Ask the Scholar
Document scope · 1 page
Scholar
Ask about this object, its catalog metadata, its source description, or the page inventory.
For page-specific OCR and visual context, open one of the page chats.
Source Description
Records pertain to the Office of Science and Technology Policy.
Scholar Source Context
Document identity
localId
285791893
label
Environment - Boston Harbor [1989]
core
doc
dtoType
document
citationUrl
pageCount
1
Source metadata
id
285791893
contentType
document
title
Environment - Boston Harbor [1989]
description
Records pertain to the Office of Science and Technology Policy.
citationUrl
identifierLocal
62052-004
collections
Records of the White House Office of Science and Technology (George H. W. Bush Administration)
Allan D. Bromley Files
largeImageUrl
imageCount
1
hasImages
yes
source
import
hasTranscription
no
Source extras
naId
285791893
levelOfDescription
fileUnit
recordType
description
ocrSource
nara-archive
Single page context
seq
1
pageIndex
0
type
document
mediaId
ec7dda70d72559be
ocrText
Originally Processed With FOIA(s):
FOIA Number:
2005-0336-F
2005-0336-F
FOIA
MARKER
This is not a textual record. This is used as an
administrative marker by the George Bush Presidential
Library Staff.
Record Group/Collection:
George H.W. Bush Presidential Records
Collection/Office of Origin:
Science and Technology Policy, Office of (OSTP)
Series:
Bromley, D. Allan, Files
Subseries:
Global Climate Change Files
OA/ID Number:
62052
Folder ID Number:
62052-004
Folder Title:
Environment - Boston Harbor [1989]
Stack:
Row:
Section:
Shelf:
Position:
0
0
0
0
THE WHITE HOUSE
WASHINGTON
August 3, 1989
MEMORANDUM FOR JOHN H. SUNUNU
DaByon
FROM:
D. ALLAN BROMLEY
SUBJECT:
BOSTON HARBOR
Although I am certainly not an expert in the areas involved
here, I have checked with a variety of people whom I trust.
The consensus appears to be this:
a) Donald Harleman, whose paper you sent me, is a very
reputable individual and very highly respected.
b) Those in a position to know believe that Harleman is
correct in his evaluation of the current Boston Harbor
situation.
c) Secondary treatment is apparently inappropriate for
Boston and for ocean water generally; it was developed
for inland waters where the biochemical oxygen demand
problem is a very real consideration.
d) Secondary treatment is expensive and would be
particularly so in Boston Harbor because considerable
real estate is required and construction for the Boston
plant would require moving of an existing prison on
Deer Island.
e) Secondary treatment is, in fact, irrelevant to the
outstanding problem, following primary treatment,
namely the removal of toxic wastes. This was not
fully recognized when the EPA made the original rulings
regarding secondary treatment for Boston. It clearly
must be addressed and this is recognized in Boston; but
secondary treatment won't do anything for it.
f) Secondary treatment in Boston will exacerbate an already
onerous sludge problem to no great benefit.
g) The funding now earmarked for secondary treatment in
Boston, in any rational scheme should be devoted to
rectifying the combined sewer overflow problem which is
resulting in the frequent dumping of substantial raw
sewage into the harbor.
h) In short, the EPA requirement for the secondary
treatment appears to me as an example of rather
mindless enforcement of a questionable decision made
in 1983 -- a decision that has even less justification
now than it might have had when originally made.
i) The question is -- can we do anything directly with
EPA? or do we need to pull together a small group of
experts to provide us with the detailed scientific and
technical backup for Harleman's paper before we can take
action?
j) Apparently a group at NOAA including Drs. Andrew
Robertson, Thomas O'Connor and Douglas Wolfe has been
working on ocean pollution for a number of years and
would qualify as experts I think. I tracked them down
through Dr. Nancy Maynard of NASA -- Goddard whom I
intend to appoint as my OSTP Assistant Director for
Environmental Science.
