longer     contact     time.   Secondary      wastewater        treatment      fol-
lowed by chlorination,           as generally       practiced,        will   not re-
duce virus      concentrations      effectively,         particularly        in the
case of the more resistant           viruses       such as those which cause
hepatitis.         Only where plants       provide     tertiary       treatment

L/Report    No. 76-17,      "Wastewater     Disinfection:      The Case
   Against   Chlorination,"       published      in June 1976 by the De-
   partment    of Research and Development             of the Metropolitan
   Sanitary   District      of Greater    Chicago.

 (for example,    high levels     of filtration)     to produce very
clear  affluent     can they achieve       effective   virus    inactiva-
tion.   A relatively      small number of sewage treatment              plants
in the United     States   provide   such tertiary       treatment.
Foreign      disinfection
              ------a----      practices
        The United States appears        to be unique in its exten-
sive year-round      chlorination    of sewage.      Representatives    of
other countries      with public    health   experience    similar   to
ours generally     told us that sewage disinfection           is only rarely
practiced    in their    countries.
         --Officials      from Scandinavian       countries      l/ said that
            sewage disinfection        is rare in their         countries'and
            cited    the harmful    environmental       effects     of chlorine
            as a reason.        The Secretary     of the Embassy of Norway
            said that c'llorine      was not used for disinfection               be-
            cause of the possible         poisonous     effects     on the re-
            ceiving     water body.      The Science Attache          of the Em-
            bassy of Sweden said that chlorine               was not used for
            sewage disinfection        and that it was regarded             as a
            harmful     substance   not to be indiscriminately              dumped
            into the nation's       waters.
         --The Science Attache    of the Embassy of Great Britain
            said that sewage disinfection      is rarely   practiced     in
            Great Britain  and that it is considered       undesirable.
            He said that a study found no beneficial        effects     on
            the Thames River from chlorinating       sewage discharges.
          -The Science Attache       of the West German Embassy said
            that sewage disinfection       is practiced    very rarely      in
            West Germany and that it is considered           unnecessary.
            She said chlorination       is only used in connection         with
            some advanced waste treatment        processes    in which chlo-
            rine is used for its ability        to oxidize    certain     sub-
            stances,  not necessarily      for its disinfectant       proper-
         --The Scientific       Attache    of the Embassy of France stated
            that there is no general          requirement     in France for
            sewage disinfection.         Technicians      may require   disin-
            fection    in particular     instances.       Most such instances
            involve    the protection      of (1) drinking      water sources,
             (2) seaside   resorts,     and (3) shellfish.        A French spe-
            cialist    in sanitary     engineering     told us that less than


l/Denmark,        Norway,   and Sweden.

           2 percent   of the sewage in France is chlorinated                          and
           that requirements    are imposed on a case-by-case                         basis,
           generally   only for the 3 summer months.
       --The Science         Attache    of the Embassy of the Netherlands
          told us that         sewage chlorination    is practiced     only at
          plants that        discharge    near oyster   beds and, during
          the summer,        at several    municipal  sewage treatment
          plants that        discharge    near public   bathing   beaches.
Public     health  statistics       shown on page 11 indicate           that death
rates    for bacterial        and viral    gastrointestinal       diseases   are
similar     in these countries          to rates    in the United States.        It
should be noted that while              the Swedish rate for enteritis          and              *
other diarrhea1        diseases     is one-sixth        that of the United
States,     the Norwegian       rate is almost twice the rate for this
Sewage disinfection            in the     United     States
         Only recently          has wastewater         disinfection         in the United
States       become widespread.              Until    1945 most sewage treatment
plants       practicing       disinfection         belonged       to the U.S. Armed
Forces.         In 1958 about 30 percent                of all wastewater          treatment
facilities         were equipped          for chlorination;           these chlorinating
facilities          served about 38 million              people.        In 1968, 41 per-
cent of all municipal                wastewater       plants      in the United States
were using chlorine               for disinfection.             In mid-1976      our sur-
vey of nearly           400 sewage treatment             plants     showed that 74
percent       of those responding             used chlorine         for disinfection.
The Executive           Secretary       of the Water Pollution             Control      Feder-
ation      explained       that municipalities            probably       were slow in im-
plementing         disinfection         because of the uncertain              health     ben-
efits      of disinfecting           treated      wastes and the cost of chlorine.
Also,      the Chief of EPA's Municipal                  Technology       Branch stated
that States          have had differing            views on the need for disin-
       The Assistant         Director    of the Bacterial     Diseases     Division
of the Center for           Disease Control       told us that there     is no                   c
evidence    that the        substantial     increase   in sewage chlorination
over the last 5 to            10 years has resulted       in any reduction        in
waterborne     diseases.           The Center for Disease Control       has taken
the position       that     disinfection      of sewage produces     few public                  c
health   benefits.
        The GAO medical       consultant    contacted      a variety     of ex-
perts    in epidemiology       and sanitary      engineering.        He found
that there is no unanimity            of opinion     concerning      the desir-
ability      of discontinuing      the chlorination        of sewage efflu-
ents.      On the one hand, the medical           epidemiologists       we con-
tacted     tended to feel that sewage chlorination                is wasteful

    and does not really        contribute     to human health    and well
    being.     On the other hand, public          health engineers   favor
    continuing    chlorination        to ensure reasonably    high water qual-
    ity standards      for recreational       waters.
            In our opinion,          epidemiological       studies  attempting    to
    relate     bacterial      levels     in swimming waters with levels         of
    illness      have been inconclusive.              (For a review of the prin-
    cipal     studies,     see app. I.)          In fact,    a 1952 study by the
    U.S. Public        Health    Service      (see p. 38), suggested       that swim-
    ming in a polluted           river     is no more hazardous       to health   than
    swimming in a chlorinated                swimming pool.
              The Assistant        Director       of the Bacterial          Diseases       Divi-
    sion,     Center for Disease Control,                told us that the risk of a
    swimmer incurring           a bacterial        gastrointestinal           infection        from
    swimming is small.             According       to a Center for Disease Control
    memorandum dated August 20, 1975, and data from volunteer
    typhoid      fever    experiments        i/,   a large       number of infectious
    organisms       must generally         be ingested         to cause a typhoid             or
    other salmonellosis            infection        in a healthy       adult.        The Assist-
    ant Director        told us that the average number of typhoid                            and
    other     salmonella       bacteria       occurring      in the amount of sewage
    water normally          ingested      while swimming is only a fraction                      of
    the infectious         dose (in the absence of raw sewage or fecal
    particles)       and is highly         unlikely      to cause disease.              Although
    the number of infectious               organisms       that would have to be in-
    gested to cause one form of shigellosis                         is quite     low, only
    one outbreak        of swimming-related             shigellosis        (possibly        from
    raw sewage) had been documented                    as of March 1975. 2/
           We could find no justification              for chlorinating       munici-
    pal waste discharges         during    the nonswimming        season (with     the
    exception    of shellfish-harvesting            areas).     Numerous experts
    told us that chlorination            is usually      unnecessary    during    cold
    winter    months when human contact           and the chance of disease
    transmission     from undisinfected         sewage is negligible.
            --The Assistant          Director of the Bacterial                Disease Divi-
               sion, Center        for Disease Control,   said              that there is

    L/A section        entitled, "A Probabilistic                 Model of Bathing   Beach
       Safety,"      in the book The Science               of   the Total  Environment,
    z/From a Center for Disease                 Control    report dated March              18,
       1975, on the transmission                of shigellosis    by swimming              on a
       portion of the Mississippi                River in 1974.

         no public      health      justification        for sewage disinfection
         during     the period        of the year when swimming is not
         likely     . Although         officials       of two States        justified
         chlorination         during      cold winter      months on grounds
         that it is necessary               to protect     hunters,     fishermen,
         and hikers,        the Center for Disease Control                  official
         told us that there is little                  public    health     evidence
         to support       chlorinating          to protect     fishermen        and
         hunters      who may come into casual primary                  contact       with
         waters     receiving       unchlorinated        sewage.
      --A British       sanitary      engineer  teaching   at the University
         of California        told    us that chlorinating     sewage in cold
         weather     to protect       fishermen   from primary   contact   is
      --EPA scientists        and foreign     experts     said that,     in the
         absence of shellfish        harvesting       areas,   other nations
         with similar      levels   of mortality       from gastrointestinal
         diseases   practice      sewage chlorination         near bathing
         beaches,   if at all,      only in the summer months.
      --EPA research          scientists        studying     sewage disinfection
         said that the need for universal                    year-round      sewage
         disinfection         has not been clearly             demonstrated.        In
         addition,      in March 1976, an EPA task force report                       on
         wastewater       disinfection          recommended that disinfec-
         tion not be required             in cold weather           when there is no
         swimming.        The report        cited     favorably      the example of
         communities,         such as New York City,               which chlorinate
         only during        the swimming season.               EPA has reported
         in the Federal          Register       that requiring         a minimum level
         of disinfection          for all wastewater             is of question-
         able benefit         when the possibility             of human contact        with
         the receiving         water is remote.
Even in the absence of shellfish-harvesting              areas,     we found
that many cold weather     States,    including      Alaska,     Michigan,
and Minnesota,   require   continuous      year-round     sewage chlo-
rination,   with no reductions     permitted      during     cold-weather
        Some lakes and streams are unswimmable             for a variety     of
reasons and chlorinating          discharges    into these waters would
still    not make them swimmable.          A public   health     expert  from
the Center for Disease Control            said there is no need to
chlorinate     discharges     into unswimmable      waters    since public
health     is not jeopardized.

