United States
Environmental Protection
Agency
EPA JOURNAL
Communications, Education,
And Public Affairs
Volume 20, Number 1-2
Summer 1994
EPA175-N-94-002
       Clean Water Agenda	

       Remaking the Laws
       that Protect Our Water Resources



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United States
Environmental Protection Agency

Carol M. Browner
Administrator

Communications, Education,
and  Public Affairs

Loretta M. UcelJi
Associate Administrator
Miles Allen
Director of Editorial Services
Karen Flagstad
Senior Editor

Catharina Japikse
Assistant Editor

Ruth Barker
Photo Editor

Nancy Starnes
Assistant Editor

Marilyn Rogers
                                        A Magazine on National and Global Environmental Perspectives
                                        Summer 1994   •   Volume 20, Number 1-2  •  EPA 175-N-94-002
Marilyn Rogers
Circulation Manager

Francheska Greene
Intern
Design Credits
Ron Farrah
James R. Ingram
Front Cover: Photo by Nathan Farb
Sack Cover: Water Totvfff. Phixo copyright Jei!
Zaruba. Folio, Inc.
   Please note: Due to staff and
   resource limitations, only tivo issues of
   EPA journal (Summer 1994 and
   Fall 1994) ivill be published in the
   volume 20 (1994) sequence. Regular
   quarterly production w7/ resume with
   the Winter 1995 issue.  Subscribers
   will nevertheless receive four issues per
   $7.50 subscription.
Correction: Oue to an editorial error, October 1995
was incorrectly cited as the Congressionalty
mandated issue date lor EPA regulations that will
require realtors and landlords to provide home
buyers and renters with information on lead hazards
belore they move Into a home (Oct.-Dec. 1993
issue ol EPA Journal: article by Representative
Henry A. Waxman, p. 39J. The Congressional/
mandated Issue date is October 1994 lor
regulations intended to take effect October 1995.
From the Editors

        Twenty-two years ago, against the backdrop of a Cuyahoga River so
        polluted that it caught fire and inflamed public concern, Congress
        passed the first Clean Water Act. Targeting mainiy so-called
"point sources," such as municipal and industrial outfalls, the 1972 iaw set
a "fishable and swimmabJe" goaJ for a]] U.S. waters, a goal thought to be
achievable within a decade. The 1974 Safe Drinking Water Act, enacted
on the heels of the Clean Water Act, mandated national standards for
contaminants in drinking water and established monitoring requirements.
    Despite progress made over the last two decades, particularly in curbing
point-source pollution, serious problems remain.  These lingering problems
are more difficult to deal with than the kinds of gross pollution caused by
discharges of raw  sewage and industrial wastes. Today's problems are
primarily due to polluted runoff from farms and cities (diffuse "nonpoint-
source" pollution  that  does not lend itself to traditional regulation), which
is not adequately  controlled under current law. According to the most
recent data provided to EPA by the states, roughly 40 percent of assessed
rivers and lakes and more than 30 percent of assessed estuaries are pres-
ently not suitable for fishing,  swimming, or other uses.
    What's more, recent episodes involving waterborne disease in Milwau-
kee and elsewhere have raised alarms about the safety of U.S. drinking
water systems. As many state and local officials attest, funding is also a
problem, in many states and municipalities, there is a shortage of funds at
hand to deal with water pollution and other environmental problems.
States and localities are also concerned about a lack of flexibility in federal
standards.
    Both the  Clean Water Act and the Safe Drinking Water Act are cur-
rently up for renewal, affording an opportunity to strengthen  the legislative
framework for protecting U.S. water resources. This issue of EPA Journal is
keyed to the reauthorization debate on  both laws. D
EPA JOURNAL Subscriptions
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I202) 512-2262.
EPA Journal is printed on recycled paper.

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  Contents

  Clean Water Agenda:
  Remaking the Laws that Protect Our Water Resources
 Articles
                                                       Departments
| Q


   }


1 Q


2(1



22
T.f\
*1A
       The Administration's Proposals
          by Carol M. Browner

       The Clean Water Act: Has it Worked?
          by Robert  Adler

       Disaster in Milwaukee
          by Velma Smith

       Monitoring Lead in Drinking Water
          by David Urbinato

       Blue Plains:
       Saga of a Treatment Plant
          by Myron  F, Um;m

       Portland, Maine:
       Case of a Combined Sewer System
          by David Urbinato

       New York City:
       Case of a Threatened Watershed
          by Keith S. Porter

       Albemarle-Pamlico:
       Case Study in Pollutant Trading
          by John Hall and Ciannat Howett

      President Clinton's Clean Water Initiative:
      Costs and Benefits
          by Mark Luttncr

       Amending the Safe Drinking Water Act:
       View from Congress
          by Henry Waxman

       Amending the Clean Water Act:
       View from the States
          by Howard Dean

       Questions the Reader Might Ask
          An interview with Robert Perciasepe
                                                          |  EPA ROUNDUP

                                                         C  LIST OF CONTRIBUTORS
42  F°R THE CLASSROOM
     Exploring Water Quality
         by Stephen Tchudi

44  CHRONICLE
     London's Historic "Pea Soupers"
         bv David Urbinato
45
ON THE MOVE
Thy U.S. linvironment.il Protection Agency is charged by Congress to protect the nation's land, Air, and water systems. Under a mandate of national environmental laws, the
Agency strives to formulate and implement actions which lend to a compatible balance between human activities and the ability of natural systems to support ,\nd nurture life
 EPA journal is published by EPA. The Administrator of I!PA has determined that the publication of this periodical is necessary in the transaction of the public business
required by law of this Agency. Use of funds tor printing this periodical has been approved by the Director of the Office of Management and Budget. Views expressed bv the
authors do not necessarily reflect EPA policy. No permission necessary to reproduce contents except copyrighted photos and other materials.
 Contributions and inquiries arc welcome and should be addressed to: Editor, EPA Journal (1704), Waterside Mall, 401 M Street, SW, Washington, DC 20460.

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EPA ROUNDUP*
 New Superfund Law  Proposed
                                                                               hn Gillifrt fiinrto. l-PA. l-ctison, NJ.
 The Clinton Administration
 lias proposed a new Super/fold
 law  that will directly affect
 those 73 million Americans who
 live near hazardous waste sites.
 The new law would make
 Superfund cleanups faster,
fairer, and more efficient. EPA
 Administrator Carol Browner
 said: "America needs
 Superfund, but it needs a
 Superfimd that works.  The
 Administration is committed to
 ensuring that the funds go to
 cleanups, not lawyers.  We
 remain firm that polluters must
 pay-but we will limit the
 liability of small businesses and
 individuals. And our proposal
 will put people first by ensuring
 that communities are fully
 involved in clean-up  decisions in
 their towns and cities."

 The Washington Post
 commented:". . . Hastily
 enacted by Congress in
 1980 following the public
 outcry over the discovery of
 the Love Canal dump in
 upstate New York,
 Superfund mushroomed into
 a massive and complex
 federal program. In recent
 years, it has been beset by
 long delays in cleanups,
 hobbled by drawn-out
 lawsuits and burdened by
 enormous costs. It has come
 under attack by industry,
 environmental groups,
 insurers, and state and local
 governments.  The
 administration's proposal
 retains the original law's
 fundamental principle that
 polluters must shoulder the
 burden of cleaning up the
 thousands of hazardous
 waste sites identified by the
 government.  But it seeks to
 funnel more money into
 cleanups and less into legal
 and administrative costs by:
 limiting the liability of small
 polluters; providing
 incentives for polluters to
 agree to mediation rather
than to litigate; and using
new taxes on insurance
companies to settle old
claims against them by their
policyholders.  Under the
current law's liability
provisions, even a relatively
minor polluter of a
hazardous waste site can be
held liable for the entire
cleanup if other site
polluters are out of business
or cannot be found. In
addition, polluters can be
held responsible for
dumping of wastes even if
such actions were legal at
the time. The  law has thus
encouraged companies to
sue one another or their
insurance companies in an
attempt to shift some of the
blame-and the financial
liability-elsewherc. Under
the new plan, polluters that
agree  to a process of
apportioning responsibility
by a 'neutral professional'
would be protected from
further liability in the
future. Another far-reaching
change contained in the
proposal would permit
different approved levels of
restoration for hazardous
waste sites based on their
probable future use. For
example, a site in an
industrial area would no
longer be required to be
cleaned sufficiently to make
it safe for a day care center
or residential housing. .  . ."

The Philadelphia Inquirer
reported:  "... The
administration is seeking to
tie cleanup standards to
local land use decisions and
allow for a mix of public and
private funds to finance the
work. Depending on the
future use of the dump site,
the land would be subjected
to more--or less—rigorous
cleanup, according to Carol
Browner, head of the U.S.
Environmental Protection
Agency. 'One community
may decide to asphalt over
contaminated soil and make
it a parking lot.  For
another, it may mean
hauling away the soil and
building a playground. But
both communities will have
equal protection,' she said.
Browner predicted that the
new approach would both
cut the cost of the
Superfund program by 20
percent and speed the
cleanups.  The program
currently has an estimated
price tag of $300 billion. . . .
Under the administration's
revamped  Superfund
program:

• A community group,
composed of citizens and
local government officials,
would be created to evaluate
the site and decide on  its
future use.

• The site, once its use was
determined, would be
subject to specific cleanup
standards set by the EPA.
These standards would be
national.

• The EPA would also
provide a cleanup 'recipe'
that private industry could
follow for each standard.
This recipe would remove
some of the uncertainty for
businesses.

• The cleanup costs would
be distributed among the
responsible parties according
to their share of the
responsibility.  But the
federal government would
pay for small-property
owners and any additional
costs. .
                                                                                                       EPA JOURNAL

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   A subsequent article in
 The Washington Post
 reported: "... A panel of
 environmentalists and
 corporate executives
 yesterday [May 3, 3994]
 pledged to support a Clinton
 administration proposal for
 cleaning up the nation's
 hazardous waste sites, and
 key lawmakers said they will
 push for early passage. . . .
 Environmental Protection
 Agency Administrator Carol
 M, Browner presented the
 plan to a White House
 meeting attended by the
 heads of Dow Chemical Co.,
 E.I. du Pont de Nemours &
 Co. and other chemical
 companies, insurance and
 small business interests and
 groups such as Friends of the
 Earth.  . . .  Both
 environmental and
 corporate organizations have
 criticized current Superfund
 legislation for different
 reasons.  Administration
 sources said the new version
was crafted to meet the
 interests of both. In
 response to
 environmentalists' concerns,
 for example, the plan calls
 for community leaders to
participate directly in
decision-making about
cleanup procedures and in
the oversight of
enforcement.  Under the
plan, if community leaders
are not consulted about
cleanup, they have the right
to sue.  . . .Environmentalists
had pushed for a provision
saying that Superfund sites
close to residential areas
should  be made suitable for
residential use. Corporate
leaders opposed that
provision, which was not
included. . . ."
 Expansion
 Proposed for
 Toxics Release
 Inventory

 EPA has proposed 313
 additional chemicals whose
 releases or transfers industry
 would have to report
 annually to the Toxics
 Release Inventory (TRI).
 The new chemicals, 1 70 of
 which are active ingredients
 in pesticides, would nearly
 double the list to a total of
 633.  In a further expansion
 of the inventory later this
 year,  the Agency will
 propose that additional
 facilities be required to  make
 the reports.  Currently,  the
 requirement applies only to
 manufacturing facilities;
 EPA is looking at other
 activities responsible for
 substantial releases, such as
 mining and wholesale
 distribution.  The Agency is
 also considering adjustments
 that would reduce to a
 minimum unnecessary data
 collection and reporting,
 especially by small sources.
   EPA began publication of
 TRI in 1989 under the
 Emergency Planning and
 Community Right to Know
 Act. Companies report  the
 amounts of toxic chemicals
 they have released to the
 environment during
 manufacturing or the
 amounts they have
 transferred to other
 facilities, including amounts
 transferred for disposal.
 EPA publishes the data  as is.
 Numerous groups have used
 the data to lobby for more
 stringent controls on toxic
 chemicals or to pressure
 local industries to cut down
 on releases.  In addition,
 many companies, upon
 reviewing their own release
 reports, have voluntarily
-adopted pollution
 prevention measures to
 reduce releases. Beginning
 with the  1991 reporting
year, companies had to
 document progress made in
 preventing pollution.
 WasteWi$e
 Off to a  Good
 Start

 In a January letter to the
 CEOs of the "Fortune 1000"
 companies, EPA
 Administrator Carol
 Browner called on the
 nation's major corporations
 to voluntarily reduce the
 amount of waste they
 generate.  Participants in the
 program, called WasteWi$e,
 set their own waste-
 reduction goals and
 schedules.  To date, more
 than 240 major companies
 have joined WasteWi$e,
 including AT&T,  Warner-
 Lambert, Texas Instruments,
 American Airlines,
 McDonald's, Bell  Atlantic,
 and Federal Express.
 Companies that signed on
 before May 20. 1994,
 became charter members,
 which gives them  special
 recognition and makes them
 candidates tor case studies
 to be published by EPA.
   The Wa$teWi$e program
 asks participating  businesses
 to reduce waste bv
 preventing waste,  recycling,
 and buying/manufacturing
 products witli recycled
 content.  Examples include
 setting up systems to reuse
 shipping packaging,
 conserving paper through
 two-sided copying and
 electronic mailings, reducing
 customers' waste through
 more efficient packaging or
 mailings, and using recycled
 products wherever possible.
   The American commercial
 sector accounts for 40
 percent of the municipal
waste stream. Beyond the
benefits to the community,
companies' solid-wastc-
reduction efforts can be an
 internal economic boon.
 State Farm Mutual
 Automobile Insurance
 Company has reportedly
 saved approximately
 $300,000 annually using
 waste-reduction measures.
 Interested businesses and
 other members of the public-
 can call EPA's WasteWi$e
 hotline at I-800-EPAWISE
 (372-9473).

 Utilities  Receive
 Bonus Allowances
 for Acid Rain

 Five electric utilities have
 been awarded a total of 532
 acid-rain bonus allowances
 by EPA for their efforts to
 use energy more efficiently
 or to use renewable energy
 resources. Each allowance
 equals one ton of sulfur
 dioxide (SO2), the main
 ingredient in the formation
 of acid rain. Under the
 1990 Clean Air Act
 amendments, all electric
 utilities must hold enough
 allowances to cover their
 annual emissions of SO3.
 They can meet the
 requirement by either
 reducing emissions or by
 purchasing allowances from
 other utilities.  Congress set
 up a reserve of 300,000
 bonus allowances under the
 act to reward utilities that
 voluntarily reduced
 emissions before the
 deadlines. Utilities can use
 the bonus allowances to
 meet their own immediate
 requirements, they can bank
 them  for future use, or they
 can sell them.  EPA  began
 accepting applications to the
 reserve last July anil makes
 awards on a first come, first
 serve basis. The five utilities
 are: ESI  Energy
 Incorporated, Florida;
 Portland General Electric,
 Portland, Oregon; Puget
Washington Power,
Washington; the New
 England Electric System
 (Massachusetts Electric,
 Massachusetts, and Granite
 State Electric, New
 Hampshire); and the City of
Austin, Texas.
  SUMMER 1994

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EPA ROUNDUP

  Canisters on Cars
  to Cut Pollution from Refueling
  Commencing with the 1998
  model year, EPA will require
  manufacturers to install new
  automobile canisters that will
  capture gasoline vapors during
  refueling.  The requirement will
  apply to light trucks, mini-vans,
  and other utility vehicles
  commencing with the 2001
  model year.  When tlte new
  canisters are  completely phased
  in on new vehicles, states will he
  able to eliminate the
  requirement for vapor recovery
  nozzles at service stations.
  Administrator Carol Browner
  said: "Today's rule breaks years
  of gridlock over whether or not to
  require cars and trucks to
  capture smog-producing
  emissions during fill ups. Now,
 for the first time, we are taking
  an  action that is both cost-
  effective for consumers and will
  offer important environmental
  benefits that are protective of
  human health."

  The Detroit Free Press
  reported:  ". . . Automakers
  have long argued the devices
  were expensive, dangerous,
  and unnecessary.  But
  environmentalists and
  regulators saw them as the
  best way to  stop gas fumes
  from escaping into the air.
  Those fumes can aggravate
  smog in some cities as well
  as hurt crops and make it
  difficult for  people to
  breathe, especially young
  children and the elderly. . . .
  The regulation won't require
  a completely new device.
  Most cars already have
  canisters in  the engine
  compartment to capture
  polluting fuel evaporation.
  Federal regulations call for
  those canisters to be
  improved  beginning in
  1996.  Monday's
  announcement means
  refueling vapors will have to
                                         J
be captured and diverted to
those enlarged, improved
canisters. The American
Automobile Manufacturers
Association called the rule
tough, but said xthe
graduated nature of the
phase-in enables us to gain
valuable experience on
passenger cars which we can
then transfer to our truck
designs. . . .'"

The Washington Post said:
". . . The EPA estimated the
canisters will add $20 to the
price of a vehicle.  But
automakers have said costs
could be closer to $50 a car.
. . . The action, taken under
court order, ends a seven-
year battle with the auto
industry, which had strongly
opposed the canisters.
Automakers contended it
would be cheaper to equip
gasoline pumps with
pollution-control devices.
Major oil companies fought
that idea. During his
reelection campaign in
1992, President George
                                 Dctaney photo. l:J>A.
Bush directed service
stations in areas with the
worst air pollution to install
pollution-control nozzles on
pumps.  Bush said he did
not want to burden the
struggling auto industry with
yet another environmental
regulation.  But 10 months
later, responding to a
lawsuit filed by
environmentalists, a federal
court said Bush's order had
violated the 1990 Clean Air
Act. The appeals court said
the EPA must require the
on-board vapor-recovery
system.  The Clinton
administration agreed to
comply with the court order
without an appeal. Browner
went a step further
yesterday by requiring the
increasingly popular vans,
utility vehicles and small
trucks-not directly
mentioned by the clean air
law-to begin phasing in the
canisters in 2001. . . ."
Ongoing Enforcement

Arctic Fisheries to
Pay $725,000
Penalty

Arctic Fisheries Incorporated
has agreed to pay a penalty
of $725,000 to settle
charges that it violated its
Clean Water Act (CWA)
permit by repeatedly
discharging fish processing
waste into Alaskan waters.
The penalty is the largest
ever collected in Alaska on
the Pacific Northwest for
CWA permit violations.
The Justice Department
lodged a consent decree on
behalf of EPA in U.S.
District Court in Seattle,
Washington. The complaint
included the charge that
waste found floating in the
waters of Lost Harbor off
Adun Island had been
discharged by an Arctic
Fisheries seafood processing
plant. In addition to paying
the penalty, Arctic Fisheries
agreed to conduct sampling
and to make visual
inspections not previously
required by their permit, as
well as to stop discharging
fish processing waste into
Lost Harbor.

Sara Lee
Volunteers
Its Violations,
Pays Penalty

Sara Lee Corporation,
headquartered in Chicago,
Illinois, has voluntarily
disclosed to EPA that three
of its facilities failed to meet
the reporting requirements
of either the Emergency
Planning and Community
Right-to-Know Act (EPCRA)
or the Comprehensive
Environmental Response,
Compensation, and Liability
Act (CERCLA).  A facilitv in
Forest, Mississippi, failed to
report the release of more
than 2,000 pounds of
ammonia to the
environment and failed to
                                                                                                       EPA JOURNAL

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file Toxic Release Inventory
(TRI) reports for three
separate years.  Facilities in
Fort Worth, Texas, and in
New London, Wisconsin,
failed to file TRI reports on
releases of suifuric acid,
hydrochloric acid, and
ammonia for the years 1987
through 1990.  As a result of
Sara Lee's voluntarily
disclosing the violations,
EPA chose to issue a civil
complaint simultaneously
with the signing of a consent
agreement settling the case.
Sara Lee will pay a penalty
of $118,830 and will audit
its more than 140 facilities
for compliance  with EPCRA
and CERCLA.

