United States       Office of Planning     April 1979
          Environmental Protection   and Management
          Agency         Washington DC 20460
&EPA     EPA Research and
          Development Guidance
          Fiscal Year 1980/81
                                001 B97101

        FISCAL YEARS 1980/81
           WASHINGTON, D,C,
             APRIL,  1979

     This year marks the first time that EPA's Office of
Research and Development has participated in the Agency's
annual Guidance activities.  The document which follows
represents a significant step forward in our continuing
efforts to improve communication and coordination between
the research laboratories within the Agency, and the
program offices which use research results in their
day-to-day activities.


     The Research and Development Guidance contains two
parts.  The first is the Policy Guidance, in which
Administrator Costle, Deputy Administrator Blum, and the
Assistant Administrators set forth their goals and
priorities for the coning two fiscal years.  The Policy
Guidance is followed by a Research Guidance for each of
the nine media (including Energy and Interdisciplinary)
which have programs within ORD.  The Research Guidance
for each of the media contains, first, a Media Overview
written by the program office, describing the program's
priorities and objectives for 1980 and 1981.  Following
the Media Overview is a section, written by ORD, outlining
specific research priorities.


     Each of the Research Guidances was reviewed by its
appropriate Media Task Group.  These groups, with represen-
tatives from Headquarters and Regional offices, were
responsible for reviewing the Guidance for consistency
with the goals set forth by the Administator/Deputy
Administrator and the AA's.  ORD representatives on these
Groups played an important role in providing information
about research priorities and activities, and brought an
important critical perspective to the proposals contained
in the draft program Guidances.  As activity within the
Media Task Groups shifts toward the ZBB ranking, ORD
representatives should continue to play an important role
in examining the Agency's priorities along with represen-
tatives from other offices.


     The discussions within the Media Task Group, including
the common review of Guidance and the MTG ranking to come,
are still just first steps in the necessary process of
strengthening the links between research and program
personnel within EPA.  The next step -- actually using a
framework of common assumptions, improving joint planning,
increasing "teamwork" on Agency projects, and implementing
the choices and priorities described in the Guidance — -
will take place in the twelve Research Committees which
ORD has established to ensure closer coordination of its
research plans with the needs of its regulatory "consumers".
These working groups will play a vital role in the trans-
lation of necessarily broad media guidance into a set of
concrete plans for conducting specific research programs
in FY 80 and 81.


     We encourage research personnel to study this Guidance
carefully.  It contains information you will need in drawing
up your FY 1980 Operating Plans and FY 1981 Budget.  In
particular, Media Task Groups will review all Decision
Unit submissions for consistency with those priorities
set forth by program and labs in the Guidance.  Research
projects which fulfill priority information needs for EPA
operating programs can expect to benefit from this
     We hope that this Research Guidance can become a regular
fixture of the Agency's planning and budgeting activities.
It has great potential as a tool for coordinating the many
and diverse efforts going on within EPA and increasing our
ability to learn from each other.  The many talented
personnel within the Agency are our greatest resource for
finding better ways to protect our environment.  The success
of this Guidance will be measured by how well it helps us
work together to get this job done.

                 FISCAL YEARS  1980/81

      POLICY GUIDANCE  	      3





      TOXIC SUBSTANCES	     26

      ENFORCEMENT	     41



      AIR	     53

      WATER QUALITY	     71

      DRINKING WATER 	     97

      SOLID WASTE	    115

      TOXIC SUBSTANCES	    129

      PESTICIDES	    149

      RADIATION	    161

      ENERGY	    169

      INTERDISCIPLINARY   	    185




     EPA and State and local agencies can be proud of what
they have accomplished over the last two years.  We have
won strong legislative mandates, and we are making good
progress in implementing them.  EPA is better  integrated,
and we have begun the process of strengthening our State
and local relationships.  We are making good progress in
developing effective controls for toxics.  In  area after
area we are recognized front-runners in the Administration's
reform efforts.  The air and the water are getting cleaner.
The people, the President, and the Congress support our
work: they respect both our professionalism and our
ability to get a tough job done.

     This Guidance addresses the future.  But  before we
go on to define what lies ahead, we wanted to  note how far
EPA has come.  The Agency has been working hard and well.
Congratulations and our thanks.

     In this Agency Policy Guidance we identify what we
feel the Agency's priorities should be for the next
several years.  Our Assistant Administrators follow with
more detailed guidance for each of their areas of respon-
sibility.  We have worked closely with them in developing
these program guidances.

     Broadly stated, the Agency's priorities are as

     o  To reduce public exposure to dangerous

     o  To protect sensitive ecological systems;

     o  To improve management of our environmental

     Over the last several years we have come to understand
more of the connections between the thousands of chemicals
our society has put into our environment and a great many
of the diseases that afflict modern man.  EPA has been
given lead responsibility for identifying, evaluating,
and controlling environmental pollutants.  Doing so is one

                           - 4 -

of our chief objectives.  We are approaching the problem at
every point — when a chemical is produced, shipped, used,
or ultimately disposed of.  Our Toxics, Air, Water,
Pesticides, Drinking Water, Radiation, Hazardous Waste,
and spills programs must all give the toxics problem
greater priority.  In doing so we expect that all action
on individual pollutants should generally be governed by
the principle of addressing first those that present the
greatest health risks.  A major part of that effort has
been the development of an integrated strategy for toxic
substances, a strategy which we will continue to develop
and refine throughout 1980 and 1981 through vigorous
implementation of the Toxic Substances Control Act.

     As another element of an Agency-wide toxics strategy,
we will develop an Agency cancer policy.  The policy
will provide a framework for continuing decision-making
in our pesticides, toxics, and drinking water programs
and for emerging carcinogen regulations under the Agency's
air, water, and hazardous waste programs.

     Finally, our urban strategy is a key part of this
effort because it is based on attacking the unhealthy
environmental conditions of cities.  We expect the
Assistant Administrators and you to continue to implement
our existing urban initiatives and to develop innovative
solutions for urban problems.


     Increasingly during the past two years, we have
focused the Agency's efforts on dealing with pollutants
as they affect public health.  Ultimately, however, we
must protect the environment that supports us and all
other life.  While continuing to clean up our air and
water, we need to give much more attention to particularly
sensitive environmental systems such as wetlands.  Though
natural systems like wetlands and fisheries are usually
described as renewable — on the assumption that they can
regenerate themselves when depleted or damaged — we are
beginning to learn how fragile they truly are as we begin
to understand sensitive ecological relationships.  Once a
groundwater supply is contaminated with toxics, for
example, it may take centuries for natural restoration
(or millions of dollars for clean-up) if it is ever to
support healthy natural life or to be used for drinking

                           - 5 -


     We have made a major commitment to finding better,
more effective ways of regulating.  There are almost fifty
reform efforts in progress across the Agency now.  We are
beginning to see the results of this commitment, and we
expect a great many more initiatives to move into
implementation stages over the next several years.  We
will continue to look for complements to traditional
regulation, such as offsets and the bubble, our reporting
requirements, sunset, and procedural simplifications.  We
want your active help in finding better ways to carry out
our responsibilities.  Specifically, we want to continue

     o  Integrate EPA programs — We have made a good
        start in our efforts to consolidate our grant
        and permit programs.  The integration of programs
        in water quality, drinking water, solid waste,
        hazardous wastes, and underground injection can
        serve as a good model for other program areas.

     o  Strengthen Federal/State/local partnerships —
        Establishing the State/EPA Agreements and
        encouraging appropriate delegation should streng-
        then and improve environmental programs at all
        levels.  We also need to retain and improve our
        ability to assess performance at all levels.  We
        want to work for passage of an Integrated Environ-
        mental Assistance Act as a legislative base for
        increasing management flexibility between us and
        the States as well as in State programs.

     o  Improve coordination with other Federal agencies —
        We must make greater use of the IRLG and Regulatory
        Council mechanism to assure coordinated and
        concerted action among all Federal agencies.  We
        must work particularly closely with the Department
        of Energy in developing environmentally and health
        sensitive energy policies.

     o  Reform and refine our management practices —
        In this area we are emphasizing the completion of
        Civil Service reforms recently enacted.  We must
        also put in place the planning, zero-based
        budgeting accountability system for the Agency.

                           - 6 -

        In addition, we are reassessing our monitoring
        with an eye to the quality, utility and compati-
        bility of our information systems.

     o  improve regulatory reform — We are giving major
        emphasis to the development of more flexible, less
        costly alternatives to our traditional regulatory
        approaches, such as the "bubble" concept and
        "banking" of offsets in nonattainment areas.  We
        want to continue improving the quality of our
        regulations.  One of the most important elements
        to the latter is continued strengthening of the
        Steering Committee; we want to enlarge the role
        of the Regions in this process.

     o  Strengthen the Agency's research capacity and
        programs — We want to improve our ability to
        forecast environmental problems and solutions,
        particularly in the long term.  We need to expand
        the data base for our regulatory decision-making.

     Finally, there are a number of cross-cutting issues
we want to flag.  We expect:

     o  a strong commitment to improving public partici-

     o  a determined affirmative action program; and

     o  continued attention to the Administration's
        urban programs.
     The 1980-1981 planning years present a great challenge
to us as managers.  We must continue to move this Agency
toward protecting public health and the environment more
fully.   We expect that each participant in this planning
will consider how his or her program can contribute to
these initiatives.

                           - 7 -
     The following sections of this Guidance set forth our
priorities in greater detail.  They serve as the basis for
FY 1980 Federal and State program implementation and as
the policy framework for program and resource recommen-
dations to the President for FY 1981.
                                  Dojuglas M. Costle
                                  Barbara Blum
                                  Deputy Administrator








        Overview Statement of Priorities and Goals

         Stephen J. Gage, Assistant Administrator
     During the next two years, three major objectives will
be driving the Environmental Protection Agency's research
and development program: (1) continuing the integration of
the Office of Research and Development into the mainstream
of the Agency's activities, (2) enhancing the Office's
capability to provide the scientific and technological data
the Agency will use for future regulatory and enforcement
actions, and (3) improving that data through scientific peer
review of research procedures and results, quality control
of risk assessments, and quality assurance of monitoring

     Much of the groundwork for achieving these objectives
has been laid during the past year.  The Research Committees
have been quite successful in planning research in five
critical areas jointly with the Program Offices.  A signifi-
cant Public Health Research Initiative ($37 million, 46
positions) was developed and successfully defended with
OMB through the cross-agency zero-based budgeting for toxics.
A new Office of Health and Environmental Assessment, building
on the successful experiences in scientific assessments by
the Carcinogen Assessment Group and the Environmental
Criteria and Assessment Office, has been proposed.  Other
developments have also built a good foundation for future


     Joint planning of the Agency's research and development
activities through the five pilot Research Committees already
provides a very valuable linkage between the regulatory
program offices responsible for developing regulations and
the ORD scientists and engineers supporting the regulatory
efforts.  During early 1979,  we will establish seven new
Research Committees to cover the joint planning of sub-
stantially all of the research in support of regulation and
enforcement.   Each of the 12 committees will be specifically
oriented to the users of the research information, typically
Program Office Deputy Assistant Administrators or, in some
instances, Division Directors (see Attachment A).

                           - 12 -
     The new Research Committees will develop multi-year
research strategies oriented toward supporting regulatory
needs; identify research outputs required within the next
budget year (now beginning the FY 1981 cycle); seek the
required resources through the Agency's ZBB process; and
monitor and evaluate ongoing and completed research.  We
must make special efforts during this formative period
to bring more fully the Agency's enforcement and Regional
programs into the joint planning process.  In the interest
of cost-effectiveness, it will be necessary for the Regional
Offices to coordinate their participation and share respon-
sibility for representing Regional interests in the Research
Committee; ORD will support the Regional Offices in this

     We will continue to experiment cautiously with matrix
management approaches as a means of improving the coordi-
nation and delivery of high-visibility, short-term research
outputs.  Matrix management of the diesel emissions program
will continue, and we will consider establishing a limited
number of similar programs, such as in Acid Precipitation.

     Closely related to the evolution of the joint research
plannng approach is the long-overdue simplification of
ORD'S planning and reporting systems.  We must take this
step to bring ORD's planning and management approaches into
synchronization with (1) the five-year plan developed in the
preparation of the Agency's Research Outlook, (2) the multi-
year plans developed by the Research Committees, and (3) the
Agency's ZBB review and decisions.  We must also eliminate
the redundant paperwork that absorbs too much ORD staff time,

     In order to improve accountability for the research
and development efforts, we must bring into operation a
reliable tracking system for the critical outputs required
by the Program Offices as identified by the Research
Committees.  As a corollary, we must also reduce i-~> a
manageable number the outputs to be tracked.  While we must
have adequate information to monitor progress of the key
outputs, we must vigorously resist spending too much time
and effort reporting preliminary and fragmented data.  Good
research management means monitoring the right indicators,
not all of the possible indicators, of orderly progress
toward objectives.  Too much reporting together with
overspecification of research investments will counterpro-
ductively tie the hands of the research managers and stifle
innovcitive research.  Management flexibility must, of
course, be coupled with accountability.

                           - 13 -
     With the increased pressure for higher quality manage-
ment of several key research areas, we will be realigning
the laboratory reporting relationships to consolidate
functional or discipline groupings.  These changes, which
should improve morale and productivity, will allow us to
improve the implementation of the Agency's research efforts.
Specifically, the realignment will establish an office for
health effects research management; an office to integrate
environmental transport, fate, and effects research; and an
office to integrate control technology and hazardous waste


     We made important progress in the past year in starting
the long-term process of building a foundation for a signifi-
cantly improved scientific and technological data base for
the future regulatory and enforcement actions of the Agency.
Planning and budgeting the Public Health Research Initiative
was a critical first step, but it was only a beginning.

     We must now commit ourselves to the detailed planning
and implementation of the Initiative.  Since the Initiative
represents the first significant expansion of the Agency's
basic environmental health sciences, we must wisely dedicate
it to achieving a solid understanding of human health effects
caused by both direct and indirect environmental exposures.
Because we will be drawing heavily on scientific talent in
the private sector to assist us in this effort, we must
begin immediately to seek the best scientific advice
available to help us in this planning effort.

     The second critical step, a broad environmental
research initiative, must be taken immediately.  Because
of the heightened awareness in the Administration of
EPA's requirements for the best scientific and techno-
logical data that can be developed for the Agency's
comprehensive environmental regulations, we now have an
excellent opportunity to seek a government-wide review of
environmental research.  This review will focus on how
existing and future Federal resources can support broader
based, longer term environmental research to build an
improved data base.  We must assume the leadership in
developing the conceptual framework for such efforts,
bringing to bear on the program design the best scientific
advice available.  We must look to the Agency's Science
Advisory Board, the President's Office of Science and

                           - 14 -
Technology Policy, and the National Academy of Sciences as
well as numerous individual scientists in this comprehensive
planning and review effort.  We are now in the process of
developing a select set of initiatives for 1981 and beyond,
focusing on protecting humans from environmentally mitigated
pollutants; identifying and protecting critical components
of ecosystems from injury; and addressing the more global
problems of protecting our life support systems.

     In parallel with these activities, we must carefully
review the longer-term research already underway in ORD to
assure ourselves that we are directing our attentions to
the most important future problems and are using the best
scientific talent we can attract to work on these problems.
We must determine if we are obtaining high quality, well-
documented results from our research grants -- the primary
mechanism we have for supporting innovative ideas.  We must
make the scientific community more widely aware of our
research grants, encourage much greater competition for
those grants, and ensure that they are awarded strictly on
the basis of merit through enhanced peer review.  We should
also see if alternative approaches for handling these longer
term grants can relieve the burdensome monitoring loads
placed on the individual laboratory researchers.

     An invigorated, competitive grant program for longer-
term research in each research area, coupled with an expanded
Anticipatory Research Program, will provide the Agency with
an important new base of exploratory research.  It is
essential that, with the significant infusion of new funding
associated with the Public Health Research Initiative, we do
not waste this opportunity to build a firmer foundation with
the help of the best scientific talent available in the


     Scientific and technological data come in many forms
and in varying quality.  The credibility and integrity of
all data used in Agency decisions is a prerequisite for
any analyses.  The evaluation and synthesis of the data is
an essential step in informing the many far-reaching
regulatory decisions.  We have made significant progress
during the last year in providing carcinogenic risk
assessments for the Program Offices and in improving the
capability of ORD to prepare Air and Water Quality criteria
documents by establishing the new Environmental Criteria and
Assessment Offices in Research Triangle Park and Cincinnati.

                           - 15 -
     We have not yet, however, undertaken the special
responsibility assigned by the Administrator to provide
quality control of the Agency's risk assessments.  With
approval of ORD's new Office of Health and Environmental
Assessment (OHEA), we must now move ahead, first to quickly
develop guidelines for the several types of risk assessments
required for the Agency's regulation development, and then
to exercise oversight to ensure that the asssessments
prepared by the Program Offices conform reasonably to the
guidelines.  We must also proceed to staff OHEA with the
best qualified people we can attract from the scientific
community, significantly upgrading in this process ORD's
capability to provide consultation to the Program Offices
and, upon request, assessments of specific chemicals.

     Although we in ORD have discussed the role of peer
review extensively during the past year, we must now
act in the coming year to build into all of the Agency's
scientific and technological efforts appropriate review
mechanisms.  We must begin with enhanced peer review for
individual research projects.  The ORD senior laboratory
management must convey to the professional staff strong
support for and assistance in periodic external peer
review of individual projects.  Whenever feasible, the
results of individual projects should be subjected to
rigorous scientific or technological scruntiny through
publication in referred journals.  We should also see
that the results of our grants and contracts are published
in peer-reviewed journals, slowing the grov/th of that body
of EPA-published "gray literature" which now constitutes
the only publication channel for too much of our work.
Publication of research results in the peer-reviewed
literature must become an important criterion for advance-
ment in all of our laboratories.

     In addition to peer review of individual research
efforts, we must systematically review our research programs.
While such reviews may begin at the laboratory level, it is
usually more appropriate to conduct them at the level of the
Deputy Assistant Administrators or even of the Assistant
Administrator.  Since the Research Committees will be
providing the primary focus for the bulk of our research
activities, it is logical that we direct our attention
increasingly to programmatic reviews along the lines of the
committees.  We should also be mindful of other mutually
supporting programmatic areas which may provide results for
several committees, such as biological screening tests,
analytical methodologies, etc.

                           - 16 -
     Finally, we have been expanding in the past year our
efforts to provide support to Agency laboratories for
quality assurance of environmental monitoring data.  We must
now assume the lead for improving the quality assurance of
all of the environmental monitoring data used in the Agency's
decisions.  We must first make sure our house is in order
by requiring adequate quality assurance practices for all
environmental quality monitoring, sampling, and analytical
activities conducted in the ORD laboratories or by our
contractors or grantees.  This policy should become effective
immediately.  We must also require, through the Blue Ribbon
Monitoring Task Force, similar quality assurance practices
for all of the Agency's laboratories, contractors, and
grantees.  Lastly, we must work closely with the Regional
Offices to bring quality assurance practices into uniform
use in all of the State and local laboratories, which
provide the bulk of the environmental quality data available
to the Agency.


     Overview Statement of Priorities and Goals

      David G. Hawkins, Assistant Administrator


     Each OANR program plan should include resources and
should plan for effective participation.  Limited resources
should also be available for case-by-case assistance to
participants in a small number of major rulemaking and/or
permit proceedings.

     I would also like OANR offices to work with Regional
Offices to develop effective public participation programs
for their activities.

     Finally, each office should review existing public
information materials in its area of responsibility.
Program plans should provide for major improvements in
our information base and should include a system for
keeping our public information materials current.  Please
work with our Office of Public Awareness representative
in this effort.  Our laws, particularly the Clean Air
Act, are complex but their purposes and effects can be
simply explained.  We must make more of an effort to do


     High priority must be given in 1980 to completing all
actions required as a result of State implemention plan
submissions in 1979.  Most plan approvals, disapprovals,
and promulgations should be completed in 1979, as should
the schedules for implementing the plans.  However, some
such actions may not occur until 1980.  We must have in
place systems for tracking State progress in implement-
ing their approved plans.  We need to emphasize and
develop ways of assuring that the States assume their
responsibilities under the plans including all new source
review responsibilities.  It is especially important that
we encourage States to implement the program for Prevention
of Significant Deterioration.

                         -  18  -
     During 1980 programs for visibility protection and
Prevention of Significant Deterioration for pollutants
other than TSP and SO  should be ready for implementation.
States should be urged to assume responsibility for these
programs as well.

     The next major round of SIP revisions will be in 1982
for those areas where EPA has granted extensions beyond
the 1982 deadline.  Our guidance requires that for ozone
these areas base their revised plans on an air quality
model.  It appears that the most appropriate technique for
protecting future air quality in this round of SIPs will
be the relatively complex dispersion models which account
for photochemical reactions.  We should give high priority
in 1980 to the acquisition of data required for these
models and to validating them.  The 1981 program plan
should provide for the use of these models in all areas
where required in a time frame that permits technical
review and public participation on development of control
strategy to assure meeting the Clean Air requirements.

     The general problem of lack of confidence in air
quality data also must be addressed in 1980.  Emphasis
must be given to the establishment of technically sound
sites and procedures for National Air Monitoring Stations
(NAMS) and State Local Air Monitoring Stations (SLAMS) as
required by our monitoring regulations.  Participation by
State/local laboratories in quality assurance programs
should be mandatory.  If the programs require additional
resources, this should receive a high priority in the
1981 budget request.

     At Headquarters, by December 31, 1890, we must have
completed our review and appropriate revision of all
existing ambient air quality standards.  The plan for
1980 should clearly recognize this requirement and, given
the need for a better quantification of benefits, provide
for the development of such a data base and analyses as
may be required.

     The budget for 1980 provides funding to complete the
development of new source performance standards for all
major stationary sources by 1982.  The program plans for
1980 and 1981 must demonstrate that we are on a schedule
which will meet that statutory deadline.

                        - 19 -
     No large increment in resources is being provided  in
1980 for activities related to hazardous air pollutants.
I expect that, before the next fiscal year begins, we will
have in place a policy on air carcinogens providing a
systematic approach to substantially reduce risks from  air-
borne carcinogens.  Our plan in 1980 should provide for
the orderly implementation of that policy with a major
intensification of actions in 1981.  This program should
take into account and be coordinated with other programs
regulating risks from toxic or hazardous pollutants.

     In Mobile Sources we should have completed all vehicle
rulemaking specifically required by the Clean Air Act in
1980.  Our future standard-setting program should address
the need to regulate presently unregulated pollutants,  and
resources to address the light-duty diesel should be
available in 1980 in the event that research establishes
the need for additional action.  Our 1980 program should
focus on such assessment activities as may be necessary if
standards are to be proposed in FY 1981 or subsequent
fiscal years.

     Given commitments to inspection/maintenance programs
in the SIP's, we must be in a position of being able to
provide expert guidance to State and local I/M programs.
The 1980 plans should address, as a matter of priority,
such data gathering and assessment as may be necessary  to
assure that we can assist I/M programs to achieve their
maximum potential.

     We should give major attention to other activities
which will help assure that vehicles in use perform as
intended, and the 1980/81 plans should specifically address
this concern.  In particular, we should continue to examine
test procedures to improve their relation to real-world

     In FY 1980 I thifck that every effort should be made
to become current with our previous commitments to regulate
new products.  New commitments should be limited until we
are assured that the backlog of previous identifications
and/or proposals can be eliminated.  If we take on new
efforts, they should focus on transportation-related

                         -  20  -
To the extent the 1980 budget is not adequate to complete
the required pre-regulatory work for light duty vehicles
and tires, the Agency should not make formal commitments.
These sources would then be a major initiative in the
1981 budget.

     Although I am attracted by the idea of using noise
labeling as a method of enhancing consumer choice, I
believe we should complete promulgation of the general
labelling and hearing protector regulations first.  Any
proposal for additional work in the labeling area in
1980 must be carefully tailored to fit within available
resources and my desire for us to complete pending
actions.  An expanded program may be considered in 1981,
but it should have a lesser priority than work related to
transportation sources.

     I am anxious that we show material progress in
implementing the Quiet Communities Act.  To the extent
that our stated goals of 400 communities and 40 States
with effective noise programs provide a real basis for
program planning, our program plans for both 1980 and
1981 should clearly indicate projected progress against
these goals.

     We should likewise display our actions to undertake
investigations and studies on a more complete health
base for noise control against a specified objective.  I
think it important that we develop an outline which
indicated the areas in which new information should be
produced on a priority basis and that our proposed
research-related plans in both 1980 and 1981 indicate how
they will meet our needs as outlined.

     In radiation the mission of EPA is now reasonably
well defined as a result of the IRG Report, Libassi
Committee deliberations, NRC Agreements, and our own
actions in developing criteria for waste disposal.  The
IRG Report indicating the multi-agency nature of the
Federal government's nuclear waste management program
should be used as a blueprint for defining the scope of
and timing required for EPA standard-setting in this
area.  The program focus in 1980 should be on actions
delineated in that report.

                         -  21  -
     The priority we give to actions under the Clean Air
Act must be a product of the reduction in radiation risk
which such actions can accomplish compared to reduction
achieved in other radiation programs.  To the extent that
priority must be given to the issue of radioactive waste,
and/or to the completion of standards required under the
Uranium Mill Tailings Act, I am willing to accept a slower
rate of progress on Clean Air Act-related problems in 1980.
Nevertheless, the program plan for 1981 should present a
full range of actions to effectively implement our deter-
minations on the nature of radioactive air pollution
problems, we should assign them high priority.

     Given the acknowledged limitations of our resources,
I would expect only limited EPA resources devoted in 1980
to implement EPA's general authorities to provide Federal
radiation guidance.  I would much prefer that we take time
to establish an interagency committee to review the poten-
tial scope of the guidance function and assess priorities
as our major program action in the guidance area in 1980.
Implementation of the committee's recommendations would
follow in 1980 and 1981.  Additional resources for EPA in
1981 could be sought where necessary to supplement the
resources of other agencies.


          Overview Statement of Priorities and Goals

          Thomas C. Jorling, Assistant Administrator
     The priority objectives of EPA's Water and Wastewater
Management programs are to implement statutory mandates
providing for:

     o  Achievement and maintenance of the physical,
        chemical, and biological integrity of the Nation's
        ground and surface waters, with special emphasis
        on protection of public health and sensitive
        aquatic ecosystems;

     o  Treatment, containment, and control of toxic and
        hazardous materials in solid waste;

     o  Protection of an adequate supply of high quality
        drinking water for public consumption; and

     o  Federal, State, and local development of integrated
        environmental management systems which minimize
        transfers of pollutants between media and which
        identify optimal ultimate disposal strategies for

     The objectives described above can be achieved most
efficiently in terms of both dollars and manpower through:

     o  Effective use of State planning and program funds
        to implement water quality management, water supply,
        and solid waste management goals through State/EPA

     o  Management of the $4 billion/year construction grants
        program to meet the treatment needs of publicly owned
        treatment works (POTW's) effectively at least cost to
        all levels of government;

     o  Application of alternative, innovative, and cost-
        effective technologies and management practices
        to solve water and solid waste pollution problems;

     o  Emphasis on resource recovery, reuse, and recycling
        to conserve energy, materials, and water.

                          - 23 -
     The objectives and management tools to achieve them will
be delivered within a context of program integration and
consolidation.  An integrated focus for the Agency and for
OWWM in particular arises because the Resource Conservation
and Recovery Act (RCRA) closed the gaps in the waste disposal
cycle left by previous air and water legislation by providing
control for the disposal of pollutants in or on the land.
Since there is no "free dumping ground", an integrated
approach is necessary to determine the best mix of environ-
mental controls to minimize the adverse effects of pollution.
These integrative efforts will be manifest in the way we
deal with identifiable areas of control or regulation.  For
example; many programs within OWWM act on specific chemicals.
When one program is dealing with a chemical, it is imperative
that all programs regulating that chemical share knowledge,
experience, and implementation.

     Integration of water quality, water supply, and solid
waste programs will generally occur at the State level via
the State/EPA Agreement process.  EPA will encourage States
to conduct integrated problem assessments, develop long-term
strategies to solve their water and waste management problems,
and commit to one-year work programs to implement their
strategies.  In return, EPA will supply program and planning
grants from the Clean Water Act (CWA), Safe Drinking Water
Act (SDWA), and RCRA to assist the States that undertake
integrated approaches.

     An integrated State/EPA agreement process is a logical
outgrowth of the Water Quality Management (WQM) program,
which is a key focus of the Office of Water and Waste
Management.  The major goal of WQM is the development of a
State and local decision-making process to control point and
nonpoint sources of pollution.  Current WQM efforts are
concentrated on plan implementation to achieve water quality
improvements.  Continuing WQM grants will only be made to
State and areawide agencies who can show evidence of imple-

     In managing the $4 billion/year construction grant
program, the Agency will consider publicly-owned treatment
work systems as a structural and functional component of
human community.  This should enable questions relating to
levels of performance and technology, operations and
maintenance, sludge management, pretreatment, toxics,
combined storm water overflow and urban drainage to be
viewed as parts of a single system.