         Officials      from several         States    told us that they had many
lakes and streams            that are never used for swimming or for
irrigation          and therefore       they believed        disinfection        was prob-
ably unnecessary.              One Indiana        State official         estimated        that
only 50 of Indiana's              estimated       300 municipal        sewage treatment
plants       (17 percent)       discharge       sewage to waters          used for di-
rect water recreation,               yet 90 percent        of these plants            dis-
 infect     wastes.       An Illinois        State official         estimated       that 80
percent       of all municipal          sewage treatment          plants      in Illinois
discharge         to streams not used for swimming or other                      water
recreation,          but 60 percent        disinfect      wastes.        A New York
State official          estimated       that only 75 of New York's               500 mu-
nicipal       sewage treatment          plants--l5       percent--discharge             to
waters used for swimming,                 but 90 percent         of the plants          dis-
 infect     wastes.
        According   to State officials,   people avoid direct                        water
recreation      in some lakes and streams   for the following                        rea-
       --Man-made      pollution   makes water aesthetically        unswim-
          mable.      (For example,   floating  debris,     algae blooms,
          or high proportions       of sewage discourage        swimming in
          the Spokane River and Long Lake in Washington               State,
          the Trinity       River in Texas, and streams       in Indiana.)
        --Non-point     source pollution   makes water                look unpleas-
           ant for swimming.      (For example,      soil            erosion  reach-
           ing levels    of 20,000 tons a year makes                  the Palouse
           River    in Washington   State unattractive                for swimmers.)
        --Heavy     commercial navigation     prevents safe water rec-
           reation.     (For example,     the Chicago barge canal and
           the Hudson River in New York are unswimmable         for this
        --Stream   water conditions      are such that they do not
           lend themselves    for water recreation.         (For example,
           many streams    in Illinois,     Indiana,    and Texas are too
           narrow or shallow       for swimming,     and in New York many
           are unswimmable    for this     and other reasons,    namely,
           water temperature       and speed of flow.)
        At least   one unit of local         government     has attempted        to
prevent     unnecessary      chlorination      where water (in this case,
the Chicago Sanitary           and Ship Canal) is not used for primary
recreation.       In February        1976 the Metropolitan        Sanitary      Dis-
trict    of Greater     Chicago petitioned        the Illinois      Pollution
Control     Board to grant a sewage treatment              plant   a variance
to the statewide        disinfection      requirement.        Evidence     cited
by the sanitary       district       to support    its petition      included

                             --the     board rules and regulations              which   designate  that
                                 the   Chicago Ship Canal is not             intended    for swimming;
                             --heavy    commercial    use (2 million     tons of freight
                                carried   by ships and barges each month) and its                      nar-
                                row channel,     which make recreational      activities               vir-
                                tually   impossible;
                             --a     lack of historical           evidence   to suggest    that     the
                                   canal is used by the           citizens   for recreational         pur-
                                   poses; and
                             --significant         chlorination       costs in excess      of     $1 million
                                 a year)     without     public     health  benefits.
      In November 1976 the director          of research     and develop-
ment for the sanitary    district       told us that the State board
had denied the variance.        The district      now plans to request
a change in the statewide       disinfection      requirement.
        Most States,   however,  do not adjust   requirements for
disinfection     of wastewater   because of the use of the receiv-
ing stream (if any) or the proximity        of the wastewater   dis-
charge point     to the location   of water use.

        Sewage chlorination       has been supported          on grounds     that
 it is necessary      to protect     (1) raw drinking         water supplies
downstream     from sewage outfalls,          (2) water from private           wells
located    near streams     and rivers,       and (3) drinking       water for
cattle    which use streams and rivers            as a source of water.
We believe,      however,   that there      is an insufficient        public
health    basis to warrant       widespread      chlorination      of treated
sewage for any of these reasons.
        In its July 1976 change in disinfection           requirements,
EPA encouraged     continued      sewage disinfection     to protect      pu.b-
lit   water supplies.       The Center for Disease Control,           however,
has taken the position         that disinfection      of sewage as a backup
to disinfection      of drinking     water has very little        public
health    basis.   The Assistant       Director    of the Bacterial      Dis-
eases Division     of the Center for Disease Control             made the
following     comments concerning       protection    of drinking     water
                             --Sewage disinfection  is generally      not useful   as a
                                means of protecting drinking    water,   since water sup-
                                plies can be much more appropriately       and economically

           disinfected      during  the course of drinking         water
           treatment.       Sewage disinfection       as a preparation      for
           drinking     water treatment      is usually   not cost-benefi-
           cial    because only a small percentage         of diluted      sewage
           water is generally       reused in drinking       water.
        --Available   evidence     suggests    that the drinking      water
           in areas of the United States            where sewage disinfec-
           tion still  is not widely       practiced     carries no more
           risk of disease    transmission        than in other areas.
        --Sewage      disinfection does not provide   an effective
           backup     in cases of drinking water treatment      failure.
       EPA research        scientists      also discounted        the importance
of chlorinating        sewage as a safety          factor    in case of a drink-
ing water chlorination             breakdown.      According      to a professor
of sanitary       engineering        at the Johns Hopkins University,            the
question     as to whether         sewage should be chlorinated           should
be determined       on an individual          basis taking      into consider-
ation    proximity     of the sewage outfall            to the water intake,
the rapidity       of water movement, and the amount of sewage
being deposited.
        Several      public      health    officials        expressed      concern      that
sewage chlorination             was necessary           to protect       owners of wells
close to rivers           that receive         sewage discharges.             According         to
EPA officials,          sanitary       practice       requires      that wastewater          be
disinfected        as an added level             of protection         from source con-
tamination       which might be transmitted                  to these wells.            De-
pending on the quality               of the raw well water,               chlorination
or other treatment             to provide        a potable       supply may be needed.
However,       sewage seepage into drinking                  wells     is unlikely        be-
cause the normal hydraulic                  flow would be in the opposite                   di-
rection      (that    is, toward the river).                 The Assistant          Director
of the Bacterial            Diseases      Divison       of the Center for Disease
Control     'said that there have been a few cases in which a well
near a river         had been polluted             by river      water    because of
unusual      conditions.          However, he said that even in those few
cases,     the answer is not to attempt                   to make the raw river
water drinkable           by disinfecting            sewage.      Instead,       he said it
would be much safer and cost-effective                         for individual          well
owners to chlorinate              their    own well water or, where feasible,
jointly      to build       a (drinking)         water treatment          plant.
        Several  public   health    officials      expressed      a concern with
transmission     of diseases      in human sewage to cattle           who drink
from streams receiving         such sewage.        Two professors       of veter-
inary medicine       at Washington      State University        told us that
such concerns     were invalid      because cattle        generally     are not
subject    to the human diseases          normally    transmitted     through
sewage.      In addition,    they said that there is no scientific

evidence     tracing    animal disease    to sewage in river    water.
Although    cattle    are subject    to tuberculosis     and worm infesta-
tions,   normal sewage chlorination          is not effective   against
the carriers       of these diseases.     l/
---------------------- CHLORINATION
       An EPA report,   "Restoring   the Willamette       River:    costs
and Impacts on Water Quality       Control,"    published     in Septem-
ber 1976, concluded     that post chlorination        of wastewaters
requires   large  amounts of energy and should be better            regu-
lated.    The report  recommended,     among other things,       that
            '* * * Chlorine          production      is highly       energy inten-
            sive and a substantial             reduction       in its use would
            yield    significant        energy savings.           This fact,
            along with chlorine's             counter-productive           instream
            biological       effects     and possible        carcinogenicity,
            clearly      shows the need for further               research.        This
            work should        include    evaluating       the need for bac-
            terial     reduction       as well as evaluating,            alternative
            means by which this reduction                might occur."
        For the Willamette   River Basin,    the study reported
that the energy needed to produce the chlorine          used for dis-
infection     of municipal wastewaters    was equal to between 40
and 50 percent     of the electricity    used to operate    the treat-
ment plants.
       In August 1973, although              EPA was aware of the potential
for harmful    environmental          effects        from chlorinated        dis-
charges   and although       we believe          the public      health    need for
it was tenuous,        EPA virtually         mandated year-round           universal
sewage chlorination.           It did so by defining              secondary       treat-
ment to include        a bacterial        limitation       based on levels          attain-
able in most     facilities        only by disinfection.               Chlorine       (in
one form or another)         was virtually             the only sewage disinfec-
tant available      to meet these bacterial                standards.
       In 1973 an estimated                 2,000 tons of chlorine    was used
for   wastewater treatment                in the Willamette     River Basin.   The
total   annual expenditure                for chlorine    in the 1973-74 period
was $260,000.


l/From      an article     entitled,           "Compatability          of Wastewater  Dis-
    infection      by Chlorination,"'               in the September       1961 issue of
    the ------
           Journal    of the---mm
                                Water        Pollution
                                             -------------_l- Control.   Federation.

