United States Office of
Environmental Protection Public Awareness (A-107) OPA 88/9
Agency Washington DC 20460
&EPA EPA Annual Report to
Pollution Engineers
Reprinted from Pollution Engineering magazine,
January 197!, Volume Eleven, Number One.
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Streamlining the regulatory effort
DOUGLAS M. COSTLE
Administrator
President Carter's message to the nation on inflation
set an important new course for the nation's economy.
Prior to his national address, the President asked the
regulatory agencies to develop recommendations for
improving management of the entire—and somewhat
fragmented—federal regulatory system. These agencies
jointly proposed the formation of a council which
would analyze and better manage aggregate regulatory
economic impacts, hold all agencies accountable for the
results of their decisions, and also allow agencies to
freely and openly pursue the regulatory task assigned
them by Congress.
In my role as Chairman of the Council, I have
already concluded—in discussions with my colleagues
in other agencies and departments—that there is a very
serious determination throughout this administration to
make regulation more effective; to eliminate un-
necessary economic and administrative burdens; to do
away with duplication, overlaps and inconsistencies;
and to accelerate our efforts to carry out more effective
research, regulatory development and enforcement.
I think you will find some significant new approaches
in our regulatory agencies—a greater emphasis on the
big problems and on the setting of priorities; a pruning
of the undergrowth of regulation which has sprung up
over the years, often obscuring the total landscape of
purposes and objectives.
The President reminds those of us in government that
we are a community of interests, that sometimes
individual sacrifice is necessary for the greater good of
the nation. In some of our regulatory activities we have
lost that sense of community. We have sometimes
hidden the broader perspective behind a more narrow
expediency. The Regulatory Council will attempt to
restore that perspective, that sense of community. It
will attempt to rationalize the complete body of
government regulations.
That does not mean we will go through the
regulatory calendar like a thresher, throwing out
regulations by the bushel, or even by the peck. Nor
does it mean that the door is open to a challenge of
every regulation that may seem individually burden-
some. It does mean a careful, studious examination of
the total regulatory agenda.
More specifically, the Council will:
• Develop a regulatory calendar for major (costing
over $100 million) regulations, and update this docu-
ment on a semiannual basis;
• Identify and seek to eliminate duplication, overlap
and inconsistencies among regulations proposed by the
various agencies;
• Seek areas where cooperative efforts will be
beneficial, such as common data bases or joint
economic studies;
• Identify areas of the economy which may be par-
ticularly affected by agency regulations—combined or
individual—and work together to help minimize the
impact;
• Identify areas for potential joint development of
regulations; and
• Make recommendations to the Council members and
to the President regarding desirable changes in
regulatory programs which may resolve difficult issues.
On its own, EPA has continued to take steps to
overhaul its standards and regulations in an attempt to
make them compatible with America's economic goals.
The Agency has proposed revised conventional water
pollutant standards for 36 industries under authoriza-
tion of the 1977 Clean Water Act. The changes were
proposed in light of the fact that: (1) the affected
(primarily food processing, glass manufacturing and
ferroalloy) industries were already cleaning up 98
percent of their discharges; (2) left as they are, the
current standards would force these industries to spend
roughly the same amount to clean up the remaining two
percent of the pollution at an estimated $200 million,
and; (3) the revised standards would not result in any
significant adverse water quality impact.
After reviewing recent scientific evidence on the
health and welfare effects of photochemical oxidants
(smog), EPA in June proposed to adjust the ambient
air quality standards set in 1971 for this pollutant.
Reevaluation of the evidence indicated the incidence of
asthmatic attacks is greater above 0.2S parts per million
(ppm) than below. EPA's proposal, while still retaining
the legal "margin of safety" requirement, would change
the standard from 0.08 to 0.10 ppm and would
probably save business and industry millions of dollars.
The EPA's new standards for airborne lead also call
for the agency to work closely with states and affected
industries to develop plant-by-plant monitoring and
compliance programs. While airborne lead must be
curtailed, we do not believe that a major disruption of
the smelting industry is an acceptable consequence. At
the same time, such a one-on-one approach as men-
tioned above will enable EPA to better illustrate its
concerns over the economic impact of its regulations.
And the EPA has instigated other regulatory reform
JANUARY 1979
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430R79001
measure:, both procedural and substantive in nature.
Proposals to revamp the administrative hearing process
under the Clean Air and other Acts—which could save
industries some 30 percent in time delays and hearing
costs—have been put forth. EPA has begun a thorough
overhaul of regulations dealing with the processing of
permit applications under the Clean Air Act, the Clean
Water Act—under all federal laws forming the founda-
tion upon which the Agency bases its rules and
regulations. These proposals, which have been
developed with business and industry assistance, should
save time and money for both government and in-
dustry.
While the EPA will continue to concern itself in part
with the economic impact of its decisions, it will also
continue to follow its Congressional mandate for
environmental protection. The federal legislature has
assigned the Agency with this task, and the American
people are increasingly embracing a- stronger concern
for environmental quality improvements.
Recent public opinion polls exemplify the public's
concern with environmental pollution problems. An
average of 66 percent of those polled in a July 20, 1978
Harris Survey cited air pollution by industry, the
pollution of lakes and rivers with toxic substances and
other pollutants, and pollution by chemicals as "very
serious environmental problems." Still another survey
revealed that 76 percent of all Americans feel that
curbing air and water pollution is very important to
improving the quality of life in this country, up from 68
percent last year.
Even where their pocketbooks are affected,
Americans are still firmly in favor of environmental
progress. One survey by a major polling organization
last year found a 68 percent majority willing to pay
higher taxes and prices for environmental protection.
And while increased government spending is obvious-
ly not a popular subject right now, polls indicate that
not enough is being spent on environmental controls; a
majority of Americans—52 percent—feel the govern-
ment is spending too little. That figure is up from 47
percent last year. Even in California, where voters
started a political storm by passing Proposition 13,
citizens there also passed a $375 million bond
authorization measure promoting water pollution con-
trol, reclamation and reuse.
The EPA is well aware of the economic impact of its
many regulations and, as noted above, it is attempting
to reduce some of the impacts when leeway is both
deemed environmentally sound and allowable under the
law. At the same time, the Agency is well aware of what
Congress has ordered it to do, and it is well aware of
the public cry for a cleaner environment. It will
continue to do its work with these concerns in mind.
EPA must, as is its mission, enable the public use of
the environment without allowing the environment to
be "used up" and rendered useless for all. There are
economic incentives for this also.
Americans have indicated their support for en-
vironmental objectives. But they remind us that we
must pursue those benefits at reasonable costs.
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A look at the environmental
balance sheet
BARBARA BLUM
Deputy Administrator
Somehow, somewhere, there has developed the myth
that it is inappropriate for regulators to be interested in
things like free enterprise, inflation and economic
growth. That myth has been supported by another
myth: that economic growth and environmental protec-
tion are fundamentally at odds. These myths deserve to
be debunked.
A healthy environment and a healthy economy are
both necessities. I find it tiresome to have our work
constantly judged in terms of "selling out the environ-
ment to make life easy for industry" or of "ignoring
economic realities in pursuit of some super-idealistic
concept of the environment." Sometimes we're attacked
in both sets of terms for the very same decision.
We are here to protect the environment, under the
terms of laws signed by both Republican and
Democratic Presidents. We are here to uphold our
duties under those seven laws at a minimum level of
interference with business, industry, local government,
state government and everyone else the law tells us to
regulate.
We don't feel that there is an either-or relationship
between sound economics and the environment, that
pollution is free and cleanup is costly. We don't think
that when industries polluted the Cuyahoga River so
thoroughly that it could catch on fire there was no cost
to the people of Cleveland, even if the pollution was
accomplished at next-to-no cost by the dumping in-
dustries. We don't think that there is no cost to the
people of Gary, IN when United States Steel pollutes
the air. Yet neither do we think that there is no cost to
Gary when United States Steel shuts down.
There are costs in cleaning up the environment, but
there are severe costs for economists to measure in
public health when pollution continues.
We can reasonably hope that some day the counter-
pans of the economists who are so quick to figure the
cost of pollution control will learn to calculate the cost
of the public health menace of leaving things alone.
Yet I'm not sure that we will ever be able to put a price
tag on the ability of a father in Cleveland, Detroit or
Chicago to take a child fishing.
We think that it is possible to clean up the
environment and do it in a way that avoids unnecessary
costs, and in a way that takes into account the
difficulties that the sudden changes or adjustments
compelled by environmental laws impose. We don't
want to put companies out of business, because we
don't want people to lose their jobs.
However, we don't want to be used as an excuse for
second-rate management, either. We don't want to be
blamed for some company's distress because we seem
like an easier target than the Japanese, the unions,
changing consumer tastes, or just a plain old-fashioned
failure to keep up with the industry.
There may be no alternative for the cost of a
scrubber that removes emission from a power plant
smokestack but, from a regulatory perspective, there is
plenty of alternative for seven forms when one will do.
Regulatory reform is one of our major interests at
EPA, from shortening the time for various actions, to
making English the official language of EPA. One
effort we made that has attracted some favorable
attention lately—even from such a critical observer as
James J. Kilpatrick—has been the changes in the way
we issue pollution control permits.
In September we announced new procedures that will
take some of the uncertainty and some of the cost out
of obtaining all the different pollution control permits
required to build a new plant or factory. There are
several elements in this plan, and they include a single
individual in each Regional Office charged with
shepherding the various applications through the
bureaucratic maze. We're working to develop a single
application, even if the terms of the different laws do
prevent us from developing a single permit covering
water, air, solid waste and everything else.
What may be even more important than the sub-
stance of these changes is the way that we got there. We
didn't start with a blinding flash of inspiration at
Headquarters. This process started when Bill Dodge,
the environmental control manager at Caterpillar Trac-
tor, wrote us a letter outlining some of the problems
and uncertainties in the way we did our business. At
least theoretically, a company could invest millions of
dollars in a new factory before learning that the permit
which-took-the-longest couldn't be issued.
We thought Bill Dodge made sense. We got him
together with other industry representatives, with
leaders of environmental organizations, and with the
people in our Agency who write and administer the
procedures, and we worked together to eliminate
pointless costs.
Looking—again with industry and environmentalists'
cooperation—at a series of reforms we group together
as "regulatory market strategies," we recognize that not
all methods of controlling pollution are created
economically equal, and that a more flexible approach
JANUARY 1979
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may get as much or even more pollution control at less
cost.
The potential applications of these strategies include
"banking" of pollution control in excess of require-
ments for later use in plant expansion, various possible
ways of trading or selling such accomplishments, and
the bubble concept, under which the pollution from an
entire plant instead of each individual process is mea-
sured. These approaches could enable the operators of a
plant to decide, for example, if it is cheaper to control
one pollution source drastically and another lightly,
instead of controlling both moderately. We think that
we can make regulation cheaper, thus making cleaning
up the environment cheaper.
We're at work on a major effort to learn what we
have gained from several years of pollution control
efforts. Specialists within the Agency are at work on a
series of environmental indices which should, when fully
developed, tell the American people what they are get-
ting in exchange for the time, trouble and money that
have been expended on behalf of a clean environment.
Publication of these reports has already begun in our
northwest Regional Office; and we are pushing ahead
with national measurements.
Another major emphasis in our work will be a much
heavier investment in research to determine as precisely
as possible the public health impact of various pollut-
ants and levels of pollution. For some elements of our
basic legal charters, such as automobile emissions, Con-
gress set a specific standard. For many others, it left the
job of deciding what was an "ambient" and "hazard-
ous" standard up to us. We are going to be putting more
money and more effort into health effects research on
those issues.
Our duties in regulating toxic chemicals will require us
to regulate specific products, rather than overall levels
of pollution, as the general focus of the Clean Air and
Clean Water Acts has compelled us to, and this plainly
requires an expanded research effort to know how dan-
gerous any particular chemical may be.
Any time we can deal with an issue or a problem
before us in a way that will save time, money and jobs
for the American economy, but will not threaten the
environment, we intend to do so. This is our position,
because we do not want pollution control to be a burden
that is resisted. Money saved by reducing unnecessary
regulation means more money available for more pollu-
tion control, for modernization of plant and equipment,
for holding prices down, for dividends for stockholders.
Each one of those uses is more desirable than spending
on unnecessary regulation.
It is the same self-perception that led us to work on
developing an urban policy for the Environmental Pro-
tection Agency, and to join enthusiastically in develop-
ing the Carter Administration's overall urban policy. The
simple explanation for our concern is that the worst ex-
amples of every kind of environmental insult can be
found in the cities, whether it is bad air, foul water,
waste disposal or whatever. For many years, the envi-
ronmental movement has focused so much of its atten-
tion on the wilderness that we have been regarded as
elitist. This is a charge with more than a grain of truth to
it. EPA will not forget the wilderness, but it is in the
urban environment that people, particularly inner-city
people, are our most endangered species.
There are several concrete ways in which we, at EPA,
can help the nation's cities. The various offset policies I
discussed earlier will have their primary impact in areas
where the air is already bad, so that they will help pre-
serve the possibilities of economic growth.
We are concerned that our sewage treatment grants
have encouraged a suburban sprawl that has stimulated
inefficient use of resources. We are now seeking to use
those grants to encourage more sensible use of sewage
treatment funds. We think of this policy as another con-
structive approach to the economy. Consider tax dollars
alone, for a moment, of permitting our cities to fall
apart and our inner-city residents compared to sub-
urbanites to suffer from 50 percent higher levels of
hypertension, heart disease, chronic bronchitis, emphy-
sema, sight and hearing impairment, cancer and con-
genital anomalies. This is a social waste—far more
serious than unnecessary paper work imposed from
Washington.
Our primary concerns are environmental, not eco-
nomic. If there is no alternative between closing down a
polluting factory and continuing an illegal level of pollu-
tion—a level prohibited by an act of Congress—we will
have that factory closed down.
But we do not believe that extreme case is typical or
even frequent. We think that we can work with industry,
and with environmental organizations, for a healthy
environment, and a healthy economy.
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EPA's share in the regulatory
reform program
WILLIAM DRAYTON, Jr.
Assistant Administrator
for Planning and Management
As part of his anti-inflation program. President
Carter has established a Regulatory Council to manage
the federal government's overall regulatory program.
