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
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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
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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
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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
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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
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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
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• 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)
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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-
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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
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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

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 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

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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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