       In establishing           bacterial    standards,    EPA stated       that it
considered       disinfection        to be an important       element    of second-
ary treatment,          which is necessary        for protection      of the pub-
lic health.          In our opinion,       the effect    of this action         was
to establish         sewage disinfection         as the norm in the protec-
tion of national           water quality.        The EPA action,      according
to State officials,            resulted    in much unnecessary        chlorina-
tion,    including       that of discharges         into dry stream beds.
        On July 26, 1976, approximately                  3 years after       establish-
ing the requirement,            EPA removed the bacterial              standard       from
its definition          of secondary        treatment.       Now State and local
water quality         standards      are used to determine           disinfection
practices.         State and local          water quality       standards      will
use EPA's water quality              criteria      as a basis for regulating
a plant's      effluent.        This procedure         allows     the States       to
stop some chlorination             if they consider          it unnecessary,          for
example,     discharges       into dry stream beds and discharges                     dur-
ing cold weather.
       The Chief of EPA's Municipal         Technology      Sranch stated
that EPA intended       to have the States      determine       site   specific
requirements     based on water use.        EPA's change in secondary
treatment    standards,    however,    will  probably      have only a lim-
ited impact in reducing        unnecessary    chlorination.           Our sur-
vey of State disinfection        practices    and policies          showed that
25 States    did not plan to reduce chlorination              requirements
even with EPA's change.
        In addition,        EPA's water quality          criteria         dated July 26,
1976, includes        the same low bacterial              levels      (200 fecal         coli-
form per 100 ml.) for swimmable waters.                        No consideration
was given to limiting            the bacteria       criteria        for swimming to
certain     times of the year.            Since Public         Law 92-500 estab-
lishes     as a national       goal that,      wherever        attainable,          all
waters be swimmable,           inclusion      of a bacterial            limitation         in
water quality        criteria      for swimming waters will                essentially
reestablish      universal       year-round      chlorination           of sewage.           An
EPA official       in the Criteria         and Standards           Division        stated
that the current          water quality       standards,         including         bacterial
standards,      do not allow for seasonal               variation,          and this
might have to be changed.
       EPA's criteria        for bacteria         in swimmable waters do not
have a strong     scientific          basis.      The level    of 200 fecal    coli-
form per 100 ml. as a safe level                  for swimming water was
formulated   from a 1952 study which reported                    that swimmers
in a heavily     polluted        river    experienced      somewhat more nausea,
cramps# and diarrhea           than statistically          expected   when com-
pared with swimmers in a chlorinated                  swimming pool.      This
study found no relationship,                 however,   between bacterial

levels     and disease     incidence.      (See p. 38.)     After    reviewing
this     and other   studies,     the National     Academy of Sciences-
National     Academy of Engineering         Committee    on Water Quality
Criteria,      in 1972, refused       to establish     any standards      for
microbial     organisms      in swimming water because of the pau-
city    of evidence.

        There are many reasons           for questioning        the value of
sewage chlorination         as practiced        in the United       States      today.
There are differing         views among experts           concerning       the need
for disinfection,        but it appears that widespread                 year-round
sewage chlorination         is questionable.          Certainly,        in the
absence of shellfish          harvesting       or unrestricted        irrigation,
disinfection       of treated     wastes is usually          not needed to pro-
tect drinking       water supplies         since the water is purified              in
water treatment       plants.      Nor is it usually          needed to protect
swimming waters        in cold weather or to protect               waters rarely
used for swimming.          Chlorine       is energy intensive          and a re-
duction      in its use would save substantial               amounts of energy.
        EPA could do more to discourage             unnecessary    disinfec-
tion.     Because EPA includes          a bacterial    limit    in its water
quality    criteria       for swimming,    many States plan to continue
to require       universal    year-round     sewage disinfection.
       We recommend       that   the   Administrator        EPA:
       --Revise     the Agency's      water quality   criteria    regarding
          the bacteria      standard    for swimming waters to recog-
          nize seasonal      variations     and that he specifically        de-
          lineate     those circumstances      in which sewage chlorina-
          tion    is or is not needed to protect          the public    health.
--------e-e         THE CONGRESS
        To reduce unnecessary       chlorination      of sewage, the Con;
gress should amend the Federal            Water Pollution     Control     Act
of 1972 to permit      exceptions      from the national      goal of swim-
mable waters     to recognize     those situations        in which waters
are determined      to be unswimmable         because of other    factors,
such as heavy barge traffic,           cold seasons of the year, and
general    appearance.

                                        CHAPTER 4
         Although        sewage disinfection         appears     to be needed only
in certain         specific     situations,      such as reducing         disease
transmission           through    raw shellfish       and sewage used for un-
restricted         irrigation,       sewage disinfection           is widely     practiced.
Where sewage chlorination                 is practiced,       levels   of residual
chlorine       are far in excess of levels               found safe to the aquatic
environment,           and frequently,       because of imprecise           testing
procedures,          the levels      being reported        grossly    understate       the
actual      levels       being discharged.
        Public     Law 92-500 calls            for control       of toxic     pollutants,
and chlorine         is a toxic      pollutant        as defined       by the act; how-
ever,     EPA has not listed           residual       chlorine      as a toxic       pollut-
ant requiring          standards     for its discharge.              Other groups,
including       both the U.S. National               Academy of Sciences           and the
European Commission            on Inland         Fisheries,      have strongly         recom-
mended control          of chlorine        residuals.          EPA has taken some
action,     though inadequate            to protect         the aquatic     environment,
to limit      chlorine      residuals        in powerplant        discharges.          In
addition,       several     States     have taken actions            to limit      chlorine
discharges.          Methods of removing             most of the toxicity            of
chlorine      residuals       (dechlorinating)            are available,       though
        Chlorine       toxicity        in receiving      waters      can be avoided
by using other methods of disinfection.                           However,    the prin-
cipal     alternatives,           while    appropriate       under limited       circum-
stances,       all have disadvantages               which make it unlikely            that
any of them will            generally        replace    chlorination        in the near
future     as the principal              means of disinfecting           wastewater.
These alternatives              include      land treatment,         lagoons,    and
disinfection         with ozone, ultraviolet               radiation,       and bromine
chloride.          For further        details      on these alternatives,            see
appendix       II.
        Improving    the efficiency        of the disinfection      process
reduces both dosages and residuals                and thus minimizes      the
toxic     effects  of chlorine        on receiving    waters   and the dis-
charge of potentially           carcinogenic      compounds.    Improved effi-
ciency     can be achieved       by improving      the design of chlorina-
tion facilities,        selecting      more effective     equipment    for the
chlorination      process,      and improv,ing     the quality   of the ef-

        Progress      has been slow, however,     by the States       and EPA in
improving      the disinfection     process    in existing     plants   or in
ensuring     that new construction       provides    for efficient      and
effective      chlorination.
        The chlorination             of sewage may be of significant                      value in
reducing        disease      transmission         through    consumption           of raw shell-
fish grown in fecally                 contaminated       water.       In the process           of
feeding,        shellfish,         such as oysters         and clams,       filter        and re-
tain harmful           bacteria       and viruses;       in doing soI they concen-
trate      these bacterial            and viral      pathogens      in their         flesh.
Shellfish         grow in coastal          waters,      and nearly       all shellfish
waters       are subject         to some degree of pollution.                    In the past,
when typhoid           fever was more prevalent,               consumption          of raw
shellfish         was associated          with the transmission             of that
disease.          The last       such case in the United              States       occurred      in
1939.        In the United States,              no outbreaks       of salmonellosis             or
shigellosis          have been traced           to the consumption             of raw shell-
fish     in the last         10 years.        Chlorination        of sewage discharges
into shellfish-harvesting                  areas may therefore            have helped con-
trol    transmission           of bacterial        diseases     in shellfish.
        Infectious    hepatitis    continues      to be associated       with in-
gestion      of raw or partially     cooked shellfish.            The effective-
ness of sewage chlorination           in killing       the hepatitis     virus    is
not known with certainty.           The virus       that is presumed to cause
hepatitis       has never been isolated,          Viruses    are generally       more
resistant       than bacteria    to chlorination,         and the hepatitis
virus     appears to be among the more resistant              viruses.
     Fruits   and vegetables     growing     in infected     soil    can be-
come contaminated    with pathogenic        bacteria,     and these bacteria
may survive   for periods    from a few days to several            weeks or
more in the soil.      However, pathogens          are seldom detected       on
farm produce unless     the plant      samples are grossly        contaminated
with sewage or have fecal       particles      clinging    to them.
       The National         Academy of Sciences-National              Academy of Engi-
neering     Committee        on Water Quality       Criteria,     after      reviewing
the dangers of parasitic              worms and other organisms              not effec-
tively    destroyed        by sewage treatment         or chlorination,           stated
in its 1972 Water Quality               Criteria    that it is good practice
to restrict       irrigation       with sewage water to crops that are
adequately      processed       before     sale and to crops that are not
used for human consumption.                  For unrestricted       irrigation,
for example,        on fresh     fruits      and vegetables,      the 1972 Water

Quality        Criteria  indicated      that      wastewater   should    receive
primary        and secondary     treatment        and adequate   chlorination.
        Very low concentrations       of chlorine         residuals     are toxic
to aquatic      life.   Based on scientific         research,       experts--both
foreign     and American--   have developed       the following         residual
chlorine     standards   to safeguard     aquatic      life:
          --The European Inland       Fisheries     Advisory     Commission    has
             recommended,   as criteria       to protect     European fresh-
             water fish species,      residual    chlorine     ranging    from
             4 to 121 ppb, depending        on temperature       and acidity/
             alkalinity   of the water.
          --Various   U.S. scientists     have developed     residual
             chlorine  criteria    for freshwater    aquatic     life.     These
             criteria  run from 2 to 20 ppb for continuous             discharge
             and from 40 to 200 ppb for intermittent           discharge.
          --The National       Academy of Sciences-National          Academy of
             Engineering     Committee       on Water Quality    in its fresh-
             water aquatic       life   criteria     recommended a maximum
             residual    chlorine      concentration      of 3 ppb for contin-
             uous discharge         and 50 ppb for intermittent       chlorination
             of up to 30 minutes          in any 24-hour period.
           --Fifteen      States have established             maximum residual
              chlorine     effluent      standards      for at least       some waste-
              water discharges.            Some States       and local     areas have
              established       maximum residual          standards     for all chlori-
              nated discharges.            For example,       in the area of San
              Francisco      Bay, all sewage dischargers              are required      to
              reduce chlorine         residuals     virtually       to zero because
              of the toxic       effects     of chlorine,        according      to an
              official     of the regional         water quality        control    board.
           During our review,         however,     we noted that wastewater
effluent        often contains        residual     concentrations many times
higher       than the levels         mentioned     above that are considered
safe.        For example:
           --Research     scientists      have observed  total  residual
              chlorine    values of      5,170 ppb in treatment    plant

