United
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Agency
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Off ice of
Public Affairs (A-107)
Washington DC 20460
Nfoiume 7
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Sept/Oct 1981
oEPA JOURNAI
Environmental Protection: A Look at Pennsylvania
The Administrations Clean Air Principles
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Construction Grant Regulation Slash
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Front Cover: A panoramic view of
Philadelphia with Independence Hall in
the left foreground.
The East and West Branches of the
Susquehanna River form a picturesque
junction at the town of Northumberland,
Penn.
The Pursuit of a Better Environment
In this issue, EPA Journal reviews
developments at both the National and
State levels in the quest for a better
environment.
We have an article on the 11 principles
which will guide the Reagan
Administration in its efforts to extend the
Clean Air Act. We also take a look at
where most of the work is done in the
battle for clean air — at the State level.
We begin with a number of reports
from Pennsylvania, partly because this
State has such a variety of environmental
problems and assets. We hope to review
environmental difficulties and progress in
States in other sections of the Nation at a
later time.
An article on how the Clean Air Act
could be made more effective is the first
in a series the Journal plans to carry on
various aspects of this legislation.
The issue also carries a photo essay on
Pittsburgh which indicates that
substantial progress in cleaning the air
was sometimes possible even before the
Clean Air Act was passed.
More new top appointments for EPA
are disclosed in this issue. Also included is
an article about a proposal explained by
Deputy Administrator John W.
Hernandez to slash by 50 percent the
number of Federal regulations governing
construction of municipal waste
treatment plants. D
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United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington, D C 20460
Volume 7
Number 8 "^
September-October 198 1
?/EPA JOURNAL
Anne McGill Gorsuch. Administrator
Byron Nelson III, Director, Office of Public Affairs
Charles D. Pierce, Editor
Truman Temple, Associate Editor
EPA is charged by Congress to
protect the Nation's land, air and
water systems. Under a mandate
of national environmental laws,
the Agency strives to formulate
and implement actions which
lead to a compatible balance be-
tween human activities and the
( ability of natural systems to sup-
port and nurture life.
The EPA Journal is published bi-
monthly by the U.S. Environmental
Protection Agency. Use of funds for
printing this periodical has been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect EPA policy Con-
tributions and inquiries should be
addressed to the Editor (A-107).
Waterside Mall, 401 M St . S W.,
Washington, D C. 20460 No per-
mission necessary to reproduce
contents except copyrighted photos
and oilier materials
Text printed on recycled paper.
The 11 Principles 2
The President's general
approach in seeking extension
of the Clean Air Act is
outlined.
Why the Clean Air Act
Needs Adjustment 4
Atop EPA official discusses
revisions in the Act.
Cutting Construction Grant
Red Tape 10
A proposal to cut the
regulations on building
wastewater treatment plants is
under consideration by EPA.
A Reporton Pennsylvania 11
The beginning of a special
section on environmental
issues in this State.
New Perspectives on the
Environment 12
U.S. Senator Jonn Heinz
discusses the impact of the
Administration's regulatory
reform program on the
environment.
For the Benefit of All 14
A key Pennsylvania official
reviews environmental
programs in the Keystone
State.
Pennsylvania's
Environment 19
The leader of an
environmental organization
assesses her State's progress.
Pittsburgh: Yesterday
and Today 22
A photo essay illustrating the
famous air cleanup in one of
the Nation's major industrial
centers.
You Have a Friend in
Pennsylvania 24
A report on efforts to improve
relations between EPA and
Keystone State officials.
The Selling of Waste 26
Philadelphia's Water
Commissioner reports on the
sale of sewage sludge.
An Industry View 28
An official of U.S. Steel notes
that environmental and
economic progress can be
realized jointly.
More Key EPA
Appointments
Additional Headquarters and
Regional Posts Filled
Design Credits. Robert Flanagan and
Ron Farrah.
Photo Credits: Dave Rente of
Associated Photographers; Stave
Delaney; Pennsylvania Department of
Environmental Resources;
Pennsylvania Dutch Visitors Bureau;
John L. Alexandrowicz; Photri; Dick
Swanson.
EPA Journal Changes
The annual subscription price for the EPA Journal
is being dropped from $12 a year to $8.50 for
subscribers in the U.S. because the number of
issues per year is being reduced from 10 to six.
Budget constraints require the new bi-monthly
schedule which begins with this issue. The charge
to subscribers in foreign countries will decline
from $15 a year to $10.65. The price of a single
copy of the Journal will be $2.50 if sent to an
address in the U.S. and $3.15 if mailed to a foreign
address. All these prices include mailing costs.
Subscriptions to EPA Journal, as well as to other
Federal Government magazines, are handled only
by the U.S. Government Printing Office. Anyone
wishing to subscribe to the Journal should fill in
the form at right and enclose a check or money
order payable to the Superintendent of Documents.
The form should be mailed to: Superintendent of
Documents, GPO, Washington, D.C. 20402.
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The 11 Principles
The Nation should continue its steady progress toward
cleaner air.
President Reagan in seeking
extension of the Clean Air Act has
approved a general approach based
on 11 basic principles.
EPA Administrator Anne M.
Gorsuch has disclosed that the
principles are based on
recommendations and options
presented to him by the Cabinet
Council on Natural Resources and
Environment and its Working Group
on the Clean Air Act headed by
Mrs. Gorsuch.
The Administrator said that the
principles provide the framework for
continuing work with Congress in
developing legislation to extend the
Act.
"Working with the key
Congressional leaders, we are
confident that specific legislation
based on these principles can be
drafted which will ensure we choose
the most effective means to maintain
continued improvement in the quality
of the air that all Americans
breathe," said Mrs. Gorsuch.
The 11 principles are:
O)
Statutes and regulations should be reasonable and
Should be related to the economic and physical realities
of the particular areas involved.
The basic concept of the health-based primary standards
in the Clean Air Act should be maintained. Cost-benefit
analysis should not be included as statutory criteria in
setting these standards, but standards should be based
on sound scientific data demonstrating where air quality
represents real health risks.
Secondary standards should also continue to be set at
the Federal level.
The current program for the prevention of significant air
quality deterioration should be maintained for the
protection of park and wilderness areas. In other areas,
protection should be based on uniform technology
requirements for pollution control.
States should be accorded a full partnership in
implementing the Nation's standards. The Federal
Government will monitor state achievement of national
health and welfare standards.
A more effective hazardous pollutant program should be
established to allow, for the first time, efficient control of
the serious health hazards posed by airborne toxic
pollutants..
Research on acid deposition should be accelerated.
\ Deadlines for achieving primary air quality standards
j should be adjusted to reflect realities in particular areas.
As suggested by the National Commission on Air
Quality, automobile standards should be adjusted to
more reasonable levels. The limit for nitrogen oxide could
be raised to a level slightly higher than that suggested by
the Commission without affecting air quality goals.
Pollution control standards for new coal-fired plants
should be based on uniform emissions standards.
Environmental protection should be the criterion.
EPA JOURNAL
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The U. S. Capitol, where Congress will decide what to do about the Clean Air Act.
SEPTEMBER/OCTOBER 1981
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Why The
Clean Air Act
Needs
Adjustment
By Kathleen M. Bennett
EPA Assistant Administrator for Air
Noise, and Radiation
The Clean Air Act has contributed to
significant improvements in air quality
over the past ten years and should serve
as the basis for continued progress in the
future. Clean and healthful air is
important to America and the original
goals of the Act remain valid.
However, despite its many strong
points, a number of the Act's provisions
need adjustment. The air quality problems
of the 1980's are different from the
problems of the 1970's. Some have been
virtually solved and others are simply
better understood. Institutions,
particularly State and local agencies, have
grown and matured. Experience has
shown some provisions require
unnecessarily burdensome procedures
and others are relatively ineffective in
accomplishing their purposes. Finally,
several provisions impose costs which are
clearly disproportionate to any associated
environmental benefit.
It is time to consider revisions to the
statute which will contribute to a more
efficient program, reduce duplication,
uncertainty, and delay and help insure
that we get a full return for our
investments in air quality protection.
Under the Clean Air Act of 1970, EPA
identified and established ambient air
quality standards for six major pollutants:
Sulfur dioxide, carbon monoxide,
paniculate matter, lead, nitrogen
dioxide, and ozone or smog.
The States have adopted control
programs limiting emissions from
factories, power plants and other
stationary sources of these pollutants and
the Federal government has imposed
stringent controls on automobiles and
other mobile sources. As a result we have
seen major improvements in air quality
and can predict with confidence the
attainment of several of the ambient
standards virtually everywhere in the
country within the next several years.
For example:
• Carbon monoxide ambient
concentrations have decreased by more
than 40% over the past ten years.
Attainment of the standard is virtually
assured throughout the country before
1987. Individual cars sold in 1980 emitted
less than one tenth of the carbon
monoxide that was emitted by the cars of
the late 1960's. The 1981 requirement
reduced this even further. This progress
represents a clear victory for the statute
and the vanishing nature of this problem
must be considered in the design of future
control requirements.
• Sulfur dioxide levels also declined by
more than 40% during the last decade.
These reductions followed an even
sharper decline in the late 1960's as States
moved independently to control power
plants and other major sources of this
pollutant. In 1981 we have a relatively
small number of localized sulfur dioxide
problems usually associated with
individual sources which have yet to
come into compliance with State-
imposed emission limitations. Of the more
than one thousand sulfur dioxide
monitors being operated by State and
local governments only about three
percent recorded readings above the
standard in 1980.
• Emissions of paniculate matter from
industrial sources were reduced 50%
during the 1970's. However, ambient
concentrations declined by only 20%.
This is because many monitors are
influenced by localized dust problems
caused by agricultural activity, unpaved
rural roads or dust from traffic on urban
streets. Most industrial sources have
installed control technology which
captures more than 90% of their
paniculate emissions and many are
capturing more than 99%.
No longer are we faced with the rather
simple regulatory problem of controlling
smokestack emissions. Now we must
deal with unconventional sources of dust,
a pollutant of limited health significance.
In many cases such dust control may
require costly and disruptive changes in
transportation and agricultural practices.
• Lead Is emitted from both automobiles
and stationary sources such as smelters
and battery factories. Most public
exposure occurs in major urban areas
where the use of leaded gasoline in cars
and trucks historically has caused high
ambient lead concentrations.
The use of unleaded gasoline in new
cars has resulted in substantial
improvements in urban air quality. Over
the past 10 years the amount of lead used
in gasoline has declined by almost 70%
and urban air lead levels have shown
corresponding improvement. Since the
lead standard was not adopted until 1978,
States are just beginning to implement
control programs and reductions from
stationary sources will take place in the
next three years.
• Photochemical smog, measured as
ozone, is the nation's most pervasive air
quality problem. In 1980, more than 40%
of the ozone monitors showed the
standard being exceeded, sometimes by a
factor of 2 or 3. Over 500 counties in 45
EPA JOURNAL
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Smoke from factories like these along the Rouge River in the Detroit area helped
spur the demand for pollution control laws.
States do not meet standards for this
pollutant and in 35 urban areas in 24
States the problem was sufficiently
severe to require extensions of the
attainment date to 1987.
Ozone is formed by the chemical
reaction of hydrocarbons and other
volatile organic compounds in sunlight.
These pollutants are emitted from
automobiles, chemical plants, painting
and printing operations, gasoline storage
and distribution and petroleum refineries.
Because the problem was poorly
understood in the early 1970's, it was
generally assumed that the Federal
automobile emission limits would
eventually solve the problem. Only
recently have the States and Federal
government come to understand that
stationary sources contribute
approximately 50% of these emissions.
They have now begun to initiate
regulatory action to control emissions.
Reductions in hydrocarbon emissions
from automobiles have barely kept pace
with increased automotive travel. This
combined with deferred action to control
stationary sources has resulted in
continued high levels of ozone. There is
no measurable downward trend to date.
• Nitrogen dioxide is formed in the
atmosphere through a chemical reaction
involving sunlight and nitrogen oxides
from automobiles and other fuel burning
sources. Few areas exceed the ambient
standard and in those cases it is exceeded
by only a relatively small margin. At this
time only seven areas are designated
nonattainment for this pollutant (Chicago,
Denver, and five California cities).