In this interview, William Drayton, Jr., EPA Assis-
tant Administrator for Planning and Management,
discusses the Agency's continuing efforts to improve its
regulatory process and the role of the Regulatory
Council, chaired by EPA Administrator Douglas Cos-
tie.
Q. In simplest terms, what does regulatory reform
mean at EPA?
A. It means finding ways to do our job better—more
surely, with more careful balance, quicker and more
economically. Regulatory reform helps everyone. Get-
ting a pound of pollution out for SO cents rather than a
dollar helps the environment as much as those we
regulate: it makes it easier to get more pounds out.
Taking away the advantages of noncompliance that the
small minority of scofflaws have traditionally obtained
by violating the law, as we are doing with our new
economic charges for noncompliance, removes the
economic incentive that encourages noncompliance,
reduces the Agency's and the states' administrative
costs, and protects the scofflaws' complying com-
petitors from unfair competition. A simpler, less
legalistic hearing process helps everyone get to more
sensible decisions with less effort and cost.
Q. How does this tie in to the new Regulatory
Council?
A. President Carter wants all federal regulatory
agencies to adopt such a streamlining policy; he's asked
the Council to help him in this regard.
Q. Is the principal purpose of the Regulatory Council
to keep regulations from being written?
A. No, absolutely not. The President created the
Council chiefly because he wanted his regulatory
managers to help him manage the government's overall
regulatory program. Regulation has grown very rapidly
over the last decade. Until now it has been run in tiny
pieces. There are over 100 federal organizations in the
regulatory business. We haven't had an ..overall picture
of what we're doing, and efforts to make the pieces fit
together have b-en, by and large, weak and inadequate.
Since the Carter Administration began, the regulatory
agencies have been trying to work together more and
more. For example, EPA has cooperated with the
Consumer Product Safety Commission, the Oc-
cupational Safety and Health Administration, and the
Food and Drug Administration to do a better job of
regulating toxics, a critical field where their respon-
sibilities interrelate.
The Council is the logical next step. It will develop a
calendar laying out all the significant regulations being
developed around the government; using this overview,
it will spot overlaps, conflicts, and opportunities for
collaboration and efficiencies. Then, led by the Council,
the affected members will form work groups to take
appropriate action. Because the Council and its
chairperson report to the President and will meet
regularly with him, it will provide him with the
mechanism he needs to manage his regulatory establish-
ment more effectively. This whole approach is a good
example of his management style—active, direct,
sophisticated, even when dealing with something as
complex as Federal regulation, and reliant on his line
management team.
O. Who will participate in the Regulatory Council?
A. All of the Executive Branch Departments and
Agencies with major regulatory responsibilities, sitting
in their capacity as regulators. Independent regulatory
agencies (e.g., the Consumer Product Safety Com-
mission) have also been invited to participate in the
Council's work, and we expect most of them will.
Q. Will the Council be able to veto regulations?
A. No. It has no legal authority to do so. It can help
the member agencies to recognize problems for those
being regulated and can recommend ways of avoiding
those problems. It does, however, have the specific
authority to recommend that its very interested boss,
the President, take action.
Q. What yardsticks will apply in judging regulations?
A. There are a number of yardsticks: importance of
the public benefits achieved, energy efficiency, direct
and indirect costs, whether or not there are more
promising alternatives, impact on the distribution of
goods and service, administrative feasibility, whether or
not the proposed regulation can be enforced easily,
legality and others. We must weigh costs against
benefits carefully, even while recognizing that such
analysis can only help, not replace judgment. What is
the value to society of a life, or illness, or clean air and
water? There is no simple regulatory "go/no go"
formula. But we can do a much better job of
underpinning judgment with disciplined analysis. EPA
and the Council will press the development and
application of those methodologies.
Q. Which is more important, controlling inflation or
cleaning up the environment?
A. They are both important, and by and large these
two objectives do not conflict. As long as the benefits of
JANUARY 1979
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environmental regulation—ranging from fewer deaths
and illnesses through increased crop yields to the freedom
to swim or fish on the river next door—exceed the costs,
environmental regulation leaves society richer on balance
than it would be without regulation. This is anti-
inflationary. That's one of the reasons the public con-
tinues to advocate more spending on environmental
cleanup (60 percent of those polled), not less (7 to 10
percent). People are pretty smart. They know en-
vironmental regulation is a bargain. The public's judg-
ment is supported by the studies we and others have done.
EPA was created to correct a massive market failure. It
has made our peoples' lives safer and happier; i.e., it has
made our economy much more efficient. That is not to say
that we can't achieve those objectives more efficiently. We
can and, through our regulatory reform program, are
trying to do so. Every such improvement we make helps in
the fight against inflation.
Q. What is known about the cost of all government
regulations?
A. Unfortunately, very little. Some agencies may
have identified the cost and impact of their own
regulations, and some academic studies have taken a
stab at overall estimates of cost, but no one has
thoroughly, systematically compiled all regulatory costs
or their effects on inflation. The Regulatory Council is
going to attack this problem. It's going to be a very
tough job. We should not expect too much too soon.
Q. Is the public willing to pay for environmental
cleanup now that it's so costly?
A. I believe the public is willing to pay if the costs are
reasonable. The polls consistently show that people are
willing to pay for the cleanup. But the polls also show
that inflation is the number one concern among our
citizens. 1 think this calls for the approach we are
taking: cost-beneficial regulation.
Q. What compromise is EPA willing to make to
combat inflation?
A. It is not necessary to compromise our basic goals
or objectives. We will continue to try to regulate in the
spirit that our job, representing the President, is to try
to make the same sort of balanced judgment the public
would if it had the time to master all the technicalities.
We actively try to balance costs and benefits as best we
can. We have, for example, cut back several air and
water standards that, on review, seemed to impose
excessive cost—saving over $1 billion.
Q. What is the Regulatory Council's agenda?
A. Its first order of business will be to prepare, by
February 1, 1979, a calendar that lays out what
regulations the various agencies are developing, on
what schedule, for what purpose, and at what cost. This
calendar will help the President and the Council decide
where it should focus its work over the coming year.
We have a lot to do.
Controlling toxics: The road ahead
STEVEN D. JELLINEK
Assistant Administrator
for Toxic Substances
One of the major concepts underlying the Toxic
Substances Control Act (TSCA) is that the health and
environmental hazards stemming from our society's
heavy reliance on commercial chemical substances
reach into virtually every nook and cranny of modern
life. Nothing we touch, smell, consume or otherwise use
throughout a given day hasn't in turn been affected in
some way by chemicals.
Relatively little is known about the long-term,
chronic effects that result from exposure to many of
these chemicals. Under TSCA, however, EPA for the
first time has the necessary authority to gather certain
kinds of basic information on chemicals, to identify
harmful substances, and—when other environmental
laws cannot control the specific sources of exposure,
which often involve production and use—to control
those substances whose risks of injury to public health
and the environment outweigh their benefits to society
and the economy. Not only can we prohibit the
production and use of such chemicals, but we can take
a number of other actions to attack the root causes of
toxic substances problems in virtually every facet of
industry—product development, testing, manufac-
turing, processing, distribution, use and disposal. EPA
takes these enormously difficult and complex respon-
sibilities very seriously. With jurisdiction over as many
as 70,000 commercial chemical substances manufac-
tured or processed in up to 115,000 establishments
nationwide, TSCA's mandate to protect public health
and the environment from unreasonable chemical risks
will not be achieved overnight.
However, we have set a number of short- and long-
term objectives for implementation of TSCA aimed at
building a strong, viable program for the future, while
vigorously addressing very real and pressing chemical-
related problems we face today. These objectives may
be summarized as follows:
• Develop the organization and staff necessary to carry
out EPA's responsibilities under the Act;
• Define methods for assigning priorities to chemical
substances requiring investigation or regulation;
• Gather information on the production, use, exposure
and other basic characteristics of important chemicals;
• Develop testing standards for health and en-
vironmental effects of concern, and issue rules requiring
testing of selected substances or classes of substances;
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• Regulate the production, use, distribution, and/or
disposal of selected substances or classes of substances;
• Develop a coherent Agency-wide approach to toxic
substances; and
• Work toward consistent international approaches to
toxic substances control.
Under TSCA, EPA will assign highest priority to
those substances that pose the greatest risk as a
function of both toxicity and exposure. This means we
are going to concentrate on the most important
problems—problems whose actual or potential
magnitude present the greatest threats to public health
and the environment.
For example, chemicals that may produce chronic or
irreversible health effects such as cancer, birth defects
and gene mutations will take higher priority than those
that produce acute effects such as eye and skin
irritations. Similarly, substances that are widely dis-
persed in the environment and that may significantly
disrupt ecosystems will take a higher priority than those
that threaten individual species other than man.
We already have taken, or are in the process of
taking, a number of actions to gather the kinds of basic
information we need to determine priorities for various
chemical regulatory actions. For example, we have
issued rules under sections 8(a) and (b) to compile a list
of chemical substances and to learn which substances
are manufactured where and in what quantities. Final
rules governing industry reporting for this inventory
were issued in December 1977. Domestic manufacturers
and importers of chemical substances had until May 1,
1978 to report the initial inventory information to EPA.
About 50,000 reporting forms were submitted to EPA
in response to the inventory regulations, covering some
125,000 substances. Once we have sorted out
duplications in reporting among various companies that
make the same substance, we expect that the actual
number of commercial chemicals listed on the pub-
lished inventory could be as high as 70,000. Our schedule
called for the inventory data to be processed by the end
of 1978, and for the initial inventory to be published
early in 1979.
Once these inventory data are available, we will be in
a position to begin selecting chemical substances and
classes of chemical substances for further attention
based on their production volumes. Also, publication of
the inventory will trigger TSCA's section 5 premanufac-
ture review program. The inventory data also will be
useful in responding to emergency situations and
quickly identifying possible sources of exposure to
specific chemical substances.
Guidance we have published under section 8(e)
provides another channel through which we can iden-
tify and address significant problems. Specifically, this
guidance encourages manufacturers to establish an
internal reporting procedure to insure that EPA will
expeditiously receive any new information that
reasonably supports the conclusion that a chemical
substance may present a substantial risk to health or
the environment.
The authority to require chemical manufacturers and
processors to undertake testing under section 4 is
another important tool we can use to get information
about chemicals that is not currently available to EPA
or other regulatory agencies.
In designing an overall approach to testing re-
quirements under TSCA section 4, we intend to obtain
the information we need without imposing needlessly
burdensome costs or tying up personnel and facilities
with excessive testing requirements. Therefore, we plan
to rely largely on a tiered set of standards—that is, the
need for long-term, more definitive, more costly tests
will be determined from the results of short-term,
relatively simple screening tests, together with other
factors, such as the extent of exposure.
The section 4(e) Interagency Testing Committee has
submitted three sets of recommendations to EPA
regarding chemicals and classes of chemicals identified
for priority testing consideration. We have solicited
public comment on these recommendations, and expect
this year either to require testing for the Committee
recommendations or to explain our reasons for not
doing so, as TSCA mandates.
Under section 8(d) we have promulgated rules requir-
ing all chemical manufacturers and processors to
submit lists and/or copies of any unpublished health
and safety studies already performed on substances
recommended in the first Interagency Testing Com-
mittee report. In general, we plan to review results of
tests already performed before requiring manufacturers
and processors to perform additional tests.
Development of the premanufacture review program
is among EPA's most critical tasks under TSCA. As
provided in section 5, any person intending to manufac-
ture or import a new chemical substance must submit a
premanufacture notice to EPA at least 90 days before
introducing the substance into commerce. Any chemical
substance not included on the inventory of substances
compiled under section 8(b) will be considered "new."
The premanufacture notification requirements become
effective 30 days after publication of the inventory.
EPA proposed a rule governing reporting for new
chemical substances last fall. This rule, together with
the notice form, will specify the types of information to
be reported to EPA. We also invited public comment
on the development of separate testing guidelines to
help inform industry on what kinds of evaluations EPA
considers necessary to make decisions on new
chemicals. The development of such guidelines, along
with the section 4 testing standards, will in many cases
permit chemical companies to take adequate action on
potential chemical hazards on their own without EPA
intervention.
EPA has taken action under section 6 of TSCA
aimed at controlling the production, distribution, use
and disposal of specific chemical substances or classes
of substances. Our first action was to issue regulations
on the labeling and disposal of polychlorinated
biphenyls (PCB's). The second phase of PCB
regulations, implementing the ban on manufacture and
use in any way other than a totally enclosed manner,
was proposed in June 1978.
In a joint action in March 1978 with the Food and
Drug Administration and the Consumer Product Safety
Commission, we have banned most aerosol uses of
chlprofluorocarbons (CFC's). EPA is further in-
vestigating ways to reduce CFC emissions from non-
aerosol sources.
In short, we are well on our way to completing the
foundation for controlling toxic substances, and plans
JANUARY 1979
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are underway to attack specific chemical hazards. The
year 1979 will see additional activity in both of these
areas, particularly regarding premarket notification to
EPA on new compounds. Our aim this year remains as
it has been—to minimize the human health and
environmental risks posed by some chemicals while
maximizing the social and economic benefits derived
from the majority of them.
Increasing the effectiveness
of environmental programs
THOMAS C. JORLING
Assistant Administrator
for Water and Waste Management
The 1977 Clean Water Act has provided us with
some major and, in my opinion, much needed direc-
tions toward the application of alternative treatment
and the control of toxics. Since the bill was passed late
last year we have been conducting an intensive effort to
translate the amendments into the requisite guidance
and regulations.
In late September we issued final regulations con-
stituting a comprehensive change in the rules governing
the construction grants program. This was a con-
siderable achievement, a large amount of work being
accomplished a mere nine months after the law was
passed. I am especially pleased that the new rules were
developed in full view of the public with heavy reliance
upon participation by those outside the Agency.
Developing these and other regulations required by
the new Act has called for closer integration of the
management of related environmental programs. In the
process, we have been forging an internally consistent
and unified process to implement our various statutory
authorities in a complementary way. It is inherently
logical that tying our programs together wherever
possible will make them ultimately more effective.
A prime example of this integrative theme is the
pretreatment of industrial wastes. We will only be able
to solve such serious problems if we make the needed
effort to integrate skillfully a number of separate
authorities and programs.
During the first five years following passage of the
1972 Amendments, approximately one-half of all in-
dustrial dischargers—the indirect dischargers—were vir-
tually free of any direct burden for pollution control.