         effluent     in central     Illinois l/,      over 10,000 ppb in
         southern    Wisconsin     A/, and up-to       7,000 ppb in Cali-
         fornia.    2/
      --Ten waste treatment        plants     in the Tualatin         River
         Basin in Oregon reported           annual average chlorine
         residuals    in treatment      effluents      ranging     from 1,300
         to 3,400 ppb, with most of the values                 around 2,000
         wb.      Peak chlorine    residuals      during     the year were
         much higher.
      --In    our national      survey of sewage plant     disinfection
          practices,    we found that over 30 percent          reported   an
          average chlorine       residual  for 1975 at or above 1,000
          ppb in their     effluents.     About 27 percent       reported   a
          peak measurement       for the year between 2,000 and
          5,000 ppb, with about 8 percent        reporting       even higher
          peak measurements.
       In addition      to being excessive,        the reported     residuals
frequently      understated      the actual   level   of chlorine      residual
in the discharge.           There are two principal       causes of such
understatement:          (1) widespread     use of an inadequate         measur-
ing method and (2) not sampling             when chlorine     residuals
are likely      to be high.
Inadequate    measuring     method
        The most common means of measuring         residual     chlorine      in
wastewater      is the orthotolidine      method.    Using this method,
orthotolidine        is added to a sample and the resulting           color
is compared to a color          standard  chart.   This method is sub-
ject    to interferences,       and it tends to understate       the pres-
ence of chlorine.         Orthotolidine    measurements     generally     re-
port about one-half         of the actual   amount of chlorine        3/,

L/From a paper by W. A. Brungs entitled,       "Effects    of Waste-               t
   water Chlorination  on Freshwater   Aquatic    Life"   presented,
   at the annual meeting   of the Water Pollution       Control   Fed-
   eration  in October  1975.
/Mentioned    in a November 1, 1974,           transcript      of proceedings
  of the California   Regional Water           Quality      Control  Board.
g/From an article        by C. M. Robson, B. S. Hyatt,   Jr.,  and
   S. K. Banerji      entitled,  "We Must Improve Chlorination
   Design,"     in the September   1975 issue of Water and Wastes

and they have reported   as low as one-sixth        L/ of the residual
chlorine   measured by more sophisticated       methods.     In our
survey of sewage treatment    plants,     however,   we found that
76 percent   were still using the orthotolidine         method.
Inadequate      testing     of chlorine          residuals
        Although      chlorine     residuals   are monitored        regularly      by
most treatment         plants    using chlorine,     many plants        in our
survey reported          that they did not test during            the early
morning      hours (prior      to 7 a.m.) when, we were told,               condi-
tions    of low flow and demand and, thus,               high residuals         tend
to predominate.            The differences     of chlorine      residuals       in
tests     taken at times of low flow and tests               taken during
periods      of high flow can be substantial.               An authority        on
wastewater       disinfection        said that in early      morning      hours
 (e.g.,     5 a.m.) chlorine         residuals   from small plants          may
run as high as 22,000 ppb.
         Public    Law 92-500 established            a national       policy     against
discharge       of toxic      pollutants       in poisonous'amounts.             Sec-
tion     502 of the act defines             "toxic   pollutant"       as a pollutant
which will       cause death,         disease,     or physiological          malfunc-
tions     after    assimilation         into any organism          (human, fish,      etc.).
As demonstrated         in chapter         2, residual      chlorine     fits    this
definition        and it is being discharged              in excessive        amounts.
       Section     307 of the act requires          the Administrator         of
EPA to publish        a list   of toxic   pollutants       and to set effluent
standards      for them.      In June 1976 EPA published          a list      of 65
toxic    substances     proposed    for control,       but final    effluent
standards     have not been established           for any of these sub-
stances.      The Chief of EPA's Criteria             Branch explained        that
elemental     chlorine      was not included      in the list     of 65 sub-
stances    because it does not persist            in the aquatic        environ-
ment.     Scientists      are concerned,     however,      that when chlorine
is mixed with sewage or cooling            waters      it may form toxic         com-
pounds such as chloroform.

L/From a paper by Thomas E. Harr, entitled,           "Residual     Chlo-
   rine in Wastewater       Effluents Resulting   from Disinfection,"
   -.Technical   Paper No. 38, prepared    by the Environmental       Qual-
    ity Research Unit of the New York State Department            of
   Environmental      Conservation.

        Research results      presented    at the Conference         on the
Environmental       Impact of Water Chlorination           in October     1975,
indicated     that five of the EPA listed          toxic     substances    can
be created      by mixing    chlorine   with sewage or powerplant
cooling    waters.       Two of these substances        were included      on
an EPA priority        list  of toxic   substances      for which "no
effective     threshold     dose can yet be established."
        The National           Academy of Sciences             classified       substances
as "highly       toxic"        to aquatic      life     when a concentration             of
10,000 ppb will           kill      half a test population               within   96 hours.
The extreme        toxicity         of chlorine       is best illustrated,             there-
fore,    by research           which found that a level                 of 10 ppb killed
67 percent      of a population             of brook trout            in 96 hours.       &/
The harmful        effects        of chlorine       discharges          on salmon,
menhaden, and shrimp have already                       been illustrated          earlier
in this    report.          EPA has stated          that effects          on economically
important      species,          such as trout,         salmon,      menhaden, and
shrimp,    are properly             considered      in the development             of a pro-
tective    criterion           level    for toxic       pollutants.
           Others also contend         that chlorine      discharges    are a
serious        problem and that        chlorine    residuals     should be con-
           --The Assistant       Director for Water Quality      Criteria
              at EPA's Environmental      Research Laboratory,        Duluth,
              Minnesota,     said that one might hypothesize        that
              chlorine     as a pesticide   should be registered        just
              like    other pesticides.
           --Water     Quality   Criteria-1972,        a report     prepared    by the
              National     Academy of Sciences-National             Academy of Engi-
              neering    Committee      on Water Quality       Criteria,     under EPA
              contract      and approved by EPA for publication,              listed
              chlorine      among toxic     substances.
       The Chief of EPA's Standards         and Criteria      Development
Branch,   Water Supply Division,       said the feeling        at EPA was
that to classify      chlorine   as a pollutant      would be "illogi-
cal"   so long as it is still      needed as a disinfectant.            The
Assistant    Director    of EPA's Effluent      Guidelines     Division
said that he does not believe        chlorine     is toxic     enough to
be so classified      under Public   Law 92-500.         He told us that

L/From an article     by William   A. Brungs entitled,    "Effects    of
   Residual Chlorine    on Aquatic   Life"  in the October     1973 issue
   of the Journal    of the Water Pollution    Control  Federation.

EPA does not plan to control                 chlorine        discharges     from     sewage
plants  or other industries.
        While EPA sets no limits              on residual          chlorine       in ef-
fluents       from sewage treatment           plants       and other       industrial
effluents,        in October      1974 it limited           chlorine       discharges
in powerplant         effluents.         The maximum limit            was set at 500
ppb of free residual             chlorine,      and the average limit               was 200
ppb of free residual             chlorine.        In setting        its standard,          EPA
noted the large quantities                 of chlorine        added annually          to
waters      from powerplant         discharges.         In contrast          to the na-
tional      standard,      an EPA region        III    official       told us that re-
gion III has set a maximum 200 ppb total                         of residual         chlo-
rine    (free     and combined chlorine)             for powerplants            in its re-
        In contrast,       EPA has not set a maximum standard                for
the levels     of chlorine       in discharges        from sewage treatment
plants,    which collectively            use an estimated     200,000      tons L/,
about twice as much chlorine                as powerplants.    2/    When EPA
proposed    the powerplant         standards,     comments were received
from powerplant        officials       that sewage treatment        plants       were
not similarly        controlled      in their    chlorine   discharges.
         Means are available           to remove most chlorine              residuals
and the hazards         associated         with them.        The addition        of sul-
fur dioxide       to wastewater          is the most common dechlorination
method.       It increases        the cost of chlorination               by an esti-
mated 20 to 30 percent.                Addition      of sulfur      dioxide     may
reduce the level          of dissolved         oxygen,     but an EPA Research
Microbiologist         said that reaeration              would not be needed
except     in the case of gross overdosing                   with sulfur       dioxide.
Other chemicals         may also be used as dechlorinating                     agents.
In addition,        dechlorination          with activated        carbonp      a physi-
cal filtering        process,       not only alleviates           the problem of
toxicity      associated      with chlorine           but it also may remove
some of the potentially              toxic     chlorinated       organics.         However,

L/From an article      entitled,  "Toxicity                  of Wastewater         Disinfect-
   ants,"    in the July 5, 1974, issue                 of     the EPA News        of En-
   vironmental     Research in Cincinnati.
z/From a paper entitled,     "Effects     of Wastewater    and Cooling
   Water Chlorination    on Aquatic    Life,"  presented     at the
   Washington   State Department     of Ecology Disinfection       Seminar
   on May 26, 1976.