                           - 24 -
     EPA's strategy for 1980-81, then, is to orient funding
toward meeting environmental requirements through stringent
cost-effectiveness review and to stress innovative and
alternative approaches to waste treatment, including water
and energy conservation, reuse and recycling of pollutants,
and small systems.  Funds earmarked for State delegation
under Section 205(g) of the CWA will be directed toward
State assumption of program activities with high pro-
fessional quality consistent with Congressional policy and
requirements.  In addition, the construction grant program
will move rapidly toward reinforcing other Agency actions
such as the control of toxics and enforcement objectives
through implementation of the municipal enforcement strategy.

     Industry is a key focal point for the application of
technology and management practices to control environmental
pollution.   The multiple controls on industry must be
applied in a coherent way to a single facility or industry
category to control toxic and hazardous pollutants effectively.
The available control mechanisms include spill prevention
control plans; best management practices for toxics; BAT,
pretreatment, new source performance standards, and BCT;
RCRA hazardous waste controls; and underground injection
control (UIC).

     This arsenal of controls will be implemented coherently
through consolidated permitting of NPDES, RCRA Section 3005,
and UIC permits.  Permit consolidation will enable concen-
tration on programmatic, environmental, and procedural
permitting elements which allow technical and legal talents
to be applied effectively and efficiently to achieve environ-
mental objectives.

     All OWWM programs will emphasize conservation of our
precious natural resources:  energy, water, minerals and
other materials.  The resource recovery program will strive
to maximize the use of energy and materials which are
currently disposed of as solid wastes.  Municipal and
industrial point source control programs will stress
reuse of wastewater and recycling of pollutants through
standards, permits, and financial assistance.  In parti-
cular, the construction grants program will focus attention
on multi-purpose projects which recover energy and materials
and reuse wastewater.

     Four final OWWM priority areas are:  attention to
specific ecosystems; development of criteria and standards;
implementation of new OWWM public participation regulations;
and emergency response.

                  - 25 -
An important focus is on specific ecosystems or
subsets of ecosystems, such as:  ground water as it
is influenced by the programs of OWWM; wetlands
protection as it is specifically achieved by the
regulatory program under section 404, and wetlands
as influenced by such other factors as solid waste
facility siting, treatment systems siting, and
others.  The oceans represent another ecosystem
which is high priority and can only be protected
by the integrated application of OWWM programs.

Another integration of OWWM activity ranging across
all programs is in development of criteria and
standards.  Water quality criteria, 404 criteria,
403 criteria, safe drinking water standards, and
hazardous substance criteria all will be looked at
as they are developed, issued and applied.

Overall public participation regulations for water
quality, water supply and solid waste programs,
which were promulgated in February 1979, will be
implemented in 1980.  These regulations support
program integration objectives by standardizing
certain public participation requirements for OWWM
programs.  They should foster more effective and
constructive public involvement across these

1980 must see the emergency response capabilities
of OWWM integrated so that the various authorities
under the Safe Drinking Water Act, Resource
Conservation and Recovery Act, and the Clean Water
Act are carried out in a coherent way by adequately
trained people.  We must build on the emergency
response capabilities already in place under
section 311 and expand them to recognize that the
response is attentive not just to surface waters
but also to ground waters and to the landscape
and atmosphere.


    Overview Statement of Priorities and Goals

    Steven D. Jellinek, Assistant Administrator
     This Overview Statement lays out what I believe
to be the important priorities for achievement by the
pesticides and toxics programs for the years 1980
and 1981.  As such, it represents my "guidance" to
the managers and staff of the two programs and infor-
mation of interest to our colleagues throughout the

     I have arranged the objectives for each into
"general" and "specific" categories.  The specific
objectives are subdivided further into "highest"
priority, "high" priority, and "other."  We have no
low priority objectives.

     The general objectives are provided to give a
sense of what I believe are the thrust and tone of
the programs.  The specific objectives are more in
the nature of outputs I expect to be delivered.


General Objectives

     o    Continue the thrust toward institution-
          building.  From the organizational per-

               Secure adequate space.

               Staff up to budgeted levels with
               qualified professional and support
               personnel, with special efforts on
               increasing the number of women
               and minorities.

          -    Organize to the branch level.

                       - 27 -
     From the regulatory perspective:

               Place more emphasis on premanufacture
               review, test standards, and test rules.

               Give less emphasis to existing chemical

     o    Complete the development of a priority
          setting system for choosing chemicals for
          testing and regulation under TSCA and
          other statutes; clarify and establish the
          role of the Toxic Substances Priorities
          Committee in this system.

     o    Develop a detailed program planning system
          for each DAA-ship.

     o    Clarify the regional role in TSCA implementation.

Specific Objectives

     Highest Priority

     o    Publish the Chemical Substances Inventory.

     o    Promulgate the final regulations on premanu-
          facture notification; establish and operate
          a system for screening and assessing notices;
          and take actions under TSCA sections 5Ce)
          and 5(f) to prevent or control the manufacture
          of new chemicals, as required.

     o    Promulgate a final regulation establishing
          test standards for oncogenicity, chronic
          toxicity, combined oncogenicity and chronic
          toxicity, and good laboratory practices.

     o    Propose the first section 4 test rule
          requiring industry to test 20-30 chemical
          substances and categories of substances.

     o    Propose a rule under section 8(a) to develop
          basic use/exposure information on approximately
          2-3,000 chemicals to aid in setting priorities
          for regulation.

          Propose a regulation under section 6 banning
          or limiting the use of one existing chemical
          that poses an unreasonable risk to public

          Fully implement the program to help States
          and school districts identify and control
          asbestos in school buildings.
High Priority
          Propose testing guidelines for premanufacture

          Propose remaining test standards for health
          effects and several fate and ecological
          effects test standards; resolve inconsis-
          tencies with pesticides testing guidelines.

          Conduct health and environmental effects
          assessments, monitoring, and economic impact
          analyses to support regulation of new and
          existing chemicals.

          Follow premanufacture notices with individual
          "significant new use rules" and/or individual
          section 8(a) information rules for a few
          selected new chemicals, as required.

          Begin the development of generic follow-up
          systems for "significant new use rules" and
          section 8(a) information rules for new

          Begin developing proposed regulations banning
          or limiting the use of an additional 2-4
          existing chemicals that pose an unreasonable
          risk to health or the environment.

          Complete an analysis of the issues concerning
          the impact of testing costs on small volume
          chemicals and, if appropriate, develop
          proposed legislative solutions.

                       - 29 -
          Continue the development of TSCA and inter-
          agency chemical information systems and data

          Complete the development of responsive and
          effective document control data services,
          and FOI procedures.

          Develop model rules for information gathering
          under section 8(a).
     o    Develop a process to review and act expedi-
          tiously on carcinogens, mutagens,  and terato-
          gens under section 4(f).

     o    Initiate the development of generic approaches
          to banning or controlling the use of chemicals
          under section 6.

     o    Promulgate the PCB ban rule.

     o    Provide industry assistance on TSCA require-
          ments .

     o    Distribute State grants.

     o    Continue development of public participation

     o    Support OECD and other planned international
          harmonization programs.

     o    Propose model regulations under section 8(c)
          -and 8(d) to require recordkeeping and submission
          of health and safety studies concerning signifi-
          cant effects of chemicals.


General Objectives

     o    Continue the thrust toward institution-
          building.  From the organizational perspective:

                       - 30 -
               Staff up to budgeted levels with
               qualified professional and support
               personnel, with special efforts on
               increasing the number of women and

               Build effective staff teams through
               management actions and training.

     From the regulatory perspective:

               Fully operate premanufacture review
               and test rule development.

               Increase emphasis on existing chemical
               regulation, both individual and generic

     o    Operate a priority-setting system for choosing
          chemicals for testing and regulation under TSCA
          and other statutes, in conjunction with the
          Toxic Substances Priorities Committee.

     o    Operate a detailed planning system for the
          toxic substances program; initiate formail
          evaluation; modify program design, as needed,
          to increase quality and quantity of output;
          develop, jointly with the R&D community,
          specific program requirements for high
          priority research; examine the need for
          major legislative changes in 1981.

Specific Objectives

     Highest Priority

     o    Fully operate the premanufacture notification
          review process; take actions under sections
          5(e)  and 5(f)  to prevent or control the
          manufacture of new chemicals, as required.

     o    Promulgate the section 4 test rule proposed
          in 1979; propose and promulgate additional
          test rules.

     o    Conduct health and environmental effects
          assessments, monitoring, and economic
          impact analyses to support regulation of
          new and existing chemicals.

                  - 31  -
     Promulgate the section 6 regulations proposed
     in 1979 banning or limiting the use of one
     chemical; propose section 6 regulations for
     several additional existing chemicals.

     Promulgate the section 8(a) information rule
     on 2-3,000 chemicals proposed in 1979.
High Priority
     Promulgate final testing guidelines for premanu-
     facture notification.

     Propose and promulgate model rules under
     section 8 (a); promulgate model rules for
     sections  8(c) and 8(d).

     Promulgate the full set of health effects test
     standards and the fate and ecological effects
     test standards proposed in 1979; propose
     additional fate and ecological effects test

     Futher develop and begin to use generic
     follow-up systems for "significant new use
     rules" and section 8(a) information rules for
     new chemicals.

     Publish the revised chemical substances
     inventory; maintain the integrity of the

     Develop proposed regulations implementing
     generic approaches to regulation under
     section 6.

     Begin partial operation of TSCA and inter-
     agency chemical information systems and data
     bases; continue systems development.

     Review and act expeditiously on carcinogens,
     mutagens, and teratogens under section 4(f).
     Begin reviewing existing test standards as
     required by section 4.

                       -  32 -
     o    Begin review of overall economic and
          innovation effects of TSCA.

     o    Provide industry assistance on TSCA require-

     o    Continue to develop public participation

     o    Support OECD and other planned international
          harmonization programs.


General Objectives

     o    Achieve institutional maturity.  From the
          organizational perspective:

               Have a stable organization in place with
               technically and managerially qualified

     From the regulatory perspective:

               Fully operate all major program com-

               Balance emphasis on regulation of new
               and existing chemicals.

     o    Operate an integrated priority-setting system
          for choosing chemicals for testing and regu-
          lation for TSCA and other statutes, in con-
          junction with the Toxic Substances Priorities

     o    Operate a detailed planning and evaluation
          system for the toxic substances program;
          explore alternatives to established regu-
          latory approaches.

     o    If appropriate, develop and support pro-
          posals for major legislative changes.

                       -  33 -
Specific Objectives

     Highest Priority
          Fully operate the premanufacture notification
          review process at an improved level; take
          actions under sections 5(e)  and 5(f) to pre-
          vent or control the manufacture of new chemicals,
          as required.

          Promulgate and propose regulations under section
          6 with greater emphasis on generic approaches,
          banning or limiting the use of a significantly
          greater number of existing chemicals that pose
          unreasonable risks to public health.

          Conduct health and environmental effects
          assessments, monitoring, and economic impact
          analyses to support regulations of new and
          existing chemicals.

          Continue promulgating rules under sections 4
          and 8 to obtain data to support assessment
          and regulation.
     High Priority
     o    Revise testing guidelines for premanufacture
          notification to provide more specific guidance,

     o    Complete fate and ecological effects test
          standards; review existing test standards
          as required by section 4.

     o    Use routine, generic follow-up systems for
          "significant new use rules" and section 8(a)
          information rules for new chemicals.

     o    Complete chemical information systems
          development; operate systems, services, and
          data bases at full scale.


     o    Continue actions under 4(f) .

     o    Maintain industry assistance.

                       - 34 -
     o    Continue to develop public participation

     o    Support international harmonization programs.

     o    Continue TSCA overall economic and innovation
          impact studies.

     o    Evaluate and refine operating programs.


General Objectives

     o    Continue the thrust toward institution-building.
          From the organizational perspective:

               Secure adequate space.

               Staff up to budgeted levels with qualified
               professional and support personnel, with
               special efforts on increasing the number
               of women and minorities.

               Complete the reorganization; fill senior
               line positions.

     From the regulatory perspective:

               Place more emphasis on completing major
               RPAR actions, initiating conditional
               registration, establishing the registra-
               tion standards process, and making
               registration decisions on new chemicals
               with adequate hazard data.

 —      -    Give less emphasis to large-scale
               operation of the registration standards

     o    Develop management systems for expediting
          decisionmaking on high volume operations,
          such as registration and registration

     o    Develop a detailed program planning system.

     o    Clarify the regional role in FIFRA implementation,

                       - 35 -
Specific Objectives

     Highest Priority
          Review benefits and risks of 15-20 RPAR com-
          pounds identified as posing potentially
          unreasonable adverse effects.

          Reach 17-23 final risk/benefit determinations
          on RPAR compounds.

          Implement the conditional registration program.

          Process 25-30 new registrations,  5,000-5,600
          administrative/technical amendments and 2,000-
          2,500 routine/intrastate registrations in an
          efficient,  effective manner.

          Give registration priority to new chemicals
          for which complete hazard data are submitted.

          Inititate the preparation of 42-47 generic
          standards,  including the reassessment of
          associated tolerances.

          Evaluate the scientific basis of  the system
          for establishing tolerances, including con-
          sideration of inert ingredients in order to
          revise tolerance regulations.
     High Priority
          Provide timely and responsive guidance to the
          States relative to their FIFRA section 5(f)
          experimental use permits and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

          Review 1,000-1,500 section 24(c)  special local
          needs registrations and conduct overview
          activities on their final actions.

          Review 170-220 section 18 emergency exemptions
          in a median turnaround time of 4  weeks,  including
          full scientific review of pertinent data.

                       - 36 -
          Develop proposed guidelines for biological

          Establish 80-120 pesticide residue tolerances
          and review 75-100 amendments for food and
          animal feed crops after review of data and
          Tisk/benefit analyses in a median turnaround
          time of 105 days.

          Accelerate the program to classify pesticides
          for restricted use.  Aim for completion in

          Develop and initiate procedures to require
          early testing to fill data gaps on existing
          compounds instead of waiting until such geips
          are identified in the development of generic

          Integrate IPM into the RPAR process and into
          regulatory actions (e.g., section 18 emergency
          exemptions) when technically appropriate.
          Audit 50-70 testing laboratories.

          Develop more precise procedures for handling
          confidential business data.

          Conduct training program.

          Improve FOI response procedures, so that all
          requests are given an initial response
          within 10 days and a final response as
          quickly as possible.

          Monitor for hazard prediction and significance
          of potential problems.
General Objectives
          Continue the thrust toward institution-
          building.  From the organizational perspective;

               Build effective staff teams through
               management actions and training.

                       - 37  -
     From the regulatory perspective:

               Emphasize completion of the remaining
               RPAR reviews,  increasing production of
               registration standards, and registration
               decisions on new pesticide chemicals.

               Initiate reregistration of existing

     o    Operate priority-setting systems for selection
          of chemicals for the registration standard
          process and for priority registration decisions.

     o    Operate a detailed planning system; initiate
          formal evaluation;  modify program design, as
          needed, to increase quantity and quality of
          output; develop, jointly with the R&D
          community, specific program requirements for
          high priority research.

Specific Objectives

     Highest Priority

     o    Review benefits and risks of 12-17 RPAR com-
          pounds identified as posing potentially un-
          reasonable adverse effects.

     o    Reach 15-20 final risk/benefit determinations
          on RPAR compounds.

     o '   Implement the conditional registration

     o    Give registration priority to new chemicals
          for which complete hazard data are submitted.

     o    Reregister 1,000-1,400 products from available
          generi c s tandards.

     o    Complete the generic standards initiated last
          year, and initiate the preparation of 40-50
          generic standards,  including the reassessment
          of associated tolerances.

                       - 38  -
     High Priority
          Provide timely and responsive guidance to the
          States relative to their section 5(f)  experi-
          mental use permits, and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

          Review 1,000-1,500 section 24(c)  special local
          needs registrations and conduct overview
          activities on their final actions.

          Review 170-220 section 18 emergency exemptions
          in a median turnaround time of 4 weeks, in-
          cluding full scientific review of pertinent

          Promulgate guidelines for biological pesticides

          Establish 80-120 pesticide residue tolerances,
          and review 75-100 amendments for food and
          animal feed crops after review of data and
          risk/benefit analyses, in a median turnaround
          time of 105 days.
          Audit 50-70 laboratories.

          Improve FOI response procedures, so that all
          requests are given an initial response within
          10 days and a final response as quickly as

          Monitor for hazard prediction and significance
          of potential problems.
General Objectives
          Achieve institutional maturity.  From the
          organizational perspective:

                       - 39 -
          -    Have a stable organization in place,
               with technically and managerially
               qualified staff.

     From the regulatory perspective:

          -    Fully operate all major program com-
               ponents .

               Substantially complete RPAR.

     o    Operate an integrated priority setting system.

     o    Operate a detailed planning and evaluation

     o    Intensify strategy for replacement of older
          pesticides with unknown or hazardous effects
          with new, safer pesticides and alternative
          pest control actions.

Specific Objectives

     Highest Priority

     o    Integrate the  RPAR process into the generic
          standards production process.

     o    Give registration priority to innovative,
          environmentally protective compounds.

     o    Reregister 1,000-1,400 products from available
          generic standards.

     o    Complete the generic standards intiated last
          year, and initiate the preparation of 40-50
          generic standards, including the reassessment
          of associated  tolerances,  with attention to
          detail and quality.

     High Priority

     o    Provide timely and responsive guidance to
          the States relative to their section 5(f)
          experimental use permits,  and review 180-240
          section 5 registrations in a median turn-
          around time of 120 days.

                  -  40  -
o    Review 1,000-1,500 section 24(c) special
     local needs registrations, and conduct
     overview activities on their final actions.

o    Review 170-220 section 18 emergency
     exemptions in a median turnaround time of
     4 weeks.

o    Establish 80-120 pesticide residue tolerances,
     and review 75-100 amendments for food and
     animal feed crops after review of data
     and risk/benefit analyses, in a median turn-
     around time of 105 days.
     Audit 50-70 laboratories.

     Improve FOI response procedures, so that all
     requests are given an initial response within
     10 days and a final response as quickly as

     Monitor for hazard prediction and significance
     of potential problems.

                    OFFICE OF ENFORCEMENT

          Overview Statement of Priorities and Goals

          Marvin B. Burning, Assistant Administrator
     This guidance builds upon the top priority activities
set out for enforcement in the EPA Policy Guidance for
FY 1979/80.  The activities described are our top enforce-
ment priorities, not a complete list of all enforcement
activities.  These priorities are stated as programmatic
priorities and as management-institutional priorities, but
the two are obviously interrelated.


Enforcement in Emergencies

     All EPA, State, and local enforcement personnel should
give top priority to any true emergencies involving sub-
stantial threats to public health and safety.  Containment
and removal of the dangers is, of course, the top priority.
Follow-up on penalties for violations can be undertaken in
the course of other enforcement, rather than as an emergency,
This guidance applies, of course, to emergency enforcement
response to hazardous spills.

     At this time in FY 1979, EPA personnel have as their
top priority the investigation and prevention of substantial
and imminent hazards created by existing or abandoned
chemical waste sites.  Those efforts will continue as facts
may dictate.  We expect a large number of civil actions of
this nature in FY 1980 and 1981.

Major Source Enforcement Effort

     The major source enforcement effort against violators
of the Air Act and Water Act is our next highest priority
after emergency situations.  Enforcement against these major
sources is critically important to accomplishing our environ-
mental goals.  It is directed against that small minority of
major sources which failed to meet the requirements of the
Air and Water Acts by the statutory deadlines.  It includes
many of the most serious and most recalcitrant sources of
pollution in the country.  By bringing these sources into
compliance, with penalties where appropriate, we will keep

                          - 42  -
faith with the great majority of firms and public bodies
which met their responsibilities and will build the
confidence necessary to continue voluntary compliance
with all the environmental laws.

     In FY 1980, Regions and States will bring the major
source enforcement actions to decision by settlement,
administrative process, or court trial, including
appropriate penalties, and make or defend appeals.  By
the end of FY 1980, the major source drive should be
nearly completed, with only a few actions and appeals
still pending in trial or appellate courts.  In FY 1981,
actions and appeals still pending should be completed as
rapidly as possible.

Enforcement against Automobile and Truck Pollution

     Because of the great public health and environmental
significance of air pollution from automobiles and trucks,
especially in urban areas, enforcement against mobile
sources of pollution will continue to be a top enforcement
priority in FY 80/81.

     EPA enforcement will continue to ensure that new
vehicles meet emission standards.  We will increase our
emphasis on maintaining the effectiveness of emission
control systems throughout the period of their use.  To
achieve this, EPA's main emphasis will be on inspection
and maintenance systems in the major nonattainment areas
for auto-related pollutants, supplemented with Head-
quarters audits and I/M programs.

     o   To ensure that new vehicles meet standards, EPA
         enforcement will continue our assembly line
         audits, recall and warranty efforts.

     o   To ensure that cars in use meet standards and to
         support introduction of inspection and maintenance
         systems where needed, EPA will continue to focus
         investigations and enforcement actions (a) on
         national or regional fleets, chains, dealership or
         repair facilities, or "pattern" violations and (b)
         in major metropolitan areas where auto pollution
         is high and I&M will be introduced.  EPA will
         encourage State and local anti-fuel switching and
         anti-tampering efforts.

                          - 43 -
     We will use private, State, or local contracts to
carry out inspections to ensure the availability and purity
of unleaded gasoline, and the installation and operation of
vapor recovery systems on fuel delivery trucks and at
gasoline outlets.

     EPA and the States, in cooperation with other agencies,
will implement any programs authorized to control the
leaded-unleaded gas price differential and other authorized
environmental/energy programs.

Consolidated and Simplified Permitting

     EPA is consolidating its permit programs, both to
simplify administrative steps and to get all important
environmental problems addressed in a single process.  By
October 1, 1979, companies will be able to submit just
one application for all water, solid and hazardous waste
permits, go through one review, and be issued one permit.
We expect application forms for air quality permits to be
consolidated in late FY 1980  (or early FY 1981).  NPDES
second round permits under the Clean Water Act will be
issued throughout FY 1980/81.  We will begin to issue
hazardous waste permits in late FY 1980, accelerating in
FY 1981.  We will also start  issuing Underground Injection
permits in FY 1981.

     In all permitting activities, we will give first
priority to large or major sources with serious adverse
health effects, including those with significant toxic

Full Federal Compliance

     President Carter has directed all Federal facilities
to come quickly into compliance with Federal, State, and
local environmental requirements.

     By the end of 1980, we expect all, or almost all,
Federal facilities both major and minor sources will be
in compliance.   Regions should see to it that all Federal
facilities do indeed come into compliance as soon as
possible.  EPA will ensure that Federal agencies request
necessary funds for compliance by reviewing the agencies
plans included in the annual A-106 report.

                          - 44 -
     EPA is encouraging the States to assume these respon-
sibilities for Federal facilities.  The States should
find the managers of Federal facilities cooperative.  EPA
will assist the States in getting any disputes resolved.

Stationary Sources

     Completing the Major Source Enforcement Effort contin-
ues to be of highest priority in FY 1980/81, including the
monitoring of compliance orders to ensure that sources comply
with the terms of the orders.  We also want to ensure that
major sources comply with new requirements placed on them
by SIP revisions and by the ambient standards for lead, and
to enforce new source performance standards and national
emission standards for hazardous air pollutants.

     As the Major Source Enforcement Effort is completed in
FY 1979/80, EPA will design and implement an improved program
of compliance monitoring and enforcement to ensure continuous

     During FY 1979, regulations will be promulgated for
administrative assessment of noncompliance penalties under
Section 120 of the Clean Air Act.  This program should be
fully implemented during the second half of FY 1979 and
throughout FY 1980/81.  Prompt implementation of these
penalties should assist in obtaining and maintaining
compliance with the Air Act.

Water Enforcement

     Completion of the Major Source Enforcement Effort,
including actions against publicly owned treatment works
(POTW's), continues to be of highest priority in FY 1980/81.
As this effort is completed, EPA will design and implement
an improved program of compliance monitoring and enforcement
to ensure continuous compliance.

     Beginning in FY 1979 and growing in importance in
FY 1980/81 will be advice and assistance to delegated States
so that State pretreatment programs can be established and
the conditions of those programs enforced.  During FY 1981
the activities of assisting and advising States and POTW's,
modifying permits to incorporate pretreatment requirements,
approving POTW treatment programs, notifying affected
indirect dischargers, and determining treatment levels
should be at their peak level and of prime importance if we
are to achieve compliance by all affected POTW's and indirect
dischargers by FY 1983 or FY 1984.  NPDES permits will be
issued as part of the consolidated permits program.

                          - 45 -
Strategies for New Programs (TSCA, RCRA, SDWA, FIFRA)

     In recent years, Congress has provided new programs
and has amended existing statutes to respond to the threats
of chemical poisons, hazardous wastes, and pesticides, and
to protect drinking water supplies.  We must carefully
devise or revise enforcement strategies under the additional
provisions of the Toxic Substances Control Act (TSCA), the
amended provisions of the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA), the hazardous waste provisions
of the Resource Conservation and Recovery Act (RCRA), and
the Safe Drinking Water Act (SDWA).

     Under RCRA, our priority enforcement activities in
FY 1980/81, in addition to responding to emergencies,
include monitoring and enforcing the notification program
(Section 3010); reviewing proposed State programs for
enforceability and adequacy; issuing permits, monitoring
permitted sites, and ensuring that Compliance Schedules
are met; and monitoring and enforcing the manifest

     Under TSCA, our compliance monitoring and enforcement
will initially focus on PCBs, chlorofluorocarbons, inventory
requirements and to premanufacturing notice requirements.
We will continue our special investigative efforts regarding
the accuracy and truthfulness of laboratory test data in
the toxics and pesticides programs.

     Under FIFRA, during FY 1980/81 EPA will attempt to
develop cooperative enforcement grant programs with the
remaining seven States (for a total of 50) and will
continue to enforce regulations on pesticide use until
States assume this responsibility.

     Under SDWA, EPA will respond to emergency situations
threatening public health and will concentrate on enforce-
ment of primary drinking water standards, particularly in
non-primary States.

Noise Control

     The noise enforcement program will continue to ensure
compliance with standards and requirements for products and
procedural labeling as its top priority.  Although urban
noise can often be controlled through State and local efforts,
it continues to be a Federal responsibility to ensure that
products meet the standards established under the Noise Act.
EPA Headquarters will carry out this function.

                          - 46  -

     In addition to the preceding programmatic priorities,
we have a number of management and institutional improve-
ments as top priorities.  These improvements have to some
degree already been described in the programmatic priorities
and they obviously interrelate with them.

     o  Consolidated Permitting — EPA will consolidate
        and simplify its permitting activities, mostly
        during FY 1979 and totally by the end of FY 1980.
        It will assist and encourage States to do so as

     o  Industry Enforcement Strategies — During FY 1979
        and FY 1980 EPA will develop and implement industry
        enforcement strategies for selected industries.

     o  Continuous Compliance — We will develop programs
        for ensuring continuous compliance by regulated
        sources, including compliance monitoring (and
        information systems for recording and tracking
        compliance), penalties to remove the economic
        benefit of non-compliance and remote sensing

     o  Improved Oversight of State Enforcement — During
        FY 1979 and thereafter, Headquarters and Regional
        personnel will begin to apply standards of perfor-
        mance to State enforcement activities under all
        Federal grants or contracts for enforcement.

     o  Management and Management Information Systems —
        During FY 1979 and FY 1980 as needed, we will
        review our management, reporting, and information
        systems (including ADP systems).  Our emphasis will
        be on improved accuracy, usefulness, simplicity,
        and compatability.

     o  Improved Cooperation with Other Agencies —
        During FY 1979, 1980, and 1981, we will improve
        our cooperation with other agencies, such as the
        Department of Justice, the other members of the
        IRLG (OSHA, FDA, and CPSC), the Securities Exchange
        Commission (SEC), and the Departments of Energy and

                  -  47  -
Innovative Methods — Throughout FY 1979, 1980,
and 1981 the Office of Enforcement will explore
innovations such as widened use of penalties to
remove economic benefits of delay, environmental
auditing, and contracts or grants with citizen

Investigating Criminal Violations — During
FY 1980/81 EPA enforcement will improve its
ability to investigate criminal violations of
environmental laws by recruiting and training
EPA investigative personnel.


       Overview Statement of Priorities and Goals

     William Drayton, Jr., Assistant Administrator
     The Agency's central management objective remains that
of creating a national environmental program that derives
strength and initiative from decentralization and purposive-
ness and environmental coherence from effective integration.
Toward these and other ends we must strengthen our analytic
and common services in a number of areas.  This guidance
deals first with that central objective, then with other
objectives connected with our analytic and common services.