During this same five years, the direct dischargers—
comprising 87 percent of all other industrial
dischargers—made major investments in applying the
Best Practicable Technology to the treatment of their
wastes.
It is more than just a matter of equity, however.
Indirect dischargers are a major source of toxic
chemicals entering the environment—toxics that are
either uncontrolled or inadequately treated by
municipal treatment plants. They can also render
treatment facilities inoperative.
Once in our waterways, many of these pollutants are
toxic to aquatic life, are persistent, can concentrate in
POLLUTION ENGINEERING
the food chain, and are known or suspected car-
cinogens. These toxics also contaminate municipal
sludges.
The removal of toxic industrial wastes before they
enter the sewer system will result in increased potential
for the reclamation of wastewater and the reuse of
municipal sludge, such as through land application. The
reclamation of wastewater is especially important in
water-short areas. The reduction of toxics in municipal
sludge is important because of the growing need to use
the sludge as a beneficial resource. We can no longer
afford to deal with it merely as an unwanted waste
product which would otherwise have to be disposed of
in more costly ways.
In June we took a first major step in controlling the
sources of toxic pollutants introduced into municipal
sewer systems. We issued the national pretreatment
strategy and a regulation to implement it. The strategy
commits the Agency to developing national pretreat-
ment standards by the end of 1979 covering ap-
proximately 40,000 indirect dischargers of toxics. The
standards will be based upon the Best Available
Technology economically achievable by indirect dis-
chargers. As in the case of BAT standards for direct
dischargers, the Agency will initially focus on 21
industrial categories and 65 categories of toxics. The
pretreatment standards will be promulgated for each
separate industrial category. For existing sources, com-
pliance will be required within three years from
promulgation. New sources will have to comply im-
mediately.
The national pretreatment strategy and the im-
plementing regulation require all municipalities having
plants with capacity above five million gallons per day
to develop programs to enforce the national standards.
In addition, a demonstrated intention to enforce the
standards will be a prerequisite for any municipality
seeking to modify its NPDES permit.
Implementing the pretreatment strategy will require
integration of a number of programs along the lines I
mentioned earlier. The NPDES permit program
provides the basic enforcement mechanism. As
municipal NPDES permits expire and are reissued, they
will be revised to require the development of a local
program to enforce local, state and national pretreat-
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merit standards. Municipal treatment systems that
allow industries to violate national standards will be
subject to enforcement actions along with the violating
industry.
The cost of developing the local program has been
made eligible for 75 percent federal funding. The new
regulations for construction grants require specified
increments of progress in developing local pretreatment
programs prior to award of Step 2 and 3 grants. To
ensure that the annual local costs of operating the
pretreatment program are provided for, grant
applicants must also show that user charges and any
industrial cost recovery, in conjunction with other
revenue sources, will be sufficient to continue im-
plementing the pretreatment program.
At the same time we have been devoting special
attention to the management of municipal and in-
dustrial sludges. Reducing the concentration of toxics
in the municipal sludge provides opportunities for
lower-cost methods of sludge disposal and the
beneficial reuse of sludge. Conversely, the preremoval
of toxics in industrial waste streams will inevitably add
to the residual of hazardous materials that the industry
and the community must deal with safely.
Our evolving integrated municipal sludge manage-
ment strategy is designed to attain two principal goals.
One, to assure that municipal sludge is managed so as
to protect public health and the environment; the other,
to conserve energy and natural resources through the
beneficial use of municipal sludge wherever practicable.
Both goals represent the expressed mandate of
Congress in the 1977 Act.
Municipal strategies covering the disposal of sludge
must be responsive to the provisions of four major
federal statutes: the Clean Water Act, the Resource
Conservation and Recovery Act, the Marine Protec-
tion, Research, and Sanctuaries Act, and the Clean Air
Act. These statutes address the major sludge disposal
practices: landfilling, landspreading, incineration and
ocean disposal.
To effect a comprehensive and integrated Agency
approach to municipal sludge management, I have
made the tentative policy decision to depend primarily
upon the regulatory authorities granted under Section
405 of the Clean Water Act. Using this approach,
regulatory guidelines for municipal sludge utilization
and disposal will be developed, with implementation
through the NPDES permit program and the general
enforcement provisions of the Clean Water Act.
We are trying to carry out our sludge management
strategy in such a manner that municipalities have
adequate time to control the sources of toxic pollutants
in sludge before being forced to adopt disposal options
that are resource- or energy-intensive.
I should add that the November 1977 amendments to
the Marine Protection, Research, and Sanctuaries Act
requires the termination of all ocean dumping of
sewage sludge by the end of 1981, placing even greater
emphasis on alternatives to ocean dumping and com-
pliance with implementation schedules in adopting the
chosen alternatives.
The pretreatment and sludge disposal issues ex-
emplify our effort to carry out environmental statutes
in a coordinated way that recognizes the interdependen-
cies of the various parts. As environmental managers,
we have no choice but to do so.
Past cases of failure to integrate fully the implemen-
tation of our various authorities—and thus realize their
full potential—have been a serious public concern. I am
therefore greatly encouraged by our development of a
coherent strategy for environmental management. The
trend will continue.
A reaffirmation of
environmental goals
DAVID G. HAWKINS
Assistant Administrator
for Air, Noise and Radiation
EPA is charged with setting in motion a number of
incredibly complex laws that involve the states to a
greater degree than ever before.
Despite the progress that has been made in reducing
nationwide emissions of air pollutants, failure to
achieve the National Ambient Air Quality Standards in
many areas of the country represents the reality of the
implementation of the 1970 Clean Air Act. The
Congress began to address this situation more than
three years ago and initiated the drafting of the first
comprehensive amendments to the Act since 1970.
With the enactment of the Clean Air Act
Amendments of 1977, Congress has reaffirmed its
commitment to the goals originally established by the
1970 legislation. The new Amendments provide a
strong mandate and make it clear that Congress does
not intend that the nation's energy problem be allowed
to compromise environmental quality. Some people
JANUARY 1979
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have referred to the new legislation as a "mid-course
correction." I believe that "mid-course reaffirmation" is
more appropriate. The Act strongly reaffirms our goals
of attainment and the prevention of significant air
quality deterioration. It renews and strengthens our
existing programs as well as adding new directives
which pose some of our greatest challenges. The new
Act strengthens the air quality management approach
by placing more responsibility on state and local
general purpose governments. The Amendments call for
new patterns of interaction between all levels of
governments. As a result of these requirements, a
strong program for enhancing public understanding
and participation will be necessary in order to
successfully implement the mandates of the Act.
To a large extent the hardest phase of our efforts to
meet ambient air quality is yet to come. The progress to
date has been achieved through the application of
controls to sources generally amenable to control
requirements. During this next round of control we will
be forced to concentrate on the less conventional
sources (fugitive dust, fugitive emissions, transportation
activities) with which we have far less control ex-
perience. In other words, we have done the easy things
and what is left are the more difficult, less tried and
true methods of air pollution control.
The heart of the new Amendments focuses on the
problem of attainment in areas where the National
Ambient Air Quality Standards continue to be violated.
States were required to submit revisions to their State
Implementation Plans (SIP's) for all areas that are not
attaining the national ambient air quality standards.
The SIP revisions' deadline was January 1, 1979, and
must demonstrate attainment of the national standards.
The Act provides economic sanctions for those nonat-
tainment areas that do not have approved plan
revisions by July 1, 1979. These sanctions include
prohibiting the construction of major new or modified
air pollution sources and discontinuing certain EPA
and Department of Transportation grants.
Let me put the new source growth issue into some
perspective. The review of new sources is an important
part of the effort to achieve and maintain ambient
standards. Initially, the 1970 Act was interpreted as not
allowing any new source construction in areas which
were in violation of the primary standard. However, it
became increasingly obvious that a total ban on new
source growth was neither realistic nor necessary. In
December 1976, EPA established what is known as the
"offset policy." This balanced the two goals of
economic development and progress toward health
standards. It allowed new source construction in
nonattainment areas provided there was a net air
quality benefit due to compensating emission reduc-
tions from existing sources and that emissions were
curtailed from the proposed new source to the greatest
extent feasible. The offset policy was endorsed by
Congress in the 1977 Act as a viable way of handling
new source growth. EPA's "offset policy" is effective
until July 1979.
At that point, the law requires states to have
developed their own provisions for the review of new
sources' in nonattainment areas. The Amendments
provide either of two options: States can devise
management plans which both attain standards and
provide a quantified margin for emissions growth for
new construction, or states can adopt their own version
of the case-by-case offset approach. Either way, the SIP
must attain standards by new statutory dates and show
continuous progress in the interim. Construction of new
sources is prohibited in areas where states fail to adopt
new regulations and plans by July 1979, until an
acceptable plan is developed by the state and approved
by EPA.
Let me take a few lines to discuss the so-called
"sanctions.'' First, let me point out that these
limitations are not meant to be punitive. They serve as
an indication of the serious need for states to develop
and submit plans in January 1979, which provide for
attainment of the National Ambient Air Quality Stan-
dards as expeditiously as practicable. We believe that in
most cases the states are seriously working toward the
development of the 1979 plans. These states do not look
upon these limitations as a threat, but rather a means of
protecting those that are working toward the develop-
ment of a plan which will provide for attainment of the
national standards. In this way states that have not
submitted such a plan will not possess an advantage
regarding new source growth over states that have
developed a comprehensive air pollution control
program.
I'd like to touch briefly on what flexibility is available
to the states as they revise their SIP's and what we are
doing to provide some options in both guidelines and
approaches.
The new schedules established by the 1977 CAA call
for SIP revisions to go into effect by July 1979. These
must provide a mix of control strategies sufficient to
achieve the national standards by the end of 1982.
However, for those pollutants most difficult to
control—carbon monoxide and photochemical ox-
idants, for which major area-wide transportation emis-
sion reductions are necessary—the Amendments allow
a two-stage SIP process: If the January 1979 submittal
shows that, after the adoption of all known reasonably
available control measures, standards cannot be achiev-
ed by December 1982, an extension for up to five years
can be requested. This means that additional measures
which are not feasible to implement at this time can be
delayed until 1982 to 1987.
There are, however, some additional requirements for
areas with attainment dates after 1982. For these areas,
the SIP must commit by 1979 to an automobile
inspection and maintenance (I/M) program. Man-
datory inspection and mandatory repair must begin no
later than 1982 where a centralized (state operated)
system is used and no later than 1981 where a
decentralized (private garage) system is used. Also, a
more comprehensive new stationary source siting
procedure, which examines location size alternatives
along with social and nonenvironmental costs, must be
used. Finally, additional SIP revision must be sub-
mitted by July 1982 to ensure attainment by 1987. This
provides extra time to develop some of the most
difficult control strategies.
EPA is trying to develop a reasonable approach on
our requirements for what constitutes reasonably
available control technology. We will focus at first on
hydrocarbon sources because so little has been done in
the past to control hydrocarbon emissions through
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regulations. We will be issuing guidance to define
suggested levels of reduction for hydrocarbon sources,
and we'll permit states to phase in these requirements as
we issue the guidelines. In addition, we will work
closely with the states and allow them to phase in
unconventional controls for particulates, with emphasis
on fugitive dust emissions.
Finally, the SIP's must demonstrate that the
emissions reductions will take place throughout the
plan period and will not concentrate at the end. Under
the 1970 Act, it was only necessary that the plan
demonstrate attainment. However, in the 1977 Act,
Congress said the SIP's must also show annual in-
cremental reductions in total emissions (new as well as
existing) including substantial reductions in the early
years. States will report annually on the progress being
made. Congress added this provision to ensure that
attainment dates do not once again come and go
without an adequate early warning of implementation
problems and the initiation of corrective actions.
Clearly the development of SIP's has posed many
new challenges. The deadlines contained in the
Amendments are extremely tight when measured
against the complexity of the job to be done. EPA has
devoted much time and energy in trying to establish
reasonable and achievable goals for SIP submissions
that both meet the intent of Congress and are
achievable with the available resources.
Radiation
The keystone of the federal system for providing
consistent radiation protection is Federal Radiation
Guidance issued by the President to all federal agencies.
The authority "to advise the President with respect to
radiation matters, directly or indirectly affecting health,
including guidance for all federal agencies in the
formulation of radiation standards and in the establish-
ment and execution of the programs of cooperation
with states" was formerly vested in the Federal Radia-
tion Council. With the establishment of EPA in 1970,
the Federal Radiation Council was abolished and this
authority granted to the Administrator of EPA. Under
this authority, EPA develops and recommends radia-
tion protection guidance to the President. When ap-
proved by the President, these recommendations are
published as Federal Radiation Guidance to the agen-
cies in carrying out their radiation control programs.
Historically, this Federal Guidance has provided the
formal basis for most federal and state radiation
protection regulations, including those limiting occupa-
tion exposure; providing protection of the public from
exposure due to such radiation sources as nuclear
power operations, commercial and medical uses of
radioisotopes, fallout from nuclear weapons testing,
and occupational exposure of uranium miners to
radioactive materials resulting from the radioactive
decay of radon. It has recently been amplified in the
area of medical radiation exposure. The use of radia-
tion in the practice of medicine, although it represents
by far the most significant source of manmade exposure
to the public, has been until now a source for which
only minimal federal guidance on radiation protection
existed. However, with the help of an Interagency
Working Group on Medical Radiation, we have now
succeeded in formulating a comprehensive set of guides
for radiation protection in the use of diagnostic x-rays.
Following joint recommendation of this guidance by
the EPA administrator and the Department of Health,
Education and Welfare assistant secretary for health,
the President approved the guidance and it was
published on February I, 1978, in the Federal Register.
Thus, for this source of greatest public exposure to
manmade radiation, we have broken significant new
ground in radiation protection.
Under this Federal Radiation Guidance authority, we
have also proposed guidance for cleanup of areas
contaminated with transuranic elements (plutonium)
and are in the process of updating the basic guidance
for occupational radiation exposures and guidance for
protection of the public during and after nuclear
incidents. In addition, we are developing guidance or
environmental protection criteria for the Storage and
disposal of all forms of radioactive wastes, and we
expect to conduct a review of the radiation protection
standards for the general public in the near future.
In addition to these guidance and standards ac-
tivities, we operate the only nationwide environmental
radiation monitoring system, we conduct field studies
of the environmental impact of specific nuclear
facilities, and we are heavily involved in the review of
environmental impact statements for nuclear power
plants and all other nuclear and radiation activities.
