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                   Challenges:

              An EPA
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ENVIRONMENTAL
PROGRESS
AND CHALLENGES
AN EPA PERSPECTIVE
United States Environmental Protection Agency
William D. Ruckelshaus
Administrator

Alvin L. Aim
Deputy Administrator

Milton Russell
Assistant Administrator for Policy, Planning, and Evaluation

Josephine S. Cooper
Assistant Administrator for External Affairs

Ronald Brand
Director, Office of Management Systems and Evaluation
June 1984

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                            DEDICATION TO DR. TIMOTHY A. MATZKE


                All of us in the Environmental Protection Agency (EPA) owe an immeasurable
         debt of gratitude to Dr. Timothy A. Matzke. In addition to contributing to this report,
         Tim provided leadership in strengthening the Nation's environmental monitoring pro-
         grams until his untimely death on August 24, 1984.  Throughout his decade—long
         career with EPA, Tim's vision and dedication were instrumental in improving our
         ability to meet the environmental challenges described in this report.  As a small
         token of our esteem, we dedicate this report to his memory.
ACKNOWLEDGEMENTS
This report was prepared by the Environmental Results Branch of the
Management Systems Division, Office of Management Systems and
Evaluation of the Office of Policy, Planning, and Evaluation, U.S.
Environmental Protection Agency, under the leadership of Lewis S W.
Crampton, Director, OMSE, Cynthia C  Kelly, Director, Management
Systems Division; and Sherron L. Hiemstra, Chief, Environmental Results
Branch.

Within the Environmental Results Branch, many persons contributed
their time, energy, and support to developing the report. We would
particularly like to recognize the following individuals.
  Robert W. Barles, Project Manager;
  Charles A. Parker, John W. Wilson, William V. Garetz, and Michael T
Grepo, who researched and wrote major sections of the report;
  Sandra D. Oden, Charles E. Roark, Geraldine Schweitzer, and Deloise
Brooks, who typed and distributed many drafts and revisions of the
material within extremely short time frames;
  Constance L. Tasker and David F. Hamnett, who edited the report
and researched and wrote many of the highlights in the report.

Many persons outside the Office of Management Systems and Evaluation
also made very important contributions to the report. Although it would
be impossible to fully acknowledge all those individuals and their
contributions, some of the persons who deserve special thanks are:
  Donald Bliss of EPA Region 10, who spent weeks in Washington editing
numerous drafts of the report and significantly improving it in the process,
  Diane Smimow, who was the graphic designer,
  Dave Berg, Greg Dana, Greg Glahn, Bill Hunt, and Fred Renner, who
reviewed and contributed to the Air section of the report;
  FredLeutner, BobLinett, Marian Mlay, Sally Neuber, Steven
Schatzow, Suzanne Schwartz, and Rita Smith, who reviewed and
contributed to the Water section of the report;
  Bonnie Casper and Dana Rodgers, who reviewed and contributed to the
Land section of the report;
  Norm Chlosta, Bob Janney, Casey Jason, Walt Kovalick, and Marylouise
Uhlig who reviewed and contributed to the Toxic Chemicals section of
the report;
  Paul Ciriello, Jim Finger, Dave Hill, and Bill Sanders, who provided many
of the highlights used in the report as well as serving as very active and
diligent members of the Advisory committee;
  Amy Marasco, Clem Rastatter, and Claire Gesalman, of the Synectics
Group (TSG), who helped develop the concept of the report;
  Robert Flanagan, who provided typesetting for the text and Litho
Composition Services, Inc., who typeset the charts and graphics;
  Steve Delaney, Joe Sabbagh, M.E. Warren and the U.S. National
Archives who provided the photography;
  Angela Bradley, who assisted with the graphic production, Marilyn
Kaufman, who illustrated some of the graphics, and Bobbi Tull, who did
the cover illustration.

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•••^^^^^^••••••^^^^^^^•••••••^•^•^^^^^^^^^^^•^^^^^B
 CONTENTS
  1  Preface

  3  ADMINISTRATOR'S OVERVIEW
 11
 12  An Overview
 18  Ozone
 22  Airborne Particulates
 24  Carbon Monoxide
 26  Sulfur Dioxide
 28  Airborne Lead
 30  Airborne Toxics
 34  Acid Deposition


 41  WATER
 42  An Overview
 48  Ground-Water Protection
 52  Toxics Pollution
 56  Drinking Water
 60  Wetlands
 62  Pollution from Sewage
 66  Nonpoint Source Pollution
 71  LAND
 72  An Overview
 78  Uncontrolled Hazardous Site Cleanup
 82  Newly Generated Hazardous Waste Control
 86  Radioactive Waste Disposal
 88  Municipal Sludge
 93  TOXIC CHEMICALS
 94  An Overview
102  Pesticides
108  Dioxin
110  Asbestos
114  PCBs (Polychlorinated Biphenyls)

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PREFACE
 This report presents the
 Environmental Protection
 Agency's (EPA's) assessment of
 the progress we have made as a
 Nation in improving the qual-
 ity of the air we breathe, the
 water we depend on, and the
 land where we live. More im-
 portantly, it presents EPA's
 agenda for restoring and pro-
 tecting these resources from
 past and future environmental
 hazards.
    In large part, this report is
 based on "Environmental
 Management Reports" (EMRs)
 prepared for the first time last
 year by each of EPA's ten
 Regional offices. Drawing from
 the EMRs, the report presents
 the progress we have made
 and problems that remain in
 each environmental
medium—air, water, and
land—and for controlling the
risks of pesticides and toxic
substances. In addition, we
have selected 22 issues for
more detailed discussion.
    Virtually every office in
EPA contributed to this re-
port. Prepared by the Office of
Management Systems and
Evaluation, drafts have been
extensively reviewed by mem-
bers of an Advisory Review
Panel and contacts throughout
EPA Headquarters and Region-
al offices. We gratefully
appreciate the valuable con-
tributions that our colleagues
throughout EPA have made in
formulating and critiquing
this report. In particular, we
want to acknowledge the ex-
traordinary work of EPA Re-
gional staff who produced the
Environmental Management
Reports. The EMRs have not
only made a national environ-
mental report possible but
have provided a unique basis
for managing our programs to
achieve the greatest environ-
mental benefits in years
ahead.

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ADMINISTRATOR'S
OVERVIEW
 When I became the first Ad-
 ministrator of the Environ-
 mental Protection Agency in
 1970, the Nation was suf-
 fering from many years of en-
 vironmental neglect. We not
 only read about it and saw its
 effects reported on television
 but experienced it personally
 in our daily lives.
    Although cities, States,
 and the Federal Government
 were attempting to halt the
 spread of pollution and to pro-
 tect public health,  their efforts
 were having limited success.
 Raw sewage and industrial
 waste were being discharged
 into our waters, forcing many
 rivers, lakes, and beaches to
 be closed to swimming and
 boating and to be unusable as
 sources of drinking water.
 Some waters were  so fouled
 that they occasionally caught
 fire. Warnings  not  to eat fish
 caught in certain waters were
 common, and some fish pop-
 ulations were disappearing
 completely.
    Air pollution from cars
 and industries  was also  an in-
 creasingly serious problem.
 The elderly, children, and
 others vulnerable to air pollu-
 tion were regularly cautioned
 not to venture outdoors on
 certain days, and some per-
 sons were even hospitalized.
 Many cities were blanketed in
 smoke and fumes that blocked
 the sky, caused eye irritation,
 and smelled so offensive that
 complaints were commonplace.
   Finally, the land was
being used indiscriminately as
a dumping ground for the
wastes of our growing in-
dustrial and technological
society.
   The major force that
brought a halt to this de-
structive spiral was  public
awareness and concern. That
concern brought about a grass
roots movement to clean up
the environment that culmin-
ated in an "Earth Day"
demonstration in April 1970 in
which thousands of people
called for national action to
control the pollution.
   There were immediate
and strong responses to this
call for action. The President
established the Environmental
Protection Agency to strength-
en the Federal response to
pollution. The Congress
passed the great environmen-
tal legislation of the 1970's.
That legislation enhanced ex-
isting programs and created
tough new laws that coordi-
nated local, State, and Federal
environmental programs.

ENVIRONMENTAL
PROGRESS
It has been ten years since I
left EPA. Over these ten years
the Agency has accumulated
the knowledge and experience
that allows us to look back
and assess how well the en-
vironmental laws have
worked and how effective the
concerted action of EPA,
State, and local governments
have been.
    It is particularly impor-
tant to make that assessment
now, as the Congress is con-
sidering how to reauthorize
much of the environmental
legislation that guides us. To
hilly appreciate this legisla-
tion and its effects,  consider
where we would have been
without it.
    Our experience with en-
vironmental cleanup over the
past 13 years illustrates that

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economic growth and environ-
mental protection can coexist.
Since 1970 our population has
grown by over 13 percent, our
economy by over 40 percent.
With such development came
expanded industrial de-
velopment and urban growth
that, if left unregulated, could
have greatly accelerated the
deterioration of environmental
quality. Our manufacturing
sector expanded by 36 percent,
growth that might easily have
spelled disaster for the Na-
tion's waterways  and air quali-
ty. Higher prices for oil and
gas meant greater reliance on
coal, a less "clean" fuel. The
number of motor vehicles on
the Nation's highways in-
creased by 44 percent.
    Notwithstanding all this
growth, environmental actions
taken during the  1970's have
resulted in tremendous prog-
ress. The great majority of in-
dustries across the country
have installed the equipment
necessary to control their
pollution. Cities have spent
substantial sums  of money for
safe treatment and disposal of
their sewage and other waste.
These and other efforts have
resulted in visible environ-
mental progress. For example:
• In the late 1960's, Lake Erie
was one of the most tragic
cases of pollution in the Na-
tion. Large blankets of green
slime lined its shores, with
fishing populations impaired
and many beaches closed out
of concern for public health.
Today Lake Erie's beaches are
open for swimming, and sport
fishermen caught three mil-
lion walleyed pike last year.

• Many major metropolitan
areas, including New York,
Philadelphia, Detroit,  Chicago,
and Los Angeles, have signifi-
cantly improved the quality of
their air by controlling emis-
sion of air pollutants from in-
dustrial and municipal sources
and by requiring adequate
maintenance of cars, trucks,
and buses.

• In the early 1970's,  residues
of numerous pesticides, herbi-
cides, and toxic substances
were beginning to be detected
in surface waters and wells
across the Nation, as well as
in the tissue of fish  and other
wildlife, and were thought to
be responsible for the  abrupt
decline of a number of species
of fish and wildlife.  Since that
time, numerous substances
have been banned, or their use
has been restricted.  Standards
for  allowable limits  have been
established for many others.
    These accomplishments
have been achieved  without a
loss in public support. A sur-
vey conducted in 1980 by Re-
sources for the Future drama-
tically illustrated the contin-
ued strong public interest in
and support of the environ-
mental movement. Among
the findings of the poll were
that:

• Nearly three-quarters of all
Americans consider them-
selves to be environmentalists
at least to some degree, and
42 percent think that "pro-
tecting the environment is so
important that requirements
and standards cannot be too
high, and continuing im-
provement must be made
regardless  of cost."
• Americans generally are not
in favor of protecting the en-
vironment at the expense of
an adequate energy supply,
but ... "forced to make a
choice a strong majority of
people will choose environ-
mental quality over [eco-
nomic] growth."

• Sixty-four percent of those
polled said they were con-
cerned "a great deal" about
the disposal of hazardous in-
dustrial chemical wastes,
while only nine percent said
they were concerned "not
much" or "not  at all."

• Seventy-three percent felt
that endangered species must
be protected, even at the ex-
pense of commercial activity,

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 and 65 percent said marshes
 and swamps should be pre-
 served in their natural state,
 instead of being drained for
 development.

     The strength of the Amer-
 ican people's commitment to
 environmental quality is
 underscored by this and other,
 even more recent, survey find-
 ings that  support does not
 vary among people with dif-
 ferent backgrounds, jobs,
 education or income.  Support
 for protecting our environ-
 ment is a fact of life.

 THE CHALLENGES AHEAD
 The environmental victories
 of the seventies notwithstand-
 ing, continued progress will be
 much more difficult. The en-
 vironmental challenges of the
 1980's are much more com-
 plex than the ones we tried to
 address in the 1970's,  and
 they will  not yield quickly  to
 our efforts. As the science and
 administration of environmen-
 tal protection have  become
 more sophisticated, we have
 learned of many subtle and
 potentially more dangerous
 threats to public health and
 the ecology. These stem from
 environmental contamination
 from minute concentrations of
 thousands of man-made chem-
 icals found ubiquitously in
 our technological society.
 Such contamination by these
 "toxic" chemicals presents
 health and other risks about
 which we still have only lim-
 ited knowledge. Indeed, our
present knowledge is such
 that we may exaggerate the
 risks in some cases while in
 others be unaware of them.
     These challenges are even
 more difficult because we are
 now aware of how interrelated
 pollution is and of how some
 actions to eliminate pollution
 merely transfer it from one
 place to another.
    In setting out to find solu-
 tions to the environmental
 issues of the eighties and
 nineties, we start with a
 healthy appreciation of the
 difficulties involved. Finding
 the evidence of contamina-
 tion, assessing the threat,
 correcting the damage, setting
 up preventive  measures, and
 paying the price of
 protection—all raise questions
 of science, technology, and
 public policy that are as dif-
 ficult as they are important. In
 a number of cases, we must
 decide whether the very fear
 of risk is sufficient cause to
 act or whether we must await
 more certain evidence that the
 risk is real. In  these and other
 cases, we lack both certainty
 as to the degree of risk and
proven technology to remove
it. In nearly every case, the
 cost of protection gives pause
 to any public servant who
 must weigh the investment of
 public or private funds against
 the value of the protection to
 be purchased. We must make
 judgments with whatever
 information we have and ex-
 pect to learn more as we go.
    I believe that EPA's
 highest priorities for meeting
 our future and its challenges
 are to maintain progress, im-
 prove our understanding and
 knowledge,  and anticipate
 new challenges. All this must
 be done while strengthening
 our partnership with State and
 local governments and main-
 taming public support and
 trust.

 Maintain Progress
 The first thing we must do is
 to make sure we maintain the
 success we have worked so
 hard to achieve in the past  13
 years. Industries have installed
 billions of dollars in pollution
 control equipment, but they
 must now work to operate
 and maintain it properly.
 Municipalities must set  aside
 adequate resources and retain
 well-trained staff to keep their
 sewage treatment works
functioning properly,  as well
as cope with additional waste
 generated by growing pop-
 ulations. A major EPA prionty
 for the next few years is to en-
 sure that both industrial and
 municipal facilities comply
 continually with environmen-
 tal requirements. If we should
 relax our enforcement efforts,
 the progress made in the past
 decade would quickly erode.
 Therefore, we will continue to
 insist on vigorous compliance
 programs, including
 monitoring and enforcement,
 so that States or EPA can take
 whatever remedial action may
 be necessary.

 Improve Our
 Understanding and
 Knowledge
 While there have been signifi-
 cant breakthroughs in all
 aspects of environmental sci-
 ence in the last decade, we are
 still operating on the frontiers
 of knowledge in attempting to
 assess the risks associated
 with different levels of human
 exposure to pollutants. The
 ramifications of this un-
 certainty for EPA are signifi-
 cant as critical decisions often
 must rest on controversial
 scientific judgments. Instead
 of denying the uncertainties,
our approach will be to articu-
late them. One of my highest
                                                                                              -BSE'

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priorities is to develop a
systematic approach to de-
termining all the factors that
need to be considered in mak-
ing such decisions. My objec-
tive is to ensure that our de-
cisions are based on high-
quality data and rigorous anal-
ysis. In addition, we will place
increased emphasis on im-
proving the quality of the
scientific information we use
to support our decisions.
    I am convinced of the im-
portance of a balanced re-
search approach. While pro-
gram needs must be met, a
certain percent of EPA's re-
search should be dedicated to
improving our understanding
of fundamental scientific un-
certainties that currently cloud
our decisions. The most impor-
tant of these areas include:
• The relationship of single
chemical toxicities found in
laboratory animal studies to
the human health impacts
that may result from long-
term, relatively low-level en-
vironmental exposures to a
multitude of chemicals;

• The actual fate of pollu-
tants in the environment; and

• The means to measure sys-
tematically environmental im-
provements or to identify
emerging contamination prob-
lems  before they become en-
vironmental crises.
    Whether or not it is im-
mediately applicable to a
specific regulatory or other ac-
tion, well-planned research in
these areas will undoubtedly
pay dividends in the long run.
Anticipate New Challenges
Changes in population and
technology, and economic, in-
dustrial, and agricultural
growth are influencing our
current environmental prob-
lems and presenting new en-
vironmental challenges. Rapid
population growth coupled
with extensive energy de-
velopment in the West, for ex-
ample, is putting severe
strains on natural resources in
this area, particularly water
resources. At the same time,
the lack of growth in some of
the country's older cities is, in
some cases, creating problems
of financing basic environ-
mental services such as sew-
age treatment. In areas where
there is a trend toward widely
dispersed, high-technology
facilities, there is the possibil-
ity of discharges of small
amounts of unusual chemicals
into rural treatment systems
not designed to handle them.
The growing popularity of
wood stoves may present air
pollution problems that will
be difficult to control. New
agricultural processes, such as
"no-till" farming and ex-
panded irrigation, could affect
the amount of pesticide
runoffs into nearby water sup-
plies. On the other hand,  ad-
vances in biotechnologies hold
the promise for chemical proc-
essing methods that are more
environmentally benign or
perhaps organisms capable of
rapidly and cheaply detoxify-
ing hazardous waste or spills.
But such new technologies
also convey environmental
concerns as their public health
and environmental con-
sequences are not known.
    While we have made en-
vironmental gains in the past,
we need to constantly antic-
ipate and evaluate the poten-
tial effects of these changes.
Moreover, we must carefully
balance environmental goals
with the Nation's other social
and economic needs, in-
cluding economic growth and
technology leadership.

Build a Stronger
Partnership with the States
EPA's role in environmental
protection is essential but not
sufficient to bring about the
genuine change we need. Over
the past several years, States
have increasingly taken over
full management and opera-
tion of environmental pro-

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grams. In fact, it is fair to say
that States are now the actual
operating arm of the national
network for environmental
protection. As States conduct
the lion's share of day-to-day
permitting and enforcement,
EPA's role must shift to em-
phasize national leadership
and support of States. Our
Federal Agency will continue
to set national standards  to be
administered by States, but
we will also concentrate  on
providing States the tools they
need to succeed. That means
research and technical support
directed to meet the needs of
States in their everyday work.
EPA remains responsible  for
national program success, but
we will increasingly account
for the contnbutions of State
programs to our country's en-
vironmental health.

Ensure Understanding of
Choices
If the Nation is to continue to
make progress in preventing
and abating contamination of
our environment, EPA's
efforts must be undertaken
with the full understanding,
cooperation, and participation
of the public, industry, and
government. We will often
have to debate and come  to
some agreement on how to
balance our desire and need
for a clean environment with
other economic and social
needs.
    The challenges ahead will
demand more than the skill
and commitment of EPA staff
working with many other gov-
ernmental agencies for en-
vironmental protection. Public
support will continue to be vi-
tal in maintaining the
momentum of past success.
But the public support also
places a responsibility on us  at
EPA and on other public ser-
vants to educate and inform
the American people on the
difficulties we face and the
tough tradeoffs future environ-
mental decisions will entail.

THE NATIONAL
ENVIRONMENTAL REPORT

Upon returning to EPA, I have
consistently stressed the need
to have greater public in-
volvement in our decisions.
This public involvement can
take two forms. The first is
through citizens making their
opinions known on key en-
vironmental issues by partici-
pating in local government de-
cisions and by writing EPA,
the President, or their repre-

                                         FOR
                                                •  ' .
       •-1HB                              NO
                                           MADE
       .WIJHQUT THE
sentatives in Congress. This
type of involvement is crucial
if we are to resolve the many
conflicts in values which we
now face. The initial responsi-
bility of this involvement lies
with EPA. We must make an
effort to get proposals to the
public for a meaningful di-
alogue to take place.
    The second form of public
involvement is a very con-
crete one. No matter what
laws are passed for the protec-
tion of the environment, no
progress will be made without
the fullest support of the
American people. This public
support, however, places a
great responsibility on us to
inform and to educate. EPA
publishes this report as a
means of accounting to the
American public for our ste-
wardship of public funds over
the past 13 years. I believe the
report demonstrates that our
accomplishments to date have
been well worth the in-
vestment. But there is more to
do. An equally important rea-
son for publishing this report
is to alert the public to some
of the most difficult environ-
mental problems the Nation
is now facing. We at EPA can-
not succeed if the American
people are not aware of the
complexity of the problems
and the difficulty of the
choices ahead. I hope this re-
port encourages understanding
and opens the dialogue so es-
sential  to better, more in-
formed decisions and actions
by EPA on behalf of this coun-
try and our world's most pre-
cious resources.

                                                           William D. Ruckelshaus

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Most Americans over 30 can
remember seeing clouds of
pollution cover a city and  feel-
ing their eyes smart and lungs
begin to tighten up when
passing near industrial areas.
For good reason, air pollution
has been a major health and
environmental concern for
several decades.

• There were instances in the
late 1940's and early 1950's,
both in the United States and
other countries, where air
pollution levels were so bad
that people were hospitalized
and many died.
• Many urban areas were  per-
petually enveloped in a smoky
haze, as industries emitted
thousands of tons of pollu-
tants into the air with few or
no controls.
• Dirt and grime from the air
were commonplace in homes,
on laundry hung outside to
dry, and on buildings, cars,
and vegetation.

    Over the last 13 years, we
have made significant prog-
ress. Levels of air pollution are
consistently lower. Days
when air pollution makes  it
unhealthy to be outside are far
less frequent. Most industries
have put pollution controls in
place, and many communities
have restricted open burning
and other practices that con-
tribute to local air pollution
problems.
    However, many tradition-
al air quality problems still re-
main, and new ones are
emerging. This chapter begins
with an overview of EPA's
approach to air pollution con-
trol and the progress achieved
so far. It then discusses eight
major air pollution issues
facing the Nation and how
EPA plans to address them.
                                                                                       11

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                               Despite considerable im-
                               provement in air quality over
                               the past decade, air pollution
                               of some sort is found in nearly
                               every area of the United
                               States. It is particularly  severe
                               in urban areas. Air pollution
                               can cause both health and en-
                               vironmental damage. Some of
                               the health problems brought
                               on or aggravated by air pollu-
                               tion include lung diseases,
                               such as chronic bronchitis and
                               pulmonary emphysema; can-
                               cer, particularly lung cancer;
                               neural disorders, including
                               brain damage; bronchial
                               asthma and the common cold,
                               which are more persistent in
                               places with highly polluted
                               air; and eye irritation (Figure
                               A-l). Environmental problems
                               range from damage to crops
                               and vegetation to increased
                               acidity of lakes that makes
                               them unsuitable for fish and
                               other aquatic life.
                                   As early as the 1940's it
                               became clear air pollution was
                               a serious problem. In the late
                               1940's, Los Angeles took
                               measures to control its smog
                               problem. However, States and
                               local governments were gener-
                               ally reluctant to impose tough
                               requirements on industry
                               which might make other
                               States seem more attractive
                               places for industry to locate.
                               To address air pollution more
                               effectively, it became neces-
                               sary to develop a national
                               approach.
                                   In 1963, Congress passed
                               the Clean Air Act (CAA),
                               which authorized the U.S.
                               Public Health Service to study
                               air pollution and to provide
                               grants and  training to State
                               and local agencies to control
it. This legislation was
strengthened considerably
when the Clean Air Act
Amendments of 1970 were
signed into law, making the
recently created EPA the focal
point of the Federal effort.
    The  1970 amendments to
the Clean Air Act required
EPA to set  National Ambient
Air Quality Standards for
"criteria air pollutants." These
are air pollutants  found com-
monly throughout the coun-
try. EPA has identified six
criteria pollutants: ozone, car-
bon monoxide,  total sus-
pended particulates, sulfur di-
oxide, lead, and nitrogen di-
oxide. For these pollutants,
primary standards are set to
protect human health and sec-
ondary standards to protect
what the Act refers to as
"welfare," primarily crops and
livestock, vegetation, build-
ings, and visibility. For some
of these pollutants, one stan-
dard has been set that protects
both health and welfare.
    The Clean Air Act
Amendments also require EPA
to review and regulate
hazardous air pollutants.
These pollutants are defined
as those that can contribute to
an increase in mortality or in
serious illness but which are
not already regulated as
criteria pollutants. EPA is cur-
12

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rently analyzing a number of
air pollutants to determine
whether they are hazardous
and require regulation. The
Agency already has issued
standards for four of these pol-
lutants: asbestos, beryllium,
mercury, and vinyl  chloride.

SOURCES OF THE PROBLEM
AND ERA'S APPROACH

Both criteria and hazardous air
pollutants come from two ma-
jor categories of sources, mo-
bile sources and stationary
sources. Mobile sources in-
clude passenger cars, trucks,
buses, motorcycles, boats, and
aircraft. Stationary sources
range from iron and steel
plants and oil refineries to dry
cleaners and gas stations.
    Under the Clean Air Act,
as amended, State and local
governments have primary re-
sponsibility for the control
and prevention of air pollu-
tion. EPA is responsible for
setting national standards to
protect public health and wel-
fare, conducting research on
Darkness at noon: Pittsburgh during the 1940s before air pollution
control efforts
                                                         13

-------
prevention and control of air
pollution, and providing tech-
nical and financial assistance
to State and local gov-
ernments for air pollution
control. Each  State must draw
up a State Implementation
Plan (SIP) describing how it
will control emissions from
mobile and stationary sources
in order to meet National
Ambient Air Quality Stan-
dards (NAAQS).

Mobile Sources
Mobile sources of air pollution
produce more than half of all
air pollution emissions. Ex-
haust from mobile sources
contains carbon monoxide,
volatile organic compounds,
nitrogen oxides, particulates,
and lead. All of these pollu-
tants, except volatile organics,
are regulated as criteria air
pollutants, and EPA has set
ambient standards for them.
Although volatile organic
compounds are not regulated
as a criteria pollutant, their
emissions are controlled be-
cause of their role in ozone
formation.
    EPA has tried to control
the emission of these pollu-
tants from motor vehicles
through the Federal Motor
Vehicle Control Program
(FMVCP). Under this program,
EPA sets national emission
standards for carbon monox-
ide, nitrogen dioxide, volatile
organic compounds,  and par-
ticulates and requires car
manufacturers to design new
cars so that they meet those
standards. EPA and State and
local governments also sup-
port and operate inspection
and maintenance programs to
test emission levels of cars in
use. In addition, State and lo-
cal governments try  to meet
ambient standards by
encouraging public transporta-
tion systems and improving
traffic patterns.

Stationary Sources
Stationary sources generate air
pollutants as by-products of
fuel burning and industrial
processes. Electric utilities, in-
dustrial facilities, and residen-
tial and commercial buildings
are the principal contributors
of the pollution generated by
burning coal, oil, natural gas,
wood, and other fuels. The
pollutants produced include
sulfur dioxide, nitrogen ox-
ides, carbon monoxide, and
                                                         FIGURE A-2

                                CRITERIA POLLUTANT EMISSIONS HAVE GONE DOWN
                                                                     Fuel combustion from
                                                                       stationary sources

                                                                     Industrial processes

                                                                     Solid waste disposal and
                                                                       miscellaneous sources
                                                                                               These figures represent total emis-
                                                                                               sion estimates and do not reflect the
                                                                                               relative health impact of the pollut-
                                                                                               ants  See highlight on the Pollution
                                                                                               Standard Index for an indication of
                                                                                               relative health impacts.

                                                                                               Source National Air Pollutant Emission
                                                                                               Estimates, 1940-1982, USEPA
14

-------
particulates. The by-products
of industrial processes gener-
ate these same pollutants as
well as volatile organic com-
pounds and lead.
    Hazardous air pollutants
come from a variety of in-
dustrial and  manufacturing
processes. In addition, fuel oils
contaminated with toxic
chemicals, hazardous waste
disposal facilities, municipal
incinerators, and electric utili-
ties may also be sources of
hazardous air pollution.
    EPA relies heavily on the
States to control emissions
from stationary sources. States
review whether they are
meeting ambient standards for
individual criteria pollutants.
Where they are not meeting
these standards, they develop
plans to achieve them. Once
these State Implementation
Plans are developed, the States
                                   tiacmg." Emissions
                                                    Jjffr
                                                      ,


                                              the credits


     '
or EPA writes specific permits
limiting the emissions from
individual facilities. They
monitor the facilities to en-
sure they comply with emis-
sions limits and take action
against violators.

PROGRESS TO DATE
EPA and State and local gov-
ernments have taken many of
the necessary steps to control
air pollution. Most industries
now have air pollution control
equipment in place. New cars
are built to standards that
represent a reduction of about
95 percent for volatile organic
compounds and carbon mono-
xide and 75 percent for nit-
rogen oxides. Because the
principal design changes made
to reduce emissions require
use of unleaded gasoline, a
side effect of design changes
has been significant reduc-
tions in lead emissions. These
emission reductions from mo-
bile and stationary sources
have resulted in considerably
lower ambient levels of all the
pollutants and far fewer
communities with pollution
levels exceeding air quality
standards.

Ait Pollution Emissions
A recent report prepared by
EPA's Office of Air and Radia-
tion concludes that air pollu-
tion emissions from all types
of sources and for almost all
pollutants were reduced dra-
matically between 1970 and
1982 (Figure A-2).
• Paniculate  annual emis-
sions have been reduced by 58
percent since 1970 because in-
dustries have installed air
pollution control equipment
and because there is less
burning of solid waste.
• Sulfur dioxide emissions in-
creased from  1970 through
1973 as a result of increased
burning of coal and other fos-
sil fuels. Since then, however,
sulfur dioxide emissions have
decreased as a result  of the in-
stallation of controls at
coal-fired power plants, the
burning of less coal by other
sources, and reduced emis-
sions from smelters.
• Nitrogen oxide emissions
overall have increased slightly.
Emissions from transportation
sources increased through
1978 because of increased
motor vehicle travel but have
declined slightly since then.
Electric utility emissions in-
creased due to greater use of
fossil fuels. Industrial emis-
sions decreased slightly.
• Volatile organic compounds
annual emissions, which
along with nitrogen oxides are
contributors to ozone forma-
tion, decreased by about 28
percent between 1970 and
1982. This has been due pri-
marily to the Federal Motor
Vehicle Control Program and
less burning of solid waste.
• Carbon monoxide annual
emissions from transportation
sources and industrial proc-
esses declined about 27 per-
cent, as did emissions from
burning of solid waste and
agricultural refuse.
• Lead emissions decreased
69 percent between 1975 and
1982.

Ambient Levels
EPA and the States measure
levels of criteria pollutants in
the ambient air by using a
network of monitors across
the country. Because the
monitors are deliberately con-
centrated in cities, where
there is the greatest potential
for exposure, there is an urban
bias to the data. In general,
however, the data reliably
show trends in air quality.
Data from this network for
the period from 1975 to  1982
show that ambient levels of
all criteria pollutants are
down nationwide (Figure A-3).
• Paniculate levels decreased
15 percent between 1975 and
1982. While emissions de-
creased 27 percent during this
period, ambient levels only de-
creased by about half this
                                                                                                                      15

-------
Source- National Air Quality and Emissions Trend Report, 1982, USEPA
much because of the large
amounts of natural wind-
blown dust, as well as dust
from streets and construction
sites.
• Sulfur dioxide levels de-
creased 33 percent between
1975 and 1982.
• Nitrogen dioxide levels in-
creased between 1975 and
1978,  but dropped between
1979 and 1982. The 1982 level
was the same as the level in
1975 and well below the
ambient  standard.

• Ozone levels decreased 18
percent between 1975 and
1982,  and exceedances of the
ambient  standard during the
ozone season (July-September)
during these years  dropped
even more dramatically, by 49
percent. Part  of this decrease
can be accounted for by a
calibration change in the
monitoring equipment in
1979.