     From its inception EPA rejected the top-down, over-
centralized, untrusting Louis XIV/Herbert Hoover form of
management common to most government organizations, a form
that has failed.  Instead we are building on the philosophy
of the Federalist Papers:  decentralize and democratize
within a realistic set of incentives designed to ensure
organizationally responsible results.

     Not only are we doing what makes sense for EPA, but
we're setting the pace for others.  That's why others in
the government have quickly recognized so many of our
reforms as models.

     No matter how satisfying being out front is, however,
it doesn't make ground breaking any easier.  Although
we've come a long way, we still have several years of
intense work ahead of us:

     (1)  We should continue to strengthen our regulation
          development and zero-base budgeting.  They
          provide the structure that makes possible broad
          involvement in the Agency's two principal cross-
          cutting areas for decision making:  respectively,
          (a) regulation and policy development and (b)
          priority setting, management, and resource allo-
          cation.  Regulation development is mature, and
          ZBB is over the worst of its start-up pains.
          Both need continuing adjustment and strong support,

                    - 49 -
     The Regions should contribute more heavily to
     regulation development and review, especially
     regarding operational and resource issues.

     Last year ZBB focused heavily on process;
     henceforth it should focus more on substantive
     analysis: getting workload analysis fully
     implemented, finding efficiencies, developing
     new program initiatives, and re-examining older
     programs carefully.  We must also continue to
     help Office of Management and Budget develop
     cross-agency ZBB.

(2)   We need both stronger State programs and
     stronger State/EPA collaboration.  State and
     local officials now staff 85 percent of the
     national environmental regulatory effort,  and
     we are seeking to delegate even more.  We must
     strengthen our joint environmental management
     effort, especially in the following areas:

     -  We have more than doubled the .Federal grant
        support to State and local units since 1977
        (including the addition of the Clean Water
        Act, Section 205(g) funds).

     -  Our new State/EPA agreements should become
        more than contracts:  they should induce
        joint planning and they should press
        decision making up to the senior policy
        officials on both sides.  This should make
        it easier to refocus programs as our needs
        change and to innovate and integrate.  By
        1981 the agreements should cover all our

     -  We must win passage for and then implement
        our Integrated Environmental Assistance
        legislation to give the States the flexibility
        and added resources for such refocusing,
        innovation, and integration.

     -  We should encourage personnel interchange
        and training, e.g., through group IPA's.

(3)   Our Regional Administrators must strengthen
     their management/analytic capacity so that
     they can better manage their Regions, lead
     and evaluate the State and local agencies in

                         - 50 -
          their areas more effectively, and participate
          equally in Agency-wide policy and management
          decision making.  Unless the Regions' ability
          to think and manage is strong, both Regional
          decentralization and EPA's linkage with State
          and local government are at risk.  Headquarters
          analytic units must help the Regions develop
          this capacity, and both sides should build
          strong, continuing ties.

     (4)  Our managers should adopt Agency-wide career
          paths.  True independence, based ultimately
          on the real ability to move if frustrated,
          will flow from the professional breadth,
          self-confidence, and reputation such mobility
          will foster.  It will also give the Agency a
          management team with Agency-wide environmental
          perspective and loyalty, a critical step in our
          successful integration.

     (5)  The Agency's grantees, programs, and managers
          should be held accountable for their perfor-
          mance.  We do not do this core management task
          at all well now.  Our new personnel performance
          evaluation and reward program — probably our
          most demanding management reform for the next
          12 to 18 months — will make major difference.
          Our review of monitoring and the new Regional
          Profiles may help.  OUr fundamental scrutiny
          and rationalization of our many computer-based
          information systems will help.  A systematic
          regiment of evaluations beginning at the local
          and State levels and working up is critical.
          Such evaluations should be backed by a reformed
          reporting system and tied to the promises made
          in ZBB.  Designing and implementing a practical,
          integrated, limited-cost way of holding the
          States' and our own decentralized managers
          accountable is a difficult, missing part of our
          management construction.


     We will continue implementing a number of fundamental
improvements in the Agency's services in 1980-81:

                         - 51 -
     (1)  We must begin to manage EPA's personnel.  The
          new Civil Service Reform Act only makes this
          possible:  we will have to make it happen by
          changing the way each of our managers does his
          or her most important job.

     (2)  We will begin pilot tests of contracting reform
          in 1979 to improve responsiveness and cut
          processing time.

     (3)  The Agency will commit to new computers after
          a thorough management review of our data needs
          and of our existing and planned programs.


     Our analytic services — directly supporting our top
managers, helping prepare regulations, checking budget
pricing, providing legal or economic analyses, negotiating
with other agencies, and the like — must keep up with a
growing workload and maintain a superior level of pro-
fessional quality.  Compromise here is foolish.

     We must continue our leadership in regulatory reform.
Finding more effective, equitable, and economical ways of
doing our work is one of the most useful, highly leveraged
opportunities open to us.  (Further, as America's largest
regulatory agency, we have a responsibility to lead.  Our
two most important reforms are controlled trading and tools
for regulatory decision making, including benefits analysis,

     Once we set a standard for controlled trading of
clean-up requirements, we can allow those we regulate to
find more efficient ways of achieving the same (or better)
environmental result.  These alternatives must also be as
administrable and enforceable as our initial approach.
Offsets (in both non-attainment and PSD areas), the bubble,
banking, brokerage, and perhaps marketable rights should
gradually all fit together into an increasingly important
complement to traditional "command and control" regulation.
If we can make this approach work on a wide scale, we will
provide our first positive incentive for control technology
innovation and significantly reduce clean-up costs (and
therefore resistance to clean-up).

                          -  52  -
     To strengthen both performance and accountability
we should strengthen our program evaluation capacity at
all levels.  We should also play a stronger leadership
role in Administration debates on both economic and energy
policies; the best defense is a more sensible alternative.




Planning Assumptions

     New Source Review (NSR) — In FY 80, most States
     will have EPA approved State Implementation Plans
     for Prevention of Significant Deterioration (PSD).
     During FY 80, Regional Offices will curtail their
     review of PSD permit applications with the princi-
     pal Regional Office role in FY 81 being one of
     maintaining an overview of State and Local pro-
     grams with little or no direct EPA permit issuance.
     EPA will make maximum utilization of contractor
     support in conducting required permit review acti-
     vities in 1980 until State plans are approved and
     will utilize Section 105 grant funds to secure such

     Headquarters and Regional Offices will provide
     specific expertise and interpretation of Agency
     policy and guidance (ex. modelling) to States in
     implementing the PSD program.  In addition, the
     Regional overview function in FY 81 will give par-
     ticular attention to assuring consistency between
     adjoining States.  The Regional Offices with
     assistance from Headquarters will be involved
     in mediating/arbitrating issues relative to inter-
     state impact on growth plans and use of the increment
     particularly in high growth areas.

     The promulgation of regulations expanding PSD
     requirements to include carbon monoxide, nitrogen
     dioxide, and volatile organic compound emissions
     will be completed by Office of Air, Noise, and
     Radiation (OANR) by the end of FY 80.  OANR will
     support the States efforts to insure consistent
     policy in the review of new source permits and
     control technology determinations by maintaining
     a clearinghouse for these decisions.

     During FY 80/81, the number of New Source Performance
     Standard promulgations by OANR will be greatly
     increased.  These new emission limits will provide a
     general basis for determining required case-by-case
     Best Available Control Technology  (BACT) by either
     the State or Regional Office for sources subject
     to PSD.

                   - 56 -

In those States not delegated New Source Performance
Standards (NSPS), National Emission Standard for
Hazardous Air Pollutants (NESHAPS)  or having an
approved SIP for PSD, Regional Offices will con-
tinue to verify the compliance and initiate enforce-
ment action against new sources including Federal
facilities subject to NSR requirements which are in
violation of procedural, permit, or emission require-

The Office of Air, Noise and Radiation and the
Office of Enforcement in FY 80 will develop procedures
for the overview and audit of State new source review
activities including engineering determinations,
modelling, public notification, surveillance, and
enforcement to assure new source compliance with both
procedural and emission requirements.  This review
will also include adequacy of procedures for tracking
increment utilization, growth and impact on air
quality including Reasonable Further Progress in
attaining standards.

The consolidation of EPA new source permitting
programs will continue in 1980.  Inclusion of the
air permits into the consolidated program where
direct Regional Office permitting activities are
still necessary will occur in FY 81.

Carbon Monoxide and Ozone (CO/0-3) — During FY 80,
the review and possible revision of the National
Ambient Air Quality Standards  (NAAQS) for CO will
be completed.  It is expected that if there is a
revision to the CO standard, it will not signicarttly
change the number of major urban nonattainment areas
where the development and implementation of trans-
portation measures  (including automobile inspection/
maintenance  (I/M))  by the States would be necessary to
attain the standard by 1987.

In FY 80 followup actions to remedy deficiencies in
the 1979 SIP submissions will be completed by most
States and reviewed by Regional Offices.  Also, the
schedules contained in the 1979 SIP for developing
mandatory I/M programs, conducting a transportation
control planning process, and enacting additional
volatile organic compound (VOC) regulations consis-
tent with the Control Technology Guideline  (CTG)
documents will be met by most States in both FY 80/81.
Regional Offices will track the progress of States
in meeting these schedules with major guidance being

                   - 57 -

provided in the development of the transportation
planning process in urban areas greater than 1,000,000
population, and the development of mandatory I/M
programs.  The appropriation by Congress of any
additional Section 175 monies for support of the
transportation planning process is not expected in
FY 80 or 81.

Development of a regional ozone model will be completed
by the Office of Research and Development (ORD) in
FY 81 with support from OANR.  The model will serve
as a major tool in developing the appropriate strat-
egies by States for inclusion in the 1982 SIP sub-
mission for those major urban nonattainment areas
having an extension that are experiencing extensive
air quality violations and which will require imple-
mentation of complex and costly control measures to
attain by 1987.  Use of the model will require in
FY 1980 the development by the States of extensive
data bases within these areas  (i.e., emissions, air
quality, meteorology).  The establishment of National
Air Monitoring Stations (NAMS) for ozone and the
quality assurance of the data from these stations
should be completed by the States to provide the
ambient data necessary for model application.

Verification of compliance and initiation of necessary
enforcement action by the States against existing
stationary sources subject to the new VOC emission
limits included in the 1979 SIP and the additional
regulations required to be enacted by January 1980
will commence.  Regional Offices will work with
States to develop a strategy for these sources and
oversee State efforts to verify and secure compliance.
The Regions will initiate necessary enforcement action
where States fail or cannot act or request EPA
assistance.  The 1979 SIP is expected to increase
the number of major VOC sources subject to the SIP
by 3,000 with an estimated 6,000-8,000 additional
sources anticipated by the end of FY 81.

In FY 80, enforcement by EPA of anti-tampering and
fuel switching requirements in areas requiring man-
datory I/M programs will be initiated by Mobile
Source Enforcement Division  (MSED).  These actions
will assist in reducing the costs to the public of
passing a mandatory vehicle inspection.  States will
be encouraged to enforce existing State anti-tampering
or fuel switching regulations or to develop regu-
lations if none exist.

in FY 80, both EPA Regional Offices and the States
will establish more effective measures for informing
the public and securing public participation in the
strategy development and implementation process
particularly as it relates to the transportation
planning process and mandatory I/M programs.

Procedures will be established and implemented by
OANR to insure consistent application of sanctions
nationwide as required by Sections 176 and 316 of
the Clean Air Act where States fail to enact or
carry out necessary controls for the attainment of

The development and promulgation of additional mobile
source emission standards required by the Clean Air
Act will be completed by OANR in FY 80.

Total Suspended Particulates and Sulfur Oxides
(TSP and SOX) — In FY 80, the required review of
NAAQS for TSP and S02 will be completed by OANR with
necessary revisions to be promulgated by EPA in FY 81.
The review of the TSP standard may result in the
promulgation of new primary ambient standard for
inhalable particulates (IP) and subsequent secondary
ambient standards for sulfates and fine particulates
during FY 81.  The modification and promulgation of
additional TSP/S02 standards will require major State
efforts to revise the SIP in FY 81 with completion
required in FY 82.  In FY 80, efforts to refine the
definition of the nature and extent of the TSP prob-
lem  in urban nonattainment areas where re-entrained
fugitive dust is a major element will be conducted
by both ORD and the States in anticipation of the
new standards.

By the beginning of FY 80, all State or EPA-initiated
civil/criminal actions associated with the Major Source
Enforcement Effort (predominantly TPS and S02 sources)
will have been undertaken with decisions either by
settlement, administrative process, or trial completed
by the end of FY 80 and disposition of appeals com-
pleted as early as possible in FY 81.  The compliance
of Federal facilities with existing SIP requirements
will also be completed by EPA or the States by the
end of FY 80.  States in FY 80 will assume a larger
role in securing and maintaining the compliance of
Federal facilities.

                        - 59  -
     Delegation to the States of the non-compliance
     penalty program (Section 120)  initiated by EPA in
     FY 79 will be undertaken in FY 80 and accelerated
     in FY 81.   It is estimated that the program will be
     delegated to 15 percent of the States in FY 80 and
     to 30 percent in FY 81.

     In those cases where the States have not accepted
     delegation for the non-compliance penalty program by
     FY 81, Section 105 grant funds will be utilized by
     EPA for implementing the program.  These funds will
     provide contractor assistance for implementing the
     program to minimize impact on available EPA resources
     in assessing penalties.

     In FY 80/81 new programs devoted to ensuring that
     major TSP/S02 sources that have obtained or are
     presently in compliance remain in compliance will be
     initiated both by EPA and the States.  OE will
     complete development of an improved program in FY 80
     in consultation with the States and then secure
     State plans for implementing the improved program
     with the States focusing first on a limited number of
     selected troublesome sources.

     Toxics —  During FY 1980/81 emphasis on control of
     hazardous  pollutants will increase  as result of the
     Air Carcinogen Policy.   Promulgation of NESHAP
     standards  will be accelerated,   NESHAPS for benzene
     and arsenic are currently olanneri for FY 1980/81.
Goals/Priorities/Obj ectives

     The goal of the program is to protect public health
     and welfare through a combination of national efforts
     which provide for consistent and timely progress in
     rectifying existing air pollution problems and avoiding
     new ones.

     With respect to priorities, States were required to
     submit revised Implementation Plans in January 1979
     outlining their strategies for attaining ambient air
     quality standards in designated nonattainment areas.
     High priority will be given to correcting deficiencies
     in these SIPS and to providing adequate guidance to
     States in developing and implementing additional pro-
     grams required for the attainment of standards.  High
     priority will also be given to review of ambient air
     quality standards and development of supporting
     analyses for revisions to the standards.

                   - 60
Emphasis will be given to a program obtaining State
acceptance of full responsibility of all New Source
Review activities, providing adequate guidance for
development of PSD SIPs and maintaining an effective
national clearinghouse for NSR decisions.  The
clearinghouse will be used by both Regions/States to
assure consistent policy in conducting NSR.

The NSPS program will receive increased funding in
FY 80, thereby allowing work to begin on all NSPS
on schedules consistent with the statutory deadline.
When an Air Carcinogen Policy has been established,
development of NESHAPS consistent with that policy
will become a priority item.

In FY 80 priority will be given to establishment of
technically sound NAMS/SLAMS and implementation of
quality assurance measures to establish increased
credibility to air data.

Development of regulations for PSD Set II and
visibility will receive priority in FY 80.

The highest priority in the mobile source program is
the support of I/M implementation by States and the
development of requisite technical information on
evolving aspects of I/M programs, such as its appli-
cability to newer technology control systems.  Also
of importance will be the completion of the standard-
setting activities mandated by the Clean Air Act, and
the implementation of controls necessary to assure
public health protection.

During FY 1980, many standard-setting activities will
result in final rulemaking.  It is expected that
during FY 1981 the standard-setting program will shift
its priority focus to the control of hazardous pollu-
tants, bioactive materials, and emissions under non-
FTP conditions.

Enforcement priorities include:

     o    Enforcement actions in emergency situations
          involving substantial threats to public
          health and safety.

     o    Major Source Enforcement Effort against
          violators of the Clean Air Act.

                    - 61 -
     o    Enforcement against automibile/truck pollution.

             fuel switching
             inspection and maintenance program

     o    Fuel compliance by Federal Facilities.

     o    Review for enforceability in FY 1980/81 with
          respect to any continuing SIP revision work

     o    Section 120 noncompliance penalities

     o    Major source compliance with SIP revisions, and
          enforcement of NSPS and NESHAPS

     o    Improved program of compliance monitoring and
          enforcement to assure continuous compliance

Regional priorities are set forth in the Regional Guidance

The objectives of the Air Program Regional Activities in
1980 and 1981 are to:

     o    Assure attainment of standards in accord with
          the approved SIP schedules

     o    Assure consistent application of the law in all

     o    Increase the State responsibilities in new source

     o    Initiate enforcement actions in all appropriate
          emergency situations

     o    Complete all civil/criminal action associated
          with the Major Source Enforcement Effort

     o    Implement effective inspection and maintenance,
          anti-tampering, and fuel switching program

     o    Initiate civil/criminal actions and impose
          noncompliance penalties against all appropriate
          major sources in violation of SIP standards,
          NSPS, and NESHAPS

     o    Perform annual evaluations/audits of State
          enforcement programs

                        - 62 -

          o     Improve and have at least quarterly updcites of

          o     Assure full compliance by Federal Facilities

          o     Followup on all enforcement actions and
               compliance schedules
Research and Development

     In FY 81 and FY 81 the research and  development
     program will continue to carry out  its  extensive
     activities in support of the full range of  short- and
     longer-term needs of the Office of Air, Noise and
     Radiation Programs.   The program will include,  however,
     some major shifts in emphases in response to the
     changing nature of the air pollution problems.   The
     FY 80 program has already passed through ZBB process;
     its general contours have been established.   Therefore,
     we do not anticipate any major shifts to occur as a
     result of detailed plan implementation  in coordination
     with the relevant research planning  committees.   Shifts
     that do occur are expected to be at  a level  of resolu-
     tion that will not affect the FY 80  program.

     In FY 81, we do anticipate some major shifts in pro-
     gram emphases that will lead to redirection  of resources,
     These emphases reflect certain assumptions  about
     national and program office concerns with respect to
     the most pressing research needs.   In some  cases,
     the emphases flow directly from a research  plan,
     e.g., work on inhalable particulates, in others,
     they reflect ORD's attempt to get the jump  on what
     we anticipate to be program office  needs within the
     next five years.

     This guidance is not exhaustive. It merely  identifies
     the peaks on what is the much more  elaborate and
     extensive topography of the complete research program.

                         - 63 -
     The exact composition of the entire research program
     will be hammered out in detail in the deliberations
     of the appropriate research committees.  The guidance
     provides only the benchmarks for that detailed planning
     activity.  Effective with the FY 80/81 planning cycle,
     the major part of the Office of Research and Develop-
     ment (ORD) planning and management system is organized
     around 12 research committees.  These research
     committees provide the means for ORD to work jointly
     with representatives of the program offices in preparing
     research plans.

     All of the research in support of air program regulations
     in FY 80/81 is covered by the planning activities of
     four committees:

          1.   Oxidants (includes ozone, NOX and hydro-
               carbon research)

          2.   Gaseous and Inhalable Particles (includes
               SOX, nitrates, suspended particles, and

          3.   Mobile Source Air Pollution

          4.   Hazardous Air Pollutants (includes organic
               emissions as toxics, metals, such as Hg,
               As, Cd, and asbestos)

     For purposes of clarity and consistency, this research
     guidance has been organized along the lines of the
     research committee structure.  Such a division can
     never be totally clean.  For example, field studies on
     NOX and nitrates provide outputs that are valuable in
     addressing both the oxidant and the inhalable particles
     problem.  Similarly,  research on the characterization
     and control of fugitive emissions can address questions
     concerning both the suspended particle and the
     hazardous air pollutant problem.  The guidance does
     not attempt to deal with this ambiguity.  Rather each
     major effort is assigned to a particular research
     committee domain based upon that aspect of the study
     which appears most critical from a programmatic

Oxidants (Ozone, N0y, and Hydrocarbons)

     In FY 81, the health effects program will continue
     to focus on ozone.  Studies will be undertaken to
     determine conclusively the effects of low level

                    - 64  -
exposures on the cardiorespiratory efficiency of
health exercising individuals.  Also, an attempt
will be made to isolate the effects of low level
exposures to ozone on individuals suffering from
chronic lung disease, viz., asthma and bronchitis.
The effects of low level exposures on defense
mechanisms to bacterial and viral infection will also
be studied.

The program will also focus upon the potential health
effects from exposures to secondary photochemical
products such as formaldehydes, formic acid and
acrolein.  The ecological effects program will carry
out studies to determine the acute and chronic effects
of exposures to ozone on important and signal plant
species.  Assessment of impacts will include the
effects on productivity, quality, and basic processes
for forest and crop species and on integrated eco-
systems.  Some work will continue to assess the bio-
genie emissions from vegetation and their contribution
to ambient ozone and oxidant levels.

In the transport area, the FY 81 program includes a
commitment to continue ORD's program of targeted field
studies.  In addition the program includes continuation
for a major effort begun in FY 80 to assess the impact
of regional scale oxidants in the Northeast.  Laboratory
studies will complement the field studies in order to
provide a more comprehensive understanding of the
atmospheric reactions that occur among ozone precursors
(volatile organic compounds and oxides of nitrogen).

The characterization program in FY 81 will continue
field and laboratory measurements to determine the
formation and distribution of secondary photochemical
products associated with mobile and stationary sources.

In the control technology area, the effort wil continue
to demonstrate NO  control technology to include
industrial processes employing fuel combustion,
advanced control technology for stationary internal
combustion engines and gas turbines, and new techno-
logies for power plants.

Finally, the modelling area work will continue to
provide improvements with particular emphasis on
developing validated, multiday air quality simulation
techniques for ozone and oxidants.

                         -  65  -

Gaseous and Inhalable Particles  (includes S0y,  Nitrates
suspended particles and lead

     Inhalable particulates will continue to demand major
     attention in the FY 81 health effects research program.
     Animal toxicology studies will examine potential
     chronic effects of exposure to coarse and  fine particles,
     Clinical studies will  examine the acute, effects of
     exposure to combinations  of particulate pollutants.
     In addition, studies will continue on the  acute effects
     of exposures to N02, on healthy and sensitive popula-
     tions, and the short-  and long-term effects of exposures
     to nitric acid vapor and  nitrates, including the
     possibility of in vivo nitrosamine formation.  Finally,
     the health effects program  will contain a  significant
     effort in the area of  particle epidemiology studies.

     As part of the mandatory  5-year review and updating  of
     criteria documents, in the  area of secondary air
     quality standards, research will continue  to improve
     our ability to assess  the impact of gaseous and particle
     pollutants in the terrestrial environment.  Long-term,
     low-level chronic exposures of gaseous pollutants
     acting singly and in combination need to be further

     In anticipation of a possible change in the TSP
     standard that may include separate consideration of
     inhalable and fine particulates, the FY 81 program
     will include considerable effort in the areas of
     characterization and methods development,  modelling,
     and control technology for  inhalable particles.  The
     program includes an extensive emissions characteri-
     zation/emission factor program to provide  a national
     assessment of sources, concentrations, distributions,
     and components of particulate matter.  Control tech-
     nologies will be evaluated  with an emphasis upon
     their removal efficiencies  for inhalable size fractions
     and selected chemical  components.

     Paralleling the characterization effort will be a
     continuing program to  develop particulate  emission
     measurement equipment  and materials.  This research
     will address problems  of  continuous measurement, size
     distribution, and identification of individual com-
     pounds in particle emissions.  Studies will also try
     to establish signatures for emissions from different
     sources in order to attribute ambient air  particulate
     concentrations to specific  sources.

                      66  -
Transportation studies will include a continuing
major effort to provide validated multiday air quality
simulation models for sulfates, nitrates and other
inhalable particles.  The modelling research will
attempt to provide a means for assessing the long-
range impact of particle emissions on primary
standards and visibility under the assumption that
a secondary standard for visibility may be necessary.
During FY 81, data analysis and modelling activities
in State will be emphasized using the FY 80 experi-
mental results from the PEPE field intensive study.
These results will substantially support the develop-
ment of a visibility standard and of air quality
transport models.

Field studies of visibility will continue to better
identify the particle species and their source that
contribute most significantly to visibility reduction.
Methods development will continue to improve the
existing instruments and techniques for quantifying
visibility and related parameters.  The FY 81 modelling
program will also include a significant continuing
effort to evaluate, validate and apply an acceptable
complex terrain emissions assessment system.

The FY 81 program contains a significant effort to
deal with the problem of acid rain.  The emphasis of
the program will be on the solution of those aspects
of the problem are most critical and most amenable
to solution.  Most of the acid rain research will be
funded under the Anticipatory Research Program
(planned by the interdisciplinary Media), but some
ancillary  applied research will be funded by base
research under the Air Media.  Quality assurance in
FY 80 will continue to conduct and coordinate on-site
inspections and performance audits for the National Air
Monitoring Stations with some increased support to
EPA Regional reviews of State and Local Air Monitoring

Exposures assessment methods will also continue to
demand a significant share of the monitoring and
measurement techniques resources for inhalable parti-
culates as well as all other air pollutants.  Particular
emphasis will be given to tying together epidemiological
methods, stationary site monitoring systems, and per-
sonal monitors into compatible systems in terms of
time, space and concentrations.  As part of this effort,
the FY 80 program will include the final stage of
deployment of the inhalable particle sampler network.

                        - 67 -

     Control technology research will continue to evaluate
     the relative efficiencies and costs of alternative
     means to control different size fractions of primary
     emissions.  Control of fugitive emissions will also
     be investigated for priority industrial processes
     as well as for problems of resuspended particles from
     streets and other nonpoint sources.  Associated with
     the technology studies will be the development of
     methods for and the actual acquisition of emissions data
     from non-traditional particulate matter sources needed
     for evaluating the long-term and short-term impacts of
     fugitive emissions of particles.

Mobile Source Air Pollution

     The FY 81 program will continue to focus heavily upon
     the effort to define better the risks from diesel
     emissions by means of bench and field studies.  In
     the characterization area, there will continue to be
     a substantial demand for the collection of exhaust
     products with different operating conditions, different
     engine designs, and fuel types.  In addition, there is
     likely to be some characterization and measurement of
     exhaust products from candidate control systems.

Hazardous Air Pollutants (includes organic emissions as
toxics, metals such as Hg,  As,  Cd, and asbestos)

     The FY 81 health program will also include a signi-
     cantly expanded emphasis on air pollutant induced
     carcinogenesis.  The primary emphasis will be on
     testing methods and epidemiological investigations.
     The test method development will address the design
     of an optimal tiered battery of tests for assessing
     potential for carcinogenesis.  The epidemiological
     program will try to relate the incidence of cancer
     observed on cancer registeries to exposure to air
     pollutants.  In the area of prospective epidemiology
     research will focus on the development of methods to
     track health status of populations subject to extra-
     ordinary exposure incidents.

     In addition, we expect the research on air pollutant
     health effects begun under the Public Health Initiative
     to continue in FY 81.   Some of the major problems that
     will continue to be addressed include:  the improvement
     of methods to relate animal toxicity to human clinical

                    - 68 -

results; the development of faster, sensitive methods
to detect biochemical, genetic and immune changes; and
and epidemiological studies of selected pollutant
problems, e.g., indoor pollution, improvement of our
quantification ability with respect to exposure
characterization, and temporal exposure patterns.

The FY 81 research program will also emphasize the
characterization of hazardous organic emissions from
stationary sources—both constrained emissions from vents
and stacks and fugitive emissions.  In both instances,
the characterization may require the development of
either sampling and collection methods or improved
analytical techniques, e.g., for total organic emissions
or for selected toxic substances.

Characterization activities in FY 81 will be expanded
to begin a systemmatic effort to determine the inventory
and significance of regulated air pollutants from
stationary sources.  In addition, the program will
focus upon the characterization of indoor air and attempt
to relate indoor air quality to 24-hour and annual
exposures to various air pollutants.

Studies will be carried out to assess population
exposures to toxic organic vapors and particulates,
especially potential carcinogens and mutagens developing
and employing where appropriate personal monitors.

The FY 81 program will include an attempt to identify
and quantify hazardous materials associated with fugitive
dust from mining activities, transportation of materials
and industrial operations.  Research will also be
carried out to characterize VOC emissions and develop
appropriate control technology.  The development of
solvent collection and disposal/recovery systems will
also be pursued as well as the development of alter-
native solvents or solvent-free processes.

The control technology program will also include an
expansion of the demonstration control options for the
second round NSPS stationary sources and the effort to
generate AP 42 emission factors and cost curves for
selected control technologies and pollutants.