The radiation program, although one of the smaller
programs in EPA, is very comprehensive and obviously
very busy.
Noise
Though hearing loss is the most clearly understood
noise hazard, it may not be the most serious threat to
health posed by noise. Mounting evidence from recent
studies in the United States and abroad suggests that
noise's other health effects may prove to be more
pervasive and serious than hearing loss. For example;
there is growing evidence of a link between noise and
the development of high blood pressure and other heart
circulatory problems.
Of the total noise problem, urban traffic and freeway
noise affects more people than any other group of noise
sources in this country. We believe the most cost-
effective method of reducing traffic noise is to reduce
the noise at the source. In order to take maximum
advantage of available technology, this noise reduction
should be designed into newly manufactured motor
vehicles. The Noise Control Act of 1972 gave EPA the
authority to control the noise levels from newly
manufactured vehicles, as well as vehicles now being
used by interstate motor carriers, and we are devoting a
great deal of our effort in developing such regulations.
The loudest, most pervasive source of noise is, of
course, the truck. In 1974, EPA promulgated
regulations limiting the noise from vehicles over 10,000
pounds operated by interstate motor carriers. This in-
use vehicle regulation was designed to remove the most
serious peaks of noise from interstate trucks and buses,
and it became effective in October 1975. Although
applying to at least 1 million of the over 5 million
trucks and buses in this country, such a reduction from
existing vehicle fleet noise levels alone was not suf-
ficient.
Accordingly, we started work simultaneously to
JANUARY 1979
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further reduce traffic noise by setting standards for
newly manufactured motor vehicles. We issued
regulations which became effective in January 1978,
requiring that new trucks over 10,000 pounds emit no
more than 83 decibels at 50 feet. This level will be
lowered to 80 decibels in 1982. We have also proposed
noise limits for new buses, motorcycles and garbage
trucks which we expect to issue in 1979.
Although all of these actions will help to control
highway noise, they can in no way be viewed as a total
solution. The growth of both the motor vehicle fleet
and the number of people living in urban areas,
together with an expected increase in the average
automobile noise levels as a result of auto industry
efforts to meet fuel economy standards, are expected to
worsen the urban noise problem in coming years.
Clearly then, even to hold national surface transpor-
tation noise levels at no higher than those of today will
require substantial further action. Truck noise levels
must be reduced further than EPA has currently
prescribed—and we propose to do just that with current
efforts we now have underway. Also, we have under
intensive study the remaining contributors to the
surface transportation noise problem: automobiles,
light trucks and tires. As a supplement to these actions,
regulatory initiatives on mufflers are being considered.
Even with strong state and local ordinances to supple-
ment the federal standards, we expect that it will be
necessary for us to promulgate more stringent
regulations for vehicular sources beyond the initial
round of regulations which are now in process.
In other noise development, EPA has issued final
standards for interstate rail carriers and portable air
compressors, and proposed standards for hearing
protectors. Regulations are under study for other
transportation vehicles, and selected industrial, con-
struction site and household products.
In 1979 the Noise Program will increase its emphasis
on technical assistance and grants to other federal
agencies and to state and local governments for the
development and implementation of noise control
programs. Assistance will be provided in establishing
complementary state/local in-use enforcement activities
for noise sources where new product regulations have
been federally established, and in developing programs
directed at localized problem areas that are particularly
amenable to state /local actions.
Technical assistance will also be provided in the form
of direct guidance to state and local agencies on how to
define noise problems, and to other federal agencies
whose programs have noise control implications.
Two good examples of EPA's technical assistance
grant efforts are the "Quiet Community Program"
(QCP) and the "Each Community Help Others"
Program (ECHO). QCP works with a few selected
communities to develop comprehensive noise programs.
ECHO provides technical assistance to local com-
munities on specific noise problems by providing
consultative services from officials of communities
which have successfully overcome similar problems.
During 1979, EPA plans to designate 30 communities
for technical assistance under the ECHO program and
three new localities for assistance under the QCP,
bringing the total number of on-going QCP's to six.
Uncovering second generation
pollution problems
STEPHEN GAGE
Assistant Administrator
for Research and Development
Our efforts to protect the quality of our environment
are undergoing a qualitative shift. Many of the most
obvious sources of health hazard—the open sewers,
belching smokestacks, fuming automobiles and
smoldering dumps—are gradually being brought under
control. As with any other major problem, we tackled
the most obvious symptoms first and are making
excellent headway. While tackling these problems, we
have gained a far greater understanding of how human
activities impact the environment. For example, in
studying how biologically harmful sulfate pollutants are
formed in the atmosphere, we have discovered that
concentrations of these pollutants are sometimes the
result of the emission of precursor pollutants a hundred
or more miles away.
An increased understanding of environmental
processes, of pollutants and their impacts, along with
vastly improved technologies for measuring or con-
trolling pollutants, has allowed us to focus our atten-
tion more precisely upon a new set of salient remaining
problems which once lay hidden behind those more
obvious hazards mentioned above.
For example, despite heavy spending to control
municipal and industrial wastewater discharges, it is
becoming increasingly apparent that water pollution
from such diffuse sources as agricultural runoff and
fallout from polluted air adversely affect receiving
waters, in many cases rendering them unsuitable for
their planned uses. Our research efforts address many
such "second generation" environmental problems
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which may well be of primary concern in the near
future.
As we begin to deal with these newly recognized
problems, our research and development program will
lead the way. The following are some of the en-
vironmental problems which I feel are on the horizon.
Air pollution
While we have made significant progress in recent
years in controlling sulfur dioxides, paniculate and
carbon monoxide concentrations, we still have a long
way to go before the air is healthy throughout the
nation. The more we learn about the health effects of
the mixture of sulfur dioxides, fine particulates and
other airborne pollutants, the deeper our concerns
become.
In addition, recent studies have improved our ability
to estimate the benefits of air pollution controls. This
benefit side of the environmental protection equation—
so long neglected because of the apparent difficulty of
putting a dollar value on clean air—is being fleshed out.
Preliminary results of an EPA-sponsored study of the
Los Angeles Basin indicate that the benefits of pollu-
tion control in terms of improved property values,
improved health and the willingness of residents to pay
for cleaner air, may well be several times larger than
indicated by earlier studies.
In addition to improving our ability to quantify the
benefits of pollution control efforts, future air-related
research will concentrate on a number of topics. First,
we need to know more about the long-range movement
and change of air pollutants such as fine particles,
ozone/oxidants and secondary organic compounds.
Information on human exposure to, and the health
effects of. such substances, along with alternative
control strategies, is essential for effective regulatory
efforts.
We must also know more about trace elements and
air pollutants which degrade visibility. Some trace
elements can be toxic to both humans and their
environment in particular concentrations or chemical
forms. To focus our control efforts more effectively, we
need more information on the sources and impacts of
the most hazardous of these substances.
Finally, we may soon be able to put major pieces of
the air pollution puzzle together. As we gather more
and better data on pollutant sources, human and
ecological health effects, and ambient exposure con-
ditions, we improve our ability to identify cause-and-
effect relationships and to quantify costs and benefits.
To improve such abilities, we need more data
characterizing the emissions from different sources,
better data on fugitive emissions and dust as these
relate to paniculate pollutants, and improved in-
struments and techniques to measure and control
fugitive emissions.
Drinking water
It is commonly accepted that one responsibility of
modern government is to provide its citizens with a safe
supply of drinking water. Early concerns were focused
on security and adequacy of supply and on eliminating
waterborne diseases. Currently our task is to reduce the
risk from chemical contamination while, at the same
time, avoiding the risk of waterborne infection.
The overall goals of EPA's drinking water research
program are to develop measurement and monitoring
methods to identify and quantify drinking water con-
taminants, to assess the health effects of these sub-
stances and to develop treatment technology to reduce
contaminant levels to acceptable concentration!. We
also seek to provide the scientific and technical bases
for protecting groundwater quality. This goal is es-
pecially important because approximately SO percent of
the U.S. population depends on underground sources
for their drinking water.
In the short term, the greatest needs and accordingly
our highest priority will be on technology development
and on assuring the quality of analytical methods. In
the long term, emphasis will be placed on health effects,
development of analytical methods, and groundwater
research.
Energy and environment
EPA has long been in the forefront of research into
the effects of, and technologies to control, pollutants
from nonnuclear energy development and use activities.
This central role was acknowledged by Congress when,
in 1974, it sponsored the Interagency Energy/Environ-
ment R&D program and gave EPA the responsibility
for planning and coordinating that SlOO-million per
year effort. Out of this program have come major
scientific advances—the identification of long-range
movement of sulfur pollutants in the atmosphere, for
example, and the development of flue gas scrubber
technologies.
In addition to expanding our role in measuring long-
term movement of energy-related air pollutants, and
maintaining our involvement in other areas such as
mining impact assessment and control, EPA has taken
several major research initiatives in the energy /environ-
ment arena. The first is to ensure that new and
developing energy-related technologies such as coal
gasification, liquefaction or fluidized bed combustion
will be developed in concert with adequate environmen-
tal safeguards. Via cooperative agreements with the
Department of Energy, we are making significant
progress toward that goal, We are also anticipating
development of solar and geothermal resources by
developing environmental assessments of the former
and preliminary environmental development guidelines
for the latter. Most of the research and development
activities in the energy area are divided among several
federal agencies and departments. A high and very
effective level of cooperation has developed among
these different groups and is helping to assure the most
effective possible investment of our energy /environ-
ment research dollar.
At the same time as we look to future energy
technologies we are also focusing on cleaning up and
improving those technologies which are with us today.
For example, nitrogen oxides (NO,) have been im-
plicated in damage to the earth's protective ozone layer,
smog and high nitrate rainfall. We estimate that 99
percent of nitrogen oxide emissions originate from fuel
combustion, approximately half coming from
JANUARY 1979
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stationary sources such as boilers, and the other half
from mobile sources such as automobiles. By 1985,
however, with the continued growth in energy use and
increased reliance on coal as fuel, EPA anticipates a
70/30 percent split of stationary to mobile polluters.
A major breakthrough in controlling NO, emissions
occurred in 1978. Our research into staged combustion
techniques in an experimental mid-sized (IS to 20 MW)
boiler consistently produced NO, emissions below 150
parts per million—a decrease in emissions of as much
as 85 percent compared with conventional burners of
this size. In addition, the new boiler design is compati-
ble with new coal-fired utility and industrial boilers,
boilers switching from gas and oil to coal, can be
retrofitted to existing boilers and offers an energy
efficiency equal to or greater than comparable conven-
tional boilers. We expect to improve on those
developments in the coming years.
Expanded use of existing coal-burning technologies
also requires that technologies for sulfur oxide and
particulate control be improved. Additionally, research
must strive to fill major information gaps regarding the
magnitude of the health and environmental problems
associated with trace elements, radioactive material and
polycyclic organic emissions produced during conven-
tional combustion of coal.
Toxic substances
The chemical industry is a constant contributor to
contemporary American life. Pesticides and fertilizers,
for example, are important agricultural tools. Drugs
save lives; plastics save money and weight. Millions of
jobs are generated, billions of dollars exchanged.
However, the manufacture, use and disposal of the
everyday products that contain some of the more than
two million recognized chemical compounds can pre-
sent significant dangers—dangers that are often difficult
to anticipate.
The fundamental issue is how to derive maximum
social benefit from modern technology while limiting
attendant risk to an acceptable level. It is this issue
which lies at the heart of the regulatory dilemma. It is
this issue which has formed the basis for the evergrow-
ing body of landmark environmental, public health and
other regulatory legislation which has been enacted by
the United States Congress. Research plays a key role
in the decision process providing the necessary technical
information base from which estimates of relative risk
versus benefits may be evaluated.
To fulfill its mission in protecting our citizens from
exposure to toxic chemicals, EPA has established two
general research goals:
1. To characterize the nature and extent of the risk
posed by potentially hazardous chemicals; and
2. To develop control strategies, systems and/or
management practices which will prevent, or at least
minimize, exposure to hazardous chemicals.
Accomplishing the first of these goals involves
research in three general areas: the human and en-
vironmental effects of toxics substances, the assessment
of the magnitude and mechanisms of exposure to
toxicants, and the production of integrated risk assess-
ment and criteria documents as input to the regulatory
decisionmaking process. Achieving the second goal
involves first the characterization of toxic emission
sources (answering the how, why, when, where and how
much questions relating to chemical production) and
the development and evaluation of alternative control
strategies and/or technological systems which can
mitigate exposure to hazardous compounds.
To provide some of the information we need to
effectively control toxic substances, a program was
begun in 1978 to analyze approximately 1000 types of
industrial wastewater for organic compounds thought
to pose health hazards. The tool for this analysis is a
gas chro'matograph mass spectrometry system.
This system, using a single, comprehensive analytical
procedure, is capable of identifying any active organic
substance in concentrations as low as 10 milligrams per
liter of water. Once identified, the toxicity of a
substance can then be determined using computerized
access to an organic substance data base.
Currently, ORD chemists are developing a protocol
for the standardized analysis of 114 key industrial
effluents, a procedure complicated by the presence of
more than ten times that number in a typical
wastewater sample. Information developed in these
analyses and through additonal surveys, along with
health effects data already established, will be used to
establish whether or not given chemical discharges
should be limited or prohibited.
In addition to the above efforts, EPA's research seeks
to develop procedures to rapidly test the toxicity of a
substance. The availability of such procedures is key to
the cost-effective assessment of the large number of new
chemicals entering the marketplace each year. Our
efforts to develop rapid testing procedures focus on two
areas. First, we are developing and testing computer
models capable of delineating the pathways followed by
potentially harmful chemicals in freshwater ecosystems.
Such models, when developed, will improve our ability
to project the ultimate fate of a substance before that
substance becomes a threat to human health. Second,
we are improving our understanding of bioaccumula-
tion. Bioaccumulation is the process whereby a sub-
stance, even in small amounts, can enter the water
environment and food chain and be highly concentrated
in fish tissues. Such fish may then become food for
humans and, thus, a health hazard. We are working to
improve our ability to predict the bioaccumulation
potential of substances based upon their chemical
characteristics. Such an ability will allow us to focus on
controlling those substances most likely to enter the
human food supply.