Reductions in auto emissions over the
next several years are expected to
eliminate all but one or two of these
problems. Compared to the ozone and
particulate problems discussed above, the
nitrogen dioxide problem is of minor and
declining significance.
STATUS OF
CONTROL PROGRAMS
Over the past ten years, Federal, State,
and local agencies have significantly
increased their staffing and level of
expertise in air pollution control
programs. State and local agency staffing
has increased from about three thousand
in 1970 to almost nine thousand today.
State and local funding has increased
similarly to more than $230 million in
1981, including $88 million in Federal
grants. These state and local agencies are
the key element in the air quality control
program — they operate virtually all
ambient monitors, adopt the vast majority
of emission limitations, conduct
inspections, answer complaints, and
constitute the first line of enforcement.
To meet the Federal ambient standards
the States have adopted plans and
regulations. These plans incorporate
emission limitations and compliance
schedules applicable to thousands of
existing sources. In addition, all States
require permits for major new sources and
many States issue operating permits
which are renewed periodically. The vast
majority of this structure has been
implemented since 1970 as a result of the
Clean Air Act's mandates.
In addition to State plans, Federal new
source performance standards have been
promulgated for 37 source categories and
proposed for 15 more. By the end of 1983,
virtually all major source categories will
have been incorporated in this program
which established a uniform national
requirement for the application of best
available control technology to all major
new construction.
Less progress has been made in the
control of potentially hazardous
pollutants for which ambient standards
have not been adopted. Seven such
pollutants have been identified to date
and regulations adopted for four of those.
Although other pollutants have been
identified as being of potential concern,
the process of reviewing scientific data
and making decisions as to the
significance of any risk and the
appropriateness of regulation has been
slow and inconclusive.
SEPTEMBER/OCTOBER 1981
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UNREASONABLE
SCHEDULES
The Clean Air Act includes optimistic
deadlines for attaining ambient standards
— deadlines which have proved to be
impossible to meet. Despite the real and
measurable progress in improving air
quality, this failure to meet the Act's
unrealistic schedules has created a major
problem of public credibility.
The particulate matter, sulfur dioxide
and nitrogen dioxide standards cannot be
attained everywhere by 1982.
While nitrogen dioxide is not a
significant national problem, attainment
in the few areas that exceed the standard
will be delayed until cars with better
controls are phased in.
The particulate matter problem is
marked with hot spots caused by both
rural and urban dust from agricultural and
transportation activities. These emissions
will be difficult to reduce, and control
measures will take years to implement.
Regulatory and enforcement actions
addressing the remaining sulfur dioxide
problems will require additional time to
complete.
In a few areas, the 1987 date for
attaining the ozone and carbon monoxide
standard will not be achievable. The Los
Angeles smog problem will require more
time and new technology before it is
solved.
Failure to attain the standards carries
with it the threat of construction bans and
funding sanctions provided by the Clean
Air Act. These are hardly appropriate
responses in cases where there are not
feasible solutions to the problem. The
dates must be changed if the program is
to be made credible. Reasonable time
must be provided for planning and
implementation.
Recognizing the special problems faced
by the non-ferrous smelting industry.
Congress provided for deferral of control
requirements until 1988 where significant
adverse economic impacts were
anticipated. Several smelters continue to
face severe economic problems and will
be forced to close in 1988 under the
current statute. Such closures will cause
major unemployment in affected areas
where smelters are frequently the only
major employer and will force further
reliance on foreign sources of copper and
smelting capacity.
STATE
IMPLEMENTATION PLANS
The Clean Air Act requires the States to
incorporate emission limitations for tens
of thousands of stationary sources in their
State implementation plans. These
emission limits and any subsequent
changes to them or to compliance
schedules must be reviewed and
approved by EPA before they can take
effect. In addition, EPA must review and
approve State designations of attainment
status and subsequent changes to them.
This approval and revision process
requires the annual submission by the
States of literally thousands of individual
actions to EPA and the processing of
hundreds of Federal Register auctions.
Experience has shown the duplicative
Federal review of many State actions
serves little purpose other than to divert
the skills of Federal and State
professionals from more productive work.
At the State level, implementation plan
revisions require notice and an
opportunity for public comment prior to
submission to EPA, where the process
must be repeated at the Federal level.
Even simple changes can take years
despite the fact that many are technical
amendments in which the public has little
interest. This is most clearly evidenced by
the fact that the overwhelming majority of
Federal proposals elicit no public
comments or, at most, a single comment
from the affected State or source.
The expected processing time for
Federal approval is more than 10 months
and includes two dozen separate review
steps to insure conformance with the
multitude of applicable Federal rules and
policies. Over one hundred Federal and
State employees are occupied full-time
processing this paper, not counting those
that are involved in the substantive
aspects of the rulemaking.
Because the Federal staff is always
behind in processing these State actions
— over one thousand have been in EPA
for more than a year — there has been little
opportunity for EPA to get involved early
in the State process. The resulting
second-guessing of State actions has
frequently contributed to poor
Federal/State relations and increased
tension between the two levels of
government.
In addition to requiring unnecessary
Federal approval of minor changes, the
Act imposes specific control requirements
on the States and threatens costly and
disruptive sanctions if they are not
adopted. For example, the Act requires 29
States to enact and implement automobile
inspection and maintenance programs. In
many cases these programs are not
necessary to attain the standards, and
would do little more than accelerate the
attainment date by one or two years.
The States were not given adequate
time to evaluate and adopt this difficult
program, but instead were forced into
precipitous action under the threat of
prohibitions on economic growth and the
loss of critical transportation funding. As
a result, the opportunity for a potentially
beneficial environmental program may
have been lost. States have adopted
hurriedly designed programs and have
had to require participation without
adequate time to inform the public of the
potential benefits. In some cases, costly
facilities have been constructed or
contracted for and those States and
municipalities face the prospect of
spending millions on poorly designed
programs with little chance for public
acceptance and success.
Similarly, millions of Federal dollars
have been spent to satisfy the
transportation control requirements of the
statute despite the fact that in many areas
these programs hold little promise for
significant air quality improvement.
The Federal government cannot
effectively mandate the uniform adoption
of programs such as inspection and
maintenance or transportation controls.
These programs must be considered and
adopted on their merits after adequate
public involvement and consideration of
local political realities.
NEW
SOURCE REVIEW
All major new sources and
modifications to existing sources locating
in either clean or dirty air areas must
obtain preconstruction permits. In clean
air areas the prevention of significant
deterioration program establishes limits
on the air quality impact of industrial
growth. In nonattainment areas, new
sources must contribute to or be
consistent with State plans for reducing
current levels of emissions. In both cases,
sources must meet specified technology
requirements.
Visitors can see for miles in this
canyon/and in southeastern Utah where
the San Juan River carves a meandering
course.
EPAJOURNAL
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Each year about 500 large sources
locating in clean (prevention of significant
deterioration) areas must obtain a Federal
permit before they can construct. Some
of these are modifications to existing
factories which would result in increased
emissions while others are totally new
facilities such as new power plants or
manufacturing facilities. In addition,
hundreds of sources locating or
expanding in areas where the standards
are not being met require Federally
mandated State issued permits. In many
cases sources are required to obtain both
permits.
Unfortunately, the permit requirements
in prevention of significant deterioration
and nonattainment areas are different,
the criteria for deciding whether a source
needs a permit are different and the
processes and decision criteria are
different. This complex web of new
source review requirements is
disproportionately burdensome when
compared to the limited environmental
benefit achieved by a number of the
provisions.
Under the current system,
modifications resulting in even very small
increases of some pollutants (as little as a
few pounds per year) can force an
existing source to obtain a prevention of
significant deterioration permit with
attendant delays and costs while a
completely new source emitting 240 tons
per year of the same pollutant would not
require review. In some cases, sources
can avoid new source review by offsetting
emission increases associated with
modifications with decreases in other
parts of the plant, but could still be
required to meet the new source
performance standard where such
offsetting is not recognized
AIR QUALITY
ASSESSMENTS
In clean air areas, industries frequently
must delay siting decisions for more than
a year while they conduct ambient
monitoring studies costing hundreds of
thousands of dollars. The data collected
must be submitted to the permitting
agency but serves no real purpose in the
permit decision.
Industries and other pollution sources
must show that they will neither
individually nor in combination with all
other sources in their area of influence
exceed applicable increments and
ambient standards. Frequently, other
sources in the area will not have been
issued permits and there will be no
current inventory at either the State or
Federal level on which to rely. In one
case, a source seeking a permit was
forced to conduct a census of more than
100 separate sources in the vicinity of its
plant just to identify candidates which
might be affecting air quality. That was
only the beginning of the problem since
the source then had to try to evaluate the
cumulative effects of these sources on
the short-term prevention of significant
deterioration increment — effects which
are a function of changing operating
characteristics and weather conditions -
a virtually impossible task.
TECHNOLOGY
REQUIREMENTS
Despite uniform national rules
prescribing best available control
technology for major new sources, permit
applicants must subject their proposals to
a case-by-case review of alternative
control technology, costs and energy
impacts. Such demonstrations may cost
tens of thousands of dollars to prepare
and can result in months of uncertainty
and delay as various government
reviewing officials redefine control
requirements. Such reviews have
accomplished only minimal reductions
beyond those required by the new source
performance standards and have not
been found to have any environmental
significiance.
In nonattainment areas the problem of
case-by-case technology reviews is even
SEPTEMBER/OCTOBER 1981
-------
Plumes from an old steel company quenching tower.
worse. Sources must identify the most
stringent requirement imposed on similar
sources in any other State or local
jurisdiction and must demonstrate that
they meet an equivalent level or that it is
unreasonable for them to do so. States
are required to make case-by-case
determinations to this effect prior to
issuing permits despite the fact that it is
virtually impossible for EPA to collect,
evaluate, and disseminate the necessary
information for their use.
A recent survey of permits conducted
by EPA indicates that case-by-case best
available control technology
determinations reduced emissions from
214 permitted sources by only 15%
beyond that which would otherwise have
been accomplished by relying on
applicable new source performance
standards. This difference represented
less than 1 % of national emissions of
sulfur oxides and less than . 1 % of
national industrial emissions of particulate
matter.
PERMIT
DELAY
The "average" Prevention of Significant
Deterioration permit takes nine months to
process and approve in addition to the
many months or even years required to
prepare the application and conduct
required monitoring. In a number of
cases, the review has taken years as the
applicant and the government debated
modefing results and case-by-case
technology determinations. Such delays
cost sources millions of dollars as inflation
increases the cost of construction and the
use of investment capital is delayed. In
virtually all cases where the applicant
has the necessary patience, the permit
ultimately will be issued with little
substantive change in environmental
impact. High cost — little or no benefit.
In summary, the new source review
provisions of the statute as interpreted by
the courts are so complex that they are
unworkable. Many aspects of them
contribute to delay and uncertainty but do
little for the environment. Simplification is
essential and can be accomplished while
retaining effective protection of the
standards and air quality in national parks
and by insuring that all new sources are
designed to incorporate best available
control technology.
UNNECESSARY
COSTS
The statutory automobile emission
limitations are more stringent than
necessary to assure that the ambient air
quality standards for carbon monoxide
and nitrogen dioxide are attained in
virtually every area of the country.
Automotive emission controls are
estimated by EPA to add more than $300
to the price of a new car (the
manufacturers believe them to add more
than $700). The cost to make the last step
from the 1980 standards to the 1981
standards cost more than $100 per car
(the manufacturers believe this to be as
much as $300 per car).
Uncontrolled cars in the 1960's emitted
more than 80 grams per mile of carbon
monoxide and more than 4 grams per mile
of nitrogen dioxide. The average car on
the road in 1981 emits about 48 grams
per mile of carbon monoxide and about 3
grams per mile of nitrogen dioxide. As
new, cleaner cars are phased in and old,
dirtier cars phased out of the fleet,
emissions will continue to decline.
Automobile limits of 7.0 grams per mile
carbon monoxide and 2.0 grams per mile
nitrogen dioxide will result in reduced
emissions when compared to current
levels. By 1990 average in-use emissions
of carbon monoxide will be reduced by
about 50% from today's levels and of
nitrogen dioxide by about 25%. These
alternative limits would ultimately save
consumers over $1 billion per year.