• Carbon monoxide levels
dropped 31 percent between
1975 and 1982. Moreover, ex-
ceedances of the ambient
standard dropped 87 percent
during this period.
• Lead levels decreased
nationally 64 percent between
1975 and 1982, primarily be-
cause of a drop in the use of
leaded gasoline.

Areas Meeting Ambient
Standards
Across the Nation, we have
made considerable progress in
meeting air quality standards.
As shown in Figure A-4, many
                                                              Source EPA's Office of Air Quality Planning and Standards
more areas are now attaining
standards for ozone, particu-
lates, sulfur dioxide, and car-
bon monoxide than in 1978.
(Lead nonattainment was not
reported at that time, so there
is no basis for comparison.)

TODAY'S AIR QUALITY
CHAL1ENGES

Although we have made con-
siderable progress in con-
trolling air pollution from
both mobile and stationary
sources, much still needs to
be done. Five of the six
criteria pollutants, all except
nitrogen dioxide, are currently
of major concern in a number
of areas of the country. There
are many counties or portions
of counties where health-
related standards for one or
more of the criteria pollutants
are not being met.
     In addition, certain areas
still  have levels of pollution
on some days that are far in
excess of those considered safe
for the protection of human
health and the environment.
For example, in 1981, the Los
Angeles metropolitan area vio-
lated ozone standards 165
days of the year, with levels
sometimes as much as four
times higher than the ambient
standard.
     EPA also needs to do
more work to determine the
extent and nature of problems
with hazardous air pollutants.
One of EPA's highest priori-
ties for the next two years is
to develop and implement an
effective national air toxics
program. As part of this pro-
gram, EPA will provide guid-
ance and assistance to States
in monitoring and controlling
these pollutants. In addition,
we need to make considerably
more progress in under-
standing acid rain.
    The rest of this chapter
focuses  on eight of the most
significant air quality chal-
lenges that now face the Na-
tion. These challenges are:
•  Ozone. Although much
progress has been made in
reducing ozone levels, people
in several areas across the Na-
tion continue to be exposed to
high concentrations of this
pollutant. In a number of ma-
jor metropolitan areas, it is
unlikely that the ozone  stan-
dard will be met because it
would require reductions in
emissions of volatile organic
16

-------
compounds of as much as 40
to 85 percent.
• Airborne participates.
Numerous areas of the coun-
try continue to violate par-
ticulate standards. A number
of these areas are rural sites
with natural wind-blown dust
which, because it consists of
large particles, is not a health
threat. In other areas, how-
ever, large numbers of people
are exposed to particulates
that are the product of in-
dustrial processes, wood and
coal burning, and motor vehi-
cles. These particulates, which
consist of both large and small
particles, can damage cars,
buildings, and vegetation. The
smaller particulates can also
cause serious health problems
including throat irritation and
lung damage. EPA has pro-
posed refocusing its regula-
tions to control these small
particulates because they con-
stitute the greatest health
threat.
• Carbon monoxide. Carbon
monoxide,  which is produced
primarily by motor vehicles, is
most severe in urban areas.
Where it is a problem, it is
considered serious because of
its effects on health. These
effects include aggravation of
heart and lung disease and im-
paired  mental functioning and
alertness.

• Sulfur dioxide. Sulfur di-
oxide is a product primarily of
fossil fuel combustion by elec-
tric utilities.  While only a few
areas are classified as non-
attainment for this pollutant,
it remains  a concern both be-
cause it can have serious
effects on health and because
it plays a role in the forma-
tion of acid deposition.

• Airborne lead. Levels of air-
borne lead have decreased dra-
matically due to the increased
use of  unleaded gasoline.
However, lead is still a con-
cern in many areas, particular-
ly near current or former sites
of lead smelting operations.

• Airborne toxics. There is in-
creasing evidence that many
toxic compounds are trans-
ported through the air. Some
of these chemicals may pose
both immediate and long-term
health problems, including
respiratory illness, cancer, and
birth defects. The issues in-
volved in controlling toxics
are complicated since it is not
clear what effects these sub-
stances have at the very low
levels found in the ambient
air.
• Acid deposition. Acid is
formed in the air primarily as
a result of the interaction be-
tween  sulfur dioxide or nit-
rogen dioxide and water. This
acid  not only affects the area
where  it was emitted but
often falls to earth far from
the original sources of these
cigarette smoke, building
materials, fumes from heating
and cooking devices, and a
variety of other sources.
Levels of pollutants inside
buildings may be much
higher than levels outdoors.
Because Americans spend an
average of 80 to 90 percent of
their time indoors, there is in-
creasing concern about this
problem.
pollutants, making control
measures complicated and
controversial. Some lakes and
streams have become so acidic
that they cannot support fish
or other aquatic life. It is re-
ported that acid deposition
may also damage crops, vegeta-
tion, and forests.
•  Indoor air pollution. Indoor
air can become polluted by
                                                                                                                       17

-------
Ozone
 Ozone is still the Nation's
 number one air pollution
 problem. Many areas across
 the country, including a num-
 ber of the major metropolitan
 areas, continue to have levels
 of this pollutant which are
 higher than EPA's ambient
 standard (Figure A-7). The ma-
 jor component of smog,  ozone
 can cause serious respiratory
 problems.
    Ozone is produced when
 sunlight triggers chemical
 reactions involving volatile
 organic compounds (VOCs)
 and nitrogen oxides (NOx).
 Levels are highest during the
 day, usually after heavy
 morning traffic has released
 large  amounts of the precursor
 pollutants (Figure A-5). Con-
 trol of these precursors is dif-
 ficult because their sources
 are varied and widely dis-
 persed. Motor vehicle traffic is
 growing so fast and is such  an
 essential aspect of life in
 many places that even
 strenuous efforts may not suf-
 ficiently reduce emissions.
 Like motor vehicles, other
 small sources such as dry
 cleaners and gas stations,
 though individually only emit-
 ting small amounts of the pol-
 lutants, are collectively a sig-
 nificant part of the problem.
                               ^•^™™^^™^^^™™^^™«^^^^"^^^«^^^^™^^^B^^^B^H^B^™^
                               Source Perkins, H C (1974] Air Pollution, McGraw Hill New York, p 97 and Center for Air
                               Environment Studies, Penn State University
18

-------
Ozone is one of the six
criteria pollutants for which
EPA sets ambient standards.
Considerable progress has
been made in reducing it over
the past several years.
Ambient levels of ozone
nationally fell 18 percent be-
tween 1975 and 1982 (Figure
A-6). An even more dramatic
improvement was seen during
the summer months when
ozone levels are usually
highest. By 1982, the number
of violations of the ambient
standard during the summer
was 49 percent less than in
1975. The number of "nonat-
tainment" areas where the
standard was violated more
than once a year dropped from
607 in 1978 to 471 in 1983.
Some of this  recorded im-
provement, however, is the re-
sult of changes in the ambient
standard in 1978 and
recaliberation of monitoring
equipment in 1979. Despite
these gains, ozone remains a
serious problem in hundreds
of urban areas across the
country.
    In many  areas, the
greatest contributer to ozone
remains motor vehicles. Auto-
mobile emissions of ozone-
producing chemicals have
been reduced considerably
since 1970 because all new
motor vehicles must now
meet EPA emissions stan-
dards. This program has been
reinforced by automobile in-
spection and maintenance pro-
grams in cities where ozone
has been a particularly in-
transigent problem. Twenty
States have inspection pro-
grams under way, with eight
more expected to begin this
year.
    Emissions from major sta-
tionary sources such as chem-
ical plants, refineries, and in-
dustrial processes have been
substantially controlled
through EPA, State, and local
permitting and enforcement
efforts. However, some  sta-
tionary sources such as paint
manufacturers, dry cleaners,
and gas stations have not been
widely controlled. EPA  is
assessing methods to control a
number of these small station-
ary sources. New emission
standards for industries pro-
ducing synthetic organic
chemicals, surface coatings,
and pesticides are part of this
effort.
                              Source National Ail Quality and Emissions Trends Report, 1982, USEPA
                                        FIGURE A-7
                 COUNTIES IN PARTIAL OR TOTAL NON-ATTAINMENT
                                      FOR OZONE
                                           1983
                                        Source Maps Depicting Non-Attainment
                                        Areas Peisuant to Section 107 of the Clean
                                        Air Act- 1983, USEPA
                                                                                                                    19

-------

While considerable reductions
have been achieved nation-
wide, persistently high levels
in some areas mean that we
must go beyond our efforts to
date.
Mobile Sources
Cars made before 1970
are not subject to national
emissions programs. In addi-
tion, over 13 percent of the
cars built since 1975 have had
their pollution control devices
disabled. These factors make
mobile sources a remaining
concern.
Discarded catalytic converters and mufflers. Removal of catalytic con-
verters greatly increases a car's ozone-causing emissions.
Small Sources
Small stationary sources were
not initially regulated by EPA
or States. However, the reduc-
tions achieved by controlling
automobile and large station-
ary source emissions have not
been sufficient to solve the
ozone problem in several
areas. Further controls will be
required on small stationary
sources if the ambient stan-
dards are to be met. The costs
of controlling these sources,
primarily small businesses
with slim profit margins, pre-
sent difficult cost-benefit
decisions.

Ozone Transport
Ozone and its precursors are
frequently transported across
State and national boundaries,
creating considerable inter-
state and international con-
troversy. The lack of con-
sensus in the scientific com-
munity on modeling tech-
niques makes these con-
troversies difficult to resolve.
  % \  - %~ ' \J I  f f^"\
rw ^ V ^ &~* i  %:&*.-« J. \

Among the criteria air pollu-
tants, ozone is EPA's highest
priority. EPA is focusing its
regulatory and enforcement
efforts on the control of new
and existing sources of vola-
tile organic compounds
(VOCs). EPA is developing
new  source emissions stan-
dards based on the best con-
trol technology for VOCs, par-
ticularly for the surface
coating and synthetic organic
chemical industry.
    As required by the Clean
Air Act, EPA has begun the
periodic reevaluation of the
National Ambient Air Quality
Standard for ozone. As part of
this process, EPA must con-
sider any new research on the
health or environmental risk
of ozone and determine
whether the present standard
needs to be modified.
    For States with one or
more of the  154 counties
granted extensions until 1987
to attain the ozone standard,
EPA is helping  develop and
implement mobile and sta-
tionary source controls. EPA
is also trying to help resolve
interstate disputes over ozone
transport with models pre-
dicting the possible path of
pollutants. These models
work in much the same way
as weather forecasting models.
In addition, EPA is planning a
special study to determine
what changes may be needed
in State Implementation Plans
in the areas where the air still
fails  to meet  the health-
related standard. Where com-
pliance is past due and an ex-
tension has not been granted,
EPA will require more strin-
gent  control efforts and im-
pose sanctions if States fail to
take  necessary actions.
20

-------
Los Angeles developed a smog problem during the 1940's and 1950's.
                                                                      21

-------
Airborne   Particulates
 Particulates in air such as
 dust, smoke, and aerosols may
 have both acute and long-term
 health and environmental
 effects. These effects range
 from irritating the eyes and
 throat and reducing resistance
 to infection, to causing
 chronic respiratory diseases.
 Fine particulates, about the
 size of cigarette smoke parti-
 cles, can cause temporary or
 permanent damage when they
 are inhaled deeply and lodge
 in the lungs (Figure A-10).
 Some particulates, such as
 those from diesel engines, are
 suspected of causing cancer.
 Others, such as windblown
 dust, can carry toxic sub-
 stances such as polychlonn-
 ated biphenyls (PCBs) and pes-
 ticides. Particulates can also
 cause corrosion of buildings,
 damage vegetation, and
 severely reduce visibility.
    Since 1971, EPA has had
 a National Ambient Air Qual-
 ity Standard for Total Sus-
 pended Particulates (TSP).
 This standard covers all kinds
 and sizes of particulates. Re-
cent research suggests that
smaller inhalable particulates
present the most serious
health threat as they tend to
become lodged in the lungs
and remain in the body for a
long time. EPA is now in the
process of replacing the pr-
esent health standard with
one aimed at these smaller
particles.
    There are numerous
sources of particulates, some
of which may be controlled by
conventional means and
others which require more
creative approaches. Major
sources of particulates include
steel mills, power plants, cot-
ton gins,  cement plants, smel-
ters, and diesel engines. Other
sources are grain storage ele-
vators, industrial haul roads,
construction work, and demo-
lition. Wood-burning stoves
and fireplaces can be a signifi-
cant source of particulates in
rural parts of the country.
Urban areas are likely to have
windblown dust from roads,
parking lots, and construction
activity.
EPA and States have sought to
meet the standard by limiting
emissions from industrial faci-
lities and other sources. To
meet emissions limits, in-
dustries have installed pollu-
tion controls such as electri-
cally charged plates and huge
Source National Air Quality and Emissions Trends Report, 1982, USEPA
                                                                     FIGURE A-9
                                               COUNTIES IN PARTIAL OR TOTAL NON-ATTAINMENT
                                                               FOR PARTICULATES
22
                                        Source Maps Depicting Non-Attainment
                                        Areas Persuant to Section 107 of the Clean
                                        Air Act- 1983, USEPA

-------
filters. EPA has also set emis-
sions standards for diesel auto-
mobiles. Improved paving, bet-
ter street cleaning, limits on
agricultural and forest burning
practices, and bans on back-
yard burning in urban areas
are also helping to reduce par-
ticulate levels.
    Such measures have re-
duced concentrations of dirt
and contaminants in most
areas; however, the TSP stan-
dards still have not been
achieved in 345 areas (Figure
A-9). For many of these areas,
particularly in the western
States, a major barrier to
achieving the current stan-
dard is natural windblown
dust.
    EPA data show a 15 per-
cent decrease in ambient par-
ticulate levels from 1975 to
1982, although  some of this
decrease reflects a change in
the filters EPA  used to moni-
tor particulates (Figure A-8).
During the same penod, emis-
sions dropped 27 percent
nationwide. The difference in
the emissions reductions and
the ambient decreases reflects
the impact of windblown dust
from streets, construction
sites, and natural sources.
                             dad-ant
Two of the greatest challenges
we face are making the transi-
tion to the inhalable particu-
late standard and controlling
new sources of particulates.

Inhalable Particulates
When EPA completes the revi-
sion of the existing standard
to focus on smaller particu-
lates, a number of areas now
classified as "nonattainment"
because of natural dust will
meet the new standard. On
the other hand, monitoring
suggests that some areas  that
now attain the total particu-
late standard may not meet
the new standard for inhalable
particles.

Changing Energy Sources
Higher prices for oil and gas
have led many homeowners
to burn wood to heat their
homes and factories and utili-
ties to switch to coal. These
trends toward greater wood
and coal burning promise to
increase particulate emissions
substantially. Moreover, ener-
gy legislation allows facilities
converting to coal to tempo-
rarily increase emissions  until
they install new control
devices.

         FIGURE A-10

 ONLY SMALL PARTICLES
      ARE INHALED
    INTO LUNG TISSUE
                                                                                  Others get
                                                                                 caught in the
                                                                                  smaller air
                                                                                   passages
         £,i5¥Tii»^rvi* ^A«*? %  ~ *'^* '  ~ r^t ""^"^J^raf-^^"- -p*™ TI^VTT"
                                                  *•/ /
EPA is continuing to enforce
against sources violating the
current paniculate emission
standards. At the same time,
the Agency is expediting de-
velopment of the revised stan-
dard, as well as the ambient
monitoring and testing
methods necessary to im-
plement  it.
    After promulgation of the
new standard, the Agency will
help States modify existing
ambient  monitoring sites for
these particulates. It will also
issue guidelines for States to
determine whether an area is
in attainment under the new
standard and, if not,  how to
achieve attainment.
    The  Agency will conduct
studies to determine the prin-
cipal sources of inhalable par-
ticulates and assess the
effectiveness of traditional
particulate matter control
technologies in reducing emis-
sions of small-sized particu-
lates. It will also evaluate the
impact of the size-specific
standard  on current New
Source Performance Standards,
identifying those which will
need revisions.
    By the end of 1984, an in-
tragency  work group will
issue a report assessing re-
search needs, regulatory
alternatives, and potential
problems brought about by
the new standard. The work
group will provide a detailed
look at the ramifications of
the new standard for EPA's
Regional offices and States
which are responsible for im-
plementing and enforcing it.
                                                           Only the
                                                           smallest
                                                           particles
                                                           get into
                                                           lung tissue
                                                                                                                      23

-------
Carbon   Monoxide
Carbon monoxide is an invis-
ible, odorless product of the
incomplete combustion of
fuel. When inhaled, it replaces
oxygen in the bloodstream
and can impair vision, alert-
ness, and other mental and
physical capacities.  It has par-
ticularly severe health effects
for people with heart and lung
problems.
    The main source of car-
bon monoxide is motor vehi-
cles, especially when their en-
gines are burning fuel in-
efficiently, as  they are when
starting up in the morning,
idling, or moving slowly in
congested traffic. Other
sources are fuel burning in
homes, incinerators, and in-
dustrial processes. Although
carbon monoxide levels have
declined in most parts of the
country since 1970, the stan-
dards are still exceeded in  151
cities and counties throughout
the U.S. (Figure A-12). Many
areas have local "hot spots"  of
carbon monoxide pollution,
usually near heavily congested
roadways and intersections.
    Since 1968, the Federal
Government has required that
new cars be equipped with
emissions controls.  Further re-
ductions in carbon monoxide
in most places will  depend on
additional actions to ensure
that these emission controls
function as intended. Local
"inspection and maintenance"
programs are one way to
police against disabling the
control equipment by
tampering with it or using
leaded fuel.
National emission standards
for motor vehicles, requiring
reductions in carbon monox-
ide levels from 87 grams to
3.4 grams per mile, have been
very successful in reducing
the ambient levels of this pol-
lutant. Ambient levels of car-
bon monoxide fell 31 percent
between 1975 and 1982 (Fig-
ure A-ll). An even greater im-
provement was seen in the
number of exceedances of the
ambient standard, which de-
creased 87 percent during this
period.
    Between 1975 and 1978
there was a 16 percent in-
crease in car use which damp-
ened the progress made by
emissions controls. Since
then, however, vehicle use has
stabilized, making progress in
emissions control more
obvious. Many communities
promoted mass transportation,
ride sharing, fringe parking,
and timed signal lights to im-
prove traffic flow. State and
local vehicle inspection and
maintenance programs also
helped reduce the carbon
monoxide levels.
Three factors make it particu-
larly difficult for some areas
to attain acceptable levels of
carbon monoxide.

The Growing Number of
Automobiles

We expect additional emis-
sions due to an increase in the
total number of cars in use.
In addition, older cars are not
being replaced as rapidly as
was expected, increasing the
average age of cars on the
road. Since older cars are
generally the most serious
polluters, this trend could
have an impact on further
progress for several years.
                                                           Inspection and maintenance programs are needed in some cities to
                                                           combat air pollution.
24

-------
Tampering and Fuel
Switching
Because it is cheaper and has
higher octane, some people
have put leaded fuel in cars
designed for unleaded. This
destroys the catalytic con-
verter, resulting in higher car-
bon monoxide emissions.

Delays in Implementing
Inspection and
Maintenance Programs
The public as a whole is not
fully convinced of the need
for, or effectiveness of, vehicle
inspection and maintenance
programs. Because of this,
States have been slow to pass
authorizing legislation and
provide funds to operate such
programs. These delays will
undoubtedly continue to post-
pone attainment of the carbon
monoxide standard in many
places.
Source National AIT Quality and Emissions Trends Report, 1982, USEPA
                                        FIGURE A-12
                 COUNTIES IN PARTIAL OR TOTAL NON-ATTAINMENT
                              FOR CARBON MONOXIDE
As required by the Clean Air
Act, EPA is in the process of
reassessing the carbon monox-
ide air quality standard and
will reaffirm or modify the
standard in 1984.  EPA is also
pressing States to  carry out
commitments (principally in-
spection and maintenance pro-
grams) to reduce carbon
monoxide in the 97 counties
where attainment is due by
1987. In 1985, EPA will an-
alyze these State plans to see
what additional steps, if any,
will be needed to  meet the
deadline.
    For the remaining areas
where compliance was due by
the end of 1982, EPA will
work with States to correct
the deficient implementation
plans. Where  States fail to
take action, EPA will impose
sanctions and additional con-
trols as necessary.
    EPA is also presently
assessing several possibilities
for eliminating or curtailing
the use of leaded gasoline
much earlier than originally
planned. One of these would
be a total  ban of leaded gaso-
line. The other would be  a
leaded gas, but with about
one-tenth the current amount
of lead. Either of these options
should solve most of the mis-
fueling problems.
          Source Maps Depicting Non-Attainment
          Areas Perswnt to Section 107 of the Clean
          Ail Act- 1983, USEPA
                                                                                                                    25

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Sulfur  Dioxide
The ambient standard for sul-
fur dioxide is still exceeded in
several areas of the country
(Figure A-14). Excessive levels
of this chemical in the
ambient air have been associ-
ated with significant increases
in acute and chronic respira-
tory diseases, hi addition, sul-
fur dioxide bonds to particles
of dust, smoke, or aerosols,
and can be transported long
distances in the atmosphere.
The consequences of this,
"acid deposition," are dis-
cussed as a separate issue.
    Electric generating plants
account for about 67 percent
of total sulfur dioxide emis-
sions. The proportion of sulfur
dioxide from these plants is
high partly because Federal
energy policies  since the oil
shortage in the  early 1970's
have encouraged utilities to
switch to more available fuels,
including coal and "sour" oil
containing relatively more sul-
fur. Other sources include  re-
fineries, pulp and paper mills,
steel plants, smelters, and
chemical plants (Figure A-15).
Energy facilities related to  oil
shale, synfuels,  and oil and gas
production may also produce
sulfur dioxide emissions.
Home furnaces  and coal
burning stoves are sources
that can more directly affect
residential neighborhoods.
The problem of sulfur dioxide
air pollution was well known
when EPA was established in
1970; some States already had
begun to limit sulfur dioxide
emissions from power plants
and factories. One of EPA's
first actions was to set
National Ambient Air
Quality Standards for sulfur
dioxide.
    To meet the standard,
State environmental au-
thorities developed control
plans for sulfur dioxide as var-
ied as the industrial facilities
whose emissions were being
limited. Some mines and fac-
tories installed equipment to
wash excessive sulfur from
coal. Scrubbers and de-
sulfurization equipment re-
duced emissions from other
sources, principally utilities.
Some of these facilities con-
verted the sulfur emissions in-
to commercial products such
as sulfuric acid.
    One technique used to
attain the ambient standards
may now prove to have been
shortsighted. In response to
growing energy problems, EPA
and States sometimes allowed
the use of tall stacks as an
alternative to further reducing
emissions. These stacks dis-
persed the gas and effectively
reduced the local impact of
sulfur dioxide from power and
industrial plants. However, we
now realize that emissions
Source National Air Quality and Emissions Trends Report, 1982, USEPA
                                        FIGURE A-14
                  COUNTIES IN PARTIAL OR TOTAL NON-ATTAINMENT
                                 FOR SULFUR DIOXIDE
26
                                         Source Maps Depicting Non-Attainment
                                         Areas Persuant to Section 107 of the Clean
                                         Air Act - 1983, USEPA

-------
from the tall stacks may be
responsible for sulfuric acid
deposition, with both local
and distant impacts.
    Overall the efforts to con-
trol sulfur dioxide have been
quite successful. Ambient
levels have fallen 33 percent
between 1975 and 1982 (Figure
A-13]. The number  of ex-
ceedances of the ambient
standard dropped 91 percent
during the same period. Emis-
sions, however, have only de-
creased 17 percent.  Dif-
ferences between emissions
and ambient trends  reflect a
shift in the use of high sulfur
fuels from urban areas, where
most of EPA's monitors are,
to rural areas.
Since the ambient standards
for sulfur dioxide were set,
several issues have arisen. The
geographical distribution of
high-and-low sulfur coal, the
economic impact on the
mining and utilities industries
of restrictions on high sulfur
coal, and the variability of the
sulfur content within coal
have all engendered consider-
able debate.

State Requests
EPA has  been requested by
several States to relax sulfur
dioxide emission limits in
areas where the air is cleaner
than required under the
national standard for sulfur di-
oxide. Some of  these actions
                              the bamim of. fossil' fatels,.-
                   i^«i is tfeoa^i the me of
                             (3PGDA typicaMy a«s. wafer
                             gases, ,    •
                   a AarpNw tewsfeis of & tikeoefy&t- wfti
                              emwt w^'feb A^ite? &
would permit facilities to use
less expensive and locally pro-
duced fuels. These requests
have generated considerable
debate within  EPA because of
the potential impact on acid
deposition. While these
changes may cause concern,
as long as the  ambient stan-
dards continue to be met EPA
must approve them under the
Clean Air Act.

Sulfur Content of Coal
The sulfur content of coal var-
ies greatly according to where
it is mined. The technical,
political, and economic rami-
fications of this variance have
complicated the task of set-
ting sulfur dioxide limits for
facilities burning coal.
                                                                        FIGURE A-15
                                                                   UTILITIES ARE THE
                                                                PRIMARY SOURCE OF
                                                                   SULFUR DIOXIDE
                                                                      EMISSIONS
                                                                          1982
                                       Non-utility stationary source
                                       fuel combustion 14.5%
                                                             Transportation
                                                             4.2%  \
                                              Industrial processes
                                                      /14.5%
                                                              Fuel combustion from utilities
                                                               66.8%

                                                             Source National Air Pollution Emission
                                                             Estimates, 1940-1982, USEPA
EPA and the States have com-
pliance programs to maintain
air quality gains made so far
and to improve the quality
and usefulness of monitoring
data for managing future
efforts to control sulfur  di-
oxide. EPA and the States will
continue to enforce limits on
sources affecting air quality in
the areas where  the national
standard is violated.
    EPA is near completion of
its review of the national air
quality standard for sulfur di-
oxide, as required by the
Clean Air Act. If necessary,
EPA will propose modification
of the standard in 1984, with
final action due in 1985. In
that event, EPA  will issue
guidelines for States to change
implementation plans.
    EPA's policy with respect
to emissions from tall stacks
is currently being rewritten as
the result of a judicial chal-
lenge. New regulations may
require further tightening of
current emission limits  on ex-
isting sources, changing im-
plementation plans in some
States, and revising certain
new source permits.
    Performance standards for
sulfur dioxide emissions from
new or extensively modified
industrial boilers are sched-
uled to be proposed in the Fall
of 1985, although EPA is cur-
rently under litigation to issue
these standards more quickly.
The evaluation of the standard
for new or modified utility
boilers is just getting under
way. EPA will continue to re-
solve formal petitions under
the Clean Air Act involving
interstate problems.
                                                                                                                       27

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Airborne  Lead
 Lead is a heavy metal that
 presents serious health and
 environmental threats. Lead
 can irreversibly damage the
 brain and kidneys and impair
 the circulatory and nervous
 systems. Once inhaled, ap-
 proximately 25 to 50 percent
 is retained in the body.
 Fetuses and children under
 five are acutely sensitive to
 lead poisoning. Since their
 nervous systems are still de-
 veloping, they risk brain dam-
 age and retardation if exposed
 to too much lead.
    About 80 percent of the
 lead in the ambient air comes
 from leaded gasoline used in
 motor vehicles; the rest
 comes from stationary sources
 including lead smelters and
 battery plants. The lead prob-
 lem is most severe near lead
 smelters.
In the early 1970's, EPA re-
quired oil companies to re-
duce the amount of lead in
gasoline. In 1975, when new
cars with catalytic converters
had to use unleaded gasoline,
the use  of leaded gasoline de-
clined even more sharply.
    As a result of the de-
creased  use of leaded gasoline,
violations of the air quality
standard for lead have drop-
ped. Overall, there was a 64
 Eercent  decrease in ambient
 ;vels between 1975 and 1982
(Figure A-17). A recent survey
found that lead levels in the
ambient air, gasoline, and
blood dropped at similar rates
(Figure A-16). Even so, expo-
sure to lead is still a serious
problem near lead smelters
and in areas where use of
leaded gasoline is still high.
                                                             FIGURE A-16

                                   LEAD IN THE AMBIENT AIR, GASOLINE AND BLOOD HAS DECLINED
Regular
                           Source National Air Quality and Emissions Trends Report, 1982, USEPA
28

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Further progress in reducing
ambient levels of lead is com-
plicated by several factors.

Continued Use of
Older Cars
Because of a tighter economy
and an increase in two-car
families, the average age of
U.S. cars has increased 25 per-
cent since 1970, from 5.5
years to 6.9 years. Because
most older cars were designed
to operate with leaded gaso-
line, elimination of lead emis-
sions from motor vehicles
may be delayed.

Fuel  Switching
The relatively high price of
unleaded gasoline has caused
a large number of motorists to
use leaded gas in cars designed
for unleaded. This not only in-
creases  lead emissions but
also makes the catalytic con-
verters, which are designed to
clean up other criteria pollu-
tants, ineffective.

Industrial Emissions
Most industrial emissions of
lead are from smelting and
processing. Many of these are
old facilities where particles of
lead escape easily through
windows and walls rather
than through smokestacks.
These "fugative" emissions
are hard to measure, monitor,
and control.

State Support
In the belief that reductions in
the use of leaded gasoline
would achieve the ambient
lead standard, some States de-
layed efforts to achieve com-
pliance by lead facilities. A
number of these States fell be-
hind the Clean Air Act sched-
ule for submitting plans to
control these emissions. EPA
is now implementing  a sched-
ule in conjunction with the
States for the completion of
these  plans by the end of Fis-
cal Year 1985.
EPA is developing reports on
the health and environmental
impacts of air pollution from
lead as part of the required re-
view of the current national
standard for lead. Upon com-
pletion of the review, EPA
will reaffirm or modify the
standard, as required by the
Clean Air Act. Final action is
expected in  1986.
    Settlement of litigation
with the Natural Resource
Defense Council over attain-
ment of the lead standards
calls for the completion and
approval of overdue State Im-
plementation Plans. Where
States fail to develop the
necessary plans,  EPA will im-
pose Federal plans including
compliance schedules for
sources whose emissions must
be reduced to achieve the lead
standards.
    In addition,  EPA's Air and
Superfund programs will coor-
dinate efforts to  resolve emis-
sions and lead dust problems
around major smelters and
lead facilities.
    Finally,  with EPA help,
States are completing a 350-
station network  for
monitoring ambient levels of
lead in the air. States are also
developing programs to pre-
vent the illegal use of leaded
gasoline in cars with catalytic
converters.
Source National Air Quality and Emissions Trends Report, 1982, USEPA
                                                                                                                      29

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Airborne  Toxics
 Toxic pollutants are the most
 serious emerging problem the
 Agency faces today. Toxic
 substances are found in all en-
 vironmental media. Attempts
 to remove them from one
 medium often merely transfer
 them to another. Despite their
 low concentrations, toxic
 chemicals emitted into the air
 by industrial processes may
 have serious long-term effects
 on human health and the
 environment.
     Once toxic contaminants
 are emitted from a stack or
 tail pipe, for example, we may
 be exposed to them in a vari-
 ety of ways. The most com-
 mon is by inhalation. Indirect
 exposure may occur after air-
 borne particles fall to earth
 and are taken up by crops, an-
 imals, or fish that we con-
 sume. These particles may
 also contaminate the water
 we drink. Through these
 routes, these substances
 accumulate over time to reach
 quite high concentrations in
 human fatty tissue and even
 breast milk.
     Most information on the
 direct human health effects of
 airborne toxicants comes from
 studies of industrial workers.
 Exposure to these substances
 in the work place is generally
 much higher than in the
 ambient air. We know rela-
 tively little about the specific
 health and environmental
 effects of most of these sub-
 stances at the low levels at
 which they are found in
 ambient air.
     There are many possible
 sources which emit toxic
 chemicals into the atmos-
 phere: industrial and man-
 ufacturing processes, solvent
 use, sewage treatment plants,
 hazardous waste handling and
 disposal sites, municipal
                                 PLAZA
                            CLEAKERS
waste sites, incinerators, and
motor vehicles. Smelters, met-
al refiners, manufacturing
processes, and stationary fuel
combustion contribute toxic
metals such as cadmium, cop-
per, lead, arsenic, chromium,
nickel, and silver. Toxic orga-
nics, such as vinyl chloride
and benzene, are released by a
variety of sources such as
plastics manufacturing plants,
chemical manufacturing,  and
gas stations. Chlorinated di-
oxins are emitted by some
chemical processes and the
high-temperature burning of
plastics in incinerators.
    Figure A-18 shows the
levels of six volatile organic
chemicals found in the
ambient air near their sources
and in urban and rural areas.
Some of these compounds
were found in urban areas at
levels nearly equal to those
found immediately around
plant sites. All six compounds
are now being assessed for
possible future regulation.
Emissions from small stationary and mobile sources, such as dry
cleaners and diesel trucks, make the control of toxics difficult.
30

-------
Source Volatile Organic Chemicals in the Atmosphere  An Assessment of Available Date, USEPA, 1982
                                                                                                                                                                     31

-------
EPA has issued National
Emissions Standards for
Hazardous Air Pollutants
(NESHAPS) under the Clean
Air Act for four hazardous air
pollutants: asbestos, beryl-
lium, mercury, and  vinyl
chloride. National emission
standards for three more toxic
pollutants, benzene, arsenic,
and radionuclides, have been
proposed, and EPA is assessing
risks and control options on
many additional chemicals.
    Many State and local air
agencies are developing their
own programs for toxic pollu-
tants. Some  have addressed a
large number of pollutants
and, with EPA's help,  are im-
proving monitoring  tech-
niques to measure these pollu-
tants in the  environment. EPA
also works with State or local
agencies to investigate partic-
ular problems.
Risk Assessment
With improved scientific tech-
niques, EPA can identify en-
vironmental contaminants at
very low concentrations. Con-
ducting a scientific assess-
ment of the risk of these sub-
stances and deciding how to
manage these risks usually in-
volves very complex and con-
troversial scientific and policy
issues. For  example, because
of the number of assumptions
involved, scientists often dis-
agree over the risk assessment
for a substance. Beyond this
are additional issues  con-
cerning what exposures are ac-
ceptable from a health and en-
vironmental perspective and
the social and economic costs
and benefits of control.