A final area of emphasis will be development and
deployment of monitoring systems to allow broad scan
screening of emissions and ambient air for a variety

                    - 69 -

of toxic organics.  In addition, the program allows
for some contingency to cover short-term delivery of
targeted measurement devices to deal with particular
problems, e.g., those efforts in the past to measure
vinyl chloride around PVC plants.

Technical Support

The FY 81 program anticipates a significant amount of
resources will be devoted to technical support to the
program offices.  In the past, this support has been
provided, and we assume will continue to be provided,
by the ORD base program.  There is no rational way to
assign specific levels of effort to each of the four
major research areas a priori.  The level and distri-
bution of this technical support activity will be set
as a result of the deliberations of the respective
research committees.

Quality Assurance

Following on the major effort of FY 80, Quality Assurance
will continue to be a major concern in the FY 81 research
program.   In addition to maintaining oversight over the
Agency's quality assurance system,  the research program
will continue to investigate ways to improve the Agency's
Quality Assurance activities.

Exploratory Research

The new structure for planning research in the Agency
provides assurance that studies will be carried out
in the support of the regulatory programs.  However,
the long-term viability of the Agency's assessment
and control of environmental problems as well as the
quality of ORD's programs depend upon a stable base
level of exploratory research.  The exact nature and
amount of such research that is necessary will vary
from program to program within any medium and even
accross media.  The FY 81 program for air research
assumes that 15% of the total budget will be devoted
to exploratory research, i.e., research which is not
in direct support of some existing or anticipated
regulatory need.  This 15% figure appears low but
given the pressing need for research in support of
regulation, such minimum level may be necessary.  In
any event, this guidance establishes this minimum
level of 15% as a base on which the research committees
can base their deliberations.

                   - 70 -
The Energy Research Program is ranked by the Energy
media team.  Nevertheless, a great deal of the eneirgy
research addresses air pollution problems.  Every
attempt will be made to factor the Energy activities
into the deliberations of the Air media group.  To
aid in those deliberations, the following major
emphasis of the FY 81 Energy program are provide for

          Field experiments on the formation and
          transport of nitrates and secondary
          organic particles will continue in FY 81.
          An effort will be initiated in FY 81 to
          expand the geographical areas of concern
          for baseline measurements of nitrates and
          organic particles beyond the Ohio Valley

          Continuation of the demonstration of low
          NOX burner technology for new and existing
          industrial and utilty oil and coal-fired

          Continuation of the characterization of
          particulates (including the condensible
          fraction) for energy facility emissions.

          Development and demonstration of dry low
          cost SOX control technology for new and
          exixting industrial and utility boilers.

          Continuation of the air quality monitoring
          network in the East in order to establish a
          baseline from which to assess the impact of
          energy activities.

          Finally, consultations and discussions
          during FY 80 between EPA and National
          Laboratory Scientists in DOE should lead
          to integration of the MAP3S program into
          the overall EPA-ORD research program.


                   WATER QUALITY


Major Objectives

During 1980/81 the Water Quality Program will aggressively
pursue the following three central objectives which are
encompassed in this Guidance:

     o  To aggressively control pollution discharges in
        order to protect public health and sensitive
        ecological systems such as wetlands;

     o  To share responsibilities with States and localities
        while encouraging public participation in water
        quality management; and

     o  To manage the program in an efficient manner.

Clearly, the driving force in the Water Quality Program is
to control pollution, to protect public heatlh and the
environment.  As our knowledge has increased regarding the
effects of toxic pollutants on human life, so too have we
intensified our efforts on controlling toxic pollutants
from entering the environment.  Similarly, the significant
improvements in our understanding of aquatic resources,
especially wetlands and shallow water areas, is paralleled
by increased legislative attention to protect these
resources through Section 404 of the Clean Water Act.
It is essential that responsibilities are shared between
Federal and non-federal authorities to maximize our efforts
on improving water quality, to limit redundancies in
Federal and non-federal programs, and to utilize the best
mix of resources to identify and solve our environmental
problems.  Because of the critical nature of the Water
Quality Program and the large number of dollars the program
utilizes, it is essential that the program be managed
efficiently to maximize environmental benefits.  This can
be achieved through an integrated planning and implementation
process within the Agency as well as integration with other
Federal agencies and States and localities.

Major Planning Assumptions

Inherent in the priority activities for FY 80/81 for
achieving media objectives are the following major planning

                  - 74 -

Construction Grants

o  The Construction Grants appropriation will be
   $3.8 billion in FY 1980 (available by October 1,
   1979),  and $4 billion is requested in FY 1981,
   with the allotment formula for both years the
   same as in FY 1979.

o  The Congress will enact a one-year extension of the
   allotment period for FY 1979-1982 Construction
   Grants  funds, increasing the period of availability
   to three years for all appropriations authorized
   in the Clean Water Act.

Spill Prevention

The Spill Prevention and Response Program, while
continuing in the general program direction established
during the last two years, is experiencing some major
changes in emphasis to allow response to hazardous
spills.  The principal assumptions for program
planning in FY 1980 are:

o  Publication of final Hazardous Substances Reg-
   ulations, revised to incorporate the October 1978
   amendments to Section 311 of the Clean Water Act,
   is expected in the Spring of 1979.

o  The list of 299 hazardous substances which must be
   reported in the event of a spill and which will
   require EPA spill emergency response will be
   expanded by 1981.

o  Based on voluntary reports, the program estimates
   about 700-1,200 hazardous spills, involving one or
   more of the 299 substances, will occur annually.

Ocean Disposal

o  All interim Ocean Disposal Permits are to be
   phased out by the end of 1981, by regulation.
   All dumping of harmful sewage sludge is to stop
   by the end of 1981, by statute.

Dredge and Fill

o  Transfer of Section 404 Dredge and Fill Program
   responsibility to qualified States will begin in
   FY 80 and increase in FY 81.  Approvals will remain
   low until later years  (reflecting both a waiting

                       - 75 -

        period while EPA  finalizes regulations and the
        lead time for States to develop their programs),
        but EPA will be heavily involved in assisting
        interested States in program development.

     o  The total Dredge  and Fill permit load will
        increase gradually from the current level  as
        EPA enforcement activities increase.   This change
        results from better surveillance methods and more
        citizen participation and increasing attention to
        the total acreage and stream mileage being actually

     Water Quality Management

     o  Funding of continuing planning will be limited to
        those areas in which substantial implementation of
        the initial approved plan is taking place.

     o  Funds will be available for continuing planning
        under Section 208 in FY 81 with emphasis on com-
        pletion of planning in high priority problem areas.

     Permits Issuance

     The FY 80/31 Guidance is premised on three major

     o  FY 80/81 priorities will be essentially the same
        as in FY 79, that is emphasis is placed on issuing
        and reissuing permits to control major sources
        of industrial and municipal pollution, including
        Federal facilities.

     o  Additional priorities which must be addressed
        within the context of decreasing resources are
        implementation of the permits consolidation
        effort and implementation of the National  Pre-
        treatment Program.

     o  Clean Water Act amendments require consideration
        of new variances  such as the Section 301(i)
        municipal time extension, the Section 301(g)
        water quality variance, and the Section 301(h)
        marine waiver.

Media Priorities

Program plans in FY 80/81 will emphasize activities that
are designed to better assess environmental problems, and
to develop and implement programs to solve and prevent
environmental hazards.

                       - 76 -
Essential to an efficient pollution control program is
the ability:

     o  To identify potentially harmful pollutants;

     o  To assess the effects of levels of pollutants on
        aquatic organisms, other food chain organisms,
        and man;

     o  To assess the transport and fate of pollutants
        in the environment;

     o  To monitor for potential pollution problems, and

     o  To evaluate improvements in water quality.

Much is known about conventional pollutant indicators such
as biological oxygen demand and bacterial counts.  However,
our ability to assess toxic pollution problems is hampered
by the large number of toxic pollutants in the environment
and the necessity of using highly sophisticated and
expensive technology to monitor pollutant levels.  Currently
there is much ongoing work to resolve these problems.

Program plans demonstrate an integrated effort by the Office
of Research and Development and the Office of Water and
Waste Management to improve problem assessment capabilities.

Concurrent with our activities designed to identify and
assess environmental problems, the Water Quality Program
is aggressively pursuing activities to solve our water
quality problems while limiting environmental impacts to
other media.  Major Water Quality Program thrusts for
1980/81 are in response to the mandate of the Clean Water
Act of 1977.

Program plans represent a coordinated effort by the Office
of Water Program Operations, Office of Water Planning and
Standards and Office of Enforcement, working in concert
with States and localities to:

     o  Control industrial and municipal dischargers of
        pollutants through technology-based controls.

     o  Control nonpoint source pollution and prevent
        and clean up oil and hazardous spills.

     o  Protect sensitive ecological systems such as
        lakes and wetlands.

                        -  77  -

     o  Utilize Water Quality Standards and environmental
        quality based effluent controls, where necessary,
        to assure protection of public health and

     o  Enforce environmental control requirements.

The implementation of these priorities will be characterized
by their integration within the Water Quality Program and
integration with other Agency activities directed at
improving environmental quality.  Information gleaned
from problem assessment activities will be critical to
the continuing evolution of solutions and strategies.

     Industrial and Municipal Dischargers

     In 1980 and 1981 the control of industrial and
     municipal dischargers of pollutants will remain the
     keystone to water programs control activities.  The
     1980 program will also include additional pollutant
     studies (e.g., "hot spots" analyses) that will con-
     centrate on selected areas of industry where monitoring
     data indicate high cancer incidence or potential water
     pollution problems would persist after the imple-
     mentation of effluent limitations.  The studies will
     lead to the development and implementation of additional
     controls.   Efforts also will continue in 1980 to
     identify other toxic pollutants and industries that
     should be addressed in effluent guidelines.

     By 1984, industrial sources of toxic pollutants will
     be required to meet technology-based toxic effluent
     discharge limitations for both direct and indirect
     wastewater  discharges.  This effort entails detailing
     the presence or absence of 65 toxic pollutants or
     classes of toxic pollutants.  An in-depth economic
     analysis of each industry also must be conducted
     to ensure that regulations are economically achievable
     and equitable.  This program will peak in 1979 and
     1980 and continue through 1981 with final promulgations
     and court defenses.

     Municipal point source control activities are addressed
     principally through the Waste Treatment Facility
     Construction Program.  This program is of major
     importance to reduce water pollution problems resulting
     from conventional pollutants, such as suspended
     solids, bacteria, and oxygen demanding loads that
     degrade our waters and continue to pose problems to
     public health and the environment.  The long range
     goal of the Construction Grants Program is to eliminate

                  - 78 -

the municipal discharge of untreated or inadequately
treated pollutants and thereby help restore or
maintain the quality of the Nation's waters.  A
large number of amendments to Title II of the
Clean Water Act created incentives for use of
environmentally justifiable, innovative and
alternative technologies in municipal treatment
systems; established funding for States to assist
them in adopting and managing Construction Grants
Programs; made special considerations for the needs
of small communities;  and increased emphasis on water
reuse and recycling, recovery of energy, and confined
disposal of pollutant wastes to prevent their migration
to the water.

Through the passage of the Clean Water Act the Congress
reaffirmed its intention that States have a major and
continuing role in environmental programs.  The year
1980 will mark the start of a new era in planning,
implementing and managing environmental programs at
the Regional and State levels.  State/EPA Agreements
will present consolidated approaches to solving
water supply, solid waste, and water pollution control
problems.  The integration of these program areas
will be a major step toward the objective of compre-
hensive environmental planning and management.

Activities aimed at integrated management are being
initiated in 1979.  EPA is requiring all States to
develop comprehensive State/EPA Agreements to cover
Clean Water Act programs including consolidation of
Sections 106, 208, 303, and the Clean Lakes provisions
of Section 314.

State/EPA Agreements will be the result of a negotiation
process between each State and its respective EPA
Region.  The Agreements will describe activities that
States and EPA will undertake during the coming year.
An agreement will be the result of an assessment of
the environmental problems faced by an individual
State, development of a long-term strategy to solve
those problems, and a determination of critical steps
to take during the next year.

Each State/EPA Agreement will reflect important decisions
on environmental and programmatic problems, State and
EPA priorities, timing, and responsibilities.  It
also will be a management tool which focuses attention
on the evaluation and accomplishment of major
environmental efforts.

                   - 79 -
Initial Water Quality Management Planning will be
completed by all States and areawide agencies by
the end of 1979.  The continuing planning effort by
local and State agencies in 1980 will focus on the
highest priority problem areas with special emphasis
on toxics.  The Agency will stress implementation
of the initial plans and require that substantial
implementation occur as a condition for future

The key change in program management to ensure Section
208 plans are being carried out is the development
of the State/EPA Agreement process.  State imple-
mentation will utilize funds provided under Section 106
Program Grants to accelerate establishment of regulatory
programs and to provide for monitoring to assess the
adequacy of clean-up efforts.

Implementation of the Construction Grants Program
requires integrated Agency and State efforts with a
large delegation of responsibilities to the States.

The program strategy for 1980 recognizes that there are
limited funds available to meet these pollution control
needs and that the funds available must go toward
assisting municipalities in meeting the most critical
needs in the shortest possible time.  Accordingly,
the EPA strategy for 1980-1931 is:  (a) to orient
funding toward meeting the environmental requirements
of the Act through stringent cost-effect review on
a project-by-project basis, and (b) to stress
innovative and alternative approaches to waste
treatment, including emphasis on water and energy
conservation, waste water reuse and recycling of
pollutants, and small systems.  Funds specifically
earmarked for State delegation under Section 205(g)
of the Act will be directed toward maximizing
State assumption of program activities in the shortest
possible time.  In all cases, State delegation will
be part of an overall agreement that will ensure that
EPA policies and environmental objectives continue to
be met.

EPA will continue to pursue program strategies that
provide sufficient certainty and stability to States
and municipalities to facilitate effective planning
and management at all levels.  The 1980 appropriation
request of $3.8 billion is a critical component of
this management need.

                  - 80 -

The State Management Assistance Grant Program
authorizes the use of two percent or $400,000,
whichever is greater, of each allotment to cover
the cost of delegation to the States of the
Construction Grants Program and (to the extent that
funds suffice) the National Pollution Discharge
Elimination System  Permit, Dredge and Fill, and
Section 208 Management Programs.  EPA's long-term
goal is to allow the States, rather than EPA, to
assume responsibility for day-to-day management of
Construction Grants activities.  The timing and
extent of delegation to each State depends on the
State's ability to operate a program that meets the
necessary competency requirements and policy direction
mandated by the law and EPA objectives.  A grant is
given to a State when it can show that it is able to
assume delegated responsibility for a substantial
portion of Construction Grants program activities.

Approximately 26 States are expected to receive
State Management Assistance Grants during 1979,
which will allow gradual phase-in of most program
activities as the States staff up and are trained
to accept each task.  Most of the remaining interested
States will have entered into preliminary negotiations
during 1979 leading to a grant in 1980 and 1981.
Resource benefits from this State delegation strategy
should begin to be evident in 1981.

Control of Nonpoint Sources

Nonpoint source pollutants are a continuing cause of
water quality degradation.  A substantial number of
the nation's waterways will continue to fail to meet
their intended uses unless nonpoint source programs
are developed and controls enacted.  Nonpoint
source problems require further identification;
control techniques must be developed and tested;
and cost effective, best management practice
systems designed and demonstrated.  Substantial
efforts will be directed to the identification and
evaluation of these practices both with Agency resources
and in conjunction with other Federal agencies.

It is a priority to continue to develop and assess
methods of controlling urban nonpoint source
pollution and additional methods for controlling
rural nonpoint source pollution.

Hazardous Spills

In 1980, the Agency will implement and expand its
Spill Prevention and Response Program to cover not
only oil spills but also the discharge of those
substances determined to be hazardous by EPA.  The
Agency is currently developing and will promulgate
regulations for hazardous substances designations,
removability, harmful quantities, and rates of
penalty.  An Environmental Emergency Response Team
has been established to provide immediate on-the-
scene expertise in handling, clean up, and disposal
of most critical oil and hazardous substance spills.

Protection of Ecological Systems


In FY 80 and especially FY 81 the Wetlands Protection
Program will have a high priority within the Office
of Water and Waste Management.  Section 404 of the
Clean Water Act provides the principal protective tool
and may underpin other non-Federal activities for
protection of wetlands.  EPA shares the responsibility
for implementing Section 404 with the U.S. Army
Corps of Engineers, the U.S. Fish and Wildlife
Service, and in the future, with the States.

A significant increase, in Section 404 responsibility
for EPA will occur in 1980 as the Agency provides
a significant degree of the substantive review on
at least the most significant environmental permits,
whether issued by the Corps or the States, and
responds to the variety of new program developments.

Under the 1977 Act, the Corps will continue to allow
dredge and fill material discharge in the traditionally
navigable waters.  States may assume permit respons-
ibility in other waters, if they are qualified.  EPA's
role in this process is large and includes respons-
ibility for issuing regulations, establishing State
program approval criteria, reviewing and acting upon
applications from States, and providing continuing
oversight for both States and the Corps permit programs,

EPA is currently drafting two sets of regulations
for State assumption of permitting responsibilities.
The regulations are for program approval and State
program operations.

     Lake Protection

     The Clean Lakes Program is authorizei h    ef,  ic.
     of the Clean Water Act.  The j •; - jrara ,   .,   c  -
     to States for:  identificatiui  and class  xija.,,o..
     according to euthrophic condition of all  prope  *-
     around freshwater lakes; procedures, processes,  arul
     methods to control sources of poll\.A.-\onr  and  pro-
     cedures for restoration.

     Proqr^m n.lans demonstrate continual  efforts di-f:cted
     at 3fiicient control of lake pollution problem,  aad
     activities designed for lake quality enhancement.

     Water Quality Standards anJ Environmental Quality
     Based Effluent Controls

     Water quality .. c^ndards are a means  for States  to
     "rotect the vJient quality of  ':hei.r waters.  Section
         Oj. ^h,e Clif.'! tfater Act requirer-  States to review
     v,'.ii-.e.r Quality  •. tandards every three  ears and to
      , b^a.!1: -lew an-" '^vised standards LO  . Lo Administrator
     * •>-. "j'prow'al.   Tf standards are  u~>a.  rep table  to  the
     Administrator, the EPA can promulgate State standards
     where States fail to comply with Federal  regulation.

      f. present, man--- State standards do  not contain
     criteria for toxic substances.   Even where States  do
     have certain criteria for toxics, NPDES permits
     frequently are not written to meet such criteria.
     In F" 30/81 EPA is considering  revising the Federal
     standards regulations so that States may  be required
     to adopt numerical criteria for  a minimum list  of
     toxic substances.  The Office of Water Planning  and
     Standards is further attempting  to remedy this
     through technical assistance on wasteload  allocation
     procedures and methods of implementing bioassay
     criteria in Water Quality Standards.   An  additional
     priority here is to develop a strategy for the  use
     of Section 307 (a^ toxic effluent limits where BAT
     requirements a? e _ufficient to  protect public health
     and environmer .,.


Enforcement activities play a central role in  implementing
an effective pollution control program.   Toxic pollutant
and hazardous materials enforcement wll be pursued through
enforcing reissued permits, bioassay  inspections,  pre-
treatment requirements, Section 404  requirements,  Section 311

hazardous substances  : e -'_uir--.n-_Att,.  auo  i:se of Section 504
emergency powers,   J r> V}',?'   -  v.   > -nt, •  pr-ocr;:an\ w.ixi. initiate
its issuance Cj. pei.nics  uaseo on  prOiunigat-ed effluent
guidelines for toxic pollutants.

Implementation of  the pretreatment  reqvirenents demon-
strates the importance of''working  liaison between the EPA
and localities.  The Clean  Wate/r  Jxc>':  of 1979 requires that
POTWs must develop programs  to enforce Uie EPA's national
Pretreatment Requirements.  Fol.lo-nxno  tf-~, 1978 promulgation
of Federal pretreatmenh  guidelines   trie prog:>:aui v/i.Xl begin
to shift in 1979 and  1980 to  v,ho  local  iv; .ex.  To.-J.«:
pollutant controls  will  proceed  tlirough incorporating
pretreatment requirements in  municipal  permits :o.r control
of indirect discharges,   Enforce.Tien-.:  resources will be
devoted to the pretreatment programs,  jonnider requests
for modification of prelreatment  ,-.; •'.anda.raj,. and modify
municipal permits  to  incorporate  yretrea'-jnent. requirements.

The Water Quality  Program will make  a major initiative
to limit the redundancies of  the  regulatory process and
to provide for more efficient program management.  In
1930 the Permit Program  will  work  co  consolidate National
Pollutant Discharge Elim;',nation System  (NPDIIS) permits
under the Clean Water Act with Hazardous tfaste permits
under the Resource  Conservata on and  Recovery Act, and
Underground. Injection Control permits under the Safe
Drinking Water Act,  Consolidation  of these permit programs
will eliminate duplicative  permit  issuance reporting
requirements for affected f ac . 1.:'. t.. ;.F

Emphasis will continue in 1979 and  198C on che Municipal
Enforcement Strategy  first  formulated, in l.<7l..  As with
other water quality programs, this  strav.egy ia an attempt
to integrate program  activities' of  the  Grants, Enforcement,
and NPDES Permit Compliance Programs,  to better coordinate
and reinforce planning and  scheduling of municipalities to
meet the goals of  the Act-,  llie principal effort in 1979
and 1980 will be to implement a orogram of action through-
out EPA and the States,.  Ler.ainc- tc .•

     o  Integrated  municipal  permit and grants schedules;

     o  Compatible  information  systems;

     o  Internally  consistent operating pr'/cadures; and

     o  Coordinated grant and enforcement sanctions for
        noncomplying munj.cj.pai.'. ties.

                        - 84  -

The overall result is expected to be more effective and
expeditious actions toward the compliance of municipal:, f- z-s
with requirements established in the Ant.

Permits Issuance

The major objectives of the FY 1980/81 Permits Program
will be to maximize the control of toxic pollutants
through the initiation of the second round permitting
effort and the implementation of the National Pretreatment
Program; to accomplish a major regulatory and management
reform initiative by streamlining the permit process to
allow for consolidated procedures, organization and permit
format; and contribution to the major source enforcement
effort through implementation of the National Enforcement

Under separate cover, OWE will provide more detailed
guii: nee on Integrating permit program priorities
with particular reference to pretreatment activities.
              control through second-round permits-- NPDES
        second-round permits under the Clean Water Act
        will begin to be issued in FY 80 and will be issued
        throughout FY 80/81.  The reissuance of expiring
        permits to these industries, including Federal
        facilities, covered by the NRDC consent decree
        ("primary" industries) will be of particular
        importance as it will impose BAT/toxic limitations
        on the significant sources of toxic pollutants.
        Emphasis on permits issuance will be prioritized
        in FY 1980/81 as follows:  major primary industries
        which could be sources of highly toxic substances,
        major secondary industries, remaining  (80%) minor
        primary industries, and minor secondary industries.

        Regulatory and management reform through consolidated
        permitting -- EPA is consolidating its permit pro-
        grams, both to simplify administrative steps and
        to facilitate rfdrcs^ing all environmental concerns
        through a single process „  By October 1, 1979,
        EPA will consolidate permit issuing, i.e. , permit
        drafting, paper flow and initial point of contact,
        for NPDES permits; Hazardous Wastes permits;
        Underground Injection Control permits; Ocean
        Dumping permits; Air New Source permits; and other
        permit-like programs in one place in each of its
        Regional Offices.   Regulated facilities will be
        able to submit one application for all water, solid
        and hazardous wastes related nermits ;  go through
        one review; and be issued one permit.

                        - 85 -

     o  Toxic control through pretreatjt.e:^ -•- The pre~
        treatment program is expected' trT'tar.-e en increasing
        importance in 1980.  Pretref* ::inent activities in
        FY 1980 should be addressee -generally according
        to the following priorities;  1) provide assistance
        to States in developing State protreatment programs
        and approve such programs: 2) review and make
        determinations on requests for local pietreatmant
        program approval; 3) develop compliance schedules
        for insertion in NPDES municipcil permits requiring
        the development of a local pretreatmerit program;
        and 4) work with States and municipalities \n
        identifying industrial users subject to categorical
        pretreatment standards as such standards are

     o  Major source enforcement through implementation of
        the Municipal Strategy — The National Municipal
        Policy and Strategy published in FY 19/9 sets forth
        priorities for reissuing expiring major municipal
        permits.  This policy directs that municipalities
        requesting time extensions for compliance with
        secondary treatment requirements  (Section 3Cl(i)
        extensions) be given priority in permit reissuance.

        The 301(i) compliance extension is a major
        mechanism for bringing non-complying municipalities
        into compliance with the lav/ thus contributing
        significantly to the Agency's major source enforce-
        ment effort.

Research and Development

Much is known about conventional pollutant indicators such
as biological oxygen demand, and bacterial counts.
However, our ability to assess toxic pollution problems
is hampered by the large number of toxic pollutants in
the environment, and the necessity of using highly
sophisticated  and expensive technology to monitor pollutant
levels.  Currently there is much work ongoing to resolve
these problems.  Priority activities (not necessarily in
priority order) in 1980/81 include an integrated effort
by the Office of Research and Development and the Office
of Water and Waste Management to:

     o  complete the publication of water quality criteria
        for 65 classes of toxic pollutants, to assess
        impacts of those pollutants on aquatic species
        and human health, and to determine acceptable

                   - 86 -
o  select additional priority pollutants and develop

o  develop wet weather criteria for pollutants to
   account for nonpoint source contributions during
   high flows,

o  add carcinogens and chronically toxic pollutants
   to the hazardous substance list,

o  develop recreational water quality criteria,

o  expand selected water quality predictive models to
   include toxics and sediments in assessing transport
   and fate of pollutants,

o  develop rapid screening tests for characterization
   of toxic pollutants in complex effluent,

o  assess effects of specific pollutants, pollutant
   transformation products and combinations of
   pollutants on marine biota,

o  develop simulation techniques, including microcosms,
   to predict pollutant stress on marine biota and

o  develop a simple implementable technique for
   assessing wetlands transition zones, and
   characterization of productivity of wetlands,, as
   a tool for assessing the quality of wetlands,

o  improve solid phase bioassay techniques to test
   toxicity of dredged and fill material,

o  develop broader spectrum and more cost-effective
   methods for screening and quantifying organics in
   water and wastewater with increased emphasis in
   FY 81 on nonvolatile organics,

o  develop more cost effective multi-element and
   chemical specification methods, with emphasis
   in FY 81 on solids,

o  perform multi-media toxic and hazardous material
   problem assessments in local areas in response to
   public health concerns, in absence of State or
   local capabilities,

o  continue study of toxic materials in publicly
   owned treatment works in order to develop compre-
   hensive urban toxic pollutant control strategies,

                -  87  -

continue development of methodologies to assess
impact of nonpoint source pollution, and perform
nonpoint source assessments,

integrate Agency monitoring efforts for priority
pollutants, including establishing a single
data base system and approved quality assurance,

develop, evaluate, and report on a practical lake
(quality) evaluation index  (LEI) procedure to
assist lake managers in interpreting lake problems
and selecting corrective actions,

assist Regions and States to develop toxic pollutant
monitoring capabilities to support State/EPA
Agreements, toxic wasteload allocations, water
quality standards, permit setting, and permit
compliance monitoring,

continue exploratory research to identify potential
pollutant problems in the future and to develop
potential controls for pollution problems; to
develop technologies that minimize pollution

sludge:  evaluate innovative and alternative
technology projects;  improve data on exposures of
organics, metals,  and pathogens from land appli-
cation; develop beneficial uses, including energy
recovery technologies,  evaluate detoxification

small flows/land treatment: demonstrate central
management of onsite systems; extend overland
flow systems to colder climates; evaluate toxics
management in land application systems; investigate
higher rate nutrient update systems,

investigate process development for treatment
systems for small communities and combined sewer
overflow management and technology; evaluate
conservation/reuse demonstrations and high rate
biological removal of specific pollutants; and
develop surrogate control parameters,

initiate a major program for development and
demonstration of reuse/recycle technologies and
to reduce intermedia impacts of wastewater

                        - 88 -

     General R&D Management

     In FY 80 and FY 81 EPA's R&D program will have three
     major management goals:

        o  Continue the integration into the main stream of
           the Agency's activities of all of ORD's research
           in support of regulation and enforcement.

        o  Enhance ORD's capability to provide better data
           for future Agency regulatory and enforcement

        o  Improve the quality and utility of scientific
           and tecnnical data used by the Agency.

     Actions to be taken to achieve these goals  include
     the following:

           Establish Research Committees to cover all water
           .-	  - •	 ~ • — 	 	 —	i	  ~  '	    . --- ~r	-n   	 "     .- — —.---i-i n.M_ — ~- . ._  	I...
           quality research in support of regulations and

           Currently one Research Committee exists —
           Industrial Wastewater Research.   Three Committees
           will be established during FY 79 to cover
           essentially all research conducted in support of
           water quality regulation and enforcement.