The average cost of reducing carbon
monoxide emissions at the 7.0 grams per
mile standard is $19 per ton while the
incremental cost between the 7.0 grams
per mile and the 3.4 grams per mile
standard is $89 per ton. Similarly the
EPA JOURNAL
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average cost of nitrogen dioxide emission
reduction at the 2.0 grams per mile
standard is $57 per ton while the
incremental cost between 2.0 grams per
mile and 1.0 gram per mile is $512 per ton.
These are significant changes in cost-
effectiveness which should not be
imposed, given the limited air quality
problem.
The current statutory requirement that
all 1984 cars be able to meet the emission
limit for carbon monoxide when operated
at high altitude would impose hundreds of
millions of dollars in additional costs and
is not necessary to attain the ambient
standards in high altitude areas.
The current approach of certifying
individual prototypes to meet emission
limits served a useful purpose when the
technology was developing and changing
frequently. This is no longer the case.
Manufacturers are now using control
systems which have already been shown
to meet the standards and in the future
the certification process will contribute
little to air quality improvement.
The hundreds of millions of dollars
now spent certifying prototype cars could
be better spent on insuring that cars
continue to perform while in use.
The current requirement that every car
meet the same emission limit constrains
the manufacturers, limits consumer
choices and results in increased costs. A
change which would permit
manufacturers to average emissions
across several models would provide the
same level of environmental protection at
a lower cost.
The 1977 Amendments require that all
fossil-fuel-fired combustion sources
employ scrubbers or other technology to
obtain a specified percentage reduction in
sulfur oxide emissions. This requirement
applies to both high and low sulfur fuels
and was designed to achieve objectives
other than environmental protection.
This provision will increase costs to
consumers in 1985 by $3 billion per year
more than they would have paid if plants
were simply to meet the emission limit
established by the original new source
performance standard for power plants.
Stack gas scrubbers are more cost-
effective when used on high sulfur coals.
Because the standard wil! require new
plants to scrub low-sulfur coal, marginal
costs of removal will exceed $1,000 per
ton of sulfur dioxide. A ton of sulfur
dioxide emissions could be reduced by
scrubbing high-sulfur coal for less than
one-half that cost.
Fears that western low-sulfur coal will
displace eastern coal and cause
widespread unemployment are unfounded.
Available evidence suggests that rail rates
will preclude such long distance transport
and that growth in coal demand will insure
continued employment opportunities for
high-sulfur coal miners.
The country cannot afford to increase
its electric bill by billions of dollars without
obtaining any environmental benefit.
There are cheaper and more efficient
ways to achieve reductions in sulfur
dioxide emissions than the mandatory
percent reduction.
INEFFECTIVE
PROVISIONS
Over the past ten years only four
hazardous pollutants have been regulated
under the Clean Air Act (beryllium,
mercury, asbestos, and vinyl chloride).
Three others have been listed but
standards have not been promulgated
(arsenic, benzene, and radionuclides).
Air emissions are the largest source of
environmental contamination of the
twenty highest priority chemicals which
have been identified by EPA. A number of
pollutants have been identified as
potentially hazardous and candidates for
regulation, but decisions on the
appropriateness of such regulations have
been impeded by the structure of the
current statute.
No provisions for comparing the degree
of risk to the cost of control are provided
in the current statute. Given the fact that
no absolutely safe level can be identified
for suspected carcinogens and some
other toxicants, it is not possible to
establish the "no risk" level called for by
the statute. As a result, decision-making
is hampered and little progress has been
made to establish and implement a policy
for dealing with ambient exposures to
these compounds.
While attainment of the ambient
standards is accomplished through the
state implementation plan process where
the reasonableness and cost of control
can be considered, no such buffer exists
for the emission limits established for
sources of hazardous air pollutants.
Clarifying language is necessary if
decision-making on these pollutants is to
proceed and regulations eliminating
unreasonable public health risks are to be
implemented.
New, more effective and less costly
technology is essential to attain and
maintain ambient standards and provide
for continued economic growth.
Technology-based standards (newsource
performance standards) have the
potential to discourage innovation by
making it easy to comply using the known
technologies on which the standards
were based.
Despite provisions in the law to permit
waivers from new source standards for
innovative technology, few such waivers
have been granted. This is in part because
the current statute does not provide
adequate time for sources to amortize
control equipment investments.
Air pollution does not respect political
boundaries. Asa result, industrial
development in one State can create
attainment problems in another. This is
particularly apparent in major river valleys
where industry concentrates and which
frequently form the boundaries between
States.
Under the current statute, States can
request relief by petitioning EPA. EPA is
required to hold hearings and respond to
the petition, but is given virtually no
guidance as to the nature and magnitude
of the problems for which relief is
appropriate or the factors to be
considered in specifying relief. Further, it
is unclear what burden petitioning States
should bear in demonstrating problems or
in contributing to their solution.
As a result of the statute's ambiguity,
States have been unable to obtain relief
under this section and petitions have
generated little more than hearings and
paperwork.
We have not attempted to describe in
every detail the changes in the Clean Air
Act that the Administration considers
necessary or desireable. But some
changes are needed, and the
Administration proposals are worthy of
serious consideration by the Congress
and by the public.
As it is written now, the Clean Air Act
has in some instances actually slowed our
progress toward cleaner air. Many of the
problems are procedural. Uncertainty and
delay have inhibited business decision-
making. We have to eliminate or modify
requirements that simply raise obstacles
while producing little or no improvement
in the Nation's air quality. These
obstacles adversely affect productivity.
They adversely affect employment. And
they adversely affect the public health.
Our first concern is the well-being of
our citizens and the generations to come.
That must also be the priority concern in
building a more efficient, more effective
air pollution control program in this
country. D
SEPTEMBER/OCTOBER 1981
-------
Construction under way on new wastewater treatment plant facilities.
Cutting Construction Grant Red Tape
EPA is considering a major cutback in
red tape for compliance with Federal
requirements for construction of
municipal waste water treatment plants.
EPA Deputy Administrator John W.
Hernandez explained that the Agency's
new goals include giving "States and
local government more responsibility in
determining when and how a treatment
plant is built." He added that "less
paperwork and red tape in complying with
Federal requirements will also reduce
costs for the taxpayers."
He said that EPA is reviewing four
major factors in the control regulations:
Determining which construction grant
provisions are required by the Clean
Water Act and therefore cannot now be
altered;
Deciding which regulations should be
retained because they are the minimum
necessary requirements;
Determining which provisions
are necessary for guidance, but not as
regulatory requirements;
Indentifying existing regulations which
are unnecessary or not needed for Federal
guidance.
"Wherever guidance is desired by a
State or municipal agency, EPA will work
to help develop such materials," Dr.
Hernandez said. "In any case, the local
and State agencies will have discretion on
how to reach the pollution control goal
line. We'll only suggest the possible
plays."
He noted that the proposed regulatory
reform could result in faster processing of
Federal grants and significant savings in
direct construction costs for local
communities.
Hernandez said that comments from
citizens and officials is invited on this
proposed cutting of red tape. The formal
process of changing the construction
grant regulations is expected to begin in
November. Q
1>
EPA JOURNAL
-------
A
Report
Pennsylvania
-------
New Perspectives
on the
Environment
By U.S. Sen. John Heinz
of Pennsylvania
The President's regulatory reform
program will have positive and far-
reaching implications for the environment
in Pennsylvania and all other States.
Regulatory reform, one of the four
elements of the President's Economic
Recovery Program, is being spurred by an
Executive Order mandating what many of
us have been trying for years to
accomplish legislatively: attaining
regulatory goals in the most cost-effective
manner.
To conduct the painstaking review of
all existing regulations to weed out or
modify those that are duplicative,
contradictory, or needlessly burdensome,
the President has appointed a Task Force
on Regulatory Relief chaired by Vice
President Bush.
One of the Task Force's first actions
was to extend the "bubble policy" under
the Clean Air Act so that industrial plants
in non-attainment areas like Pittsburgh
can qualify. This allows companies in
such areas the flexibility to meet
regulatory goals in the most cost-effective
manner, while nor jeopardizing
environmental quality ... in the long run,
the poiicy may actually enhance quality
because the bubble policy removes the
most serious objections to environmental
laws — the costs they impose on
workers, consumers, and producers alike.
The process going on in Washington
amounts to the reexamination of all the
goals we've set for ourselves — all
laudable in themselves — and the
establishment of priorities in the
knowledge that we don't have the
resources to do everything at once. The
process is healthy, it's long overdue, and 1
don't believe it will mean sacrificing the
environment. It will mean trying new
approaches, because some of the old
ones haven't worked or have had
unintended consequences for economic
growth and employment.
Take the area of environmental
regulation, for example. The goals of a
healthy, clean, and aesthetically pleasing
environment have, over the past decade,
been translated into reams of regulations
and dozens of laws . . . like the National
Environmental Policy Act, the Federal
Water Pollution Control Act, . . . the
Clean Air Act, the Safe Drinking Water
Act, and the Noise Control Act.
These laws and regulations reflect
value judgments based on political as well
as public health considerations: they
reflect the determination by our society
that the levels of air and water pollution,
noise, and hazardous substances
produced by industry must be controlled
and reduced.
The effect of these laws and
regulations has been on balance, positive,
as environmental quality has improved
and the external costs of pollution have
been reduced. But some provisions of
these laws have, in certain
circumstances, hurt economic
development.
Moreover, an army of technocrats and
lawyers has been recruited to write,
interpret, and litigate the laws and
regulations. All too often, the resultant
technocracy has become a nightmare for
the state and local governments, the
businesses, and private citizens alike.
Rather than incentives for cleaning up
the environment, the current system
seems to produce mostly incentives for
delays, for litigation, and for added costs.
The result has been a counter-productive
adversarial relationship between business
and government, so that the interests of
neither are served. And, as a direct result
of this adversarial relationship, both labor
and business seek major amendments to
the Clean Air Act.
A significant problem is that our current
system of environmental regulations
ignores the basic strengths of the
American enterprise system:
decentralized decision-making and
motivation by economic self-interest.
Rather than simply coercing industry to
meet detailed and costly regulations, we
ought to make it in their economic self-
interest to attain certain goals — and then
let the private sector do what it does best:
12
EPAJOURNAL
-------
find the most efficient means of attaining
its objectives.
As an example of steering toward
providing incentives rather than only
imposing regulations, I have introduced
legislation, namely, S. 169, providing
expanded tax incentives for pollution
control. These tax incentives could be a
significant first step toward re-ordering
our current regulatory maze towards
economic incentives.
In short, I believe that regulatory reform
does not have to involve a rollback of
standards. Instead, we can often achieve
our objectives differently. In another
case, we may decide to accept a delay in
attaining the standards so that they do
not have so great an adverse economic
impact.
A case in point on the latter is a bill I
have pushed in particular, growing out of
my interest as Chairman of the Senate
Steel Caucus. The so-called "steel
stretchout bill" amends the Clean Air Act
but doesn't lower or revise the standards
themselves. Rather, it simply allows
individual steel companies to extend
compliance deadlines up to three years, if
they can demonstrate that they will use
resultant savings to modernize existing
steelmaking facilities. The effect of the bill
should be to preserve jobs and allow us to
compete better with foreign producers
. . . without sacrificing our environment.
In other words, there are responsible
regulatory reform approaches now
underway with the common objective of
ensuring that laudable goals — such as
the current environmental goals
Americans agree are socially desirable
and necessary — are not attained at the
unnecessary expense of economic
growth.
Let me caution you against two traps:
what I call the "so am I" and the "either
or."
The "so am I" trap is simple. Not every
reform proposed will be benign or
environmentally well-intentioned.
The "either or" trap would have us
believe that we cannot have both
environmental quality and economic
growth.
We cannot afford to fall in the "either-
or" trap. In my judgment, returning to the
days of unrestrained industrial pollution
isn't a credible alternative. But neither is
remaining in this present day of arbitrary
and inflexible regulation.
We have to balance both the economic
and environmental considerations.
Americans need jobs and housing as well
as a safe and unspoiled environment.
And, as I hope my modest examples
demonstrate, we can achieve this
balance.
It will be all the more attainable for us
with a healthy and strong economy.