Meaningful Involvement of
the Public
EPA wants to be sure the pub-
lic is informed about the
issues and  uncertainties in the
risk management process and
to involve  interested and
affected citizens in evaluating
possible options to the
greatest extent possible. Be-
cause of the highly technical
nature of the issues,  it is often
difficult for citizens to partici-
pate without special effort on
EPA's part.

More Potential Sources
Economic growth in the
chemical industry during the
next ten years is expected to
outpace the average of all
other industrial  growth. This
will probably mean more new
plants in States where the
chemical industry is already
concentrated — California,
Texas, and New Jersey. With-
out adequate control of emis-
sions, this  growth may in-
crease the  range and quantity
of toxic substances released  to
the environment.
One of EPA's highest priori-
ties is to solve the growing
national problem or air toxics.
EPA intends to move aggres-
sively under the Clean Air
Act authorities and  to assist
State and local governments
as they develop their own
programs.
    Specifically, EPA will
continue to promulgate and
enforce National Emission
Standards for Hazardous Air
Pollutants (NESHAPs) for sig-
nificant sources of air toxics.
By late 1985, EPA will decide
whether 20 to 25 substances
currently under review will re-
quire regulation as hazardous
air pollutants. The Agency
will be involving the public in
these complex decisions
through information work-
shops, hearings, and other
means. Because the NESHAPs
process is cumbersome and re-
source intensive, during 1984
EPA will evaluate alternative
approaches to controlling air
toxics.
    In a related study, EPA
will examine ways to improve
its health and exposure assess-
ments. Specifically,  EPA in-
tends to make better use of
analytical tools such as pollut-
ant dispersion modeling and
analyses of the intermedia
transfer of pollutants.
    Another very high priority
for EPA is to increase com-
pliance with emission stan-
dards, especially with stan-
dards for volatile organic com-
pounds (VOCs). EPA's recent-
ly developed Compliance
Strategy for Stationary Sources
of Air Pollution defines how
EPA will work with States to
improve industries' com-
pliance. Bringing sources of
volatile organic compounds
into compliance should reduce
both ozone levels and poten-
tial air toxics emissions.
    EPA will also work  to ex-
pand and improve long-term
air toxics monitoring pro-
grams including those op-
erated primarily by State and
local agencies. This work will
focus on consistent sampling
and measurement techniques
for toxic air pollutants. To en-
sure compatibility and ready
access to data, EPA will devel-
op criteria for monitoring net-
works and data handling sys-
tems that could be used by
State and local programs as
well.
     The Agency is trying  to
integrate its approach to tox-
ics. We must coordinate our
regulatory efforts and avoid in-
advertently shifting problems
from one medium to another
or from one geographic loca-
tion to another. An integrated
approach is essential to  man-
aging cross-media toxic  sub-
stances problems.
32

-------

                                          (
                      ace operated t>% the public
r?-.M#*ti&*
                           ttouefe
                            benets of c(m-
                                        te~
                               iwofc ofr azas-
                           fa  oj air and water.
                             complete, the OsMP
                            insights feto both
                                       and the

                                            33

-------
Acid  Deposition
 EPA and State environmental
 officials in many parts of the
 country report that acid depo-
 sition is a serious environ-
 mental concern now or is
 likely to be one in the future.
 Whether acid deposition pre-
 sents a serious problem in a
 given area depends on two fac-
 tors: the degree of acidity of
 the deposition itself and the
 ability of the land or water to
 neutralize it. Ohio,  for ex-
 ample, has some  of the most
 acidic (i.e., lowest pH value)
 precipitation in the country,
 but its soil also has a high
 ability to "buffer" it. New
 England soils, on the other
 hand, have very low buffering
 capacity (Figure A-19).
     Surface waters, soils, and
 bedrock which have a rela-
 tively low buffering capacity
 are unable to neutralize the
 acid effectively. Under such
 conditions, the deposition
 may increase the acidity of
 water, reducing much or all of
 its ability to sustain aquatic
 life. Forests and agriculture
 may be vulnerable because
 acid deposition can leach nut-
 rients from the ground, kill
 nitrogen-fixing micro-
 organisms that nourish plants,
 and release toxic  metals.
     The process of acid depo-
 sition begins with emissions
 of sulfur and nitrogen oxide
 gases which interact with sun-
 light and water vapor in the^
 upper atmosphere to form
 acidic compounds. During a
 storm, they fall to earth as
    Source The.National Atmospheric Deposition Program and the Canadian Network for Sampling Precipitation
acid rain or snow. Alternative-
ly, they may join dust or other
dry airborne particles and fall
as "dry deposition." When
pollutants are emitted through
tall stacks, they rise high into
the atmosphere and form
acids which may fall in the
immediate area or stay air-
borne for a long time,
travelling hundreds of miles
across county,  State, and even
national boundaries.
    In the East, the majority
of the acidity in precipitation
is from sulfur dioxides. In the
West, a greater proportion is
from nitrogen dioxides. Sulfur
dioxide is primarily the result
of the burning of fossil fuel.
High-temperature burning from
both stationary and mobile
sources produces nitrogen ox-
ides. Ozone and other ox-
idants also may encourage the
formation of acidic materials.
    Acid deposition is be-
lieved to pose little direct risk
to human health. Although
the inhalation of acid fog may
present some health threat,
the typical acidity of acid rain
can be well tolerated by
human skin and intestinal
tracts.
34

-------
Acid deposition involves a
number of air contaminants
already regulated by EPA and
the States under the Clean Air
Act. However, acid deposition
can occur even when current
clean air standards and emis-
sion limits are met. The prob-
lem poses extremely difficult
scientific, economic, and poli-
tical issues.
    Federal research activities
on the effects and extent of
acid deposition are coordi-
nated by the National Acid
Precipitation Assessment Pro-
gram initiated in 1980. This
program incorporates the
Federal Interagency Task
Force on Acid Precipitation,
Northeast Acid Rain Task
Force, and the cooperative
Southern Blue Ridge Province
Study. Working with the Ten-
nessee Valley Authority, the
Blue Ridge study is particular-
ly interested in the effects of
acid ram in warm climates.
    EPA and other scientists
are reviewing data from
monitoring networks such  as
the Great Lakes Air Deposi-
tion study and the National
Atmosphenc Deposition Pro-
gram. The National Academy
of Sciences is reviewing the
acidification of surface waters
and will recommend addition-
al research to understand this
process.
    An interagency research
program is working on the
problem of damage to our
forests. EPA is sponsoring
joint meetings and field
observations by European and
American scientists to develop
and test hypotheses to explain
the mechanisms of forest
damage.
    EPA is initiating field
tracer studies to understand
the complex meteorology of
long distance pollutant trans-
port. Efforts are also under
way  to characterize the com-
plicated sequence of chemical
reactions by which sulfates,
nitrates, oxidants, and other
pollutants are formed in the
atmosphere. Improved under-
standing of meteorology and
chemistry and more sophisti-
cated atmospheric models will
help  EPA assess alternative
control strategies.
    Congress has also been
wrestling with the acid depo-
sition issue. Proposed
approaches range from in-
tensified research to requiring
certain industries, most not-
ably  electrical utilities, to re-
duce sulfur dioxide and nit-
rogen dioxide emissions by as
much as 12 million tons a
year  nationwide.
 The level of scientific and eco-
 nomic uncertainty concerning
 acid deposition must be re-
 duced before we can make
 sound public policy decisions.

 Scientific Uncertainty
 Any acid deposition control
 program will represent a ma-
 jor environmental, economic,
 and social investment for this
 country. Knowledge of how
 and where to target that pro-
 gram, how big to make it, and
 what to expect from it will be
 crucial  to assure that our in-
 vestment is wisely made.

 Cost of Controls
 Any control program will be
 costly. Before large sums of
 money are  committed to con-
 trols, we should have as clear
 a picture as possible of what
 we are getting for this in-
 vestment. Our research pro-
 gram under the National Acid
 Precipitation Act  is aimed at
 closing  the gaps in our
 understanding.

Regional and International
 Conflicts
This issue has been and re-
mains a most divisive one.
More than any other pollution
problem, acid rain has the
potential for dividing us along
regional and international
lines. To solve it,  we must all
approach the problem with
goodwill and a recognition of
the legitimate concerns of
people in every section of this
country and Canada.
The Administration is
requesting a total of $127 mil-
lion in Fiscal Year 1985 to
deal with acid rain. Of this,
$55.5 million will go to an
interagency research effort ad-
ministered by EPA, the De-
partment of Agriculture, and
National Oceanic and the
Atmospheric Administration.
The balance will go to re-
search on control technology
and ways to reduce the dam-
age caused by acid deposition.
    Planning has been com-
pleted for a survey of some
two to three thousand lakes in
sensitive areas. This National
Lakes Survey will begin in the
Fall of 1984 and provide in-
formation on the extent of
acid rain damage in lakes and
watersheds.
    A national trends net-
work to monitor wet deposi-
tion will be expanded in the
next few years. We are also
developing a monitoring net-
work for dry deposition. These
efforts should give us a much
better idea of the nature and
extent of total deposition and
eventually reveal long-term
deposition trends.
   The Interagency Task Force
plans to produce formal re-
ports based on the acid deposi-
tion research program in 1985,
1987, and 1989. Knowledge of
the deposition problem will
increase our ability to de-
termine the need for and
select effective controls.
                               Tall stacks disperse Sulfur Dioxide
                               high into the air.
                                                                                                                      35

-------
WVTER

-------
When EPA was established in
1970, the Nation was painful-
ly aware of water pollution.
For example:
• The Izaak Walton League
described the Willamette Riv-
er in Oregon as a "stinking
slimy mess, a menace to pub-
lic health, aesthetically
offensive, and a biological
cesspool."
• In the Nation's capital,
huge mats of smelly, floating
algae clogged the Potomac
River.

• Escambia Bay, East Bay,
Pensacola Bay, and Santa Rosa
Sound, Florida, were so pol-
luted that fish kills were
measured in terms of square
miles of dead fish.
    During the years since
Earth Day, individual citizens,
businesses, industries, and
governments have achieved
important successes in
restoring water quality. Sport
fishermen again line the
banks of  the Willamette, the
Potomac has raft races, fishing
derbies, and waterfront festi-
vals, and rather than square
miles of dead fish, shrimp and
oysters are back in Pensacola
Bay. Yet, in contrast to the
many dramatic water quality
successes, many of our Na-
tion's lakes and streams are
still too polluted for fishing or
swimming.
    This chapter begins with
an overview of the Nation's
approach to controlling water
pollution and describes the
progress achieved so far. The
rest of the chapter is about
the six most significant prob-
lems facing the Nation's wa-
ters and EPA's plans to ad-
dress those problems.
                                                                                       41

-------
                           AN   OVERVIEW
                            The Environmental Protection
                            Agency, in partnership with
                            State and local governments,
                            has responsibility for water
                            quality in three areas. The
                            first is reducing pollution of
                            surface waters, i.e., rivers,
                            lakes, streams, coastal waters,
                            oceans, and sensitive areas
                            such as wetlands and es-
                            tuaries. The second is pre-
                            venting contamination of
                            ground waters, i.e., under-
                            ground formations of saturated
                            rock and sand. The third is
                            maintaining the purity of
                            drinking water, i.e., the sur-
                            face and ground waters needed
                            for human consumption.
                                Congress has given EPA
                            and the States broad authority
                            to deal with toxic and con-
                            ventional water pollution. The
                            principal law  is the Clean
                            Water Act (CWA). In 1972,
                            the CWA set  as a goal "the
                            restoration and maintenance
                            of the chemical, physical, and
                            biological integrity of the Na-
                            tion's waters." The law man-
                            dated a variety of new pro-
                            grams to reduce the volume of
                            pollutants entering surface
                            waters. Congress also set an
                            interim goal of achieving,
                            where possible, water suitable
                            for fishing and swimming.
                                To protect the marine en-
                            vironment from the harmful
                            effects of ocean disposal, Con-
                            gress passed the Marine Pro-
                            tection, Research, and Sanc-
                            tuaries Act. The Act es-
tablished a program to ensure
that ocean disposal is con-
ducted according to carefully
drawn environmental criteria.
    No Federal law directly
addresses ground-water quality
or establishes objectives or
goals for managing ground
water or the contaminants
that can pollute it. Several
Federal laws, however, cover
specific sources of ground-
water contamination. These
include:

• The Safe Drinking Water
Act to protect underground
sources of drinking water
from fluids injected into  the
ground.

• The Resource Conservation
and Recovery Act (RCRA) and
the Comprehensive Environ-
mental Response, Compensa-
tion, and Liability Act (known
as CERCLA or "Superfund")
to prevent  ground-water con-
tamination from active and
abandoned hazardous waste
facilities.

        FIGURE W-l

     MAJOR CAUSES
 OF STREAM POLLUTION
   (for 200,000 miles of streams
  not meeting their designated uses)

Industrial
      Other / unknown
• The Federal Insecticide,
Fungicide, and Rodenticide
Act (FIFRA) to control the
production and use of agricul-
tural and other pest control
chemicals.

• The Toxic Substances Con-
trol Act (TSCA) to review new
chemicals before they are in-
troduced into commerce and
control the public health and
environmental risks of ex-
isting chemicals.

    EPA's approach to the
problem of contaminated
drinking water focuses on pro-
viding safe water to users of
public water systems. Under
the Safe Drinking Water Act
(SDWA), EPA sets national
standards for drinking water
and requires routine
monitoring  to ensure that
drinking water is free of harm-
ful levels of contaminants.
    For this report we divide
the pollutants that affect these
waters into  two major groups:
"toxic" and "conventional"
pollutants.

• Toxic substances include
heavy metals, such as mer-
cury and lead, and organic
chemicals, such as PCBs, sol-
vents, and pesticides. Many
toxic substances do not break
down readily in the environ-
ment and, once released, are
very difficult if not impossible
to control. Toxic substances
produce a variety of serious
human and  environmental
problems, even when present
in water in very small
amounts. Control of toxic pol-
lutants is an expensive, com-
plex, and highly controversial
problem.
                                                            Nonpoint Sources

                                                         Source America's Clean Water, Association
                                                         of State and Interstate Water Pollution Con-
                                                         trol Administrators, 1984
42

-------
•  Conventional pollutants in-
clude organic waste, sediment,
acid, bacteria and viruses, nut-
rients, oil and grease, and
heat. The effects of these pol-
lutants vary. In high con-
centrations, some of these are
also "toxic." Some, such as
organic wastes and nutrients,
consume dissolved oxygen,
making water unsuitable for
fish. Others, such as sediment
and oil and grease, cloud the
water, choke fish gills, and
smother bottom habitats and
egg deposits. Bacteria and
viruses can become serious
threats to public health.

    One  of EPA's key jobs to
control these pollutants is to
prepare "criteria documents"
to set water quality standards.
A  criteria document sets forth
what amounts of a pollutant
are safe for human health and
aquatic life based on the latest
scientific information. States
use them to establish the
necessary water quality stan-
dards, e.g. the criteria that a
stream must meet in order to
support its desired use.  For
example,  Vermont wants a
stream to meet the "use" of a
spawning areas for brook
trout,  salmon, rainbow trout,
and brown trout. The dis-
solved oxygen criteria docu-
ment prescribes that seven
milligrams per liter of dis-
solved oxygen must be present
for a "cold water fishery/
spawning area," the appropri-
ate use designation for these
type of fish. Together the use
and criteria are the water
quality standard. These water
quality standards are used to
 determine whether current
 controls are protecting water
 quality and serve as a bench-
 mark to determine what level
 of additional controls are
 needed.

 SOURCES OF THE PROBLEM
 AND EPA'S APPROACH
     The job of cleaning and
 protecting the Nation's water
 is made complex by the vari-
 ety of sources of pollution. In
 general, water quality prob-
 lems are caused by one of four
 major categories of pollution
 sources: municipal, industrial,
 nonpoint, and dredge and fill
 activities (Figure W-l). Occa-
 sionally a stream or ground-
 water aquifer is affected by
 only one of these sources.
 More often, it is a combina-
 tion of these sources that pol-
 lute streams, lakes, coastal
 areas, or ground water.

 Municipal
 Municipal wastewater pri-
 marily consists of water from
 toilets and "gray water" from
 sinks, showers, and other
 uses. This wastewater which
 runs through city sewers may
 be contaminated by organic
 materials, nutrients, sediment,
 bacteria, and viruses. Toxic
 substances used in the home,
 including crankcase oil, paint,
 household cleaners, and pesti-
 cides, also make their way in-
 to sewers. In many towns, in-
 dustrial facilities are hooked
 into the municipal system and
 frequently discharge toxic
 metals and organic chemicals
 into the systems.  Sewage is
 sometimes combined with
 storm water from downspouts,
 streets, and parking lots.
    Municipal pollution can
be controlled by properly con-
structed and maintained
household systems and, where
necessary, by the construction
and operation of sewage treat-
                                                        43

-------
ment plants. Toxics dis-
charged by industry are con-
trolled by "pretreating" in-
dustrial wastes before they are
discharged into municipal
sewers. The Clean Water Act
mandated a program of Feder-
al grants to share the cost of
sewage treatment plant con-
struction with States and local
governments.
    The CWA also es-
tablished a program to issue
permits to every facility that
discharges waste into water,
including all sewage plants.
The permits, under the
National Pollution Discharge
Elimination System or
NPDES, establish the amount
of each pollutant that the
plant may discharge based on
national effluent limits or,
where necessary, the quality
of the water. (See highlight on
NPDES.)
    A by-product of these
water pollution controls is
sludge, a dense, mudlike
material made up of the pollu-
tants removed from the water
and the bacteria used in the
treatment process. Appropriate
disposal of sludge is a serious
problem for many cities. (See
section on Municipal Sludge.)

Industrial Sources
    The use of water in in-
dustrial processes, such as the
manufacturing of steel or
chemicals, produces billions of
       What Is a
       jwarf* in       fy

                                 .
                                        fet-
             afBSt'-iwwBfffym fit
            w ysot&' Them «tte
                       '
       permits,
      *4
       limitations and monitoring and  _ *
       reporting feq^etymts. Effluent limita-
       tions aie restrictions titt ta&aaHwsgtFQf
              pollutants, that a. facility can
              to monitor the effluent go a .
       fwfy* wseejrif, cr monthly baste. The
       IB 'At tgtog tesults ate to«J fn^ajotfy te-
            t to As £F4 and State flHrf»«rW«s.
             A M&ibaigei f4$l$ to cozaply with
             fa«?» iauattips aud monMoattg
           aborting -xeqaatisamte. W~A or the
                   e mfcFcoateaJt oettoa.

       Developed}
       •Co&ffess rea^nfezrf that ft woaW b» an
       operw&fibttERy tesft fat BA4 ta establish
       effluent limitations for each individual
      ' industrial and municipal discharger.
               «» Congress aatiharizgd tm ,
               to develop amform effimnt
                 fat eadi ca^gatj ofpoiat

                                tti
                 What Are Water
                              „  ~
                iota me smam,         ,_„__„
                Jgvds Jmmful to ftsh^,              ; •
                facilities on that stream must meet    i
                more stringent treatment
                known as w$t& quality-based h'mita-
                titm$< T^e^tmina&^^^M^i^^' .
                control the pollutants covered by each
                facility's NPDES permit.  '  ";.,   ^*,  '•'  •'
gallons of wastewater daily.
Some industrial pollutants are
similar to those in municipal
sewage but often more con-
centrated. Others are more ex-
otic and include a great vari-
ety of heavy metals and syn-
thetic organic substances. In
large enough dosages, these
pollutants may present serious
hazards to human health and
aquatic organisms.
    Industrial water pollution
control also relies mainly on
enforcing NPDES permits.
Many industrial permits are
now being revised in a
"second round" of permits to
better control toxic substances
in their discharges.

Nonpoint Sources
"Nonpoint sources" refer to
multiple, diffuse sources of
pollution as opposed to a
single "point" source such as
a discharge pipe from a fac-
tory. For example, rainwater
washing over farmlands and
carrying top soil and chemical
residues into nearby streams
is a major nonpoint source.
The primary nonpoint sources
of pollution include water
runoff from urban areas and
from farming, forestry,
mining, and construction
activities.
    By volume, the major pol-
lutant from nonpoint sources
is sediment. Runoff may also
carry oil and gasoline, agricul-
tural chemicals, nutrients,
heavy metals, and other toxic
substances, as well as bacteria,
viruses, and oxygen-
demanding nutrients.
    Due to the variety, scope,
and complexity of water
pollution from point and non-
point sources, Congress au-
thorized EPA to award grants
44

-------
for State and local programs to
develop water quality man-
agement (WQM) plans. These
plans identify water pollution
problems and the appropriate
control programs including
controls for nonpoint sources.
EPA has approved over 200
State and local WQM plans.
State and local governments,
along with EPA; now are
refining and updating these
plans to meet our water quali-
ty goals.

Dredge and Fill Activities
When waterways are dredged
to make  them wider or deep-
er, the dredging churns up
bottom sediments and other
pollutants,  such as PCBs and
heavy metals, which are
bound to the sediments.
These resuspended pollutants
thus get a new chance to pol-
lute the environment. More-
over, when dredged materials
are dumped onshore, they can
seriously harm sensitive
wetland areas such as
swamps,  bogs, and coastal
marshes.
    The Federal program to
regulate the discharge of
dredge or fill material in
United States waters is jointly
administered by EPA and the
U.S. Army  Corps of Engineers.
In this program,  EPA encour-
ages careful consideration of
alternative  sites and methods
to mitigate the effects of
dredged or fill material on
wetlands or open waters.

PROGRESS TO  DATE
Overall, the national strategy
to restore and maintain water
quality is working. EPA and
States' actions are reducing
the volume of pollutants
going into the Nation's wa-
ters. As a result, many
streams, lakes, and rivers have
shown dramatic im-
provements. In spite of these
accomplishments, however,
the goals of restoring and
maintaining water quality for
fishing and swimming are still
                                          ACTION
                                               thebioaccurnulationaf
                                               toxic contaminants
                                                       '
                                               cieased~throu$out:the    ,
                                               versify and abundance of b
                                               isms have declined as a result of the
                                                                        *        '
                                                                                  • '> •
                                                    md
                                                                    "
                            i one of the most    ting four major
       vivid examples in the country of the
                                               tectthewater quality and hvrng re-   .
                          al point sources.
                                                              sources.

                                                               ment, and eve
        •*.  .,,,«•--•>.,- MVJ---- JJtAl6?*  '"S^etM^-  '    '. •' -  --••
        the water and sediments. Evidence of    .this unique national resource.
not met in many bodies of
water. Furthermore, the quali-
ty of ground water and extent
of toxics pollution remain
largely unknown.
Surface Waters
Clean Water Act programs
have generally been effective
in reducing the volume of pol-
lutants entering the Nation's
waters.

• Industrial pollution has
been reduced significantly
since 1972. Biochemical ox-
ygen demand (BOD), the
measure of organic materials
that deplete the dissolved ox-
ygen in. water, has decreased
71 percent. Total suspended
solids,  such as soil particles,
dropped 80 percent; dissolved
solids,  52 percent. Oil and
grease fell 71 percent; phos-
phate, 74 percent; and heavy
metals, 78 percent.
                                                                                                                   45

-------
•  Municipal sewage treat-
ment plants now remove
13,600 tons a day of sus-
pended solids and BOD, an in-
crease of 65 percent from 1973
levels. The Clean Water Act
requires that most publicly
owned sewage treatment
plants meet "secondary treat-
ment" levels, i.e., remove at
least 85 percent of several key
pollutants or whatever level is
necessary to meet the local
water quality standard. In July
1977, 37 percent of the plants
which were needed in 1972 in
order to meet this goal had
been built; by June  1983 that
figure almost doubled, to 69
percent.

•  In the last decade, the pop-
ulation served by sewers grew
by 18 million and the average
water flow increased by
almost 7 billion gallons a day.
Because of better treatment
methods, the amount of pollu-
tion discharged into the water
from sewage treatment plants
has stayed  about the same in
spite of this increased
demand.

•  Pollution control equip-
ment designed to remove con-
ventional pollutants does a
better than expected job of
removing toxics, especially
toxic metals. The construction
of sewage treatment plants
and industrial controls has
markedly helped reduce the
amount of toxic pollutants
discharged into water.

    The best measure of prog-
ress, however, is how well we
have achieved the water quali-
ty goals of the law. State and
Federal data indicate that our
water pollution efforts have
made significant headway to
restore or protect water
quality.
    In 1983, the Association
of State and Interstate Water
Pollution Control Administra-
tors (ASIWPCA),  under a
cooperative agreement with
EPA, worked with the States
to assess progress in pro-
tecting surface waters. The
States looked at the 354,000
miles of rivers for which they
had water quality information
for the entire decade since
1972. They reported that
47,000 miles of streams got
better, 11,000  miles got worse,
and 296,000 miles stayed
about the same. Similar trends
were noted for lakes and
estuaries.
    Another way to assess
water quality is to look at the
extent to  which waters sup-
port their intended use, e.g.,
swimming, sport  fishing, or a
drinking water source. Over
99 percent of the streams
nationwide are designated for
water uses equal to or better
than the "fishable/
swimmable" goal mandated
by Congress. The States re-
ported that,  of the 758,000
miles of rivers assessed in
1982, uses were supported on
488,000 miles, partially sup-
ported on 167,000 miles (i.e.,
some water  quality standards
are met), and not supported on
35,000 miles. The status of
68,000 miles is unknown.
    The States' conclusion
that  the water quality of most
water bodies has stayed the
same or improved corrobo-
rates a study undertaken in
1982 to assess the biological
health of the Nation's rivers
and streams. In this study the
U.S.  Fish and Wildlife Service
and EPA asked State fish and
game officials to estimate the
health and diversity of fish in
each of 1,300 statistically
selected streams.  Each of the
selected streams was ranked
on a relative scale from zero,
for inability to support any
fish, to five, for the maximum
ability to support desirable
fish species. The health and
diversity of the fish communi-
ty is considered to be a good
yardstick of the overall health
of a stream, i.e., it indicates
whether it meets the "fish-
able" goal of the Clean Water
Act.
    The survey found that 67
percent of the Nation's waters
have at least a minimum abil-
ity to support  sport fish or
other fish species of special
concern. Many of the
remaining streams which can-
not support fish do not flow
year-round and, therefore,  are
not likely to be improvable.
The survey further shows  that
the ability of the Nation's wa-
ters to support sport fish pop-
ulations has not changed
much over the past five years.
In 91  percent of waters, this
ability has not appreciably
changed; in 5  percent of wa-
ters it had deteriorated, and in
4 percent it had improved
(Figure W-2).
    Water quality was found
to affect the fish community
adversely in 56 percent of the
Nation's waters. Overall, non-
point sources were found to
affect 38 percent of all waters
and are ranked as major con-
cerns in 19 percent of waters.
Municipal and industrial point
source dischargers are located
on, or have potential to affect,
only about 20  percent of the
Nation's rivers and streams.
However, the  survey found
that over 10 percent of all wa-
ters are adversely affected  by
point sources,  and that in  5
percent of all waters,  point
sources are ranked as major
concerns.
    Most of the available
water quality information re-
lates to water  pollution from
conventional pollutants. How-
ever, in the ASIWPCA study,
officials from 39 States pro-
vided additional information
                                Source "Ground Water Supply Survey, Summary of Volatile Organic Chemical Datj
                                EPA's Office of Drinking Water, January, 1983
46

-------
Source National Fisheries Survey, EPA and the U S Fish and Wildlife Service, 1984
on the effects of toxics on sur-
face water. They reported that
14,000 miles of streams,
638,000 acres of lakes, and
920 acres of estuaries have
known toxic pollution prob-
lems. The National Fisheries
Survey found that the fish
community in approximately
ten percent of all waters were
affected by toxics.

Ground Water
While most ground water
appears to be of good quality,
contamination has been found
in many places from Maine to
California. Several factors
have focused our attention on
ground-water quality:
• Many towns and busi-
nesses, particularly farms, are
using more ground water to
supplement surface water sup-
plies,  particularly in dry spells.

• Ground water is now the
source of drinking water for
about half of all Americans. It
is the sole source for many
communities, especially in ru-
ral areas.
• There has been a significant
increase in well closings due
to toxic contamination.

    EPA's understanding of
the sources and dimension of
the threat to ground water is
limited, but increasing. For ex-
ample, EPA recently surveyed
volatile organic chemicals
(VOCs) in public water sys-
tems which are dependent on
ground water. VOCs are man-
made and are not found natur-
ally in water. Although the
concentrations detected were
generally very low, the extent
of contamination was greater
than anticipated. Detectable
levels of volatile organic
chemicals were found in 20
percent of the small public
water systems (less than
10,000 users) and 28 percent
of larger systems (more than
10,000 users) (Figure W-3).
While low levels of volatile
organic chemicals in ground
water do not definitely indi-
cate a health hazard, some of
these chemicals are highly tox-
ic and may be carcinogenic.
Drinking Water
When the Safe Drinking
Water Act became law, there
was public uncertainty not
only about chemical purity
but also about who provided
drinking water and who was
responsible for its purity. The
Federal Government had reli-
able water quality  information
on only about 19,200 commu-
nity water systems in 1969.
Today more than 59,000  sys-
tems  are known to provide
water on a daily basis.
    More importantly, the
number of systems meeting
monitoring requirements and
water quality standards has
risen  steadily. In 1969, only 15
percent of community sys-
tems  were believed to routine-
ly monitor drinking water for
bacteria that may cause dis-
ease.  By 1982, 70 percent were
doing regular bacteriological
analyses and meeting the
national standard for bacter-
iological contamination.