The above examples represent but a few of our 2500
research projects, but should evidence the diversity and
scope of EPA's research program as we move to
address these newly recognized environmental
problems. The quality of our work sets the standard for
the Agency. This is a challenge that we are meeting with
enthusiasm and confidence.
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Report from
Region I
WILLIAM R. ADAMS, Jr.
Region I Administrator
The year of 1978 has been a year of changes for the
Environmental Protection Agency. We have broadened
our scope to include activities that have previously
received relatively little attention, and we have begun to
approach the whole question of environmental regula-
tion from a new standpoint designed to emphasize
public participation in the regulatory process.
One of our highest regional priorities last year and in
coming years is development of environmentally sound
management practices for solid and hazardous wastes.
This area has traditionally received much less
attention—and certainly less funding—than air and
water pollution control. In fact, in some instances, air
and water pollution control activities have actually
created solid waste management problems, as with
disposal of sludges.
We cannot continue to ignore the problem. We are
rapidly running out of inexpensive disposal alternatives
and must begin to exercise so-called cradle-to-grave
management of wastes, including conservation, source
reduction, recycling and reuse where possible, and
environmentally acceptable disposal of residuals.
Hazardous waste management is another area that
simply cannot be ignored any longer. Already we have
experienced incidents of contamination in Lowell, MA
at a private disposal facility; in Gray, ME where
groundwater was contaminated by a private disposal
operation; and in Rehoboth, MA where a private
disposal operation threatened drinking water supplies
in Rhode Island.
These incidents are in fact only symptoms of a
problem that has been with us for some time. For years
we have been disposing of toxic and hazardous
chemicals in environmentally unsound ways, and now
our mistakes are coming back to haunt us.
And yet these environmentally unsound disposal
practices continue. Each year we generate enormous
amounts of hazardous wastes, an estimated 87 million
gallons each year, in this region. But we do not have a
single approved hazardous waste disposal area in New
England. Some of the wastes are exported out of the
region but we believe the majority of this material is
illegally dumped into drains or directly into our
waterways, or stored at illegal sites.
We cannot allow these practices to continue. And we
cannot continue to simply export the problem outside
our own regional boundaries.
At the request of the New England Governor's
Council, the New England Regional Commission has
undertaken a $245,000 study of the disposal of toxic
wastes. The Commission will try to put together a
precise inventory of the chemical wastes generated in
New England and to find regional solutions to such
problems as where to dump wastes and who is
responsible for them. In the coming year, we will be
working closely with them and with the New England
states on this matter, because I believe it is potentially
one of the most serious this Agency has to face.
In the air pollution area, smog, or ozone, continues
to be a very serious problem in the region. Violations of
the ozone standard were reported at every station in
New England that monitors this pollutant, and the
frequency of violations appears to be increasing. In
fact, some areas of Connecticut are second only to Los
Angeles with respect to the severity of smog problems.
About one-half of all the hydrocarbons that form
smog are generated by automobiles. The federal Clean
Air Act requires auto manufacturers to achieve certain
emission limitations, and most do so by installing
pollution control equipment, such as catalytic con-
verters. However, this equipment can go out of adjust-
ment just as any other part of the automobile can. In
order to make sure that this equipment operates up to
its design capability, periodic inspection and
maintenance is necessary. Rhode Island passed I&M
legislation two years ago, and Connecticut in May of
this past year. One of this region's highest priorities in
the coming year will be encouraging Rhode Island and
Connecticut to implement their legislated programs and
Massachusetts to pass an I&M bill.
In the field of water pollution control, progress has
been slow and steady, not as dramatic as in the early
days of the Agency. All the major industrial dischargers
in the region have installed best practicable control
technology or are on enforceable schedules to do so.
Municipalities do not have such an impressive com-
pliance record, but we will continue to make grants to
municipalities for sewage treatment facilities, and as
facilities currently under construction come on line, we
will be seeing more and more improvement to our
region's waterways. Already it is possible to catch a
salmon in downtown Bangor, ME or a trout in New
Hampshire's Pemigewasset River.
As point sources of pollution come under control,
nonpoint sources of pollution such as urban,
agricultural and silvicultural runoff will have an in-
creasing impact on our waterways. The 208 water
quality management programs which are designed to
control nonpoint source pollution problems are enter-
ing the implementation phases and we should start
seeing results of these programs in the next few years.
Another priority for this Agency in the coming year
will be assuring the protection of the environment in
energy development projects. New England has no
indigenous energy supplies and has traditionally been at
the end of the energy pipeline. We cannot continue to
rely on other regions and other nations for our energy
but, at the same time, we cannot and will not
compromise our environment in order to permit energy
development. Thus, during the next few years we will
be looking very closely at energy projects such as the
proposed Pittston oil refinery, the Dickey-Lincoln
hydroelectric power project, and the Sears Island power
plant, all in Maine, and the proposed Charlestown, RI
nuclear power project to make sure that, if these plants
are built, ajl reasonably available technology to
minimize adverse environmental effects is employed.
Last, but by no means least of the issues with which
JANUARY 1979
-------
this Agency will concern itself in the coming year, is
public participation in Agency decisionmaking.
Although public participation has always been
accepted, it has never before been so actively sought.
The issues this Agency faces in the coming years are
going to require very difficult decisions. Some decisions
will involve application of relatively expensive control
technology. Some decisions will have impacts on
individual citizens as is the case with l&M programs.
Decisions like these will require careful cost/benefit
analysis, and the public should be involved in deciding
whether the sometimes considerable cost of pollution
control equipment is worth the public health and
environmental benefits the equipment is supposed to
provide.
The public has both a right and a responsibility to
participate in decisions of this magnitude. It is the job
of this Agency to provide people with the information
necessary to make decisions, and the opportunity to
participate in the decision. I believe that, given the
opportunity, the public will accept this responsibility
and add a very important element to our decision-
making.
Report from
Region II
ECKARDT C. BECK
Region II Administrator
Region II encompasses one of the most diverse areas
in EPA's entire structure—from Puerto Rico and the
Virgin Islands, which share a beautiful but fragile
ecology, to New Jersey, the most densely populated
state in the country and one of the most industrial, yet
with a land area that is still 25 percent wilderness.
Then, there is New York with its raw sewage discharges
into the Hudson River and erupting chemical landfills,
such as Love Canal in Niagara Falls, where the
honeymoon is over.
Love Canal can now be added to a growing list of
environmental disasters involving toxics, which range
from industrial workers stricken with nervous disorders
and cancers, to PCB's in the milk of nursing mothers
living all over the country. The tragedy of Love Canal
demonstrates that most environmental problems are
not confined to one media. In this instance, a waste
disposal problem is triggering the emission of hazard-
ous gases into the atmosphere, and, at the same time,
causing the leaching of highly contaminated wastes.
In the past year, the major priority for Region II has
been to integrate environmental programs into a
comprehensive overall plan directed at specific goals.
Divisions and branches of the Regional Office in New
York City are undergoing a reorganization process to
better reflect this philosophy of environmental manage-
ment. Concurrently, we have been working closely with
the state agencies to draft agreements that will shift the
emphasis of environmental cleanup from cure to
prevention. The development of these State/EPA
Agreements represents a joint state/federal effort to
integrate program management and eliminate gaps
between levels of authority, responsibility and interest.
The purpose of the Agreement is to develop com-
prehensive five-year strategies for pollution abatement.
These strategies will identify for each state and territory
the program objectives, the delineation of respon-
sibilities among agencies under each objective and the
level of commitment by each agency. The Agreements
are more than just a description of a state's en-
vironmental management plan for a specific media.
Each is a management tool which will assist and guide
the state in carrying forward "second generation"
stfategies to combat "second generation" problems such
as toxic chemical contamination of groundwater. These
documents also provide a direct statement about the
process of environmental management to concerned
citizens and government officials. They open the
process by which choices and tradeoffs are made while
the future course of the program is determined.
The very process of developing these agreements is
helping bring together levels of government—federal,
state and local—in practical, analytical, negotiative
sessions for determining which environmental problems
need to be tackled first, as well as where and how to
tackle them together.
When this article is published, the New York
State/EPA Agreement on Water Quality Management
will have been signed in final form by the commissioner
of the state's Department of Environmental Conserva-
tion and me. But the Region has already reaped the
benefits of having gone through the process. One
example involves the State Management Assistance
Grant (SMAG) to New York pursuant to Section 205
(g) of the 1977 Clean Water Act. We were in an
excellent position to make a SMAG to New York that
will effectively address its priority water quality
management problems through a review of the com-
prehensive list of tasks laid out in the NYS/EPA
Agreement. Selections were made, of course, on the
basis of which tasks have the highest priority and for
which SMAG funds are appropriate.
The Agreement details how New York plans to spend
both state and federal money over the next five years in
attacking major water pollution problems. Region II is
developing another agreement on air quality manage-
ment with New York, and water quality management
agreements with New Jersey and the Commonwealth of
Puerto Rico. Air agreements for these jurisdictions are
also planned.
One of the top priority problems listed in the
NYS/EPA Agreement on water quality management is
elusive toxic pollutants, like PCB's, Mirex, lead, zinc
and cadmium, which come mainly from industrial
processes. EPA pretreatment requirements are one tool
that will help halt their discharge into lakes and rivers.
But many businessmen are worried that the cost of
meeting these, plus the high cost of secondary treatment
standards, will drive them out of business. The City of
Buffalo, NY is a prime example of the environmental
and economic problems facing the Agency in the
Northeast. On the one hand, in Buffalo we have the
POLLUTION ENGINEERING
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serious impact of toxics and phosphorous discharged
into the fragile and vital ecosystem of the Great Lakes.
On the other, we have the impact of cleanup costs on
older industrial plants.
EPA is making an in-depth study of these economic
impact problems using Buffalo as a model. The Agency
is giving particular attention to potential plant closures
or relocations. These plant level effects will ultimately
be combined to develop an estimate of the overall
economic impact on Buffalo attributable to the en-
vironmental regulations affecting industrial dischargers.
What to do with sludges from municipal treatment
plants, a major unresolved issue for many New York-
New Jersey communities, is another top priority ad-
dressed in the NYS/EPA Agreement. Ocean dumping
of sewage sludge is prohibited by law after 1981, and
new alternatives, such as landfilling or composting, are
being sought. Metropolitan area sewage sludge contains
constituents which are environmental problems in
themselves. The decision point for the 55 remaining
municipal sludge dumpers in the region on which
alternative method to implement is at hand, but no
matter what method is used—landfill, incineration,
pyrolysis, recycling—some environmental impact will
result. The NYS/EPA Agreement outlines two major
strategies for dealing with residual wastes. One
recognizes that valuable energy and usable resources
can be developed from them. The second deals with the
proper disposal of any remaining residual wastes. While
Region II continues to view ocean dumping as the least
acceptable disposal method, emphasis has been placed
on tying our ocean dumping phaseout program into
such progressive state legislation as now exists in New
York, where it is mandatory that 75 percent of wastes
generated in the state be used in some kind of resource
recovery scheme by 1985.
All municipalities with ocean dumping permits for
their sludges have been afforded the opportunity of
using construction grant funding for putting into effect
land-based alternative disposal methods. Most have
chosen that path. When Camden, NJ officially stopped
dumping its sewage sludge in the ocean at midnight,
June 15, it became the first major city in the country to
use composting as an alternative to ocean dumping its
wastes. Region II funded 75 percent of the $3 million
needed to plan and build the project, which processes
the city's total daily sludge output. Most of the New
York and New Jersey municipalities still dumping
sludge in the ocean are considering composting in one
of a mix of alternatives to the practice.
If compliance schedules are not met in the facility
planning, construction and implementation of sludge
management alternatives, the Region has been taking
the appropriate enforcement actions.
The number of industrial dumpers in the Region has
dwindled greatly over the years, and those still dumping
their wastes have adhered to the phase-out dates on
their renewable one-year permits, as have the com-
panies on a single three-year special permit to dump.
While discussing coastal water quality in Region II, it
seems appropriate to mention here that crewmen
aboard Exxon's Glomar Pacific began drilling the first
oil well off the East Coast on March 29, launching the,
exploration of an undersea tract that could yield huge
reserves of oil and natural gas. The ten oil companies
involved in the exploration work protested conditions
they considered too stringent in their EPA discharge
permits for the drilling rigs. Region II denied their
request for hearings because I found the provisions of
the permits sound and could see no technical basis for
changing those conditions. We intend to do our utmost
to ensure that the marine environment of the outer
continental shelf is protected, despite high investment
and hope on the part of companies and the public that
East Coast oil and gas will mean energy harvested at
home in the years ahead. We intend to prove that the
two goals can be and are compatible.
Combined sewer overflows, one of the most pressing
water problems for the major cities in the Region, is
pinpointed in the NYS/EPA Agreement as needing
concerted federal and state attention. New systems must
be built and existing systems upgraded. Opportunities
for more effective use of beach facilities exist in many
parts of New York and New Jersey, including the Great
Lakes, as a result of adequate control of these urban
wastewaters.
The principal environmental problem associated with
hazardous and solid waste disposal is water quality
degradation. Linking together the management of
wastes and the protection of drinking water sources is
also high on the NYS/EPA Agreement priority list.
Through the strategies outlined in the agreements we
intend to bring the financial resources of the Clean
Water Act to bear more effectively on solid /residual
waste problems as a supplement to the authorities and
resources available under Resource Conservation and
Recovery Act (RCRA).
Region II is participating in the planning of resource
recovery elements of the South Bronx redevelopment
project, including refuse-to-energy facilities and is
helping to revive a New York City-sponsored source
separation of garbage program. In Puerto Rico, Region
II has helped the Environmental Quality Board to
establish a Source Separation Task Force to comple-
ment the island-wide Solid Waste Authority which is
being organized under new legislation. An EPA consul-
tant is organizing a resource recovery feasibility study
for the U.S. Virgin Islands. Energy recovered from
refuse there may be used for desalinization of sea water
to provide potable water supply.
The 1977 Clean Air Act Amendments significantly
increased the responsibilities of all levels of government
to control air pollution. Region II is drafting a
NYS/EPA Agreement on air quality management in
order to maximize productivity in the coordinated
strategic approach between various levels of govern-
ment that is so essential. The Agreement has gone
through the initial stages of development and is
expected to be in final form around mid-February 1979.
