TECHNICAL PRIMER ON
   MAJOR EPA PROGRAMS

       DESIGNED FOR USE BY EPA'S
   QUALITY ASSURANCE COMMUNITY
               Prepared By
      BREGMAN & COMPANY, INC
                       .
                                         .
                   for the

             Quality Assurance Management Staff
             U.S. Environmental Protection Agency
               under Contract 68-02-4552
           (Prime Contractor: JWK International, Inc.)

EPA 650-B-70-005

-------
                             TABLE OF CONTENTS
Chapter                                                Page
      I ntrodu ct ion	1
      Drinking Water	3
      Surface Water	12
      Ground Water	20
      Estuaries and Oceans	26
      Wetl ands	32
      Air Quality: Indoor Air	37
      Air Quality: Mobile Sources	....44
      Air Quality: Stationary Sources	51
      Radi ati on	.58
      Federal Activities			65
      Pestici des	71
      Toxic Substances	80
      Solid and Hazardous Wastes	88
      Superfund and Emergency Response	94
      Enforcement and Compliance Monitoring	...106
      Information Resources Management	113
      Library Management	120

-------
                                INTRODUCTION

The Environmental Protection  Agency  Quality  Assurance  Management  Staff
has  a  continuing  commitment  to  ensure  that Quality Assurance-Managers
(QAM)  and  their  staff  members  have  the  information  they   need   to
effectively   perform   their   tasks.   This  includes  knowledge  of  the
multitude of the agency's programs.  This document  was  produced  to  give
the QA team an overview of the agency's programs and issues.

The  Manual  is  intended  to  serve  as  a  reference  guide  to major EPA
operational programs.  It is an effort to address  each  program  concisely
and  broadly  and  to  discuss  and  record  on  a  few pages the program's
highlights.  The Manual  deliberately  does  not  contain  a  comprehensive
discussion  of  agency  programs.   Rather, its goal is to foster a general
understanding of the  purposes  and  operation  of  the  programs.   It  is
intended to familiarize staff with a wide range of programs and issues.

This  Manual  should  be useful to many who want to broaden their knowledge
about various EPA programs.  While this effort  was  designed  as  a  quick
reference,  it  should  be  of  assistance  to  other EPA professionals who
become involved with an EPA program that  may  not  be  included  in  their
past  experience.   The  brief  review  in  this Manual of a particular EPA
program provides information about each program's background,  as  well  as
an  understanding  of- program  language and data systems.  The document is
not meant to be comprehensive and totally self-sufficient in terms  of  any
of   the   programs.   Rather,  it  is  intended  to  serve  as  a  general
introduction to each program, with a list of references  presented  at  the
end of each chapter for further detailed reading.

Each   program   discussion   contains   a   summary   of   the  pollution,
environmental or other concerns, as well as the management  strategies  and
data  systems  employed.  The summary is followed by sections that describe
sources, the nature and extent of the problems; program controls; regula-
tory controls or other actions to control the concerns;  data  systems  and
quality assurance requirements to support the standards, criteria, rules,

-------
advisories,  or  permits;  and any special  national  studies  of  significance
to the program office.  Lastly, the  discussion  is   followed  by   selected
reading  references  for  the  person  wanting to gain a more comprehensive
understanding of the program and its needs.

Your  reactions  and  suggestions  for  improvement   of  this  Manual    are
encouraged  and  are welcome.  Comments and concerns should  be  addressed to
Mr.  Kevin  Hull,  Quality  Assurance  Management   Staff,    RD-680,    U.S.
Environmental  Protection  Agency, 401 M Street, SW, Washington, DC  20460,
(202)382-5763.

-------
                                DRINKING WATER

                                    SUMMARY

Public water systems supply drinking water from rivers, lakes,  reservoirs,  and
wells.   Pathogens,  organic  compounds,  excess  nitrates, and tastes and odors
that may be associated with these supplies  are  overcome  through  disinfection
and   proper   water   treatment   system  operation.   The  U.S.   Environmental
Protection Agency  promulgates  drinking  water  regulations  that  ensure  safe
drinking  water  at  the  tap and provide for a public water systems supervision
program that is principally conducted by the States.

EPA has a designated Quality Assurance Officer for Drinking  Water  programs  in
Headquarters  and  a  Quality  Assurance  Coordinator  in  its Technical  Support
Division in Cincinnati,  OH.   The  EPA  laboratory  certification  program  for
drinking  water  analysis  requires  on  site laboratory technical system audits
that examine quality assurance  procedures  and  quality  controls  in  analytic
performance,   and  peVformance  evaluation  sample  analyses.  States  and  EPA
require that a  certified  laboratory  analyze  all  water  system  samples  for
compliance  monitoring.   EPA Regions certify State laboratories which, in turn,
certify plant and commercial laboratories.

Drinking  water  quality  is  monitored   via   Federally   approved   sampling,
analytical  and  data  handling  requirements  as  provided  by 40 CFR 141.  All
laboratories conducting analysis under the Safe Drinking Water Act  must  follow
Federally  approved  methods  of  sampling  and  analysis.   To  ensure adequate
laboratory control over the analysis  and  to  obtain  data  of  known  quality,
routine  quality  control  (QC) procedures are carried out in the field,  as well
as in the laboratory.  QC procedures may include  standardization  of  titrants,
analysis  of  spikes,  duplicates  and  analysis of quality control  samples.   In
addition to QC  measures,  the  laboratory  must  prove  competence  via  annual
Performance  Evaluation  (PE) analyses of unknown samples, and the facility must
be certified on  an  on-site  triennial  basis  by  a  State  Quality  Assurance
Officer  (QAO)  or  EPA  QAO  for  States  where the programs are not delegated.
Certification  consists  of  on-site  inspections  of  sampling,   preservation,
analysis,  QC  and  data  handling  techniques  to  ensure  adherence to Federal
regulations governing analysis of water samples.

-------
In addition to  certification  of  laboratories,  States  may  provide  a  water
treatment  operators'  certification program.   Annual  treatment  plant operator's
short  courses,  usually  four  or  five  days  in   length,  provide  continuing
education for the operator in state-of-the-art  plant operation.

EPA provides oversight of State  drinking  water  programs,  training   of  State
personnel,  audits  and inspections, and training for  small  public  water systems
personnel.

                                SOURCE OF SUPPLY

Drinking water for  public  water  systems  comes   about  equally   from surface
supplies  or  from wells.  Both types of sources are subject to  spills  and other
sources of contamination.

SURFACE SUPPLIES: These include rivers, lakes,  and   impounded   reservoirs.  They
may  receive  runoff and stormwater from the land,  discharges  from  industries or
from  cities,  drainage  from  mines,  or   return    flows   from    agricultural
irrigation,  or  they  may be supplied by well-controlled,  protected watersheds.
Turbidity, mineral content, and degree of contamination  may  vary   daily   in  a
river  and  temperature  may  vary  throughout  the year.  Deep water intakes in
lakes and reservoirs provide cool water with generally consistent  quality.

WELLS; Water may contain hardness caused by calcium  and  magnesium  leached  as
the  water  percolates  through  mineral  deposits;  it  may  contain  iron   and
manganese in objectionable concentrations.

                                QUALITY CONCERNS

PHYSICAL;  Concerns  are  turbidity,  color,  temperature, taste and odor. Clay,
silt, and finely divided  organic  matter  cause  turbidity.  Dissolved  organic
materials  from  decaying vegetation and certain Inorganic matter cause color in
water. Temperature 1s  dependent upon the  source  of  supply.    Inorganic  salts,
and  dissolved  gases, cause taste and odor.

Impounded water  may   leach   undesirable  materials  from  flooded  soils.  Land
clearing,  or covering,  of organic materials prior to Hooding in reservoir

-------
construction or rehabilitation will reduce potential taste  and  odor  problems.
Ground  water  from  certain  areas may contain hydrogen sulfide gas, which must
be removed to preclude taste and odor.

CHEMICAL; Toxic or hazardous substances .enter surface waters  through  pollution
or  accidental  spills.  Rich  ore  deposits  contribute  to  concentrations  of
certain  toxic  inorganic  properties. Most waters contain chloride in solution;
excessive concentrations produce taste, and may cause  corrosion  in  hot  water
pipes.  Copper,  in  excess,  causes  taste  and  porcelain  staining.  Iron and
manganese cause taste and a brownish color to laundered goods.

Organic compounds  from  effluents,  land  runoff,  natural  decomposition,  and
water  and  wastewater  chlorination  cause  human  health  concerns.  They  are
presently,  the  subject . of  an  intensive  EPA  effort  to  regulate  allowable
concentrations and to develop analytical techniques for measuring them.

Excess  nitrate  in  drinking  water  has  produced serious and occasional fatal
poisoning in infants, particularly those less than  three  months  old.   Nitrate
interferes  with  the  capacity  of  their blood pigment to carry oxygen.  Excess
sulfates tend to form scales in boilers and cause,taste and laxative effects.

BIOLOGICAL; Safe dri'nking water requires it to be free from pathogens  that  may
come  from  human,  animal or industrial wastes.  Production of water that poses
no threat to health depends upon continuous vigilance  and  use  of  appropriate
disinfectant technology.

Iron  bacteria  in  distribution  systems may cause turbidity and discoloration,
taste and odor, and hard deposits that fill pipes.  Algae  corrode  metal   tanks
and  concrete  reservoir  walls,  clog sand filters, and cause taste and odor in
surface supplies.  Other problem organisms  may  be  bloodworms,  clams,   snails,
and nematodes in distribution systems.

                                   TREATMENT

pH:  This  is a measure of the hydrogen ion activity, which indicates the  degree
of acidity. On a scale of 0 to 14, a pH of 7.0 is neutral. At low pH, water  is
acid and tends to be corrosive and dissolve materials. Lead, cadmium, iron or

-------
copper  may  enter  the supply from pipes. At high pH,  water  1s  alkaline and may
deposit calcium and/or magnesium carbonate scale  in pipes.   Sodium  hydroxide,
lime,  soda  ash,  carbon  dioxide,  and  sulfuric acid are used to adjust pH to
within a range of 6.5 to 8.5.

SEDIMENTATION; Settling removes settleable materials.   Coagulants  are  used  to
speed  settling  and  aid  in  the  removal  of  both   settleable  and suspended
materials.  Following addition of a coagulant, water passes   slowly  through  a
sedimentation basin where materials settle and are removed.

FILTRATION:  Sand,  anthracite,  and diatomite filters, or microstrainers remove
particles too light or too  finely  divided  to  be  removed   by  sedimentation.
Water  is  passed  through  a  layer  of  filtering material. As algae or debris
collect on the filter surface, the process is slowed,  and  the  filter  must  be
taken  out  of  service  and  backwashed  to  remove  the  collected  debris.  A
microstrainer  is  a  drum-shaped  screen  with  uniform  small  openings through
which water passes.  A low-quantity jet  spray  on  the  opposite  side  of  the
screen removes the collected debris as the screen rotates.

DISINFECTION;  This  process  destroys  pathogenic organisms. Generally chlorine
1s used and 1s applied as a gas or a solution* either alone  or  in  conjunction
with  other  chemicals.  Ozone  may be used in place of chlorine.  However, this
practice  1s not common in the United States, since unlike chlorine,  ozone  does
not provide a residual disinfectant throughout the distribution system.

AERATION;  This  process  removes volatile substances and excess carbon dioxide.
Aerators  Include cascades and sprays that expose water to the atmosphere.

COMBINATIONS; The  several basic water treatment operations described  above  are
used  in   sequence  or  in  combination  along  with  other treatment methods to
produce a safe and aesthetically pleasing product. Iron  and  manganese  may  be
controlled by   aeration  followed  by  filtration, lime and soda softening, ion
exchange,  or by  adding polyphosphates  or  other  organic  sequestering  agents.
Corrosion  protection  may  be  achieved  by  good  engineering  design,  proper
selection  of  pipe  materials,  pH  adjustment,  reduction  of  oxygen,  use of
Inhibitors such  as phosphates and  silicates,  and  lining of tank and  pipe  walls
with  coatings  and  paints.

-------
                              REGULATORY CONTROLS

NATIONAL  PRIMARY  DRINKING  WATER REGULATIONS: These regulations protect health
by specifying maximum levels allowed in drinking water at the  tap  for  certain
bacteriological,  radioactive,  organic  and  inorganic  chemical  contaminants.
Over  65  contaminants  are  addressed  {Table 1),; monitoring, reporting, record
keeping, and  public  notification  for  certain  regulatory  noncompliance  are
required.  Use of lead pipes, solder and flux are prohibited.

NATIONAL  SECONDARY  DRINKING  WATER  REGULATIONS:  Not  Federally  enforceable,
these  aesthetic  quality goals are guidelines for States. Thirteen contaminants
are addressed (Table 1).

STATE  PROGRAMS:  All  but  a  very  few  States  have  been  delegated  primary
enforcement responsibility to  operate  the  public  water  systems  supervision
program.  To  do  so,  a  State  must have a drinking water program in agreement
with 40 CFR  142.   Regulations  require  record  keeping,  reporting,  a  State
laboratory  certification  program unless all compliance samples are analyzed in
the State laboratory which is certified by EPA, and certain  administrative  and
approval matters.

                               QUALITY ASSURANCE

LABORATORY   CERTIFICATION  PROGRAM;  The  Office  of  Drinking  Water  provides
program policy and guidance for  the  drinking  water  laboratory  certification
program.   A   manual  has  been  developed  for  this  purpose  (see  Suggested
Reading).  EPA's Environmental Monitoring Systems  Laboratory,  Las  Vegas,  NV,
oversees    radiological   testing;   the   Environmental    Monitoring   Systems
Laboratory, Cincinnati, OH, oversees other testing and  certifies  EPA  Regional
Laboratories.  EPA  Regional  laboratories, in turn, certify State laboratories.
State laboratories certify public water  systems  and  commercial  laboratories.
Certification   involves   inspection   of  facilities,  equipment,  procedures,
personnel training, quality assurance plans,  quality  control  procedures,  and
satisfactory    completion   of   periodic   performance   evaluation   samples.
Compliance monitoring data  from  water  systems  plants  must  be  produced  by
certified laboratories.

-------
Table 1. Regulated Drinking Water Contaminants as of June 15, 1990
Primary Drinking Water Regulations
(40 CFR Part 141)
Required Monitoring for Unregulated
Volatile Organic Chemicals
Microbiology & Turbidity
      Total coliform organisms
      Turbidity
Inorganic Elements
      Arsenic
      Barium
      Cadmium
      Chromium
      Lead
      Mercury
      Nitrate
      Selenium
      Silver
      Fluoride
    Organic Chemicals
      Endrin
      Lindane
      Methoxychlor
      Toxaphene
      2,4,-D
      2,4,5-TP
      Total trihalomethanes
    Volatile Organic  Chemicals
      Trichloroethylene
      Carbon tetrachloride
      Vinyl chloride
      1,2-Dichloroethane
      Benzene
      para-Dichlorobenzene
      1,1-Dichloroethylene
      1,1,1 -Tri chloroethane
    Radionuclides
      Radium 226 and  228
      Gross alpha  particle activity
      Beta particle and  photon
         radioactivity
Chloroform
Bromodi chloromethane
Chlorodi bromomethane
Bromoform
trans 1,2-Di chloroethylene
Chlorobenzene
m-DiChlorobenzene
Dichloromethane
ci s-1,2-Di chloroethylene
o-Di Chlorobenzene
Dibromomethane
1,1-Dichloropropene
Tetrachloroethylene
Toluene
p-Xylene
o-Xylene
m-Xylene
1,1-Di chloroethane
1,2-Dichloropropane
1,1,2,2-Tetrachloroethane
Ethylbenzene
1,3-Di chl oropropane
Styrene
Chloromethane
Bromomethane
1,2,3-Tri chloropropane
1,1,1,2-Tetrachloroethane
Chloroethane
1,1,2-Trichloroethane
2,2-Dichloropropane
b-chlorotoluene
p-chl oro toluene
Bromobenzene
1,3-Dichloropropene
Ethylene  dibromide
1,2-Dibromo-3-chloropropane
 Secondary Drinking Water'Regu1ations(40 CFR Part 143)
       Chloride
       Col or
       Copper
       Corrositivity
       Fluoride
       Foaming agents
       Iron
       Manganese
       Odor
       pH
       Sulfate
       Total dissolved solids
       Zinc
                                        8

-------
PERFORMANCE  AUDITS:  Sealed,  numbered ; vials  of  drinking water samples whose
constituent concentrations are unknown to  the  receiving  laboratory  generally
are  sent  to  each  laboratory  at  least  every 12 months.  They are currently
supplied by the Cincinnati, OH, EPA  laboratory.   Analytical  results  must  be
reported   by   the   receiving   laboratory  within  a  specified  time  frame.
Laboratory   certification   may   be   denied   or   withdrawn   following   an
unsatisfactory performance on the performance audit sample(s).

STATE PROGRAM OVERSIGHT: EPA Regions conduct audits and inspections  of  primacy
State  enforcement  and  compliance  programs.  States  inspect  water treatment
plants routinely, which includes  operator  performance,  plant  operation,  and
the  facility.  In  addition,  Headquarters  and  EPA  Regions provide technical
assistance and training, particularly to small public  water  systems.  Emphasis
is  on  noncompliance  or  potential  noncompliance  problems  but  may  involve
sampling, reporting, or management concerns.

DATA  SYSTEMS;  FRDS,  the  Federal  Reporting  Data  System  is  a computerized
repository for compliance monitoring data from  water  supply  systems.  Samples
are  analyzed  by a certified laboratory. Individual system's analytical  results
are forwarded to the State, which reviews the data  either  manually,  or  by  a
computer  program  designed  to  highlight  noncompliance  with  drinking  water
regulations  and  potential  errors in data or information entry. States  forward
the  violation  of  the  regulations  to  EPA  Regions.  Regions  conduct   data
verification  audits  at  intervals  based  upon  an  examination of the'data at
hand, and enter data  into  the  computerized  system,  FRDS.  The  computer  is
programmed  to  check  entry errors, but a computer check of the analytical  data
is not made. A data base for unregulated contaminants also is maintained.

NATIONAL PESTICIDE STUDY: EPA often conducts  special  studies  to  support  the
development  of  regulations.  One  example  of  a major study of this type that
               ' "> -
falls within the drinking water area and has strong QA elements is  the  effort,
now   being   completed,   to   understand   and  characterize  the  problem  of
agricultural chemicals in ground water. The  study  tested  750  rural domestic
wells  representing  a  universe  of  13  million wells, and 599 community water
systems representing a universe of 51,000 community water systems.  The  quality
assurance (QA) organization was extensive, with a full time QA officer, under

-------
contract  to  EPA,  and assistance from QA officers  from  the  Offices  of Drinking
Water and Pesticide Programs, who supported the Survey  jointly.   Well   sampling
adhered  to  a  QA Project Plan and a Sampling Manual.  Because  of the complexity
of the QA program, various aspects of the Survey adhered   to  eight  QA  Project
Plans under the umbrella of a master QA Project Plan.
                                        10

-------
                               SUGGESTED READING

1.  40 CFR Parts 141, 142, and 143.

2.  Anon.  (Not  dated).   Manual  of  Instructions  for  Water  Treatment Plant
    Operators.  New York State Department of Health, Albany, NY.

3.  Drew.  1977.   Principles  of  Industrial  Water  Treatment,  Drew  Chemical
    Corporation, Bbonton, NJ  07005.

4.  Fair,  Gordon  M.,  John  C.  Geyer,  &  Daniel A. Okun.  1971.  Elements of
    Water Supply and Wastewater Disposal.  John Wiley & Sons, Inc., NY

5.  Kemmer, Frank  N.  (Ed.).   1977.   Water:  The  Universal  Solvent.   Nalco
    Chemical Company, 2901 Butterfield Rd., Oak Brook, II  60521.

6.  Kerri,  Kenneth  D.   1988.   Water  Treatment  Plant Operation.  California
    State University, 6000 J Street, Sacramento, CA 95819 (Vols. 1 & 2).

7.  Larson, Richard A.  1989. Biohazards of  Drinking  Water  Treatment.   Lewis
    Publishers, Inc., 121 S. Main St., Chelsea, MI  48118.

8.  Riehl,  Merrill  L.   1976.   Hoover's  Water Supply and Treatment (Eleventh
    Ed.).  National Lime Association, Washington, DC  20016.

9.  Steel, Ernest W. 1960.  Water Supply and Sewerage.   McGraw-Hill  Book  Co.,
    Inc. NY

10. US   EPA.    1980.   National  Secondary  Drinking  Water  Regulations.   US
    Environmental Protection Agency, Washington, DC, EPA 570/9-76-000.

11. US EPA.  1982.  Manual of Individual Water  Supply  Systems  (Revised).   US
    Environmental Protection Agency, Washington, DC, EPA 570/9-82-004.

12. US   EPA.    1990.   Manual  for  Certification  of  Laboratories  Analyzing
    Drinking  Water,  Criteria  and  Procedures  and  Quality  Assurance  (Third
    Edition).  U.S. Environmental Protection Agency, Washington, DC,
    EPA 570/9-90-008.
                                       11

-------
                            SURFACE FRESH WATERS

                                  SUMMARY

Surface waters are used as sources of  drinking  water,  as  recipients  of
treated   and  ' sometimes   inadequately   treated   wastes,  for  fishing,
recreation, navigation  and  in  agricultural   and  industrial  activities.
Principal  regulations  to control surface water pollution include effluent
guidelines, water quality  standards,  discharge  permits,  and  wastewater
sludge  management  requirements.  Pollution control  activities for surface
fresh waters are managed by  the  EPA  Offices  of  Water  Regulations  and
Standards,   Water   Enforcement   and  Permits,  and  Municipal  Pollution
Control.  National data-gathering studies collect  Information  to  support
regulation  development.   These  data-gathering  activities are subject to
quality  assurance  program  plans.   They  require  project  plans   where
environmental  data  are  collected by EPA, through grants to States, or by
contracts  with  consultants  and  others.   A  number  of  different  data
systems  then are used to store and provide data to program managers.

                              WATER RESOURCES

Rivers,  streams, lakes, reservoirs, and  ponds  are  the  focal  points  of
this  surface  water  discussion;  wetlands will be discussed in a separate
chapter.  Rivers drain  the land and carry  with  them  wastes  from  cities
and   industries,  as  well  as  pollutants  in  runoff from agriculture and
urban areas.   U.S. rivers, on the average, carry 12 cubic  miles  of  water
1n  their  channels;  many  exceed  1,000  miles in length.  U.S. lakes and
reservoirs, numbering in excess of 1.5 million, contain 4,500  cubic  miles
of    water.    Geologically,   lakes   may   be   considered  as  temporary
water-holding  vessels on the landscape.

The water quality determines the  uses that may  be  made  of  any  specific
water  body.   Waters   are used by humans in many (and sometimes competing)
ways  Including boating, swimming,  fishing,  aesthetics,  navigation,  for
drinking water,  and   for  agricultural  and  Industrial  purposes.   Many
cities  were  built on  rivers because of their navigation potential.
                                      12

-------
                       POLLUTION CONCERNS AND SOURCES

PHYSICAL;  Aesthetically  pleasing  waters  add  to  the  quality  of human
experience.  Oil  contamination. - is  toxic  to  aquatic  life.   Settleable
solids   and   erosion  from  natural  sources,  construction  activity  or
farmland screen out necessary light,  change  heat  radiation  and  blanket
the  stream  bottom,  thereby smothering bottom dwelling food organisms, as
well  as  removing  organic  materials  and  nutrients.   They   also   may
introduce  toxic  substances  into  the  water body.  Temperature is one of
the most important  and  influential  water  quality  characteristics  that
affects biological life in water.

CHEMICAL:  Toxic  or  hazardous substances may enter surface waters through
direct discharge, runoff, or accidental spills.   They  may  bioaccumulate,
impair  reproductive  activity, or cause tumors or cancer.   Some chemicals,
when bioaccumulated in  aquatic  organisms  and  ingested  by  humans,  can
cause  diseases  such  as cancer.    Fish eating birds and mammals have been
killed  by  ingesting  the  chemicals  secondhand.   Excess  nitrogen   and
phosphorus  nutrients  stimulate  aquatic  plant  growth,  which  result in
vegetation decay, water oxygen  reduction,  fish  kills,  foul  odors,  and
unsightly  decomposing  algal  masses.   When water becomes too acid or too
alkaline,  aquatic, life is affected adversely.  Thus,  for  example,  dense
algal  growths  can make the water alkaline, while acid mine wastes destroy
aquatic life by lowering the pH below tolerable limits.

BIOLOGICAL: Pathogenic organisms that cause infection  or  disease  may  be
present  in  surface  water.  Natural beaches are monitored closely and may
be closed when body contact  water  quality  criteria  are  exceeded.    The
basic  indicator  is  the  concentration  of fecal coliform bacteria,  which
can cause  diarrhea.   Swimmers  itch,  an  irritating  rash  caused  by  a
parasite  liberated  by  certain  snails, is prevalent in some areas.   Some
species of blue-green algae, when stimulated to grow  in  massive  quantity
because  of  abundant  nutrients,   produce  a  toxin that has been fatal to
mammals, birds, and fish when ingested.  It has caused  gastroenteritis  in
humans.   Human  respiratory  and  skin disorders also have been associated
with algae.
                                     13

-------
SOURCES: Spills, leaks, and  Illegal  dumps  contribute  to  surface  water
pollution.   Point  source  discharges from industrial  plants and municipal
wastewater   treatment   systems   historically   have    been    principal
contributors,  but,  in  recent  years, much has been accomplished to abate
these  sources.   Nonpoint  source  runoff  (such  as  from   farmland   or
construction),  stormwater,  and combined sewer overflows are major sources
yet to be effectively addressed in many areas of the country.

                              PROGRAM CONTROLS

WASTEWATER TREATMENT;  Publicly  owned  treatment  works  are  designed  to
separate  solids  from  liquids  (primary treatment) and to provide optimum
conditions  in  a  confined  area  for  bacteria  and  other  organisms  to
decompose and convert liquid wastes to  more  simple  and  stable  products
(secondary  treatment).   Wastewater  entering  a treatment plant is passed
slowly through a sedimentation tank,  where  heavier  materials  settle  to
the  bottom  and  are removed.  Grease and scum are skimmed from the liquid
surface.  Following this primary  treatment  process,  the  liquid  may  be
sprayed  over  a trickling filter column of rocks where organisms feed upon
and digest the organic material.  In other  facilities,  it  is  introduced
into  an  activated  sludge unit which is aerated to provide organisms with
optimum conditions to feed upon the  organic  material.   As  a  result  of
this  secondary  treatment,  the oxygen demanding quality of the wastewater
is greatly reduced.  This is a critical factor in the  maintenance  of  the
oxygen  level  of  the  water  body  into  which this treated wastewater is
discharged.    In   some  facilities,  chemicals  may  be  added  to   remove
phosphates  and  nitrates  where  eutrophication  is a problem in receiving
waters  (tertiary treatment).

INDUSTRIAL  WASTE  TREATMENT:  Many types  of  industrial  wastes  require
treatment other   than  the  biological  process  described  for   domestic
wastewater.    Such  treatment  may  include processes such as neutralization
of   excessive   acidity    or   alkalinity;   chemical   precipitation;   air
flotation,   thus   removing   fats,   oils,  and  greasy solids; ion exchange;
decolorization;  resource  recovery;  and waste minimization procedures.
                                      14

-------
BEST MANAGEMENT PRACTICES (BMPs): These are good "common  sense"  practices
employed  to  reduce  the quantity of a waste and minimize its effects upon
the receiving environment.  For construction  sites,  for  example,  a  BMP
may  involve  staking  bales of hay to serve as a filter and silt basin for
silt-laden runoff water.  In lake management,  it  may  involve  stormwater
and  treated  wastewater  diversion  around  the lake or a vegetated buffer
zone to filter land runoff before it  enters  a  lake.   For  an  industry,
BMPs  involve  such  things  as  spill control, reporting, and containment;
secondary  containment;   materials   compatibility;   employee   training;
inspections and audits; mitigation clean up methods; and spill drills.  .

TOXIC  POLLUTANT  IMPAIRED  WATERS: States are required to develop lists of
toxic pollutant  impaired  waters,  and  identify  the  point  sources  and
amounts  of  pollutants  discharged that cause violations of water quality.
Individual control strategies for the point sources  identified  then  must
be  provided.   EPA  has  approval  authority  over  these  State lists and
itself prepares lists and individual  control strategies  for  those  States
whose lists have been disapproved.

FINANCIAL  ASSISTANCE:  Grants  and  a  new  revolving  loan  fund are made
available by EPA by way of the States to the local   communities  to  assist
them  in  construction  of  publicly  owned  treatment  works,  clean lakes
restoration,   conducting   water   quality   investigations,   management,
pollution abatement, and corrective or restorative  activities.

