Karch - Pollution Control Costs Too Much!

POLLUTION CONTROL COSTS TOO MUCH!
An Address By

Kenneth M. Karch, PE

Executive Director

Iowa Department of Environmental Quality
Des Moines, Iowa 50216

Before the

Institute of Environmental Sciences
Shoreham-Americana Hotel
Washington, D. C.

April 30, 1974

I would like to spend the next 15 or 20 minutes talking about a basic defect in the mechanism which this nation has chosen to control pollution and to suggest an alternative which I believe requires serious consideration by the Congress and the Federal and State Environmental Control Agencies. in suggesting this mechanism, I speak as an engineer with 10 years of experience in local and state pollution control agencies, consulting engineers, and with a regional planning agency, and not in my current capacity as Director of the Iowa Department of Environmental Quality.

The basic reason for undertaking economic activity is to produce more of the goods and services that people want. Unfortunately, as a byproduct of this production of goods and services, waste products are generated. These waste products are generally dispersed into the air, into the water, or onto the land, thereby causing pollution and other social costs. Because these costs are not accounted for in the price of the products, they are called external costs, because they are outside the decision making process of the industry or municipality.

Disposal of these materials into the air, water and land has been done indiscriminately in the past because these resources were essentially free for the taking; therefore, dischargers maximize the use of these resources.

As a result of each industry and municipality wishing to utilize the free resource to the maximum extent, the resource capacity for assimilation of discharged materials was exceeded, resulting in air pollution, water pollution and the degradation of our land.

Such a preemption of the assimilative capacity raises the cost to other users of these resources in terms of adverse health effects, property damage, vegetation damage, destruction of natural environments, etc., and in a sense constitutes a capture of the public domain for private use without compensation or in the case of a public discharge, a taking of a right without compensation. Neither of those concepts has achieved widespread legal support.

It was generally conceded that the free enterprise economic system should adjust itself to account for these external costs through some kind of a balancing of benefits and costs among users. The question was how this could be accomplished.

It seemed that there were two basic approaches which might be followed. The first approach was that of direct governmental regulation of individual dischargers. The second was to develop sufficient governmental regulation to allow the market place to allocate these scarce natural resources and internalize the environmental and social costs arising from the disposal of waste materials into the environment.

The approach that was selected in the United States to solve air and water pollution problems was that of direct governmental regulation of individual dischargers. This approach had been used for many years on the State and local level and recently, with the passage of Federal water and air pollution legislation, has been adopted by the Federal government as well.

I should like to suggest in this paper that this approach has largely failed to accomplish the job, has resulted in the waste of huge amounts of scarce public funds, has helped turn the public off on government while building a massive and essentially unnecessary bureaucracy, has delayed the solution to problems, has had severe anti-competitive effects, has created a massive and nationally significant strains on limited energy resources.

Because there are no continuing positive economic incentives to abate pollution, the strict governmental regulation effort has generated reluctance by municipalities and industries to control pollution which has manifested itself in excuses for inaction, proposals for long-term studies to solve the problem, delays of various kinds and ultimately court fights--some of which have delayed effective pollution control for years. In order to try to counteract the negative effects of the direct govern­mental regulatory program, we have attempted to give tax write-offs and subsidies of various kinds to industry, and have developed a construction grant program for municipalities which provided funds for industry as well, until recently.

The pure governmental regulation control method has severe anti­competitive aspects. Economies of scale in production apply equally well to pollution control. Pollution control costs for large industries per unit of production generally tend to be lower than for a small industry. In addition, larger industries tend to be better capitalized, tend to be able to fight regulation more effectively, tend to be able to get more time for compliance, and are generally better able to cope with the regulatory function.

Direct governmental regulation has had severe tax impact as well. Municipalities suddenly were faced with large increases in property taxes for construction of wastewater treatment facilities that they generally didn't benefit from since benefits were largely accrued downstream. Recognizing this, a whole series of construction grant and loan programs from HUD, FHA and EPA and its predecessor agencies were generated. The most significant effect of these grant programs was to give essentially complete control to the Federal, government and to create a near perfect pork-barrel program (everybody gets a little; it's a popular issue; it's a move in the direction of more progressive taxation; it provides increased business for local business, etc.).

A direct governmental regulation program had substantial impacts upon intergovernmental cooperation. The large Federal construc­tion grant programs may have encouraged a "go it alone" attitude, since without such grants local communities probably could not have afforded to go it alone. The recent industrial repayment provision has effectively discouraged industry from seeking out intergovernmental regional joint municipal-industrial treatment approaches. And finally, the States' seem to be fighting amongst each other to get the biggest piece of the Federal construction grants pie in the development of their needs surveys.

The regulatory approach was a deterrent to innovative solutions to pollution problems. The regulatory approach encouraged "end-of-the-pipe" technology. The construction grants and other public subsidy programs has discouraged improved in-plant housekeeping and process changes and reduced innovative waste recovery and reuse and recycling efforts. The program has largely ignored the benefits which might be achieved through progressive urban and basin planning. The regulatory approach has largely ignored the concept of land capability for develop­ment and other land use issues. These issues are only now beginning to be recognized in the designation of the water quality limited segments of our streams.

The regulatory approach upsets the market system by causing sometimes serious distortions in market decisions. There is essentially no way in telling whether an extra dollar in pollution control costs produces an extra dollar in benefits. Industry has been forced to aim at a continually moving pollution control target.

Finally, the emphasis upon governmental regulation has caused technical and economic feasibility problems. The time limitations spelled out in the Clean Air Act and the Water Quality Act were determined with more hope than realism and grave doubts are being expressed about their attainability by EPA and Congress as well as industry. In addition, governmental regulation has played a major part in placing a strain on certain resources including gasoline, natural gas, and low sulfur fuel.

When I was named to organize and head Iowa's then new Department of Environmental Quality some two years ago, I enjoyed toying with my audiences by saying that one of my primary tasks was to assure that we spent as little as possible on pollution control in the State. This attitude both horrified the environ­mentalists, and pleased the polluters, until each began to understand what I meant.

I was convinced then, and I remain convinced today, that the methods being used throughout the nation to control pollution are grossly inefficient from an economic standpoint and although I have no way of proving it, I am convinced that the public is paying, either through increased taxes or increased prices, half again as much and perhaps twice as much as it should have to pay to meet the ambient or water quality standards set up as a result of the air and water pollution control acts. I believe Congress as well as Federal and State pollution control agencies have gone a long way down the road to creating a public crisis of confidence by insisting on a system of uniform national effluent or emission standards, an incredible emphasis on end-of-the-­pipe technology and the creation of a near perfect pork-barrel program of municipal construction grants.

Let me say at this point, that I recognize the social, political, technical, and legal problems associated with the control of air and water pollution in metropolitan areas and in no ways are my remarks today to be construed to downplay those problems. Nevertheless, I feel that a major restructuring of the approach that this nation has used in its air and water pollution control efforts is necessary at the earliest possible time. The reasons for this are many and varied.