           Water Resources  (relating primarily to OWPS

           Industrial Wastewater  (broadening the existing
           Industrial Wastewater Committee).

           Municipal Wastewater, Ocean Disposal, and Spill
           Prevention (relating primarily to OWPO activi-
           ties) .

           One major concern is how to incorporate require-
           ments and views of the Regional Offices into the
           Research Committee process.  This will make it
           necessary for the Regional Offices to coordinate
           their participation and share responsibility for
           representing regional interests.

                   -  89  -
      Develop an exploratory research .^'forh which
      applies the Nation's best scientific_capability
      to addressing future Agency problems.

      Fifteen percent of ORD resources for water quality
      will be devoted to research which has  the purpose
      of applying the best available scientific capa-
      bilities to research which looks beyond immediate
      (1-3 years) Agency needs or involves biuher risk
      but potentially higher pay-off, than xeEeaich
      normally undertaken in support of regulation or
      enforcement.  This effort will be developed by ORD
      in consultation with the scientific  community
      external to the Agency.  Al.l plans for exploratory
      research will be reviewed by the Agercy's Research

      Scientific peer review of Agency research projects
      and reports.

      Mechansims will be established to ensure, wherever
      feasible, scientific peer review of the plans for
      and results from individual research projects.

      Establish an environmental criteria and assess-
      ment function^~~

      This involves completion of the staffing and imple-
      mentation of ORD's new Office of Health and
      Environmental Assessment in orde : to provide consis-
      tency in the Agency's risk ass^ssia nits anc provide
      water quality assessments upon request by the

      During FY 80 and FY 81, "technology transfer"
      activities will no longer be planned and budgeted
      separately.  Plans and resources for technology
      transfer in a given program,, e.g., municipal waste-
      water, are to be included in Decision Units for
      that program.

Health and Research

   o  Determine the health implications of existing
      and new technology for the treatment,  disposal
      and reuse of wastewater and sludge.

                      -  90 -
      o  Determine the health effects of priority toxic

      o  Develop rapid screening tests suitable for
         extrapolation to man for characterization of
         toxic pollutants in complex effluents.

      o  Develop recreational water quality criteria.

Research will proceed as described in the FY 80 budget,
except for the following:

      o  In developing screening tests which can be:
         extrapolated to man,  mammalian and in  vitro
         tests will be considered along with bioassay
         tests normally used by aquatic biologists.

      o  Current discussions may lead to a new effort
         for nonpoint sources.

Environmental Processes and Effects

Freshwater environmental effects research will focus
on the following priority areas in FY 80 and FY 81:

      o  Nonpoint source impacts, including recovery
         rate ; and montoring methods.

      o  Test protocols for toxics, including mutagenic
         and carcinogenic effects.

      o  Effects evaluation of complex toxic effluents.

      o  Test methods for the bioaccumulation potential

      o  Environmental effects of land application of
         municipal wastes.

Marine environmental effects research will address:

      o  Methods for measuring the relative "health" of
         marine ecosystems.

      o  Simulation techniques, including  "microcosms" for
         predicting pollutant stress on marine biota
         and ecosystems.

      o  Effects of specific pollutants from ocean dumping,
         outfalls, dredged materials,  and  other sources
         pollutant transformation products, and combina-
         tions of pollutants on marine biota and ecosystems,

                  - 91 -

   o  Questions of wetland function anc importance.

Transport and fate research goals include:

   o  Expansion of selected water quality predictive
      models to include toxics and sediments.

   o  Development and joint evaluation with OWWM
      of a method for determining gross environraental
      "mass balances" for toxics.

   o  A continued, limited effort to vorify selected
      water quality predictive models, primarily
      through use of existing data, with emphasis
      on utility for wasteload allocations and advanced
      waste treatment facility decisions.

   o  Studies of the transport and fate of selected
      pollutants in the marine environment.

The Great Lakes research program will in FY 80, verify
phosophorous-plankton models used in load reduction
simulations, and begin an effort to expand in FY 81,
research on the risks to man from toxics transported
through the lakes system.

The Chesapeake Bay research program will carry through
studies, just initiated, on assessing, in reference to
competing uses of the Bay, existing and projected
consequences of toxics and nutrient loadings on the
Bay system, human health and the economy of the Bay.

Measurement and Monitoring

Measurement methods research in FY SO and FY 81 will

   o  Broader spectrum and more cost-effective methods
      for screening and quantifying organics in water
      and wastewater, with increased attention in FY 81
      to nonvolatile organics.

   o  Completion in FY 81 of identification of
      volatile organics in industrial effluents  (in
      direct support of Effluent Guidelines Division,

                    -  92  -
     o  More cost-effective multi-element and chemical
        specification methods, with emphasis in FY 81
        on techniques for soils, sediments and sus-
        pended solids.

Quality Assurance Program Activities will include-:

     o  Completion in FY 80 of analytic methods aind
        quality assurance materials for consent decree
        toxics in sludges, ambient waters and fish

     o  Evaluation of surrogate methods for toxics in
        effluents and sludges.

     o  Evaluation of alternative monitoring methods
        for erforcement.

     o  Quality assurance support for all Agency labora-
        tories and Agency sponsored contracts.

Monitoring nethods and systems research will include:

     o  Correction of deficiencies and analytic methods
        for consent decree toxics in effluents, sludges
        and ambient waters.

     o  Specifications for EPA approved Regional sampling
        and monitoring instruments.

     o  Development of pathogen idenfication and
        concentration procedures.

     o  Evaluation of biological monitoring systems.

     o  Development of monitoring system concepts for
        linking Agency monitoring systems to facilitate
        correlation of monitoring data with health
        statistical data.

Technical support program will provide:

     o  Remote sensing support for spill prevention and
        emergency oil spill response activities.

     o  Monitoring and analytic support, consultation,
        and expert testimony, as needed.

                    - 93 -
Control Technology

In FY 80 the Industrial Wastewater Control R&D program
will focus on:

     o  Optimization of available treatment methods and
        development of innovative technologies for
        control of toxic pollutants.

     o  Laboratory and pilot scale treatability studies
        for priority pollutants.

     o  Development of BMP's for industrial sources not
        readily covered by BAT or revised BAT.

     o  Technology development for control of hazardous
        materials spills.

     o  Initiation of a major program for evaluation
        and development of reuse/recycle technologies.

     o  Major effort to evaluate and establish ways in
        which to minimize intermedia impacts from
        wastewater pollution abatement practices.

In FY 81, the Industrial Wastewater Control Program
will continue the initiatives described under FY 80,
and in addition, will include:

     o  Demonstration of reuse and.recycle systems for
        those industrial segments which contribute a
        high number of the 129 priority pollutants in
        their discharge.

     o  Acceleration of development of technology to
        support an Agency emergency response capability
        for the control of hazardous waste incidents
        of all types.

     o  Technology transfer of reuse/recycle technology
        to industrial users.

     o  Assessments and treatability studies on toxic
        pollutants to be added to the original list of
        priority pollutants.

                    - 94 -

Municipal control technology priorities will include:


     o  Evaluation of innovative and alternative
        technology projects.

     o  Assessment of exposure levels of organics,
        metals, and pathogens from land application.

     o  Development of beneficial uses, including
        energy recovery technologies.

     o  Evaluation of detoxification methods.


     o  Characterization of sources and magnitude.

     o  Determination and development of predictive
        methods for treatability.

     o  Evaluation of urban-wide toxics control and
        pre-treatment strategies.

     o  Evaluation of promising control strategies.

Small flows/land treatment:

     o  Demonstration of central management of on-site

     o  Extension of overland flow systems to colder

     o  Evaluation of toxics management in land
        application systems.

     o  Investigation of higher rate nutrient uptake

Process development:

     o  Treatment systems for small communities.

     o  Combined sewer overflow management and technology.

     o  Evaluation of reuse demonstrations.

                    -  95 -

     o  Evaluation of high rate biological systems
        for removal of specific pollutants.

     o  Development of surrogate control parameters.

Cincinnati Test and Evaluation Facility:

     o  Response to short-term needs of Regions and
        Program Offices.

Agricultural control technology will emphasize:

     o  Field evaluation of best management practices,
        in coordination with the Model Implementation
        Program and Rural Clean Water Program.

     o  Validation of recently developed pollutant
        loading models.


                       DRINKING TiAIER


     The goal of the drinking water program is to
protect the public health by assuring the safety
of the drinking water.

     Assuring the safety of drinking water is primarily
the responsibility of State and local governments,
However, Congress has determined that the Federal
Government should share in this responsibility by
assisting, reinforcing, and setting standards for
State and local efforts.

     The Safe Drinking Water Act requires (1) primary
health related drinking water regulations requisite
to protect the public health,  (2)  public water systems
supervision programs  (PWS) to assure compliance with
the regulations, (3) underground injection control
programs  (UIC) to protect underground sources of
drinking water, and  (4) the provision of emergency
assistance.  The Act envisioned that the States would
have primary enforcement responsibility for both the
PWS and UIC programs.  Moreover, the Act is designed
to encourage voluntary compliance with the regulations.

     The program activities will focus on implementation
of the primary drinking water regulations in non-primacy
States and on Indian lands, assistance on the implementation
of the trihalomethane and synthetic organics regulations;
maintaining a strong management program in primacy States
to assure primacy implementation;  continuing efforts to
encourage non-primacy States to assume primacy; emergency
assistance; financial assistance to States; research,
development and implementation of additional regulations
to control other contaminants in drinking water; implementation
of a program to protect underground sources of drinking water;
the initiation of enforcement actions to ensure compliance
and implementation of State/EPA agreements.

     Activities within each major area involve at least
two of the program offices.  The assignment of program office
responsibilities is based on program expertise.  In general,
the Office of Drinking Water and its Regional counterparts
will be responsible for the program activities involving
on-going communications with the public, the water systems,
injection facility operators, and the States.  The responsi-

                              -  100  -
bilities also include laboratory certification, tenh-:cal
assistance and evaluations, standards developir3nt -  tec^-'ic, "
expertise in regard to variance and exemption application,
and other legal action, data handling and evaluation, UIC
primacy application review, technical evaluation of
permit applications, and sole source petitions reviews.

     Drinking Water Enforcement positions in Headquarters
will be devoted to the following activities:  permitting
and enforcement guidance for the UIC program; coordination;
budget and administrative efforts; legal strategies for
regional and State overview programs, including guidance on
compliance monitoring and inspection; enforcement and legal
assistance for regional PWS programs; and legal support for
actions initiated in response to emergency situations.

     Regional Drinking Water Enforcement staff will participate
with Drinking Water program offices in legal aspects cf
issuing variances and exemptions by assisting in developing
compliance schedules and interim reporting and monitoring
requirements to be included in variances and exemptions to
be approved by the Regional Administrator (unless otherwise
delegated); providing legal and administrative support in
initiating formal enforcement actions; working with ODW to
ensure enforceability of compliance actions or other require-
ments imposed on public water systems; issuing UIC permits
to facilities disposing of wastes underground; investigating
and initiating civil and criminal actions for violations of
the UIC regulations; and providing technical and legal support
in legal actions initiated in response to emergency situations.

     The Research program will relate to:   (1) causes,
diagnoses, and prevention of diseases and other impairments
in man resulting directly or indirectly from contaminants
found in drinking water; (2) the treatment and control of
those contaminants; and (3) the provision of dependable,
economical, and safe supplies of water, including the
protection of underground sources of drinking water.
Research will also be conducted to develop and implement
quality assurance procedures and protocols for water supply
laboratories to assure that laboratory analytical data are
accurate and valid.

Planning Assumptions

     The planning and operating guidance for FY 1980
is based upon the following assumptions.  For consistency
purposes, the Regions are requested to adopt similar
assumptions in preparing their submissions.

                             - 101 -

          o  Currently proposed organic regulations
             will be promulgated in Summer, 1979.
          o  Revised drinking water regulations
             will be proposed in early FY 1980.
          o  UIC regulations will promulgated by
             January, 1980.
          o  By FY 1981, all 57 States will be listed
             as requiring underground injection
             control programs.  They will then become
             eligible for grants.  The following list
             shows for each year, the number of States
             first becoming eligible in that year:

               -  FY 1979 - 23
               -  FY 1980 - 18
               -  FY 1981 - 16

          o  Consolidated permit regulations
             will be in effect in FY 1980.
          o  EPA itself will utilize the grant allo-
             cation for underground water source
             protection of listed States that  (1) do
             not apply for grants or (2) indicate
            • that they will not assume primacy for the
             UIC program.
          o  Sole/principal Source Aquifer  (1424(e))
             regulations will be promulgated in
             Spring, 1979.
          o  In FY 1980, EPA will implement public
             water systems supervision programs in
             12 States:  Indiana, Pennsylvania, Oregon,
             District of Columbia, South Dakota, Utah
             Wyoming, Illinois, Vermont, North Carolina,
             American Samoa, and Northern Marianas.
          o  A legislative amendment extending the
             compliance schedule for exemptions will
             be adopted.

     These assumptions represent the best projections
based upon information available to Headquarters at
this time.  There undoubtedly will be changes; however,
for consistency these assumptions should be reflected
in Regional operating plans.

Media Priorities

     The media priorities for FY 1980 and FY 1981
provide general guidance reflecting the National
Program Managers' high priority items.  These
priorities may differ from one Region to another
depending upon each Region's particular situation.
Regions maintain the flexibility to pursue priorities
which satisfy the needs of their unique situations.

                   - 102 -
°  Priority 1 activities are:

     -  to establish maximum contaminant
        levels and/or treatment techniques
        to assure the safety of drinking
        to implement the organics regulations.
     -  to initiate enforcement actions and
        respond to emergency situations
        involving substantial threats to
        public health.
        to take enforcement actions, as
        necessary, in non-primacy States.
        to maintain a strong management
        program in primacy States including
        overview of State enforcement
        activities and grants administration.
        to develop a coordinated ground-water
        policy and strategy by the third
        quarter of FY 80.
        to encourage State assumption of
        primacy for PWS and UIC programs.
        to implement and enforce a program
        for assuring compliance with the
        primary drinking water regulations
        in non-primacy States and on Indian
        to conduct research into the health
        effects and treatment of trace
        organics and investigate alternative
        disinfectant techniques.
        to maximize program effectiveness and
        integration through the consolidated
        permits program, the State/EPA agreements,
        to complete the assessment of surface

o  Priority 2 activities are:

        to protect designated sole source
        to develop UIC implementation plans
        where necessary.
        to investigate the relationship  of
        inorganic contaminants and asbestos
        fibers on health.
        to provide technical and legal
        assistance for enforcement actions
        in primacy States.
      -  to increase public awareness and
        public participation.

                  -  103 -
°  Priority 3 activities are:

        to develop a coordinated ground-
        water research program.
        to conduct research on direct and
        indirect additives.
        to conduct studies on home water
        treatment devices.
        to initiate enforcement actions
        in primacy States, as appropriate,
        where a State is unable to or fails
        to do so.

                         - 104 -


Research and Development

           The Safe Drinking Water Act is reasonably speci-
     fic in setting forth the Agency's responsibilities, so
     it has been possible to develop a drinking water
     strategy with a "step-by-step" schedule of future
     activities.  One major element of this strategy is to
     conduct research to improve the scientific and tech-
     nical basis for Primary and Secondary Drinking Water
     Regulations (especially regulations based on Maximum
     Contaminant Levels — MCL's), and regulations to protect
     the quality of ground water.  The issues have been
     reviewed by a non-government advisory committee formed
     to update the 1962 U.S. Public Health Service Drinking
     Water Standards, an ad hoc group of the Agency's Science
     Advisory Board, the National Drinking Water Advisory
     Council and by the Drinking Water Research Committee
     during its deliberations on FY 80 research activities.
     These groups and others from within the Agency's
     Operating and Research Offices determined that research
     was necessary to help answer the following basic

           1.  What substances occur in drinking water
               supplies at a sufficient number of locations
               to warrant regulation?

           2.  What are the effects of these substances
               on human health?

           3.  What analytical procedures should be used
               to monitor water to assure that the Revised
               Primary Drinking Water Regulations are

           4.  Because some of these substances are formed
               during transport, storage, treatment and
               distribution, what changes in treatment
               practices would be appropriate to minimize
               the formation of these compounds in water
               delivered at the consumer's tap?

           5.  What treatment technology must be applied
               to reduce contaminant levels to the concen-
               trations specified in the Regulations?

                     - 105
       The  Agency  has  decided  to  focus  on  these broad
 questions  in  order  to develop a  defensible  basis  for
 standards.  These same questions  apply to wastewater
 when  it  is  being  considered as a  water source for
 drinking.   Underlying this research  is a  quality
 assurance  effort  that also plays  an  important role  in
 the certification of  non-EPA  laboratories and, generally,
 in assuring the reliability and  accuracy  of laboratory
 analyses of drinking  water samples.

       The  setting of  research priorities  has resulted
 primarily  from the  interpretations by  the Office  of
 Drinking Water and  the Drinking Water  Research
 Committee  of  the  regulatory requirements  set forth  in
 the Safe Drinking Water Act in light of the target
 dates  specified in  that Act.   These  groups  have given
 full consideration  to the  gaps  in existing information
 and to the principal  problems referred to them for
 action by  the Regions, the National  Drinking Water
 Advisory Council, and  the National Academy  of Sciences.
 The research  staff, however,  plays a major  role in
 setting priorities  due to their  insight (derived  from
 experience) regarding  the general feasibility of  broad
 classes of analytical  measurements,  the time it takes
 to conduct health effects and  engineering experiments,
 and the cost  of generating additional  research data.

      These deliberations resulted in  a balanced
 research program  that  includes studies of short-  and
 long-range health effects studies, as  well  as efforts
 to improve analytic methods and treatment techniques.
Approximately 45  percent of the budget will go to health
effects projects  (many of which are  conducted jointly
with the Department of Health, Education  and Welfare),
40 percent to the development of  treamtment technology,
6.5 percent to improvement of analytical  methods, and
8.5 percent to groundwater concerns.   These allocations
may change as a result of the Drinking Water Research
Committee's deliberations for  FY  81.

      Trace organics  are still the least  understood
and most troublesome drinking water  contaminants, so
approximately 43 percent of the funds  are directed
toward that problem.   Research into  trace organics
will examine  their health effects, and will also
focus on development of appropriate monitoring and
treatment technology.  The second highest priority

                     -  106  -
is the impact of inorganic contaminants, particularly
asbestos fibers, on health, so a large effort will be
made in this area, too.  We will also closely examine
the implications of the difference in the incidence of
cardiovascular disease between those consumers drinking
soft water and those drinking hard water.  Determining
the incidence and effects of microbial contamination as
well as developing appropriate monitoring and treatment
technology for such contaminants will remain a relatively
high public health priority because outbreaks of
water-borne disease still occur in the United States,
especially in poorly operated distribution systems.  We
.will also study the causes of corrosion in distribution
systems and possible methods for controlling it, and we
will give greater attention to the development of
cost-effective treatment techniques for removing
contaminants from small water supplies.

      The various elements of the program have been
arrayed in priority order for FY 80/81.

      In the short term, our highest priority will be
technology development and assuring the quality of
analytical methods now in use.  In the long term,
emphasis will be placed on health effects, development
of improved analytical methods, and ground-water

      The research strategy has been designed to
develop information from which EPA can determine if
there is a need to regulate additional drinking water
contaminants.  Furthermore, if regulations are deemed
appropriate, our research information can help
establish the levels at which standards should be set.
Our drinking water research data will also be used
by EPA's Office of Drinking Water to evaluate insti-
tutional solutions to some drinking water problems.
Some of the pertinent areas are regionalized water
supply systems to serve the small scale user, aid to
states regarding the economics of water supply, and
the management of water supply systems.

Better Methods to Identify and Quantify Contaminants
    In the absence of reliable contaminant measure-
ment and monitoring methods, it will be impossible to
provide scientifically valid and legally defensible
data to support and enforce the regulations issued

                     - 107  -
under the authority of the Safe Drinking Water Act,
Consequently, primary emphasis will be placed on
continuing our quality assurance program in EPA,
state, local, and contract laboratories.

Priority 1

    Continuing quality
    assurance functions
Major Research
Qualitv assurance
program to support
tnon j. tor i ng require-
merits for Safe
Drinking Water Act
performance evalua-
    Analytical methods
    for organics
    Surrogate methods for
    measurement of classes
    of organics
Priority 2
    Analytical methods
    for microbial
Analytical methods
for nonpurgeable

Surrogate methods
for measurement of
volatile organic
Methods to determine
presence of cysts
and viruses.

Radiometric methods
for detection of
sanitary indicator
microorganisms in
treated water.

Analysis of ATP
methods for moni-
toring bacterial

                     -  108  -
Priority 3
    Multielement analytical     -   Comparison of
    techniques                      several methods
                                    of multielement
                                    analysis, i.e.,
                                    optical emission
                                    spectrometry with
                                    an inductively
                                    coupled plasma
      "'#*   #'&'''
                **     v             source and x-ray
Better Treatment Technology for Drinking Water —
The lack of unequivocal health effects data related
to organic contaminants in drinking water does not
relieve EPA of responsibility for developing appro-
priate treatment methods when reasonable doubt about
health effects exists and monitoring is not practical.
The development of treatment processes to control
organic compounds will be the first priority in the
area of treatment technology.  Organic contaminants
selected for study will be identified in surveys that
quantify the prevalence of the compounds and identify
available health effects data.  Treatment processes
will then be developed through bench and pilot-scale
studies and will be studied in field evaluations.
We will attempt to adopt some processes now used in
larger treatment systems for use in the smaller
systems.  In doing so, oar objectives will be to keep
the technology simple enough so that the training
required for operators will be minimal.

      The two immediate needs in the inorganics area
are:  to develop treatment processes that will enable
small systems to meet regulations economically, and
to evaluate treatment processes for removal of asbesti-
forms.   A further objective will be the development of
treatment processes to control other inorganic
compounds in small systems, with primary emphasis on
the more troublesome inorganics such as nitrates,
arsenic, fluorides, and selenium.

                     -  109  -
      The major thrust in the area of treatment tech-
nology to reduce microbial contaminants will be the
evaluation of alternative disinfection methods with
emphasis on (1) small systems and (2) preventing the
deterioration of water quality in distribution systems

Priority 1

    Processes for organics
    control including
    alternative disin-
    fection technology

Priority 2

-   Processes for inorganics
    control with emphasis
    on small systems
Major Research
Field studies
involving carbon
adsorption methods
for organics con-
Bench-scale studies
of techniques for
controlling fluo-
ride, arsenic,
nitrates and selenium.

Field studies to
evaluate full scale
operations of
promis ing
inorganics control
methods that were
successful at bench

Field studies to
evaluate processes
for removing asbesti-

Special studies to
provide treatment
methods for small
systems, e.g.,
reverse osmosis,
ion exchange,
activated alumina.

                     - 110 -
Priority 3
    Microbial control
                                    Virus and parasite

                                    Identification of
                                    factors affecting
                                    growth of micro-
                                    organisms in

                                    Development and
                                    evaluation of
,                                    indicators of

 Health  Effects — As of April 1978, 698 organic com-
 pounds  had^ been  identified  in drinking water within
 the  United'States. While  important  information on
 incidence,  concentrations,  and health effects still
 needs to  be developed, a  number of  these compounds
 are  already strongly suspected to be detrimental to
 health.   Therefore, we will  first attempt to assess
 the  health  effects of certain of these organic com-
 pounds.   The focus of this  health effect research
 will be on  potential carcinogenicity.  Because there
 is  such a large  number of compounds, our research will
 follow  two  distinct avenues  of investigation.  First,
 we  will examine  those compounds which have already
 been identified  as potential human  health hazards.
 Our  second  avenue of investigations will focus on
 various groupings of compounds selected on the basis
 of  their  high observed concentrations and high fre-
 quency  of occurrence, in  conjunction with preliminary
 determinations of significant hazard based either on
 available data or on short-term bioassays.

      Considerable attention has been given  to the
 relationship between the  presence of inorganic compounds
 in  drinking water and cardiovascular disease.  The
 National  Academy of Sciences predicted a possible 15%
 reduction in heart disease  mortality by manipulation
 of  the  hardness  of the nation's water supplies but

                     - Ill
stressed that the specific alterations thst would be
appropriate have yet to be determined.  Rie Council on
Environmental Quality has also published information
that suggests a correlation between water softness and
heart disease.  As with organics, we will continue to
develop health effects information on these various
inorganic compounds.

Priority 1

    Health effects of
    organic compounds
    and alternative dis-
    infection techniques
Major Research
Concentration and
chemical character-
izations of organic
compounds from tap
water in five

Selection and
evaluation of
indices of
significant to

Association between
cancer and exposure
to drinking water

Selection of
organic parameters
which can be used
for standard

Toxicological and
studies to validate
the health signi-
figance of organic

Health impacts of
the use of alter-
native uis infection

                     - 112  -
Priority 2
    Health effects of
    inorganic compounds
    Health effects of
    additives used in
    treatment and distri-
    bution of drinking
Priority 3
    Protect drinking
    water from micro-
    bial contamination
Health effects of

effects of lead.

Carcinogenic poten-
tial of nitrate.

Health effects of

Inorganics and

Assistance in
protocols and
the program.
Annual review of
waterborne disease

Characterization of
the etiological
agents of viral
and giardiasis.
Scientific Basis for Protecting Ground Water Quality
    A primary objective of the program is to identify
major problems in the protection of ground water and to
provide the appropriate assessment methods to States
and communities.  A corollary objective is to develop
scientific and engineering guidelines on which we can
base source control criteria.  Work on assessment

                     - 113 -
methods will include development of biological and
chemical indicators of ground-water pollution, methods
to detect pressure increases resulting from well
injections, and protocols for determining, in any given
locality, the probable impact of specified activities
with known pollution potential.

Priority 1

    Assessment methods for
    monitoring the trans-
    port and transformation
    of ground water contami-
Priority 2
    Establish scientific
    basis for controlling
    various classes of
    pollutant sources
Priority 3
    Identification of
    major ground-water
    pollution problems
Major Research
Biological and
chemical indicators
of ground-water
                                    Pressure increases
                                    resulting from well

                                    Transport and
                                    transformation of
                                    hazardous materials
Petroleum explora-
tion and development.

Land application of

Artificial recharge.

Agricultural practices.
Extension of State-
specific studies
from the current 34
States to 50 States.

                     - 114  -
Changes Anticipated - FY 80/81

o   The ORD public health initiative for FY 80 includes
    an increase of nearly $5 million over the FY 79
    level for health research.  These resources will
    be used to intensify our research into the health
    risks posed by organic, inorganic, and microbial
    contaminants.  A strong emphasis will be placed
    on organic compounds and their carcinogenic poten-
    tial.  ORD will initiate the development of an
    investigative strategy which will help address
    systematically the numerous organic compounds that
    have been identified as being of potential concern.
    Emphasis on the public health initiative will
    continue in FY 81.

o   In FY 80 and 81, we will emphasize field evaluations
    of modular treatment methods for control of
    organics. Information from these field evaluations
    will be used to guide regulation development and

o   In accordance with a congressional mandate, ORD
    expanded research into the reuse of wastewater for
    potable purposes by $8 million in FY 1979. $1
    million for the reuse program is in the FY 80
    research budget for drinking water.  ORD plans to
    budget the $1 million for FY 81 within the research
    budget for water quality.



     The Solid Waste Media is concerned with the national
management of three Resource Conservation and Recovery Act
(RCRA) programs;  the Subtitle C  (haza;-:dou.i~ Waste) program;
the Subtitle D program for the management of. wastes not
classified as hazardous; and the Technical Assistance Panels
program, designed to support: the two foregoing efforts by
providing implementation ass.i stance.

Media Priorities

     The first priority of the Solid Waste Media is the
national management of the hazardous waste program.  All
Subtitle C regulations are expected to be promulgated by
December 31, 1979, and to become effective in July 1980.
The major hazardous waste activities of the Solid Waste
Media are responding to emergencies (highest priority),
issuing guidance for implementing the regulations, assisting
in the defense of the regulations against court challenges,
authorizing and overseeing State programs, conducting
Federal enforcement activities, and identifying, evaluating
and enforcing against facilities which may pose imminent
hazards (to be referred to as problem sites),

     The second priority is the national management of the
Subtitle D program.  In 1980, high priority activities will
include management of the land disposal site inventory,
State program development and management of grants under the
President's Urban Policy program.