TODAY'S WATER POLLUTION
CHALLENGES

In the 1970's, EPA sought to
control major sources of "con-
ventional" pollutants, primari-
ly from large point sources
such  as industries and munic-
ipal sewage treatment plants.
Much progress has been made,
but this work is not complete.
    Progress in reducing the
amount of conventional pollu-
tants  from point sources has
meant that other problems,
such as toxic contaminants
and nonpoint sources, have
taken on greater importance
in our efforts to achieve the
goals  of the law. EPA and the
States also are looking more
carefully at problems in
ground water, oceans, and
inland and coastal wetlands.
    The following  are six of
the most significant water
quality challenges of the fu-
ture. The combined attention
of EPA, other Federal agencies,
the States, local governments
and individual citizens will be
needed to address these prob-
lems and achieve the Nation's
clean water goals.
• Ground-water protection.
Contamination of ground
water is potentially the most
serious water problem because
of the difficulty of detecting
and remedying ground-water
pollution after it has occurred.

• Toxics pollution. Although
we have made great strides in
controlling conventional pol-
lutants, the problem of toxics
contamination from in-
dustrial, municipal, and non-
point sources remains a major
challenge.
• Drinking water. Public
health problems related to
drinking water still persist,
particularly in small systems.
Contamination by man-made
organic chemicals may require
new techniques to monitor
and treat drinking water.

• Wetlands. These important
local ecosystems have been
destroyed, almost as a matter
of course, for farming  and
forestry, disposal of waste, and
other land development activi-
ties. Although the economic,
environmental, and aesthetic
value of wetlands is better
understood, losses continue
today.
• Pollution from sewage.
Problems remain in assuring
continuous adequate treat-
ment at existing treatment
plants. Moreover, providing
adequate capacity to handle
population and economic
growth will continue to chal-
lenge government at all levels.

• Nonpoint source pollution.
A combined effort of Federal,
State, and local governments
is needed to help restore and
protect surface and ground
waters degraded or threatened
by nonpoint source pollution.
                                                                                                                    47

-------
WATER
Ground-Water   Protection
 THE

 PROBLEM

 Ground water is a major
 source of water for agricul-
 tural and industrial purposes.
 It is also an important source
 of drinking water. About half
 of all Americans, and up to 95
 percent of those in rural areas,
 rely on ground water as their
 principal source of drinking
 water.
     Withdrawal of ground
 water to meet these needs has
 been steadily increasing. Be-
 tween 1950 and 1980, with-
 drawal of ground water in the
 United States more than dou-
 bled (from 34 to 89 billion gal-
 lons per day). Withdrawals are
 expected to reach 100 billion
 gallons per day  by 1985.
     There also  is evidence
 that ground water is becoming
 increasingly contaminated.
 The most troublesome con-
 taminants include organic sol-
 vents,  such as trichlor-
 oethylene and benzene; gaso-
 line; pesticides  and soil fumi-
 gants;  disease-causing orga-
 nisms; and nitrates. A recent
 study by EPA showed that
 nearly one-third of large pub-
 lic water systems are detect-
 ing the presence of man-made
 chemicals in their ground-
 water supplies.  In addition, re-
 cent Congressional studies
 have indicated that more than
 4,000 private, public, or in-
 dustry wells have been closed
 or affected  by chemical con-
tamination. Many of these
wells served only a few in-
dividuals; some were the pri-
were the primary water source
for entire cities.
    The sources of ground-
water contamination vary from
place to place (Figure W- 4).
Inappropriate waste disposal
may present the greatest
nationwide threat of ground-
water contamination. We now
realize that many types of
waste disposal, such as in-
dustrial and municipal land-
fills and storage lagoons,
pose risks to ground-water
quality. Unfortunately, past
decisions on locating
hazardous waste disposal faci-
lities gave scant consideration
to these consequences.
    For example, in the mid-
1970's, EPA and the States be-
came aware that waste dis-
posal landfills (not just those
receiving hazardous waste)
were creating ground-water
contamination problems. There
are an estimated 93,000 such
landfills in the United States.
The vast majority of such sites
produce liquid leachates,
contaminated fluids that drain
from these areas. Such facilities
can be sources of ground-
water pollution. However, we
have insufficient knowledge of
the specific impacts of these
sites on ground water.
    Similarly, there are about
181,000 surface impound-
ments (e.g., pits, ponds,
and lagoons). Approximately
half are located in areas with
thin or permeable soils, over
ground water currently or
potentially used for drinking
water. Only about seven per-
cent of all sites appear to be
located where they pose little
or no threat to ground water.
    Septic systems, used by
about 29 percent of American
households, also discharge
waste to ground water. In
areas of the eastern United
States,  they are among the
most frequently reported
sources of ground-water con-
tamination. Septic systems
have always been a threat to
ground water from pathogens
and nitrates. Now they appear
to be a source of hazardous
organic solvents as well,
flushed down the drain by
consumers to degrease the
plumbing.
    Other sources may
account for up to two-thirds
of the incidents of ground-
water contamination.  Im-
proper  use of pesticides and
fertilizers, coating of roads
with contaminated waste oils,
use of highway de-icing com-
pounds, leaking underground
storage tanks and pipelines,
accidential spills and "mid-
night dumping," abandoned
wells, over-pumpage, and ex-
cessive drawdowns have all
caused ground-water con-
tamination.
    Many of these practices
go on with little recognition
or concern for their potential
impact on ground-water quali-
ty. The waste contributed
through leakage from  under-
ground storage tanks is es-
timated to be considerable.
For example, as many as 25
percent of the underground
gasoline storage tanks at the
10,000 or more retail gasoline
outlets in the State of Maine
may be leaking. The es-
timated waste which leaks
each year from these tanks is
11 million gallons.
EFFORTS

To DATE

Until the mid-1970's, ground
water was generally viewed as
a self-renewing resource. Since
then, however, we have recog-
nized that the rate of renewal
is being outstripped by the sig-
nificant threats to ground
water by man-made con-
taminants. Because of these
threats, ground-water protec-
tion  has emerged as a major
concern.
    States use a variety of
mechanisms to protect
ground-water quality. These
mechanisms include using
water-quality standards for
ensuring safe drinking water
supplies, requiring a discharge
permit for some types of dis-
charges, or imposing land-use
controls. To deal with con-
tamination  incidents, at least
21 States  have established
cleanup funds. In addition,
nearly 40 States maintain
monitoring networks for de-
termining the general quality
and quantity of ground water
within the State. About the
same number of States active-
ly monitor the ground water
surrounding land disposal faci-
lities for hazardous waste and
known contamination sites.
    Local governments also
have taken  action to prevent
and address ground-water con-
tamination. Through local
zoning, lot sizes have been
regulated in some localities to
prevent intensive residential
or commercial development
over ground-water recharge
areas. Some have set restric-
tions on the density of septic
systems as well. Some areas,
like  Long Island and Cape
Cod, have enacted strict local
control programs to protect
ground water.
    In addition, EPA has be-
gun  to use its authority under
several laws to prevent and
control ground-water con-
tamination:
 48

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                                                         FIGURE W-4

                              A VARIETY OF SOURCES CONTAMINATE GROUND WATER
                                                                                        Surface
                                                                                     impoundment
                                                                                                            Septic
                                                                                                           systems
                                             Spills and        Leaking
                                                dumping    underground
• Under the Safe Drinking
Water Act, EPA and States
protect underground sources
of drinking water and regulate
the underground injection of
fluids. EPA sets "maximum
contaminant levels" and pub-
lishes health advisories for
contaminants in drinking
water, including ground water
used for drinking, hi systems
which obtain drinking water
from ground water, violations
of these standards can indicate
contamination. In addi-
tion, EPA is progressing with
implementation of the Under-
ground Injection Control Pro-
gram. That program will regu-
late activity at approximately
160,000 injection wells.

• Under the Resource Con-
servation and Recovery Act,
EPA has implemented regula-
tions to control disposal of
solid waste and to provide
"cradle to grave" management
of hazardous wastes, including
control of hazardous waste
generators and the transport,
storage, and disposal of those
wastes. All active hazardous
waste landfills now  are re-
quired to monitor ground
water to detect and  evaluate
contamination. These landfills
can be required to correct
ground-water contamination.
• The Comprehensive En-
vironmental Response, Com-
pensation, and Liability Act,
also called "Superfund," es-
tablishes a fund to support
Federal and State actions to
respond to hazardous waste
problems. Of the 546 sites
now proposed for priority
attention, 410 appear to have
caused ground-water problems.
• The Federal Insecticide,
Fungicide, and Rodenticide
Act (FIFRA) allows EPA to re-
strict 01 prohibit the use of
pesticides in places where
they most adversely affect
ground water. A major effort
is under way to review the
impacts on ground water from
previously registered
pesticides.
• Under the Toxic Substances
Control Act, if a chemical has
the potential to contaminate
ground water, EPA has author-
ity to limit certain uses, re-
quire warning labels, and take
other actions to reduce unrea-
sonable risks from these
chemicals. EPA is exploring
the problem of leaking under-
ground storage tanks.

• Under the Clean Water Act,
funds are being provided to
States for water-quality pro-
grams, including ground-water
management programs, hi
addition, sewage treatment
facilities using land applica-
tion techniques are required to
be designed in a way to pro-
tect ground water.

• EPA has a significant re-
search effort devoted to
ground-water protection. In
addition to research on
methods to protect and moni-
tor ground water, EPA is
tracking and measuring pollut-
ants at the point of human ex-
posure. Examples include re-
search on where ground water
is used as a source of drinking
water and determining health
effects associated with various
pollutant concentrations.
                                                                                                                    49

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TODAY'S

CHALLENGES
Identifying ground-water con-
tamination problems, de-
termining what their effects
will be, and cleaning up ex-
isting hazards present unique
challenges.
    Lack of data concerning
health effects has made it dif-
ficult to set standards or
health advisory levels for
many ground-water con-
taminants. Our knowledge of
               specific ground-water sources
               is also sketchy. We sometimes
               do not know the direction and
               rate of flow in a specific aquif-
               er or where it joins nearby
               aquifers and surface waters. In
addition, data that are avail-
able often are not readily
accessible. These problems
may lead to inaccurate assess-
ments of current or emerging
problems and inadequate
        GROUND-WATER
        CONTAMINATION IN FLORIDA
                                                > CHARLOTTE
         The Miami, Port Lauderdale, and
         West Palm Beach metropolitan
         areas are the heart of a major pop-
         ulation and economic center mat
         extends for about 100 miles along
         the Atlantic Coast of Florida. This
         "(Sold Coast" has experienced rapid
         growth since World World War II,
         and development continues at a
         fast pace. In addition to its well-
         known tourism economy and pop-
         ularity as a retirement center, the
         area is also a major h'ght manu-
         facturing center.
           Drinking water supplies for about
         3.5 million people are obtained
         from the highly productive  Biscayne
         Aquifer, a sand/limestone aquifer
         underlying most of the developed
         area. This highly permeable aquifer
         has a thickness of about 50 to 200
         feet and lies immediately below the
         ground surface. The aquifer is
         recharged by rainfall, outflow from
         the Everglades, infiltration of sur-
         face water from numerous drainage
         canals, and wastewater and surface
         runoff discharged directly into the
         ground at numerous locations.
           The aquifer is particularly vulner-
         able to contamination by pollutants
         introduced in the recharge water.
         Any release of pollutants into the
         area environment, such as spills or
         leaks of chemicals, improper
         hazardous waste disposal, or dis-
charge of inadequately treated was-
tewaters, may result in contamina-
tion of ground water and, in some
cases, of drinking water.
  There has been increasing evi-
dence in recent years that some of
the drinking water supplies in the
region are contaminated with sig-
nificant levels of synthetic organic
chemicals. A national screening
survey in 1974 found significant
levels of previously undetected
organic chemicals in various public
water supplies including Miami.
Additional sampling of water sup-
plies in Dade County for organic
chemicals began in 1977 and was
expanded to include Broward and
Pahn Beach Counties in  1981 and
1982. By 1983, public health offi-
cials were concerned about the
level of contamination and frequen-
cy of occurrence of several volatile
organic chemicals. Of about 250
public water supply wells sampled,
nearly 20 percent were found to be
contaminated with one or more
volatile organic chemicals. Most of
the wells sampled were in Dade
County, but observed levels and
frequency of contamination were
similar in Broward and Pahn Beach
Counties.
  These 250 wells represented only
a small fraction of the area's sever-
al thousand public and private
                                               Naples!
                                                Gulf of
                                                Mexico
                                                                                                        Atlantic
                                                                                                         Ocean
                   -West
                   Palm
                   Beach

                   ioea
                   Raton

                 [Lauderdale
                                                                         f Miami
                                                                        .1*
                                                                        laigo
                                                     "Biscayne Aquifer", maximum yield
                                                     7000 giHons per minute

                                                     Shallow, S.W. Florida aquifer, maxi-
                                                     mum yield 2500 gallons fee minute

                                                     Coastal aquifer, maximum yield 1000
                                                     gallons per minute
                                               wells. The presence of volatile
                                               organic chemicals in area water
                                               supplies was thus only partially de-
                                               fined. Sources of contamination of
                                               some wells had been identified, but
                                               in most cases only general con*
                                               elusions could be drawn. In mid-
                                               1983, EPA initiated a more com-
                                               plete study of contamination of
                                               these ground-water supplies. We
                                               have realized that this aquifer
                                               is seriously threatened by
                                               man's activities. This problem will
                                               require a concerted effort to iden-
                                               tify and control the pollution
                                               sources and protect drinking water.
50

-------
efforts to protect ground
water.
    Three major types of
ground-water contamination
sources are (1) storage tanks;
(2) pits, ponds, and lagoons
containing non-hazardous
wastes; and (3) municipal
landfills. To control leakage
from storage tanks, we must
learn a great deal more about
the problem. A number of
States have undertaken an in-
ventory of storage tanks that
may be sources of pollution.
Some States, like Maryland
and California, are establish-
ing design standards and
critena for installing, testing,
and maintaining underground
storage tanks used for
hazardous wastes. In addition,
several major oil companies,
long aware  of their potential
liability, have begun an
aggressive program to replace
old metal tanks and to in-
stitute periodic inspection and
better inventory controls.
    The majority of States
have some type of system of
issuing permits for pits, ponds,
lagoons, and municipal  land-
fills under either State or
Federal authority. In im-
plementing these programs,
however, they have only re-
cently begun to focus on try-
ing to protect ground water.
Some State programs (particu-
larly in New Mexico, New
Jersey, Pennsylvania, and Cali-
fornia) directly control the dis-
charge of wastes to ground
water. However, the level of
effort  to ensure compliance is
quite uneven among the
States.
EPAs

AGENDA

The principal challenge to im-
proving ground-water protec-
tion is to develop an overall
strategy that harmonizes the
implementation of many
Federal, State, and local pro-
grams to protect this critical
resource. One of EPA's
highest priorities in the next
two years is to develop a
ground-water protection strat-
egy and provide the necessary
leadership and assistance to
State and local agencies to im-
plement it.
    EPA is considering a strat-
egy with four major elements:

Support State
Ground-Water Protection
Programs
The States will have the lead
role in planning and im-
plementing ground-water pro-
tection programs. EPA will
encourage the use of existing
grant monies  for the States to
develop ground-water pro-
grams. Funds  will support
efforts to increase the
accessibility and quality of
ground-water  information, de-
velop State action plans, and
design permit systems and
other regulatory programs to
control sources of ground-
water contamination.
Control Unaddressed
Sources of Contamination
EPA will identify the nature,
extent, and severity of ground-
water contamination from
leaking tanks, and consider
developing a national regula-
tory program based on exist-
ing statutes. In the meantime,
EPA is issuing a chemical
advisory on fuel oil tanks and
will work with the States and
with trade associations, such
as the American Petroleum
Institute and the Society of In-
dependent Gasoline Marketers
of America, to negotiate
voluntary steps to reduce con-
tamination.
    EPA  also will decide
whether more comprehensive
Federal control is needed for
unregulated pits, ponds, and
lagoons and landfills. An
ongoing study will identify
and classify impoundments,
survey State control programs,
and recommend any needed
Federal or State controls.

Build More Consistency
Among EPA Programs
EPA will also issue guidelines
under which EPA  regulatory
and other controls would vary
in stnngency according to the
significance of the ground
water to be protected. Several
States now classify aquifers  to
coordinate their own ground-
water protection efforts. EPA
will work with the States to
devise a mechanism to recog-
nize State classification pro-
grams, where feasible, in the
implementation of EPA
programs.
Make Institutional
Changes in EPA to Direct
Ground-Water Strategy
EPA is establishing a new
Office of Ground-Water Pro-
tection at Headquarters and a
counterpart to the new office
in each Region. The Regions'
primary responsiblities will be
to coordinate ground-water
programs carried out under
various statutory mandates
and to provide guidance, tech-
nical assistance, and man-
agement support to the States.
The  Director of the Headquar-
ters Office will work with
other EPA programs and Re-
gions to define EPA and State
ground-water roles, plan for
correction of uncontrolled
sources of contamination,
identify and resolve in-
consistencies among EPA pro-
grams, and learn  more about
the nature and extent of
ground-water contamination.
                                                                                                                   51

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WATER
Toxics  Pollution
THE

PROBLEM
Well closings, restrictions on
shellfish beds, fishing bans,
and condemnations of homes
in Love Canal, New York, and
Times Beach, Missouri, are all
symptoms of the seemingly
pervasive threat  of toxic sub-
stances. While the most
obvious water pollution prob-
lems, such as choked, algae-
coated lakes and rivers, are
due to the "conventional pol-
lutants, " toxics present a less
visible and ultimately more
challenging problem to
control.
    What is a toxic pollutant?
While nearly all of the pollu-
tants we have discussed can
be toxic in certain con-
centrations, we have become
concerned about a number of
pollutants whose effects
appear to be much more in-
sidious, long-term, and effec-
tive in extremely low con-
centrations. These substances
are commonly referred to as
"toxics." Toxic pollutants
may be man-made substances,
such as polychlorinated
biphenyls (PCBs) and DDT, or
naturally occurring sub-
stances, such as  cadmium,
lead, or arsenic. Although the
effects of many of these pollu-
tants are not well known, low
concentrations of some of
these toxic compounds can re-
sult in public health problems
such as kidney ailments, can-
cer, birth defects, and damage
to aquatic life.
    EPA is responsible for de-
fining the levels at which
these pollutants may be harm-
ful and developing controls to
protect human health and the
environment from harmful
effects. This is an extremely
difficult proposition.
    Some pollutants are more
toxic than others. For ex-
ample, the toxicity of copper
to aquatic life is 200 times
that of chromium. Dioxin's
potency as a carcinogen is
1,000 times that of PCBs.
Some pollutants, such as cer-
tain phenols, are not a major
water pollution concern be-
cause they readily disappear or
volatilize into the atmosphere.
Others, like DDT,  can remain
toxic for long periods of time.
    Still others,  including
PCBs, bind to sediments in
the water and may con-
taminate bottom dwelling
organisms such as  clams. The
bottom sediments of the Hud-
son River, New York, and the
Lake Michigan Basin contain
PCBs and metals which in
turn have contaminated fish
and other aquatic life.
                                                          EPA encourages the use of biological methods, such as this test which
                                                          exposes minnows to pollutants to assess the toxicity of waste waters.
52

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    Toxic pollutants can also
affect an ecosystem by elimina-
ting sensitive species. Studies
of the Chesapeake Bay have
shown that areas with highly
toxic sediments support only
worms and a few other
organisms that can survive in
these highly  polluted waters.
Areas that are not as contami-
nated have a rich variety of
different organisms, including
crabs, clams, and oysters.
    While the greatest source
of toxics is municipal and in-
dustrial wastewater, nonpoint
sources are also a major con-
tributor. In agricultural areas,
runoff may contain pesticides.
In urban areas, runoff may be
contaminated with heavy
metals, gasoline, and asbestos.
Hazardous waste disposal
sites, landfill sites, and aban-
doned mines are among other
sources. Another source, yet
to be fully investigated, is the
atmosphere. Attaching them-
selves to small particles of
dust, toxic substances may be
transported far from their
source. For example, high
levels of toxaphene were
found in trout taken from Sis-
kiwit Lake, a small lake lo-
cated on an isolated island in
Lake Superior. Since there are
no other known sources, the
toxaphene must have come
from the atmosphere.
    Toxic CONTAMINATION IN  PUGET SOUND
    The public and the legislature in Washington State re-
    cently became alarmed by reports showing high rates of
    fish abnormalities due to toxic contamination in Puget
    Sound. There is significant concern about potential
    human health effects from eating fish caught in the
    Sound's urban bays and about the long-term effects on
    marine resources.
      A large number and wide range of sources of toxic
    contaminants in the Sound have been identified, in-
    cluding municipal and industrial discharges, surface
    runoff, leachate from nonpoint sources,  and atmospheric
    deposition. Some contaminants also reach the Sound in-
    directly, from rivers and ground water.  Ultimately,
    physical and chemical processes in the  Sound redistri-
    bute contaminants. Where they come to rest is not cer-
    tain, but evidence suggests they are not carried to the
    open sea.  In the past marine water quality data collec-
    tion and pollution control focused primarily on con-
    ventional pollutants. We must now adjust existing pro-
    grams or develop new approaches to gather data and es-
    tablish effective toxic control programs.
      However, because circumstances are forcing im-
    mediate actions by regulatory officials,  decisions must
    be made on the basis of incomplete knowledge. Im-
    mediate questions include:

    • Should fishing be banned in certain areas}
    • Should technology-based National Pollutant Dis-
    charge Elimination System permits be revised with
    stricter limits on toxic discharges to meet water quality
    needs}

    • What additional contaminants should be limited,
    and to what levels}

    • Where should enforcement actions be focused}
    • What criteria should be used to control disposal of
    contaminated sludge}
                             The State of Washington Department of Ecology and
                           EPA officials have joined in a Puget Sound Water Qual-
                           ity Management Program to manage environmental
                           risks in Puget Sound. The plan has two related parts.
                           One is closely focused on urban industrial bays (e.g.,
                           Seattle, Tacoma, and Everett) where high numbers of
                           diseased fish and shellfish have been found and sedi-
                           ments are heavily contaminated. The other part of the
                           program covers Puget Sound as a whole.
                             Top priority has been assigned to Commencement
                           Bay (Tacoma) and Elliot Bay (Seattle). Work to de-
                           fine problems and identify waste sources already is
                           under way in these bays. Work on the Sound as a
                           whole involves assessing existing contaminant levels
                           and discharges and improving methods to predict
                           effects of future activities.
                             Restoring the Sound poses extremely complex scientif-
                           ic, economic, and political challenges.  Only with the
                           combined efforts of EPA, the State, and the citizens of
                           the Northwest will we save this valuable resource for
                           future generations.

                                                    Canada
                              \Bremerton*
                                          PUGET SOUND

                                          • Everett
                                          ) Seattle
                                        fTacoma
                                      • Olympia
                                                     Washington
                                                                                         Oregon
                                                                                                              53

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 EFFORTS

 To DATE

 To understand current and fu-
 ture actions by States and
 EPA to control toxic dis-
 charges, a perspective on past
 efforts is needed. These past
 efforts were based on the 1972
 requirements of the Federal
 Water Pollution Control Act
 that all industries meet dis-
 charge limits reflecting the
 use of the best practicable
 control technology (BPT) by
 July 1, 1977. BPT is generally
 defined as the "average per-
 formance" that could be
 achieved by wastewater treat-
 ment methods available to the
 industry. Since the importance
 of toxic pollutants was not
 fully realized in  1972, these
 BPT limitations  were primari-
 ly aimed at controlling "con-
 ventional" pollutants, such as
 oil and grease.
    Compliance with these
 BPT limitations  now nears 90
 percent. With full compliance,
 EPA foresees nationwide re-
 ductions from 1972 levels of
 four key conventional pollu-
 tants: biochemical oxygen de-
 mand by 69  percent;  sus-
 pended solids by 80 percent;
 oil and grease by 71 percent;
 and dissolved solids by 52
 percent.
    In 1977  the Clean Water
 Act was amended to control
 toxics more aggressively. Con-
 gress required EPA to adopt
 more stringent technology-
 based limitations on certain
 toxic and nonconventional
pollutants. These new require-
Source From EPA testimony before the subcommittee on Environmental Pollution, July 21, 1982
ments were labelled the Best
Available Treatment Econo-
mically Achievable (BAT). Be-
cause of delays, EPA was sued
and put under court orders to
complete BAT guidelines for
65 classes of pollutants. More
than half of the court-ordered
BAT rules are now completed,
and all will be issued by the
end of 1985.
    Best available treatment
will significantly reduce the
discharge of toxics. In de-
termining BAT limits, EPA
found that the less stringent,
best practicable limits (BPT),
though aimed at conventional
pollutants, incidentally re-
duced toxics as well. Figure
W-5 shows reductions of cer-
tain toxics achieved under
BPT treatment requirements.
    More progress is in sight
as BAT limits are incorporated
into individual permits. For
example, iron-and-steel in-
dustry achievement of BAT
will reduce total toxic orga-
nics in discharges by 20 per-
cent and total toxic metals by
60 percent. In addition, EPA is
developing rules to limit the
amounts of toxics an industry
may discharge to a publicly
owned treatment works.
These "pretreatment" regula-
tions will require industries to
treat wastes before discharging
them to a municipal sewage
system.
54

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TODAY'S

CHALLENGES

In addition to the con-
ventional pollutants, the
Agency's water program has
focused primarily on the 65
toxics named by Congress in
the Clean Water Act. How-
ever,  there are hundreds of
other toxic substances in-
troduced into our waters.
Although the Agency has de-
veloped controls for some of
them, far less information is
available on the toxicity of
most of these pollutants.
    We have a limited scien-
tific basis for developing
criteria documents that set
forth the effects of many of
these pollutants on human
health and aquatic life. In
addition, innovations in the
pesticides, pharmaceutical,
and "high tech" industries
often involve new production
processes and raw materials,
and consequently new was-
tewaters. We must make sure
that existing wastewater  treat-
ment methods effectively re-
move these new pollutants.
EPA'S

AGENDA

Implementing monitoring and
control strategies for toxics in
surface waters is one of EPA's
highest priorities for the re-
mainder of this decade. It is
EPA's job to work with the
States and reissue industrial
and municipal discharge per-
mits to incorporate the best
available treatment (BAT)
standards required by the
Clean Water Act. The process
of developing national limits
for industrial categories has
taken several years of difficult
technical and policy analysis.
It required that EPA look at
each industrial category and
choose limits reflecting the
use of best  available treatment
to remove toxic contaminants.
EPA will complete the de-
velopment of national limits
for the court-ordered in-
dustrial categories in 1985.
    In a related effort, the
Agency will assess the need for
additional guidelines to meet
water quality standards. This
may be a special concern for
areas with the "high tech" in-
dustries. Knowing what new
raw materials and products
are involved in these new in-
dustries, EPA will determine
what treatment methods will
be effective.
   EPA recently reiterated to
the States that they must en-
sure that all streams meet
water quality standards  for fish-
ing and swimming with few
exceptions. The Agency and
States anticipate the permits
incorporating BAT require-
ments may not always, how-
ever, protect aquatic life.
from toxics. Where this is the
case, EPA will help States de-
cide how to set more stringent
pollution controls. EPA also
has issued a new policy which
encourages the use of biologic-
al methods to assess the acute
and chronic effects of toxic
discharges.  In some cases, this
policy will  require dischargers
to regularly report on the
effects of their effluent on
aquatic organisms as part of
their permit conditions.
    Other toxic chemical con-
trol activities being pursued
include the dioxin strategy.
(See section on Dioxin). In
addition to  cleaning up sites
known to be contaminated
with dioxin, EPA and States
are monitoring other areas to
determine the extent of dioxin
contamination. Fish tissues
will be examined in this study
to determine whether other
pollutants should be further
studied and controlled.
                                                                                                                  55

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WATER
 Drinking  Water
THE
PROBLEM
 Along with controlling
 ground-water contamination,
 the most significant chal-
 lenges facing EPA and States
 to protect drinking water sup-
 plies are to (1) eliminate
 disease-bearing organisms, pri-
 marily in small water supply
 systems; (2) develop standards
 for toxic contaminants; and (3)
 control  contamination from
 distribution systems.

 Bacteriological Violations
 in Small Systems
 All naturally occurring water
 contains microbes — bacteria,
 viruses, and protozoa. While
 most such organisms are
 harmless, some are pathogen-
 ic. They can cause diseases
 such as cholera, dysentery,
 and giardiasis. Although most
 drinking water now meets
 national standards for bacteria,
 a few systems persistently fail
 to meet the standards.
 Thousands of cases of disease
 from contaminated drinking
 water still occur each year.
 Such contamination occurs
 mostly  in small public water
 supply systems which typical-
 ly rely on untreated ground
 water, unfiltered surface
Drinking water: a precious resource

water, or poorly protected
springs (see Figure W-6).
Microbial contamination con-
tinues to be a concern because
contaminated drinking water
systems can rapidly spread
disease.

Lack of Standards for
Toxics
When the Safe Drinking
Water Act was passed in 1974,
little information was avail-
able on contamination of
drinking water by toxic chem-
icals. Analytic methods, de-
scriptions of drinking water
supplies, treatment  tech-
niques, and costs all had to be
developed before standards
could be set.
    In  the late 1970's, a
group of organic chemicals
called trihalomethanes
(THMs) were the focus of reg-
ulatory attention. These
chemicals, including some
known carcinogens, occur as a
by-product of disinfection to
kill organisms that may cause
disease. In 1979, shortly after
national standards were de-
veloped for trihalomethanes,
attention shifted to volatile
organic compounds (VOCs).
These chemicals are man-
ufactured in billions of pounds
annually. A recent EPA survey
found VOCs in ground-water
sources of drinking water
more frequently than had
been expected.
    Another concern is con-
tamination of drinking water
supply systems across the
country with pesticides.
Although most heavily used
in agriculture and forestry,
these chemicals are com-
monly used in homes and on
construction sites. Recent dis-
coveries of pesticides in
drinking water have made
their detection and control a
high priority.