First of all, the planning, construction, and operation and maintenance of air and water pollution control facilities have become a significant part of this nation's gross national product. Expenditures for air and water pollution control have been rising continuously for 20 years or more and promise to continue to rise in the short-term future. In view of the increasing demands upon limited State and Federal resources as well as private investment capital, it is essential that funds used for pollution control be expended in the most efficient manner possible.

Second, public expecta­tions created by the passage of the Clean Air Act Amendments and the Water Quality Act Amendments will not permit excuses when deadlines arrive that are not met. Only through economically efficient expenditure of these limited resources, can we hope to ever come close to achieving these deadlines.

And third, and finally, environmentalists are in a very vulnerable position if expenditures for air and water pollution control are not made effectively due to the pressures being applied resulting from the energy crisis.

During the last 2 years I have learned a little bit about tilting with windmills.

Nevertheless, I am heartened by a considerable amount of recent literature describing alternatives to the governmental regulations scheme for controlling air and water pollution. Most of these proposed alternatives involve the use of economic incentive techniques of one sort or another, primarily taxes, effluent charges, and environment leasing mechanisms. It is not my intent in this paper to defend any one particular method, nor to debate their pros and cons. I have attached a bibliography for those who wish to pursue this matter further.

Basically the objective of the various economic incentive plans for controlling air and water pollution rest upon bringing to bear market forces in allocating resources.

As you know, one of the most basic aspects of pollution is that the generator of the pollutant is generally not harmed by it. That harm is often borne by other persons (for example, a downstream community subject to discharges of sewage from an upstream community, or farmers who live downwind from the copper smelter.)

Furthermore, the impacts of the pollutant are generally spread among a large number of receivers. Thus the economic incentive to use the courts was nonexistent, since virtually any court of equity would rule that the massive interest of the polluter was of more importance than the individual interest of the recipient of the pollution. While the class action suit concept helped reverse this legal problem, only in rare cases was the social cost being imposed upon society internalized to the polluter by requiring that these social costs be reflected in the cost of the products of that producer.

While the attempt to establish uniform effluent or emission standards for all industries of like nature will tend to internalize some of these external costs by reducing discharges, such a system inherently results in over-kill for some industries and inadequate control in others, thereby wasting resources, at the same time doing a less than adequate job.

In addition, because of economies of scale, large industries who are forced to meet a uniform effluent standard will do so often at a cost per unit of output substantially less than their smaller competitors, thereby offering large industries a competitive advantage over small industries, contrary to the expressed intent of other Federal legislation. Reliance upon a tax or effluent charge or assimilative capacity exceed capacity of the stream or air shed while assuring that those industries with the least cost treatment options would treat (generally the large industries) while those with high unit cost of treatment (the small industries) would continue to discharge.

The simplest market scheme to implement might involve the rental or lease of the environmental resource, the air, the stream, the lake, etc. to the highest bidder. This was proposed for ocean dumping in the 1971 Economic Report of the President. Such a system would limit the amount of discharge directly but would allow the price for discharging a unit amount of a substance to be set indirectly by the market system. Under such a plan, a governmental agency would determine the capacity of a resource to assimilate different wastes and would then issue permits specifying the type and amount of waste with the total amount permitted not to exceed the natural limit of the resource.

Then the government would auction off these permits to the highest bidders and allow private resale thereby allowing a price to be established for the use of the resource.

Since the prices that the bidders would be willing to pay would measure the costs of alternative waste disposal methods, this method would ensure that scarce waste assimilative capacity of the resource was being put to its most productive use. The beauty of the system lies in its simplicity and flexibility, reducing governmental involvement to the setting of the environment's assimilative capacity (just as we are doing now), the monitoring of discharges and the collection of fees. The revenue derived from the sale of the permits could be applied to other environmental needs.

Other techniques using effluent changes and taxes have also been suggested, in order to cope with particular problems such as interstate control, etc. No single set of economic control techniques will suffice and some combination of such techniques and direct governmental regulation will probably be necessary I believe it is long past the time when we can be satisfied with engineering solutions without considering other factors, and l would urge the Congress and the EPA to press forward with studies of the advantages and disadvantages of alternative regulatory mechanisms so that we can have a basis for making rational, cost-effective decisions on the future of pollution control in this country while minimizing aversive controls which limit freedom of choice.

Bibliography

Riordan, Barrett J., Environmental Quality and New York_. City, First National City Bank, New York, 1972.

--- , More Effective Programs for a Cleaner Environment, A Statement on National Policy by the Research and Policy Committee of the Committee for Economic Development,New York, 1974.

Page, Talbot, Testimony before EPA Upon the Interpretation of No Significant Determination" For the Clean Air Act, Aug. 29, 1973.

Solon, Robert M., The Economists Approach to Pollution and Its Control", Science 173:498, August 6, 1971.

Westman, Walter E. & Gifford, Roger M., "Environmental Impact Controlling the Overall Level", Science 181:819, August 31, 1973.

Delogu, Orlando E., "A State Approach to Effluent Change," Maine Law Review 23:2:281, 1971.

Freeman, A. Myrick, "Economic Incentives in Water Pollution Control," Dept. of Economics, Bowdoin College, Brunswick, Me., 1972.

Seaquaves, J. A. "Surcharges and Stream Changes as Economic Incentives," North Carolina State University West Raleigh Station, Raleigh, N. C., 1972.

Freeman, A. Myrick, & Haveman, Robert H., “Residuals Changes for Pollution Control; A Policy Evaluation," Science  177:322, July 28, 1972.

Hardin, Garret, The Tragedy of the Commons, Science 162,1243, 1968.

Wallich, H. C., Fortune, October 1972, p. 114.

---, Congressional Record, November 2, 1971, p. 517425.

---, U. S. Senate Committee on Public Works, Water Pollution Hearings, Government Printing Office, Washington, D. C., 1970, part 1, p. 187-200, 346-364.

Kneese, A. V., "Environmental Pollution Economics and Policy," American Economic Review (Papers Proc.) 61, 153 (1971).

Ayres, R. U. & Kneese, A. V., "Production, Consumption, and Externalities, " Amer. Econ. Rev. 59,286 (1969).

Gilbertson, W. E., Statement on Effluent Tax for Water Pollution Control, before Joint Economic Committee Hearings on Economic Incentives for Pollution Control, July 19, 1971.

Freeman, M. Myrick, "Cleaning Up Foul Waters: Pollution Tax," New Republic (June 20, 1970) p. 13.

Kneese, A. V., The Economics of Regional Water Quality Management (1964).

Kneese, A. V., & Bower, B., Managing Water Quality: Economics, Technology, Institutions (1968),

Grady, "Effluent Charges and the Industrial Water Pollution Problem," 5 New England Law Review 61 (1969).

Karch Comments to DOE on Proposed Permit for Alum Treatment of Waughop Lake April 10 2019

Comments of Kenneth M. Karch, PE
on Waughop Lake Alum Treatment Proposal
by the City of Lakewood

To:
Washington State Department of Ecology
Water Quality Program
Attn: Aquatic Pesticide Permit Manager
PO Box 47600
Olympia, WA 98504-7600

Introduction

These comments are submitted to the Department of Ecology in opposition to the request for permit for alum treatment for algae control in Waughop Lake in Lakewood, WA. A quick bio on Mr. Karch is attached at the end, as well as a list of references.