     The third priority is the Technical Assistance Panels

Planning Assumptions

     The Solid Waste Guidance for 1980 is based upon the
1980 President's Budget.  This budget does not include
adequate resources to handle the priority activities listed
earlier.  There are substantial resource shortages in many
areas, but particularly for identifying, evaluating and
enforcing against abandoned or problem hazardous waste
sites.  There are, however, several uncertainties regarding
resources for handling abandoned or problem sites that could
significantly alter this Guidance.  This section wii_. describe
the assumptions used within the limits of the 1960 "''"'resident's
budget, and will also describe in some detail the uncertainties
that exist regarding resources for solid waste la FY j.980.

                        - 118 -

Base Level Assumptions

     o    Schedule of Regulations:

     Section of RCRA                   Date

     3001, 3002, 3003, 3004         12/31/79

     3005, 3006                     10/31/79

     4004 and 1008 (a) (3)             07/31/79

     1008 (a) (1)                     01/31/80

     4002 (b)                        06/30/79

     405  (Clean Water Act)          08/31/80

     0    FY 1980 Grant Levels;

               Hazardous waste - $18,600,000

               Solid waste - $10,000,000

               Urban Policy program - $13,950,000

                (See Table 1 for State allocations)

     0    Subtitle D grant funding;

                    Declining at a rate of $2 million
                    per year for 5 years

                    To fund high priority activities
                    only  (inventory, State regulatory
                    program, State plan development)

                    No pass-through unless clearly
                    supporting high priority activities

     0    Permitting function will be split in all
          budget documents  (irrespective of Regional

                    Abatement and Control will handle
                    technical reviews

                    Enforcement will handle administrative
                    processing and compliance monitoring

                             -  119

SufctUls C
761 ,856
Subtitla D


REGION I 1,013,350 602,300

PEGION II 1,795,086 1,348,800

REGION III 2,035,398 1,121,400

REGION IV 2,728,434 1,471,400

REGION '/ 3.79.1,446 2,035,200

RI.GION VI 2,357,332 941,900

REGION VII 721,680 513,300

REGION VIII 693,108 352,000

REGION IX 2,173,410 1,253,600

REGION X 78.0,456 354,100

TOTAL 18,600,000 10,000,000

18,600,000     10,000,000

                       - 120 -
     0    Penalty policies, enforcement stra-agies
          and implementation plans will be prepared
          during FY 1980

     0    No specific funding is provided in 1980
          President's budget for the discovery and
          evaluation of abandoned and problem hazardous
          waste sites

1979 Reprogramming — Although no specific funds have
been provided in either the 1979 or 1980 budget for the
discovery, evaluation and enforcement activities associated
with abandoned hazardous waste sites, considerable
activity of this type is presently ongoing.  It has
been estimated that approximately 30 workyears of
effort are being expended on this activity, utilizing
Headquarters and Regional solid waste enforcement, and
surveillance and analysis resources.  The effort is not
spread even] 7 among the Regions, but appears to be
rela ,ed  o  _i > number of problem sites per Region.

     Two eniorcemenc cases related to problem or
 '•ar^onod sites have currently been filed, and eight
                        - 121  -
this, EPA has already established a new institutional
structure of national and Regional coordinators and has
issued a change in programmatic priorities that will
result in the reprogramming of approximately 50 workyears
into this program.  Also, EPA is preparing to convene a
three-day workshop to orient the appointed coordinators
and train participating personnel.  Although EPA has
some experience in acting on abandoned/inactive site
incidents, the techniques for investigating cases,
protecting the safety of investigating personnel,
documenting data and preparing cases are still to be
perfected and many of the personnel that will be investigating
and bringing enforcement action on abandoned/inactive
sites will need additional training and experience.

     The discovery of abandoned/inactive sites will
basically involve receiving (or otherwise obtaining)
and recording leads on suspected sites.  Currently
there is no formal mechanism for the discovery of
problem sites.  Most of the known problem sites have
been identified through informal communications with
States and through citizen complaints.  This portion of
the program will systematize the documentation of
information received from various sources.  It will
also involve several low-cost efforts to search for
undiscovered sites.  The discovery component of the
program will be institutionalized and carried out
throughout the 18 months of the program and thereafter.

     The reconnaissance investigation component of
the program will involve making a preliminary investigation
of those sites identified as suspected problem sites in
the discovery phase of the program.  Supplemental funds
of $1.5 million in FY80 are requested for this work.

     The full investigation component of the program
involves conducting extensive field investigations, in-depth
sampling and analysis, and other related studies on
sites identified by the reconnaissance investigation as
being potential significant hazards.

     It is projected that approximately 300 sites can
and should be investigated over the next 18 months.  At
a cost of 5.5 workyears per site, this workload (930
workyears) would far exceed the current resource capacity
of EPA and would even exceed EPA's capacity to hire and
train personnel if additional personnel were authorized.
Accordingly, it is proposed to use as many as 30 contractors
under level-of-effort contracts to supplement State and

Regional :,*6.so,u'oes under c jse'-by--cao-.,  .'.auk  Gt,ck;rs  to
conduct full investigations.  There  are  contractors
available for such an effort.

     Xc i:s assumed that 225  si t.es v:.au  be  invest! gated
by the States, but with varying  amounts  uf  EPA  assistance
from the above-described contracts.  'The  initialling 75
site;s would be fully investigated by EPA also using
contractors.  It is further  assumed  chat  ail !.]. this
effort would be performed in Fi  1980 following  discovery
and reconnaissance activities in FY  1.979.   Using  these
assumptions, the full investigucion  ^ompoijc.u L  > 1:  the
program will cost $53.2 million.  To uiar.dga the Contractual
effort, and provide quality  assurance, a  limited  number
of in-house experts, 43 additional positions and.  $1.7
million will be required..  A.cco idingry,  supplemental
resources of 43 positions and $'54,9  million are requested
for FY 1930,

     The anforcament component of i,he  m, oyraru will
involve bringing suits to require responsible parties
to take corrective actions.  This phase  encompasses the
preparation of legal cases and  the additional technical
work and investigations necessary to support such
cases.  It is assumed that following fall  investigations,
the States will assume responsibility  for  enforcement
action, through State courts  in  50 cases,  with varying
amounts of EPA assistance,, and that EPA will  pursue
action on 50 cases under '-;'edera.L authorities.   Using
workload experience to dace  in similar enforcement
actions, 60 additional personnel and $2.4  million  will
be required in supplemental  funding  for  FY  1980.

     The emergency response  componeir:  of  L.ne program
will involve Federal funding of  clean-up  actions deemed
necessary to immediately contain extremely  hazardous
situations.  This will, include action  such  as  :.he
removal of drams of chemical wastes  from  navigable
waters and drainages into navigable  waters  (e.g.,
Louisville, Kentucky), the segregation and  removal of
drums of chemicals that pose a fire  or explosion  threat
or which are leaking into the environment t, and the
temporary containment of subsurface  migration of toxic
chemicals through the construction of  drains or other
means  (e.g., Love Canal).  These actions  will not  cover
permanent remedy.  They will be  employed  wriere
a. responsible party is not aval), ablt cr  tefuses to take
the emergency action.   Whenever  ijussiblt.,  recovery of
costs will be sought from available  responsible parties.
Also, enforcement/injunction ac'.ions will  ;.>e concurrently
taken wherever possible.

                        - 123
     Of the projected 300 sites that will be fully
investigated, it is assumed that 20 sites will require
critical emergency response.  At an assumed average
cost of $2 million, $40 million will be required.  It
is proposed that 75 percent of these 20 emergency actions
can be taken under the response authority of Section
311 of the Clean Water Act and that the remainder will
have to be addressed under Section 504 of that Act.
Accordingly, $30 million is requested to supplement the
Section 311 fund and $10 million is requested to fund
the Section 504 authority.  Five additional positions
are requested to manage these clean-up actions which
are very complex and long-term compared to oil and
hazardous materials spills.

     In addition, it is assumed that at least five
sites will require emergency response requiring application
of innovative technology.  The La Bounty site in
Charles City, Iowa, is a good example.  To deal with
these situations, 5 additional positions and $10 million
are requested.

     In summary, 10 positions and $50 million are
requested for emergency response actions.

     Overall, the following supplemental resources are
requested for the proposed program:

                                   FY 1980
Component                        pos     $1,000


Reconnaissance Investigation      -       1,500

Full Investigation               43      54,900

Enforcement                      60       2,400

Emergency Response               10      50,000
                                TTJ     108,800

     It should be noted that this proposed 18 month
program is designed to address only a small part (300)
of the estimated potential universe of significantly
hazardous abandoned/inactive sites.  Continuing activity
beyond FY 1980,  at the same or higher level,  is expected.

                             - 124  -

Research and Development

     The Resource Conservation and Recovery Act requires
that hazardous waste be identified, separated and managed
so as to assure environmental protection.  Because of the
relatively small amount of research in the past, the
information available on the quantities and characteristics
of hazardous wastes and on the costs and capabilities of
environmental control options is limited.

     The awareness of and concern over hazardous wastes
has increased very substantially.  As the Agency has moved
to use the authorities of the new legislation, information
on the actual size of the hazardous waste problem has
begun to be available.  Several aspects emerge as parti-
cularly acute.  First, an appreciation has developed for
the number and size of unaccpetable facilities that are
now in operation or have been abandoned.  Second, the long
term environmental consequences of storage, disposal or
destruction alternatives is quite uncertain.  The costs of
these different alternatives can vary considerably.  Third,
a desirable degree of general knowledge or accuracy in
characterizing wastes and control options does not exist.
At the present time each individual waste and the proposed
management practices must be evaluated separately to
establish costs and performance.  Without detailed studies
in each specific case, projections of acutal operating
characteristics are presently impossible.  F'ourth, as the
requirements and costs for managing hazardous wastes
increase, present waste generation patterns and practices
will change.  Our understanding of how waste generators,
transporters, and disposers will respond to increased
costs are limited.  For example, a regional liquid and
solid waste management facility may be the least expensive
and most effective option for metal plating and finishing
firms.  However, the costs of a facility designed for an
existing situation may affect the economics of these firms
enough to change their operations.

     The purpose of this section is to present issues and
questions inherent in the current planning of EPA's research
effort in hazardous waste management.  The concerns raised
here are meant to stimulate thought and discussion to produce
a better designed and executed research and development

                          - 125 -
     Program Office Views on Research and Development

     The Office of Solid Waste has not and does not rely
upon or assign high priority to research in solving the
hazardous waste problem.  Their position is founded upon
four separate points.

     o   Effective programs for dealing with hazardous
         wastes and rectifying unaccepatable or abandoned
         sites will cost tens of billions of dollars.
         The technological problems in establishing
         these programs are remarkably small compared with
         the problems of obtaining the necessary financial
         and institutional commitment.

     o   The Office of Management and Budget has decided
         that EPA will not undertake a grant program to
         either plan or site hazardous waste facilities
         or to finance their construction.

     o   RCRA calls upon EPA to establish rules for the
         disposal of future wastes.  Research results will
         not be available on a schedule compatible with the
         legislated requirement. Resources to generate the
         information for rule making are $20 million less
         than that required, resources for research should
         therefore be minimal.

     o   Research and development efforts cannot yield
         results quickly enough to respond to the problems
         of abandoned or unacceptable facilities.  These
         facilities must be addressed with presently available

     Is objective information available that est'hlishes that
aspects of dealing with the hazardous wastes are, in fact,
critically limited by lack of knowledge?  Are there cogent
reasons to believe that Federal R&D should generate that

     Research Required

     An effective research program for solving the problems of
managing hazardous wastes must address a variety of subjects.
Planning such a program must systematically identify these
problems.   One approach is to divide the research into three
general areas:

                            - 126 -
     o   The costs and capabilities of alternative hazardous
         wastes disposal options are not well documented.
         Options include storage or landfilling, fixation,
         detoxification, and incineration.  Efficient pro-
         cedures for dealing with various types of wastes
         have not been demonstrated.

     o   The characteristics and quantities of wastes from
         various sources have not been well documented.  The
         properties of wastes that must be known to allow safe
         and effective disposal have not been catalogued in
         a comprehensive fashion.

     o   Regional hazardous waste problems at abandoned,
         existing and future sites nay differ.  Techniques
         have yet to be developed that will lead to efficient
         regional waste management or minimization systems.

     What structure should be used in planning a research and
development program?  What types of problems and activities
should be included?

     Other Solid Waste Research

     ORD's research program now includes activities in both
hazardous and municipal solid waste.  In addition, the
activities are directed to defining environmental problems
as well as to solving them.  The problem definition research
activities include health effects, measurement and environ-
mental assessment.  The problem-solving activity includes
technology research, development, demonstration, evaluation
and technology transfer.

     Is the scope of research program inappropriate?  Should
research on specific topics be terminated?  Should research
be initiated on new topics?

     Research Management

     At the present time, three separate laboratories conduct
research on solving hazardous wastes.   The mission of the two
lERL's is defined by industrial sector and deals with all
environmental problems, including hazardous wastes.  Within
the lERL's the organizational structure follows industrial
sectors.  At the MERL solid wastes are assigned to a single
division and the division's structure  reflects alternative
control technolgies.

                            - 127 -
     ORD has not specifically addressed the problems of
designing a research program on hazardous wastes and has
not clarified divisions between organizations' respon-
sibility.  How might such a clarification be accomplished.

     What structure should be used in planning a research
and development program?  What types of problems and
activities should be included?

     Research Planning

     The Office of Research and Development is reexamining
thoroughly all of its present research in solid waste and
the emerging R&D needs of the Agency.  This examination
includes all facets of research and development activity and
will not be restricted to present, or proposed technology

     The activities will be divided into categories:

         Municipal Solid Wastes
         Waste-as-Fuel (Energy Funding)
         Health Research
         Transport and Fate of Pollutants
         Quality Assurance, Measurement and Monitoring
         High Volume Mining Wastes
         High Volume Energy Wastes (Energy Funding)
         Thermal Decompostion
         Hazardous Waste Treatment
         Waste Characterization
         Regional Hazardous Waste Management
         Abandoned Facilities Response

     Documents are being developed in each area that will
define the research needs, goals and outputs.  These
documents also define alternative program levels in each of
the thirteen areas.   The Office of Solid Waste and other
interested parties will evaluate and rank the program
options.  This ranking will provide the direction for the
FY-80 and FY-81 research programs.


                     TOXIC SUBSTANCES


Planning Assumptions

     The FY 1980 toxic substances abatement and control'
program activities and outputs are based on assumptions
about resource status and on program activity level.
The significant programmatic assumptions are related
to actions external to the toxic substances program.
The major one is that we will receive 400 premanufacture
notifications annually for review.  We expect that the
Interagency Testing Committee will continue to make
recommendations for priority testing up to the statutory
limit of 50 chemicals.  We are assuming that we will
receive industry substantial risk notifications at the
same rate as up to now.  Requirements for industry
assistance are assumed to remain fairly constant
overall.  We expect that many of the actions the
Agency takes initially will be the subject of petitions
and suits and that this will require significant pro-
gram effort to respond.  We have assumed that section 28
State grant authority and funding authorizations will
not be extended beyond FY 1979 by Congress.  We assume
that imminent hazard actions under TSCA section 7 will
be nonexistent or nearly so.  These assumptions will also
apply to FY 1981.  No legislative changes are assumed
for FY 1980.

     Abatement and control resources for the Regions
will provide for a minimal program level.  Only a
small amount of resources are provided for necessary
actions resulting from regulations.  Coordinative
resources are provided for Regional integratic , but
it is assumed that other media will provide resources
for activities to control toxic chemicals which are
being integrated.  No resources are provided for toxic
chemical emergencies or other activities not required
to support legislatively mandated functions.

     Output levels are based on the assumption that the
program operates at the full programmed resource
level in both FY 1979 and FY 1980.  This assumes that
we will be able to locate, hire, and integrate into
our organization large numbers of people with neces-
sary skills and use our contract money effectively.
This in turn depends on having adequate space when
needed and necessary administrative support.

                       - 132 -

     Finally, because this is a new program, we
have had to base many output levels on models of
resource needs and projections of program design rather
than on actual experience.

     The toxic substances enforcement program antici-
pates that by the end of FY 1980, the Agency will have
promulgated several TSCA section 4 testing standards,
including oncogenicity, chronic toxicity, and combined
oncogenicity and chronic toxicity standards.  In addi-
tion, a section 4 testing rule, requiring the submis-
sion of test results data relating to health and
environmental effects, will have been promulgated and
20-30 chemicals selected for testing under this regu-
lation.  Standards for providing test data in support
of a premanufacturing notice under section 5 will also
have been promulgated, and a number of section 5(e)
and 5(f) rules or orders will have been issued.  An
additional section 6 rule is expected to become effective
by the end of FY 1980.  Under section 8(a), the Agency
will have promulgated a use/exposure rule gathering
information on 2000-3000 chemicals.  In addition to
individual section 8(a)  information rules for a few
selected new chemicals, model rules will be issued under
sections 8(a), (c), and (d).  Finally, regulations
governing the importation of chemicals will be in

     FY 1981 will bring additional chemical control
regulations under section 6.  New section 4 testing
rules and new rules and orders under section 5(e)  and
5(f)  are also expected.  Furthermore, additional
section 8(a)  reporting regulations will be finalized
by the close of FY 1981.

     The enforcement resources necessary to adequately
monitor compliance with these program activities will,
for the most part,  be cumulative.  We assume that
resource allocations to existing programs will decrease
with time.   The net effect of the promulgation schedule,
however, will be to increase the demand for enforcement

     Research and development planning assumptions will
be identified through the research committee mechanism
which is being established presently for the toxic sub-
stances media.
     The FY 1980 and 1981 toxic substances programs re-
flect increasing levels of program activities and out-
puts.  These expanding activities are based on the
necessary foundations for program operation such as a
chemical selection and priority setting system, assess-
ment process, premanuf acture review process, including
testing guidelines for new chemicals, and data manage-
ment systems and capabilities for the most part being
in place and functioning.  These activity levels also
require that expedited procedures be in place for such
activities as reporting and recordkeeping rulemaking
and for control actions on new chemicals, which must be
taken quickly in order to be effective.

     In FY 1980, we will continue establishing these
toxic substances abatement and control program founda-
tions while more fully operating most aspects of the
program.  We will put priority on making the premanuf acture
review program fully operational, in order to review
new chemicals and take action on those that may be
hazardous before their release into the environment.
We will also emphasize development of rules to obtain
testing data upon which to make chemical assessments
in support of regulatory actions.  We will begin to
increase our emphasis on control of existing chemicals
which are identified as hazards through our assessment
process.  We will operate a priority setting system
for choosing chemicals for testing and regulation under
TSCA and other statutes, in conjunction with the Toxic
Substances Priorities Committee.  In FY 1981, we will
emphasize full operation of all major program components.
We will place a balanced emphasis on regulation of new
and existing chemicals based upon the information base
we establish in FY 1979 and 1980.  We will operate an
integrated priority setting system for choosing chemicals
for testing and regulation under TSCA and other statutes
in conjunction with the Toxic Substances Priorities
Committee.  Public participation in these key programs
will be emphasized in both years.

                       - 134 -

     The Office of Enforcement will concentrate its
FY 1980 and FY 1981 resources on the enforcement of
those regulatory programs which provide the most
effective means of (a)  abating threats to public
health or the environment due to chemical contami-
nants, (b)  gathering accurate cind comprehensive data
concerning the universe of potentially harmful sub-
stances,  and (c)  monitoring compliance with existing
standards to determine that regulated chemicals are
handled as required, and (d)  assuring the integrity
of the regulatory program.  Based on these criteria,
the following priority hierarchy has been established.

     Emergency Response — Since emergency situations
     by definition present a direct and substantial
     threat to public health or the environment, co-
     ordinating Agency response to such imminent
     hazards will be the highest priority for the
     Office of Enforcement.  The Office of Enforcement
     will bring actions under section 7 of TSCA
     for such injunctive relief as may be necessary
     to remedy the risk at hand.  Moreover, the
     Office of Enforcement will actively enforce the
     requirement under TSCA section 8(e)  that persons
     immediately report any emergency incidents of
     environmental contamination.  Finally, every
     effort will be made to use, where appropriate,
     emergency response tools available under other
     environmental statutes such as the Solid Waste
     Disposal Act.

     Premanufacture Notification - TSCA Section 5 —
     Becausethe premanufacture notification require-
     ment contained in section 5 of TSCA can be used
     both to gather information and to reduce ^he
     risk of hazardous chemicals being introduced into
     commerce,  monitoring compliance with this require-
     ment is a high priority.  The proper implementation
     of the section 5 screening mechanism will allow
     the Agency (a)  to prevent hazardous substances
     from reaching the marketplace, and (b) develop a
     more accurate profile of the chemical industry.

Chemical Control Actions - TSCA Sections 6, 5(e),
and 5(f) — Chemical control regulations con-
stitute the primary means by which the Agency
directly controls risks to public health and
the environment.  Section 6 rules on PCBs, CFCs,
and any other substances in effect will receive
special attention.  Since rules or orders
issued under TSCA section 5(e)  and 5(f) (in con-
junction with the review of premanufacture notices)
also impose chemical-specific controls, the en-
forcement of the terms of such rules or orders
will receive the same priority as that assigned
to other chemical control enforcement activities.

Information Gathering - TSCA Sections 4 and 8 —
TSCA sections4"andoprovide the principal
authority for obtaining information regarding
chemical toxicity and exposure.  Since a violation
of section 4 or section 8 does not directly
endanger health or the environment the enforcement
of these programs receives a lower ranking than
the compliance monitoring activities described
above.  The Office of Enforcement recognizes,
however, that since the success of other TSCA
sections depends upon the integrity of the data
received under sections 4 and 8, the Office of
Enforcement must provide the resources necessary
to assure that the information received under
these programs is valid and complete.

Imported Chemicals Control - TSCA Section 13 —
A smaller portion of resources will be used
to inspect imported chemicals at U.S. ports of
entry.  The Office of Enforcement will monitor
imported chemicals in cooperation with the U.S.
Customs Bureau.  Developing a specific protocol
to control imported substances will also be a
part of the strategies devised to enforce each
of the programs listed above.

Federal Facility Enforcement -- By the end of
FY 1980, it is expected that all, or almost all,
Federal facilities which are major sources will
be in compliance with applicable TSCA regulations
and most minor source Federal facilities will
also be in compliance.  Regions should assure

                         -  136 -
     that all Federal facilities do indeed come into
     compliance as soon as possible, and no later
     than the end of FY 1980.

     Apart from the enforcement of the substantive
mandates of TSCA, the Office of Enforcement will enhance
the efficiency of its compliance monitoring management
system during FY 1980 and 1981.  Among the many pro-
grams which will be implemented to achieve this objec-
tive, the Office of Enforcement will focus on the
following activities.

     Multi-Media Enforcement — The Office of
     Enforcement plans to implement an intra-agency
     multi-media approach to toxic substances enforce-
     ment.  As appropriate, the Office of Enforcement
     will use both the enforcement tools and
     the resources available under other EPA-
     administered programs to integrate compliance
     monitoring and enforcement activities.

     Inter-Agency Cooperation — To further expand
     inspectional resources, the'Office of Enforcement
     will work with participating agencies of the
     Interagency Regulatory Liaison Group  (IRLG) to
     (a) develop cooperative joint, referral, and
     crossover inspection programs, and (b) coordinate
     complementary compliance monitoring programs.

     Evaluation of the TSCA Enforcement Program —
     The Office of Enforcement will continue to
     evaluate and refine its compliance monitoring
     and enforcement programs in FY 1981.   As part
     of this procedure, the Office of Enforcement
     will establish a formal, automated system of
     processing information generated through
     compliance monitoring and enforcement activities.
     It will also conduct a periodic review of
     Regional programs and will establish a Regioncil
     team to evaluate Headquarters performance.

     Research and development priorities for toxic
substances will be established jointly by the research
committee participants.

                       - 137  -
Major Objectives

     The abatement and control program objectives are
to implement the Toxic Substances Control Act's
policy that (1) adequate data should be developed with
respect to the effect of chemicals on health and the
environment and that the development of such data should
be the responsibility of those who manufacture and
process the chemicals, and  (2) adequate authority should
exist to regulate chemicals which present an unreasonable
risk of injury to health or the environment.  These
objectives include the information related activities
of developing test standards and applying them to
specific chemicals by rule  to obtain test data from
industry, establishing reporting and recordkeeping
requirements to obtain existing information on chemical
substances, setting requirements for submission of
information by industry on  new chemicals and significant
new uses, monitoring for field data, implementing
and operating data management systems, and exchanging
nonconfidential information with other programs,
Federal agencies, States, public interest groups, and
the general public.  It also includes scientific assess-
ments of effects, exposures, and risks for new and
existing chemicals based upon this information and
technical determinations of control options, including
economic considerations.  Control related activities
include taking formal actions on the manufacturing,
processing, distribution, use, and disposal of new
and existing chemicals under TSCA authorities, refer-
ring action to other programs or agencies, and taking
nonregulatoiy approaches.

     The fundamental objective of the toxic £_bstances
enforcement program is to protect public health and
the environment from unreasonable risks posed by
chemical substances regulated under the Toxic Substances
Control Act.  The risk abatement process will be
accomplished through:

     (1)   The implementation of a program to prevent
or respond to toxic substances emergencies and notices
of substantial risk,

     (2)   The achievement of compliance with the substan-
tive requirements of TSCA and regulations promulgated

                        -  138 -
     (3)  Assuring that information gathered under TSCA
is accurate and complete so that correct assessments
of toxicity and exposure can be made, and

     (4)  The expansion of inspectional resources
and improvement of the TSCA enforcement management

     Research and development objectives will be
established through the research committee for toxic

                        - 139 -

Research and Development

     Plans and Priorities/Changes — In FY 1980 and and FY
     FY 1981, EPA's R&D program will focus on three manage-
     ment priorities:

          o    Continue the integration of OPD's research
               into the Agency's activities.

          o    Enhance ORD's capability to improve the
               scientific and technological data for future
               Agency  regulatory and enforcement actions.

          o    Improve the quality and utility of the
               scientific and technical data used by the

     Plans for accomplishing these priorities include the

          o    Establish research committees to oversee
               the joint planning of all toxic substances
               research in support of regulations and
               enforcement.   Three committees are proposed:

                    Pesticides established in FY 1978
                    (relating primarily to the Office of
                    Pesticide Programs).

                    Testing and Assessment to be estab-
                    lished in FY 1979 (relating primarily
                    to the Office of Testing and Evalua-
                    tion and the Office of Program Inte-
                    gration and Information).

                    Chemical Control, deferred (relating
                    primarily to the Office of Chemical

         - 140 -

These committees will develop multi-year
research  strategies and will incorporate
requirements  and reviews of the Regional
Offices.  To  accomplish this, it will be
necessary for the Regional Offices to coor-
dinate their  participation and share respon-
sibility  for  representing Regional interests,

Review all longer-term research efforts
underway  in ORD to assure that the best
scientific capabilities are being directed
toward the most important future problems.
Fifteen percent of ORD resources for toxic
substances R&D will be devoted to existing
and future broader-based,  longer-term re-
 search efforts to build an improved data

Plan  and implement the Agency's Public
Health Initiative which will provide an
integrated data base for assessing the
significance of human exposure and adverse
human health effects from chemicals and
chemical mixtures released into the
environment.   This will include the estab-
lishment of a National Neurotoxicology
Research Facility to serve,  particularly,
the Federal agencies forming the Inter-
agency Regulatory Liaison  Group.   Also
within this initiative are cooperative
programs  which include NCI, OTS, and ORD.
These programs involve research to develop
enough basic data relating to chemicals,
animal species, and biological mechanisms
to permit estimates of human effects.

Establish mechanisms to assure, wherever
feasible, peer scientific review of the
plans for and results from individual
research  projects, bringing to bear on
the program design the best scientific
advice available.

                        - 141 -

          o    Establish an environmental criteria and
               assessment function to provide quality
               control for the Agency's risk assessments
               and develop a program for quality assur-
               ance of biological research and testing.

FY 1980 Health Research

     The health research program will focus on develop-
ing new and improved techniques for rapid, reliable and
economical screening of toxic substances to provide
scientific data for regulating new and existing chemicals
in the marketplace.  Efforts will also be directed toward
improving the reliability of studies on the carcinogenic
effects of ultraviolet rays.  These plans include the
following priorities:

     o    Perform epidemiological studies of the reaction
          of human populations to environmental toxic
          chemicals, for example, epidemiology in the
          area of human reproduction and sterilant effects

     o    Develop methods for analytically determining
          the exposure history of specific populations
          to chemicals in general.

     o    Develop screening techniques for determining
          means of detecting the effects of toxic
          substances on the nervous system and evaluate
          the significance to humans.

     o    Develop rapid,  reliable and low-cost screening
          techniques using bioindicators for assessment
          of the commercial chemicals reaching the

                         - 142  -

      o    Develop testing procedures  and  techniques;  to
           measure effects of toxic  substances  on  the
           immune  system.

      o    Examine the  feasibility of  using  the toxicology
           of  aquatic and  mammalian  organisms as short-
           term  testing indicators of  human  health effects.

      o    Apply the time-to-tumor model to  reduce time
           required for obtaining carcinogenicity  test

      o    Test  personal dosimeters, develop models to
           forecast UV-B skin cancer incidence  and compare
           the economic value of reduced risk of skin
           cancer  to future generations.