the costs of dechlorination     using activated    carbon are 13 to
20 times the cost of dechlorination      with sulfur     dioxide.
Where sufficient   land is available,    holding   chlorinated
sewage in a pond or lagoon prior      to discharge    substantially
reduces residual   chlorine and its effects.
       Improving    the quality    of sewage effluent     reduces   the
levels   of chlorine    needed for good disinfection         and thus
reduces the toxicity      of the sewage effluent.        The quality
of sewage effluent      can be improved     by (1) providing      a higher                    c
level   of treatment    and (2) improving     the operation      and main-
tenance of the treatment        facility.
        Many sewage treatment       plants    use too much chlorine           and
have high chlorine        residuals    because of inefficient          chlorina-
tion systems.        Even in designs      for new plants,     elements        of
efficient    chlorination       are often overlooked.        We believe
State and EPA emphasis on improving             chlorination     efficiency
has been inadequate.
Need to improve treatment
effectiveness  and efficiency
        In primary      treatment,        solids      are screened       out and re-
moved by settling.             Secondary       treatment       removes more solid
material      and uses bacteria           to break down the organic              matter.
By reducing       the chlorine-demanding                material     and the bacteria
levels     in sewage, it is easier               to obtain       good disinfection
with lower chlorine            residuals.          Also,    the amount of chlori-
nated organics        is reduced.           EPA has estimated          that 40 to 50
percent      of municipal        dischargers        will    achieve    secondary     treat-
ment by 1977.         In addition,          the EPA Administrator             has pointed
out that projects           to be completed           by 1978 will       handle the
wastes from approximately               80 percent        of the population.           As
additional      treatment        plants     are brought        up to secondary       treat-
ment, effective         disinfection          with less chlorine          will   be pos-
sible.                                                                                        c

       Good plant       operation        also reduces the chlorine           needed
for effective       disinfection.            Operation    and maintenance           prob-
lems which adversely             affect     water quality      are widespread          in
wastewater     treatment        plants.       An EPA report       published       in
September     1976 reported           that overapplication         of chlorine
was noted at plants            in the Willamette         Basin,    and a large
savings    of resources          could be realized        by proper      surveillance
of chlorine      use.


         Our recent       report     on the "Continuing            Need for Improved
Operation       and Maintenance           of Municipal        Waste Treatment            Plants,"
B-166506,       April     11, 1977, stated           that many municipalities                 are
not\efficiently           operating       their    wastewater       treatment         facil-
ities     at designed        pollution-removal           levels.       The basic causes
of operation          and maintenance          problems     include      excessive         flows
of water from nonsewer sources,                    inadequate       laboratory         con-
trols,      lack of sufficient            numbers of qualified             staff,      design
deficiencies,          inadequate        budgets,      and industrial         wastes which
upset treatment           processes.         Another     recent     report,       "Improve-
ment Needed in Operating                 and Maintaining         Waste Water Treat-
ment Plants,"          June 18, 1976, B-166506,               stated     that,      of the
Department       of Defense waste treatment                 plants     examined,         50 per-
cent were understaffed               and that there was a need for addi-
tional      operator      training.         The two reports         included        a number
of recommendations             for improving         the operation         and mainte-
nance of treatment             plants.
Need to      improve     chlorination         efficiency
        Because most plants      do not vary the amounts of chlorine
in proportion     to the flow of wastewater,       they use excessive
amounts of chlorine.        In addition,    most plants  use extra
chlorine     to compensate    for contact   times which are too short
and/or    for poor initial     mixing.
        Flow-proportional           dosage      adjustment
       A procedural          manual for evaluating           the performance           of
wastewater        treatment      plants,     prepared    under EPA contract              and
published       in 1972, states          that all chlorination            equipment
used to disinfect            wastewater      effluent    should at least           provide
for chlorine         dosages which are proportionate                 to the effluent
flow.      If dosage adjustment             must be done manually,             a dosage
set to achieve          adequate disinfection           at higher       flows,     unless
manually      reset,      overchlorinates         at lower flows.          Amounts and
concentrations          of sewage vary substantially              throughout         the
day,    and   a   California       Department      of  Health    official       told     us a
chlorinator         set to dispense         a dosage producing          a 1,000 ppb
residual      at peak flow may produce a residual                   many times
higher     at low flow.
        In our survey of about 400 sewage treatment                plants     from
five EPA regions,       more than 82 percent        of the plants         using
chlorine     reported   they still      adjusted   chlorine    doses man-
ually,    and less than 23 percent          of the plants    that adjusted
manually     were staffed     continuously.       About 33 percent          of the
plants    that adjusted      manually    did not adjust     daily.        In some
cases chlorination        rates appear to be set in periods               of
high flow (winter)        and are not adjusted        downward as dry
weather     approaches.

          Contact     times

        Increasing        contact      time   between sewage and chlorine
permits      disinfection          with less chlorine        residuals.         The May
1974 California           Interim      Manual for Wastewater           Chlorination
and Dechlorination             Practices,      written    by nationally         known
disinfection         experts,       and an EPA technical          bulletin      published
in July 1974, both recommended a contact                       time between the
sewage and the chlorine                of at least      30 minutes       at peak flow.
If the contact          time     is shorter      than this,      even for a portion
of the sewage, an unnecessarily                    high amount of chlorine            is
needed for good disinfection,                  and in some cases good disin-
fection      cannot be achieved             in spite    of high residuals.
        In our survey of sewage plants,         43 percent        of those
practicing    chlorination       were not designed      to provide      even
30 minutes    contact      time.   The actual   contact     time for the
portion    of the sewage that passes through            the system fastest
is generally     far less than the theoretical            contact    time.

         Researchers      have recommended a minimum 4O:l length-to-
width ratio         for the contact         chamber to allow for adequate
contact     times.      Baffling        may permit        a poorly   designed    rec-
tangular      chamber to attain           this     ratio.      Many basins,    however,
have length-to-width             ratios     of 2:l or less and extremely              in-
adequate      baffling.        (See pictures           on pp. 32 and 33.)       An
official      of the California           Water Resources          Control   Board
told us that in many plants                 baffles       could be added quickly
and cheaply         to improve contact           times.

       Actual  chlorine  contact  times can be measured by dye-
tests,   with minimum times being measured by the time it
takes for the first     dye to pass through    the contact     chamber.
In our survey of sewage treatment       plants   using chlorine,     54
percent    had never conducted   such a test,    and another     30 per-
cent did not know if such tests       had ever been conducted.
Initial      mixing
         Rapid and thorough          initial      mixing       of wastewater       with
chlorine      is needed for efficient              chlorination.          To achieve
good initial       mixing,      it is necessary            to apply chlorine          in
conditions       of turbulent        flow or by mechanical             mixing.        How-
ever, specialists           in sewage treatment              told us it is common
practice      for the chlorine           solution      to be applied        directly
to chlorine       contact      basins or to open channels.                  More than
two-thirds       of the plants         we studied        had no special        device--
hydraulic       or mechanical--        to provide        rapid mixing       of chlorine
and wastewater.           An official        of the Maryland          State Water
Resources       Administration         told us that existing             chlorination
facilities       can be modified           by adding mechanical           mixers      to im-
prove initial        mixing..

Lack of State          and EPA emphasis
on chlorination          efficiencv
          Neither       EPA nor the States          have effectively         used the
National         Pollution     Discharge        Elimination     System (NPDES) pro-
gram to improve the efficiency                     of existing     chlorination      fa-
cilities.           In addition,        neither      EPA nor the States         have ade-
quately        reviewed     plans and specifications             for new construc-
tion of chlorination              facilities         to ensure chlorination         effi-
        An official        of EPA's Municipal          Permits     Section      said that
EPA could include           requirements      for specific         equipment       in
NPDES permits          but it avoids doing so because of the problem
of liability         if the equipment        does not achieve           the desired
objective.         In a recent      report    entitled,        "Continuing       Need
for Improved Operation             and Maintenance         of Municipal         Waste
Treatments       Plants,"      B-166506,     April     11, 1977, we recommended
using the NPDES pollutant              discharge       permits     to require        spe-
cific    actions       at existing     plants      that would help improve
plant    operation        and maintenance       (for example,         installing
selected      instrumentation).           A similar       approach      could be used
to improve the existing             plants    chlorination         practices.
        In our survey of State policies               and practices,     less than
12 percent       of the States       said they required        rapid mixing      de-
vices--hydraulic         or mechanical --as a permit          condition.        Less
than 16 percent        said they required          automatic     dosage control
for sewage treatment           plants.     Only about 40 percent         required
adequate     contact     times,     and, of these,      only 2 out of 18 re-
quired    as much as 30 minutes           at peak flow.       No States     re-
ported    that they required           dye testing     of minimum contact
times,    and less than 10 percent            required     a minimum length-to
width ratio        for the contact       chamber.
        EPA's review of plans and specifications                             for new chlo-
rination      facilities         is inadequate.              Our review        of 20 sewage
treatment       plant      designs       approved       in EPA region          III    (Philadel-
phia),     from     July    1,   1974,     through        December      31,    1975,     indi-
cated the lack of review for elements                           of efficient          chlorina-
tion.      Of the 20 plants,              designs       for 3 were approved without
automatic       dosage adjustment             of chlorine.            Only 4 of the 20
plant    designs       provided        for even a contact             time of 30 min-
utes at peak flow.               Ten had a contact              time of 15 minutes,
and six had a contact                time of less than 15 minutes.                       None
met the 40~1 length-to-width                     ratio;      rather,      they ranged from
1:l to 33:l.            Seven of the 20 plant                designs     provided        for the
addition      of chlorine          inside      the chlorine          contact       chamber
without      mechanical        mixing.        According         to EPA engineers,              ini-
tial    mixing      was accomplished             by turbulence          of the wastewater
as it entered           the chlorine         contact       tank.      At the insistence






of a State director                 concerned with the adequacy of mixing,
plans for an eighth                 facility, originally   designed   to include
an in-tank diffuser,                 were amended to include    mechanical
       An EPA technical       bulletin       recommended that the chlorine
be rapidly    and thoroughly         mixed with the wastewater,prior            to
its entering     the chlorine        contact     chamber l/,    and experts
have stated    that mixing       inside      the contact-chamber     should be
avoided.   2/    For these reasons,            we concluded   that the designs
for the seven facilities           would not ensure a sufficiently
rapid and thorough      initial        mixing    of chlorine    and wastewater.