It is attempting to:
Identify the course of existing or potential air quality
problems and define the methodology for tracking
future progress,
• describe the development and implementation of a
management program to solve the problems identified
in the air quality management assessment,
• address the interface with other media (i.e., water,
solid waste), and
JANUARY 1079
-------
• address the strategy for ensuring a coordinated effort
among federal, state and local governmental in-
stitutions to implement an effective air pollution abate-
ment program.
New York Governor Hugh Carey, New York City
Mayor Ed Koch and I have signed a memorandum of
understanding that defines how the city's 1978
Transportation Control Plan (TCP) will be revised to
conform with the Clean Air Act Amendment of 1977.
The memorandum commits the three parties to adopt a
work plan for carrying out the revision, to involve
appropriate governmental agencies and nongovernmen-
tal representatives in the process and to include air
quality considerations in all transportation planning.
The great majority (approximately 94 percent) of the
745 major stationary sources in New Jersey have come
into compliance with SIP requirements, and most of
those which remain out of compliance are only in
marginal violation. Region II intends to relax the state's
SIP requirements as they pertain to the glass industry
because the action will not interfere with the desired
attainment of air quality standards. New Jersey is now
formulating a revision to the SIP which will increase its
ability to control the emission of hydrocarbons. Con-
currently, Region II intends to implement the many
regulatory requirements of TSCA and RCRA to
control the introduction of hazardous pollutants into
the environment.
Ninety-two percent of the major stationary sources in
New York are in compliance with the SIP and
applicable federal regulations. Region II and the state's
Department of Environmental Conservation confer on
a formal and frequent basis to establish a coordinated
strategy for enforcement.
The Regional Office of Toxic Substances has been
developing an integrated toxic substances control
program that encompasses all EPA media programs.
Included in the integrated approach are coordinated
response to crisis incidents; coordinated review of toxic
related aspects of media programs; identification,
assessment and prioritization of toxics of concern;
acquisition and evaluation of information relative to
toxics in the environment; magnitude of exposure,
sources, cause-effect relationships, intergovernmental
cooperation, as well as public participation and
awareness.
The regional staff played a key role in responding to
the Love Canal disaster, providing expertise when
needed, marshalling regional efforts to assist the City of
Niagara Falls and the State of New York, and
providing analytical and technical equipment and ex-
perts for both environmental and health studies in the
area. During the mysterious cancer cluster scare in
Rutherford, NJ, staff in the Regional Office of Toxic
Substances provided state experts and federal
researchers with data essential to their exhaustive, 4-
month investigation. The investigators were not able to
confirm a specific cause for the disease, and the incident
remains a mystery.
Region H's Office of Toxic Substances will hold a
joint workshop in March with Environment Canada,
New York Department of Conservation, the Inter-
national Joint Commission, and the Great Lakes Basin
Commission dealing with the many issues of mutual
concern associated with toxic substances control in the
Great Lakes. It will be the first in a series of such
workshops. The endeavor is endorsed by the Water
Quality Board of the International Joint Commission.
Report from
Region III
JACK J. SCHRAMM
Region III Administrator
During my first year as regional administrator I have
come to realize that one of our basic problems, and
indeed a problem inherent in most regulatory agencies,
is that we continually find ourselves in adversary
relationships with one faction or another. What is really
unfortunate about this, is that we seem to be at odds
with our friends as often as we are with our detractors.
I am speaking specifically about our relations with state
governments and with the citizens at large.
Cooperation between EPA and the states has been a
well traveled theme. Most of the federal laws which
EPA administers call for states to assume primary
authority over many important environmental
programs. Since its inception. Region III has delegated
many of these programs to the states. Perhaps the most
important recent delegation was .that of the NPDES
wastewater discharge permit program to Pennsylvania.
Since the Commonwealth contains over half of point
source discharges in the Region, this delegation was a
big step forward.
However, we still have a long way to go. Many
programs still remain to be delegated. But perhaps even
more important, is the development of comprehensive
agreements between EPA and the states which will help
to integrate and coordinate many antipollution ac-
tivities that are now fragmented. This fragmentation
has been the cause of a great deal of wasted time and
resources. An integrated and coordinated approach will
not only help us save citizens' tax dollars, but also helps
improve our ability to attack many environmental
problems.
Negotiation of these comprehensive EPA/State
Agreements is a national priority with the Agency, and
Region III has already taken several steps on its own
which should help in this effort.
At the beginning of the year I ordered a major re-
organization of all those Regional staff positions whose
main purpose it was to interact with the states and the
public. I have called this new organization the Office of
Intergovernmental Relations and Public Awareness
(OIRPA).
One of the major innovations of the reorganization
was the creation of a program officer position for each
state in the Region. The state program officers are
senior level staff who are responsible for liaison with
state and local elected officials and officials of the state
environmental agencies. Their most important role will
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be to help integrate the activities of various EPA
programs and divisions whenever necessary in their
states. I believe that they will help to increase coopera-
tion between EPA and the states and provide both of us
with the up-to-date information we need in order to
make decisions that are acceptable to all.
In developing the EPA/State Agreements, we will
concentrate on several vital programs. These are the
control of toxic substances, the redevelopment of State
Implementation Plans, and improvement of state
capability to administer the EPA Construction Grants
Program and the development of Water Quality
Management Plans.
Toxic substances have become our number one
environmental problem in recent years. Almost every
day we are being confronted with toxic time bombs
which have just blown up or are about to do so. In
order to control this problem effectively it will require
us to integrate several existing programs including the
NPDES permit program, certain authorities under the
Safe Drinking Water Act and the Resource Conserva-
tion and Recovery Act (RCRA), industrial pretreat-
ment of wastewater, plus several others. The states
already have substantial experience with many of these
programs except RCRA, which is yet to be fully
implemented. Consequently, we will concentrate a good
deal of effort on getting the states to accept respon-
sibilities under this Act.
Two years ago Region III, consulting with the states,
reviewed all State Implementation Plans (SIP's) and
found them to be inadequate to ensure that national air
quality standards could be attained or maintained. In
the meantime, the Clean Air Act Amendments of 1977
required that all areas which are not meeting air quality
standards would be required to revise their SIP's. In
Region III this is a massive task, and some of the states
will have to make some hard choices in order to meet
the Congressional mandate. We expect to work closely
with the states in this effort.
EPA's Construction Grants Program is one of the
largest and most important of all Agency programs. It
allows communities to build vitally needed sewage
treatment facilities, and is the source of many
thousands of jobs. But the size and complexity of this
program also makes it a great drain on EPA ad-
ministrative resources. Therefore, we are working
towards implementation of a new amendment to the
Clean Water Act which will give more money to the
states so that they can assume more of the ad-
ministrative responsibilities.
Water Quality Management Planning will help deter-
mine where and when facilities will be built under the
Construction Grants Program. Proper implementation
of this program will help to ensure that the grants
program is administered in the most cost effective and
environmentally sound manner as is possible.
Other aspects of the EPA/State Agreements will be
the improvement of several support-type activities. One
of the most important of these is environmental
monitoring. Monitoring is a necessary basis for many
of the technical decisions in other programs. We will
also improve our cooperation with the states on general
enforcement activities and will provide them with
special technical assistance through our R&D program.
While relations with the states are important, we
have not forgotten our responsibility to improve
relations with our other constituencies. In order to
strengthen the role individual citizens can play in the
decisionmaking process, we are in the process of
upgrading our citizen participation efforts. We will
make additional attempts to inform citizens early about
important projects or rules that might affect them. We
will give them adequate opportunity to make their
views known through public meetings, letters and other
forms of communication. Finally, we pledge to careful-
ly consider all citizen comments in our decisionmaking
process.
Mindful of the need to minimize adverse economic
impacts of our activities, we are strengthening our
ability to help businesses that wish to locate in the
Region. We have appointed a new source coordinator
who will act as the liaison between new businesses and
the Agency. This coordinator will be able to tell a
business executive which environmental permits and
reviews he will need in order to do business, and then
will ensure that the Agency completes its review of new
source applications as expeditiously as possible.
As you can see, I have set forth many challenges for
Region III in the coming year. My staff and I are ready
and eager to address these challenges, and we invite
other realistic and caring elements in our society to join
forces with us in this effort.
Report from
Region IV
JOHN C. WHITE
Region IV Administrator
Problems arising from the use and misuse of toxic
substances will command much of our attention in
coming months. Major toxic "incidents" seem to be
continuing. For example, just when Louisville was
about to rid itself of contaminated sewers, the State of
North Carolina was forced to deal with more than 200
miles of roadway saturated with PCB's.
Again in 1978, there were more reported spills in
Region IV than in other parts of the country. Many of fi
the more serious incidents were the result of train
derailments. Spill response always has been a major
activity in the eight southeastern states. In all probabili- •
ty response and prevention activity will increase during
the coming year with more emphasis on spills of
hazardous materials.
In 1979, we'll be seeing more cities in the Southeast
turn to automobile inspection and maintenance
programs to bring about reduced levels of hydrocar-
bons and carbon monoxide. Louisville, Tampa,
northern Kentucky and Atlanta have voluntary I&M
programs underway. In the offing are similar programs
for Columbia, SC; the south Florida counties of Dade,
Broward and Palm Beach; also Davidson (Nashville)
JANUARY 1979
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and Shelby (Memphis) counties in Tennessee.
Reviews of new sources of air pollution will increase
substantially as the 1977 Clean Air Amendments are
implemented and the southeastern states continue their
rapid industrial growth.
Intensive activity will be required by Region IV's
staff and state agencies in order to complete approval
of SIP revisions before July 1, 1979.
We're looking for an increasing number of en-
vironmental impact statements in Region IV, including
site specific statements for new phosphate mines in
Florida. A draft EIS on the phosphate industry calls for
the elimination of slime ponds, suggests the rock drying
process be eliminated, and says prime wetlands should
not be disturbed. Florida is the major phosphate-
producing state in the nation.
A noise abatement and land use study of Atlanta's
Hartsfield International Airport (the world's second
busiest) is expected to be completed in 1979. Using an
earlier survey as a starting point, the new study,
ordered by the city, will look at a broad range of
operational alternatives designed to bring about noise
abatement.
Coastal areas are a prime concern in Region IV. Six
of our eight states have coastlines totaling more than
2000 miles. As offshore drilling activities increase, the
development of onshore facilities will surely make the
job of protecting wetlands and estuarine areas more
difficult.
Coming up, we probably will be studying for the first
time a proposal calling for direct discharge of treated
municipal wastewater to the Gulf of Mexico. This
would, no doubt, call for the preparation of an EIS in
which all disposal options would be considered.
More farmers use more pesticides in the Southeast
than in any other region. Some pesticides in our region
are misused. Region IV inspectors in FY 78 made more
than 160 investigations. Each involved human health
effects. Over the next year we will be delegating more of
this investigatory function to the states.
At this writing, a federal judge's decision is pending
on Ferriamicide, the Mirex replacement developed by
the State of Mississippi for control of fire ants. The
Environmental Defense Fund had sought an injunction
prohibiting use of the new chemical. EPA feels
Ferriamicide shows much promise. It degrades rapidly
and does not persist in the environment. It would be
used under tight controls.
Construction grant activity will continue at a pace
similar to FY 78 with expected new awards to total
$330 million and outlays amounting to $460 million.
We expect to make 27 Step 1 grants, 106 Step 2 grants,
and 115 Step 3's. Major emphasis will be placed on
quality assurance and new requirements of the 1977
amendments, such as innovative and alternative
technology. We'll also work on getting the backlog of
Step 3 projects under construction.
We will continue to delegate some construction grant
program functions to the states. Georgia will be the
first.
The EPA/Corps of Engineers agreement to assist in
review and inspection of construction aspects of the
construction grant program should be fully operational
in FY 79.
In water supply the emphasis will be on developing
strong management programs in those states which
have assumed primary enforcement responsibilities.
Seven of the eight southeastern states have assumed this
responsibility, and we hope the eighth (North Carolina)
will in FY 79.
In the 208 program I believe we'll see the completion
of initial planning efforts and the initiation of con-
tinuing planning process grants to state and areawide
agencies. Many water quality problems were addressed
with the initial 208 grants, but specific needs still exist
in many areas.
Also, the Region will work toward the integration of
program planning requirements of various environmen-
tal control programs through negotiation of State/EPA
Agreements.
An integral part of all our efforts will be an increased
emphasis on public participation. Active citizen in-
volvement is an absolute must. We'll do our best to
bring this about.
Report from
Region V
JOHN McGUIRE
Region V Administrator
Air pollution and hazardous waste problems led the
priority list in Region V this past year.
Region V encompasses America's industrial
heartland—Illinois, Indiana, Michigan, Minnesota,
Ohio and Wisconsin.
A major issue climaxed on August 22 when nearly
3000 miners in the Ohio River Valley attended a
hearing to voice their concerns about Ohio utilities use
of out-of-state coal to meet clean air standards. There
were strong concerns that over 15,000 miners could lose
their jobs if a switch by utilities to Western coal was
allowed.
A series of hazardous waste disposal crises also
occurred in the Region. In Wilsonville, IL a judge
closed down a major Midwestern Disposal facility used
for PCB burial. In Mio, MI, strong local opposition
developed over proposed disposal of some 5000 head of
cattle that contained trace amounts of PBB's. In the
Twin Cities, citizens turned out in the thousands to
reject siting of a model hazardous waste landfill, to be
paid for mostly with EPA funds. A new treaty was
negotiated for the Great Lakes between U.S. and
Canada which calls for new emphasis by both countries
in controlling toxic dischargers.
As of September, 25 of 32 local planning agencies in
the Region turned in completed plans for water quality
management (208). In the coming year emphasis will be
on state agency planning.
Also, as of early autumn three states in Region V had
requested new delegations allowing them to ad-
POLLUTION ENGINEERING
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ministrate major phases in the construction grants
program. Those states include: Illinois, Indiana and
Ohio.
Regional compliance figures for 1978 through
September showed that 80 percent of 550 major
industrial dischargers have facilities built to meet state
cleanup requirements in the Region.
A major thrust in the air pollution effort in the
Midwest was designation of nonattainment areas for air
pollutants. Since those designations. Region V states
have been busy at work developing new state im-
plementation plans, most of which heavily emphasize
controlling ozone from automobiles through auto
inspection and maintenance programs.
The state implementation plan revisions also are
taking into account rules governing the prevention of
significant deterioration. Region V states, concerned
about future growth, have been asked to develop plans
that will both meet standards and allow for future
growth.