FY 1981 Health  Research

      The FY 1981  research plan will include the continua-
tion  of the research identified for FY 1980 and will
expand the parameters  to  support development of testing
standards  for existing chemicals as required under
TSCA  section  4.

FY 1980 Changes

      Research will proceed as described in  the FY  1980
budget with the following exceptions:

      o    The immune system research will be broade;ned
          in scope to  include other aspects of host defense
          systems  such  as whole organs (lung and  liver)
          and whole organisms.

      o    Screening with  short-term testing using bio-
          logical  indicators will include end  points
          relating to mutagenic, carcinogenic, and
          reproductive  hazards.

     o    Analytical chemical procedures may incorporate
          development of quality assurance  procedures to
          be used in determining human exposure levels.

FY 1981 Changes

     No changes are anticipated at this time.

                         -  143  -

FY 1980 Environmental Processes and Effects Research

     Transport and Fate —  The research work under the
     plan will focus on the development of exposure
     assessment models for  toxic  chemicals in multimedia
     environments, development of improved protocols to
     be used in testing of  toxic  chemicals, and techni-
     cal assistance to OTS  on complex problems.  The
     following are priorities:

          o    Develop exposure assessment models to
               predict the  concentration of toxic chemi-
               cals in air, water and soil/sediment
               environments.  Incorporate single media
               models for the development of a multimedia
               exposure model.

          o    Investigate  complex environmental trans-
               formation processes such as photolysis
               (in air, soil, sediments)  and microbial
               degradation  for the development of proto-
               cols for toxic chemical testing.

          o    Investigate  complex transport processes
               such as leaching and partition coefficient
               for the development of testing protocols
               to be used in exposure assessment models.

          o    Develop model ecosystems and smog chambers
               for the validation of exposure assessment
               models and for screening of toxic chemicals.

          o    Characterize and select soils and sediments
               to be used in testing of toxic chemicals
               and to determine the feasibility of a soil/
               sediment bank.

          o    Validate and develop a representative
               chemical or  benchmark concept to predict
               the behavior of  toxic chemicals in the

     Ecological Effects Research  -- The major emphasis
     of research in this area is  to develop screening
     procedures and protocols for testing of toxic chemical
     effects on living organisms  in freshwater, marine
     and terrestrial environments.   Under this plan, a
     major effort on the Public Health Initiative will be

                   - 144  -
 initiated  to develop a better understanding of  the
 effects of  exposure and develop methods to predict
 human  exposure  to environmental toxicants.  Specific
 priorities  include the following:

     o   Develop, refine, validate, and calibrate
          ecological screening procedures for defin-
          ing the effects of toxic substances on
          organisms and ecosystems.

     o   Conduct round-robin testing of methods
          such  as acute bioassay and bioconcentra-
          tion  tests, for assessing toxic chemicals.

     o   Develop predictive techniques and methods
          to determine levels of human exposure to
          environmental toxic chemicals.  This will
          involve validation of existing exposure
          models and initiation of "benchmark" and
          structure activity concepts for predicting
          toxic chemical behavior.  The development
          of exposure models will require a better
          understanding of transport and transforma-
          tion processes, biochemical transformation
          into the food chain, validation of exposure
          models into laboratory model ecosystems and
          microcosms.  These models will be used in
          the screening of toxic chemicals.

     o    Delineate evaluative methods to determine
          human exposure to toxic chemicals at
          environmental levels to validate exposure
          models.  The work will involve monitoring
          and field surveys.

     o    Develop the data base on human exposure.  The
          work will include the evaluation and analy-
          sis of the exposure data currently availa-
          ble at the Federal and State level.

     o    Initiate experiments on photosynthesis
          reactions of field crops to UV-B.

Characterization and Measurement Methods Development
-- The main thrust ofthe research plan under this
program is to develop improved methods for the
characterization and quantification of toxic chemicals
in air, water,  soils and sediments.  Such methods

                         - 145 -

     are needed in determining exposure to toxic
     chemicals, monitoring toxics and carrying out
     transport, fate and effects studies on toxic sub-
     stances in the environment.  Furthermore, TSCA
     requires regulation of large numbers of chemicals.
     For many chemicals, especially new chemicals, adequate
     methods for characterization do not exist.  The
     specific priorities are as follows:

          o    Develop improved methods for the charac-
               terization of toxic chemicals in air using
               such methods as resins, high pressure liquid
               chromatography and mass-spectrometry.

          o    Develop improved collection devices for
               toxic chemicals to be used in determining
               exposure concentrations of toxics in air.

          o    Develop methods for separation and charac-
               terization of toxic chemicals in soil/
               sediments.  Although soil/sediments repre-
               sent a major sink for toxics, the current
               state of the art for measuring and identi-
               fying toxics in soil/sediments are extremely

FY 1981 Environmental Processes and Effects

     Transport and Fate — The research plan for FY 1981
     will involve the continuation of the work identified
     for FY 1980 with the following modifications:

          o    Acceleration of work on methods develop-
               ment for exposure assessment of toxic
               chemicals in multimedia environments.

          o    Initiation of work on transport and trans-
               formation of chemicals in marine and terres-
               trial environments.

     Ecological Effects  — The research plan for FY 1981
     will involve the continuation of the work identified
     for FY 1980 with the following modifications:

          o    Termination of  the work on development of
               acute bioassay  testing methods for use in
               evaluating toxic chemicals.

                    - 146 -

      o     Initiation of  chronic effects testing  for
           toxic chemicals  on organisms and the aquatic

 Characterization and Measurement Methods Development
 -- The research plan for FY 1981 will involvethe
 continuation of the work identified for FY 1980
 with  the  following modifications:

      o     Expansion and  acceleration of work on  the
           development of methods for characterization
           and quantification of toxic chemicals  in
           soil/sediment  environments.

 FY 1980 Measurement and Monitoring Research —
 The measurement and monitoring research will focus
 on the areas of biological laboratory quality assur-
 ance  and  technical support related to data collection
 capabilities.  The priorities include:

      o     Develop reference and quality control
           materials, and prepare technical guidelines
           pertaining to methodology and biological
           laboratory testing.

      o     Develop a laboratory intercomparison
           studies program and evaluate laboratories
           and laboratory procedures.

      o     Develop a training program comprising
           quality assurance procedures and method-
           ologies .

      o     Determine the nature and extent of toxic emis-
           sions to the atmosphere through ftaceline
          monitoring studies around chemical complexes.

      o     Provide aerial sampling,  photography and
           interpretation to identify and assess  the
          nature,  extent and source of toxics in
           the environment resulting from the manufacture,
          processing and disposal of toxic substances.

FY 1981 Measurement and Monitoring — In FY 1981
this program will focus on quality assurance for
biological testing which will be sufficiently
developed  to stock and operate a repository of
biological testing and reference materials.  This

                    -  147 -

 will  allow interlaboratory  testing of biological
 testing  protocols  to  be  conducted on  a routine basis.
 It  will  facilitate conducting  evaluations  on  a routine
 basis.   It will  also  permit an assessment  of  the
 proficiency of analyses  and the performance of techni-
 cians  conducting biological tests.  Technical assist-
 ance  support will  be  maintained in essentially the same
 areas  as were identified in FY 1980.

 FY  1980  Changes  --- The FY 1980 plan for quality assur-
 ance  of  biological laboratory  testing is a new start.  A
 small  program has  been in existence which  demonstrated
 the feasibility  of in_ vivo  incorporation of inorganic
 toxics into plant  tissues which could be used as
 biological testing reference materials.  This initial
 program  indicates  the probability of  the success of the
 development of organic toxic materials into tissue
 samples  is good.   No  changes are  anticipated  in the
 technical  support  program to provide  data  collection
 capabilities  in  the area of toxics  monitoring.

 FY  1981  Changes  --  No changes  are anticipated.

 FY  1980  Control  Technology  Research -- In  FY  1980
 emphasis will be placed  on  expansion  of  the regulatory
 data base,  specifically  the development  and expansion
 of  the predictive  model  for chemical  manufacturing.
 The plan includes  the following priorities:

     o     Use process expertise in  the manufac-
           ture of  existing  chemicals  to  provide and
           predict  information  on  the  occurrence of
           toxics as contaminants  in intermediates,
           by-products, products and wastes.

     o     Develop  marketing arid use information to
           provide  a basis for  identifying  substitute
           chemicals and  alternative process routes
           including recovery reuse  and recycling of
           toxic wastes.

     o     Develop  a predictive model  for new  chemical
           manufacture to identify  anticipated processes
           and expected releases of  toxics.

FY 1981 Control Technology  Research -- This program
which originatecTIn FY 1978 and is  approaching  critical
mass in FY  1980,  will be expanded  in  Fi'  1981.    The

                        - 148 -

     major emphasis will be to support manufactur-
     ing regulations development as well as control of
     existing chemicals, emergency response techniques
     and assistance to the regions.  The predictive model
     for new chemical manufacture to identify anticipated
     processes and expected releases of toxics will also
     be expanded.

Alternatives — An alternative to the planned
method of operation (a balance between in-house and
extramural)  is an all extramural effort.  This was
rejected because:

     o    EPA has now established expertise in terms
          of both facilities and highly specialized.
          interdisciplinary personnel.

     o    Additional cost of extramural work.




Planning Assumptions

     The Federal Pesticide Act of 1978, which amended
the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA), will make the regulation of pesticides more
efficient, more effective, and more timely.  All
registration (section 3) guidelines will be completed
and in force by the second quarter of FY 80 and new
regulations, where appropriate, will be in effect at
this tine and fully enforceable.  The following
assumptions reflect the new directions and resumed
activities that those amendments have nade possible.

     Studies required by the FIFRA as amended on methods
of pesticide applications and minor use pesticides will
be completed the third quarter of FY 79, but at this
time, we do not anticipate the results to cause any
major realigning of OPP's regulatory activities.  Ef-
forts to refine and improve the Agency's tolerance-
setting mechanisms will continue through FY 80 and
FY 81; no radical departures affecting Agency or
registrant resources are anticipated.  Legal chal-
lenges to the trade secrets and data compensation
provisions in the 1978 FIFRA amendments are anticipated.
OPP and the Office of General Counsel expect these to
be resolved in EPA's favor.

     The Generic Standard development process will be
fully productive by the beginning of FY 80.  RPAR will
be merged into the generic standards in FY 81 when the
original RPAR commitment to 65 chemicals has been

     Until pesticide generic standards are developed,
EPA will be granting conditional registrations.  Con-
ditional registrations will allow the Agency to process
applications for registration of new products which
are like one already registered.  Ultimately, OPP wi
review all products comprehensively when they are
reregistered under generic pesticide registration

                       - 152 -

     "Me-too" products and new uses of "old" chemicals
will be eligible for conditional registration if EPA
determines that enough information is available to
evaluate unique hazards that may be posed by the new
uses.  The Agency will also issue conditional registra-
tion of new chemicals in the public interest if risk
during the period required to complete and submit
additional studies is not unreasonable.

     States will have broader authority and responsi-
bility for registering Section 24(c) "Special Local
Needs" pesticides without requiring EPA's approval.
Regions will assist States in establishing their 24(c)
programs and will provide early guidance and screening
to States on individual 24(c) applications.  Final
review/disapproval will remain a headquarter's function,

     EPA will use broad discretion granted by the 1978
amendments to waive the submission of efficacy data.
OPP will evaluate this during 1980 and, if it does not
prove to be effective, will reconsider this approach.
In any case, the Agency will continue to consider
efficacy when performance of the product bears upon
public health.

     In FY 1980 EPA will complete (except for updating)
the process of classifying uses by regulation, apart
fron the registration process.  This will help to
realize the objectives of the applicator certification
program with regards to restricted use products.

     The effort to develop grants-in-aid with States
and Territories for enforcement will be continued.  By
the end of FY 1980, 43 States will have cooperative
grants-in-aid, and by FY 1981 the number of grants will
increase to 50.

     The Office of Enforcement will initiate a new pro-
gram (Investigations of Nationally Targeted Pesticides
Public Health Incidents) during FY 1979 to focus upon
all aspects of the manufacture, distribution, use, and
disposal of certain restricted use pesticides.  This
effort will be given continued empahsis in FY 1980.

                       -  153  -
     By the end of FY 1980, it is expected that all, or
almost all, Federal facilities which are najor sources
will be in compliance and nost minor source Federal
facilities as well.  Regions should see to it that all
Federal facilities do indeed come into compliance as
soon as possible, and no later than the end of FY 1980.

     Research and Development will be integrated into
supporting pesticide activities in 1980.  Furthermore,
ORD will receive its planning priorities from the
Pesticide Research Committee and specific requirements
from OPP.

     The Federal Certification program in Colorado and
Nebraska will continue at least through FY 1981.

     OPP will be staffed up to budgeted levels with
qualified professional and support personnel.  Both
Regional RPAR and Special Registration Decision Units
are eliminated commencing in 1980.


     FY 80 priorities will emphasize the completion of
the remaining RPAR reviews, completion of registration
standards initiated in FY 79 and reregistration of
existing pesticides based on these registration stand-
ards, registration of new environmentally protective
pesticide products for which complete hazard data are
submitted, expanded enforcement involvement on the
part of the States, and increased response to emergency
situations which involve substantial threats to public
health and safety.

     FY 1981 priorities for the pesticide program will
be similar to those for FY 1980.  RPAR will be substan-
tially completed and integrated into the registration
standards process.  Highest priority will be registra-
tion of new environmentally protective pesticide
products.  Continued completion of registration standards
and reregistration of existing pesticides based on them
will also be emphasized.  Cooperative enforcement grants-
in-aid are expected to be developed in all or most States
by the end of FY 1981.

                      - 154 -
     In those States which have Federal certification
programs, enforcement activities will be in support of
efforts directed toward developing approved plans,,

Federal personnel will continue to be responsible for
enforcement of applicator certification in Colorado and

Major Objectives

     In FY 80 the Agency plans to review benefits and
risks of 12-17 RPAR compounds identified as posing
potentially unreasonable adverse effects and reach 15-20
final risk/benefit determinations on RPAR compounds;
implement the conditional registration program; give
registration priority to new chemicals for which com-
plete hazard data are submitted; reregister 1,000-1,400
products from available generic standards; complete the
generic standards initiated last year and initiate the
preparation of 40-50 generic standards, including the
reassessment of associated tolerances.

     Major objectives, reflective of the special
registration program, will be for Regions and Head-
quarters to provide timely and responsive guidance to
the States relative to their Section 5(f) experimental
use permits and review 180-240 Section 5 registrations
in a median turnaround time of 120 days; review 1,000-
1,500 Section 24(c) special local needs registrations
and conduct overview activities on their final actions;
review 170-220 Section 18 emergency exemptions in a
median turnaround time of 4 weeks including full scien-
tific review of pertinent data.

Guidelines for biological pesticides will be promul-
gated.  The Agency will establish 80-120 pesticide
residue tolerances and review 75-100 amendments for food
and animal feed crops after review of data and risk/
benefit analyses in a median turnaround time of 105 days

     The laboratory audit program will be continu€id;
50-7U laboratories will be audited.

     FOI requests will be given an initial response
within 10 days followed by a final response as quickly
as possible.  Monitoring for hazard prediction and
significance of potential problems will continue, but
will be more closely tuned to support the regulatory
process .

                      - 155 -
     The abatement and control objectives for 1981 re-
main the sane as for 1980 except that the RPAR process
will be integrated into the generic standards process
and increased empahsis will be given to registration
of innovative, environnentally protective compounds.

     The Federal Enforcement role will continue to be
one of oversight, guidance, an support of non-Federal
enforcement effects in States and Territories.  The
program will also focus upon all aspects of the manu-
facture, distribution, use, and disposal of certain
restricted use pesticides.

     During the next two years, four major objectives
will be driving the Environmental Protection Agency's
research and development program.  These are (1) con-
tinuing the integration of the Office of Research and
Development into the mainstream of the pesticide
activities by supporting the Pesticide Research
Committee that was jointly developed by ORD, OPP,
Office of Enforcement and regional representation,
(2) enhancing the Office's capability to improve the
scientific and technological data for use in future
regulatory and enforcement actions, (3) improving
that data through scientific peer review of research
procedures and results, quality control of risk assess-
ments, and quality assurance of monitoring data, and
(4) providing specific data in response to OPP's
immediate needs.

                         - 156 -


Research and Development

     Plans and Emphases

          The Office of Research and Development will
     intensify efforts to develop protocols for obtain-
     ino a scientifically sound, legally defensible
     pesticide data base, to provide specific data
     requested by OPP, and to assist in assessing the
     data in relation to pesticide renulatory actions
     required by the Aqency.  Special enphasis will be
     placed on a continuing integration of the Office
     of Research and Development into the nainstrean
     of the Agency's pesticide activities by supporting
     the Pesticide Research Committee that was jointly
     developed by OPD, OPP, Office of Enforcement arid
     Regional Representation.  OPD's planning and
     reporting systen will be synchoron ized v;ith the
     plans of the PEsearch Committee and the Agency"s
     ZRP process.  Certain laboratory reporting
     relationships will be realigned; this realignment
     will enhance human health research and integrate
     the environmental transport, fate, and effects
     research pertaining to pesticides.

          The increased integration of OPD efforts into
     the renulatory mainstream will result in an in-
     crease of data and methods to support OPP's
     regulatory needs.  In looking at health effects,
     OPD will conduct exposure estimates on priority
     compounds identified by the PPAP and generic
     standards process.  Similarity, OPD will conduct
     research into ecological effects in response to
     near-tern regulatory needs.  This will include
     data assessments, toxicological tests and trans-
     port and fate tests for RPAR compounds.  In
     addition, ORD will develop the duality level of
     analytical measurement data, expressed in terns
     of precision find accuracy, to support OPP regula-
     tory dec is ions.

          Additional activities include efforts to
     build into our scientific and technological
     activities appropriate review mechanisms, includ-
     ing enhanced peer review for individual research
     projects and systemic programmatic review for
     pesticide research activities.  OPD will reouire,
     to a greater extent than in the past, quality
     assurance practices for all environmental quality
     monitoring and analytical activities.

                     -  157  -

     Research activities will follow as closely
as possible the strategy and needs developed by
the Pesticide Research Connittee and be responsive
to the specific OPP needs.  The Connitee contempla-
ted research required by OPP, OE, and the Peqions to
fill knowledqe and data-gaps, to develop scienti-
fic techninues for obtaining these data, and to
respond to future needs that are rnore appropri-
ately anticipatory in nature.  Research needs
v;ere discussed under three najor topics;  popula-
tions at risk, exposure assessment, and adverse
effects.  Also included were research needs for
quality assurance, integrated pest manaqenent and
technical support.  The Committee agreed that
exposure assessment should receive special
attention in FY PO and Rl.

     The Integrated Pest T'anagenent (IPM) proqran
will develop systens for use with chenical pesti-
cides to provide a necessary alternative for the
pesticide registration process.  Prinary emphases
will be directed to najor crop ecosystens (corn,
cotton, soybeans, alfalfa, and apples) and urban
pests.  Technolony transfer activities will
continue in order to educate the use community.

     The registered uses of a pesticide determine
the population group at risk.  As increased amount
of exposure data for different pesticides become
available, it will be possible to make accurate
and meaningful identifications of overall popula-
tions risk.  Within these populations, attempts
will be made to pick out subgroups of persons at
relatively hiqh risk of developino illness frort
pesticide exposure.  Extrapolation from teratology
and reproduction studies in experimental animals
will help to define those compounds that nay pose
a risk to pregnant women as well as to the fetus
and the newborn child.  Other research will study
susceptibility to pesticides of aninal given sub-
optional diets.

     Interest in the population at risk also
includes pesticide exposed populations that may
have incurred vulnerability to other hazards.
New studies to survey this problem will include
evaluation of the innunologio competency of
animals exposed to various pesticides and
capability of pesticide exposed animals to with-
stand bacterial and viral challenge.  FY 79 and

                       - 158 -
earlier research activities in pesticide exposure
studies have produced guidelines for qeneral use
by reqistrants in measuring exposure of workers
to pesticides.  Enphasis in 1980 and 1081 will
he on developinq and validating procedures useful
in neasurinq environmental exposure to pesticides,
particularly exposure of nearby residents to drift
fron agricultural application.  Also, research
will be begun to evaluate qeneric models for con-
pounds and application methodology in estimating
hunan occupational and environmental exposure to
replace study of individual situations.

     In-house and extrarural studies will produce
the requisite scientific understanding, laboratory
measurement techniques, and mathematical descrip-
tions of the interactions of pesticide chemicals
with air, water, and soil and the actions of
orqanisns on the chemicals.  This information will
then be developed into test protocols that incor-
porate necessary cuality control provisions and
decision-making tools to evaluate the environ-
mental transport, transformation and distribution
of pesticides.  Specifical]v , research on
environmental exposure will include determination
of transport processes in water, sediment of soil
and biota in terrestrial and aouatic environments.

     mhere will be a close coordination between
exposure research and effects to define the degree
of hazard or extent of safety of current pesti-
cide exposures for both occupationally and
environmentally exposed populations.  For many
pesticides, by-products, metabolites and biotrans-
formation products, exposure methodology is now
sensitive to levels below those known to have
toxic effects on man and the environment.  Effects
research will be carried out to continue to assure
the safety of ambient levels of pesticides or to
detect any hazardous levels that exist.  Pioloni-
cal-type pesticides are a special problem and will
be given special attention.

     In addition to the usual research on effects
of specific pesticides on aquatic and terrestrial
organisms, ORD will develop the car.ability to

                   - 159 -

conduct subacute avian toxicity tests on a limited
scale.  These tests will yield information unat-
tainable fron other Federal agencies.

     Quality assurance, includinn both internal
quality control and external quality assurance,
will be made an integral part of every protocol.
Current procedures in analytical and biochemical
projects provide for such procedures, but quality
assurance can and will be improved.  Additional
efforts will be nade to ensure that in-house and
extramural pesticide laboratories are routinely
involved in quality assurance programs for
chemical analysis.

     In a closely related area, ORD will work
closely with OPP and OE to develop protocols
for "good laboratory practices" and will become
involved in transferring this information to
Regional Inspectors and others as necessary.


     Other than items addressed in the "Plans and
emphases" section, there are no najor changes
anticipated in R & D activities.


     Research activities are now conducted through
a mixture of in-house  and extramural activity.
Alternatives to this approach include accomplish-
ing research activity through grant and contracts
only or through in-house activity only.

     Grant and contract work permits exclusive
control over planning and implementation of
desired research but often requires even longer
lead-times than now required.  This approach does
not furnish the agency with required data analysis
and necessary expert testimony at regulatory

     The office of Research and Development is
not able to maintain under present resource allo-
cations, the necessary skills mix or expertise  to

                    - 160 -
address the entire scope of scientific questions
that arise within the Agency.  Also, it is scien-
tifically advisable to maintain close contact
with academic and private sectors.

     Therefore, a research operation which is
either exclusively in-house or conducted through
grants and contracts is not feasible.




     The Environmental Protection Agency is responsible
for protecting the public and the environment from the
adverse effects of unnecessary radiation.  Recent Con-
gressional and Executive mandates have directed EPA to
focus on the following specific radiation sources and

     o  The Resource Conservation and Recovery Act
        (RCRA) and the Uranium Mill Tailings Radiation
        Control Act  (UMTRCA) charge EPA with providing
        standards for protection from waste materials
        with radioactive content.

     o  The Interagency Review Group on Nuclear Waste
        Management (IRG) identifies EPA as the standard
        setter for the various classes of waste in its
        Report to the President.

     o  The Clean Air Act Amendments of 1977 require
        EPA to protect public health and the environ-
        ment from harmful radioactive airborn effluents.

These specific authorities dictate the major emphases
which EPA's radiation program will pursue in FY 1980-81.

Planning Assumptions

     FY 1980 — The Radiation Guidance assumes the passage
     of no new legislation, but does assume endorsement
     by the President of the agency roles and work
     schedules proposed in the IRG Report.  In addition,
     Guidance assumes that:

          o  EPA will promulgate the standard for disposal
             of high-level radioactive waste in FY 1980.

          o  The Agency will complete its cancer policy.

          o  No major changes in Federal energy policy
             will be made.

                          -  164 -
          o  No major natural or man-made event will
             occur or be discovered to require imme-
             diate EPA action to prevent or mitigate
             serious acute population exposure to
             radiation.  If such an event does occur,
             EPA will provide required support by
             diverting efforts from lower priority

          o  The Office of Radiation Programs will
             determine sources or substances requiring
             control under the Clean Air Act Amendments
             of 1977 by the beginning of FY 1980.

     FY 1981 — The following additional assumptions
     apply to FY 1981:

          o  EPA will promulgate standards for three
             major source categories under CAA.  Atten-
             tion can then focus on other sources.

          o  EPA will issue the standard for inactive
             uranium mill tailings.

          o  EPA, other Federal agencies, and the Con-
             gress will agree on EPA's role in develop-
             ing Federal Radiation Guidance.

Media Priorities

     Two priorities are proposed for FY 1980: developing
standards for radioactive wastes and airborne radioactive
emissions; and establishing organizational roles and
procedures to enforce these standards.  In FY 1981, the
Radiation Program will continue to emphasize standards
activities, while implementing an effective standards
enforcement program.

Media Objectives

     In FY 1980, ORP will give top priority to developing
standards for inactive uranium mill tailings, with imme-
diate transfer of that effort to developing standards for
active uranium mill tailings as it becomes possible to do
so.  The Interagency Review Group schedules will serve as
a guide to planning the EPA program for developing
standards for transuranics waste (TRU), land and sea dis-
posal of low-level wastes, and the decommissioning and

                            165  -
decontamination of nuclear facilities.  Work will progress
in all of those areas with resource commitments generally
in the amounts specified in the IRG Subgroup II Report
on Involvement.  ORP will pursue these efforts through
both FY 1980 and 1981, on the assumption that this level
of effort will continue until the recommended IRG
schedules are completed.

     To the extent possible, the Radiation Program will
support international efforts to harmonize radiation pro-
tection policies for environmentally sound nuclear

     Of equal importance are continued efforts to imple-
ment the Clean Air Act.  ORP will issue the first stan-
dards for CAA radioactive effluents in FY 1980, and the
Office of Enforcement will begin planning for enforcement
of these standards.

     EPA will continue to perform its Federal Guidance
functions as prescribed by the Atomic Energy Act.  Both
ORP and ORD will continue to study the prevalence of and
health effects caused by nonionizing radiation.  The
degree to which this role is pursued is the subject of a
separate paper for the Administrator's Analytical Agenda.
Precisely how EPA exercises this authority will affect
ORP's resource requirements.

     ORP will give second priority to operating the
Environmental Radiation Ambient Monitoring System (ERAMS),
and identifying potential hazards through a limited pro-
gram of special studies and assessment of emerging
technology.  Headquarters and Regional personnel will
review significant Federal actions as required under the
National Environmental Policy Act (NEPA).

     ORP will limit technical assistance to States to
localized problems which have wider ranging significance
and can be accommodated in the work schedules for higher
priority efforts.  These priorities may change, however,
if specific situations are found to pose significant

                          - 166  -
Research and Development

     Plans and Emphases

          o  Nonionizing Radiation (NIR)
                FY 1980 — Experimental animal research
                on the teratologic,  mutagenic, immuno-
                logic, behavioral,  and neurophysiologic
                effects of low power density,  chronic
                exposure to frequencies of environmental
                significance.   Investigations  of the
                mechanisms of  interaction of NIR with
                biological systems  using microwave
                spectroscopy,  experimental studies of
                effects of NIR and  amplitude-modulated
                NIR on membranes and isolated  systems.
                Initiate pilot epidemiological studies
                of selected populations.   Begin to
                develop a competence in thermoregulatory
                physiology and the  dosimetry of partial
                body resonance.

                FY 1981 — Thermal  physiology  research to
                determine the  biological correlates of
                localized heating in animals;  investiga-
                tions of the interspecies comparisons of
                thermoregulatory systems; computer
                modeling of human thermoregulatory
                systems.   Conduct experimental and theore-
                tical studies  of the interaction of NIR
                with biological  membranes, directed
                towards mechanisms  of interaction.
                Investigate amplitude-modulated NIR
                phenomena in whole  animal systems.  If
                warranted, conduct  full-scale  retro-
                spective epidemiologic studies and
                initiate pilot prospective studies.