Contamination in
Distribution Systems
Poorly maintained drinking
water delivery systems — in-
cluding reservoirs, pumping
stations, and distribution lines
— can contaminate clean
drinking water before it comes
out of the tap. Twenty percent
of waterbome disease in the
United States is caused by
pathogens entering water by
way of the distribution sys-
tems. For example, Legionella,
the cause of Legionnaire's Dis-
ease, can breed in water dis-
tribution systems although we
do not know if infection can
occur from drinking water.
Excessive levels of lead from
pipes have been found in
some tap water samples.
    Persistence and regrowth
of organisms in distribution
systems depend on the physi-
cal and chemical characteris-
tics of the water, the age of
the system, the variety of pipe
materials in use, the availabil-
ity of sites suitable for col-
onization, and other factors.
Delivery systems account for
80 percent of the cost of water
supply and problems are ex-
pensive  to correct. However,
correction of contamination
due to faulty distribution sys-
tems is a major consideration
in drinking water im-
provement programs.
 56

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EFFORTS

To DATE
Federal legislation to protect
drinking water dates from the
turn of the century when the
Nation had a larger death rate
from waterborne disease than
it currently has from auto
accidents. In 1974 Congress
passed the Safe Drinking
Water Act because of concern
about contaminants in
drinking water and uneven
State supervision of public
drinking water supplies.
    Regulations under the law
set maximum contaminant
levels (called MCLs) for coli-
form bacteria, turbidity, and a
number of inorganic, organic,
and radioactive chemicals.
These regulations also call for
periodic monitoring of public
water supplies for the speci-
fied contaminants and
notification of water users
when any of the standards are
exceeded. Violations of
drinking water criteria — as
well as of monitoring and
reporting requirements — are
analyzed periodically by State
agencies and EPA.
    EPA also publishes health
advisories to help local and
State officials determine the
health hazard of unregulated
contaminants in drinking
water. This guidance includes
available scientific data and
information on analytical
methods and treatment tech-
niques. State and local offi-
cials use these health advisor-
ies to select measures to pro-
tect public health where con-
taminants for which no MCL
has been established are found
in drinking water supplies.
                                                     FIGURE W-6
                             SMALL SYSTEMS ARE THE MOST FREQUENT VIOLATORS
                                        OF DRINKING WATER STANDARDS
Source A Status Report The National Public Water System Program (May 1982 and 1983), EPA's Office of Drinking Water
                                                                                                                57

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 TODAY'S

 CHALLENGES
 More than 50,000 small drink-
 ing water systems serve 11.4
 percent of the U.S. population
 relying on community water
 supply systems. These sys-
 tems typically have the great-
 est problems with microbial
 contamination. Similiar prob-
 lems can often occur at the
 over  160,000 private wells and
 systems that serve seasonal
 facilities and the travelling
 public. Supervising and
 monitoring such small sys-
 tems is expensive, time-
 consuming work, and States
 commonly assign higher prior-
 ity to systems serving larger
 numbers of people. Thus,
 communities with small
 drinking water systems tradi-
 tionally receive low priority,
and violations, when they do
occur, may go uncorrected.
    The need to monitor
water for toxic organic com-
pounds at extremely low con-
centrations is emerging as an
economic and health issue of
enormous importance. Cost-
effective analytical methods
that are comparatively easy to
use are needed.
    Little information is
available on deterioration of
delivery systems. Preliminary
studies indicate significant
drinking water quality prob-
lems are caused by antiquated
systems that need repairs or
 replacement of pipe networks.
 For example, tuberculation,
 the build-up of rust and other
 by-products of corrosion, is a
 serious problem in older sys-
 tems with metal pipes. These
 build-ups not only reduce
 drinking water quality but
 also restrict capacity, in-
 creasing operating costs and
 interfering with service.
    Rapid population growth
 is generating more and more
 wastes. If not disposed of or
 treated properly, these wastes
 will increase the potential for
 microbial and chemical con-
 tamination of surface and
 underground supplies of
 drinking water. Growth in ru-
 ral areas is likely to further
 strain small supply systems
 that already have difficulty
 complying with the law.
    Safe drinking water de-
 pends on adequate well-run
 drinking water supply and de-
 livery systems. Equally impor-
 tant is preventing pollutants
from reaching drinking water
sources in the first place. Our
 efforts to protect the quality
of surface and ground waters
are instrumental to ensuring
continued supplies of safe
drinking water.
                              Protecting drinking water reservoirs from contamination is essential for
                              ensuring public health.
58

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EPA'S

AGENDA

The centerpiece to the nation-
al safe drinking water program
is the national primary
drinking water regulations.
These regulations set the
"Maximum Contaminant
Levels" for different pollutants
that drinking water systems
must meet.
    EPA is currently revising
these regulations in phases. In
order, EPA will revise the reg-
ulations for (1) volatile organic
chemicals (VOCs); (2) other
organic chemicals (including
several pesticides), inorganic
chemicals, and microbiological
contaminants; (3) radio -
nuclides; and (4) disinfection
practices and by-products.
In the last phase EPA will re-
view the recent trihalo-
methanes regulations.
    The main objective of
EPA and State drinking water
programs is to eliminate per-
sistent violations of micro-
biological  standards. EPA will
Eremote improved treatment
 icilities at small water sys-
tems and stress good opera-
tion and maintenance.  The
Agency will continue to de-
velop less expensive tech-
niques that small systems can
use to control biological
contaminants.
    Where necessary, EPA
and the States will take en-
forcement actions against
violators  of drinking water
standards. First priority will
be given to public health
threats and recalcitrant and
persistent violators.
    One, major effort will be
to improve compliance by
very small systems serving
transient or intermittent pop-
ulations.  As a first step, EPA
will identify the most  critical
systems serving the most peo-
ple or people most susceptible
to disease, such as the sys-
tems at summer youth camps,
hospitals, and restaurants.
                                                                                                                  59

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W\TER
Wetlands
THE

 PROBLEM

 Once regarded as wasted land,
 wetlands now are understood
 to provide irreplacable benefits
 to people and the environ-
 ment (Figure W-7). Wetlands
 provide natural flood-
 prevention and pollutant-
 filtering systems and contrib-
 ute significantly to ground-
 water recharge. Wetlands in
 the Charles River Basin of
 eastern Massachusetts, for ex-
 ample, absorb floods that
 otherwise would cause mil-
 lions of dollars in annual dam-
 age. These wetlands also are
 valued at $17,000 per acre
 each year for their equivalent
 waste-treatment capacity.
     Destruction of wetlands
 also reduces wildlife pop-
 ulations. Many sport fish,
 migratory waterfowl, furbear-
 ers, and other valuable wild-
 life live and breed in wetlands.
 A third of all endangered spe-
 cies depend on wetlands for
 some part of their life cycle.
     Piecemeal destruction of
 U.S. wetlands has destroyed
 slightly more than half of the
 Nation's original resource. Be-
 tween the 1950's and the
 1970's  alone, over 7.6 million
 acres were drained or filled
 (Figure W-8). Over 95 percent
 of this  acreage was inland
 fresh-water wetland; the rest
 was coastal or salt-water
 wetland. Thousands of acres
 are still being filled or drained
 each year.
EFFORTS

To DATE

By law, wetlands are consid-
ered "U.S. Waters" and are
protected like streams, lakes,
and rivers. Under Section 404
of the Clean Water Act, EPA
and the U.S. Army Corps of
Engineers work together to
protect valuable wetlands.
Dumping dredged or fill mate-
rial into U.S. waters is prohib-
ited unless authorized by a
"404 permit" issued by the
Corps. EPA and other Federal
or State agencies review permit
applications and advise the
Corps as to the environmental
effects of proposed activities.
    Where wetlands de-
velopment must be permitted,
environmental losses may be
at least partly offset. For ex-
ample, in Puerto Rico, when
no practical alternatives to
dredging and filling wetlands
can be found, developers must
plant mangroves in new areas
of equal or greater size. In
Green Bay, Wisconsin, build-
ers of an interstate highway
created a wetland for migra-
tory waterfowl to compensate
for one destroyed in the
highway construction.
    The Fish and Wildlife Ser-
vice is creating an inventory
that will classify and map the
Nation's wetland resources.
These maps will identify wet-
lands and help reduce further
losses.
                                                             nursery areas


                                                         into water table
TODAY'S

CHALLENGES

Growth is the greatest threat
to wetlands. Population migra-
tion and urban sprawl are
rapidly encroaching on wet-
lands. Recreational and resi-
dential developers seek to de-
velop attractive coastal islands
and other wetlands. In the
Midwest, farmers want to
drain prairie potholes for agri-
culture. Southern farmers seek
to expand into bottomland
hardwoods, particularly along
                                                         Source Environmental Trends, Council
                                                         on Environmental Quality, 1981
 60

-------
 the alluvial plain of the Mis-
 sissippi River. (See highlight
 on Bottomland Hardwoods.)
 There is a steady and poten-
 tially increasing demand for
 Federally sponsored dredging
 to maintain and deepen navi-
 gational channels.
    Industrial development
 also puts pressures on wet-
 lands. Intensive peat mining
 in eastern North Carolina is
 threatening thousands of acres
 of wetlands. The development
 of freshwater  canal systems in
 Alabama and  Mississippi is
 changing water movement in
 the area upsetting the ecolo-
 gical balance of wetland areas.
 These and other developments
 may be economically valu-
 able, but we pay with the loss
 of wetlands.
    The cumulative impacts
 of numerous small under-
 takings that fill or drain wet-
 lands also are of concern. Each
 action by an individual land-
 owner may not cause great
 harm, but cumulatively they
 add up to sizable net losses of
 wetlands.
    The value of wetlands as
 a unique natural resource is
 not yet widely appreciated.
 This may be the greatest bar-
 rier to preservation of the
 remaining wetlands. Many
 government policies and reg-
 ulations still endorse the con-
version of wetlands. For ex-
 ample, agricultural price sup-
ports, flood insurance pro-
grams, and relatively high
rates of taxation of wetlands
all encourage alternative uses
of wetlands.
EPA'S

AGENDA
Protecting the wetlands
through vigorous attention to
review of Section 404 permits
is at the top of EPA's priority
list for the next two years.
EPA will work closely with
the Corps to improve the
effectiveness of the Section
404 program in protecting the
Nation's aquatic resources.
EPA is currently developing
guidance to clarify the
jurisdiction of the program
and to identify which wet-
lands are most ecologically
important where develop-
mental pressures are
greatest. For example, EPA
has initiated a study of
bottomland hardwood wet-
lands to evaluate the effects of
conversion of this valuable re-
source to agricultural uses.
Similar studies are being
planned to assess the impact
of development on tundra
wetlands in Alaska, prairie
potholes in the Northern
Plains States, and pocosine
(freshwater] swamps along the
Atlantic coast. EPA is
also assessing techniques to
minimize the effects of
wetland losses and the in-
dividual and cumulative im-
pact of placing dredged and fill
material on wetlands.
    Another priority is to trans-
fer permitting authority to the
States. EPA will encourage
more States to develop their
own capability to review pro-
posed 404 permits for wet-
lands conversion. In coopera-
tion with the States,  EPA also
will investigate more effective
means to protect small inland
wetlands, typically small bogs,
marshes, and swamps that
have been casually filled in
the past.
                              A Great Blue Heron
      Botra
      i/^i^^pisi&t^                               H^Sf*

                                                V^f-
      lejr orfto. raer rttt rdftiabfo ^nr t«liiip itwdttng as
      n«tt^ iind fuint&t mea$jrjUBt0Gt^fwatf£ fU^Ktj
      dy acting as AMmel. pll^/ttetet&rf •rtigf jwla-
      tonts; Aod, especially,                   contain
      flood waters mctreatiee So^Mst^aHs diUtaate. Levee
      construction, combined wa'ift dfertriaf «arf ofe-
                of         !fi	*' -' ** ~  "•"•'• -'"
                                           '.arms, ae®                      saw? in-
                                           otef poUutaait
                                    tan? at A®
                                                    eft* ed
                                                           « .- , .,  .     ..,,
                                                                             a&t
                                               Like mria&y' (SdiJf'tffjis ef''wtlfa& earn-
                                    wee&oti' of I^to^^rf JibrfifoMs to,          ais&s
                                    difficult ijuBstims, &fjlaa$     i$« -dSstof Uiaa-HMde
                                    controls^ etad th& btoaA^fm^tgqfiXfOf'^tyizoffami-
                                    to! protection versus Jaii<4» '^litfs of mm&rship.
                                                                                                                 61

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WATER
 Pollution from Sewage
THE

 PROBLEM

 Raw or insufficently treated
 sewage from municipal and
 other wastewater treatment
 plants still threatens fish,
 shellfish, and recreational re-
 sources in many parts of the
 country. Organic matter and
 plant nutrients in sewage
 foster excessive growth of
 algae and other aquatic plants.
 These plants then die and de-
 cay, depleting the dissolved
 oxygen needed by fish. More-
 over, poorly treated
 wastewater may contain bac-
 teria and chemicals toxic to
 both human and aquatic life.
                           Source America'& Clean Water, Association of State and Interstate Water Pollution
                           Control Administrators, 1984
EFFORTS

To DATE

The Congress saw in the late
1960's that local and State
governments needed Federal
help to build sewage treat-
ment plants. Since the 1970's,
more than $40 billion has
been appropriated by Con-
gress. EPA has awarded $37
billion in grants, and State and
local governments have spent
more than $13 billion to build
thousands of treatment plants
and other sewage facilities.
   In 1982, the great major-
ity of the Nation's 224 mil-
lion people were served by
adequate sewage treatment.

• Eighty-three percent, or 186
million people, were served by
sewer plants or on-site sys-
tems providing treatment
equal to or better than levels
required by the Clean Water
Act. Of that total, 142 million
were served by plants pro-
viding the secondary levels of
treatment required by the
Clean Water Act, or better.
This was an increase of 57
million people since 1972.
The remaining 44 million peo-
ple were served by adequate
on-site septic systems.
• Ten percent, or 23 million
people, still were served by
plants or on-site septic sys-
tems providing less than ade-
quate treatment. The number
 62

-------
of people in areas where pub-
lic sewage treatment systems
are needed, but who were not
served by such facilities, drop-
ped 33 percent from 21 to 14
million people.

•  The number of people using
sewer lines that merely dump
raw wastes into streams drop-
ped 60 percent from 5  million
to 2  million in the decade.

    While not yet an un-
qualified success, the program
to build sewage treatment
plants, set discharge limits for
these plants, and enforce these
limits has reversed water qual-
ity deterioration in thousands
of miles of waterways  around
the country. The reopening of
beaches and shellfish beds and
the return of desirable  fish to
many rivers and harbors is
largely due to gains from
these programs. Especially in
areas where population and
industry have grown rapidly,
the construction of sewage
treatment plants has been es-
sential to reduce the amount
of pollution and prevent fur-
ther loss of water quality
(Figure W-9).
 TODAY'S

 CHALLENGES

 Some large cities and rural
 communities still discharge
 raw sewage. Most remaining
 sewage pollution problems,
 however, are a result of sew-
 age that gets inadequate treat-
 ment at existing treatment
 plants. Among the leading
 causes for failures at existing
 systems are overloading and
 poor operation and mainte-
 nance. Toxic substances in the
 wastewater entering the plants
 also remain a source of
 problems.

 Overloading
 Overloading is often a result
 of failure to anticipate the
 needs of growing com-
 munities. The time required
 to adequately plan and con-
 struct additional treatment
 plants may be ten years or
 more. Planning for new treat-
 ment plants must begin long
 before the problems of over-
 loading become obvious. The
 purpose of the Federal grant
 program was to construct
 treatment plants to meet ex-
 isting needs. State and local
 governments must shoulder
 the costs to construct addi-
 tional treatment plants to sup-
 port growing populations.
    Overloading is also a
 problem where storm and
 sanitary sewers are connected
 in one "combined sewer sys-
 tem." During a heavy rain-
 storm,  rainwater runs off city
 streets into sewers and over-
 whelms plant capacity,
 resulting in the discharge of
 untreated sewage.

 Poor Operation and
Maintenance
Poor operation and mainte-
nance leads to breakdowns,
disruptions of treatment, and
untreated or only partially
treated discharges. Although it
was clear from the outset that
                                                                                                                  63

-------
plants built under the grant
program would be operated
and maintained by local au-
thorities, some cities have
been unable or unwilling to
operate or maintain  their sew-
age treatment plants.
    The number of systems
failing to meet the discharge
limits in their  operating per-
mits is considerable. Of the
approximately  3,600 major
treatment plants designed to
handle more than 1  million
gallons per day, over 600 are
not in compliance with their
permit limits.
    Some problems  occur be-
cause municipal systems are
too costly or sophisticated for
small communities to operate.
Some local agencies, lacking
knowledge of operations,
costs, and management, over-
looked simpler, more appropri-
ate technologies. Elaborate
systems often proved too large
and sophisticated for small
communities.

Toxic Substances
Toxic substances passing
through municipal sewage
treatment plants are another
major cause of breakdowns or
poor operation. In many com-
munities, plants without in-
house treatment facilities put
industrial wastes directly into
the municipal system. Some
industrial wastes include
heavy metals and toxic organ-
ic chemicals. Most municipal
sewage treatment plants can
remove 75 to 80% of these
toxics. In some cases, how-
ever, such substances can kill
the microorganisms essential
for the plant's filtering sys-
tems and otherwise disrupt
the plant's operations. This re-
sults in the untreated sewage
and toxics passing through in-
to a waterway. The toxics can
also be retained by the plant's
treatment process and con-
taminate the sludge, ex-
acerbating the problems of
safe disposal of this material.
(See the section on Municipal
Sludge.)
EPA'S

AGENDA

EPA's sewage treatment pro-
gram has initiated many di-
verse approaches to solve the
problems described above. The
following are some of the ma-
jor actions EPA and the States
will pursue in the coming dec-
ade to meet these and other
objectives.

Evaluate the Need for a
Continuous Federal Role
EPA is undertaking a study to
be completed in November
1984 of Federal, State, and lo-
cal roles to achieve ex-
peditious construction of  sew-
age treatment facilities needed
to meet the Clean Water Act.
Congress originally envisioned
the Federal grants program as
a short-term effort to meet the
Nation's need for sewage
treatment plants. It was not
intended to be a permanent
Federal program. Consistent
with this goal, Congress has
reduced the funding level for
construction grants to $2.4
billion annually and made
other changes to reduce the
Federal role. In  1984 EPA will
evaluate alternative financing
for municipal sewage treat-
ment and explore alternative
types of assistance  to local
communities to meet their
water pollution needs.

Direct Federal Grants to
Significant Water Quality
Problems
While the need for a contin-
ued Federal program is being
evaluated, EPA  will work
with States to ensure that
they direct the remaining
Federal grants to projects  that
will contribute  to meeting the
environmental goals of
restoring and protecting water
uses and protecting public
health.
Enforce Against Municipal
Facilities
Enforcement is the keystone
of EPA's strategy to improve
sewage treatment nationwide.
In January 1984, EPA issued a
"National Municipal  Policy."
According to this policy, Re-
gional EPA Offices will work
with State agencies to identify
facilities not meeting pre-
scribed effluent limits and de-
velop plans to  achieve com-
pliance as quickly as  possible.
The annual State grant
negotiation process will be
used to reach agreement on
specific activities to achieve
compliance.

Carry Out the Industrial
Pretreatment Program
EPA, States, and local au-
thorities will require  in-
dustries to provide better "pre-
treatment" of wastes  before
they are sent through public
sewage treatment plants. Pre-
treatment would remove toxic
contaminants that disrupt
sewage plants and are harmful
to people or the environment.
EPA will help  States expand
their water quality analytical
capabilities to  evaluate pre-
treatment systems in light of
water quality and public
health goals.

Improve Sewage Treatment
Plant Operations and
Maintenance
States are to use Federal
grants to continue training for
64

-------
sewage treatment plant op-
erators. EPA will develop
guidelines for improving op-
erations and maintenance pro-
grams and help communities
develop and ensure the finan-
cial capability to build and
operate municipal sewage
treatment works. Training and
assistance will be provided to
States to enable them to eval-
uate community capability to
support wastewater treatment
facilities  and to identify high-
cost, problem projects before
they are constructed.

Provide Incentives for
Construction of
Small-Scale Technologies
For several years, EPA has
provided grant incentives to
encourage construction of
small-scale wastewater treat-
ment projects that involve
simple, less costly technology.
These systems often do a bet-
ter job and are more reliable
than conventional or advanced
systems.  Some systems, for
example, recycle and reuse
wastewater and its nutrients.
Such systems may be suitable
for small communities facing
very stringent limits on pollu-
tion. EPA wants to ensure
that communities have sys-
tems they can afford to oper-
ate and maintain.
    Through States and the
EPA Regional Offices, EPA is
providing information to grant
recipients on what works and
what does not in sewage treat-
ment technology. EPA encour-
ages innovation in sewage
treatment and supports field
testing of promising but un-
proven technologies.
                                                                                                                     65

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WATER
 Nonpoint  Source  Pollution
THE

 PROBLEM

In 1982, virtually every State
reported having some water
pollution problems caused by
nonpoint sources, such as agri-
cultural, urban, or construc-
tion runoff. Approximately
half indicated that nonpoint
sources were major con-
tributors to their water quality
problems. About one-fifth of
the States identified nonpoint
sources as their primary cause
of surface or ground water
pollution.
    Sediment and nutrients
including animal wastes, ferti-
lizers, herbicides, and pesti-
cides transported from farm-
lands by rain and irrigation
water are the most pervasive
nonpoint pollution problems.
Sediment, that is, sand, silt,
clay, and organic materials, is
the largest contributor by
volume to nonpoint source
pollution. It adversely affects
portions of more than two-
thirds of all U.S. river basins.
Excessive sediment clouds the
water and reduces the amount
of light which reaches deeper
water. This reduces oxygen
levels and limits the number
of species of aquatic life
which can survive. Chemicals
such as pesticides and nut-
rients often bind to sediment
particles. Nutrients are also
major pollutants from non-
point sources. While essential
to agriculture, nutrients
stimulate excessive growth of
algae and can seriously deplete
oxygen levels in water.
    Runoff from urban lands
and mines are the next most
commonly reported nonpoint
source problems. Urban
runoff, generally a localized
water quality problem, fre-
quently contains heavy metals
and other toxic substances.
Abandoned mines can  cause
particularly severe impacts, in
some cases resulting in the
devastation of stream life.
Additional nonpoint sources
of localized concern include
forestry and construction.
    Some effects of nonpoint
source pollution are more
noticeable to the general pub-
lic. For example, drinking
water costs often rise because
additional treatment systems
must be installed to remove
sediments and other con-
taminants. In many parts of
the country, dams, lakes, re-
servoirs, and wetlands are
slowly being filled with sedi-
ment. Fishermen notice
shrinking catches, the storage
capacity of these waters is re-
duced, and waters become un-
desirable or unsafe for
swimming and boating.
66

-------
EFFORTS

To DATE

Experts believe that a signifi-
cant portion of nonpoint
pollution problems can be
solved through better man-
agement of activities such as
farming, forestry, construc-
tion, and mining. The Federal
Government, through a num-
ber of agencies, provides tech-
nical and financial help to
State and local agencies to
compile nonpoint source in-
formation and develop control
programs. The U.S. De-
partment of Agriculture, for
example,  has several programs
to control soil erosion and
chemical runoff from farm-
lands. The Office of Surface
Mining at the Department of
Interior is generally respon-
sible for reducing drainage
from mines.
    The Clean Water Act rec-
ognizes that nonpoint source
pollution is best managed at
the State  and local level. EPA
provides grants to assist State
agencies to revise and update
their water-quality man-
agement (WQM) plans. These
plans identify water-quality
problems and necessary con-
trol action. Most often the
plans rely on "best man-
agement practices" or cost-
effective and practical
methods to prevent or reduce
nonpoint  source pollution.
The most common best man-
agement practices are volun-
tary and apply to runoff from
agriculture sources. For ex-
ample, conservation tillage re-
duces erosion by leaving crop
residues on the soil, stream-
bank protection practices re-
duce sediment runoff into
streams, and contour plowing
reduces runoff from sloping
lands. Although most best
management practices are
voluntary, there are a number
of enforceable State laws or lo-
cal ordinances.  For example,
16 States  have enacted laws to
control runoff from construc-
tion sites.
TODAY'S

CHALLENGES

Nonpoint sources present con-
tinuing problems for achieving
national water-quality goals in
many parts of the country.
They are estimated to have a
major impact in as many as
60 percent of our streams and
75 percent of our lakes. The
manner and extent to which
specific nonpoint source prob-
lems are addressed, however,
varies widely.
     For example, although
agricultural nonpoint sources
are a pervasive problem, only
19 States have assistance pro-
grams for best management
practices in agriculture. Addi-
tionally, most of these pro-
grams were originally es-
tablished to  control soil ero-
sion, not to improve water
quality and therefore focus
primarily on where soil ero-
sion is most severe, not where
sediment will have the
greatest impact on stream
quality or use. In addition, few
States have nutrient manage-
ment programs for agriculture.
Recently, some States have
modified their programs to in-
clude water-quality objectives.
    Most solutions to non-
point pollution lie with in-
dividual actions. Because
benefits, such as improved
recreational opportunities,
seem to accrue more to soci-
ety as a whole than to an in-
dividual landowner, control
measures may appear unduly
burdensome to individual
landowners. These benefits,
along with the benefits to far-
mers of reducing soil erosion
or chemical runoff through
better tillage practices, have to
be balanced with the addition-
al cost or inconvenience of
implementing best man-
agement practices.
EPA'S

AGENDA

In a number of areas, the con-
trol of nonpoint sources of
pollution will be necessary to
maintain water quality and
meet the goals of the Clean
Water Act. The sensitive local
land use decisions needed to
implement nonpoint source
controls are best made at the
State and local level. As stated
in the "Report to Congress:
Nonpoint Source Pollution in
the U.S." issued by EPA in
January 1984, Federal pro-
grams should provide advice
on controlling nonpoint
source pollution as part of
technical assistance on soil
conservation, agriculture and
forestry. Federal agencies will
also need to continue to sup-
port research on needed con-
trol methods and disseminate
information on innovative
management approaches.
                             Uncontrolled storm-water runoff from a cornfield
                                                                                                                67

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LAND

-------
LAND
Environmental protection has
historically focused on air and
water pollution. While the
Federal Government has been
involved in protecting wildlife
and other natural resources
since the turn of the century,
it was not  until the 1970's
that there was much public
concern about pollution of the
land. Now contamination of
the land not only threatens fu-
ture uses of the land itself but
also affects the quality of the
surrounding air, surface water,
and ground water. Love Canal
in New York State, the Valley
of the Drums in Kentucky,
and Times Beach in Missouri
are notorious examples of this.
All have been severely dam-
aged by careless disposal of
hazardous waste.
    While these sites are
among the worst, similar
situations across the country
have raised public awareness
of the environmental and
health threats posed by
hazardous wastes. Without
question, the public's top en-
vironmental priorities are to
clean up these problems and
to regulate current hazardous
waste handling to prevent
similar problems in the future.
    EPA is working with
State and local governments
to determine which sites pre-
sent the greatest dangers and
to take appropriate action as
expeditiously as possible. To
prevent a proliferation of prob-
lem sites, governments at all
levels now require newly
generated hazardous wastes to
be treated or disposed of in an
environmentally sound
manner.
    This chapter begins with
an overview of problems in
the generation and disposal of
waste, EPA's approach to
waste management, and prog-
ress achieved so far. The rest
of the chapter describes four
key land disposal problems
facing the Nation and
EPA's plans to address those
problems.
                                                                                71

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                           AN  OVERVIEW
                            More than six billion tons of
                            waste are produced in the
                            United States each year in-
                            cluding agricultural, com-
                            mercial, industrial, and
                            domestic waste. Most waste
                            presents few health or en-
                            vironmental problems. Half
                            the total, for example, is agri-
                            cultural waste, primarily crop
                            residues, most of which is
                            plowed back into the land.
                            Other waste, particularly that
                            from industrial sources, can
                            imperil both public health and
                            the environment.
                                If not properly disposed
                            of, even common household
                            wastes can cause environmen-
                            tal problems ranging from pro-
                            ducing foul-smelling smoke
                            from burning trash to pro-
                            viding breeding grounds for
                            rats, flies, and mosquitoes.
                            Furthermore,  small quantities
                            of toxic substances such as
                            pesticides, paints or solvents
                            may be dumped with house-
                            hold wastes. Even at properly
                            run disposal sites, rain water
                            seeping through the buried
                            wastes may form "leachate,"
                            which percolates down and
                            may contaminate ground
                            water. Other organic wastes
                            such as garbage and paper
                            products decompose and can
                            form explosive methane gas.
                                Industrial wastes may pre-
                            sent particularly troublesome
                            problems. Many components
                            of these wastes such as chlor-
                            inated hydrocarbons may pre-
                            sent serious health or
                            environmental threats by
                            themselves; others are
                            hazardous only in combina-
                            tion with other substances.
                            Potential health effects range
                            from headaches, nausea, and
                            rashes to acid bums, serious
                            impairment of kidney and liv-
                       FIGURE L-l

 6 BILLION TONS OF SOLID AND HAZARDOUS WASTE
       ARE GENERATED IN THE U.S. EACH YEAR
               (Excludes high-level radioactive waste)
  Mining/milling 39.0%
  (includes uranium mill tailing:
              \
 Industrial 6.4%

        Municipal 3.1%

               Utility 1.2%
                                       \
er functions, cancer, and ge-
netic damage.
    Congress enacted several
laws to regulate the genera-
tion and disposal of hazardous
wastes. These laws are aimed
at two basic objectives:
• Proper management and
disposal of wastes being gener-
ated now and that will be
generated in the future.

• Cleanup of sites where the
results of past disposal prac-
tices now threaten sur-
rounding communities and
the environment.
                                        Agriculture 50.3%
      Source EPA's Office of Solid Waste

SOURCES OF THE PROBLEM
AND EPA's APPROACH

Waste is a seemingly inevit-
able by-product of virtually all
activities people pursue in
their daily lives. Every major
sector of the economy con-
tributes. Figure  L-l shows the
six major sources of the waste
generated each year in the
United States.
    The kinds of wastes pro-
duced by these sources and
their effects vary greatly.  As
a result,  the various kinds of
waste need different levels and
types of control. The principal
sources of waste and the
Federal agencies that control
them are discussed below.
72

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Agriculture and Forestry
Of the six billion tons of
waste generated each year,
half is from agriculture and
forestry. The threat posed by
most of this waste is rela-
tively small.  Much forestry
waste is now burned for ener-
gy, and agricultural waste is
mostly plowed back into
fields or burned. Some agricul-
tural wastes, like unused pes-
ticides and empty pesticide
containers, do present special
hazards and are regulated by
EPA.

Mining Wastes
Almost 40 percent of the total
waste generated is from
mining coal,  phosphates, cop-
per, iron, uranium, and other
minerals and from ore proc-
essing and milling. These
wastes consist primanly of
"overburden," the soil and rock
cleared away before mining,
and "tailings," material dis-
carded during ore processing.
Although mining wastes are
generally considered  to present
low hazards,  they can be a
disposal problem because of
the large volumes generated.
Mining wastes  are a  major
source of environmental prob-
lems in most areas with ex-
tensive mining activity.
Runoff from mining  waste in-
creases the acidity of streams
and pollutes them with toxic
metals. Furthermore, the tre-
mendous overburden gener-
ated in surface  mining can
also pose major local manage-
ment problems.
    Some mine wastes are
controlled at the Federal level
by the Department of the In-
terior under the Surface
Mining Control and  Reclama-
tion Act of 1977. With the ex-
ception of specific responsibil-
ity for uranium mill tailings,
discussed below, under Federal
law EPA's primary role is to
identify the potential health,
safety, and environmental
hazards of mining wastes and
determine the need for further
regulation.

Industrial Wastes

Industries are the major
source of hazardous wastes.
However, it is not yet fully
known what portion of the
400 million tons of industrial
wastes generated each year are
hazardous.  A recent EPA
survey of 1981 activities
roughly estimated that
about 290 million tons of
hazardous waste subject to
current Federal requirements
are generated by industry each
year. Although this hazardous
waste is generated by the full
range of major American in-
dustries, the chemical and
petroleum industries account
for over 70 percent of these
290 million tons.
    EPA and the States share
responsibility for management
of newly generated hazardous
waste under the Resource
Conservation and Recovery
Act (RCRA) — a "cradle to
grave" effort covering the
generation, transportation,
storage, treatment, and dis-
posal of newly generated
hazardous waste.
    The Comprehensive En-
vironmental Response, Com-
pensation, and Liability Act
(CERCLA), which established
the Superfund program,  au-
thorizes EPA to act directly to
clean up those sites where
hazardous wastes from aban-
doned or inactive waste sites
endanger public health, wel-
fare, or the environment. It
provides a special fund for
cleanup of uncontrolled
hazardous sites.  A total of
$1.6 billion is currently avail-
able for that work.
Municipal Wastes
Municipal wastes include
household and commercial
wastes, demolition materials,
and sewage sludge. Solvents
and other harmful household
and commercial wastes are
generally so intermingled with
other wastes that specific con-
trol of such materials is vir-
tually impossible. Also,
"leachate" resulting from rain
water seeping through munic-
ipal landfills may reach and
contaminate underlying
ground water.
    Although addressed under
another provision of RCRA,
household  wastes are  specif-
ically exempted from  regulation
as hazardous waste. While
the degree  of hazard presented
by this leachate is often rela-
tively low, the volume pro-
duced is  so great that  it is
being investigated as a possible
contributor to ground-water
contamination.
    EPA under its program to
regulate  non-hazardous waste
does issue  standards and guid-
ance for  such  facilities. It is
then the responsibility of
State and local governments
to ensure compliance.
While most counties and
States do regulate municipal
landfills, concern for
potential contamination of
ground water has not  been
widely evident.
    Sewage sludge is  the
waste material produced by
municipal  wastewater treat-
ment plants. It is the  solid,
semisolid,  or liquid material
                               Garbage is dumped in municipal landfills where it is covered with a
                               layer of dirt.
                                                                                                                      73

-------
that remains after sewage has
been treated. Nearly seven
million tons of sludge (meas-
ured in terms of dry weight)
are generated each year.
    Due to its volume and
potential toxicity, sewage
sludge is a major waste man-
agement problem in a number
or municipalities. Some sew-
age sludges contain high levels
of pathogens or disease-
carrying microorganisms, toxic
metals, or toxic organic chem-
icals. Such sludge is regulated
as a hazardous waste under
RCRA if it is found to be a
potential threat to ground-
water quality.