And it is here that the President's
economic program is undeniably on the
right track. We do not need and we
cannot afford business as usual —
especially if we care about both the
environment and jobs.
Since 1973, we've had a major fall-off
in the productivity growth rate, and we've
had virtually no real economic growth.
What has been growing . . . partly
because of the Federal Government's
approach to regulation ... is inflation,
interest rates, and unemployment, . . .
and the size and cost of government. . .
beyond the willingness of people to pay
that cost.
As a result, the Federal Government is
borrowing vast amounts of money . . .
so much, and with such success, that the
private sector has had trouble getting the
money it needs to invest and be
competitive and create jobs.
We should all be deeply concerned that
over the past decade, most people have
come to accept federal deficits as a way
of life. The fact that our national debt will
break $1 trillion with this year's estimated
$75 billion deficit doesn't mean much to
most people. But the problem takes on
meaning when you realize that in 1981 the
interest on the national debt will be $90.6
billion — the third largest single
expenditure in our whole budget!
We simply must do something to rein in
federal spending that's galloping out of
control. That's why the President is rjght
in restraining the growth of the federal
budget, emphasizing tax incentives for
savings and investment, and urging
regulatory reform.
I know very well that people differ over
what should be cut back, and some
shifts will be made — I hope especially the
ones I propose, but the answer is that
virtually every item will have to experience
some shrinkage from projected levels.
I believe that reducing the budget
already has had some positive
consequences.
First, it has forced us to reevaluate and
justify all Federal programs, as has
happened at Interior and at EPA.
Second, it has spurred us to look for
ways to do more with less. With my bill,
S. 169, for example, we are exploring the
economic incentive approach to
environmental goals.
Third, it has forced us in Congress to
determine the truly fundamental needs of
our regions and act on those needs, while
still maintaining the integrity of our new
budget.
We must restore the proper relationship
between the public and private sectors
... or else face economic, and ultimately,
social ruin.
In the end, there can be no choice
between a healthy environment and a
healthy economy. The future of the
environmental movement is inextricably
tied to the health of the economy.
Industry needs profits to clean itself up.
And my hunch is that if a deep depression
hit us, the political pressures on
government to sacrifice environmental
standards would be tremendous. Thus,
it's in the best interests of
environmentalists to work not against
business, but together with business to
find ways to balance environmental and
economic issues. D
SEPTEMBER/OCTOBER 1981
13
-------
For The
By Cliff Jones
Secretary, Pennsylvania Department
of Environmental Resources
it of All
The Pennsylvania Department of
Environmental Resources recently
celebrated a "Decade of Service." While
during its first 10 years the department
has taken giant strides toward alleviating
many environmental problems, there are
many challenges still to be met as we
pursue our goal of assuring the
commonwealth's residents of clean air,
pure water and uncontaminated land.
Many of Pennsylvania's water systems
are in need of repairs and improvements,
a condition highlighted by the recent
drought. Beset by old age and lack of
funding for maintenance and
improvements, the condition of many of
these facilities casts doubt on whether
the commonwealth will continue to have
enough fresh water for its many
domestic, industrial, agricultural and
recreational needs.
Before recessing for its summer
vacation, the General Assembly passed a
legislative packet calling for establishment
of a Water Resources Management Code
for a referendum on a $300 million loan
program to provide financial assistance
for the restoration of aging, ailing water
supply systems across the state.
If voters approve the referendum on
the pay-back loan program, funds
would be used to rehabilitate water
supply systems plagued with supply,
storage and distribution problems; to
rehabilitate unsafe water supply dams; for
flood control projects; and for port
facilities,
Water-borne disease outbreaks cost
Pennsylvanians more than $16 million
annually. Many of these outbreaks can be
attibuted to crumbling water distribution
systems and to uncovered reservoirs that
expose treated water to possible
contamination. Recent studies show that
many water distribution systems are too
small to store the amounts of water
needed to properly serve their consumers.
Pennsylvania has 2,400 community
water supply systems. Of these, 1,800
serve fewer than 1,000 people, and 540
serve between 1,000 and 15,000 people.
More than 100 report annual revenues of
less than $5,000. At least 360 systems
have deficiencies in their distribution
systems, 255 need filtration plants, 62
have filtration plant deficiencies, 278 have
insufficient yields, 240 have insufficient
storage capacity, 164 have difficulty
meeting drinking water bacteriological,
chemical and turbidity standards, 200
have uncovered reservoirs, 300 have
inadequate sources and many lose up to
50 percent of their treated water through
leaking pipes each day.
State and federal surveys also revealed
93 unsafe water supply dams in the state.
Public safety is threatened by dams with
spillways so inadequate that water
"overtops" the dams after heavy rainfalls.
The department now has a
comprehensive statewide Dam Safety
Program.
Pennsylvania is blessed with more than
50,000 miles of streams. Its citizens rely
on fresh water for their everyday needs,
for recreation, for electric power and to
produce a variety of agricultural and
industrial products.
Helping to keep Pennsylvania's
waterways clean are some 550 municipal
waste-water treatment (sewage) plants,
about 1,200 non-municipal plants which
handle domestic sewage from trailer
parks, schools and similar areas and 2,800
industrial waste treatment facilities. The
Department of Environmental Resources
issues permits to all these and
applications for about 200 additional
industrial waste treatment permits are
being processed.
When the Department of
Environmental Resources was activated
Jan. 19, 1971, only some 1,300 industrial
waste treatment facilities and 650
municipal and non-municipal sewage
treatment plants were operating. New
and upgraded treatment facilities, the
department's active erosion and
sedimentation control program,
completion of 364 stream improvement
projects and 195 acid mine drainage
projects all contributed to the state's
realization of a net gain of 981 miles of
clean streams during the past decade.
Today, 10,110 miles, or 78 percent of
Pennsylvania's nearly 13,000 miles of
major waterways meet water quality
criteria. We keep check on the water
quality through hundreds of chemical and
biological monitoring stations on major
river basins throughout the state. We also
certify 5,920 sewage treatment plant
operators, 3,790 waterworks operators
and 1,133 sewage enforcement officers.
However, the department cannot rest
on its laurels where water is concerned.
While coal and limestone deposits make
the commonwealth a leading mineral
producer, the recent energy squeeze and
the national deregulation of oil and gas
prices have attracted many new oil and
gas prospectors to the state.
Oil and Gas
Ten years ago we issued 2,500 permits
for oil and/or gas wells. The department
now is issuing 10,000 to 12,000 such
permits a year and anticipates that the
number will be increased to between
15,000 and 20,000 a year within the next
two years.
Because of the increased activity, the
commonwealth is witnessing increased
problems of soil erosion and
sedimentation, improper disposal of brine
and process waters, and oil spills. An Oil
and Gas Environmental Advisory
Committee was formed recently to help
the department get input into the drafting
of needed law and regulation changes
and to step up the cooperative training
Canadian geese feed in a Philadelphia park.
EPA JOURNAL
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program. The department also is seeking
increased monetary resources to beef up
its inspection and enforcement program.
Fishing, boating and other water sports
are among the many attractions which
bring thousands each year to the nearly 2
million acres of forest land and 117 state
park areas managed by the department.
We used more than $25 million to acquire,
develop, rehabilitate and improve
recreational facilities during the past
decade when 15 new state parks and
expanded facilities at 21 others were
dedicated, 44 State Forest Natural Areas
and 15 State Forest Wild Areas were
designated, a Pennsylvania Scenic Rivers
System was authorized and two
components were named to the systems,
368 million park visits were recorded, a
Coastal Zone Management Program was
developed to protect the Delaware
Estuary and 40 miles of Lake Erie
shoreline and a biological control program
was instituted to battle the gypsy moth.
Much yet is to be done to keep these
recreational lands and the lands on which
people live and work free from pollution,
particularly that caused by the improper
handling of toxic and hazardous wastes.
July 7, 1980, was a "red letter" day for
the department. That is when the Gov.
Dick Thornburgh signed Act 97,
Pennsylvania's new Solid Waste
Management Act, which provides for
state and local cooperation in establishing
a comprehensive program to properly
manage all solid wastes within the
commonwealth.
The act places special emphasis on the
proper "cradle-to-grave" handling of
hazardous wastes. It defines such wastes
as those which could cause severe illness
or death or which pose substantial threats
to the environment when improperly
SEPTEMBER/OCTOBER 198'
-------
stored, transported or disposed. Wastes
which could contaminate surface and
underground waters, explode and burn,
pollute the air, contaminate food and
poison by direct contact are included.
Pennsylvania is the fourth largest
hazardous waste generating state in the
nation. While al! hazardous wastes are
not of industrial origin, the department
estimates 4 million tons of the 26 million
tons of industrial wastes generated
annually within the commonwealth are
hazardous. These wastes are produced by
as many as 3,000 sources. Pennsylvania
has some 2,000 transporters of hazardous
wastes, about 2,000 unpermitted
hazardous waste storage areas and some
265 hazardous waste disposal sites.
Solid Waste
Pennsylvania's new Solid Waste
Management Act was only a week old
when, on July 15, 1980, the state's
Environmental Quality Board adopted
rules and regulations detailing the
"Criteria, Identification and Listing of
Hazardous Waste." On Nov. 18, 1980,
the environmental board adopted
regulations governing the transportation,
storage, treatment and disposal of
hazardous wastes, setting requirements
for hazardous waste activities and
defining more than 100 hazardous waste-
related words and phrases. The
Department of Environmental Resources
instituted its hazardous waste manifests,
which trace such wastes from point of
generation to point of disposal, on
Nov. 29, 1980.
Recently we initiated one of the most
important phases of its stepped-up solid
waste management program — the
search for adequate disposal sites.
Everyone enjoys the modern life-style
which helps create wastes, many of them
hazardous and/or toxic, but no one wants
a waste disposal site in his neighborhood.
This anti-disposal sentiment is most vocal
on the issue of locating sites for
hazardous waste treatment and disposal
facilities.
Aided by a 14-member Hazardous
Waste Facilities Planning Advisory
Committee, mandated by the act, the
department had drafted proposed
"Preliminary Environmental, Social and
Economic Criteria and Standards for
Siting Hazardous Waste Treatment and
Disposal Facilities." These proposed
criteria define environmental, social and
economic factors which must be
considered to assess the geologic,
hydrologic, soils, air and water quality,
natural, scenic, aesthetic and economic
impacts of locating each hazardous waste
facility. They also define how the effects
of each facility should be assessed in
relation to transportation, population,
land use, ownership, and proximity and
possible compensation to the host
municipality.
The proposed criteria were published in
the Pennsylvania Bulletin, the
commonwealth's legal publication
comparable to the Federal Register, for
public comment. They also were the
subject of public meetings and of press
briefings. Once all the written and oral
comments are digested, the proposed
criteria will be amended to reflect this
public input. The criteria then will be
made part of the Pennsylvania Hazardous
Waste Facilities Plan, which must be
adopted by the Environmental Quality
Board by July 1982, and will be applied to
all prospective and existing hazardous
waste treatment and disposal facilities
which must be permitted under the act.
While the department looks for
adequate disposal sites for wastes which
cannot be recycled or reused, it also
recognizes that "one man's waste can be
another man's raw material." Therefore,
it not only encourages recycling, but also
offers grants for unusual resource
recovery projects under the state's 1974
Solid Waste Resource Recovery
Development Act. Several on-going
projects have been funded and
applications now are being sought for a
special $535,000 grant to be used for a
municipal waste-to energy project
demonstrating the burning of municipal
wastes in a modular, or pre-packaged,
incineration system with the resulting
energy being sold to facilities owned and
operated by private enterprise.
Late last year, the Pennsylvania
Chamber of Commerce launched PWIX
- the Pennsylvania Waste Information
Exchange — through which both
hazardous and non-hazardous industrial
wastes are transferred from generators to
potential users. This saves the generator
high treatment and disposal expenses and
enables him to recoup a percentage of his
original investment while enabling the
user to reduce capital expenditures for
raw materials. At the same time, the
department is promoting the use of
treated sewage sludge as a fertilizer and
to reclaim strip-mined land.
Mining
Solid wastes and sewage sludge are
not the only threats to the
commonwealth's precious land and
water. Mining can have a devasting effect
on these. The state has spent millions
restoring land scarred by strip mine pits
and culm banks and treating water
polluted by acid mine drainage. The
department now wants to achieve
"primacy" under the federal Surface
Mining Control and Reclamation Act so
that it can implement the
commonwealth's coal mining acts as
amended in October 1980.