        In EPA region        I (Boston),      we reviewed     plans and specifi-
cations    for 15 wastewater          treatment     plants'approved          between
July 1, 1974, and December 31, 1974.                   In eight      cases, mixing
was effected        by the natural       turbulence     of the wastewater           as
 it flowed across a chlorine             diffuser.       Two of the plants
lacked    automatic       dosage control,        and 11 of them provided            less
than 30 minutes          contact   time at peak design          flow.     Length-to-
width ratios        for the 14 plants         having chlorine        contact     tanks
generally      fell    far short of the desired           4O:l ratio.         Seven
provided     less than 20:1, and three of these provided                      less
than 1O:l.
        We examined construction          review guidelines     from all EPA
regions      included     in our review and found little        evidence    of
EPA concern with minimizing            chlorine     residuals  by efficient
chlorination        except in Seattle       (region    X) and Kansas City
(region      VII).     Region X has published        design guidelines
which,     in part,     require  that
           --chlorine  contact   tanks be sized to provide                  each mole-
              cule of water with an actual    contact time                 of not less
              than 30 minutes  at peak flow;
           --the    actual      contact   time be verified      by dye testing    or
               an equivalent        method during  start-up      of the disinfec-
               tion facilities;
           --hydraulic       or mechanical rapid-mix          facilities      be de-
              signed     ahead of the contact    tanks        or basins;      and

-l/A      technical      bulletin      entitled, "Protection of Shellfish
       Waters,"     published        in July 1974 by the EPA Office    of Water
       Program Operations.
z/Reported    in the           support   for a full-scale      study of waste-
   water disinfection              by a California      Department   of Health
   Senior Sanitary             Engineer.

        --automatic        dosage      adjustment        be used for         larger     plants.
        For new construction,         only about 43 percent            of the
States     require     a special   mixing     device--hydraulic          or mechan-
ical-- to ensure good initial            mixing.       Only slightly        more than
40 percent       require   automatic     dosage control         in new construc-
tion.      While nearly      all States     require     a minimum contact
time at peak flow,         only eight     States     require      at least      a
contact      time of 30 minutes       at peak flows.           Only 3 States
require      dye testing     to assure actual        minimum contact          times
prior    to acceptance       of new construction,          and only 21--about
43 percent--       require   any specific      length-to-width         ratio.
         In February      1976 EPA published           a handbook of procedures
for the construction             grants     program.      The handbook contains
a recommended checklist               for the review of treatment             facility
plans and specifications.                 The checklist       contains     a section
on chlorination         facilities        but it does not specify           acceptable
design or equipment             requirements,        such as rapid,      thorough
 initial    mixing     and flow-proportional             dosage adjustment;           nor
does the checklist            refer     to EPA technical       bulletins      that
contain     guidelines        for regional         and State personnel        in re-
viewing     construction          grant projects.         A manual of design           and
practice     for wastewater           chlorination       systems is also being
developed      by the State of California                for the EPA Office           of
Research and Development.
        Sewage chlorination                may be needed in certain                specific
circumstances.            When it is practiced,                 however,      residual       chlo-
rine is generally             discharged         far in excess of levels               safe to
aquatic     life.       Unnecessary           use of chlorine           contributes         to
energy sources          being unnecessarily                reduced since extensive
amounts of energy are needed to produce chlorine.                                   Although
chlorine       residuals        are clearly         toxic,      improved      sewage treat-
ment and more efficient                  chlorination          would allow disinfection
with lower chlorine               residuals.          However, EPA and the States
have generally           failed       to use NPDES permits              to require       sewage
treatment        plants      to use specific           pieces of equipment             which
would significantly               improve chlorination              efficiency.           In re-
viewing     plans and specifications                   for new construction,                EPA
and the States          have also generally                failed     to require       effi-
cient    chlorination           facilities.
        We recommend          that    the   Administrator,           EPA:
        --When      disinfection         is deemed necessary      for the protec-
           tion     of the public          health, include   chlorine    residual

   limitations           in   all   NPDES permits      for    sewage treatment
   plants       and for       all   industrial    dischargers       of chlori-
   nated      effluents.

--Lower      the limitation           on chlorine        residuals        in   power-
    plant    effluents.

--Require        regional      offices       or the States,         where   appro-
   priate,       to tailor       NPDES permits        to assure        the use of
   chlorine        testing     and operating         equipment        which   would
   significantly           improve      chlorination       efficiency       at in-
   dividual        treatment       plants.

--Incorporate          efficient          chlorination        factors,        such as
    rapid,     thorough,         initial       mixing     and   flow-proportional
    dosage     adjustment,           into    construction         review      criteria
    for    all   new plant         construction.

    APPENDIX I                                                                       APPENDIX I
                       REVIEW OF EPIDEMIOLOGICAL                  STUDIES OF
                          DISEASE TRANSMISSION BY SWIMMING
                                      IN POLLUTED WATERS
             Epidemiological          studies      attempting         to demonstrate           the
    differences          in bacterial       levels      in bathing        waters       to levels
    of illness         in swimmers have been inconclusive.                         A cause-and-
    effect      relationship,         at the bacterial            levels      typically        found
    in the United          States     today,     is questionable            considering          the
    amount of swimming done by the American public,                                the number
    of polluted          beaches and old swimming holes,                    and the insig-
    nificant       number of illnesses             related      to water contact.                Mar-
    ginal      beaches and areas used by bathers                      despite      high bac-
    terial      levels     have had an extremely              favorable         epidemiolog-
    ical     record.       The few studies           conducted        on bathing         water
    quality       and health      have been, at best,               inconclusive.
            In    a 1961 study 1/ of salt water beaches on Long Island
    Sound,       New York, no relationship       between illness      and water
    quality       was observed.    A 5-year     British    study l/ came to a
    similar       conclusion,   namely,    that unless there were large
    visible       amounts of human waste in the water,           there was lit-
    tle risk       to the health   of bathers       in salt water.
           A 1951 study at two Chicago beaches 2/ found a generally
    lower ratio       of swimmer illness               to nonswimmer illness               preva-
    lent   at the poorer           quality        beach.       In addition,        the percentage
    of illnesses       reported        as gastrointestinal                was smaller        at the
    poorer    quality       beach.        Illness      data were analyzed              in various
    ways in an attempt             to correlate          illness       with exposure         to bath-
    ing waters of varying              bacterial         densities.         Only one method
    of analysis       offered        any suggestion            of a positive         result--evi-
    dence of a higher           illness         incidence        following     3 days of swim-
    ming in high bacterial               density       waters compared to 3 days of
    swimming in low bacterial                  density       waters.       Additional        analy-
    sis,   however,       tended to refute             the suggestion          of a relation-
    ship between bacterial                (coliform)         levels      and disease.

.   L/Reported      in Water Quality             Criteria   1972, a report   of the
       Committee      on Water Quality            Criteria,    National Academy of
       Sciences-National      Academy            of Engineering.
    z/"A Study of Bathing    Water Quality   on the Chicago Lake Front
       and Its Relation  to Health   of Bathers,"      Public   Health Serv-
       ice Environmental   Health  Center,  Cincinnati,       Ohio.

APPENDIX I                                                                APPENDIX I

      A 1952 study 1/ compared              the incidence    of disease   among
persons  swimming iz a heavily              polluted   river  and persons
swimming in a well-chlorinated                swimming pool and found that:
       (a)   The group that did most of its                swimming in the chlo-
             rinated  swimming pool apparently               had the greatest
             number of illnesses.
       (b)   There was no correlation    between the bacterial                     qual-
             ity of the river   water and the general   illness                    inci-
             dence experienced    by the bathers.
       (c)   Pool swimmers showed a tendency       to have more ill-
             ness of nongastrointestinal      types (i.e.,    eye, ear,
             nose, throat,   and skin)   than did river    swimmers.
       (d)   River swimmers showed a statistically              significant
             tendency     to have more gastrointestinal           illness   than
             pool swimmers,        although   the number of gastrointes-
             tinal   illnesses       reported   by river    swimmers was only
             53 in over 3,700 swimmer-days,              13 more than statis-
             tically     expected.
       A 1974 study 2/ of illnesses                 related    to two bathing
beaches-- a relatively           unpolluted       beach and a barely           accept-
able beach-- found that the rate of subsequent                       vomiting,      diar-
rhea, and stomach ache was significantly                     higher     among swim-
mers (4.2 percent)          relative      to nonswimmers         (2.6 percent)         at
the barely      acceptable       beach but not at the relatively                  unpol-
luted    beach (3.9 vs. 3.5 percent).                   This overall      finding     was
highly    dependent     on illnesses          experienced      by children        under
age 10 --unusually        high both for swimmers on the barely                     ac-
ceptable     beach and for nonswimmers                on the relatively         unpol-
luted    beach.     Other data suggested              that,  within     the range
studied,     ocean water quality            is not related         to rates of swim-
mer illness:
       (a)   The rate of swimmer gastronintestinal                   illness     at the
             barely  acceptable beach (4.2 percent)                  was not

L/"A Study of Bathing        Water Quality    on the Ohio River at Day-
   ton,  Kentucky,     and Its   Relation  to  Health of Bathers,"      Pub-
   lic Health    Service   Environmental     Health  Center, Cincinnati,                    .
Z/A draft    paper on the Relationship       of Microbial      Indicators
   to Health   Effects  at Marine Bathing        Beaches,    EPA Health
   Effects   Research Laboratory,     Cincinnati,      Ohio.