I hope you will take my concerns in the spirit in which they are offered…that of a Lakewood resident for the past 12 years, of the State of Washington since 1977, and one whose background is as an environmental engineer and student of governmental policy and procedures, who wishes Waughop Lake to be returned, to the extent possible, to the valuable natural resource condition which my fellow citizens deserve and expect.

My background specific to this matter is described in the attached biography. To the point, I served as the first Executive Director of the Iowa Department of Environmental Quality, and later as the Director of the Missouri Division of Environmental Quality, both positions being the comparable position to the Director of the Washington State Department of Ecology. In fact, I worked with John Biggs, former Washington DOE Director, and our counterparts in a dozen other states, to anticipate and respond, from the states’ perspective, to the National Environmental Policy Act (NEPA) and the creation of the US Environmental Protection Agency.

I have studied the several reports on the eutrophication issues of Waughop Lake, as well as the 35 or more communications from a variety of persons, some of whom clearly have in-depth knowledge of eutrophication issues, which have recently appeared in local paper and online media, and concluded that I needed to recommend that the State DOE not issue the permit for alum application to resolve the eutrophication issue at Waughop Lake.

Philosophy of Pollution Control

The “polluter pays” principle is the fundamental principle of environment law in the US and many other industrialized countries. It is based on the idea that, whenever the producer of pollution can be identified; the nature of the pollutant and its effect on the public defined; the polluter still exists, can be found, and is capable of contributing, in whole or in part, to the mitigation of the external costs imposed on the public, it should be required to do so.

Examples of the “polluter pays” principle include the “gas guzzler” tax; the CAFÉ fuel economy standards; the Superfund system; payment for the use and abuse of public resources (eg., grazing and oil exploration fees, effluent standards), many recycling and reuse alternatives; responsibilities incorporated into most Federal, State, and local environmental regulations, and most recently, the proposed carbon tax.

Taxes and fees which do not fall primarily on the generators of pollutants do not fall in this category, the highly subsidized municipal waste treatment construction grants program being an example. From an economist’s viewpoint they do not “internalize the externalities” thereby distorting price signals and increasing inefficiency in the marketplace.

A high level summary of the recent change in support for economically efficient pollution control systems is contained in the Brookings Institution’s Robert Crandall (post-2004) which updates comments by the author in 1974 (Karch (1974). Copies of both are attached.

The provisions in Federal and Washington State law and the City of Lakewood’s environmentally-related ordinances have been described in detail elsewhere, and are clear on supporting this principle. Their application to the Waughop Lake water quality issue make clear to me the State’s responsibility in this matter. Other commenters have made this point repeatedly and in depth. I support those comments.

Unfortunately, the Washington State DOE, as the permitting agency on the Waughop Lake alum treatment proposal (and related alternatives, such as dredging) is in an awkward position, since other State agencies, or their predecessors, have apparently been largely responsible for creating the problem for which solutions are sought. The DOE may therefore, be subject to criticism or legal action simply by issuing a permit, by the EPA or citizen-based environmental groups. Nonetheless, review of the DOE authority and potential liability for issuing the subject permit should be assessed by the DOE legal team, the Attorney General, or outside counsel.

What is the Problem?

The primary issue at Waughop Lake is one of health concerns (blue-green algae toxic end products) preventing water contact beneficial uses (as water use closures by the Pierce County Health Department, supported by the very high readings reported in the CDC study and toxins reports from 2007 through 2018, require). Of the 324 results reported between July 5, 2007 and September 6, 2018, 144 (40.9%) failed to meet State guidelines, almost all for microcystin. The failure rate was largely in the September/October period, with a scattering in the July/August and January/February periods.

The primary root cause of this is the benthic flux resulting from years of man-made deposits of organic materials, which, in turn produces high levels of phosphorus in the lake, resulting, in turn, in algae blooms, and toxic by-products. Simply preventing the mobilization of phosphorus by alum treatment addresses one of the symptoms of the root cause, but does not remove the root cause, the sludge on the bottom of the lake.

(chart omitted)

While it will be nice to have clear water in the lake for aesthetic purposes, it is much more important to resolve the fundamental water contact (and perhaps airborne) health issues surrounding the toxins produced during algae blooms.

Therefore, any proposed solutions should focus on, and be measured by the removal of the risk to public health.

Will Alum Treatment Work?

A wide range of studies of the nature of the algae blooms and toxic byproducts in Waughop Lake have indicated that, compared to all other lakes studied and reported on in the Pacific Northwest, 1) Waughop Lake is singularly shallow; 2) the sediment is singularly thick from many years of man-made deposits; 3) the benthic flux of phosphorus is by far the highest as a percentage contributor to phosphorus in the water, the trigger for algal blooms, 4) all other sources of phosphorus are correspondingly lower; 5) the lake is of very low alkalinity, making it susceptible to pH stresses; 6) the lake is far more eutrophic; and 7) the appearance of toxins is singularly by far the highest.

(charts omitted)

As a result, confidence in the relatively large body of evidence supporting the view that alum
treatment may provide a major and long lasting “solution” to the algal bloom problem, may be
sharply reduced by comparing its efficacy only to those situations having characteristics similar to
those found in Waughop Lake. I have seen none in a brief literature search conducted on the matter, and the Brown and Caldwell plan is silent on providing such examples (the few examples they provided are not on point). A query of key algal experts in DOE and in Jefferson County about whether they knew of any such comparable lake conditions drew demurrals.

In Waughop Lake, the phosphorus levels are so high, and the algal trigger levels are so low, that it leaves considerable doubt about whether treatments found effective in other moderately polluted lakes would apply in Waughop Lake.

Unless such unequivocal evidence can be found of comparably bad lake situations, I don’t see that the issuance of a permit for alum treatment is a wise idea. The application of alum to Waughop Lake may be considerably less effective than the evidence reported only from moderately affected lakes. The engine that generates phosphorus in Waughop (benthic flux) is so powerful that I have little faith that alum treatment will be either as initially effective or as long lived as hoped for.

There are many lake algal studies in the literature. I have suggested development of a neural network for mining of the data in these studies to determine whether there are hidden and unknown solution alternatives to alum treatment in a situation such as that found uniquely in Waughop Lake. DOE, and the fine Washington education system, no doubt has personnel who could help answer such a question.

What is the Chemistry?

Several of the studies of alum and/or calcium hydroxide have indicated that things can go wrong, leading to failure of the proposed treatment, including early or variable reemergence of blooms, including toxic properties, pondweed increases, and/or fish kills.

The chemistry and biology of natural waters is extraordinarily complex, involving a “slumgullion” stew of inorganic and organic constituents.