Because the necessary amendments to
the state's coal mining acts were not
signed prior to the fail 1980 deadline for
application for such primacy, the
department made a preliminary
application.
EPAJOURNAL
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Heading for home after a day's work in
the fields, an Amish farmer gives
directions to his team of seven mules.
Commonwealth Court issued an
injunction, at the request of the state's
coal mining interests, stopping the
department from making final primacy
application and/or implementing
regulations adopted by the Environmental
Quality Board as part of the primacy
package. This injunction will expire under
its own terms on Nov. 26, 1981, and could
be lifted earlier by a Commonwealth
Court decision.
Once granted primacy, the department
plans to implement a set of mine-related
regulations that provide for maximum
environmental protection while being
least burdensome to the industry. The
department also must develop a bonding
system which keeps rates reasonable
while assuring adequate funds for
completing reclamation of mined areas
where operators can't, or don't, properly
reclaim the land. We plan to continue
offering mine subsidence insurance
against structural damage to buildings
constructed above or near coal and clay
mines.
At the same time the department will
continue to try to make mines safer for
miners. We have an active mine safety
program which includes a statewide
program of pre-employment orientation
training and retraining for coal and non-
coal surface and deep miners, periodic
safety inspections, an emergency medical
training program for coal miners, a mine
rescue team program, an emergency
response procedure for underground
mining accidents and two mine rescue
emergency vehicles with sophisticated
equipment.
While miners often wear protective
breathing apparatus, most
Pennsylvanians must breathe "raw" air.
The department constantly keeps a check
on the quality of this air through a
concentrated ambient air surveillance
program which encompasses a network
whose 97 stations sample total suspended
particulates every six days; the
Commonwealth of Pensylvania Air
Monitoring System (COPAMS), a
computer-controlled system of 17 remote
stations in major population areas where
sensing equipment measures a variety of
data related to air quality; and
Pennsylvania Air Quality Surveillance
System (PAQSS), 15 microprocessor-
controlled air sampling modules which
continuously measure sulfur dioxide and
ozone and record results on magnetic
tapes.
These systems have shown the
department that total suspended
particulates levels have been declining but
still remain a problem; sulfur dioxide
levels fluctuate but remain within
compliance standards; carbon monoxide
and nitrogen dioxide levels remain the
same and are not problems in
Pennsylvania; and ozone continues to
exceed the standard and remains a
problem throughout the state despite
significant improvement in recent years.
Major amendments to the state's Air
Pollution Control Act gave the
department the authority to press for
specific emission limits by air contaminant
sources and more than 6,500 such
sources achieved compliance during the
past decade.
However, because air knows no state
boundaries, many sectors are unable to
meet national ambient air standards.
Pennsylvania has rigid regulations
governing sulfur dioxide emissions, but
sulfur dioxide-polluted air drifts into the
state from West Virginia, Ohio and other
upwind midwestern States. Pennsylvania
industries face increasingly heavier
regulations as long as this inequity in
emission controls exist. The department
would like to see equal air regulations
among all states in the air region.
Sulfur dioxide drifting into the state is
transformed into sulfate particulates
affecting the state's ability to comply with
national particulate standards,
endangering health and contributing to
acid rain.
Air, land and water are the basic
elements of life. They form a circle of
interdependence bound so tightly that
one cannot be changed without
disturbing the delicate balance in which
they all exist. Pennsylvania's General
Assembly recognized this
interdependence when it created the
Department of Natural Resources and
when it proposed and adopted an
Environmental Amendment which
became Article 1, Section 27, of the
Pennsylvania Constitution on May 18,
1971. The department's programs are
dedicated to carrying out the principles of
this amendment which states:
"The people have a right to clean air,
pure water, and to the preservation of the
natural, scenic, historic and esthetic
values of the environment.
Pennsylvania's natural resources are the
common property of all people, including
generations yet to come. As trustee of
these resources, the Commonwealth shall
conserve and maintain them for the
benefit of all people." n
SEPTEMBER/OCTOBER 1981
17
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A horse-drawn carriage at sunset in Pennsylvania's Amisn country.
EPAJOURNAL
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Pennsylvania's Environment
Its Assets and Problems
By Eleanor W. Winsor,
Executive Director
Pennsylvania Environmental Council, Inc.
A: its formation in iate 1969, the
Pennsylvania Environment Council,
Inc., perceived that Pennsylvania's
environmental problems would only be
solved if environmentalists worked
together and cooperated with government
and industry. Equally important, its
founders realized that the State legislature
and administrative agencies could act
before environmentalists in outlying
areas of the Commonwealth had any idea
what was happening. These grassroots
organizations needed a source of accurate
information rapidly so they could respond
accordingly.
The result was creation of the Council.
Since 1979 its membership has grown to
over 150 organizational members in
addition to individual and corporate
supporters. When developing its
positions on environmental issues, the
Council reviews available technical and
scientific information, talks with people
with as many viewpoints as possible,
discusses the issues at board meetings,
and develops a stance. When dealing
with legislation, however, such a
methodical approach is not always
practical. Action must be fast.
"A blitz in time" was how the Delaware
Valley Agenda described the Council's
intensive six-day effort to prevent
passage of a bill to prevent the
Department of Environmental Resources
from enforcing Pennsylvania's
constitutional environmental amendment.
This amendment guarantees all citizens
the right to clean air and water and a
healthy environment. In September,
1980, the bill, introduced at the request of
the coal lobby, was set to pass until the
environmental grassroots effort
mobilized. The Council concentrated on
four areas: member groups, which could
contact their members to expand the
public response, the Council's individual
members, the media, and the Legislature.
Letters and telephone calls were used to
reach the maximum number of people.
When the dust had settled, the bill was
never called up for a vote, and it died in
the waning days of the Legislative
session.
Such action indicates how a public
interest organization can act effectively.
The day-to-day reality, however is not as
visible or exciting. Citizen involvement is
a slow, steady, methodical process
embracing these principles: Get the facts,
learn who the actors are, develop a
position, and work to see that it comes to
fruition. Many times goals are only partly
realized. Resources are always limited for
non-profit groups, but enthusiasm is
never lacking.
Managing
Rich Resources
For those people who know
Pennsylvania, it's easy to see why. Rich in
historical heritage and natural resources,
Pennsylvania is the keystone of the
Atlantic Seaboard States and the
transitional area between the East and the
Midwest. While it has many points
of great beauty, including the historic
streets of Philadelphia, the rolling
farmlands of Lancaster County, the
meandering paths of the upper reaches of
the Susquehanna River, the Delaware
Water Gap, the canyon of Pine Creek,
shores of Lake Erie, white waters of the
Youghiogheny, and a myriad of other
beautiful spots, it is the resource base
that concerns her environmentalists
most. Air, water, forests, coal, and
agricultural lands — these are five
resources Pennsylvanians are still
struggling to handle in an environmentally
responsible manner. In some areas the
past decade has resulted in resource
management. In others, developments
have not been so fortunate, in the eyes of
environmentalists.
SEPTEMBER/OCTOBER 1981
19
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The 1970's saw an improvement in
Pennsylvania's air quality. There was still
plenty of room for additional cleanup, but
there was a steady change for the better.
Governor Dick Thornburgh, in his first
year in office, moved vigorously in the
courts to eliminate a major Pennsylvania
problem which is the transport of air
pollutants, particularly sulfur oxides, from
the Ohio Valley eastward into
Pennsylvania. This failed to solve the
problem, however, and the pollution
continues to migrate eastward unabated.
Acid rain increases with it, and for a wide
swath of Pennsylvania the acidity of the
rain is impacting fishing streams, lakes,
and forest productivity.
An inspection and maintenance program
for automobiles in certain heavily
industrialized areas has lapsed after the
Legislature almost unanimously voted to
ignore a court order and postpone using
State funds to finance an inspection and
maintenance program, despite efforts of
the Delaware Valley's Clean Air Council.
Saving
the Schuylkill
Pennsylvania's many clean streams are
matched by those which new pollution
sources are destroying. The Schuylkill
River changed over the past thirty years
from a mine silt laden disaster area to a
relatively clean resource, showing that
industrial and recreational users can
utilize the river compatibly. Strong
grassroots citizens support, led by the
Schuylkill River Greenways Association,
resulted in the Schuylkill being named the
first recreational river in the State's Wild
Scenic and Recreational River System.
In contrast, however, the Citizens
Advisory Council to the Department of
Environmental Resources reported in
April, 1981, that "water quality in
northwestern Pennsylvania . . . was being
severely degraded as a result of
production practices associated with oil
and gas development." The Department
issued 79 percent more drilling permits for
oil and gas in 1980 than in 1979.
Regulations for oil and gas activities are
limited, and water pollution is a major
problem.
Water quality as well as quantity is a
factor in Pennsylvania. The contrasting
nature of the State's different
geographical areas stands out clearly.
While the western part of the
commonwealth is deluged with rain, for
the past year and a half the eastern
portion has suffered from a drought.
Clearly, more effective water resource
management is catled for, and
Pennsylvanians are now reviewing what
the method shall be.
The third Pennsylvania resource, coal,
may have greater impact than any other
on air and water. Environmentalists see a
twofold problem here. The rush for
energy is resulting in more coal
operations. Enforcement of the State's
stringent surface mining standards is lax
and hampered by a court injunction
obtained by the coal industry prohibiting
the Department of Environmental
Resources and its Environmental Quality
Board from enforcing regulations which
the industry, the Department, and
environmentalists had spent over two
years working together to develop. The
impetus for delay in part came from a
belief by the industry that Federal
regulations would be relaxed.
Solid Waste Law
Revised
The highlight of 1980 for Pennsylvania
environmentalists was a complete
revision of the State solid waste
management law, which included major
provisions governing the storage,
disposal, and treatment of hazardous
wastes. This was the result of a strong
push by the Governor, the Legislative
leadership, the Department of
Environmental Resources, and
environmentalists. The challenge now is
to implement it — setting criteria for waste
disposal sites that protect the public,
developing a State plan for management
of such wastes, setting up permit,
inspection, and enforcement procedures,
and educating the public on how waste
streams can be reduced, the nature of the
wastes remaining, and how these can be
handled safely. Improper hazardous
waste management can jeopardize the
quality of other resources in the State.
Since November 19, 1980, when the
majority of regulations under the Federal
Resource Conservation and Recovery Act
went into effect, the State has seen an
increase in illegal disposal of hazardous
waste due to a lack of treatment and
disposal facilities..
Pennsylvania's backbone since its
founding has been agriculture. More than
many people realize, agriculture still remains
critical to a healthy Pennsylvania
economy. To many Pennsylvanians
nothing is lovelier than the rich farmlands
of so many counties, yet this irreplaceable
resource is being whittled away far too
rapidly. The Pennsylvania Farmers
Association points out that in the last
decade approximately 52,000 acres of
cropland have been lost annually to
urbanization. Losses from erosion add
substantially to that.
20
EPA JOURNAL
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A Pennsylvania
farm scene.
T2
Ironically, it was the industrialists who
came to the environmentalists in the
1970's, urging the adoption of consistent
environmental standards Nationwide so
that companies op-rating in one section
of the United States did not obtain an
unfair economic advantage, as a result of
laxer environmental standards. Coal,
steel, petroleum, and paper were but a
few of the industries the Pennsylvania
Environmental Council worked with to
push for the National standards.
In reviewing Pennsylvania's
environment one is always impressed by
how blessed Pennsylvanians are. There is
a temptation to say, "there is so much,
the loss of a little agricultural productivity
here, or stream mileage there, will not
matter." This is not the case. The loss of
a little here and a little there results in a
cumulative impact that can be
devastating. To counteract the
cumulative impacts of improper resource
use, which all of us in Pennsylvania
would pay for in the future through
scarcity, all of us must use the resources
available today wisely. The
environmentalist is a true conservative.
He or she wants to manage society's
assets in such a way that the resources
upon which the economy depends are
available for succeeding generations. This
is the same philosophy that guides a
board of directors of a company when it
declares dividends today, but retains
sufficient capital for a successful and
prosperous future for tomorrow. D
Although they are as diverse as the
Commonwealth in which they live,
Pennsylvania environmentalists are united
firmly in their concern that the 1980's can
result in the sacrifice of many of the
environmental gains of the 1970's.