To better help the public, the Regional office began
publishing this year a biweekly "tip sheet" called the
Public Participation Printout, to alert interested per-
sons of upcoming agency activities, events and decision
points. Nearly 6000 persons receive the document each
month.
A two-year surveillance study of Lake Michigan was
released by the Region's Great Lakes office in the
spring. The study showed that in the last decade Lake
Michigan has been showing increasing evidence of
eutrophication. And, while measurable improvements
can be seen in the nearshore waters of the lake, the
open waters are still showing the impact of decades of
heavy pollution. Because of a phosphate detergent ban
in Indiana, phosphorus levels at the lower end of the
lake have dropped dramatically, but overall salt levels
in the lake are continuing to rise. PCB levels have not
increased since 1976 and there is some indication they
are declining. DDT levels have fallen to 10 percent of
their 1969 levels. At the same time, the Region began a
new two-year study of the open waters of Lake Erie
aboard its new research vessel, the Rachel Carson, a
former Vietnam gunboat from the Navy. A second
EPA vessel, the Roger Simons, began studying the
nearshore waters of Lake Erie.
A new, $3 million environmental testing lab was
dedicated in February. Called the Central Region
Laboratory, it is one of the best equipped environmen-
tal labs in the Midwest and handles a wide range of
analytical work, including testing on toxic substances.
Following a chemical plant explosion last August, the
lab even ran tests for the Food and Drug Administra-
tion of pizza samples from a restaurant downwind from
the explosion.
In a major enforcement action, the Region filed suit
in Federal District Court in Chicago against Outboard
Marine Company demanding the company remove
from the North Ditch and assess removal from
Waukegan Harbor of about 600,000 pounds of PCB-
laden sediments.
The Region also denied approval to the Indianapolis
Power and Light Company's request to build a 1950-
MW coal-fired power plant along the Ohio River near
Rockport, IN. It was the first denial of such a request
in the Region.
Region V in August authorized a $709 thousand
grant to the State of Ohio for its water pollution
control program. That grant had been withheld
previously because of concerns over the adequacy of its
water enforcement plan. An upgraded enforcement
program was agreed to by the state in August.
A major enforcement action was taken by the
Regional office against 12 federal facilities accused of
air and/or water pollution activities.
During the year, sixteen cities in Region V adopted
new antinoise ordinances with the help of the Regional
office. National news attention focused on Galena, IL
which enacted a tough new ordinance cracking down
on motor vehicle noise.
The Region's environmental impact reviews raised
concerns over a highway development on wetlands in
southern Wisconsin, a new steel facility in northeastern
Ohio, and expansion of a coal pit in downstate Illinois.
Important issues for the coming year in Region V
will continue to be in the air pollution and hazardous
waste areas. The major regional effort will be in
supporting state agencies as they work to deal with
existing air pollution problems and the potential
impacts on air quality of economic growth.
Report from
Region VI
ADLENE HARRISON
Region VI Administrator
As I look back on the past year in Region VI, I am
reminded that there are no absolutes in life—many
events in the Region seem to have been contradictions
of what some of us expected and, in some cases, the
paths to decisions have seemed obscure. The decisions
have had endless ramifications. I am sure these facts are
as true elsewhere in the country as they are in the five-
state area of federal Region VI.
Region VI is an enormous area of 550,000 square
miles covering 15 percent of the land area of the United
States. Traveling distances within the Region are often
staggering.
There are over 20 million people here, and that
number is increasing at a rate approximately double the
national average. The Region is an environmental
microcosm, with mountains, prairies and shores.
This is the leading Region in energy production and
balancing that production with environmental harmony
and the protection of human health and well-being is an
ever present challenge.
Protecting and improving the quality of water here is
particularly important to us. Along with the long
stretch of coastline and the many underground drinking
water sources, the Region has the predominant portion
of the nation's wetlands that are an integral part of the
food chain. As noted by President Carter recently, we
JANUARY 1979
-------
are losing 300,000 acres of wetlands annually in the
nation. Microscopic plants and animals thrive in the
wetlands forming the base of the food chain, of which
man is the ultimate consumer. Therefore, controlling
water pollution in each of these areas is essential.
To continue the positive steps to control water
pollution, Texas was the second state in the nation
which was delegated administrative responsibility by
EPA for the management of its wastewater treatment
facility construction grants program. Over 100 state
jobs will be created by this delegation, freeing the
Region EPA staff to concentrate on other urgent
program needs.
In other similar action, EPA negotiated an agreement
with the Corps of Engineers in March of this year
which provides that the Corps will assist in the review
and inspection of the construction of new wastewater
treatment plants. Region VI was the pilot Region for
this effort. The three major tasks the Corps will
perform are: (1) reviewing plans and specifications prior
to bidding ("constructability and bidability reviews"),
(2) insuring that EPA-approved projects are bid,
contracted for, and constructed in accordance with the
highest standards of the construction industry; and (3)
providing continuous on-site presence on projects
costing about $50 million or more.
The development of a sound, workable areawide
water quality management plan is difficult at best—but
it can be done. Only a year ago, the development of the
Oklahoma Indian Nations Council of Governments
areawide plan was in difficulty, and few seemed to be
able to agree on a solution. The council, by working
closely with the public and elected officials, turned itself
around and now has the distinction of having the first
state-approved plan. We are looking forward to ap-
proved plans from all parts of the Region in 1979.
Water, below the surface, is also of concern in this
Region. We are concentrating on delegating the prime
responsibility to each state for the Underground Injec-
tion Control Program, and anticipate this delegation
will be made to each state by the end of 1979. To
achieve this goal, we are working with the states to
obtain the regulatory changes and enabling legislation
as needed. Total public participation in the process will
be assured in line with our commitment to full public
awareness and involvement in environmental issues.
The public will also play an increasingly important
role in our Wastewater Treatment Facility Construction
Grants Program. Increased public participation will be
sought by dissemination of information to the media,
by making information readily available to various
citizen advisory committees, workshops and public
meetings and hearings, and by special mailings to
specific groups. We believe that active public participa-
tion is the base upon which we will achieve Regional
environmental goals.
We have addressed the first round of major problems
in water quality in the Region and that work will
continue. We are presently addressing the way to solve
the air pollution problems in the Region. Through
increased intergovernmental cooperation and planning,
we are beginning to see successes with the Emission
Offset Policy which provides for reduced air pollution
since new polluting sources must demonstrate that
pollution from other sources in the area are reduced by
at least an amount greater than the new source would
pollute.
In the forefront, the Texas Air Control Board is
implementing Congressional requirements for emission
offsets in Texas. In addition, hard work by several
government agencies and industry made possible the
identification of the necessary pollution offsets to allow
new automotive plants to be built in Louisiana and
Oklahoma. This has demonstrated that continued
growth, with environmental protection, is possible. A
willingness to make the program work and close
cooperation are the keys.
A major job in the Region this year undoubtedly is
the development of approvable air quality State
Implementation Plans (SIP's). The extraordinary in-
dustrial growth in the Region and large population
increases make the job of achieving and maintaining
good air quality difficult. The rapid growth of urban
areas in the Region and the resulting air quality impacts
must be carefully considered when the states develop air
pollution control plans. These plans will include
transportation control measures and automobile inspec-
tion and maintenance programs where they are
necessary.
We are anticipating major progress in controlling air
pollution through increased cooperation with the states
and the implementation of new technology and control
techniques.
While we are involved in the challenges of developing
additional energy and ensuring that the environment is
protected in the process, the industrial boom requires
that we be constantly involved in minimizing the
environmental impacts of increased industrial growth,
particularly in Louisiana and Texas where special
attention to the coastal zone management and wetlands
protection is required. We are continuing to develop
more effective and efficient systems to measure the
environmental impacts of proposed projects. We are
also streamlining the handling of applications for
dredge and fill permits, the issuance of Prevention of
Significant Air Deterioration (PSD) permits, and the
handling of National Pollutant Discharge Elimination
System (NPDES) permits by increasing the role and
responsibility of the states.
We are initiating new approaches to coordinate and
manage environmental programs in order to increase
our effectiveness, and we will closely coordinate our
activities with state and local officials and other
agencies, with great emphasis on involving the public.
In line with the directions of the President, we intend
to respond to citizen needs quickly, courteously and
completely. One of our top priorities is firmly cemen-
ting faith, trust and credibility, and we seek the same
spirit of cooperation from the states and the public in
the Region. Our goal is that Region VI and its people
will be national environmental leaders.
Our activities are geared toward this goal. The tasks
are complex, but, because of the industrial growth in
the Region, we must and will meet the environmental
challenges head-on.
POLLUTION ENGINEERING
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Report from
Region VII
KATHLEEN CAMIN
Region VII Administrator
Most people don't understand what is going on in the
environment today. They look around and see enor-
mous environmental problems—smog, trash, toxic
chemicals and pollution—created by a world of big
business, big institutions and big government. These
problems are even more difficult to understand when
people working on them use a scientific-technical
language that few people really understand.
The people who work in the Environmental Protec-
tion Agency have sometimes been cut off from the
citizens they serve by the magnitude of the task of
cleaning up the environment. We have changed that.
EPA today is trying to bring the two together. We are
concerned that people know what is going on and what
they can do to help clean up the world in which they
live. We need their help. In fact, it is the only way that
we can really achieve our goal. We call this public
participation. Very simply, it means communication
between EPA and the public.
Everyone is aware of the problem. Bureaucrats worry
about disappearing into a fog of MOL's, I / I's, AZMA's
and red tape. Citizens worry that the quality of their
air. water and land will deteriorate before they find out
who to talk to about it. How do you get the
government and the people together?
To overcome the jargon and the problem of citizens
getting through to the people they need to, a new
communication channel was established—a toll free
Environmental Action Line. Calls began to flow in.
Because the Action Line filled a need, calls soon
multiplied, sometimes 30 to 50 a day. The person
answering the Action Line tries to handle as many of
the calls as possible. In some cases, all of the caller's
questions cannot be answered by the Action Line
Operator. If this should happen, the Action Line
Operator searches for the right person in EPA or goes
to the state or local government agency that could best
solve the caller's problem. The Action Line has handled
calls on everything from airplane noise to sewer odors.
A good example is the call from Nancy McConnell.
Nancy was upset, worried and bewildered by the
situation at her parents' farm. Her parents had been
forced to move, cattle had died, a great deal of money
had been lost and her mother was suffering from
possible lead poisoning. The family felt that oil and gas
runoff from a nearby truck stop was causing the
problem. But how to get action?
Nancy heard about the Environmental Action Line
and decided to give it a try. When the phone call was
received at the Regional Office, it was immediately
referred to the Region VII Emergency Response sec-
tion, which began work. The State Department of
Environmental Quality and local officials were alerted.
Two members of the EPA Region VII staff went to
solve the problem. They found that the creek was
contaminated with oil from the truck stop parking lot.
The oil had accumulated over the winter. When the
snow melted, it washed the oil from the parking lot into
a ditch. The ditch carried the oil to a creek which
flowed across the McConnell property. Action to clean
up the creek began immediately. The result was a
successful removal of the oil.
Not all the results have been this successful, but
many of the problems can be solved in short order and
all are followed up.
EPA is able to help many people in this way, but we
have also received an unexpected environmental bonus
from the Action Line. People are helping us. They are
reporting environmental violations ranging from the
tampering of automobile pollution control devices to
chemical spills. The Environmental Action Line has
become a source of two-way communication which
promises to help Region VII clean up the environment.
In areas where specific groups have an interest in
technical subjects. Region VII is trying other new
approaches. A group of interested and knowledgeable
farmers is lending its knowledge of agriculture and farm
situations and has joined with EPA personnel to form a
working group. This exchange helps the Region to
work for realistic regulations in rural areas.
When EPA was forced to assume primacy for water
supply in Missouri, city officials had a difficult time
with new forms and regulations. Eight workshops were
set up across the state and all water suppliers were
invited to attend.
Regional water supply personnel discussed the new
situation in depth. Representative operators appeared
on the program and asked questions. As a result, the
operators understood the law better and the quality of
their reporting improved. The EPA personnel came
away with a good understanding of the operators'
problems.
Because of the deep interest of city councils, civic
clubs and environmental groups in how air quality
regulations affect their community's future. Region VII
has established a pool of speakers on the Clean Air Act.
This group is drawn from all fields but is specially
trained by the air pollution staff. These speakers will
eventually talk to all interested groups on the vital need
for clean air and what is needed to clean it up.
The communication problem is still ahead of us. The
toxic effect of minute quantities of pollutants over a
long period of time must still be explained. Complex
water pollution trade-offs must be made understand-
able. EPA still is heavily working in many very
narrowly specialized technical fields which almost defy
communication. However, Region VII strongly feels
that the Environmental Action Line and other public
participation efforts are a good start. While serving the
people of the Region, we are also able to see better their
first-hand reaction to environmental issues. This
clarifies our thinking on priorities and methods. Quite
often too, we find that people want to help clean up the
environment—all they need is the opportunity.
JANUARY 1979
-------
Report from
Region VIII
ALAN MERSON
Region VIM Administrator
As we forecast in our last year's report to
POLLUTION ENGINEERING Magazine. 1978 was a
year of progress, of focusing of issues and of tough
decisions. Already, the difficult issues of 1979 and
beyond are beginning to take shape and in an at-
mosphere of reduced resources at the federal level.
Easily the most intractable environmental problem in
the region is the battle to reclaim clean air in the
Denver metropolitan area. More than a million people
in the area are exposed to health-damaging levels of
primarily auto-related air pollutants with a chilling
frequency. The past year, however, saw substantial
movement toward solutions.
Efforts of federal agencies to reduce their employees'
contribution to the problem merged with strategies
being developed by the state and local governments.
Most importantly, the business community and citizens
groups launched efforts of their own.
In May, President Carter pledged his personal
support for Denver's clean air program and announced
the availability of some $42 million in federal assistance
of various kinds.
Candidates for local offices in the recent elections
were closely questioned regarding their positions on the
air quality solutions.
At this writing, the state is preparing to hold public
hearings on revisions to their State Implementation
Plan—revisions designed to show how standards can be
met in the Mile-High City during the 1980's. If we are
accurately judging the support of Denver area residents,
they will insist on a plan that will work, bringing us one
step closer to being able to write the "Denver Air"
success story for POLLUTION ENGINEERING.