APPENDIX    I                                                          APPENDIX      I

            substantially         different     from that at the relatively
            unpolluted       beach (3.9 percent)           for persons     over
            age 9; the rate at the relatively                  unpolluted     beach
            (4.2 percent)         was actually       higher    than that at the
            barely     acceptable         beach (3.7 percent)        in spite    of
            the fact that the barely              acceptable      beach was imme-
            diately      adjacent       to a beach posted as unsafe for
            swimming,       and the data suggested            an immediate      source
            of raw fecal        wastes.
      (b)   For persons over age 9, the gastrointestinal                  illness
            rate associated     with swimming (i.e.,        swimmer rate
            minus nonswimmer rate)        on the relatively         unpolluted
            beach (1.0 percent)       was actually    higher      than that on
            the barely    acceptable     beach (0.8 percent);         for per-
            sons over age 19, the gastrointestinal             illness        rate
            associated    with swimming on the relatively             unpolluted
            beach (1.3 percent)       was nearly   twice as great            as that
            on the barely     acceptable     beach (0.7 percent).
      (c)   Ethnic     differences       may account       for the unusually       high
            rate of illness          associated      with swimming,      for chil-
            dren under 10, at the barely                acceptable     beach.    The
            Latin Americans          in the study experienced           much higher
            swimming-associated            illness    rates,     were more likely
            to swim than non-Latins,               and constituted      a much
            higher     percentage       of the beach population          at the
            barely     acceptable       beach (54 percent)         than at the
            relatively        unpolluted       beach (20 percent).

APPENDIX II                                                                APPENDIX II
       Land application        frequently       provides      an effective     way
to remove harmful        bacteria     and viruses        (and other pollutants)
from wastewater.         In addition,        nutrients      in wastewater      enrich
the land.      Treated     sewage is used for irrigation                of crops,
pasture    lands,    orchards,     and vineyards;         and for watering
parks,   golf courses,       freeway      landscapes,       and forests.       There
are, however,      disadvantages        which limit       the applicability         of
land treatment:
       --Local  conditions   have a major               effect    on applicability
          and economic feasibilty.
       --Each land application            site generally    requires      a design
          produced   specifically         for it to preclude      serious     ad-
          verse environmental           impacts;  such designs     frequently
          require  input     from      a number of specialized       profes-
       --Harmful     bacteria      may survive   for periods    of a few days
          to several     weeks or more in the soil          and crops,       and it
          may be transmitted          when spray irrigation      is used.        Ac-
          cording    to several       experts,  when chlorine      disinfection
          is practiced      prior     to land treatment,     the effects        of
          the chlorine       residual     on the soil    are not known.
       --Irrigation        of pasture   lands and of crops which are
           consumed raw may subject          animals and humans to worm
            infestations.       The eggs or intermediate    forms of the
           organisms      are resistant    to both sewage treatment  proc-
           esses and chlorination.
        There are over 5,000 wastewater                  treatment       ponds in the
United     States       representing        about 25 percent         of all wastewater
treatment       facilities        and 90 percent        of the facilities           in com-
munities      under 5,000 people.              Well designed         wastewater
lagoons      can reach disinfection              standards      without     chlorination
prior    to discharge          but they cannot normally             meet suspended
solids     standards        consistently.          Most facilities         could be
economically          upgraded     to meet suspended          solids     standards.
They require          large tracts        of land,    however,       and the cost of
land for evaporation              ponds is not an eligible              cost for Fed-
eral construction            grants.       Most lagoons       are, therefore,          con-
structed      in areas where land is readily                  available.

APPENDIX II                                                                APPENDIX II
        Ozone has received             the most attention         as a disinfectant
alternative         to chlorine.          Ozone has been used for 60 years
to treat       drinking      water supplies          in Europe and Canada.             Its
use in wastewater            applications         has been generally          limited      to
pilot     plant     studies.       Ozonated effluents           appear to be less
toxic     than chlorinated           effluents       to aquatic     life.       Ozonation
is also effective            against      viruses.      In order to be an effec-
tive disinfectant,            however,        ozone requires      a highly       treated
effluent        (beyond secondary           treatment)     at all times and/or
very high doses of ozone.                   Even without      the cost of the addi-
tional      treatment      or high dosage,          ozonation     costs considerably
more than chlorination/dechlorination                      and its production            con-
sumes considerably            more energy than chlorine                production.         As
with chlorine,          toxic    compounds may be formed from reaction
of ozone with organics.
--pm        RADIAT-ION
        Ultraviolet       radiation    has seen limited      use in wastewater
disinfection.          It is not toxic        to the aquatic    environment,
but it is more         expensive    than chlorine,     and, for adequate
disinfection,         a high quality      effluent   (beyond secondary       treat-
ment) must be         provided.
--      CHLORIDE
        Bromine chloride,           at an equal dosage with chlorine,                   will
provide       comparable     bacterial       disinf.ection        and better      viral
disinfection.          Brominated      effluent         may be as toxic         as chlori-
nated effluent,          but its residual            toxicity     is much shorter-
lived.        Existing    chlorination         facilities        would require       only
minor modifications           to convert         from chlorine         to bromine chlo-
ride.      The cost may be considerably                   higher    than that of chlo-
rine,     however,     and the toxicity            of brominated         organic    com-
pounds is generally           greater      than that of the corresponding
chlorine       compounds.

APPENDIX III                                                              APPENDIX III
                        LIST OF SUGGESTED REFERENCES
Ad Hoc Study Group, "A Report Assessment            of Health    Risk from
  Organics    in Drinking      Water,"   Science  Advisory   Board, U.S.
  Environmental     Protection      Agency, April   30, 1975.
American Water Works Association,                "Water Chlorination     Prin-
  ciples and Practices,"  American               Water Works Asociation,       New
  York, 1973.
Benenson, Abram S, (ed.)p   Control    of Communicable    Diseases
  in Man, 12th ed., American    Public   Health Association,      1975.
Blogoslawski,         Walter J. and Mary Elizabeth             Stewart,       Marine
   Applications        of Ozone Water Treatment.
Brungs,   William       A., "Effects     of Residual        Chlorine    on Aquatic
   Life,"  Journal       Water Pollution     Control        Federation,    Washing-
   ton, D.C.
Brungs,     William     A., "Effects      of Wastewater  and Cooling  Water
   Chlorination        on Aquatic    Life,"   Program Element lBA608.
Brungs,   William    A.,     "Effects     of Wastewater        Chlorination        on
   Freshwater     Aquatic     Lifee"     October  1975.
Bureau of     Sanitary      Engineering,      State of California         Depart-
  ment of     Public      Health,     "Wastewater       Chlorination   for Public
  Health     Protection,"         Proceedings     Fifth     Annual Sanitary    Engi-
  neering     Symposium, May, 1970.
Cabelli,    Victor     J., Alfred       P. Dufour,      Morris    A. Levin,
  Leland J. McCabe, Paul W. Haberman,                   "Relationship        of Micro-
  bial   Indicators       to Health       Effects    At Marine Bathing
  Beaches,"      Health     Effects     Research Laboratory           Cincinnati,
  U.S. Environmental           Protection       Agency,   Rhode Island,          Center
  for Policy       Research,      New York.
Cabelli,     Victor      J. and Leland J. McCabe,           "Recreational Water
  Quality     Criteria,"      News of Environmental           Research in Cin-
  cinnati,      U.S. Environmental     Protection           Agency, November 11,
Cabelli,    Victor   J., Harriet     Kennedy, and Morris             A. Levin,
  "Pseudomonas      Aeruginosa-fecal        coliform      relationships        in
  estuarine      and fresh recreational          waterslm      Journal   of the
  Water Pollution       Control    Federation,       vol.    48, no, 2, Feb-
  ruary 1976,

APPENDIX III                                                           APPENDIX III
Cabelli,     V.J.,  M.A. Levin,      A.P. Dufourp    and J.J.  McCabe,
  "The Development       of Criteria      for Recreational    Waters,"   U.S.
  Environmental      Protection      Agency,   Recreational   Water Cri-
  teria    Program,    National    Environmental     Research Center,
  Cincinnati,      Ohio 1975.
California       State Water    Resources    Control        Board,  "Long Term
  Effects      of Toxicants     and Biostimulants           on the Waters of
  Central      San Francisco     Bay," Publication           no. 51, 1974.
Chambers,      Cecil W., "Chlorination     for         Control    of Bacteria           and
  Viruses      In Treatment  Plant Effluents,'             Journal,   February
Collins,    Harvey F. and David G. Deaner,        "Sewage Chlorination
  Versus Toxicity-A         Dilemma?"  Journal  of the Environmental
  Engineering     Division,      December 1973.
Collins,      Harvey F., George C. White,           and Endel Sepp, "Interim
  Manual      for Wastewater   Chlorination         and Dechlorination    Prac-
  tices,"       the State Water Resources          Control Board, California,
Cookson,      John T.,   Jr.,   "Virus    and Water        Supply,"     December
Coordinating Council    for Vocational   Education, Division    of
  Vocational Education,     "Waste Water Plant Operators     Manual,"
  State of Washington.
Gulp, Russell     L., "Breakpoint         Chlorination         for    Virus   Inacti-
  vation,'    Journal,   December        1974.