Asbestos Removal
Violation Brings
Record  Penalty

Violations of work-practice
standards at an asbestos
removal project have
resulted in a court ordered
$1.675  million  civil penalty
against  B&.W Investment
Properties, Inc., a Chicago,
Illinois, property
management firm, and Louis
Wolfe, owner of the three
buildings in Cicero where
the project was being carried
out. The penalty is the
highest ever awarded under
the Clean Air Act's NESHAP
(National Emission
Standard for Hazardous Air
Pollutants) for  asbestos.
The court held  that the
defendants violated the
NESHAP by failing to notify
EPA of their intent  to
renovate or  demolish the
buildings and by failing to
wet friable asbestos and
insure that it stayed wet
until collected for disposal.
The property is located
adjacent to a Chicago
Transit Authority "El"
station  and  has been used
occasionally by transients
for shelter.U
                                   CONTRIBUTORS TO  THIS EPA JOURNAL ISSUE
Robert Adkr
Senior Attorney
Natural Resources Defense Council
1350 New York Avenue, NW.
Washington, DC  20005
Phone: 202 783-7800
Fax-. 202  783-5917

Carol M.  Browner
Administrator (1101)
Environmental Protection Agency
401 M Street, SW.
Washington, DC  20460
Phone: 202 260-5700
Fax: 202  260-5711

Howard Dean
Governor
109 State Street
Montpelier, Vermont 05609
Phone: 802 828-3333
Fax: 802  828-3339

John Hall
Kilpatrick and Cody
700 13th Street, NW.
Suite 800
Washington, DC  20005
Phone: 202 508-5800
Fax: 202  508-5858

Ciannat Howett
Kilpatrick and Cody
HOOPeachtree Street
Suite 2800
Atlanta, Georgia 30309
Phone: 404 815-6184
Fax: 404  815-6555

Mark Luttner
Director
Office of Policy and Resources Mgmt.
Office of Water (4102)
Environmental Protection Agency
Phone: 202 260-5700
Fax: 202  260-5711

Robert Perciasepe
Assistant Administrator
Office of Water (4101)
Environmental Protection Agency
Phone: 202 260-5700
Fax: 202  260-5711
 Keith S. Porter
 Director
 New York State Water Resources Institute
 Cornell University
 472 Hollister Hall
 Ithaca, New York 14853
 Phone: 607 255-5941
 Fax: 607  255-5945

 Velma Smith
 Director of Domestic Policy
 Ground Water Project Director
 Friends of the Earth
 1025 Vermont Avenue, NW.
 3rd Floor
 Washington, DC 20005
 Phone: 202 783-7400 exr. 294
 Fax: 202  783-0444

 Stephen Tchudi
 Professor
 Department of English
 University of Nevada
 Reno, Nevada 89557-0031
 Phone: 702 784-6728
 Fax: 702  784-6266

 David Urbinato
 7628 Dorchester Road
 Boynton Beach, Florida 33437

 Myron F. Uman
 Assistant Executive Officer for Special
 Projects
 National Academy of Sciences
 2101 Constitution Avenue, NW.
 Washington, DC 20418
Phone: 202 334-1659
 Fax: 202  334-1690

 Henry Waxman (D-California)
 U.S. House of Representatives
512 House Annex 1
Washington, DC 20515
Phone: 202 226-7620
Fax: 202 226-7092
SUMMER 1994

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 The Administration's  Proposals
 We  must  embrace a watershed approach
 by Carol M. Browner
       On Earth Day in April this year,
        I spent a morning with
        elementary school students on
 a boat on the Anacostia River here in
 Washington, DC. We caught some
 fish and carried out simple tests to
 assess the overall condition of the river.
 More than two decades after Congress
 first passed the Clean Water Act, we
 did not like what we saw. One of the
 fish had a tumor.  Old tires, broken
 bottles, and trash  studded the banks.
 We couldn't steer  into a once-thriving
 marina because it  is now abandoned,
 choked with mud  and weeds.
 Everywhere we saw evidence that
 America's water laws arc not working as
 they should.
   The same dav,  I released the latest
 National Water Quality Inventory, a
 biennial report on  the state of our
 nation's rivers, lakes, and estuaries.
 The report, based on data collected in
 199 ] -92, shows that America's waters
 arc indeed in trouble.  Approximately
 40 percent of the waters assessed by
 the states are not suitable for simple
 activities such as fishing or swimming.
   Our drinking water is also at risk.
 In the past year, residents of
 Milwaukee, New York, and
 Washington, DC, were ordered to  boil
 the water that came out of their tap
 because of contamination of tin-
 drinking water supply. In Milwaukee,
 thousands of people fell ill.  Some died.
   Millions of Americans make their
 living Irom the nation's waters, fish and
 swim for recreation, or choose to locate
 their homes or businesses near
waterways.  And Americans expect
      More than two
 decades  after Congress
  first passed the Clean
 Water Act, we did not
     like what we saw.
their drinking water to be the cleanest
in the world.  We depend on water to
cook with, water to wash our children,
water to nourish our farmlands, water
to sustain the birds and fish and plants
with which we share our world.
      (limviier is Administrator of EPA.)
   To protect this vital resource, the
 Clinton administration has proposed to
 change the two major laws that
 safeguard our nation's waters:  the
 Clean Water Act, which has jurisdiction
 over our rivers, lakes, estuaries, and
 wetlands, and the Safe Drinking Water
 Act, which regulates tap water quality.
 Both are up for reauthorization.
   America's water-quality laws have
 accomplished a great deal. The flow of
 untreated sewage and industrial
 wastewater into our surface waters has
 been sharply reduced. We no longer
 have rivers catching on fire, but new
 legislation is necessary to solve the
 problems that remain, such as polluted
 runoff and persistent toxic pollutants
 in water bodies, and to maintain the
 progress we have made.
   The single greatest remaining threat
 to America's rivers,  lakes,  and estuaries
 is polluted runoff, sometimes called
 nonpoint-source pollution. Silt,
 pesticides, fertilizer, and other
 pollutants are carried off farms,
 suburban  lawns, industrial plants, and
 city streets into water bodies whenever
 it rains.
   Controlling runoff from hundreds
 of thousands of fields and streets is far
 more difficult than controlling the
 pollution emitted from the end of a
 pipe.  To solve this problem,  we must
 change the Clean Water Act  to
 embrace a comprehensive  "watershed"
 approach to water quality. A
 watershed is all the  land forming a
 drainage basin that  surrounds a body of


 Thanks to a  team effort  by local and
federal governments, Washington, DCs
 Kenilworth Marsh—once badly
contaminated-- lias been restored to
health.  Carol Browner visited the site
during National !}nrk* Week.
                                                                                            EPA JOURNAL

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                                                                   EPA Administrator Browner surveys tin1
                                                                   Anacostia River at the nation's capital
                                                                   Denis I'aquui phrta.  Wide Wprtii,
                                                                                   water.  To protect our water, we must
                                                                                   control the pollution that drains off our
                                                                                   land.
                                                                                      For years, Americans have taken the
                                                                                   purity of their drinking water for
                                                                                   granted. But any community-like
                                                                                   Milwaukee--that experiences a
                                                                                   contamination crisis comes away with a
                                                                                   sobering sense of urgency.  Our system
                                                                                   for providing safe drinking water is
                                                                                   broken. Many communities cannot
                                                                                   afford to comply with federal
                                                                                   monitoring requirements.  Many
                                                                                   cannot afford to upgrade their
    President Clinton's
    Clean  Water Initiative

        Federal water-pollution legislation
        dates back ID 1948. The original
        Clean Water Act was passed in
    1972 and has been amended several
    times since.  Following are key
    elements of President Clinton's Clean
    Water Initiative, which was sent to
    Congress for consideration as they
    took up reauthorixation of the Act.

    • Controlling Polluted Runoff

    EPA would specify measures for
    controlling polluted runoff; states
    would choose which measures to apply
    in priority waters.  After an initial five-
    year implementation period,  states
    would determine whether water-
    quality standards were being met.  For
    those that were not, another five years
    would be allowed for application of
    additional controls. Enforcement
    would be authorized to ensure that
    proper action is taken.
 • Stornrvvater Control in Urban
 Areas

 The administration would give local
 governments more flexibility in
 assessing and selecting control options
 so that they could target the highest
 priority problems. Overall costs for
 these programs could be reduced by
 four-fold compared to the extremely
 broad current program.

 • Watershed Management

 Incentives would encourage states to
 adopt a watershed approach to
 managing water quality. For example,
 states would be given greater flexibility
 to tailor nonpoint-source programs to
 fit site-specific conditions in
 watersheds,  To reduce  administrative
 burdens, federal reporting
 requirements and grants would be
 consolidated.

 • Financial Assistance

. Continued federal assistance for the
 state revolving loan fund would be
 provided through the vcar 2004 to
better ensure the fund's long-term
viability. Also, a tee program would
help states recover the costs associated
with managing Clean Water Act
programs such as pretrentment, the
National Pollutant Discharge
Elimination  System, and sludge.

• Greater Authority to Restrict
Discharge of Toxics

Establishing limits on industry and
setting numeric criteria for water
quality are the two mechanisms by
which toxics currently are controlled.
Both can be  costly and time-
consuming.  When scientific evidence
demonstrates that a serious threat
exists, EPA needs the authority to take
more immediate action.

• Strengthening Enforcement

Enforcement provisions would be
streamlined and strengthened to equal
those found  in comparable
environmental laws. Also, a stronger
role would be given to citizens to
pursue enforcement  action.
SUMMER 1994

-------
infrastructure to meet federal
treatment standards. The. current law
limits the Agency's ability to focus on
those contaminants that pose the
greatest risk to public health by
requiring that we regulate 25
contaminants every three years,
regardless of public health risks.
Likewise, the law fails to provide
communities with the flexibility and
the kuuling they need to target their
resources to the most urgent problems.
   Most important, the current system
focuses on monitoring and treating
drinking water. It docs little to protect
the sources of drinking water from
contamination. Clearly, treatment
costs could be greatly reduced if
communities prevented contaminants
 To  protect our water,
  we must control the
 pollution that drains
        off our land.
from entering the drinking-water
supply in the first place.
   The Clinton Administration's
proposal addresses all these flaws.  Our
new Safe Drinking Water Act will
improve public health protection and
reduce costs for water suppliers.
 Source-water protection measures will
prevent pollution from entering
drinking water in the first place-thus
reducing treatment costs and reducing
the likelihood of dangerous
contamination. The administration's
package will provide billions of new
federal dollars to upgrade systems that
treat drinking water and assure that
water suppliers meet basic safety
standards. At the same time, our
recommendations for a new Clean
Water Act emphasizing watershed
management and the control of
polluted runoff will reinforce Safe
Drinking Water Act objectives.
   As our population grows, the
demand for clean, safe water will also
grow. New, sensible water-quality
                                                                                                    EPA JOURNAL

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                                         Safe Drinking Water Act Reform
laws can reduce red tape and give state
and local governments the funding
they need to solve problems facing
their communities.
   We have an historic opportunity to
protect public health and restore our
rivers, lakes, and estuaries. On some
future Earth Day, when those elementary
school students go down to the Anacostia
River with their own kids, I want them to
find safe, clean water. Q

                Volunteers
                clean up the banks
                of a stream near
                Lititz, Pennsylvania.
                Grant Hcilman photo.
     The Safe Drinking Water Act was
     passed in 1974; major
amendments were made in 1986.
Following are key elements of reforms
recommended by President Cinton as
the act comes up for rcauthorization in
the Congress.

• Regulating Contaminants

The current requirement that calls for
EPA to regulate an additional 25
contaminants every three years would
be replaced with new authority under
which EPA would consider any number
of contaminants and decide upon the
most appropriate response for each--
regulation or further study.

• Financing Infrastructure

Similar to the fund established under
the Clean Water Act, a stnte rewiring
loan fund  would be established to help
communities and water suppliers
finance needed infrastructure. The
fund would be authorized at $599
million for 1994, $700 million for 1995,
and $1 billion a year from 1996 to 1998.

• User Fees

To ensure that states have sufficient
resources to implement Safe Drinking
Water Act requirements, authority
would be provided to states, or to EPA
in those states where EPA administers
the act, to establish a user  fee program.

• Special Assistance for  Small
Systems

States would establish small-system
viability programs that would evaluate
existing systems to determine whether
they have the means to comply with the
law.  They would also prevent new,
nonviable systems from being
established and would provide
authority to order consolidation of
 existing noncompliant, nonviable
 systems, where needed.  Further, a less
 expensive treatment technology would
 be established specifically for small
 systems. To ensure that public health
 is protected, systems adopting this
 technology would be required to take
 added precautions, such as
 implementing source-water protection
 programs and assuring certification of
 system operators.

 • Encouraging Source-Water
 Protection

 To reduce monitoring and treatment
 costs and prevent contamination from
 occurring in the first place, states
 would be required to develop source-
 water protection programs.  These would
 delineate drinking-water protection
 areas and assess contamination threats
 to the sources in these areas. To
 further reduce costs and provide greater
 management options at the local  level,
 states could approve alternative
 monitoring and treatment processes if
 the community implemented an
 "enhanced" source-water protection
 program.  The definition of enhanced
 would be determined by EPA via the
 regulatory process.

 • Strengthened Enforcement

 Enforcement authority would be
 strengthened to make the Safe
 Drinking Water Act consistent with
 other environmental statutes.
 Improvements would include
 consolidating and addressing
 inconsistencies among multiple
 enforcement provisions and clarifying
 that federal facilities must be in
 compliance.

 • Training  and Certifying
 Operators

 States would be required to set up
 programs for training and certifying all
drinking water system operators.
 Systems that cannot afford to train
staff or hire certified operators could
contract for part-time services or share
services with other local systems.
SUMMER 1994

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The  Clean  Water  Act:
Has It  Worked?
        by Robert Adler
We have a  long  way to go
         More than two decades after
         the Clean Water Act was
         passed, little clear
 information is available on basic-
 questions about the health of our water
 bodies:  I low much cleaner are our
 rivers than they were 20 years ago?
 Are our beaches safe for swimming?
 Do our lakes support more fish, and
 are the fish safer to eat? What is
 happening to species that relv on
 aquatic habitat?
    Numerous government reports are
 available on virtually all aspects of
 Clean Water Act program
 administration, (lovcrnment
 computers store extensive technical
 data related to the quality ol our
 waters and the health ol our aquatic
 ecosystems. These data are riddled
 with inconsistencies, however, making
 it almost impossible to determine
 whether, on a national basis, we  have
 made significant progress in the war
 against water pollution.
 (Ailler is Sciiwr Attt>i'iie\' nt the National
 Resources Defense Council in Washington,
 DC..  This article mis excerpted from
 CJiiijitt-r 2 f>/'The (lean Water Act: 20
 Years later [Island Press  /
-------
                                                                                Kids escape heat in Lake Michigan.
                                                                                Miiiiy U.S. water bodies are still not
                                                                                "swiminablc."
with raw sewage discharged into public
waters.  About 70 million people were
not served by public sewers.  While
many of these had properly designed
and maintained septic systems, others
had in-ground systems that leaked
pollutants into surface or ground water.
   Similar gains are evident in the
industrial sector.  In 1973, industry
spent about  S 1.8 billion on water
pollution controls. By 1986, this had
jumped to almost $5.9 billion.
   Again, these investments have
reaped large dividends in total
pollution reductions. According to
EPA, pollution controls implemented
in 22  industries since 1972--undera
Consent Decree between EI'A and the
National Resources Defense Council
(NRDC)--havc reduced releases of
selected "priority" toxic organic
pollutants by 99 percent, or by almost
660,000 pounds per day. Reductions
in toxic metals are estimated at almost
98 percent, or more than 1.6 million
pounds  per day.  liven higher  amounts
of conventional pollutants, like organic
waste and solids, have been controlled
with this new technology.
   As with sewage pollution, however,
industrial water pollution is far from
contained.  In  1 990, for example, U.S.
industries reported the release of
almost 200 million pounds of toxics
into surface waters, and another 450
million pounds into public sewers.
    Despite these reductions in
pollutants from point sources, on a
national basis gains in ambient water
quality are hard to measure.
Thousands of water-quality monitoring
stations exist around the country, but
relatively little of the information
collected at these stations is suitable to
determine long-term water quality
trends.
   The Clean Water Act requires states
to submit reports even1 two years to
EPA, which must evaluate, among
other things,  the extent to which state
waters  meet the basic goals  of the act.
In turn, EPA  is required to analy/.c
these reports  and submit a
comprehensive analysis to Congress
every two years. These reports are
known as the National Water Quality
Inventory. The first  inventory was
released in  1 974; the most recent,
released in April 1994, covers the years
1990-91. The most recent inventory
demonstrates that even the  interim
goals of the 1  972 Clean Water Act
have not  been met:  Roughly 40
percent of our assessed rivers and lakes
and roughlv a third of our assessed
estuaries are not meeting or fully
supporting designated uses (e.g.,
fishing, boating, swimming, thinking
water supply). Other reports, to be
discussed later, suggest that these
numbers are seriously understated.
Clearly we have not yet met the  1983
"fishable and swimmablc" goal of the
law. And despite incomplete
monitoring, states report that toxic-
pollutants affect a large percentage of
waters. Thus, we have not eliminated
the release of "toxic pollutants in toxic
amounts" either.

Human Health
Still Threatened

Swimming Hazards and Beach
Closures

Among  the  first questions the average
person would ask about whether the
Clean Water Act has succeeded is
whether it is safe to go to the beach.
   Until the most recent inventory
(1992), not published until spring
 1994, EPA did report how many waters
the states believed were "swimmablc."
In the 1990 inventory, for example,
EPA reported that the Clean Water
Act's swimmable goal was  met in about
three-quarters of our rivers and
estuaries, more than 82 percent of our
lakes, and almost 90 percent of our
ocean waters.  Even these optimistic
numbers lead  us to conclude that,
almost a decade after the 1 983 goal for
swimmable waters,  a large number of
water bodies (one out of ten ocean
miles and one of five lake acres) are not
safe  for  swimming. But a closer analysis
indicates that many more waters are
not safe for swimming. Even based on
inadequate and inconsistent
monitoring,  there were over 2,600
reported coastal beach  closures or
advisories in 1 992, and over 7,700
reported closures or advisories between
1988-1992.

Pollution of Drinking Water

The Safe Drinking Water Act, passed
in 1974, regulates the quality of water
as it leaves your tap, while the Clean
Water Act is designed to eliminate
water pollution in the rivers and lakes
from which half of the country (by
SUMMER 1994
                                                                                                                 11

-------
 population) gets its drinking water.
 But while the general public does not
 care about this fine legal distinction,
 progress under the Clean Water Act is
 critical to the average citizen's drinking
 water for two reasons. First, ultimately,
 cleaner water supplies will produce
 cleaner water to drink.  Second, the
 public faces increasing costs for treating
 drinking water to eliminate
 contaminants that should not  be there
 in the first place. For a  status  report
 on the Safe Drinking Water Act, see
 boxed article on page 1 5.

 Fish and Shellfish Contamination

 In late 1 992, EPA released the results
 of a five-year effort to evaluate the
 presence of toxic chemicals that may be
 bioaccumulating in fish. This effort
 tested for the presence of 60 pollutants
 in 1 19 species of fish collected from
 3 14 water bodies.
   The results are sobering.  Biphcnyl,
 mercury, PCBs, and  DDE were found
 at more than 90 percent of the test
 sites.  And every pollutant in the study
 was found in at least one location.
 Concentrations of pollutants varied
widely among individual samples.
 Nevertheless, EPA calculated that the
 levels of pollutants measured in fish
around the country posed significant
 risks of cancer and other health effects
to average fish consumers and even
higher risks to subsistence and
recreational anglers (who consume
more fish from contaminated waters).
   The overall level of contamination
    Fish kills
   still occur
       with
    alarming
   frequency.
of coastal waters by sewage and other
sources of pathogens appears to be
getting worse, although this probably
reflects better monitoring and reporting
as well as ongoing pollution.
   The National Shellfish Register, for
example, shows that the amount of
estuarine waters in which shellfishing
was banned increased by 6 percent
from 1985  to 1990.  By 1990,  in fact,
less than two-thirds of our shellfish
waters were unconditionally approved
for shellfish harvest.  On a regional
basis, the situation was even worse.
Between  1985 and 1990, the
percentage  of waters in which
shellfishing was banned jumped by 10
                            '77i/i isn't tup wnter, is it?"
percent in the Gulf of Mexico; it nearly
tripled (from !() to 29) in the North
Atlantic. While shellfish waters were
degrading on the East and Gulf coasts,
they appear to have been improving
along the Pacific.

Sediment Contamination

Toxic pollutants in sediment
contaminate small aquatic organisms
that live or feed  in the sediment. These
small animals are consumed by
bottom-feeding fish, which in turn are
eaten by larger fish. In fact, because
levels of toxic pollutants bioaccumulate
or biomagnify in higher levels of the
food chain, sediment contamination
levels can actually understate
concentrations of the same pollutants
in fish and  shellfish.
   In 1992  the  Coast Alliance
prepared a comprehensive survey of
available information on sediment
contamination.  Based on studies and
compilations by  EPA, the National
Oceanic and Atmospheric
Administration,  and the National
Research Council {NRQ, this review
noted hundreds of problem sites
throughout the Atlantic, Gulf,  and
Pacific coasts, and the Great Lakes.
The nation's waters have become so
polluted that, according to EPA, onlv
the most remote water bodies can be
expected to have pristine sediments.
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Aquatic Species and
Ecosystems in  Jeopardy

Trends in Aquatic Biodiversity

In 1979, the American Fisheries
Society (AFS) compiled a list of 25 I
North American fish designated as
endangered, threatened, or of special
concern. When AFS revisited its
catalog a decade later, the situation
had deteriorated severely. The 1989
list added 139 new types and removed
26, producing a total of 364 fish that
warrant protection due to rarity.
   The AFS experts concluded that the
factors that threaten most fish had
changed little since the 1979
classification: "Habitats continue to he
degraded through human activities
associated with agriculture, mining,
industry and urban development, while
harmful, exotic species continue to be
introduced and native fishes are
transplanted beyond their natural
ranges."
   But fishes are not the only category
of aquatic and aquatic-dependent
species in jeopardy. The current Fish
and Wildlife Service list of threatened
and endangered species includes, in
addition to 90 fish, 1 3 snails, 42 clams
and mussels,  and 10 aquatic
crustaceans. Many other species on the
list rely heavily on  aquatic ecosystems.
Mammals include the Florida manatee,
stellar sea lion, and southern sea otter;
wetlands or beach-dwelling species such
as beach mice, voles, and shrews; and
the Florida panther, whose habitat in
the Everglades is facing increasing pres-
sure from development. Currently
listed bird species include waterfowl
and other species that use wetlands and
other waters for food, nesting, staging,
and other critical habitats. Most
experts agree, moreover, that currently
listed species reflect only the tip of the
iceberg.

Trends in Aquatic and Other
Water-Dependent Populations

America's coasts and some inland
waters continue to  provide a
tremendous bounty of fish and
shellfish, with vital economic and
SUMMER 1994
nutritional value to the nation. Indeed,
many seafood populations-including
the American lobster-are on the rise.
But other indicators are more ominous.
For example, between 1970 and 1989,
harvest of oysters dropped by 44
percent and landings of spiny lobster
declined  by 34 percent.  Commercial
landings  of striped bass have declined
continuously since 1973, with a fall of
92 percent since 1982. Between 1983
and 1989, landings of bay scallops fell
by 88 percent.