In reading the Brown and Caldwell and Tetra-Tech reports, I felt that the treatment of this complexity was limited. Most environmental engineering students will have had some exposure to one or more of the many works on the subject, such as that by Stumm and Morgan (1970, 1996). The influence of phases of phosphorus and nitrogen under varying pH conditions, as well as the effect of dissolved oxygen, as a contributor to pH changes in a low alkalinity lake, could have been better described.

What Are the Economics?

I was expecting, but did not find, a discussion of the economics of alternative solutions in the Brown and Caldwell report (nor, for that matter, in the other reports on the Waughop Lake algae issue). The economic information was limited to suggesting capital costs for several alternatives (which varied by very high percentages) along with estimated costs for re-treatment at some highly variable time frame in the future.

The relatively high initial capital cost estimate of dredging would be offset by relatively lower future O&M costs (since the likelihood of success is higher and longer) and, of course, by the possibility of economically beneficial uses of the dredged material (eg., for fertilizer or soil amendments). The alum treatment was acknowledged as having a highly variable effective life, with future uncertain repeat applications likely to be necessary.

Situations arising where there is a choice between choosing a high capital/low O&M costs versus a low capital/high O&M cost alternative, are an economist’s dream, and depend on the assumptions made about amounts, timing, and interest rates, and are the classic case of the time value of money. I am reminded of the ditty by Kenneth Boulding, the poet-economist and one-time professor of mine, remarking (from memory) on the high first cost Feather River project to move water from northern to southern California:

“Around the mysteries of finance,
We must perform a ritual dance,
For every project owes its fate,
To the long term interest rate.
At 1 percent the case is clear;
At 2 some sneaking doubts appear;
At 3 it draws its dying breath;
While 4 percent is sudden death.”

While today’s interest rates may bear little relationship to those of the 1960s, it is all the more important, when considering options such as alum treatment vs. dredging, to conduct an economic analysis, including a sensitivity analysis, to determine what effect changes in success assumptions; alum treatment recurrence; governmental preferences and hurdle rates; reuse income; disposal cost; grant eligibility; and other factors have on the relative desirability of the two alternatives.

High Uncertainty Requires Reducing the Risk

Whenever uncertainty about a course of action is high, it is wise to syndicate the risk, or to rely on alternative risk reduction approaches. One of the most useful may be a performance bond on the applicator, or a staged program, with release of portions of the funds based on achievement of annual performance measures. Such performance measures should be clearly stated, well understood, measureable, quantified, and time bound.

Reluctance to agree to such a requirement diminishes one’s confidence in the efficacy of the proposal.

Release of funds without a requirement to achieve the measures represents a fiduciary failure on the part of the funding organizations to their constituents, the tax and rate payers, who expect and deserve prudent use of scarce fiscal resources, which could have been used elsewhere for public benefits.

If a performance bond ever became workable the success measures should include measures of public benefit, such as fishability and freedom from toxic algae, and not simply secchi disk or other aesthetic measurements, or even levels of phosphorus in the water column.

I have been informed by the member of the City Council of The City of Lakewood, that the City, applicant for this permit, has indicated in general that it will have interim “check points,” but the specific nature of the measurements has not been agreed to.

I would urge the DOE to incorporate specific, measureable, objectives as a condition of the permit issued for application of alum to Waughop Lake, which are clearly stated, well understood, quantified, and time bound, similar to the provisions in the state agency performance audit system, approved by the voters as Initiative 900 in 2005.

The Dredging Option is Best

All the key studies of which I am aware (including two citizen committee reports, the Brown and Caldwell report, and the Tetra Tech report) indicate that dredging is the best assured, long-term solution to nuisance algae blooms and attendant toxic conditions in Waughop Lake.

The City of Lakewood is clearly concerned with the projected costs for dredging, based on projections made by the two consultants, but has not carried out a more rigorous evaluation seeking and releasing information from dredging and/or recycling contractors. Others have made estimates which suggest considerably lower costs for dredging, land disposal, and recycling/resale opportunities. I would urge DOE, as part of the permitting process, to do an assessment of the costs of dredging and/or recycle/reuse of dredged materials. Clearly, the DOE has the skills and information in house to do so.

Beyond that, I would urge that the DOE not issue a permit for alum treatment if it concludes that such treatment would preclude the use of the sludge material, when it is eventually removed from the lake, as fertilizer or soil amendment. Sludge tests I have seen to date would not preclude such use, even with slightly increased levels of some heavy metals from the Tacoma smelter.

Phosphorus levels which trigger algae blooms may never be achievable, given the lake’s advanced eutrophic condition, without physical removal of the accumulated sludge of 100 or more years. Following that, periodical treatment with algaecides and/or alum may be effective.

I also have concerns that bottom-feeding fish (eg., carp), continually stirring up the settled material; natural phenomena (eg., wind action on the shallow lake, or temporarily clear water leading to increase pond weed growth); and man-made phenomena (increased water sports, such as boating, again in the shallow lake) will never allow reductions below the phosphorus trigger levels if the heavy sludge layer is not physically removed.

If Not Now, When?

Suggestions have been made that dredging may be a solution for the future, after an alum treatment now, to provide temporary relief from nuisance algae bloom and toxics.

Given the fact the City of Lakewood is rapidly developing the park surrounding Waughop Lake, and would not be doing so unless there was a prospect of increased use for a variety of activities by the public, I would argue that there will never be a time when it will be easier than today to remove a significant barrier to such increased use (use of the lake itself for boating and fishing).

The argument that interference with present uses of the park for other purposes will be disrupted by a dredging alternative will only become stronger with time and increased use of the park. And while I don’t believe swimming is a likely potential water contact use, miracles seem to sometimes happen.
I call to your attention the “solution space” concept, where a variety of actions over time may make a large solution space (i.e., many possible solutions to a problem) today shrink over time. Think of the solution space as a pie, and the actions taken over time being bites from that pie. As the bites occur, the solution space gets smaller.

A practical solution, though perhaps seemingly expensive today (dredging of the sludge from Waughop Lake) may become, over time, infeasible due to the small bites occurring each year. Bites in this case include rising prices for dredging; increased alternative uses of the park for other purposes (including demands to fill the lake and use it for land uses, such as sports fields, expanding dog-walking, concert venues, community centers, community gardens, outdoor art, a botanical garden, a nature center, bike trails and velodromes, and any number of others, all of which have three critical characteristics: they take up space, bring people in, and raise the cost of alternative uses, including dredging); hardening of the state’s position on its own responsibility; creation of animus between the City and the State on the matter; continuing small uncontrolled contributions of nutrients to the lake; etc.