Citizens of a State where special interests
have historically controlled the
governorship and the Legislature, they
are particularly concerned to see the
strong National movement to transfer the
setting of regulations and the
administration of those regulations
"back to the State." They perceive it as a
"divide and conquer" syndrome, with
State officials lacking the political support
to enforce the regulations.
SEPTEMBER/OCTOBER 1981
21
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Pittsburgh:
Yesterday
and Today
A letter to the Pittsburgh Gazette on June
10, 1814, recognized that "much of the
prosperity of Pittsburgh is owing to its
'Fires,' but complained that the evil of
smoke is "daily increasing and relief is
now universally called for." Despite this
early identification of the smoke problem,
the Pittsburgh skies were not cleansed of
this type of pollution until community
leaders mounted an effective campaign
after World War II.
Above: An old Pittsburgh cartoon post
card which joked about the smoke
pollution problem.
Right: This is Fifth Ave. in Pittsburgh on
Nov. 5, 1945, before the smoke control
campaign became effective.
Below: Darkness at noon. A Pittsburgh
scene before pollution controls helped
ease the smoke problems.
EPA JOURNAL
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An aerial view of modern Pittsburgh on a clear day. In the left foreground is the Three Rivers Sports Stadium. Rising behind the
riverfront point near ihe center of the photo is the Golden Triangle area with its looming skyscrapers.
SEPTEMBER/OCTOBER 1981
23
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You Have a Friend in Pennsylvania
Nicholas De Benedictis
Director, Office of Intergovernmental
Relations and Public Affairs.
EPA Region 3
The "You Have a Friend in Pennsylvania"
theme being advertised by the State
of Pennsylvania in its campaign to attract
tourists also symbolizes the improvement
in cooperative efforts in recent years
between EPA and the Pennsylvania
Department of Environmental Resources.
EPA will now be making even more
vigorous efforts to help improve the
already cordial relations it enjoys with
Pennsylvania.
Pennsylvania boasts the origins of
America's environmental rebirth. Here is
Pittsburgh, where the Nation's most
dramatic beginnings were made in
fighting air pollution ... by State and local
governments. Here also is Moraine State
Park, where abandoned mines are now
restored, acid flows stopped, and a
lovely, safe lake created. Moraine is one
of the Nation's pioneer mine reclamation
projects . . . again, the work of State and
local governments.
Early on, officials at EPA's Middle
Atlantic Region (Region 3) and at
Pennsylvania's Department of
Environmental Resources (DER)
recognized that environmental goals
could best be achieved through
cooperation, not confrontation.
EPA's new Administrator, Anne M.
Gorsuch, is making improved relations
between EPA and its State partners a top
national priority for the Agency.
Improving intergovernmental relations
has been one of our Region's top
priorities.
The Regional office has consolidated
the areas of intergovernmental relations
and public information. This organization
is called the Office of Intergovernmental
Relations and Public Affairs (OIRPA).
The major role of this office is to
facilitate communications and
cooperation between EPA and each one
of the States in the Region. In addition,
stepping on each other's toes has been
avoided partly because many groups have
been able to participate in advising EPA
and State officials responsible for making
specific environmental decisions.
This procedure has worked well,
particularly in our relations with
Pennsylvania. The office tracks the
programs of other Federal agencies in the
housing, health, and agricultural areas, to
make sure EPA/State environmental
programs are complementing and not
contradicting other national policies. The
EPA Congressional office also keeps in
close touch with Pennsylvania's
Senators and Congressmen, to respond
to their constituents' suggestions
concerning EPA and DER environmental
activities.
A Basin Commission Coordinator
maintains contact with the Federally-
sponsored river basin commissions which
are responsible for many important water
quality programs in the Commonwealth.
The Delaware, Susquehanna, and Ohio
River Basin Commissions are partners
with EPA and the Department of
Environmental Resources in ensuring that
Pennsylvanians have the use of clean
streams and rivers.
Important projects such as
environmental impact statements are
moved with greater ease because of
coordination by Region III. A recent
example is the Gettysburg environmental
impact statement which provides options
that permit the construction of needed
sewage facilities while still protecting the
unique environment of this historically
significant area. Another important area
of emphasis is public communication on
EPA projects. EPA's Public Affairs Office
works closely with the Department of
Environmental Resources' Public
Information Office to communicate with
the public about environmental matters,
particularly in issues concerning
hazardous wastes, and especially during
emergencies such as oil spills. The days of
EPA or the Department of Environmental
Resources trying to upstage each other
for a headline are gone.
The most notable example of this close
cooperation began in July 1979 during the
"Pittston Emergency" when toxic
chemicals began pouring from
abandoned coal mines into the
Susquehanna River in northeastern
Pennsylvania. While the technical experts
from DER and EPA worked on containing
the chemicals, a joint on-scene press
office was established to handle the
hundreds of daily press inquiries and calls
from concerned citizens.
Region 3's Public Affairs chief, George
Bochanski, believes that the information
provided to the media was made more
credible because of the cooperation
between EPA and the State agency. "We
avoided the possibility of incomplete or
conflicting new releases which would
have surely occurred otherwise," says
Bochanski. The State DER and EPA public
affairs personnel continued to work
together during the entire cleanup effort
which lasted more than a year.
Following the episode, Robert
Niehand, President of the Professional
News Media Association of Northeastern
Pennsylvania, cited the Pittston incident
as one in which State/Federal
cooperation provided the media with "a
clear, concise, and accurate account of
what was going on ... and that because
of this cooperation the news media, and
most importantly, the public which we all
serve came out the winners."
Perhaps the most innovative aspect of
OIRPA is the utilization of State program
officers who ensure that a single contact
point exists for State and iocal officials
to call with their problems or questions.
While EPA managers have worked closely
24
EPA JOURNAL
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with counterparts at the State level for
years, difficulties often arise when a
particular problem cuts across several
environmental program areas (air, water,
solid waste) or when State officials are
unsure of the right person at EPA to
contact on specific issues.
A program officer has been assigned to
each State in the Region. For
Pennsylvania, the program officer is
Richard Pastor. Although Pastor primarily
provides liaison with State officials, he
also keeps in touch with local officials,
public interest groups, state legislators,
citizens, and trade and environmental
organizations as the personal
representative of the Regional
Administrator.
One of the program officer's most
important activities is negotiating the
State/EPA Agreement with the
Commonwealth. This agreement provides
for joint Federal/State decision making
on important environmental priorities.
This is particularly important for those
programs where Federal enforcement
authority has been delegated to
Pennsylvania and where substantial
amounts of Federal funds are being
provided to help the State carry out
pollution control programs.
While the State/EPA Agreement is not
a panacea for all environmental problems,
it has eliminated much duplication of
effort and has set priorities for State and
Federal pollution cleanup efforts. It has
also aided Pennsylvania's own program
planning process. The Department of
Environmental Resources is a large
integrated agency responsible for all of
the Commonwealth's environmental
programs. The State/EPA Agreement
process has enabled DER officials to
A view from the steps of the Philadelphia
Museum of Art down the Benjamin
Franklin Parkway toward City Hall.
better manage pollution control
programs, particularly those that address
problems that cut across traditional
program boundaries.
The program officer also works with
municipal governments on sewage facility
construction grants, the issuance of
wastewater discharge permits, and the
location or cleanup of waste disposal
sites. These activities are highly
controversial local matters, even though
the decision-making authority many times
rests at the State and Federal levels.
One of Pastor's most time-consuming
jobs is coordinating activities that involve
joint State, local, and EPA action
bringing people together and chiefly
setting the stage for decision makers at all
levels of government to communicate.
Another task of the program officer is
that of reaching out to the general
public, environmental, and industrial
groups, and State legislators to seek their
input and inform them of EPA
activities. Pastor often attends public
meetings or addresses citizen groups
about important local issues. He also has
spoken to industrial trade organizations
concerning Federal programs that impact
their activities. Further, he has testified
before Pennsylvania legislative
committees to explain various Federal
laws and regulations. At all of these
meetings, he listens as well as talks, and
has often brought back valuable
information which helps EPA better serve
the citizens of Pennsylvania and improve
its programs.
The employees of EPA and the
Pennsylvania DER are working hard to
make sure their cooperative approach
works. There is too much at stake
for it not to. fj
SEPTEMBER/OCTOBER 1981
25
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The Selling of Waste
By William J. Marrazzo
Water Commissioner for Philadelphia
The City of Philadelphia is putting to
constructive use a by-product of its
wastewater treatment that once posed an
environmental problem along the Atlantic
coast.
The product is sludge, and at one time
the disposal of this unwanted substance
embroiled the city, the State of
Pennsylvania, the U.S. Environmental
Protection Agency and several other
organizations in protracted litigation.
Thanks to research and some creative
technology, the product is now not only
being used to help transform abandoned
strip mines into grazing lands, but it also
helps keep Philadelphia baseball parks
and golf courses green and is even
earning revenues marketed as a soil
conditioner called "Gardenlife." To date,
the city has sold an estimated quarter
million 40-pound bags of what it used to
haul, in cruder form, in barges out to sea
where it was dumped east of coastal
beaches.
The story of the waste conversion
program began in 1971 when Congress
passed the Marine Protection, Research,
and Sanctuaries Act, aimed at controlling
ocean dumping. Under its authority, EPA
required Philadelphia to move its sludge
dump site 36 miles farther out into the
Atlantic as an interim measure while the
city developed an alternative and more
hygienic methods of sludge disposal.
Some of Philadelphia's treated and
screened sludge is marketed in 40-pound
bags under the name of "Gardenlife. "
EPA further required Philadelphia under
the permit system to reduce the quantity
of barged sludge for ocean dumping by 50
percent before 1979, and totally stop
ocean dumping by December 31, 1980.
After a number of lawsuits involving
many parties, agreement was reached on
May 30, 1979, when they signed a
consent decree incorporating three major
provisions. First, the decree called for
specific construction dates for upgrading
each of the three city-operated
wastewater treatment plants.
The construction schedule is designed to
ensure that by November 1983, 86 to 89
percent of the biochemical oxygen
demand (BOD) that the three plants
discharge into the Delaware River will be
removed. (Biochemical oxygen demand
refers to the oxygen required to
decompose organic matter in water.)
To accomplish the cleanup, the
secondary treatment systems of the three
plants will increase their capacities to 250
million gallons per day (mgd) at the
Northeast Plant, 210 mgd at the
Southwest Plant, and 140 mgd at the
Southeast Plant.
A second part of the decree called for
the city to reaffirm its commitment to
stop its ocean dumping of sludge by
December 31, 1980 (EPA Journal,
January 1981). Third, the agreement
provided for the creation of a fund with a
deposit of $2.165 million, to be used to
undertake environmentally beneficial
projects not currently required by law. One
such program that the city has initiated
is a monitoring program for metals and
toxic chemicals entering the city's water
treatment plants and being discharged
from wastewater treatment plants. This
program is funded for $165,000. The
other existing program is a $2 million
project to upgrade Philadelphia's
combined sewer overflow control system.
Sludge
Characteristics
Philadelphia presently generates 190
dry tons of sludge per day (70,000 per
year) and the projected sludge load for
1985 is 305 tons per day (111,300 per
26
EPA JOURNAL
-------
year). In comparison to that of other large
cities, Philadelphia sludge is rich in
organic nutrients and low in contaminants
- averaging 20 parts per million (ppm)
cadmium, less than 2 ppm
polychlorinated biphenlys(PCB's), and
600 ppm lead.
The Philadelphia authorities examined a
series of alternatives to ocean dumping of
its sludge, particularly thermal
processing, land disposal, and land
utilization. One form of thermal
processing that the city chose is known as
the "Ecorock" process, where dewatered
sludge and municipal solid waste
incinerator residue is combined in a rotary
kiln. The inert material in the wastes will
reach a molten state at 981 °C (1,800°F)
that, when cooled, becomes a hard rock.
When crushed, the rock is expected to be
a high quality road aggregate that will
pass Federal Highway Administration
tests for paving materials. A
demonstration plant for the project is
being completed.