Utility Wastes
The principal wastes produced
by electric power plants are
sludges from air and water
pollution treatment processes.
Some of these plants also pro-
duce radioactive wastes.
Under RCRA EPA is primarily
responsible for determining
whether there is a need to
regulate the sludges resulting
from air pollution control at
these plants. The regulation of
radioactive utility wastes is
discussed below.

Radioactive Wastes
There are four classes of
radioactive wastes.

• High-level radioactive
wastes (HLRW) are generated
in nuclear reactors and during
nuclear weapons production.
These wastes pose a serious
threat to anyone who comes
near them without shielding.

• Transuranic wastes are also
generated by nuclear reactors
and during weapons produc-
tion. These wastes contain
radioactive metals, such as
plutonium, curium, amer-
icium, and neptunium. Some
are highly toxic and very long-
lived. Actual ingestion or in-
halation is required for them
to produce toxic effects; mere-
ly being "exposed" to them is
not inherently dangerous.
Once inhaled or ingested they
can be extremely toxic even
in very small amounts.

• Low-level radioactive
wastes (LLRW) come from a
variety of sources, such as
hospitals, research labs, and
certain industries. These
wastes for the most part pre-
sent a much lower level of
hazard.  Nevertheless, they can
contain some highly radioac-
tive resins from nuclear power
plants. Special handling is re-
quired since repeated or ex-
tended exposure is dangerous.
• Uranium mill tailings are a
special category of low-level
radioactive waste. They vary
considerably in degree of
hazard and present special
problems due to their large
volume and because they con-
tain a long-lived isotope of
radium.
    The Department of Ener-
gy, the Nuclear Regulatory
Commission, the States, and
EPA share responsibility for
managing these wastes.  EPA
sets standards that specify the
maximum allowable increase
in radiation levels in the en-
vironment due to human
activity. EPA standards apply
to all commercial or gov-
ernmental organizations that
use radioactive  material. EPA
also proposes guidance to
Federal agencies on their use
of radioactive materials and
their physical handling of
radioactive wastes. If adopted
by the President, these recom-
mendations take the form of
official guidance to these
agencies.
    In addition, EPA monitors
radiation levels in the en-
vironment and provides tech-
nical assistance to other
Federal agencies and to States
and local governments carry-
ing out their own radiation
programs. EPA also maintains
an emergency response capa-
bility to monitor accidental
releases of radioactive mate-
rials such as at  the Three Mile
Island facility in Pennsylvania.
Aerial view of the cleanup operation at the Valley of the Drums Superfund site in Kentucky where barrels are
being recovered and stacked for removal.
74

-------
The MIDCO I Superfund site in Gary, Indiana before (left) and after (right) removal action.
PROGRESS TO DATE
While EPA's hazardous waste
programs are still relatively
new, we have made consider-
able progress towards man-
aging currently generated
wastes and cleaning up aban-
doned or inactive hazardous
waste sites. Regulations gov-
erning the treatment, storage,
and disposal of currently
generated hazardous wastes
are now in place. States have
begun to assume authority for
the RCRA program. EPA is
accelerating its permitting of
land disposal facilities and in-
cinerators and is moving
aggressively to enforce interim
requirements. EPA has also
moved forward in addressing
the problems posed by in-
active hazardous sites. In the
three years since the Super-
fund program was established,
EPA and the States have
worked to inventory the ex-
tent of the problem across the
country and to establish pro-
cedures for cleaning up these
sites. More than 540 sites are
currently included or proposed
for inclusion in the National
Priorities List.  The necessary
steps to clean up over 140 of
these sites are  now underway.
As illustrated in the before
and after photographs of the
MIDCO I site in Indiana,
cleaning up one site can be a
major undertaking costing
millions of dollars.

Abandoned and Inactive
Hazardous Sites
Under the Superfund program,
EPA and the States may di-
rectly initiate action to clean
up hazardous sites where
timely voluntary cleanup by
responsible companies or in-
dividuals is not undertaken.
Under these circumstances,
cleanup costs are paid directly
from the $1.6 billion Super-
fund with a contribution from
the State of at least 10 per-
cent. The Government can
later sue to recover its cleanup
costs from identified respon-
sible parties.
    EPA and the States have
identified over  17,000 aban-
doned or otherwise inactive
sites that may contain
hazardous waste. The total
number of identified sites  is
expected to reach 22,000 by
the end of 1985. EPA is now
carrying out a multi-step
assessment procedure to de-
termine which  of these sites
actually pose a danger to pub-
lic health, welfare, or the en-
vironment and what cleanup
actions are appropriate.

Municipal Wastes and
Sludge
State and local governments
have the primary responsibil-
ity for managing non-
hazardous municipal waste so
it will present little or no
health or environmental prob-
lems. The States report  to
EPA annually on progress in
identifying and cleaning up
municipal waste sites which
do not meet national
standards.
    Except for situations that
present imminent hazards,
EPA's role in dealing with
non-hazardous municipal
waste is more advisory than
regulatory. While EPA pub-
lishes a national inventory of
open dumps identified by the
States, the States are respon-
sible for closing or upgrading
the identified dumps. EPA
also has used its authority to
develop national standards for
landfill performance and op-
erations,  provide critena for
classifying existing land dis-
posal facilities according to
their environmental sound-
ness, and issue guidance on
development of State waste-
management plans and other
topics.
    EPA has greater direct au-
thority to oversee the man-
agement of sludge generated
by municipal wastewater
treatment plants. Under the
Clean Water Act, EPA is de-
veloping guidance to States on
how to use or dispose of this
sludge. EPA will also soon be
calling for the establishment
of State sludge management
programs. The management of
municipal sewage sludge, one
of our major challenges, is dis-
cussed more fully in the next
section. (See section on Mu-
nicipal Sludge.)
    Finally, in response to in-
creasing evidence that even
leachate from well-run munic-
ipal landfills contributes to
ground-water contamination,
EPA is investigating this
potential impact of municipal
landfills. (See section on
Ground-Water Protection.)

Industrial Hazardous
Wastes
The basic approach  to man-
aging hazardous wastes under
the Resource Conservation
                                                                                                                      75

-------
                                                                                               EPA's highest priorities. This
                                                                                               program will focus first on
                                                                                               hazardous waste handlers
                                                                                               with significant violations.

                                                                                               Radioactive Wastes
                                                                                               EPA has issued final standards
                                                                                               for the control of effluents and
                                                                                               emissions from uranium mill
                                                                                               tailings during mill operations
                                                                                               and for final disposal of these
                                                                                               tailings. EPA has also es-
                                                                                               tablished standards for
                                                                                               cleanup and long-term control
                                                                                               of uranium mill tailings at the
                                                                                               24 inactive mill sites that
                                                                                               qualify for remedial actions
                                                                                               under the Uranium Mill Tail-
                                                                                               ings Radiation Control Act.
                                                                                                   Environmental standards
                                                                                               for high-level radioactive
                                                                                               waste disposal are now being
                                                                                               finalized. These standards also
                                                                                               will apply to transuranic
                                                                                               wastes containing high con-
                                                                                               centrations of radioactive
                                                                                               material. Technical analyses
                                                                                               to select appropriate standards
and Recovery Act is to track
such wastes from "cradle to
grave" through a system of re-
cords called "manifests." The
manifest system is now in
place. Basic requirements gov-
erning waste treatment, stor-
age, and disposal have also
been established and are being
enforced. What remains to be
done is to issue final operating
 Eermits for hazardous  waste
 icilities and ensure com-
pliance with all the RCRA
regulations through a strong
enforcement program.
    Specifically, EPA and the
States are taking steps to en-
sure that currently generated
waste will not result in addi-
tional multi-million dollar
cleanup problems:
•  EPA and the States have
taken steps to identify every
active hazardous waste facility.
• Regulations setting stan-
dards for industries generating
hazardous waste and for facili-
ties treating, storing, or dis-
posing of such wastes are now
in place. All treatment, stor-
age, and disposal facilities are
subject to these "interim stat-
us" requirements until they
can be issued final permits.
• EPA has begun to issue per-
mits to hazardous waste facili-
ties with priority given to land
disposal facilities and in-
cinerators which present the
greatest environmental risks.
These permits are facility-
specific and are more stringent
than the interim-status
standards.

• EPA and the States inspect
these facilities and vigorously
pursue enforcement actions as
necessary to ensure com-
pliance with interim status
and permit requirements.  De-
veloping an effective RCRA
compliance program is one of
Top: Removal of hazardous waste requires great care. Bottom: The
Chemical Control Corporation Superfund site before the catastrophic fire.
76

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for disposal of low-level radio-
active wastes are near comple-
tion. EPA plans to propose the
standards later this year.


TODAY'S LAND
PROTECTION CHALLENGES

The most important achieve-
ment that has been made to
address land contamination is
that there is now widespread
recognition of the major
health and environmental
problems that may result from
indiscriminate dumping of
wastes on the land. Such prac-
tices in the past have left a
legacy of air, ground-water,
and surface-water contamina-
tion as well as land con-
tamination. Now, for the first
time, the Nation is in-
vestigating all potentially
hazardous sites, and work is
under way to clean up the
most threatening of these
sites. In addition, EPA regula-
tions now provide for environ-
mentally sound management
of the millions of tons of
hazardous waste newly gener-
ated each year. Cooperative
efforts by the States and in-
dustry are bringing about a
dramatic improvement in the
management of hazardous
waste.
    The actual cleanup of
past problems, however, has
only just begun, and many
problems will  remain as long-
term challenges.
    The remainder of this
chapter discusses in greater
detail the four most signifi-
cant land pollution challenges
faced by EPA,  the States, and
industry. Other parts of this
report also describe problems,
such as ground-water con-
tamination, related to the
management of wastes on
land. The four most signifi-
cant current land pollution
challenges are:
• Uncontrolled hazardous site
cleanup. One of EPA's highest
priorities is the cleanup of the
many uncontrolled hazardous
sites across the country. EPA's
attention is now focused on
how to speed up the rate at
which these sites are cleaned
up without compromising the
quality or permanence of
these cleanups.

• Newly generated hazardous
waste control. EPA and the
States are taking steps to en-
sure the proper management
of these wastes. They are
focusing on major hazardous
waste generators and major
treatment, storage, and dis-
posal facilities.

• Radioactive waste disposal.
The safe disposal  of high-level
and low-level radioactive
wastes and the management
of uranium mill tailings are
difficult long-term problems.
Working with other Federal
agencies and with the States,
EPA has a major role in
meeting these environmental
challenges.

•  Municipal sludge.  Although
sewage  sludge is not  an en-
vironmental threat as serious
as industrial wastes and
radioactive materials, this
sludge often contains
hazardous pollutants. Further-
more, it is generated  in the
greatest quantities in cities
and communities  with the
fewest economically  and en-
vironmentally acceptable
alternatives for its safe use or
disposal. As a result, it con-
stitutes a serious environmen-
tal management problem.
    The order of presentation
of these four challenges re-
flects their relative urgency
and seriousness. Many in-
active hazardous sites present
an immediate hazard to public
health and the environment.
Identification and cleanup of
health hazards at these sites
have the highest priority.
While safe management of
radioactive waste is a major
long-term problem, it is
ensuring the proper man-
agement of other hazardous
wastes that is the most press-
ing current need. Finally,
while sewage sludge presents
much less in the way of haz-
ard, the problem it does pre-
sent must be addressed fully
and quickly to prevent it from
creating inordinate manage-
ment difficulties for our cities.
                                                             Inspection team collecting waste samples from drums at an uncontrolled
                                                             hazardous site
                                                                                                                     77

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Uncontrolled  Hazardous  Site  Cleanup

     IT
       •it, r \
        (u. * «* JU~  *
Evidence is mounting that un-
controlled hazardous sites
may present some of the most
serious environmental and
human health problems the
Nation has ever faced. In most
cases, these sites resulted
from hazardous waste disposal
with little awareness of the
hazards such disposal could
eventually pose.
    Thousands of abandoned
or inactive sites containing
hazardous waste have been
identified nationwide. Many
of these sites are located in
environmentally sensitive
areas such as floodplains and
wetlands. Ram and melting
snow seep through the sites,
carrying chemicals that con-
taminate underground waters
and nearby streams and lakes.
At some sites, the air is also
contaminated as toxic vapors
rise from evaporating liquid
wastes or from uncontrolled
chemical reactions. Some pol-
lutants, such as metals and
organic solvents, are known  to
damage vegetation, endanger
wildlife, and threaten the
health of people who un-
knowingly drink con-
taminated waters. For other
pollutants, the extent of the
danger is not fully known. In-
formation on the health and
environmental effects of
hazardous wastes comes
mainly from laboratory stud-
ies of pure chemicals. There
still is much  to leam about
the nature  and impacts of the
complex mixtures of wastes
generally found at these sites.
    Most of these sites were
created primarily by the
chemical and petroleum
industries. A smaller number
of sites were once municipal
landfills  that may have
become  hazardous simply as a
result of accumulated pesti-
cides, cleaning solvents, and
other chemical  products dis-
carded in household trash. A
few sites are  the result of
transportation spills or other
accidents. Others are the final
resting place of persistent tox-
ic pollutants contained in in-
dustrial  wastewater discharges
or air pollution emissions.
EFFORTS

To DATE
Congress passed the Com-
prehensive Environmental Re-
sponse, Compensation, and
Liability Act (CERCLA), often
called "Superfund," in 1980 to
address the nationwide prob-
lem of uncontrolled hazardous
sites.
    Under CERCLA, EPA
may require that sites be
cleaned up by the "responsible
parties" who generated or
transported the wastes or
owned or operated the dis-
posal site. If there appears to
be no responsible party able or
willing to clean up the site
quickly enough, EPA may pro-
ceed under the Superfund, a
special fund financed mainly
by a tax on chemical produc-
tion. The States must contrib-
ute ten percent of the cost of
Superfund-financed cleanups.
Later, EPA and the States may
seek reimbursement by the re-
sponsible parties under the
"cost recovery" provision of
CERCLA.
    Starting in 1980, EPA and
the States began a concerted
effort to identify  all un-
controlled hazardous sites. To
date, this effort has produced
an inventory of over 17,000
potential sites; by the end of
1985, there may be as many
as 22,000 sites.
    Once identified, these
sites are subject to a series of
steps to determine whether
the sites present a hazard and,
if so, what cleanup actions are
appropriate.  These steps in-
clude one or more of the
following: (1) preliminary
assessment;  (2)  site in-
spection; (3) inclusion on the
National Priorities List; (4) de-
tailed field sampling (remedial
investigation); (5) a decision
on how to achieve permanent
cleanup; and (6) engineering
design and actual cleanup at
site (remedial action). Also, an
immediate "removal action"
can be taken at any step of
this process  if imminent
hazards are found. (See high-
light on Cleaning up an Aban-
doned Hazardous Waste Site.)
    Preliminary assessments
— the first step in determining
if a site poses a threat —
                                                   FIGURE L-2
                       546 SITES ARE ON THE NATIONAL PRIORITIES LIST FOR SUPERFUND
                                              (Includes proposed sites]
Source EPA's Office of Emergency and Remedial Response
78

-------
have been conducted  at 7,300
of the more than 17,000
inactive sites already  identi-
fied. On-site inspections
— more in-depth evaluations
of selected sites — have been
undertaken at 2,700 sites. EPA
plans to complete preliminary
assessments at all sites by
1986 and to complete site in-
spections by 1987.
    Of the sites investigated
to date, EPA has rated 546 as
eligible for inclusion on the
National Priorities List (NPL)
and thus eligible for long-term
remedial action. This list  con-
sists of sites across  the coun-
try where cleanup needs are
so serious as to warrant the
use of Superfund (Figure L-2).
EPA now estimates that even-
tually some 2,000 sites will be
designated as national
priorities.
    By the end of 1983, re-
moval actions — expeditious
cleanup actions to reduce im-
minent hazards — had been
approved for 231  sites. Of
these, removal actions have
been completed at 185 sites.
Longer-term remedial work
currently is being planned or
is under way for 147 of the
546 sites proposed or currently
on the National Priorities List.
The bulk of Superfund
cleanup activities have been
completed at six sites: Chem-
ical Metals (Baltimore,
Maryland), Wolcott Chemical
Company Warehouse (near
Greenville, Mississippi),
Luminous  Processes (near
Athens, Georgia), Butler Tun-
nel (near Pittston, Pennsyl-
vania), Chemical Minerals
(Cleveland, Ohio), and Gratiot
County Golf Course (St.
Louis, Michigan).
    Since December 1981,
Federal and State authorities
have reached settlements  with
responsible parties that will
result in having these parties
spend $277.3 million  for
cleanups at Superfund sites.
To date, Federal and State au-
thorities have also sued re-
sponsible parties to recover an
additional $17.2 million m
cleanup costs initially paid by
the Superfund. Such funds,
once recovered, will be re-
turned to the Superfund for
use at other sites.
    In addition to this partici-
pation in the activities listed
above,  States and responsible
parties on their own have con-
tained, neutralized, or re-
moved hazardous substances
from a number of other sites
across the country.

-------
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80

-------
To; )AY fs
    HA'  IE?
The cost of cleaning up un-
controlled sites is often very
high. Although Superfund can
be quickly tapped for
emergency cleanup, States
have to come up with 10 per-
cent of the costs of permanent
cleanups at privately owned
sites and 50 percent at public-
ly owned sites. Some States
have not had such funds
readily available.
     Other States, however,
have already set up mechan-
isms for financing cleanups. A
few have established funds for
cleanup of sites that are a
State priority, regardless of
whether they are included on
the national list for funding
under Superfund.  Several
others have begun to establish
similar legislation.
    It normally takes about
four years from initial site
identification to completion of
final remedial action. This
process is time consuming for
the following reasons:

• When a site is determined
to present serious hazards, an
on-site, "remedial investiga-
tion" is needed. This carefully
planned investigation includes
sample collection and analysis
to identify the nature and
quantity of wastes present and
an assessment of the terrain,
soil type, proximity of under-
ground aquifers, and drainage
to nearby surface streams.

• Remedial measures must be
carefully designed to ensure
that the measures taken will
provide long-term protection
of public health, welfare, and
the environment. Problems at
each site are unique, and it is
often necessary to develop
customized, site-specific
solutions.
• There are many participants
in a typical Superfund cleanup
including government agen-
cies at all levels, responsible
parties, and the local commu-
nity. Because States are re-
quired to pay at least ten per-
cent of the actual cleanup cost
and to assume full responsibil-
ity for post-cleanup costs, EPA
must work closely with State
officials. EPA also puts high
priority on  ensuring the in-
volvement  of local officials
and concerned citizens, es-
pecially those who live near
the site.
    In implementing
CERCLA, EPA is concerned
with balancing the investment
it makes as evenly as possible.
In determining the nature of
the remedy selected for the
site,  EPA must balance the
potential cleanup costs with
the cost of  cleanup at all the
other NPL  sites across the
country. The cost of the rem-
edy selected must therefore be
"within reason" given the to-
tal funds available to pay for
cleanup at  all NPL sites.
For the next two years, the
Agency's highest priority is to
stabilize and clean up
hazardous waste sites under
the Superfund program. Ac-
cordingly, EPA is committed
to accomplish the following:

Complete Identification and
Assessment of Uncontrolled
Hazardous Sites
The first step in achieving the
overall goals of the Superfund
program is to complete the
identification of the universe
of possible hazardous sites by
October 1985.

Secure Responsible Action

EPA is speeding up the pace of
cleanups in part by pushing
for quick resolution of nego-
tiations with responsible par-
ties. EPA is using administra-
tive orders or litigation where
necessary to compel  cleanup
or recover costs already in-
curred by the Federal
Government.
Respond to Immediate
Threats
When a responsible party will
not agree to act quickly, EPA
will take action under Super-
fund to remove immediate
health or environmental risks
and seek cost recovery later
from the responsible parties.
EPA is making an all out
effort to take removal actions
to stabilize the sites currently
on the National Priorities List
by October 1985.

Accelerate Remedial
Actions
A major thrust of the next few
years is to accelerate cleanup
of all National Priorities List
sites. EPA will take enforce-
ment actions as necessary to
secure prompt cleanup by a
responsible party  or undertake
site cleanup financed by
Superfund.

Delegation of Authority to
Make  Site-Specific Decisions
As EPA Regional  offices gain
operating expenence under Su-
perfund, Headquarters is de-
legating increasing authority
to them. While Headquarters
must review decisions on the
final cleanup actions at each
site, many more site-specific
decisions will be made at the
Regional level. This will con-
tribute significantly to in-
creasing the rate of cleanup.
                               Removal work going on at a Superfund site.
                                                                                                                     81

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LAND
Newly  Generated
Hazardous  Waste  Control
THE

PROBLEM

About 290 million tons of
hazardous wastes are gener-
ated in the United States each
year. As we have learned from
experience, unless their treat-
ment, storage, and disposal are
carefully managed, these new
wastes may introduce even
more contaminants into our
drinking water supplies, re-
lease additional toxic vapors,
create more explosive dump
sites, and otherwise threaten
public health and the environ-
ment. (See section on Un-
controlled Hazardous Site
Cleanup.)

Origin of Hazardous
Wastes
Most hazardous wastes result
from the production of famil-
iar goods such as plastics, pes-
ticides, medicines, and petro-
leum products. As illustrated
by Figure L-3, the chemical
and petroleum industries are
responsible for over two-thirds
of the hazardous wastes
generated.
    A small percentage (four
percent) of the hazardous
wastes generated are recycled.
The rest are treated, stored, or
disposed of. Most generators
treat or dispose of their own
wastes. In fact, only four per-
cent of the hazardous wastes
generated ever leave the site
where they were generated.
Treatment, Storage, and
Disposal

Of the hazardous wastes dis-
posed of, most are injected as
a liquid into the ground in
specially designed injection
wells. A large quantity is
placed in surface im-
poundments (pits, ponds, and
lagoons). Only a small portion
is placed directly on the land
or buried (Figure L-4).
    Fear of hazardous wastes
has made it difficult to gain
necessary support from local
residents to build even the
most environmentally sound
new facilities. This, ironically,
increases the risk of accidental
spills during long-distance
transport.
    The number of facilities
available for management of
industrial wastes is shrinking
steadily. EPA expects several
existing facilities will not con-
tinue to operate and take the
necessary steps over the next
five to ten years to obtain the
final permits required under
the Resource Conservation
and Recovery Act (RCRA). In
many areas, the remaining
facilities are increasing their
capacity in order to meet cur-
rent and projected needs. Un-
less there is adequate safe
treatment and disposal capac-
ity reasonably close to the
generators of waste, the
alternatives may be more
stockpiling of wastes at in-
dustrial sites, illegal storage,
and "midnight dumping."
EFFORTS

To DATE
The Resource Conservation
and Recovery Act (RCRA) was
created in 1976 to minimize
the risks from hazardous
wastes at all points in their
life cycle, from generation to
disposal. Thus, under RCRA,
EPA and the States have the
authority to regulate facilities
that generate, treat, store, and
dispose of hazardous wastes.
    EPA's goals in im-
plementing RCRA are to es-
tablish and implement a
sound and effective regulatory
program and ensure that
hazardous waste handlers
comply with those
requirements.
    As a first step, EPA es-
tablished requirements that
must be met by generators
and transporters and basic op-
erating requirements called
"interim status standards" for
treatment, storage, and dis-
posal facilities that were op-
erating before November 20,
                      FIGURE L-3

      MOST HAZARDOUS WASTE IS GENERATED
    BY THE CHEMICAL AND PETROLEUM INDUSTRIES
                   (Estimated 1981 figures)



      Chemical and petroleum industries 71%
                                                                         Other industries 7%
                                                                                                Metal-related
                                                                                                 industries
                                                                                                   22%
                                                                                       Source EPA's Office of Solid Waste
 82

-------
 1980. Under these standards,
 operators of hazardous waste
 landfills, for  example, are re-
 quired to keep thorough re-
 cords of the types and quanti-
 ties of wastes disposed of.
 They also must have staff
 trained to take emergency
 measures in  case of accidents.
 Operators must have evidence
 that they can pay if the public
 is injured as  a result of their
 operations. In addition, they
 must be financially able to
 close the  site safely and  to
 monitor and manage  the site
 after closure. While operating
 the site, they must monitor
 ground-water quality near the
 facility and report any con-
 tamination to the State or
 EPA. Finally, they must  com-
 ply with restrictions regarding
 the handling of certain types
 of wastes and waste con-
 tainers. For example,  a liquid
 waste may not be disposed of
 directly in a landfill but  must
 first be treated to solidify it.
    The second major step
was to establish technical or
permit standards for the  de-
sign and safe operation of var-
ious classes of treatment, stor-
age, and disposal facilities.
These standards are more
stringent than the interim
status standards and serve as
the basis for issuing operating
permits that may have addi-
tional facility-specific require-
ments and conditions.
    Issuing facility-specific
operating  permits is the heart
of the RCRA program. There
are some 4800 facilities that
must receive permits. Even
relying upon the States to
issue a substantial portion  of
the permits, it may be five to
ten years before all facilities
receive final permits. As dis-
cussed below, EPA has de-
cided both to accelerate the
permit process and to focus
first on the most environmen-
tally significant permits: those
for land disposal facilities and
incinerators.
                                                                                                                        83

-------
 l\  >l
Issuing permits for hazardous
waste operations presents a
considerable challenge for EPA
and States for a number of
reasons. First is simply the
sheer number of permits that
must be issued. Even if the es-
timate of 4800 is off by a signi-
ficant margin, the work load is
staggering. A second reason is
the technical and legal com-
plexity of the task. Thorough
assessments of each site are
needed in order to develop op-
erating requirements for the
permit. Specialists trained in
engineering, hydrology, and
chemistry are often needed  to
determine the risks involved
and develop site-specific per-
mit conditions to minimize
them.
    At the same time, today's
permit decisions set legal pre-
cedents, and  careful legal
review is required before
making these decisions. Once
a precedent is set, decisions
in similar situations
can be fully delegated to pro-
gram managers in EPA's Re-
gional offices and in the
States.
    Experience to date is that
most initial permit applica-
tions are incomplete and re-
quire several rounds of review
and revision. This obviously
slows the rate at which per-
mits can be issued and further
complicates the task. Finally,
in many  cases,  State agencies
issuing these permits also run
other environmental pro-
                                                              EFA'S
grams. In many cases persons
responsible for issuing final
permits also are responsible
for ensuring compliance with
interim requirements. In some
States the same staff issues
both RCRA and water permits.
The lack of enough skilled
permit writers has been a
serious  problem.
    Difficult policy issues
have arisen as well. Some
treatment, storage, and dis-
posal facilities have elected to
close or to stop handling
hazardous wastes in order  to
avoid the stringent new re-
quirements. While this may
weed out some problem sites,
it may also reduce existing
hazardous waste disposal
capacity in some areas at a
time when new facilities are
difficult to establish.
    New requirements for
handling, transporting,
treating, stonng, and disposing
of hazardous wastes have in-
creased the cost to generators
of disposing of such wastes.
For the long term, high costs
create an incentive to increase
recycling and reduce waste
generation. In the short  term,
however, they may lead to
longer storage at industrial
sites, illegal storage, and
"midnight dumping."
    In addition to these dif-
ficulties, a number of scientif-
ic and technical problems  re-
main. Little is known about
the ultimate fate and effects of
many hazardous wastes in the
environment, making it dif-
ficult to know what control
measures should be required.
For example, if a substance is
very persistent and is taken
up by fish and other animals,
it may have serious long-term
toxic effects and should be
controlled accordingly. For
most substances, however, we
do not have complete in-
formation on persistence or
toxicity.
    To compound the prob-
lem, continued growth in the
manufacture and use of chem-
icals may increase the volume
and variety of hazardous
wastes. In addition, growth in
light, "high-tech" enterprises
may disperse the hazardous
waste problem among many
more small facilities using a
greater variety of chemicals.
We now  realize that some
facilities  now exempt from
EPA requirements may pose
problems. Examples include
small-quantity generators and
municipal landfills where
small amounts  of hazardous
waste mingle with trash and
garbage.
    Finally, the state-of-the-
art of hazardous waste control
is not well advanced. For ex-
ample, there is  growing evi-
dence that even the most
technically sophisticated syn-
thetic liners may not per-
manently seal hazardous
wastes in landfills. EPA has
therefore put considerable em-
phasis  on research to develop
new treatment  methods to de-
stroy, neutralize, or detoxify
hazardous wastes that cannot
be recovered and reused eco-
nomically. Once developed
and successfully demon-
strated, such treatment
methods would be available as
alternatives to land disposal.
Two of EPA's highest priori-
ties are to expedite the per-
mitting of land disposal sites,
incinerators, and other ma)or
hazardous waste facilities, and
to ensure compliance by
hazardous waste handlers
with regulations under RCRA.
Working with the States to
achieve those ob)ectives is
critical to avoiding the serious
environmental consequences
of improper handling and dis-
posal of hazardous wastes.

Accelerated Permitting
EPA and the  States are
committed to issue
site-specific permits  (to re-
place interim status  require-
ments) as expeditiously as
possible. Beginning in 1984, a
new strategy involves calling
on facilities to submit applica-
tions on  an accelerated sched-
ule. The  strategy will empha-
size permits for the most en-
vironmentally significant faci-
lities. Accordingly, land dis-
posal and incinerator facilities
will be addressed first. To help
expedite  the permit process,
EPA and the  States will give
operators advanced notice of
modifications in design or op-
erations likely to be  called for
in their permit. Specifically,
EPA and the  States will in-
spect facilities and counsel
facility managers on  what is
needed for a permit for that
facility and how to prepare an
application. Trade associations
will also be encouraged to
help members submit com-
plete applications. At the
same time, EPA and the
States  will begin to seek
monetary penalties from faci-
lities submitting late or in-
complete applications.
    EPA will also speed up
the permitting process by fully
delegating more permit de-
cisions to States and EPA  Re-
gional  offices, especially once
key precedent-setting de-
cisions have been made.
84

-------
                                          FIGURE L-4
                       HOW HAZARDOUS WASTE IS DISPOSED OF
                                    (Estimated 1981 figures)
                                                                            Landfill and
                                                                           land treatment
                                                                               6%
Source EPA's Office of Solid Waste

Improved Compliance
An extremely important prior-
ity for RCRA is to achieve a
high level of compliance by
major hazardous waste hand-
lers with RCRA regulations.
In particular,  EPA and State
enforcement officials will
focus on requirements for
ground-water monitoring, clo-
sure and post-closure plans,
and financial  responsibility re-
quirements. Under the latter
requirements, facility op-
erators must demonstrate that
they have an  adequate source
of funds to pay for closure and
post-closure care as well as to
pay damages in the event of
harm to the public.
    Significant violations of
these and other RCRA regula-
tions will bring immediate en-
forcement action by EPA and
States. To ensure continued
compliance, States and EPA
conduct comprehensive in-
spections of both newly per-
mitted and interim-status faci-
lities. In  the next few years,
EPA will work jointly with
the States to place  special em-
phasis on compliance
monitoring and enforcement
programs.

Expanded State Role
Implementation of RCRA is
premised on a strong and
effective EPA/State part-
nership. EPA will continue  to
help States develop programs
so they can assume
responsibility for regulation
of generators, transporters,
treatment, storage, and
disposal facilities. EPA's pri-
mary role will be to provide
technical guidance and to
oversee and evaluate State
programs to ensure consistent,
effective implementation of
the law. At the same time,
EPA will act directly to en-
force RCRA where it deems
such action necessary to sup-
plement State enforcement ac-
tivities. This combination of
State enforcement responsibil-
ity backed up where necessary
by EPA will ensure that the
requirements of the law are
met by all facilities covered by
the RCRA program.