Summary

I recommend that the Department of Ecology reject the City of Lakewood request for a permit for alum treatment of Waughop Lake, pending further consideration of the circumstances described above, including further analyses described above, and for the following reasons:

1. The proposal does not effectively address the question of responsibility for the sludge which is the primary cause of the algae blooms and toxic by-products encountered regularly in the lake

2. Credible evidence has not been presented that, in lakes as badly degraded as Waughop, the proposed application will be effective

3. The chemistry and related biological factors which are at play in the Waughop Lake environment have been relatively poorly defined by the applicant, and relatively well defined by professional personnel who oppose the alum treatment (see some 35 or more recent letters to the editor on the matter, and the reports of the proponents and opponents

4. The economics of alternative issue resolution practices (primarily alum vs. dredging) have not been given adequate treatment, using standard engineering economics principles

5. The high level of uncertainty demands a strong risk reduction strategy, perhaps involving a performance bond or other measures to ensure the fiduciary responsibility of the City, State, and Federal governments to their constituents are observed

6. Dredging is the only technique which will permanently remove the deep layer of man-made sludge which has gathered over the past 100 years or more and is the primary contributor to high phosphorus levels, with resulting algae and their byproduct toxins in the water

7. There will be no better time than now to remove the accumulated sludge, as pressures to develop the park (already in play) will inevitably reduce available space in the park, increase public use of the park, and increase the political and financial cost of dredging in the future. These will effectively preclude a dredging option in the future, and result in the loss of a prime water body for public use.


A Quick Biography of Ken Karch Ken Karch is a registered professional engineer with over 35 years of experience in environmental and organizational management in local and state government, non-profit organizations, private consulting, and industry. He holds an undergraduate degree in Civil Engineering from Illinois Institute of Technology, and Masters degrees in Engineering and in Public Health from the University of Michigan. He is a graduate of the University of Chicago’s Industrial Relations Executive Program and Columbia University’s Executive Program in Business Administration. Ken has served on a variety of high-level nation-, state-, region-, and industry-wide boards, commissions, and councils, chairing many of them.

Ken’s experience has included environmental work in a County Health Department in Illinois and the Regional Planning Agency in Washington DC. He was appointed the first Executive Director of the Iowa Department of Environmental Quality and the first Director of the Missouri Division of Environment Quality. He was Washington State and national Environmental Affairs Manager with Weyerhaeuser. He has served as manager of a 7000 acre property for the Nature Conservancy; Vice President of a Public Development Authority managing a public water system in Ocean Park, WA; President and General Manager of a 2000 member homeowners association; and a facilities manager for the Tacoma Mountaineers.

Ken’s personal statement regarding eutrophication and related issues:

I have studied and prepared reports on the condition of several rivers and streams, including my Master’s Thesis at the University of Michigan on the Computer Simulation of the Dissolved Oxygen Condition in the Ouachita River in Arkansas and Louisiana, subject to varying industrial waste inputs, releases from upstream reservoirs, temperature conditions, dissolved oxygen levels and standards, and tidal effects.

I served as a member and Chairman of Seattle METRO’s Citizens’ Water Quality Advisory Committee, dealing with secondary and advanced waste treatment alternatives and sludge recycling and reuse issues.

I authored papers on the computerization of county health department inspection programs; the application of remote sensing data from the Earth Resources Technology Satellite (ERTS) system to urban planning; the literature of packinghouse wastes; wastewater reclamation and reuse; economics of pollution control and surface water diversion projects; public water supply planning; sediment control; flood control; and urbanization effects of water and sewerage planning.

I worked to reduce the eutrophic conditions of rivers, farm ponds, and reservoirs in Iowa and Missouri; and on controls for feedlots, grazing, soil conservation, fishery enhancement, and on reducing pesticide by-products in bottom feeding fish in the interstate commercial fisheries market.

References

1. Stumm, Werner, & Morgan James J., Aquatic Chemistry: Chemical Equilibria and Rates in Natural Waters, 1970, 1996
2. Karch, Kenneth M., POLLUTION CONTROL COSTS TOO MUCH! An Address Before the Institute of Environmental Sciences, Shoreham-Americana Hotel, Washington, DC, April 30, 1974 (attached)
3. ENTRANCO Engineers, A Proposal for Waughop Lake Restoration, for the Pierce County Parks and Recreation Department, February 27, 1978
4. Moss, Brian, Engineering and Biological Approaches to the Restoration From Eutrophication of Shallow Lakes in Which Aquatic Plant Communities are Important Complements, Department of Environmental and Evolutionary Biology, University of Liverpool, UK, 1990
5. Rydin, Emil et al, Amount of phosphorus inactivated by alum treatments in Washington lakes, Limnol. Oceanogr., 45(1), 2000, 226–230
6. Canadian Council of Ministers of the Environment, Canadian Water Quality Guidelines for the Protection of Aquatic Life, 2004
7. Crandall, Robert W., Pollution Controls (post-2004); https://www.econlib.org/library/Enc/PollutionControls.html
8. Hamel, Kathy, Freshwater Algae Control Program (Washington State Department of Ecology) Report to the Washington State Legislature (2008 – 2009)
9. Johnson, Art, Blue-Green Algae Toxins in Washington Lakes: Screening Fish Tissues for Microcystins and Anatoxin-a, March, 2010
10. McClellen, Tom, Draft Remedial Action Plan Waughop Lake Cleanup, December 24, 2012
11. SePRO Corporation, Restoration of Water Quality in Lake Lorene, April 1, 2013
12. Washington State Departmant of Ecology, Aquatic Plant and Algae Management General Permit, effective April 1, 2015
13. Jacoby, Jean, at al, Dominant Factors Associated with Microcystins in Nine Mid-latitude, Maritime Lakes, Inland Waters (2015) 5, pp. 187-202, April 22, 2015
14. Brown and Caldwell, Waughop Lake Management Plan, February, 2017
15. Thurlow, Theresa, (Federal Way) City Council Presentation on the Data Analysis Report for Upper Joe’s Creek Watershed Nutrient Reduction Study, June 20, 2017
16. Dawson, Raechel, Federal Way’s upper Joe’s Creek study suffers backlash from twin Lakes community, July 21, 2017
17. Harry Gibbons, Shannon Bradttebow, and Adam Barnes, Tetra Tech Memorandum to Greg Vigoren (City of Lakewood) entitled Waghop Lake Dredging Feasibility Water Quality Analysis, June 26, 2018
18. Seebacher, Lizbeth, Washington State Department of Ecology, Detailed Algal Toxicity Data for Waughop Lake, July 5, 2007 through September 6, 2018, consisting of 352 tests
KMK Comments on Proposed DOE Permit for Alum in Waughop Lake 20190408 Page 12
19. Ackerman, Daniel, This Chemical Turns Polluted Green Lakes Clear. Is it safe?, October 17, 2018
20. Lindauer, Jack and Tepper, Jeffrey, Contrasting Causes of Hazardous Algal Blooms in Two South Puget Sound (WA) Lakes, Geology Department, University of Puget Sound, 2018
21. City of Lakewood, Volunteer Lake Monitoring Program, 2018 Season Report
22. McClellen, Tom, personal communication conveying Powerpoint presentation to be discussed with City of Lakewood personnel, February 28, 2019
23. McClellen, Tom, personal communication conveying results of meeting with City of Lakewood personnel, February 28, 2019
24. McClellen, Tom, comments to Washington State Department of Ecology opposing issuance of General Permit to City of Lakewood for aluminum sulfate treatment, February 23, 2019
25. Karch, K. M., Compilation of 35 articles and letters published in Suburban Times from 2008 through 2019

Bucich, Paul - Lakewood Public Works Engineering Director - Waughop Lake – the rest of the story - January 18 2019

Waughop Lake – the rest of the story

Submitted by Paul A. Bucich, P.E., Public Works Engineering Director, City of Lakewood.