k) If we were to put together a small group of experts I
would try to get the following persons:
(i)
Dr. Edward Goldberg
Scripps Institution of Oceanography
(ii)
Dr. Roger Revelle
Scripps Institution of Oceanography
(iii) Dr. Lawrence Roessner
Camp, Dresser and McKee
Maitland, Florida
(v)
Dr. Norman Brooks
California Institute of Technology
1) It turns out that the National Academy of Sciences is
undertaking a very closely related study and I am
attaching, hereto, a copy of the proposal for that
study that has been provided by NAS.
m) I would welcome an opportunity to discuss this matter
with you.
Attachment
08/03/89 09 42
202 334 2620
CETS
€012
NATIONAL RESEARCH COUNCIL
WATER SCIENCE AND TECHNOLOGY BOARD
2101 Consitution Avenue Mashington. 20 20418
(202) 334-3422
August 3. 1989
MEMORANDUM VIA FAX
TO:
Dr. D. Allan Bromley (395-3261)
Dr. Nancy Maynard (286-2717)
FROM:
Stephon D. Parker
SUBJECT: Issues in Constal Wastewater Management
Per Nancy's request, attached is a prospectus describing a study for
which the Water Science and Technology Board is currently seeking support from
the U.S.E.P.A. and others. I have a huge file of background material and would
be pleased to provide more Information Please let me know how we can help.
Attachment
John:
Ra knows whatharpened
to the NAS for machine
buttles The but can
The moment.
As
08/03/89
09:19
202 334 2620
NRC CETS
002
DRAFT #3 7/25/89
NATIONAL ACADEMY OF SCIENCES/NATIONAL ACADEMY OF ENGINEERING
NATIONAL RESEARCH COUNCIL
COMMISSION ON ENGINEERING AND TECHNICAL SYSTEMS
WATER SCIENCE AND TECHNOLOGY BOARD
Proposal No.
for a Study of Opportunities to
Improve Wastewater Management for Urban Goastal Areas
This proposal 1 $ submitted by the National Academy of Sciences, which assumes
full technical and financial responsibility under its Act of Incorporation for
the work to be carried out under any resultant agreement
Contract Adtinistration
Program Administration
Gary E. Dwoskin. Director
Stephen D. Parker. Director
Office of Contracts and Grants
Water Science and Technology Board
National Academy of Sciences
National Research Council
Telephone: 202/334-2888
Telephone: 202/334-3422
JULY 1989
DRAFT #3 7/25/89
LIMITED USE DOCUMENT--NOT FOR PUBLICATION OR ATTRIBUTION-This document is only for the information and use of recipients
in furthering the work of National Research Council committees of which they are members or with which they are working
08/03/89
09:43
202 334 2620
NRC CETS
£014
NATIONAL ACADEMY OF SCIENCES/NATIONAL ACADEMY OF ENGINEERING
NATIONAL RESEARCH COUNCIL
COMMISSION ON ENGINEERING AND TECHNICAL SYSTEMS
WATER SCIENCE AND TECHNOLOGY BOARD
Opportunities to Improve Wastewater Management for Urban Coastal Areas
SUMMARY
The Water Science and Technology Board (WSTB) of the National Research
Council (NRC) proposes to undertake an assessment of opportunities to improve
wastewater management for urban coastal areas. The study will be carried out
by a multi-disciplinary committee of approximately 15members and take 30
months. The committee will meet scveral times to acquire information.
deliberate on issues, and produce a report. The report will have a broad
audience, including legislators, federal and state regulatory authorities,
dischargers, consultants, industry, planners, academia, and public interest
groups. It is expected that the report will serve to help assure and increase
the scientific basis, innovation, environmental effectiveness from a multimedia
perspective, flexibility, and cost-effectiveness of policies and practices
portinent to coastal wastewater management in urban areas. Estimated expenses
for this activity are $450,000, of which $X00,000 is requested from the U.S.