Other Current Initiatives
    EPA is also working to
improve the effectiveness of
the hazardous waste program
by focusing on the following
needs:
• Improved monitoring.
Monitoring the generation,
handling, and disposal of
hazardous wastes will help
EPA tell whether wastes are
being properly disposed of or
not. EPA's first national report
on the generation and disposi-
tion of hazardous wastes will
be issued in 1985. EPA and
the States will then focus en-
forcement efforts on any types
of wastes or industries for
which there are indications of
significant patterns of un-
authorized disposal.
• Prosecute illegal dumpers.
Administrative enforcement
actions play a much larger
role in RCRA than does judi-
cial enforcement. Neverthe-
less, more than 15 cases of
illegal dumping of hazardous
wastes have been referred to
the Department of Justice for
prosecution, and additional
cases are now under investiga-
tion. EPA and the States will
continue to take vigorous ac-
tion when instances of illegal
dumping are discovered.

• Assess current exemptions.
EPA will reassess the signifi-
cance and impact of
activities now exempt from
Federal regulations such as
mining or generating only
"small quantities" of waste.
Where appropnate, EPA will
modify existing regulations.
In 1983, EPA tightened rules
for facilities that recycle
hazardous wastes or use them
as fuel.
• Promote better ways to deal
with hazardous wastes. While
EPA is conducting research  to
make landfills more secure,
safer alternatives to  land dis-
posal of hazardous wastes are
needed. EPA is now
sponsoring research  on prom-
ising new treatment processes
to destroy, incinerate, or de-
toxify wastes. In addition,
several industries are de-
veloping ways to recover and
reuse hazardous by-products
to reduce the volume of
hazardous waste requiring
treatment or disposal.
                                                                                                                     85

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LAND	
Radioactive  Waste
THE

PROBLEM
Since the early 1900's, the
United States has made sig-
nificant use of radioactive
materials and as a conse-
quence has generated  large
quantities of radioactive
wastes. When handled im-
properly, these wastes can pr-
esent serious public health
and environmental threats
that  sometimes last many
generations. Radioactive mate-
rials may emit dangerous
levels of radioactivity for hun-
dreds or even thousands of
years. Exposures to high levels
of radioactivity can result in
acute health effects; high
enough levels can result in
death within hours. Smaller
doses are known  to cause can-
cer and genetic damage. The
combination of its longevity
and life  threatening effects
makes proper disposal of
radioactive waste imperative.

High-Level Radioactive
Wastes
Spent fuel elements from nu-
clear reactors contain  highly
concentrated radioactive mate-
rials. If this fuel is reprocessed
to recover uranium and pluto-
nium, much of the remaining
radioactive material goes into
the liquid wastes generated
during this reprocessing. As of
1981, about 11,000 cubic feet
of spent fuel and  77,000 cubic
feet of reprocessing wastes
have accumulated. These
materials are currently stored
at the facilities where they
were generated or at special
sites such as locations near
West Valley, New York;
Aiken, South Carolina; and
Morris, Illinois. The primary
commercial source of these
wastes, the nuclear reactors
operated by the Nation's elec-
tric utilities, are currently
generating about  1,600 cubic
feet of spent reactor wastes
(spent fuel) each year.
    High-level radioactive
waste (HLRW) is also gener-
ated during nuclear weapons
production and through the
use of nuclear reactors to
power naval  vessels. The
present inventory of defense-
related HLRW stands at about
ten million cubic feet and is
presently stored at three
Federal facilities located at
Richland, Washington; Aiken,
South Carolina; and Idaho
Falls, Idaho.
    The radioactive materials
found in HLRW emit several
kinds of radiation including
gamma rays  which are highly
penetrating. These materials
can, therefore, produce harm-
ful effects without having to
enter an organism by inges-
tion or inhalation. Many of
these materials remain
radioactive for thousands of
years.

Transuianic Wastes
Transuranics are those rela-
tively few elements that are
heavier than uranium such as
plutonium, americmm,
curium, and  neptunium.
While some transuranic
wastes are produced in nu-
clear reactors, the primary
source is the production of
nuclear weapons. Transuranic
wastes generally emit a form
of radiation called alpha parti-
cles that do not easily pene-
trate materials or living tis-
sues. Transuranics are there-
fore usually only damaging as
a result of mgestion or inhala-
tion. Once in the body, how-
ever, transuranics prove ex-
tremely toxic. Furthermore,
several transuranics, including
plutonium, also maintain
their radioactivity for ex-
tremely long periods of time,
with half-lives of thousands of
years.
    There are about 1,900 kil-
ograms of transuranic ele-
ments contained in about 13
million cubic feet of national
defense-related waste at var-
ious sites operated by the U.S.
Department of Energy (DOE).
Beginning in 1988, a large
amount of these existing
wastes and newly-generated
transuranic wastes will be
placed at the Waste Isolation
Pilot Plant (WIPP), which will
be operated by DOE at Carls-
bad, New Mexico.
Low-Level Radioactive
Waste
Examples of low-level radioac-
tive wastes (LLRW) include
radiopharmaceuticals; labora-
tory clothing from hospitals or
research facilities involved in
nuclear medicine; tools used
in cleaning up radioactively
contaminated areas; and mate-
rials filtered from nuclear
reactor cooling systems. Some
small quantities of transuranic
wastes are also treated as
LLRW. In general, LLRW con-
tains much less radioactivity
per unit of weight than does
HLRW.
   By 1981 130.6 million
cubic feet of civilian LLRW
had been buried at 6 com-
mercial sites and 57.2 million
cubic feet of governmental
LLRW at 17 DOE sites. About
3.1 million cubic feet of
LLRW is currently being pro-
duced by private industry each
year with about 2.0 million
            „'*,'_ „• ';•«€%""• $:>%£&'* "i



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-------
cubic feet by government op-
erations. There are currently
only three operating com-
mercial waste sites for such
materials, all licensed by the
host States acting under agree-
ments with the Nuclear Reg-
ulatory  Commission (NRC).
These are located at Richland,
Washington; Barnwell, South
Carolina; and Beatty, Nevada.
    Eventually, radioactive
facilities wear down or be-
come obsolete and must also
be disposed of. Currently op-
erating commercial, military,
and research reactors are ex-
pected to be in service no
longer than 40 years. It will
then be necessary to dispose
of them in an environmental-
ly sound manner. Nuclear
components of reactor-driven
naval vessels, most of them
submarines, must also even-
tually be disposed of
appropriately.

Uranium Mill Tailings

Uranium ore has been mined
in significant quantities in the
United States for over 30
years  with 27 mines currently
in operation. Tailings, pro-
duced when uranium is ex-
tracted from the mining ore,
contain  small concentrations
of radioactive materials such
as radium and thorium and
emit radon, a radioactive gas.
In addition to an  estimated
183 million tons  of tailings
already produced, an equal
amount may be generated by
the turn of the century.  Be-
cause they normally contain
relatively small amounts of
radioactivity per unit volume,
uranium mill tailings con-
stitute a special class of low-
level radioactive waste.
EFFORTS

To  DATE

EPA shares responsibility for
radioactive waste man-
agement at the Federal level
with the Nuclear Regulatory
Commission (NRC) and the
Department of Energy (DOE).
The NRC has direct regula-
tory authority over com-
mercial  nuclear activities, and
DOE oversees government nu-
clear activities including both
energy and nuclear weapons
production. EPA issues radia-
tion standards that set limits
on human radiation exposure
levels or on quantities or con-
centrations of radioactive
materials that may be released
to the environment. Once
issued, EPA standards apply to
all commercial and most gov-
ernmental operations. EPA
also develops recommenda-
tions for Federal guidance for
radiation protection that  ap-
plies only to Federal agencies
that handle radioactive
materials.
    In addition, EPA  provides
technical assistance to other
Federal agencies and to State
and local governments for
carrying out their radiation
protection programs. EPA also
monitors radiation levels in
the environment both on a
regular basis and on an
emergency basis in the event
of major accidental releases of
radioactive materials.
TODAY'S

CHALLENGES

The basic challenge for EPA
in environmental radiation
management is to establish
what level of radiation expo-
sure is acceptable for the pro-
tection of human health and
the environment. EPA man-
ages its radiation activities on
the premise that any exposure
to radiation carries some risk,
with the risk increasing as ex-
posures increase. In de-
termining at what levels to
set standards or provide Feder-
al Guidance recommenda-
tions, EPA takes into account
technological, social, and eco-
nomic factors to reduce risks
to reasonable levels. In accord-
ance with this approach, EPA
has established standards for a
number of sources disposing
of radioactive waste.
    In January 1983, EPA es-
tablished standards for
cleanup and  long-term control
of uranium mill tailings at the
24 inactive mill sites that
qualify for remedial actions
under the Uranium Mill Tail-
ings Radiation Control Act.
Two types of remedial actions
are required: cleanup of tail-
ings that have spread from the
original site or have been re-
moved for use elsewhere and
disposal of tailings  to ensure
their environmentally sound,
long-term stabilization. These
remedial actions are being car-
ried out by DOE and affected
States, with the concurrence
of the NRC.  In September
1983, EPA issued final stan-
dards for the control of
effluents and emissions from
uranium mill tailings during
mill operations and for the
final disposal of these tailings.
The standards require disposal
of tailings so that possible
health hazards will be con-
trolled and limited  for at least
1,000 years.
 EPA'S

 AGENDA

 High-Level Waste

 EPA is now developing en-
 vironmental standards for
 HLRW disposal. These stan-
 dards will also be applicable to
 transuranic wastes  containing
 high concentrations of
 radioactivity. The proposed
 HLRW environmental stan-
 dard would require con-
 tainment of radiation wastes
 so that potential health im-
 Eacts to the U.S. population
 jr the next 10,000 years are
 not more than 1  additional
 cancer every 10 years. For
 comparison, the natural back-
 ground radiation levels cur-
 rently cause more than 3,000
 fatal cancers every year in the
 United States.

 Low-Level Waste
 Work to provide a technical
 basis for LLRW environmental
 protection standards has been
 under way at EPA for several
 years. EPA plans to propose
 these standards this year. For
 commercial sites, standards
 for LLRW disposal will even-
 tually be implemented and en-
 forced directly by the NRC
 through its licensing require-
 ments or by individual States
 having regulatory agreements
 with the NRC. For Federal
 Government disposal facili-
 ties,  DOE will implement the
 EPA standards.

Decommissioned Facilities
and Equipment

 EPA is initiating work to de-
 velop background information
 concerning permissible levels
 of residual radiation and ac-
 ceptable procedures for de-
 contamination of sites, build-
 ings, and equipment at nu-
 clear reactor facilities and re-
 search laboratories that will
 soon be reaching the end of
 their useful lives. This in-
formation could then be used
 in either recommending Fed-
eral Guidance or promulgating
 standards. In the spring of
 1985, EPA will decide which
 of these options to  pursue.
                                                                                                                 87

-------
LAND
Municipal  Sludge
THE

PROBLEM
Sludge is the by-product of
most air and water pollution
control processes, including
the treatment of sewage.
While sludge from municipal
water treatment processes
does not usually present a ma-
jor threat to health or the en-
vironment, it often poses a
major environmental man-
agement problem.
    Sludge can be an ex-
tremely diverse material —
biologically, chemically, and
physically — and it varies
substantially among treatment
plants  serving different com-
munities and over time with-
in individual treatment plants.
Some sludges may be
hazardous and require special
handling, while others are suf-
ficiently innocuous to be used
as a livestock feed supple-
ment. Not only are sludges
themselves highly variable,
but their potential environ-
mental effects are also closely
tied to both site-specific fac-
tors — soil type, climate, local
vegetation — and to the man-
ner in which sludges are local-
ly disposed of or used.
    It is estimated that nearly
7 million dry metric tons of
municipal sludge are gener-
ated annually by the Nation's
16,000 municipal sewage
treatment plants. A small frac-
tion of the plants produce
                  Source EPA's Office of Water
most of the sludge (Figure L-
5). Options for the use of mu-
nicipal sludge include use as a
fertilizer or soil conditioner;
in energy generation (methane
gas production or combustion
in heat recovery systems); or
as a construction material.
Disposal alternatives include
disposal on land (including
landfills and land treatment
processes), incineration, and
ocean dumping. Today about
one-half of municipal sludge is
applied to or disposed of on
the land,  one-quarter is in-
cinerated, and the rest is put
in surface impoundments,
stored, or dumped in the
ocean (Figure L-6).
    Sludge is generated in the
greatest quantities in those
cities with the fewest econo-
mically and environmentally
acceptable options for dealing
with it. In many of these
cities, air quality problems
can mean that incineration of
sludge must be tightly con-
trolled or cannot be permitted
at all. Even if the levels of
toxic contamination are ac-
ceptable,  land for landfilling or
surface application is often
only available at great dis-
tances from the treatment
plant or across political
boundaries, making access dif-
ficult. Because of the dif-
ficulties presented by incinera-
tion, land disposal, and ocean
dumping, many cities are in-
vestigating options for making
productive use of sludge.
EFFORTS

To DATE
At least five different Federal
laws address various aspects of
the municipal sludge man-
agement problem. Principal
among them is the Clean
Water Act (CWA). To ensure
the disposal of municipal
sludge in a manner that would
protect the Nation's waters,
the CWA specifically ad-
dresses the management of
sludge by:
• Requiring EPA to issue reg-
ulations on the use or disposal
of municipal sludge;
• Requiring local gov-
ernments to have responsibil-
ity  for sludge management
and to institute programs for
the pretreatment of industrial
discharges to their sewers to
reduce the amounts of toxic
contaminants; and
• Providing, under the con-
struction grants program,
funds for constructing sludge
treatment processes as well as
wastewater treatment proc-
esses at municipal sewage
treatment plants. A significant
portion of the construction
costs of a sewage treatment
plant now go to facilities
and equipment for sludge
processing, utilization and
disposal.
    The disposal of municipal
sludge on land is also subject
to regulations for waste sites
developed under  the Resource
Conservation and Recovery
Act (RCRA). Criteria es-
tablishing guidelines for
sludge disposal at waste sites
have been implemented joint-
ly under RCRA and CWA au-
thorities. Criteria have also
been developed for the use of
municipal sludge as a soil
conditioner. RCRA regula-
tions for the management of
hazardous wastes are applied
to municipal sludge disposal
in those relatively few cases
where sludges have been
found to meet the RCRA
hazardous waste  criteria (e.g.,
because of high concentrations
of toxic metals).

-------
                              TODAY'S            EPA'S
                              CHALLENGES   AGENDA
          FIGURE L-6

     WHAT WE NOW
         DO WITH
   MUNICIPAL SLUDGE

Surface impoundment 12%
         Ocean dumping 7%
                      Land
        , ~^^^mmg^^~  disposal
       /             or land
Incineration 27%      treatment
                       54%
Source Municipal Environment Research
Laboratory, Cincinnati, Ohio, USEPA

    The incineration of mu-
nicipal sludge must also com-
ply with the Clean Air Act's
(CAA's) regulations for
hazardous air emissions and
performance standards for new
sludge incinerators, where
applicable. They must also be
accounted for in State  Im-
plementation Plans for
meeting ambient air standards
for criteria pollutants.  (See Air
Overview.)
    The ocean disposal option
for sludge management is only
used by a limited number of
cities. The number of com-
panies and cities engaging in
ocean dumping declined dra-
matically in the late-1970's as
a result of regulations oriented
toward phasing out such prac-
tices by 1981. Although the
number of ocean dumpers de-
clined, the amount dumped by
the largest remaining dumpers
increased, with the net result
that the total amount dumped
increased. A court order in
1981 rescinded the coming
deadline for a ban on ocean
dumping and required  EPA to
reconsider the environmental
and economic impacts of
alternatives such as land dis-
posal prior to eliminating the
ocean disposal option.
Management of municipal
sludge continues to be a dif-
ficult problem, particularly for
a number of cities with lim-
ited use or disposal options.
Management of sewage sludge
has complicated and increased
the cost of the operation of
sewage treatment plants.
    A major barrier to proper
management of sludge is the
fragmented and uncoordinated
regulatory structure at both
the Federal  and State levels of
government. At the Federal
level, regulations developed
under five major laws directly
involved with sludge man-
agement have been fashioned
independently. As a result of
this fragmentation, present
Federal regulations are both
uneven in their stringency and
incomplete in their coverage.
The same is true at the State
and local level. As a conse-
quence,  sludge use and dis-
posal programs, reflecting dif-
ferences in Federal, State, and
local objectives and concerns,
present a bewildering array of
often conflicting objectives.
    Another frequent barrier
is the presence in some cities
of toxic  chemicals in the mu-
nicipal sludge they produce.
Much of this contamination
results from the discharge of
inadequately treated industrial
wastewater into the cities'
sewers. When contaminated
in this way, the potential for
using the sludge as a soil con-
ditioner is greatly reduced.
The sludge  ceases to be a
potentially revenue-generating
resource and instead becomes
a major, resource-draining dis-
posal burden.
EPA's agenda will be guided
by a Policy on Municipal
Sludge Management to be
issued in the Summer of 1984.
Given the complexity and var-
iability of sludges and local
situations, it is EPA's position
that any effective regulatory
framework must provide for
substantial decision making at
the State and local level.
Many States have already
demonstrated considerable ini-
tiative and ability in
regulating sludge and often
provide needed assistance to
local government. Some
Federal involvement,  however,
is needed to help ensure  that
effective sludge management
programs are developed and
implemented by all States and
local governments needing
them. EPA's strategy  calls for
the following:

Coordinate All Federal
Regulations Pertaining to
Sewage Sludge
As a first step, EPA intends to
build an integrated, com-
prehensive Federal regulatory
structure for sludge disposal
and use. EPA will consolidate
regulations where appropriate
and develop new regulations
where important gaps remain.

Improve Sludge Quality
Through Pretreatment
The "pretreatment program"
requires industries to remove
certain pollutants from their
wastewater before discharging
it into municipal sewers.
Since municipal sewage treat-
ment plants are not designed
to treat adequately all forms
of industrial wastes, some pol-
lutants remain after process-
ing  at a municipal treatment
facility. These  remaining pol-
lutants end up in the sludge
produced by the municipal
plant. To protect water quality
and reduce sludge contamina-
tion, EPA has established
national standards for in-
dustrial pretreatment of toxic
metals and organics in
wastewater before it enters
municipal sewers. EPA will
continue work with States
and local governments to de-
velop and implement local
pretreatment programs con-
sistent with standards.
Issue Federal  Standards for
the Reuse and Disposal of
Municipal Sludge
The Agency has initiated a
major effort to publish Federal
standards for each possible use
or disposal alternative for
sludge. These standards will
specify the maximum accept-
able contaminant levels for
each use or disposal method.
EPA intends to revise or de-
velop regulations for land
application, landfilling, in-
cineration, and ocean
dumping as well as distribu-
tion and marketing of sludge
for soil conditioning. These
regulations will provide ade-
quate protection for public
health and the environment
while promoting the beneficial
resources of municipal sludge.

Require Each State to
Develop a Sludge
Management  Program
The Agency will develop reg-
ulations requiring each State
to develop a sludge man-
agement program to integrate
disparate State regulations and
programs concerning sludge
management. EPA will describe
the minimum objectives a
State program must meet while
allowing each State to design
a program best suited to  its
needs.
Provide Technical
Guidance
EPA will continue to provide
technical information and
guidance on  sludge man-
agement to supplement the
sludge management regula-
tions. General guidance will
be completed in August 1984.
In addition, EPA will main-
tain an active center for public
information and education.
                                                                                                                  89

-------
Toxic CHEMICALS

-------
Toxic  CHEMICALS
 More than 60,000 chemical
 substances are manufactured
 in the United States for use in
 an almost unlimited number
 of products. The benefits de-
 rived from such extensive use
 of chemicals are significant.
 However, we now know that
 a number of chemicals may
 cause cancer, birth defects, re-
 productive failures, and other
 irreversible effects. Exposures
 to these substances have
 serious health and environ-
 mental consequences that
 must be addressed. Examples
 include:

 • Extensive exposure to
 asbestos in numerous build-
 ings where this cancer-causing
 substance has been used for
 insulation and fire-proofing;

 • Contamination of harbors,
 lakes, and rivers with poly-
 chlorinated biphenyls (PCBs]
 that accumulate in fish and
 shellfish;
 • Buildup of persistent pesti-
 cides such as DDT, aldrin,
 and chlordane in the tissues of
 people and wildlife as the pes-
 ticides are passed through the
 food chain; and
 • Ground water contaminated
 by pesticides and toxic  sub-
 stances that leach readily in
 many soils.
   As described in earlier
sections of this report, EPA is
controlling exposure to toxic
chemicals by regulating air
emissions, water discharges,
and the disposal of chemical
wastes on the land. This
chapter discusses EPA's
alternative, "front-end"
approach which can ban or re-
strict the manufacture and use
of new and existing chemicals
to prevent or remove any un-
reasonable risks that a sub-
stance may pose to human
health or the environment.
This is EPA's general
approach to the control of
both commercial chemical
substances under the Toxic
Substances Control Act
(TSCA) and pesticides under
the Federal Insecticide, Fungi-
cide and Rodenticide Act
(FIFRA).
   This chapter begins with
an overview of this approach
and the progress EPA has
achieved in addressing the un-
reasonable risks of toxic sub-
stances and pesticides. The re-
mainder of this chapter pre-
sents in more detail some of
the challenges we face today
and EPA's  response.
                                                                           93

-------
                         AN  OVERVIEW
                          People have long recognized
                          that sulfuric acid, arsenic
                          compounds, and other chem-
                          ical substances can cause fire,
                          explosion, or poisoning.
                          Although accidents and mis-
                          use of chemicals continue to
                          occur, we have learned to
                          handle chemicals to minimize
                          these hazards. More recently,
                          we have become aware that
                          many chemical substances
                          such as benzene and a number
                          of chlorinated hyrdocarbons
                          present potential risks of can-
                          cer, birth defects, and other
                          chronic health effects. More
                          often than not, however, de-
                          termining which chemical
                          substances will cause harmful
                          effects under what circum-
                          stances is shrouded by
                          uncertainty.
                              Often chronic health ef-
                          fects can result only after long-
                          term exposure to toxic chem-
                          icals. In other cases, such
                          effects may develop many
                          years after a single exposure.
                          Furthermore, these toxic sub-
                          stances can work together or
                          in combination with other
                          substances such as those in
                          cigarette smoke to greatly in-
                          crease the likelihood of
                          chronic health effects. We
                          understand little about the
                          synergistic effects of these
                          substances.
                              Since its inception, EPA
                          has had regulatory responsibil-
                          ity for pesticides under the
                          1947 Federal Insecticide, Fun-
                          gicide, and Rodenticide Act
                          (FIFRA). This law has been
                          amended to encompass all
                          pesticides used in the United
                          States and requires a balancing
                          of a pesticide's benefits
                          against its health and environ-
                          mental risks. In 1976 Con-
                          gress passed the Toxic Sub-
                          stances Control Act (TSCA).
                          This new legislation has given
                          EPA the tools to identify and
                          control unreasonable risks
94

-------
Source EPA's Office of Pesticide Programs

that may be posed by some of
the thousands of commercial
chemicals that are not reg-
ulated as either drugs, food
additives, cosmetics, or
pesticides.

SOURCES
OF THE PROBLEM
AND EPA'S APPROACH

With sales of over $182 billion
per year, the chemical in-
dustry consists of over 12,000
firms employing over one mil-
lion people.  Many of the
chemical industry's products
are derived from oil or natural
gas. These substances are
often termed petrochemicals
and, except for the nitrogen or
ammonia derived from natural
gas, they are organic com-
pounds. The remainder of the
industry produces inorganic
chemicals such as chlorine
and soda ash; industrial gases
such as  oxygen, nitrogen, and
helium; and a variety of mis-
cellaneous chemicals. Other
industries that are major
sources  of toxic substances in-
clude those involved in metal
and mineral processing.

Commercial
Chemical Substances
TSCA gives EPA authority to
control the risks from the
60,000 commercial chemical
substances currently in com-
merce. For new commercial
chemicals, EPA requires a
manufacturer to submit a
"premanufacture notice" that
contains the chemical's name,
structure,  production process,
intended uses, and other avail-
able information about the
health and environmental
effects of the chemical. EPA
may prohibit or limit the pro-
duction and use of a new
chemical if it presents an un-
reasonable risk to health or
the environment.  EPA has
similar authority to review
and control significant new
uses of existing chemicals or
chemicals newly imported in-
to the United States.
    For existing commercial
chemicals, TSCA gives EPA
the authority to regulate the
manufacture, processing, dis-
tribution, use, and disposal if
there are unreasonable public
health or environmental risks.
Regulatory tools range from
labelling and use restrictions
to outright bans on their
manufacture.
    TSCA also authorizes
EPA to require that industry
test a chemical when there is
insufficient data to assess the
risks and there is  likely to be
substantial exposure. EPA also
may require industry to main-
tain records  of allegations of
significant adverse reactions
by workers and to report new
information  that suggests
there may be substantial risks
associated with the substance.

Pesticides
About  3.5 billion pounds of
formulated pesticide products
(1.2 billion pounds of active
ingredients) are used in the
United States each year. As
might be expected, farmers are
the biggest users of pesticides,
                                                                                            accounting for about two-
                                                                                            thirds of all pesticides used
                                                                                            (Figure T-2).
                                                                                                As a class, pesticides are
                                                                                            at the same time among the
                                                                                            most beneficial and the most
                                                                                            hazardous of substances. Far-
                                                                                            mers depend upon pesticide
                                                                                            products to protect crops from
                                                                                            insects, mildew, plant disease,
                                                                                            and other pests. Health offi-
                                                                                            cials need  them to combat the
                                                                                            spread of diseases carried by
                                                                                            mosquitos and other insects.
                                                                                            On the other hand, because
Chemical products are now an
accepted part of everyday life.
                                                                                                                    95

-------
pesticides are designed to kill
living organisms, unintended
exposure to them can be very
hazardous if sufficiently high.
Because most pesticides are
used on human or animal food
crops, human dietary exposure
is often unavoidable.
    Under FIFRA, EPA has
authority to control the nsks
of pesticides primarily through
a registration process. All pro-
posed uses of a pesticide must
first be approved by EPA. This
process involves a com-
prehensive review of potential
health and environmental
risks. The approved uses of a
pesticide must be clearly in-
dicated on the product's label.
EPA has the power to initiate
civil or criminal proceedings
against any violation of the di-
rections on the pesticide's
label. EPA may also restrict or
cancel some uses of an ex-
isting registered pesticide or
completely remove the prod-
uct from the market if it is
found to pose unreasonable
risks. Finally, EPA has author-
ity to establish the maximum
acceptable levels of pesticide
residues in foods and animal
feed, called "tolerance levels,"
that will protect human
health while allowing for the
production of an "adequate,
                                      • •
             wholesome and economic
             food supply."

             PROGRESS TO DATE
             Commercial
             Chemical Substances
             Since the enactment of TSCA,
             EPA has screened more than
             3,300 new commercial chemi-
             cals. The majority of these
             chemicals were found to pre-
             sent no unreasonable risk to
             human health or the environ-
             ment. As a result of these re-
             views, however, EPA has pro-
             hibited or restricted the man-
             ufacture of 37 new com-
             mercial chemicals pending the
                    A
                   APPROACH fc
                               FOR
      „ Jfeefa*? complete risk assessments can
      ' tyut mv&at mtffidB,«Wte$, they can
       •JB&lf- is? z&iaited far a small ftacttm of.
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                     of cJtemicats ttte withotit
                epsts, To. this end, -2M has
              ®(t a mal&'fac&ed ajp-Qscfi for
                w&fcfe of toe thousands of new-
                iig commercial chetMcals to
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                indudes':     ;    '""      •  ,
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       chemical dosses have repeatedly been
       shown to p&se little, if anyf possible risk
      : f&iatiam health or the enmonmmt ;1&. '
     '•" tfte new chemical review prospam,
      • &Kad4ta$e4 exemptions are being con-.
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      . faiffmtemates that aremaffljfuctttred • ,
      .- an^d consumed only withm the pKkfee-
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     •\«&falfeifc wftwe exgoswes OK exacted
     ' •<.'w'mtaf(timaL These ^fdqgtlQns-jroaM
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development of additional test
data. EPA has also extended
the 90-day time limit for the
review of numerous other new
chemicals to allow for more
thorough reviews or to give
the applicants an opportunity
to submit additional informa-
tion. As a result of these ac-
tions, 61 new chemicals have
completed or are now under-
going extensive health and en-
vironmental testing.
    After several years' expe-
rience in new chemical review
and regulation, EPA can now
act more quickly to identify
potential problems. EPA's risk
assessments now screen
chemicals for cancer, genetic
mutation, birth defects, dam-
age to the nervous or immune
system, and reproductive fail-
ures  as well as adverse en-
vironmental impacts.
    We have chronic health
effects and environmental data
for only a small fraction of the
chemicals in commerce.
Identifying which among the
thousands of existing com-
mercial chemicals to test is a
very important first step in
managing risks from these
chemicals. By March 1984,
EPA had decided  to request
additional health and environ-
mental testing by the man-
ufacturers of 46 chemical
groups. In addition EPA has
reviewed, or is currently
reviewing, an additional 20 ex-
isting chemicals or chemical
                                                                  IN FOOD HAVE
                                                                 ,
                                                                                        Source U S Food and Drug Administration
                                                                                        Diet Studies
96

-------
             WHILE NEARLY EVERYONE NOW HAS
            ^4^<->;"«>V^^*,r;i''':W ;••,-"-= *'" -' •
            ;^^|*|it-:;^^lll%iH';^:'^ %!/T\ '::'•
                                  ^^ . Population with
                                       '
                                                    ••
                        ' LEVELS HAS GONE DOWN
Source EPA's Office of Toxic Substances

groups for possible regulatory
controls. Examples of chem-
icals in the regulatory review
process are:
• MBOCA. A curing agent
used in plastics manufacturing
has been shown to be carcin-
ogenic in several species of
animals.
• MDA. A high-production
chemical, used primarily as an
intermediate in the man-
ufacture of other chemicals,
has been shown to have
serious carcinogenic potential.
• Two glycol ethers and their
acetates. Large-volume  chem-
icals used primarily as sol-
vents for protective coatings
and as intermediates may
cause birth defects and  liver
and kidney damage.
• 1,3-butadiene. A large-
volume commodity chemical,
used primarily in the produc-
tion of synthetic rubber and
resins, is an animal
carcinogen.
• TDA. A large-volume
chemical used primarily in
the manufacture of
polyurethanes (plastics) has
been found to be carcinogenic
in animal studies.
• Epichlorohydrin. A large-
volume chemical, used as an
intermediate to produce
glycerin and epoxy resins, has
been found to be carcinogenic
in animal studies.
    Earlier actions taken
under TSCA have already be-
gun to show results. For ex-
ample, restrictions on the use
and disposal of polychlorinated
biphenyls (PCBs) has resulted
in a significant decline
of these residues in the
environment, food (Figure T-3)
and human tissues (Figure T-4).
While trace levels (less  than
three parts per million)
of PCBs are now almost


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                                                                                                                     97

-------
 uniformly present in the U.S.
 population, the number
 of individuals with high PCB
 levels (greater than three
 parts per million) has declined
 dramatically to less than one
 percent of the population.
     Similarly, prior to EPA's
 1978 ban on the use of chlor-
 ofluorocarbons (CFC) in aero-
 sol sprays, estimates of ozone
 depletion in the upper atmos-
 phere were as high as 18.6
 percent.  At that rate, the in-
 crease in ultraviolet light
 reaching the earth's surface
 would raise the incidence of
 skin cancers and have sub-
 stantial impacts on crop pro-
 duction. Since  CFC produc-
 tion dropped to approximately
 half of what it was before
 1980, estimates of the
 amounts of ozone depletion
 were revised considerably
 downward to between five and
 nine percent. A better under-
 standing of stratospheric che-
 mistry has further revised that
 estimate to between two and
 four percent based on 1980
 production levels.