Recent articles published in the Suburban Times regarding Waughop Lake have not included all the facts around how the City arrived at its decision to apply alum treatments to the lake to control toxic algae blooms. 

There are many opinions on what to do about the lake, from do nothing to dredge it and start over. We believe we have found a solution through a management strategy that addresses the issue in a reasonable manner that is affordable and has the smallest impact on Fort Steilacoom Park, park users, and surrounding neighborhoods.

As most users of Fort Steilacoom Park know, toxic algae in Waughop Lake is a decades-long problem. In its search for a solution, the City consulted with national experts and state ecology officials, held extensive discussions with University of Washington professors and others with expertise in lakes and aquatics issues, and listened to residents.

In an effort to make sure the City had all the information before proceeding with a treatment option, two independent consultant firms were hired to provide recommended treatment options.

The suggested solutions proposed by Mr. McClellan (Jan. 14 “Lakewood is on the wrong path for its biggest environmental problem“) and Mr. Russell (Jan. 11 “Letter: Council should reconsider Waughop Lake plan“) fail to mention key information that led the City Council to its final decision. 

That information is outlined below:

Lake Dredging

Nationally recognized consultants have evaluated options for addressing the algae blooms in Waughop Lake, including treatment with Aluminum Sulfate (alum) or hydraulic dredging of the bottom sediments. Consultants hired by the City, Brown and Caldwell as well as Tetra Tech, independently assessed the feasibility of treatment options and the costs of alum treatment vs. dredging. The 2017 Brown and Caldwell report recommended the following management strategy: “Conduct further lake sediment assessments to provide more accurate costs for sediment removal; if costs are higher than City can fund, conduct whole-lake alum treatment to remove phosphorus from the water column and inactivate phosphorus in the sediment; evaluate if sediment removal long term is feasible in regards to permitting requirements, costs for operations, impacts to park users.”

This is the strategy the City has followed since 2017. In 2018 the City hired Tetra Tech to conduct another review, this time asking specifically about dredging costs. Work done in 2018 and already in 2019 revealed the high cost of sediment removal and the impacts it would have on the park and adjacent neighborhoods.

Removal of sediments from a lake bottom is challenging even when a suitable location for disposal of that sediment is adjacent to a lake. In the case of Waughop Lake, it is even more challenging because the City is not able to dispose of the sediment within Fort Steilacoom Park without having a significant impact on existing park uses and features.  

The 2018 study by Tetra Tech determined that the costs to dredge the lake ranged between $7.9 Million and $34.5 Million depending on the depth of materials removed. With a shallow removal, the probability of success was estimated at 20 percent. With a deeper dredging effort, the probability of success was estimated at 90 percent. Success is viewed as significant reduction or elimination of algae blooms.

The significant impact of dredging was not relayed in the recent articles in the Suburban Times. It is important for the public to understand all the impacts the City Council considered when making its decision.

Dredging requires a significant operation including pumping the materials, drying the materials, and transporting them off-site.  

It was estimated a 20-acre “pond” would be needed as a drying facility to dry the materials. This facility would be six feet deep and would be built on top of the existing ground so as to not disturb any potential artifacts in the park.  

The facility would be lined with an impermeable layer to ensure stability to hold the liquid/solids. As the dredged material dried, we would expect an odor to develop (think of the beach at low tide but worse) that would affect park users, nearby neighborhoods, Western State Hospital, and the commuting public. Hydraulic dredging of the material with the expected branches, rocks, and other debris would be challenging. Further, we anticipate the dredging/drying/removal process would require significant closures of large areas of the park for up to two years. The lakeside trail would be closed to public access during the dredging operation which would most likely occur during the summer season(s).

Disposal is Problematic  

It was suggested that this material is equivalent to Tacoma’s Tagro product based on an analysis of the nutrient loadings alone and that it has a market value. What is missing from this assertion is the complex nature of the bottom sediments. We fully expect to find organic materials such as logs, branches, bones from fish, waterfowl, and potentially detris from the historic use of the lake by Western State Hospital such as bones, bottles, bricks, etc. These materials would need to be separated in the removal process, some by the hydraulic pumping system installed to move the loose bottom sediments, the rest by any product manufacturer prior to sale. It is unclear if the dry material can be used freely or if there is additional processing that would be needed.  

Tagro is a product that the City of Tacoma has spent over 30 years perfecting and is a blend of bio-solids and other weed free garden products composted to rigorous standards prior to sale. It is unrealistic to expect any topsoil manufacturer to take on the lake sediments at no or minimal cost without additional processing. The market for this product is unclear and as such, we have to anticipate disposal at a landfill.  

‘Alum is Toxic and Short Lived’

Statements have been made that alum treatment is dangerous, environmentally toxic to the lake, will lead to an explosion of aquatic weed growth, is limited in life span, will not work in a shallow lake, and not a preferred option by experts. These statements are misleading and in some cases outright wrong.  

Alum treatment is a nationally recognized treatment process and deemed safe by state and federal agencies after extensive testing and review. Alum is a nontoxic material commonly used in water treatment plants to clarify drinking water. In lakes, alum is used to reduce the amount of the nutrient phosphorus in the water. Yes, there have been instances where applications in lake environments have failed. These are almost exclusively due to applicator error. To address this, the City will contract with our design firm to ensure a qualified expert is on hand to oversee the application to Waughop Lake. The expert we are working with from the consulting firm of Tetra Tech has over 40-years’ experience, is a nationally recognized Ph.D water quality scientist and expert who has designed and overseen the treatment of over 200 lakes.  

Failed alum treatments are usually due to a lack of understanding of the sources of nutrients leading to the algae blooms. Waughop Lake has no external sources other than runoff from the park and the adjacent college and we expect a successful application. We are currently evaluating the sediment concentrations and refining the treatment needs of the lake to more accurately plan the alum concentrations needed for the treatment.

The City understands that alum treatment is not a one-time event. The typical treatment life span is between 5-10 years at which time a smaller treatment is likely going to be needed. This known aspect of alum treatment, when compared to the costs and impacts associated with dredging the lake, is deemed acceptable. Alum has not been determined to be environmentally harmful to any of the number of lakes treated over the past decades of use.

  

But What About…

It has been suggested that the City treat the lake with algaecides and herbicides in lieu of an alum treatment; that this is a viable management approach for the lake. 

When we hired Tetra Tech, the City specifically asked for this option to be reviewed. The expert we are working with said:

“Given the level of ‘production’ within Waughop Lake, algaecides are not a sustainable approach for reducing and controlling” the algae blooms. The City was told repeated use will affect the food chain abundance leading to reduced water quality and affect the fisheries food base. It will also likely lead to groundwater and sediment contamination — the issue being presented by some as the reason not to use alum.  Algaecide would have to be applied repeatedly throughout the summer, likely every 14 to 21 days, due to the reproduction cycle of algae. Aquatic herbicides would only be used if the clarity of the water reaches the point where aquatic plant growth impacts lake uses; this strategy would be applied even with the alum treatment strategy.