                            REGULATORY CONTROLS

EFFLUENT GUIDELINES: The regulations that are specific  for  each  industry
consist  of  national   levels  of wastewater contaminant control  based upon
the highest level   of  treatment  technology  economically  achievable  and
technically  feasible.   Addressing  an industrial  category with applicable
subcategories,   effluent  guidelines  involve  engineering   and   economic
studies,   wastewater  characteristics,  treatment   options,   and  economic
effects of regulations  upon  the  affected  parties.    Guidelines  for  57
industrial  categories  have  been promulgated.   They are easily adapted to
a discharge permit to regulate a specific industrial  discharge.
                                    ,15

-------
WATER QUALITY STANDARDS; Adopted by States,   and  approved  by  EPA,  water
quality   standards   identify  water  body,  uses,  provide  water quality
criteria to support the designated  uses  and  include  an  antidegradation
policy  for  waters  presently  of  higher quality than that designated for
their uses.  Designed for ambient water conditions,  such  standards   define
human  health  and  aquatic  life water quality goals and provide the basis
for enforceable requirements through discharge  permits.   Those  discharge
permits,  using  the  effluent  guidelines described above, are designed to
see that the receiving water  body  attains  and  remains  at  the desired
water quality levels.

DISCHARGE  PERMITS;  Specific  for  each identified point source discharge,
they   provide   effluent   limits,   discharge   conditions,    monitoring
requirements,  and  reporting  schedules.    Biological  toxlclty testing of
effluents now is commonly required.  A BMP plan, as well as  an  industrial
waste  pre-treatment  program,  may  be  required.  Permit limits are based
upon applicable effluent  guidelines  where  available,  best  professional
judgement   where   promulgated  guidelines  are  inapplicable,  and  water
quality standards.

WASTEWATER  SLUDGE  MANAGEMENT;  For  wastewater  sludge  pollutants    with
potential  public  health  or  environmental effects, regulations have  been
developed  that  specify  acceptable  sludge   management   practices   and
pollutant   specific  numeric  criteria  for  each  of  five  major   sludge
disposal options.

                             QUALITY ASSURANCE

Surface fresh water pollution controls are addressed  by  the  EPA offices
of  Water  Regulations  and  Standards,  Water Enforcement and Permits, and
Municipal Pollution Control.

ENVIRONMENTAL  DATA  COLLECTION;  The  Office  of  Water  Regulations   and
Standards   has   prepared   a   number  of  quality  assurance  documents,
references to which are Included In the Suggested  Reading  section.    They
operate  under   a  quality  assurance  program  plan  that addresses  quality
assurance  policies, procedures, and management systems  (OURS QA-4),   as  do
other  EPA  offices  Involved with surface waters.  The  program plan

                                     16

-------
requires  a  quality  assurance  work/project  plan when environmental data
are collected either by EPA or  through  contractor  support.   A  detailed
quality  assurance  project  plan is not required for the initial screening
or a pilot survey to establish  the  boundaries  of  a  study;  however,  a
standard  operating  procedure  short  form  project  plan is used instead.
OWRS operates the Sample Control Center which manages the  sample  analyses
for  effluent  guidelines  development  under  a  quality assurance project
plan.

DISCHARGE MONITORING: The Office of Water Enforcement  and  Permits  (OWEP)
is   responsible   for   Discharge   Monitoring   Reports  submitted  by  a
permittee.   A  permittee  is  currently  supplied  performance  evaluation
samples,  furnished  by  the  EPA  Cincinnati,  OH,  laboratory,  for   the
constituents  for  which  the  permittee must monitor in wastewater to meet
permit conditions. If  analytical  data  from  the  performance  evaluation
samples  are  of  inferior quality, an inspection is made by the applicable
EPA Region or State to determine  the  cause.   Routine  performance  audit
inspections  also  are made of permittees and may include permit compliance
evaluation or biological toxicity testing.   Enforcement  action  has  been
taken  against  a  permittee  for  violating  quality assurance procedures.
OWEP also is in the planning and development  stage  of  providing  quality
assurance guidance for biological toxicity testing.

MUNICIPAL  POLLUTION  CONTROL  NEEDS:  The  Office  of  Municipal Pollution
Control is responsible for the long-standing biennial survey  to  determine
municipal  pollution  control  needs.   Data are provided by the States.  A
contractor reviews  and  enters  the  data  into  the  Municipal  Pollution
Control  Needs  Survey.   There is a computer audit for data logic and data
entry errors.

DATA SYSTEMS:  OWRS  operates  a  number  of  location-type  data  systems.
These   include   the   surface  drinking  water  supply  facilities  file,
industrial facilities discharge file, stream flow gage  station  file,  and
fish  kill  file.   The  widely  known STORET, a water quality data system,
has a  history  dating  back  25  years.   A  Water  Quality  Data  Systems
Steering  Committee  is working to "integrate all of the data systems in the
Office of Water.

                                     17

-------
OWEP manages the Permit Compliance System  where  permits  information   and
the  discharge  monitoring  report  data  are  stored.    Quality  assurance
procedures  are  being  developed  and  implemented to quality assure these
data.  A statistical sampling check of the data is in a  pilot  test mode.
A guidance document on quality assurance is being developed.

OMPC  operates  the  Grants  Information  Control  System,  which  provides
information  on  municipal  pollution  control   grants  and  facilities  to
program  managers.   Data  are  supplied  by  the  States  and  there  is a
computer audit programmed for the system.

                              SPECIAL STUDIES

Examples of data-gathering special studies conducted by  OURS  include  the
National  Dioxin  Study,  which examined water, sediment and fish; the pish
Bioaccumulation  Study,  which  examined  fish  flesh  for  many  potential
bioaccumulants at 400  locations,  and  selected  sediments;  the  National
Sewage   Sludge   Survey,  which  determined  the  hazardous  condition  of
wastewater sludge resulting from the hazardous waste  exclusion  when  such
wastes  are  mixed  with  domestic  wastewater  in  a  sewer  system  to  a
publicly-owned  treatment  works, and identified new industries to regulate
with effluent guidelines; and the National  Sediment  Project,  which  will
examine    sediment   constituents   at   400   locations.    These   large
data-gathering studies have separate quality assurance project plans.
                                      18

-------
                             SUGGESTED READING

 1. Hynes, H. B. N.  1960.  The  Biology  of  Polluted  Waters.   Liverpool
    University Press, Liverpool.

 2. Mackenthun, Kenneth M.  1973.  Toward a Cleaner Aquatic Environment.
    US  Environmental  Protection Agency, Office of Air and Water Programs,
    Washington, DC.

 3. Metcalf & Eddy, Inc. 1972.  Wastewater Engineering.   McGraw-Hill  Book
    Co., New York.

 4. Ruttner,  F.   1963.   Fundamentals of Limnology (3rd Ed.).  University
    of Toronto Press, Toronto, Cananda.

 5. US EPA.  1980.   Primer  of  Wastewater  Treatment.   US  Environmental
    Protection Agency, Washington, DC, MCD-65.

 6. US  EPA.   1984.   Guidance  for  Preparation  .of Combined Work/Quality
    Assurance Project Plans for Environmental  Monitoring,  OWRS  QA-1.  US
    Environmental Protection Agency, Washington, DC.

 7. US  EPA.   1985.   Guidance  for  State  Water Monitoring and Waste!oad
    Allocation Programs.  US Environmental Protection  Agency,  Washington,
    DC, EPA 440/4-85-031.

 8. US EPA.  1987.  National Water Quality Inventory - Report to Congress.
    US  Environmental  Protection Agency, Washington, DC, EPA 440/4-87-008.
    (Or the most recent edition of this report.)

 9. US EPA.  1987.  Program Survey -- Biological Toxicity  Testing  in  the
    NPDES  Permits  Program.   US  Environmental Protection Agency, Permits
    Division, Washington, DC, August.

10. US EPA.  1987.  Surface Water Monitoring: A Framework  for  Change.  US
    Environmental   Protection  Agency,  Office  of  Water  and  Office  of
    Policy, Planning and Evaluation, Washington, DC, September.

11. US EPA.  1988.  Implementing the  Data  Quality  Objective  Process  in
    Surface   Water  Monitoring  Programs,  OWRS  QA-2.   US  Environmental '
    Protection Agency, Washington, DC.

12. US EPA.  1988.  Incorporating  Data  Quality  Objectives  into  Quality
    Assurance   Project   Plans   -   Interim   Report,   OWRS   QA-3.   US
    Environmental Protection Agency, Washington, DC.

13. US EPA.  1988.  Constructed Wetlands  and  Aquatic  Plant  Systems  for
    Muncipal  Wastewater  Treatment.   US  Environmental Protection Agency,
    Washington, DC, EPA 625/1-88-022.

14. US EPA.  1988.  Quality  Assurance  Program  Plan  for  the  Office  of
    Water   Regulations   and  Standards.   OWRS  QA-4.   US  Environmental
    Protection Agency, Washington, DC.
                                     19

-------
                                GROUND WATER

                                  SUMMARY

As  a  result  of  the  increase  of  freshwater  withdrawals, ground water
depletion and  contamination  have  become  significant  issues  in  almost
every  State.   Irrigation  of  crops creates the greatest demand on ground
water quantity.  More than 200 different organic and  inorganic  chemicals,
pesticides,  radionuclides  and  organisms  have been found in ground water
as contaminants.  Pollution sources are  many  and  include  virtually  any
source  that  affects  land  or  water.   Although ground water quantity is
vast, its quality must  be  diligently  protected  because  pollutants  are
very difficult and costly to remove from the subsurface.

To  protect  the ground water resource, EPA established an Office of Ground
Water  Protection  in  1984.   This  emerging  program  does  not  generate
environmental  data,  develop  regulations,  maintain  a  data  system,  or
conduct  special  studies.   Rather,  it  provides  assistance,   guidance,
direction,  and  program  approval.   The  focus  is on policy development,
inter- and intra-agency operational coordination for  resource  protection,
ground  water  monitoring  strategies,  and  a wellhead protection program.
EPA Regions implement the  wellhead  protection  and  other  programs  with
States  through  their  ground  water  program  offices.  Other EPA offices
support  the  Office  of  Ground  Water  Protection  in  data   collection,
regulations and data systems.

                           GROUND WATER RESOURCE

Each  day  approximately  4.2 trillion gallons of precipitation fall on the'
continental  United  States.   About  two-thirds  of   that   precipitation
evaporates,  about  61  billion  gallons   (1.5 percent) soak into aquifers,
and the remainder is carried away by streams and rivers.

Estimates  of the ground water resources of the U.S. found  within  one-half
mile  of   the  land  surface  range from 15 to 100 quadrillion gallons.  These
resources  are  50 times greater  than all of the Nation's surface  waters  at
any  given  time.  They are 35 times the total annual surface runoff and

                                     20

-------
 400  times  the country's  total water withdrawals.

 Ground  water  depletion and contamination are localized problems.  Ground
 water   availability   is   a   significant  issue  in  almost   every   State.
 Declining  ground  water levels  have  occurred  in  a  number  of  areas,
 including  portions   of   California,  the Dakotas, Illinois, Indiana, Iowa,
 and  Wisconsin.

 Fresh water withdrawals  from ground water more than  doubled  between  1950
 and  1980.   Crop  irrigation  alone  uses  60  billion  gallons per day of
 ground  water.  Other  major   users  include  public  water  supplies,  rural
 water   supplies,   and   industrial  withdrawals  from  other  than  public
 supplies.

                       POLLUTION CONCERNS AND SOURCES

 CHEMICAL:  About 245  different chemical substances have been found  in  the
 Nation's   ground  water   according  to  U.S. Congress' Office of Technology
 Assessment (OTA).    These   include  175   organic   chemicals   (including
 pesticides),  50  inorganic  chemicals,  and  20  different  radionuclides.
 Adverse health  effects associated with these contaminants include cancer;
 reproductive,  teratogenic,  and  pyschological  disorders;   and   adverse
 effects on  nearly all  body systems.  Contaminants, once they have entered
 ground  water, are difficult  and expensive to treat or remove.

 Ground  Water  velocities are  low  in   comparison   to   surface   water
 velocities;  thus,  a contaminant  introduced  into  a ground water system
 does not mix rapidly  with the existing water  in  the  aquifer.   Generally
 the  flow  paths,  concentration,  and  chemical changes that a contaminant
,may  undergo as a result  of   such  processes  as  degradation  or  reactions
 with the  soil  are  either  unknown or difficult to ascertain.  Identifying
 the  source and extent of contamination is made problematic by  the  complex
 physics and chemistry of the flow system.

 BIOLOGICAL:   The  OTA  study also found bacteria, viruses and parasites in
 ground  water during their survey.  Adverse health effects  associated  with
 these   biological  contaminants  are  similar  to  those  listed  above for
 chemicals.
                                     21

-------
SOURCES; Sources of ground water pollution are numerous and  varied.    (See
Table  1  on  next  page.)   High  on  the list of concerns of ground water
pollution control authorities  are  failing  systems  of  the  existing  23
million   domestic  septic  systems;  leaking  underground  storage  tanks;
agricultural activities including pesticide  and  fertilizer  applications,
Irrigation  return  flows,  and  animal  feedlot runoff; landfills; surface
waste water impoundments; and abandoned waste sites.

                              PROGRAM CONTROLS

EPA's Office of Ground Water Protection was created in 1984  to  provide  a
focal  point  for  evolving agency ground water programs.  Efforts thus far
have  concentrated  on  policy   development,   inter-   and   intra-agency
operational  coordination  for resource protection, ground water monitoring
strategies, and wellhead protection.  EPA Regions implement  programs  with
States through their ground water program offices.

MONITORING;  In  1982, the US Geological Survey began a national program to
study toxic wastes and their behavior and  fate  in  aquifer  systems.   At
least  eight  separate  Federal  statues  require  ground  water monitoring
under specific conditions.  In  1985,  EPA  formulated  a  national  ground
water  monitoring  strategy  designed to coordinate many of these disparate
monitoring efforts.  The strategy  contains  an  action  plan  designed  to
characterize  the  Nation's ground water resource, identify new contaminate
problems,  assess  known  problems,  assure  compliance  with  regulations,
evaluate  program  effectiveness,  improve  data  quality,  and  develop  a
ground water data system for storing all ground water quality  and  related
well  information.   A  minimum  set  of  22 data elements necessary to use
information from wells and springs across  ground  water  related  programs
has  been  developed.   Thirty-eight States monitor ground,water quality or
are  developing monitoring programs.

WELLHEAD  PROTECTION;   There  are  187,000  public  drinking  water   well
systems  including  47,000  community  and 140,000 non-community facilities
such as camp grounds and truck stops.  The wellhead protection  program  is
designed  to  protect  the  surface  and  subsurface  areas  through  which
contaminants are likely to pass and eventually reach a well or well field

                                     22

-------
                                    TABLE  1

                  SOURCES OF GROUND WATER CONTAMINATION
CATEGORY I - Sources designed to discharge substances
Subsurface percolation (e.g.. septic tanks and cesspools)
Injection wells
   Hazardous waste
   Non-hazardous waste (e.g., brine disposal and drainage)
   Non-waste (e.g.. enhanced recovery, artificial recharge
      solution mining, and in-situ mining)
Land application
   Waste water (e.g.. spray irrigation)
   Waslewater byproducts (e.g.. sludge)
   Hazardous waste
   Non-hazardous waste

CATEGORY II • Sources designed to store, treat, and/or
   dispose of substances; discharge through unplanned
   release
Landfills
   Industrial hazardous waste
   Industrial non-hazardous waste
   Municipal sanitary
Open dumps, including illegal dumping (waste)
Residential (or bcal) disposal (waste)
Surface impoundments
   Hazardous waste
   Non-hazardous waste
Waste tailings
Waste piles
   Hazardous waste
   Non-hazardous waste
Materials stockpiles (non-waste)
Graveyards
Animal burial
Aboveg round storage tanks
   Hazardous waste
   Non-hazardous waste
   Non-waste
Underground storage tanks
   Hazardous waste
   Non-hazardous waste
   Non-waste
Containers
   Hazardous waste
   Non-hazardous waste
   Non-waste
Open burning and detonation sites
Radioactive disposal sites

CATEGORY Ill-Sources designed to retain
   substances during transport or transmission
Pipelines
   Hazardous waste
   Non-hazardous waste
   Non-waste
Materials transport and transfer operations
   Hazardous waste
   Non-hazardous waste
   Non-waste

CATEGORY IV • Sources discharging substances as
   • consequence of other planned activities
Irrigation practices (e.g.. return flow)
Pesticide applications
Fertilizer applications
Animal feeding operations
De-icing salts applications
Urban runoff
Percolation of atmospheric pollutants
Mining and mine drainage
   Surface mine-related
   Underground mine-related

CATEGORY V • Sources providing conduit or Inducing
   discharge through altered flow patterns
Production wells
   Oil (and gas) wells
   Geothermal  and heat recovery wells
   Water supply wells
Other wells (non-waste)
   Monitoring wells
   Exploration wells
Construction excavation

CATEGORY VI • Naturally occurring sources whose
   discharge Is created and/or exacerbated by
   human activity
Groundwater - surface water interactions
Natural leaching
Salt-water intrusion/brackish water upconing (or
   intrusion of other poor-quality  natural water)
Source:  Office of Technology Assessment, Protecting The Nation's Groundwater From Contamination.
          October 1984.
                                                  23

-------
that  supplies  a  public  water system.   Because the ground water around a
pumping well Is depressed as water 1s drawn Into  a  well,   wellhead  areas
are  most  vulnerable  to  pesticides,  fertilizers,  road  salts,  and other
contaminants  that  may  enter  near-surface  ground   water.    Government
management  activities  Include  land use regulation, land  acquisition, and
prohibition of specified  activities  1n  the  vicinity  of  the  wellhead.
Funding for Federal support of State programs has been authorized.

                            REGULATORY CONTROLS

EPA  does  not  develop  regulations for groundwater.  This 1s done by some
States.

                             QUALITY ASSURANCE

The EPA Office of Ground Water Protection does not  generate  environmental
data.    Basically,   it  provides  assistance,  guidance,   direction,  and
program approval.  No data system'presently  is  maintained,  although  one
is  being  developed,  as  described  in  the  above section on monitoring.
Quality  assurance  1s  provided  in  the  minimum  set  of  data  elements
mentioned above in the section on monitoring.  These  elements  have  seven
geographic   descriptors,   seven   well/spring   descriptors,   and  eight
sample/analysis descriptors.  However,  EPA  grants  are  provided  to  the
Universities  of  Texas  and  Wisconsin to maintain data systems for ground
water  quality and wellhead studies.  There are no  special   studies  except
for  those  conducted by the Office of Drinking Water, which were described
1n  the  chapter  on  drinking  water.   These  Involve  the   problem   of
agricultural chemicals In ground water.
                                      24

-------
                             SUGGESTED READING
1.   Cantor,  L.W.,  R.C.  Knox,  and D. M. Fairchild.  1987.  Ground Water
     Quality Protection, Lewis Publishers, Inc., Chelsea, MI.

2.   Freeze, R. Allen and John A. Cherry.   1979.   Groundwater.   Prentice
     Hall, Inc., Englewood Cliffs, NJ.

3.   Lehr,  Jay  H.   1977.   Ground  Water  -  Fact  and Fiction.  IN: The
     Integrity of Water.  US Environmental  Protection  Agency,  Office  of
     Water and Hazardous Materials, Washington, DC.

4.   Office  of  Technology  Assessment.   1984.   Protecting  the Nation's
     Groundwater from Contamination.  US  Congress,  Office  of  Technology
     Assessment, Washington, DC.

5.   US  EPA.   1985. .  Ground-Water Monitoring Strategy.  US Environmental
     Protection Agency, Office of Ground-Water Protection, Washington, DC.

6.   US EPA.  1987.  Improved Protection of Water Resources from Long-Term
     and Cumulative Pollution:  Prevention  of  Ground-Water  Contamination
     in  the  United States.  US Environmental Protection Agency, Office of
     Ground-Water Protection, Washington, DC.

7.   US EPA.  1987.  Wellhead Protection:  A  Decision-Maker's  Guide.   US
     Environmental Protection Agency, Washington, DC, EPA-440/6-87-009.

8.   US  EPA.   1988.   Developing a State Wellhead Protection Program.  US
     Environmental Protection Agency, Washington, DC, EPA-440/6-88-003.

9.   US EPA.  1988.  EPA Workshop  to  Recommend  a  Minimum  Set  of  Data
     Elements  for  Ground  Water.   US  Environmental  Protection  Agency,
     Washington, DC, EPA-440/6-88-005.
                                     25

-------
                            ESTUARIES AND OCEANS

                                  SUMMARY

Most of the principal population centers of the United States  are  located
within  100  miles  of  estuaries  and  near-shore  oceanic coastal  waters.
Consequently, rich aquatic resources found 1n these  waters  are  subjected
to  multiple,  conflicting, and often degrading uses; In addition, they are
the  ultimate  recipients  of  pollutants  transported  from  the  land,  by
rivers.   Contamination  concerns  are  similar  In   category   to   those
associated  with  freshwater,  except  for the addition of large quantities
of  floatable  materials.   These" floatable   materials,   which   Include
plastics,  bottles,  medical  wastes, other trash, pollutants from combined
sewer overflows, as well as from Illegal dumping from shore  and  ships  at
sea, have become the subject of significant public outrage.

The  ocean  dumping permit program, the national estuary program, and point
source discharges  to  the  marine  environment  are  managed  by  the  EPA
Regions.   The  programs  originate with the Office of Marine and Estuarine
Protection (OMEP).  These  programs  are  coordinated  with  several  other
Federal agencies who have statutory interest in oceans and estuaries.

Oce'an  dump  site  monitoring,  the  ocean  data evaluation system, and the
comprehensive national  estuary  program  operate  with  quality  assurance
programs.   Analytical  methods  for  the  estuarfne  and  marine ecosystem
components are being developed Into standard techniques by  the  Office  of
Marine and Estuarine Protection.

                               HATER RESOURCE

Estuaries,  coastal  waters,  and adjoining oceans comprise three-fifths of
the U.S.  International Boundary.  About 100 million people, more  than  one
out  of   every  three  U.S.  citizens, live within 100 miles of an ocean or
Great  Lakes  coast.   Estuaries  and  embayments  are   among   the   most
biologically  productive  waters  because  of  an  abundance  of nutrients.
shallow well-mixed   waters,  and  teeming  plant  and  animal  communities.
There  are over  150 large estuaries, myriad Inlets, and small embayments

                                     26

-------
in   the   United  States.   These  highly  productive  estuaries  are  the
transitional zones formed when rivers and ocean, meet.

The  oceans,  estuaries,  and  the  Great  Lakes  provide   for   multiple,
conflicting   human   uses   related  to  resource  extraction,  commercial
shipping,  recreational  boating,  body  contact  recreation,   sunbathing,
aesthetic  enjoyment,  drinking  water  supply,  and  waste  disposal.  The
estuaries  and  oceans  are   the   ultimate   recipients   of   pollutants
transported from the land by rivers.

                       POLLUTION CONCERNS AND SOURCES

PHYSICAL:  Solid  wastes  including  plastics, bottles, medical wastes, and
other non-biodegradable materials that  float  have  become  the  focus  of
public  concern  for  many  beaches  and  certain  parts of the open ocean.
Flotable  wastes  strangle  and  mutilate  wildlife,  as  well  as  destroy
habitats.  They originate principally from illegal dumping  of  trash  from
shore    or    ships    at    sea.     Other   sources   include   combined
sanitary-stormwater sewer overflows, wastewater treatment  plant  bypasses,
and ocean dumping.

Spills,  leaks,  and accidents including those from tankers and offshore or
coastal oil production rigs introduce  crude  oil  and  oil  products  into
water.   Results  include  ecosystem  destruction and death to fish, birds,
and marine mammals.  Death is caused by  toxicity  from  the  oil,  coating
the  animals,  drowning  through  loss of buoyancy, exposure caused by loss
of body heat insulation, or starvation.

CHEMICAL: These  come  from  a  variety  of  sources  including  industrial
wastes,  municipal  wastewater,  agricultural  and  urban runoff.  They are
primarily organic chemicals including chlorinated  hydrocarbons  and  heavy
metals.   Toxic  substances adversely affect fish, shellfish, wildlife, and
human health.  Major organism responses include death,  tumors  or  cancer,
bioaccumulation  with  threats  to  the  food web, and reduced reproductive
ability.
                                     27

-------
BIOLOGICAL; Bacterial or viral organisms that  cause  diseases   1n  humans,
including  diarrhea,  hepatitis,  and typhoid,  come from ingestion of water
at a beach or the consumption of contaminated  shellfish.    The  prevalence
of  these  organisms  in recent years has resulted in closures  of shellfish
beds and recreational beaches.  Excessive  marine  algal   and  other  plant
growths  resulting  from  high  nitrogen  and phosphorus concentrations are
problems in many estuarine and coastal areas.   Decomposing  plants  reduce
necessary  oxygen  for  aquatic  life,  algal  mats  smother  the  plankton
beneath them, and foul odors of decomposition fill the shoreline air.

SOURCES;  Many  types  of sources contribute to the above quality concerns.
Estuaries and  oceans  are  the  ultimate  receivers  of  wastes  from  the
continent  and  ships at sea.  Direct discharges, ocean dumping, stormwater
and runoff, spills, leaks, accidents,  and  illegal  solid  waste  disposal
are contributing sources.

                              PROGRAM CONTROLS

POINT  SOURCE  CONTROLS; The Clean Water Act has two sections applicable to
direct dischargers to  the  marine  environment:  it  requires   a  Publicly
Owned  Treatment  Works  to  provide  secondary treatment, but  allows  for a
waiver to  less  than  secondary  treatment  if  the  plant  meets  certain
criteria;  it  also  allows  regulators  to  consider  sediment, as well as
water column effects in issuing a discharge  permit,  and  is  intended  to
protect  unique,  sensitive, and ecologically critical species, in addition
to aquatic life in  general.   This  section  may  require  zero  discharge
following  assessment  of alternative disposal  or recycling options and the
Impact  of  alternative  uses  on  the  oceans.   Both   sections   require
site-specific evaluation of environmental information.

NATIONAL  ESTUARY  PROGRAM; Currently composed of 12 estuaries  located from
Massachusetts to Washington State, this program  has  four  phases  leading
to  cleanup.   These  phases  include  a management conference for decision
making, Information to characterize and define the  problems,  creation  of
a  comprehensive  conservation and management plan to identify  action  plans
for pollution control and resource management, and  implementation  of  the
plan.   Each  of  the  original  six  estuaries  in  this program will have
completed management plans In the early 1990s.

                                     28

-------
                            REGULATORY CONTROLS

OCEAN  DUMPING  PERMITS:   Regulations  and  criteria   controlling   ocean
dumping  as  described  in  40  CFR  220  through  229  are governed by the
requirements of The Marine Protection, Research  and  Sanctuaries  Act  and
The  International  Convention  on  the  Prevention  of Marine Pollution by
Dumping of Wastes and Other  Matter,  which  was  ratified  by  the  United
States  in  April, 1974.  EPA issues permits for non-dredged materials; the
U.S. Army Corps of  Engineers  issues  permits  for  dredged  materials  in
conformity  with  criteria  established  by EPA.  EPA specifies sites where
dumping may be permitted and develops  an  environmental  impact  statement
on  each  specified  site.   EPA  may  specify  areas of the ocean where no
dumping shall  occur.   The  law  has  prohibited  the  ocean  disposal  of.
certain  agents  of  war.  The Ocean Dumping Ban Act of 1988 terminates the
dumping of wastewater sludge and industrial wastes by December 31, 1991.

                          MULTIAGENCY COORDINATION

Several Federal agencies are  involved  in  studies  and  other  activities
related  to  estuaries  and  oceans.   The National Oceanic and Atmospheric
Administration (NOAA) is  dedicated  to  improving  the  comprehension  and
uses  of  the  physical  environment and oceanic life.  The Coastal  Program
Division in NOAA provides financial and technical  assistance  to  approved
State  Coastal  Zone  Management  Programs,  the  Estuarine  Program Office
which  coordinates  NOAA's  various   estuarine   activities,   the   Ocean
Assessment  Division,  and  the  Ocean Pollution Planning Office.  The U.S.
Army Corps of Engineers manages ocean dumping through  permits  of  dredged
material.   The  U.S.  Fish  and Wildlife service has review authority over
ocean dumping permits and discharges to  marine  waters.   Coordination  of
EPA  estuarine  and  ocean  programs  with  these  Federal  agencies  is an
ongoing activity.

                             QUALITY ASSURANCE

MONITORING:  Ocean  dump  sites  are  monitored   by   EPA   to   determine
environmental  impacts  and  to  ensure that adverse effects as a result of
dumping are confined to the dumpsite.  When a survey plan is prepared for

                                     29

-------
monitoring a dumpsite, a quality assurance project plan 1s developed.