 Pesticides
 EPA has cancelled some or all
 uses of a number of pesticides
such as DDT, aldrin, dieldrin,
toxaphene, and ethylene di-
bromide (EDB) because of both
their toxicity and persistence
(Figure T-5). These com-
pounds generally do not break
down in the environment but
accumulate in the tissue  of
living organisms, including
people who consume
food containing pesticides.
Figure T-6 shows the trends of
Aerial spraying of a pesticide
                                   Source EPA's Office of Pesticide Program;
98

-------
these pesticides in fish and
birds in the United States. As
a result of the banning of
DDT and dieldrin there has
been dramatic resurgence of
birds that had been threatened
by extinction. As illustrated in
Figures T-8 and T-9, the levels
of these pesticides in food
have also significantly de-
clined. The levels of pesticides
in people have also either di-
minished or are soon expected
to do so in a pattern similar to
that of DDT (Figure T-7).

TODAY'S TOXIC
SUBSTANCES CONTROL
CHALLENGES

The following sections of this
report present some of the
major challenges EPA faces to-
day in managing risks from
pesticides and other com-
mercial chemicals. Briefly,
these challenges are:

• Reducing unreasonable
risks from pesticides. EPA's
continuing challenge is to
identify and reduce unreason-
able risks posed by pesticides.
The contamination of ground
water by pesticides has recent-
ly emerged as  a major en-
vironmental threat.

• Controlling critical toxic
substances. Dioxin, asbestos,
and polychlorinated biphenyls
are examples of the challenges
that EPA faces in controlling
the risks of chemical sub-
stances that are highly toxic
and have become widespread
in our environment. EPA
must use all of its authority
and work closely with other
agencies to address the risks
these substances present.
                             FIGURE T-6

EPA ACTIONS HAVE RESULTED IN DECLINING PESTICIDE LEVELS
                                                                                           Source U S Fish and Wildlife Service
                                      Pacific   Central
                                                         Mississippi   Atlantic
                                                                          WATERFOWL
                                                                            FLYWAYS
                                                                                                                    99

-------
                           HGORE T-7
                 PESTICIDE LEVELS CONTINUE
                   TO DECLINE IN HUMANS
DDT AND DIELDRIN LEVELS IN FOOD
        HAVE GONE DOWN
                                                                                                BCURET-9

                                                                                                DIELDRIN
Source EPA's Office of Toxic Substances, Human Adipose Tissue Program
                                                         Source U S Food and Drug Administration Dietary Studies
                                                                                     atee fgsdteRf IP
                                                                   .».
                                                      metabolism of
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                                                                            lid      552 mated pairs of birds.
                   a fcrown peMcm become
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               pt^ssme from SPA and the Los
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            ^c^aet stopped piping its con-
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                                               iA^ .eottifei
-------
Toxic CHEMICALS
Pesticides
THE

PROBLEM
Pesticides contribute signifi-
cantly to improved crop yields
and to public health by con-
trolling a wide variety of
pests. On the other hand, pes-
ticides can adversely affect
people and non-pest organ-
isms. Each year, almost 3.5
billion pounds  of pesticides
are used in the United States.
If not handled correctly, some
pesticides can cause serious
health problems, even death if
spilled on the skin, inhaled, or
otherwise misused. Some of
the earlier pesticides also per-
sist in the environment over
long periods  of time, moving
up through the food chain —
from plankton or insects to
birds, fish, animals, and even-
tually to humans through
food. Finally, some pesticides
exhibit evidence of causing
chronic health effects such as
cancer or birth defects. In
short, while  pesticides were
initially considered to be a
sort of modem day miracle,
they have now come to be
viewed more circumspectly.
EFFORTS

To DATE
Under FIFRA, EPA registers or
licenses all pesticide products.
EPA must approve any use of
a pesticide, and manufacturers
must clearly state the con-
ditions of that use on the pes-
ticide label. Under this pro-
gram, pesticide package safety
and label instructions and pre-
cautions have been improved
substantially. Use of es-
pecially hazardous pesticides
is restricted to certified appli-
cators. Allowable limits of
pesticide residues in food are
set by EPA in cooperation
    with the U.S. Food and Drug
    Administration. When partic-
    ular pesticides present unrea-
    sonable risks, EPA may under-
    take a variety of actions in-
    cluding immediate temporary
    suspension, permanent
    cancellation, or restriction of
    some or all uses.
        EPA conducts research on
    potential health and environ-
    mental effects of pesticides
    and on ways to use them that
    minimize unintended ex-
    posures in the environment.
    EPA also has sponsored re-
search in the area of Inte-
grated Pest Management to
achieve equal or greater pest
control using less pesticide.
    Under FIFRA, the States
have primary responsibility for
enforcing pesticide use regula-
tions. States may also es-
tablish EPA-approved pesticide
certification and training pro-
grams. Individual States have
also taken independent action
to restrict certain pesticides.
Some have more stringent
controls governing pesticides
than Federal programs.
                                     FIGURE T-10
               PESTICIDE USE PLAYS A MAJOR ROLE IN AGRICULTURE
      TYPE OF PEST
      CONTROLLED
        Total Agricultural Usage:
1.2 billion pounds of active ingredient per year
             (U.S. only)
                      Insects and mites 30%
                                                     WHERE USED
                                                                                                  Cotton 24.0%
                                                 Tobacco 3.7% -

                                                Livestock 0.8%-
                                               Ornamental 1.3% —
                                         Hay and small grain 3.6%"


                                                 Sugar beets 2.5%


                                                     Sorghum 3.7%
                                                            Other 3.8%
                                                                                                     Corn 24.5%
                                                                   Vegetables 5.9%
                                                                                         Soybeans 11.2%
 102

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TODAY'S

CHALLENGES

EPA faces many challenges in
protecting human health and
the environment from unrea-
sonable risks of pesticides.
The following are some of the
most significant of these
challenges.

Re-Register Pesticides
Over 50,000 pesticide products
have been registered since the
program began in 1947. Most
pesticide products were reg-
istered before we fully under-
stood the long-term health
and environmental effects of
these chemicals and must be
re-registered with these effects
and others, such as potential
for contaminating ground
water, in mind. This task is
complicated by the need to
ensure reliable registration
data. In the past, several cases
have occurred in which in-
valid or misleading data have
been submitted.

Avoid Abuse of Emergency
Exemptions
Emergency exemptions may
be granted to State or Federal
agencies, authorizing pesti-
cides to be used for purposes
not yet registered. Emergency
situations must meet the
following requirements: (1)
there is no registered pesticide
or alternative method to con-
trol a pest outbreak;  (2) sig-
nificant economic or health
problems will occur without
the use of the pesticide; and
(3) the time available is insuf-
ficient for a pesticide to be reg-
istered for that particular use.
    An EPA audit of the
Emergency Exemption pro-
gram has led to concern of
Source EPA's Office of Pesticide Programs

possible abuse or at least over-
use. Since the uses involved
have generally not undergone
as extensive a risk assessment
as is normally required for
registration, Emergency Ex-
emptions should only be au-
thorized for genuine emergen-
cy situations.

Stop the Misuse and
Careless Application of
Pesticides
The purpose of the registra-
tion process is to evaluate the
risks from particular uses of a
pesticide and limit the risks,
where necessary. If a person
uses a pesticide in-
appropriately, it may cause
significant risks to public
health and the environment.
The large number of pesticide
users makes enforcement of
pesticide restrictions very dif-
ficult. A particular problem is
how pesticides are applied.
Failure to apply pesticides
carefully, particularly from
airplanes or helicopters, can
result in damage to nontarget
crops, contamination of
streams, and direct exposure
to man, domestic animals,
and wildlife. Such pesticide
drift has posed problems in all
major crop-producing regions
of the country.

Prevent Ground-Water
Contamination
In some areas of the country,
ground-water wells are con-
taminated with pesticides.
Such contamination has often
been a result of improper or
excessive uses of pesticides. In
some  cases, it may have been
caused by approved uses as
well. Certain types of pesti-
cides such as high-soluable,
soil-applied pesticides are now
known to have great potential
to move downward through
soil in areas where the soil is
sandy or where irrigating is
extensive.

Improve Environmental
Information
For some time, there has been
little coordinated effort to
monitor long-term trends of
pesticide contamination in the
environment. The U.S. Fish
and Wildlife Service does
monitor for some pesticides in
fish and birds while EPA
monitors for pesticide in
human tissues. USDA moni-
                                                                                                                   103

-------
tors for pesticide residues in
meat and poultry. The U.S.
Food and Drug Administration
(FDA) performs residue anal-
ysis for all other food prod-
ucts. These and other State
and local efforts are not well-
coordinated. The lack of well-
coordinated pesticide
monitoring efforts makes it
difficult to determine what
the nature and extent of pesti-
cide contamination of the en-
vironment is.
•Mfttf^He^wir 5ft. JiM*^iiMM*fer"f¥» "y^%»««r*PMii^-"y ^i»dPii:lliii.rfiMr*
                                  FUTURE CONCERN
                       , » modify  -
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                             toMtor-
                                   . .products $ '$
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-------
EPAs

AGENDA
Expedite the
Re-Registration of Existing
Pesticides
EPA has established the Regis-
tration Standards Process to
streamline the re-registration
of existing pesticides. Instead
of re-registering each of the
thousands of pesticide prod-
ucts on a case-by-case basis,
EPA is developing com-
prehensive standards for each
of the 600 basic active in-
gredients used to formulate all
pesticide products. Currently,
EPA has set standards that
cover 25 percent of existing
pesticide products or 35 per-
cent of the total tonnage of
pesticides used in the United
States. By the end of 1985,
EPA plans to increase its
coverage to about 52 percent
of total U.S. pesticide tonnage
by developing and applying
standards for an additional 50
basic active ingredients in the
next two years.
    To assure validity of
registration data, EPA and the
U.S. Food and Drug Adminis-
        DDT  LEVELS FOUND To BE
        DDT has been turwng op in increasing concentrations
        in several western States, Officials in Cafi/bnjia and
        Tessas,. where, elevated lewis of the pesticide could
        tbmatm critical wildlife bleeding gtotmd$t Relieve that
        the fresh cdatattttGatiOB is a result ofAm&icm farmers
        using DDT purchased in Mexico, where it is still used
        legally. U.S. Pish and Wildlife Service (FWS) officials
        share that belief, MPA, however, is reviewing the pesti-
        cide dicofol, which is legally registered in, toe United
        States, as a possible source of this contamination
        problem.
          According to a PWS study, the most critical aim of
        DOT contaroination appears, to be the Arroyo Col-
        orado watershed of western Texas, where jftslt and
        tiicts 'h&veresidues within or above the rongeknown
        to canse jBfJUlatrott declines, More importantly, the
        report finds tfte contaminated area empties into the
        LaganaMadfe, me of the most extensive breeding
        and uneasy grounds for fish and wildlife in the
        United States, The FWS study found DDT levels as
                              high as 40 and SO'parts per mUBkai in some ipse/fes.
                              If cancenttaMQOshadfoem daeMmtmg'-at, the speeted
                              rate, Jevels:-$honJd fe? down to- tie am m'tjvo jtarts
                              pgr mUMon raagA State health o^pstels b&vs- men
                              concerned'mengh to      warnings afcoat eating fish
                              from the Arroyo Gototado area.
                                CaMforai® afffatds haw 
-------
                ^.'  w   ,0^^




tration are conducting audits
of testing facilities to de-
termine if they are using
sounti laboratory practices and
ensure that the data and re-
ports submitted accurately re-
flect the test results.

Re-examine the Emergency
Exemptions Program
EPA is planning to revise its
regulations for emergency ex-
emptions and is holding hear-
ings across the country to so-
licit comments from the pub-
lic prior to publishing any pro-
posed changes. One possible
option being discussed is to
limit the period of time an ex-
emption can remain in effect.
EPA also will be examining
the need for more stringent
criteria for risk and economic
loss information which must
be shown to support a claim
of emergency exemption.

Ensuring Proper Use and
Application
EPA will continue to support
State enforcement efforts with
Federal funds and training of
State enforcement personnel.
EPA will also continue to pro-
vide funds to States for the
certification and training of
applicators. Enforcement
efforts will focus on ensunng
proper use of pesticides, par-
ticularly for cancelled or sus-
pended products.
    To address the pesticide
drift problem, a spray drift
task force has been established
to assist States. The task force
includes EPA, the U.S. De-
partment of Agriculture, and
the National Aeronautic and
Space Administration along
with State officials and in-
dustry representatives. EPA is
exploring the usefulness of ap-
plicator training sessions in-
cluding pre-season "fly-ins,"
which are used to demonstrate
the latest methods and
equipment for reducing drift
problems.

Focus on Prevention of
Ground-Water
Contamination
EPA will focus its registration
process on assessing the
potential for pesticides to
reach ground waters. EPA will
publish guidelines advising
registrants on how to develop
data needed to predict the
potential for pesticides to con-
taminate ground waters. EPA
is also supporting the de-
velopment of new scientific
models for predicting the
movement of pesticides in the
soil into ground waters and is
developing ground-water
monitoring strategies. Finally,
EPA will continue to publish
health advisories for pesticides
in drinking water to assist
States in dealing with their
ground-water problems. (See
section on Ground-Water
Protection.)

Implement a National
Pesticides Monitoring Plan
A final plan for a National
Pesticide Monitoring Program
will be completed in 1984 and
implemented beginning in
1985. The program  will help
assess the actual environmen-
tal results of pesticide regula-
tory policies, program, and ac-
tions. The effort will also help
uncover any new environmen-
tal contamination problems.
The plan will emphasize in-
volvement of other Federal,
State, and local agencies.
106

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107

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Toxic CHEMICALS
Dioxin
THE

PROBLEM

One of the most hazardous of
all chemicals, dioxin (2,3,7,8-
tetrachlorodibenzo-e-dioxin or
TCDD) can cause both acute
and long-term effects ranging
from chloracne, a skin disease,
to cancer, reproductive fail-
ures, and reduced resistance to
infectious disease.
    Dioxin is an inadvertent
contaminant produced in the
manufacture of trichlorophe-
nol (TCP), an herbicide and
basic feedstock  chemical used
to produce the herbicides
2,4,5-T and silvex. Also con-
taminated with dioxin, these
two pesticides were used until
recently in agriculture, forest
management, and lawn  care.
The herbicide 2,4,5-T was also
an ingredient of Agent
Orange, a defoliant used in
Vietnam.
EFFORTS

To DATE
EPA has taken a number of
regulatory actions to control
dioxin contamination. In 1973,
the Agency attempted to can-
cel the registration of the pes-
ticide 2,4,5-T because of its di-
oxin contamination. This
effort was not successful, par-
tially because analytical che-
mistry techniques were not
available at the time to
 2,4,5,7-Tetrachlorodibenzo-g-dioxin

          DIOXIN
  measure dioxin at the ex-
  tremely low levels found in
  food or the environment. In
  1979, EPA placed an im-
  mediate suspension on the
  majority of 2,4,5-T and silvex
  uses, including their use  in
  forests, rights-of-way, pastures,
  and home gardens. In 1980,
  under the Toxic Substances
  Control Act, EPA required
that anyone handling dioxin-
containing wastes notify EPA
60 days before moving or dis-
posing of the wastes. Finally,
in October 1983 the Agency
proposed to cancel registration
of all remaining uses of 2,4,5-
T and silvex. Currently, EPA
is not aware of any production
of TCP,  2,4,5-T or Silvex  in
the United States.
                          _                   per trillion of dioxin

       »4*,3»4,&-f registered as awstkttte with U.S.  »7» ^& i
                                         USDA establishes residue levels for
                                                                            2,4,5-T spraying of forest and miscarriages in
                                                                                              "
                                     im
                                     likelihood of
jAlMBBSB exjXJSWKK   IfiA stndy-IM^ low te»dn««to«|B^teia<;
                 .  KX ia&MUft&ffi&KM' * "' "   '"  *"
                   municipal incinerators
       EPA is formed and

       »71 lab s
       4 number w

        1973 Viemaroese study links higher incidences
                     -

                                                                   > in non-
                                     prescription soaps and deodorants out of con-     dioxin-contaminated wastes
                                     cem for possible dioxin contamination
                                                                            mem discussions begin
                                     defects to A^rt^
                                     EPA begins cancellation hearings for remaining
                                     use«< "

                                                 i cancellation hearings because
                                                 '""  ' Is Ii3«aild«t «j 4«er-
                                     gram to improve analytical capabilities

                                        i Cheaical pbott-itiL My m»toa*js spead-
                                     Lng dioxin through densely populated area

                                     1977 Dioxin Implementation Program develops
                                              50pttsip«»ffllw
-------
TODAY'S

CHALLENGES

While it appears that the ma-
jor sources of dioxin (i.e., TCP
production and the use of
2,4,5-T and silvex) are being
eliminated, other potential
and uncontrolled sources of
dioxin have been identified.
These include: (1) the produc-
tion of other chlorinated
chemicals similar to TCP;  (2)
fires involving electrical trans-
formers containing polychlor-
inated biphenyls (PCBs); and
(3) the burning of some mu-
nicipal wastes that may con-
tain significant amounts of
either plastics made of poly-
vinyl chloride or wood pre-
served by certain chlorinated
chemicals.
    Moreover, the extent of
dioxin contamination and
associated health risks at sites
where dioxin-containing prod-
ucts were produced, used, or
disposed of remains uncertain.
To date, EPA knows that at
least the following places have
some degree of contamination
by dioxin:
• Thirty-three sites in
Missouri;

• Tittabawassee River and
Saginaw River and Bay, Michi-
gan (Dow Chemical plant);

• Newark, New Jersey (Dia-
mond Shamrock plant];

• Hyde Park Landfill, New
York;

• Bayou Meto, Arkansas (Ver-
tac plant, Jacksonville); and

• Sauget, Illinois (Clayton
Chemical site).
    The challenge for EPA is
to identify and clean up sites
that may pose significant nsks
from dioxin.
Times Beach, Missouri where dioxin contamination resulted in the
abandonment of homes
EPA'S

AGENDA

EPA is implementing a
national strategy to determine
the extent of dioxin con-
tamination and; where neces-
sary, limit further human ex-
posure by isolating and
cleaning up contaminated
sites. In addition, EPA will
identify disposal methods to
alleviate current problems and
develop regulatory measures to
prevent future contamination.
    EPA estimates that 80 to
90 percent of dioxin con-
tamination will be found at
TCP manufacturing, process-
ing, and waste disposal sites.
Cleanup activities at these
areas will be managed under
the Superfund program. Con-
gress has provided special
funds to address other dioxin-
contaminated sites.
    Dioxin research will be
undertaken with other Federal
agencies to learn more about
its effects with different types
and levels of exposure. EPA
also has concern for the
potential adverse effects of a
number of chemicals  that are
very similar to TCDD in
chemical structure. EPA will
be investigating their presence
in the environment and toxic-
ity as part of the Agency's di-
oxin research effort. EPA is
evaluating alternative ways to
    Source Poland and Knutson,
    Annual Review of Pharmacology and
    Toxicology, 1982

dispose of soils and wastes
contaminated with dioxin
such as solvent extraction of
dioxin from soils and
incineration.
    In addition, EPA has in-
itiated other regulatory activi-
ties, such as the addition of
several industrial wastes that
often contain dioxin to the list
of hazardous wastes regulated
under the Resource Conserva-
tion and Recovery Act.
                                                              Substance
                                                              Boftdiaum
                                                              Tetaoos toxla  ,  - •£
                                                              Diphtheria ftttto.: >''
                                                              Curare
                                                              Strychnine
                                                              Miweatio
                                                                Source EPA's Office of Toxic Substances
                                                                                                                 109

-------
 Toxic CHEMICALS
 Asbestos
 THE

 PROBLEM

 A strong and incombustible
 mineral fiber, asbestos has
 been widely used for fire-
 proofing and insulating homes
 and other buildings. Some
 800,000 tons of asbestos have
 been mined or processed in
 the United  States each year to
 make about 3,000 different
 products, two-thirds of which
 have been used in the con-
 struction industry.
     Once in the air, asbestos
 fibers, much smaller and more
 buoyant than ordinary dust
 particles, float almost in-
 definitely and can easily be in-
 haled or swallowed. Once the
 fibers enter  the body, they can
 cause a number of serious dis-
 eases including:

 • Asbestosis. A chronic dis-
 ease of the lungs which makes
 breathing more and more dif-
 ficult and can cause death.

 • Cancer. Breathing asbestos
 fibers can cause lung cancer.
 Also, since some of the asbes-
 tos fibers are rejected by the
 lungs, move up to the throat,
 and are swallowed, breathing
 asbestos may also cause can-
 cer of the esophagus, stomach,
 intestines, and rectum.
 • Mesothelioma. A cancer of
 the membranes that line the
 chest and abdomen. Mesothe-
 lioma almost never occurs in
 people who  have not been ex-
 posed to asbestos. It is always
 fatal.
    Once asbestos gets into
the body, it remains there in-
definitely. It can move from
the lungs to almost all other
parts of the body. Cancers can
occur anywhere from 15 to 40
years after the first exposure.
No safe limit or "threshold"
of exposure is known. Any ex-
posure to asbestos carries
some risk to health, and peo-
ple exposed to low levels of
asbestos for a very brief period
have later contracted mesothe-
lioma. Finally, anyone exposed
to asbestos who also smokes
cigarettes has five times the
likelihood of contracting lung
cancer than does a cigarette
smoker who has not been ex-
posed to asbestos.
110

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Top: Raw chrysotile asbestos. Bottom: Magnified asbestos fibers.
    Asbestos was once con-
sidered a health risk only for
asbestos workers. Now asbes-
tos is known to be a potential
hazard to the health of mil-
lions of people, on and off the
job, who are routinely exposed
to asbestos fibers in the air
they breathe. Among those
whose health may be en-
dangered by asbestos are chil-
dren, teachers, and others in
schools where  asbestos was
sprayed or troweled  on ceil-
ings, rafters, beams,  and  other
structural building parts  for
fire-proofing, insulation,
sound-deadening, or
decoration.
EFFORTS

To DATE

The Occupational Safety and
Health Administration has es-
tablished limits for worker ex-
posure to asbestos on the job.
The Food and Drug Adminis-
tration is responsible for mak-
ing sure that foods, drugs, and
cosmetics are not con-
taminated with asbestos. The
Consumer Products Safety
Commission (CPSC)  regulates
asbestos in consumer pro-
ducts,- it has already banned
the use of asbestos in hair
dryers, consumer clothing,
ceramic logs in gas-fired fire-
places, and dry-wall patching
compounds. CPSC is studying
the extent of asbestos use in
all consumer products and is
considering banning all non-
essential uses of asbestos in
consumer products that can
release asbestos fibers.
    In addition to regulating
air and water contamination
by asbestos, EPA also prohib-
ited the spraying of asbestos
materials for fire-proofing and
insulation in  1973,  banned the
use of asbestos that can
crumble in pipe and boiler
coverings in 1975, and prohib-
ited virtually all uses of
sprayed asbestos materials in
1978.
    Of particular concern is
the exposure of children to
asbestos as a result of the use
of this material for insulating
and fire-proofing school build-
ings. Since children would be
exposed early in their lives,
asbestos-induced cancers
would have plenty of time to
develop. To safeguard the
health of school children, EPA
issued regulations under
TSCA and launched a pro-
                                                                                           gram to: (1) have schools in-
                                                                                           spect their buildings for
                                                                                           asbestos; (2) maintain inspec-
                                                                                           tion records; and (3) inform
                                                                                           employees and local PTAs
                                                                                           when asbestos is found. EPA
                                                                                          Damaged asbestos pipe insulation
                                                                                                                  111

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is conducting a survey to see
how many schools have com-
plied with these requirements
and what abatement activities
have been undertaken.
    EPA has prepared and
made available to State and
local governments and schools
two manuals that explain,
step-by-step, how asbestos
problems can be identified and
corrected. The Asbestos
School Guidance Package and
a videotape  outlining the pro-
cedures explained in the man-
uals is available from EPA's
Regional offices.
TODAY'S

CHALLENGES

Recent compliance informa-
tion indicates that many
schools are not complying
with EPA's regulations
requiring them to inspect
their buildings for  asbestos
problems. Furthermore, it is
difficult to determine if cor-
rective measures, when they
have been taken, adequately
reduce or prevent future expo-
sure. Moreover, EPA has not
yet addressed other sources of
asbestos in commercial as
well as other public buildings.
EPA's challenge is to make
sure that the hazards of ashes -
tos are identified and promptly
addressed to reduce exposures
by the general population.

EPA'S

AGENDA

EPA is increasing its com-
pliance monitoring efforts
aimed at ensuring the inspec-
tion of school buildings for
asbestos problems. Approx-
imately 2,500 compliance in-
spections will be conducted
during  1984 and 1985. EPA is
also in the process of
obtaining public comment on
more stringent regulations of
asbestos in schools. Such reg-
ulations would set acceptable
levels of asbestos in schools
which,  if exceeded, would re-
quire specific corrective
actions.
    EPA is currently gathering
information on the extent to
which friable asbestos-
containing materials are  pres-
ent in other public and com-
mercial buildings. Through its
technical assistance program,
the Agency is also continuing
to assist building owners in
the detection and correction of
hazards posed by asbestos.
Top: Asbestos in a lined drum for disposal at an approved landfill. Bottom: Asbestos being removed.
112

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113

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Toxic  CHEMICALS
 PCBs
THE

 PROBLEM

 Polychlorinated biphenyls,
 commonly called PCBs, were
 manufactured in the United
 States from 1929 to 1977.
 PCBs have characteristics that
 make them ideal for many
 commercial uses, especially as
 heat transfer fluids in electri-
 cal transformers and capacitors.
 PCBs have also been used as
 hydraulic fluids; as dye car-
 riers in carbonless copy paper;
 and in paints, adhesives, and
 caulking compounds.
 Although manufacturing and
 importing of all but research
 quantities of PCBs stopped
 over a decade ago, EPA es-
 timates there are over 750,000
 pounds of PCBs still in use  ifl
 transformers, capacitors, and
 other products.
    PCBs  are among the most
 stable chemicals known. Once
 they are released into the en-
 vironment, PCBs decompose
 very slowly over a period of
 several decades. Plants and  an-
 imals can  absorb PCBs from
 their surroundings and con-
 centrate these chemicals with-
 in their tissues to levels above
 those found in the environ-
 ment. As living organisms
 containing PCBs are eaten by
 other organisms, the amount
 of PCBs consumed by each
 higher organism increases.
 The concentrations consumed
PCBs are still in use in thousands
of electrical transformers.

by humans, at the end of the
food chain, can be significant.
    In well-documented tests
on laboratory animals, it has
been shown that PCBs can
cause reproductive disorders,
birth defects, gastric disorders,
skin lesions, swollen limbs,
cancers, tumors, and eye and
liver disorders, among other
health problems. The dangers
from relatively high exposures
to  PCBs were dramatically
and tragically demonstrated in
1968, when some 1,300 people
in  Yusho, Japan, used nee oil
that had been accidentally
contaminated with PCBs
leaking from a transformer.
The victims developed a vari-
ety of ailments characterized
as  "Yusho Disease"  including
skin lesions, eye discharges,
abdominal pain, and reproduc-
tive and nervous system dis-
orders. There is also evidence
of  an increased rate of cancer
PCB warning label on electrical
equipment

among the Yusho victims
who have died since 1968. As
a result of the Yusho tragedy,
the Japanese government vir-
tually banned the production,
import, or export of PCBs in
1972.
    PCB contamination has
also been observed in the
United States. Measurable
amounts of PCBs can be found
in soils, water, fish, milk, and
human tissue. Some fish in
the Hudson River, New Bed-
ford Harbor, Great Lakes, and
other water bodies have be-
come too contaminated with
PCBs for human consumption.
In addition, there have been
several major incidents of PCB
contamination in food proc-
essing plants. For example,  in
Billings, Montana, PCBs
leaking from  a transformer  at
a packing company con-
taminated animal feed that
was later distributed and used
in several States.
EFFORTS

To DATE

Until 1976, EPA could only
regulate discharges of PCBs in-
to waterways. Through the
enactment of TSCA in 1976,
Congress directed EPA to pro-
hibit the manufacture, proc-
essing, distribution and use of
PCBs, except for totally en-
closed uses. Congress also au-
thorized EPA to require ade-
quate labeling and safe dis-
posal of the PCBs still in use.
Under this authority, EPA has
issued regulations prohibiting
the manufacture and distribu-
tion of PCBs and limiting
their use to totally enclosed
electrical equipment. Where
there are no unreasonable
risks to health or the environ-
ment, EPA has allowed a few
additional uses of PCBs until
July 1, 1984. Some of these ex-
ceptions are currently being
considered for extension. EPA
requires weekly inspections of
transformers and electromag-
nets with a PCB concentration
of 500 parts per million or
greater in food or feed op-
erations and prohibits them
altogether after October 1,
1985. EPA has also established
strict regulations for the final
disposal of PCBs in in-
cinerators or chemical waste
landfills.
    With the banning of PCB
manufacturing and strict
limits on their use and  dis-
posal, the levels of PCBs in
the environment are begin-
ning to decline. In a number
of areas, including the Great
Lakes and the Hudson River,
fish that were once too con-
taminated with PCBs for
human consumption have re-
cently been found to have
much lower levels. While re-
strictions on fishing remain in
a number of these areas, there
is hope that levels will contin-
ue to decline and eventually
these areas can be reopened to
both commercial and sport
fishing.
 114

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    EPA surveys have also
found a decline in the number
of people with "high" levels
(i.e., greater than three parts
per million) of PCB in their
tissues although "trace" levels
(i.e., less than three parts per
million) are now ubiquitous
within the U.S. population.
                           TODAY'S           EPA'S
                           CHALLENGES   AGENDA
Thousands of electrical trans-
formers and capacitors con-
taining PCBs remain in use
throughout the United States.
The challenge for EPA is to
ensure that PCB-contaminated
equipment and fluids are prop-
erly maintained and disposed
of in accordance with the reg-
ulations under TSCA.
Ensuring compliance with
PCB regulations will receive
additional emphasis by EPA.
EPA's efforts will concentrate
inspections and enforcement
actions on the greatest poten-
tial sources of exposures to
PCBs and those industrial sec-
tors exhibiting  unacceptably
high violation rates such as
transformer manufacturing
facilities and scrap and salvage
operations. Because the life of
a transformer containing PCBs
can be 20 to 30 years, EPA
must maintain a vigilant en-
forcement effort for some
time.
   PCB  TRACES FOUND  IN HARBORS AND BAYS
   The EPA-sponsored U.S. Mussel Watch Program col-
   lected and analyzed mussels and oysters from 106
   stations along the Nation's Atlantic, Gulf and Pacific
   coastlines from 1976 to 1978. The soft tissues of
   these marine bivalves were analyzed for a variety of
   toxic substances including PCBs, pesticides, lead,
   plutonium, and petroleum contamination. Several
   "hot spots" of PCBs were identified including the
   mouth of New Bedford Harbor in Massachusetts,
   which has since been placed on the Superfund's
   National Priority List for cleaning up extensive PCB
   contamination.
     Also located were "high" PCB areas including
   some spots along the coast of Cah'fornia. As a result
   of concern for this contamination by PCBs and
   several other  toxic substances, the State of California
   initiated its own mussel watch program with
   specimens collected in 1977.
     The Cah'fornia Mussel Watch has recently found
   measurable levels of PCBs in the Los Angeles and
   Long Beach Harbors as well as in San Diego Bay and
   Newport Harbor.  While the amounts found do not
   exceed Federal health standards, they show for the
   first time that levels there have come close to the
   five parts per million Federal standard.
     The study found the most serious PCB problem in
   San Diego, where the level at one test site was dis-
   covered to be four parts per million. Here, the source
   appears to be an airport where PCB equipment was
   in heavy use.
     Los Angeles Harbor had lower levels of PCBs than
   that of San Diego, but residues were found through-
   out the area.  The major source in this harbor appears
   to be shipyards.
     Cahfomia is intensifying these monitoring studies
   to further pinpoint the sources of PCB contamination
   and determine if there is any threat to people or to
   the environment.
                       Monitoring stations
                       3 i
                       5 •
                      10

                      11 k

                      12
                      13
                      14

                      15

                      16

                      17

                      18

                      19

                      20

                      21

                      22

                      23
                                                 PARTS
                                                 PER MILLION
                                                                                                       115
                                                 •tr U.S.  GOVERNMENT PRINTING OFFICE :  1984 O - 444-729

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