Environmental Protection Agency/National Science Foundation
BACKGROUND
At present the Federal Water Pollution Control Act requires coastal
communities to provide full secondary treatment of municipal and industrial
wastewaters and prohibits ocean disposal of sludge, a by.product of treatment.
Though an amendment to the Aet allows dischargers to apply for 4 waiver of che
required level of treatment, in accordance with EPA's interpretation of the
law. few significant waivers have ever been granted by the U.S. EPA.
08/03/89
09:37
1202 334 2620
NRC CETS
€003
-2-
Experiences with disposal of primary effluents and sludges with low levels of
toxic compounds present have demonstrated to the satisfaction of some that the
coastal ocean often has considerable capacity to assimilate such organic
wastes and that suitable management strategies to reduce toxics, such as
pretreatment (source control). primary treatment. and long outfalls with
diffusers, can provide for disposal with minimum environmental risk. Such
experiences suggest that flexibility in the law and its interpretation might be
justified on scientific, technological. and economic bases.
The WSTB first considered this issue at its August 18.19, 1988 meeting
when if was briefed about plans for wastewater management for the Boston, MA
metropolitan area. Boston provides a current example of the complex issues
being faced by water resource managers, because the city is proceeding to plan
a multibillion dollar disposal system (including secondary treatment). in spite
of serious reservations by some experts concerning the effectiveness and
environmental efficiency of this approach compared to its costs. For example.
It has been claimed that the funds necessary to provide secondary treatment
would produce far greater benefits if used to address 8 serious combined sever
overflow problem. (The cost of providing secondary treatment is great and, at
the same time, federal grants for construction of wastewater treatment plants
are no longer available.)
Discussion of the Boston example was illuminating ar.d suggested the value
of a generic evaluation of the scientific. technological. and economic bases
for wastewater management for urban coastal areas. In an effort to expand on
the perspectives of its membership, on April 19. 1989 the WSTB hosted a special
one-day planning session involving about 20 experts from a variety of
organizations and with special expertise relevant to wastewater management in
marine envirorments.
08/03/89
09:37
202 334 2620
NRC CETS
0004
:-
The planning session concluded that such & generic study would be both
Valuable and timely. Because the nation stands to make considerable future
investment in coastal area wastewater facilities, related policies should be
flexible and scientifically-based. Such policies could: balance costs and
environmental benefits, consider the full range of media involved (i.e., land,
air, coastal, inland water bodies), and be flexible to account for regional
conditions and new information regarding system performance. X
Whether because they have failed to modernize their sewage systems,
Identified new pollution problems. or outgrown the capacity of their current
systems, coastal urban centers around the country. and in fact the world- face
the same need to set priorities for Wastewater management and choose
technologies that are most appropriate for long.term conditions. The
experience gained in science and engineering during the past two decades since
passage of the Clean Water Act in 1972 provides the nation the opportunity to
open new horizons in the decision making process. The study will be limited to
"coastal discharges." It will not address wastewater discharging to
freshwater. saline bays or estuaries.
The study should help in the development of needed waste management
strategies for the future that maximize innovative, flexible, and
cost-effective options for coastal environments. The results of the study
should be useful to legislators and regulators at the federal and state levels,
the municipalities. and the public. as well as the research and engineering
community professionally involved In coastal pollution control. The proposed
study is appropriate at this time because of experience gained in recent years,
the availability of better cools to assess and manage risk, and the fact that
governments at all levels are faced with difficult allocations of scarce
financial resources.
08/03/89 09:38 $202 334 2620
NRC NRC_CETS CETS
2005
PROPOSED PLAN OF ACTION
This study will be carried out by an appointed. multi-disciplinary
committee of approximately 15 experts from & variety of specialties such as
environmental engineering. civil engineering, oceanography. marine biology.
toxics reduction, ecology. economics, public policy, social science, and law.