Fish Kills

At first blush, the number of fish kills
appears to have declined over time.
Until 1981, states generally reported
between  700 and 850 fish "kills per
year; this level dropped to 500 or fewer
for much of the 1980s. But these
numbers arc skewed by extreme
variations in the numbers of states
reporting fish kills during certain years.
Reporting dropped from all states in
the early 1970s to an average of 36
states from 1977 to 1985, with a low
of 24 in  1 986 and with 43 reporting in
1992. Adjusted to reflect these varia-
tions in the number of states reporting,
the trends show an increase between
700 and  750 incidents per year in the
early 1970s to between 800 and 1,000
incidents per year in the late 1970s
and 1980s. In 1992, 43 states reported
a total  of 1620 fish kills, of which 930
were attributed to pollution.
                                   Aquatic Toxicity

                                   Much of the growing body of evidence
                                   about the effects of toxics on fish and
                                   wildlife comes from the Great Lakes
                                   and has been presented in useful
                                   summaries. For example, a 1991 report
                                   by the National Wildlife Federation
                                   and the Canadian Institute for
                                   Environmental Law and Policy
                                   summarized the effects of toxic
                                   contaminants on wildlife in the Great
                                   Lakes area.

                                   • Fifteen kinds of birds, animals, and
                                   fish in the Great Lakes region have had
                                   reproductive problems and/or
                                   population declines since the 1950s.

                                   • Missing brains, missing eyes, internal
                                   organs located outside the body, and
                                   deformed feet and wings are among the
                                   abnormalities found in Great Lakes
                                   wildlife.  Birth defects occurred in
                                   almost 50 percent of the species
                                   studied.
                                   • Six species of wildlife have shown
                                   serious documented behavioral
                                   changes.

                                   • Sexual changes are thought to be
                                   caused by the similarity in structure of
                                   PCBs, DDE, and other pesticides to
                                   female hormones.

                                   • Beluga whales, terns, and herring
                                   gulls have suffered a suppression of
                                   their immune svstcms.
     60
     80
             Aquatic Species in Jeopardy
        1
        1
        i
        V)
        .ffi
        o
        g.
     20
   Birds     Mammals    Reptiles  Amphibians    Fish
Swiri-c. 'llic Nature OKrn'rtmy. lliodivfrsity Network New. Navetnlifr 3, 1 9
-------
 Lost and Damaged Aquatic Habitats

 To help fiil the gap in knowledge of the
 overall  biological health of rivers and
 lakes, in 1982, EPA and FWS
 conducted the National Fisheries
 Survey.
    The conclusions were striking:  81
 percent of the nation's waters,
 including 53.3 percent of all perennial
 waters, had fish communities adversely
 affected by a variety of factors.
 (Perennial waters run continuously, as
 opposed to intermittent streams, which
 run only during wet periods of the year
 or only after  sufficient precipitation.)
 All told, even for perennial streams,
 more than one out of four provided
 minima! support at best for healthy
 fish populations. Less than 4 percent of
 waters were rated as completely
 healthy.

 Wetlands

 When the Clean Water Act began to
 regulate wetlands in the mid-1970s, an
 estimated 105.9 million acres of
 wetlands remained. By the mid-1980s,
 only 103.3 million acres remained,
 with a total loss of 2.6 million acres, or
 an average of 260,000 acres per year.
 Estuarine wetlands have declined by
 about 1 percent—mostly in Gulf Coast
 states--in  most cases due to conversion
 to open salt water. Inland vegetated
 wetlands have decreased by nearly 2.5
 million acres, with the largest losses in
 forested wetlands, primarily in the
 South.
    At the same time, the situation is at
 least somewhat promising from the
 perspective of recent trends. The rate
 of wetlands loss has slowed by about
 half since  the wetlands protection
 provisions of the act have been in
 place. If this trend continues and
 wetlands protection efforts are
 expanded  and strengthened, perhaps
 we can reverse the tide and begin to
 restore rather than degrade the nation's
 wetlands resources.

 Floodplains  and Riparian Habitat

 Estimates  of loss of floodplain and
 riparian (riverbank) habitat vary.  But
while  they differ in detail, all lead to
the conclusion that a large percentage
of the original riparian habitat in the
United States has been lost, and a large
percentage continues to be lost. A
                                                 />
                   "Somehow, it's not the same as ivlim ive were here on our honeymoon."
 detailed 1992 assessment of floodplain
 management in the United States
 provides useful perspectives:

 • By the late 1970s, an estimated 3.5
 million to 5.5 million acres of
 floodplain had been developed for
 urban use, including more than 6,000
 communities with populations of 2,500
 or more.

 • Out of 75 million to 100 million
 acres of indigenous, woody riparian
 habitat, less than half (about 35
 million acres) remain in nearly natural
 condition. The  rest have been
 inundated, channelized, dammed,
 riprapped, farmed, overgrazed, or
 altered by other land uses.

 • The Army Corps of Engineers
 estimates that there are 574,500 miles
 of stream bank with erosion problems
 in the United States, 142,100 of which
 are characterized as "serious."

 Conclusion

 We have good reason to applaud the
 success of the Clean Water Act over
 the past two decades.  Pollution from
 point sources has been reduced
 dramatically, and some human health
 and environmental threats have
 declined accordingly. It is equally clear
 from the above, however, that  we still
 have a long way to go in meeting the
 basic goals of the Clean Water Act.
   Three basic messages predominate
 from this evaluation. First, although
 point-source pollution has declined, we
 continue to release large amounts of
 toxic and other  pollutants into our
water, causing continuing
contamination of water, sediment, and
 fish and wildlife.  Second, although we
 have paid much attention to pollution
 from point sources, relatively little has
 been done to stem the tide of polluted
 runoff from farms, lawns, and city
streets.  Third, while some progress has
 been made in restoring the chemical
 integrity of our waters, the biological
 health of these same waters is moving
 in the wrong direction.
    A revised and revitalized Clean
Water Act could address these  major
flaws in the current law, and in current
programs.D
14
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    The  Safe  Drinking  Water Act  in Retrospect
          Twenty years following the
          passage of the Safe Drinking
          Water Act in 1974, the Natural
    Resources Defense Council has
    recently completed an analysis of the
    protection and treatment techniques
    currently used by the nation's largest
    drinking-water systems. The results of
    this analysis were published in a
    March 1994 report entitled Victorian
    Water Treatment Enters the 21st Century
    (authors:  Brian A. Cohen and Erik D.
    Olson).
       As the title of this report indicates,
    NRDC finds that most large water
    suppliers in the United States arc
    traveling on a technological "dirt road"
    at the same time that most Americans
    are preparing to enter the
    "information superhighway."
    Following are some highlights from
    the report:

    • The vast majority of large water
    suppliers do little or nothing to prevent
    contamination of the watershed or ground
    Mater that they rely upon for source water.
    The  most  effective way for drinking-
    water utilities to protect public health
    and reduce the  risks from chemical
    contamination is  to provide multiple
    barriers of protection.  The first and most
    effective technique is protecting water
    supplies from deterioration by
    preventing their pollution.  However,
    about two-thirds of large surface water
    systems have failed to adopt even
    minimal watershed protection
    techniques such as watershed land
    ownership and stream or reservoir
    buffers to prevent runoff or discharges
    of chemically or microbiologicallv
    polluted water into their source water.
    About 8 of 10 ground-water-supplied
    systems have failed to adopt wellhead
    protection programs to prevent
    contamination of their wells.

    • More than 90 percent of major water
    utilities have failed  to install modern, post-
    World War I chemical-contaminant
    removal technology,  despite widespread
    chemical contamination. Fewer than 10
    percent of large community water
    systems are using modern water
    treatment technologies (such as
    granular activated carbon or 07.0110,
    both widely used by European
    drinking water systems) to reduce
    risks of chemical  contamination  by
    pesticides, arsenic, and other
    contaminants as well as disinfection
    byproducts. Moreover, only 26
    percent of all large utilities are using
the centuries-old and simple technique
of aeration for removing volatile
contaminants. While a relative
handful of U.S. water systems have
pristine watersheds and produce low
levels of disinfection byproducts, most
do not and should therefore consider
a shift to higher quality treatment.

• Scores of major systems with
inadequately protected source waters have
dragged their feet and have not installed
basic 19th-century filtration and particle
removal technology needed to protect water
from dangerous microbes. As of February
1994, more than 80 large surface-
water systems (serving over 10,000
people each), which provide water to
over 4.5 million people, have
inadequately protected their
watersheds and have  not installed
filtration, in violation of EPA's Surface
Water Treatment Rule,  according to
EPA data.  This does not include cities
with watershed protection programs
tentatively approved by EPA as
adequate to avoid filtration, such as
the Delaware-Catskill watershed of
New York  (see article on page 24).
Approximately 140 large svrface-
water-supplieci utilities (ap, x>ximately
10 percent) also are not usii,tj
coagulation and flocculation-basic
steps in the preireatment process
needed to remove particles prior to
filtration of all but the most pure
source waters.
    Moreover, as of 1989, nearly 50
large ground-water systems provided
no water treatment whatsocvcr-not
even basic disinfection.  Many experts
argue that ground water adequately
protected from surface contamination
does not need extensive treatment
because passage of the water through
the aquifer is enough to remove many
particles and contaminants.  However,
many of the ground-water systems are
under the influence of surface water
and arc subject to contamination from
surface sources.

• Aged, crumbling distribution systems are
neglected and are often the cause of
traterborne disease outbreaks. The final
step in the provision of safe drinking
water is water distribution: the
network of pipes that carries the water
from the treatment plant to the
customer. The distribution system is
fraught with concerns. Millions of
pipes arc made with lead, and as a
result, millions ot Americans are
exposed to unsafe levels of lead in
their drinking water (see boxed item
on page 19).
    In addition, there are less obvious
concerns.  In many cases, the pipes
that bring us our water are 100 or
more years old and are cracking or
crumbling. These aged pipes often
harbor microbial growth and arc
subject to catastrophic breakage.
Broken or "cross connected" pipes that
allow contaminated water to seep into
the water system have often been
linked by the Centers for Disease
Control and Prevention to waterborne
disease outbreaks, vet the average
water pipe will be over a century old
before it is replaced.
   These findings underscore the
need to strengthen both the Sale
Drinking Water Act. which sets
standards for the quality ol water
coming from your tap, and the ("lean
Water Act, which sets standards for
discharges and runoff into surface
waters, in order to protect our
drinking water supplies.  In NKDC's
view, necessary legislative changes
should include strengthened
provisions lor watershed and ground-
water protection, tougher drinking-
water standards for contaminants,
increased funding to help systems pay
for improvements, and beefed-up
enforcement authority for EPA and
citi/cns to ensure that standards are

SUMMER 1994
                                                                                                                         15

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Disaster  in  Milwaukee
Complacency  was the  root cause
                             by Velma Smith

 Milwaukee rcsiilcnts stand in line to fill miter jugs.
          More than a year has passed
          since Milwaukee's drinking
          water crisis. The April 1993
 outbreak of cryptosporidiosis remains
 an unpleasant memory for most of the
 nearly 400,000 people who were
 stricken with the waterborne disease.
    For some, exposure to the
 contaminated water was disastrous. A
 woman in a weakened state from
 chemotherapy lost her life to
 ayptosporidittm. Another, stricken with a
 rare blood disorder thought to have
 been brought on by cryptosporidiosis,
 lost her spleen. An HIV-infected child,
 who lived without the  ravages of that
 disease until the outbreak, has now
 spent a year in bed--a three-year-old
 living with the pain and frustration of
 chronic diarrhea and frequent
 vomiting.

 16
   All in all, Milwaukee's
cryptosporidium experience had a stiff
price, much human suffering as well as
an estimated $37 million in lost wages
and productivity.
   Discovering how it happened might
not help the people who suffered most
from the nation's worst drinking water
disaster. But finding answers is crucial
to preventing further cases of
contamination-in  Milwaukee or in any
community served by the nation's
200,000 public water systems.
   One theory holds that the
Milwaukee plant was old and the
design flawed, which  resulted in the
return of dirty backwash water to the
reservoir.  Another suggests that plant
personnel  failed to act quickly when
turbidity levels rose.  Some charge that
more than human error was involved,
and that critical monitoring equipment
was broken at the time turbidity levels
peaked.  Still another theory focuses on
the fact that the water intake point was
vulnerable to contamination.
Upstream feedlots and an alleged
illegal discharge from a slaughterhouse
are considered culprits, as is a sewage
treatment plant sited upriver less than
two miles from where Milwaukee draws
its water.
   Critics of the Safe Drinking Water
Act counter that regulation, rather than
its absence, was to blame for the
episode.  Milwaukee's operators, these
(Smitli is Director of Domestic Policy at
Friends of the Earth. She also directs
FOE's Groundtvater Project.)

                       EPA JOURNAL

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critics claim, most iikely missed the
cryptosporidium not because EPA had
held off regulating it, but because they
were side tracked by lower priority
problems on which the law mandated
they focus.  In this case, the so-called
lower priority problem was  lead.  In an
effort to reduce the acidity of the water
supply, and thereby reduce  the amount
of lead leached from  pipes,  Milwaukee
plant operators were experimenting
with changes to their chemical
treatment regime when the  warning
signs of cryptosporidium
contamination  appeared, and they
missed them.
   Unfortunately, in most of these
difficulties—from poor plant design
and aging equipment to inadequate
operator training, from gaps in the
protection of water sources  to
difficulties in coping with a host of
contaminants all at once-Milwaukee is
not unique. It  may be the norm.
When all is said and done, there may
be one critical threat to safe water, a
threat that has allowed these problems
to go unnoticed in the day-to-day
operations of water protection and
treatment across the country.
Complacency about the quality of U.S.
water supplies could  be the  greatest
threat to the safety of those supplies.
   "It was an issue of complacency,
false complacency," said the city's
health commissioner, Paul Nannis, of
the Milwaukee episode. "I think the
feeling was—'Hey, the water's always
been fine."'
   It was also complacency that let
federal regulators deliberate over,
rather than decide on, standard-setting
for dozens of contaminants during the
Reagan years. Complacency lets state
drinking-water budgets be the first on
the chopping block in tight budget
years, and it allows water-intake points
to be located down river from farm
runoff or poorly regulated wastewater
discharges.
   Drinking water complacency means
that in some states the training
requirements for hairdressers are
tougher than those for water-system
operators. It means that drinking-
water wells pull from ground-water
sources in the vicinity of chemical
plants, oil storage tanks, and landfills,
and that fewer than a quarter of
systems using ground water have
wellhead  protection programs to
safeguard against contamination.
  Finding  answers is
 absolutely  crucial to
  preventing further
           cases of
     contamination.
   Though EPA and its Science
Advisory Board have ranked drinking
water in the top four environmental
health risks facing the nation, drinking-
water safeguards have not fared well  in
terms of federal, state, or local
resources.  Indeed, the entire fiscal year
1995 budget request for EPA's Office
of Drinking Water is less than $150
million. That amount must fund
research; development of standards,
criteria, and guidelines; oversight of
state-administered programs;  and
grants to state agencies as well as
regulation of underground injection of
waste and general EPA efforts on
ground-water protection. The total
adds up to less than a third of the cost
of a single C-l 7 airlift aircraft.
   Clearly, when it comes to drinking-
water protection, the nation's
management philosophy  has been
penny-wise and pound-foolish. In
1984, for example, the Congressional
Joint Economic Committee studying
public infrastructure policies found
deterioration of drinking-water
distribution systems, inadequate
sources of water supply, overdrafting of
aquifers, contamination, and
inadequate treatment.  According to
the committee's report, the  price tag for
addressing those problems,  calculated
in 1982 dollars, was over $5 billion.
Those problems have not disappeared
in the decade since the committee's
report.
   A 1994 report by the Natural
Resources Defense Council charges
that the nation's drinking-water
systems are moving into the 21 st
century "on a technological dirt road,"
using "Victorian-age" treatment
processes. (See article on page 15.)
   According to EPA's own data, some
80 large systems serving a total of more
than a million people have failed to
meet regulatory deadlines for installing
the fundamental protection of
filtration.
   While many large water systems are
deficient in treatment or  protection in
certain respects, the condition of small
systems is clearly worse.  EPA's data for
1991 indicate that nearly 15,000 small
systems serving populations of 3,300
or fewer were in violation of basic
drinking-water-quality limits or
Maximum Contaminant Levels
(MCLs). These small systems, which
in fact comprise the vast majority of
the nation's water systems and exist
within metropolitan, areas as well as
rural areas, present an administrative
challenge at best and a dear threat to
public health in too many cases.
   Small systems are numerous and
needy. They account for a
disproportionate share of Safe
Drinking Water Act violations and are
plagued by financial instability and
lack of access to capital, poor
management and accounting,
substandard water quality, and limited
technical understanding and capability.
   The problems of small systems,
much like the broader problems of
underinvestment  in drinking water,
have been with us for a long time.
Over 20 years ago, the Assistant
Surgeon General warned of an
"immediate need in many localities for
upgrading present water treatment and
distribution practices," and in 1980,
EPA concluded that many smali
systems could not meet then-existing
water standards because of "serious
SUMMER 1994
                                                                                                              17

-------
 financing and/or operating problems."
 In  \l)H7, the National Council on
 Public Works Improvement warned
 that "many small water systems, as
 currently managed and operated,
 constitute a significant threat to public
 health."
    Still, there are those who would
 discount the historical context in which
 today's drinking water problems must
 be viewed and addressed. Increasing
 rates of noncompliance among systems,
 the rising cost of water, and strains on
 state budgets all had their genesis, they
 argue,  in the halls of Congress.
    Manv state regulators and drinking
 water purveyors believe that the 1986
 reauthorization  of the Safe Drinking
 Water Act precipitated a water crisis.
 They believe this crisis will be cured by
 substantially weakening the Act and
 putting EPA in the back seat when it
 comes  to judging and securing the
 safety of drinking water from one
 community to the next.
   Friends of the F.arth and others in
 the environmental and public-health
 community do not share this view.  We
 understand that new regulations
 adopted since the passage of the  1986
 Amendments have highlighted the
 seriousness of these long-standing
 problems. We do not believe, however,
 that the law or its regulations are the
 root cause of these problems.
    On the contrary, the amendments
 to the federal drinking-water law which
 pressed for a 20th century definition of
 "potable" may help to address
    While many large
    water systems are
               j
        deficient, the
    condition of small
     systems is clearly
             worse.
significant weaknesses in the nation's
approach to domestic water supply.
According to the National Regulatory
Research Institute, the long-term effect
of the Act may be "positive,"
stimulating technological innovation
and forcing much needed restructuring
of the water-supply industry, an
industry dominated bv small,
                                                                              Milwaukee restaurants like
                                                                              Miss Katie's Diner hud to
                                                                              boll writerjor drinking.
                                                                              MilKftukff Jcntnial pholff
 undercapitalized systems unable to
 cope with the challenges of providing
 safe water in the 21st century.
    In our view, the 1986 Amendments,
 as controversial as they have become,
 have provided an important public
 service for they have brought issues of
 drinking-water supply to the forefront
 of public debate. Though this debate
 on drinking water has been heated at
 times, some good things have already
 happened because of it.
    Most notably, the Clinton
 administration has sold the notion of
 investment in drinking water not only
 to federal lawmakers but also to federal
 appropriators. Already $599 million
 dollars has been budgeted for a state
 revolving loan fund for drinking water.
 As soon as Congress reauthorizes the
 drinking water law, federal monies can
 be spent improving the safety of water
 supplies in many locales and employing
 workers in the business of providing
 safe water.
   In addition, the Congress, prompted
 in large part by the administration, is
 beginning to recognize that safe
 drinking water requires two critical
 steps:  protection as well as treatment.
 More of the public and policy makers
 are awakening to the need to improve
 and integrate pollution-prevention
 programs with approaches to assuring
 tap water safety.
   And finally, complacency about
 drinking-water safety, though it may
 yet survive to threaten more
 communities, has been shaken
 somewhat. However today's debate is
 resolved, we hope that commitment to
 safe water will win out over
complacency before another
community suffers the public and
personal losses that befell
 Milwaukee.D
18
                                                                                                     EPA JOURNAL

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    Monitoring Lead in  Drinking Water
                    —David Urbinato
      A  ccording to the latest round of
     f-\ monitoring completed at the
    •*•  -Vrnd of 1992, more than 10
    percent of all large and medium-sized
    public water systems in the United
    States provide drinking water that
    contains lead levels exceeding the
    "action level" of 15 parts per billion
    established by EPA under the Safe
    Drinking Water Act. Those systems
    that exceed the action level must take
    corrosion-control measures to reduce
    lead levels, perform additional
    monitoring, and inform the public.
       Overall, 100 large systems and 719
    medium-sized systems exceeded the
    action level. By definition, large
    systems serve more than 50,000
    people, and medium-sized systems
    serve 3,301 to 50,000 people.
    Altogether the 819 systems provide
    drinking water to 30 million people.
    The five large public water systems
    with the highest reported (90th
    percentile) lead levels were:
    Charleston and Columbia,  South
    Carolina; Utica, New York; and
    Newton and Medford, Massachusetts.
    The five medium-sized drinking water
    systems with the highest report levels
    were: U.S. Marine Corps Camp
    Lejeune-Hadnot Point, North
    Carolina; Grosse Point Park,
    Michigan; Goose Creek, South
    Carolina; Honesdale, Pennsylvania;
    and Mangum, Oklahoma.
       The law requires systems to test
    the tap water in residences likely to
    have high lead levels; consequently,
    monitoring results do not represent
    average levels of lead in drinking water
    for the entire system. Normally, areas
    served by lead service lines  or
    residences containing lead interior
    piping or copper piping with lead
    solder installed after 1982 are
    considered high risk. Studies have
    shown that lead solder installed before
    1982 is no longer leaching lead into
    water, thus those water lines are
    excluded from testing. Since 1986, it
    has been illegal to use lead solder that
    contains more than 0.2 percent lead.
    A water system is found to  exceed the
    action level if more than 10 percent  of
    its high-risk residences contain lead
    levels above 15 parts per billion.
       In  April 1994, EPA advised
    homeowners with submersible brass
    pumps installed within the  last year  to
    switch to bottled water until they
    could test their tap water for lead.
    Laboratory research done by the
    Natural Resources Defense Council
and the Environmental Defense Fund
showed that the brass parts of newer
pumps release large amounts of lead
during their first months of use.  EPA
is conducting studies to assess how the
laboratory findings relate to lead
concentrations in water as it comes
out of the tap. Concerned
homeowners can call EPA's Drinking
Water Hotline at 1-800-426-4791
with questions on the pump problem.
   Lead is rarely found in either
surface water, such as lakes and rivers,
or ground water, which are the sources
of drinking water for many Americans.
Lead usually enters the water supply
after it leaves the treatment plant.  In
some systems, the water is corrosive
enough to leach lead from household
plumbing pipes and lead service lines
through which it passes.  Treatment
techniques sometimes include  putting
additives such as lime, calcium
carbonate, or phosphate and silicate-
based corrosion inhibitors into the
water.  These additives make the
water less corrosive and leave a
protective coating of minerals on
pipes, so that less lead can be
absorbed by drinking water.
   Lead is especially threatening to
children and infants.  In large
quantities it can delay physical and
mental development in babies  and
impair mental abilities in children.
On average, about 10 to 20 percent of
a child's exposure to  lead comes from
drinking water.  Combined with the
other major sources of lead exposure,
 contaminated soil and lead-based
 paint, however, the levels could be
 high enough to cause adverse health
 affects.
    Individual households located in
 communities where the lead level has
 exceeded the action level do not
 necessarily have high lead levels. EPA
 suggests that homeowners in these
 communities have their water tested
 to determine the lead levels for their
 households. Homeowners can call
 their community water supplier for
 help in locating EPA-certified
 laboratories that test for lead, or, once
 again, they can call EPA's Safe
 Drinking Water Hotline at  1-800-426-
 4791. A single test ranges between
 $15 and $40, depending on the
 laboratory.
    Following are some preventive
 measures consumers may take to
 reduce high lead levels in their
 drinking water:

 • Run the tap for several minutes
 before using water. This water can be
 used for cleaning and watering plants.