DATA SYSTEM; EPA's Ocean Data  Evaluation  System  contains  water  quality
data,  tissue  data,  and  sediment data for the marine environment.  There
Is strict control of data entry.  Data related  to  the  conditions  for  a
waiver  to  less  than  secondary  treatment are checked by a biologist for
reasonableness and methods  used  to  obtain  the  data.    Other  data  are
checked electronically for conformance to a designated range of values.

                              SPECIAL STUDIES

NATIONAL ESTUARY PROGRAM; Twelve estuaries are undergoing intensive study.
Each  has  a  number  of  specific study efforts, perhaps 12 to 15 for each
estuary.  One such effort may  concentrate  on  sediments  and  constituent
concentrations,  while  another  may  examine  the  biota  including  fish,
benthos,  and  plankton.  Each of the individual study efforts must have an
approvable quality assurance project plan.  OMEP has prepared a  Guide  for
Preparation  of  Quality Assurance Project Plans for the National Estuarine
Program  (EPA-556/2-88-001).   Two  of  the  intensive  estuarine   studies
operate  under  a  quality  assurance  program plan approved jointly by the
EPA Regional Quality  Assurance  Officer  and  the  Office  of  Marine  and
Estuarine Protection Quality Assurance Officer.

CHESAPEAKE  BAY  OVERSIGHT;  Chesapeake  Bay  1s the largest estuary 1n the
contiguous United States, one of  the  most  productive  estuaries  In  the
world,  and  potentially  the most complex ecosystem anywhere.  It receives
wastes from 3,000 point source discharges in Maryland  and  Virginia.   Its
nutrients,   sediment,  water,  plankton,  benthos,  fish,  shellfish,  and
vegetation  are  being  monitored  at  50   ma1nstern   and   85   tributary
locations.   Data  are  screened  by  a  computer  programmed  to  Identify
          /
outliers.   The  monitoring  program  operates  under  a  quality assurance
program plan.

ANALYTICAL  METHODS;  Analytical   methods   for   estuarine   and   marine
environmental  studies  currently are not as advanced as for the freshwater
environment.  The Office of Marine and Estuarine Protection  Is  developing
a compendium  of  satisfactory analytical methods.

                                     30

-------
                             SUGGESTED READING
1.  40 CFR 220 through 229.
2.  Anikouchine,  William  A.  and  Richard W. Sternberg.  1981.  The World
    Ocean: An Introduction to  Oceanography.   (2nd  Ed.)   Prentice  Hall,
    Inc., New York.

3.  Gross, M. Grant.  1982.  Oceanography: A Viev/ of the Earth.   (3rd Ed.)
    Prentice Hall, Inc. New York.

4.  Harvey,  H.  W.   1960.   The  Chemistry  and  Fertility of Sea Waters.
    Cambridge University Press, New York.

5.  Hedgpeth,  J.  W.,  Ed.   1957.   Treatise  on   Marine   Ecology   and
    Paleoecology.    I.  Physical  and  Chemical  Characteristics  by  K. 0.
    Emery and R. E. Stevenson.  II. Biological Aspects by  J.  W.  Hedgpeth.
    Geol. Soc. Amer., Memoir 67.

6.  Hill,  G.  H.,   Ed..  1964.  The Sea, Volume II.  The Composition of Sea
    Water; Comparative and Descriptive Oceanography.   Wiley  Interscience,
    New York.

7.  Lauff,   G.  H.,  Ed.  1967.   Estuaries.   Publication  83.   American
    Association for  the Advancement of Science, Washington, DC.

8.  Sverdrup, H. I., M. W. Johnson and R. H. Fleming.  1946.   The  Oceans,
    their Physics, Chemistry and Biology.  Prentice Hall, Inc., New York.

9.  US  EPA.   1988.   Guide  for  Preparation of Quality Assurance Project
    Plans  for  the   National   Estuarine   Program.    US   Environmental
    Protection Agency, Washington, DC, EPA 556/2-88-001.
                                     31

-------
                                  WETLANDS

                                  SUMMARY

Wetlands,  Including  marshes,  swamps,  and bogs, provide food and habitat
for water, air, and land animals; spawning and nursery  areas  for  aquatic
life;   sanctuary  for  rare  and  endangered  species;  flood  protection;
erosion  control;  wood  and  other  products;  hunting  and  fishing;  and
aesthetic enjoyment.  Once regarded by  humans  as  wastelands  and  a  tax
burden,   they  were  destroyed  at  random  until  the  Nation's  wetlands
resource was diminshed by more than half.   Now  recognized  as  among  the
most  productive  ecosystems  and as essential to the survival of many fish
and other species, they are being protected.

Wetlands protection began after the  enactment  of  the  1972  Clean  Water
Act,  which  required  a  permit  for  the  discharge  of  dredged  or fill
materials into the waters of the United  States.   The  gradual  growth  of
that  program  resulted  in  an  Office of Wetlands Protection in EPA.  The
focus of  EPA's  program  has  been  on  the  development  of  guidance  to
identify  wetlands  and  their  boundaries  in a consistent manner, enhance
monitoring capabilities and requirements, and require  mitigation  and  the
creation  of  new  wetlands elsewhere when wetland areas must be destroyed.
While the US Army Corps of Engineers issues permits for  the  discharge  of
dredged  and  fill  material,  EPA  has review authority and the ability to
veto action over permits when  environmental  quality  may  be  threatened.
No environmental data presently is generated by EPA concerning wetlands.

                             WETLANDS RESOURCES

Wetlands  is  a  collective  term  for  marshes,  swamps, bogs, and similar
areas that are either inundated or saturated by water  during  the  growing
season   so  that  they support a prevalence of vegetation typically adapted
for life in  saturated  soil  conditions.   Wetlands  are  among  the  most
productive  natural  ecosystems  1n  the  world.   They are critical to the
survival of a wide  variety of animals and plants.  They  provide  food  and
habitat,  Including that  necessary  for   spawning and growth for fish and
wildlife, Improvement In water quality, flood protection, erosion control,

                                     32

-------
natural products  for  human  use,  and  opportunities  for  a  variety  of
recreation  and  aesthetic  enjoyment.   A  number  of  rare and endangered
species depend upon wetlands for survival.

The need for wetlands protection is evident  from  the  fact  that  of  the
original  215  million  acres  of  wetlands in the lower 48 states, only 99
million acres, or 46 percent, remained as of the mid-1970s.   Between  1955
and  1975,  11  million  acres  were  lost  while  2  million  acres of new
wetlands were created; the  net  loss  equals  an  area  the  size  of  New
Jersey.    The   most   extensive   losses   have  occurred  in  Louisiana,
Mississippi, North Carolina, the Dakotas, Nebraska, Florida, and Texas.

                       POLLUTION CONCERNS AND SOURCES

PHYSICAL; Major causes of wetlands loss and  degradation  through  physical
means  include  drainage,  dredging  and  stream  channelization,  filling,
diking  and  damming,  tilling  for  crop  production,  grazing by domestic
animals, and any actions that lead to flow alteration.

CHEMICAL; Although wetlands are efficient  in  stabilizing  organic  wastes
and  removing  suspended  solids,  they are affected by toxic and hazardous
wastes in a manner similar to surface waters.   Wetlands  are  particularly
vulnerable  because  they  are inhabited by the very young of aquatic life.
Persistent, bioaccumulative, toxic, organic  chemicals  head  the  list  as
destructive  forces  in  this  type of ecosystem.  The food web in wetlands
extends from small invertebrates  through  fish  to  predator  animals  and
humans.    There  is  a  broad  problem  with  contamination  of  wetlands.
Irrigation return flows  have  introduced  high  selenium  levels  in  some
western  areas  that  have  resulted  in deformed ducks in refuges.  Boron,
heavy metals, and PCBs have created pollution problems in many areas.

SOURCES; Agricultural drainage of wetlands was responsible, for  87  percent
of  wetlands  losses  between  the  mid-50s  and  mid-70s.  Urban and other
development  accounted  for  the  remaining  13  percent  of  the   losses.
Irrigation  return  flows  in  the West, and both point and nonpoint source
pollutant discharges are responsible for the chemical  pollutant concerns.
                                     33

-------
                              PROGRAM CONTROLS

GUIDANCE; Guidance has been provided by EPA to States and  eligible  Indian
Tribes  on  the  designation  of wetlands as surface waters of a State, the
application of water quality standards  and  dredge  and  fill  permits  to
wetlands,  and  the  use  of  the Clean Water Act Section 401 certification
process for a federally permitted or licensed activity (See  EPA,  1989  in
Suggested Reading).

MONITORING;  Currently,  there  is  insufficient  monitoring in wetlands to
fully understand  their  environmental  complexities.   Efforts  are  being
                          v
made  to  bring  wetlands  into  national  monitoring programs and into the
water quality reports submitted biennially  by  States  and  summarized  by
EPA  as  a  National  Water  Quality  Inventory  Report to Congress.  These
efforts require the development of  water  quality  criteria  for  wetlands
and  the  identification of satisfactory monitoring indicators to represent
biological integrity.

EVALUATION TECHNIQUES; A goal of this emerging program is  to  ensure  that
wetlands   are  identified  consistently  and  that  their  boundaries  are
established consistently throughout the  Nation.   To  meet  this  need,  a
Federal  manual  for  identifying  and  delineating jurisdictional wetlands
was developed as an interagency cooperative publication by  EPA  and  three
other agencies whose interests include wetlands.

MITIGATION;  When  wetlands  destruction  may occur as a result of a permit
to dredge or fill, mitigation  is  required.   Such  mitigation  takes  the
form  of  stopping  the  discharge  of dredged or fill material, minimizing
such discharge, and/or creating new wetlands In another location.

                            REGULATORY CONTROLS

The US  Army Corps  of Engineers issues permits  under  Section  404  of  the
Clean   Water  Act   for   the  discharge of dredged or fill materials through
the application of EPA guidelines developed  to  protect  the  environment.
The  EPA guidelines take  the form of specifications for disposal sites for
dredged or  fill material.  The guidelines prohibit  the discharge of

                                     34

-------
dredged or fill material if there could be a violation  of  any  applicable
State  water  quality  standard  and  stresses  that a filling operation in
wetlands  is  considered  to  be  among  the  most   severe   environmental
impacts.   EPA  maintains  review  authority  over permit issuance.  In the
final analysis, EPA has veto power over an action by the US Army  Corps  of
Engineers  to  issue  a  specific  permit.   The  procedures and conditions
under which this can occur are contained in 40 CFR Part 231.   In  addition
to  these  regulations,  there are others that specify the conditions under
which a State may administer its own program in lieu of the US  Army  Corps
of Engineers.

                             QUALITY ASSURANCE

The  Office  of Wetlands Protection does not generate data, but coordinates
with other agencies and Offices within EPA, to  obtain  program  data.    It
maintains  a  data  system  of  State  wetlands  programs  and the wetlands
associated with such programs.  The US Army Corps  of  Engineers  maintains
a  programmatic  data  system,  used  by  EPA,  that  contains regulations,
policies, and  an  information  bulletin.   No  special  quality  assurance
programs are involved.

                              SPECIAL STUDIES

No  special  studies of a national scope are conducted by EPA.  The US  Fish
and  Wildlife  Service  conducts  a  national  trend  analysis  related  to
wetlands destruction  that  is  based  upon  3,700  two-mile  square plots
throughout the United States.
                                     35

-------
                             SUGGESTED READING

1.  40 CFR Parts 230, 231. and 233.

2.  Anon.    1989.     Federal   Manual   for  Identifying  and  Delineating
    Jurisdictional  Wetlands.  An Interagency Cooperative  Publication.    US
    Army  Corps  of  Engineers, US Environmental  Protection Agency, US  Fish
    and Wildlife Service, and USDA Soil Conservation Service.

3.  COE.  1987.  Wetlands Evaluation  Technique.    Volume  II   Methodology.
    US  Army  Corps  of Engineers, Waterways Experiment Station, Vicksburg,
    MS.

4.  Hammer, Donald A.,  Ed.  1989.   Constructed   Wetlands  for  Wastewater
    Treatment.  Lewis Publishers, Inc., Chelsea,  MI.

5.  Leopold,  Aldo.   1949.   A  Sand  County  Almanac.   Oxford University
    Press, New York.

6.  T1ner, R. W. Jr, 1984.  Wetlands of the United States:  Current  Status
    and Recent Trends.  US Fish and Wildlife Service, Washington, DC.

7.  US  EPA.   1988.   America's  Wetlands: Our Vital Link Between Land and
    Water.    US   Environmental   Protection   Agency,   Washington,   DC,
    OPA-87-016.

8.  US EPA.  1989.  Wetlands  and  401  Certification.   Opportunities   and
    Guidelines  for  States  and  Eligible Indian Tribes.  US  Environmental
    Protection Agency, Office of Wetlands Protection  (A104F),  Washington,
    DC.
                                      36

-------
                          AIR QUALITY: INDOOR AIR

                                  SUMMARY

Indoor  air  quality  is  becoming  a major cause of employee complaints in
the  office  environment.   Residential   indoor  air  quality  is  even  of
greater'concern because persons have contact with it for  a  longer  period
of  time  and  often  do  not  realize  that  they have a problem.   A large
number of physical, chemical, biological, and radiological   pollutants  are
associated  with  indoor  air.   Many  can  lead to serious health  effects.
These pollutants come from stoves, heaters,  building  materials,  carpets,
pets,  hobbies,  tobacco  smoke,  household chemicals,  some water supplies,
motor vehicles in attached garages, and  the  soils  and  rocks  beneath  a
house.

EPA  has  established a new program in the Office of Atmospheric and Indoor
Air  Programs  to  deal  with  the  problems  associated  with  indoor  air
quality.  Although this program does not now have  statutory  authority  to
generate  regulations,  other  EPA  Offices  have  produced regulations for
certain  pollutants.   Major  programs  for  indoor  air  quality   control
include    asbestos,    radon,    formaldehyde   in   building"  materials,
environmental tobacco  smoke,  volatile  organic  compounds,  and  building
ventilation.
                                     37

-------
                       POLLUTION CONCERNS AND SOURCES

PHYSICAL:   Indoor  air  sources  can  emit  products  of  combustion  from
appliances,   dirt,   dust,  asbestos,   fabric  fibers,  insect  parts  and
environmental   tobacco  smoke  that  may   cause   eye   and   respiratory
Irritation,   respiratory  function  impairment,  allergic  and  infectious
diseases, asbestosis, and cancer.

CHEMICAL;  Many chemicals are emitted within a building from  household  or
commercial   products   by  evaporation,  combustion,  volatile  breakdown,
degassing or intentional use.   .A  partial  list  includes  the  following.
Inorganic  gases  such  as  nitrogen  dioxide,  carbon monoxide, and sulfur
dioxide can cause eye  and  respiratory  irritation,  neurotoxicity,  blood
effects,  and  respiratory function impairment.  Volatile organic compounds
such as kerosene and mineral spirits  can  cause  neurotoxicity.   Aromatic
hydrocarbons  such  as  toluene, styrene, ethylbenzene, benzene and xylenes
can cause liver and kidney effects, blood effects,  leukemia,  and  anemia.
Halogenated  carbons  such  as methylene chloride, 1,1, 1-trichloroethane,
chlordane, ethylene dichloride,  freon,  PCBs,  carbon  tetrachloride,  and
chloroform   can   cause  liver  and  kidney  effects,  neurotoxicity,  and
cancer.  Alcohols such as ethanol, methanol, ethylene glycol,  phenol,  and
cresol  can  cause  developmental  effects,  neurotoxicity,  and  liver and
kidney effects.  Ketones such as acetone, methyl ethyl  ketone  and  methyl
isobutyl  ketone  can  cause  developmental effects and eye and respiratory
irritation.  Aldehydes such as  formaldehyde can cause eye  and  respiratory
irritation  and  cancer.   Organic  pesticides  such as malathion can cause
neurotoxicity.

There are many more.   It should be noted  that many of these  chemicals  may
be   present   as   the   volatile   breakdown  products  of  materials  of
construction,  dry  cleaning,   pressed  wood,  Insulation,   carpets,   and
spray-on  materials,  etc.    It 1s  cautioned that the effects, noted above
may not  necessarily occur at  indoor exposure levels.    In  many  cases  the
exposure  data  are   Insufficient  to  determine  the  levels  at which the
listed effects will  occur.
                                     38

-------
BIOLOGICAL;  Many potential sources of biological irritants  and  toxicants
may  be  found  in  residential  and  commercial buildings.  In many cases,
they are of much greater concern indoors than  out  because  of  the  close
proximity,  closed  environment,  and  fertile breeding grounds.  Among the
potential concerns, bacteria  and  viruses  can  cause  illnesses  such  as
Legionnaire's  disease,  and  pneumonitis.   Animal dander and excreta, and
molds  and  mildews  can  cause  respiratory   irritation,   allergic   and
infectious diseases, and produce immune effects.

RADIOLOGICAL;   Radon  found  in  soils and rocks beneath a house can cause
cancer.  Electromagnetic radiation from nearby  high-voltage  power  lines,
appliances  and  television  sets  is  suspected  of  causing reproductive,
developmental, and neurobehavioral effects, as well as cancer.

SOURCES;  Sources of all of these  air  pollution  problems  are  many  and
varied;  they  include  gas  stoves,  kerosene heaters, building materials,
human activities, pets, insects, arachnids, pesticides,  combustion  fuels,
painting  supplies,  hobby  supplies,  solvents,  cleaners,  tobacco smoke,
toilet deodorizers, fabric protectors, adhesives, certain  cosmetics,  some
tap  water,  motor  vehicles  in  attached garages, facilities  such as damp
basements and air conditioning cooling  towers  that  serve  as  bacterial,
viral  and  fungal breeding grounds, the soils and rocks beneath a building
and nearby power lines.
                              PROGRAM CONTROLS

Title IV of the  Superfund  Amendments  and  Reauthorization  Act  of  1986
directed  EPA  to  establish  an  indoor  air  quality research program, to
coordinate  with  other  public   and   private   organizations,   and   to
disseminate  Information  on  indoor air quality issues to the public. This
new program, based in the Office of Atmospheric and  Indoor  Air  Programs,
has  used  EPA  programs and laws other than the Clean Air Act to implement
controls on indoor air  pollutants,  since  the  Clean  Air  Act  does  not
directly  address  Indoor  Air  Quality.  Among the existing and developing
programs within EPA that deal with indoor air are the following.
                                     39

-------
ASBESTOS;   The  asbestos  program  1s  a  major  national    program   that
encompasses  the  full range of regulatory, grant, and technical  assistance
activities.  It responds to the Asbestos  Hazard  Emergency  Response  Act,
the  Asbestos  School  Hazard  Abatement  Act,  and  the  Toxic  Substances
Control  Act.   EPA  has  published  a  rule on proper asbestos Inspection,
management planning and appropriate response actions in  schools,  as  well
as  a  model  accreditation  plan to provide for training and accreditation
of persons who inspect  school  buildings,  develop  management  plans,  or
design    and   conduct   response   actions.    Several   asbestos-related
regulations  have  been  issued  under  the  Clean   Air   Act,   Including
regulations  specifying  workplace  procedures  to  use  1n demolitions and
renovations  where  asbestos  is  present.   Under  the  Toxic   Substances
Control  Act,  a  rule  was Issued to extend worker protection in abatement
activities, to ban certain asbestos products and phase out others.

RADON;  EPA estimates that about 20,000 lung cancer deaths  each  year  may
be  attributable  to  indoor  radon, and as many as 8 million houses may be
affected.  The Indoor Radon Abatement Act was  signed  Into  law  1n  1988.
The    action   program  consists  of  problem  assessment,  mitigation  and
prevention, capability development, and public  Information.   Standardized
measurement  protocols  have  been  Issued.   The mitigation and prevention
program includes demonstrations and evaluations of  cost-effective  methods
to  reduce  radon  levels  in  existing  homes  and  the identification and
evaluation of ways to prevent elevated radon levels in new construction.

FORMALDEHYDE;  EPA 1s currently Investigating the need for,  and  potential
nature of,  additional  Federal  regulations  under  the  Toxic Substances
Control Act affecting formaldehyde emissions  from  pressed  wood  products
such   as  particleboard,   hardwood  plywood  paneling,  and  medium density
flberboard.

ENVIRONMENTAL TOBACCO SMOKE:   Reports  published  by  the  Surgeon  General
and   the   National   Research   Council  of   the National Academy of Sciences
conclude  that exposure to  environmental  tobacco smoke 1s a  cause  of  lung
cancer 1n healthy nonsmokers  and  Is responsible for other health
                                      40

-------
effects.   Published  risk  estimates  of  lung  cancer  in nonsmokers from
environmental tobacco smoke range from about 4,000  to  50,000  deaths  per
year.   EPA  has undertaken activities including research, risk assessment,
and public information.  EPA has no regulatory authority in this area.

VOLATILE ORGANIC COMPOUNDS;  Chronic  exposure  to  some  volatile  organic
compounds  is  suspected  to  contribute  to mortality from cancer.  Common
sources include building materials  and  furnishings,  paints  and  related
products,   cleaning,   disinfecting   and   odor   control  products,  and
pesticides.   EPA.is  conducting  research  under  the  Toxic   Substances
Control Act on building materials and furnishings in chamber laboratories.

BUILDING  VENTILATION;   Another program promoted by the indoor air program
is that of building ventilation.  The air  we  breath  while  at  work  can
affect  our  job performance, comfort, general sense of well being, and our
health.  With millions of Americans working in  buildings  with  mechanical
heating,   ventilation,   and   air-conditioning   systems,   the  system's
efficiency and effective  operation  can  well  determine  our  indoor  air
quality.   For  example,  when  ventilation  is  inadequate,  excess carbon
dioxide produced by people  breathing  accumulates.   Building  spaces  may
become  stuffy,  and  occupants grow drowsy, get headaches, and function at
lower activity levels.   Ventilation  rates  specified  in  local  building
codes  often  are  not  enforced  and  in  many jurisdictions the rates are
designed to conserve energy rather than promote Indoor  air  quality.   EPA
has  no  regulatory  authority  in  this  area.   The  American  Society of
Heating,  Refrigerating,  and  Air   Conditioning   Engineers   establishes
ventilation  rate  procedures  which become mandatory ventilation standards
when adopted by applicable building codes.  EPA promotes the  concept  that
energy  costs  should  be  balanced with indoor air quality considerations,
as well as employee health and productivity costs.

                             QUALITY ASSURANCE
                   /
The asbestos program consists of detailed regulations on  how  samples  are
taken  and  analyzed.  Certification is required of asbestos Inspectors and
removers.  The sampling process requirements are built around  the  concept
of QA/QC.  Similarly, regulations are provided for formaldehyde.

                                     41

-------
The  generation  of  most environmental  data as they may affect indoor air,
however, are conducted by EPA and Federal  offices  other  than  the  Office
of  Atmospheric  and  Indoor  Air  Programs.  Quality assurance and quality
control are provided these data by the  respective  offices  that  generate
them.   These  include  such  data  as  radon  measurement  and indoor auto
emissions.

The  radon  program  conducts  proficiency  evaluations  of  private  radon
measurement  companies  and  non-commercial  laboratories  who  voluntarily
demonstrate  their  measurement  capacities.   Several  States  use   these
proficiency  evaluations  as  a basis for regulating measurement companies.
A radon mitigation contractor proficiency program is under development.

                              SPECIAL STUDIES

An   example  of  a  special  study  was  the  Total   Exposure   Assessment
Methodology    (TEAM)   study   to   directly   measure  human  exposure  to
pollutants.    The  study  focused  on  volatile   organic   compounds   and
developed  methods  to  measure Individual total exposure and the resulting
body   burdens  of  toxic  and  carcinogenic  chemicals.   The  TEAM   study
Involved  600  participants  from New Jersey, North Carolina, North Dakota,
and  California.  These  participants  were  chosen  to  represent  a  total
population  of  700,000.   Inhalation  provided  greater than 99 percent of
the  exposure risk for 10  of 11 target volatile organic compounds studied.
                                      42

-------
                             SUGGESTED READINGS

1.    Meyer, Beat. 1983.  Indoor Air Quality.  Addison Wesley Pub; Co.,
      Inc. Reading, PA.

2.    Walsh, Phillip J., et al. (Eds.)  1984.   Indoor  Air  Quality.   CRC
      Press, Boca Raton, FL.

3.    US  EPA.   1987.   Indoor  Air Quality Implementation Plan, Report to
      Congress.   US  Environmental  Protection  Agency,  Washington,   DC,
      EPA-600/8-87-031.

4.    US   EPA.    1987    Preliminary  Indoor  Air  Pollution  Information
      Assessment.   Appendix  A   of   the   1987   Report   to   Congress.
      EPA-600-/8-87-031.

5.    US  EPA.   1988.   The  Inside Story:  A Guide to Indoor Air Quality.
      US    Environmental    Protection     Agency,     Washington,     DC,
      EPA-400/1-88-004.

6.    US   EPA.    1989.    Report  to  Congress  on  Indoor  Air  Quality.
      Executive Summary + 3 Volumes.  US Environmental  Protection  Agency,
      Washington, DC, EPA-400/1-89-001.

7.    Wallace,  L.A.    1987.   The  Total   Exposure  Assessment Methodology
      (TEAM) Study: Summary and Analysis:   Volume  I.   U.S.  Environmental
      Protection Agency,^ Washington, DC.

8.    U.S. EPA.  1986.  Indoor Radon Fact Sheets.
                                     43

-------
                        AIR QUALITY:  MOBILE SOURCES
                                  SUMMARY
The  Clean  Air  Act  provides  for  the  regulation of on-road vehicle and
commercial aviation emissions.  Proposed revisions to  the  Act  now  under
consideration   would   authorize   the   regulation  of  off-road  vehicle
emissions as well.  Mobile sources contribute as  much  as  60  percent  of
the urban air toxics emissions.

EPA's  Office  of Mobile Sources undertakes a number of programs to curtail
emission pollution.  Technology within the  auto  industry  is  continually
assessed.    Testing   procedures   often   must  be  developed  to  enable
laboratories to conduct reliable and repeatable  tests.   There  are  three
principal  testing  procedures  associated with the sale of motor vehicles.
Before a manufacturer can offer a motor vehicle  for  sale,  a  certificate
of  compliance  with  emission  standards  must  be  obtained.   This  is a
preproduction  test  where  the  prototype  design  model  must   pass   an
emissions  test  conducted  under  EPA  inspection  before the model can be
offered for sale.  Second, as cars are produced on the assembly  line,  EPA
representatives   randomly   select   some  for  emission  testing  by  the
manufacturer.  If enough of the vehicles tested  fail  to  meet  standards,
the  manufacturer  must  make  a  change  in  the  design of the vehicle to
correct the problem.   Third,  random  vehicles  in  use  are  selected  to
determine  their  emission levels after they have been purchased and driven
by their owners.  These tests are conducted with the owners'  consent.   If
a  substantial  number  of any class of vehicles do not conform to emission
standards during their useful lives, they may be subject to  an  EPA  order
to  recall  the  vehicles.    In  addition,  EPA coordinates with States and
cities in their vehicle inspection programs and provides  the  public  with
Information  on  its  fuel  economy  program for new model cars and trucks.
Regulations are promulgated to provide the structure  and  enforcement  for
these pollution abatement programs.
                                     44

-------
A  data  system  is  maintained  for  the  data  collected  in  the  in-use
emissions  testing  program.   This  system  provides  data  for predicting
emissions from future model vehicles and  for  requiring  manufacturers  to
recall  a  class  of  vehicles  that  fails  to  conform  to  the  emission
standards.

                       POLLUTION CONCERNS AND SOURCES

The  pollutants  and  their  sources  of  concern  to  the Office of Mobile
Sources are those found in emissions from motor vehicles in  operation,  as
well  as  the  volatilization  of  fuels  that  are being pumped into those
vehicles.  Currently there is authority  for  regulating  on-road  vehicles
only.   The  revisions  to  the Clean Air Act now under consideration would
authorize  regulating  off-road  vehicles  as  well,  which  would  include
railroads,  boats,  construction  equipment,  motorized   farm   equipment,
lawnmowers,  and  similar equipment.  Specific regulated pollutants include
particulates, hydrocarbons, carbon  monoxide,  oxides  of  nitrogen,  lead,
and the vapors from gasoline and other fuels.

Hydrocarbons  from  combustion processes and gasoline vapors can react with
the oxides of nitrogen from motor  vehicles  in  sunlight  to  form  ozone.
The  ozone,  formed  in  the  lower  atmosphere, contributes to respiratory
problems, eye irritation and crop  damage.   Nitrogen  dioxide  causes  the
yellow-brown  color  that  is sometimes seen in the urban atmosphere.   This
and other oxides of nitrogen may  affect  the  respiratory  system  causing
bronchitis, pneumonia and lung infections.