Committee members will be chosen so as to assure a flexible view of their
charge and to provide an over-all balance to the committee. They will meet
approximately eight times to acquire information, deliberate on issues. and
wrice their report.
The agends for this study is long. but many parts have been studied
previously. What will be different about this study is the objective of
integrating a great deal of diverse multidisciplinary information to recommend
a clear sense of direction and logical priorities and alternatives for managing
coastal water quality. The committee will undertake a review of numerous
issues grouped into three categories. Those found to be useful to the primary
purposes of the study will be included in the committee's final report. The
committee will:
Environmental Objectives Policies and Regulations
(1) Review the existing literature (including previous NRC reports). focusing
on forward-looking documents. and provide an overview of the technical and
policy objectives and problems related to wastewater management in coastal
environments.
(2) Assess the effectiveness of various regulatory approaches (e.g.,
technology-based, water quality standards feedback from observed
ecosystem effects. phased variances) for safely protecting the quality of
the coastal ocean.
(3) Evaluate current (and proposed) criteria for (a) water quality. and (b)
sediment quality for various classes of pollutants. Consideration will be
given to general issues of adequacy of toxicity evaluations (acute and
chronic). bioaccumulation. health, and ecological effects. This will
LIMITED USE DOCUMENT-NOT FOR PUBLICATION OR ATTRIBUTION -This document is only for the information and use of recipients
ID furthering the work of National Research Council committees of which they are members or with which they are working
08/03/89
09:38
202 334 2620
NRC CETS
2006
include assessment of the effects of long.term genotoxic discharges on the
ecosystem. (Note: This will not be pollutant-by-pollutant evaluation of
numbers, but a general assessment of the process.)
(4) Assess the criteria for controlling undesirable biostimulation due to
nutrient discharge and the extent of the problem for coastal waters
(5) Identify and assess approaches to risk-assessment procedures for coastal
water and sediment contamination.
(6) Assess the seriousness of combined sewer overflows, storm drain
discharges. and other non-point sources: suggest effective regulatory
approaches.
(7) Determine the adequacy and utility of monitoring of the water column,
ecoaystems, and bottom sediments for providing needed foodback to decision
makers. Evaluate the importance (In terms of resource allocation) of
monitoring vs. other activities (research, source control, etc.).
(8) Evaluate regional-scale assessment techniques that incorporate all loading
into the marine system to assure system level coastal preservation.
Technology and Management Techniques
(9) Assess and summarize the performance and cost of the various alternative
wastewater treatment technologies that may be appropriate in conjunction
with ocean discharges. Special attention should be given to the
capability for removal of heavy metals and xenobiotic organic compounds
Describe the problems of solids residual disposal and air pollutant
emissions associated with each treatment technology in multimedia
evaluations. Consider performance, costs. flexibility, robustness. and
environmental compatibility.
08/03/89
09:39
202 334 2620
NRC CETS
7
007
.6.
(10) Assess the effectiveness and practicality of various disinfection
techniques for wastewater effluents (at various treatment levels) and for
digested sludge.
(11) Summarize and evaluate the degree of success lor failure) of source
control (pretreatment and waste minimization) by dischargers into
unicipal. wastewater treatment plants for various coxic substances (or
classes of substances). Assess the long range viability of source control
as a basic technique for control of toxic emissions and as an alternate to
secondary treatment.
(12) Identify and evaluate current technologies and management approaches for
control of pollutants in urban runoff whether from separate storm drains
or combined sewer overflows (CSO'E). Particular attention will be
directed to seciments, toxic substances, and fecal coliform.
(13) Study the possibility of increased banning of the use of particular
substances and other pollution prevention approaches in urban areas
(including household products) as a means of controlling toxics in both
sewage and urban runoff. Consider the effects of other infrastructure
changes. such as separating combined sewers. innovative drainage system
design, better street cleaning, and control of illegal connections of
rainwater pipes to sanitary sewers and wastewaters to storm sewers.