The City was approached by Mr. Russell who asked we try a new process being used on a lake in Federal Way. We informed him that in our opinion, this was an experimental process with an uncertain potential for success. We declined and explained that we were not set up to do the required testing for an experimental process. We encouraged him to contact larger agencies dealing with similar issues on lakes to see if they would be willing to have their lakes be the testing grounds for this treatment. Should it be successful and develop a proven track record, we would consider this new treatment process on future applications. At this time, we are unaware of any agencies taking on this new treatment alternative.

Funding for Treatment

Treatment with alum has been estimated to cost between $300,000 and $750,000. Current tests of Waughop Lake will provide a more refined plan for treatment and a better cost estimate. The City has applied for a $50,000 grant from the Department of Ecology to assist in treatment of Waughop Lake and received confirmation from Pierce County that a $300,000 Flood Control Zone District allocation for Lakewood can be used for this application. In our application for the Ecology grant, we were clear the money was to be used for alum treatment. Additional funding, if needed, would come from the City’s Storm and Surfacewater Utility fund.  

The State Should Do It

In 1967 the State of Washington transferred the operational responsibilities for Fort Steilacoom Park to Pierce County through a lease. That lease was subsequently transferred to the City of Lakewood. The agreement releases the State of Washington from any and all responsibilities for virtually anything related to the park lands. There are improvements the City plans on making to the park and we have been very successful obtaining state grants for past and current improvements. There are no established grants we could apply for to dredge the lake, and if there were, the impacts to the park and surrounding properties would still remain.

The Answer is Clear

Removal of the bottom sediments through hydraulic dredging or other means is difficult, expensive, and fraught with significant unknowns. Impacts to the park users and adjacent neighborhoods are likely to be high. Impacts to the park will be extensive. When compared with the alternative of alum treatment, a well-known and permissible process, the choice is clear, alum treatment is the viable solution at this time.

TetraTech - Waughop Lake Dredging Feasibility Water Quality Analysis - June 20 2018

 Executive Summary

The management goal for Waughop Lake is to reduce the intensity and duration of Cyanobacteria blooms resulting in harmful algal blooms (HAB) events, while improving the overall water quality and aquatic habitat that supports a recreational fishery. To attain this goal there are 6 potential alternatives that could be implemented; 4 include dredging alternatives to remove phosphorus-rich sediment and 2 are alum treatment alternatives that are directly targeting phosphorus to prevent HABs through phosphorus inactivation (making phosphorus unavailable to aquatic plants). Due to the uncertainty of the sediment depth needed to be removed to meet the management goals, there is a shallow dredging and deep dredging alternative, each with and without direct phosphorus inactivation via alum treatments.

The dredging alternatives 50-year life-cycle cost range from $7,900,000 to $34,500,000 with a probability of success (increasing water quality while reduced HABs) ranging from 20% to 90% over the 50-year period. The 50-year life-cycle cost for the two alum treatment alternatives range from $2,500,000 to $3,300,000 with a probability of success ranging from 75% to 85% over the 50-year period.

The dredging alternatives would result in no direct use of the lake for almost 1 year during dredging activities and no use of 60 to 100 acres of park land for 1 year, plus limited lake access for 1 week per year from year 2 through 50. The alum treatment alternatives would result in limited lake access for 1 week each year for the 50-year period.

General Discussion

Based upon the available information presented in the Waughop Lake Management Plan by Brown and Caldwell the following is a brief outline of a dredging approach for Waughop Lake. Due to data gaps and necessary assumptions, this discussion includes alternative dredging actions with additional alternative management actions relative to effectiveness in controlling HAB events and water quality improvements. The assumed management goal is to reduce the intensity and duration of HAB events, while improving the overall water quality and aquatic habitat within Waughop Lake. Previous studies and reporting have assumed that dredging will give the lake a 50-year period of good water quality without additional significant efforts needed. This assumption does not truly account for the role of groundwater phosphorus inputs and internal sediment phosphorus loading from sediment not removed in the proposed dredging process. It also does not consider the necessity to inactivate sediment phosphorus (remove the potential for phosphorus to become biologically available) from the newly exposed lake water/sediment interface, (Gibbons, et al 1983).

The purpose of lake sediment removal (i.e. dredging) is to remove the reservoir of phosphorus that is assumed to be currently contributing to excessive production of cyanobacteria. The effectiveness of dredging in Waughop Lake is dependent upon two undefined phosphorus loading potentials; 1) depth of sediment phosphorus contributing to the cyanobacteria production and 2) the impact of groundwater relative to its direct contribution of phosphorus to the lake and groundwater inflow through the lake sediments contributing to sediment phosphorus availability to the water column. This translates into two dredging alternatives depending upon depth of sediment to be removed. It also requires the inactivation of remaining sediment phosphorus that will be exposed after dredging and the inactivation of phosphorus brought into the lake via groundwater.

A viable dredging approach is to employ a hydraulic dredge to minimize water contamination and to remove phosphorus most efficiently. This approach would assume that sediment would be dredged and removed from the lake at a 5% solids content. This dredgate would be pumped from the hydraulic dredge to a treatment pond near the lake.

Assuming a pond depth of 9.8 ft (3 m), the area of the pond would be 18 to 20 acres (7.3 to 8.1 ha) (Figure 1). The treatment pond would need to be constructed above grade and lined to prevent interaction with groundwater. As the dredgate enters the pond, a flocculate (either a polymer or alum) would need to be added to aid in dewatering the dredgate and retaining phosphorus in the dredge spoils. The pond would be designed to have four cells. Three cells would store one day’s worth of the treated dredgate (approximately 26,150 yd3 (20,000 m3) at 1,307 yd3 (1000 m3) of lake sediment) to allow the dewatering to occur over 24 to 72 hours.

Clarified water would then be transferred via inverted syphon to the remaining pond cell for additional clarification. Water would then be removed from the fourth pond cell and returned to the lake after passing through a sediment curtain. This would translate to approximately 20,915 yd3 (16,000 m3) per day of water returning to the lake.

Dewatered dredgate would be transferred to a composting disposal site assuming that metal and other contaminate concentrations in the sediment do not require hazard waste disposal. Note that sediment metal concentrations reported would not allow disposal of dredgate to crop lands. Therefore, disposal would be to a landfill, or non-crop landscape, i.e. park and golf course sites. Landfill disposal cost would be very high due to limited land fill capacity and this could drive dredging cost higher than potentially stated in this memo.

For cost savings, it was assumed that the park would be the site for the dewatering pond and dredgate disposal. Hence, the dredgate would be transferred to a soil spreader to place 6” of dredgate over 66 acres or 12” over 33 acres as shown in Figure 1. This would be done at a rate of 1” per 7 seven days.