Carbon  monoxide  is  a  colorless,  odorless and poisonous gas produced by
the incomplete combustion of fuel.  Most of it comes  from  motor  vehicles
and,  thus,  is  especially bad in urban areas.  Carbon monoxide enters the
blood stream and binds to hemoglobin, reducing the transport of  oxygen  to
the  cells.   Persons  already in ill health can be more severely affected.
Even at low levels, carbon monoxide can affect mental function  and  visual
acuity.

Lead  is  a  toxic metal that tends to accumulate in the tissues of man and
other animals.  It is strongly suspected of producing subtle effects such

                                     45

-------
as  Impaired  neurologic  and  motor  development  and  renal    damage   in
children.    The  control  of  lead  in  gasoline  has  been  'exceptionally
successful; the lead in the atmosphere from cars has  gone down   97  percent
in the last 10 years.

                              PROGRAM CONTROLS

TECHNOLOGY  ASSESSMENT;   The  Office  of  Mobile  Sources keeps abreast of
technological developments within the auto industry in  order  to  be  able
to  advise  the  Administrator, other Federal  agencies,  and the Congress as
to the ability  of  the  industry  to  meet  emission  standards  and  fuel
economy goals.

TEST  PROCEDURE  DEVELOPMENT;   Once  a  need  for  control  is determined,
reliable and repeatable test procedures must  be  developed  and  published
to  enable  laboratories  to  conduct  identical  tests.   Test  procedures
generally  are  published  as  appendices  to  the  regulations.   One such
example  is  the  pollutant  characterization  of   currently   unregulated
vehicle  pollutants  and  fuel  additives  that have the potential of being
health hazards.  Special test procedures to  measure  levels  for  the  new
pollutants must be developed for this purpose.

VEHICLE  CERTIFICATION;   Before  a  manufacturer can offer a motor vehicle
for sale in the United States, a certificate of  compliance  with  emission
standards  must  be  obtained.  The  prototype  design  model   must pass an
emissions  test conducted under EPA  inspection  before  the  model  can  be
offered  for sale.

ASSEMBLY-LINE   TESTING;    As   cars  are  produced,  EPA  representatives
randomly select some  for  emissions  testing  by  the  manufacturer.   For
every  car randomly  selected for the manufacturer's test during an audit,
over a hundred cars are voluntarily tested  by  auto  producers  to  assure
that  the  audits  do  not  result  in  failures which could  affect vehicle
production.   If enough of the vehicles tested fail to meet  standards,  the
manufacturer  must  make  a  change in the design of the vehicle to correct
the problem.  Quality assurance 1s built into this program, as
                                     46

-------
well as  the  vehicle  certification  program  cited  above.   Confirmatory
tests  are  made  by the EPA testing laboratory at Ann Arbor, MI on some of
the same vehicles that the manufacturer tests.   EPA  personnel  audit  all
testing  procedures  from the selection of the vehicles to be tested to the
completion of the tests and the recording of the data.

SURVEILLANCE OF IN-USE VEHICLES:  Randomly selected  vehicles  in  use  are
chosen  to  determine  their emission levels after they have been purchased
and driven by their owners.  The results of  this  EPA  program,  conducted
with   the  cooperation  and  consent  of  the  vehicle  owner,  serve  two
purposes.  First, the data are used to  estimate  emission  rates  for  air
quality  planning  purposes  and  are  entered  into  a  computer  modeling
program  to  project  future  emission  levels  and  suggest whether new or
different control programs are necessary.  Second, Section  207(c)  of  the
Clean  Air  Act  authorized  EPA  to  order  the  recall  of  vehicles if a
substantial number of any  class  do  not  conform  to  emission  standards
during  their  useful  lives.  During 1987, a total of 1.5 million vehicles
were recalled as a result of  EPA  investigations.   In  the  same  period,
manufacturers  voluntarily  recalled  an additional 1.4 million vehicles to
correct emission problems.

FUEL ECONOMY TESTING;  Concurrent with  its  emission  testing,  EPA  tests
new  car  models  and  light trucks to determine their fuel economy.  These
data are made available to  the  public  through  the  annual  Gas  Mileage
Guide  published  in cooperation with the Department of Energy.  These data
also are used by the Department  of  Transportation  in  administering  the
fuel economy standards program.

VEHICLE  INSPECTION  PROGRAM:   Urban  areas which obtained an extension in
the deadline for attaining the ambient  air  quality  standards  for  ozone
and  carbon  monoxide  beyond  1982  are  required  by the Clean Air Act to
implement  an  inspection  and  maintenance  program.    To   assure   that
operating   inspection   programs   are   achieving  the  planned  emission
reductions, EPA has instituted a systematic auditing program.   Audits  and
follow-up  audits  have  indicated  major  operating problems in some areas
and have required several States to submit corrective plans.   Many  States
are switching to computerized analyzers in the inspection networks.

                                     47

-------
TAMPERING  AND  FUEL  SWITCHING;   EPA 1s responsible for  programs  to deter
tampering with vehicle emissions control   systems  or  the  use  of  leaded
fuel  in  vehicles  which require unleaded fuel.   Surveys  undertaken by EPA
have shown tampering and fuel switching to be continuing  serious  problems
which   undermine   the   emissions  control   performance   of  many,  in-use
vehicles,  particularly  those  of   fleets   such   as   taxi    cabs   and
municipalities.   The  1987  Motor  Vehicle Tampering Survey indicates that
about 19 percent of the vehicle fleet is subject to  gross  tampering,  and
about  7  percent  to  fuel  switching.  EPA promotes the  Implementation of
State and local  antitampering  enforcement  programs.  Tampering   or  the
removal  of  emission  control  equipment  1s  a Federal offense for repair
shops, while fuel  switching  is  a  Federal   offense  for  fleet  and  gas
station owners.

                            REGULATORY CONTROLS

Regulations  for  motor vehicles are to be found at 40 CFR Parts 85 and 86;
regulations for motor vehicle fuels are at 40 CFR Parts 79  and  80.   Fuel
economy  regulations  are  at  40 CFR Part 600.  Emission  standards are set
at  levels that are technically and economically  feasible   and  to   provide
maximum  health  protection achievable.  EPA provides enforcement for motor
vehicle  emissions  and  the  Federal  Aviation   Administration   provides
enforcement for commercial aviation standards.

One of  the  major  regulatory  actions  that has been very successful has
been the regulation of lead  In gasoline.  This activity  has  reduced  lead
emissions  from  motor vehicles by more than 90 percent.  The regulation of
hydrocarbons from tailpipe emissions also has been quite successful.

Limitations are placed  on   additives  other  than  lead  in  fuels,  e.g.,
ethanol.   Certain  characteristics  of  diesel  fuels  are regulated.  The
vaporization of gasoline while being pumped into motor vehicles,  which  is
a   major  source  of  urban  pollution,  Is  controlled by some cities that
require devices on  the fuel  Injector.   Legislation  now  In  Congress  may
require  additional  equipment on motor vehicles that will capture gasoline
vapor  and burn it.
                                     48

-------
                             QUALITY ASSURANCE

FIELD FACILITY;  The field facility and  motor  vehicle  testing  and  fuel
testing  laboratory  is  located  in _Ann Arbor, MI.  Contract laboratories
also are used.  The Office has a  quality  assurance  officer  in  its  Ann
Arbor facility.  The laboratory operates under a quality assurance plan.

DATA  SYSTEM;   Data from the testing of in-use vehicles are stored in MTS,
the Michigan  Telecommunications  System.   Such  data  include  background
information  on  the  vehicle  tested,   results  of the emission tests, and
responses to a routine  questionnaire  by  the  vehicle  owner.   Prior  to
entry  into  the  data  system,  a  contractor  manually checks the data to
determine that all required data are there  and. that  the  information  is
within  expected  bounds.   There  is  a  range  check  of  the data by the
computer and the contractor  reviews  any  information  that  the  computer
flags.   Data  from  the  system  are used in MOBILE-4, a computer model to
predict  emissions  from  future  automobile  models   and   to   determine
potential environmental effects based upon these predictions.

                              SPECIAL STUDIES

OFF-ROAD  VEHICLES:   A  review of available information is being conducted
on emissions from ofNroad vehicles, particularly diesel  engines  used  in
railroads,  farming,  and construction equipment.   This study  is being done
in anticipation of potential changes  to  the  Clean  Air  Act  that  would
include such vehicles within the regulatory framework.

ALTERNATIVE  FUELS;   Alternate  fuels   and  alternative vehicles are being
examined  as  an  opportunity  for  further  vehicle  emissions  reduction.
Alternative fuels currently being examined include  methanol   and  ethanol,
natural  gas,  which  principally  is  methane  and   liquid petroleum gas,
which is propane  and  butane  or  a  combination  of  the  two.    Electric
powered  vehicles  also  are being examined.  The alternative  fuels program
is supported both by EPA personnel and  through contract funding.
                                     49

-------
                             SUGGESTED READING

1.    Patterson,  D.  J.  and  N.   A.   Henein.    1972.     Emissions   from
      Combustion  Engines  and  their Control.  Ann Arbor Publishers, Inc.,
      Ann Arbor, MI.

2.    US EPA.  1989.   Progress  In  the  Prevention  and  Control   of  Air
      Pollution   in   1987.   A  Report  to  Congress.    US  Environmental
      Protection Agency, Research Triangle Park, NC, EPA-450/2-89-009.

3.    US EPA.  1989.  Status of Selected Air  Pollution  Control  Programs.
      US  Environmental  Protection  Agency, Office of Air Quality Planning
      and Standards, Research Triangle Park, NC.

4.    US EPA. 1989.   Fundamentals  of  Air  Pollution  and  Motor  Vehicle
      Emissions  Control,  Training  Manual.  US  Environmental  Protection
      Agency, Office of Mobile Sources, Washington, DC.
                                      50

-------
                      AIR QUALITY: STATIONARY SOURCES

                                  SUMMARY

EPA  has  set  National  Ambient  Air Quality Standards (NAAQS) for six air
pollutants; ozone, oxides of nitrogen, carbon monoxide,  lead,  particulate
matter,  and  sulfur  dioxide.   A  geographic area is termed in attainment
for a specific pollutant if the ambient  concentration  is  less  than  the
standard;  it  is  in  non-attainment  if  the  concentration  exceeds  the
standard.   The  attainment status is determined through direct measurement
of the six pollutants by the State and  Local  Ambient  Monitoring  Station
(SLAMS)   Networks.   These  networks  of  fixed  monitors  are  developed,
deployed, and operated according  to  uniform  criteria  specified  in  the
regulations.

In  addition,  the  States  and  EPA  monitor the ambient concentrations of
many air pollutants that are  not  specifically  regulated.   For  example,
many  States  measure ambient concentrations of acid deposition parameters,
volatile   organics,   other   metals,   benzo-alpha-pyrene    and    other
semi-volatiles,  along  with meteorological parameters needed for pollutant
transport modeling.

The stationary source compliance program  focuses  on  the  six  pollutants
for  which  EPA has specified National Ambient Air Quality Standards and on
the  hazardous  air  pollutants  for  which  EPA  has  designated  National
Emission Standards for Hazardous Air  Pollutants  (NESHAPS).   Examples  of
stationary  sources  include  power  plants,  factories, or waste treatment
facilities that generate various  air  pollutants  and  emit  them  through
stacks  or  as fugitive emissions.  This program is based on the permitting
process, in which specific sources that  apply  for  permits  to  construct
and  operate  facilities  are  tested to demonstrate compliance with permit
conditions,  and  are  audited  to  confirm  continuing   compliance.     In
general,  EPA  delegates  authority to administer the compliance program to
States through the State Implementation  Plans  (SIPS)  or  through  direct
delegation  of  specific  Federal  programs such as NESHAPS, the Prevention
of Significant Deterioration (PSD), or  New  Source  Performance  Standards
(NSPS).

                                     51

-------
The  most  important  data  elements  relate to the demonstration of source
compliance, usually in the form of stack emission tests,   overseen  by  EPA
or  State  QA  personnel.  Emission data, along with compliance information
are stored in a  large  national  data  base,  the  Aerometrfc  Information
Reporting System (AIRS).
                       POLLUTION CONCERNS AND SOURCES

Not  a  respecter  of  boundaries,  the effects of air pollution frequently
appear  far   from   their   source.    Atmospheric   pollution,   however,
principally  is  an  urban  problem.   Most  air  pollution from stationary
sources  comes  from  industries  such  as  factories,  power  plants,  and
smelters.

EPA has set National Ambient  Air  Quality  Standards  (NAAQS)  based  upon
medical  and  other scientific evidence of health and environmental effects
for six pollutants.  These standards apply to ozone,  oxides  of  nitrogen,
carbon  monoxide,  lead, particulate matter, and sulfur dioxide.  Ozone and
smog are formed when volatile organic  compounds  and  oxides  of  nitrogen
interact   in   the  presence  of  sunlight.   Ozone  irritates  the  eyes,
aggravates  respiratory  problems,  and  causes  crop  damage.   Oxides  of
nitrogen  affect  the  respiratory  system  and   can   cause   bronchitis,
pneumonia,  and  lung  infections.   Lead,  which  can  come  from  battery
factories  and  non-ferrous  smelters,  is a dangerous pollutant because it
accumulates in body  tissues  (particularly  in  children)  and  can  cause
neurological  impairment  and  behavioral disorders.  Particulate matter is
a general term for airborne particles, some of which are seen in  the  form
of  smoke  or  dust;  some  are  too  small  to  be seen.  Particulates can
Irritate the  respiratory  system  and  may  carry  metals,  sulfates,  and
nitrates.   Sulfur  oxides, and particularly sulfur dioxide, come primarily
from the burning of coal and oil  and  various  industrial  processes.   In
the  atmosphere,  they  react to form sulfuric acid, sulfates and sulfides.
They can affect the respiratory system, especially when the  sulfuric  acid
settles on a fine particle which is inhaled.
                                     52

-------
 In   addition    to    the    National  Ambient  Air  Quality  Standards,  EPA
 establishes  National   Emission   Standards   for  Hazardous  Air  Pollutants,
 which  are   called   NESHAPS^    These  standards-are designed to control the
 emission of  toxic substances, even small amounts  of  which  may  adversely
 affect  health.   Examples  of   these  pollutants  are  benzene,  asbestos,
 beryllium,    mercury,    vinyl   chloride,   coke   oven   emissions,   and
 radionuclides.
                              PROGRAM CONTROLS

AMBIENT  AIR  MONITORING;   States  and  local  agencies  are  required  to
develop, set up, maintain, and operate the State and Local  Air  Monitoring
Stations   (SLAMS)   networks  to  provide year-round measurements of the six
NAAQS pollutants.   A sub-set of  these  monitors,  specifically  designated
as  National  Ambient  Monitoring  Stations  (NAMS),  is  used  by  EPA for
national trend analyses.  The NAMS and  SLAMS  monitoring  must  adhere  to
very   specific   network  design,  probe  siting,  monitoring  method  and
equipment,  and  quality  assurance  requirements   stated   in   the   EPA
regulations.    There  are  about  4,500  SLAMS  monitors  and  1,000  NAMS
nationwide.  The  resulting  data  are  used  by  EPA  and  the  States  to
determine  the  attainment status of specific geographic areas, to evaluate
air quality trends, and as the basis for the development of  air  pollution
control    strategies   and   regulations  to  reduce  or  maintain  ambient
concentrations.

STATE IMPLEMENTATION PLAN (SIP);  SIPS form the  basis  of  all  State  air
pollution  assesment  and  control  activities,  as  well  as management of
emerging problems.  They contain a State's  plans,  policies,  regulations,
and  schedules  for controlling air pollution.  They result from the formal
requirement for a State to determine  if  national  air  quality  standards
are  being  attained.   States  must develop and enforce a SIP that details
measures to be undertaken to achieve compliance with national  air  quality
standards  for  any  non-attainment areas.  EPA approves these plans.   If a
State plan is  not  acceptable,  EPA  is  required  to  provide  a  Federal
implementation  plan  which EPA itself must then enforce.  When a State has
not shown that it can achieve air quality standards by an acceptable

                                     53

-------
date, EPA may disapprove the SIP and propose bans on  construction  in  the
area Involved or take other measures.

NATIONAL   EMISSION  STANDARDS  FOR  HAZARDOUS  AIR  POLLUTANTS  (NESHAPS);
Developed for a  particular  source  category,  NESHAPS  currently  control
arsenic,  benzene,  asbestos, beryllium, mercury, vinyl chloride, coke oven
emissions, and radionuclides  in  about  25  source  emissions  categories.
Several  more  substances  are  under  consideration  for  NESHAPS  action.
NESHAPS  is  a  Federal  permit program, delegatable to the States, that is
designed to control emission  of  particular  hazardous  materials  without
regard to NAAQS.

NEW  SOURCE  PERFORMANCE  STANDARDS  (NSPS);   NSPS  is  a  Federal  permit
program  for  new  sources  of air pollution in specific source categories.
Any new or modified facility in one of  these  categories  is  required  to
install  control  equipment along with the process construction.  The level
of control required depends upon the current air quality in  the  area  for
the  pollutant  in  question.   If the area to be affected by the source Is
currently attaining the NAAQS, the source is required to install  the  best
available  control  technology,  while  a  source  in a non-attainment area
must meet the lowest achievable emission rate  for  that  source  category.
Source  testing  and monitoring requirements, along with quality assurance,
are specified in the regulations.  While NSPS  is  a  Federal  program,  it
may  be  delegated  to any State that demonstrates Its ability to enforce a
program at least as stringent as EPA's.

PREVENTION OF SIGNIFICANT DETERIORATION  (PSD):  PSD is a  program  designed
to  ensure  that new or modified air pollution sources constructed in areas
with clean air will not cause ambient air concentrations to rise  over  the
NAAQS.   It  requires  that  a potential  source demonstrate that  Its process
and controls will  achieve the desired ambient air  concentrations.   It  is
different  from   NSPS  and   NESHAPS  In  that they are emission  and control
oriented while  PSD Is  oriented toward ambient air quality Impact.
                                      54

-------
                            REGULATORY CONTROLS

Principal  stationary  source  pollution  control   regulations   are   the
National  Ambient  Air  Quality Standards, National Emissions Standards for
Hazardous Air Pollutants, New  Source  Performance  Standards,  Significant
Deterioration   standards  in  pristine  areas,  and  State  Implementation
Plans.  Ambient air monitoring reference and equivalent  test  methods  are
published  in  40  CFR  53.   The NAAQS  set levels for six pollutants that
must  be  attained.   NESHAPS  establish   source   levels   for   specific
pollutants  to  protect  ambient  air  from toxic pollutants.  NSPS require
best available control technology  in  air  quality  attainment  areas  and
lowest  achievable  emission  rate  in  ambient  air  non-attainment areas,
which are specified on a case-by-case determination.
An SIP describes in detail  the measures being undertaken or  planned  by  a
State  to  attain ambient air quality standards in non-attainment areas.   A
SIP is Federally enforceable.

                             QUALITY ASSURANCE

EPA administers a national  performance audit  program  for  ensuring  SLAMS
and  NAMS  monitor  performance  and  conducts  periodic  audits  of sites,
equipment, and the State programs as  a  whole.   For  specific  stationary
source  sampling,  the  analytic  procedures  are  included  in  QA project
plans, which often  are  called  stack  test  protocols  in  this  program.
These  must  be  approved  ahead  of  time  and must be followed during the
testing.  In addition, EPA and State personnel often are  able  to  arrange
for  performance  evaluation  audit  samples  to  improve confidence in the
analytical results.

DATA SYSTEMS; The Aerometric Information Reporting System (AIRS) is  a  new
integrated  data  system  that  consolidates  existing  data systems at the
national level.  AIRS contains the ambient air  monitoring  data  collected
through  SLAMS  and  NAMS programs.  States are required to enter NAMS data
and yearly summary data from SLAMS activities.  They  may  enter  other  or
all  data  collected  in  the  SLAMS program.   AIRS contains stack emission
data originally entered into the National Emissions Data System (NEDS).
                                     55

-------
AIRS  also  contains  data  describing  the  compliance   status    and   the
enforcement  activities  of  all  major and  many minor stationary  sources of
air pollution.  These data previously were  stored  in   the  Compliance  Data
System  (CDS).   Output  reports  from  the system enable management to (1)
maintain an inventory of  facilities  emitting  regulated  pollutants;   (2)
assess  enforcement  strategies  with  regard to those sources;  (3)  monitor
local, State and regional enforcement actions; and (4)  measure   compliance
and enforcement programs.

AIRS  further  contains  geographic  and common  information,  which includes
city and county location codes and  other  descriptive  information.   When
AIRS  becomes  fully  operational,  the  other data systems described above
will lose their individual identity.
                                      56

-------
                             SUGGESTED READING
1.    Cross, Frank L., Jr.   1973.   Handbook  on  Air  Pollution  Control.
      Technomic Publishing Co. Inc., Westport, CT.

2.    Stern,  Arthur  C.   1976.   Air Pollution, 3rd Edition, in 8 volumes.
      Academic Press, NY.  Vol. 1. Air Pollutants: Air  Transformation  and
      Transport.  Vol. 2. Effects of Air Pollution.

3.    US  EPA.   1989.   Progress  in  the  Prevention  and  Control  of Air
      Pollution  in  1987.    Report   to   Congress.    US   Environmental
      Protection Agency, Research Triangle Park, NC, EPA-450/2-89-009.

4.    US  EPA.   1989.   Status of Selected Air Pollution Control Programs.
      US Environmental Protection Agency, Office of  Air  Quality  Planning
      and Standards, Research Triangle Park, NC.
                                     57

-------
                                 RADIATION

                                  SUMMARY

The health effects associated with radiation exposure may  include  anemia,
loss  of  hair,  deleterious genetic changes, risk of cancer, or death from
a single rapid dose.  Environmental sources  of  radiation  are  many,  but
natural  background  and  radiation associated with diagnosis and treatment
of diseases are among the major contributors.   However,  any  exposure  to
radiation carries some risk, which increases as the exposure increases.

EPA's  Office  of  Radiation  Programs conducts a radon action program that
involves identifying the problem in homes, schools,  offices,  and  Federal
buildings.   The  Government  has  the  capability  to  respond  to nuclear
accidents.   Protective  action  guides  have  been  issued  to  States  to
protect persons from accidents at  nuclear  power  plants.   Assistance  is
provided  in   the  clean-up  of  radioactively contaminated hazardous waste
sites.  Routine monitoring is  carried  out  at  268  nation-wide  sampling
stations  on  milk,  surface  water,  drinking water, and air.  Regulations
have been developed to control disposal of spent nuclear fuels,  high-  and
low-level   radioactive  wastes,   uranium  mines  and  mill  tailings,  and
industrial radionuclide emissions.  Two field facilities  are  operated  by
EPA  that  provide  technical  assistance,  investigations,  and  emergency
response.
                                      58

-------
                       POLLUTION CONCERNS AND SOURCES

CONCERNS:   Concerns  involving  radiation are associated with exposure and
resultant bodily effects.  Ionizing radiation  can  remove  electrons  from
atoms.   Whether  in  the  form of x-rays, neutrons, protons, alpha or beta
particles,  or  gamma  rays,  it  acts  either  directly  or  by  secondary
reactions  to  produce  biochemical  lesions  that  initiate  a  series  of
histologic changes, as well as physiologic symptoms  and  signs  that  vary
with  the  radiation  dose  and  time.   A  single rapid dose may be fatal,
while the administration of the  same  dose  over  a  period  of  weeks  or
months  may  be  tolerated with few measurable acute effects.  Tissues vary
in response to immediate radiation injury, and, generally, the  more  rapid
the   turnover   of  the  cell,  the  greater  the  radiation  sensitivity.
Prolonged or repeated exposure to low  dose  rates  may  produce  decreased
fertility,  anemia,  leukopenia,  cataracts,  loss  of  hair, skin atrophy,
deleterious genetic changes, and cancer.

SOURCES;  Environmental radiation sources include  uranium  mine,  and  mill
tailings,  industrial  emissions,  nuclear reactors, high-level radioactive
waste disposal, naturally occurring radon from  soils  and  rocks,  nuclear
weapons     production,     medical     radiation     in     x-rays     and
radiopharmaceuticals,  low-level  radioactive  waste  disposal,  and  radio
frequency  radiation.    Secondary   contaminant   sources   include   air,
precipitation,  surface  and  drinking  water and milk.  Natural background
(cosmic,  terrestrial,  internal)  accounts  for  44.6  percent  of  annual
whole-body radiation dose-equivalent  rates,  medical  radiation  for  49.4
percent,  fallout  from  weapons testing 2.4 percent, consumer products 1.9
percent, and airline travel 0.3 percent.
                                     59

-------
                              PROGRAM CONTROLS

The basic assumption behind  radiation  protection  programs  is  that  any
exposure  to  radiation  carries some risk, which increases as the exposure
increases.

RADON  ACTION  PROGRAM;   The  program  consists  of  four  main  elements:
problem assessment,  mitigation  and  prevention,  capability  development,
and  public  information.   Problem  assessment  relates to determining the
national  distribution  of  radon  occurrences  in  schools,  houses,   the
workplace,  and  the  associated health risks that go with those locations.
A  National  Residential  Radon  Survey  has   been   initiated   by   EPA.
Mitigation  and  prevention includes demonstrations and evaluations of cost
effective  methods  to  reduce  radon   levels.    Capability   development
includes  radon  diagnostic  and  mitigation  techniques, training courses,
implementation of regional radon  training  centers,  a  radon  measurement
proficiency  program  and  a  radon contractor proficiency program.  Public
information includes the dissemination  of  information  through  brochures
and technical reports.

PROTECTIVE  ACTION  GUIDES;   EPA  has  issued Protective Action Guides and
Implementation Guidance for use by  States  relating  to  exposure  of  the
whole  body  and the thyroid gland to airborne radioactivity from accidents
at nuclear power plants.

RADIOACTIVELY  CONTAMINATED  SITES;   The  Office  of  Radiation   Programs
supports  the  Superfund  program to ensure that site cleanup activities do
not result in radiation hazards and  that  appropriate  cleanup  technology
and  methods  are adopted to effectively and efficiently reduce the hazards
associated with radiation problems encountered at  the  sites.   Twenty-one
sites  on  EPA's  National  Priority List are contaminated with radioactive
materials.  The Office is responsible for  establishing  safety  protocols,
data quality objectives, investigative procedures, and cleanup levels.

RESIDUAL  RADIOACTIVITY;   EPA  is developing criteria for cleanup of sites
and buildings that  are  contaminated  with  radioactivity.   Thousands  of
facilities,  such   as  laboratories and power plants 1n operation around the
country  use  radioactive materials.  When these facilities cease operation,

                                     60

-------
they must be cleaned before they can be  made  available  for  other  uses.
Any remaining equipment must be decontaminated.

                            REGULATORY CONTROLS

LOW-LEVEL  RADIOACTIVE  WASTE:   It  is  estimated  that  by the year 2000,
there will be  about  3  million  cubic  meters  of  low-level  radioactive
wastes  generated  by  commercial  activities  and 1.5 million cubic meters
generated by the Department of Energy.  There  are  now  three  operational
land  disposal  commercial sites at Barnwell, SC; Beatty, NV; and Rich!and,
WA.  There are 16 Federal  storage  sites  widely  distributed  around  the
country.  Proposed standards for management and land disposal of low-level
radioactive  wastes  are  being  developed  and  publication is expected in
1990.  The standards will include natural and accelerator  produced  wastes
and  will  establish  criteria  for  designating levels of radioactivity in
wastes below regulatory concern.

SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTES STANDARDS:   In  1987,
there  were  about  16,000 metric tons of commercial spent nuclear fuel and
382,000  cubic  meters  of   liquid   and   solified   waste.    High-level
radioactive  waste  is  the  waste  from  reprocessing  spent reactor fuel.
Commercial wastes  are  now  stored  at  individual   reactor  sites  or  at
storage  sites  in  West Valley, NY; Aiken, SC; and Morris, IL.  Department
of Defense wastes are stored at special sites in Rich!and, WA;  Aiken,  SC,
and  Idaho  Falls,  ID.   Spent nuclear fuel is being stored temporarily in
pools of water at  individual  reactor  sites  and  at  three  specifically
designated  sites  in  the  United States.  Environmental standards for the
management  and  disposal  of   spent   nuclear   fuel,   high-level,   and
transuranic  radioactive  wastes  were issued but portions were remanded by
the Court.  They are being reevaluated and it is expected  that  they  will
be proposed late in 1990.

URANIUM  AND  THORIUM  STANDARDS;   Both  air and water standards have been
issued for  the  control  of  effluents  and  emissions  from  uranium  and
thorium  milling  operations  and for the final disposal of tailings for 27
active milling sites, and 24 inactive sites.  Tailings must  be  stabilized
so that health hazards will be controlled and limited.  Quantitative

                                     61

-------
standards  are  being  developed for inactive  sites,  including  ground-water
protection standards.