(14) Review briefly the recent advances in outfall design and construction
technology in terms of capability to discharge effluents far offshore with
high initial dilution and plume submergence.
Systems Analysis and Design: Environmental Mcdelling
(15) Evaluate the capability of the profession to design overall systems
(source control, collection, treatment, outfall disposal) to meet
LIMITED USE DOCUMENT-NOT FOR PUBLICATION OR ATTRIBUTION - This document IS only for be information and use of recipients
at which they use members At with which they are working
08/03/89
09:40
6202 334 2620
NRC CETS
Z008
.7.
specified water quality objectives in the ocean and the likely uncertainty
of such predictions. This includes the full range of engineering design
and environmental simulation on probabilistic basis) of physical.
chemical, and biological processes in the ocean.
(16) Analyze the sdvantages/disadvantages of the water-quality driven approach
compared to the technology-driven management approach. The differences
can be monetary (costs of construction and operation). or in terms of
ecological impact, health impact. welfare impact. and/or in administrative
effectiveness (including encouragement of Innovation and allowance for
future flexibility).
(17) Assess the utility of risk-analysis including the limitations caused by
complex mixtures of toxics in wastewaters and sludges, both with respect
for the effects of the discharge and the uncertainty in predicting these
effects.
(18) In cases of multiple discharges (including urban runoff) to the same
receiving water body, 888855 the capabilities for allocation of societal
resources. or setting of priorities, for pollution control: and make
recommendations for improvements in such multisource management (e.g.,
control of CSO's versus more treatment of dry weather flows).
(19) Identify techniques to:
a. Encourage innovation in systems to manage marine discharges:
b. Promote flexibility in systems. to provide greater opportunities to
apply knowledge learned from the operating prototype to make future
decisions on changing source control, upgrading treatment. etc.
(20) Identify research and monitoring needs and strategies related to
wastewater management. Recommend steps to improve the nation's research
efforts, ireluding making better use of large quantities of monitoring
date now being gathered and improving modelling capabilities.
08/03/89 09:40 202 334 2620
NRC CETS
€009
is
-8-
(21) Explore ways to make decisions in a multimedia framework, e.g., taking
Into account the impacts of sludge disposal (whether to air, land, or
water), Air pollutants generated. and energy requirements.
The committee will not perform original research. The body of its report,
and its conclusions and recommendations. will be produced from the collective
expertise of its members, assessment of the relevant literature including
relevant recent reports of the National Research Council, and review of several
case histories. Such case histories will not be reviewed in an investigative
spirit but in an attempt to illustrate what changes in approach might produce
more effective water quality management.
The committee will receive technical and administrative support from the
staff of the Water Science and Technology Board who will also be responsible
for assuring that all Academy/NRC policies and procedures are followed and that
appropriate coordination occurs with other units of the NRC with relevant
interests. Appropriate liaisons with a variety of agencies and entities will
also be established with the committee.
ANTICIPATED RESULTS
The committee will issue di report at the end of a two-year review which
will provide both scientific and policy perspectives on innovative
cost-effective, and environmentally effective approaches to wastewater
management in coastal areas. The report audience will be legislators, federal
and state regulatory authorities, dischargers, industry, planners, consultants
seademia. and public interest groups. The report will be subject to peer
review in accordance with procedures established by the Report Review Committee
of the NRC. These reports will be made available to the public without
restriction and will be prepared in sufficient quantity to ensure distribution
to the public and all relevant parties.
08/03/89 09:41 202 334 2620
NRC CETS
0010
is
ESTIMATE OF COSTS
Estimated total expenses for this two-year activity are $450,000, of which
$X00,000 is requested from the U.S. Environmental Protection Agency/National
Science Foundation, as detailed in the attached estimate of costs.