Partly as a federal complement to the state's planning
for air quality and water quality, we completed a
comprehensive impact statement in 1978 establishing a
link between EPA construction grant funds for
wastewater treatment projects and air quality and land
use in the metro area.
To continue to fund projects without examining
those interrelationships would be an unconscionable
waste of tax dollars and an abrogation of federal
responsibility.
In fact, we devised a set of criteria which will guide
our funding decisions on construction grant
applications.
Among those criteria are requirements for metro
communities to participate in the planning and im-
plementation of the metro clean air plan, to limit plant
capacity and sewer taps consistent with population
projections agreed upon by the local council of
governments, to tie plant service to contiguous develop-
ment, reducing leapfrog development and other ideas to
promote appropriate and innovative technology.
Working with local governments to achieve such
mutual goals is one of the most exciting challenges
facing the regional office during the coming year.
These first examples of regional activities have
concerned primarily the cleanup of past or existing
pollution problems. But aside from its relatively few
major urban areas, this is a rural region with broad
expanses of clean air. It is an arid region where many of
our streams have escaped serious pollution.
In such areas, the responsibility for preventing
environmental degradation becomes ever more impor-
tant, as the region strives to share its vast energy
resources with the nation.
Thus, the task facing the entire region is to balance
the nation's energy needs with the needs to protect
agricultural production in the West and to protect
values and lifestyles representing an important compo-
nent of the American character.
National attention focused on that balancing act in
1978 when this regional office denied crucial en-
vironmental permits for the proposed construction of
two huge coal-fired power plants in southeastern
Montana, at Colstrip. Based on exhaustive analysis of
meteorological data and modeling, we concluded the
units, if built as planned, would violate allowable
increments of sulfur pollution on the nearby Northern
Cheyenne Indian reservation. That reservation enjoys
Class 1 air quality under the Clean Air Act's prevention
of significant deterioration policy. The allowable pollu-
tion increases are tiny indeed, far more stringent than
those allowed where only national standards must be
met. The issue is not yet firmly resolved. Administrative
and legal reviews remain. It serves as a pointed
example, though, of the difficulty of decisions facing all
of us as we attempt to accommodate a variety of needs,
values and viewpoints.
In Region VIII, we pursue that spirit of accommoda-
tion. To facilitate it. we have established a staff office in
Helena, MT. and hope to establish similar offices in our
other regional capitals, bringing our services closer to
the people for whom we work. We will be working to
turn over to the states the programs which Congress
intended to be run by the states, by far the bulk of
environmental regulatory programs.
It has been our experience that misunderstanding
increases with distance. It is my intention to cut down
those distances, not just the geographical ones, though
they are important, but also the "psychic distances"
between people who perceive themselves on different
"sides'" of environmental issues. In the past year, we
have markedly expanded our Office of Public
Awareness and Intergovernmental Relations, a major
part of whose job it will be to reduce the distances
between people and shore up the conviction that
environmental improvement and protection are
necessities toward which we should all work in good
faith, not elitist luxuries for us to quibble over.
We are keenly aware of the critical importance of
solid engineering in our quest for environmental quality
and invite your continued support in this most impor-
tant of tasks. Together, we can earn the gratitude of
tomorrow's generations.
POLLUTION ENGINEERING
-------
Report from
Region IX
PAUL DE FALCO, Jr.
Regional IX Administrator
As in EPA's other regions. Region IX's programs
and operations during FY 79 will be based upon the
national priorities established in Washington. Those
priorities are as follows: (1) protection of public health;
(2) enforcement of the law; (3) integration of
state/local/EPA environmental programs; (4) manage-
ment and regulatory information. However, authority
for development and implementation of programs in
•EPA has been extensively delegated to the regional
administrators. There is, therefore, sufficient flexibility
that program emphasis within each region may reflect
the needs and requirements that are peculiar to that
region.
The rationale Region IX used in ranking its
programs while embodying the above priorities can best
be stated as follows:
1. State/ local governments are closest to the
problems and consequently are the most effective units
of government to carry out federally mandated en-
vironmental programs where (a) they have the basic
interest and desire, (b) there is compatibility between
goals of federal/state statutes, and (c) they have the
resources to carry out the program.
2. Given this then, EPA programs should be man-
aged to (a) support/assist and develop state/local
programs, (b) effectively integrate the often separate
media programs, and (c) provide direct program opera-
tion where state/local programs are lacking or ineffec-
tive.
Following this rationale. Region IX has ranked its
programs for FY 79 to ensure that programs within the
following three functional areas are funded adequately
to carry out effective operations.
These provide direct support for federally mandated
programs. Priority is given to developing and support-
ing those programs directly related to public health
protection—drinking water, air and hazardous waste.
First priority is being given to development of nonat-
tainment plans, evaluation and revision of transporta-
tion control plans. Additionally, the construction grant
program is accorded the same high priority because it
provides both support for strengthening state programs
and direct cleanup of public health related water
quality problems. This takes on an added dimension of
importance in Region IX, which is generally water
limited because of water resource related issues.
This includes the water quality management, air
quality management, hazardous waste management,
and drinking water programs. In Region IX these are
principally aimed at developing the regulatory base for
effective enforcement through state/local government
and integration of the various media programs both at
the state and federal levels. These programs are
designed to assist and strengthen the state/local in-
stitutional capability to manage total environmental
programs in cooperation with EPA. They provide the
primary mechanism toward achieving state/EPA
Agreements that encompass a total environmental
program. Permit issuance and reissuance (both air and
water), development of local pretreatment programs,
integration of permit programs, and development of
California air emergency episode plans are leading
priorities.
Where state and local programs are inadequate, even
though both technical assistance and financial
assistance via program grants have been provided,
direct "EPA operation of programs will continue to be
implemented. This will be primarily in the functional
area of enforcement. Enforcement priorities for FY 79
have been given to those programs having the greatest
impact now on public health protection; i.e., those
where rules, regulations and permits are in effect and
enforceable. These include stationary source, water and
pesticides enforcement^ hazardous material spills, and
permits (NPDES and d'redge/fill). The other programs
such as drinking water, toxic and solid waste, while
extremely important, are accorded a lower priority for
FY 79 since they are just now being developed and will
not have the impact of established programs.
The national priorities give us a realistic basis for
making progress this year in areas where progress not
only needs to be made, but can be made, while laying
the groundwork for progress in other areas next year.
Report from
Region X
DONALD P. DUBOIS
Region X Administrator
The number one challenge facing Region X is for
EPA and state pollution control agencies to develop,
adopt and implement effective air pollution control
strategies that will enable Alaska, Idaho, Oregon and
Washington to achieve the goals set by Congress when
it enacted the Clean Air Act Amendments of 1977.
A key measure of progress to be made during 1979
will be to get on the books workable State Implementa-
tion Plan (SIP) revisions to achieve clean air in areas of
the four Region X states where a total of 37 nonattain-
ment designations were made last year.
First and foremost, EPA's chief criterion in ap-
proving those revisions will be whether those plans
contain assurance that air quality standards will be met
and maintained. But EPA will also examine those plans
in terms of how well they reflect citizen involvement in
their preparation and how well those plans
acknowledge other environmental considerations.
Compromise will have had to be reached, and
conflicting interests will have had to be balanced for
those plans to succeed.
Spokane, WA offers an illustration of how revised
JANUARY 1979
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SlFs will have to take into account a variety of
environmental, social, public health and economic
issues.
The Spokane SIP revision process is complicated.
V/hat makes it so is that a number of pending
decisions—related to local zoning, the construction of a
new freeway off-ramp and on-ramp, protection of
drinking water, and the building of nearby sewage
treatment works—carry just as much importance as
does the concern that proposed industrial and residen-
tial growth in the area may cause frequent violations of
national ambient air quality standards for carbon
monoxide.
In Spokane, careful consideration must be given to
drinking water because of EPA's designation last year
of the Spokane Valley-Rathdrum Prairie Aquifer as a
sole source drinking water aquifer. The Spokane
designation meant that any construction project receiv-
ing federal financial assistance that has the potential for
polluting the aquifer will be subject to a special EPA
review to make sure such contamination does not
occur. This review includes highway construction,
multiunit housing development and municipal sewerage
facilities built under EPA's own construction grants
program—exactly the types of construction that are
being considered in the area east of Spokane.
The challenge for EPA, in evaluating whether to
approve the revised SIP for Spokane, is to avoid
making decisions that would adversely affect the
Spokane area's underground drinking water supplies
and—what's more—to consider whether any con-
templated EPA action (like the decision to go ahead
with the new sewage treatment works nearby) will
create leapfrogging development that might be inconsis-
tent with local land use policies or that might defeat the
clean air intentions of the SIP itself.
The need to integrate EPA's various environmental
programs holds true not just in Spokane, but in other
parts of Region X as well. The problems faced in the
Pacific Northwest and Alaska transcend those
associated with only air, or water, or pesticides, or
noise, or radiation, or solid waste. They cannot be
addressed on a one-at-a-time basis, each in isolation
from the other. Nor can they be addressed by EPA
attempting to work one-on-one with pollution control
agencies at the state and local level. The problems, if
they are to be solved, need to be addressed by EPA and
its state and local counterparts in consultation and
partnership with other agencies of government outside
the pollution control field, with economic interests
directly affected and with citizens concerned with
preserving the amenities of living in the region.
In the case of Spokane, recognizing that the issues
cross jurisdictional boundaries, and involve other
federal agencies, units of state government, and elected
and appointed officials at the municipal and county
level, EPA is attempting to bring about solutions
through the two-year assignment of an EPA staff
person to the mayor's office in Spokane. Details of the
arrangement, to be worked out through negotiations
with the mayor, would provide for the EPA assignee to
serve as a coordinator between all the city, county, state
and federal agencies that are trying to find compatible
solutions to interdependent problems.
Similar intergovernment and interdisciplinary ap-
proaches, modified to fit individual circumstances, may
have to be used in 1979 as EPA and state and local
pollution control agencies address such top-priority
items as these:
• Adoption of transportation control plans to reduce
air pollution from automobiles in Boise and
Anchorage, the two new cities in the region (Seattle,
Spokane and Portland were already on the list) that
must develop such plans.
• Adoption by the forest products industry of a best
management practices approach to solving air and
water quality problems associated with timber
harvesting.
• Helping landfill operators along the Pacific Coast,
where rainfall often amounts to more than 100 inches a
year, meet EPA criteria intended to prevent the
leaching of harmful chemicals into groundwater, or
nearby lakes, rivers and streams.
• Implementing the first phase of a toxic substances
control strategy that will lead to a program that will
coordinate the statutory requirements of the Toxic
Substances Control Act, the Resource Conservation
and Recovery Act, and the industrial pretreatment and
hazardous materials provisions of the 1977 Clean Water
Act.
• Encouraging local communities to adopt resource
recovery programs that will enable them to participate
in the Resource Recovery Implementation Grant
Program.
• Helping local sewerage agencies build community
sewerage systems where good sense shows they will do
the job as well as or better (and at less cost) than
conventional sewage treatment plants.
• Assisting growers and others in agricultural areas
implement measures identified in 208 plans to reduce
nonpoint source water pollution.
• Establishing a Prevention of Significant Deteriora-
tion permit system in a region that has more land area
designated as Class I than any other region.
• Helping secure needed sewerage improvements for
the more than four dozen publicly owned systems
discharging to marine waters, all of whom have
announced their intention to apply for waivers from
secondary treatment, once it's decided whether they
qualify for the waiver.
Success in dealing with these problems will not come
solely as the result of transactions between EPA and
state and local pollution control agencies in Alaska and
the Pacific Northwest. EPA approval of state and local
plans and strategies to deal with all these problems will
be the culmination of a process that involves the
delicate accommodation of conflicting demands that, at
the outset of the process, may have appeared to be
irreconcilable.
The process—if it is to work best—must start with
the willingness of persons with competing points of
view to sit down together to find common ground on
which fair and workable solutions can be reached.
That's the way EPA's Region X is pledged to continue
to work to make things happen in 1979.
POLLUTION ENGINEERING
•frU.S. GOVERNMENT PRINTING OFFICE: 1979-281-147/67
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EPA is charged by Congress to protect the Nation's land, air and water systems. Under a mandate
of national environmental laws focused on air and water quality, solid waste management and the
control of toxic substances, pesticides, noise and radiation, the Agency strives to formulate and
implement actions which lead to a compatible balance between human activities and the ability of
natural systems to support and nurture life.
If you have suggestions, questions
or requests for further information, they
may be directed to your nearest
EPA Regional public information office.
EPA Region 1 • JFK
Federal Bldg. • Boston
MA 02203 . Connec-
ticut, Maine, Massachu-
setts, New Hampshire,
Rhode Island, Vermont •
617-223-7223
EPA Region 2 • 26
Federal Plaza • New
York NY 10007. New
Jersey, New York, Puer-
to Rico. Virgin Islands •
212-264-2515
EPA Regions* 6th
and Walnut Streets •
Philadelphia PA 19106
• Delaware, Maryland,
Pennsylvania, Virginia,
West Virginia, District of
Columbia • 21 5-597-4081
EPA Region 4 • 345
Courtland Street NE •
Atlanta GA 30308 •
Alabama, Georgia,
Florida. Mississippi.
North Carolina, South
Carolina, Tennessee,
Kentucky* 404-881-3004
EPA Region 5« 230 S.
Dearborn • Chicago IL
60604* Illinois, Indiana,
Ohio, Michigan, Wiscon-
sin, Minnesota •
312-353-2072
EPA Region 6* 1201
Elm Street • Dallas TX
75270 • Arkansas, Loui-
siana, Oklahoma, Texas.
New Mexico •
214-767-2630
EPA Region 7 • 324
East 11th Street*
Kansas City MO
64106* Iowa, Kansas.
Missouri, Nebraska •
816-374-6201
EPA Region 8* 1860
Lincoln Street*
Denver CO 80295 •Col-
orado, Utah, Wyoming,
Montana, North Dakota,
South Dakota •
303-837-3878
EPA Region 9* 215
Fremont Street • San
Francisco CA 94105 •
Arizona, California, Hawaii,
Nevada. Pacific Islands
.415-556-1840
EPA Region 10* 1200
Sixth Avenue • Seattle
WA98101 'Alaska,
Idaho, Oregon, Washing-
ton • 206-442-1203
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