RADIONUCLIDES  EMISSION  STANDARDS;    EPA  has  listed    radionuclides    as
hazardous  air  pollutants.   Early   in 1989,  EPA proposed four alternative
approaches  for  controlling  radionuclide  emissions    from   12   source
categories   including   reactors   and   support   facilities,   elemental
phosphorus  plants,  coal  fired  utilities and industrial  boilers,  uranium
mines  and  tailing  piles.   The  Agency  found,  for   example,  that   the
emission rate of radon  from  underground  mines  may  be  highly variable
depending  on  mine  ventilation  rates,  ore  grade,  exposed surface areas,
mining practices  and  geologic  formations.   This  latest  effort   is  in
accordance  with  a  court-mandated  process  following  earlier  standards
setting actions.

                             QUALITY ASSURANCE

There  are  two  types  of  EPA  activities  in  the radiation  field  that
emphasize quality assurance.  These include the field facilities  and  data
systems.

FIELD  FACILITIES;   Two  field  facilities  are operated by EPA; one is in
Montgomery,  AL,  the  other  is  in  Las  Vegas,  NV,    which   coordinate
monitoring   activities   east   and   west   of   the   Mississippi   River,
respectively.   The  Eastern  facility  conducts   field   and   laboratory
measurement  programs,  operates two radon calibration  chambers to evaluate
•instruments    and    methods   for   radon   measurements,   operates    the
Environmental   Radiation  Ambient Monitoring System, provides personnel and
equipment for EPA's  nuclear  accident  response  program,  develops  and
validates computer radiation dose  models,  provides  technical  assistance
and  laboratory assistance  to  States  and  conducts   special studies and
programs  in   support  of  Superfund.   The  Las  Vegas  facility  conducts
studies   In   radiation   problem  areas  such  as  Superfund  sites,   waste
disposal,  mill   tailings,   construction   materials,  and  uranium  and
Plutonium operations;  operates a radon  chamber   in  support  of  the  Radon
Measurement    Proficiency   Program;    conducts   measurements  related  to
electromagnetic fields;  estimates dose  and  risk  from radionuclides with

                                      62

-------
the use of computer models; provides an emergency response capability for
radiation incidents; and provides assistance and  advice  on  radiochemical
analyses and measurements of both ionizing and electromagnetic radiation.

EPA  established  the  Radon  Measurement Proficiency Program to assess the
capabilities of private  radon  measurement  companies  and  non-commercial
laboratories.    Under   this   program,   companies  offering  measurement
services  voluntarily  demonstrate  their  measurement  capabilities.   EPA
provides lists of successful participants  to  the  States  who  distribute
them to homeowners upon request.  Over 800 companies are listed.

DATA  SYSTEMS:  -The  Environmental  Radiation  Ambient  Monitoring  System
(ERAMS)   comprises   268  nation-wide  sampling  stations  at  which  air,
precipitation,  surface-water,  drinking  water,  and  milk  samples   are
collected   to   derive   radiation  levels.   In  cooperation  with  State
radiation program personnel, 65 composite pasteurized milk  samples,  which
are  representative  of  a significant fraction of the US milk consumption,
are  collected  quarterly;  air  filter  and  precipitation   samples   are
obtained  twice  weekly  from  locations;  and  river  samples are obtained
quarterly from  58  locations.   In  all,  the  monthly  sampling  schedule
accounts   for   2,000   samples  for  6,000  analyses.   Results  of  this
monitoring  are  published  in  Environmental  Radiation  Data,   which   is
distributed  quarterly  to  States  and  interested  private organizations.
ERAMS is subjected to rigid quality assurance controls.

                              SPECIAL STUDIES

Three  studies,  national  in  scope,  relate  to  radon.    The   National
Residential  Radon  Survey, mentioned earlier, involves a year-long testing
of 7,500 homes selected according  to  population  density.    A  contractor
collects  the  samples, which are analyzed in a commercial laboratory.   The
Office of Radiation Programs is w'orking  with  other  Federal  Agencies  to
survey  all  Federal  buildings for radon.  A national survey of schools is
being initiated through the States.
                                     63

-------
                             SUGGESTED READINGS
].    Eisenbud, Merril.  1963.  Environmental Radioactivity.   McGraw-Hill
      Inc., NY.

2.    NCRP. 1975.  Natural  Background  Radiation  in  the  United  States.
      National   Council   on   Radiation   Protection   and  Measurements,
      Washington, DC.

3.    US EPA. 1986.  A Citizen's Guide to Radon:  What it is  and  what  to
      do   about   it.   US  Environmental  Protection  Agency,  Office  of
      Radiation Programs, Washington, DC.

4.    US EPA. 1987.  Radon Reference Manual.  US  Environmental  Protection
      Agency, Washington, DC, EPA-520/1-87-020.         -

5.    US  EPA.  1989.   Office  of Radiation Programs: Program Description.
      US Environmental Protection Agency, Washington, .DC.
                                      64

-------
                             FEDERAL ACTIVITIES

                                  SUMMARY

EPA   has   far-reaching   environmental   review   and  comment  authority
associated with the National Environmental Policy Act, Section 309  of  the
Clean  Air  Act,  Executive  Order  12088,  and  Office  of  Management and
Budget's Circular A-l06.   These  authorities  provide  oversite  authority
for  virtually  all  major Federal actions that may impact the environment.
In addition, EPA's Office of  Federal  Activities  exercises  oversight  of
EPA compliance with these statutory and administrative authorities.

Programs  that  manage  the  above  authorities  include Federal facilities
compliance, NEPA compliance,  environmental  review,  and  compliance  with
certain  cross-cutting  environmental  statutes.   In  addition,  an Indian
activities program ensures adequate protection  of  human  health  and  the
environment  on  Indian  reservations.   Two programmatic data systems, the
Environmental  Review  Tracking   System   and   the   Federal   Facilities
Information  System,  provide  the  reservoir  of  information necessary to
manage the programs. ^

                             PROGRAM ACTIVITIES

EPA's Office of Federal Activities is the  focal  point  for  oversight  of
other  Federal  agencies  to ensure that they carry out their activities in
an environmentally  sound  manner.   This  oversight  addresses  multimedia
environmental  concerns,  with  particular  emphasis  on natural resources,
environmental values, and public health.  This Office  is  EPA's  principal
liaison  with  the  Council  on Environmental Quality and the center within
EPA for environmental impact studies and evaluation.

The National Environmental Policy Act (NEPA), signed on  January  1,  1970,
1s  the  basic  national  charter  for protection of the environment.  That
law establishes policy, sets goals, and provides  means  for  carrying  out
the  policy.   The  Council  on  Environmental  Quality regulations, 40 CFR
1500, notify Federal agencies of what they  must  do  to  comply  with  the
procedures and achieve the goals of the Act.   These regulations provide

                                     65

-------
guidance  on  the necessity for environmental  impact statements, as well  as
the recommended procedures and format for their  development  and  issuance
for public review.

EPA  has  been  delegated  the management of the official filing system for
all  Federal  Environmental  Impact  Statements  (EISs).   The  Office   of
Federal  Activities  provides  general liaison and coordination between EPA
and other Federal agencies on environmental  issues.   Further,  the  Office
oversees  EPA  compliance  with  a  variety   of  environmental statutes and
Executive Orders primarily administered  by   other  agencies  such  as  the
Endangered  Species  Act  and  the  Floodplain  Management Executive Order.
Any significant environmental action by  another  Federal  agency  receives
EPA  review  and  comment  under  the authority of Section 309 of the Clean
Air Act.

EPA has significant review and comment authority 1n three  legislative  and
administrative  areas:   NEPA,  Section  309,  and the Office of Management
and Budget's Circular A-106.  About 10,000  environmental  assessments  for
projects  with  minimal  environmental  Impacts  are  prepared  annually by
Federal agencies.  About 450 environmental Impact statements  are  prepared
annually   for   projects   that  the  proposing  agency  views  as  having
significant potential for environmental Impacts.  EPA reviews  all  of  the
environmental  impact  statements and about 20 percent of the environmental
assessments.   In  addition,  EPA  reviews  the  environmental  impacts  of
legislation, regulations, or other major  actions  proposed  by  a  Federal
agency.
                                      f-

In Its  public  comments, EPA assigns a rating to Its environmental Impact
statement reviews.  The rating scheme may Indicate  a  lack  of  objection,
an  environmental   concern   that   should   be   avoided  or  mitigated,
environmental  objections  that  must  be  corrected  to  provide  adequate
environmental protection, or the project may be classed as environmentally
unsatisfactory.   In the latter case,  If a negotiated  agreement  cannot  be
reached  between   the  proposing  agency  and EPA to correct the problem in
the Final EIS, EPA may refer the matter to  the  Council  on  Environmental
Quality  for  further  Investigation  under the authority of Section 309 of
the Clean Air Act.

                                      66

-------
Under Circular A-106, EPA  reviews  all  Federal  agency  annual  pollution
abatement  plans  and  budgets  and  provides  comments  to  the  Office of
Management  and  Budget.   In  1988,  there  were  758   proposed   Federal
pollution abatement projects that totaled nearly $1.1 billion.

                              PROGRAM CONTROLS

FEDERAL   FACILITIES   COMPLIANCE;    The  Office  provides  oversight  and
coordination of EPA activities designed to bring  Federal  facilities, into
compliance  with  pollution  control  requirements, and in conformance with
Executive  Order  12088.   Federal  environmental  statutes  require   that
facilities  of  the  U.S.  Government comply with Federal, State, and local
pollution control requirements to the same extent as non-Federal entities.
Executive Order 12088 established the Executive program  for  carrying  out
these  legislative  mandates.   Disputes  regarding  compliance  by Federal
facilities are resolved  through  administrative  procedures  specified  in
the   Executive   Order.    EPA  coordinates  implementation  of  pollution
abatement programs with other Federal agencies, provides  technical  advice
and  assistance  to  ensure  cost-effective and timely compliance, conducts
reviews  and  inspections  to  ensure  compliance  by  Federal  facilities,
assists agencies and the Office of  Management  and  Budget  in  developing
budgetary  plans  for controlling pollution from Federal facilities, tracks
Federal agency compliance records, and resolves  disputes  between  Federal
agencies and States regarding non-compliance by Federal facilities.

ENVIRONMENTAL  REVIEW;   EPA  has  responsibility  to review and comment on
major Federal actions affecting the  quality  of  the  environment.   Under
Section  309  of  the  Clean Air Act, as well as under NEPA, EPA's comments
are  made  available  to  the  public.   Major  Federal  actions  presently
include the Waste Isolation Pilot Plant for Department of  Defense  nuclear
wastes;   the   Army's   program   for  destruction  of  obsolete  chemical
munitions; Department of Interior's Outer Continental  Shelf  oil  and  gas
lease  sales;  the U.S. Forest Service's forest management plans; the Corps
of Engineers public works  projects;  navigation  projects;  flood  control
projects; Section 404 dredge and fill permits; highway and airport
                                     67

-------
projects;  and  the  Bureau  of  Reclamation's  water  contracts,  dams, or
operating plans.

NEPA COMPLIANCE;  Procedual  compliance  with  the  National   Environmental
Policy  Act  Is  required  for  municipal wastewater treatment construction
grants, EPA-issued NPDES permits  for  discharges  subject  to  new  source
performance  standards,  research and development projects and EPA facility
construction.  Voluntary development of an environmental   Impact  statement
pursuant  to  EPA policy applies to radiation and portions of the clean air
program, ocean dumping regulations  and  ocean  dump  site  specifications.
The  remainder  of  EPA's  programs  are deemed to provide reviews that are
"functionally  equivalent"  to  NEPA  reviews.    EPA's   NEPA   compliance
involves  the  preparation  of an environmental assessment, a finding of no
significant  impact,  or  the  preparation  of  an   environmental   Impact
statement,  as  well  as overview of State programs under delegation of the
construction grants program and under the State Revolving Fund.

INDIAN  ACTIVITIES;   EPA's  programs  are  designed  to  ensure   adequate
protection  of  human  health  and  the environment on Indian reservations.
The.policy  involved  is  to  ensure  that  EPA  works  with  Tribes  on  a
government-to-government  basis  and  that Indian tribal  governments have a
role in the environmental programs  on  the  reservation,  ranging  from  a
participatory  role  in  program  implementation to full  program delegation
where  this is appropriate.

CROSS-CUTTING ENVIRONMENTAL STATUTES;  EPA  1s  responsible  for  complying
with   a  number  of  environmental  statutes and Executive Orders where the
agency does not have primary responsibility for their  Implementation,  but
where  agency  action  may  come  within  their  purview.  Examples of such
statutes and Executive Orders are the National Historic  Preservation  Act,
Historic  Sites  Act,  Endangered  Species Act, Wild and Scenic Rivers Act.
Farmlands Protection  Policy  Act,  Fish  and  Wildlife  Coordination  Act,
Coastal  Zone  Management Act, Coastal Barrier Resources Act, the Executive
Order  on Floodplains, and the Executive  Order  on  Wetlands.   Interagency
agreements   are  developed  to  detail  procedures  for compliance with the
requirements and to  enable  State  agencies  directly  to  assure  project
compliance with these statutes for the State  Revolving Fund program.

                                     68

-------
                            REGULATORY CONTROLS

40  CFR  Part  6  regulations  provide  EPA  procedures for compliance with
NEPA.  Revised NEPA-implementing regulations for Research  and  Development
Projects are in the development stage.

                             QUALITY ASSURANCE

DATA  SYSTEMS:   Although  environmental data are not collected, the Office
operates two  data  systems.   The  Environmental  Review  Tracking  System
(ERTS)  is  operated  in  coordination  with  the  Council on Environmental
Qaulity.   The  system  maintains  information  on   environmental    impact
statements,  date  of  draft  publication,  date of comment closure period,
and date of final publication.  The system also  maintains  information  on
Section  309  EPA reviews and comments.  ERTS has the capability to provide
information on any of 14,000  environmental  impact  statements  that  have
been filed since 1970.

The  Federal  Facilities Information System (FFIS) tracks needs information
for  Federal  facilities  for  budget  purposes.    The   system   provides
information  on  the  environmental  pollution control facilities needed by
various  Federal  agencies.   EPA   reviews   all   Federal   budgets   for
expenditures  for  Federal   facilities pollution control  needs and provides
comments on these reviews to the Office of Management and Budget.

                              SPECIAL STUDIES

Investigations and studies  are  undertaken  where  there  is  disagreement
among  States  over  the  environmental impacts of Federal actions or where
additional information is needed for NEPA compliance.  Special  studies  of
the  Office  of  Federal  Activities  are  limited  to environmental impact
statement type actions.  Examples of such studies include a  study  of  the
environmental  effects  of  EPA's new source performance  standards based on
effluent guidelines for Alaska's placer mining  Industry,  studies  related
to  Federal  projects  on  Indian reservations, and a study of the Illinois
River and the placement  of  a  Federally-funded  sewage   treatment  plant.
These  studies  generally  are  of a localized, short-term nature.   Quality
assurance is applied to the contractor-operated studies.
                                     69

-------
                             SUGGESTED READING

1.  40 CFR Part 1500

2.  Kennedy, William V.  1988.  Environmental Impact  Assessment  In  North
    America,  Western  Europe,  What  Has  Worked,  Where,  How.  and  Why.
    International  Environmental  Reporter,  as reproduced by The Bureau of
    National Affairs, Inc., Washington, DC., p.257.

3.  Wathern, Peter (Ed.).  1988.  Environmental Impact  Assessment,  Theory
    and Practice.  Unwin Hyman Publisher, London.

4.  U.S.  EPA.   1985.   Interim  Strategy  for  Implementation  of the EPA
    Indian  Policy.   U.S.  Environmental  Protection  Agency,  Office   of
    Federal Activities, Washington, DC, (November).

5.  U.S.   EPA.   1988.   Federal  Facilities  Compliance  Strategy.   U.S.
    Environmental  Protection  Agency,  Office   of   Federal   Activities,
    Washington, DC.

6.  U.S.   EPA.   1988.   Environmental  Protection  Agency  Activities  on
    Indian Reservations, FY  87.   U.S.  Environmental  Protection  Agency,
    Office of Federal Activities, Washington/DC.

7.  U.S.  EPA.   1988.   A  Look at NEPA: A Series of Six Articles on NEPA,
    Section 309, and OMB Circular A-106 Processes, IN: EPA  Journal.   U.S.
    Environmental    Protection   Agency,   Office   of   Public   Affairs,
    Washington, DC, January/February, pp.21-39.

8.  U.S.  EPA.   1989.   Generic  Protocol  for  Multi-Media  Environmental
    Audits at Federal. Facilities.  U.S.  Environmental  Protection  Agency,
    Office of Federal Activities, Washington, DC.

9.  U.S.  EPA.   1989.   Environmental  Audit Program Design Guidelines for
    Federal Agencies.  U.S.  Environmental  Protection  Agency,  Office  of
    Federal Activities, Washington, DC.

10. U.S.  EPA   (Revised annually).  Review of Federal Actions Impacting the
    Environment.  A manual.  Office of Federal Activities, Washington, DC.
                                     70

-------
                                 PESTICIDES

                                  SUMMARY

Chemicals formulated to kill a multitude of  plant  and  animal  pests  can
cause  serious  human  health and environmental damage when used improperly
or against other than a target species.  EPA regulates  the  sale  and  use
of  pesticides  through  registration  and  labeling.    It  is unlawful for
anyone to use a pesticide in violation  of  label  instructions.   Further,
for  the  protection  of  human  health,  EPA sets maximum legal limits for
pesticide residues on foods sold in the United States.

EPA regulates a pesticide in a manner  such  as  to  preclude  unreasonable
risk  from  its  use  to  human  health  or  the  environment.  The process
requires a balancing  of  risk  against  the  benefits  to  be  derived  by
pesticide  use.   Pesticides  are  registered  on the basis of their active
ingredients.  Recent amendments to the Federal Insecticide,  Fungicide  and
Rodenticide  Act  require  EPA to reregister all existing pesticides in the
context of  current  standards  and  testing  by  1991.   If  a  registered
pesticide  shows  evidence of unreasonable adverse effects, EPA can conduct
a Special  Review.   The  results  of  that  Special   Review  can  lead  to
cancellation,   suspension,  restriction  of  pesticide  use  to  certified
applicators,   requiring   protective   clothing,    prohibiting    certain
application  methods  or  use  in  certain areas, or continued registration
with no change.

Product  enviornmental   and   health   effects   data   for   registration
requirements  include  the  use  of  Good Laboratory Practice standards, as
well  as  EPA  chemical  fate  testing  guidelines,  environmental   effects
testing  guidelines,  and   health   effects   testing   procedures.   Good
Laboratory  Practices  compliance  audits  are conducted by EPA's Office of
Compliance monitoring.  Quality assurance audits and  protocols  apply   to
pesticide  registrants  and  laboratories  analyzing  pesticide samples for
registration.
                                     71

-------
                      ENVIRONMENTAL CONCERNS AND USES

By definition, pesticides are toxic chemicals.   They are designed  to  kill
specific  pests  including  terrestial   and aquatic plants, insects, fungi,
bacteria, nuisance snails,  clams,  barnacles,   and  selected  fish.   Some
pesticides  have  been found to cause cancer, birth defects, skin, eye, and
other adverse health effects in human beings.

EPA regulates the sale and use of pesticides in  the  United  States  under
the  authority  and  direction  of  the  Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA) and  the  Federal  Food,  Drug,   and  Cosmetic  Act
(FFDCA).   Under  FIFRA,  all pesticides must be registered with EPA before
they may  be  sold  or  distributed  in  commerce.   There  is  an  overall
risk-benefit   standard   for   pesticide   registration,   requiring  that
pesticides  perform  their  intended  function,  when  used  according   to
labeling  directions,  without posing unreasonable risks of adverse effects
on human health or the environment.  In making pesticide  registration  and
labeling  decisions,  EPA  is  required  to take into account the economic,
social, and environmental costs and  benefits  of  pesticide  uses.   Under
FFDCA,  EPA  sets  tolerances,  or  maximum  legal  limits,  for  pesticide
residues  on  food  and  feed commodities marketed in the U.S.  The purpose
of the tolerance is to ensure that consumers  are  not  exposed  to  unsafe
food-pesticide residue levels.

In  addition  to  the  use  of  pesticides in agriculture and silviculture,
they also are used as  slimlcides,  as  antifouling  paints  on  ships  and
boats,   in  hospitals, in greenhouses, and for a variety of home and garden
applications.  Pesticide use in the United States more than doubled  in  21
years;   it  increased from 540 million pounds of active Ingredients in 1964
to over  one billion pounds in 1985.  Agriculture accounted for  77  percent
of  the  uses  in  1985,  which  cost  the  farming  industry $4.6 billion.
Pesticides are used on  as  many   as  two  million  farms,  in  75  million
households,   and  by  40,000  commercial  pest control firms.  Thirty major
and  100 minor  companies  produce  active  pesticide  ingredients,  3,000
companies formulate pesticides, and there are 29,000 distributors.
                                     72

-------
The regulation of pesticides requires a balancing of  risks  and  benefits,
including  a  balancing  of  human health and environmental protection with
agricultural and other  pest  control  needs.   For  the  50,000  pesticide
products  registered  on the basis of their active ingredients, EPA can (1)
continue registration with no changes  where  risks  and  benefits  already
are  in  balance;  (2)  modify the terms and conditions of the registration
to, lower  the  risk  by  requiring  protective  clothing  for  application
including gloves, hats, respirators, outer  clothing;  restricting  use  to
persons  who  have  been  certified  by  a  State as qualified; prohibiting
certain formulation uses;  prohibiting  certain  application  methods;  and
other  constraints;  (3)  cancel the use of a pesticide; or (4) suspend use
of a pesticide on a regular or emergency basis.

                              PROGRAM CONTROLS

REGISTRATION OF NEW PESTICIDES:  Pesticide  registration  is  a  pre-market
review  and  licensing program for all pesticides marketed in the U.S.  EPA
annually reviews about 15,000 registration submissions  of  various  kinds.
Only  about  15  new active ingredients chemicals are registered each year.
The  agency  bases  registration  decisions  for  new  pesticides  on   its
evaluation  of  test data provided by applicants.  Required studies include
testing to show whether a pesticide has  the  potential  to  cause  adverse
effects  in  humans,  fish,  wildlife,  and  endangered  species.   Data on
environmental  fate  and  effects  also  are  required  so  that  EPA   can
determine  whether  a  pesticide poses a threat to ground or surface water.
EPA reviews, evaluates, and validates data submitted on  toxicological  and
adverse  effects  on humans and domestic animals and on effects on fish and
wildlife, as well as ultimate fate.  Human and non-human  risk  assessments
are  made.   Economic  analyses  on  the  impacts of regulatory options are
developed.    Registration   standards   are   issued   for   new    active
ingredients.   Registration  standards  include  a  comprehensive review of
all available data on a chemical, a list  of  additional  data  needed  for
full  registration,  and  the  agency's  current regulatory position on the
pesticide.  For  a  new  active  ingredient  that  has  not  been  marketed
before,  it  may  take  six  to  nine years and $2 million to $4 million to
comply  with  all  registration   data   requirements.    EPA   may   issue
experimental use permits or temporarily authorize State or Federal

                                     73

-------
agencies  to  combat  emergencies  with  pesticide  uses  not  permitted by
existing Federal registrations.

RERE61STRATION  OF   EXISTING   PESTICIDES:    The   Federal    Insecticide,
Fungicide  and  Rodenticlde  Act,  as  amended  in  1988,  now requires the
reregistrati on of all existing pesticides within an approximate  nine  year
time.     For    reregi strati on,   a   pesticide   must   meet   the   same
no-unreasonable-adverse-effects criteria  that  apply  to  new  pesticides.
Through   Its  Registration  Standards  program,  EPA  is  reexamining,  by
current scientific standards, the health and environmental  safety  of  the
approximately   600   active  ingredients  contained  in  45,000  currently
registered products.

SPECIAL REVIEW;  If a registered  pesticide  shows  evidence  of  posing  a
potential  safety  problem,  EPA  can conduct a Special Review of risks and
benefits 1n which  all  interested  parties  and  the  general  public  may
participate.    A   notice   initiating   a  Special  Review  can  lead  to
cancellation, suspension proceedings, or to restricting  pesticide  use  to
certified  applicators,  requiring  protective  clothing,  and  prohibiting
certain application methods or use in certain areas.

TOLERANCE  LEVELS  FOR  PESTICIDE RESIDUES:  EPA sets tolerances or maximum
legal limits for pesticide residues on food  commodities  marketed  in  the
United  States.   Before a pesticide can be registered for use on a food or
feed  crop, EPA must either establish a tolerance designed  to  ensure  that
consumers  are  not  exposed  to  unsafe  food-pesticide residue levels, or
grant an exemption from the  tolerance  requirement.   The  Food  and  Drug
Administration  and  the  Department  of  Agriculture  are  responsible for
enforcing pesticide tolerances and  for  taking  any  necessary  regulatory
action.

APPLICATOR   CERTIFICATION  AND  TRAINING:  Most States have primacy for the
enforcement  of pesticide  regulations  and   for   certifying   pesticide
applicators.    EPA  establishes policy and maintains national oversight for
the applicator  programs.
                                     74

-------
FARM WORKERS PROTECTION:  Because it is unlawful to apply  a  pesticide  in
violation   of   label   directions,   EPA's  authority  is  through  label
issuance.  EPA is issuing label  statements  to  protect  farm  workers  by
requiring  protective  clothing,  washwater  and  shower  availability, and
defining reentry days for work in a field following spraying.

PESTICIDES STORAGE, TRANSPORTATION, AND DISPOSAL;   EPA  is  authorized  to
establish   labeling   requirements    for   transportation,  storage,  and
disposal of pesticides and pesticide containers,  including  rinsates  used
to  clean  a  pesticide  container,  or  other materials used to contain or
collect excess or spilled pesticides.  EPA is directed by  the  1988  FIFRA
amendments  to  regulate; the  design of pesticide containers to facilitate
their safe use, disposal, refill, and reuse.

GROUND WATER PROTECTION:  For pesticides not yet  on  the  market,  EPA  is
using  sophisticated  environmental  chemistry  and  mathematical models to
predict whether a pesticide has the potential to reach ground  water.   All
prospective  registrants  of  outdoor  usage pesticides must submit a range
of test data to enable prediction of pesticide  fate.    Efforts  are  being
made  to  bring  all  previously registered pesticides up to current ground
water safety, standards.

ENDANGERED SPECIES;  As  an  emerging  program,  efforts  are  underway  to
identify  through  range  maps  the  potential  location  of  endangered or
threatened species.  When this is  accomplished,  action  is  taken  for  a
label   amendment   to  restrict  use  of  certain  pesticides  within  the
endangered species range area.
                            REGULATORY CONTROLS
Regulations are  the  vehicles  for  implementing  the  programs  described
above.   Regulations  provide requirements for registration of a product to
be used for pest control, or for  reregistration  of  existing  pesticides.
Registration  standards  for  active  ingredients  are provided through the
regulatory process. Special review procedures are implemented through

                                     75

-------
notice  and  regulation,  as  are  cancellation  and  suspension   actions.
Tolerances  for  pesticide  residues  on  raw  agricultural  commodities are
established through regulatory procedures.

Regulations  provide  chemical  fate  testing   guidelines,    environmental
effects   testing   guidelines,  and  health  effects  testing  procedures,
including the use  of  quality  assurance  and  Good  Laboratory  Practices
Standards.    Regulations   govern   the  requirements  for  States  to  be
delegated primacy in the  enforcement  of  pesticide  regulations  and  the
certification and training requirements of pesticide applicators.
                             QUALITY ASSURANCE

Quality  assurance  for  pesticide  registration  is regulated through Good
Laboratory  Practices,  which  EPA's  Office   of   Compliance   Monitoring
enforces.   Other  aspects,  such as test protocols and data acceptability,
are provided in test guidelines and data  acceptance  criteria,  which  are
required  by   the  1988  FIFRA  amendments.  EPA's QA program Is applied to
data collected or funded directly by the  pesticide  program  and  includes
the  requirement  for  quality  assurance  project  plans  for  cooperative
agreements and special projects.

LABORATORIES;    EPA   operates   two   pesticide   laboratories,   one  in
Beltsville, MD, and  one   in  Bay  St.  Louis,  MS.   The  Beltsville,  MP,
laboratory  validates  analytical  methods submitted by industry to enforce
tolerances and ingredient  statements, collaborates  on  analytical  methods
development    with   other national  laboratories,  distributes  technical
reference standards, and performs  special  analytical  measurements.   The
laboratory  has  its   own  quality  assurance  program.   The  laboratory's
quality  assurance  coordinator  chaired  committees  in development of the
second laboratory validation programs  and  a  split  sample  program,  and
developed   the  , standard  Evaluation   Procedures  for  Petition  Method
Validation.