08/03/89
6202 334 2620
NRC CETS
Z011
07/18/89
18:22
NRC EXEC OFFICE
2002
VA-HUS Indebandere SubCommittee Agrucles
45
$1,000,000 for controlling sources of pollution to the Spokens
+ clean lakes program, to
level of $10,000,000. The
aquifer +$600,000 as initial funding through a cooperative agreement
ided for the section 315(b)
for a two-year study on high risk pollution sources and human
year 1990 and are suffl-
health in the Baton Rouge/New Orleans corridor.
designated projects. The
+ $500,000 for a nonpoint source control demonstration for the
IT the cleanup of Delvan
ble to the program office.
Rouge River.
+ $350,000 for the Small Plows Clearinghoust to design and con-
ate grants to place great-
duct workshops on successful alternative technologies for small sys-
rom high risk sources, in-
teme, including facility planning. water conservation and reuse.
e, and interstate air qual-
+$300,000 for a National Academy of Sciences study of opportu-
nities to improve wastewater management and water quality for
hird Federal share of the
Boston and other urban coastal areas. This study should review
and assess alternative wastewater management technologies, sys-
affort;
ind Federal share to begin
tems, and strategies that may be appropriate for urban coartal
to support a Federal clean
communities, including Boston. The study should evaluate techni-
These funds are not to be
- cal alternatives and staging options with respect to environmental
or approves an agreement
benefits, technological innovation and flexibility. and economic
and Michigan which in-
Practicality from & multimedia perspective.
tifying roles and responsi-
+ $250,000 for assistance to Northwest Indian tribes to support
Juality model and control
their initiatives in controlling nonpoint source pollution to protect
provide the two-thirds Don-
salmon streams.
complete this multi-year
The Agency is directed to use existing resources to assess the ef-
fectiveness of eutrophication control programs in the Maumee
share to assist in complet-
River and Bay and survey existing research on the western basin
port of a Federal clean air
of Lake Erie to document trends, patterns and environmental pres-
in California;
if interstate efforts in ad-
sures. The Committee has not included the proposed bill language relat-
ogone nonattainment and
ing to the licensing fund or language making abatement, control,
and compliance funds eligible for building construction and im-
funding to complete the
provement costs. Language has been included to permit EPA to
I in the Juares/El Paso
transfer up to $10,000,000 of abatement funds to "Salaries and 02.
penses." Such transfers shall be subject to the normal Committee
m support.
reprogramming procedures and to the approval of the Office of
operator training to main-
Management and Budget.
nical assistance and imple-
BUILDINGS AND PACILITING
fund the Rural Water Asso-
$6,000,000
1980 appropriations
000 for Rural Community
8,000,000
Estimate, 1990
12,000,000
for integrated compliance
Recommended in bill
+4,000,000
ance and training to prob.
Incruase above estimate
commental training centera.
This activity provides for the design and construction of EPA-
ards should be made in con.
owned facilities M well as for the repair and improvement of facill.
cy to assure that resources
ties utilized by the Agency. The funds are used primarily to correct
blams.
unsafe conditions, to protect health and safety of employees, and to
levelopment for state/local
prevent serious deterioration of structures and equipment.
nity colleges.
The Committee has included $12,000,000 for buildings and facili-
ruality, including air togica,
ties in 1990, an increase of $4,000,000 above the request, to be dis-
nta, and food chain models
tributed as follows:
les. The Committee empha-
+$3,000,000 for critical health and safety repair and improve-
age blocking the 80 percent
ment projects at the Administrator's discretion. and
funds for EPA's Great Lakes
+$1,000,000 for improvements to the Ada, Oklahoma research
laboratory.
a studies.