Land disposal of sludge was not a
viable alternative, because the
Pennsylvania Department of
Environmental Resources does not
recommend mixing wastewater sludge
with municipal refuse in landfills. Using
sludge to help improve land, on the other
hand, presented the most economically
feasible alternative. The Philadelphia
authorities were particularly interested in
using the sludge to recover stripmined
areas of the state.
After examining the alternatives,
Philadelphia formulated the Sludge
Master Plan, which incorporated a
number of programs.
Producing
A High-Quality
Product
The sludge must be as free of toxics as
possible. One way in which Philadelphia
maintains a consistently high quality
sludge is through its industrial waste
regulations. Starting in 1977 and before
EPA promulgated industrial effluent
limitations for metals, the city
implemented its own set of metals
effluent limitations for industrial
contributors to the city's treatment
facilities. These limitations significantly
lowered the metals concentrations of the
city's sludge.
Philadelphia's sludge is further
improved by anaerobic digestion for at
least 15 days at 37°C <98°'F), which
serves to significantly reduce pathogens
and odors. The digested product (5%
solids) can then be utilized in one of the
alternative plans — the Liquid
"Philorganic" Program. Containing up to
50% organic matter with 3 to 4% nitrogen
by weight, the liquid digested sludge can
be sprayed or injected on grain or sod
farms.
Dewatering also enhances the use of
other alternatives in managing sludge.
After dewatering, the sludge is loaded
on dump trucks and transported to
interim composting sites at each plant.
The Philadelphia authorities use the
extended pile aeration method, where
woodchips are used as a bulking agent in
a 2 to 1 ratio of woodchips to sludge.
Because woodchips are a major expense
at over $8 per cubic yard, a shredder and
screen system is used to reclaim them.
Moreover, the screened compost is a fine,
homogeneous soil conditioner that is
marketed under the name "Gardenlife" as
a soil conditioner and may be purchased
in 40-pound or bulk quantities. The
screening process greatly increases the
desirability of the product, and the city
therefore plans to expand the screening
facilities, presently rated at 200 cubic
yards per day.
The marketing program sold more than
250,000 bags of "Gardenlife" by July of
1981. This may eventually phase out a
current give-away program, but both will
continue until marketing proves
successful.
Sludge not screened and sold is given
away as part of the Philorganic program.
The city provides a series of brochures at
distribution centers that explain how the
compost can and should be used by
consumers. No EPA regulations or
guidelines cover the distribution and
marketing of Philorganic, although the
Philadelphia Water Department has
adopted a conservative policy, one
condition of which recommends that
Philorganic not be used on vegetables.
The program's popularity is on the
increase. Between July and December of
1980, 2,600 dry tons of Philorganic were
given away.
Dry and liquid Philorganic has also been
used in several special projects. Ball
parks, parks, and city-owned golf courses
have benefited from Philorganic, as have
several reclaimed landfills and abandoned
lots.
Reclaiming
Strip Mines
Philadelphia's plan to use sludge to
reclaim strip mines stemmed from a
demonstration project conducted in 1978
on 10 acres of land in Somerset County in
southwestern Pennsylvania. One part
unscreened compost and one part
dewatered digested sludge, called a
"mine mix," are added to loosened soil
that has previously been recontoured and
limed to immobilize heavy metals. Present
guidelines allow a maximum application
rate of 60 dry tons per acre.
For each reclamation project, a permit
application is prepared and submitted to
the Pennsylvania Department of
Environmental Resources, with copies
also sent to township supervisors and
local health officials for review. Once a
permit is approved, local truckers are
hired to transport the sludge. Usually,
these are coal trucks delivering coal to the
Philadelphia area that can transport the
mine mix back to western Pennsylvania
on the return trip.
Before the sludge is applied to the land,
erosion and drainage control measures
must be carried out and the site
preparations approved by inspectors. For
the application, 2-acre plots are staked
out, and at the 60 dry tons per acre loading
rate, 10 truckloads of mine mix are added
to the limed soil. Finally, a seed mixture of
two legumes and two grasses is spread at
a rate of 60 Ib. per acre. The site will then
be monitored for two years to guard
against contamination by metals. The
goal is to make the land suitable for
grazing.
The city presently is using 60 to 70
percent of its sludge in the stripmine
reclamation program, and plans are being
made to reclaim 800 acres in Fiscal Year
1981. The cost of the program is about
$200 per dry ton, making it one of the
city's most economically feasible
alternatives to ocean dumping. LJ
SEPTEMBER/OCTOBER 1981
-------
An Industry View
By Philip X. Masciantonio
Vice President, Environment
and Energy, U. S. Steel Corp.
Modern waste treatment facilities at a U. S. Steel plant at the Homestead Works
near Pittsburgh.
The past decade has seen
improvement in environmental quality
in Pennsylvania as a result of the
combined effort and cooperation by
government and industry as well as by
our local communities. Pennsylvania has
unique environmental problems
associated with its river valley terrains and
sharply contrasting urban and rural areas.
On the one hand, we have vast forests,
streams, and agricultural regions, and on
the other, highly developed cities with
heavy industries such as steel, power
generation, and mining that play a
significant role in the economic backbone
of the State.
Immediately following the post-World
War II era, emphasis on cleaning our
streams of acid mine drainage and solving
municipal sewage problems produced
significant environmental improvement
that was obvious both in the visible and
the chemical purity of our water. The
emissions from burning bituminous coal
as a source of power for railroads and
industrial plants were also cleaned and
the air was cleared of "soot." The dirty
image of our major metropolitan areas
was transformed in an outstanding
example of cooperation between
government and the private sector.
The opportunity to advance these air
and water'cleanup activities further came
with the environmental movement in the
late 1960's and early 1970's. A major
effort in pollution abatement was made
by industry as required under the Clean
Air Act of 1970 and the Clean Water Act
of 1972. New State and county
regulations also provided the added
degree of environmental improvement
required by the Federal laws.
There were many arguments among
industry, the government,
environmentalists, and others during the
period of the 1970's. An intense
emotion-filled climate characterized the
period, with participation at all levels to
28
EPA JOURNAL
-------
resolve differences. Some of these
problems were associated with forcing
untried technology as required by various
laws and regulations. This made it very
difficult to agree always on installation of
control facilities. Nevertheless, some
progress was made, and the 1970's can
be looked upon as a time in Pennsylvania
when a readjustment was made in how
our environmental problems could be
solved.
The progress that was made in this
period in pollution control ultimately will
be most remembered and represents a
lasting benefit to our State. For example,
in Eastern Pennsylvania (Bucks
County) where we operate steel facilities,
air quality is now meeting standards. In
Western Pennsylvania, a dramatic air
quality improvement has been realized in
metropolitan areas of Allegheny County
and Pittsburgh. Readings for total
suspended particulatesand sulfur
dioxide have been reduced drastically,
and air pollution episodes have been
essentially eliminated. Date collected
from four suspended particulate monitors
near U.S. Steel's Clairton Coke Works,
one of the largest of its kind in the world,
show a dramatic reduction in this
pollutant. Two of the stations have gone
fron nonattainment to attainment with
primary standards. Sulfur dioxide
measurements also have sharply
declined. Some of the air quality
improvements were made because of
controls installed by industry and utilities,
and others by better quality control of
government sampling devices and
attempts in recent times to get more
representative samples.
Water
Quality
The water in our State has continued to
show improvement. The progress in
cleaning up the Monongahela and Ohio
Rivers and other smaller streams and
tributaries is gratifying. Further
environmental improvement from
industrial as well as municipal sources is
continuing.
The cost to achieve this was very
significant, and at times meant a great
sacrifice in terms of other competing
priorities. We are now at the point where
we need to examine the benefits of
sacrifice for further progress. We have
removed sufficient pollution from the air
and water so that no obvious health
effects presently endanger our citizens.
Even the most extreme environmentalists
recognize that as we achieve greater
degrees of environmental cleanliness, the
cost for removal of the last traces of
impurities becomes exorbitant. It is
necessary to examine such expenditures
carefully to be sure that the high cost
associated with achieving the final
percentage of cleanup is properly
assessed. We cannot afford to spend
billions of dollars on additions and
questionable environmental improvement
projects in the absence of evidence that
this is necessary to protect health or
public welfare, particularly in view of
other pressing community needs.
However, the steel industry is ready to
move forward on additional
environmental improvement in a cost-
effective manner if we know that the
benefits from such improvement are
justified. The State of Pennsylvania can
proudly look to its environmental record,
knowing that its efforts have been the
result of a cooperative and continuing
activity by government, industry, and the
public.
It is important that careful study be
given to the strategy for further
environmental cleanup, particularly with
regard to industrial sources of pollution. A
recent study by A.D. Little, Inc., indicates
that the steel industry has already
reduced air emissions by 95 percent and
water pollutants by 91 percent from its
discharge. Numerous studies have shown
that the cost for removal of the initial 90-
95 percent of the pollutants involved a
cost-effectiveness factor of about $1,000
per pound per hour of pollutant removed.
As efforts are made to remove the last
remaining percentages of pollutants from
industrial sources, the costs rise
dramatically and cost-effectiveness
factors approaching several hundred
thousand dollars per pound per hour are
not uncommon. Although, in certain
cases, such pollutant removal may be
necessary when it is clear that a
significant pollution problem is involved,
for the most part removal of the small
amount of particulate matter or sulfur
dioxide that remains does not result in any
measurable environmental improvement.
Detailed studies on a number of these
cases at steel plants in Pennsylvania and
across the nation have shown
consistently that removal of the last few
percent of pollutants has no significant or
measurable effect on air quality in the
vicinity of the community involved.
It appears imprudent to require that
existing sources of pollution retrofit costly
control facilities because of the adverse
effects that this has on the competitive
capability of the steel plants involved.
Imposing costly retrofit controls on older
steel plants causes premature closure and
loss of productive facilities. For example,
it has been estimated that to add retrofit
controls to an old sinter plant to meet
allowable limits could cost about $30
SEPTEMBER/OCTOBER 1981
29
-------
million. An owner would have to give very
serious consideration to spending this
magnitude of funds, especially with the
severe shortage of capital that already
exists in the steel sector. Any
unnecessary upgrading of environmental
controls subtracts from the capital for
modernization or construction of modern
production facilities.
Experience since enactment of the
Clean Air and Clean Water Acts has
shown that environmental cleanup takes
place quickly and effectively when
modern facilities are constructed. Efforts
to retrofit older plants are difficult, not
only in installing controls in crowded and
outmoded plants, but also in trying to
capture the emissions cost-effectively
from older processes.
Best
Interest
It is in the best interest of all concerned in
industrial, government, and public
sectors to provide as rapidly as possible
the means for industrial modernization
and to accomplish this through every
means available including proper tax
legislation, proper control of imports
which violate our trade laws and, most
important, supporting reasonable
environment regulatory strategies that
encourage (not discourage)
modernization, and do not overburden
certain fragile industrial facilities that are
struggling to maintain even marginal
profitability.
With regard to the problem of
particulates in Pennsylvania, road dust
controls and other strategies should be
carried out by government as well as
industry sources. Existing industrial
emissions in air and water should be
manageable with reasonable enforcement
and interpretation of regulations and
reasonable location of sampling monitors.
There is considerable uncertainty as to
how the Resource Conservation and
Recovery Act will be implemented to
handle the disposal of solid and
hazardous waste in the State. There also
is a significant problem with siting
facilities needed to take care of future
industrial hazardous wastes.
Industry, including the major steel
producing facilities in the State, must
continue to maximize recycling and reuse
of such materials. Those materials which
do not lend themselves to recycling or
reuse must be handled so as to pose no
threat to the environment. On the other
hand, there is a need to inform the public
properly on the nature of waste materials
which must be disposed of at future sites.
All sectors including government, the
public, and news media should work
together to avoid the impression that
every material classified on paper as
hazardous poses a real threat to the future
of our State. In many cases, hazardous
wastes have been managed in a safe
manner by responsible industries for
many years. The occasional incident
where material has escaped into the
environment does not necessarily mean
that additional legislation or regulation is
needed.