 • Use cold water for cooking as  lead
 leaches more readily into warm water.

 • Avoid the use of hot water in
 preparing baby formula.

 • Consider installing "point-of-entry"
or "point-of-use" devices if testing
indicates highlead levels.

• Consider using bottled water of
known quality.
SUMMER 1994
                                                                                                                      19

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Blue  Plains:
Saga  of  a  Treatment  Plant
Investments in technology have paid off
                                  by Myron F. Urnan
Klue Plains, located in tin-
District of Columbia on Hie
Potomac River, is now one of the
world's largest and most advanced
wastnvater-treatinent plants.
 (Dr. Unnin is assistant executive officer of
 the National Research Council of the
 National Academy of Sciences ant! National
 Academy of Engineering and teaches part-
 time at George Mason University.)
      The Blue Plains wastewater-
      treatment plant currently
      handles about 70 percent of the
municipal sewage generated in the
immediate metropolitan Washington,
DC, area. The plant is operated by the
District of Columbia and serves
portions of the Maryland and Virginia
suburbs.
   The Blue Plains plant currently
provides tertiary treatment for an
average influent of 309 million gallons
per day (mgd). It can provide primary
treatment and disinfection for an
additional 289 mgd  of stormwater
surge.  About i ,800  tons of sludge are
generated daily. The removal
 20
efficiency for biochemical oxygen
demand (the amount of oxygen that
would be consumed by natural
organisms in the process of breaking
down waste in polluted water) is 98
percent, and for suspended solids, 95
percent.
   Over the years, the plant's operators
have been faced with a constant
challenge to enhance the plant's
performance and to catch up with
expanding demand that resulted from
population growth that consistently
exceeded projections.
   In the Washington area, the
practice of using water to remove waste
via storm sewers dates from about

                     EPA JOURNAL

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1840. Between that time and 1938,
raw waste was dumped directly into the
Potomac River. As the population
grew, the Potomac became an open
sewer. President Lincoln was known to
leave the White House frequently
because of the stench emanating from
the river. After the Civil War, the city's
population continued to grow and the
sewage problem worsened. In 1889, a
board appointed to consider the
pfoblem recommended moving the
sewer outfalls downstream, which, the
board concluded, would allow the city
to double its population to 500,000
without  recreating the nuisance in the
city proper.  Imagine trying to solve a
pollution problem today merely by
moving the outfall downstream!
   The population reached that figure
in the early 1930s, by which time
bacterial pollution had closed the river
from the city to a distance 10 miles
south. In  1934, the federal
government provided $4 million to
build a treatment plant at Blue Plains,
at the southern end of the District.
The plant, which at the time
incorporated only primary treatment,
started operation in 1938 with a
capacity of 130 mgd in order to treat
municipal  wastewaters of a population
of 650,000 people.  By 1940, the
plant's service area had a population of
850,000, the plant was overloaded, and
untreated sewage was being dumped
into the river again. Due  to the war
effort, the  population had jumped to
1.5 million by 1943, and about one-
third more pollution was being dumped
in the river than before Blue Plains was
built.
    In 1949, the capacity of the Blue
 Plains plant was expanded to 175 mgd,
 which would have been sufficient for a
 population about one-fifth the size of
 the service area. Fish kills and blooms
 of algae were commonplace. In the
 early 1950s, water from anywhere in
 the Potomac was unsuitable for
 drinking without treatment. Below the
 District, the river was unsuitable for
 swimming and fishing. Between 1932
 and 1956, the nutrient loading of
 discharges to the river was doubled.
   President Lincoln
  was known to leave
    the White House
frequently because of
the stench emanating
      from the river.
    The capacity of the plant was
 further expanded to 240 mgd by 1959,
 and full secondary treatment processes
 had been installed.  Chlorination was
 added in 1968 to disinfect the effluent.
 Still, by 1970, the pollution loading
 was higher than it was in 1932,  and
 mats of algae extended for as far as 50
 miles downstream in the summer.
 Fishing and swimming in the river were
 prohibited.
    In the 1970s, investments in
 treatment technology at Blue Plains
 amounted to about $1.6 billion. The
 river finally began to recover. Although
 algae blooms continued, they were less
 severe. Recreational boating had
 returned to the river by  1976 and, after
 a long hiatus, bass returned as well.
Advanced treatment, aimed in part at
reducing nutrient inputs to the
Chesapeake Bay, began in 1980, when
the plant's capacity was expanded to
309 mgd. The tertiary treatment
facility cost $500 million to build and
costs $50 million per year to operate.
The additional capacity also allowed
for storage and treatment of part of the
region's stormwater surge.
   In the early 1980s, bottom
vegetation returned to the Potomac
and fish populations  noticeably
increased.  In 1988, the plant began
removing excess chlorine from its
discharge waters to protect fish larvae.
Capacity will be expanded to 370 mgd
by the end of 1995.  Currently, 78
species of fish are found in the river at
the District of Columbia.
   The history of Blue Plains is one of
many failures and a few successes as
the demands for its services grew faster
than it could expand or incorporate
more efficient technology. With
massive investments  in tie 1970s and
1980s, however, it appears as if Blue
Plains, with other wastewater-
treatment facilities in the metropolitan
region, has finally achieved success
marked by a dean, healthy river
despite a population  that continues to
grow.D
Copyright Myron F. Uman 1994. Source:
Interstate Commission on the Potomac
River Basin and the District of Columbia
Department of Public Works. Tiiis article is
an excerpt from What Makes Cities
Tick? a manuscript in preparation.
 SUMMER 1994
                                                                                                            21

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Portland,  Maine:
Case  of  a   Combined Sewer  System
When  it rains,  the system  overflows       by David
     O CSO Locations
       CSO Locations to be deactivated
       upon implementation of the recommended plan
       As anyone who has ever had
       problems with a clogged toilet
       knows, sewer systems are an
 important but easily taken for granted
 asset. As far back as the mid-19th
 century, Americans were building
 systems to get waste, both human and
 animal, out  of town. Since animals
 were the main source of transportation
 (Urbinato wrote r./;w article while at EPA
 as part of the University of Missouri's
 Washington, DC, program for graduate
 students in journalism. Ile graduated in
 May with an MA. in journalism.)

 22
towns had to devise a way to get their
waste off the streets. So they
combined their street, or storm, sewers
with their residential sewers to avoid
the cost of building separate systems.
There arc 1,100 of these combined
sewer systems (CSSs) still in use today,
most of them in the Northeast and
Midwest. Together they serve 43
million people.
  There is a problem with CSSs:
When it rains, they often overflow,
because they carry more wastewater
than either treatment facilities or their
piping systems can handle. Portland,
Maine, is one of the communities
struggling with "combined sewer
overflows" (CSOs). About 720 million
gallons pour into the coastal waters
around Portland every year.  That
amount of flow would cover  most of
downtown Portland, about three
square miles, with a puddle more than
a foot deep. The city's efforts to come
up with a plan to deal with CSOs show
how difficult and expensive a problem
they have become.
   CSOs are responsible for  closing
Portland's East End Beach several times
during the summer, and they
contribute to the closing of the city's
shellfish beds. Back Cove, which is in
the center of the city-and is  for
Portland the kind of recreational focal
point that the Tidal Basin is  to
Washington, DC—is unsuitable for
recreation for several days after storms.
Though the outfall from  Portland's
wastewater-treatment facility is partly
responsible for these problems, there is
no question that CSOs are a
substantial threat to human and
aquatic life in the waters around the
city.
   Portland's problems come from the
city's collection system. During rainy
periods, the pipes and mains in certain
parts of the system can't get combined
sewage flow to the treatment plant.
Whatever can't be accommodated by
the conveyance system gets piped
straight into the receiving water. In
Portland, there are 39 locations where
this happens.
   In 1991, the city of Portland and
the Portland Water District were
required by a consent agreement with
the Maine Board of Environmental
Protection to develop a CSO
abatement plan.  In response to the
consent agreement, the city formed a
task force consisting of state, regional,
and local officials and local
environmental group,? to study the
problem. Over a three-year period the
task force came up with a plan that,
when fully implemented, will allow
greater use of Portland's public beaches

                     FPA JOURNAL

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throughout the summer and will
control 99 percent of all wastewater
flows generated during wet weather.
Overall CSO volume will be reduced by
88 percent, and the number of CSO
events will be reduced by 85 percent.
   Portland aims to control CSOs with
a variety of methods: reduce pollutants
at their source, improve the system's
ability to store wastewater and convey
it more slowly to the treatment plant,
increase the capacity of key pumping
stations,  control the storm flow into
the sewer system, and use watershed
management to help control runoff.
   Presently, Portland is already
reducing pollutants at their source and
plans to expand the practice under
their CSO plan. The city will continue
to aggressively implement an industrial
pretreatmcnt program that requires
companies to remove their toxic and
other nonconventional wastes from
their wastewater before discharging it
to the sewers.  Portland also sweeps its
streets twice a year, removing 1 7,000
cubic yards of material that would
otherwise end up  in the treatment
plant or be piped  into the city's
waterways.  The city will expand its
efforts to clean the sewers to prevent
waste from accumulating and thus
impeding the flow of water to the
treatment facility.
   The city also plans to improve its
system's ability to move waste after it
gets into the sewer system.  Many
sewer systems rely on gravity to get
waste to the treatment plant.  Pumping
stations are used when gravity can't do
the job. The Portland plan calls for
optimizing the capacity of two
pumping stations, which are now
overwhelmed during storms. The city
also plans to build a storage facility
near one of the stations to detain
storm flow, which can then be pumped
to the treatment plant in dry periods.
Storage facilities are among the more
expensive elements  of the plan,
accounting for just under one-fourth of
the total CSO plan  costs.
   Controlling flow before  it gets into
the sewer system is  another major
element of Portland's CSO  plan. One
technique applies "brakes" at certain
points in the system. These devices,
known as vortex valves, reduce storm
flow entering certain street  sewers and
force it to travel over ground on streets.
The storm flow then enters the
combined sewer at a point where there
is capacity, enters a separate storm
sewer, or ponds in an area where
flooding is not a problem.  Vortex
valves, which are already being used in
Portland, will continue to be installed
throughout the combined sewer
system. Stonmvater detention facilities
will also be built.  Unlike storage-
facilities, these collect storm flow above
ground before it enters the system so
that it can be controlled separately.
   To complete the picture, Portland
plans to incorporate watershed
management  programs to remedy
certain parts of their CSO problem.
These include planting grassy areas and
building wetland systems so that
        Dry Wealher Flow Drops lo Inlerceplo
                                                               e rf low
SUMMER 1
 nature can detain and soak up rain and
 slowly release it into the city's sewers
 and waterways, cleaning it along the
 way.  Also, some combined sewers will
 be separated.
    Portland officials say the plan will
 cost S52 million.  If it is implemented
 over a 15-year period, as is planned,
 the annual sewer costs to Portland's
 households will rise from the current
 rate of $200 a year to $250 during the
 average year of the plan and $325
 during the peak year of the plan.  The
 peak year cost represents
 approximately 1.22 percent of income
 for a household with median income.
    Portland's plan reflects in several of
 its key elements a national policy on
 CSOs recently adopted by EPA.  The
 plan,  like the policy, was formulated
 with input from the principal
 stakeholders, not merely released to
 them  for comment after the fact.  As
 allowed in the policy, Portland's plan
 spreads the costs out over 15 years,
 scheduling the larger, capital-intensive
 projects for the latter part of the
 period.  That way, if the cheaper,
 earlier control efforts are successful in
 reducing the CSO load,  the later
 projects can be scaled down to save the
 ratepayers money.  As mentioned
 earlier, Portland's plan will reduce
 overall CSO volume by 88 percent;
 EPA's policy calls for a reduction, in
 most cases, of at least 85 percent.
 Current law, which  many
 municipalities complain  is unrealistic,
 can be interpreted to require 100-
 percent control.
    Nevertheless, several  issues need to
 be resolved before Portland's plan can
 be approved by EPA. For example,
 Portland officials intend to bypass a
 significant portion of their storm  flow
 around secondary treatment  at the
wastewater-treatment facility; this
 storm flow would receive primary
 treatment only. This practice would
 require a special NPDES permit
 provision from EPA to avoid being a
direct violation of the Clean Water
Act. To be granted  the NPDES bypass
provision, the officials would have to
show, for one thing, that the bypass
would not cause or contribute to
violations of water-quality standards in
Casco Bay.
   Portland and EPA currently are
negotiating to reach  consensus on the
city's plan.D
                                                                                                                   23

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New  York  City:
Case  of  a  Threatened  Watershed
Pollution  prevention could save huge filter costs
                                                 by Keith S. Porter
Kensico Reservoir near New York City. Kensico serves
as a distribution reservoir from which water is conveyed
to the city through a gravity-fed system of tunnels.
Nathan Farli photo.
 (Porter is Director of the New York State
 Water Resources Institute, Cornell
 University.)
       New York State law authorizes
       New York City to regulate the
       two upstate watersheds—the
Croton and the Catskill-Delaware-that
provide the city with drinking water.
These two watersheds cover an area
nearly the size of Delaware. They
contain within their boundaries parts
of eight counties, 60 towns, One city,
and 11 villages, and more than 500
agricultural and horticultural units.
They provide drinking water for nine
 24
million consumers—roughly half the
population of the state. Eight million
of these reside or work in New York
City itself; the remaining one million
reside upstate in the watersheds.
   The two watersheds, together,
produce 1.2 billion gallons of water
daily. This water traditionally has been
of such high quality that it often won
contests. The city found no need to
filter it before supplying it to
consumers.
   The natural beauty of the
watersheds, however, and their
proximity to the metropolitan area
have encouraged land development.
Close to the city, development has
been aggressive. For example, since the
second world war, suburban
encroachment in Westchester and
Putnam counties has caused serious
degradation of the Croton reservoirs.
Consequently, filters to treat the water
produced in the Croton system are now
required. Expected construction and
annual operating costs are $600
million and $45 million, respectively.
   The Croton system produces only
about 10 percent of the water
consumed by New York City. If similar
degradation were to occur in the more
remote Catskill-Delaware system, and
filters became necessary, the costs
would be enormous. Construction
could exceed $5.0 billion; annual
operating costs would approximate
$300 million.
   Some scientists believe filters
should be constructed to protect
against already existing risks. Such a
position has been taken by an expert
panel formed by EPA's New York
regional office. The panel also stated
that comprehensive watershed
management is required regardless of
whether the filters are installed.
   Last December, EPA agreed to
postpone the decision on filtering the
Catskill-Delaware supply  for three
years while the city attempts to
demonstrate that it can maintain the

                     EPA JOURNAL

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quality of the water through watershed
control.  As a backup measure, the city
must complete the preliminary design
of the filters during the period.
   For the nine million consumers in
New York City and Westchester
County, failure of watershed control
programs upstate will mean they have
to bear the brunt of paying for filters.
To pay greatly more for water of equal
or lesser quality will seem economic
perversity. On the other hand, the
watershed residents believe that
economic perversity is already upon
them.  Under the watershed control
programs, they are being asked to incur
unknown economic and social costs to
protect water that is consumed
primarily by people outside the
watersheds.  And so the conflict is
joined.
   Over the past three years,
representatives of watershed interests
and New York City have negotiated
over watershed management.  The
negotiations are  intensive and often
acrimonious. New York City is
determined to fully protect its water
supply.  Communities in the
watersheds are equally determined to
protect their way of life. The forced
acquisition of land and subsequent
destruction of many communities
during the original construction of the
New York City reservoirs has left bitter
memories. Nevertheless, progress has
been achieved, especially with respect
to farming in the watersheds.
Negotiations between the city and
farmers have proceeded separately from
those dealing with communities and
non-farm open spaces.  The New York
State Department of Agriculture and
Markets has facilitated discussions
through an inter-agency/farmer ad hoc
task force.
   More than two years ago, a
comprehensive farm management
program was established under the
title, "Whole Farm Planning Program."
The program  is endorsed by New York
State agencies, New York City, the
farmers themselves, and EPA. The
program assumes that, in a populated
rural landscape, well-managed
agriculture is the best protection for
water quality.  Further, compulsion is
unlikely to succeed with fiercely
independent farmers, and the program
should be a voluntary one based on
providing incentives  to farmers to
participate.  Finally,  farming practices
adopted to protect water quality should
be based upon sound scientific
principles. The farmers seek best
scientific options for farming purposes,
and New York City seeks scientific  .
assurance that those  options will satisfy
water-quality objectives. An inter-
disciplinary group of Cornell scientists
is working to meet both these needs.
    New York  City provided $4.0
million for the first two years of the
program, during which the objective
was to develop plans on 10
demonstration farms. Of the roughly
500 farms in  the watersheds, the
majority are dairy farms, and the  10
selected for demonstration were all
dairy.  Another important reason for
selecting dairy farms is that daily
animals are a known source ofgiardia
and cryptosporidium.
   Plans for the farms are now
developed. Each farmer worked with
County Project Teams comprising staff
from Cornell Cooperative Extension,
Soil and Water Conservation Districts,
and the U.S Soil Conservation Service.
These teams received advice and
training from scientists at Cornell
University. Administrative
coordination was provided by the New
York City Soil and Water Conservation
Committee.  Leadership is now passing
to a Watershed Agricultural Council
comprising watershed farmers,
watershed agribusiness, and the New
York City Department of
Environmental Protection (NYCDEP).
   Preventing pollution from farms has
a cost.  For it to succeed, water quality
needs must be reconciled with the
economic constraints and interests of
the farmer. There must be gain to
balance pain.  The solution relies upon
an exhaustive examination of the farm
as a whole. This strategy is called
Whole Farm Planning, which seeks
gains in efficiency by evaluating and
integrating all aspects of management.
This requires coordinated planning bv
agricultural scientists. Farm
economists,  agricultural engineers,  soil
scientists, animal scientists, crop
specialists, veterinarians,
microbiologists, pest management
specialists, and hydrologists must
combine their expertise.  This
integration of multiple scientific
        New York City Watersheds
                                 Schoharie County
        Delaware County
                                Sullivan County
             Catskill/Delaware Watershed
                                                                                                         Westchester County
                                                         Croton Watershed
 SUMMER 1994
                                                                                                                  25