ID # 055819
THE WHITE HOUSE
CORRESPONDENCE TRACKING WORKSHEET
INCOMING
DATE RECEIVED: JULY 21, 1989
NAME OF CORRESPONDENT: MR. JAMES L. SULLIVAN
SUBJECT: ENCLOSES INFORMATION REGARDING THE CLEAN UP
OF BOSTON HARBOR
ACTION
DISPOSITION
ROUTE TO:
ACT DATE TYPE C COMPLETED
OFFICE/AGENCY
(STAFF NAME)
CODE YY/MM/DD RESP D YY/MM/DD
JOHN SUNUNU
ORG 89/07/21
/ /
REFERRAL NOTE:
allan Bromley
C 89/08/02
/ /
REFERRAL NOTE:
/ /
/ /
REFERRAL NOTE:
/ /
/ /
REFERRAL NOTE:
/ /
/ /
REFERRAL NOTE:
COMMENTS:
ADDITIONAL CORRESPONDENTS:
MEDIA:L INDIVIDUAL CODES:
CS MAIL
USER CODES: (A)
(B)
(C)
*ACTION CODES:
*DISPOSITION
*OUTGOING
*
*
*
*CORRESPONDENCE:
*
*A-APPROPRIATE ACTION
*A-ANSWERED
TYPE RESP=INITIALS
*
*C-COMMENT/RECOM
*B-NON-SPEC-REFERRAL
*
OF SIGNER
*
*D-DRAFT RESPONSE
*C-COMPLETED
*
CODE = A
*
*F-FURNISH FACT SHEET *S-SUSPENDED
* COMPLETED = DATE OF
*
*I-INFO COPY/NO ACT NEC*
*
OUTGOING
*
*R-DIRECT REPLY W/COPY *
*
*
*S-FOR-SIGNATURE
*
*
*
*X-INTERIM REPLY
*
*
*
REFER QUESTIONS AND ROUTING UPDATES TO CENTRAL REFERENCE
(ROOM 75, OEOB) EXT-2590
KEEP THIS WORKSHEET ATTACHED TO THE ORIGINAL INCOMING
LETTER AT ALL TIMES AND SEND COMPLETED RECORD TO RECORDS
MANAGEMENT.
50819
THE CHIEF of STAFF
has
seen
AUG
Greater Boston
James L. Sullivan
Chamber of Commerce
President
600 Atlantic Avenue
Boston, MA 02210-2200
(617) 227-4500
July 18, 1989
The Honorable John Sununu
Chief of Staff
The White House
Washington, D. C. 20500
Dear Governor Sununu:
On your recent visit to Boston I had the opportunity to discuss
briefly with you the E.P.A. requirements that Secondary Treatment Facil-
ities be a part of the clean-up of Boston Harbor. The cost of construc-
tion for Secondary Treatment is approximately 2½ billion dollars and Dr.
Donald R. F. Harleman, Ford Professor of Engineering at M.I.T., has devel-
oped a paper that makes the case that the E.P.A. requirements are not
based on scientific evidence and would be an unwise expenditure of public
funds. I asked that you put on your Civil Engineering hat and take a
look at his position paper. You asked that I forward material to you
at the White House.
I am accordingly enclosing Dr. Harleman's resume and his position
paper as well as testimony that he presented before the State Legislature
together with a supporting article from the San Diego Tribune that appears
to independently support his position by the Scripps Institution of Ocean-
ography on the West Coast.
It would appear that the Scientific Community does not agree that
Secondary Treatment should be required in Coastal Cities. A study is
proposed for the National Academy of Sciences to study methods to improve
waste water treatment in Boston and other coastal cities.
Since the cost of secondary treatment is in the billions of dollars
in coastal cities --- 4.2 billion in San Diego and 2½ billion in Boston ---
substantial savings could be made without the expenditure of these funds
if some members of the scientific community are correct. I recognize that
the Clean Water Act of 1972 requires a national standard of secondary treat-
ment but if in fact ocean disposal does not require this level of treatment
many billions of dollars could be saved nationally for there are many coastal
cities that could benefit from an objective analysis of the requirements.
Being aware of your strongly held convictions that public dollars should
be expended prudently and efficiently I felt that you would be interested
in the controversy.
Very truly yours,
JLS:eb
Enclosures