                     - 167 -

     o  Ionizing Radiation

           FY 1980 — The ORD reimbursable program
           provides comprehensive off-site support
           to the Department of Energy programs at
           the Nevada Test Site (NTS) and other
           sites.  This support will include mobile
           and aerial radiological surveillance of
           each nuclear test and radiation monitor-
           ing of groundwater, animals, and other
           types of samples in and around NTS.
           A new emphasis for FY 1980 will be in
           the development of exposure and dose
           estimates for the population in the
           vicinity of NTS as a result of all pre-
           vious nuclear tests.   The quality
           assurance program provides radioactive
           reference standards and samples, the
           development of quality control guides,
           and on-site inspection and interlaboratory
           tests to determine the capability and per-
           formance of measurement systems and

           FY 1981 — The Agency will consider
           initiating a program of research for
           ionizing radiation.

Changes Anticipated

     o  Nonionizing Radiation (NIR)

        -  FY 1980 — An ORD Public Health Initiative
           in FY 1980 will provide $2.0 million and
           3 man-years to expand research on the
           mechanisms of interaction, to develop
           exposure systems for long-term experi-
           mental animal studies,  to begin epide-
           miological studies, and increase our
           knowledge of the ambient radiofrequency

           FY 1981 — None anticipated.

                     - 168 -
     o  Ionizing Radiation

        -  FY 1980 — Over the past two years the
           Off-site Program has been extensively
           reviewed up through OMB.  The present
           program is the minimum satisfactory
           product resulting from these reviews.
           No further changes are anticipated in
           this or the quality assurance program.

           FY 1981 — The Agency anticipates no
           changes at this time.  An Analytic
           Agenda Issue will consider a research
           program for ionizing radiation.  The
           Agency will also review again how the
           Off-site Program should be operated.
     o  Nonionizing Radiation (NIR)

        Elimination of this R&D program either out-
        right or through contracting out in toto
        would likely cost the Agency its expertise
        in nonionizing radiation health effects,
        an area of growing public concern.

     o  Ionizing Radiation

        There are three alternatives for the
        operation of the Off-site Program.  The
        first is that ORD continue to operate
        the program in its present mode.  The
        second alternative is for EPA to discon-
        tinue support to DOE's testing program.
        These two alternatives have been widely
        discussed previously, and they will
        necessarily be treated in the ranking
        process of Radiation Decision Units.
        The third alternative is for EPA to accept
        full responsibility for design, operation,
        and funding of the Off-site Program.

        The Agency has not conducted a research
        program for ionizing radiation since 1976.
        An Analytic Agenda Issue will examine the
        alternative of starting such a research
        program again.


                    ENERGY RESEARCH GUIDANCE


     The Energy/Environment research and development program
was initiated in FY 75 following the recommendations of two
OMB/CEQ task forces — one on pollution control technology
and the other on the environmental processes and effects of
energy pollutants.  These recommendations were based on a
desire to develop needed control technology and health and
effects data necessary to help avoid an irreconcilable conflict
between energy supply and environmental protection interests.
Such a conflict seemed likely since it appeared that the nation
would necessarily be relying more heavily on the "dirtier" fuels
such as coal and oil shale and less on the cleaner domestic
gaseous and liquid fuels.  This trend has been accelerated by
our national energy policy, which although only slowly evolving,
calls for a widespread conversion of utility and industrial
power facilities from scarce oil and gas to plentiful coal,
decreased fuel consumption, and in the longer term, the use
of technologies that are only now beginning to emerge for the
production of liquid and gaseous fuels from coal and oil shale.

     Projections indicate that total U.S. coal mining activities
will increase from today's annual production of 700 million tons
to nearly 1 billion tons by 1985 and will more than double by
the year 2000.  In 2000, conversion of existing utility and
industrial facilities from oil and gas to coal coupled with
construction of new conventional and advanced coal utilization
facilities will consume approximately 1.4 billion tons of coal
annually.  Although conventional combustion of coal will
predominate, by the year 2000 emerging coal-based technologies
are projected to consume 300 million tons of coal per year.

     These shifts in energy development and use pose potential
significant threats to human health in the next two decades.
Massive increases in coal and oil shale mining, off-shore
oil and gas prodution, and uranium extraction are all projected
by the year 2000.  Intensified mining activity will create
erosion problems and generate runoff which can contaminate
surface waters.  Aquifers may also be polluted as a result
of leachate or drainage from the mines themselves, or from
the improper disposal of mining wastes.  Increased use of
coal by utilities, industries, and new technologies will
produce more air pollution and solid waste residue than are
currently produced.  The pollutants expected to increase
are; nitrogen and sulfur oxides, ashes, and sludges.  Because
of the way they are formed, pollutants emitted from new
technologies can be varied and complex and may prove to be
even more harmful to human health than those emitted from
cui'rent technologies.

                         - 172 -

     To address the environmental threat associated with
energy and industrial pollution EPA's enabling legislation
has been toughened with the aim of tightening effluent and
emission limitations.  The Clean Air Amendments of 1977,
the Resource Conservation Recovery Act and the Federal
Water Pollution Control Act Amendments will require improved
control of emissions, effluents and solid residuals,,

    • The trend toward increased reliance on coal and other
potentially damaging fuels and technologies can only occur
without massive environmental impact if the necessary data
base is available to quantify effects and if affordable
control technology can be applied in a timeframe consistent
with technology utilization.

     The following discusses major priorities of the FY 80-81
program in the control technology and effects programs.


     EPA's energy control technology program has the overall
goal of providing information of the types and quantities of
pollutants released by current and emerging energy supply
activities and where necessary, to develop control options.
The following delineates major research priorities in the
FY 80-81 tiraeframe for the six control technology subpro-
grams: flue gas sulfur control, nitrogen oxide control,
particulate control, environmental impacts of conventional
and advanced energy systems,  fuel extraction and fuel

Flue Gas Sulfur Control

     This program includes sulfur oxide pollution control
research and development relating to electric utility and
industrial power generation.   Technology improvement is
important since EPA regulations are expected to require
from $2-4 billion in annual expenditures on relatively
immature SOX removal technology in the 1990's.  Major
efforts are directed towards flue gas desulfurization
(FGD)  technology development and assessment; assessment of
the capital and operating costs of FGD systems; research
and development directed towards increasing FGD system
reliability, reducing sulfur oxide emission levels and
reducing capital and operating costs.  Special attention
should be paid on transferring information to the public

                          -  173-

     o    Research Priorities  (Air)

          1.  Continue to issue quarterly updates of the
              performance and status of existing FGD
              systems for new FGD installations in the
              U.S., Japan and Europe.  Also continue
              technology transfer program via symposia,
              data books and seminars.

          2.  Document the full scale evaluation of the
              adipic acid modified limestone FGD process
              evaluation.  Special attention will be given
              to the economic impacts of this process
              modification and any secondary operational or
              environmental factors.  Preliminary testing
              indicates such an approach offers potential
              of greater than 95% SOX control capability
              at costs lower than current technology.

          3.  Complete the duel alkali evaluation program at
              Louisville Gas and Electric.  The final report
              will provide an evaluation of performance and
              economic factors; this technology offers
              potential for cost and reliability advantages
              over commercial lime and limestone FGD systems.

          4.  Complete the preliminary evaluation of dry
              sulfur oxide control processes.  Such processes
              offer the promise of low cost energy-efficient
              alternatives to commercial FGD systems,
              particularly for low to moderate sulfur coals.

Nitrogen Oxide Control

     This program includes research and development relating
to nitrogen oxide control from electric utility boilers,
industrial boilers, process furnaces, and other stationary
sources.  Successful conduct of such a program is important
since NOX emissions from stationary sources are projected
to increase at an alarming rate over the next two decades.
This is primarily due to the projected increased combustion
of coal and the current absence of cost effective NOX control

     o    Research Priorities  (Air)
          1.  Document the status of NOX control for utility
              and industrial boilers to support the 1982/1983
              review of the Standard of Performance for NOX,
              as required by the Clean Air Act Amendments of

                         - 174  -

          2.  Demonstrate the low NOX coal burner on two
              industrial boilers and a utility boiler.
              The program goal is an emission rate of 0.2
              pounds of NOX per million BTU in a timeframe
              compatible with possible revised NSPS in
              the 1982/1983 timeframe.

          3.  Evaluate dry NOX control technology for
              Stationary, high efficiency gas turbines
              to support the Congressionally-mandated
              review of the New Source Performance
              Standard for Gas Turbines.

          4.  Demonstrate combustion modification concepts
              to simultaneously reduce NOX and particulate
              emissions from stationary internal combustion

          5.  Conduct assessment and applications testing of
              combustion modification technology for stoker
              coal-fired commercial and industrial boilers.

          6.  Continue bench-scale research and assistance
              to California on the technical and economic
              factors relating to flue gas treatment for
              NOX and simultaneous NOX/SOX control.  Such
              processes offer the potential of greater than
              90% NOX control albeit at substantial costs.

Particulate Control

     The overall objective is to assess, improve and develop
technological methods for the control of all forms of man-made
(and induced) particulate matter; especially those controls
effective at minimizing emissions of inhalable size particu-

     o    Research Priorities (Air)
              Characterize inhalable particulate matter
              emissions from important energy and industrial
              sources.  Such information will be required to
              allow selection of the appropriate control
              technology to achieve a possible ambient
              inhalable particulate matter (fine) particulate
              standard.  Such a revised ambient standard is
              under active evaluation by EPA.

                        - 175 -

          2.  Evaluate the sources and controls for urban
              fugitive dusts.  Such sources are major
              contributors to total suspended particulates
              in certain urban locations.

          3.  Review the industrial and utility boiler
              particulate control technology adequacy in
              order to help the Air Program Office evaluate
              the appropriateness of revising the NSPS in
              1982/1983 timeframe.

          4.  Complete evaluation of a full scale baghouse
              on low sulfur coal utility boilers, and continue
              assessment of electrostatic  enhancement of
              fabric filtration for baghouse applications.
              Baghouses represent the most cost-effective
              control alternative for stringent particulate
              emission limitations particularly for low
              sulfur coal applications where ESPs are costly.

          5.  Complete the initial evaluation of after-treat-
              ment particulate trapping devices for mobile
              source diesel emission control, and assess the
              prospect of their use to support an emission
              standard for autos and trucks.

          6.  Continue assessment and development of flue gas
              conditioning additives and the engineering
              evaluation of a 30,000 SCFM electrostatic
              precipitator (ESP) precharger for enhanced
              particulate control.  Subsequently, perform
              evaluation of control enhancement options for
              low sulfur coal boilers with low performance

          7.  Continue evaluation of optimized  (S0x-Particu-
              lates) mini-plant wet scrubber with the
              objective of achieving the proposed 1979
              Utility NSPS for particulates and SOX with
              a single low-cost control device.

Environmental Impact of Conventional and Advanced
 Energy Systems

     The program includes the following four subprograms:

     o    Conventional combustion environmental assessments;
          define environmental impacts of unregulated
          pollutants from utility, industrial,  commercial
          and residential sources.

               -  176  -

Waste and water:  define the impact and where
required evaluate/develop controls for the solid
waste and water residuals associated with coal
and oil combustion sources.

Conservation and advanced energy systems:
environmentally assess wastes-as-fuel, geothermal,
solar and other emerging non-fossil fuel energy

Integrated technology assessments: identify
environmentally,  socially and economically
acceptable alternatives for meeting national
energy objectives.

Research Priorities


     1.  Define the environmental impact of POMs,
         heavy metals and direct sulfate emissions
         from selected coal and oil combustion

     2.  Complete combustion source chemical and
         bioassay studies for utility and industrial
         coal and oil sources, aimed at comprehen-
         sive screening for unregulated air

     3.  Define the environmental impact of
         increased wood burning in industrial,
         commercial and residential sources.

     4.  Define the air impact and evaluate control
         of commercial and near-commercial waste
         (municipal refuse) - as-fuel systems.

     5.  Define air impact and evaluate controls
         for geothermal energy systems.
         Continue regulatory support efforts to
         provide characterization data and control
         technology information for the promulgation
         and implementation of effluent guidelines
         for the electric utility industry.

          - 177 -

2.  Complete comprehensive combustion source
    chemical and bioassay studies for utility
    and industrial coal and oil sources aimed
    at comprehensive screening for water

3.  Continue limited assessment and control
    technology evaluation for waste-as-fuel
    and geothermal water pollution problems.

Solid Waste

1.  Complete regulatory support program to
    obtain sufficient data and information to
    enable promulgation of guidelines or
    regulations under RCRA for the storage,
    treatment and disposal of coal ash and
    scrubber waste from coal-fired electric

2.  Evaluate second generation ash and scrubber
    waste disposal approaches with the aim of
    identifying more affordable and effective


1.  Perform congressional-mandated analysis of
    the Federal energy/environmental and con-
    servation programs; present annual findings
    to the Congress.

2.  Extend coal technology, electric utility,
    coal development and oil shale development,
    integrated technology assessments (ITAs)
    to evaluate impacts of energy conversion
    technologies and development strategies
    on residuals disposal, toxic and trace
    elements levels and water use.

3.  Extend the regional ITA of the Ohio River
    Basin and Appalachia to identify energy-
    development policy options for local,
    state and regional governments.

                          - 178  -

Fuel Processing, Preparation and Advanced Combustion

     The program includes  the characterization of effluents
and emissions, assessment  of related environmental impacts,
and development and evaluation of necessary pollution control
technology for various emerging coal, oil shale and biomass
fuel processes.  The results of this effort are used as input
on the Agency's standard setting process.  Fuel processes
assessed include:  (1) coal cleaning, (2) fluidized bed
combustion, and  (3) synthetic fuels generation from coal,
biomass and oil shale.

     o    Research Priorities (Multi-Media)

          1.  Continue improving methods for sampling,
              analysis and continuous monitoring of air,
              water and solid waste effluents/residuals to
              quantify total organics,  characterize toxics
              and determine inorganic compounds for coal
              processing technologies .

          2.  Update multi-media pollution control guidance
              document and environmental assessment report
              (EAR) for first generation above ground and
              in-situ oil  shale processes.

          3.  Prepare multi-media pollution control guidance
              document and environmental assessment reports
              for low/high BTU coal gasification, coal
              liquefaction and fluidized bed combustion

          4.  Evaluate air, water and solid waste environ-
              mental problems and controls for coal
              preparation  (cleaning) plants.

          5.  Evaluate environmental problems and controls
              for first generation biomass energy systems.


     The general objective of the extraction research program
is to assess, develop, identify, and verify control technology
for solid fuel,  oil and gas extraction  which will assure that
the recovery of the nation's fuel reserves is conducted in an
environmentally acceptable manner.  To  this end, equipment,
methods, and technology are assessed and developed to prevent,
control, and abate the discharge of environmental pollutants
from both point and non-point sources.   Pollution sources
include facilities for exploration, production, storage, and
transportation of coal, uranium, oil shale, oil, and gas.
Both normal operations and accidental spills are examined.

               - 179 -

Research Priorities


     1.  Characterize fugitive particulates by size
         and chemical composition in extractive

     2.  Relate ambient particulates to sources.

     3.  Conduct fate and effect studies related for
         extractive processes.

     4.  Evaluate fugitive process particulate

     5.  Evaluate the role of natural hydrocarbons
         on 63 and aerosol problems.


     1.  Evaluate the effects of Western coal and
         oil shale extraction on surface and ground-
         water quality.

     2.  Develop water quality monitoring network in
         Western energy development areas.

     3.  Determine the best management practices for
         surface mine sediment control.

     4.  Develop techniques for removal of toxic
         materials from mine drainage.

     5.  Identify the best available technology for
         the treatability of effluents.

     Solid Waste

     1.  Determine adverse effects of solid waste
         from mining.

     2.  Determine the best management practices
         for solid waste from mining.

     3.  Assess methods for mining waste reduction,
         recovery and reuse.

                          -  180  -

     The major thrust of the second five year effort should be
to respond to specific EPA and other agency research require-
ments.  This trust will strengthen the utility and effective-
ness of the program.  The second five year effort should be
closely coordinated with the base research programs both in
EPA and the other agencies.

     During the course of the Interagency Steering Committee
Meetings helping to plan the FY 80-85 program, the non-EPA
members have voiced concern that appropriate sensitivity to
the interagency character of the program be recognized during
EPA's ZBB process.  They remind us of their feelings that EPA's
ZBB process may not adequately reflect the priorities and
needs of other agencies participating in the program.  The
research program should be sensitive to these concerns.

     The following are the research objectives of the programs
identified by the four major subdivisions: Ecological Fate and
Effects, Air Transport and Fate, Monitoring and Instrumentation,
and Health Effects.

Ecological Fate and Effects - Research Priorities


          1.  Development and validation of quick and
              economical methodologies to test the biological
              effects of toxic energy-related chemicals in
              support of TOSCA's requirements to regulate
              hazardous chemical substances and mixtures.
              Evaluate the effects of energy-related air
              pollutants on aquatic and terrestrial ecosystems
              and their components in support of the Clean Air
              Act requirements to prevent the significant
              deterioration of air quality and the development
              of national ambient air quality standards.
              Identify techniques to prevent adverse environ-
              mental effects from coal mining operations in
              support of the permanent regulation of the
              Office of Surface Mining (DOI) and the develop-
              ment of best management practices in support of
              EPA's national water standards for the coal
              mining industry.

                          -  181

          2.  Assess the  impact ot energy-related consent
              decree pollutants on various ecosystems in
              support of  EPA's development of the water
              quality criteria documents.

          3.  Evaluate the effects of offshore oil and gas
              exploration and extraction of marine environments
              in support  of EPA's requirements pertaining to
              the National Pollutant Discharge Elimination
              System permit program.

Air Transport and Fate^ -  Research Priorities


          1.  Development of complex terrain air pollution
              dispersion  models to support the Agency's
              efforts to  establish environmental standards
              based on sound scientific information and to
              develop and evaluate abatement programs.

          2.  Development of regional (long-range) transport
              and dispersion model to support Agency efforts
              to understand the atmospheric transformation
              and impact  on visibility of pollutants origina-
              ting from energy sources and to develop
              standards and abatement strategies.

          3.  Fine particulates - studies to characterize
              their formation, transport and affect visibility.
              Caitput to support Agency fine particulate stand-
              ard development.

          4.  Pollutant, behavior studies - chemical and
              physical atmospheric processes, fi^Id and chamber
              studies.  Output information for use in model
              development.  This includes studies of scrubbed
              and unscrubbed pluiaos and of nucleation and
              cloud phenomena.

Monitoring and Instrumentation - Research Priorities


          1.  MAS - Master Analytical Scheme.  Continuation of
              development of this comprehensive and ultra-
              sensitive GC/MS system for analysis of complex
              organic molecules.  The computerized detection
              module of this sytein has a library of 50,000
              fingerprints of the organic species most likely

                    - 182  -
         to be found in environmental samples, including
         many that are toxic or carcinogenic.  This
         powerful tool will be used by the Agency in
         pseudo mass-balance studies to identify the
         major sources of particular toxic substances
         to assure that regulatory initiatives are
         realistic and effective.
     1.  Visibility monitoring in Federal Class I areas
         in support of Agency efforts to implement Clean
         Air Act mandates for prevention of significant

     2.  Acid precipitation and dry deposition monitoring
         in support of Agency efforts to identify the
         ecological and economic impacts of acid

     3.  Fine Particulates - development of methodology
         for monitoring the organic and nitrate fractions
         in support of the Agency's efforts to understand
         atmospheric transport and transformation of these
         pollutants.  The monitoring methodology also
         supports agency efforts to devise and evaluate
         abatement strategies.

     4.  Air quality baseline documentation for the
         western area where intense energy development
         activity is projected to occur by 1985 -
         summaries and analysis of data obtained during
         the first five years.  This data will enable the
         Agency to see and prove the environmental impacts
         of energy developments.
     1.  Development and implementation of a nationwide
         anticipatory monitoring program for toxic
         pollutants from energy developments (AMTES:
         Anticipatory Monitoring for Toxics from Energy
         Sources).   The monitoring system will be used
         to devise and evaluate abatement strategies
         and to raise alarm flags to avert potential

                         -  183  -

              Development of advanced monitoring systems and
              strategies for particular field applications
              related to new energy developments, e.g., OCS
              drilling platforms, in-situ retorting.  Thess
              monitoring systems will support the NPDES
     Water Supply
          1.  Basin studies in the western energy development
              areas to establish baseline hydrological and
              chemical groundwater data in order to predict
              impacts on groundwater of energy developments.
              Energy developments threaten both the quality
              and quantity of water supplies in the semi-arid
              regions of the West which accelerated development
              of vast energy resources is occurring.


          1.  Multi-media development of monitoring and
              instrumentation technology for energy source
              monitoring and ambient monitoring for pollutants
              from energy sources in support of Agency enforce-
              ment activities and Agency efforts to evaluate
              abatement programs.

          2.  Multi-media development of pollutant measurement
              methodology in support of health effects,
              ecological effects and transport, transformation
              and fate studies of pollutants from energy
              sources.  These studies support the Agency's
              efforts to establish environmental standards
              based on sound scientific information and to
              develop and evaluate workable and effective
              abatement strategies.

Health Effects - Research Priorities
              Development of techniques to identify manufactured
              agents/mixtures that can produce adverse effects
              on human health.

                     - 184  -
         Development of a data base to assist in
         determining the impact on humans of specific
         manufactured energy-related chemicals (and
         mixtures) for specific biological endpoints
         (birth defects, cancer, mutagenic effects).
         These techniques/data are needed to provide
         EPA support to the Toxic Substances Control
         Act of 1976
         Development of a data base to assist, EPA in
         establishing energy-related National Ambient
         Air Standards.  This data base enables the
         development of reliable estimates of human
         health damage functions for various population
         groups through a balanced program in animal
         toxicology, epidemiology and clinical studies.
     1.  Development of techniques to identify waterborne
         agents/mixtures that can produce adverse effects
         on human health.

     2.  Development of a data base to assist in deter-
         mining the impact of humans of energy-related
         waterborne effluents (individual agents and
         mixtures) for specific biological endpoints
         (cancer, cardiovascular disease).
Solid Waste
     1.  Development of techniques for identification of
         energy-related hazardous wastes that can produce
         adverse effects on human health.




     The past years have seen the development of a growing
recognition that the Agency must improve its exploratory
research capabilities in parallel with integrating its
research and regulatory functions.  Likewise, the development
of the regulatory decision process has come to require that
the risks, benefits and costs of EPA's regulatory decisions
be documented with improved methodologies and data.  In
response to these developments ORD established its Anticipatory
Research program as a cornerstone in the development of a
long range research program and proposed the establishment
of an Office of Health and Environmental Assessment.  During
this same period of time, operational components of the
Agency have recognized that segmented state grant mechanisms
did not always encourage innovative multimedia management
approaches for dealing with health and environmental problems.
The Agency accordingly proposed the integrated Environmental
Assistance Act of 1979 to assure that alternative ways to
foster and support a total grant delivery approach.  Finally,
an ongoing agency activity most representative of the inte-
grative approach needed to examine environmental problems,
is the environmental impact statement.  Total NEPA compliance
and 309 Review activities relating to all media categories
are the overview responsibility of the Office of Federal


     o    Develop an integrated exploratory research program
          within ORD.

     o    Fully implement a health and ecological assessment
          capability within ORD to serve program office

     o    Coordinate environmental training programs throughout
          the EPA by the National Workforce Development

     o    Integrate new Council on Environmental Quality
          regulations, Endangered Species Act regulations,
          Historic Preservation regulations and the Executive
          Orders on Floodplain Management and Wetlands
          Protection in all NEPA programs.

               - 188 -

Implement the Integrated Environmental Assistance
Act emphasizing simple administration, enhanced
state program integration and flexibility and
incentives for good performance.

Develop and publish a set of Environmental Profiles.

                             - 189 -



Development of an Exploratory Re seajrc h Capability

     We have made important progress in the past year in
starting the process of building an exploratory research
capability.  Within the Anticipatory Research Program initi-
ation of the Center Support Program provides us with the
beginning of a long term research program in critical areas
to serve as a foundation for our applied research in support
of regulations .  It will become an increasingly important
link to the best institutions in the academic community in
the future.  Internally, the Innovative Research Program is
providing new opportunities for our own scientists to surface
basic research proposals and unique ideas.  Finally,, more
mature; multidisciplinary programs aimed at assessing antici-
pated problems have begun to focus on areas like.ly to be of
growing future concern.

     Since these advances provide the underpinnings to our
ability to ultimately get ahead of our future problems, we
must be careful of their design and assure that the best
scientific talent of the country participates in their
development.  Moreover f our efforts to identify new prob-
lems must also take advantage of the government wide re-
sources devoted to similar undertakings in offices such as
the Office of Technology Assessment, National Science Founda-
tion and Congressional Research Service.  We must articulate
our research interests to the scientific community with
increasing clarity and assure through greater competition
that the best scientific proposals are awarded.  Finally,
there remains the task of assui ing that exploratory research
conducted within all media is integrated into a compre-
hensive effort.   This task must focus on identifying exploratory
research across all areas and assuring that those problem
areas in need of fundamental research are adequately supported.

     °    Plans and Priorities ™FY 80
               Provide increased competition and improved
               peer review of EPA grant programs.

               Implement Center Support activities initiated
               in FY 79 and establish four (4) new centers
               for long-term research,

               Expand Innovative Research activities pro-
               viding for increased ORD participation by
               Laboratory and extramural scientists.

               Integrate Acid Rain and Cancer Program research
               programs .

                          ...  19Q  -

      o    Plans  and  Priorities  -  FY  81

                Integrate  long range  research conducted
                through  the  Public Health Initiative:, Antici-
               patory Research  and Base Programs  into explora-
                tory  research program,,

 Implementation of  a  Health  and  Ecological Assessment Capability

      The  scientific  assessment  program is made up of two
 distinct  but  interrelated operations: a criteria  and assess-
 ment  development activity;  and  a  special assessment, activity
 on  risk and exposure.   In FY-79 OHEA (Office of Health and
 Environmental Assessment) was proposed to institutionalize
 both  the  existing  Cancer Assessment  Group and Environmental
 Criteria  and Assessment Office  scientific assessment pro-
 grams  and the new  1979  initiatives (ECAO-CIN, Reproductive
 Effects Risk Assessment,  Exposure Assessment).  FY 1979 was
 a start-up year  for  the new programs with the ECAO-CIN
 developing proposed  water quality criteria for the 65
 Consent Decree Chemicals, the Reproductive Risk Assessment
 Group  developing guidelines for Agency wide adoption and the
 Exposure  Assessment  Group initiating methodology devel-

     The  entire scientific assessment program is Program
 Office oriented  in its outputs.  The needs are articulated
 by  the others and  converted into work plan priorities.

     FY 1981 should  see a strengthening of the Agency's
 capability to develop health related assessments  in a uniform
 and consistent manner.  The quality  control afforded by OHEA
 either through the ECAO programs or  the special risk groups
 assessment will be apparent.  The capability for exposure
 assessments, and estimating tota". body burdens etc. will
 likely be  much improved on an Agency wide basis as we approach
 the end of FY-80 and look into 1981.  For planning purposes
 OHEA expects to receive more requests for assistance from
 the program offices  in the development of assessments.
 Moreover,  as we approach FY 1981, ORD anticipates that
 effects other than carcinogenic and  reproductive impairment
 will be emerging for regulatory analysis.  Pulmonary, neuro-
 logical,  and cardiovascular effects  are likely candidate
 areas.  The establishment of a special assessment group for
 these health areas appears appropriate as a final step in
 the development of this capability.  OHEA functional state-
ments provide for this event*

                          -  191  •-

     o    Plans and Piorities - FY 80

               Fully implement a scientific assessment
               capability in the. area of Carcinogenesis and
               Reproductive Risk Assessments.

               Fully implement a scientific assessment
               capability to conduct Exposure Assessments.

     o    Plans and Priorities - __F_Y_8_0

          -    Expand scientific assessment capability to
               include pulmonary, neurological and cardi-
               ovascular effects.


     In the next two years the Office of Research and
Development will take steps in four broad areas:  (1) move
more education, employment, and training on environmental
subjects into the self-supported systems; (2) coordinate the
full range of training in the Agency - including enforcement
related training; (3) expand the use of workforce planning
tools in Integrated Environmental Assistance and State-EPA
Agreements; and (4) determine the shortages likely to occur
in highly specialized environmental occupations.

     o    Plans and Priorities -•_ FY 80

          -    Expansion of the Senior Environmental Employ-
               ment Program to all 50 States by 1980.

          -    Establishment of a strong Co-op Education
               Program for State and local environmental

          -    Publication of a guide to extra- .gency

          -    Preparation of composite training plans
               across program lines, e.g., hazardous waste
               dumps; hazardous spills, enforcement.

          -    Identify with the regions non-compliance
               situations related to human resource deficiencies
               and promote with the regions education and
               training on topics such as I/M, hazardous
               waste management, land application of waste
               water, and waste treatment, plant operations.

     o    Plans and Priorities^^FY 81

          -    Continue FY 80 initiatives.