2 Dust Ash Manufacturing is hoping to increase its revenues

2. Dust & Ash Manufacturing is hoping to increase its revenues through a plant expansion that would require building near wetlands adjacent to the Blugreen River. Analyze whether Dust & Ash needs to get a Clean Water Act permit for its expansion. (15 points). a. If the expansion required building near a pond behind thoe Dust & Ash Manufacturing facility that had a subsurface connectio to a stream that ran to a tributary that fed into the Blugreen River, analyze whether the company would need a Clean Water Act permit for its expansion. (15 points)

Solution

Glancing back through history, waste disposal became increasingly urgent as population
density increased. Solutions for how to best handle biological waste have been evolving
ever since. In many areas serious waste treatment strategies did not emerge until the
19th century when correlations were drawn between waterborne illnesses and human
contact with waste. Over time, centralized systems displaced decentralized systems
because they were thought to better protect citizens from rampant disease, as well as
easier to maintain and operate in compliance with impending laws.
In the United States, technologies for carrying away waste date back to the mid to late
1700s, about 100 years after communities began installing fresh water conveyance
systems. In the Puget Sound, many early communities collected their waste in wood
chutes, boxes and troughs and discharged it to the most convenient point, usually local
water bodies at a lower elevation. The fi rst large-scale strategy to replace the privy
vault and cesspool systems was the centralized water-carriage sewer system. This
system solved some problems and created others, especially in more densely populated
communities. Many city residents accepted the
sanitation problems and nuisance
conditions such as odor as a necessary
part of urban life.1
But because it wasn’t
widely understood that biological waste
could contaminate water sources, open
sewers lined the streets. First-fl oor
dwellers could often connect to the
sewer system via a drainpipe but it was
commonplace for upper-story households
to cast their biological waste products
out the window to the streets below.
City boosters advocated for centralized
waste management and sewer systems,
believing it would help attract people
and industries with a cleaner urban
image. Opponents to centralized waste
management and sewers argued that
a source of fertilizer would be lost, soil
and water supplies would be polluted at
the system outfalls and “modern sewer
systems” would create and concentrate
“disease-bearing sewer gas”.2
The design of the early centralized
systems was also vigorously debated,
pitting advocates for combined sewer
systems against proponents for separated sewer systems. The combined sewer systems
used a single pipe to transport both stormwater and wastewater to a designated disposal
location, as opposed to the separated sewer systems which required laying two pipes.
Many cities unwittingly installed combined systems because they were thought to be less
expensive to build, unaware of the environmental problems that would later be imposed
on discharge sites.
In Olympia, “adequate fl ushing and some dilution were seen as benefi ts over separate
sanitary sewers.”3
It was a widely held belief that ‘dilution was the solution to pollution’,
making combined systems the superior choice. But as populations in cities grew and it became necessary to treat sewage to alleviate
nuisance pollution problems, cities with
combined systems now had signifi cantly more
volume to clean.
Major advancements in sewer system design
did not take place until the end of the 19th
century when studies emerged demonstrating
that sand fi ltration processes could help lower
the infection rate of waterborne illnesses such
as cholera, dysentery and typhoid. It was at this
time that sewage treatment plants became
commonplace.
Even after the King County Board of Health
passed a resolution that required all
wastewater discharged to Lake Washington to meet the United States Public Health
Service bacteriological standard for drinking water, community members demanded
that intercepting pipes divert the effl uent away from Lake Washington. Outfalls were
connected to the intercepting pipes by 1936, but large storm events continued to cause
overfl ows that polluted Lake Washington. Many cities with similar situations began
building ‘compound systems’ — combined sewer systems in some areas of town
and separated sewer systems

Decentralized and distributed wastewater treatment strategies should not necessarily be
managed at the municipal level by publicly-owned utilities alone. As such, the cost burden
for treatment systems, as well as their ongoing operation, maintenance and replacement
needs can be shifted from the utility to the individual project owner. While this can create
fi nancial barriers for project owners, unique opportunities exist for utilities to develop fee
structures and incentives to support the transfer of capital cost, expense and revenues
to offset an owner’s upfront investment in on-site water systems.14 Utilities could even
develop a new revenue stream by providing system maintenance and testing to ensure
operations perform at required public health levels.
A project owner’s upfront investments in on-site treatment systems can create
burdensome fi nancial barriers. Even when life-cycle costs are taken into account,
artifi cially low utility rates for water and wastewater services translate to long payback
periods. Not all utilities use full cost pricing — past and future, operations, maintenance
and capital costs — to establish rates for water and wastewater services and therefore
miss an opportunity to encourage conservation and reuse strategies employed by
alternative waste treatment systems.
Financial barriers for distributed water systems can be directly related to the regulatory
barriers noted above. Backup or redundant connections to municipal wastewater utilities
may be required by codes even when a system is designed and operated not to use
them. Composting toilets sometimes require backup sewer connections and associated
plumbing, creating a fi nancial disincentive for project owners to even consider their
use. Likewise, capacity charges are established by utilities to recoup sunk costs for
large investments in centralized infrastructure projects and are required to be paid by
all building projects located within their service area, regardless of whether or not onsite systems can be utilized to meet individual treatment needs. Some municipalities
have instituted innovative fee structures, such as the City of Portland’s Bureau of
Environmental Services in Oregon, which allows for emergency-only connections to their
wastewater treatment facilities but charges large use fees in the event that the utility
connection is actually needed.
Removing regulatory barriers to decentralized systems can help spur market innovations
and new products available to designers and homeowners pursuing decentralized and
distributed systems, thus bringing down upfront costs and reducing life-cycle cost
payback periods. For years, fi nancial incentives for energy effi ciency measures and onsite renewable energy generation have been accelerating market adoption, serving as
examples for similar approaches for decentralized and on-site wastewater systems.