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                      Gargantuan in scale,
                      NtK York City's
                      third water tunnel
                      system, now under
                      construction, will
                      bolster the city's
                      water distribution
                      system. Shown is
                      (lie new Van
                      Cortlantlt Valve
                      Chamber, built
                      250 feet deep under
                      the Bronx, due to ga
                      on line next summer.
                      Nathan i'arb photo.
disciplines is difficult but necessary.
   Whole Farm Planning starts out by
evaluating three stages at which
pollution  can be stopped.  The first is
the source of pollution, such as
barnyard areas, silage systems, stored
manure, and sheds containing
chemicals. If a source is managed so as
to eliminate or reduce releases of
contaminants, then risks to water
quality are diminished. The second
stage is  the farm field over which
contaminants may be transported to a
watercourse following  precipitation  and
runoff.  By releasing contaminants only
when there is no runoff, by reducing
the amount released, or by managing
soil and crops to minimize effects of
runoff, transport across the field is
reduced. The third  stage  is the
watercourse itself, along which buffer
zones may be kept to prevent
contaminants from  reaching the water.
This evaluation is a rational means to
identify and rank risks  posed by
farming activities. Options for
management can then be selected to
minimize  risks and costs.
   The protozoan pathogens, giardia
and ayptosporidiiatt, are a problem. We
require knowledge about animal
sources of these protozoa and their
environmental fate.  Little is known
about dairy farms as a cause of
microbial pollution of water.  An inter-
agency  pathogen group, including
Cornell scientists, is studying the
incidence of the parasites in dairy herds
and their possible control.  An
associated group is evaluating methods
to identify critical hydrological areas on
the farms.
   The farm management program is
about to enter its second phase, in
which we expect to  implement Whole
Farm Planning on 85 percent of the
remaining farms over the next three to
four  years.  Present  funding for  the
program amounts to $35 million.
   As Whole Farm  Planning has
progressed, inter-agency and
community groups have sought  to
establish a Whole Community
Planning Program.  Local government
is represented by the Coalition of
Watershed Towns.  Technical working
 groups and a policy dialogue group,
 involving about 300 individuals, have
 been created to seek technical and
 institutional agreements.
    To demonstrate how community
 planning might protect water quality,
 six towns assumed a pilot role.  1 he
 towns are Denning, Middlctown, and
 Neversink  in the Catskill-Dclaware
 watershed, and Kent,  Patterson, and
 Southeast in the Croton Watershed.
 (See map inset, page 25;  not shown:
 Middletown, the southernmost pilot
 town in the Catskill-Delaware
 watershed.) Each town  formed a
 Citizen Advisory Committee; the
 committees are supported by technical
 staff from County Health and Planning
 Departments,  by Cornell Cooperative
 Extension,  the New York State Water
 Resources Institute, and the NYCDEP.
 Each committee has identified and
 assessed priorities for their town. On-
 site wastewater disposal, stormwater
 and drainage, and land-use
 management are shared  major
 priorities. The towns  in the Catskill-
 Delaware watershed are also concerned
 with streambed and streamhank
 management.  Denning and Neversink
 have proposed a joint  Watershed
 Council for the Neversink Reservoir
 whose  catchment area lies within the
 two towns.
    The declared intention of New York
 City to acquire additional land to
 protect its reservoirs has seriously
 jeopardized further negotiations
 between the city and watershed leaders.
 Currently about 350,000 acres,  or
 roughly one quarter of the watersheds,
 is owned either by New York State or
 by the  city. The city now proposes to
 purchase an additional 80,000 acres,
 for  which it has committed $201
 million. Unfortunately,  the city has
 not yet explained why it needs 80,000
 acres, nor has it developed an
acquisition  strategy. As shown by the
 history of acquiring land for the
construction of the reservoirs, land
purchasing  by the city is a heatedly
contended issue. The  towns are also
worried about consequences for their
tax  base.
    Nevertheless, there is shared hope
that this critical dispute can be
resolved.  In the absence of local
cooperation, nonpoint sources will not
be controlled sufficiently to  make
pollution prevention work.  The
outcome bears watching  as a case study
in watershed management.D
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Albemarle-Pamlico:
Case  Study  in  Pollutant Trading
Most of the  nutrients came from  nonpoint sources
                                                                              by John Hall
                                                                              and Ciannat Howett



                                              Alb
                                                 marle-
                                                 ^'f Swn
                                                 Utrnrrsit
(Hull and llntvt'tt air environmental
attorneys at Kilpathck &. Cody in
Washington, DC. Hall is a partner and
Howett, an associate. Tlie authors provide
legal and tcclinical counsel to groups of
industrial and municipal dischargers
nationwide, including the Tar-Pamlico
Basin Association.)

SUMMER 1994
                                                                      TI

                                                                      •
                                                                      I
     'he Albemarle-Pamlico estuary of
      North Carolina is the second
      largest and one of the most
productive estuarine systems in the
country.  Over the past two decades,
excess nutrients entering the estuary
from the Tar-Pamiico River have
caused algal levels to increase.  These
increased levels can lead to fish kills,
odors, and habitat loss and can
generally diminish water quality. The
system has also suffered significant
losses in wetlands, submerged aquatic
vegetation, and spawning areas due to
real estate development.
   To reverse the degradation  of the
estuary, in 1989 North Carolina's
Department of Environmental
Management decided to increase
control of municipal and industrial
point-source dischargers along the
river. Under a proposed watershed
plan, these dischargers would he forced
to build advanced treatment facilities
to reduce their nutrient loading to the
river. Estimated capital cost for the
facilities was approximately $50
million.
   The problem with the state's
strategy was that almost SO percent of
the nutrient pollution entering the Tar-
Pamlico River was discharged not from
point-sources, but from agricultural
and urban runoff and other nonpoint-
sources of pollution. (See pie chart on
page 29.)  The state's strategy provided
for only minimal increased attention  to
reducing nonpoint-source pollution and
did not earmark additional funding or
staffing for such efforts. Technical
analyses indicated that little, if any,
actual improvement in  water quality
would occur from the point-source
control measures.
   In 1 989, a group of municipalities
and industries located along the Tar
and Pamlico Rivers joined together to
form the Tar-Pamlico Basin
Association, Inc. Their purpose was to
                                                                                            27

-------
 develop an alternative strategy that
 addressed both point and nonpoint
 sources of pollution in the entire Tar-
 I';milia> watershed on a cost-effective
 basis.
    1 he Association proposed to
 optimize reductions in point-source
 loadings through existing facilities and
 to promote nonpoint-source reductions
 through innovative financing
 arrangements.  Both technical and
 regulatow assistance was offered to
 leverage state resources in reaching a
 better understanding of the nutrient
 dynamics of the estuary and in
 identifying the most cost-effective mix
 of point- and nonpoint-source controls.
This concept of point sources contributing
to nonpoint-source controls is known as
point/nonpoint-source "trading."
    In December 1989,  the
Association's alternative strategy was
adopted, and an agreement was signed
by the Tar Pamlico Basin Association,
the State of North Carolina's
Department of Environmental
Management, the Environmental
Defense Fund, and the  Pamlico- Tar
River Foundation.  The strategy
consisted of three primary components:
group point-source controls, nutrient
discharge trading that funded nonpoint-
source controls, and nutrient modeling
of the watershed that improved
targeting and tracking of pollution
sources.

Point-Source Controls

Under the Tar-Pamlico agreement, the
Association is given group nutrient-
reduction goals, rather than individual
nutrient limitations being placed in
each member's discharge permit.  The
goals arc set at increasingly stringent
levels each year for the first five years
of the project.
   The agreement requires members of
the Association to evaluate their
facilities to identify operational or
minor capital improvements that could
reduce nutrient discharge levels. Once
they have optimized existing facilities,
they are given the choice of achieving
the group limitations by making major
improvements to their facilities,
"trading" discharge levels between
themselves, or by funding
implementation of nonpoint-source
pollution controls.
   As a  result of the initial evaluation,
                      "  2
                              Nutrient Load Reductions by
                              Tar-Pamlico Basin Association
                       Baseline Year 1989
                                         1991
                                                     1992
                                                                  1993
28
Association members were able to meet
almost SO percent of their group
nutrient-reduction targets through
operational changes alone.  By working
together as a group, they were able to
finance a sophisticated engineering
evaluation of their plants which as
individuals—particularly the small
towns that are members of the
Association—they never could have
afforded.
   The bar chart shows the
Association's success in reaching its
nutrient-reduction goals during the first
phase of the project.  From 1989 to
1993, the new approach reduced
overall nutrient loading to the
watershed by 28 percent even though
the average flow per month to the
watershed increased by 18 percent.
Effluent  nitrogen concentrations, the
primary pollutant of concern, decreased
from 14.4 mg/1 to 8.9  mg/1. This result
far exceeded reductions that would
have occurred under the original state
proposal.

Nonpoint-Source Controls and
Nutrient Trading

If the Association members had  not
been able to reach their group nutrient
reduction goals, the Tar-Pamlico
strategy would have allowed them to
pay into  a fund to implement
nonpoint-source controls. The
arrangement was for them to pay $56
for each kilogram of nutrients they
discharged over the target level.  A 10-
year credit was to be given for each
kilogram funded by this approach. The
flexibility of this arrangement is
important because, once plant
performance is optimized, preventing
nutrient  pollution through nonpoint-
source controls, such as agricultural
best management practices (BMPs), is
far less costly than it is through
advanced wastewater treatment.
Further,  it also promotes habitat
restoration, wetlands preservation, soil-
quality control, and those other
benefits that come with agricultural
BMPs.
   Even  though point/nonpoint-source
trading has not been necessary yet, the
Association has provided almost Si
million for demonstration projects in
the watershed, primarily involving

                          EPA JOURNAL

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                                                            Egrets art'
                                                            native to
                                                            I'ar-Pamlicu
                                                            river marshes.
                                                            CoQ/ri&t
                                                            Xivrr Taylor phots
                                                            Dukt liunmit}-
                                                            \larnif Laboratory.
implementation of agricultural BMPs.
Witli the help of federal funds, the
Association developed model BMP
projects to ensure that the
infrastructure is present when trading
becomes necessary.  In addition, the
Association has spent $150,000 to
finance additional personnel in the
North Carolina Division of Soil and
Water Conservation to assist in
identifying .nonpoint sources and
implementing BMPs in the watershed.

Nutrient Modeling

In addition to obtaining funding for
BMP projects, the Association funded
creation of a water quality model of the
Pamlico estuary and obtained funding
for development of a geographic
information system  (GIS) of the
watershed.  Through the use of these
models, the state can target BMPs to
those operations that are causing the
greatest impact and can determine if
additional point-source limitations
would improve water quality. This
capability allows the state's regulatory
strategy to  move beyond the scatter-
shot approach of controlling all point
or nonpoint sources to the maximum
extent and  brings to bear a more
sophisticated cost/benefit analysis of
pollution improvement impacts.

RUMMER 1994
Conclusion

At the end of 1995, the Tar Pamlico
project will move into Phase II.
Development of the project, in which
the infrastructure and foundation for
trading and nonpoint controls were
established, will give way to
implementation, in which the basic
concepts will be retained  and trading
can occur as necessary. Negotiations
on the specific provisions of Phase II
are just beginning, but there is no
question that the project  is  considered
a success by all the parties involved:
the Association members, the
regulators  at the  state and federal
         1988 Tar-Pamlico Nitrogen Sources
                                         [Industry (2%)
levels, and the members of the
environmental community.
   The concepts of point/nonpoint-
source trading and watershed-based
management have also become
increasingly popular since the i'ar-
Pamlico project first introduced these
concepts.  Despite some initial
skepticism, EPA is now pointing to the
project as  a model for cost-effective and
innovative water-quality control.  Both
the House and Senate versions of the
Clean Water Act reauthorization
contain provisions for a watershed
approach to water-quality
improvement; both versions would be
improved  if additional provisions are
included to encourage cost-effective
alternatives such as point/nonpoint-
source trading.
   As this concept grows in popularity
and prominence, communities
interested  in implementing similar
approaches should look to Tar-Pamlico
as a case study experience. To aid
communities in such an endeavor,
Congress recently appropriated funds
for creation of a guide to watershed
planning and point/nonpoint-source
trading as  implemented in the Tar-
Pamlico basin. This guide will be
available in the fall of  I 994 through
the North  Carolina Department of
Environmental Management, 512
North Salsbury Street; Raleigh, North
Carolina 27604. D
        Urban (4%
      (Figures total greater than 100 percent due to rounding.)
                                                                          29

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  'resident
      inton's
      ean  Water
Act Initiative:
  Josts  ant
  Jenefits
 Costs avoided would
 outweigh costs incurred
 by Mark Luttner
Annual Cost of Major Provisions
    iOtoer              Billions 1993 dollars 100
    ; Stormwater(Phasell)
L" ID Mines
I   ._] Combined Sewer Overflow
BB Nonpoinl Sources
HH Stormwater (Phase I)
    I Base                1	175
                                  25
 Current Spending  Clinton Proposal   Current CWA
 Includes cost ol   Does not include    Requirements
 proposed and     potential cost savings under strict
 final rules       (or future costs    Interpretation
            avoided) tram
            ellluenl trading
      President Clinton's Initiative for
      reforming the ("lean Water Act
      (CWA) will reduce red tape,
streamline administrative procedures,
and target expenditures—all for the
purpose of realixing our water-quality
goals more efficiently. Equally if not
more important, the initiative focuses
on those pollutant sources that have
been controlled inadequately in the
past: wet weather runoff from
agriculture, combined sewer overflows
(CSOs), and stormwater.  Rather than
imposing across-the-board, national
mandates, the initiative calls  for more
targeted approaches based on risk. In
other words, state and local
governments would be given greater
flexibility to focus on highest priority
problems.
   In developing recommendations to
improve the Clean Water Act, the
Administration estimated the costs and
projected benefits for implementing
each of its major provisions. Costs
were estimated  for private sources,
municipalities, state governments, and
the federal government. Estimates
were made for what is currently being
spent, what would be required under
the President's Initiative, and what
would be required under the existing
law if nothing changed.
   The annual  incremental costs of the
Initiative for all sectors range from
$5.0 to $9.6 billion.  However, the
proposed recommendations would also
result in cost savings or costs  avoided
for all sectors of $29.1 to $33.8 billion
annually compared to current law, with
the majority attributable to urban areas
that have historically faced large
stormwater and CSC) costs.

Watershed Approach

Currently, programs to control runoff
from agricultural and urban areas  cost
between $1.0 and $1.3 billion
annually.  The Initiative would require
an increase of between S 1.0 and $ 1.7
billion. However, this does not include
related savings to the agricultural
community from reduced  pesticide and
fertilizer use, nor docs it take into
account savings to those areas that
develop and implement plans for
runoff management on a watershed
basis. Watershed management, which
provides an integrated approach to
controlling pollution sources, results in
resources being coordinated and
leveraged more efficiently. The result
is increased long-run savings, savings
that are not reflected here.

Stormwater

Under the existing CWA, the estimated
annual  cost, for businesses and
municipalities to control polluted
runoff from yards, streets, and  parking
lots would be between $23.6 and $24.5
billion.  The President's Initiative,
however, calls for spending $7.0 to
$10.1 billion annually.  Thus, the
Initiative would provide welcome
financial relief to hundreds of
communities as they struggle to address
one of the most complex and expensive
water-quality problems in the country.

Combined Sewer Overflows

Combined sewer systems are a remnant
of the country's earliest water
infrastructure. They date back to the
19th century, when getting animal
waste off the street was a municipal
priority and towns frequently
combined their street (storm) sewers
with  their residential  sewers  for
economic reasons. Combined sewer
overflows (CSOs) occur when heavy
rains or snowmelt overload the system
with  more wastewater than their piping
systems and treatment facilities can
handle.
   Replacing this  infrastructure has a
significant price tag, one that many
cities have difficulty paying.  For many
years, CSO communities have regarded
existing requirements as simply
unachievable, and as a result many
have done little or nothing.  The
President's Initiative is a consensus
product negotiated by EPA and a
diverse group of interests, including
environmental groups and the cities
themselves. It is a more workable
solution that would provide
communities with additional flexibility
in developing CSO controls while still
meeting water quality goals.  The
annual cost would be $3.5 billion, a
$10.7 billion savings over existing
requirements.

Toxics Control

The Initiative proposes to limit the
releases of the most persistent,
bioaccumulative toxic pollutants and
refocus the process for developing
water-quality standards and criteria.
30
                                                                                                 EPA JOURNAL

-------
Toxic reductions would be achieved
through multi-media strategies and by
providing industry with flexibility in
selecting the most cost-effective
controls.  For example, an industry
might choose to change its production
process rather than having to buy more
expensive treatment technology.

Ground-water Protection

The Initiative would protect ground
water and drinking water by including
provisions for regulating certain point-
source discharges that are likely to
contaminate ground water and related
surface water. The cost to private
sources for control measures, such as
landfill liners and leachate-collection
systems, are estimated to average
between $150 and S600 million  per
year.  Ultimately, the Initiative will
reduce future ground-water
contamination and save millions, if not
billions, of dollars in cleanup costs.

Pollution Prevention Planning

More and more, senior company
managers are asking an obvious
question: Why spend money on
controlling pollution if it  can be
prevented from occurring in the first
place? Many industries have adopted
pollution-prevention planning
voluntarily; however,  for those that
have not, the initiative would give EPA
and the states the authority to require
pollution-prevention plans from
industries holding water-pollution
permits. EPA estimates that the
annual cost of preparing such plans for
about  6,000 industrial permittees
would range between S60 and S120
million.
   Again, this estimate does not
reflect the financial benefit (i.e., cost
savings) that industry may realize by
implementing pollution-prevention
measures. For example, industries that
capture and reuse solvents may lower
production costs.

Abandoned Mines

Approximately 500,000 abandoned
mines can be found on federal lands
around the country. Historically, only
 Benefits

 In addition to saving billions in costs,
 the President's Initiative would result
 in significant benefits in water quality:

 • An enhanced program for controlling
 polluted runoff (nonpoint sources)
 would result in measurable water-
 quality improvements in 52 percent of
 impaired or threatened rivers and 63
 percent of impaired or threatened
 lakes.

 • Stormwater controls could reduce
 loadings of sediments, toxics, and
 nutrients in urban communities by  75
 to 80 percent in developing areas and
 by 15 to 25 percent in areas already
 developed.

 • The Combined Sewer Overflow
 policy will provide adequate treatment
 for over one billion gallons of raw
 sewage, urban runoff, and industrial
 wastewater that are currently
 discharged without treatment during
 an average year.  The enhanced
 treatment would reduce pollutant
 loadings by 2 billion pounds of total
 suspended solids and 445 million
 pounds of biological oxygen demand
 annually.
 minimal effort has been made to
 address these sites despite some serious
 water quality problems. Rather than
 address all 500,000 sites, as is currently
 required under the CWA, the initiative
 would require controls only at those
 mines known to cause water quality
 problems.  The result would be an
 annual cost of $0.3 to Si. 1 billion,
 compared to S 1.1 to $3.5 billion if all
 sites were addressed. The net annual
 savings to the federal government is
 estimated at $0.8 to $2.4 billion.

 Discharge Fees

 Every year, states spend approximately
 $394 million managing permit
 programs-National Pollutant
 Discharge Elimination System
 (NPDES), pretreatmcnt, and sludge.
 To help recover these costs and to
 ensure the long-term viability of these
 programs, the Initiative would require
 states (and EPA in those states with
 programs administered by EPA) to
 assess a fee against permittees.

 Economic Incentives-Effluent
 Trading

 Trading pollutant reductions between
 sources is a concept that was
 introduced in the Clean Air
 Amendments of 1990.  The President's
 CWA Initiative would allow similar
 actions for water pollutants in .select
 circumstances. For example, in a
 watershed heavily affected by farms,
 point sources might subsidize the cost
 of measures to reduce agricultural
 runoff. By thus helping to reduce
 overall pollutant loads on local
waterbodies, point sources might avoid
 having to meet more stringent and
 significantly more expensive treatment
 requirements. (See article on
 point/nonpoint pollutant trading on
 page 27.) EPA's preliminary analyses
 show that trading (between point
 sources, between point and nonpoint
sources, and between indirect
dischargers in pretreatment programs)
could achieve pollution reduction at
significantly lower costs--between $0.7
to $7.5 billion less than the costs of
current mandatory discharge
requirements. D

(Litttner is Director of the Office of Policy
and Resources Management within EPA's
Office of Water.)
                                                                                                                 31

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Amending  the  Safe  Drinking  Water  Act:
View from  Congress
                 The outcome  is not assured
 by Henry Waxman
    In 1986, the last time Congress
    amended the Safe Drinking Water
    Act, the legislative process was a
 model of cooperative progress. But
 times have changed.  The drinking-
 water debate in 1994 may be a
 legislative donnybrook.  On one side
 are water companies seeking to relax
 regulations; on the other are millions of
 Americans concerned about
 contamination of the water they drink.
    The American public became all too
 aware of the potential consequences of
 contamination last year, when
 problems in Milwaukee elevated the
 issue as never before. In March of
 1 993, that city's water supply was
 contaminated with an intestinal
 parasite that made more than 400,000
 ill. For a week, more than 800,000
 residents were without potable tap
water. Drinking water became a
precious commodity. In the end, more
than 40 people died. Many remain
seriously ill even today. Shortly after
this tragedy, a senior EPA official
conceded to Tiie New York Times that,
given the existing drinking-water
protection system, "what happened in
Milwaukee is likely to happen again,
but I can't predict where."
   There have, of course, been other
incidents, including contamination
problems that led to boil orders in the
Washington, DC area, and parts of
New York city.  Also, although they
have not received the same press
attention as the problems in
Milwaukee, New York, and
Washington, many smaller towns  have
been affected by contamination
incidents afflicting tens of thousands in
Texas, Oregon, Missouri, and Cieorgia.
In fact, a June 1991 study in the
American journal of Public Health
estimated that "35 percent of the
reported gastrointestinal illnesses
among . . . tapwater drinkers were
water-related and preventable." (See
Vol. 81 at  703.)
  Across our nation, the message is
clear: Safe drinking water can no longer
be taken for granted. Polls show that
drinking water safety is a growing
public concern, with one industry
survey showing that more than 80
percent of consumers are willing to pay
more for water meeting federal
standards, while less than 2 percent
agree with the industry position that
federal standards are too strict
(Consumer Attitude Survey of Water
Quality Issues, American Water Works
  (Representative Waxman (D-California)
  chairs the House Subcommittee on Health
  and the Environment.)
  32
                    Incidents of tapwater contamination are widespread. Shown here, t< store
                    in Duluth, Minnesota, supplied customers with free cartons of water.
                    Wide World photo.