Dredging will result in a direct impact to park use in the areas of the treatment pond and disposal site for the period of operation. Park use and access would also be severely limited post dredging to allow the plant community to recover. See Figure 1 for proposed dredgate disposal areas and treatment pond location. It would be at least a year before park use within these areas could be allowed. The estimated total area of park to be impacted, excluding the lake, is approximately 60 to 100 acres. If off site dredgate disposal is utilized the impacted park area would be approximately 30 to 40 acres.

Small Dredge Volume Alternative

Due to the lack of current depth profile sediment data, it was assumed that approximately 3.3 ft (1 m) of sediment will need to be removed over 30 acres (12.1 ha). It was also assumed that groundwater inflow will replace any water removed from the lake via the hydraulic dredging process. Specifically, at 1,307 yd3 (1,000 m3) of sediment removed per day, with a total dredgate of 26,150 yd3 (20,000 m3), 24,850 yd3 (19,000 m3) of lake water would be removed per day. Total volume of sediment removed would be 158,700 yd3 (121,400 m3). Dredging would take approximately 30 days for mobilization including temporary treatment pond construction and dredge pipeline installation, 120 days for dredging, and another 30 days for final dredgate disposal and pond deconstruction with both sites replanted.

Following the dredging operation within the lake, a phosphorus sediment inactivation, combined with a water stripping treatment using alum, would be necessary to bind newly exposed sediment phosphorus, with the added benefit of clearing the water column. Again, due to the lack of sediment profile of phosphorus fractions the dose of that treatment was assumed to be 4 mg Al/L for water column phosphorus removal and 40 mg Al/L for sediment inactivation, for a one-time total dose of 44 mg Al/L. This sediment inactivation treatment would take place within 5 days of the sediment removal completion within the lake.

To address on-going loading of phosphorus to the lake via groundwater, an annual spring alum treatment at a dose of 4 mg Al/L would be needed to remove and inactive phosphorus for external sources (mainly groundwater) to prevent extreme HAB events. This annual dose would be further refined with lake and groundwater monitoring data.

Small Dredge Volume Alternative without Phosphorus Inactivation or Annual Control

This alternative is the same as the dredging option described above to remove 158,700 yd3 (121,400 m3) of sediment, but without the alum addition to inactivate newly exposed sediment phosphorus and annual phosphorus loading to the lake via, i.e. groundwater.

Large Dredge Volume Alternative

Due to the lack of current depth profile sediment data, it was assumed that approximately 6.6 ft (2 m) of sediment will need to be removed over 30 acres (12.1 ha). It was also assumed that groundwater inflow will replace any water removed from the lake via the hydraulic dredging process. Specifically, at 1,307 yd3 (1,000 m3) of sediment removed per day, with a total dredgate of 26,150 yd3 (20,000 m3), 24,850 yd3 (19,000 m3) of lake water would be removed per day. Total volume of sediment removed would be 317,400 yd3 (242,800 m3). Dredging would take approximately 30 days for mobilization including temporary treatment pond construction and dredge pipeline installation, 240 days for dredging, and another 30 days for final dredgate disposal and pond deconstruction with both sites replanted.

Following the dredging operation, a phosphorus sediment inactivation treatment would be necessary to bind newly exposed sediment phosphorus. As stated above, the dose of that treatment is assumed to be 4 mg Al/L for the water column phosphorus removal and 40 mg Al/L for the sediment inactivation for a total dose of 44 mg Al/L. This sediment inactivation treatment would take place within 5 days of the sediment removal completion within the lake.

To address the on-going loading of phosphorus to the lake via groundwater an annual spring alum treatment at a dose of 4 mg Al/L would be needed to remove and inactive phosphorus from external sources to prevent extreme HAB events. This annual dose would be further refined with lake and groundwater monitoring data.

Large Dredge Volume Alternative without Phosphorus Inactivation or Annual Control

This alternative is the same as the large dredging option described above to remove 315,400 yd3 (242,800 m3) of sediment, but without the alum addition to inactivate newly exposed sediment phosphorus and annual phosphorus loading to the lake via groundwater.

Phosphorus Inactivation and/or Annual Phosphorus Control without Dredging

The dose for an alum treatment without dredging is assumed to be 4 mg Al/L for water column phosphorus removal and 80 mg Al/L for sediment inactivation, based on the limited sediment phosphorus data available. If sediment cores were collected and analyzed for detailed phosphorus fractions and these data showed less phosphorus potential, the estimated dose of 80 mg Al/L could be reduced. Based on the currently available data, the total dose would be 84 mg Al/L. Due to cost and a relatively high dose, the alum treatment could be conducted over a 2 to 4-year period with an annual maintenance alum treatment to address on-going loading of phosphorus to the lake, mainly via groundwater inputs. An annual spring alum treatment at a dose of 4 mg Al/L would be needed to remove and inactive phosphorus from external sources on an annual basis following the sediment phosphorus inactivation dosing.

See Table 1 for relative costs and effectiveness assessment of the alternatives. Costs are based upon recent lake dredging operations and alum treatments conducted within the state. Effectiveness assessments are based upon both literature and direct experience with lake dredging projects since 1979 and alum lake treatments since 1974 throughout the US to improve water quality and control phosphorus

Insights and Recommendations

It is highly recommended, to both save costs and ensure the potential of achieving the lake management goal of reducing the number and intensity of HAB events in Waughop Lake, that three sediment cores of at least 6.6 ft (2m) depth be collected and analyzed every 5 cm for phosphorus fractions. This would cost about $15,000 but could result in 25 to 50% alum treatment costs savings.

To assess the effectiveness and plan for dredging and/or alum treatment, the sediment composition of Waughop Lake must be characterized. Specifically, the amount of phosphorus that is available to be released from the lake sediments (and must be removed by dredging and/or inactivated by alum) must be quantified. Therefore, all forms of phosphorus in every 5-cm sediment layer for at least 2-meter depth of sediment must be characterized including, total phosphorus (TP), mobile phosphorus (Mobile- P), organic phosphorus, biogenic phosphorus, Aluminum bound phosphorus (Al-P), and calcium bound P (Ca-P). Total phosphorus is a sum of all the components together. Mobile-P is the phosphorus that is susceptible to changes in the oxidative conditions and is the sum of iron-bound phosphorus (Fe-P) and loosely-bound phosphorus. Mobile-P can also consist of a portion of organic and biogenic phosphorus that is released through mineralization.

Based upon the probability of attaining the management goal for Waughop Lake, the relative impact to park users and the relative estimated life-cycle costs of dredging and alum treatments, it is recommended that a phased management approach be implemented at the lake. This approach would first include an alum treatment to inactivate the sediment phosphorus over a 2 to 4-year period and then implement annual alum maintenance treatments. This management strategy would result in improved water quality and reduced HABs, while also significantly reducing the life-cycle costs. It would also limit the impacted park area to just the lake for approximately 1 week per year, compared to at least 1 year of limited access of both the park (60 to 100 acres) and the lake for the dredging alternatives.