In summary, environmental progress
has been made in Pennsylvania during the
decade of the 1970's. If further
environmental progress is to be realized, it
must be consistent with modernization
and economic growth. Some of the
principal problems that still face us relate
to emissions from congested urban
systems, discharges into our waterways
by municipalities from storm runoff, and
other urban discharges. The solution will
rest with the development of a solid
economic base in the State for managing
these remaining areas. Pennsylvania has
been abundantly blessed not only with
minerals and various energy sources, but
also with water supplies and a highly
developed transportation system. In
addition, we have a vast pool of skilled
labor and an excellent educational and
research base to provide for further
economic development.
It has been shown repeatedly that
industrial modernization and
environmental cleanup can harmoniously
proceed to the benefit of all citizens in our
State. The adversarial relationship which
characterized the period of the 1970's
must not recur to inhibit the harnessing of
the forces and resources available to our
State. The key to further progress is
cooperative action from all segments of
our society. In this respect, industry has a
grave responsibility to proceed in a
manner that is consistent with the
protection of our environmental resources
and of our job opportunities. The
economic development so badly needed
by our State is the area where the private
sector is most uniquely suited to act. With
understanding and with the good faith
effort of all parties, continued economic
and environmental progress can be
realized, jointly. D
30
EPAJOURNAL
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Matthew N. Novick
Richard Funkhouser
More Key EPA
Appointments
Announced
President Reagan and Administrator
Anne M. Gorsuch have announced
additional selections for management
positions at EPA both at Headquarters
and in the field.
Matthew N. Novick, a government
budget and fiscal expert, was nominated
by the President to be Inspector General
of EPA, responsible for managing audits
and investigations to ensure the fiscal
integrity of the Agency's operations.
The Honorable Richard Funkhouser,
former Ambassador and career Foreign
Service Officer, was named by Mrs.
Gorsuch as Director of the Office of
International Activities. Other key officials
selected by Mrs. Gorsuch include:
A former business and government
official. Jack Woolley, as Director of
Congressional Liaison.
Andrew P. Jovanovich, a management
and research expert with experience in
the chemical industry, as Acting Assistant
Administrator for Research and
Development.
Bruce R. Barrett, a veteran Federal
environmental specialist, as the Acting
Assistant Administrator for Water.
The Administrator also has appointed
Lester A. Sutton as New England
Regional Administrator of EPA Region 1,
and John R. Spencer as Northwest
Regional Administrator for Region 10.
Helen Cameron, executive assistant to
two U.S. Senators since 1973, has been
named by Deputy Administrator John
W. Hernandez as his executive assistant.
Lewis S.W. Crampton, a management
expert and consultant, was appointed
Director of the Office of Management
Systems and Evaluation at Headquarters.
In commenting on Novick's
nomination, Mrs. Gorsuch said:
"Fiscal integrity is a cornerstone of
efficient government. Mr. Novick's
expertise and experience will play an
important role in ensuring that EPA's
programs meet the highest standards of
efficiency, honesty, and effectiveness."
Novick, 47, was formerly Director of
the Office of Technical Assistance at the
Interior Department. From 1978 to 1980
he was Deputy Director for Finance and
Administration there, and Financial
Manager and Budget Officer under the
Deputy Assistant Secretary for
Management 1974-78. He served as
budget analyst in the Office of the
Director of Procurement in the Defense
Department 1971-74. Previously he had
served as an auditor in the U.S. Army.
Novick received a Bachelor of
Commercial Science degree in 1963 from
Benjamin Franklin University in
Washington, D.C., and a diploma in 1971
following a year's study at the Industrial
College of the Armed Forces.
Funkhouser has served as a career
diplomat in several countries. He was
United States Ambassador to Gabon in
Africa, Economic Counselor in Moscow,
Political Counselor in Paris, and was a
member of the State Department Policy
Planning Staff as energy specialist 1972-
74. He resigned from the Foreign Service
in 1976 to become an international affairs
consultant, living in Edinburgh. He is a
Trustee of the Scottish Civic Trust, the
principal environmental organization in
Scotland. He is author of numerous
papers relating to international affairs,
energy, and geology, including the basic
table on the magnetic susceptibility of
sedimentary minerals.
SEPTEMBER/OCTOBER 1981
31
-------
Jack Woolley
Andrew P. Jovanovich
Bruce R. Barrett
Funkhouser studied civil engineering,
geology, and geophysics at Princeton and
was graduated in 1939 summa cum laude
and a member of Phi Beta Kappa. Prior to
World War II he served as a geologist with
steel and oil companies in the United
States and abroad. During World War II
he was a pilot in the China-Burma Theater
with the rank of first lieutenant in the
U.S. Army Air Corps. He holds the
Distinguished Flying Cross with three Oak
Leaf clusters and the Air Medal with four
Oak Leaf clusters.
Woolley held key positions in the
Eisenhower and Nixon Administrations
and in the California Republican Party.
"The Agency, the Congress and
Congressional staff will all profit from
Jack Woolley's knowledge of the
legislative process and his longtime
relationship with the members, both in
the Senate and the House," said EPA
Administrator Anne M. Gorsuch.
In 1966, Woolley became director of
federal government relations for the
T.R.W. Systems Corp., Redondo Beach,
Calif.
During the first Nixon term, Woolley
served as Assistant Secretary for
Legislative Affairs with the Department of
Housing and Urban Development. He
then became Washington office manager
for PPG Industries, from which he retired
in 1980.
A native of Salina, Kan., Woolley was
commissioned as an ensign in the Navy
after graduation from the U.S. Merchant
Marine Academy in 1944. He served in the
Atlantic, Mediterranean and Pacific
theaters, joined the Naval Reserve in
1946, switched to naval aviation and
retired as a captain in 1975.
At the University of Southern
California, Wooliey received a M.B.A.
degree in 1949 and is a doctoral candidate
there. He also was an adjunct professor
there from 1949 to 1956 in business and
telecommunications.
Woolley lives in Alexandria, Va., with
his wife, Judith, who is a confidential
assistant to the Deputy Attorney General
of the Department of Justice.
Jovanovich, 37, will head EPA's
national research and development effort
which has a quarter-billion-dollar budget
this fiscal year. He was appointed for an
interim period until the President selects a
nominee for the position. Since 1977, he
has been a senior research chemist and oil
shale program manager at the Denver
Research Institute of the University of
Denver, managing about $1.5 million in
research annually and serving as senior
technical expert for various research
projects. From 1975 to 1977, Jovanovich
held a number of senior management
positions at Western United Resources,
Inc., a manufacturer of agricultural
chemicals, including Vice President. He
also has published numerous technical
articles in professional journals on such
subjects as chemistry, air pollution, and
environmental aspects of oil shale
development. Jovanovich received his
Ph.D. in physical organic chemistry in
1970 from Northwestern University, and
a B.S. in chemistry from Colorado
College in 1965. Most recently, he
received an M.B.A. in marketing and
finance from the University of Denver in
1974.
Commenting on the selection of
Barrett as Acting Assistant Administrator
for Water, Mrs. Gorsuch said:
"Mr. Barrett has been a pollution
control specialist for 19 years, and has
experience in municipal and industrial
waste treatment technology, water
quality surveillance and analysis, and
regulatory and legislative procedures at
the Federal and State levels. We look
forward to sharing his knowledge and
expertise in directing the EPA water
programs during this interim."
Barrett formerly headed the
environmental affairs office at the
Department of Commerce. He had been
in that operation for nine years, during
which time his special assignments
included participation in the Domestic
Council Task Force on Water Quality and
an assignment with the Public Works and
Transportation Committee, U.S. House
of Representatives, which has
responsibility for pollution control
legislation.
From 1966 to 1972, Barrett was
assigned to the EPA Research Center at
Ada, Okla., and was involved in several
multi-discipline surveys and investigations
of water pollution control problems.
From 1962 to 1966, Barrett was on the
staff of the Central Valley Regional Water
Quality Contro! Board in California.
A native of Ardmore, Okla., Barrett is
a registered professional engineer in that
state and also in Texas and California. He
received a B.S. in Civil Engineering in
1961 and an M.S. in Environmental
Engineering in 1962 from Oklahoma State
University. He has written on environ-
mental issues for several publications.
Sutton, 51, has had more than 25 years,
professional experience in all aspects of
environmental engineering and
management. In announcing his
32
EPAJOURNAL
-------
Lester A. Sutton
I
Helen Cameron
John R, Spencer
*>
appointment, Deputy Administrator John
W. Hernandez declared that Sutton's
"technical experience coupled with his
administrative abilities make him uniquely
qualified to administer EPA's programs in
the New England States."
Sutton has been with the Region 1
office since its inception in 1971, The
Region includes Connecticut, Maine,
Massachusetts, New Hampshire, Rhode
Island, and Vermont. For the past two
years he has served as Senior Project
Manager, responsible for planning,
management and implementation of
major urban water pollution control
projects in Boston, Providence, and New
Haven. Previously he served as the
Region's Water Division Director and
headed the Air and Water Program
Division there when the Agency was
created. He also has had extensive
experience with the Interior Department,
U.S. Army Corps of Engineers, and U.S.
Public Health Service.
He received a Bachelor of Civil
Engineering degree in 1953 from City
College of New York and a Master of
Civil Engineering degree with a speciality
in environmental engineering from New
York University in 1959. He is a licensed
professional engineer and a member of
numerous professional associations.
Spencer, 41, has been chief executive
officer in Alaska of Anchorage Telephone
Utility, the Anchorage Water and Sewer
Utility, and the Municipal Light and
Power Department since 1977,
supervising some 1,200 employees and
managing an annual operating budget of
about $100 million plus a current
construction budget of more than $65
million.
The Administrator termed him "a
skilled manager with a solid experience in
both business and government," adding:
"He will bring to EPA a pragmatic results-
oriented approach that will help State and
local governments protect the justifiably
highly-prized quality of life of people living
in the Pacific Northwest and Alaska."
EPA Region 10 includes Alaska, Idaho,
Oregon, and Washington.
During his tenure with the three
Anchorage utilities, Spencer introduced
new planning and budget processes that
reduced expenses at a time when levels of
service were being increased, with the
result that the utilities — although owned
by the city government — are operated as
a profitmaking business earning in excess
of 20 percent on equity.
Spencer was with RCA Alaska
Communications, Inc., 1975-77, where he
became vice president and general
counsel, and was Anchorage city attorney
1971-75. He served in the U.S. Army in
Anchorage 1967-70.
He received a bachelor's degree in
business administration in 1964 and a law
degree in 1965, both from the University
of Texas.
Ms. Cameron, the new executive
assistant to Deputy Administrator
Hernandez, is a native of New Mexico.
Her grandfather helped settle the town of
Alamogordo when New Mexico was still a
territory. Before joining Senator Robert
W. Kasten, Jr., (R-Wis.) last March,
Cameron was on the staff of Senator Pete
V. Domenici (R-New Mexico). She served
in numerous management posts with the
New Mexico Republican Party.
"We are fortunate to have Helen in top
management," said Dr. Hernandez. "She
brings to the Agency a breadth of
administrative experience which will be
highly beneficial."
Crampton, 40, will evaluate Agency
programs, suggest any needed reforms,
and will design and operate a
management accountability system to
improve the Agency's overall efficiency.
The Administrator said Crampton's
management expertise "will be a definite
asset to EPA as we strive to improve
efficiency. His analytical and
management skills will do much to
increase the Agency's effectiveness."
He has served as EPA Region 5's
Assistant Regional Adminstrator for
Planning and Management since last
December. Before joining EPA he was
senior consultant with the Arthur D.
Little, Co. for two years, specializing in
studies of toxic substances regulation and
international trade. He also worked on a
self-auditing program to help industries
meet environmental requirements. During
1979 he appeared regularly on "The
Advocates," a TV program on current
events, discussing issues such as
undersea mining, nuclear power, and
energy policy.
Crampton served as Commissioner of
the Massachusetts Department of
Community Affairs 1973-75 and also has
held several teaching positions. He
received a B.A. degree with honors in
public administration from Princeton
University's Woodrow Wilson School of
Public and International Affairs in 1965,
an M.A. in East Asian studies from
Harvard University School of Arts and
Sciences in 1967, and later pursued
graduate studies in urban and regional
planning at M.I.T. D
Back Cover: A rural road winds over a
one-lane bridge in this Autumn scene of
Pennsylvania's Poconos Mountains
country.
-------
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