The Bay  St. Louis laboratory supported the National Survey  for  Pesticides
in Drinking Water Hells, validated an ASTM Organotin Release Rate Method.

                                     76

-------
prepares  performance  evaluation  samples (e.g., for dioxins and furans in
pulp, sludge, and water), and operates  under  its  own  quality  assurance
program.   Each  laboratory  has  a  quality  assurance  coordinator and an
alternate quality assurance coordinator.

QUALITY ASSURANCE  PLANS:   The  Office  of  Pesticides  Programs  operates
under  a  QA  Management  Plan  and  a  QA  Facilities  Plan.   Audits  are
performed  periodically  to  ensure  that  the  plans  are  consistent with
operations.  All  cooperative  agreements  must  contain  approved  quality
assurance   project   plans   prior   to   funding.   EPA's  two  pesticide
laboratories use a QA Project Plan  Short  Form,  except  for  projects  of
more   than   100  samples  where  a  quality  assurance  project  plan  is
developed.  Standard operating procedures have been developed  for  routine
operations.

Because  pesticide  registration  programs  rely on data submitted by those
who wish to have a pesticide product registered, EPA's  principal  role  is
one of data validation, audits, and information confirmations.

AUDITS;   Each  organization  funded  undergoes  at  least  one  audit each
year.  Laboratories involved in pesticide sample examinations  are  audited
via  a  protocol  and questionnaire.  Technical audits, systems audits, and
data  audits  are  performed  concurrently  with  an  examination  of   the
organization's  management  of  QA  and  its adherence to QA Project Plans.
The laboratories are scored so that  improvement  can  be  judged  readily.
Laboratory   audits   follow  the  good  laboratory  practice  regulations.
Before audit reports become final, an auditor  obtains  a  commitment  from
the  facility  to  implement  specific  corrective  actions  in response to
problems observed by the auditor.  The  commitments  are  detailed  in  the
final  audit  report.   Laboratories,  contractors,  and subcontractors for
the National Pesticide Survey of Drinking Water  Wells  are  audited  every
six months.

Performance   evaluation   pesticide   ingredient  containing  samples  are
formulated in  the  Bay  St.  Louis  laboratory  and  sent  to  cooperative
agreement laboratories.                               v
                                     77

-------
DATA  SYSTEMS;   A  National Pesticide Information  Retrieval  System (NPIRS)
contains  information  on  products,  active   ingredients    in   pesticide
products,  and  commodities  treated  such  as  tobacco or  peas,  and pests.
Information  can  be  retrieved  through  any  of  the  above   Information
routes.   An  effort  is  underway to develop a data system that will  track
all current pesticide programs.

The Pesticide Information Network  (PIN)  is  a  collection  of  up-to-date
pesticide   information   files   on  a  personal  computer  accessible  by
data-phone.  PIN contains the Pesticide Monitoring  Inventory,  which  is  a
compilation  of  pesticide  monitoring projects performed by Federal,  State
and  local  governments  and  private  institutions;  the  Restricted   Use
Products  File,  which  is  a  listing  of all pesticide products that have
been classified as Restricted  Use  Pesticides;  and  the  Chemical  Index,
which  is  a  list  of  all  chemicals  in  the  above two  files with cross
references to synonyms and CAS numbers.
                              SPECIAL STUDIES

The pesticide program, especially at  the  Bay  St.  Louis  laboratory,  is
heavily   involved  in  the  national study on pesticides in drinking water,
which was discussed  in the Drinking Water chapter.

EPA is investigating the nature  and  extent  of  the  pesticide  container
problem   as  it  may relate  to  size  restrictions,  pouring hazards when
transferring a concentrated pesticide to  a  solution,  residues  in  empty
containers,  and  household  and  agricultural  uses.   More information is
being  sought on  household use patterns,  which  will  impact  exposure  and
risk assessments,  as well as the economics of regulatory actions.
                                      78

-------
                             SUGGESTED READINGS
1.    National  Research  Council.   1987.  Regulating Pesticides in Foods:
      The Delaney Paradox.  National Academy Press, Washington, DC.

2.    US   EPA.    1985.   National   Pesticides   Monitoring   Plan.    US
      Environmental Protection  Agency,  Office  of  Pesticides  and  Toxic
      Substances, Washington, DC.

3.    US  EPA.   1986.   Pesticides Fact Book.  US Environmental Protection
      Agency, Office of Public Affairs, Washington, DC, A-107/86-003.

4.    US EPA. 1987.  Pesticides and  the  Consumer.   EPA  Journal  (Entire
      issue).    US  Environmental  Protection  Agency,  Office  of  Public
      Affairs, Washington, DC.

5.    US EPA.  1989.  General Information on Applying for  Registration  of
      Pesticides   in  the  United  States.   US  Environmental  Protection
      Agency, Office of Pesticides Programs, Washington, DC.
                                     79

-------
                              TOXIC SUBSTANCES

                                  SUMMARY

EPA  has  been  given  broad  powers  by  Congress  to  regulate   chemical
substances  that  may  present  an unreasonable risk of Injury to health or
the environment.  More than 60,000  chemical  substances  are  manufactured
or  processed  for  commercial use and nearly 2,000 new chemical substances
are Introduced each year.  EPA regulates these  substances  through  review
and  action  on premanufacture notification for new chemical substances, as
well as by requiring  testing  and  reporting  of  unpublished  health  and
safety  data  for existing chemical substances.  Regulatory action may take
the form of label modifications  such  as  the  Introduction  or  warnings;
limits  on  manufacture, Import, processing, distribution, use or disposal;
recall of a substance; or total ban.

Quality  assurance  is  provided  1n  good  laboratory  practice  standards
promulgated to  control  data  submitted  to  the  agency,  and  through  a
Guidance   Document  for  the  Preparation  of  Quality  Assurance  Project
Plans.  All risk assessment and other reports are  subjected  to  stringent
peer  review,  which  may  include  scientists  within  EPA, scientists and
academic experts external to EPA,  the  Agency's  Science  Advisory  Board,
and  the  National  Academy  of  Sciences.   A  number  of data systems are
associated  with  the  program,   which   track   both   confidential   and
non-confidential   information  regarding  the  universe  of  chemicals  in
commerce.
                                      80

-------
                      ENVIRONMENTAL CONCERNS AND SOURCES

 The production of chemicals and allied  products  accounts  for  roughly  5
 percent  of  the U.S.  Gross National  Product,  and the industry employs  over
 one million people.   More than 60,000  chemical   substances  are  presently
 manufactured  or  processed  for  commercial   use in the United States, and
•about 2,000 more are introduced every year.   Many of these  chemicals  pose
 toxic hazards to both humans and the  environment.

 In  1971,  the  President's  Council   on  Environmental Quality developed  a
 legislative proposal  for coping  with  the  increasing  problems  of toxic
 chemical   substances.    After  five  years  of  public hearings and debate,
 Congress  enacted the Toxic Substances Control  Act (TSCA)  in  the  fall  of
 1976.  The  Congress  defined  the coverage of the Act as the manufacture,
 distribution, processing, use, or  disposal   of  a  chemical   substance or
 mixture  that  may  present an unreasonable risk of injury to health or the
 environment.  With the specific exceptions of  tobacco,  nuclear  material,
 firearms   and  ammunition,  food  additives,   drugs and cosmetics,  Congress
 gave EPA  broad powers to regulate a chemical   risk at  any  stage  of  that
 chemical's life cycle.

 Programs   have  been  implemented  to  evaluate  chemicals  prior  to their
 appearance on  the  market  through  premanufacture  notification  for   new
 chemical    substances   and  significant  new   uses  of  existing  chemical
 substances, evaluation of  existing  chemicals  by  requiring  testing   and
 reporting   of   unpublished   health  and  safety  data,  and  control  of
 unreasonable  risks    of   existing   chemicals   by   regulatory   action.
 Regulatory  action  can  include label  modification; limits on manufacture,
 import, processing,  distribution, use or disposal; recall of  a  substance;
 or   total   ban.    Asbestos,   formaldehyde,   methylene   chloride,   and
 poly chlorinated biphenyls are among the more toxic chemicals regulated.

                               PROGRAM CONTROLS

 The Toxic Substances Control  Act  cuts  across  all   environmental   media.
 EPA  must  decide whether  or  not  it  is  most  effective  to regulate  a
 substance under this Act or under  other  laws  such  as  those  associated
 with surface water,  air, drinking water, pesticides,  marine protection,

                                      81

-------
hazardous  wastes  or  Superfund.   EPA activities  must be coordinated with
other Federal programs involved in  toxic  chemical   control   such  as  the
Consumer  Product  Safety Commission, the Food and  Drug Administration, the
Department   of   Agriculture,   the   Occupational    Safety    and   Health
Administration,  the  Department  of  Transportation,  the  Department   of
Health and Human Services, and others.

Programs  for  toxic  substances  control  mostly are divided between those
directed at new chemical substances and existing chemical  substances.

NEW CHEMICAL SUBSTANCES;  Manufacturers are required to  provide  EPA  with
a  premanufacture  notification 90 days prior to manufacture  or Import of a
new chemical substance, or the creation of a significant  new  use  for  an
existing  chemical  substance.   Any  chemical  which  is not listed on the
inventory of existing chemicals published by the agency  is  considered  to
be  "new"  for  this purpose.  The premanufacture notification must include
the  identity  of  the  chemical;   its   molecular   structure;   proposed
categories  of  use;  estimate  of  amounts to be manufactured, imported or
processed; byproducts resulting from the manufacture, processing,  use  and
disposal  of  the  chemical;  exposure  estimates,  and test data related to
human health and environmental effects.  In addition, if a  rule  requiring
testing  of  the  chemical  or  its chemical class  already has been issued,
the notice must include the test data developed from that testing.

Chemicals  produced  in  small  quantities  solely  for  experimental   or
research  and  development  purposes  are  automatically  exempt  from  the
premanufacture  and  significant  new  use  notification  requirements.  In
addition, exemption  may  be  made  for  chemicals  used  solely  for  test
marketing   purposes   or  those  determined  by  EPA  not  to  present  an
unreasonable risk of injury to human health or the environment.

If EPA determines that insufficient Information is  in  a  notification  to
evaluate  potential  risks,   it  may extend the 90 day review period for 90
more days and order that the  manufacture or  Importation  of  the  chemical
be  limited  or  prohibited until adequate data are developed.  Most of new
chemical substances reviewed  are  determined  by  EPA  not  to  present  an
unreasonable risk of Injury to health or the environment.  In such event,

                                     82

-------
a  Notice  of  Commencement  of  Manufacture  after the review, when actual
manufacturing begins, must be submitted by  the  manufacturer  to  EPA  and
the new substance then is added to the Chemical Substances Inventory.

EXISTING  CHEMICAL  SUBSTANCES:   The  goal  of  this  program is to reduce
unreasonable risk to health or the environment from  chemicals  already  in
commerce.   To  attain  the  goal, EPA identifies potential risks to health
or  the  environment  from  those  chemicals,  evaluates  the  risks,   and
addresses  risks  with regulatory action when appropriate.  EPA may require
testing by manufacturers and processors when there  are  insufficient  data
available  with  which  to  perform  a  reasonable  risk assessment; when a
chemical may present an unreasonable risk to  health  or  the  environment;
and  when  a  chemical  is  produced in substantial quantities resulting in
significant human exposure or environmental release.

BIOTECHNOLOGY;  EPA is responsible for regulating  microorganisms  used  as
pesticides,  or  for general industrial or environmental purposes.  Special
consideration is given to microorganisms that contain new  combinations  of
traits  or  that  are  new to the environment in which they are to be used,
microorganisms that are pathogens or that  contain  genetic  material  from
pathogens,  and  microorganisms  that  are  deliberately released.  As with
all toxic substances, EPA must be notified  by  manufacturers,  processors,
or  distributors  if  they  become  aware  of new information that suggests
that microorganisms or any chemical substance present  a  substantial  risk
of injury to human health or the environment.

POLYCHLORINATED  BIPHENYLS:   Congress  singled out PCBs for both immediate
regulation and phased withdrawal from the  market.   PCBs  are  of  concern
because  tests  on  laboratory animals show that long-term exposure to PCBs
may cause reproductive  failures,  gastric  disorders,  skin  lesions,  and
tumors.   PCBs  are  persistent and tend to accumulate in tissues of living
organisms.   Standards  for  the  cleanup  of  spilled   PCBs   have   been
published,  as  have other regulations involving their manufacture, use and
disposal.  Efforts continue for a phase-out leading to total  prohibition.

ASBESTOS;  An agressive asbestos reduction program is  underway.    EPA  has
issued a rul« to protect State and local  government employees from the

                                     83

-------
potential  hazards  of  asbestos  abatement work.   In addition,  all  schools
must have asbestos removed.  The manufacture,   import,   and  processing  of
certain  asbestos  products  have  been  banned.    Labeling  of  non-banned
asbestos  products  has been proposed.   Asbestos  abatement training  courses
have been  sponsored  by  EPA  and  certification  requirements  have  been
developed  by  EPA,  states  and  some cities  for personnel involved in the
surveying and removal of asbestos.

                            REGULATORY CONTROLS

SIGNIFICANT NEW USE RULES:   Any  person  who   intends  to  manufacture  or
import  a  substance  for  a specifically designated significant new use is
required to submit a  notification  for  EPA  review,  as  described  above
under Program Controls.

PREMANUFACTURE  NOTIFICATION;   This  rule, which  carries out the  Program
Control on that subject described above, details  the  required  information
on  worker  exposure  and  release  to the environment; and data concerning
the health and environmental effects,  confidentiality  and  public   access
information,   compliance   and   inspections;  as  well  as  the required
information on proposed uses, amounts to be manufactured,  byproducts  and
planned commencement of manufacture or import.

HEALTH  AND  SAFETY  DATA REPORTING;  This regulation provides requirements
for submission of  health and safety  studies  on   chemical  substances  and
mixtures selected  for priority consideration for testing.

TEST  RULES  AND CONSENT AGREEMENTS:  A test rule specifies the chemical to
be  tested,  health  and  environmental  effects  for  which   testing   is
required,  test  standards,  schedules  for  submission of data, and who is
responsible for conducting the  testing.   To  require  testing,  EPA  must
find  that  a  chemical  may  present  an unreasonable risk, that there are
Insufficient data  available with which to reasonably determine  or  predict
the  effects  of   the  chemical,  and that testing is necessary to generate
such data.  A test rule may also be  based  on  a  finding  of  substantial
production  and  exposure  to  humans  and the environment.  Procedures are
included  for using enforceable consent agreements to require testing.

                                     84

-------
This allows EPA to negotiate  with  manufacturers,  processors,  and  other
interested  parties  to establish testing programs that satisfy EPA testing
needs.

LABORATORY PRACTICES AMD  TESTING  GUIDELINES;   Good  laboratory  practice
standards,   chemical   fate   testing  guidelines,  environmental  effects
testing guidelines, and health  effects  testing  guidelines  with  quality
assurance   and   standard   operating   procedures  provisions  have  been
promulgated.  These good laboratory  practices  and  other  guidelines  are
applicable to data submitted under any test rule.

                             QUALITY ASSURANCE

OTS  GUIDANCE  DOCUMENT;   The Office of Toxic Substances Guidance Document
for the Preparation of Quality Assurance Project Plans is tailored  to  the
needs   of  toxic  substance  investigations.   It  provides  specific  and
additional requirements, in addition to the minimum standards  for  quality
assurance   provided  in  the  good  1aboratory  practices  and  associated
testing guidelines.

PROGRAM MANAGEMENT;  Toxic substances programs  are  examined  pursuant  to
the   Federal  Managers  Federal  Integrity  Act  to  ensure  good  program
quality.  Reports  receive  a  quality  check  on  their  technical  merits
through  both  an internal and external peer review.  For example, the risk
assessment  report  on  formaldehyde  was  reviewed  by  the  EPA   Science
Advisory  Board  after  it  received  external  peer  review.   In  another
example,  the  National  Academy of Sciences is reviewing procedures in the
National Human Adipose Tissue Survey.

DATA  SYSTEMS;   A  number  of  data  systems  are  associated  with  toxic
substances; some contain confidential business information and  others  are
more  generally  accessible.   The Chemicals in Commerce Information System
(CICIS) contains inventory information on the,,more  than  60,000  chemical
products  in  the  United  States.  The Chemical  Update System (CUS), which
contains non-confidential business information, has  about  12,000  of  the
60,000  chemical  products,  as  well  as inventory information about them.
There is a confidential tracking system for premanufactur* notices, and

                                     85

-------
there  1s  a  document  tracking  system  with  some   portions   held   as
confidential.   The  Chemicals  on  Reporting Rules (CORR)  system 1s a list
of chemical substances, categories, and mixtures  that  are  or  have  been
the   subject   of  proposed  or  final  regulations.    The  Toxic  Release
Inventory  System  (TRIS)  1s  a  more  recent  system  arising  from   the
requirement  that  Industries  report  the  quantities  of  toxic substances
environmentally released.

Data are entered Into data  systems  by  contractors.    A  recent  Internal
check  of  1,000  forms compared with data entry on TRIS revealed less than
2 percent data entry errors.  In addition, 15,000 data  entries  were  sent
to  reporting  Industries  and,  In  the  returns received, there were less
than 2 percent data entry errors.

                              SPECIAL STUDIES

NATIONAL HUMAN ADIPOSE TISSUE SURVEY;  NHATS is  a  long-term  study  where
human  tissues  are  sent  by  coroners  and others to a central collection
agency.  Such tissues later are analyzed  for  volatile  and  semi-volatile
organic  compounds,  PCBs,  dioxins,   furans,  and some elemental metals to
track  the  national body burden of  toxic substances.
                                      86

-------
                             SUGGESTED READING
1.    Kamrin, M.A.  1988.  Toxicology: A Primer  of  Toxicology  Principles
      and Applications.  Lewis Publishers, Inc., Chelsea, MI.

2.    CMA.   1989.   The  Toxic  Substances  Control  Act: An Assessment in
      1989. Chemical Manufacturing Association, Washington, DC.

3.    US EPA.   1987.   Toxic  Substances  Control  Act  (TSCA)  Report  to
      Congress  for  Fiscal Year 1986.  US Environmental Protection Agency,
    .  Office of Pesticides and Toxic Substances, Washington, DC.

4.    US  EPAk   1987.   OTS  Guidance  Document  for  the  Preparation  of
      Quality  Assurance  Project  Plans.   US   Environmental   Protection
      Agency, Office of Toxic Substances, Washington, DC.

5.    US  USA.   1987.  The  Layman's Guide to the Toxic Substances Control
      Act.    US   Environmental   Protection   Agency,   Washington,   DC,
      EPA-560/1-87-001.
                                     87

-------
                         SOLID AND HAZARDOUS WASTES

                                  SUMMARY

EPA  estimates  that  about  3.6  pounds  of  municipal   solid  waste  Were
generated per person per day 1n 1986.   With  these  wastes  straining  the
Nation's  landfills,  EPA's  goal  Is a 25 percent reduction by 1992.  This
1s  to  be  accomplished  through  source  reduction,  including  reuse  of
products, recycling of materials and composting,  with special  emphasis  on
yard  wastes.   Incinerators  are  projected  to  handle about 20 percent of
the  waste  stream,  and  the  remaining  55  percent  is   projected  'for
landfills.   This  is  a  reemerging program because, until recently, EPA's
solid and hazardous  resources  have  been  directed  towards  placing  the
hazardous waste cradle-to-grave regulatory system 1n place.

With  60,000  large  quantity  hazardous  waste  generators,  140,000 small
quantity generators, 12,500 transporters and 5,700 facilities  that  treat,
store   or  dispose  of  a  hazardous  waste,  the  management  program  is
                   )
formidable.  Since 1980, regulations  have  been   promulgated  to  identify
and  define  hazardous wastes, as well as to provide a paper trail  and best
management practices for those who generate, store,  transport,  treat,  or
dispose  of  hazardous  waste.   Permits  are required for those who treat,
store or dispose of the waste.  Waste  testing,  ground  water  monitoring,
labeling,  and  reporting are requirements of various activities within the
program.

Hazardous waste disposal on land  is  prohibited  by  the  1984  amendments
except  for  such  methods as EPA may determine will be protective of human
health and the environment for as long  as  the  waste  remains  hazardous.
One  million  underground  storage tanks containing hazardous substances or
petroleum  products,  have  recently  been  brought   into   the   program.
Designed  by  the  Congress  as  a  State  program with EPA oversight, most
States have  been authorized for  basic  program  Implementation.   However,
the  1984  Hazardous  and  Solid  Waste  Amendments substantially Increased
Federal accountability,  and  only  a  few  States,  thus  far,  have  been
delegated program  Implementation for this enlarged and modified program.

-------
A  new  program information management system, RCRIS, for use by States and
EPA, is to be implemented in every State by 1992.
                     ENVIRONMENTAL CONCERNS AND SOURCES

This chapter covers the  solid  waste  and  hazardous  wastes  programs  as
mandated  by  the  Resource  Conservation  and Recovery Act and amended and
expanded by the 1984 Hazardous and Solid  Waste  Amendments.    There  is  a
considerable  overlap  between  the  two  in  the  case  of solid hazardous
wastes.

In the past 25 years, municipal solid  waste  has  risen  from  87  million
tons  per  year  to nearly 158 million tons per year.  Paper and paperboard
make up 41 percent of this waste; yard  wastes,  18  percent;  metals,  8.7
percent;  rubber,  leather,  textiles,  and  wood,  8.1 percent; glass, 8.2
percent;  food  wastes,   7.9   percent;   plastics,   6.5   percent;   and
miscellaneous  inorganic  wastes,  1.6  percent.   Sources  of these wastes
include residences, institutions,  commercial  businesses,  municipalities,
and  industry.   EPA  estimates  that  about  3.6 pounds of municipal solid
waste were generated per person per day in  1986.   At  present,  about  11
percent  of  all  US  solid  waste  is  recycled,  but  the full recyclable
potential may be as high as 50 percent.

Solid wastes are defined in the 1984 Amendments to include  both  hazardous
and  non-hazardous  wastes.   A hazardous waste is a particular solid waste
(so defined) that is listed as hazardous in the regulations,   or  it  is  a
solid  waste  that  exhibits  hazardous  characteristics.   There  are four
characteristics that define hazardous wastes: 1) Ignitable wastes  such  as
solvents  and  friction-sensitive  substances  can  flash  and create fires
under certain conditions.  2)  Corrosive  wastes  include  those  that  are
acidic  and  those that can corrode metals. 3) Reactive wastes are unstable
normally, and can create intense  heat,  explosions  or  toxic  fumes  when
mixed  with  water.  4)  Toxic  wastes are those that have the potential to
pollute    ground    water.     They    are    identified    by     failing
laboratory-conducted  solubility  and analytical tests.  There are specific
laboratory tests for each of the hazardous characteristics.

                                     89

-------
Waste  generators  include  chemical   manufacturers,   vehicle   maintenance
shops,  the  printing  Industry,  leather products manufacturing,  the paper
Industry,   construction   Industry,    cleaning   agents   and    cosmetics
manufacturing,  furniture  and  wood   manufacturing  and refinlshlng, metal
manufacturing, and others.  It  Is  estimated  that  527  million   tons  of
hazardous  waste  are  generated annually.  There are 200,000 generators of
hazardous waste; about 60,000 of these are large  quantity  generators  and
the  remainder  are  small quantity generators.  A large quantity  generator
produces more than 2,200 pounds of hazardous  waste  per  month.   A  small
quantity  generator  produces  between  220  pounds  and  2,200 pounds  of
hazardous   waste  per  month.   There  are  12,500  firms  that  transport
hazardous waste from one place to another, and there are  5,700 facilities
that  treat,  store,  or  dispose  of  hazardous  waste.  Source reduction,
recycling, incineration, and land disposal are  the  four  principal  waste
management means.

                              PROGRAM CONTROLS

INTEGRATED  WASTE  MANAGEMENT;   For  non-hazardous  wastes,  EPA's present
goal, established in 1988, is a 25 percent  reduction  in  solid  waste  by
1992.   This  is  to  be achieved through source reduction, Including reuse
of  products,  recycling  of  materials,  and  composting,   with    special
emphasis  on  yard  wastes.  On-line and already permitted combustion units
are projected to handle about 20 percent of  the  total  waste  stream  and
the   remaining  55  percent  1s  projected  for disposal 1n landfills.  EPA
intends to reach these goals through Increasing Its  available  Information
in  the  form and guidance and materials on the technical aspects  of source
reduction, combustion, recycling, landfill1ng, composting, and collection;
and through encouraging State and  Indian  Tribe  strategies  and   planning
for   managing  municipal  solid wastes.  EPA already has Initiated a number
of  these  programs,  Including   guidance   on   operator   training   and
certification  on  combustion  and landfill activities, on Improving source
reduction, and recycling.  For the latter, yard wastes and  paper  products
have   been   given   high  priority,  because  these  products  contribute
significantly to the filling of landfills.
                                     90

-------
LAND DISPOSAL;  The 1984 Hazardous and Solid Waste Amendments  require  EPA
to  evaluate  all  hazardous  wastes  according  to  a  strict  schedule to
determine whether land disposal of these  wastes  is  protective  of  human
health  and  the  environment.   Certain  toxic  materials  above specified
concentrations are banned from land disposal, as are certain  solvents  and
dioxins.    Deep   well   injection   is   to   be   minimized.    Bulk  or
non-containerized liquid hazardous  wastes,  including  free  liquids,  are
prohibited  from  disposal  in  landfills.   Land  disposal, either by land
treatment or landfill, of other materials can be  permitted  if  the  waste
meets  specified  standards.   This action was taken by Congress because of
long-term uncertainties  about  the  persistence,  toxicity,  mobility  and
accumulation   in  plants,  animals  and  human  tissues  of  land-disposed
hazardous wastes.

UNDERGROUND  STORAGE  TANKS:   One  million   underground   storage   tanks
containing  hazardous  substances or petroleum products, including gasoline
and crude oil,  are  now  subject  to  hazardous  waste  regulations.    The
installation   of   corrodable   tanks  is  banned.   Standards  have  been
developed  covering'  leak  prevention,  leak  detection,   and   corrective
actions.

PERMITTING;   The  treatment, storage, and disposal facilities that receive
hazardous waste from  a  transporter  are  subject  to  an  EPA  permitting
system  that  ensures  their  safe design, construction and operation.  The
1984  amendments  provide  several  new  restrictions  for  land   disposal
facilities,  which  include:  banning  underground  injection  of hazardous
wastes within 1/4-mile of a drinking water well; requiring  more  stringent
structural  and  design  conditions  for  landfills;  requiring  cleanup or
corrective  action  if  hazardous  waste  leaks  occur  from  a   facility;
requiring  information  from  disposal  facilities on pathways of potential
human exposure to hazardous substances; and  requiring  location  standards
that  are  protective  of  human  health  and the environment.  Up to 4,000
facilities may require corrective action to meet these standards.

STATE PROGRAMS;  EPA implements the hazardous waste  requirements  until  a
State  is  authorized  to  assume  that  responsibility.  Forty-five States
have been authorized for basic program implementation.  The 1984

                                     91

-------
Amendments Increased Federal accountability for the  program,   and  only  a
few States have been authorized to Implement the new, expanded program.
                            REGULATORY CONTROLS

Regulations  have  been  promulgated  for  the management of both the solid
waste and hazardous waste programs.  The former begin at 40  CFR  240;  the
latter  begin  at  40  CFR 260.  Solid waste management regulations provide
guidelines for land disposal of  solid  wastes;  solid  waste  storage  and
collection;  resource  recovery  facilities; criteria for classification of
solid  waste  disposal  facilities  and  practices;  and   guidelines   for
development and Implementation of State solid waste management plans.

Complex  hazardous  waste regulations are separated into identification and
listing  of  hazardous  wastes;  standards  for  owners  and  operators  of
hazardous  waste  treatment,  storage,   and   disposal   facilities;   and
requirements  for  authorization of State hazardous waste programs.  A rule
to implement corrective actions is expected to be promulgated soon.

                             QUALITY ASSURANCE

DATA SYSTEMS:  Developed cooperatively by EPA and the  States,  RCRIS.  the
Resource   Conservation   and   Recovery   Information  System,  Is  to  be
Implemented in every Region and  State  by  the  end  of  1992.   RCRIS  1s
replacing  the  Hazardous  Haste  Data  Management  System (HWDMS), and the
data stored 1n HWDMS will be archived by the end  of  1991.   RCRIS  1s  an
Information   management  system.   States  and  Regions  will  use  1t  to
collect, enter, track,  and  report  day-to-day  hazardous  waste  handler,
permitting,  Inspection,  and  enforcement  Information.   It will be used,
also, to track and report budgeting  and  program  management  Information.
Six  major  modules  will  be  designed  to report Information on hazardous
waste  handlers;  permitting,  closure,   and   post-closures;   compliance
monitoring  and  enforcement;  corrective  actions; program management; and
facility management planning.  States  and  EPA  will  enter  data  to  the
system.   Edit-checks  of  data entry will be made by computer.  The system
will not contain environmental quality data.