                                                       EPA JOURNAL

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 Assoc. Research Foundation, November
 1993).
    Probably the single most
 widespread and serious drinking water
 problem in the United States is not
 microbial contamination, but
 contamination from byproducts of the
 disinfection process, such as
 chloroform, that can cause cancer.
 Researchers at the Harvard School  of
 Public Health, the Medical College of
 Wisconsin, and other institutions have
 associated these contaminants with
 more than 10,000 cancer cases each
 year, including nearly 20 percent of all
 rectal cancers and 10 percent of all
 bladder cancers.
    Lead contamination is another
 major problem.  Last year, EPA found
 that more than 800 cities exceeded the
 lead action level established under the
 SDWA.  These high lead levels are  a
 special danger to small children, whose
 developing nervous systems can be
 altered by lead, resulting in reduced
 intellrgence and/or a variety of other
 serious problems.
    Some insights into the nation's
 drinking-water problems can be gained
 from a recent report by the Natural
 Resources Defense Council (NRDC).
 Using industry data, NRDC found that
 90  percent of the large public water
 systems in the United States continue
 to use technology developed before
 World War I to clean their water. (See
 boxed article on page 15.)
   An additional shortcoming common
 to most systems is that treatment
 plants are operated by inadequately
 trained staffs with minimal oversight.
 A two-year General Accounting Office
 (GAO) study concluded last year that
 states, all but one of which have
 authority for assuring drinking-water
 safety under the SDWA, do not
 undertake even the  routine inspections
 necessary to assure that systems are
 operating safely. In most cases, state
 supervision was found to be incomplete
 or superficial, and many states were
 found to rely on inadequately trained
 personnel to review water-system safety
 (GAO, Drinking Water: Key Quality
Assurance Program is Flawed and
 Underfunded, April 1993).
   Given these problems, it is perhaps
 understandable that many cities have
 problems with even the basic necessity
 to keep human and animal wastes out
 of drinking water.  As mentioned
 earlier, the intestinal parasite that
contaminated Milwaukee's water is
believed to have come from animal or
human feces entering Lake Michigan.
Potential contamination from this
same organism has prompted "boil
orders" in a number of other localities,
including two in Racine, Wisconsin.
Even worse, water systems across the
country have been coping with a
variety of other contamination
problems thought to be associated with
sewage. In Washington, DC, fecal
coliform has been found in tap water
on more than one occasion.  In New
York City, another waste-related
   Many  cities have
 problems with even
  the basic necessity
 to keep  human  and
animal wastes out of
    drinking water.
 contaminant, the bacteria e. coli,
 showed up unexpectedly last summer.
 And last Christmas, the bacteria
 salmonella found its way into the water
 of the small Missouri town of Gideon,
 leaving half the residents ill with
 vomiting and diarrhea.
   The range of serious problems
 plaguing our nation's drinking-water
 systems must be addressed by Congress
 in the ongoing effort to amend the
 SDWA. President Clinton has
 proposed a broad new program to do
 just that. The Clinton Safe Drinking
 Water Initiative would provide for more
 financial and technical assistance
 to water suppliers, assure better
 training for system operators,
 streamline the law's requirements,
 provide special relief for small water
 systems, and guarantee more effective
 oversight.  More than that, the Clinton
 administration has put its money
 where its mouth is and secured a 1994
 budget that includes, for the first time
 ever, a major new funding program to
help systems meet drinking-water
standards.
   Enactment of the Clinton proposal,
however, is not assured. The
President's initiative has been
undermined by extremists in the
drinking-water supply industry, with
support from some state and local
groups. Despite recent contamination
problems, they stubbornly insist that
the law's health standards are the
problem and should be rolled back.
Water suppliers, many of which are
municipalities, argue that current
requirements to provide safe water are
"unfunded mandates" and should be
weakened or eliminated. Their rhetoric
on unfunded mandates may sound
populist, but their ideological
intransigence ignores public safety and
will only lead to a legislative stalemate.
   Legislation they support in the
House and in the Senate would
dramatically undermine health-
protection efforts by rolling back
standards, eliminating requirements for
water systems to inform consumers
when standards are violated, broadly
weakening the existing requirements to
reduce lead contamination, eliminating
even the basic requirements for water
systems to test for contamination
levels, and authorizing broad variances
from the act's requirements.
   I take a different view.  One of the
most fundamental responsibilities of
government is to provide safe  drinking
water to all Americans, even where the
water supplier is a  local government.
Parents are concerned about their
children's health, not about faddish
political slogans like unfunded
mandates.
   The unpleasant truth is that we are
confronted with glaring shortcomings
in the program for assuring that the
nation's drinking water is free of
contamination by dangerous
substances. Congress shouldn't weaken
vitally important health standards, but
it should pass legislation that will
strengthen health protection and
provide for more financial and
technical assistance to water suppliers.
   The President has sought to
respond to the nation's drinking-water
problems with an approach that will
reduce the burden  on water suppliers
and provide greater public-health
protection. That is the path to
restoring public confidence in  our
drinking water. D
 SUMMER 1994
                                                                                                             33

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Amending t
View from t
ie  Clean  Water  Act:
ie  Slates
by Howard Dean
 Heavy-handed  control by Washington won't work
S'mw melt In-uiis for Vennonfs Luke (.'hamplain.
l.tfrftA /iijiunmi ;>/iur<>
34
                                                                  A  s the weight of financing and
                                                                 /—% implementing many federal
                                                               _X  jjaws has shifted to the states
                                                                over the past 15 years, governors have
                                                                been pressing for greater participation
                                                                in the legislative process.
                                                                  When representatives of 25 states,
                                                                the National Governors Association,
                                                                and the Association of State and
                                                                Interstate Water Pollution Control
                                                                Administrators met in March of this
                                                                year to discuss their needs in terms of a
                                                                ("lean Water Act reauthorization, two
                                                                words were used repeatedly: consensus
                                                                and constructive,
                                                                  It is obvious that different states
                                                                have different water resource problems;
                                                                compare, say, Vermont to Arizona.
                                                                Nevertheless, taking these differences
                                                                into account, a clear state consensus on
                                                                certain key points is important:  We
                                                                must agree on  what is required by the
                                                                people who will implement this law.
                                                                Moreover, despite some charged
                                                                rhetoric surrounding the Clean Water
                                                                Act reauthorization, the message our
                                                                group sent to EPA was clear: Our goals
                                                                at the federal and state levels are not
                                                                far apart.
                                                                  We want to work constructively
                                                                with the executive and legislative
                                                                branches of the federal government.
                                                                This implies an active role, not the
                                                                marginalized role of naysayer. Thus, as
                                                                strongly as I can, 1 am encouraging
                                                                different groups to work together to
                                                                help House and Senate committees
                                                                write a thoughtful and effective Clean
                                                                Water Act.
                                                                  What do the states want?  In a
                                                                word:  flexibility. Heavy-handed control
                                                                by Washington is doomed to fail or, at
                                                                best, be divisive.  We need flexibility
                                                                concerning our regulatory approach,
                                                                federal oversight provisions, and use of
                                                                federal program-support grants.  We
                                   (Dean, an M.D., is Governoroj Vermont.)

                                                       EPA JOURNAL

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agree with many points of the
President's Clean Water Initiative, but
we are strongly united in some desired
changes. I've summarized some of
them below.

• Co»tpre!iensive watershed management.
This concept is terrific. Comprehensive
watershed management envisions the
states designating whole watersheds for
planning and implementing the needed
facilities or best management practices
required to resolve all watershed
pollution problems in a coordinated
fashion. This approach is meant to
resolve all problems, leaving none
neglected. Functionally equivalent
statewide or regional plans, which
integrate both our  point-  and
nonpoint-source control programs,
should be accepted, and funds should
be made available to accomplish the
goals of comprehensive watershed
management.
   In Vermont, sve have already
identified our problem areas and
necessary corrective actions through
programs that integrate both point and
nonpoint problems. For example, we
have completed--and EPA has
approved--our statewide Nonpoint-
Source Assessment and Management
Plans as well as our State Clean Water
Strategy.

• Nonpoint-source management. Everyone
acknowledges the need for aggressive
nonpoint-source policies to reduce the
amount of polluted runoff from
farmland and urban areas. However,
some proposals in Congress are much
too heavy-handed.  These include
federally prescribed and mandated best
management practices, enforceable
within three years,  which  would
undermine existing state voluntary and
cooperative efforts that are being
carried out in concert with Department
of Agriculture (USDA) programs.
    Requiring each landowner to
develop site-specific management
plans, as proposed in the Senate, would
create a bureaucratic nightmare
because it would be  impossible for the
states to review, approve, and monitor
hundreds of such plans, many of which
are already managed by USDA.
   What do the states
    want? In a word:
          flexibility.
   States should be able to develop
and implement voluntary and
regulatory approaches in any mix that
complements ongoing efforts. We must
be held accountable, of course, for
achieving water-quality standards in a
timely fashion.

• Water-quality standards. Current
proposals in Congress presume that
EPA-developed criteria would become
mandatory in the states after three
years.  This would occur without a
public adoption process regardless of
the site-specific characteristics of the
state and waters or the applicability of
the criteria to those waters. Very few
criteria have such universal
applicability, and this proposal would
be disruptive to state standards setting.
Reauthorization of this section should
focus on better science, not command
and control efforts  that would, for
example, require states to develop
methodologies to translate water
quality into a specific numerical limit
for various pollutants.
   Individual states must set standards
to reflect the unique quality of their
respective waters, after considering
federally developed criteria for toxic or
conventional pollutants. Federal
procedures should prevail if states fail
to act.
   We strongly support amendments
that clarify the scope of state water-
quaiity-standards certifications for
federally licensed projects.

• State Revolving Fund. We need more
money for infrastructure projects such
as wastewater-treatment plants.  The
proposed $2.5 billion authorization
should be doubled to meet identified
state needs, and states should have
more  flexibility  to provide for their
disadvantaged communities.  For
example, states  may need to provide
zero-interest loans or construction
grants to disadvantaged communities
that cannot bear the normal cost-share
of constructing  needed wastewater- or
stormwater-treatment facilities.
Normal cost-sharing or repayment
provisions may  need to be waived.

   The challenges are many. The
rewards and benefits are great. As with
any ambitious endeavor, this
reauthorization will take time and
effort.
   The nation's governors look forward
to working with Congress, EPA, and
others affected by this law to ensure
that our water supplies are the cleanest
and safest possible.D
SUMMER 1994
                                                                                                                35

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Questions  the  Reader  Might  Ask
An Interview with  Robert Perciasepe
EPA's Office of Water administers several
environmental statutes including the Clean
Water Act and the Safe Drinking Water
Act, both of which are currently up for
reauthorization by Congress.  To get
answers to wide-ranging questions that
readers might ask in liglit of the ongoing
reauthorization debates, EPA Journal
interviewed Robert Perciasepe, the Agenci/'s
Assistant Administrator for Water.
     Recent episodes involving the
occurrence or threat of waterborne
disease in Milwaukee, New York City,
and our own Washington, DC, have
triggered public concern about the
safety of tap water. Is there reason to be
worried about the quality of tap water
in these and other cities?

/V  We can't rest on our laurels.  Things
are changing, and we have to keep ahead
of the changes. The population of the
country has doubled in the past 25 to 30
years, and that puts stresses on the
sources of our drinking water as well as
on the treatment plants, most of which
have been in place for many years. The
approach that Administrator Browner
and I recommend is one of pollution
prevention. We look at source-water
protection as a first line of defense rather
than relying solely on treatment. I think
that's where the United States has an
advantage over many other places in the
world, in that we have a strong Clean
Water Act as well as a safe Drinking
Water Act.  Working together, they can
produce the long-term security we need
for drinking water.
   As far as these episodes are
concerned, it's been my experience that
treatment processes, like everything
else humans design and operate, will
occasionally fail. Whether the system
is something as high tech as a computer
or as low tech as a sand filter, mistakes
can be made. Exactly what happened
in the episodes you mention  is a matter
for further analysis. Again, I think the
episodes underscore the  need for
protecting water sources as the first line
of defense. We've made proposals for
reforming the Safe Drinking  Water Act
that would strengthen source
protection as well as provide  for
                                                                          operator training and for the
                                                                          installation of new technologies. We've
                                                                          also proposed setting up a state
                                                                          revolving fund to help finance
                                                                          improvements to older systems.
    What about tap water safety in
small communities: Do they have
special problems?

/v As for the special problems of
small communities, we have to keep in
mind that the vast majority of people,
89 percent, are served by larger
systems-those serving more than 3,300
people. Only 1 1 percent are on
systems that  serve fewer than 3,300
people. But on the flipside, there are
50,000 of these small systems
(compared to 1 0,000 of the big ones),
so the job of making sure the same
quality of water is provided to that 1 1
percent is much different. There are
more systems to evaluate, more
systems to monitor, more systems that
need trained  operators, and so on.
   To help small systems, we've
proposed  that the states set up small
system viability programs that would
look at existing systems to see which
ones are going to work over the long
term.  If they're not, let's try to figure
out another solution, like setting up a
new management structure, drilling
another well, or connecting some small
systems with somebody else's system.
If they're in a rural area and they're
nonviable because of operation and
maintenance, maybe we can have a
circuit rider, who is also a trained
operator, visit each system periodically.
We're also proposing to establish a
"small systems best available
technology" that will allow these
systems to adopt a less costly package
plant approach.
   Small communities do have some
unique problems that must be
addressed in the Safe Drinking Water
Act reauthorization, and we've made
some proposals to address them. The
idea is to continue to improve the law,
to keep it flexible, so that we can
maintain the integrity we have.
30
                                                                                                 EPA JOURNAL

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                                                      p

                                       Most Americans
                          have grown up taking the safety of
                                drinking Kilter for granted.
                                     Stft'r ndtuity fhoto. l:J'A
    In discussions about the Safe
Drinking Water Act, the theme of
"unfunded mandates" inevitably
comes up in the context of state and
local responsibilities. What is an
unfunded mandate exactly?
    To some extent, unfunded
mandates are in the eye of the
beholder. But they would generally be
described as federal requirements for a
state or local government to carry out a
national imperative for which no funds
are provided. Now that's pretty
straightforward.  But some people use
this characterization unfairly.  For
instance, you might hear somebody say
that their entire sewer and water
budget was an unfunded federal
mandate. The fact is 80 to 90 percent
of the cost of running a utility system
is basic operation and maintenance
costs that every municipality has to
face regardless of federal requirements.
If you're a business, you're not going to
locate in a city that has no water or
sewer systems,  right?  These are basic
necessities that have to be provided.
The real debate is over the incremental
cost that one can attribute to federal
requirements for the good of the
country as a whole. If we say we want
everybody to have safe drinking water
and water pollution control that they
can count on, then we're talking about
national standards that everybody has
to meet.  So the difference between
what governments are willing to do for
their local basic infrastructure versus
what national standards are imposed
over and above that basic
infrastructure, I think can legitimately
be called a national mandate.
   Now,  1 have to say there are many
who feel meeting national standards for
the good of the country should not be
construed as an unfunded mandate.
They argue it is the government's
responsibility to  provide water that is
safe to drink, and that we need
minimum federal requirements. One
community's drinking water standards
might not be acceptable to another. So
some argue these minimum
requirements are not unfunded
mandates at all, but rather necessities
of modern society.  When you consider
that we provide substantial funding for
water and sewer infrastructure through
a variety of federal sources, a strong
argument can be made that the
national mandates on top of basic
needs are well funded.
Q
  ^ During your tenure as a
Maryland state official, did you
experience problems with unfunded
mandates?

/V There were instances when the
general assembly passed laws that were
for the good of the state, but county
governments said, "Wait a minute,
that's an unfunded mandate." For
instance, equal education. The state
provides a lot of money for education,
but it's not enough. And some local
governments provide more money than
others, which means different
opportunity levels were offered to
different populations in the state. But
just about  everyone from the Supreme
Court on down agrees that we should
all have equal access and opportunity
in public education.  So are we talking
about an unfunded mandate or a
necessity of our society?
   In my view, some national
mandates are inevitable, and the
federal government should provide
what resources it can.  Resource
number one is money,  and for both
wastcwater and drinking water we're
proposing that our country's
communities receive more money
through the State Revolving Funds.
We're also proposing that the law
authorize the states to collect fees to
run the programs. The second resource
is time. And in both the Clean Water
Act and the Safe Drinking Water Act
we're proposing more time for
compliance. The third type of resource
is more flexibility for states and local
governments in terms of how they
achieve federal standards. These are
the major elements we've built into our
proposals to help bridge the gap
between what would normally be
provided under a basic infrastructure
program and what might be perceived
as an increase due to national
standards.
                                          Under the Safe Drinking Water
                                      Act, EPA delegates "primacy"
                                      (responsibility for implementing
                                      drinking water programs) to the
                                      individual states, but primacy may
                                      revert to EPA under certain
                                      circumstances. Reportedly, some
                                      states— e.g., Maine, Washington,
                                      and Alaska—have come close to
 SUMMER 1994
                                                                                                                37

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                                                                                                         Wetland protection
                                                                                                                needs to be
                                                                                                              considered at
                                                                                                             the beginning,
                                                                                                               nut the end,
                                                                                                              oj watershed
                                                                                                                planning.
                                                                                                         .SVrrr Di-lancy plwto.  /:7M.
losing primacy.  Can you tell us why
the system is set up in this way, and
what happens if primacy really does
revert to EPA?

/\ EPA wants the states to maintain
primacy. We don't want it to revert to
us. We believe drinking water
programs are better run at the state
level, where they can be more sensitive
to the needs of the community. EPA is
too far removed from day-to-day
activity.  Congress set the system up
for primacy to revert to us  as a  failsafe
measure. In other words, if all  else
fails, and no one is watching the
quality of drinking water in a particular
state, then at least there's a federal
backstop. But we don't have the
capabilities the states have in terms of
technical assistance and working with
communities.  So it behooves us to
make sure the states maintain primacy,
and that's behind some of the
recommendations we've made for
reauthorizing the Safe Drinking Water
Act. Again, we're talking about  offering
some of the resources I mentioned
earlier.

V£ The President's Clean Water
Initiative would encourage states to
take a watershed approach to
managing their remaining water
pollution problems. What is a
watershed, and how does the
approach differ from the more
traditional source-by-source
regulation we are familiar with?

/v Another name for watershed is
drainage basin. It's an area where all
the runoff, and water from the  ground
water systems, the creeks, and streams
eventually ends up in the same water
body.  So we could define the country
in terms of watersheds separated by  the
continental divide. On one side of the
divide, the water flows to the Pacific
Ocean. On the other, it flows into the
Mississippi.  Those are watersheds on a
macro scale.
Combined sewer overflows
     are a major source
      of polluted runoff.
         Mike /Jmstvi photo
    On a small scale, you have Rock
 Creek and the Anacostia River
 watersheds here in Washington.  They,
 too, have their own divides from which
 water flows into them on one side and
 away from them on the other.  And
 there are watersheds within watersheds.
 Inside the Anacostia you could break
 the watershed down into smaller and
 smaller drainage units. We believe
 watersheds arc an important unit for
 managing water quality because the
 sources of pollution within a watershed
 inevitably affect water quality.
    Every watershed in the country is
 different. Some are more urbanized;
 some are more rural. Some are growing;
 some are not. Some have industry;
 some don't.  Some have pollution
 problems; some don't.  Instead of a
 one-size-fits-all solution, watershed
 management provides a flexible tool for
 states to identify important watersheds
 and take a comprehensive look at
 what's going on. Instead of just
 implementing each EPA program
 separately, they can tailor the programs
 to work together in each watershed to
 solve its particular set of problems. It's
 also important to involve the
 stakeholders in each watershed.  Who
lives there?  What are their goals? Is it
fishing? Is it recreation? How do the
stakeholders sec the problem? That
way, you have their understanding of
what's going on and their buy-in when
the time comes for developing and
implementing the solution.
   We even see this as the proper
framework for pollutant trading. You
can't trade between watersheds, but
you can within a watershed.  Look at
the possibilities. You can have trades
between point sources and nonpoint
sources, nonpoint to nonpoint source
and so on-all to reach an overall goal
of reduction that would be defined for
the watershed.  (See story on pollutant
trading on page 27.)
   Now, implicit in what I'm saying is
that we  will still maintain a basic
federal program. We will still need to
ensure that certain technology levels
are maintained and, for nonpoint
sources, we still have to initiate basic
management practices. But you'll find
when you focus on impaired
watersheds that oftentimes these
solutions are not enough.  So how do
you get  further reductions  in pollutant
levels? The question is critical because
the cost  goes up the more you get
 38
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above basic technology levels. That's
where flexibility comes in, making it
possible for us to get the most for our
buck.
   I might add that watershed
management planning goes beyond
pollution control, allowing you to take
into account other factors that  might
otherwise go unaddressed.  For
instance, what if the reason that you
don't have a sustainable population of
fish is because you have dams that
prevent them from spawning?  You can
treat the water until it's pristine, but if
your goal is a sustainable population of
certain species of fish, wouldn't it make
more sense to  somehow bypass the
dam or remove it?  Watershed
management planning gives you the
opportunity to look at all the
possibilities for achieving your goals.
Q
     New York City's drinking water
supply system is a particularly
interesting case. As we understand
it, EPA is allowing the city to defer
committing to a multi-billion dollar
filtration plant  in favor of investing
in a watershed protection approach
to protect its  source waters.  Is this
a unique case?  Or will New York
City's approach work for other
cities?