Gulp, Russell      L.I "Virus      and Bacteria          Removal in Advanced
  Wastewater      Treatment,"      Public  Works         for June 1971.
Deanp Robert B., "Toxicity     of Wastewater                Disinfectants,"     News
  of Environmental    Research   in Cincinnati,                U.S. Environmental
  Protection   Agency, July 5, 1974.
Deaner,      David G., "Chlorine      Contact    Chamber Study at Redding
  Sewage      Treatment     Plant,"  Bureau of Sanitary     Engineering,
  State      of California      - Human Relations    Agency, Department   of
  Public      Health,     1970.
Department     of the Army Corps of Engineers,    'Assessment      of the
  Effectiveness      and Effects of Land Disposal    Methodologies      of
  Wastewater     Managementpn Wastewater  Management Report 72-1,
  January     1972.

APPENDIX III                                                              APPENDIX III
Earampamoorthy,     Sinnadurai,    and Raymond S. Koff,                    "Health
  Hazards of Bivalve-Mollusk        Ingestion," Annals                   of Internal
  Medicine   83:107-110,     1975.
Esvelt,     Larry A., Warren J. Kaufman, Robert E. Selleck,
  "Toxicity      Assessment  of Treated    Municipal      Wastewaters,"  pre-
  sented at the 44th Annual Conference            of the Water Pollution
  Control      Federation,  San Francisco,    California,       October 4-8,
Esvelt,   Larry A., ------
                       Toxicity    Removal From Municipal  Wastewaters,
  Volume IV of a Study o~-ToxiSity-ana-sios~i~~~~i~insan
  Francisco    Bay-Delta     Waters for the State Water Resources                        r
  Control   Board Under Standard       Agreement No. 260809, Octo-
  ber 1971.

Fugs,     G. Wolfgang,  "A Probablistic Model of Bathing    Beach
  Safety,     "The Science of the Total  Environment,   Elsevier  Sci-
  entific     P~~i~~ns-~mpany,Amsterdam,-----
  Coastal          Edwin E.,
                  Bathing     Microbiological
                          Wat-~-y-------"-----~--T---   Criteria     Concepts     for
  ---------~-----                      Elsevier       Scientific     Publishing
  Company, Amsterdam,          Ocean Management,              3 (1974-75)     225-248.
Genetelli,       Emil J.,    B.A. Lubetkin,          and J.   Cirello,      Chlorina-
  tion      of
  ------------- Wastewater    Effluents         A
                                   --y----v------ Critical    Review.
Harr,  Thomas E.,        "Residual      Chlorine     in Wastewater    Effluents
  Resulting   from       Disinfection,"        Environmental    Quality     Research
  Unit Technical         Paper No. 38, March 1975.
Harvard    University,     "Formation     of Halogenated           Organics       by
  Chlorination        of Water Supplies,"     March 26,           1975.
Heukelekian,    H. and S.D. Faust,     "Compatibility        of Wastewater
  Disinfection    by Chlorination,"     presented      at the Annual Meet-
  ing of the Pennsylvania        Water Pollution      Control   Association
  in University    Park, Pa., on August 10-12,           1960.
Huff,   E. Scott,      "Diligent       Chlorination      Practices      Yield     Mul-
  tiple   Savings,"       Water
                         --------_I- & Sewage     Works,  July    1976.
Huggett,        Robert J., and Michael      E. Bender,   Investigations
  of    Two    Estuarine       Fish
  -------~--------_uI-----~~~~--~-~ Kills Caused by  ChlEiri?ie    ResiauaTs.
Ingols,   Robert S., "Chlorination    of Water-Potable,                     Possibly:
   Wastewater,   No! ," -------m-e---
                        Water & Sewage Works, February                      1975.
Jolley,      Robert L. (ed.),      Proceedings      of the Conference    on the
    Environmental       Impact of Water Chlorination,          Oak Ridge Na-
    tional    Laboratory,     Energy Research and Development          Adminis-
    tration,    U.S. Environmental       Protection      Agency, July 1976.

     APPENDIX III                                                   APPENDIX III

    Lewis,  Ronald R. and John M. Smith,           "Upgrading     Existing
      Lagoons,"   National     Environmental      Research    Center,     Advanced
      Waste Treatment      Research Laboratory,        Office   of Research
      and Development,      Cincinnati,      Ohio, October     1973.
    Lue-Hing,     Cecil,    Bart T. Lynam, David R. Zenz, "Wastewater
      Disinfection:         The Case Against     Chlorination,"    The Metro-
      politan      Sanitary   District  of Greater      Chicago,  Department
      of Research and Development,           report    no. 76-17, June 1976.
    Martens,    D.W. and J.A. Servizi,   "Dechlorination       of Municipal
      Sewage Using Sulfur     Dioxide,"  Progress     Report No. 32, In-
      ternational    Pacific  Salmon Fisheries     Commission,    Canada,
    McCarthy,    Jeremiah    J., and Cecil   H. Smith,  "A Review of Ozone
      and Its    Application     to Domestic Wastewater   Treatment,"
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    Middlebrooks,    E. Joe, Donna H. Falkenborg,      Ronald R. Lewis,
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       Proceeding,   November 1974.
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      Ohio, 1951.

APPENDIX III                                                   APPENDIX III
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  March 1972.                                                                     *
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  May 1974.                                                                       6

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  of Selected   Chronic  Digestive      Conditions,    United States-
  July-December   1968," publication        no. (HRA) 74-1510,     series
  10, no. 83, September 1973.
U.S. Department    of Health,   Education, and Welfare,    Reported
  Morbidity  and Mortality    In the United States    1974, vol.    23,
  no. 53, Center for Disease Control,      Public  Health Service,
  Atlanta,  Georgia,   for year ending December 28, 1974.
U.S. Environmental     Protection     Agency,   "Disinfection       of Waste-
  water,"   task force report,       General  Services      Administration,
  Denver,   EPA-430/g-75-012,       March 1976.
u-s.   Environmental    Protection     Agency,  "Fish Kills   Caused By
  Pollution     In 1972,"   Thirteenth    Annual Report,    Government
  Printing     Office,  EPA-440/g-73-001.
U.S. Environmental    Protection     Agency,  "Fish Kills   Caused By
  Pollution   In 1973,"   Fourteenth    Annual Report,    Government
  Printing   Office,  EPA-440/g-75-003.
U.S. Environmental      Protection     Agency,    "Land Treatment   of Mu-
  nicipal   Wastewater     Effluents,"    Case Histories,      EPA Technol-
  ogy Transfer     Seminar Publication,        January   1976.

APPENDIX III                                                        APPENDIX III
U.S. Environmental      Protection        Agency,   "Land Treatment    of
  Municipal   Wastewater      Effluents,"       Design Factors-I,     EPA
  Technology   Transfer     Seminar Publication,         January    1976.
U.S. Environmental      Protection       Agency,   "Land Treatment    of
  Municipal   Wastewater     Effluents,"       Design Factors-II,     EPA
  Technology   Transfer     Seminar Publication,        January    1976.
U.S. Environmental       Protection      Agency,    "Preliminary      Assessment
  of Suspected     Carcinogens        in Drinking    Water,"     An Interim
  Report to the Congress,           June 1975.
U.S. Environmental        Protection     Agency,  "Preliminary              Draft      Qual-
   ity Criteria    tar    Water,"    October   10, 1975.
U.S. Environmental      Protection     Agency,    Process         Design       Manual
  for Upgrading    Existing      Wastewater    Treatment          Plants,       "Dis-
  infection   and Odor Control,"        ch. 9.
U.S. Environmental   Protection   Agency,           "Protection        of      Shellfish
  Waters,"   July 1974 EPA 430/g-74-010.
U.S. Environmental     Protection        Agency,    "The   Economies           of     Clean
  Water-1973,"     December 1973.
Weibel,    S.R.,   F.R. Dixon,   R.B. Weidner,    and L.J. McCabe,
  '-'Waterborne-Disease     Outbreaks,  1946-60,"    A paper presented                         on
  Nov. 1, 1962, at the Ohio Section         Meeting,   Cincinnati,
Wheeland,     Hoyt A. and B.G. Thompson, "Fisheries         of the United
  States,     1974," United   States  Department      of Commerce, Na-
  tional     Oceanic and Atmospheric     Administration,     National
  Marine     Fisheries Service,    Washington,     D.C., March 1975.
World     Health Statistics Annual - 1972, vol. 1, Vital                       Sta-
tistics     and Causes of Death, world Health Organization,                           1975.

APPENDIX IV                                                           APPEDIX IV

                          PRINCIPAL    EPA OFFICIALS
                        RESPONSIBLE FOR ACTIVITIES
                          DISCUSSED IN THIS REPORT
                                                        Tenure   of office
                                                        From                 -To
    Douglas M. Costle                           Mar.      1977       Present
    John R. Quarles,        Jr.
        (acting)                                Jan.      1977      Mar.           1977
    Russell      E. Train                       Sept.     1973      Jan.           1977
    John R. Quarles,        Jr.
        (acting)                                Aug.      1973      Sept.          1973
    Robert W. Fri (acting)                      Apr.      1973      Aug.           1973
    William      D. Ruckelshaus                 Dec.      1970      Apr.           1973
     Thomas C. Jorling                          June      1977       Present
     Dr. Andrew Breidenback                     Sept.     1975       June    1977
     James L. Agee                              Apr.      1974       Sept. 1975
     Roger Strelow    (acting)
        (note a)                                Feb.      1974      Apr.           1974
     Robert L. Sansom (note a)                  Apr.      1972      Feb.           1974
    John T. Rhett                  Mar.                   1973      Present
    Louis De Camp (acting)         Sept.                  1972      Mar.    1973
    Eugene T. Jensen               June                   1971      Sept. 1972
a/Before     April   22, 1974,    the title    of this position   was
   Assistant      Administrator     for Air   and Water Programs.


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