                                     92

-------
                             SUGGESTED READING

 1.   Dawson, G. W. and B. VI. Mercer.  1986.  Hazardous  Waste  Management.
      John Wiley & Sons, New York.

 2.   HWHM.   1988.  Hazardous Wastes and Hazardous Materials.  Proceedings
      of the 5th National  Conference.   The  Hazardous  Materials  Control
      Research Institute, Silver Spring, MD.,

 3.   Minnesota.   1987.   Environmental  Risk  Discussion  of  Solid Waste
      Management Systems.  Minnesota Pollution Control  Agency,  St.  Paul,
      MN.

 4.   Relis,  P.  and  A.  Dominski.   1987.  Beyond the Crisis: Integrated
      Solid  Waste  Management.   Community  Environmental  Council,  Santa
      Barbara, CA.

 5.   US  EPA.  1985.   The  New  RCRA:  A  Fact  Book.   US  Environmental
      Protection Agency, Washington, DC, EPA/530-SW-85-035.

 6.   US EPA.  1986.  Solving  the  Hazardous  Waste  Problem:  EPA's  RCRA
      Program.    US   Environmental  Protection  Agency,  Washington,  DC,
      EPA/530-SW-86-037.

 7.   US EPA.  1988.  Report to  Congress  on  Solid  Waste  Disposal.   US
      Environmental  Protection  Agency, Office of Solid Waste, Washington,
      DC.

 8.   US EPA.  1989.  The Solid Waste Dilemma: An Agenda  for  Action.   US
      Environmental Protection Agency, Washington, DC, EPA/530-SW-89-019.

 9.   US  EPA.   1989.   EPA Journal - The Garbage Crisis. US Environmental
      Protection  Agency,  Office  of  Public   Affairs,   Washington,   DC
      (March-April).

10.   US  EPA.  1989.   Decision-Maker's  Guide  in Solid Waste Management.
      US  Environmental  Protection  Agency,   Office   of   Solid   Waste,
      Washington, DC.

11.   Wagner,  Travis.   1988.   The  Complete  Handbook of Hazardous Waste
      Regulation. A Comprehensive Step by Step Guide to the  Regulation  of
      Hazardous  Wastes  under  RCRA,  TSCA,  and  Superfund.  Perry-Wagner
      Publishing Co., Inc., Brunswick, ME.

-------
                      SUPERFUND AND EMERGENCY RESPONSE

                                  SUMMARY

The Superfund program was established to provide a mechanism  for  cleaning
up  abandoned  or  uncontrolled  hazardous  waste sites 1n order to protect
human health and the  environment.   The  National  Priorities  List  is  a
listing  of  hazardous waste sites with EPA priority for long-term remedial
response.  EPA has now identified 1,200 sites  as  proposed  or  final  for
this  list.   Once  remedial  action  has  begun,  it may take four to five
years at some sites and up to 50 years at others to remediate the  site  to
the  required  clean-up  levels,  particularly  where  there  is  extensive
ground  water  contamination.   Only  those  sites included on the National
Priorities  List  are  considered  eligible  for   Fund-financed   remedial
action.   EPA  has  an  additional  list  of  31,000  sites  that have been
provided to it by  the  States  for  possible  inclusion  on  the  National
Priorities List.

Procedures  for  Superfund  site  cleanup  are  detailed  in  the  National
Contingency  Plan  (NCP)  at  40  CFR  300.  The steps taken in cleanup are
discussed in  the  NCP.   They  include  discovery  or  notification  of  a
hazardous  waste  release  or  potential  problem,  and an investigation to
determine if response action is warranted, must occur  immediately,  or  if
long-term  cleanup  is required. In the latter case, the site may be placed
on the National  Priorities  List.   A  remedial  investigation/feasibility
study   Is   undertaken   to   characterize   the   nature  and  extent  of
contamination and the risk posed  by  the  site,  as  well  as  to  analyze
potential  remedial  alternatives.   The selection of a remedy,for the site
is documented in the Record  of  Decision  (ROD).   A  remedy  may  involve
several  process  technologies  depending  on  the media affected and other
considerations.   Remedial  design  and  action  follow.   Remedial  design
involves the preparation of detailed engineering plans .and  specifications
for  the  selected  remedy.   Remedial  action  or site cleanup may involve
treatment, disposal, and containment of the hazardous  waste  and  cleanup,
restoration,  or  replacement of the affected resources.  EPA works closely
with the States throughout the above activities.
                                     94

-------
EPA's Emergency Response Program  is  designed  to  react  quickly  to  the
spillage of oil or hazardous substances.  The National Contingency Plan
describes  a  scenario  for  this response, in which EPA works closely with
the States and the  Coast  Guard  to  plan,  implement,  and  evaluate  the
effectiveness of the cleanup operation.

Enforcement  activities  are  a  key  part  of  the Superfund and emergency
response programs.  Where possible, legal or  other  actions  are  used  to
persuade  the  responsible parties to conduct the cleanup operations.  When
EPA does the cleanup, legal actions  may  then  follow  against  identified
responsible parties to recover cleanup costs.

                     ENVIRONMENTAL CONCERNS AND SOURCES

Superfund,  The  Comprehensive  Environmental  Response,  Compensation  and
Liability  Act  (CERCLA)  of  1980,  and  its  subsequent  amendments,  was
created  to  address  the  potentially  hazardous  conditions  at  the many
inactive, abandoned hazardous waste sites through the  nation.   The  solid
and  hazardous  waste  program,  discussed in another chapter, was designed
to provide guidelines for prudent hazardous waste management  and  disposal
in  the  present  and  the  future,  and  to  provide a tracking system for
hazardous waste from generation to disposal.  The objectives  of  Superfund
are:

      o    Develop  a  comprehensive program to set priorities for cleaning
           up  the  existing  abandoned  or  uncontrolled  hazardous  waste
           sites with the greatest risk to human  health  or  environmental
           qua!i ty;
      o    Use  enforcement  procedures to make responsible parties pay for
           cleanup wherever possible;
      o    Operate under a  Trust  Fund  for  the  purposes  of  performing
           Federal  remedial  cleanups  in  cases where responsible parties
           could not be identified or held accountable;
      o    Respond to emergency situations involving hazardous substances.
                                     95

-------
In  the  case  of  Federal  payment  for  remedial   cleanup  or   emergency
situations,  enforcement  actions  may be taken later to recover costs from
responsible parties after they are identified.

The list of sites submitted by the States to  EPA  for  possible  Inclusion
on  the  National  Priority  List  numbers 31,000,  with an average of 2,000
new sites added to that list  each  year.   EPA  now  has  1,200  sites  as
proposed  or  placed  on the National Priority List and has determined that
about 16,000 others are not condidates for the List.   Cleanup  action  may
take  four  to  five  years at some sites, and decades at others.  In cases
of  extensive  ground-water  contamination,  long-term  "pump  and   treat"
response  actions  are often projected to take 20 to 30 years, and, in some
cases, up to 50 years.  The cost of cleanup now approaches  an  average  of
$25  million  for  construction  costs at each site.  The current projected
total cost of construction for all sites on the current  National  Priority
List is $30 billion.

States  have  always  been  encouraged  to  participate  in  the  Superfund
process.  States are formally involved in the selection, initiation, and
development  of  remedial  responses.   There are a number of opportunities
for States  to  participate,  including  review  and  comment  on  planning
documents,    involvement   in    long-term   planning   activities,   and
participation in negotiations.

Either EPA or the  State  may  take  the  lead  role  1n  managing  cleanup
activities.   When  EPA   takes   the  lead, the U.S. Army Corps of Engineers
manages the remedial design and  remedial action phases  for  EPA.   Private
contractors  may  complete  the  work  at  a  site  under  Federal or State
government supervision.

The National Oil and Hazardous Substances  Pollution  Contingency  Plan  is
designed  to  provide  a  rapid  response  cleanup  to  a  spill  of oil or
hazardous  substances,  so  that major  incidents  may   be   avoided   or
minimized.  EPA works closely with  the Cosat Guard  1n this activity.
                                      96

-------
General  activities  associated  with actions on a Superfund site are shown
in Exhibit 1.  Principal activities are discussed more fully  in  the  next
section.
                           SUPERFUND SITE CLEANUP

DISCOVERY;   The  Superfund  program  is  intended  to  clean  up  existing
hazardous  waste  sites.   This program has a number of identifiable steps,
the first of which is discovery.  EPA learns of potential  hazardous  sites
through  reports  submitted  in  regulatory  compliance,  investigations by
government authorities, and citizen petition.

RESPONSE ACTION AUTHORIZATION:  Should there be  immediate  risk  to  human
health  or  the  environment,  EPA  is  authorized  to  administer response
actions immediately using Fund monies.  Responsible parties  can  undertake
a  response  action  as  a result of EPA's enforcement authorities.  States
can act using Fund monies pursuant to a  cooperative  agreement  with  EPA,
described  in  40  CFR  35,  Subpart  0.   Many  States  now have their own
Superfund trust funds and deal with some sites on their own.

PRELIMINARY ASSESSMENT;  Once EPA learns of a possible hazardous  site,  it
collects  all  available background information from files, State and local
records and U.S. Geological Survey  maps.   This  information  is  used  to
identify  the  site  and  perform a preliminary assessment of its potential
hazards.  EPA determines,  where  possible,  the  size  of  the  site,   the
identity  of  the  parties  most  likely to have disposed wastes there, the
types and quantities of  wastes,  local,  hydrological  and  meteorological
conditions, and the possible impacts of the wastes on the environment.

REMOVAL  EVALUATION;   Where  prompt  action  is  required  because  of  an
emergency  or  time-critical  situation  for the protection of human health
or the environment, a removal site evaluation is  made.   If  it  is  found
that  a  potential  exists  for  fire, explosion, contamination of drinking
water or other hazardous release, removal action may be instituted  at   any
time during the remediation process.   Removal  actions range from
                                     97

-------
                                             Exhibit 1
            FUND-FINANCED, FEDERAL-LEAD REMEDIAL RESPONSE PROCESS
              ACTTVmtS
               REMEDIAL
               PLANNING
            WLEMENT,"
                    ATOM
                 1
                                             8TO DISCOVERY

                                             NOTIFCATON
                                             .PRELIMINARY
                                             ASSESSMENT
-
             REMOVAL1
                                               WSPI
                                                 PECTCN
                                              APPLY HAZARD
                                             RANWNG SYSTEM
x
s.
•~
i

I.
j

1

1

|


(
'l£t&.HJHDO*^
ENFORCEMENT: ^s .
FEDERAL OR ^
. STATE .^P'

FUND^INANCED.
FEDERAL-LEAD
1
REMEDIAL
SWESTIGATION
PEASlBn (TY BTUOY
1
RECORD OF
DECISION
1
REMEDIAL
DESIGN
1
"SSfgJ1 .


MAINTENANCE
	 I BffOF«MEKTa




1 EXPEDTTED
J RESPONSE
	 1 ACTON*







1 COST WE COVE RV


^Removtls may occur at tny point in the remedU) proctn. If the lead i|tncy determinet that there it a threat to human health or the
environment, the lead agency may lake a removal action to abate, ninimize, stabilize, mitipte, or eliminate the release or threat of
release.

'Where the reipontible partiet an known, cflortt an made, to the extent practicable, to have then perform the icspoue actions.
Enforcement negotiations eommonJy occur Jvst prior to the Rl/FS aad apin just prior to the RD/RA.

'Expedited Response Action (ERAs) an taken at NPL sites by the remedial profram osin( removal program authorities. ERAs must
comply with the policies, procedures, and refutations of the removal program. Like nmovals, ERAs may occur at any point during the
remedial process.
Source  is Reference 6.
                                                     98

-------
installing   security   fencing  to  excavating  and  removing  wastes  for
appropriate disposal.  EPA has conducted removal actions in response  to  a
wide    range    of    situations    including    illegal    disposal   and
transportation-related incidents.

SITE INSPECTION:  Where there is evidence that a site  poses  a  threat  to
human  health  or  the  environment, inspectors collect information to rank
its hazard potential.  Site inspectors look for  obvious  signs  of  danger
such  as  leaking  storage  drums,  dead or discolored vegetation, and soil
discoloration.  They  may  take  samples  of  soil,  water  or  air.   They
analyze  ways  that  hazardous  materials  from the site could be polluting
enviornmental resources, and check to see if children have  access  to  the
site.

HAZARD  RANKING;   Each  site  is  evaluated  against a ranking system that
addresses a variety  of  factors,  including  the  types,  quantities,  and
toxicity   of  the  wastes  involved,  the  number  of  people  potentially
exposed,  the  likely  pathways  of  exposure,  and  the   importance   and
vulnerability  of  the underlying supply of ground water.  Sites which meet
a threshold score on the ranking are added to the NPL.

NATIONAL PRIORITIES  LIST  (NPL);   The  NPL  is  EPA's  list  of  priority
releases  for  long-term  remedial  response.  Only those releases included
on the NPL are  considered  eligible  for  Fund-financed  remedial  action.
The  NPL  identifies the sites and the potentially responsible parties.  It
is updated once each year based on input from the States.

ENFORCEMENT:   For  all  Superfund  sites,  EPA   and   the   States   make
significant  efforts  to  identify  potentially  responsible parties and to
compel  them,  through  legal  action,  if  necessary,  to  undertake   the
required  cleanup  activities.   If  this  cannot be done, EPA will  proceed
with the .cleanup,  using  Trust  Fund  resources,   and  will  attempt  to
recover  the  costs  later, or it may ask the State to take the lead in the
cleanup.   Thus,  maintaining  complete  and  detailed  records   of   site
activities  is  essential  for  the  purposes  of  enforcement  activities.
Enforcement   actions   involve   settlement  agreements  with  responsible
parties, administrative orders against potentially responsible parties

                                     99

-------
compelling them to take various  forms  of  action   to   deal   with  problem
hazardous  waste  sites,  and civil  actions in which EPA and  the Department
of Justice are involved.

REMEDIAL INVESTIGATION/FEASIBILITY  STUDY  (RI/FSU  The  purpose  of  the
RI/FS  is  to  characterize  the  nature  and  extent of contamination, the
likely exposure pathways at a site and the extent of risk  raised  by  the
contamination,  in  order  to  select and evaluate  potential  remedies.  The
Remedial Investigation focuses on collecting data  and   characterizing  the
site  in  order  to assess threats or potential threats to  human health and
the environment posed by the  site  and  provide  data   needed  to  support
remedy  selection.   The  Feasibility  Study provides a detailed evaluation
of remedial alternatives using  environmental,  engineering,   and  economic
factors  in  accordance  with statutory requirements.  The  RI/FS results in
a  recommendation  of  preferred  remedial  action.  EPA  documents   the
selection  of  the  remedy  in  a  Record  of  Decision (ROD).  Remediation
goals, which establish acceptable exposure levels that   are  protective  of
human  health  and  the  environment, must consider "applicable or relevant
and appropriate (Federal  and  State  environmental) requirements"(ARARs).
The  evaluation  of  potential  remedial  alternatives  may  involve bench or
pilot scale  treatability  studies  to  determine  if  an  alternative  can
attain the expected or needed cleanup levels.

EXPEDITED  RESPONSE  ACTION;   When  threats  or  potential  threats to the
public  or   the   environment   are   determined   during    the   remedial
investigation,  an  expedited  response action may be Initiated.  This is a
removal action and  must  comply  with  the  regulations,  procedures,  and
policies   of   the   removal  program.   It  starts with   an  engineering
evaluation and cost analysis.  It may address such  Issues   as  alternative
public   water   supplies   and  should  address  permanent  solutions  and
alternative treatment techniques to the  maximum  extent  practicable.   An
expedited  response  action  must  meet  National  Environmental Policy Act
equivalency and must undergo a public comment period.

RECORD  OF DECISION (ROD):  The selection of a remedy 1s documented  1n  the
ROD.    All   facts,    analyses   of   facts,   and   site-specific  policy
determinations considered  in the course of carrying out activities in the

                                    100

-------
RI/FS are documented in  the  Record  Of  Decision  for  inclusion  in  the
administrative  record.   The  Record  Of  Decision describes how statutory
criteria are applied to the candidate remedial  alternatives  in  order  to
select  a  remedy.-  The ROD defines the performance levels, which provide a
baseline  for  demonstrating  remedy  effectiveness  and  compliance   with
ARARs.   The  ROD also provides the basis for future EPA efforts to recover
Fund monies spent on cleanup from responsible parties.

REMEDIAL DESIGN:  Remedial design  includes  the  preparation  of  detailed
engineering plans, drawings, and specification to implement the chosen
remedial   alternative.    It  specifies  the  requirements  necessary  for
construction or other remedial action activities  to  meet  the  objectives
of the remedial alternative.

REMEDIAL  ACTION;   Site  cleanup  is  conducted  during remedial action as
specified in the  Remedial  Design.   This  generally  involves  treatment,
disposal  or  containment  of the hazardous waste and cleanup, restoration,
or replacement of the affected resources.  The final step in  the  remedial
process  is  operation  and maintenance subsequent to the cleanup, which is
designed  to  ensure  continued  .functioning  and  effectiveness   of   the
remedial    response    action.    Operation   and   maintenance   is   the
responsibility of the States.

OIL  AND  HAZARDOUS  MATERIAL  SPILLS;   The  National  Oil  and  Hazardous
Substances Pollution Contingency Plan  defines  four  operational  response
phases   for   oil   and   hazardous  substances  removal:   discovery  and
notification;   preliminary   assessment   and   initiation   of    action,
containment,  counter-measures,  cleanup, and disposal; and documentation of
cost recovery.  The preliminary  assessment  evaluates  the  magnitude  and
severity   of   the   discharge,   assesses  the  feasibility  of  removal,
determines the existence of  potential  responsible  parties,  and  ensures
that  jurisdiction  exists for undertaking additional response actions.  In
the clean-up phase, defensive actions should begin as soon as  possible  to
prevent,  minimize,  or  mitigate  damage.   Actions may include: analyzing
water samples to determine the source and spread of the oil or hazardous
material; controlling the source of discharge; measuring and sampling;
                                    101

-------
damage control or salvage operations; placement  of  physical   barriers  to
deter  the  spread  of  the  oil  or  hazardous  substance  or  to  protect
endangered species; control of water discharged from upstream Impoundment;
use  of  chemical; and waterfowl conservation activities.   Documentation Is
collected and maintained to support  all  actions  taken  under  the  Clean
Water Act and to form the basis for cost recovery.

                              SARA, TITLE III

The  Superfund  Amendments and Reauthorlzatlon Act of 1986 (SARA), Includes
the Emergency Planning and Community Right-to Know Act of  1986,  known  as
Title  III.   It establishes an emergency planning and notification program
and a series  of  new  reporting  requirements  designed  to  Inform  local
communities  about  chemical  operations.   This  law requires that a state
emergency response commission be established  for  each  state,  which,  In
turn,   designates   emergency   planning  districts  and  local  emergency
planning  committees.    Facilities   that   handle   extremely   hazardous
substances  in  excess  of  amounts  established  by EPA through regulation
must notify the state commission of such fact and of any  releases  to  the
environment.

Other  Title  III  requirements  include  sending  the  relevant  emergency
planning  committee  and   the  local fire department a list of all Material
Safety Data  Sheets  for   chemicals  used  by  a  facility,  which  provide
chemical,  health,  and safety Information.  An inventory form must also be
submitted, which Includes  an estimate  of  the  average  daily  amounts  of
chemicals  at   the  facility  for those chemicals requiring Material Safety
Data Sheets.  Another Title III requirement is an annual report by
facilities on chemical releases to the air, water,  and  land  environments
that  result  from normal  business operations.  This report goes to EPA, as
well as to the  emergency response commissions.
                                     102

-------
                            REGULATORY CONTROLS

NATIONAL OIL AND HAZARDOUS SUBSTANCES  POLLUTION  CONTINGENCY  PLAN  (NCR);
The  NCR  is  the  regulation  governing  Superfund and Emergency Response.
Revisions to 40 CFR  Part  300  were  promulgated  on  March  8,  1990  (55
Federal  Register  8666).   The preamble provides a full explanation of the
cleanup program and the  rationale  for  any  changes.   The  NCP  addresses
both oil and hazardous wastes.

                             QUALITY ASSURANCE .

Quality  Assurance  (QA)  is an integral component of the Superfund program
and  applies  to  all  activities  affecting  decisions  on  site  listing,
emergency removals, remedial siste investigations,  and  remedy  selection,
design,  and  construction.   The  planning,  implementation, and review of
quality assurance and quality control activities  associated  with  program
activities   help   to   assure  that  the  environmental  data  collected,
analyzed, and used to make key  decisions  are  of  the  type  and  quality
necessary  for  each  decision.   The Agency has defined a comprehensive QA
program to help decision-makers identify  their  data  and  quality  needs,
provide  the  needed  level of oversight to assure that the needs are being
met, and provide a more  complete understanding of any  limitations  in  the
use of the data for their intended decisions.

DATA  SYSTEMS;   EPA's   comprehensive  data base and management system that
inventories and tracks releases addressed or needing  to  be  addressed  by
the   Superfund   program   is  CERCLIS,  the  Comprehensive  Environmental
Response,  Compensation,  and  Liability   Information   System.     CERCLIS
consists   of  three  distinct  inventories:  Removal  Inventory,  Remedial
Inventory,  and  Enforcement  Inventory.   Within   each   of   the   three
categories  are  active  and inactive releases.  Inactive releases are those
where a determination has been made based  on  available  information  that
no  further  action  is  needed.  Active releases are those for which (a)  a
lead agency has not yet  had an opportunity to  evaluate  response  actions,
(b)  there  has  been a  determination that further action is needed, or (c)
there is currently ongoing response action.
                                    103

-------
The Emergency Response Notification System,  ERNS,   tracks  response  action
notifications  or  discovery,  how  and  when  such  are received,  and what
happened as a result.

OtMTAD, the Oil and Hazardous Materials Technical  Assistance  Data   System,
1s  a  chemical  information  data  base  that  provides  human  health and
environmental effects data, criteria and standards, and  other  Information
related  to  a  particular  substance.   These  data  are  gleaned  from the
literature, and EPA reports and research.

RODS Data System for the Records of Decisions may be searched  to  identify
the  ROD  text,  abstract,  or remedy for a site; the contaminated  media or
principal contaminants; and the name and location of  the  site  addresssed
by  the  ROD  including  EPA  Region,  State, name of site, and location ID
number.
                                     104

-------
                             SUGGESTED READING

1.    40 CFR Part 300.  National Oil  and  Hazardous  Substances  Pollution
      Contingency Plan, 55 FR 8666, March 8,1990.

2.    Superfund  '88.   1988.   Proceedings of the 9th National Conference.
      The Hazardous Materials Control Institute, Silver Spring, MD.

3.    Preslo, L.M.,  et  al.   1988.   Remedial  Technologies  for  Leaking
      Underground Storage Tanks.  Lewis Publishers, Inc., Chelsea, MI.

4.    US  EPA.   1987.   Data  Quality  Objectives Development Guidance for
      Remedial  Response   Actions   (Two   Volumes).    US   Environmental
      Protection Agency, Cincinnati OH,  EPA/540/G-87/003.

5.    US  EPA.   1987.   The  New  Superfund; What It Is, How It Works.  US
      Environmental Protection Agency, Washington, DC (August).

6.    US EPA.  1987.  The RPM Primer - An Introductory Guide  to  the  Role
      and  Responsibilities  of the Superfund Remedial Project Manager.  US
      Environmental Protection Agency, Washington, DC,  EPA/540/G-87/005.

7.    US  EPA.   1987.   Superfund: . Looking  Back,  Looking  Ahead.    EPA
      Journal,   US  Environmental  Protection  Agency,  Office  of  Public
      Affairs, Washington, DC, January/February.

8.    US EPA.   1989.   A  Management  Review  of  the  Superfund  Program,
      Implementation  Plan,  The  Superfund 90-Day Study.  US Environmental
      Protection Agency, Washington, DC.

9.    US EPA.  1989.  A Management  Review  of  the  Superfund  Program,  A
      Comprehensive  Statement  of  Program  Philosophy.  US  Environmental
      Protection Agency, Washington, DC.

10.   Wagner,  Travis.   1988.   The  Complete  Handbook of Hazardous Waste
      Regulations.  A Comprehensive Step by Step Guide  to  the  Regulation
      of  Hazardous  Wastes  under RCRA, TSCA, and Superfund.  Perry-Wagner
      Publishing Co., Inc., Brunswich, ME.
                                    105

-------
                   ENFORCEMENT AND COMPLIANCE MONITORING

                                  SUMMARY

The  first  goal of enforcement is to deter persons from violating the laws
or regulations, which  protect  human  health  and  the  environment.    For
deterrence  to  occur,  both  a  potential   violator and the general  public
must be convinced that the penalty places a violator in  a  worse  position
than  those  who  have  complied  1n  a timely fashion.  EPA obtained civil
action cash penalties of $24.4 million and over $3.6  million  in  criminal
fines  in  1987.   The  Clean  Water Act led the list of civil  judicial and
administrative penalties with  66  cases  and  $6.9  million.   the  median
penalty was $50,000.

All   programs   are  designed  to  encourage  and  check  compliance  with
environmental laws and regulations.   Compliance  monitoring  includes  not
only  self  monitoring  and reporting by the manager of a facility in order
to comply with permit conditions, but also inspections  by  the  regulatory
agency.    Inspections   determine   the   compliance   of  a  facility  to
environmental regulations including the general operation of a facility.

Inspections or monitoring activities may uncover permit or law violations.
In such event, EPA may take one of  four  legal  actions  pursuant  to  the
appropriate  statute.   Generally,  the  first action is an informal  notice
of noncompliance or a warning letter.  If corrections are  not  forthcoming
as  a  result,  the  second  stage may be an administrative action under an
administrative law judge.  Usually, these actions result  in  an  order  to
correct   the  deficiencies  plus  a  penalty.  The vast majority of actions
that  EPA takes  are  through  this  process.    For   more   serious   or
recalcitrant  cases,  EPA  can  use  the  U.S.  Court  system  in  civil or
criminal  actions.   In such cases, the actions are taken by  the  Department
of  Justice  at the request of and with assistance by EPA.  Criminal  cases,
which can include Incarceration as one of the  penalties,  are  least  used
of the potential legal actions.
                                    106

-------
                                  CONCERNS

Compliance  with  Federal  statutes and regulations is the foremost goal  of
a regulatory agency.  Obtaining  compliance  and  deterring  the  regulated
party  from  future  violations are the major purposes behind penalties and
related  enforcement  actions.   Deterrence  fits  into   two   categories:
Specific  deterrence  fosters  compliance  and  deters  an  individual  from
committing a violation or allowing it to reoccur.   General  deterrence  is
an  enforcement  action that deters the individual's peers, the rest of the
regulated community, from violation.

Thus, the first goal  of  penalty  assessment  is  to  deter  persons  from
violating  the  law  or  regulation.   Successful  deterrence  is important
because it  provides  the  best  protection  for  the  environment  and  it
reduces  resources  necessary  for program administration.  If a penalty  is
to achieve deterrence, both a potential violator  and  the  general  public
must  be  convinced  that the penalty places a violator in a worse position
than those who have complied in a  timely  fashion.   The  second  goal  of
penalty  assessment  is  the  fair and equitable treatment of the regulated
community.   This  goal  is  tempered  by  factors  such   as   degree   of
willfulness  or  negligence,  history  of  noncompliance,  ability  to pay,
degree  of  cooperation  or  noncooperation,  and  other   unique   factors
specific  to  a  violator  or a case.  The third goal of penalty assessment
is swift resolution of environmental problems.

Penalties are associated  with  most  EPA  .statutes,  including  the  Clean
Water  Act,  Safe  Drinking  Water  Act,  Clean  Air  Act, Toxic Substances
Control Act, Resource Conservation  and  Recovery  Act,  The  Comprehensive
Environmental   Response,   Compensation  and  Liability  Act,  etc.   Cash
penalties are only one element of EPA's overall  enforcement  effort.   EPA
and  States  use other sanctions in addition to penalties, such as revoking
permits,  imposing  additional  compliance  conditions,   and   publicizing
enforcement  actions  to  create  deterrence.   EPA  has obtained over $114
million in civil penalties  from  its  creation  through  1987.   In  1987,
$24.4  million  in  civil  penalties  were  obtained and, in addition,  over
$3.6 million in criminal fines and over  84  years  of  incarceration  were
imposed.