*V.The short answer is we're going to
have to wait and see. EPA has issued
what we call the surface-water
treatment rule. Surface water can be
exposed to contamination, so if surface
vvater--a reservoir or river-is your
drinking water source,  then you must
meet 10 objective criteria that we've
laid down-or else you  must put in
filtration.  These criteria are
quantitative.  You either meet them or
you don't. Now, if your incoming raw
water docs meet these  10 tests, and
you have a watershed program that will
keep it that way, you can avoid
filtration. The situation is
complicated, because since we
established the rule some states have
passed more stringent laws saying that
every surface water source has to have
filtration, regardless of other
considerations.
    New York City currently meets the
10 criteria. But whether their
watershed management  program is
going to keep it that way remains to be
seen.  (See story on page 24.) EPA has
been willing to defer for three years the
decision over the city's having to build
filters. We've asked for a number of
improvements to their program, and
we've asked them  to monitor water
quality in a very stringent way.  We've
also asked them to begin the design of
the filter systems so no time is lost in
case their watershed management
program fails to assure the long-term
security of the water supply. In other
words, we could rescind  our deferral
and the filter design would be ready.
    Of course, we're talking about only
part of the city's water supply, the part
that comes out of the Catskill
Mountains. The other part comes out
of the Croton River Valley, which goes
up through suburban Westchcster,
Putnam, and maybe part of Duchess
County.  That part of their water
supply is going to  require filters.
    Can other cities avail themselves of
the watershed approach? Some already
do. Portland, Oregon, for instance, has
a watershed that supplies water that
doesn't require filtration. And there are
others in the country. Many factors
need to be considered, and simply
being in a national or state park setting
does not guarantee avoidance. For
example, in the same state of New
York there's a small town whose water
                                                                               comes from the side of one of the
                                                                               mountains in the Adirondacks. It's a
                                                                               small watershed and a small town. In
                                                                               that watershed, there is a visitors'
                                                                               center at the top of one of the
                                                                               mountains, and it uses a septic system
                                                                               to treat its wastewater. As a result, the
                                                                               town has a hard time meeting our 10
                                                                               criteria, even though it is in a much
                                                                               more isolated location than New York
                                                                               City and its watershed. So while it
                                                                               may seem that  we're giving an
                                                                               opportunity to  New York that we're
                                                                               not giving to others, you have to look
                                                                               at each case individually.
                                                                               Q
     Ground water supplies half of
the country's drinking water, yet
protecting ground water is not a
major focus of the existing Clean
Water Act. Would that change
under President Clinton's initiative?
How does the initiative tie into the
Safe Drinking Water Act?

-TV We would like to see the ('lean
Water Act and the Safe Drinking
Water Act work better together, and
ground water is probably the best place
tor this to happen.  We're proposing a
watershed management program in the
Clean Water Act and a stronger source-
protection program under the Safe
Drinking Water Act. But we don't want
states to duplicate their efforts. So if
they decide to take on watershed
management under the  Clean Water
Act, and they include ground water
under their goals for source protection,
then we feel that should double as
meeting the requirements of the Safe
Drinking Water Act.
                                                                              Q
    Currently, the federal
government shares in the costs of
building sewage treatment plants
around the country, but funding of
SUMMER 1994
                                                                                                                39

-------
the federal share is scheduled to
expire this year.  What happens to
this program under the President's
initiative? What about smaller
communities that will have a hard
time coming up with their share of
construction costs?

J\ We propose that the authorization
for the State Revolving Fund be
extended to 2004. That would add
another $12 to $13 billion over the
next 10 years to the fund to help
ensure its long-term viability. Together
with the $9 to $ 1 0 billion that's
already there and the repayments that
will be coming in, the fund can
continue revolving for the next 20 to
30 years at a rate of over $2 billion
dollars a year, adjusted for inflation.
   For small communities, we're also
proposing that states be allowed to use
a portion of the fund to provide up to a
negative 2 percent  interest rate on
loans so that they can  further subsidize
these communities or stretch out their
payment schedules. Again, one of the
resources we can provide is time.
Money is not the only means of
assistance.
     Aside from sewage treatment
plants, we understand that funding
for other programs, like the permit
program for regulating pollution
discharges from industries and
municipalities, will be reduced.
How would the new initiative cover
the costs of operating these other
programs?

J\ First of all, funding for existing
programs would remain essentially
constant.  Second, for both the Safe
Drinking Water Act and the Clean
Water Act we are proposing a fee
program, similar to what's in the Clean
Air Act, whereby the states could
charge for the permits they issue to
help recover the costs of managing
these programs. We estimate that the
fee programs could raise an additional
$300 million per year to help alleviate
the financial shortfall they now face.

40
Third, if the states choose watershed
management, we will give them the
flexibility to combine federal resources
together rather than having to manage
multiple grants.  So, cumulatively these
proposals would increase the amount of
revenues available for states, and it
would provide more flexibility in using
existing funds.
    . There have been statements in
the press that the President's
initiative would save the states
about $30 billion a year.  Other
statements indicate that it would
cost industry and government
anywhere from $6 billion to $10
billion a year more than they are
paying under the existing Clean
Water Act. How do you reconcile
the two?

J\ Under the current law, the country
is spending about $64 billion a year on
water-pollution control. If we didn't
change the law to make it more focused
and efficient, that would grow to $97
billion a year.  The proposals we're
making would result in its growing to
about $70 billion a year. So that's $6
billion more than we're currently
spending,  but $27 billion less than what
we  would  spend if we didn't put these
reforms in place. (See article on page
30.) Most of the growth in spending
under our proposals goes toward
polluted runoff, which is our biggest
remaining water-quality problem and
one that has not been adequately
addressed, to date.
   _ The press has reported a
controversy over provisions in the
initiative that could lead to an
eventual ban on the use of chlorine
or chlorine compounds both in
water-treatment facilities and in the
chemical  manufacturing industry.
What's that all about?

ji\ Protecting the public and our
environment from toxics is a very high
priority for EPA, and thus, in our
recommendations for improving the
Clean Water Act, we're seeking newer
authority to limit or prohibit discharges
of the most highly toxic,
bioaccumulative pollutants. We are
particularly concerned about some
chlorinated compounds because of
increasing scientific questions that have
been raised about potential threats to
public health and the environment.
So, in its recommendations, the
administration calls for a study of the
impacts and benefits of chlorine and
chlorinated compounds. This study
will involve all interested parties
including scientists, industry
representatives, environmentalists, and
government regulators, among others.
Based on the results, we would  then
develop a national strategy.
   The  initiative does not propose a
ban or restrict the use of these
chemicals, nor does it indicate whether
regulatory action would take place
upon completion of the study and
strategy development. Unfortunately,
that is the way it has been
characterized by some in the media,
and we've had a lot of concern and
reaction to this mischaracterization.
Our goal is to develop sensible,
scientifically based recommendations
that will best protect public health and
the environment, and we'll have to wait
and see what the study determines
before we decide what those actions
will be.
   ^ Under the existing Clean Water
Act, control of "nonpoint sources"--
i.e., sources of polluted runoff-is
left to the states, and the states, for
the most part, have relied on
voluntary programs. How would
this approach change under the
President's initiative?

/V Under the President's initiative, we
propose major improvements for
controlling three kinds of polluted
runoff. The first is combined sewer
overflows.  Today in Washington, for
example, it's raining.  Somewhere  a
sewer carrying wastewater from our
homes and industries will overflow

                         EPA JOURNAL

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                       Cincinnati invested $60 million in
                       n granular activated carbon water
                       treatment facility—one of the more
                          advanced contaminant removal
                       technologies used by U.S. drinking
                                      tvater systems.
                                     Malcolm Pintle photo
because runoff from the streets is filling
it up and overloading its capacity. As a
result, these sewers will overflow,
discharging untreated waste into our
rivers and streams. The second  is
stormwater. Some of this runoff is
going to be carried by stormwater
drains into the Potomac River.  The
third category is the more generic
runoff pollution, which is runoff from
farms, construction sites, and so on.
   Now, in the past, we've attacked
this problem inconsistently.  Some
states have strong programs, some none
at all. We've never sat down as  a
nation and asked ourselves, watershed
by watershed, what needs to be  done in
this particular watershed to solve the
nonpoint-source pollution problems?
We're proposing that states take two
and a half years to identify their
impaired waters or to carry out
watershed management planning.
Either way, in the process they would
identify what needs to be done,  and
that would put people on notice to
what they're responsible for. That's the
first step, if you want to hold people
accountable.
   Number two is time. After the
problem has been assessed and the
solutions determined, we would then
provide five years for necessary
practices to be implemented. If more
time is needed, another five years
would be given. That's  12 and a half
years for deciding what must be done
and actually doing it.  At the end of
that time, we are proposing a state
compliance assurance program of some
kind,  some enforcement of the
management measures that haven't
been carried out.  We have no
enforcement now, so this would put a
little more strength in the nonpoint-
source program.
    Wetlands have been described
as the world's most efficient water-
quality system.  Although the rate
of wetlands loss has been reduced,
some 290,000 acres still disappear
each year.  Will wetlands be better
protected under the President's
initiative?

/V Yes.  In the President's Clean
Water Initiative, we are proposing a
number of improvements to the law
that will allow us to do a better job
than what's been done in the past to
preserve wetlands.  Obviously,
everyone would like to see us achieve
the goal of no net loss. This
administration has a goal of no net loss
and a long-term goal of increasing
wetland resources.  But there are
problems with how we go about it.  We
would like to see the states get more
involved with the decisions on
wetlands.  Proper federal oversight is
essential, of course, but we need to
push the decision making down as far as
we can because it's at the lower levels of
government where initial land-use
judgements are made. We certainly
don't want to get into local land-use
control at the federal level. So the more
wetlands are taken into account in
land-use decisions that states are
making, I think the better chance we
have to avoid problems.
   We're also proposing to look at
wetlands on a watershed basis. If you
draft a watershed plan, and right up
front you set no net loss of wetlands as
one of your goals, then you're going to
be in a lot better position to  achieve
that  goal than if you don't consider
wetlands early on.  Oftentimes, the
way things work now, alter all the
decisions are made somebody says, wait
a minute, you're affecting wetlands.
This puts everybody at a disadvantage.
As long as you have wetlands being
considered at the end of the  process, as
opposed to up-front, you're going to
have difficulty achieving the  goal of no
net loss.D
SUMMER 1994
                                                                                                                  41

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FOR THE CLASSROOM l
      EXPLORING
       WATER
         by Stephen Tchudi
    This topic is a natural for study at nil levels
    oj elementary and secondary school.  We
    will focus on projects that help students
    make connections among national issues, the
    school disciplines, and their own
    communities.  To prepare for the unit,
    collect some vr all of the resources mentioned
    in the bibliography, and search your school
    or load library for materials on water

    ""
Mathematics

• Students can collect and compute a
dazzling array of statistics on water:  its
omnipresence, its use by people,
animals, plants, and  industry. See, in
particular, "Water Trivia Facts"
(available from National Drinking
Water Week, listed below under
"Resources") for statistics that range
from how much of an elephant is water
(7 percent) to the amount of the
world's water that is actually suitable,
with treatment, for drinking (1
percent).

• Review the federal "maximum
contaminant levels" (MCLs) called for
in the Safe Drinking  Water Act.
Prepare graphs and charts  showing the
permissible levels of contaminants.
Write out the MCLs  as fractions (e.g.,
1/1,000,000) to help students
understand that it takes only
infinitesimal amounts of chemicals or
microorganisms to pollute the water
supply.

• Every local water supplier must test
its water to ensure compliance with
federal standards.  Call your supplier;
obtain your community's statistics; and
graph the relationship of your drinking
water quality to federal standards.

• Measure an asphalt parking lot (the
school parking lot will probably do).
Calculate its area.  If 1/2 inch of rain
falls, how many cubic feet  of water
consequently run off the asphalt.
Where does thai water eventually go?
Sciences

• Studv how the water cycle works in
general, and in your geographical area,
in particular.  What is your average
rainfall? Where docs the water that
evaporates from your region come
down as precipitation?

• Learn about the watershed in which
your community is located. How many
square miles does it cover?  What are
its principal streams or lakes?  How is
water stored in vour area (e.g., in
reservoirs)? Create a map or model of
your watershed. Is it part of a larger
watershed?

• Create muddy, murky, or polluted
water with a variety of ingredients:
sand, scraps of paper, vegetable oil,
gravel, salt, food coloring.  Design a
series of experiments  with filters-sand,
party hose, cotton, coffee filters—to see
how difficult it is to separate water
from its pollutants.

• Investigate the differences between
"point" and "nonpoint" sources of water
pollution.  dive some examples of each
from the sources in vour area.  Why do
you think nonpoint-source pollution,
also known as polluted runoff, is more
difficult to control?

• Make a set of flash cards on science
facts and figures about water and the
water supply. Use these as the starting
point for a "Jeopardv" game on water
facts. (See the "Blue  Thumb Program"
materials available from  National
Drinking Water Week.)

• From the "Earth Day Every Day"
Teacher's Kit available from EPA's
Water Resources Center, select from
numerous classroom  exercises such as
those on the hydrologic cycle,
conservation of water resources,
chemical pollutants in water, etc.
                                                                               Social Studies

                                                                               • Stialy the economics ot your local
                                                                               drinking water. How much do people
                                                                               pay per gallon for their water?  How
                                                                               much does it cost to treat water?
                                                                               What  plans for expansion or
                                                                               innovation does vour local water
                                                                               supplier have in mind? 1 low much will
                                                                               that cost?
                                                                                                    EPA JOURNAL

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• Visit the wastewater treatment plant
for your community. (Or invite a
speaker to class.)  How is wastewater
treated?  Where does the wastewater
come from? What does  it cost to clean
up your water after it is used?

• How much of your watershed area
(see mapping activity above) is under
cultivation from agriculture? Mark this
on your map. From your county
agricultural agent, learn about the
problem of nonpoint-source pollution
due to agricultural use of chemicals.
How large is the problem in your area?
Humanities and Arts

• The National Geographic Society
suggests having students make a list of
all the words they can think of that
have to do with water-mist, dew, rain,
etc.-and water-based expressions-
"drop in the bucket," "deep six," etc.
What does the role of "water" in our
language say about its role in our lives?

• Collect and analyze advertisements
for water purification systems and
bottled water. What tactics do
advertisers use to persuade people to
buy and  use water other than that
flowing from the tap?

•Encourage students to write science
fiction or science fact scenarios about
the future of water:  e.g., the southwest
runs out of water; global warming
raises the world's sea levels; a villain
figures out a way to contaminate the
nation's drinking water supply; the
Earth becomes a desert, and water is
more precious than gold.

• Have students prepare a
photographic display or videotape on
the water-supply and wastewater
systems of your community.
Community Projects

• Adopt a stream or pond in your area,
taking responsibility for eliminating
visible trash and pollutants and even
conducting scientific measurements of
water quality. (See the Izaac Walton
League's "Save Our Streams Adoption
Kit" listed below under "Resources.")
 • Sponsor a "Drinking Water
 Awareness Week" for the school or
 community to emphasize what people
 can do to protect their local water
 supply, conserve water, and dispose of
 chemicals properly. (See also the "Blue
 Thumb Program" materials available
 from National Drinking Water Week.)

 • Sponsor a community forum where
 representatives of state, regional, or
 local water bureaus discuss programs
presently in place and planned for the
future to insure a safe and clean water
supply.  Use your own students as
panelists, moderators, questioners, and
reporters.
Resources

American Water Works Association
(sponsor of National Drinking Water
Week). 6666 W. Quincy Avenue,
Denver, CO 80235.  Customer Service
Dept (publications):  1 800 926-7337.

CONCERN, Inc., 1794 Columbia Rd.,
NW., Washington, DC 20009.
Drinking Water: A Community Action
Guide may be purchased for $4.00 plus
$1.50 postage. Bulk rates for nonprofit
organizations. Free information: 202
328-8160.

EPA Water Resource Center (mail
code: RC-4100), Room G099, 401 M
St., SW., Washington, DC 20460; you
may call the Water Resource Center at
202/260-7786 to order publications by
voice mail or EPA's Safe Drinking
Water Hotline at 1 800 426-4791 for
answers to questions  about drinking
water. The following items available
from the Water Resource Center are
especially useful:

• Bottled Water:  Helpful Facts &.
Information
• Developing Criteria to Protect Our
Nation's Waters
• "Earth Day Every Day" Teacher's Kit
(March 1993)
• Ground Water Protection: A Citizen's
Action Checklist
• Home Water Testing
• Home Water Treatment Units:
Filtering Fact from Fiction
• Is Your Drinking Water Safe?
• Lead in School Drinking Water
• Public Water Systems: Providing Our
Nation's Drinking Water
• Safe Drinking Water Act (as last
amended in 1986)
• 21 Water Conservation Measures for
Everybody
• Volatile Organic Chemicals: Are VOCs
in jour Drinking Water?

International Bottled Water
Association. 113  N. Henry Street,
Alexandria, VA 22314. Free
information: 1 800WATER11.

Izaac Walton League of America.
1401 Wilson Boulevard, Arlington,
VA  22209. "Save Our Streams
Adoption Kit" ($1.00, teachers' guide:
$8.00). Free information:  1 800
BUG-IWLA.

League of Women Voters.  1730 M St.,
NW., Washington, DC 20036. Safety
on Tap:  A Citizen's Drinking Water
Handbook  ($7.95  plus postage).  Free
catalog of publications: 202 429-1965.

National Geographic Society
Educational Services (films, videos, film
strips, books, maps, atlases, computer
courseware). Free catalog.  P.O.Box
98019, Washington, DC 20090.
Phone orders:  1 800 368-2728.

National Sanitation Foundation. 3475
Plymouth Road, P.O. Box 1468, Ann
Arbor, MI 48106. Call 313 769-8010
to inquire about free information and
other publications.

Water Quality Association.  Consumer
Affairs Department, Box 606, Lisle IL
60532.  Write for free information. D
 (Tchudi is a Professor of English at the
 University of Nevada, Reno, and co-director
 of an interdisciplinary summer institute for
 teachers that explores the lifeblood of
 northern Nevada: the Truckee River.)
SUMMER 1994
                                                                         43

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CHRONICLED
 London's
 Historic
 "Pea-Soupers
 by David Urbinato
       Americans may think smog was
       invented in Los Angeles. Not so.
       In fact, a Londoner coined the
term "smog" in  1905 to describe the
city's insidious combination of natural
fog and coal smoke. By then, the
phenomenon was part of London
history, and dirty, acrid smoke-filled
"pea-soupers" were as familiar to
Londoners as Big Ben  and Westminster
Abby.  The smog even invaded the
world of Shakespeare,  whose witches in
MacBeth chant, "Fair is foul, and foul is
fair: Hover through  the fog and filthy
air."
   Smog in London predates
Shakespeare by four centuries. Until
the 12th century, most Londoners
burned wood for fuel.  But as the city
grew and the forests shrank, wood
became scarce and increasingly
expensive.  Large deposits of "sea-coal"
off the northeast coast provided a
cheap alternative. Soon, Londoners
were burning the soft,  bituminous coal
to heat their homes  and fuel their
factories. Sea-coal was plentiful, but it
didn't burn efficiently. A lot of its
energy was spent making smoke, not
heat.  Coal smoke drifting through
thousands of London chimneys
combined with clean natural fog to
make smog. If the weather conditions
were right, it would  last for days.
   Early on, no one had the scientific
tools to correlate smog with adverse
health effects, but complaints about
the smoky air as an  annoyance date
back to at least 1272, when King
Edward I, on the urging of important
noblemen and clerics, banned the
burning of sea-coal.  Anyone caught
burning or selling the stuff was to be
tortured or executed. The first
offender caught was summarily put to
death. This deterred nobody. Of
necessity, citizens continued to burn
sea-coal in  violation of the law, which
required the burning of wood few could
afford.
   Following Edward,  Richard III
(1377-1399) and Henry V (1413-
1422) also tried to curb the  use of sea-
coal, as did a number of non-royal
crusaders.  In 1661, John Evelyn, a
noted diarist of the day, wrote his anti-
coal treatise FUMIFUGIUM: or the
Inconvenience of the Acr and Smonkc of
London Dissipated, in which he pleaded
with the King and Parliament to do
44
                   British Toitust Authority pfioto.
something about the burning of coal in
London.  "And what is all this, but that
Hellish and dismall Cloud of SEA-
COALE?" he wrote, "so universally
mixed with the otherwise wholesome
and excellent Acr, that her Inhabitants
breathe nothing but an impure and
thick Mist accompanied with a
fuliginous and filthy vapour. . . ."
   Laws and treatises failed to stop
citizens from burning coal, however.
Too many people burned it and there
were no real alternatives.  Anthracite
coal was much cleaner but too
expensive. By the  1 800s, more than a
million London residents were burning
soft-coal, and winter "fogs" became
more than a nuisance. An 1873 coal-
smoke saturated fog, thicker and more
persistent than natural fog, hovered
over the city for days.  As we now know
from subsequent epidcmiological
findings, the fog caused 268 deaths
from bronchitis.  Another fog in 1879
lasted from November to March, four
long months of sunshineless gloom.
   When it wasn't fatal, the log could
at least disrupt daily life.  A 1902, bi-
weekly report from a fog monitor gives
an indication. He wrote: "White and
damp in the early morning, it became
smoky later, the particles coated with
soot being dry and pungent to inhale.
There was a complete block of street
traffic at some crossings. Omnibuses
were abandoned, and several goods
trains were taken off."
   These conditions were not rare.  "It
was soon  found that light fogs largely
attributable to smoke were permanent,"
the same  monitor wrote of the winter
of 1 901-02.  "From the summit of St.
Paul's Cathedral of Westminster Tower
for instance, the average limit of
visibility was only one-half mile."
   At the turn of the century, cries to
reduce the smoke  faced a tough
opponent. Coal was fueling the
industrial revolution. To be against
coal burning was to be against progress.
"Progress" won out.
   Not until the 1950s, when a four-
day fog in 1 952 killed  roughly 4,000
Londoners was any real reform passed.
Parliament enacted the Clean Air Act
in 1 956, effectively reducing the
burning of coal. It was the beginning
of serious air-pollution reform in
England. D


                        EPA JOURNAL

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ON  THE MOVEt
                            John F. Kennedy School
                            of Government, Harvard
                            University.
John P. DcVillars is the
new Regional
Administrator for EPA's
Rceion !, headquartered
in Boston.  There he will
direct federal
environmental programs
in Connecticut, Maine,
Massachusetts, New
1 lampshire, Rhode
Island, and Vermont.
Me brines to the post
knowledge  of
environmental
regulation and of the
link between a healthy
environment and a
strong economy.
  From  1988 to 1991,
Devillars was
Massachusetts Secretary
of Environmental Affairs
and head of the Board of
the Massachusetts
Water Resources
Authority, where he
oversaw the cleanup of
Boston Harbor ana
delivery of water and
sewer services to Eastern
Massachusetts--the
largest public works
project in New England's
history.
  More  recent!)',
DcVillars directed the
environmental services
group for Coopers &
Lybrand in Boston
(1992 until his EPA
appointment) where he
assisted corporations in
achieving cost-effective
environmental practices
and analyzed regulatory
impacts on businesses.
  Among many
environmental awards,
he received the
President's  Award of the
Nature Conservancy for
national leadership on
the environment. I le
holds a bachelor's degree
from the University of
Pennsylvania and a
master's degree from the
Jeanne M. Fox is the
new Regional
Administrator of LPA's
Region 2, which includes
New Jersey, New York,
Puerto Rico, and the U.S
Virgin Islands.  She
brings to the post a
broad  understanding of
environmental issues
from her varied positions
with New Jersey agencies
over the past 13 years.
  Fox is an attorney with
extensive experience in
environmental problems.
She served with the New
Jersey  Department of
Environmental
Protection and Energy
(1991  to 1994) as
Deputy Commissioner
and Acting
Commissioner.  She was
the New Jersey
Commissioner on the
Delaware River Basin
Commission.
  Fox also was the state's
representative on the
policy  committees of two
EPA estuary programs,
Delaware River and New
York Harbor, and was on
the state's Superfund
Policy  Forum.
  She attended 1 larvard
University's John F.
Kennedy School of
Government, the
Program for Senior
Executives in State and
Local Governments in
1 990.  She received a
bachelor's degree in
political science from
Rutgers' Douglass
College (1975) and a law
degree from  Rutgers
University School of
Law (1979).
                           As Administrator of
                           EPA's Region 3, Peter
                           H. Kostmaycr will head
                           the Agency's
                           environmental programs
                           in the middle Atlantic
                           states covering
                           Maryland, Delaware,
           nK
           Jelawa
Virginia, West Virginia,
Pennsylvania, and the
District of Columbia.
  Prior to his
appointment, Kostmaver
served as a member of
Congress from
Pennsylvania's 8th
Congressional District.
A leading
environmentalist in the
1 louse of
Representatives for 14
years, he led the fight on
many environmental
fronts, authorizing a
score of hills ranging
from protection for the
nation's rivers, additions
to the country's
wilderness areas and
national parks, to
tougher safety standards
for nuclear reactors.
  Kostmaycr was a
journalist and press
secretary before running
for office at age 30.  1 le
is an alumnus of
Columbia University
(1971).
                                                                                  Flankinson received
                                                                                his bachelor's degree in
                                                                                psychology from Florida
                                                                                Presbyterian College in
                                                                                 1 970 and a law decree
                                                                                from the University of
                                                                                Florida in 1979.
 John H. Hankinson,
 Jr., is the new Regional
 Administrator for EPA's
 Region 4 office,
 headquartered in
 Atlanta.  He will direct
 federal environmental
 programs in Alabama,
 Florida. Georgia,
 Kentucky, Mississippi,
 North Carolina, South
 Carolina, and Tennessee.
  Flis wide experience
 covers many
 environmental areas.
 From 1988 to 1994,
 Hankinson directed the
 Planning and
 Acquisition Department
 of St. Johns River Water
 Management District,
 Palatka, Florida.  From
 I 986 to 1 988, he was
 the district's Director of
 the Office of Land
 Acquisition. While at
 the district, he directed
 the acquisition of almost
 200,000 acres of
 environmentally
 sensitive land for the
 state's Save Our Rivers
 program. Other
 positions include that  of
 Director of Coastal and
 Land Use Programs for
 the Legal Environmental
 Assistance Foundation,
 Tallahassee, Florida;
 Senior Policy Analyst in
 Florida Governor Bob
 Graham's Office of
 Planning and Budgeting;
 and Staff Director for
 the Florida House of
 Representatives
 Committee on
 Regulatory Reform,  lie
 also established and
 directed the Florida
 Defenders of the
 Environment's
Environmental Service
Center, which facilitated
participation of
academic scientists in
state environmental
 policy making.
Valdas Adamkus will
continue as Regional
Administrator Tor Region
5, a position he has held
since 1 981.  Region 5
includes Illinois,
Indiana, Michigan,
Minnesota, Ohio, and
Wisconsin.
  As Administrator of
EPA's midwcstern
region, Adamkus has
also been the U.S.
Chairman of the Great
Lakes Water Quality
Board since 1981, an
advisory body of the
U.S.-Canadian
International Joint
Commission.  He has
managed EPA's  Grout
Lakes National  Program
since 1986. Since 1970,
he has  been one of the
U.S. Commissioners on
the Ohio River Valley
Water  Sanitation
Commission.  From
1 983 to the present, he
has been  the chairman of
the joint U.S. and
Russian Federation
Workgroups on walcr-
pollution science and
technology issues.
  From 1071  to 1981,
he served as Deputy
Regional Administrator
for Region 5.  He is also
a career member of the
federal government's
Senior  Executive Service.
  Adamkus has  been
frequently called upon
to represent the EPA on
environmental affairs in
SUMMER 1994
                                                                                                                                     45

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(he former Soviet Union,
the Baltic countries, and
other eastern bloc
countries. In 1974, he
was the first EPA
representative to he
invited for a lecture tour
in the Soviet  Union, and
the following year he
was invited to serve as
advisor to the U.N.
World Health
Organization.
  In 1985, Adamkus
received the
Distinguished Executive
Presidential Award, and
he holds EPA's highest
a\vard--the Gold Medal
for Exceptional  Service.
  Me received a
bachelor's degree in civil
engineering from Illinois
Institute of Technology
(1960), an honorary
doctorate from the
University of Vilnuis
(1989), and an  honorary
doctor of laws degree
from Calumet College of
St. Joseph (1991).
Jane N. Saginaw is the
new Regional
Administrator for Region
6 in Dallas, Texas. In
this position, she will
direct the federal
environmental programs
affecting Arkansas,
Louisiana, New Mexico,
Oklahoma, and Texas.
  She comes to EPA
from the law firm of
Baron & Budd in  Dallas,
Texas, where she was a
partner  for 1 2 years.
There she specialized in
litigation and appellate
practice in the field of
chemical and
environmental injury.
  From  1980 to 19^1,
Saginaw was a trial
attorney for the Federal
Energy Regulatory
Commission. She has
served on the Texas
Agricultural Resources
Protection Authority,
City of Dallas
Environmental  Health
Commission, and is a
member of the American
Bar Association,
Association of Trial
I.a\wers of America, and
the Texas Trial  Lawyers
Association.
  Saginaw received her
bachelor's degree in
geography from the
University of California
at Berkeley, where she
graduated summa cum
hiutlf and Phi Beta
Kappa in 1976. She is a
1 980  honors graduate of
the School of Law at  the
University of Texas at
Austin.
As the new Regional
Administrator of Region
7, Dennis D. Grams
will direct federal
environmental programs
in the midwest states of
Iowa, Kansas, Missouri,
and Nebraska. He
brings to the Agency 24
years of professional
experience in the fields
of environmental
engineering and
management.
  Before joining EPA,
Grams was President of
Grams Environmental
Management, and before
that  served as Director
of the Nebraska
Department of
Environmental Control
(1984 to 1991), where
he was responsible for
the development,
implementation, and
administration of all
state environmental
programs.
  Other positions  he
held in the
environmental field
include  Director of the
Environmental Health
Division of the Lincoln-
Lancaster County
Health Department
(1972 to 1984) and Air
Pollution Control
Engineer for the
Nebraska Department of
Health (1970 to  1972).
Grams is a registered
professional engineer
and a registered
environmental health
specialist.
  I le received a
bachelor's degree (! 969)
and a master's degree
(1975) in mechanical
engineering from the
University of Nebraska.
Bill P. Yellowtail is the
new Regional
Administrator for Region
8. There he will direct
the operations of more
than 600 employees who
carry out federal
environmental programs
dealing with air, water,
and land in Montana,
Colorado, North
Dakota, South Dakota,
Utah, and Wyoming.
  Prior to joining EPA,
Yellowtai! was a
Montana state senator.
From  1981 to 1982 he
was Executive Director
for the Montana Inter-
Tribal  Policy Board.
From  1977 to 1980 he-
was Director of Human
Resource Development
and Education for the
Crow Tribal Council in
Montana.  Erom 1974 to
1977, he was Assistant
Supervisor for the Indian
Education Division of
the Montana Office of
Public  Instruction.
  The Montana rancher
currently serves on the
Board of Directors,
Burton 1C Wheeler
Center, Montana
University; Advisory
Council, Native
American  Program; and
the Environmental
Quality Control,
Montana State
Legislature.
  Yellowtail received a
bachelor's  degree in
geography and
environmental studies
from Dartmouth College
in 1971.
46
Felicia Marcus is the
new Regional
Administrator for Region
9 which covers Arizona,
California, Hawaii,
Nevada, American
Samoa, and Guam.
  Marcus comes to EPA
from the Los Angeles
Board of Public Works,
which she joined as a
commissioner  in 1989.
In 1 991, she was named
President of this
commission, which
oversees the operations
of the L.A. Department
of Public Works and  its
seven bureaus.
  From 1988  to 1989,
Marcus was director of
litigation for the Public
Counsel, a public-
interest law firm in Los
Angeles that assists the
undcrreprescnted in
such areas as poverty
law, housing,
immigration, and
children's rights. Erom
1986 to 1988, she was
Litigation  Associate for
the Los Angeles law firm
of Munger, Tollcs, and
Olson.  Previous
positions also include:
visiting fellow. Center
for Law in the Public
Interest (1984 to  1985)
and law clerk, Office  of
the Honorable Harry
Pregerson  (1983 to '
1984).
  In addition  to her
career as a public
interest lawyer, Marcus
has been a community
organizer.  She was co-
founder of 1 leal the Bay,
Inc., an environmental
watchdog organization
in Santa Monica,
California, and has
earned several  awards for
community service.
  She holds a bachelor's
degree in East Asian
Studies from Harvard
College and a law degree
from New York
University School of
Law.
          EPA JOURNAL

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 Charles C. Clarke has
 been named Regional
 Administrator for Region
 10, representing Alaska,
 Idaho, Oregon, and
 Washington.
   I le comes to EPA with
 over  1 7 years of public
 service.  Since 1992, he
 was  the Secretary of the
 Vermont Agency of
 Natural Resources,
 which provides technical
 and  financial assistance
 to local governments and
 community-based
 agencies on a broad
 range of topics.  Starting
 in 1992, he served as the
 State of Washington's
 Director for the
 Department of Ecology,
 and  from 1987 to 1992
 as the Director of the
 state's Department ol
 Community
 Development. Prom
 1982 (o 1987, he was
 Deputy Director  of the
 department. Before that
 he spent six years (1 976
 to 1982) in ihc
 Washington State
 Department of Ecology,
 serving  there as Section
 I lead for the Grants
 Administration Section,
 Municipal  Division
 (1979 to 1981), and
 planner for the Water
 Quality Management
 Section, Water Quality
 Management Division
 (1976to 1978).
   Clarke received both
 his bachelor's degree
 (1971)  and master's
 degree { 1 98 1 ) in  biology
 Irom Pacific Lutheran
 University.
Michelle Jordan will
serve as Deputy
Regional Administrator
of Region 5, which
covers  Illinois, Indiana,
Michigan, Minnesota,
Ohio, and Wisconsin.
She has been a
practicing attorney for
1 6 years, with 10 years'
experience in
environmental matters.
With the Regional
Administrator, she is
responsible for the
management of the
region's air, water,
hazardous waste, and
other pollution control
programs.
  Sne specialized in
environmental law at the
firm  of Hopkins  &
Suiier, where she
represented clients
before  federal, state, and
local agencies on
environmental matters,
and counseled clients on
environmental
regulations.  Jordan, as
an Illinois Assistant
Attorney General (1984
to 1990) and Chief of
the Environmental
Control Division, was
responsible for civil and
criminal environmental
cases.  As chief of the
division, she served as
legal  counsel to the
Illinois Environmental
Protection Agency and
the Illinois Pollution
Control Board, working
closely with officials in
Region ">.
  Jordan graduated
magna  cum laude from
Loyola University with
a  bachelor's degree  in
political science in  1974.
She earned  a law degree
from the University of
Michigan in 1977.
Mclinda L.
McQanahan is the new
Director of the Office of
Exploratory Research  in
the Office of Research
and Development. She
is responsible for the
administration of EPA's
extramural research
grant program for U.S.
colleges and universities,
14 programs of
university-based research
centers, the  Small
Business Innovation
Research program,
several fellowship
programs, and the
Senior Environmental
Employment program.
  She brings to the post
20 years' experience in
administrative
management, numerous
contacts at national
laboratories, major
universities, and
international
organizations, and
detailed knowledge ol
federal and state
environmental laws.
  As Dean of the School
of Science and
Engineering of New
Mexico Highlands
University, she
administered all
programs including
grants for the
departments of
Engineering, Physical
Sciences, Mathematics
and Computer Science,
Life Sciences, and other
disciplines.  Prom 1990
until her EPA
appointment, she was
Professor of Biology and
Instructor of Marine
Biology and
Environmental
Radiation.
  As Head of the
Department of Biology
(1978 to 1990) at
Northeast Louisiana
University (NLU), she
managed academic and
research programs and
supervised curatorial and
 field operations for
 NLU's Cancer Research
 Center/North Louisiana
 Regional Tumor
 Registry. Museum of
 Zoology, Herbarium,
 and Microbiology
 Laboratories.
  While there, she was
 twice a. visiting professor
 in radiation biology and
 medical genetics at Xuan
 WU Hospital and the
 Capita! Institute of
 Medicine in Beijing, The
 People's Republic of
 China.  During 1988 she
 conducted biological
 research in the
 mountains  of Papua,
 New Guinea.
  She earned a bachelor's
 degree (1971) and
 master's degree in
 biology (1972), and a
 doctorate degree in
 radiation biology (1974)
 from Texas Woman's
 University. She also
 received a master's in
 business administration
 from New Mexico
 Highlands University
 (1991). She is a
 certified hazardous
 materials manager
 (master's level) and a
 senior registered
environmental manager.
William Laxton is the
new Director of EPA's
Office of Administration
and Resources
Management, Research
Triangle Park (OARM-
RTP). In this capacity,
he is responsible for
Agency-wide data
management and
telecommunications, and
the operations of the
EPA National Computer
Center.  He will manage
EPA's RTP facilities, and
provide  human resources
support  for all EPA
employees in RTP,
North Carolina;
Montgomery, Alabama;
Hay St.  Louis,
Mississippi; and Bay
City, Michigan.
  Prior to becoming
Director of OARM'-RTP,
he served as Director of
the Technical Support
Division of EPA's Office
of Air Quality Planning
and Standards in
Durham, North Camlina
(1987 to 1992). He also
served as Deputy
Director of OAllM in
RTP (198-4 to 1987).
Before moving to RTP.
he had 14 years of
federal government
experience in personnel
managemcn!. .serving
live of these years as
Director of Personnel for
two federal agencies, the
Office of the Federal
Inspector for the Alaska
Pipeline (1979 to I9JH)
and the  National
Endowment for the Arts
(1983 to 1984).
  Laxton holds a
bachelor's degree (1969)
and a master's degree
(1970) in philosophy
from the Catholic
University of America.
SUMMER 1994
                                                                                                         47

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Michael Shapiro is the
new Director of the
Office of Solid Waste in
(he Agency's Office of
Solid Waste and
Emergency  Response.
  Prior to this
appointment,  he first
served as Deputy
Assistant Administrator
(from 1989 to 1993)
and then as Acting
Assistant Administrator
during 1993 in EPA's
Office of Air and
Radiation, where he
directed the
implementation of the
Clean Air Act
Amendments.  J-'rom
1980 to 1989, he held
several positions in the
Office of Pesticides and
I o.xic Substances,
including Acting
Director and Director
for the Economics and
Technology Division
(from 1982 to 1989);
Branch Chief for the
Regulatory  Impacts
Branch (from  1981 to
1982); and Policy
Analyst  (from 1980 to
1981').  Among his
accomplishments in that
office, he oversaw the
development of EPA's
Toxic Release Inventory.
  Shapiro earned a
hachelor's degree in
mechanical engineering
from Lehigh University
in 1 970, a master's
degree from 1 larvard
University in  1972, and
a doctorate in
environmental
engineering from
I  larvard University in
1976.  He has also
I aught in the public
policy program at the
John !•'.  Kennedy School
of Government.
The new Deputy
Director of the Office of
Modeling, Monitoring
Systems, and Quality
Assurance within the
Office of Research and
Development is John
"Jack" I'uzak.
  Puzak began his career
with HPAin 1971 as a
chemist at the ORD
Laboratory located in
Research Triangle Park,
North Carolina.  From
1991 to 1993, he held
several senior positions
at ORD including Acting
Director, Office of
Modeling, Monitoring
Systems and Quality
Assurance; Associate
Director for Science,
Office of Modeling,
Monitoring Systems and
Quality Assurance; and
Acting Director,
Environmental Research
Laboratory, Duluth,
Minnesota.
  From  1 985 to 1 99 1,
he held other key
managerial positions
in ORD including
Director, Quality
Assurance  Division
(1981 to 1985); Acting
Director, Environmental
Monitoring Systems
Laboratory, RTP, North
Carolina (1987); and
Acting Director,
Exposure Assessment
Research Division (1989
to  1990).
  Puzak received a
bachelor's degree in
chemistry from Carnegie
Mellon University in
1 966, a master's degree
in chemistry from Duke
University in 1974, and
a master's in business
administration from
University of North
Carolina'in 1989.
Jay Bcnforado is the
new Deputy Director of
the Office of Science,
Planning, and
Regulatory Evaluation in
EPA's Office of Research
and Development
(ORD).
  Benforado brings
extensive experience to
this post from other
positions he has held in
ORD.  He served as
Director of the
Regulatory Support Staff
since 1988, and as
Special Assistant to the
Assistant Administrator
from 1986 to 1988; he
was a program analyst
from 1 985 to 1 986'.
  Before that, he was a
wetland ccologist in the
Agency's Office of
Federal Activities (1983-
1985) and also for the
U.S. Fish &. Wildlife
Service (1981-1982).
He served as a wetland
scientist in the Coastal
&. Water Resources
Program of the
Conservation
Foundation from 1979
to 1981.
  Bcnforado received a
bachelor's degree in
/.oology/physical
geography from the
University of Wisconsin
in 1977 and a master's
degree in ecology/
environmental sciences
from Indiana University
in 1979.
Science Policy Council

A newly created Science
Policy Council has been
created to replace the
Risk Assessment
Council.  The new
council, which met in
January, will address
concerns  raised by EPA's
Science Advisory Board,
the National Research
Council, and others on
how EPA integrates
policy and science in
decision making.
      A J
  1 he Administrator
named Deputy
Administrator Robert
Sussman  as  chair of the
council and Lynn
Goldman, Assistant
Administrator of the
Office of Prevention,
Pesticides and Toxic
Substances, as vice chair
to ensure highest
priority will be given to
the council's policy
decisions.
  As an initial task, the
council designated a
steering committee to
make ongoing
assessments of science
policy and to oversee the
implementation  of
Agency science policies
in programs and
regions.D
     Environmental Q  & A
          What caused the gypsy
     moth pest problem in the United
     States?

     J\ The gypsy moth is a forest
     insect native to Europe.  In the
     19th  century,  a French astronomer
     working at Harvard brought the
     gypsy moth  to America to use  in his
     hobby-cross-breeding silk
     caterpillars.  The gypsy moth
     became a serious pest problem
     when climatic changes  brought on a
     population explosion 20 years  after
     it was accidentally released in
     Medford, Massachusetts, in 1869.
     Caterpillars  swarmed through the
     trees in Medford, eating the leaves
     and covering the ground with
     droppings.

     — Submitted by Christine L. Gillis
     Office of Pesticide Programs, EPA
48
                                                                                             USD A photo.


                                                                                          EPA JOURNAL

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                                    IITTLE BY LITTLE,
                             OUR WATERS ARE LOOKING
                                      LESS LIKE ART
                               AND MORE LIKE
                                There are toxic chemicals in our water. Such as oil.
                             And pesticides.
                                You might think industry is to blame. But they're only part
                             of the problem. You and I, in our everyday lives, are also respon-
                             sible for a tremendous amount of water pollution.
                                However, we can all help protect our water. For example,
                             use less toxic household cleaners and practice natural lawn care
                             by composting and using fewer chemicals. And instead of pour-
                             ing used motor oil onto the ground or into storm drains, simply
                             take it to a gasoline station where it can be recycled.
                                To find out more, call 1-800-504-8484, and we'll send you
                             additional information on how you can help protect our rivers.
                             lakes and oceans.
                                That way we can turn this terrible tide around. And restore
                             the beauty to our water.
                                      CLEAN WATER.
                                IF WE ALL DO A LITTLE,
                                    WECANDOALOT.
Natural Resources
Defense Council
                                           A Public Ssrviceol
                  Japan Ad Council

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