                                    107

-------
The  Clean  Water  Act  led  the  list of civil  Judicial  and administrative
penalties with 66 cases and 6.9 million 1n penalties.   The  median  penalty
was  $50,000.   The  Stationary Source A1r program was second with 62 cases
and $5.6 million in penalties.  The  Mobile  Source  Air  program  had  353
cases   with  $4.8  million  in  penalltes.   The  largest  single  penalty
obtained in 1987 was $2.6 million,  which  was  brought  under  the  Mobile
Source Air program.  The total number of cases in 1987 was 1,442.
                              PROGRAM CONTROLS

COMPLIANCE  PROGRAM:   For  each  environmental  law and regulatory program,
EPA has developed a systematic program to achieve high compliance levels.
Each program Is different, taking advantage  of  the  unique  opportunities
                                                    /
presented  by  the  nature of the regulated community and the provisions of
the law.  One element of a compliance strategy is a  compliance  monitoring
plan,  which  sets  out the priorities and rationale for conducting on-s1te
inspections and other types of compliance monitoring.  Another  element  is
an  enforcement  response  policy,  which  details the appropriate level of
enforcement action associated with the many ways that a regulation  can  be
violated,   and   the   principles   and   rationale  for  determining  the
seriousness of various  types  of  violations  as  a  factor  in  assessing
penalty amounts.

COMPLIANCE  MONITORING;   A  fundamental  principle  of  EPA  environmental
policy  1s  that  regulated  parties  should keep track of their compliance
status and report all or part of the  resulting  data  to  the  responsible
environmental  agency.   Thus,  monitoring activity usually 1s conducted by
the regulated entity.  Monitoring may be augmented with Inspection  by  the
regulating  agency.   An  inspection  1s  an  examination into the records-
operations of a  single  regulated  facility  to  determine  if  it  Is  in
compliance  with  applicable  environmental  requirements.  Inspections may
be routine, as a result of a reason to suspect  that  a  violation  exists,
to  support  the  development  of  a  case, or, as a follow-up to determine
whether a facility found to have been in violation is  in  compliance  with
an administrative order or a consent degree.
                                    108

-------
INFORMAL  ADMINISTRATIVE  ACTIONS;   These  are notices of noncompliance or
warning letters, which are advisory  in  nature.   In  these  actions,  EPA
advises   the  manager  of  a  facility  what  violation  was  found,  what
corrective action is needed, and by what deadline the violation  should  be
corrected.   Generally,  informal  actions  carry neither penalty nor power
to compel action.  The record of an informal action can be  used  later  to
support more severe actions.

FORMAL  ADMINISTRATIVE  ACTIONS;  These are legal actions that result in an
order requiring the violating facility to correct  the  violation  and,  in
most  cases,  to  pay  a  civil  penalty  that  is  commensurate  with  the
seriousness  and  the circumstances of the violation.  These administrative
actions are strong enforcement tools; if a person  violates  the  terms  of
an  administrative  order,  EPA  may  obtain  U.S.  Court  action  to force
compliance with the order.  Because they are generally the  most  expedient
means  of  requiring correction, administrative actions are used in lieu of
civil or criminal actions whenever appropriate.

Administrative  actions  are  taken  under  EPA's. internal  administrative
litigation system, which is comparable to any  court  system,  except  that
it   is   presided   over   by   EPA's   administrative  law  judges.   All
administrative actions have the potential to  be  challenged  in  the  U.S.
Court  system.   Therefore,  conduct  of  these  actions  is governed by an
extensive set of procedural rules designed to provide due  process  to  the
alleged  violator  and  ensure  the integrity of the system.   Violators may
appeal the initial rulings of the  administrative  law  judge  to  the  EPA
Administrator  and  may  appeal  the  Administrator's final decision to the
U.S. Courts.

CIVIL JUDICIAL ACTIONS;  Civil actions are taken in the U.S.   Court  system
by  the  U.S.  Department of Justice at the request of EPA.  Typically they
are  used  against  the  more  serious   or   recalcitrant   violators   of
environmental   laws.    Generally   they   are  intended  to  seek  prompt
correction of imminent hazard situations  posing  an  immediate  threat  to
human  health  or  the environment.  Preparation of civil  judicial  cases is
resource intensive, both because of the Department of  Justice  involvement
and the more formalized procedures required for court actions as compared

                                    109

-------
 to   administrative   actions.    Sometimes  judicial  litigation  may   take
 several  years to  complete.    For  these  reasons,  EPA  usually  addresses
 violations  through  administrative mechanisms.   1f possible.  Civil  cases
 often result 1n penalties and court orders   requiring  correction  of  the
 violation  and  requiring  specific actions  such  as specialized monitoring
 to prevent future noncompllance.

 CRIMINAL JUDICIAL ACTIONS;   Criminal actions  are taken  when  a  person or
 company  has  knowingly and willfully  committed a  violation of the  law.  In
.a criminal case, the Department of Justice prosecutes an   alleged   violator
 in  the  U.S.  Court  system, seeking  criminal sanctions,  usually Including
 fines  and  Incarceration.    Criminal   actions  are  taken for   flagrant,
 Intentional  disregard  for environmental laws and deliberate falsification
 of documents or  records.   Criminal   cases   are   usually  brought  by  the
 Department  of  Justice  at  the  request of EPA,  but   the Department of
 Justice can initiate  them  on  its own.   Criminal  cases  are  the   most
 difficult   to   pursue.   They  require  special  investigation  and   case
 development procedures, and they involve  the  highest  standard  of proof,
 including proof of the intent of the violator to commit the violation.

 STATE/EPA  AGREEMENTS;   Virtually every  environmental statute provides for
 EPA delegation to or approval  of  State  programs to  implement   national
 standards  and  regulations  through  State-specified  rules,  permits, and
 enforcement activities.  In the enforcement   arena,  although  States   have
 primary   responsibility  for  compliance and  enforcement  action within
 delegated or  approved  States,  EPA  retains overall  responsibility  for
 ensuring  fair  and  effective  enforcement   of  Federal requirements  and  a
 credible national deterrent to noncompllance.  States  conduct  80 to 90
 percent   of   all  compliance  inspections   under delegated  or   approved
 programs.  EPA may also conduct Inspections   in  a delegated  or   approved
 program  State.   State-EPA enforcement agreements reflect the criteria for
 direct   enforcement   in   delegated    States,    protocols   for   advance
 notification and consultation, and  the  data the State  will  report to
 EPA.    EPA   may  take  direct  enforcement action  under  the  following
 conditions:  at the request of a State; when State enforcement response
                                     110

-------
is not timely or appropriate; when there  are  national  legal   or  program
precedents involved; or when there is a violation of an EPA order or
consent degree.
                             QUALITY ASSURANCE

NATIONAL  ENFORCEMENT  INVESTIGATIONS  CENTER (NEIC);  The NEIC manages and
directs EPA's criminal  investigation  program.    NEIC  provides  expertise
and  guidance  for  the  development  of  multi-media compliance monitoring
strategies and.assists the Department of  Justice  in  evaluating  a  broad
range  of  waste disposal and emission problems, monitoring technology, and
remedial programs.  NEIC operates an extensive  quality  assurance  program
because  any  piece  of  data must be able to withstand the scrutiny of the
Court.

Standard operating  procedures  have  been  developed  for  sampling  in  a
variety  of  environmental  media  and  conditions.   A  quality  assurance
project  plan  is  prepared  for  each  sampling  effort.  This plan may be
built upon standard operating procedures  that  have  been  prepared  on  a
program-specific  basis.   A sample documentation process has been prepared
that  addresses  field  measurements  and  sampling  processes,  laboratory
analytical methodology, chain of  custody,  sample  identification,  sample
seal,  and  field logbook entry.  Detailed procedures have been prepared on
all aspects of sample collection, packaging, and shipment to a laboratory.
                                    Ill

-------
                             SUGGESTED READING
1.    US  EPA.   1984.    Memorandum:    Courtney   M.    Price.   Assistant
      Administrator  for  Enforcement  and Compliance Monitoring, New Civil
      Penalty Policy.  US Environmental Protection Agency.   Washington,   DC
      (February 16).

2.    US   EPA.   1985.   Study  of  Literature  Concerning  the  Roles   of
      Penalties In Regulatory  Enforcement.   US  Environmental  Protection
      Agency,    Office   of   Enforcement   and   Compliance   Monitoring,
      Washington, DC (September).

3.    US EPA.  1986.  Memorandum:  A. James Barnes,  Deputy  Administrator,
      Revised  Policy  Framework  for State/EPA Enforcement Agreements.   US
      Envlromental  Protection  Agency,  Office   of   the   Administrator,
      Washington, DC  (August 25).

4.    US  EPA.   1988.   FY  1988  Enforcement  Accomplishments Report.   US
      Environmental  Protection   Agency,   Office   of   Enforcement   and
      Compliance Monitoring, Washington, DC.

5.    US  EPA.   1989.   Basic  Inspector Training Course:  Fundamentals of
      Environmental Compliance  Inspection.   US  Environmental  Protection
      Agency,    Office   of   Enforcement   and   Compliance   Monitoring,
      Washington, DC.
                                     112

-------
                      INFORMATION RESOURCES MANAGEMENT

                                  SUMMARY

Information gathering and management are extensive  and  capital   intensive
investments  of  EPA's human and operational resources.  In the information
area, EPA is governed by a number  of  applicable  Federal   laws  including
The  Paperwork  Reduction  Act, The Brooks Act, Freedom of Information Act,
Privacy  Act,  Federal  Records  Management  Amendments,   Competition   in
Contracting  Act,  and  Federal  Information  Processing  Standards.   These
Acts and  Standards  mandate  that  the  gathering,  use,  and  storage  of
information   be  done  wisely,  with  adequate  safeguards  for  sensitive
information and privacy protection.

EPA has established an internal  information  resources  management  office
that  has  review  and  oversight  authority  of EPA data systems, of which
there are  600,  including  10  to  15  major  systems,  that  concern  the
generation   of   new   systems,   data  collection  instruments  including
regulations, and general use of hardware and software.  Before a  new  data
system   can   be   implemented,  it  must  receive  careful   planning  and
documented   justification.    A   "mission   needs   analysis"    requires
consideration  of  the mission to be served, problems with  the present data
management system, alternative solutions, costs,  users  of  and  uses  for
the  system,  an  investigation of similar systems within EPA that might be
adapted and whether adaptable hardware and software  are  available  within
the Agency.

Federal  Information  Processing  Standards  and EPA Data Standards require
that data elements are consistent among all Agency data  systems  and  that
one  type  of data is defined in the same manner in all systems.   A Systems
Development  Center  is  provided  for  the  evaluation   of    new   system
development  methodologies  and  technologies  and to support, develop, and
enhance EPA existing data systems.
                                    113

-------
                                  CONCERNS

Information is an Agency asset, like personnel,  funds,  and  property.    The
gathering   and   management  of  Information and  information  technology
represent an extensive and capital intensive  investments  of  EPA's  human
and  other  operational  resources.   The  Paperwork  Reduction Act of 1980
Introduced Information Resources  Management  to  the  Federal  Government,
and  emphasized  information  as  a  resource with  associated  costs  and
values.   This  Act  established  a  broad  mandate for agencies to perform
their information activities in an efficient, effective  manner.   Concepts
advanced  through  the  Information  Resources  Management approach include
the life  cycle  management  of  information  activities,  i.e.,  creation,
collection,   and   use;   information   functions,  I.e.,  automatic   data
processing,     records     management,     reports     management,     and
telecommunications;  the  integrated  approach  to   managing   information
resources,  i.e.,  total  systems concept; and the promotion and use of new
technologies  to  improve  the   effective   use   and   dissemination   of
information.   The  objectives  of  the  Act  are  to  reduce  the  Federal
paperwork  burden;  reduce  the  Federal  cost  of  collecting,  using, and
disseminating  information;  increase  the   use   of   Federally-collected
information;  and  ensure  that applicable laws  relating to confidentiality
and privacy are followed.

There are several other associated laws and  directives.   The  Brooks  Act
(1965)  is  the  primary  law governing the overall Federal acquisition and
management  of  automatic  data  processing  equipment.   The  Freedom   of
Information  Act  (1966)  allows public access to a wide variety of Federal
Information.  The  Privacy  Act   (1974)  provides  certain  safeguards  for
individuals  against   an invasion of personal privacy.  The Federal Records
Management Amendments  (1976) require the  establishment  of  standards  and
procedures  to  ensure efficient  and effective Federal records management
practices.  The Competition in Contracting Act  (1984)  requires  full  and
open  competition  in   as  many   procurements  as  possible.   The  Federal
Information  Processing Standards  (FIPS), issued by the National Institute
of Science and  Technology  (NIST)  1n  accordance  with  the  Brooks  Act,
contain   standards    and  guidelines  concerning  the  standardization  of
computer hardware, software, and  systems.  The National Archives and

                                    114

-------
 Records   Administration   Regulation,   36  CFR   1220   and  41  CFR   201-22,
 establish  standard   records  management  practices   throughout the Federal
 government.

 All  EPA  regulations  and  other data collection  instruments are  reviewed   to
 ensure   that   the  Agency does not impose an unnecessary paperwork burden  on
 the  public.   EPA has about  600  data systems of which  10  to  15  are  major
 systems.    An approval   and  clearance  process  now is maintained for new
 data systems  and for data collection  instruments.
                              PROGRAM CONTROLS

STATE/EPA  DATA  MANAGEMENT:    It  is  EPA  policy  that  Agency  reporting
requirements  and   information  systems   will   be   responsive   to   the
information  needs  of  State   environmental  agencies  and  will take into
account the diversity among States  in  terms  of  organization,  resources
and  program  responsibilities.   New  EPA systems and data bases developed
to process and store data obtained from State  environmental  agencies  are
designed  to  support  timely and reliable State access to these data.  For
those States that agree to meet EPA  reporting  requirements  by  directly
entering  data  into  EPA  systems, the Agency will regard such data as the
official State record  of  the  delegated  program.   EPA  will  allow  the
States,  at  their • option,  also  to  enter  data  regarding non-delegated
programs into the EPA systems.

MISSION-BASED PLANNING;  EPA policy  requires  the  annual  preparation  of
mission-based  information  resource  management  plans for investments and
management of  information  resources  and  technology.    Where  costs  for
systems  development  exceed  $250,000, or meet other established criteria,
the development stages and the decision process  require  a  mission  needs
analysis,  preliminary  design  and  options  analysis,   and system design,
development  and  implementation  for  a  fully  implemented  system.    The
mission needs  analysis  specifies  the  nature  of  the  program  mission,
problem,  functions,  processes,  information flows,  and defines a specific
set of users and uses.  When this  planning  process  has  been  completed,
EPA's decision regarding a new system can be based on an analysis of

                                    115

-------
need,  benefits,  life-cycle  costs,  and  whether  adaptable  hardware and
software are available within the Agency.

DATA STANDARDS;   As  required  by  OMB  Circular  A-130,  EPA  adheres  to
Federal  Information  Processing  Standards  (FIPS)  and  will  develop and
Implement other data standards to ensure consistency in  the  use  of  data
elements,  and  that  one  type  of  data is defined in the same way in all
systems.  This means having the same  name,  the  same  number  of  maximum
characters  and  the  same  type and content of data in all systems where a
specific data item appears.  This consistency will permit the  cross  media
approach  necessary  to  achieve  environmental results and it will enhance
the sharing of environmental data with States and other Federal agencies.

INFORMATION COLLECTION;  EPA policy provides  that  the  data  requirements
of  Information  collection from the public must be clearly dictated by the
need to support decisions that serve an identifiable program  mission.    It
also  provides  that  any  information  collection  ought  to represent the
least cost alternative of acceptable options in terms of both cost  to  EPA
and  burden  on  the  public.   Burden refers to the total time, effort, or
financial resources expended by  persons  to  provide  information  to  the
Agency.    EPA   maintains   safeguards  to  protect  the  confidentiality,
integrity, and availability of sensitive information  and  the  privacy  of
Individuals, as required by The Privacy Act of 1974.

SYSTEMS  DEVELOPMENT  CENTER;   The Systems Development Center 1s the EPA's
Center of Excellence for systems and software  development  projects  which
support,  develop,  and enhance EPA data systems.  The Center evaluates new
systems development methodologies and technologies to  Improve  system  and
software  development  methods  and  strives  to better Integrate them into
the development process.   The  Center  was  conceived  to  help  meet  the
challenges  of  the  next  decade,  which  Include  better  Integration  of
environmental  data  and  systems,  creating common user Interface and data
     i*
standards, and  utilizing  new  technologies  in  the  systems  development
process.
                                    116

-------
                            REGULATORY CONTROLS

No   EPA  rules  have  been  promulgated  regarding  information  resources
management.   However,  policy  statements  and  administrative  directives
that affect the internal operations of EPA are issued  after  Green  Border
clearance  by  the  Assistant  Administrators.  Examples of such directives
and'policy statements include information  resources  management  controls,
review,  and  approval;  mission-based planning; State/EPA data management;
software management; data standards; automated  data  processing  resources
management;   voice   communication;   information   security;  information
collection; records management; and privacy safeguards.
                             QUALITY ASSURANCE

GEOGRAPHIC INFORMATION  SYSTEM;   This  is  a  computer-based  system  that
combines  geographic  and  cartographic  analysis with a computer data base
system that can support data  entry,  data  management,  data  manipulation
and  data  display  capabilities.  The system facilitates the overlaying of
information  on  standard  USGS  quadrangle  maps.   Standards  are   being
developed  by  information  resources  management  on  building the mapping
information system.

DATA SYSTEMS:  The  Information  Systems  Inventory  (ISI)  contains  basic
information  on  the approximately 600 EPA systems, data bases, and models.
One of  the  uses  of  this  system  is  in  the  gathering  of  background
information when new data systems are being contemplated.

Data  standards  are one form of quality assurance.  Data standards now are
under development  to  identify  facilities  in  data  systems.   With  the
current  use  of  Dun  and  Bradstreet numbers for facility identification,
there is often confusion  when  a  parent  corporation  owns  a  number  of
facilities.   Each  facility must be identified with a unique number.   Data
standards also are  under  development  for  location  data.   The  use  of
latitude and longitude is not universal throughout the United States.
                                    117

-------
Such  standards  have  been developed for the entry of laboratory  analyses.
Such data, generally from contract laboratories,  must  meet  this   standard
to be entered Into an EPA data system.
                                     118

-------
                             SUGGESTED READING
1.    US  EPA.   1987.  Information Resources Management Policy Manual.   US
      Environmental Protection  Agency,  Office  of  Information  Resources
      Management, Washington, DC.

2.    US EPA.  1989.  EPA System Design & Development Guidance:  Volume A,
      Mission  Needs  Analysis;  Volume  B,  Preliminary Design and Options
      Analysis; Volume C, System Design,  Development  and  Implementation.
      US  Environmental .Protection Agency, Office of Information Resources
      Management, Washington, DC.

3.    US EPA.  1989.  Information Resources  Directory.   US  Environmental
      Protection   Agency,  Office  of  Information  Resources  Management,
      Washington, DC.

4.    US  EPA.   1989.   Systems  Development  Center.   US   Environmental
      Protection   Agency,  Office  of  Information  Resources  Management,
      Washington, DC.
                                    119

-------
                              LIBRARY SERVICES

                                  SUMMARY

EPA has 28 libraries in Headquarters, Regional  Offices  and  Laboratories.
Their   collections   include  general  and  specialized  books,   journals,
reports, microfiche, reprints, and  maps.   Their  services  are   many  and
Include  a  world-wide interlibrary loan system for any piece of  literature
that  may  not  be  found  among  the  library's  abundant  collection;    a
literature  search  of 37 available databases with access, if necessary,  to
300 commercial databases; and a translation service  for  foreign  language
scientific  and  technical  documents.   A special collection of  references
for hazardous wastes has been established in 17 EPA libraries.

In addition,  EPA  has  specialized  libraries,  such  as  the  Legislative
Reference  Library,  Law  Library  and  the  Headquarters  Office  of Toxic
Substances Non-Confidential Information Center.   That  Center  specializes
in  chemical  literature  in  areas of biotechnology, chemical industry and
process technology, ecology, health, international  chemical  control,  and
pesticides.

EPA's  dockets  provide  information  related  to rulemaking actions.  This
includes  the  official  legal  files,  hearing   transcripts,   litigation
records,   and   public  comments.   There  are  eight  individual  dockets
addressing EPA's major rulemaking activities.
                                     120

-------
                             GENERAL LIBRARIES

There are 28 EPA libraries  in  Headquarters,  Regional  Offices,  and  EPA
Laboratories.   These  libraries  contain  a  combined  collection  of over
128,900 books, 5,088 journal  subscriptions,  357,146  hard  copy  reports,
2,166,500  documents  on , microfiche,  9,000  journal article reprints, and
2,000 maps.  Most of the EPA  library  holdings  are  catalogued  on  OCLC,
(Online Computer Library Center) a national cataloging system.

The   services   provided  include  acquisition  of  books,  journals,  and
reports; cataloging;  circulation;  access  to  the  collections  of  other
Federal,  academic,  public  and  special  libraries  through  interlibrary
loans;  and  reference assistance, including preparation of special  subject
bibliographies and bibliographic database  search  services.    There  is  a
special  collection  of  3,100  books,  journals  and  reports  on hazardous
waste, which is housed in 17 selected  EPA  libraries.   The  documents  in
the   hazardous   waste  collection  have  been  entered  into   a  PC-based
database, which is updated quarterly and may be obtained.

The EPA Headquarters library has 15,000 books;  625  current  subscriptions
to  journals,  abstracts  and  indexes,  newsletters and newspapers; 23,000
hard copy documents and technical reports generated by  government  sources
or   the   private  sector;  335,000  documents  on  microfiche,  including
technical reports produced by EPA  and  its  predecessor  agencies;   and  a
microfilm  collection  that  includes  back  files of newspapers, abstracts
and indexes, and periodicals.

                        GENERAL EPA LIBRARY SERVICES

By their nature, EPA libraries  are  organized  to  serve.    They  offer  a
number  of  services in addition to the literature resources available in a
multitude of environmental  subjects.

ACQUISITIONS;   Books,  reports,   subscriptions,   and   other   reference
materials  are  ordered.  The policy varies among Regions regarding  payment
by the library or program office for literature materials purchased.
                                    121

-------
CATALOGING;  Books, journals,  and other  documents  are   cataloged   Into   the
EPA national catalog.

INTERLIBRARY   LOAN;   The  Inter!ibrary  loan  service  Is   a  cooperative
lending and borrowing arrangement  between  government,  academic,  special
and  public  libraries  throughout  the   world.    This service  provides  EPA
staff with  information  resources   that  are  not  held  in a  particular
library.   EPA  employees  may  use  this  service  for  EPA projects   and
activities.   EPA  contractors  also  may  use the service for  EPA projects
and activities if the contract project officer sends  a  signed  letter   to
the  Head  Librarian stating that he/she will be liable for  items borrowed,
how long the library should serve the  contractor,  and  the name  of   the
contractor.   The  average  turnaround  time  for borrowing  through library
loan 1s approximately 3 to 7 working days.

LITERATURE SEARCHING;  Computerized searching of commercial   databases   and
selected   EPA  databases  is  performed  for  EPA  employees  to  retrieve
information for policy decisions, report  preparation,  data analysis   and
background    research,    and   for   preparation   of   special   subject
bibliographies.   EPA  uses  37  databases  and  has  access to   over   300
commercial databases.   Examples  are:  CAS  Online,  Chemical   Information
System,  DIALOG,  Ground  Water  On-Hne,  LEXIS/NEXIS, National  Library of
Medicine, NewsNet, Washington Alert, EPA's  Hazardous  Waste Database   and
Information  Systems  Inventory,  Integrated Risk Information System, Toxic
                        -\
Release Inventory, Record of Decisions (ROD), the Department of   Justice's
JURIS,  Comprehensive  Environmental  Response,  Compensation and Liability
Information System, and Facilities Tracking System (FINDS).

REFERENCE;  On-site ready reference service Is available to  EPA  staff   and
the public.

EQUIPMENT;    Photocopy   machines   and   microform   reader/printers   are
available  to library patrons for the reproduction of  up  to  25  pages   of
literature  not covered by copyright.

TRANSLATIONS;   The  EPA  translations   service  was established 1n 1972 to
provide EPA employees with a mechanism for having scientific and

                                    122

-------
technical  documents  translated  from  and  into  English.   A  microfiche
collection of over 10,000 documents translated by EPA  since  that  service
was  initiated  is  available.   Microfiche  copies  are  available  to EPA
employees  at  no  cost.   Non-Government  requestors  can   purchase   EPA
translations.
                           SPECIALIZED LIBRARIES

LEGISLATIVE  REFERENCE  LIBRARY;   The  Legislative  Reference  Library  is
maintained  by  the  Headquarters  Office  of  External  Affairs to provide
Federal  environmental  legislation  information  for  the   Agency.    The
Library  contains  over 8,000 documents produced by Congress such as copies
of bills, reports,  public  laws,  committee  prints,  committee  hearings,
legislative  histories,  Congressional Records, Senate and House calenders,
phone books, directories, and other information.

LAW LIBRARY:  The EPA Law Library is maintained by the  Office  of  General
Counsel   to  provide  information  services  to  the  Agency's  legal   and
enforcement personnel, and to  the  ten  Regional  Counsels.   The  Library
contains  9,500  volumes of legal and law-related material concentrating on
Federal law, with special  emphasis  on  administrative  and  environmental
law.   Included  are statutes, codes, regulations, case reporters, digests,
citators, and legal reference sources.

HEADQUARTERS  OFFICE  OF  TOXIC  SUBSTANCES  NON-CONFIDENTIAL   INFORMATION
CENTER;   The  Center has 5,000 books, 89 current journals, a collection of
5,000  technical  reports,  and  a   microfiche   collection   of   140,000
scientific   and   technical   journal  articles.   The  collection  covers
chemical literature  in  areas  of  biotechnology,  chemical  industry   and
process  technology,  ecology,  health,  international chemical control  and
pesticides.
                                    123

-------
                                  DOCKETS

Dockets are the official legal  files of rulemaking actions.    They  include
official   statements  of  the  Administrator's  position,  represented  by
published  rulemaking  documents;  information  considered  by  the  Agency
during  rulemaking;  transcripts  of  hearings;  litigation   records,   and
comments  received  from  persons  outside the Agency.   Dockets are open to
the public in accordance with the requirements set  forth  in  the  Freedom
of Information Act.

The  major  dockets  in  EPA  are:  (1)  Public  Information Reference Unit
(Water,  Air,  Noise),  (2)  Air  Docket,  (3)  Resource  Conservation  and
Recovery Act (RCRA)  Docket,  (4)  Superfund  Docket,  (5)  Drinking  Water
Docket,  (6)  Toxic Substances Docket, (7) Federal Insecticide, Fungicide &
Rodenticide Act  (Pesticides)  Docket,  and  (8)  Underground  Storage  Tank
Docket.

-------
                             SUGGESTED READING
 1.   US   EPA.   1985.  Translation  Services.  Information  Services  and
      Library, US Environmental Protection Agency, Washington, DC.

 2.   US EPA.  1986. The Interlibrary  Loan  Service  of  the  Headquarters
      Library.    Information   Services   and  Library,  US  Environmental
      Protection Agency, Washington, DC.

 3.   US  EPA.   1987.   Services  of  EPA's  Public  Information   Center.
      Public   Information  Center,  US  Environmental  Protection  Agency,
      Washington, DC.

 4.   US  EPA.   1987.   Searching  for  Answers:   A  Guide  to   Database
      Searching   at   the  EPA  Headquarters  Library.    US  Environmental
      Protection Agency, Washington, DC.

 5.   US EPA.  1988.  EPA Headquarters  Library  Information  Services  and
      Collections.  US Environmental Protection Agency,  Washington, DC.

 6.   US   EPA.    1988.    Technology   Transfer:    Clearinghouses.    US
      Environmental  Protection Agency, Washington, DC, EPA/IMSD/88-006.

 7.   US   EPA.   1988.   Directory  of  State  Indoor  Air  Contacts.   US
      Environmental  Protection Agency, Washington, DC, EPA-400/1-88-003.

 8.   US EPA.  1988.   Directory  of  State  Environmental  Libraries.   US
      Environmental  Protection Agency, Washington, DC, EPA-IMSD/88-010.

 9.   US   EPA.    1989.    A   Pathfinder   to   Major  EPA  Dockets.   US
      Environmental   Protection  Agency,  Washington,  DC,  EPA/IMSD/87-001
      (Revised in 1989).

10.   US EPA.  1989.  Guide to  EPA  Libraries  and  Information  Services.
      US Environmental Protection Agency, Washington, DC, EPA/IMSD/89-008.
                                    125

-------